United States Department of Agriculture

Final Environmental Impact Statement

for the Southwest Jemez Mountains

Landscape Restoration Project

Santa Fe National Forest, Sandoval 

County, New Mexico

Santa Fe Jemez MB-R3-10-22

Forest Service National Forest Ranger District August 2015
Cover: Four images showing differing photos of ponderosa pine trees; 1) trees are same size with little 

vegetation growth; 2) cut trees; 3) stand of mixed sizes, ages, and vegetation growth; 4) well-spaced trees.

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Printed on recycled paper – August 2015 
Southwest Jemez Mountains

Landscape Restoration Project

Final Environmental Impact Statement

Sandoval County, New Mexico

Lead Agency: USDA Forest Service

Responsible Official: Maria T. Garcia, Forest Supervisor

Santa Fe National Forest

For Information Contact: Chris Napp, Southwest Jemez EIS Team Leader 

11 Forest Lane, Santa Fe, NM 87508 

505-438-5448 

cnapp@fs.fed.us 

Abstract: The Santa Fe National Forest proposes to conduct restoration activities over an 8-10 

year period or until project objectives are met. Five alternatives were considered in detail. 

Alternative1, the Proposed Action, would complete forest and watershed restoration activities 

including mechanical treatments and prescribed fire on a portion of the 110,000 acre Southwest 

Jemez Mountains Restoration Project area. Alternative 2 proposes no action; there would be no 

changes in current management. Projects approved by other environmental analyses and decisions 

would be implemented. Under Alternatives 3, 4, and 5, the mechanical treatments and/or 

prescribed fire would take place on fewer acres than the Proposed Action. All action alternatives 

include other activities that would improve soil and watershed function, improve wildlife and 

aquatic habitat, and protect cultural resources. All action alternatives require site-specific, 

nonsignificant forest plan amendments. Transportation system changes would allow for access to 

treatment areas and include road maintenance or reconstruction, road decommissioning, 

temporary road construction (alternatives 1, 4, and 5 only), and development of gravel pits. 

Alternative 1, the proposed action, is the forest supervisor’s selected alternative. Changes made 

since the draft statement are listed in appendix E. 

This project is subject to the Predecisional Administrative Review Process (Objection Process) 

pursuant to 36 CFR 218, subparts A and B. The final environmental impact statement and draft 

record of decision are available online at the project Web page (http://go.usa.gov/BUVh). These 

documents are also available for review at the Santa Fe National Forest Supervisor’s Office, 11 

Forest Lane, Santa Fe, NM. Please see the cover letter for information on who is eligible to file an 

objection and how and where to file an objection. 

FEIS for the Southwest Jemez Mountains Landscape Restoration Project i 

Summary 

The Santa Fe National Forest proposes to conduct treatments that would restore the structure and 

function of forests and watersheds across approximately 110,000 acres of the Jemez Ranger 

District. This work would be done over 8-10 years or until objectives are met. The purpose of the 

project is to restore ecosystem structure and function and increase resilience to undesirable, largescale disturbances such as high-severity wildfire, climate change, or insect outbreaks in the 

Southwest Jemez Mountains. To do this, we have identified four purposes: 

• Restore the structure, function, and resilience of ponderosa pine and dry mixed conifer 

forests, which would also reduce the potential for uncharacteristically severe and intense 

wildfires while promoting low-intensity, frequent surface fires that were common across 

this landscape.

• Improve the function of riparian ecosystems and streams, and improve fish and wildlife 

habitat, vegetative diversity, and water quality.

• Provide for the sustainability of archaeological sites, traditional cultural properties, sacred 

sites, and forest resources and areas associated with traditional practices.

• Use the forest restoration byproducts to offset treatment costs and provide economic 

opportunity to the local rural communities. 

Ecosystem conditions in the Southwest Jemez Mountains are 'out of whack'; they do not meet and 

are not moving toward the desired conditions outlined in the Southwest Jemez Mountains 

Landscape Strategy (USFS and VCNP 2010). 

The forest ecosystems that dominate this area, primarily ponderosa pine and dry mixed conifer 

forests, are highly altered from natural conditions. Instead of forests with groups of trees of 

different ages and sizes, there is a dense, continuous canopy of young and mid-age, pole-size (5-

12-inches diameter) trees. The forests are lacking mature and old-growth trees, aspen, and 

openings with understory grasses, forbs, and shrubs. In their current condition, a wildfire would 

likely burn through these forests with uncharacteristically high intensity and severity. 

Riparian, meadow, and aquatic systems are also in a degraded condition and do not provide 

quality habitat for native wildlife species. Denuded stream banks and stream-road crossings add 

more sediment to streams. Streams have few meanders, pools, and riffles that provide quality 

habitat for fish. Meadows are shrinking in size because of invading conifers. 

These conditions are the result of past intensive logging and overgrazing, road building, and fire 

suppression. The combined effects from these activities over the past 90-100 years have changed 

the forests, grasslands, and riparian areas. They are degraded and have lost resiliency. These 

ecosystems are more susceptible to severe wildfires, insect and disease outbreaks, drought, and 

the effects of climate change. 

The Proposed Action

To address these conditions, the Forest proposes to restore the landscape by mechanically treating 

forests, restoring meadows, using prescribed fire, and enhancing aspen stands. Other treatments 

would include invasive plant control, aquatic, riparian, and wildlife habitat improvement, and 

cultural resource protection. 
Summary 

ii FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Road treatments, including maintenance, reconstruction, closing, and decommissioning, would 

decrease erosion and increase the resilience and function of soils, riparian areas, and watersheds. 

Temporary roads constructed to implement the restoration treatments, would be decommissioned 

upon project completion. New and existing gravel pits would be developed to provide gravel for 

the road work. 

Twelve forest plan amendments are needed to achieve the purpose and need and to assure 

consistency with the Santa Fe forest plan. These are site-specific amendments and apply to this 

project only. 

Public Involvement 

The project was posted in the Santa Fe National Forest’s schedule of proposed actions. The notice 

of intent to prepare an environmental impact statement was published in the Federal Register on 

July 11, 2012 (Vol. 77, Issue 133). A draft proposed action was sent to a mailing list (hard copy 

and electronic mail) of individuals, organizations, State and local governments, Federal and State 

agencies, and tribes. During the spring and summer of 2012, we solicited comments on the 

proposed action through public meetings and field trips. Detailed information about these 

meetings can be found in the project record. A report summarizing the comments received was 

posted on the Santa Fe National Forest website in February 2013. 

The interdisciplinary team reviewed the comments received during the public involvement period 

and used them to identify relevant issues. Four key issues were used to develop alternatives, 

develop design criteria or mitigation measures that reduce unwanted effects, and to evaluate, 

analyze, and compare the effects of the different alternatives. These are: 

• the use of prescribed fire, smoke, and their effects on the environment and human health; 

• the scale of the area to be treated with mechanical treatments (tree cutting), and how this 

may affect watersheds, wildlife, and scenery; 

• opening closed roads and building new temporary roads and their effects on the 

environment, and 

• the effects of the mechanical treatments and prescribed fire on habitat for the Jemez 

Mountains salamander, Mexican spotted owl, and northern goshawk. 

The interdisciplinary team also identified other comments as nonsignificant issues or concerns. 

Many of these concerns were considered and incorporated in the draft environmental impact 

statement or design criteria, mitigations, and best management practices. Others were addressed 

in the environmental consequences. We also added more information about the proposed 

treatments and maps for each alternative. These and other changes that were made to the 

proposed action in response to public comments and interdisciplinary team discussions are listed 

in chapter 1 of the FEIS. Stakeholders have been and will be updated through our public 

involvement and consultation efforts. 

What are the Alternatives? 

Three alternatives were considered but eliminated from detailed study (see chapter 2) and five 

alternatives were evaluated in detail. The alternatives evaluated in detail are described below. 
Summary 

FEIS for the Southwest Jemez Mountains Landscape Restoration Project iii

Alternative 1 - The Proposed Action 

This alternative would mechanically treat approximately 29,900 acres of fire adapted ecosystems 

(ponderosa pine and dry mixed conifer) and use prescribed fire on approximately 77,000 acres. 

Other restoration treatments for cultural resources, watersheds, and wildlife habitat are included 

in this alternative. See the list of other actions below. Site-specific forest plan amendments are 

needed to implement this alternative (see tables 1 and 2 in chapter 2). This is the forest 

supervisor’s preferred alternative. 

Alternative 2 - No Action 

This is the no action alternative as required by 40 CFR 1502.14(c). There would be no changes in 

current management and the forest plan would continue to be implemented. Alternative 2 is the 

point of reference for assessing action alternatives. This alternative would thin approximately 900 

acres of ponderosa pine and dry mixed conifer and use prescribed fire on approximately 18,400 

acres. Some other pre-approved activities, such as cultural resource protection, nonnative and 

invasive plant control, and wildlife habitat improvement projects would be implemented. 

Alternative 3 - No Construction of Temporary Roads 

This alternative responds to the issue of constructing new temporary roads to implement 

mechanical treatments. Only those areas accessed by existing forest system roads would be 

mechanically treated. Those acres not accessible by existing roads would be burned instead of 

mechanically treated, as in alternative 1. This alternative would mechanically treat approximately 

28,300 acres of fire-adapted ecosystems (ponderosa pine and dry mixed conifer) and use 

prescribed fire on approximately 77,000 acres. Other restoration treatments for cultural resources, 

watersheds, and wildlife habitat are included in this alternative. See the list of other actions 

below. Site-specific forest plan amendments are needed to implement this alternative (see tables 1 

and 2 in chapter 2).

Alternative 4 - No Prescribed Fire in Mechanical Treatment Areas 

This alternative responds to the issues of smoke and the scale of prescribed fire. Prescribed fire 

would not be used in areas that are mechanically treated. The total area treated is the same as the 

proposed action. Instead of prescribed fire, slash resulting from mechanical treatments would be 

chipped or ground up (masticated), or lopped and scattered and left on site. Prescribed fire would 

occur in areas described as prescribed fire only under alternative 1. This alternative would 

mechanically treat approximately 29,900 acres of fire-adapted ecosystems (ponderosa pine and 

dry mixed conifer) and utilize prescribed fire on approximately 45,400 acres. Other restoration 

treatments for cultural resources, watersheds, and wildlife habitat are included in this alternative. 

See the list of other actions below. Site-specific forest plan amendments are needed to implement 

this alternative (see tables 1 and 2 in chapter 2).

Alternative 5 - Implement Restoration Activities While Complying with 

the Existing Forest Plan Standards and Guidelines for Managing 

Mexican Spotted Owl Habitat 

This alternative was designed in response to issues raised regarding treatments in Mexican 

spotted owl (MSO) protected activity centers (PACs) and restricted habitat. The proposed forest 

plan amendments related to treatments in Mexican spotted owl habitat would not be needed to 

implement this alternative. This alternative would mechanically treat approximately 29,900 acres 
Summary 

iv FEIS for the Southwest Jemez Mountains Landscape Restoration Project

of fire-adapted ecosystems (ponderosa pine and dry mixed conifer) and use prescribed fire on 

approximately 76,300 acres. Other restoration treatments for cultural resources, watersheds, and 

wildlife habitat are included in this alternative. See the list of other actions below. Site-specific 

forest plan amendments, those not pertaining to the Mexican spotted owl, are needed to 

implement this alternative (see table 2 in chapter 2).

Actions Common to Alternatives 1, 3, 4, and 5

• Treatments in wet mixed conifer. Mechanical treatments would occur on approximately 

1,150 acres. Areas prioritized for treatment include: areas close to endangered species 

habitat, wildland-urban interface areas, springs, areas with insects, disease, or other 

special needs, and small inclusions of wet mixed conifer within other cover types. 

• Treatments to maintain or increase aspen. Mechanical treatments would occur on 

approximately 1,800 acres on slopes less than 40 percent. The treatments are intended to 

maintain existing aspen stands.

• Treatments in piñon-juniper. Trees would be thinned on approximately 1,000 acres to 

reduce erosion, protect heritage sites, or to increase habitat for songbirds. 

• Treatments in Mexican spotted owl protected activity centers. Mechanical thinning 

treatments would occur on approximately 500 acres. The purpose of these treatments is to 

improve owl habitat and move stands toward having larger trees and a multi-storied 

canopy. 

• Treatments for old growth. The mechanical treatments would aim to increase tree growth 

and size, create down wood and uneven-aged stands, and reduce loss of these stands in a 

wildfire. 

• Treatments for maintaining or increasing meadow habitat. Cut trees from around meadow 

margins. This would occur on approximately 5,500 acres: 2,500 acres in the uplands and 

3,000 acres in riparian areas. 

• Treatments to enhance seeps and springs. Cut conifers within 100 feet of identified seeps 

or springs to improve water flow. This would occur on approximately 200 acres. 

• Treatments to reduce erosion effects from headcuts. Fill headcuts with soil, rock, or 

boulders, or areas would be recontoured. Areas would be seeded with native grasses 

afterwards.

• Treatments to enhance native riparian vegetation and restore areas damaged by dispersed 

recreation. There are approximately 150 inventoried campsites that need restoration. 

Close sites by placing soil, rocks, and boulders on and around the site and by planting 

native vegetation. Exclosures may be used to protect newly planted vegetation.

• Treatments to restore instream habitat. Use heavy machinery to create pools and 

channels, replace culverts, and place or remove log and rock stream structures on selected 

locations along the 24 miles of perennial streams in the project area. 

• Control of nonnative and invasive plants. Pull weeds, use prescribed grazing or 

prescribed fire, and methods other than herbicides to control populations of nonnative 

and invasive plants. 
Summary 

FEIS for the Southwest Jemez Mountains Landscape Restoration Project v 

• Screen water sources from human disturbance. Plant trees and shrubs to screen tanks and 

drinkers from road viewpoints. Newly planted vegetation would be protected with 

fencing. 

• Increase water availability for wildlife. Construct earthen dams or trick tanks. This would 

occur in the upper portions of watersheds and drainage headwaters throughout the project 

area. 

• Create snags for wildlife habitat. Trees would be killed by burning or other means. 

• Reduce risk of loss or damage to cultural sites. Remove trees and brush from 

approximately 3,000 known cultural sites in the project area to reduce the risk of loss or 

damage by wildfire. 

• Implement road maintenance activities in the project area. Construct and/or improve 

drainage features such as grade dips, lead-out ditches, roadside ditches, drainage 

crossings, and culverts and install erosion control treatments such as riprap, geotextile 

materials, and sediment basins. 

• Provide gravel for road maintenance and improvement work. Up to five gravel pits and 

access roads would be developed to provide gravel for road maintenance and 

improvement work. 

• Open existing closed roads and construct new temporary roads. Reopen and/or 

reconstruct approximately 20 miles of existing closed roads to provide access and product 

removal. In addition to these roads, approximately 12 miles of temporary roads would be 

constructed. All temporary roads would be decommissioned after use. No temporary 

roads would be constructed under alternative 4. 

• Road decommissioning treatments. Approximately 100 miles of roads in the project area 

have been identified as candidates for decommissioning. Methods include installing 

signs, blocking entrances, restoring vegetation, eliminating the roadbed, and other 

methods described in Forest Service Manual (FSM) 7734.1. Roads causing damage to 

hydrological resources, cultural resources, or threatened, endangered, and sensitive 

species habitat are a priority for decommissioning. 

Amendments for alternatives 1, 3, and 4

• Allows prescribed fire in Mexican spotted owl core areas.

• Allows treatments in 20 percent of the Mexican spotted owl protected activity centers 

rather than 10 percent.

• Revises paired monitoring so that treatment may occur in all six protected activity centers

within the project area and better achieve desired conditions. 

• Revises treatment within MSO PACs to allow cutting trees up to 18-inches diameter, 

mechanical fuel removal, and prescribed fire to treat fuel accumulations to abate fire risk.

• Adjusts requirements for nest/roost characteristics in recovery habitat to guidance from 

the 2012 Mexican spotted owl recovery plan (USFWS 2012).

• Removes language specifying the use of thinning from below. Allows for the removal of 

intermediate size class trees for uneven-aged management. 
Summary 

vi FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Amendments for alternatives 1, 3, 4, and 5

• Allows treatments to occur during the northern goshawk breeding season. 

• Adds language to allow for interspaces between tree groups in northern goshawk habitat. 

• Removes restrictions for turkey nesting areas to allow for treatments to occur within the 

breeding season.

• Revises the forest plan direction for peregrine falcon management. 

• Revises forest plan direction regarding scenery management within the Jemez National 

Recreation Area.

What are the Major Conclusions of the Environmental 

Analysis? 

All action alternatives, to varying degrees, would meet the purpose and need by moving the forest 

towards the desired conditions to restore ecosystem structure and function and increase resilience 

to undesirable, large-scale disturbances such as high-severity wildfire, insect outbreaks, or 

climate change in the Southwest Jemez Mountains.

Alternative 1, the preferred alternative, would improve tree growth, water absorption and 

infiltration, and increase the diversity and abundance of understory vegetation by reducing tree 

density and opening up the forest canopy. Other treatments would improve water quality by 

reducing the amount of sediment in streams. 

Soil and watershed conditions would be also improved. Forest stands would vary in density, 

providing improved habitat for the Mexican spotted owl and the northern goshawk. Habitat for 

the Jemez Mountains salamander and the owl would be better protected against an 

uncharacteristically severe wildfire. 

There would be short-term negative affects during or immediately after treatments, including soil 

disturbance and sedimentation to streams as well as impacts on grazing, visual quality, and 

recreation use. Forage availability for livestock grazing would be reduced over the short term, and 

some grazing permittees might see a reduced income from grazing. Human health would be 

affected by smoke from prescribed fires; periods of smoke would last 5-7 days. Impacts on 

human health would vary depending on the individual’s health, sensitivity, age and other factors, 

and for some individuals, some problems may be long term and serious. Some threatened, 

endangered, and proposed species and their habitats would be adversely affected in the short 

term, but over the long term, habitat conditions would improve and be more resilient to 

uncharacteristically severe wildfire. 

Under alternative 2, the no action alternative, none of the proposed restoration treatments would 

be implemented. Current conditions and trends in this area would continue. The area would 

continue to be at risk for an uncharacteristically severe fire, like the Cerro Grande or Las Conchas 

fires. 

There would be no change at the landscape level to forest structure or composition, the amount of 

live and dead fuels, or the amount of understory vegetation. Archaeological sites would be 

adversely affected by roads, heavy fuel loads, and wildfire and suppression and rehabilitation 

activities. Wildlife habitat would decline in quantity and quality. Adverse impacts on sensitive 
Summary 

FEIS for the Southwest Jemez Mountains Landscape Restoration Project vii

species, management indicator species, and migratory bird populations, and destruction of habitat 

from a severe wildfire is likely. Water quality would not improve. Ecosystems would continue to 

have limited resilience to adapt to or survive and recover from potential large-scale disturbances 

such as uncharacteristically severe wildfire or climate change.

Alternative 3 would have effects similar to alternative 1, except 1,900 fewer acres would be 

mechanically treated. These areas would be treated with prescribed fire only. Without the benefits 

of mechanical treatments, fuel loads would be higher and the effects of prescribed fire on soils, 

vegetation, wildlife habitat, and cultural sites could be more severe than under alternative 1. 

Treatments would be completed without building 12 miles of temporary roads and reopening an 

additional 11 miles of existing closed roads.

Alternative 4 would have effects similar to alternative 1, except fewer acres would be treated with 

prescribed fire. Slash from mechanical treatments would be chipped or ground up (masticated), or 

in some areas, left on site (lopped and scattered). Prescribed fire smoke emissions, as measured 

by carbon dioxide and particulate matter, would be reduced by 44 percent and 39 percent, 

respectively, as compared to alternative 1. In addition, a wildfire burning in the untreated areas 

would burn at a higher intensity. Effects on soil, watersheds, wildlife habitat, cultural sites and 

other resources would be more severe on these acres than under alternative 1. The ecological 

benefits of prescribed fire would not occur on about 32,000 acres. 

Alternative 5 would have effects similar to alterative 1, except within Mexican spotted owl 

protected activity centers and core areas. In order to comply with the forest plan, approximately 

700 acres would need to be excluded from prescribed fire. Treatments within the MSO PACs and 

other restricted habitat would meet the standards and guidelines of the current Santa Fe forest 

plan. While this would reduce adverse effects on the Mexican spotted owl in the short term when 

compared to the other action alternatives, the PACs and other restricted habitats would be less 

resilient to disturbance or other threats.

What is the Decision to be Made? 

The Santa Fe National Forest supervisor is the Forest Service responsible official. Based on the 

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

decide whether or not the proposed action should be implemented as proposed, modified by 

another action alternative, or not implemented at all, and whether to amend the forest plan. The

decision includes determining 1) the location and treatment methods for all restoration activities; 

2) design criteria, mitigation, and monitoring requirements; 3) the components that will be 

included in the monitoring plan; 4) the wood products or material made available as a by-product 

of the restoration activities; and 5) whether the forest plans will be amended if an action 

alternative is chosen. This decision is subject to the predecisional administrative review process

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

FEIS for the Southwest Jemez Mountains Landscape Restoration Project ix

Contents 

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

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

Public Involvement ..................................................................................................................... ii

What are the Alternatives? .......................................................................................................... ii

What are the Major Conclusions of the Environmental Analysis? ............................................ vi

What is the Decision to be Made? ............................................................................................ vii

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

About This Document ................................................................................................................. 1

The Proposed Treatments............................................................................................................ 1

Location and Description of the Project Area ............................................................................. 2

History of the Project .................................................................................................................. 2

Why Here, Why Now? ................................................................................................................ 4

Existing and Desired Conditions: What We Have and What We Want ..................................... 4

Our Purpose and Need for this Project ...................................................................................... 13

The Proposed Action ................................................................................................................. 15

The Decision to Be Made.......................................................................................................... 16

Tribal Consultation ................................................................................................................... 17

Public Involvement Efforts ....................................................................................................... 17

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

About this Chapter .................................................................................................................... 19

Forest Plan Consistency ............................................................................................................ 19

The Alternatives ........................................................................................................................ 19

Mitigation Measures for All Action Alternatives ..................................................................... 41

Monitoring ................................................................................................................................ 41

Forest Plan Amendments .......................................................................................................... 41

Required Permits, Approvals, and Consultation ....................................................................... 41

Alternatives Considered but Eliminated from Detailed Study .................................................. 47

Comparison of Effects of the Different Alternatives ................................................................ 48

Chapter 3. Affected Environment and Environmental Consequences ................................... 53

About this Chapter .................................................................................................................... 53

How We Determined Effects of the Proposed Action and the Alternatives ............................. 53

Air Quality ................................................................................................................................ 54

Climate Change ......................................................................................................................... 67

Cultural Resources and Tribal Relations................................................................................... 76

Fuels .......................................................................................................................................... 87

Nonnative and Invasive Plants ................................................................................................ 101

Rangeland Resources .............................................................................................................. 108

Recreation ............................................................................................................................... 119

Roads and Engineering ........................................................................................................... 130

Scenery .................................................................................................................................... 139

Social Science, Economics, and Environmental Justice ......................................................... 148

Soil and Water Resources ....................................................................................................... 162

Vegetation ............................................................................................................................... 173

Wildlife, Fish, and Rare Plants ............................................................................................... 191

Chapter 4. Consultation and Coordination ............................................................................. 239

Preparers and Contributors...................................................................................................... 239

Federal, State, and Local Agencies Consulted: ....................................................................... 240
Contents

x FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Tribes ...................................................................................................................................... 241

List of Agencies, Organizations, and Persons to Whom Copies of the FEIS Were Sent ........ 242

Glossary ...................................................................................................................................... 245

References .................................................................................................................................. 255

Index ........................................................................................................................................... 275

Appendix A. Design Features, Best Management Practices, Mitigations and Monitoring . 277

Appendix B. List of Projects for Assessing Cumulative Effects ............................................ 317

Appendix C. Response to Comments on the DEIS ................................................................. 319

Appendix D. Comment Letters Received from Federal and State Agencies ........................ 408

Appendix E. Changes Made Since the Draft Environmental Impact Statement ................ 417

Appendix F. Legal and Regulatory Findings .......................................................................... 425

List of Tables

Table 1. Amendments for alternatives 1, 3, and 4 ......................................................................... 42

Table 1a. Existing Forest Plan, Appendix D – Standards and Guidelines for Management 

of Mexican Spotted Owl, Northern Goshawk, and Livestock Grazing ........................... 43

Table 1b. Minimum desired conditions for Mexican Spotted Owl Recovery 

nesting/roosting habitat in the mixed-conifer forest type of the Southern Rocky 

Mountain Ecological Management Unit1

. ........................................................................ 44

Table 2. Amendments for alternatives 1, 3, 4, and 5 ..................................................................... 45

Table 3. Comparison of the environmental effects of each of the alternatives ............................. 49

Table 4. Total metric tons of PM2.5 and carbon dioxide emissions produced for each 

alternative and from a wildfire.. ....................................................................................... 61

Table 4a. Estimated carbon dioxide emissions, in metric tons produced by restoration 

treatments, including smoke from prescribed fire treatments over the life of the 

project. .............................................................................................................................. 71

Table 5. Number of known sites per treatment type ...................................................................... 80

Table 6. Change in fire type after mechanical treatments and prescribed fire under 

alternative 1 ...................................................................................................................... 92

Table 7. Change in fire type in ponderosa pine and dry mixed conifer forests under 

alternative 1 ...................................................................................................................... 93

Table 8. Fireline intensity after mechanical treatments and prescribed fire under 

alternative 1 ...................................................................................................................... 93

Table 9. Change in fire type after mechanical treatments and prescribed fire under 

alternative 3 ...................................................................................................................... 95

Table 10. Change in fire type in ponderosa pine and dry mixed conifer forests ........................... 95

Table 11. Fireline Intensity after mechanical treatments and prescribed fire under 

alternative 3 ...................................................................................................................... 96

Table 12. Change in fire type after mechanical treatments and prescribed fire under 

alternative 4 ...................................................................................................................... 96

Table 13. Change in fire type in ponderosa pine and dry mixed conifer forests under 

alternative 4 ...................................................................................................................... 98

Table 14. Fireline Intensity after mechanical treatments and prescribed fire under 

alternative 4 ...................................................................................................................... 98
Contents

FEIS for the Southwest Jemez Mountains Landscape Restoration Project xi

Table 15. Change in fire type after mechanical treatments and prescribed fire under 

alternative 5 ...................................................................................................................... 99

Table 16. Change in fire type in ponderosa pine and dry mixed conifer forests under 

alternative 5 ...................................................................................................................... 99

Table 17. Fireline Intensity after mechanical treatments and prescribed fire under 

alternative 5 ...................................................................................................................... 99

Table 18. Nonnative and invasive plant species found in the project area, its NMDA 

classification, associated vegetation type, and acres of infestation. ............................... 102

Table 19. Grazing allotments and acreage within the project area .............................................. 109

Table 20. Traffic on forest roads in the project area ................................................................... 131

Table 21. Amount and type of road work, by alternative ............................................................ 133

Table 22. Population by race and ethnicity, 2011 ....................................................................... 150

Table 23. Estimated annual amount of total jobs and labor income ............................................ 152

Table 24. Estimated annual number of jobs created annually for each alternative ..................... 152

Table 25. Estimated amount of labor income by resource for each alternative, in 

thousands of dollars ........................................................................................................ 153

Table 26. Estimated total production of forest products removed from the forest over the 

life of the project ............................................................................................................ 154

Table 27. Net present value of the restoration treatments for each action alternative ................. 154

Table 28. Equivalent disturbed area/equivalent roaded area (EDA/ERA) values for 

mechanical treatments across the landscape ................................................................... 168

Table 29. Equivalent disturbed area/equivalent roaded area (EDA/ERA) values for 

prescribed fire use across the landscape ......................................................................... 168

Table 30. Percent and acres of vegetation types in the analysis area .......................................... 173

Table 31. Average number of snags per acre by cover type ........................................................ 176

Table 32. Changes in density indicators for alternatives 1, 3, and 4, by Mexican spotted 

owl habitat strata ............................................................................................................ 182

Table 33. Changes in density indicators for alternative 5 by Mexican spotted owl habitat 

strata ............................................................................................................................... 182

Table 34. Changes in density indicators for alternatives 1, 3, 4, and 5 by goshawk habitat 

strata ............................................................................................................................... 182

Table 35. Changes in VSS Class percentages at the stand level with proposed treatments 

for alternatives 1, 3, 4, and 5. ......................................................................................... 183

Table 36. Distribution of VSS classes in northern goshawk foraging habitat before and 

after mechanical treatments. ........................................................................................... 185

Table 37. Approximate volume harvested by alternative over the life of the project ................. 186

Table 38. Federal threatened, endangered, and proposed species analyzed ................................ 191

Table 39. Year of establishment and survey results for the six PACs in the project area ........... 194

Table 40. Type and amount of proposed treatments in Mexican spotted owl critical 

habitat and protected activity centers ............................................................................. 201

Table 41. Amount and type of proposed treatments in Jemez Mountains salamander 

critical habitat ................................................................................................................. 204

Table 42. Management indicator species, habitat, and population and habitat trends ................ 226

List of Figures 

Figure 1. Vicinity map of the area. Jemez Springs is in the center of the project area ................... 3

Figure 2. Dense stand of ponderosa pine in the project area ........................................................... 6

Figure 3. This is a good example of our desired conditions for ponderosa pine. ............................ 7

Figure 4. Piñon-juniper is found in the southern part of the project area ........................................ 8
Contents

xii FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 5. Aerial photographs of a typical Jemez Mountains ridgetop grassland taken in 

1935 and 1979 .................................................................................................................. 10

Figure 6. Degraded section of Rio Cebolla ................................................................................... 10

Figure 7. Mexican spotted owl (left) and Jemez Mountains salamander (right) ........................... 11

Figure 8. An archaeological site before and after treatment .......................................................... 12

Figure 9. Potential locations of vegetation and prescribed fire treatments under alternative 

1 (proposed action) ........................................................................................................... 25

Figure 10. Potential locations of roads proposed for decommissioning and roads to be 

used for vegetation treatments under alternative 1 ........................................................... 26

Figure 11 Location of proposed temporary roads under alternatives 1, 4, and 5. ......................... 27

Figure 12. Potential locations of headcut and invasive plant control treatments and 

treatments in Jemez Mountains salamander habitat under all action alternatives 

(1, 3, 4, and 5)................................................................................................................... 28

Figure 13. Potential locations of proposed meadow, riparian, aspen, and piñon-juniper 

treatments under all action alternatives (1, 3, 4, and 5) .................................................... 29

Figure 13a. Potential locations of gravel pits under all action alternatives (1, 3, 4, and 5). .......... 30

Figure 14. Potential treatment locations for mechanical treatments and prescribed fire 

under alternative 2 (no action) .......................................................................................... 32

Figure 15. Locations of road decommissioning and dispersed campsite rehabilitation 

treatments under alternative 2 (no action) ........................................................................ 33

Figure 16. Potential locations of vegetation and prescribed fire treatments under 

alternative 3 ...................................................................................................................... 34

Figure 17. Potential locations of roads proposed for decommissioning and roads to be 

used for treatments under alternative 3 ............................................................................ 35

Figure 18. Potential locations of vegetation and prescribed fire treatments under 

alternative 4 in ponderosa pine, dry mixed conifer, and wet mixed conifer forest 

types ................................................................................................................................. 37

Figure 19. Locations of roads proposed for decommissioning and roads to be used for 

vegetation treatments under alternative 4 ......................................................................... 38

Figure 20. Potential locations of vegetation and prescribed fire treatments under 

alternative 5. ..................................................................................................................... 39

Figure 21. Location of roads proposed for decommissioning and roads to be used for 

vegetation treatments under alternative 5 ......................................................................... 40

Figure 22. Relative size of PM2.5 particles as compared to fine beach sand, a human hair, 

and PM10 particles. .......................................................................................................... 55

Figure 23. Locations of air quality monitoring sites, climate stations, smoke sensitive 

communities, and Class 1 Airsheds of Concern ............................................................... 58

Figure 24. Particulate matter 2.5 (PM2.5) emissions in metric tons, for all alternatives and 

a wildfire. ......................................................................................................................... 62

Figure 25. Carbon dioxide emissions produced, in metric tons, for all alternatives and a 

wildfire ............................................................................................................................. 62

Figure 26. Average emissions of PM2.5 by alternative (metric tons per acre PM2.5) and 

treatment type ................................................................................................................... 63

Figure 26a. Total emissions of carbon dioxide by, in metric tons for each alternative, for 

activities other than prescribed fire .................................................................................. 65

Figure 27. Down trees, logs, branches, and pine needles cover a prehistoric site ......................... 77

Figure 28. Rock art before (left) and after (right) fire ................................................................... 81
Contents

FEIS for the Southwest Jemez Mountains Landscape Restoration Project xiii

Figure 29. Ladder fuels in San Diego Canyon (left). The small trees and shrubs 

underneath the larger trees can move fire from the surface into the crowns of the 

trees .................................................................................................................................. 89

Figure 30. Fire types after treatments under alternative 1 (right) and alternative 2 (left) ............. 94

Figure 31. Fire types after treatments under alternative 4 (left) and alternative 2 (right) ............. 97

Figure 32. Thistle infestation after the Las Conchas wildfire ..................................................... 106

Figure 33. Tree invasion of two large meadows in the Las Conchas grazing allotment ............. 113

Figure 34. San Antonio Campground is one of the most popular campgrounds in the area. ...... 120

Figure 35. Aspen and ponderosa pine along the the East Fork Jemez Trail ................................ 121

Figure 36. Locations of developed recreation areas and roads .................................................... 123

Figure 37. Recreation Opportunity Spectrum Settings ................................................................ 124

Figure 38. Roads in the project area that would be used to access treatment sites...................... 132

Figure 39.Gravel does not last forever ........................................................................................ 137

Figure 40. Visual Quality Objective and Scenic Integrity Objectives levels in the project 

area ................................................................................................................................. 141

Figure 41. Sensitivity Level 1 areas, travelways and use areas are located along highways 

and major forest roads. ................................................................................................... 142

Figure 42. Representative view of prescribed fire and aspen treatments from Key 

Viewpoint D, along Forest Road 376 ............................................................................. 145

Figure 43. Perennial and intermittent streams in the project area. .............................................. 164

Figure 44. Areas with an erosion hazard rating of severe. .......................................................... 166

Figure 44. Dry mixed conifer forest ............................................................................................ 175

Figure 45. Wet mixed conifer forest. ........................................................................................... 175

Figure 46. This is the type of opening that forests in the area used to have, where grasses 

and flowers can grow ..................................................................................................... 179

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 1 

Chapter 1. Purpose of and Need for Action

About This Document

We have prepared this environmental impact statement in compliance with the National 

Environmental Policy Act (NEPA) and other relevant Federal and State laws and regulations. This 

environmental impact statement discloses the direct, indirect, and cumulative environmental 

impacts that would result from the proposed action and alternatives.

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

found in the project planning record at the Santa Fe National Forest Supervisors Office. 

Chapter 1 includes information on the history of the project proposal, the purpose of and need for 

the project, and our proposal for achieving that purpose and need. This section also explains how 

we informed the public of the proposal and how the public responded. 

The Proposed Treatments

We propose to carry out forest management treatments designed to restore ecosystem structure 

and function and increase resilience to disturbances such as uncharacteristically severe wildfire, 

climate change, or insect and disease outbreaks. The treatments include mechanical treatments; 

prescribed fire; meadow and riparian area restoration; enhancing aspen stands, cultural resource 

protection; invasive plant control; and aquatic, riparian, and wildlife habitat improvement. Road 

treatments include road maintenance, road decommissioning, gravel pit development and 

construction of temporary roads. Treatments would occur for 8 to 10 years or until desired 

conditions are met. 

What are ecosystem structure, function, and resilience? What do we mean by restoration?

Restoration is the “process of assisting the recovery of an ecosystem that has been degraded, 

damaged, or destroyed. Ecological restoration focuses on establishing the composition, 

structure, pattern, and ecological processes necessary to facilitate terrestrial and aquatic 

ecosystem sustainability, resilience, and health under current and future conditions.” (Forest 

Service Manual 2020.5) 

Ecosystem structure is the physical features that make up an ecosystem including the 

abundance and diversity of plant and animal species. In forest ecosystems, this is horizontal 

and vertical distribution of the vegetation of a forest stand, including the height, diameter, 

crown layers, and stems of trees, shrubs, herbaceous understory, snags, and down woody 

debris. 

Ecosystem function is the interactions between organisms (plants, animals, microbes) and the 

physical environment, such as nutrient cycling, soil development, water cycling, and 

flammability.

Resilience is the “ability of a social or ecological system to absorb disturbance while retaining 

the same basic structure and ways of functioning, the capacity for self-organization, and the 

capacity to adapt to stress and change.” (Forest Service Manual 2020.5) 
Chapter 1. Purpose of and Need for Action

2 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Location and Description of the Project Area 

The project area covers about 110,000 acres of National Forest System land and is located in the 

Middle Jemez River Watershed (figure 1). The Valles Caldera National Preserve adjoins the 

project area on the northeast side; Bandelier National Monument lies to the southeast. A parcel of 

Jemez Pueblo land lies within the southeast part of the project area near Paliza Canyon. 

The Village of Jemez Springs lies in the middle of the project area; Jemez Pueblo and the town of 

Ponderosa are 7 miles and 4 miles, respectively, to the south. There are also several small 

subdivisions and communities in the mountains around Jemez Springs, including Sierra de los 

Pinos, La Cueva, and Thompson Ridge. Other land ownerships within the project area boundary 

total 13,836 acres, broken down as follows: Jemez Pueblo (3,845 acres); State (281 acres), and 

private or other lands (9,710 acres). No treatments are proposed on these other lands. 

The Jemez River flows through the middle of the area. Other drainages include San Antonio 

Creek, Rio Guadalupe, and Rio Cebolla. Elevations range from 10,109 feet at the top of Cerro 

Pelado to 5,500 feet in the canyon bottoms at the south end of the project area. Canyons and 

mesas dominate the area and include Virgin Canyon and Virgin, Holiday, Schoolhouse, and Stable 

Mesas to the west of the Jemez River, and Paliza and San Juan Canyons and Cat and San Juan 

Mesas to the east. 

Ponderosa pine is the main forest type in the project area (48 percent), followed by piñon-juniper 

woodland (32 percent), mixed conifer (12 percent), and small patches of spruce-fir and aspen 

(less than 2 percent total) at higher elevations. 

There are several special designation areas wholly or partially within the project area: East Fork 

Jemez Wild and Scenic River, Jemez National Recreation Area, Monument Canyon Natural 

Research Area, Jemez Mountain Trail Scenic Byway, and all or part of three inventoried roadless 

areas.

The project area and its resources are described in more detail in chapter 3, in the specialists’ 

reports, and the Southwest Jemez Mountains Landscape Assessment (USFS and VCNP 2010). 

The specialists’ reports are found in the project record.

History of the Project 

In 2000, the Cerro Grande Fire burned 48,000 acres and over 400 homes on forested lands just 

east of the project area. It also destroyed structures at the Los Alamos National Laboratory. After 

that wildfire, people from agencies, communities, conservation groups, and local and tribal 

governments teamed up to rehabilitate the fire-scarred land and to consider how to reduce the risk 

of uncharacteristically severe wildfires. The group met regularly for 10 years and completed a 

number of ecological assessments of the area. The assessments showed that the forests of the 

Southwest Jemez Mountains were not very resilient to landscape disturbances such as large-scale 

wildfires and were in need of restoration. 

In 2009, Congress authorized the Collaborative Forest Landscape Restoration Program, which 

encouraged collaborative, science-based ecosystem restoration of forest landscapes. This is a 

competitive program that awards funding to the top proposals nationwide. The program provided 

a perfect opportunity for the Santa Fe National Forest and the key partners in the restoration 

group—Valles Caldera National Preserve (VCNP), Jemez Pueblo, The Nature Conservancy, 
Chapter 1. Purpose of and Need for Action

FEIS for the Southwestern Jemez Mountains Landscape Restoration Project 3 

Figure 1. Vicinity map of the area. Jemez Springs is in the center of the project area. Valles Caldera National Preserve is the large white 

block in the upper right of the inset map.
Chapter 1. Purpose of and Need for Action

4 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

New Mexico Forest and Watershed Restoration Institute—to develop a proposal and move 

forward on restoring the Southwest Jemez Mountains area. Over 40 agencies and groups met and 

developed the Southwest Jemez Mountains Collaborative Forest Landscape Restoration Strategy

(USFS and VCNP 2010) and “Out of Whack” reports (both documents are located at: 

http://go.usa.gov/BUVh). The group proposed to treat over 210,000 acres across multiple 

ownerships and integrate treatments for riparian and forest ecosystems, wildlife habitat, and 

cultural resources. 

The Secretary of Agriculture selected the Southwest Jemez Mountains Landscape Restoration 

proposal in the first round of funding awarded in 2010. Since then, the partners have purchased 

monitoring equipment and started “shovel-ready” projects already analyzed under NEPA

requirements. 

Why Here, Why Now? 

These restoration treatments are needed because current forest conditions are not as resilient to 

large-scale disturbances as they used to be. In other words, they do not easily recover from events 

such as wildfires, floods, or insect and disease outbreaks. Southwestern ponderosa pine forests 

have been studied intensively and we have good information about reference conditions (Cooper 

1960; Covington and Moore 1994b; Moore et al. 2004). There are also numerous studies on the 

forest conditions and fire cycles specific to the Jemez Mountains (Allen 1989, 2001; Touchan et 

al. 1995, 1996; Allen et al. 1995; Touchan and Swetnam 1995; Swetnam and Baisan 1996). From 

this and other research we know that current conditions are the result of past human activities 

starting in the late 1800s, including logging, overgrazing, and fire suppression. The combined 

effects from these activities have changed the forests, grasslands, and riparian ecosystems.

The U.S. Southwest, including the Jemez Mountains, has been the focus of ecological research on 

forest ecosystems, fire history and behavior, climate change, hydrologic regimes, and wildlife. 

The ecosystem changes in the Southwest Jemez Mountains have been documented in numerous 

landscape and resource assessments (http://go.usa.gov/BUVh) produced by land management 

agencies and conservation groups. These assessments identify the area as a critical conservation 

area and rank it as a top priority for restoration. 

Existing and Desired Conditions: 

What We Have and What We Want 

The description of the existing conditions in the project area is based on surveys, inventories, and 

other field work completed by Forest Service staff; Forest Service resource databases; scientific 

literature; and broad-scale resource assessment reports, including the Landscape Assessment

(USFS 2010). These references and detailed descriptions of the existing condition and the 

changes caused by human activities are summarized in this section. Full information can be found 

in the specialists’ reports, located in the project record. 

Forests and Woodlands 

The forests we have today do not resemble the forests that existed before the late 1800s. This is 

especially true for the ponderosa pine and dry mixed-conifer forests. Logging, grazing, and fire 

suppression have changed the forests to the point where they are “out of whack”—that is, they do 
Chapter 1. Purpose of and Need for Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 5 

not function in a way that allows them to recover from disturbances such as wildfires, insect and 

disease outbreaks, and overall be more resilient to long-term changes in climate.

The desired conditions for this area come from a number of sources, including the Santa Fe 

National Forest Plan (hereafter referred to as the “forest plan”) and ecological research on 

reference conditions.

1 Our desired conditions are more than just an attempt to duplicate reference 

conditions. Reference conditions act as a baseline for evaluating current conditions, and they also 

guide the development of treatments (Fulé et al. 1997). Ecosystems function best in the 

conditions to which they adapted over time (Swanson et al. 1994). For example, open forests, a 

grassy understory, and low-intensity surface fires are the key features of ponderosa pine forests. 

Moving the ponderosa pine forests toward these conditions increases resilience and the forests 

will be better equipped to handle disturbances, including climate change (Fulé 2008).

Ponderosa Pine and Dry Mixed Conifer Forests

Of all forest types in the project area, research indicates that the ponderosa pine and dry mixed 

conifer forests show a high degree of departure from condition found within the area prior to 

European settlement. This departure can be attributed, in large part, to changes in the fire regime 

of these forest types. While there is some disagreement about the historical frequency and 

severity of wildfires in the intermountain west, site-specific studies done in the Jemez Mountains 

document low-intensity, high frequency fires over hundreds of years, as far back as the late 1400s 

(Allen 1989, 2001; Touchan et al. 1995, 1996; Allen et al. 1995; Touchan and Swetnam 1995; 

Swetnam and Baisan 1996). 

There is some evidence, however, that mixed or high severity fires occurred in the area. Allen 

(1989) also found that patchy crown fires were part of the fire regime in the mixed-conifer forest 

type on wetter sites. Charcoal evidence from bogs in the Jemez Mountains indicates a mixed 

severity fire regime on wetter sites 7,000-5,000 years before the present (Allen et al. 2008). The 

complex terrain found here- canyons, steep slopes, and mesas- may have created patch scale (10-

100 acres) or larger areas of mixed and high-severity wildfire “as part of the natural fire regime,” 

(Jenkins et al. 2011, p. 139), as opposed to the occurrence of severe wildfire events separated by 

long periods without any wildfires. 

Topography, slope, aspect, climate influences, fuel continuity, invasive plants, and herbivore 

grazing (domestic and native animals) are among the factors that may result in localized areas of 

mixed and high severity fires within a low-severity fire regime landscape (Everett et al. 2000; 

Arno and Allison-Bunnell 2002; Veblen 2003; Jenkins et al. 2011). These factors can result in 

different fire regimes in different locations of the same forest type (Everett et al. 2000; Veblen 

2003). In addition to the complex terrain, other factors influencing fire type and severity in the 

Jemez Mountains are a high level of lightning activity, the effects of the El Niño Southern 

Oscillation (El Niño-La Niña effect), and the American monsoons (Allen 1989). 

Landscape-scale research suggests that both forest structure and fire severity were historically 

more variable in dry forests (ponderosa pine and dry mixed conifer) in the western United States 

 

1 Reference conditions typically refer to the state of an ecosystem before human influences. They provide a 

reference baseline of conditions that scientists can compare to current conditions. 
Chapter 1. Purpose of and Need for Action

6 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

than originally thought (Williams and Baker 2012a, b; Odion et al. 2014). These newer studies 

used forest reconstruction methods to estimate historical tree densities in dry forests in Oregon, 

Arizona, and Colorado. The historical, average tree densities calculated in these studies were 

several times higher than those found in earlier studies of Southwestern U.S. dry forests. 

Regardless, recent stand exam data shows tree densities of as high as 1,200 trees per acre in the 

project area; this far exceeds the estimated densities from both the landscape-scale and sitespecific research.

Figure 2. Dense stand of ponderosa pine in the project area. The trees are a 

similar age and size. There is little or no understory vegetation. Much of the 

ponderosa pine forest in the project area looks like this.

The dry forest systems in the Jemez Mountains have moved from open forests dominated by 

groups and clumps of trees of different ages and sizes to a dense, continuous blanket of even-aged 

(80- to 90-year-old), pole-sized (5 to 12 inches diameter) trees (figure 2). Tree densities have 

increased dramatically. In the past, average densities across the Southwest ranged from 15 to 56 

trees per acre on sites with a frequent fire regime (Covington and Moore 1994a) to as many as 57-

87 trees per acre on sites believed to have a more infrequent, higher or variable severity fire 

regime (Williams and Baker 2012b). Current densities average 500 trees per acre or more. There 

are also fewer large trees (over 18-inches diameter), old-growth trees, snags, and down wood. 

Openings and understory plants are scarce. 

Without surface fires to thin out the small trees, the number of trees is extremely high. The dense 

tree canopy also inhibits the growth of understory grasses, forbs, and shrubs. Instead, there is a 

carpet of pine needles. This means there is more competition for light, water, and nutrients. On 

average, the trees are now smaller and grow more slowly.

Dry mixed-conifer forests (primarily Douglas-fir, ponderosa pine, limber pine, and aspen) are in a 

similar state. These dense stands have more white fir and less aspen and ponderosa pine. There 
Chapter 1. Purpose of and Need for Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 7 

are fewer openings in the canopy and understory grasses and other plants are less productive and 

less diverse. Snow and rain are caught in the canopy and evaporate before reaching the ground. 

Our desired condition for ponderosa pine is to have a mix of tree sizes and ages, including old 

growth (figure 3). Trees would be found mostly in unevenly spaced groups of 4 to 100 trees 

across the landscape. Interspaces, or rooting zones, would be found between the groups of trees. 

There would be openings where seedling could germinate in full sun or where dense 

bunchgrasses could grow. This is often described as a mosaic. Desired conditions for dry mixedconifer forests are similar, except that the groups of trees would be denser and the openings 

between groups of trees would be smaller. In both forest types, the openings provide places for 

seedlings to sprout and grow. 

The more open desired conditions within the ponderosa pine and dry mixed conifer forest types 

would create a mosaic over the landscape as a whole, with areas of higher densities occurring on 

steeper terrain and within wet mixed conifer, old growth, and habitats for threatened and 

endangered species. In the more open, less dense stands, fire could play its key role in 

maintaining both types of forest and the landscape as a whole. These low-intensity surface fires 

could then reduce or maintain fuel levels and tree densities and rejuvenate the understory 

bunchgrasses. In the denser areas, mixed severity fire would create patches and small openings, 

resulting in more heterogeneity or diversity of the forest structure. This structural diversity could 

allow for the natural variability of disturbance regimes, such as fire (Allen et al. 2002). 

Figure 3. This is a good example of our desired conditions for ponderosa pine. 

There are three age and size classes of trees: older, large diameter trees on the left, 

sapling and seedlings at the center and right front, and pole size trees in the 

background. A mix of grasses and non-woody plants makes up the understory. 
Chapter 1. Purpose of and Need for Action

8 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

With more open stands, fire could play its key role in maintaining both types of forests. Lowintensity surface fires would reduce or maintain fuel levels and tree densities and rejuvenate the 

understory bunchgrasses. 

Aspen and Piñon-juniper Forests

Aspen is dependent on disturbance (fire and windthrow) for regeneration. Due to a lack of 

periodic fires that historically regenerated patches of aspen, most of the aspen is mature or overmature. Conifer trees are taking over the aspen patches due to the lack of natural fires, resulting in 

a gradual loss of aspen stands. Without fire or other disturbance, aspen stands in the area will 

gradually die out as they are replaced by conifers. 

We want to maintain the aspen we have and regenerate more stands on the west side of the project 

area for vegetative diversity. Aspen stands will also enhance wildlife habitat and provide visual 

diversity.

Piñon-juniper forests have also changed since the late 1800s. Livestock grazing reduced the 

amount of grasses and ground cover that provided fuel for fires. This encouraged the growth of 

more piñon pine and juniper trees because of reduced competition from grasses and increasing 

bare soil. Currently, tree density is high, there is very little understory vegetation, and soil erosion 

is common (figure 4). 

Figure 4. Piñon-juniper is found in the southern part of the project area. There is 

little or no understory vegetation. Large areas of bare soil are easily eroded.

In piñon-juniper forests, we want an understory that provides forage and habitat for wildlife such 

as turkey, deer, rodents, and small birds. Having more ground cover would also reduce erosion in 

this forest type. 
Chapter 1. Purpose of and Need for Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 9 

Wet Mixed Conifer 

This forest type has experienced the least amount of human-influenced change. There are dense 

stands of trees of all ages and sizes. Douglas-fir and white fir are the main species, and there is 

usually some remnant aspen in the understory. Large and small openings in the canopy have been 

created by fire and other disturbances. 

Our desired condition is to have a mix of tree species and tree sizes and ages in patches across the 

landscape. This will provide a diverse habitat for threatened and endangered species. We also 

want a lower density of trees in some areas to reduce fire hazard in Mexican spotted owl habitat 

and near wildland-urban interface areas.

Old Growth

Old growth (also called late successional stage or climax forest) is critical to maintaining the 

biological diversity and abundance of many species of native plants and animals. In the 

Southwest Jemez Mountains, important species include the Mexican spotted owl and the Jemez 

Mountains salamander (see figure 7). The project area has not been fully inventoried for old 

growth, but there are large, mature trees throughout the area. However, these large trees are not 

uniformly distributed and occur mostly on steep slopes or in canyon bottoms. On the mesa tops, 

old growth has declined due to past overharvesting. 

We want to allocate 20 percent of both ponderosa pine and mixed conifer forests as old growth. 

Our desired condition is for these areas to have snags, large trees, down logs, and thick-barked, 

fire-resistant species such as ponderosa pine and Douglas-fir across the landscape. 

Meadows, Riparian Areas, and Aquatic Habitat 

Grasslands and meadows are smaller than in the past because trees have spread into these areas 

(figure 5). This, along with increased numbers of trees overall, has altered the hydrology and 

function of wetland and riparian systems. As trees take up more water, there is less water in 

streams, seeps, and springs. Grazing, recreational use, and nonnative and invasive species have 

reduced the abundance and diversity of native vegetation in meadows. 

In riparian areas, recreation use (camping, fishing, vehicle use), and grazing have trampled 

riparian vegetation and streambanks. These bare areas along streams, headcuts (gullies), and 

eroded streambanks add sediment to streams, impacting both water quality and fish habitat 

(figure 6). Some riparian corridors do not have enough willow, aspen, or other vegetation to 

sustain beaver populations. Some streams do not meet State water quality standards because of 

high sediment levels and high water temperatures. Fish habitat—riffles, pool depth and quality, 

amount of large woody debris, and streambank condition—is also in a degraded condition. 

Our desired condition is to have meadows that are more like historical natural meadows with 

abundant and diverse native vegetation. Hydrologic function would be improved, and springs and 

seeps would produce more water. 

Aquatic habitats and riparian areas would be properly functioning, with abundant, diverse native 

vegetation that stabilizes streambanks and provides stream shading and cover for native aquatic 

species. Habitat for beaver, the New Mexico meadow jumping mouse, and threatened, 

endangered, and sensitive species would be restored and maintained. Riparian corridors would 
Chapter 1. Purpose of and Need for Action

10 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

have habitat connectivity, and streams would have more pools, curves, bends, and woody debris. 

Sediment would be reduced and water quality would move toward or meet State standards. 

Figure 5. Aerial photographs of a typical Jemez Mountains ridgetop grassland taken

in 1935 and 1979. Notice how the open meadow has become smaller because of 

invading conifers. Areas of open montane grasslands in the Jemez Mountains have 

declined by 55 percent because of conifer encroachment. 

Figure 6. Degraded section of Rio Cebolla. The stream 

channel is entrenched (below the level of the 

meadow). Sections of the bank on the middle left and 

upper right are eroding.
Chapter 1. Purpose of and Need for Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 11

Wildlife Habitat 

Our concerns about wildlife habitat are related to current forest conditions. Because of the dense 

closed canopy forest there is a lack of understory plants that provide forage and cover for 

ungulates (elk and deer) and nesting habitat for small mammals and birds. Open meadow and 

aspen habitats are decreasing due to lack of periodic fires and the ingrowth of conifer trees. 

Nonnative and invasive plants (weeds) are impacting habitat by competing with native 

vegetation. The presence of roads, vehicle use, and human activity and noise also break up habitat 

and disturb wildlife.

Water is a vital component of high quality wildlife habitat, but it is not abundant or widespread 

across the landscape. Existing water sources are diminishing and are lacking in some parts of the 

landscape. Less rain and snowfall reach the ground because it is intercepted by the dense layer of 

trees, resulting in a loss of surface and ground water supplies. Springs and seeps that provided 

water for wildlife are now dry or have less water.

If we achieve our desired conditions for forest and woodland vegetation types, we would also 

achieve most of our desired conditions for wildlife habitat, which is to provide quality habitat for 

a wide variety of wildlife species. Across the landscape, we want forests to have trees of different 

ages and sizes and a diverse understory of grasses, forbs, and shrubs. Forests would also have 

more old and mature trees, snags, and large woody debris that provide nesting and sheltering 

habitat. Water sources, including streams, rivers, springs, and artificial water sources would be 

well functioning and distributed across the landscape. Habitat for the Mexican spotted owl and 

Jemez Mountains salamander would meet the requirements in the forest plan and the recovery 

plans for these species. 

Threatened and Endangered Species

There are three listed threatened and endangered species within the project area: the Mexican 

spotted owl (threatened), the New Mexico meadow jumping mouse (endangered), and the Jemez 

Mountains salamander (endangered) (figure 7). 

Figure 7. Mexican spotted owl (left) and Jemez Mountains salamander (right). (Photos courtesy of 

Charlie Denton, Apache-Sitgreaves National Forests and Valles Caldera National Preserve, 

respectively) 

Current habitat conditions in the project area do not meet guidelines identified in the recovery 

plans for the owl (USFWS 1995, 2012) primarily due to the lack of structural and vegetative 

species diversity, large trees, and understory plants. The greatest threat to owl habitat in the 
Chapter 1. Purpose of and Need for Action

12 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

project area is the high potential for an uncharacteristically severe wildfire like the Cerro Grande 

or Las Conchas Fires. Other key problems affecting the owl habitat in this area are the lack of 

large mature trees, and habitat for prey animals. 

The scientific knowledge about the life cycle of the Jemez Mountains salamander and its habitat 

requirements is limited. It is thought that the best habitat includes heavy tree canopy, large 

downed logs that provide cover and above ground habitat, and loose rocky soils where 

salamanders lay eggs. The primary threats to these salamanders are loss of habitat due to climate 

change, stand-replacing fires, and direct loss due to human activity (such as vehicle use and 

recreation). These threats interact in a complex way that could lead to local extirpation (loss) of 

salamanders at currently occupied sites (USFWS 2013b). 

Our desired condition for the habitat for all species is to make their habitats resilient to the effects 

of their primary threats.

Cultural Resources

The Jemez Mountains are rich in cultural resources from Native American, Hispanic, and EuroAmerican residence and use. There are nearly 3,000 known archaeological sites. Tribal members 

today use the area for hunting and gathering plants, boughs, and other materials for household 

and ceremonial use. 

Currently, many sites in the area have high loads of forest fuels; trees and brush grow on and 

within sites, and dead and down logs are lying on top of walls and other features (figure 8). These 

sites have experienced and survived low-intensity surface fires for centuries, but now are at high 

risk of destruction in the event of an uncharacteristically severe wildfire. Heavy recreational use 

in the area has led to some instances of vandalism. In some places, unauthorized roads and trails 

and grazing have caused increased erosion within site boundaries. 

Figure 8. An archaeological site before and after treatment. Left: Downed trees and logs on top of 

the rock structure will damage the site, especially if there is a severe wildfire. Right: After treatment, 

fuels are gone and the site is capable of withstanding a low-intensity surface fire. (Photos courtesy 

of John Galvan)

Our desired condition for archaeological sites is to have reduced fuel levels so that they are 

resilient to the effects of an uncharacteristically severe wildfire, including the flooding and 

erosion that follow. The forest would continue to provide the resources for traditional 

communities that help preserve and sustain their traditional practices. Resilience would be 
Chapter 1. Purpose of and Need for Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 13

provided, in part, by an abundance of native grasses that stabilize the soil and provide fine fuels 

(grasses) to carry low-intensity fires. 

Roads 

The project area has a lot of roads and many are in poor condition. Most are unsurfaced (no 

gravel), primitive dirt roads (maintenance level 2) with little or no functioning drainage features. 

Many are parallel to canyon bottoms and some cross stream channels, resulting in more sediment 

in the water. Overall, roads in poor condition contribute the most to loss of soil productivity and 

impacts on water quality. Roads also impact cultural resources, wildlife habitat, and contribute to 

the spread of invasive plants.

We want adequate and safe access to the project area to accomplish restoration treatments, to 

remove products, and for public use. This can be done by using existing National Forest System 

roads, opening National Forest System roads that are currently closed (maintenance level 1) and 

closing them after use, and constructing temporary roads that would be decommissioned2 after 

use. 

We also want a road system that does not degrade water quality, soils, watershed conditions, and 

other resources. Reconstructed and adequately maintained roads would have improved surfaces 

and drainage functionality that minimize erosion, sedimentation, and other resource impacts. 

Decommissioned roads would no longer significantly contribute to resource impacts. 

Nonnative and Invasive Plants 

To date we have identified about 1,200 acres of nonnative and invasive plants (weeds) in the 

project area. Nonnative and invasive plants outcompete and displace native plant communities. 

As invasive plant populations increase, more wildlife habitat is lost, especially in critical places 

such as riparian areas and valley bottoms. This is the case in the project area. Salt cedar, Russian 

olive and Siberian elm are found along the Jemez River and other low elevation streams. 

Throughout the Southwest, these wet areas are critical habitat for many plants and animals. With 

loss of this habitat, the abundance and diversity of wildlife species also declines. Numerous other 

invasive plant species are present in the area, and although they are not present in large acreages, 

they are still a concern in regards to decreasing vegetative diversity. 

We cannot eliminate all the weeds across this landscape, but we desire to have a landscape with 

fewer weeds, more vegetative diversity, and quality wildlife habitat. We also want to reduce the 

potential for, and establishment and spread of, nonnative and invasive plant species infestations, 

especially in special plant and wildlife habitats and riparian areas.

Our Purpose and Need for this Project 

The Southwest Jemez ecosystems are in a degraded condition and have lost resiliency (the ability 

to recover from a disturbance). They are now more susceptible to severe and intense wildfires, 

insect and disease outbreaks, drought, and climate change. Therefore, our overarching goal at the 

landscape level is to restore ecosystem structure and function and increase resilience to 

undesirable, large-scale disturbances such as uncharacteristically severe wildfire, insect outbreaks 

 

2 See description of decommissioning methods in chapter 2. 
Chapter 1. Purpose of and Need for Action

14 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

and climate change in the Southwest Jemez Mountains. To do this, we have identified four 

purposes: 

Restore the structure, function, and resilience of ponderosa pine and dry mixed conifer 

forests, which would also reduce the potential for uncharacteristically severe and 

intense wildfires while promoting low-intensity, frequent surface fires that were 

common across this landscape. 

To achieve this, there is a need for:

• forest stands with a mosaic of grassy openings, shrubs, and groups of trees of various 

sizes and ages;

• native perennial grasses, shrubs, and forbs that can carry low-intensity fire across the 

landscape;

• a landscape where fire can resume its role as an essential and keystone process;

• more old-growth forest structure in ponderosa pine and dry mixed-conifer stands, and

• reduced amounts of live and dead fuels.

Improve the function of riparian ecosystems and streams, and improve fish and wildlife 

habitat, vegetative diversity, and water quality. 

To achieve this, there is a need for:

• native riparian vegetation along streams and more pools, riffles, and large woody 

debris within streams;

• aspen in a range of successional stages that are distributed across the landscape; 

• fewer impacts from livestock and elk in riparian areas and along streambanks;

• less erosion, bare soil, and unstable or raw streambanks;

• less erosion and fewer headcuts and gullies in upland areas; 

• fewer impacts from roads;

• fewer nonnative invasive plants;

• springs and seeps that function at or near their potential; 

• more structural and understory diversity in northern goshawk and Mexican spotted 

owl habitat; 

• less erosion overall, and therefore less sediment in streams;

• improved floodplain function; 

• meadows restored to former boundaries to increase meadow habitat, and

• increased water availability for wildlife.
Chapter 1. Purpose of and Need for Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 15

Use the forest restoration byproducts to offset treatment costs and provide economic 

opportunity to the local rural communities. 

To achieve this, there is a need for:

• a source of wood products for commercial and personal use;

• a transportation system to implement activities and remove wood products, and 

• reduced fuel loading through the removal of forest products. 

Provide for the sustainability of archaeological sites, traditional cultural properties, 

sacred sites, and forest resources associated with traditional practices. 

To achieve this, there is a need for:

• reduced amounts of fuel on archaeological sites; 

• erosion control measures on archaeological sites;

• forests that provide continued availability to engage in traditional practices; and 

• fewer road-related impacts on archaeological sites.

The Proposed Action

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

restore the structure and function of forests and watersheds in the project area. Treatments are 

briefly described below. The restoration treatments and the general locations are described in 

detail in chapter 2. Treatments will take place over the next 8 to 10 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 activity fuels. 

• Enhance and promote aspen by cutting and removing conifers in areas with aspen. 

Improve the Function of Riparian Areas 

and Streams, Vegetative Diversity, and Water Quality 

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

• Close and revegetate degraded campsites and trails by placing soil, rock, and boulders on 

and around the site and by planting native vegetation. 

• Place large woody debris and/or plant vegetation in or near stream channels to stabilize 

streambanks. 

• Remove, obliterate, or improve road crossings at streams to reduce sedimentation. 

• Fill headcuts and arroyos with soil, rock, or boulders to control erosion. 

• Construct earthen dams or trick tanks in upland areas to increase water availability for 

wildlife and to improve fish and wildlife habitat. 
Chapter 1. Purpose of and Need for Action

16 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

• Plant trees and shrubs around water tanks and drinkers for wildlife to screen them from 

road viewpoints. 

• Remove conifers from around meadow margins to restore meadows and increase meadow 

habitat. 

• Fence streamside areas to prevent access by livestock or elk and protect and increase 

streamside vegetation and overhanging streambanks from grazing and trampling. 

• Create pools and channels, replace culverts, and replace or repair stream structures to 

restore instream fish habitat. 

• Create snags. 

Sustain and Protect Cultural Resources

• Use contour felling, lop and scatter, seeding and mulching, and placing limbs in erosion 

cuts and rills to control and prevent erosion on archaeological sites. 

• Remove trees and brush from archaeological sites, traditional cultural properties, and 

sacred sites to reduce fuel.

Reduce Impacts from Roads 

• Decommission up to 100 miles of unneeded roads. 

• Reconstruct and maintain existing Forest system roads used for project-related access. 

This includes opening closed roads and closing them after use. 

• Develop gravel pits to reduce surfacing costs. Gravel would be used to improve road 

surfaces thereby reducing erosion and maintenance costs throughout the area. 

Access Treatment Areas and Remove Wood Products 

• Construct temporary roads and decommission them after use. 

• Reopen existing closed roads and close them after use. 

Forest Plan Amendments, Permits, Licenses, and Consultation 

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

proposed action, as well as Federal permits or licenses and consultation needed.

The Decision to Be Made 

The forest supervisor for the Santa Fe National Forest is the responsible official. Based on the 

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

decide whether the proposed action should be implemented as proposed, modified by another 

action alternative, or not implemented at all, and whether to amend the forest plan. Their decision 

includes determining (1) the location and treatment methods for all restoration activities; (2) 

design criteria, mitigation measures, and monitoring requirements; (3) the components that will 

be included in the monitoring plan; (4) the wood products or material made available as a byproduct of the restoration activities; and (5) whether the forest plan will be amended if an action 

alternative is chosen. 
Chapter 1. Purpose of and Need for Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 17

Tribal Consultation 

Tribes and Pueblos with a historical link to the area and an interest in the Santa Fe National 

Forest were contacted during the public involvement efforts described below including: Santa 

Clara Pueblo, Pueblo of Jemez, Pueblo of San Felipe, Kewa Pueblo, Ohkay Owingeh, Pueblo of 

Zuni, Pueblo of Cochiti, Pueblo of Pojauque, Pueblo of Picuris, Pueblo of Taos, Pueblo of 

Tesuque, Pueblo of Nambe, Pueblo of San Ildefonso, and Pueblo of Zia, Navajo Nation, Jicarilla 

Apache Nation, and Mescalero Apache Nation. The Navajo Nation was the only tribe to submit a 

response and did not have any concerns with the project at that time. The project was also 

included in annual consultation package submitted to 36 tribal governments, their representatives, 

and allied government organizations with a direct interest in projects conducted on the Forest (see 

chapter 4 for the complete list). The importance of protecting Douglas-fir stands was raised by 

several of the surrounding tribes. The boughs are used in ceremonies and recent fires have 

destroyed many Douglas-fir stands in and around the project area. 

Public Involvement Efforts 

We began public involvement efforts during the spring and summer of 2012. A timeline and 

description of these efforts is found in the project record. 

Issues Identified From Public Comments 

We reviewed the comments we received from all our meetings and notices and used them to 

identify relevant issues. Issues were used to develop alternatives, develop design criteria or 

mitigation measures that reduce unwanted effects, and to analyze and compare the effects of the 

different alternatives (see chapter 3). The interdisciplinary team identified several issues focused 

on: 

• the use of prescribed fire and its effects on environmental and human health; 

• the scale (number of acres) of tree cutting, the cutting of large trees and how this may 

affect watersheds, wildlife, and scenery; 

• opening closed roads and building new temporary roads and their effects on the 

environment, 

• the effects of mechanical treatments and prescribed fire on habitat for the Jemez 

Mountains salamander, Mexican spotted owl, and northern goshawk, and 

• the need for an amendment to allow treatments in Mexican spotted owl habitat and 

whether it fails to protect the owl in the short term. 

The interdisciplinary team identified some comments as nonsignificant issues or concerns. These 

were not studied in detail because they were (1) outside the scope of the proposed action; (2) 

already decided by law, regulation, forest plan, or other higher level decision; (3) not related to 

the decision to be made; or (4) conjectural and not supported by scientific or factual evidence. 

These issues and concerns and our reasons for categorizing them as nonsignificant are in the 

project record.

Concerns that Arose during Public Involvement 

Other comments, concerns, and recommendations that were not considered key issues were raised 

during the public involvement effort and included: 
Chapter 1. Purpose of and Need for Action

18 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

• keeping Native American tribes, local communities, grazing permittees updated on 

planning and implementation; 

• focusing on treating wildland-urban interface areas; 

• using the best available science regarding Southwestern forest ecosystems; 

• requests for more information about the restoration treatments and their location; 

• the effects of tree cutting and prescribed fire on wildlife, including migratory birds; 

• reducing the scale of treatments in aspen and piñon-juniper; and 

• complying with law, policy, and regulation regarding health and the environment. 

Many of these concerns were considered and incorporated in the draft environmental impact 

statement or design criteria, mitigations, and best management practices. We added more 

information about the proposed treatments, as well as maps showing the locations of potential 

treatments for each alternative. Public involvement and compliance with existing laws are part of 

the NEPA process. Stakeholders have been and will be updated through our public involvement 

and consultation efforts. We have also hired implementation and partnership coordinators who 

have been working with the public. All stakeholders will have more opportunities to participate 

and comment as we develop the final environmental impact statement.

Comments regarding effects on wildlife, vegetation, or the environment were addressed in the 

environmental consequences. Some comments were beyond the scope of the project, such as the 

reintroduction of wolves or beavers to the area or restoration of the Las Conchas burn area, and 

focusing on wildland-urban interface areas. Stakeholders recommended additional scientific 

literature references and citations, which we reviewed and considered. We have also used recent 

research about aspen to review and adjust the proposed aspen treatments. We have also 

incorporated new research done in the Jemez Mountains, about severe wildfires and permanent 

changes to vegetation types into the environmental analysis. See the scoping report in the project 

record for our responses to all of the concerns. 
FEIS for the Southwest Jemez Mountains Landscape Restoration Project 19

Chapter 2. Alternatives, Including the 

Proposed Action

About this Chapter 

This chapter describes and compares the alternatives for the Southwest Jemez Mountains 

Restoration Project and includes a map of each alternative considered. This comparison provides 

a clear basis for choice among options by the decision maker and stakeholders. Some of the 

information used to compare the alternatives is based upon the design of the alternative (e.g., 

acres burned) and some of the information is based upon the environmental, social, and economic 

effects of implementing each alternative (how well it achieves the purpose and need). 

Forest Plan Consistency 

Forestwide and management or geographic area-specific standards and guidelines have been 

incorporated into the design of alternatives 1, 3, 4, and 5 as shown in appendix A. Other 

applicable forest plan requirements that have been incorporated by resource area are in the 

resource specialist reports. With the proposed nonsignificant forest plan amendments (see tables 1 

and 2 in this chapter), alternatives 1, 3, 4, and 5 are consistent with the Santa Fe National Forest 

Land and Resource Management Plan (forest plan). All proposed amendments are site-specific 

and are only applicable to this project. 

The forest plan will be amended using the 1982 rule procedures as allowed by the transition 

language of the 2012 planning rule (36 CFR 219.17(b)(3), 2012 Planning Rule). All amendments 

are non-significant (FSM 1926.51). The report documenting the consistency of the action 

alternatives with the forest plan is located in the project record.

The Alternatives

This is a landscape-level restoration project; we are analyzing a project area that is approximately 

110,000 acres. We do not have complete information about the conditions found on every acre, 

but we do have enough data to make an informed decision about what kinds of treatments work 

best in certain conditions. 

Instead of using local-level treatments, such as a stand prescription, treatments will be guided by 

landscape features (what we find on the ground). Examples of landscape features are cover types, 

slope, scenic sensitivity levels, or threatened and endangered species habitat. 

Once a set of landscape features is identified, we would then identify the types of treatment tools 

or design criteria that we could use to treat those features. Then we would project the effects 

caused by these different kinds of tools. This approach provides flexibility and is known as the 

“toolbox” approach. This approach lets us account for imperfect information and adapt to changes 

in environmental conditions. We can also monitor effects of the individual and cumulative actions 

and make changes to the design criteria or mitigation measures if the effects differ from what we 

predicted. In this way, as landscape conditions vary, even within a vegetation type like ponderosa 

pine, the appropriate tool is applied to achieve the desired result. A tool that might be appropriate 

in one area may not be the right tool to use somewhere else. 

So, as an example, as the implementation team works its way through a potential treatment area it 

encounters an area of ponderosa pine with slopes less than 40 percent, an uneven-aged structure, 

and that is not within a Mexican spotted owl protected activity center. The treatment design 
Chapter 2. Alternatives Including the Proposed Action

20 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

criteria or tool that would be applied would be uneven-aged mechanical selection cutting and 

prescribed fire. The design criteria would be different if an even-aged structure was encountered 

or if the area being looked at was within a Mexican spotted owl protected activity center. 

The toolbox approach applies to all alternatives, except for the no action alternative. Before 

carrying out treatments, project leaders would carefully look at the specific area to be treated and 

select the appropriate treatment tool(s). Appendix A lists the design criteria or tools we anticipate 

using in different landscape conditions. 

The interdisciplinary team used comments from the public and from within the Forest Service, 

along with modeling and field surveys to modify the proposed action3 and formulate alternatives 

to the proposed action. The five alternatives analyzed in this final EIS include: 

• alternative 1, the proposed action

• alternative 2, no action

• alternative 3, no temporary roads 

• alternative 4, no prescribed fire in mechanical treatment areas, and 

• alternative 5, implement restoration treatments while conforming to the existing forest 

plan standards and guidelines for managing Mexican spotted owl habitat (Amendment 6, 

1996). 

Alternative 1 – Proposed Action

The intent of this alternative is to restore the structure and function of forests and watersheds in 

the project area as described in chapter 1. Proposed treatments to accomplish this are listed below. 

Maps showing the treatment locations are found in figure 9 through figure 13. This is the forest 

supervisor’s preferred alternative. 

Uneven-aged Mechanical Selection Cutting

with Openings and Prescribed Fire in Ponderosa Pine

These treatments are designed to restore the structure and function of ponderosa pine forest. The 

result of this treatment would be an uneven-aged forest with groups of trees of various sizes and 

ages. Grassy openings and groups of shrubs would be interspersed with the groups of trees, and 

size classes would be more balanced. This would occur on slopes less than 40 percent slope on 

approximately 23,000 acres. To achieve this goal, trees would be cut using chainsaws or other 

equipment (i.e., feller-bunchers). Cut trees would be skidded to the road to be removed as logs or 

chips. Prescribed fire would then be used to reduce fuel loading and help restore the ecological 

benefits of fire. Prescribed fire may be repeated every 5 to 10 years to maintain desired fuel loads. 

Stand Improvement Thinning and Prescribed Fire in Ponderosa Pine

These treatments would occur on slopes less than 40 percent slope on approximately 1,500 acres

in ponderosa pine stands. Stand improvement thinning is designed to improve tree growth, tree 

vigor, and create stand structure that will allow uneven-aged desired conditions in the future. We 

propose to use this type of thinning in young, even-aged stands, stands with light to moderate 

 

3 Modification of the proposed action is allowed by Forest Service regulations 36 CFR 220.5(e)(1). 

Changes to the proposed action are documented in the project record.
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 21

dwarf mistletoe, along some prescribed burn control lines, and in remote and/or steep stands. 

Logs generated during treatment would be removed and sold to a purchaser. After improvement 

thinning, we would use prescribed fire to reduce fuel loading and help restore the ecological 

benefits of fire. Prescribed fire may be repeated every 5 to 10 years to maintain desired fuel loads. 

Uneven-aged Mechanical Selection Cutting

with Openings and Prescribed Fire in Dry Mixed Conifer 

These treatments would occur on areas having less than 40 percent slope on approximately 5,300 

acres in dry mixed conifer stands. Mechanical treatments would help achieve uneven-aged 

desired conditions similar to those described in the forest plan, but we would leave a higher stand 

density and smaller openings. Logs generated during treatment would be removed and sold to a 

purchaser. After treatments, we would use prescribed fire to reduce fuel loading and help restore 

the ecological benefits of fire. Prescribed fire may occur every 7 to 12 years.

Stand Improvement Thinning and Prescribed Fire in Dry Mixed Conifer

These treatments would occur on areas having less than 40 percent slope on approximately 80 

acres of dry mixed conifer stands. As in ponderosa pine, the thinning is designed to improve tree 

growth, tree vigor and create stand structure that will allow future uneven-aged desired 

conditions. We propose to use this type of thinning in young, even-aged stands, stands with 

moderate to heavy dwarf mistletoe, and along some prescribed fire control lines. This treatment is 

similar to the stand improvement thinning for ponderosa pine, but fewer trees would be thinned 

because mixed conifer stands have a higher stand density. Logs generated during treatment would 

be removed and sold to a purchaser. After treatments, we would use prescribed fire to reduce fuel 

loading and help restore the ecological benefits of fire. Prescribed fire may occur every 7 to 12 

years. 

Landscape Prescribed Fire

Prescribed fire would be used on approximately 77,000 acres to reduce forest fuels and begin 

landscape restoration. This includes all mechanically treated areas described above plus the areas 

having greater than 40 percent slope (32,400 acres). Some thinning and limbing of trees would 

occur next to prescribed fire control lines, heritage sites, and other areas to reduce fire intensity. 

Treatments in Wet Mixed Conifer

Mechanical treatments might occur on approximately 1,150 acres having less than 40 percent 

slope in wet mixed conifer stands. Material generated during treatment may be removed. 

Prescribed fire may occur only on a limited basis to meet other objectives such as fuels reduction. 

Areas prioritized for treatment include areas close to endangered species habitat; wildland-urban 

interface areas; springs; areas with insects, disease, or other special needs; and small inclusions of 

wet mixed conifer within other cover types. 

Treatments to Maintain or Increase Aspen

Mechanical treatments (tree cutting and log removal) would occur on approximately 1,800 acres 

having less than 40 percent slope where aspen occurs. Prescribed fire may be used on a limited 

basis to meet other objectives. The treatments are intended to maintain existing aspen stands and 

would be done in stands where aspen is dominant. Patch cuts would be used to reestablish aspen 

patches (5 to 40 acres) in stands where aspen is no longer dominant. This treatment would focus 
Chapter 2. Alternatives Including the Proposed Action

22 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

on stimulating new aspen stands on the north and west portions of the project area because the 

eastern portion is near the Las Conchas Fire and has a lot of new aspen.

Treatments in Piñon-juniper

Trees would be thinned on approximately 1,000 acres of piñon-juniper stands to reduce erosion, 

protect heritage sites, or to increase habitat for songbirds. The trees cut would be made available 

to the public for firewood. Prescribed fire would not be used; instead, cut material (slash) would 

be scattered to provide ground cover. 

Treatments in Mexican Spotted Owl Protected Activity Centers

Mechanical thinning treatments would occur on approximately 500 acres on slopes of less than 40 

percent in Mexican spotted owl protected activity centers. The purpose of these treatments is to 

improve owl habitat and move stands toward having larger trees and a multi-storied canopy and 

to abate fire hazard. Trees larger than 18-inches diameter would not be cut. Cut material 

generated during treatment may be removed. Prescribed fire may occur on a limited basis to meet 

other objectives such as fuels reduction. Nest areas would not receive mechanical treatments. 

Prescribed fire would be allowed to burn through nest areas. 

Treatments for Old Growth

The forest plan calls for allocating 20 percent of each cover type within an ecosystem 

management unit as old growth, preferably in patches greater than 40 acres. For our analysis the 

entire project area will be considered an ecosystem management unit. Because our landscape 

treatments are generally limited to ponderosa pine and mixed conifer, we will only address old 

growth in these two forest types. Twenty percent each of the ponderosa pine and mixed conifer 

forest types would be managed as old growth. Stands would be mechanically treated if it would 

hasten their trajectory toward old-growth characteristics as defined in the forest plan. The 

mechanical treatments would aim to increase tree growth and size, create down wood and 

uneven-aged stands, and reduce wildfire hazard. Cut material generated during treatment may be 

removed. Stands within or next to Mexican spotted owl protected activity centers, northern 

goshawk post-fledging family areas, Jemez Mountains salamander locations, and visuallysensitive areas for old growth management would be prioritized for treatment. Trees larger than 

24-inches diameter would not be cut. 

Treatments for Maintaining or Increasing Meadow Habitat

These treatments would cut conifers from around meadow margins and within meadows. This 

would occur on approximately 5,500 acres: 2,500 acres in the uplands and 3,000 acres in riparian 

areas. This includes all meadow types: upland, lowland, and wet meadows. In some areas, this 

may include removing logs. 

Treatments to Enhance Seeps and Springs

Within 100 feet of identified seeps or springs conifer trees would be cut to improve water flow. 

This would occur on approximately 200 acres. In some areas, this may include removing logs. 

Treatments to Reduce Erosion Effects from Headcuts

These treatments would fill headcuts with soil, rock, or boulders, or areas would be recontoured. 

Afterwards, we would seed these areas with native grasses.
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 23

Treatments to Enhance Native Riparian Vegetation

and Restore Areas Damaged by Dispersed Recreation

Approximately 150 inventoried dispersed campsites need restoration. Most of the work would be 

done along the Rio Cebolla, Rio Guadalupe, and East Fork Jemez River, although some sites may 

be treated along San Antonio Creek and the Jemez River. Sites would be closed by placing soil, 

rocks, and boulders on and around the site and by planting native vegetation. Exclosures may be 

used to protect newly planted vegetation. 

Treatments to Restore Instream Habitat

To help restore instream habitat, we would use heavy machinery to create pools and channels, 

replace culverts, and place or remove log and rock stream structures on selected locations along 

24 miles of perennial streams in the project area. Treatment locations include the Rio Cebolla, 

Rio Guadalupe, San Antonio Creek, East Fork Jemez River, and Jemez River.

Control of Nonnative and Invasive Plants 

To control populations of nonnative and invasive plants, we would pull weeds, use prescribed 

grazing, prescribed fire, and methods other than herbicides. Use of herbicides may be authorized 

upon completion of the final environmental impact statement for the Invasive Plant Control 

Project for the Santa Fe and Carson National Forests. 

Screen Water Sources from Human Disturbance

To screen tanks and drinkers from road viewpoints, we would plant trees and shrubs around them. 

Newly planted vegetation would be protected with fencing. 

Increase Water Availability for Wildlife

To increase water availability for wildlife we would construct earthen dams or trick tanks. This 

would occur in the upper portions of watersheds and drainage headwaters throughout the project 

area. 

Create Snags

To create snags for wildlife habitat, we would kill trees by burning or other means. Work would 

be done throughout project area in stands lacking large-diameter snags (greater than 16 inches) or 

in stands that do not meet forest plan standards for snag density. 

Cultural Site Protection

There are approximately 3,000 known cultural sites in the project area. To reduce the risk of loss 

or damage by wildfire, we would remove trees and brush from sites. Sites on the National 

Historic Register and those eligible for the register would have priority for treatment. 

Road Maintenance

Road maintenance activities in the project area would include constructing and/or improving 

drainage features such as grade dips, lead out ditches, roadside ditches, drainage crossings, and 

culverts, and installing erosion control treatments such as riprap or geotextile materials, creating 

sediment basins, or other erosion control features. Road surfaces would be maintained and gravel 

would be replaced. This would be done on selected roads used to access treatment areas and 
Chapter 2. Alternatives Including the Proposed Action

24 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

remove material. Roads would receive maintenance as needed throughout the life of the project 

and beyond. 

Open Existing Closed Roads and Construct New Temporary Roads

Approximately 20 miles of existing closed roads would need to be reopened and/or reconstructed 

to provide access and product removal. These roads would receive maintenance as needed 

throughout the life of the project or duration of the contract and would be closed after use. In 

addition to these roads, approximately 12 miles of temporary roads would be constructed. These 

roads are generally short spurs built to avoid long skidding distances and skidding on steeper 

slopes, and to go around wet areas or meadows. These temporary roads would also receive 

maintenance as needed throughout the life of the project or duration of the contract. All temporary 

roads would be decommissioned after use. The design criteria and decommissioning methods for 

temporary roads are found in appendix A. 

Road Decommissioning Treatments

These treatments would restore unneeded roads to a more natural state. Methods include 

installing signs, blocking entrances, restoring vegetation, eliminating the roadbed, and other 

methods described in Forest Service Manual (FSM) 7734.1. Approximately 100 miles of road in 

the project area have been identified as candidates for decommissioning. Roads causing damage 

to hydrological resources, cultural resources, or threatened, endangered, and sensitive species 

habitat are a priority for decommissioning. 

Gravel Pits

Up to five gravel pits and access roads would be developed to provide gravel for road 

maintenance and improvement work. The maximum size of a single pit would not exceed 5 acres. 

Gravel pits would be located near existing system roads to minimize the need for road 

construction and no access road would exceed one-half of a mile in length. Newly constructed

pits would not be located in the inventoried roadless areas, the Jemez Wild and Scenic River 

Corridor, the Jemez National Recreation Area, the Monument Canyon Research Natural Area, 

Management Area I, Mexican spotted owl protected activity centers, Jemez Mountains 

salamander critical habitat, areas with a Visual Quality Objective level of Retention or Partial 

Retention. Design criteria for rehabilitation of gravel pits are found in appendix A. 

Forest Plan Amendments 

Forest plan amendments are needed to implement the treatments. These amendments and the 

reasons needed for the change are found in tables 1 and 2. Other required permits, licenses, and 

consultation are described later in this chapter. 

Maps Showing Potential Treatment Locations 

Figure 9 through figure 13 show the potential locations of the treatments described above. 

Treatment locations will be guided by what we find on the ground, and some areas may need a 

different type of treatment or none at all. The last two maps, figure 12 and figure 13, show the 

location of treatments common to all action alternatives (1, 3, 4, and 5). These include treatments 

for headcuts, nonnative and invasive plants, meadows, riparian areas, aspen, and piñon-juniper 

forest.
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 25

Figure 9. Potential locations of vegetation and prescribed fire treatments under alternative 1 

(proposed action). Under the proposed action, about 77,000 acres would be treated with prescribed 

fire and about 31,500 acres would receive mechanical or other treatments.
Chapter 2. Alternatives Including the Proposed Action

26 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 10. Potential locations of roads proposed for decommissioning and roads to be used for 

vegetation treatments under alternative 1. About 350 miles of forest roads would be used to access 

treatment areas and about 100 miles of road are proposed for decommissioning. Also shown are the 

approximately 150 dispersed campsites that would be rehabilitated.
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 27

Figure 11 Location of proposed temporary roads under alternatives 1, 4, and 5. There are 12 miles of 

temporary roads. Most of the proposed temporary roads are located on the west side of the project 

area and east of Forest Road 10.
Chapter 2. Alternatives Including the Proposed Action

28 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 12. Potential locations of headcut and invasive plant control treatments and treatments in 

Jemez Mountains salamander habitat under all action alternatives (1, 3, 4, and 5). These treatments 

would not occur under alternative 2 (no action).
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 29

Figure 13. Potential locations of proposed meadow, riparian, aspen, and piñon-juniper treatments 

under all action alternatives (1, 3, 4, and 5). About 1,800 acres of aspen and 1,000 acres of piñonjuniper would be treated. None of these treatments would occur under alternative 2 (no action).
Chapter 2. Alternatives Including the Proposed Action

30 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 13a. Potential locations of gravel pits under all action alternatives (1, 3, 4, and 5). Potential 

gravel pits sites are located in areas with suitable rock. 
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 31

Alternative 2 – No Action

Alternative 2 is the no action alternative as required by 40 CFR 1502.14(c). The no action 

alternative provides a baseline condition for estimating the effects of the other alternatives. In this 

alternative there would be no changes in current management under the forest plan. Under current 

management there are a number of restoration projects approved through other environmental 

analyses and decisions that would occur within the proposed project area. They include 

approximately 1,000 acres of planned vegetation treatments, 18,400 acres of planned prescribed 

fire projects, 180 acres of wildlife habitat treatments, and several recreation and other projects. 

Ongoing activities such as fire suppression, road maintenance, recreational activities, firewood 

gathering, grazing, and range improvement projects would continue. Preapproved activities such 

as nonnative and invasive plant control and travel management would also be accomplished. No 

site-specific forest plan amendments are needed to implement these activities.

There are a number of other activities that will occur in the project area but are not included in the 

no action alternative because they are not restoration activities. 

Figure 9 and Figure 10 show the proposed locations of the treatments described above.

Alternative 3 – No Construction of Temporary Roads 

This alternative is intended to show effects of not constructing new temporary roads. Only those 

areas accessed by existing roads would be mechanically treated. Those acres not mechanically 

treated would be treated with prescribed fire only. 

This alternative would reduce the area mechanically treated by approximately 1,900 acres as 

compared to alternative 1. All other treatments remain the same including prescribed fire in 

ponderosa pine and dry mixed conifer, invasive plant control, aquatic, riparian, and wildlife 

habitat improvement, cultural resource protection, road closure and decommissioning, 

construction of gravel pits, and road maintenance Site-specific forest plan amendments are 

needed to implement this alternative (see tables 1 and 2).

Figure 14 and figure 15 show the proposed locations of the treatments described above. Figure 12

and figure 13 show the location of treatments common to all action alternatives (1, 3, 4, and 5) 

and are found at the end of the map section for alternative 1 (proposed action). These treatments 

include those for headcuts, invasive plants, meadows, riparian areas, aspen, and piñon-juniper 

forests.

Alternative 4 – No Prescribed Fire in Mechanical Treatment Areas 

This alternative responds to the issues of smoke and scale of prescribed fire treatments by not 

burning areas that are mechanically treated. The total area treated is the same as the alternative 1. 

Slash from the mechanical treatments would not be burned, but would be chipped or ground up 

(masticated), or in some areas left on site (lopped and scattered). Prescribed fire would be used in 

those areas described under the proposed action as prescribed fire only. This alternative would 

reduce the acres burned from 77,000 to 45,400. This is a reduction of 31,600 acres or 41 percent. 

All other treatments remain the same including mechanical treatments and prescribed fire in 

ponderosa pine and dry mixed conifer, invasive plant control, aquatic, riparian, and wildlife 

habitat improvement, cultural resource protection, road closure and decommissioning, 

construction of temporary roads, construction of gravel pits, and road maintenance. Site-specific 

forest plan amendments are needed to implement this alternative (see tables 1 and 2).
Chapter 2. Alternatives Including the Proposed Action

32 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 14. Potential treatment locations for mechanical treatments and prescribed fire under 

alternative 2 (no action). Approximately 1,000 acres would be mechanically treated and about 18,400 

acres would be treated with prescribed fire
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 33

Figure 15. Locations of road decommissioning and dispersed campsite rehabilitation treatments 

under alternative 2 (no action). Under this alternative, 2 miles of road would be decommissioned in 

San Antonio Creek (top center) and 70 dispersed campsites would be restored.
Chapter 2. Alternatives Including the Proposed Action

34 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 16. Potential locations of vegetation and prescribed fire treatments under alternative 3. Under 

this alternative, approximately 77,000 acres would be treated with prescribed fire; this is the same as 

the proposed action. About 30,000 acres would receive mechanical treatments; this is 1,900 acres 

less than the proposed action.
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 35

Figure 17. Potential locations of roads proposed for decommissioning and roads to be used for 

treatments under alternative 3. About 340 miles of forest roads would be used to access treatment 

areas, slightly less than the proposed action. About 100 miles of road are proposed for 

decommissioning, and about 150 dispersed campsites would be restored; this is the same as the

proposed action.
Chapter 2. Alternatives Including the Proposed Action

36 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 18 and figure 19 show the proposed locations of the treatments described above. Figure 12

and figure 13 show the location of treatments common to all action alternatives (1, 3, 4, and 5). 

These treatments include those for headcuts, nonnative and invasive plants, meadows, riparian 

areas, aspen, and piñon-juniper forests.

Alternative 5 – Implement the Existing Forest Plan Standards 

and Guidelines for Managing Mexican Spotted Owl Habitat 

(Amendment 6, 1996) 

This alternative was designed in response to issues raised regarding treatments in Mexican 

spotted owl protected activity centers and restricted habitat. This alternative reduces with 

prescribed burning area treated by approximately 700 acres. This alternative would comply with 

the current forest plan. The proposed forest plan amendments related to treatments in Mexican 

spotted owl habitat would not be needed to implement this alternative. The remaining proposed 

site-specific forest plan amendments would be needed to implement this alternative. 

All other treatments remain the same including mechanical treatments and prescribed fire in 

ponderosa pine and dry mixed conifer, invasive plant control, aquatic, riparian, and wildlife 

habitat improvement, cultural resource protection, road closure and decommissioning, 

construction of temporary roads, construction of gravel pits, and road maintenance. Site-specific 

forest plan amendments are needed to implement this alternative (see table 2).

Figure 20 and figure 21 show the proposed locations of the treatments described above. Figure 12

and figure 13 show the location of treatments common to all action alternatives (1, 3, 4, and 5). 

These treatments include those for headcuts, nonnative and invasive plants, meadows, riparian 

areas, aspen, and piñon-juniper forests.
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 37

Figure 18. Potential locations of vegetation and prescribed fire treatments under alternative 4 in 

ponderosa pine, dry mixed conifer, and wet mixed conifer forest types. Under this alternative, 

mechanical treatments would occur on 31,500 acres, the same as the proposed action. 

Approximately 45,400 acres would be treated with prescribed fire, about 31,600 acres less than the 

proposed action.
Chapter 2. Alternatives Including the Proposed Action

38 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 19. Locations of roads proposed for decommissioning and roads to be used for vegetation 

treatments under alternative 4. About 350 miles of existing forest roads would be used to access 

treatment areas. About 100 miles of road are proposed for decommissioning, and about 150 

dispersed campsites would be rehabilitated.
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 39

Figure 20. Potential locations of vegetation and prescribed fire treatments under alternative 5. 

Mechanical treatments would occur on 31,500 acres, the same as the proposed action. 

Approximately 76,300 acres would be treated with prescribed fire, about 700 acres less than the 

proposed action.
Chapter 2. Alternatives Including the Proposed Action

40 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 21. Location of roads proposed for decommissioning and roads to be used for vegetation 

treatments under alternative 5. About 350 miles of existing forest roads would be used to access 

treatment areas. About 100 miles of road are proposed for decommissioning, and about 150 

dispersed campsites would be rehabilitated.
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 41

Mitigation Measures for All Action Alternatives

To reduce impacts we would use all relevant resource protection measures. These measures are 

generated from environmental regulations, Forest Service directives, applicable forest plan 

standards and guidelines, and best management practices. In addition, project-specific design 

features and mitigation measures were developed to minimize adverse effects that were identified 

during the analysis. Project-specific protective measures are listed in appendix A and would be 

used with all action alternatives. 

Monitoring 

Chapter 5 of the forest plan includes the monitoring and evaluation activities to be conducted as 

part of forest plan implementation. For all action alternatives, we would conduct the 

implementation monitoring as required in chapter 5 of the forest plan.

Forest Plan Amendments

Forest plan amendments (tables 1 and 2) are needed to achieve the purpose and need and to 

assure consistency with the forest plan. These are site-specific amendments and would apply to 

this project only. The forest plan would be amended using the 1982 rule procedures as allowed by 

the transition language of the 2012 planning rule ((36 CFR 219.17(b)(3)). 

Required Permits, Approvals, and Consultation 

• The discharge of dredged and fill material resulting from the instream habitat 

improvement treatments requires a section 404 permit from the U.S. Army Corps of 

Engineers. 

• The discharge of pollutants (sediment) to waters of the U.S. requires a Clean Water Act 

401 Water Quality Certification and a Clean Water Act 402 National Pollutant Discharge 

Elimination System (NPDES) permit from the New Mexico Environment Department. 

• Gravel pit operations, including quarrying, crushing, and screening, require an air quality 

permit from the New Mexico Environment Department. 

• Continue consultation with the U.S. Fish and Wildlife Service in accordance with Section 

7 of the Endangered Species Act.

• Consult with the New Mexico State Historic Preservation Officer, tribes, and consulting 

parties regarding identification, evaluation, and determination of the effects of the project 

on cultural resources in accordance with Section 106 of the National Historic 

Preservation Act. 

• Coordinate prescribed fire applications with appropriate air quality specialists and 

Federal and State regulatory authorities to ensure compliance with the Clean Air Act (as 

amended), the Regional Haze Rule (40 CFR 51.309) and the New Mexico Smoke 

Management Program. 

• Tree cutting in inventoried roadless areas, with Regional Forester approval, is allowed for 

stewardship purposes under the 2001 Roadless Area Final Rule.
Chapter 2. Alternatives Including the Proposed Action

42 FEIS of the Southwestern Jemez Mountains Landscape Restoration Project

Table 1. Amendments for alternatives 1, 3, and 4

Existing Forest Plan Language

Purpose of the Amendment 

(Reason for Change) Proposed Forest Plan Language

In Mexican Spotted Owl Protected Activity Centers: Designate 

a 100-acre “no treatment” area around the known nest site of 

each selected protected activity center. (Appendix D – 

Standards and Guidelines for Management of Mexican Spotted 

Owl, Northern Goshawk, and Livestock Grazing).

The 2012 Mexican Spotted Owl 

Recovery Plan allows 

prescribed fire in the 100-acre 

no treatment area.

Designate a 100-acre limited treatment area around the 

identified core area of a protected activity center (PAC). 

Limited treatment means that only prescribed fire is 

allowed. 

In Mexican Spotted Owl Protected Activity Centers: Select for 

treatment 10% of the protected activity centers where nest 

sites are known in each recovery unit having high fire risk 

conditions. (Appendix D – Standards and Guidelines for 

Management of Mexican Spotted Owl, Northern Goshawk, and 

Livestock Grazing).

This guidance is in line with the 

2012 Mexican Spotted Owl 

Recovery Plan and allows us to

treat all six PACs within the 

project area and better achieve 

desired conditions.

Conduct restoration treatments in up to 20% of PACs 

within each ecosystem management unit (EMU) that 

exhibits high fire risk conditions.

In Mexican Spotted Owl Protected Activity Centers: Also select 

another 10% of the protected activity centers where nest sites 

are known as a paired sample to serve as control areas. 

(Appendix D – Standards and Guidelines for Management of 

Mexican Spotted Owl, Northern Goshawk, and Livestock

Grazing).

The proposed monitoring was 

developed in conjunction with 

USFWS and allows for us to 

monitor changes but still treat 

the PACs. 

Paired monitoring of PACs will take place within the 

project area using the existing PACs and separating 

treatments within PACs by at least two years. This will aid 

in distinguishing between effects from treatment versus 

environmental or other influences on Mexican spotted owl. 

In Mexican Spotted Owl Protected Activity Centers: Use 

combinations of thinning trees less than 9 inches in diameter, 

mechanical fuel treatment and prescribed fire to abate fire risk 

in the remainder of the selected protected activity center 

outside the 100-acre “no treatment” area. (Appendix D – 

Standards and Guidelines for Management of Mexican Spotted 

Owl, Northern Goshawk, and Livestock Grazing)

To meet the desired conditions, 

we want to be able to cut trees 

up to 18-inches diameter in 

PACs, outside of the core area. 

Within Mexican spotted owl PACs, use combination of 

cutting trees less than 18-inches diameter, mechanical 

fuel removal, and prescribed fire to treat fuel 

accumulations to abate fire risk. 
Chapter 2. Alternatives Including the Proposed Action

FEIS of the Southwestern Jemez Mountains Landscape Restoration Project 43

Existing Forest Plan Language

Purpose of the Amendment 

(Reason for Change) Proposed Forest Plan Language

In Mexican Spotted Owl Restricted Areas: The following table 

displays the minimum percentage of restricted area which 

should be managed to have nest/roost characteristics. The 

minimum mixed conifer restricted area includes 10% at 170 

basal area and an additional amount of area at 150 basal area. 

The additional area of 150 basal area is +10% in BR-E and 

+15% in all other recovery units. The variables are for stand 

averages and are minimum threshold values and must be met 

simultaneously. In project design, no stands simultaneously 

meeting or exceeding the minimum threshold values should be 

reduced below the threshold values unless a district-wide or 

larger landscape analysis of restricted areas shows that there 

is a surplus of restricted area acres simultaneously meeting the 

threshold values. Management should be designed to create 

minimum threshold conditions on project areas where there is a 

deficit of stands simultaneously meeting minimum threshold 

conditions unless the districtwide or larger landscape analysis 

shows there is a surplus. (see table 1a below)

Adjusts requirements for 

nest/roost characteristics in 

recovery habitat to guidance 

from the 2012 Mexican Spotted 

Owl Recovery Plan.

Table C.3 from the revised recovery plan (p. 278) displays 

the minimum desired conditions for mixed-conifer forest 

areas managed for recovery nesting/roosting habitat. 

Manage stands so that a specified portion (25%) of the 

landscape does not fall below the lower stand condition 

thresholds in table C.3. Identify and protect stands that 

meet or exceed nest/roost conditions and then assess 

whether or not these stands satisfy this area requirement. 

Stands that do not meet nest/roost conditions and are not 

designated for development of such can be managed to 

meet other resource objectives. The environmental 

analysis for this project is striving for these desired 

conditions in the recommended amounts at this large 

spatial scale. see table 1b below)

In Mexican Spotted Owl Restricted Areas: Encourage 

prescribed and prescribed natural fire to reduce hazardous fuel 

accumulation. Thinning from below may be desirable or 

necessary before using prescribed fire to reduce ladder fuels 

and the risk of crown fire. (Appendix D – Standards and 

Guidelines for Management of Mexican Spotted Owl, Northern 

Goshawk, and Livestock Grazing)

Remove language specifying 

the use of thinning from below. 

This can indicate that only the 

lowest size classes of trees are 

removed. Uneven-aged 

management requires the 

removal of intermediate size 

classes as well.

Encourage prescribed and prescribed natural fire to 

reduce hazardous fuel accumulation. Thinning may be 

desirable or necessary before using prescribed fire to 

reduce ladder fuels and the risk of crown fire.

Table 1a. Existing Forest Plan, Appendix D – Standards 

and Guidelines for Management of Mexican Spotted Owl, 

Northern Goshawk, and Livestock Grazing

Variable MC 

ALL RU

MC 

BR-E 

RU

MC 

OTHER 

RU

Pineoak

Restricted 

area % 10% +10% +15% 10%

Stand 

Averages 170 150 150 150

for: Basal 
Chapter 2. Alternatives Including the Proposed Action

44 FEIS of the Southwestern Jemez Mountains Landscape Restoration Project

Variable MC 

ALL RU

MC 

BR-E 

RU

MC 

OTHER 

RU

Pineoak

Area

18 inch + 

trees/ac 20 20 20 20

Oak basal 

area

NA NA NA 20

Percent total existing stand 

class:

density index by size 

12-18" 10 10 10 15

18-24" 10 10 10 15

24+" 10 10 10 15

Table 1b. Minimum desired conditions for Mexican Spotted Owl Recovery 

nesting/roosting habitat in the mixed-conifer forest type of the Southern Rocky 

Mountain Ecological Management Unit1. 

2 Percent of Area 25%

Percent Basal Area in 12-18 inch >30

d.b.h. class

Percent Basal Area in > 18-inch >30

d.b.h. class

3 Minimum Tree Basal Area 27.5 (120)

Minimum Density 4 of Large Trees 30 (12) 1 This table is derived from table C.3 in the revised recovery plan for the Mexican spotted owl (USFWS 2012). Notes 2, 3, and 4 are the original table notes 

from table C.3.

2 Percent of area pertains to the percent of the planning area, subregion, and/or region in the specified forest type that should be managed for threshold 

conditions. 3 BAs in m2

/ha (ft2/acre), and include all trees >1 inch d.b.h. (i.e., any species). We emphasize that values shown are minimums, not targets. 4

 Trees > 46 cm (18 inches) d.b.h. Density is tree/ha (trees/acre). Again, values shown are minimums rather than targets. We encourage retention of large 

trees.
Chapter 2. Alternatives Including the Proposed Action

FEIS of the Southwestern Jemez Mountains Landscape Restoration Project

Existing Forest Plan Language 

Purpose of the Amendment 

(Reason for Change) Proposed Forest Plan Language

Northern goshawk: Limit human activities in nesting areas 

during the breeding season. (March 1- September 30). 

Limit human activity in or near nest sites and post-fledgling 

family areas during the breeding season so that goshawk 

reproductive success is not affected by human activities.

(Appendix D – Standards and Guidelines for Management of 

Mexican Spotted Owl, Northern Goshawk, and Livestock 

Grazing)

Allows treatment during breeding 

season, which facilitates meeting 

desired conditions. 

Northern goshawk: Human activities will be limited to no 

more than two consecutive years during the breeding 

season (March 1 to September 30).

No corresponding forest plan direction regarding interspaces. 

(Appendix D – Standards and Guidelines for Management of 

Mexican Spotted Owl, Northern Goshawk, and Livestock

Grazing and Glossary (for the definition) pp. 195-224). 

The definition will be added to the Glossary – pp. 195-224. 

Adds language to allow for 

interspaces in addition to VSS 

groups 1-6. 

Canopy cover is evaluated at the group level within midaged to old forest structural stages groups (VSS 4, 

VSS 5, and VSS 6) and not within grass/forb/shrub to 

young forest structural stage groups (VSS 1, VSS 2, 

and VSS 3) or in interspaces, natural meadows, and 

grasslands, or other areas not managed for forest 

conditions.

(Definition) Interspaces are areas not currently under 

the vertical projection of the outermost perimeter of tree 

canopies. They are generally composed of grass-forbshrub communities but could also be areas with 

scattered rock or exposed mineral soil. Interspaces do 

not include meadows, grasslands, rock outcroppings, 

and wetlands (i.e., exclusions adjacent to and 

sometimes within forested landscapes.)

Timber activities in turkey nesting areas will be coordinated to 

minimize impacts between April 20 and June 10 (replacement 

page 72). 

Allows treatment during breeding 

season, which facilitates meeting 

desired conditions. 

The nesting areas are not defined. 

It is impractical to identify turkey 

nesting areas. The benefits of the 

project outweigh the potential 

detriments to turkeys.

Delete. 

45

Table 2. Amendments for alternatives 1, 3, 4, and 5
Chapter 2. Alternatives Including the Proposed Action

46 FEIS of the Southwestern Jemez Mountains Landscape Restoration Project

Purpose of the Amendment 

Existing Forest Plan Language (Reason for Change) Proposed Forest Plan Language

When a peregrine falcon site plan doesn’t already exist and a Site plans established zones with The Forest will do project level surveys within 1/2 mile of 

Biological Evaluation finds that a proposed action may time restrictions for up to 4 miles peregrine falcon nesting habitat (“A” zone) before and 

negatively impact an occupied eyrie, develop a site plan for outward of the eyrie to avoid after project activities to assess how these activities 

the eyrie before approving the project. Adhere to site plan disturbance to peregrine falcon. affect occupancy and nest use.

mitigations for the eyrie. (Replacement page 62) Adhering to such restrictions would 

significantly delay restoration work 

Develop a site plan for each peregrine falcon eyrie and inhibit the Forest’s ability to 

(designated suitable nest site). Follow the specific meet the intent of the CFLRP.

requirements described in the site plans for each eyrie and the 

surrounding habitat zones, including requirements for 

evaluating potential impacts, monitoring, restricting the timing 

of activities, and controlling activities that may cause 

disturbance or pose a threat to the eyrie (replacement page 

63). 

Develop viewshed corridor plans for those sensitive level 1 The forest does not currently have Delete.

roads specified in each management area. These plans will any of these plans in place. The 

define project level landscape characteristics and identify the intent of these viewshed corridor 

key visual elements for management. Plans will outline the plans will be met through design 

activities to sustain the desired scenic landscape character criteria and mitigations included in 

overtime. (Replacement page 56) the project. 

Manage for a visual quality objective of preservation (p. 151) The visual quality objective of Manage for a Visual Quality Objective of High. 

preservation conflicts with the 

amendment in the Jemez National 

Recreation Area that allows for 

vegetation treatments in this 

management area (‘M’).
Chapter 2. Alternatives Including the Proposed Action

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 47

Alternatives Considered but Eliminated from Detailed Study 

The National Environmental Policy Act requires Federal agencies to consider a range of 

reasonable alternatives. For alternatives that were not considered in detail, agencies must briefly 

discuss the reasons for eliminating them (40 CFR 1502.14). The range of alternatives considered 

by the responsible official includes alternatives to the proposed action that are analyzed in the 

document, as well as other alternatives considered but eliminated from detailed study. The 

following alternatives were developed in response to issues raised in scoping, but were eliminated 

for reasons explained below. 

Use a 16-inch Diameter Cap on All Treatments 

This alternative responds to the issue of retaining large trees. The 16-inch diameter limit was 

selected because it was often cited as an upper limit for tree cutting in the scoping comments. 

This alternative would apply to all of the vegetation treatments and design criteria outlined in the 

proposed action. All other treatments involving tree cutting would include the cap. 

We eliminated this alternative from detailed analysis because it fails to meet the purpose and need 

of the project. We developed the proposed action to achieve several ecosystem restoration 

objectives, not only to reduce wildfire hazard. Cutting larger trees would reduce hazardous fuels, 

but more importantly, removing larger trees in certain situations would improve ecological 

conditions. 

The proposed forest restoration treatments focus on removing small trees first. We have enough 

site-specific knowledge of the project area to determine that an arbitrary diameter cap would not 

meet our restoration objectives in some circumstances: (1) for grassland, meadow, and riparian 

area restoration; (2) where stands are dominated by young, large trees; (3) in stands where large, 

late transitional (seral), fire-sensitive species (such as white fir) are undesirable; (4) in aspen or 

group regeneration areas; (5) in interspaces, (6) where severe, forest disease, insects or damage is 

present; and (7) where necessary to manage forest age distribution towards uneven-aged 

conditions. 

Cutting larger trees for restoration purposes is supported by science (Fiedler and Keegan 2003; 

Abella et al. 2006; Lee and Irwin 2005; Prather et al. 2008). A study by Triepke et al. (2011) 

modeled and analyzed the effects of a 16-inch diameter cap on forest structure, forest 

composition, and fire behavior on dry forests on National Forest System lands in New Mexico 

and Arizona. Their analysis showed that within 30 years, nearly all stands managed using a 

diameter cap would be converted to an even-aged condition. Such a landscape lacks biodiversity 

and indicates that the system is unstable and is susceptible to large-scale disturbances such as 

wildfire.

Fiedler and Keegan (2003) had similar results. Their study compared a range of treatments in dry 

forest in New Mexico: (1) thinning from below; (2) a 16-inch diameter cap; and (3) a restoration 

treatment that removed trees of all sizes. They concluded that “The restoration prescription 

evaluated in this analysis achieves greater hazard reduction and creates more sustainable 

conditions than alternative treatments. It is particularly superior when compared to prescriptions 

with a singular focus on removal of small trees,” (p. 46).
Chapter 2. Alternatives Including the Proposed Action

48 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Reduce the Area Treated with Prescribed Fire by 

Using Skyline Harvesting on Steep Slopes (greater than 40 percent) 

This alternative responds to the issues of smoke and scale of the prescribed fire treatments. In this 

alternative, skyline harvesting would occur on steep slopes instead of burning these areas. All 

other treatments would remain the same including the mechanical treatments on flatter ground, 

cutting trees for meadow restoration, seeps and springs, cultural site protection, and other 

restoration treatments. 

We eliminated this alternative from detailed analysis because while it is technically feasible, it is 

not likely to be economically feasible. It would require extensive analysis regarding harvesting 

systems and many miles of additional temporary roads to support this harvesting system. To 

reduce fuels on the slopes, whole tree yarding would be needed and would not result in a 

measurable difference in the total amount of smoke produced as the slash from the skyline units 

would be burned at the landings. 

Reduce Mechanical Treatments in Jemez Mountains Salamander 

Habitat 

This alternative was designed in response to an internal discussion about protecting the Jemez 

Mountains salamander and its habitat. Under this alternative, we would reduce treatments in the 

two areas mapped as Jemez Mountains salamander critical habitat. These areas total 

approximately 9,000 acres (27 percent of the total area that would be mechanically treated). 

Treatments outside these two large areas would be carried out as described in the proposed action. 

Treatments within the Jemez Mountains salamander areas would be modified to use the upper 

limits of the canopy closure described in the proposed action or the treatments would be dropped. 

Additional mitigation measures such as no use of wheeled or tracked equipment and use of winter 

harvesting, would be applied to reduce salamander mortality. 

We eliminated this alternative as originally developed because we added design criteria to all of 

the action alternatives to address the primary threat to the salamander (uncharacteristically severe 

wildfire) and to provide protection of known populations. 

Comparison of Effects of the Different Alternatives 

Table 3 summarizes and compares the key measures related to the purpose and need and 

environmental effects of each of the alternatives considered in detail. Chapter 3 has a detailed 

discussion of the measures and description of effects. 
Chapter 2. Alternatives Including the Proposed Action

FEIS of the Southwestern Jemez Mountains Landscape Restoration Project 49

Table 3. Comparison of the environmental effects of each of the alternatives

Objective or Issue Key Measure

Alternative 1

Proposed Action

Alternative 2

No Action

Alternative 3

No Temporary 

Roads

Alternative 4

No Prescribed Fire 

in Mechanical 

Treatment Areas

Alternative 5 No 

Mexican Spotted 

Owl Amendments

Selective cutting and 

prescribed fire in 

ponderosa pine

Acres 23,000 550 21,450 23,000 23,000

Stand improvement

thinning and prescribed 

fire in ponderosa pine

Acres 1,500 80 1,450 1,500 1,500

Selective cutting and 

prescribed fire in dry

mixed conifer

Acres 5,300 250 5,050 5,300 5,300

Stand improvement

thinning and prescrib

fire in dry mixed conif

ed 

er

Acres 80 0 80 80 80

Landscape prescribed 

efir Acres 77,000 18,400 77,000 45,400 76,300

Treatments in wet

mixed conifer Acres 1,150 0 1,150 1,150 1,150

Treatments to maintain 

or increase aspen 

ver typeco

Acres 1,800 0 1,800 1,800 1,800

Treatments in piñonniperju Acres 1,000 0 1,000 1,000 1,000

T for cultural reatments

site protection Sites 2,934 622 2,934 2,933 2,918

Treatments to restore 

areas damaged by 

dispersed recreation

and enhance native 

riparian vegetation

Sites 150 70 150 150 150

Restore instream 

abitath Miles 24 7 24 24 24
50

Chapter 2. Alternatives Including the Proposed Action

FEIS of the Southwestern Jemez Mountains Landscape Restoration Project

Objective or Issue Key Measure

Alternative 1

Proposed Action

Alternative 2

No Action

Alternative 3

No Temporary 

Roads

Alternative 4

No Prescribed Fire 

in Mechanical 

Treatment Areas

Alternative 5 No 

Mexican Spotted 

Owl Amendments

Treatments for 

maintaining or 

increasing meadow 

habitat

Acres 5,500 171 5,500 5,500 5,500

Treatments to enhance 

Mexican spotted owl 

habitat in protected 

activity centers

Acres 484 0 484 484 484

Acres allocated to old 

growth Acres 14,050 0 14,050 14,050 14,050

Treatments to enhance 

seeps and springs Acres 175 12 175 175 175

Treatments to reduce 

erosion effects from 

headcuts

Acres 860 (estimated) 0 860 (estimated) 860 (estimated) 860 (estimated)

Roads re-opened, 

maintained, and closed 

after use

Miles 87 0 85 87 87

Roads re-opened, 

reconstructed if 

necessary, and closed 

after use. 

Miles 20 0 11 20 20

Temporary roads Miles 12 0 0 12 12

Open roads maintained Miles 242 47 242 242 242

Road decommissioning Miles Up to 100 2 Up to 100 Up to 100 Up to 100

Air quality Estimated total 

CO

2 emissions

2,388,808 metric 

tons 469,004 metric tons 2,353,482 metric 

tons

1,063,991 metric 

tons

2,373,332 metric 

tons

Air quality

Estimated total 

PM2.5 emissions 

Meets air quality 

standards 

18,878 metric tons 

Unlikely to exceed 

air quality 

standards 

3,388 metric tons 

Meets air quality 

standards

19,209 metric tons 

Unlikely to exceed 

air quality 

standards

7,410 metric tons 

Unlikely to exceed 

air quality 

standards 

18,864 metric tons 

Unlikely to exceed 

air quality 

standards
Chapter 2. Alternatives Including the Proposed Action

FEIS of the Southwestern Jemez Mountains Landscape Restoration Project 51

Objective or Issue Key Measure

Alternative 1

Proposed Action

Alternative 2

No Action

Alternative 3

No Temporary 

Roads

Alternative 4

No Prescribed Fire 

in Mechanical 

Treatment Areas

Alternative 5 No 

Mexican Spotted 

Owl Amendments

Fuels and fire

Percent of area in 

surface fire, 

passive crown fire 

and active crown 

fire type.

Surface 79%

Passive 16% 

Active 5%

Surface 49.9%

Passive 33.1% 

Active 17%

Surface 77.8%

Passive 15.4% 

Active 6.8%

Surface 71.8%

Passive 23.2% 

Active 5%

Surface 79.1%

Passive 15.9% 

Active 5%

Roads and engineering 

Increase in traffic 

for project 

activities 

(round trips)

12 round trips 1 round trip 11 round trips 12 round trips 12 round trips

Roads and engineering 

Develops gravel 

pits for improved 

road maintenance

Yes No Yes Yes Yes

Visual quality and 

scenery management 

Effects to Visual 

Quality Objectives 

and Scenic 

Integrity 

Objectives

Some short-term 

effects None expected Some short

-term 

effects

Some short-term 

effects in areas 

treated with 

prescribed fire, 

much longer in 

mechanical 

treatment areas 

from slash.

Some short-term 

effects

Visual quality and 

scenery management

Improve scenic 

stability Yes No Yes Yes Yes

Social science and 

economics

Estimated jobs 

created 229

-249 168-191 226-246 218-237 229-252

Vegetation

Move the 

landscape 

towards desired 

conditions (VSS) 

Acres 

29,880 880 28,030 29,880 29,880

Vegetation

Wood volume 

made available for 

removal annuallytrees greater than 

5-inches diameter

(CCF)

29,600 1,900 27,500 29,600 32,300
52

Chapter 2. Alternatives Including the Proposed Action

FEIS of the Southwestern Jemez Mountains Landscape Restoration Project

Alternative 4

Alternative 3 No Prescribed Fire Alternative 5 No 

Alternative 1 Alternative 2 No Temporary in Mechanical Mexican Spotted 

Objective or Issue Key Measure Proposed Action No Action Roads Treatment Areas Owl Amendments

May affect, not May affect, not Wildlife, fish, and rare Mexican spotted May affect, likely to May affect, likely to May affect, likely to likely to adversely likely to adversely plants owl adversely affect adversely affect adversely affect affect affect

Addresses 

Wildlife, fish, and rare primary threat to Yes Some Yes Yes Some plants Mexican spotted 

owl

Wildlife, fish, and rare Jemez Mountains May affect, likely to May affect, likely to May affect, likely to May affect, likely to May affect, likely to 

plants salamander adversely affect adversely affect adversely affect adversely affect adversely affect

Addresses 

Wildlife, fish, and rare primary threat to Yes No Yes Yes Yes plants Jemez Mountains 

salamander
FEIS of the Southwest Jemez Mountains Landscape Restoration Project 53

Chapter 3. Affected Environment

and Environmental Consequences

About this Chapter 

This chapter summarizes the physical, biological, social, and economic environments of the 

project area and the effects of implementing each alternative on that environment. It also presents 

the scientific and analytical basis for the comparison of alternatives presented here. Only 

summaries are provided for each resource and all resource reports are incorporated by reference. 

Most specialist reports will be available for viewing on the Southwest Jemez Mountains 

Restoration Web page (http://go.usa.gov/BUVh). Those documents not on the Web site can be 

made available upon request.

How We Determined Effects of the Proposed Action and the 

Alternatives 

Chapter 2 introduced the “toolbox” approach which described how the project activities would be 

implemented on the ground based upon landscape features and design criterion. This was done 

because the traditional approach to NEPA simply lacks the flexibility to achieve desired 

conditions at the landscape level. At this level, rather than local-level treatments, such as a stand 

prescription, treatments will be guided by what we find on the ground (like selecting a tool from 

the toolbox). We use landscape features (what we encounter on the ground) and design criteria 

(the tools) as a more flexible way to achieve our desired conditions. 

The interdisciplinary team started with a group of landscape features; these are areas that we will 

potentially treat throughout the project area. Examples of landscape features are cover types, 

slope, scenic sensitivity levels, and threatened and endangered species habitat. Then the 

interdisciplinary team developed design criteria. Design criteria are limits on the treatments, or 

tools, that we will apply to any of those landscape features. For example, on cultural resource 

sites we will use directional felling to keep trees from falling on rubble mounds. An advantage of 

this approach is that we can monitor effects of the individual and cumulative actions and make 

changes to the design criteria or mitigations if the effects differ from what we predicted. The 

toolbox approach applies to all action alternatives. 

To determine how the proposed actions would affect a particular resource the interdisciplinary 

team selected potential treatment areas within the project bounds (polygons) based on specific 

landscape features (e.g. slope, cover type, habitat for threatened and endangered species). Design 

criteria were then applied to these potential treatment areas and the effects to the various 

resources were modeled. It is important to note that the polygons were used as a tool for the 

analysis rather than being prescriptive (that a particular treatment will occur on a particular acre).

The actual areas to be treated and the treatments themselves will be determined based on 

conditions encountered on the ground. The actual effects of the actions will be monitored. Based 

on the monitoring results we can determine if our analysis accurately projected the effects and 

what changes to the design criterion or mitigation measures may be needed to keep the effects 

within the limits of what was projected. This adaptive approach will give the implementation 

team a lot more flexibility to achieve the desired conditions described in chapter 1 rather than 

being constrained by the accuracy of the data used for the analysis. 
Chapter 3. Affected Environment and Environmental Consequences

54 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Air Quality

The air quality specialist report (Hall 2014) is incorporated by reference. See the report for 

detailed information on data sources, methodology, assumptions, and limitations. 

Affected Environment 

The Southwest Jemez Mountain Landscape Restoration Project proposes several actions that 

could affect air quality in the surrounding communities. The primary concern from an air quality 

perspective is the impacts on public health from smoke produced from proposed prescribed fires. 

The term wildland fire is used here. Wildland fire refers to any non-structure fire that occurs in 

the wildland and can be a prescribed fire or a wildfire. Wildland fire is used when the distinction 

between a prescribed fire and a wildland fire is not necessary. 

Description of the Airshed4

The project area is located within the Middle Rio Grande Airshed (NMED 2003). This airshed 

includes all or part of Bernalillo, Cibola, McKinley, Sandoval, Socorro, and Valencia Counties. 

There are two Class 1 areas within 50 miles of the project area, Bandelier National Monument, 15 

miles to the east, and San Pedro Parks Wilderness, approximately 25 miles northwest of the 

project area. Under the Clean Air Act, Class 1 areas require the highest level of protection for 

both National Ambient Air Quality Standards (NAAQS) and visibility.

 

Topography, Winds, and Smoke-Sensitive Areas

The topography, wind patterns, and air inversions of the Southwest Jemez Mountains area have a 

strong influence on smoke impacts. The prevailing winds in the Jemez Mountains area typically 

blow from southwest to northeast (southwesterly winds) during the day and then reverse direction 

overnight. Winds in the spring and summer are stronger during the day and weaker overnight. 

This pattern reverses in the fall. Stronger down drainage airflows typical of the fall season are 

coupled with strong inversions that tend to trap cool air close to the surface through the evening 

and into the morning. This generally does not happen during the spring and summer when any 

cool air is dispersed quickly once the sun heats up the valley floors. The topography of the area 

also affects where smoke goes. Smoke from all sources- woodstoves, prescribed fire, or wildfirestends to settle in the Jemez River Valley drainages at night.

Smoke-sensitive areas5 are places or resources that may be sensitive to smoke impacts. These 

areas include populations or specific places, views, hospitals, airports, schools, highways, or 

businesses that would likely be affected by smoke coming from the project area. For this project, 

specific smoke-sensitive areas were identified and considered in the analysis: the town of 

Ponderosa, Jemez Pueblo, San Yisidro, Jemez Springs, and Zia Pueblo. These communities would 

primarily be affected by smoke settling into the drainages at night. During the day, when 

southwesterly winds predominate, the communities most likely to be impacted are Los Alamos 

and White Rock. 

Generally, those communities closest to a given project, particularly those down drainage, would 

receive the greatest impacts from smoke. However, smoke could impact communities in 

 

4 An airshed is the air supply of a region, which may become uniformly polluted or stagnant.

5

 Smoke-sensitive areas are also called smoke-sensitive receptors.
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 55

Bernalillo County and the Middle and Upper Rio Grande Valley, including the cities of Rio 

Rancho, Albuquerque, Santa Fe, Los Alamos, and Española. 

Key Components of Smoke from Wildland Fires

Smoke is a mixture of fine particulates and gases. It also contains a wide range of pollutants, 

which can remain suspended in the atmosphere anywhere from a few seconds to several months. 

The pollutants that would be found in smoke from a wildfire include carbon dioxide (CO2), 

particulate matter (PM), nitrogen oxides (NOx), and hydrocarbons. Particulate matter has the 

potential to impair visibility and human health. Lead, sulfur dioxide, and other compounds can 

also be found in smoke but they occur in very small amounts and are less of a concern in regards 

to human health. Ozone may also be present. While many of these pollutants, as well as some 

toxic pollutants, are present in smoke from prescribed fires and wildfires, particulate matter 2.5 

(PM2.5) is the pollutant of greatest concern and is the most likely to result in public health 

impacts.

Particulate Matter 2.5 (PM2.5)

Particulate matter 2.5 is a criteria pollutant and is produced by all types of burning including 

power plants, combustion engines, woodstoves, and wildland fire. It is a major component of 

wood smoke and is produced in large quantities in wildland fires. Because of its small size, 

PM2.5 is dispersed great distances and can become embedded deep in the lungs. PM2.5 can cause 

serious health impairments, especially in individuals with pre-existing respiratory and circulatory 

system health issues. Exposure to PM 2.5 is associated with premature death, heart attacks, and 

stroke (Pope et al. 2002, 2004; Brook et al. 2004) and can trigger asthma attacks (Sheppard et al. 

1999; Delfino et al. 2009; Elliott et al. 2013). In contrast, PM10 causes eye, nose, and throat 

irritation, but remains in the upper respiratory tract because of its relatively larger size.

Figure 22. Relative size of PM2.5 particles as compared to fine beach sand, a human hair, and PM10

particles.
Chapter 3. Affected Environment and Environmental Consequences

56 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Ozone

Ozone has been associated with smoke from prescribed fire and wildfire. It is not directly 

produced by wildland fires, but the chemical compounds that form ozone- nitrogen oxides and 

volatile organic compounds- are found in wood smoke. Through a complex process, these 

compounds can react with each other and produce ozone. Wildfires have been shown to 

contribute to ozone concentrations downwind; however, predicting this is a challenge (Jaffe and 

Widger 2012). The biggest sources of the precursors to ozone in the general area are two power 

plants near Farmington, engine exhaust from oil and gas development, and mobile sources 

including cars, trucks and recreational vehicles. Ozone has also been shown to result in a number 

of health effects and symptoms across a wide range of the population. Ozone can induce 

respiratory symptoms such as coughing, pain, discomfort, and tightness in the chest, 

inflammation of the lung, loss of lung function, and asthma attacks (USEPA 2012b).

Carbon Monoxide

Carbon monoxide is another major product of wildfire smoke. Because it is a gas, it is quickly 

diluted in the atmosphere. Carbon monoxide can be of concern to firefighters in the immediate 

vicinity of any wildfire or prescribed fire because they are working quite close to the source of 

the smoke. But in general it has little impact away from the immediate project area.

Existing Conditions for Air Quality and Visibility

This section evaluates and compares the existing and reference conditions of the air resource 

within the project area, specifically regarding pollutants and visibility. Reference conditions refer 

to the national and state standards for managing air quality. The Clean Air Act (as amended) 

requires the Environmental Protection Agency (EPA) to set NAAQS for pollutants considered 

harmful to public health and the environment. The New Mexico Environment Department 

(NMED) is responsible for regulating NAAQS pollutants in New Mexico to protect human health 

and welfare. 

Air Quality

Air quality within and around the project area is generally excellent and meets all national air 

quality standards, including those for the six criteria pollutants: lead, sulfur dioxide, nitrogen 

dioxide, ozone, carbon monoxide, and particulate matter (PM10 and PM2.5). This area is not 

listed as a non-attainment6 area (USEPA 2012a). There is some concern, however, about elevated 

ozone levels in the Albuquerque metro area, and there have been smoke impacts from wildland 

fires near the project area in recent years. Regarding wildland fire, the criteria pollutants of 

concern are ozone and PM2.5, which are being monitored in the project area. 

There are several air quality monitoring stations in the vicinity of the project area: a monitor for 

ozone and particulate matter (PM2.5) on the Pueblo of Jemez south of the project area, and two 

air quality monitoring sites located in the Middle Rio Grande Valley (figure 23). Although these 

monitors are strongly influenced by emissions from the Albuquerque area, they were selected for 

use because smoke from prescribed fires can affect nearby areas. Air quality on the forest is likely 

to be better than indicated because there is less influence from the metro area. 

 

6 As defined by the Clean Air Act, a non-attainment area is one that does not meet the standards for one or 

more of the six criteria pollutants.
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 57

Visibility

Visibility relates to conditions that allow humans to see and appreciate the inherent beauty of the 

landscape, which can be greatly affected by the particular matter and gasses found in smoke or 

dust (Malm 2000). There are visibility monitors in each of the two Class 1 areas. The monitors at 

these stations measure aerosols and particulate matter that can contribute to reduced visibility. 

They also identify the chemicals and emissions responsible for human-caused visibility 

impairment (FLAG 2002). 

The Regional Haze Rule sets a goal to return these areas to natural visibility conditions by 2064. 

As of 2010, both Class 1 areas were slightly ahead of schedule, but further improvements will be 

needed to meet the national visibility goal. In 2011, visibility was impacted at both monitoring 

locations as a result of smoke from the Las Conchas and Wallow fires. The Cerro Grande Fire 

(2000) also resulted in bad visibility days.

Effects of Past Wildland Fire Events on Air Quality

Short-term elevated PM2.5 concentrations result from both prescribed fires and wildfires. There 

have been incidences of unhealthy air quality in the area based on the air quality index (USEPA 

2013a, b) from both wildfire and prescribed fire in the past several years. Wildfires often have 

greater impacts than prescribed fire, both in terms of concentrations and duration of impacts of 

PM2.5 concentrations.

Large wildfires in 2011, notably the Wallow fire in Arizona and the Las Conchas fire, adjacent to 

this project area, had significant smoke impacts. For example, in Albuquerque, over 150 miles 

away from the Wallow fire, there were several days in June 2011 when the standard of 35

micrograms per cubic meter of air (ug/m3) for PM2.5 was exceeded. 

During the Las Conchas fire, Los Alamos and many of the Pueblos downwind from the fire 

experienced significant impacts from smoke. Smoke impacts were worse than the Wallow fire. 

For example, there were several days when the 1-hour averages for PM2.5 in Los Alamos during 

the Las Conchas fire were 2-5 times higher than the highest days in Albuquerque during the 

Wallow fire. Most of these differences can be attributed to the proximity of the wildfires.

Typically, the most significant impacts from smoke are associated with wildfires, but there have 

been large smoke impacts from prescribed fires. In October 2012, the Santa Fe National Forest 

conducted two prescribed fires near the proposed project area in the Jemez Mountains. Smoke 

from these burns resulted in impacts on nearby communities and Albuquerque. With each burn, 

there were 2-3 days of elevated concentrations PM2.5 in Albuquerque, but they did not exceed 

the standard. During the first burn, impacts were significantly higher in the town of Ponderosa, 

directly below the prescribed fire. The 24-hour average for PM2.5 peaked at more than four times 

the standard. There were also reports of elevated smoke in the Jemez Pueblo during the second 

burn. Air quality alerts were issued during both of these fires.

No significant effects on ozone concentrations occurred as a result of the wildfires or prescribed 

fires described above in the communities in the project area or the Albuquerque and Santa Fe 

metro areas. Impacts to ozone levels as a result of wildland fire were not considered as part of this 

analysis. This is because of the complexity and uncertainty of modeling ozone from wildfires and 

because no impacts have been noted in recent years from wildland fire events. 
Chapter 3. Affected Environment and Environmental Consequences

58 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 23. Locations of air quality monitoring sites, climate stations, smoke sensitive communities, 

and Class 1 Airsheds of Concern
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 59

Methodology

Consume v. 3.0 (Ottmar et al. 2006) was used to model potential emissions of PM2.5 and carbon 

dioxide produced by each alternative. A scenario involving wildfire was also modeled. The 

wildfire scenario had the same footprint (area) as the prescribed fire alternatives. This scenario 

also assumed that 30 percent of the area burned with high severity, which is similar to other large 

wildfires in this area and in these fuel types. To make a meaningful comparison, we assumed that 

all of the acres were burned according to the constraints for each alternative. It is understood, 

however, that under any of the alternatives, the final footprint could vary significantly, both as a 

result of final implementation and recognizing that fire (prescribed and wildfire) leaves a mosaic 

of burned and unburned fuels across the landscape. This is the largest factor influencing 

uncertainty in the analysis. 

Consume is a fuels model commonly used to estimate emissions. The model uses the following 

data to calculate emissions: fuel type(s), the type of fire (prescribed fire or wildfire), the condition 

of the unit (has it been mechanically treated or is the fire simulating a natural broadcast burn), and 

environmental conditions (fuel moisture). The model then estimates emissions for a variety of 

pollutants, including PM2.5 and carbon dioxide. The complete set of assumptions and outputs for 

all pollutants modeled is in the air quality specialist report in the project record.

The following pollutants and emissions were not analyzed because there is a high degree of 

uncertainty associated with their analysis. Also, they would occur at levels that would be 

insignificant both in relation to the levels of concern about public health and the environment and 

the risks produced by particulate matter and greenhouse gases produced from prescribed fire:

• Toxics known to be present in smoke such as metals, including mercury; radionuclides; 

and byproducts of fire accelerants. This is due to the high level of uncertainty in such an 

analysis in terms of quantifying the amounts produced, the estimated concentrations 

downwind, and health impacts, especially when significant impacts have been shown 

from particulate matter from smoke from wildfires and prescribed fires.

• Fugitive dust from road work and gravel pits. Air quality in the project area is considered 

to be very good such that the relatively small amount of emissions from such actions 

would be considered negligible to the broader airshed. Fugitive dust from any of these 

actions would be reduced by contractual requirements for operating and best management 

practices to reduce fugitive dust.

In the draft environmental impact statement, emissions associated from other operations such as 

mechanical treatments, timber hauling, gravel pit operations, and road maintenance, construction 

and decommissioning were not considered because these emissions were likely insignificant 

compared to the emissions from prescribed fire. Further, any emissions would likely be negligible 

in terms of potential impacts to NAAQS in the surrounding area. To address the concerns of 

people who commented on this point, this analysis has now been included. 

Analysis Question

The analysis question was derived from the purpose and need and the issues that arose during 

scoping as described in chapter 1. 

• What are the impacts on public health and air quality from the proposed prescribed fire 

treatments? 
Chapter 3. Affected Environment and Environmental Consequences

60 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Summary of Effects

All of the alternatives will produce smoke. Alternatives 1, 3, and 5 produce about the same 

amount of smoke emissions. Alternative 4 produces about 39 percent of the smoke emissions of 

alternatives 1, 3, and 5. Alternative 2 produces the least, about 19 percent of alternatives 1, 3, and 

5. Smoke from prescribed fires would have short-term adverse effects on air quality, visibility, 

and health. The relative risk is related to the total amount of emissions produced by each 

alternative. Impacts on human health are due to exposure to PM2.5. The communities that would

be most affected by smoke are those in the Jemez River Valley.

Environmental Consequences

The following section analyzes the potential smoke emissions under each of the alternatives being 

considered. The primary environmental impacts to air quality analyzed are total emissions from 

prescribed fire for fine particulate matter (PM2.5) and carbon dioxide. PM2.5 is the pollutant 

from smoke that is a primary concern regarding human health impacts. Carbon dioxide was 

analyzed to represent the primary greenhouse gas emitted from wildland fire.

Emissions were evaluated instead of direct impacts to air quality at given locations. This is due to 

the high degree of uncertainty associated with assessing impacts for future actions such as 

prescribed fire. The most significant factor affecting impacts to air quality is the meteorology 

(weather conditions) at the specific time a project is implemented. Specific weather conditions 

that are likely to occur at the time of the proposed prescribed fire treatments cannot be predicted 

at any given time. We also cannot be certain that each alternative could be implemented under 

identical conditions. Weather is not included as a variable in this analysis because it would make 

evaluating any differences between alternatives irrelevant. To draw meaningful distinctions 

between alternatives, this analysis compares the modeled emission of various pollutants for each 

alternative and holds weather conditions constant. 

Effects Common to All Alternatives

Effects on Air Quality and Visibility

Air quality impacts are expected to be minimized under all of the alternatives because burning 

would be limited to days with good ventilation conditions7

. Smoke would be noticeable during 

periods of burning, which could be expected to last for five to seven days. Fuels in the interior of 

the burn would smolder for several days afterwards. Emission reduction techniques would be 

used to reduce the actual amount of emissions produced from fire and help maintain air quality. 

These techniques are listed in appendix A.

Based on typical daytime winds in the area, smoke would likely move toward the northeast and 

would likely dissipate during the periods of active burning. During the day, the amount of smoke 

generated would tend to be greatest for a few hours in the late afternoon when the fire is hottest. 

However, people in the surrounding areas and in Albuquerque and Santa Fe would likely see 

smoke in the air. 

In the evenings, it is likely that smoke would settle into canyons and stream valleys and would 

likely drain down into the community of Ponderosa and the Jemez River valley, potentially 

 

7 Ventilation is the atmospheric potential to disperse airborne pollutants. Good ventilation conditions mean 

that the smoke will disperse quickly.
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 61

reaching the Albuquerque metro area. Thus, smoke would be most noticeable in the late evening 

and early morning hours. There could also be major impairments to visibility in portions of the 

Bandelier National Monument and San Pedro Parks Wilderness. 

Effects on Public Health

There is a potential for significant health impacts from any of the alternatives because of 

exposure to PM2.5. The relative risk is related to the total amount of emissions produced under 

each alternative. The use of prescribed fire would be restricted on days with less than good 

ventilation conditions and emission reduction techniques would be required. As a result, the 

effects on air quality would be minimized because fewer emissions are produced. 

High levels of particulate matter in smoke can impair visibility. Significant visibility impairment 

can lead to highway accidents or problems with planes landing at airports. If an 

uncharacteristically severe wildfire occurred, visibility along Highway 4 from Jemez Springs to 

Los Alamos and Highway 550 to Bernalillo could be reduced. This could result in a higher risk of 

traffic accidents, road closures, or other impacts to motorists along portions of New Mexico 

highways and local, private, and forest roads. 

Amount of Particulate Matter and Carbon Dioxide Produced

Total smoke emissions are greatest under alternatives 1 (proposed action), 3, and 5; there is no 

significant distinction among the three alternatives. Emissions are least under alternative 2 (no 

action). Under alternative 2, estimated total emissions are approximately 19 percent of 

alternatives 1, 3, and 5. Alternative 4 would have approximately 39 percent of the total emissions 

of alternatives 1, 3, and 5. Emissions from a wildfire covering the same area treated with 

prescribed fire are higher than any of the alternatives. 

Table 4 shows the estimated total tons of PM2.5 and carbon dioxide produced from the prescribed 

fire treatments under each alternative and from a wildfire. There is an important distinction 

between a wildfire and a prescribed fire. A wildfire would likely occur as a single event 

potentially lasting for several weeks in one year. The prescribed fire treatments in all of the 

proposed alternatives would occur incrementally over a period of approximately 10 years. Figures 

24 and 25 present the same information in graphic form. 

Table 4. Total metric tons of PM2.5 and carbon dioxide emissions produced for each alternative and 

from a wildfire. Alternatives 1, 3, and 5 produce about the same amount of emissions.

Alternative 

Total Metric Tons 

of PM2.5

Total Metric Tons 

of Carbon Dioxide

Alternative 1 18,878 2,388,808

Alternative 2 3,388 469,004

Alternative 3 19,209 2,353,482

Alternative 4 7,410 1,063,991

Alternative 5 18,864 2,373,332

Wildfire 23,261 2,981,428

The total emissions produced for each pollutant (see figures 24 and 25) is the best way to show 

differences among the alternatives; however, the metric tons per acre of emissions produced by 

each type of treatment are also important. As illustrated below, there are approximately 19,000 
Chapter 3. Affected Environment and Environmental Consequences

62 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

metric tons of PM2.5 emissions under alternatives 1, 3, and 5 and approximately 2.4 million

metric tons of CO2 under alternatives 1, 3, and 5. Alternatives 1, 2, 3, and 5 have a combination 

of treatments: (1) prescribed fire alone and (2) mechanical treatments followed by prescribed fire. 

Alternative 4 only uses one treatment- prescribed fire on areas that have not been mechanically 

treated.

Figure 24. Particulate matter 2.5 (PM2.5) emissions in metric tons, for all alternatives and a wildfire. 

Alternatives 1, 3, and 5 produce the approximately the same amount of PM2.5. A wildfire produces 

the highest amount. Alternative 4 produces the least of all the action alternatives because fewer 

acres are burned. 

Figure 25. Carbon dioxide emissions produced, in metric tons, for all alternatives and a wildfire. 

Alternatives 1, 3, and 5 produce about the same amount of carbon dioxide. A wildfire produces the 

highest amount. Alternative 4 produces the least of all the action alternatives because fewer acres 

are burned. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 63

Figure 26 shows the average amount of PM2.5 produced in metric tons per acre under each 

alternative by treatment type. The metric tons per acre are presented in addition to the total 

emissions to further illustrate the differences between alternatives, and also to address the 

uncertainty among the alternatives regarding their final footprints. 

Figure 26. Average emissions of PM2.5 by alternative (metric tons per acre PM2.5) and treatment 

type. Alternatives 1, 3, 4, and 5 produce about the same average amount of PM2.5 per acre using

prescribed fire alone. Alternatives 1, 3, and 5 produce about the same amount of PM2.5 per acre on 

the acres that are mechanically treated and then burned. When the two treatments are averaged, 

alternatives 1, 3, and 5 produce about the same amount of PM2.5 per acre and alternative 2 produces 

the least. There is no combined treatment for alternative 4 because the acres mechanically treated 

are not burned. 

This analysis is presented to draw distinction among alternatives at the smallest scale, reducing 

the greatest factor contributing to the uncertainty- the total acres treated with prescribed fire under 

each alternative. The combined emissions per acre provide the weighted average between 

treatments across each alternative. The wildfire emissions present the weighted average of 

emissions per acre combining a mixture of burn severity and crown fire, based on similar 

severities experienced on recent large fires in the Jemez Mountains. 

• Approximately 0.18 metric tons per acre of PM2.5 were produced under alternatives 1, 3, 

4, and 5 with prescribed fire alone.

• Approximately 0.38 metric tons per acre of PM2.5 were produced under alternatives 1, 3, 

and 5 with mechanical treatment followed by prescribed fire.

The estimated metric tons per acre of PM2.5 produced by each treatment type are fairly consistent 

among all the alternatives. The differences result from the different kinds and amounts of fuels 

and the treatment type used under each alternative. For example, under alternatives 1, 3, and 5 

approximately 73 percent of the acres that are mechanically harvested and burned are the 

ponderosa pine fuel type. But under alternative 2, approximately 71 percent of the acres that are 
Chapter 3. Affected Environment and Environmental Consequences

64 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

mechanically treated and then burned are the dry mixed conifer fuel type. Although the main 

driver of the differences in total emissions among alternatives is the total number of acres treated 

by fire, the average metric tons per acre vary considerably by treatment type. 

The acres that have been mechanically treated and then burned produce the most emissions on a 

metric tons per acre basis. This is because of higher fuel loads from the slash or activity fuels left 

behind after mechanical treatments. Prescribed fire used in natural fuels (acres that were not 

previously harvested) produces the least amount of emissions on a metric tons per acre basis.

Other pollutants were modeled by treatment type, but only PM2.5 emissions are shown because it 

is the pollutant of most significant concern. For the pollutants modeled, the total emissions for 

each pollutant varied, but they all followed the same pattern of emissions shown in figure 26.

Smoke and Dust Emissions from Mechanical Treatments

No smoke would be generated from thinning or wood and slash removal. There would be minor 

impacts to air quality from these activities: fugitive dust and exhaust from vehicles, heavy 

equipment, and chainsaws. The levels of vehicle exhaust are anticipated to fall well below EPA 

emission standards. Road dust would be higher than current conditions when activities are taking 

place unless they are conducted when the ground is frozen or the road is moist. Road maintenance 

and decommissioning activities would also stir up dust. This kind of dust settles fairly quickly, 

can be mitigated with dust abatement techniques, and is limited to small, localized areas. 

Emissions from Other Treatments

To address concerns from commenters on the draft environmental impact statement (DEIS) about 

CO2 emissions from project activities other than prescribed fire, we analyzed emissions 

associated with other operations such as mechanical treatments (including timber hauling), gravel 

pit operations, air operations on prescribed fires, and road maintenance, construction, and 

decommissioning. Carbon dioxide emissions were analyzed using the carbon content of gasoline, 

diesel fuel, and aviation gasoline (EPA 2004). 

For each alternative, emissions were calculated using the carbon content of the associated fuels, 

the amount of operations assumed to occur for each activity under each alternative, and the fuel 

efficiency of each operation. These calculations are found in the project record. 

Figure 26a shows the total estimated emissions of carbon dioxide from activities other than 

prescribed fire in metric tons, by alternative, for the life of the project. All action alternatives have 

similar amounts of emissions, producing an estimated amount of 2,100 metric tons of carbon 

dioxide over the life of the project. Under each alternative, mechanical treatments produce 

approximately 70 percent of the total carbon dioxide emissions resulting from project activities 

other than prescribed fire. 

When compared to carbon dioxide produced from smoke under each alternative, non-smokerelated emissions of carbon dioxide are estimated to be less than 1% of the total carbon dioxide 

emissions over the life of the project for all alternatives. In comparison, the sum of all nonsmoke, carbon dioxide emissions from all action alternatives over the life of the project is equal 

to about 1.5 hours of carbon dioxide emissions from an average coal-fired power plant, or 

approximately 473 passenger vehicles per year (USEPA 2014). 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 65

Figure 26a. Total emissions of carbon dioxide by, in metric tons for each alternative, for 

activities other than prescribed fire. Alternatives 1, 3, 4, and 5 produce approximately the 

same amount of carbon dioxide. 

Forest Plan Amendments

The proposed amendments would have very small and insignificant effects on air quality under 

each alternative or among the alternatives. This is because of the small areas affected by the 

amendments. For example, under alternative 5 the change in emissions as compared to 

alternatives 1 and 3 was less than 1 percent. This amount of change is insignificant and does not 

allow for a meaningful distinction between the three alternatives. Since the air quality analysis 

examined effects at the project level, these amendments would have no effect of the results of the 

analysis and have insignificant effects on air quality.

Cumulative Effects

The analysis area for considering cumulative smoke-related effects is the portion of the Middle 

Rio Grande airshed. It is not necessary to analyze all the activities within the entire Middle Rio 

Grande airshed. The relatively short-term duration of smoke emissions from this project would 

not affect long-term air quality in the area. The treatments may actually mitigate the effects on air 

quality from a wildfire.

Cumulative effects include those from past, ongoing, and reasonably foreseeable future activities 

that combine with effects of the proposed project in contributing to the total particulate matter, 

carbon dioxide, and ozone load in the same airshed. There is no large industry capable of 

contributing significant amounts of particulate matter or carbon dioxide within the analysis area 

for cumulative effects. Other potential sources and amounts of these pollutants and their 

contribution cannot be accurately quantified. They include:
Chapter 3. Affected Environment and Environmental Consequences

66 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

• Use of fireplaces and wood stoves contributes particulate matter and carbon dioxide, 

mostly from November to April

• Dust from unpaved roads does not typically travel very far or contribute large amounts of 

particulate matter

• Industry emissions are a negligible contribution 

• Prescribed fire treatments by agencies and private landowners are a common contribution 

of particulate matter and carbon dioxide

• Wildfires usually occur annually and contribute relatively large amount of particulate 

matter and carbon dioxide

Thus, the amount of pollutants that would be distributed to areas downwind of the project area 

would increase when all sources of emissions are considered. These sources are: (1) emissions 

from prescribed fire activities outside the project area; (2) emissions from the other sources in the 

list above; and (3) the existing particulate matter and carbon dioxide in the air from past 

activities.

Fireplace smoke and prescribed fires would be the primary contributors to cumulative air quality 

effects because they are the most common sources of particulate matter and carbon dioxide. Fall 

and winter burning of slash piles in the project area and in the surrounding forests would 

contribute incrementally to the cumulative smoke effects from residential use of wood stoves and 

fireplaces. 

Fine particulate emissions (PM2.5) from the proposed action combined with other sources of 

PM2.5 would add to the regional haze that results when there are multiple sources of emissions 

during the same time period. The proposed actions would contribute an insignificant amount of 

fine particulate matter to the regional haze and overall air pollution load within this airshed. This 

is due in part to the timing, coordination, and monitoring of the proposed actions, the low 

emissions concentrations, and other mitigation measures previously described. 

Although prescribed fires could occur at any time of the year, most of the broadcast burning 

would not occur during the winter. In winter, the meteorological (weather) conditions that allow 

slow-moving colder air to settle in low-lying areas are more likely to occur. These low-lying areas 

are often more populated. Larger prescribed fires are not typically conducted during these 

conditions due to the concern that smoke will pool in high concentrations in these areas, 

potentially resulting in health impacts. The State also imposes restrictions on when prescribed fire 

can be used to allow for adequate smoke dispersal. 

To further reduce cumulative effects on air quality, prescribed burning would be coordinated 

between federal land managers and the New Mexico Environment Department. All prescribed 

burn operations would comply with the New Mexico Smoke Management Program. The State has 

regulatory authority and can decide if and when a prescribed fire can take place. Postponing or 

stopping a prescribed fire could be done to avoid putting too much smoke in the air and 

exceeding air quality standards. Thus overall, the cumulative increase in emissions from this 

project is not expected to be significant enough to approach concentrations that would exceed 

State or Federal air quality standards. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 67

Conclusions about the Effects on Air Quality

The analysis question is answered here. 

What are the impacts on public health and air quality from the proposed use of prescribed fire? 

• There is a potential for significant health impacts from any of the alternatives because of 

exposure to PM2.5 from prescribed fire treatments. The relative risk corresponds to the 

total amount of emissions produced from each alternative as shown in figures 24 and 25. 

• The effects on air quality would be minimized using the emissions reductions techniques 

in appendix A. Some of the key measures for reducing smoke impacts on health are (1) 

conducting prescribed fires when ventilation conditions promote good smoke dispersal; 

(2) communication and coordination with affected communities prior to and during 

prescribed fires and (3) using air monitors to assess impacts on communities likely to be 

affected by the prescribed fires and then adjust accordingly if significant impacts occur. 

• Other measures listed in appendix A would reduce the amount of emissions produced by 

up to 45 percent and would help maintain air quality. 

Climate Change

Affected Environment

Climate scientists unequivocally agree that the earth’s climate is getting warmer at an 

unprecedented rate, and that this is primarily a result of humans burning fossil fuels and changes 

in land use. These two factors have led to elevated levels of atmospheric concentrations of carbon 

dioxide (CO2) and other greenhouse gases (IPCC 2013). The observed concentrations of these 

greenhouse gases are projected to increase. Climate change will likely intensify the risk of 

ecosystem change for terrestrial and aquatic systems, affecting ecosystem structure, function, and 

productivity (USDA 2010c).

Southwestern ecosystems have evolved under a long and complex history of climate variability 

and change. Considering the mega-droughts and other climate-related variation that have

occurred over time, southwestern systems have some built-in resilience. However, between 1984 

and 2006, an estimated 18 percent of southwestern coniferous forest was lost to increased fire and 

bark beetle outbreaks likely resulting from drought and high average temperatures (Williams et 

al. 2010).

This analysis synthesizes the direct and indirect environmental consequences information found 

in the specialist reports (as applicable). The Southwestern Region Climate Change Trends and 

Forest Planning (USDA 2010c) report is incorporated by reference. See the specialist reports for 

effects and cumulative effects analyses that consider climate.

Influences on Climate in the Southwest 

The climate of the southwestern United States is often referred to as dry and hot; however, it is 

very complex. The low deserts experience heat and drying winds in the early summer, but 

forested mountain areas and plateaus may experience cold and drifting snow during winter. 

Climate variability is the norm within this region, as temperature and precipitation fluctuate over 

seasons and centuries. The major feature that sets climate of the Southwest apart from the rest of 

the United States is the North American monsoon, which, in the U.S., is most noticeable in 
Chapter 3. Affected Environment and Environmental Consequences

68 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Arizona and New Mexico. Up to 50 percent of the annual rainfall of Arizona and New Mexico 

occurs as monsoonal storms from July through September (Sheppard et al. 2002; USDA 2010c).

Many factors affect climate in the Southwest during a particular year or season, but predictable 

patterns hold across the years and decades and define the region’s climate. In summary: 

• The overall aridity relates to a global circulation pattern known as Hadley circulation, 

which creates a semi-permanent, high pressure zone over the Southwest

• Relatively high temperatures with dynamic daily swings define this geographic region

• Mountains and other differences in elevation affect local climate patterns

• The North American Monsoon works to bring moisture from the tropics into the region 

during the summer months (USFS 2010c)

Based on current projections, the primary regional level effects of climate change most likely to 

occur in the Southwest include: warmer temperatures, decreasing precipitation, decreased water 

availability with increased demand, and increased extreme disturbance events. These climate 

change factors could, in turn, affect ecological, weather related disturbances, and socioeconomic 

demands (USDA 2010c), including increases in:

• Frequency of extreme weather events (intense storms);

• Wildfire risks;

• Outbreaks of insects, diseases, and spread of nonnative invasive species;

• Water scarcity and extended droughts coupled with increased demand;

• National forest socioeconomic uses and demands; and

• Changes in habitat quality and quantity for certain desired wildlife and plant species 

Threats to Local Resources

The goal of this project is to restore ecosystem structure and function and increase resilience to 

undesirable, large-scale disturbances such as climate change. A state-wide climate change 

vulnerability assessment identified the Jemez Mountains area as having both a high exposure to 

climate change impacts and a high density of species vulnerable to climate change compared to 

other parts of New Mexico (TNC 2008). 

Much of the forested acres in the project area have reduced resiliency, which increases the 

potential for severe effects from wildfire, density-related mortality in trees, and reduced resiliency 

to insect and disease. Currently, about 50 percent of the project area could sustain high-severity 

effects from a severe wildfire. Treatments have been designed to increase forest resiliency and 

sustainability. Resiliency should increase the ability of the ponderosa pine forest in the project 

area to survive natural disturbances such as fire, insects and disease, and the extreme weather 

events associated with climate change. Other resources at risk in the project area include:

Soils and Watersheds: Uncharacteristically severe wildfires could result in a loss of soil 

productivity and sediment delivery to connected stream courses. Decreased soil moisture due to 

less precipitation expected from climate change and impaired or unsatisfactory soil conditions 

from wildfire events may lead to an overall decrease in long-term soil productivity. There may 

also be a loss of sequestered carbon through burning of the overstory and increased erosion rates.
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 69

Recreation Settings: Desired recreation setting characteristics such as large, mature trees, 

healthy understory, and diversity of tree age classes, sizes, and species would be at high risk from 

the effects of climate change. Unmanaged forests have shown increases in tree stress and 

mortality as a result of global warming, and old, mature trees are especially vulnerable (Ritchie et 

al. 2008, Van Mantgem et al. 2009, Williams et al. 2010). A greater risk of wildfire would 

increase the risk of damage and/or loss of recreational sites and facilities. 

Fire Frequency and Carbon Storage: Woods et al. (2012) found that although fire frequency 

affected the rate and total amount of carbon storage in a ponderosa pine forest, both 20-year and 

10-year fire return intervals produced forests that were net carbon sinks, while the no action 

alternative forest became a net carbon source. Climate change has the potential to affect fire 

frequency and carbon storage (Woods et al. 2012). 

Nonnative and Invasive Plants: Climate change is expected to be a source of widespread 

disturbances, and disturbance is a major factor in the spread of nonnative and invasive plants. 

Higher temperatures would occur and precipitation cycles would be modified from current 

patterns over large areas.

Rare and Endemic Plants: As environmental conditions change, the ability of rare and endemic 

plant species to adapt may be negatively affected. Water availability may decrease in some areas 

while temperatures generally increase. Climate change, coupled with other factors such as habitat 

loss, could lead to extirpations and increased risks of extinction.

Strategies to Address Climate Change 

The Southwestern Region of the Forest Service developed a strategy to address climate change 

(USDA 2010). Actions include: 

• Enhance adaptation by anticipating and planning for disturbances from intense storms

• Reduce vulnerability by restoring and maintaining resilient native ecosystems

• Increase water conservation and plan for reductions in upland water supplies

• Anticipate increases in forest recreation

• Use markets and demand for wood and biomass for restoration, renewable energy, and 

carbon sequestration

• Monitor climate change influences

The Southwest Jemez Mountains project incorporates several of the above actions. For example, 

proposed treatments including creating groups of trees with openings, returning fire to the 

landscape, and improving soils and watershed conditions. These treatments would restore and 

maintain resilient native ecosystems. 

Analysis Questions

The scope of this analysis is confined to the project area. This scale is most relevant to the 

questions (USFS 2009) addressed by the analysis:

• What are the effects of project activities on climate change?

• What are the effects of climate change on resources and ecosystems in the project area? 
Chapter 3. Affected Environment and Environmental Consequences

70 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

• Would the treatments increase resilience and mitigate the effects of climate change on the 

landscape?

Environmental Consequences

Alternatives 1, 3, 4, and 5

Air Quality

During the public involvement period, people expressed concern that the proposed use of 

prescribed fire would contribute to global climate change by adding carbon dioxide and other 

greenhouse gases into the atmosphere. The analysis in the Air Quality section above shows that 

carbon dioxide and greenhouse gases would be produced under each alternative, primarily 

through the use of prescribed fire. The analysis also demonstrated that the amount of carbon 

dioxide and greenhouse gases produced under a wildfire scenario would be greater than any of 

the alternatives. The wildfire scenario had the same footprint as the prescribed fire. 

The amount of greenhouse gases produced under any alternative is small on a global scale and 

calculating its impact would be very complex and is beyond the scope of this analysis. However, 

the release of carbon dioxide and greenhouse gases from fire, addresses only one major output of 

greenhouse gases and does not consider the forests ability to absorb greenhouse gases under each 

of the alternatives. 

The capacity of the forest to absorb carbon in its biomass (trees and other vegetation) or release it 

through decomposition was not modeled. However, research on forest treatments and carbon loss 

or absorption demonstrates that forests that are thinned and treated with prescribed fire: 

• Produce significantly less greenhouse gases initially, as compared to a wildfire;

• Will start absorbing more carbon than they produce within a couple years after treatment; 

and

• Are more resilient to large-scale disturbances that are likely to result from the forecasted 

warmer, drier climate than those that have had uncharacteristically severe wildfires.

Treatments such as prescribed fire and mechanical thinning would result in an initial loss of 

carbon. This loss of carbon is less than what would happen with an uncharacteristically severe 

wildfire. After a high-severity wildfire, forests release carbon into the atmosphere for decades 

afterwards, even after the initial loss of carbon in smoke (Dore et al. 2012). In contrast, within a 

few years after mechanical treatment and prescribed fire treatments, forests act as carbon “sinks” 

and absorb more carbon dioxide from the atmosphere than they release (Dore et al. 2012; Fulé et 

al. 2012; Honig and Fulé 2012; Stephens et al. 2012).

During the comment period for the DEIS, some commenters requested information about the 

amount of greenhouse gas emissions (primarily CO2) produced by treatments other than 

prescribed fire. As explained in the air quality section, all action alternatives have similar amounts 

of emissions, producing an estimated amount of 2,100 metric tons of carbon dioxide over the life 

of the project (see figure 27). Mechanical treatments produce about 70% of the CO2 emissions 

under each alternative.

Table 4a compares carbon dioxide emissions from all activities, including smoke from prescribed 

fire, over the life of the project. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 71

Table 4a. Estimated carbon dioxide emissions, in metric tons produced by restoration treatments, 

including smoke from prescribed fire treatments over the life of the project. All action alternatives 

produce similar amounts of emissions.

Treatment 

Type Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Mechanical 

treatments

1, 535 98 1,444 1,525 1,664

Gravel pit 

operations

424 212 424 424 424

Road 

treatments

117 112 117 117 117

Air operations 

during 

prescribed fires

77 19 77 46 77

Smoke from 

prescribed fires

2,388,809 469,004 2,353,482 1,063,991 2,373,331

The sum of all non-smoke, carbon dioxide emissions from all action alternatives over the life of 

the project is equal to about 1.5 hours of carbon dioxide emissions from an average coal-fired 

power plant, or approximately 473 passenger vehicles per year (USEPA 2014).

Cultural Resources

The proposed archaeological site treatment work primarily consists of cutting trees on 

archaeological sites by with chainsaws. The emissions produced by the chainsaws would not 

contribute to climate change in any measurable way. The fuels reduction treatments on 

archaeological sites have been designed to make the sites more resilient to current threats and 

potential future threats due to a changing climate (i.e. warmer and drier environment) versus 

doing no treatments. 

Fuels

Climate change is affecting the size, frequency, and severity at which wildfires burn in the 

western United States (Westerling et al. 2006). Predictions include a longer fire season and 

increased risk of high-severity wildfire. The current ecosystem conditions found under the no 

action alternative leave approximately 50 percent of the project area at high risk for active and 

passive crown fire. The high-severity fire effects related to this type of fire behavior increase the 

potential at which carbon stocks would be released into the atmosphere. 

Alternatives 1 and 3 use prescribed fire at low to moderate severities, reducing the amount of 

carbon released into the atmosphere as compared to the no action alternative. Alternative 4 

includes about the same amount of mechanical treatment as alternatives 1 and 3, but reduces the 

use of prescribed fire by 41 percent. This reduction in prescribed fire increases the potential for 

passive crown fire as compared to alternatives 1 and 3. Overall, the long-term effects of low to 

moderate severity fire encourage larger, fire-resistant trees and lower stand densities, which lead 

to greater carbon storage (Hurteau and North 2009).

Nonnative and Invasive Plants

Under alternatives 1, 3, 4, and 5 the potential spread of nonnative and invasive plants caused by 

ground disturbance would be reduced by use of the design features, mitigation measures, BMPs, 
Chapter 3. Affected Environment and Environmental Consequences

72 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

and invasive plant treatments. Increasing forest resiliency and function within the project area 

would diminish the impacts of climate change.

Nonnative and introduced species are a problem now because they can adapt better and outcompete native vegetation within their own present day ecosystems. With less precipitation, 

warmer climates and areas more susceptible to wildfires, nonnative species would have a greater 

advantage and would out-compete and replace native vegetation.

Rangeland Resources

Adaptive management is currently used and will continue to be used to match forage production 

with livestock numbers. Less precipitation is predicted under climate change, and water 

availability for livestock will decrease. Much of the range within the project area is only capable 

for grazing because of the existing water catchments, i.e. earthen tanks, trick tanks and spring 

developments. The mechanical treatments and prescribed burning would produce more forage 

within the upland areas but, with less available water, areas of available forage for livestock 

would decrease. The potential for wildfires with severe effects would increase. Soil loss from 

post-fire flooding and erosion would hinder ecosystem recovery. Grasses and forbs would 

establish and there would be more available forage than currently found. 

Recreation

The action alternatives would improve forest structure, composition, and diversity, and resilience. 

This would reduce the risk of losing desired recreation setting characteristics such as large, 

mature trees, a healthy and diverse understory, and diversity in tree age classes, sizes and species. 

Roads

The action alternatives would reopen and maintain closed roads and decommission nearly 100 

miles of roads. As part of these activities the drainage on the roads will be improved. Climate 

change predicts more intense rainfall events and these improvements should reduce soil loss 

associated with roads as a result of these storms. 

Scenery

The action alternatives would improve forest structure, composition, and diversity, and resilience. 

This would reduce the risk of losing desirable and valued scenery attributes such as ponderosa 

pine and mixed conifer forests, large, mature trees, aspen stands.

Social Science, Economics, and Environmental Justice

The proposed treatments would improve ecosystem resilience and reduce fire hazard. This would 

provide protection against damage to homes, communities, ecosystem services, community water 

supplies, and economic values such as livestock grazing, wood products, and ecosystem services. 

The treatments would also enhance the sustainability of traditional uses, traditional cultural 

properties, and cultural sites. 

Climate change would have long-term impacts on many of the amenities, resources, and 

ecosystem services provided by the Southwest Jemez Mountains landscape. This includes the 

distinctive scenery and resources used by Native American and traditional Hispanic communities, 

the quantity and quality of water, and the amount and type of wood products. A changing climate 

could affect jobs and income related to recreation, tourism, and hunting. Businesses related to 

hiking and camping may have increased income and employment due to longer seasons. Water 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 73

and snow-based activities and related businesses would decline. Loss of forests due to wildfires 

or type conversion would reduce the amount and type of wood products for personal and 

commercial use. Jobs and income related to forest products would also decline. Wildfires and 

weather-related disturbances such as floods and landslides could damage roads, houses, 

community water supplies, and other infrastructure

Soil and Water Resources

The action alternatives would move toward a more sustainable carbon sequestration scenario for 

the project area, especially for soil carbon. The road decommissioning, headcut treatments, and 

instream aquatic habitat improvement treatments would reduce erosion and could maintain or 

increase soil carbon levels (Neary et al. 2012). Increased storage of carbon in the soil, soil organic 

matter, and understory vegetation would reduce the potential loss of carbon stored in trees from 

wildfire (Neary et al. 2002; Stephens et al. 2012).

The mechanical treatments would improve soil condition and productivity for soil infiltration and 

nutrient cycling because of an increase in grass species results in a larger root network. These root 

networks are essential to loosening up and improving the soil structure and promote better water 

infiltration, air exchange, and nutrient cycling. These actions improve the ability of the soil to 

store water, which in turn would mitigate the potential decline in precipitation that is expected 

with climate change. 

Vegetation

Under projected future climate conditions, the proposed mechanical treatments and prescribed 

fire treatments under alternatives 1, 3, 4, and 5 would promote low-density stand structures, 

openings between groups of tree, and larger, fire-resistant trees. Mechanical treatments and 

prescribed fire would help to mitigate the negative impacts of severe wildfire in ponderosa pine 

and dry mixed conifer forests by burning less plant biomass and releasing less carbon into the 

atmosphere as compared to a severe wildfire (Finkral and Evans 2008, Wiedinmyer and Hurteau 

2010).

Natural reproduction of ponderosa pine would be impacted by a warmer, drier climate; it would 

be harder for seedlings to germinate, establish, and grow into trees. Reducing tree density would 

allow younger trees to survive by giving them more space to grow and thrive. 

Some of the carbon contained in the tree biomass material removed by mechanical treatments 

would be stored for a time in wood products such as lumber, vigas, fence posts and other building 

materials. This is supported by Ryan et al. (2010) who found that wood products and building 

material produce fewer greenhouse gas emissions during their production as compared to steel 

and concrete. Wood products also sequester carbon. A study of thinning treatments in ponderosa 

pine found that the treatment initially produced a 30 percent reduction in the carbon stored in the 

standing trees (Finkral and Evans 2008). The treated stands, however, were far less likely to 

support a crown fire, which would release even more carbon into the atmosphere. 

Risks associated with dense forest conditions such as tree mortality and disease and insect 

outbreaks would be reduced and forest resiliency would be improved by implementing the 

proposed treatments. More acres are treated under alternatives 1 and 5, and so more of the forest 

would have increased resiliency. 
Chapter 3. Affected Environment and Environmental Consequences

74 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Wildlife

Wildlife habitat for species requiring closed canopy forest conditions or old or large tree, snag, 

and log structure would be more sustainable as forest resiliency improved. Actions that reduce the 

probability and intensity of large uncontrolled wildfires would indirectly preserve habitat of 

sensitive species and the species themselves in the case of low mobility species.

The proposed action is consistent with strategies to reduce the predicted effects of climate change 

on cutthroat trout, by creating more resilient landscapes and addressing the issues of water quality 

and water quantity (Zeigler et al. 2013; Wenger et al. 2011).Changing weather conditions 

associated with climate change could result in shifts in bird communities because habitats may 

change over the landscape. Restoration projects are aimed at increasing the resilience of 

populations to adjust to these changes. 

Some areas of Jemez Mountains salamander habitat may be warmer and drier after tree density is 

reduced, and this may influence salamander activities and distribution. This effect could be offset 

by increases in snow pack, but this is still dependent on climatic conditions. Further, climate 

change may reduce snowfall and exacerbate drying of habitat. Regardless, a healthy coniferous 

forest provides year-round shade compared to the deciduous shading of early seral shrub species 

that would replace the forest after high-severity wildfire.

Alternative 2

Under the projected future climate conditions, dense forest conditions resulting from the no action 

alternative would be at a high risk of density-related mortality. Vegetation would have limited 

resilience to survive and recover from potential large-scale impacts. Under drier and warmer 

weather conditions, the potential impacts of these risks to the ecosystem would be increased, and 

carbon stocks would remain high. Individual tree growth would be low to the point of stagnation. 

As tree density increases, many areas would have a higher tree mortality (release of carbon) than 

growth (carbon storage). This would result in areas becoming a carbon source to the atmosphere.

Fire-excluded forests contain higher carbon stocks. This benefit is outweighed in the long term by 

the loss of carbon that would likely result from a severe wildfire (Hurteau et al. 2011). Under 

alternative 2, most of the area would have the potential for fire effects from an 

uncharacteristically severe wildfire. Large-scale fire events that could occur with no treatment 

would release significant amounts of carbon into the atmosphere. Kolb et al. (2007) have shown 

that forests and carbon sequestration may fail to recover. 

Larger and more frequent fires would be expected (Marlon et al. 2009). Climate may favor the 

spread of invasive exotic grasses into arid lands where the native vegetation is too sparse to carry 

a fire. When these areas burn, they typically convert to nonnative monocultures and the native 

vegetation is lost (USFS 2010c).

Soils and watersheds are at continued risk of damage from uncharacteristically severe wildfires. 

This could result in increased sediment delivery to streams and the loss of soil productivity. Soils 

could be subject to erosion above tolerable levels from severe wildfires if all soils burned under 

high-severity conditions. Soil productivity would not be improved on the untreated acres. Water 

storage in the soil is not expected to improve either. 

Tree growth would be limited to the point of stagnation, and many areas would experience higher 

tree mortality. Wildlife species requiring closed canopy forest conditions or old or large tree, 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 75

snag, and log structure would be negatively affected over the long term. Open forests and 

meadow and grassland habitats could potentially increase in the long term. There would be less 

water available to plants because of the decrease in precipitation that is predicted with climate 

change.

Allotment management would change as forage productivity changes. More extreme effects, such 

as loss of water sources, would limit the ability of adaptive management. Higher temperatures 

and lower precipitation could lead to lower plant productivity and cover which, in turn, could 

decrease litter cover. In the past, to address drought, stocking in allotments was reduced or 

eliminated. With climate change, there would be longer periods without grazing. Ranchers may 

have to purchase supplemental feed at higher costs than grazing, and this may cause some of

them to stop ranching. 

The fire season would extend into the spring and fall, resulting in more forest closures due to fire 

danger. Forest closures would be disruptive to forest recreation users. An increase in the amount 

and severity of wildfires would increase the risk of damage and/or loss of developed recreation 

sites and dispersed recreation areas.

Conclusions about the Effects

The analysis questions are answered here: 

What are the effects of project activities on climate change?

• This project is proposed on a local scale and is not intended to have cumulative effects 

that are measurable on a global scale in regards to climate change. The amount of 

greenhouse gases and carbon produced by prescribed fire treatments and other activities 

is very small on a global scale. The effects on global climate change from project 

activities cannot be calculated. 

What are the effects of climate change on resources and ecosystems in the project area?

• Climate change will likely intensify the risk of ecosystem change for terrestrial and 

aquatic systems, affecting ecosystem structure, function, and productivity (USDA 2010).

• The primary regional level effects of climate change most likely to occur in the 

Southwest include: warmer temperatures, decreasing precipitation, decreased water 

availability with increased demand, and increased extreme disturbance events. These 

climate change factors could, in turn, affect ecological, weather related disturbances, and 

socioeconomic demands (USDA 2012).

Would the treatments increase resilience and mitigate the effects of climate change on the 

landscape?

• The Southwest Jemez Mountains project incorporates several of the actions included in 

the Southwestern Region of the Forest Service strategy to address climate change (USDA 

2010). For example, proposed treatments include creating groups of trees with openings, 

returning fire to the landscape, and improving soils and watershed conditions. These 

treatments would restore and maintain resilient native ecosystems. 

• Project activities would mitigate the effects of climate change. Most of the project area is 

currently considered overstocked with trees and at risk for high-severity fires which are 
Chapter 3. Affected Environment and Environmental Consequences

76 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

the greatest cause of carbon release or greenhouse gases. Alternatives 1, 3, 4, and 5 would 

reduce the risk of an uncharacteristically severe wildfire within the project area. These 

treatments would be more effective under alternatives 1 and 5 because more acres are 

treated with mechanical treatments and prescribed fire. 

• The treatments proposed for this landscape restoration strategy are expected to move all 

ecosystems in this contiguous landscape toward more resilient conditions so they will 

have the adaptive capacity to recover from endemic insect and disease outbreaks, 

wildfires and climate change events. Woody byproducts will be an expected and 

important outcome resulting from the thinning treatments. Most importantly, the 

restoration treatments would restore natural fire regimes and reduce the risk of 

uncharacteristic wildfires to occur that would otherwise seriously damage water, soil, 

fish, wildlife, scenery, heritage resources, recreation opportunities, tourism, forest and 

timber resources, and other values in this area.

Cultural Resources and Tribal Relations

The cultural resources specialist report (Dyer and Constan 2014) is incorporated by reference. See 

the report for detailed information on data sources, methodology, assumptions, and limitations.

Affected Environment

The Jemez Mountains are known for a great number of impressive late prehistoric archaeological 

sites. Prehistoric peoples have lived in and used this area for thousands of years. Most of the large 

prehistoric sites in the project area are the remains of pueblos (villages). Many of these villages 

had multi-storied buildings, were home to hundreds of individuals, and included over a thousand 

rooms. Thousands of small one to four-room structures known as field houses surround the large 

villages. Most of the known prehistoric sites in the project area date between A.D. 1250 and 1700. 

There are some historic sites in the project area, dating to the late 19th and early 20th centuries. 

These sites are related to uses such as logging and the associated railroad construction, the 

Civilian Conservation Corps, and sheep and cattle grazing. These sites include cabins, corrals, 

logging camps, aspen trees with carved art, telephone lines, and sawmills.

About 58,000 acres, or 53 percent of the project area, have been intensively surveyed for cultural 

resources. Almost all of the ponderosa pine vegetation type has received intensive cultural 

resource surveys. Many areas (about 22,000 acres) that have not been surveyed are on steep 

slopes (greater than 40 percent). The likelihood of finding sites on steep slopes is low. There are, 

however, approximately 30,000 acres that need intensive cultural resource surveys. Most of these 

acres are on mesa tops in the piñon-juniper woodlands, where we expect to find many more 

archaeological sites. 

There are over 3,000 known archaeological sites in the project area, including 40 sites that are 

listed on the National Register of Historic Places. Based on previous surveys and site density, we 

think there are potentially 1,500 more sites that have not been found, for a projected total of 4,500

sites.

Low-intensity surface fires probably burned over most of these prehistoric sites in the past. 

Historic sites (dating primarily to the last 100 years), particularly those with wood features 

(cabins, corrals, aspen art), were protected from wildfire by past fire suppression polices. Now, 

however, these sites are likely to be severely damaged or destroyed by an uncharacteristically 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 77

severe wildfire. This elevated fire hazard (high risk of fire) is due to increasing fuel loads in and 

around sites, drought, and climate change. 

In past fuels reduction and vegetation management projects, we would “flag and avoid” sitesmark them and exclude them from treatments. Because we did not treat these sites, they are now 

covered with a heavy layer of fuel. These “islands of fuels” sitting on top of the sites puts them at 

high risk for significant damage from a wildfire, as shown in figure 27. 

Figure 27. Down trees, logs, branches, and pine needles cover a prehistoric 

site. This site would be damaged or destroyed in a severe wildfire. (Photo 

courtesy of John Galvan) 

Recreational use and livestock grazing have also caused damage to sites in the past. People riding 

ATVs sometimes drive over sites and break, move, or crush artifacts and features (walls). Sites 

have also been vandalized. The implementation of the travel management plan should help reduce 

effects on cultural resources from off-road motorized vehicle use because now trails are 

designated. Cattle walk over and bed down on sites. They are big animals and can damage 

standing walls by rubbing against them. Cattle trails running across sites can lead to erosion. 

Simple measures such as placing slash near walls to keep cows away and building fences or water 

sources away from sites have helped reduce these impacts. Our monitoring has shown that 

grazing at current levels is not causing adverse effects on cultural resources.

There are also over a dozen traditional cultural properties (TCPs) in the project area. These are 

places that are culturally significant to living communities. Examples of TCPs are shrines, trails, 

and rock art. Sacred sites, areas used for religious ceremonies are usually in the higher mountains 

and near lakes, springs, and rivers (Friedlander and Pinyan 1980). Traditional use areas, places 

where plants, boughs, and other resources are collected, are more widely distributed and do not 

usually have visible archaeological remains (Levine 1996).
Chapter 3. Affected Environment and Environmental Consequences

78 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Native American communities are linked to the landscape as part of their world view and spiritual 

being. The landscape as a whole is sacred. The Pueblo tribes have a deep connection to the Jemez 

Mountains. Many places still have a sense of importance and function for Pueblo communities. 

Access and use of these places is essential for the continuation of Pueblo life. 

The Hispanic communities here also have strong ties to the land. These same lands still provide 

grazing land, firewood and other resources for these traditional communities.

Tribal Relations

The Santa Fe National Forest recognizes the importance of the deep connections and associations 

Native American groups and other traditional communities have to the project area. The forest 

contains ancestral lands, significant ancestral sites, sacred areas, and resource collection areas 

significant to Pueblo, Navajo, and Apache communities. Many of these communities are adjacent 

to or surrounded by national forest lands. 

Treatments on and around known traditional cultural properties, sacred sites, and traditional use 

areas will be developed and implemented through ongoing consultation with Native American 

groups and other traditional communities throughout the life of this project. Information about the 

location and current use of these sensitive areas will be considered when prioritizing treatment 

areas during the implementation phase. Information from ongoing tribal consultation will be used 

to implement project-specific mitigation measures to protect sensitive sites.

This restoration project was included in the forestwide annual tribal consultation in the spring of 

2013. Consultation packages were submitted to 36 tribal governments, their representatives, and 

allied government organizations with direct interest in project work conducted on the Santa Fe 

National Forest. These tribes included Pueblo, Apache, and Navajo groups (see appendix A in the 

cultural resources specialist report). Tribal members and representatives have also participated in 

field trips to the project area. Local tribes were invited to the public meetings and public field 

trips held during 2012.

Several of the surrounding tribes raised the issue of the importance of protecting Douglas-fir 

stands. Recent wildfires have destroyed many Douglas-fir stands in and around the project area, 

which makes protecting the remaining Douglas-fir stands of critical importance to the tribes that 

collect evergreen boughs and other forest products for ceremonial purposes.

The Pueblo of Jemez has played an integral role in the development of the proposed 

archaeological site treatments. They attended early partner meetings during the development of 

the landscape strategy. This project has been discussed at all tribal consultation meetings since 

2010. We have taken Pueblo of Jemez representatives and the State Historic Preservation Office 

(SHPO) on field trips to the project area to show them the overall condition of the landscape, and 

specifically the current condition of the archaeological sites. There was strong support for the 

fuels and erosion reduction treatments on archaeological sites. The Pueblo and SHPO agreed that 

low-intensity prescribed fire would further reduce fuel loadings and promote long-term protection 

of these sites from unplanned ignitions.

Methods Used to Analyze the Effects on Cultural Resources

Two primary sources of information were used for this analysis: (1) the forest-level geographic 

information systems (GIS) layers and (2) the existing project and site files at the Jemez Ranger 

Station and the Supervisor’s Office of the Santa Fe National Forest. Other information came from 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 79

the New Mexico Cultural Resources Information System database and GIS interface. Effects on 

traditional cultural properties were evaluated using the process described in Section 106 of the 

National Historic Preservation Act. 

The number of previously recorded archaeological sites was generated by overlaying the relevant 

GIS layer polygons that model a treatment, such as prescribed fire, and examining the 

intersections of those layers. For example, the boundaries of the areas where only prescribed fire 

would be used under alternative 1 intersects with 1,172 previously recorded archaeological sites 

on the cultural site layer.

Because the project will be conducted over more than one year, clearance of the proposed 

activities will be accomplished using a phased approach8

. Before any work on any phase of the 

project can begin, the identification and protection of historic properties must be completed in 

compliance with the National Historic Preservation Act. The standard consultation protocol, 

including consultation with Native American Tribes, must also be completed. With this phased 

approach, a final NEPA decision on the project may be made before all surveys in the project area 

are completed provided that all of the requirements of the Region 3 programmatic agreement 

(USFS et al. 2010) are met. 

Analysis Questions

The analysis questions were derived from the purpose and need, found in chapter 1. 

• Would the proposed activities provide for the sustainability of cultural resources and 

traditional practices? 

• Would the proposed activities reduce erosion, site fuel loading, and impacts from roads 

on archaeological sites?

• What are the effects of the restoration treatments on cultural resources?

Summary of Effects

Effects from alternatives 1, 3, 4, and 5 are similar. More sites would be treated with prescribed 

fire and mechanical treatments under alternative 1 (table 5). Sites that are mechanically treated 

and then burned would receive the most benefits. These treatments would result in beneficial 

indirect and cumulative effects on archaeological sites by reducing fuel loads. Reducing fuels 

would decrease the threat of damaging high-intensity wildfires. Road treatments that correct 

drainage problems would reduce or eliminate erosion damage to sites. Most of the proposed 

activities have the potential to affect cultural resources and traditional cultural properties. The 

proposed mechanical and prescribed fire treatments would have the most effects on 

archaeological sites. These effects include, but not limited to, breakage, loss, compaction, or 

displacement (movement) of artifacts and structural features caused by erosion, falling trees, 

ground disturbance, or machinery. Tree removal would make some sites more visible to the public 

and increase the potential for vandalism.

For traditional cultural properties, sacred sites, and traditional use areas, access to and/or 

disruption of the function or use of the location could occur during treatments. Examples of 

 

8 The phased approach is defined in Appendix J [Stipulation 14] and Appendix E [Section VI: 1] of the 

First Amended Programmatic Agreement.
Chapter 3. Affected Environment and Environmental Consequences

80 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

potential disruptions are removal of dense vegetation, which might let the public see ceremonies 

or other activities; project activities occurring in an area at the same time as a seasonal ritual; and 

changes in the character in the immediate area of a traditional use area. All of the potential effects 

on archaeological sites and TCPs can be avoided or mitigated by following the design criteria and 

mitigations in appendix A and through tribal consultation. 

The potential effects on archaeological sites, traditional cultural properties, and traditional use 

areas are not considered to be adverse because protection measures would be implemented to 

address concerns that arise during consultation, by appropriate scheduling of implementation 

activities, and by following the design criteria and project specific mitigations in appendix A. 

Table 5. Number of known sites per treatment type. The most number of sites would be treated 

under alternative 1. Sites receiving both mechanical treatments and prescribed fire would benefit the 

most. 

Alternative 

Number of Sites 

That Would 

Receive 

Mechanical 

Treatments and 

Prescribed Fire

Number of Sites in 

Areas That Would 

be Treated With 

Prescribed Fire 

Only

Number of 

Sites in Areas 

That Would be 

Mechanically 

Treated Only

Number of 

Sites in Areas 

with Other 

Treatments*

Total 

Number of 

Sites 

Treated**

1 1,432 1,172 0 328 2,932

2 4 580 37 1 620

3 1,353 1,241 0 338 2,932

4 0 1,162 1,432 337 2,931

5 1,416 1,172 0 328 2,916

*Other treatments include headcut treatments, wildlife habitat improvement, campsite rehabilitation, and so 

on. 

**These totals do not include two sites that are historic roads and would not be treated for heavy fuels.

Under alternative 2, fewer sites would be treated. The area would continue to be at risk of 

experiencing an uncharacteristically severe wildfire. If this happened, thousands of archaeological 

sites as well as TCPs, sacred sites, and traditional use areas would be damaged or destroyed.

Alternative 3 has fewer archaeological sites in areas that would be treated with both prescribed 

fire and mechanical treatments. More sites are in areas that would be treated only with prescribed 

fire, which could lead to higher intensity fire occurring near those sites.

Under alternative 4, thousands of archaeological sites are within areas that would receive only 

prescribed fire or only mechanical treatments (see table 5). No sites would receive the benefits of

both treatments. This would increase the intensity of the prescribed fires around the 

archaeological sites and the level of ground disturbance from mechanical treatments.

Fewer sites are treated under alternative 5 than under alternatives 1, 2, 3, and 4, and many more

sites than alternative 2. Sixteen archaeological sites would not receive any treatments because 

they are in Mexican spotted owl core areas. In protected activity centers, 81 archaeological sites 

would receive limited fuels reduction treatments because only trees up to 9-inches diameter 

would be cut. Also, more ground-disturbing activities are proposed. About two miles of control 

lines would be built to ensure that prescribed fire remains outside of the Mexican spotted owl 

core areas.
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 81

Environmental Consequences 

Alternative 1

Prescribed fire has the potential to damage archaeological sites. Fire-sensitive sites (those with 

organic materials, wooden architecture) are at the greatest risk of damage or destruction from a 

wildfire, even a low-intensity fire. Other sites without flammable features are less vulnerable to 

fire, but can be damaged when exposed to high-intensity fire. Fire effects on less vulnerable sites 

include, but are not limited to: cracking of architectural stones, spalling (peeling or separating of 

the outer layer of rock), sooting (charcoal or black residue), and/or chemical changes to cultural 

materials (Lissoway and Propper 1990). The potential effects from other prescribed fire activities 

such as constructing fireline, digging out smoldering roots and stumps, and cutting trees or snags, 

could damage cultural resources and would not be allowed within site boundaries. 

Removing heavy fuels from the sites is the most effective way to protect non fire-sensitive sites 

from significant fire effects (Elliott 1999; Lentz et al. 1992; Lissoway and Propper 1990). Any 

type of fire (prescribed or wildfire) may burn more intensely in areas that were not mechanically 

treated. Trees left within the archaeological site boundary are more likely to be killed by the 

radiant heat of a fire. These trees could fall on top of sites and damage them or they could disturb 

the subsurface (below ground) deposits when their roots come out of the ground. In areas not 

mechanically treated before a prescribed fire, dead fuels would be removed for a distance around 

each site. After the prescribed fire, sites would be checked for any fire-killed trees, and these trees 

would be removed so they do not fall in or onto the sites. 

Figure 28. Rock art before (left) and after (right) fire. After a fire, patches of the rock have peeled 

away from the rock. This is an example of spalling. 

Burning could indirectly create a higher potential for erosion if a lot of plant cover (grasses, forbs, 

pine duff) is burned off of the sites (Elliott 1999). However, the proposed fuel reduction and low 

to moderate-intensity prescribed fires would not sterilize the soil or create hydrophobic soils. 

These low-intensity prescribed fires would leave some vegetation in place. The loss of plant 

cover is a minor and a short-term effect because vegetation would regrow across the sites within 

six months to two years. 

Traditional cultural properties (TCPs) would be affected by the proposed activities in a similar 

way as just described. In addition, access to the TCPs could be limited when treatments are 

happening in the area. People using the TCPs might be disturbed by the activities. Use of 

vegetative screening and considerate scheduling of project activities would reduce impacts. The 
Chapter 3. Affected Environment and Environmental Consequences

82 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

function or character of a TCP could also be affected by our activities. For example, loss of 

Douglas-fir stands during a prescribed fire could affect bough gathering (boughs are used in 

ceremonies). Consulting with the tribes before project implementation would help to identify 

TCPs and traditional use areas to avoid or mitigate these possible effects. Coordination with tribal 

governments would allow for resolution of these potential effects, and so the potential effects are 

not considered to be adverse. 

Other Restoration Treatments

Most of the restoration treatments would disturb the ground and so might affect cultural 

resources: mechanical treatments, instream and riparian habitat work, stabilizing stream banks 

and stream road crossings, head cut treatments, wildlife habitat improvement treatments, gravel 

pit construction, and temporary road construction. The protective measures listed in appendix A 

would address the potential effects from these treatments, and so these effects are not considered 

to be adverse.

Ground-disturbing activities can crush, compact, move, break, or destroy artifacts and features 

above and below the ground, or even the entire site. These effects can range in intensity. 

Mechanical treatments, for instance, can disturb cultural resources when logs are dragged across 

the ground, skid trails are created, and logs are piled at landings. Heavy equipment used in many 

of the treatments can cause rutting and compaction of the soil, which increases erosion. 

Information about the site may be lost as well as the characteristics that make historic properties 

eligible for the National Register of Historic Places. Through the design criteria and mitigation 

measures the effects on archaeological sites will be mitigated. Additionally, effects on traditional 

cultural properties, sacred sites, and traditional use areas can be mitigated by implementing 

protective measures to address concerns that arise during consultation. 

Road Treatments

Road maintenance and road decommissioning also have the potential to affect cultural resources. 

These effects are similar to those for ground-disturbing activities. The protective measures listed 

in appendix A would address all of these potential effects, and so these effects are not considered 

to be adverse.

A few of the existing roads that need maintenance or decommissioning are located within or near 

the boundaries of known archaeological sites. The original construction of these roads likely 

caused the most effects on the site. If the roadbed that intersects a site is below the cultural 

deposits of the site, road work can be done within the existing road prism9 because no more 

damage would be done. These types of road activities can actually benefit nearby sites, especially 

when poor drainage problems are fixed. If a road is not maintained properly, sites can be damaged 

when the soil erodes or when soil washes out and covers a site.

Alternative 2

Under this alternative, NEPA-approved management activities would continue. These activities 

are listed in appendix B. Without the landscape-scale treatments, the project area would continue 

to be at risk of experiencing an uncharacteristically severe wildfire. If this happened, many 

 

9 The road prism is the area of the ground containing the road surface, cut slope, and fill slope (uphill and 

downhill sides of the road).
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 83

valuable archaeological sites, TCPs, sacred sites, and traditional use areas would be damaged or 

destroyed. This would cause loss of important historic information, sacred sites, and research 

potential. If the entire project area was consumed in a severe wildfire, over 2,300 known 

archaeological sites could be damaged. These are sites that would have been treated under the 

action alternatives (1, 3, and 4) and made more resilient to wildfires. 

Fuels in and around archaeological sites would continue to increase. The buildup of fuels could 

result in more severe wildfires resulting in significant damage to sites, including spalling, 

(peeling or separating of outer layer of rock) of rock art panels, cracking and spalling of 

architectural stone, thermal (heat-related) changes in artifacts, and post-fire erosion. The loss of 

all vegetative cover due from a severe wildfire would make sites more visible to people. This 

would result in an increased risk of vandalism and artifact theft. Erosion would increase on sites 

without vegetative cover. Trees killed by fire would eventually become uprooted, which could 

result in structural damage and artifact displacement. Finally, emergency wildfire suppression and 

rehabilitation activities would likely affect archaeological sites. Bulldozing or hand-digging 

wildfire containment lines could damage archaeological sites by destroying surface features and 

subsurface deposits (Lissoway and Propper 1990).

Flammable parts of archeological remains and historic structures can be partially or completely 

consumed (burned up) when exposed to even the lowest-intensity fire (Lissoway and Propper 

1990; Elliott 1999). If exposed to high-intensity fire, noncombustible materials, such as the 

remains of ceramics, stone tools, masonry architecture, and glass and metal artifacts, become 

blackened or glazed (Elliott 1999; Deal 2012); these materials can also spall, melt, and experience 

irreversible physical or chemical changes to their composition (Lissoway and Propper 1990; 

Elliott 1999; Steffen 2005; Deal 2012). 

The loss of vegetation could expose bare surfaces and accelerate erosion; this would likely 

damage, destroy, displace, or remove certain cultural resources. Historic structures such as 

railroad beds and road-related features could be flooded, buried, or structurally weakened by 

increased sediment loads carried in streams and intermittent drainages. 

Traditional cultural properties, sacred sites, and traditional use areas would be affected by the 

same activities as the archaeological remains and historic structures. A high-intensity wildfire 

rolling across a traditional cultural property or going through a traditional use area could cause 

detrimental effects such as spalling of rock, blackening of objects, and increased erosion due to 

loss of vegetation. The plants in a natural resource collection area may be completely lost. 

Changes in the character of these areas could affect the ability of a traditional group to use the 

site. 

Alternative 3

This alternative reduces the mechanical treatment area by approximately 1,900 acres as compared 

to alternative 1. All other treatments remain the same.

Those 1,900 acres would be treated with prescribed fire only; they would not be mechanically 

treated and then burned. As discussed under alternative 1, fire intensity could be higher in areas 

that have not been mechanically treated prior to using prescribed fire. There are 69 more sites that 

would be exposed to prescribed fire only as compared to alternative 1 (see table 2 in chapter 2). 
Chapter 3. Affected Environment and Environmental Consequences

84 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The potential effects on archaeological sites and traditional cultural properties are similar to those 

described for alternative 1. The physical elements of traditional cultural properties and traditional 

use areas, such as the stones of a shrine or the plants that are collected, could be affected in the 

same way as the archaeological sites in areas that are not thinned before being burned. These 

effects would not be considered adverse when the design features and mitigation measures in 

appendix A are used. 

Alternative 4

Under this alternative, slash from mechanical treatments would not be burned. It would be treated 

in some other way and there would be more intensive ground disturbance from offsite removal of 

material, chipping, shredding, mastication, or other slash treatment method used. This alternative 

potentially could have a greater effect on cultural resources than alternative 1. There are 1,432 

archaeological sites that could be affected in the areas that are mechanically treated but not 

burned. 

Woody debris would increase in the areas that are mechanically treated only. The fuels from the 

mechanical treatments could increase the intensity of a wildfire. As described for alternatives 1 

and 3, dead trees could fall within or on top of archaeological sites or traditional cultural 

properties after a wildfire. Effects on traditional cultural properties and traditional use areas are 

also similar to those in alternatives 1 and 3. The potential effects can be addressed using the same 

measures described for alternative 1, and so the effects are not considered to be adverse.

Alternative 5

Under this alternative, no human activities would occur in Mexican spotted owl core areas and 

only trees up to 9-inches diameter would be cut in Mexican spotted owl protected activity centers. 

About 700 fewer acres would not be treated with prescribed fire as compared to alternative 1. 

Sixteen archaeological sites within the core areas would not receive treatments of any kind and 

would be at risk for damage or destruction in the event of a wildfire. The physical elements of 

traditional cultural properties and traditional use areas within Mexican spotted owl core areas 

could be affected in the same way as archaeological sites within the core areas. Restoration 

treatments conducted on the surrounding landscape would indirectly help to protect 

archaeological sites and traditional cultural properties within the core areas. 

An additional 81 sites are within the Mexican spotted owl protected activity centers that would 

receive minimal fuels reduction treatments (only trees up to 9-inches diameter would be cut). 

This is not ideal as there may be instances in which a larger-diameter tree that poses a threat to an 

archaeological site (e.g. a tree leaning toward a structure) would not be cut. However, if all dead 

and down logs and small-diameter trees are removed from these 81 sites, these protective actions 

should be enough to minimize impacts to cultural resources in the event of a fire over the short 

term. These sites would need to be monitored closely after either a wildfire or prescribed fire to 

determine whether any fire-killed trees need to be cut and removed. Snags that pose a threat to 

cultural resources (e.g. that may fall over on top of a structure or cause damage to subsurface 

deposits due to tree root pull) would be identified for removal avoid any adverse effects on 

archaeological sites. 

About two miles of fire control lines (hand-built) would be needed to keep prescribed fire out of 

the core areas, resulting in additional ground disturbance. This has the potential to affect historic 

properties. Through use of the project-specific mitigation measures for all ground-disturbing 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 85

activities (appendix A) and the site avoidance strategies and site protection measures listed in 

appendix J of the Region 3 Programmatic Agreement, the potential effects are not considered to 

be adverse.

Forest Plan Amendments, Alternatives 1, 3, 4, and 5

None of the proposed forest plan amendments are likely to adversely affect cultural resources. 

Several amendments would help to achieve the objective of cultural resource protection, 

including 1) allowing treatments in Mexican spotted owl habitat; 2) eliminating activity 

restrictions during wildlife breeding seasons; and 3) allowing for interspaces.

The proposed amendments that allow vegetation treatments in Mexican spotted owl habitat would 

be beneficial to cultural resources. The 97 known archaeological sites within the 6 PACs (3,113 

acres of the total project area) could be treated to reduce fuels within archaeological site 

boundaries. Without the amendments, only trees up to 9-inches diameter could be cut within 

protected activity centers, thereby restricting fuel reduction treatments on 81 archaeological sites. 

If no human activity were allowed within core areas around nest sites, no fuels reduction 

treatments would take place on an additional 16 sites. 

The amendments to eliminate activity restrictions during wildlife breeding seasons also have the 

potential to benefit cultural resources. By lifting the timing restrictions there would be more 

flexibility in scheduling fuels reduction activities, allowing for the treatments in and around 

archaeological sites to be expedited. Fewer acres would be treated in a timely manner if the 

breeding seasons must be avoided.

The amendment clarifying language to allow for interspaces would result in more openness 

across the landscape, which would benefit archaeological sites and traditional cultural properties 

by reducing the risk of crown fires throughout the project area. The other proposed amendments 

related to replacing plan language about site plans with surveys around falcon zones and 

amendments related to scenery, would have no effects on cultural resources.

Cumulative Effects 

Past and current activities that are affecting archaeological sites and traditional cultural properties 

in this area and their effects are summarized in the affected environment above. When 

considering past, present, and foreseeable future actions (appendix B) all of the action alternatives 

have the potential to increase the amount of ground-disturbing activities and prescribed fire 

across the landscape. All of these undertakings that have the potential to affect cultural resources 

and TCPs would be analyzed as required under Section 106 of the National Historic Preservation 

Act. Mitigation measures have been or would be implemented to keep ground-disturbing 

activities out of archaeological site boundaries. Fuels reduction treatments have been or would be 

implemented to minimize fire effects on archaeological sites and traditional cultural properties 

during prescribed fires. Because of this, the potential cumulative effects on cultural resources and 

TCPs are not considered to be adverse. 

Increasing the scale of restoration treatments instead of conducting small “postage stamp” 

restoration projects, would reduce fuels at the landscape scale. Reducing fuels would provide 

long-term protection for the entire landscape and all of the archaeological sites and traditional 

cultural properties within it, from disturbances such as wildfire. The travel management plan and 

motorized vehicle use map should also help reduce effects on cultural resources and TCPs that 
Chapter 3. Affected Environment and Environmental Consequences

86 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

would otherwise happen from off-road vehicle use and creation of new routes. Cumulatively, all 

of the various forest management projects in and adjacent to the project area would measurably 

improve long-term protection of cultural resources and TCPs. They would have a low potential 

for adverse effects on archaeological sites and TCPs in the project area.

Conclusions About the Effects 

The analysis questions are answered here to see how the alternatives meet the purpose and need. 

Would the proposed activities provide for the sustainability of cultural resources and traditional 

practices? 

• The restoration treatments would help protect archaeological sites, traditional cultural 

properties, sacred sites, and traditional use areas for future generations. 

• Alternative 1 would provide the most sustainability and protection for these areas because 

more of the areas are treated with a combination of prescribed fire and mechanical 

treatments. Alternatives 3, 4, and 5 would provide less sustainability. Areas that are only 

treated with prescribed fire could burn with a higher intensity, resulting in more damage 

to cultural properties. Areas that are only treated with mechanical treatments would have 

more ground disturbance and could burn with a higher intensity during a wildfire, which 

would have more effects on cultural resources. 

• Under alternative 2, cultural resources and traditional practices would not be sustainable 

because the area would be vulnerable to an uncharacteristically severe wildfire. If this 

happened, many valuable traditional cultural properties, sacred sites, and traditional use 

areas would be damaged or destroyed. Important historical information, sacred sites, and 

research potential would be lost. 

Would the proposed activities reduce erosion, fuel, and impacts from roads on archaeological 

sites?

• The proposed activities would reduce the amount of fuel on sites and reduce erosion and 

impacts from roads. Sites in areas that receive both mechanical treatments and prescribed 

fire would benefit the most. For all action alternatives (1, 3, 4, and 5) potentially adverse 

effects on sites would be avoided with use of the mitigation measures in appendix A. 

• Alternative 1 would treat the most sites and would be the best for cultural resources. Most 

of the 2,932 archaeological sites are in areas that would have mechanical treatments and 

prescribed fire (see table 4). These sites would benefit from having both types of 

treatment occurring in the surrounding area. None of the sites would be mechanically 

treated only. 

• Alternative 2 would not meet the purpose and need. Only 620 archaeological sites would 

be treated for fuel reduction. Most sites are in areas where only prescribed fire would be 

used. These sites are more likely to experience a higher intensity prescribed fire because 

the areas were not thinned prior to burning. Thousands of archaeological sites that would 

have been treated under the other alternatives would be vulnerable to severe damage 

should a wildfire occur in the area. This damage would result in great loss of information 

and research potential.
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 87

• Alternative 3 is good for cultural resources, but fewer archaeological sites would have the 

benefits of the combination of prescribed fire and mechanical treatments. Sites treated 

with prescribed fire only would likely experience higher intensity fire effects. 

• Alternative 4 is much less desirable for cultural resource protection. Thousands of 

archaeological sites would only receive prescribed fire or only mechanical treatments. No 

sites would receive the benefits from the combination of treatments. There would be 

more ground disturbance in areas that are mechanically treated only. Prescribed fires 

would likely be of higher intensity. 

• Alternative 5 is not as desirable for cultural resources as alternative 1.Under alternative 5, 

16 sites in Mexican spotted owl core areas would not be treated and 81 sites in protected 

activity centers would receive a limited fuels reduction treatment. Construction of fire 

control lines would result in more ground disturbance. 

What are the effects of the restoration treatments on cultural resources? 

• Almost all of the proposed activities have the potential to affect cultural resources and 

traditional cultural properties. The primary effects on archaeological sites from project 

activities are due to ground disturbance and burning. These potential effects can be 

addressed by site avoidance strategies, site protection measures, and project-specific 

mitigation measures (see appendix A). Therefore, the potential effects are not considered 

to be adverse. 

• Effects on traditional cultural properties fall into three categories: direct physical effects 

on the physical properties of TCPs, limitation on access to TCPs by traditional 

practitioners, and disruption of use or function of TCPs. To mitigate or avoid these 

effects, consultation with surrounding tribal groups will be conducted so that we can 

identify locations of TCPs and avoid physical effects on these areas. Discussion with 

tribal officials can help with implementing project activities so that access to TCPs is not 

impeded and to provide protection from disruption of the traditional uses or functions of 

property. 

• Restoration treatments would help protect archaeological sites, traditional cultural 

properties, sacred sites, and traditional use areas for future generations. The combination 

of prescribed fire and mechanical treatments would provide the most protection. Areas 

that are only treated with prescribed fire could burn with a higher intensity and cultural 

properties might receive more damage. There would be more ground disturbance in areas 

that only receive mechanical treatments. Construction of fire control lines under 

alternative 5 would also result in more ground disturbance. These areas could also burn 

with a higher intensity during a wildfire, which would have more effects on cultural 

resources. Discussions with tribal officials can help reduce problems with access to 

TCPs, sacred sites, and traditional use areas and provide protection from disruption of 

traditional uses or functions of a property. 

Fuels 

The fuels specialist report (Carabajal and Armstrong 2013) is incorporated by reference. See the 

report for detailed information on data sources, methodology, assumptions, and limitations. The 

Landscape Assessment (USFS 2010b) also has detailed information about fuels, fire behavior, 

and fire history in the Southwest Jemez Mountains and is incorporated by reference. 
Chapter 3. Affected Environment and Environmental Consequences

88 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Affected Environment 

Fuel is more than dead, down, and standing woody debris, it also includes living vegetationleaves, grasses, trees, and shrubs. Ladder fuels are the smaller trees, shrubs, and low branches that 

can carry a surface fire “from the ground to the crown”. When the fire reaches the tree canopy, it 

can spread quickly and is nearly impossible to control. These crown fires are very destructive and 

are what you usually see in news stories about wildfires. We can prevent crown fires by removing 

ladder fuels and reducing canopy density and breaking up the contiguous interlocking crowns. 

A fire regime is the pattern of the frequency, intensity (how hot it burns), and severity (how much 

is damaged) of wildfires. It describes how a fire would have acted without modern human 

interference (Agee 1993). Fire regimes can gives an idea of which tree species were more 

common, whether larger or smaller trees might have survived or been killed by fires, or whether 

trees were killed at all. We can compare today’s wildfires to the historical fire regime and see if 

they are similar (Arno and Allison-Bunnell 2002). The departure, or gap, between historical and 

current fire regimes helps us manage fuels and forests. 

We can measure changes in fire regimes using fire regime condition class (FRCC). Fire regime 

condition class represents the current ecological trend in forest structure, composition, and 

processes. The condition classes describe the degree of departure from historical conditions: 

• FRCC 1- no or low departure 

• FRCC 2- moderate departure

• FRCC 3- high departure 

Changes in FRCC happen because of changes in vegetation (species composition, structural 

stages, stand age, canopy closure); the type of fuels; and other disturbances (insect and disease 

mortality, grazing, and drought). 

Here are some other terms used in this section:

• Active crown fire: This type of fire moves into the tree crown, and advances from crown 

to crown in the tops of trees or shrubs (NWCG 2008). Active crown fires result in high 

severity burns and are considered “stand replacing” because they burn most of the 

vegetation. 

• Fire hazard: This is the chance that a wildfire may start and cause damage. It is driven by 

the frequency of lightning strikes and human ignition, neither of which is affected by fuel 

treatments.

• Fire type: A description of fire behavior and the role of fire in an ecosystem. This analysis 

refers to surface fire, active crown fire, and passive crown fire types.

• Fuel hazard: This is the volume, quantity and location of fuels. It does not include the 

influence of weather and topography. 

• Ladder fuels: Ladder fuels, are the smaller trees, shrubs and low branches that have the 

potential to carry a surface fire up into the tree crowns (Figure 29). When ladder fuels 

catch on fire, the flames can reach the lower limbs of the overstory trees and initiate a 

crown fire. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 89

• Passive crown fire: This is surface fire with enough energy to preheat and combust and 

burn fuels above the surface (Agee 2002). The fire climbs up ladder fuels into the crowns 

of individual trees or groups of trees but does not continue to spread into adjacent 

crowns. (figure 29)

• Surface fire: These fires burn debris on rangeland and forest floor surfaces including dead 

branches, leaves, and low vegetation dry enough to be fuel. The intensity (hotness) of the 

fire and the rate of spread (how fast it grows) are affected by the size, arrangement, 

amount, type, and moisture level of the surface fuels along with weather and topography. 

Figure 29. Ladder fuels in San Diego Canyon (left). The small trees and shrubs underneath 

the larger trees can move fire from the surface into the crowns of the trees. Passive crown 

fire, or torching, during a fire on the Pecos-Las Vegas Ranger District (right). The fire has 

burned into the crown of the tree in the center of the photo, but has not spread to nearby 

trees. 

Fuel and Fire Regimes in the Southwest Jemez Mountains

Wildfire in southwestern forests is inevitable and is the primary disturbance of southwest 

ponderosa pine forests. It is an essential regulating process of forest health (Edmonds et al. 2000). 

There is no substitute for fire in these ecosystems. Fire reduces and/or maintains fuel loads, low 

tree densities and the open, park-like stands typical of these forests. Fire also recycles nutrients 

and rejuvenates the understory grasses and forbs. 

Without fire the objectives of ecological restoration and fuel reduction in southwestern forests 

cannot be met. In these dry forests, woody debris accumulates rapidly, but decomposes slowly. 

Fire is the only tool that reduces surface fuels and maintains them at safe levels. When the fire 

cycle is broken, these forests become susceptible to large, uncharacteristically severe wildfires. In 

the Southwest Jemez Mountains, the fire cycle is broken as seen in the character of the Cerro 

Grande and Las Conchas fires. 

There has been a lot of research about natural forest conditions and fire regimes in ponderosa pine 

forests in the Jemez Mountains (Allen 1989, 2001; Touchan et al. 1995, 1996; Allen et al. 1995; 

Touchan and Swetnam 1995; Swetnam and Baisan 1996). Open forests with groups of trees and a 

grassy understory are the key features for the forest. Historically the fire regime was lowintensity, high frequency surface fires. These historic fires burned grasses, brush, and small trees, 

but left the large and old trees standing. They burned every few years and kept fuel loads at a low 

level. 
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90 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

In the project area, the surface fuel load ranges from 14 to 55 tons of woody debris per acre. This 

is considered a heavy load and will promote a high-intensity fire (Sackett 1979). This is higher 

than the levels needed for ecological benefits. In dry, warm forests of the northwest 5-10 

tons/acre of woody debris is recommended for ponderosa pine and Douglas-fir forests (Brown et 

al. 2004). This is very similar to the 5-13 tons/acre recommended for Rocky Mountain ponderosa 

pine (Graham et al. 1994). 

Ponderosa pine makes up the largest part of the forest, but we’re also concerned about dry mixed 

conifer. The fire regime in dry mixed conifer is similar to ponderosa pine, but the time period 

between fires is longer and the fires in dry mixed conifer forest type burned a little hotter. Much 

of the dry mixed conifer is also FRCC 3. All of the other forest types in the area are in FRCC 2 or 

3 (USFS 2010b). 

Right now, about 60 percent of the project area is currently in FRCC 3, meaning that forest 

conditions have departed substantially from historic conditions. The gap is due to the increase in 

fuels and changes in forest structure because of past fire suppression, logging, and livestock 

grazing. These changes are described in detail in the Landscape Assessment (USFS 2010b). 

Wildfires in this area have shown the results of these changes in fuel and forest conditions. There 

have been 13 large (over 300 acres) fires in the Jemez Mountains in the last 20 years. Most of 

them have exhibited crown fire behavior. Some of these recent wildfires- Dome (1996), Cerro 

Grande, and Las Conchas- were unlike the wildfires that burned in the area before the late 1800s. 

They burn through the tree crowns consuming (burning up) the leaves or foliage and killing the 

overstory trees. Crown fires generate enormous flame lengths and are difficult to suppress. These 

uncharacteristic crown fires covering large areas are historical aberrations. They are a result of 

past land use patterns and institutional decisions that tried to remove wildfire from the forests and 

left them choked with trees, laden with fuel, and susceptible to uncharacteristic and destructive 

fires. 

Other Factors that Affect Fuels and Fires

Wildfire risk is high. The Southwest U.S., including the Jemez Mountains, has a lot of lightning 

(Reap 1986), most of it occurring during July and August, the monsoon season. Most of the 

lightning ignited fires are accompanied by rain and usually do not get very large. Use and

development in the area from recreation, hunting, roads, powerlines, and communities has led to 

human-ignited fires. Our recent large fires have occurred during the spring when hot dry winds 

can make fires spread rapidly. The current long-term drought is also affecting fuel and fire 

conditions like those observed during the Las Conchas fire. The topography of the areamountains intersected by canyons- makes fire suppression operations difficult and can result in a 

larger burned area if a fire becomes established. 

Methods Used to Analyze Effects of Fuels and Fire 

The main purpose of a fuel treatment is to alter the behavior of a wildfire entering the treated area 

making it more controllable and reducing the impact (severity) of that wildfire. Fire severity is 

reduced by reducing surface fuels, increasing the height to the live crown, reducing crown 

density, and retaining large trees of fire-resistant species. In this section, we use fireline intensity 

and change in fire type (defined below) to explain the effects that the mechanical treatments and 

prescribed fire would have on a wildfire. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 91

• Fire type- Wildland fires can be classified into two different types, surface fires and 

crown fires. Crown fires are often divided into two different types, passive and active. 

• Fireline intensity- This is the rate of heat release per unit length of fireline, usually 

expressed in BTUs per foot per second (BTU/ft/sec) (SAF 2008). When the fireline 

intensity is below 500 BTU/ft/s, direct attack fire suppression tactics10 can be used. At 

this intensity, flame lengths are typically less than 4 feet.

We used the Forest Vegetation Simulator (FVS) (Dixon 2002) with the Fire and Fuels Extension 

(FFE) (Reinhardt and Crookston 2003) to model the effects of the mechanical treatments and the 

initial entry prescribed fire for each alternative. FlamMap (Finney 2006) was used to model 

potential fire behavior and fireline intensity for the project area. This showed the stand-level fire 

behavior changes resulting from the proposed treatments by alternative. 

Details about these modeling programs and the assumptions and limitations used are found in the 

fuels specialist report. The purpose of our modeling analysis was not to predict the behavior of a 

real fire, but to compare the potential effects between treatment alternatives. Alternative 2 was 

used as the baseline. Comparing the effects also lets us see how well each alternative meets the 

purpose and need. The modeling assumed that there was only one cycle of prescribed fire. 

Maintenance burns were not modeled. 

Analysis Questions

The analysis questions were derived from the purpose and need and the issues that arose during 

scoping as described in chapter 1. The relevant analysis questions are: 

• Would the mechanical treatments and use of prescribed fire reduce the potential for 

uncharacteristically severe wildfires and promote frequent, low-intensity surface fires? 

• What are the effects of prescribed fire on the environment? 

Other concerns about the use of prescribed fire came up during scoping: the need for prescribed 

fire; the potential of an escaped prescribed fire; and the number of acres proposed for restoration 

and fuels treatments. These concerns were addressed in the scoping report, which is in the project 

record. 

Summary of Effects

Alternatives 1, 3, and 5 had similar effects. All three reduced fire hazard on approximately 30,000 

acres. The potential fire type changed from active or passive crown fire to surface fire. Fireline 

intensity was similar for these alternatives. On over 80 percent of the area, a wildfire would burn 

at less than 500 BTU/ft/s. Wildfires burning at less than 500 BTU/ft/s also have lower flame 

lengths (less than 4 feet) and are typically more manageable and safer to control.

 

10 Direct attack on a fire means that firefighters build a fireline right along the edge or perimeter of a fire. 

This is usually done on low-intensity fires. Indirect attack means building a fireline some distance away 

from the edge of the fire. The unburned fuel between the fireline and the fire is backfired or burned out. 

This is usually used on high-intensity fires (very hot fires) that are spreading very quickly. In these 

situations, direct attack is not safe.
Chapter 3. Affected Environment and Environmental Consequences

92 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Alternative 2 was used as the baseline for comparison. Without treatments, half of the area would 

remain at risk for a crown fire. More of the area would burn at intensities greater than 500 

BTU/ft/s, as compared to alternatives 1, 3, and 5, making wildfires more difficult to manage. 

Under alternative 4, there are fewer acres in the surface fire type than alternatives 1, 3, or 5. The 

number of acres that would experience the passive crown fire type increases by about the same 

amount. Fireline intensities are higher over most of the area than under the other action 

alternatives because there is more fuel (slash) on the site. About 90 percent of the treatment area 

would burn at intensities greater 500 BTU/ft/s. Under alternative 1, about 17 percent of the area is 

above the 500 BTU/ft/s threshold.

Environmental Consequences 

Alternative 1

The proposed mechanical treatments and use of prescribed fire would reduce fire hazard on about 

31,000 acres. There was an improvement in fire type and fireline intensity as compared to 

alternative 2 (no action). 

The reduction in fire hazard means that conditions have improved on about 31,000 acres, or 29.1 

percent of the treated acres. The fire type changed from active crown fire to surface fire on these 

acres. This is shown in figure 30 and table 6 below. 

Table 6. Change in fire type after mechanical treatments and prescribed fire under alternative 1. After 

treatments, fire hazard would be reduced. More acres would experience surface fire.

Fire Type Alternative 1 Alternative 2* 

Fire Type 

by Acres**

Surface Fire 83,562 acres 52,751 acres

Passive Crown Fire 16,950 acres 35,081 acres

Active Crown Fire 5,226 acres 17,996 acres

Acres Improved 30,901 acres NA

Fire Type 

by Percent

Surface Fire 79% 49.9%

Passive Crown Fire 16% 33.1%

Active Crown Fire 5% 17%

Acres Improved 29.1% NA

*Alternative 2 is the baseline. Changes in fire type resulting from mechanical treatments and prescribed fire 

are compared to alternative 2. 

**Acres used in the fire modeling do not match the acres of mechanical treatments. Information about 

stand structure was missing for some areas and could not be modeled. 

Table 7 shows the changes in fire type in ponderosa pine and dry mixed conifer forests, where 

most of the treatments would take place. After treatments, more acres of each forest type would 

move from the crown fire categories into the surface fire category. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwest Jemez Mountains Landscape Restoration Project 93

Table 7. Change in fire type in ponderosa pine and dry mixed conifer forests under alternative 1. 

Without treatments, 14 percent of ponderosa pine acres would experience active crown fire. After 

treatments, only 2 percent of ponderosa pine acres would experience active crown fire. Dry mixed 

conifer showed similar improvements.

Forest Type* Fire Type Alternative 1 Alternative 2

Ponderosa Pine

43,527 acres

Surface Fire 91% 52%

Passive Crown 8% 34%

Active Crown 2% 14%

Dry Mixed Conifer

21,900 acres

Surface Fire 79% 28%

Passive Crown 16% 42%

Active Crown 5% 30%

Changes in fire type for other forest types are in the fuels specialist report.

Fireline intensity also improved (with the treatments (table 8). After treatments, the fireline 

intensity on most of the area is below 500 BTU/ft/s. Before treatments, about 60,000 acres were 

below this threshold. After treatments, over 90,000 acres were below the threshold, a 50 percent

increase in acres below the 500 BTU/ft/s threshold. 

Table 8. Fireline intensity after mechanical treatments and prescribed fire under alternative 1. After 

treatment fireline intensity is below 500 BTU/ft/s on most acres. It is safer for fire crews to use direct 

suppression tactic on fires when fireline intensity is below 500 BTU/ft/s.

Fireline Intensity * BTU/ft/sin Alternative 1 Alternative 2

0 - 100 34,798 acres 37,853 acres

101 - 500 55,856 acres 22,613 acres

501 -1,000 3,298 acres 3,693 acres

1,001 - 2,000 3,253 acres 5,788 acres

2,001 - 4,000 4,596 acres 11,524 acres

4,001 - 5,500 7,537 acres 27,840 acres

*BTU per foot per second
94

Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwestern Jemez Mountains Landscape Restoration Project

Figure 30. Fire types after treatments under alternative 1 (right) and alternative 2 (left). The change in fire type from active or passive 

crown fire to surface fire is dramatic. Nearly 31,000 acres (29 percent of the treated acres) were improved from active or passive crown

fire to surface fire after mechanical treatments and prescribed fire.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 95

Alternative 2

Without management action, much of the project area would remain at risk for crown fire because 

forest conditions would continue to decline. The departure or gap from the historic fire regime 

would increase. As seen in table 6 above, the modeling results show that crown fire potential is 

high. Nearly half of the landscape would experience crown fire. 

Alternative 3

The changes in fire type and fireline intensity under alternative 3 are similar to alternative 1

(tables 9-11). The changes in fire type under alternative 3 are virtually the same as compared to 

alternative 1, so there is no figure for this alternative. About 1,900 fewer acres would be 

mechanically treated under this alternative. These 1,900 acres would still be treated with 

prescribed fire, but there would be less slash because they are not mechanically treated. This 

small change in mechanically treated acres accounts for the subtle changes in fire type and fire 

intensities for this alternative.

Table 9. Change in fire type after mechanical treatments and prescribed fire under alternative 3. After 

treatments, fire hazard would be reduced. More acres would experience surface fire.

Fire Type Alternative 3 Alternative 2*

Fire Type 

by Acres

Surface Fire 82,359 acres 52,751 acres

Passive Crown Fire 16,281 acres 35,081 acres

Active Crown Fire 7,188 acres 17,996 acres

Acres Improved 29,608 acres NA

Fire Type 

as Percent 

of Area 

Surface Fire 77.8% 49.8%

Passive Crown Fire 15.4% 33.4%

Active Crown Fire 6.8% 16.8%

Percent of Acres 

Improved

28% NA

When looking at changes in fire type in ponderosa pine and mixed conifer (table 10), again, the 

results are similar to alternative 1, especially in ponderosa pine. In dry mixed conifer, about 3 

percent more acres are in the active crown fire type than under alternative 1. 

Table 10. Change in fire type in ponderosa pine and dry mixed conifer forests. There is a slight 

increase in active crown fire in dry mixed conifer as compared to alternative 1. Other changes in fire 

type are similar to alternative 1.

Forest Type* Fire Type Alternative 3 Alternative 2

Ponderosa Pine

43,527 acres

Surface Fire 89% 52%

Passive Crown 8% 34%

Active Crown 3% 14%

Dry Mixed Conifer

21,900 acres

Surface Fire 76% 28%

Passive Crown 16% 42%

Active Crown 8% 30%

Finally, fireline intensities mirror those of alternative 1 (see table 8). 
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96 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Table 11. Fireline Intensity after mechanical treatments and prescribed fire under alternative 3. After 

treatment fireline intensity is below 500/BTU/ft/s on most acres. These results are very similar to 

alternative 1.

Fireline Intensity in Alternative 3 Alternative 2

BTU/ft/s

0 - 100

101 - 500

501 -1,000

1,001 - 2,000

2,001 - 4,000

4,001 - 5,500

34,892 acres 37,853 acres

55,272 acres 22,613 acres

3,376 acres 3,693 acres

3,311 acres 5,788 acres

4,536 acres 11,524 acres

7,925 acres 27,840 acres

Alternative 4

Alternative 4 would reduce the acres treated by prescribed fire by approximately 41 percent. 

There are some differences in types of fire and fireline intensity under this alternative. Fireline 

intensities are higher over most of the area than under the other action alternatives. 

There would be about 7,700 fewer acres in the surface fire type than alternative 1 and 6,400 fewer 

acres in the surface fire than alternative 3 (table 12 and figure 31). The number of acres that 

would experience the passive crown fire type increases by about the same amount. There is less 

surface fire under alternative 4 because the slash is not treated by prescribed fire. The untreated 

slash can increase the intensity and flame length of a wildfire, and the potential for a passive 

crown fire is higher (Agee and Skinner 2005). 

Mechanical treatments would reduce the ability of a fire to move from tree crown to tree crown 

(active crown fire). They also reduce torching (passive crown fire) in some areas by removing 

smaller trees that act as ladder fuels. When prescribed fire is not used after thinning, however, the 

surface fuel load leads to hotter fires and torching is more likely to happen. If the slash is piled up

high enough, it can act as a ladder fuel and increase the likelihood of torching. 

Table 12. Change in fire type after mechanical treatments and prescribed fire under alternative 4. 

After treatments, fire hazard would be reduced. More acres would experience surface fire.

Fire Type Alternative 4 Alternative 2*

Fire Type 

by Acres

Surface Fire 75,962 acres 52,751 acres

Passive Crown Fire 24,577 acres 35,081 acres

Active Crown Fire 5,289 acres 17,996 acres

Acres Improved 23,211 acres NA

Fire Type 

as Percent 

of Area 

Surface Fire 71.8% 49.8%

Passive Crown Fire 23.2% 33.4%

Active Crown Fire 5% 16.8%

Percent of Acres 

Improved

21.9% NA

Ponderosa pine and dry mixed conifer cover types show no change in active crown fire potential 

between alternatives 1 and 4 (table 13). However, there is more potential for passive crown fire 

and less for surface fire in both vegetation types than alternative 1. This is due to the lack of 

prescribed fire after mechanical treatments, as explained above. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS of the Southwestern Jemez Mountains Landscape Restoration Project 97

Figure 31. Fire types after treatments under alternative 4 (left) and alternative 2 (right). About 7,500 more acres would burn as passive

crown fire than alternative 1. This is because fewer acres are treated with prescribed fire under this alternative. Most of these areas of 

passive crown fire are found on the east side of the project area, with some smaller areas on the western boundary. 
Chapter 3. Affected Environment and Environmental Consequences

98 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Table 13. Change in fire type in ponderosa pine and dry mixed conifer forests under alternative 4. 

Without treatments, 14 percent of ponderosa pine acres would experience active crown fire. After 

treatments, only 2 percent of ponderosa pine acres would experience active crown fire. Dry mixed 

conifer forests showed similar improvements.

Forest Type* Fire Type Alternative 4 Alternative 2

Ponderosa Pine

44,827 acres

Surface Fire 79% 52%

Passive Crown 19% 34%

Active Crown 2% 14%

Dry Mixed Conifer

22,835 acres

Surface Fire 70% 28%

Passive Crown 25% 42%

Active Crown 5% 30%

Table 14. Fireline Intensity after mechanical treatments and prescribed fire under alternative 4. After 

treatment fireline intensity is below 500/BTU/ft/s on most acres. It is safer for fire crews to use direct 

suppression tactic on fires when fireline intensity is below 500/BTU/ft/s.

Fireline Intensity 

BTU/ft/s

in Alternative 4 Alternative 2

0 - 100 4,456 acres 37,853 acres

101 - 500 6,640 acres 22,613 acres

501 -1,000 40,932 acres 3,693 acres

1,001 - 2,000 44,294 acres 5,788 acres

2,001 - 4,000 5,000 acres 11,524 acres

4,001 - 5,500 7,989 acres 27,840 acres

Fireline intensity is higher because the slash is not treated with prescribed fire. In the modeling 

exercise, the slash becomes surface fuel and is burned under extreme wildfire conditions, not the 

more controlled conditions found when prescribed fire is used. 

A wildfire burning with the intensity shown in table 9 would be more difficult to control. Indirect 

attack methods, such as bulldozers, helicopters, and air tankers would be used instead of direct 

methods. The fire would be larger and would likely cause more damage to forests and 

communities and would cost more to put out. 

Research on the effectiveness of treating fuels shows that only combinations of treatments that 

reduced both canopy and surface fuels had significant treatment effectiveness when modeled 

under extreme weather conditions (Omi et al. 2006). Mechanical treatments followed by 

prescribed fire are an example of a combination treatment. Mechanical treatments reduce canopy 

fuels and prescribed fire reduces surface fuels.

Alternative 5

Alternative 5 would reduce the acres treated by prescribed fire by about 700 acres, or less than 1 

percent. More restricted habitat would be mechanically treated as compared to alternative 1, but 

there is a 9-inch diameter cap on trees cut in Mexican spotted owl habitat. 

The changes in fire type and fireline intensity under alternative 5 are similar to alternatives 1 and 

3. The changes in fire type under alternative 1 are virtually the same for this alternative, so there 

is no figure for this alternative. The small change in the prescription for mechanical treatments in 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 99

Mexican spotted owl habitat and the lack of any human activity within core areas explains the 

minimal difference for the changes in fire type and fire intensities for this alternative. 

Table 15. Change in fire type after mechanical treatments and prescribed fire under alternative 5. 

After treatments, fire hazard would be reduced. More acres would experience surface fire.

Fire Type Alternative 5 Alternative 2*

Fire Type 

by Acres

Surface Fire 83,723 acres 52,751 acres

Passive Crown Fire 16,806 acres 35,081 acres

Active Crown Fire 5,299 acres 17,996 acres

Acres Improved 30,972 acres NA

Fire Type 

as Percent 

of Area 

Surface Fire 79.1% 49.8%

Passive Crown Fire 15.9% 33.4%

Active Crown Fire 5% 16.8%

Percent of Acres 

Improved

29.3% NA

Ponderosa pine and dry mixed conifer cover types show no change in surface, passive crown, or 

active crown fire potential as compared to alternative 1 (see table 8). 

Table 16. Change in fire type in ponderosa pine and dry mixed conifer forests under alternative 5. 

Without treatments, 14 percent of ponderosa pine acres would experience active crown fire. After 

treatments, only 2 percent of ponderosa pine acres would experience active crown fire. Dry mixed 

conifer forests showed similar improvements.

Forest Type* Fire Type Alternative 5 Alternative 2

Ponderosa Pine

43,527 acres

Surface Fire 91% 52%

Passive Crown 8% 34%

Active Crown 2% 14%

Dry Mixed Conifer

21,900 acres

Surface Fire 79% 28%

Passive Crown 15% 42%

Active Crown 6% 30%

Fireline intensities also mirror those of alternative 1 (see table 8). 

Table 17. Fireline Intensity after mechanical treatments and prescribed fire under alternative 5. After 

treatment fireline intensity is below 500/BTU/ft/s on most acres. It is safer for fire crews to use direct 

suppression tactic on fires when fireline intensity is below 500/BTU/ft/s.

Fireline Intensity 

BTU/ft/s

in Alternative 5 Alternative 2

0 - 100 34,704 acres 37,853 acres

101 - 500 55,721 acres 22,613 acres

501 -1,000 3,590 acres 3,693 acres

1,001 - 2,000 3,208 acres 5,788 acres

2,001 - 4,000 4,569 acres 11,524 acres

4,001 - 5,500 7,520 acres 27,840 acres
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100 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Forest Plan Amendments

Forest plan amendments related to Mexican spotted owl protected activity centers would allow 

more flexibility in conducting vegetation and prescribed fire treatments in these areas including 

the core habitat. The effects would be beneficial and would reduce the potential for a highseverity wildfire under alternatives 1, 3, and 4 as compared to alternative 5. 

Amendments allowing treatment during breeding seasons would have positive effects on fuels 

management and prescribed fire activities by increasing the treatment window. The amendment 

clarifying the language regarding interspaces would also have beneficial effects on fuels 

management. The risk of a high-severity wildfire would also be reduced. 

The amendments regarding peregrine falcon site plans and scenery management would have no 

effects on fuels management activities.

Cumulative Effects 

The cumulative effects take into consideration both planned and unplanned activities that have 

occurred in the area within the last 20 years, along with any proposed projects (see appendix B). 

Planned activities include prescribed fire and mechanical treatments that have an effect on 

limiting the potential for uncharacteristically severe wildfire. Unplanned activities include 

wildfires managed under a full suppression strategy, a confine/contain strategy, and/or a resource 

benefit strategy. All cumulative effects in this section will be described in terms of their 

effectiveness at reducing crown fire potential. 

In the past 20 years, much of the Jemez Mountains have been affected by wildfire. These 

wildfires ranged from low-severity fire to high-severity, stand replacement fires. All of them have 

had an impact on current fire behavior and the forest’s vulnerability to future uncharacteristically 

severe wildfires. For example the Las Conchas fire burned during the peak of fire season and 

burned about 150,000 acres. The fire burned just over 700 acres within the project area. Much of 

this area was severely burned and will not sustain a crown fire for many years to come.

Other wildfires in the area burned under less severe fire weather conditions than the Las Conchas 

fire and were represented more by mixed and low severity effects. The South Fork fire (2010) 

burned approximately 15,000 acres. Common effects of this and similar fires are the consumption 

of ground and surface fuels, reduction of ladder fuels, raising of the canopy base height and 

mortality of smaller isolated pockets of trees caused by burning. All of these effects contribute to 

a reduced potential of a future uncharacteristically severe wildfire. 

Past and current prescribed fire projects and mechanical treatments have been conducted within 

and near the project area. These treatments can reduce crown fire potential within a treatment 

area. Landscape-scale and/or multiple fuels treatments are needed to disrupt the spread of large 

wildfires because they can easily burn around or spot over small, individual treatment blocks. The 

accumulation of treatments across the landscape reduces the opportunity for wildfire to move into 

the tree crowns by reducing ladder fuels and excess surface fuel loads. Although the risk of 

wildfire may remain constant, the fuels hazard is reduced. Overlapping treatment areas have 

similar outcomes to that of wildfires that burned under low to mixed severity conditions. There 

are several proposed projects on the Coyote, Cuba, and Española Ranger Districts that would also 

contribute to fuels objectives. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 101

Cumulative effects on reducing crown fire potential would be minor. Past wildfires, prescribed 

fires, and mechanical treatments are distributed across the landscape. These areas are undergoing 

constant change as both live and dead fuels continue to accumulate. The past actions and 

proposed actions of the adjoining area would not contribute to any significant impacts. 

Conclusions about the Effects 

What are the effects of prescribed fire on the environment? 

• Prescribed fire would affect many aspects of the environment: air quality, forest structure 

and composition, understory vegetation, and soils and watersheds. These effects are 

discussed in the air quality, wildlife, fish, and rare plants, range, soils, and vegetation 

sections of chapter 3.

• Other important effects of prescribed fire are its effects on fuels and fire behavior. 

Prescribed fire reduces live and dead fuel. Landscape-scale fuel modifications, such as 

prescribed fire, are the most effective way to change the behavior and growth of large 

fires (Finney 2001). Stands with prior fuel treatments experience lower wildfire severity 

than untreated stands burning under the same conditions (Omi and Martinson 2002, 

Strom and Fulé 2007). 

Would the mechanical treatments and use of prescribed fire reduce the potential for 

uncharacteristically severe wildfires and promote frequent, low-intensity surface fires? 

• Prescribed fire used in combination with mechanical treatments would reduce fire hazard 

in the treatment area. Future wildfires would burn at a lower intensity and will not spread 

or grow as quickly (Graham et al. 2004). More of the area would be likely to experience a 

surface fire instead of an active or passive crown fire. Lower fire intensities and surface 

fires are closer to the natural fire regime of the fire-adapted forests here. A single 

prescribed fire, however, would not reestablish low fuel hazard conditions. Any trees 

killed by prescribed fire would add to the fuel loading over time (Keifer et.al 2006). 

• The ponderosa pine and dry mixed conifer forests in this area are fire-adapted forests. 

Fire plays a key role in these forests and is necessary for their maintenance and 

continuity. Prescribed fire can provide the ecological effects of natural fires. Prescribed 

fire can be an effective tool for restoring forests and reducing surface and ladder fuels. 

Moderate intensity prescribed fire can restore the structural diversity in mixed conifer 

forests that was lost because fires were suppressed for many years (Keifer et al. 2000). 

Low to moderate-intensity prescribed fire alone will not reduce the dense stands of trees. 

Mechanical treatments are also needed to move the forest toward its natural state,

especially in forests with mature, fire-resistant trees.

Nonnative and Invasive Plants 

The nonnative and invasive plants specialist report (Gallegos 2013) is incorporated by reference. 

See the report for detailed information on data sources, methodology, assumptions, and 

limitations.

Affected Environment 

Nonnative and invasive plants (also known as noxious weeds) are aggressive species that displace 

(push out or replace) native plant species. They often grow in areas where the soil has been 
Chapter 3. Affected Environment and Environmental Consequences

102 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

disturbed and exposed, such as along roads and trails, in dispersed campsites, and areas where 

livestock gather. They are spread by wind, rain, floods, animals, vehicles, water, and people. 

Nonnative and invasive plants can turn native plant communities into monocultures and disrupt 

natural ecological processes. They also reduce the abundance and diversity of native wildlife 

species and microorganisms in those ecosystems. Wildlife habitat is affected by nonnative and 

invasive species. They replace more nutritious and tasty native forage plants and do not provide 

good places to nest or hide. Some species are poisonous. Nonnative and invasive plants can also 

lead to economic losses. The loss of wildlife habitat and livestock reduces hunting success rates 

and rancher income. 

There are about 2,300 acres of inventoried invasive plant infestations scattered throughout 

national forest system lands within the project area. It is difficult to determine exactly how many 

acres of each separate species are out there. This is because many species grow in the same area, 

creating mixed infestations. The most common invasive plant species in the project area are 

tamarisk, Russian olive and Siberian elm. These plants are found along the Jemez River and other 

low elevation streams. Concentrations of other invasive plants are usually seen in riparian areas, 

wildfire scars, and along roads. 

The New Mexico Department of Agriculture (NMDA) currently lists 37 weed species on its 

noxious weeds list (NMDA 2009). Table 18 lists of the nonnative and invasive species currently 

inventoried and mapped within the project area. It also shows the classification, the dominate 

vegetation type where it is found, and approximate acreage of the infestations. 

Table 18. Nonnative and invasive plant species found in the project area, its NMDA classification, 

associated vegetation type, and acres of infestation. The most acres of infestations are in riparian 

areas, meadows, and sensitive areas.

Name of Nonnative

and Invasive Plant NMDA Class Vegetation Type Acres of Infestation 

within Vegetation Type

Bull Thistle

C- species are 

distributed throughout 

the State

Riparian Areas, 

Meadows, and Sensitive 

Areas 

2,100 acres

Canada Thistle

A- species are not 

present or have very 

limited distribution in the 

State

Riparian Areas, 

Meadows, and Sensitive 

Areas 

Field Bindweed

C- species are 

distributed throughout 

the State

Riparian Areas, 

Meadows, and Sensitive 

Areas 

Nodding Thistle 

(Plumeless or Musk 

Thistle)

B- species are 

widespread in the State

Riparian Areas, 

Meadows, and Sensitive 

Areas 

Poison Hemlock 

(Spotted Hemlock)

B- species are 

widespread in the State

Riparian Areas, 

Meadows, and Sensitive 

Areas 

Russian Olive

C- species are 

distributed throughout 

the State

Riparian Areas, 

Meadows, and Sensitive 

Areas 

Saltcedar (Tamarisk)

C- species are 

distributed throughout 

the State

Riparian Areas, 

Meadows, and Sensitive 

Areas 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 103

Name of Nonnative

and Invasive Plant NMDA Class Vegetation Type Acres of Infestation 

within Vegetation Type

Siberian Elm (Chinese 

Elm) 

C- species are 

distributed throughout 

the State

Riparian Areas, 

Meadows, and Sensitive 

Areas 

A- species are not Riparian Areas, 

White Top (Hoary present or have very Meadows, and Sensitive 

Cress) limited distribution in the Areas 

State

Nodding Thistle 

(Plumeless or Musk 

Thistle)

B- species are 

widespread in the State

Ponderosa Pine 195 acres

Scotch Thistle

A- species are not 

present or have very 

limited distribution in the 

State

Ponderosa Pine

Russian Knapweed B- species are Ponderosa Pine

(Hardheads) widespread in the State

Nodding Thistle B- species are Mixed Conifer 20 acres

(Plumless or Musk widespread in the State

thistle)

Other nonnative species, such as common mullein, have been found in the project area. Although 

mullein is not currently listed on the NMDA noxious weeds list, its ecological effects can be just 

as damaging as those species that are listed. 

We have not done many surveys for invasive plants, and we believe that there are considerably 

more infestations and species that have not been found and mapped. Efforts to find these new or 

unknown infestations would continue throughout the life of this project. We will treat nonnative 

and invasive species found within the project area regardless of their listing status.

A forestwide environmental impact statement that evaluates weed control treatments is in 

progress. The use of chemicals (herbicides) to treat invasive nonnative plant infestations 

identified within the project area would be delayed until the completion of the invasive plant 

control (weeds) EIS. Until then, we would use other non-chemical treatment methods, such as 

hand grubbing. Proposed activities would create an environment that is vulnerable to new 

infestations and the expansion of existing ones. Timely detection and effective treatment methods 

are vital to controlling and containing existing, new, and expanding infestations. 

Methods Used to Analyze Effects

The methodology used to analyze the extent and status of infestations and effects on nonnative 

and invasive species within this area is largely based on Geographic Information Systems (GIS) 

technology and personal knowledge of the area. Data sets were used from the U.S. Forest Service 

GIS Corporate Data (2012) and the Forest Service Activity Tracking System (FACTS). The 

FACTS database is used to track infestations and treatments. Field personnel used GPS to map 

infestations. The location was entered into the GIS database. The species name, size of the 

infestation, and type of treatment (if treated) were recorded in FACTS. 
Chapter 3. Affected Environment and Environmental Consequences

104 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Analysis Questions

The analysis questions were derived from the purpose and need and the issues that arose during 

scoping as described in chapter 1. The relevant analysis questions are: 

• What effect would the proposed activities, including the treatments for nonnative and 

invasive species, have on the establishment, spread, and control of nonnative and 

invasive plant species? 

• How would the proposed treatments of nonnative and invasive plant species limit or 

control their spread? 

Summary of Effects 

Alternative 1 would provide the best response to the threat of nonnative and invasive species 

because some control methods- hand grubbing, prescribed grazing, and prescribed fire- would be 

implemented. These control methods, along with the mitigation measures and monitoring, would 

reduce and control infestations of nonnative and invasive plants. Alternative 1 would also provide 

the largest increase in herbaceous native vegetation, which directly compete with nonnative and 

invasive species. The mechanical treatments and use of prescribed fire would reduce the risk of a 

severe wildfire and potential post-fire infestations. 

Alternatives 3, 4, and 5 would have similar benefits as alternative 1, but on fewer acres. Areas 

that are not treated would be more susceptible to severe wildfires and other disturbances that may 

help the spread of nonnative and invasive plant species. Alternative 3 would have the best shortterm effect on preventing the spread of nonnative and invasive plants because temporary roads 

would not be built. 

Alternative 2 would have the least benefit to ecosystem resilience as only small, fragmented 

projects would be carried out. The inventory, monitoring, and treatment of infestations would not 

be done. Ecosystem conditions would continue to decline and there would be an elevated risk for 

an uncharacteristically severe wildfire. These conditions would allow existing infestations to 

spread and new ones to become established.

Environmental Consequences 

Alternative 1

All of the proposed activities would cause some level of soil disturbance. The amount and 

duration of soil disturbance influences the severity of the infestation. The road treatments- road 

maintenance, road decommissioning, and construction of temporary roads- pose a larger threat 

because they cause more soil disturbance and remove more vegetation than other activities.

Road Work 

The more developed a road11 is, the more likely there will be an infestation of nonnative species 

near the road and in the forest (Gelbard and Belnap 2003). These roads have higher levels of soil 

disturbance from vehicle traffic and maintenance activities. Roads are good habitat for invasive 

plants because they typically have less tree cover and so get more sunlight. Water runs off the 

 

11 Developed roads have a better surface and are easier to drive on. A gravel road is more developed than a 

dirt road, and a paved road is more developed than a gravel road.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 105

road and increases soil moisture next to the road. These create good conditions for the spread of 

invasive plants. 

Building temporary roads and skid trails and the development of gravel pits would disturb the soil 

and create bare ground. That makes these areas vulnerable to the establishment of nonnative and 

invasive species. Not only that, these areas would also have a lot of vehicle traffic, which would 

help spread invasive plants around that particular site and carry seeds to other areas. 

Road decommissioning activities may or may not cause the establishment and spread of 

nonnative and invasive species as vehicles and machinery enter the site to remove the roads from 

the landscape. The length of a decommissioning project and the extent of the work being done 

(seeding alone, ripping and seeding, building earthen barriers or water bars) will largely affect the 

vulnerability of a site to infestations. Over time, the risk of establishment and spread may be 

reduced once work is completed as vehicles will no longer enter these areas. Road maintenance 

activities would also disturb the soil and have the potential to provide seedbeds or serve as a 

pathway for the introduction and spread of invasive plants. 

Prescribed Fire

The low-intensity prescribed fires proposed for ponderosa pine forests are not expected to 

contribute to the spread of nonnative and invasive plants. The research on prescribed fire and the 

spread of invasive plants is mixed, but generally, low-intensity burns in ponderosa pine do not 

disturb the soil very much and this limits the establishment and spread of plants (Fowler et al. 

2008). Other factors besides soil disturbance contribute to the spread of these plants. Keeley 

(2006) noted that regardless of the size of the burn, the amount of nonnative and invasive species 

already present on the landscape was the largest factor influencing whether or not burned areas 

would become infested. 

Burn preparation activities such as fireline construction would disturb the soil and create bare 

ground. Burning slash piles may also contribute to the spread and establishment of invasive 

plants. The heat generated by burning slash piles remains localized and can cause severely burned 

soils. This destroys the seedbank of native vegetation and alters the soil chemistry. The soils may 

become hydrophobic- the water rolls off instead of being absorbed (Ballard 2000). Pile burning is 

usually done from fall to early spring when temperatures are cooler. This reduces the amount of 

heat on the soil. 

Other Activities that May Contribute to the Spread and Establishment of Nonnative and 

Invasive Plants

The other restoration treatments have the potential to disturb the soil and create bare ground: 

instream habitat work, development of water sources for wildlife, screening water sources, 

enhancing seeps and springs, headcut treatments, enhancing riparian vegetation and restoration of 

dispersed campsites. These activities include the use of hand tools, heavy machinery, and 

vehicles. 

Measures to control and contain infestations of nonnative and invasive species are included in the 

proposed action. Methods used include hand pulling of weeds, prescribed grazing, and prescribed 

fire. These proposed treatments, in combination with the existing monitoring program would 

allow managers to better prevent new infestations and prevent their spread, and treat current 

infestations. 
Chapter 3. Affected Environment and Environmental Consequences

106 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Design criteria and mitigation measures have been developed to reduce the spread or 

establishment of nonnative and invasive species from all activities (appendix A). 

Alternative 2

The effects displayed under alternative 1 would not occur because the proposed activities would 

not be carried out. Current management would continue as is, and projects that have completed 

NEPA planning would be implemented. Without treatment, nonnative and invasive plant species 

would continue to expand. Infestations would not be treated; we would only inventory and/or 

monitor new and existing infestations until the EIS for the invasive plant control project is 

completed. Treatments occurring outside of the project boundary would continue. However, as 

much of the Jemez District is included under the proposed action for this project, a large portion 

of the district would not receive treatment. As a result, current infestations would continue to 

spread and new infestations will become established and grow.

Figure 32. Thistle infestation after the Las Conchas wildfire. The fire created large areas of bare soil 

that allowed invasive plants to establish and spread. 

Alternative 3

The effects under this alternative would be the same as alternative 1, but on fewer acres. Under 

this alternative, about 1,900 acres would not be mechanically treated because no temporary roads 

would be built to these areas. These acres would be treated with prescribed fire only. Roadways 

are the main way that nonnative species are spread (Von der Lippe and Korwik 2007). Under this 

alternative the risk of new infestations would be reduced. However, these areas would remain at 

risk for uncharacteristically severe wildfire and other disturbances that could lead to larger 

infestations. 

Alternative 4

The effects are similar to those of alternative 1, except for the areas that are mechanically treated. 

In mechanically treated areas, slash would not be burned; it would be treated by some other 

method. Native vegetation would not respond as quickly without the use of prescribed fire, giving 

invasive plants an advantage. The amount of fuel on the ground would increase. In the event of an 

uncharacteristically severe wildfire, the soil may be damaged by the intense heat and create large 

areas of bare soil. This increases the likelihood of new infestations and the spread of existing 

ones. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 107

Alternative 5

The effects are similar to those of alternative 1. In Mexican spotted owl habitat, mechanical 

treatments would be of lower intensity, and there would be about 700 fewer acres of prescribed 

fire. The potential of the spread or establishment of invasive plant infestations would be slightly 

reduced because there would be slightly less ground disturbance due to the lower intensity of the 

treatments. However, these untreated areas would still remain at risk for uncharacteristic wildfire 

as well as insect and disease outbreaks. 

Forest Plan Amendments

The proposed amendment changes would not have an effect on the spread or establishment of 

nonnative plant populations. Prescribed fires and mechanical treatment would still occur; they are 

the primary mechanism for the spread or establishment of nonnative plant populations. 

Cumulative Effects 

The area considered for cumulative effects is the entire project area. Nonnative and invasive 

plants are easily established and have the potential to spread rapidly without treatment. So, all 

ground-disturbing activities would create conditions that encourage the establishment and spread 

of these plants. 

Activities on the Valles Caldera National Preserve, Jemez Pueblo lands, private, state, county, and 

other federal or other tribal lands adjacent to the project boundary are expected to continue. 

Management actions on those lands could also help nonnative and invasive species to establish 

and spread. However, these landowners may also treat infestations with herbicide or other control 

methods, which would contribute to the reduction of infestations across the landscape. 

Conclusions about the Effects 

The analysis questions are answered here. 

What effect would the proposed activities have on the establishment and spread of nonnative and 

invasive plant species? 

• All of the alternatives have ground-disturbing activities from increased vehicle use that 

could potentially contribute to the spread of nonnative and invasive plant species. The 

proposed design features and mitigation measures would minimize the spread of invasive 

plants. The implementation plan would also minimize the effects of the proposed 

activities on the spread of invasive plants and the appropriate response to infested areas. 

Alternative 2, no action, does not include any preventive or control measures, and 

populations of invasive plants would continue to increase. 

How would the proposed treatments of nonnative and invasive plant species limit or control their 

spread? 

• The current condition would be expected to improve. Treatments to control the 

establishment and spread of nonnative and invasive plants would maintain or enhance 

native plant communities and other natural resources on the forests. Mechanical 

treatments would allow understory vegetation to establish and grow. This native 

vegetation would directly compete with the nonnative and invasive plants. The 
Chapter 3. Affected Environment and Environmental Consequences

108 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

implementation plan would also minimize the effects of the proposed activities on the 

spread of invasive plants and the appropriate response to infested areas.

Rangeland Resources 

The rangeland resources specialist report (Gallegos 2013) is incorporated by reference. See the 

report for detailed information on data sources, methodology, assumptions, and limitations. The 

social science, economics and environmental justice specialist report discusses the economic 

impacts related to livestock grazing use. 

Affected Environment 

Livestock grazing is important to the local economy and is directly tied to the history and strongly 

rooted culture that has shaped the present day area. There are several small predominantly 

Hispanic villages in the area. The residents retain their traditional values and depend on the use of 

natural resources, including livestock grazing and the use of forest products. Raising livestock 

contributes to a sense of identity, prestige within the community, pride of lifestyle, and a feeling 

of self-sufficiency. These create a strong sense of community (Raish and McSweeny 2003; 2012). 

Livestock grazing contributes to the livelihood of permittees and the economy of local 

communities and counties. For most permittees, livestock grazing is generally not a commercial 

venture. Most of the permittees have other jobs and do not make their sole living from livestock 

production, although for some, a substantial portion of their income is derived from livestock. 

The permittees typically own small ranches, and federal grazing permits are integral to their 

overall operations. 

The project area contains all or part of nine grazing allotments: Bear Springs, Cebolla/San 

Antonio, Del Norte, Las Conchas, Peralta, Ponderosa, San Diego, Vallecitos, and V-Double Slash 

(table 19). The 13 permits cover 24 individual livestock operations. The Jemez National 

Recreation Area is not part of an active grazing allotment and so is not analyzed. In the project 

are there are 87 miles of fence, 14 corrals, 65 earthen (dirt) tanks, 29 spring developments, 3 

wells, 31 miles of pipeline, 7 storage tanks, 32 drinkers and 43 cattleguards. 

Adaptive management is used to adjust current resource conditions with livestock numbers. The 

number of authorized livestock, season of use, and levels of livestock use can vary from year to 

year based on resource conditions. It is important to note that the current standard as formalized 

in the Forest Service Handbook may be different from that used in older allotment decisions. For 

example the Cebolla/San Antonio Decision Notice (1998) states that the selected alternative 

“provides for flexibility and adaptation of management techniques and stocking levels for 

individual pastures or the allotment as a whole through monitoring and evaluation.” Although this 

may not meet the formal definition of adaptive management, it allows the rest areas to provide for 

recovery of specific areas following drought or a management action such as those proposed 

under this project.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 109

Table 19. Grazing allotments and acreage within the project area

Allotment Name

Total 

Acreage 

of 

Allotment

Acres of 

Allotment in 

Project Area

Number 

of 

Permits**

Number 

of 

Permitted 

Livestock

Bear Springs* 2,301 67 NA NA

Cebolla/San 

Antonio 26,171 7,164 4 

347

Del Norte 7,890 176 2 67

Las Conchas 1,396 1,396 1 27

Peralta 12,882 1,178 1 53

Ponderosa 2,816 2,561 1 28

San Diego 102,738 54,741 1 

250 and 

14 bulls 

(December 

–April) 

117 and 

14 bulls 

(MayNovember)

Vallecitos 16,254 16,254 1 

107

5 bulls

V-Double Slash 37,408 22,548 2 

181

6 bulls

Totals 209,856 106,085 13** -- 

*The Bear Springs allotment is vacant. About 90 percent of the allotment was given to the Santo Domingo 

Pueblo in a land transfer, and the associated permit was also waived to the pueblo.

**The 13 permits represent 24 individual livestock operations. 

Methods Used to Analyze Impacts on Rangeland Resources 

The methods used to analyze the capacity and effects on rangelands within this area is largely 

based on Geographic Information Systems (GIS) technology, the Terrestrial Ecosystem Survey 

(TEUI) of the Santa Fe National Forest and personal knowledge of the area. Data sets were used 

from the U.S. Forest Service GIS Corporate Data (SNF 2012a). The silviculture, fire, and soil and 

water resources specialists’ reports were also used in the analysis. Private and Pueblo lands were 

not analyzed. 

Analysis Questions

This analysis will address the following questions: 

• What effect would the proposed activities have on herbaceous vegetation? 

This is the response of native herbaceous vegetation12 to the proposed activities.

• What effect would the proposed activities have on grazing and allotment management? 

This is the effect the proposed activities would have on the ability to continue grazing 

 

12 Herbaceous vegetation is non-woody plants eaten by cows, elk, and other grazing animals.
Chapter 3. Affected Environment and Environmental Consequences

110 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

within the project area. It also looks at the effects of the proposed activities on the 

management of the entire allotment as a whole because most allotments are not entirely 

within the project boundary.

• How would the proposed activities affect the permittees? 

This is the potential economic effect on the permittees.

• How would impacts on grazing be minimized? 

Summary of Effects 

Under alternative 1, range condition is expected to improve as forage production and quality 

increases, utilization rates decrease, and distribution of livestock improves. The long-term 

benefits would outweigh the short-term effects and would ultimately improve the ecological 

sustainability of livestock grazing, and substantially increase ecosystem resilience to 

uncharacteristically severe wildfire and other disturbances. There would be a temporary reduction 

in authorized livestock numbers, reduced seasons of use, or a combination of both so that 

prescribed fire could be used. Effects would be short term and would not result in permanent 

changes to permitted livestock numbers or season of use. These effects would only occur in order 

to facilitate the use of prescribed fire.

Alternatives 3, 4, and 5 would have the same benefits as alternative 1 but on a smaller scale 

because fewer acres are treated with prescribed fire and mechanical treatments. Under alternative 

4, the herbaceous vegetation would not respond as quickly after a prescribed fire. 

Alternative 2 would have the least benefit to rangeland resources and ecosystem resilience 

because only small-scale, fragmented projects would be implemented across the landscape. 

Herbaceous vegetation and available livestock forage would continue to decline in areas that are 

not treated. There would continue to be periodic reductions in authorized livestock numbers or 

season of use, or a combination of both due to localized treatments. 

It will be difficult to minimize the short-term effects on the livestock permittees that would occur 

from using prescribed fire. Vacant, unused, or other grazing opportunities are not currently 

available to permittees who may need alternate grazing areas after allotments are treated with 

prescribed fire. 

Proposed treatments within the Bear Springs, Del Norte, and Peralta allotments are not expected 

to have a large effect on the management of the entire allotment. Only a small part of each 

allotment, about one pasture, is within the project boundary. Also, the Bear Springs Allotment is 

currently vacant, so activities are not expected to affect an individual permittee. There would be 

minimal effects on the Ponderosa Allotment also, because it is grazed only during winter months 

when plants are dormant. Access to this allotment is very limited, which would restrict the 

amount of treatments being implemented. 

Environmental Consequences 

Alternative 1

Under this alternative the number of permitted animal unit months (AUMs) would stay the same. 

This alternative would largely affect the Cebolla/San Antonio, Las Conchas, San Diego, 

Vallecitos, and the V-Double Slash Allotments. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 111

Prescribed Fire 

We expect an increase in range capability and improved range conditions after using prescribed 

fire. This means that more of the allotment can be used by grazing animals under proper 

management without long-term damage to the soil resource or plant communities. Right now, 

cows cannot get to some areas because of the dense stands of timber. Other areas have limited 

amounts of forage, again, because there are too many trees. Prescribed fire would thin the dense 

stands of trees and remove fuels. This would allow livestock to use areas that were inaccessible 

before burning. 

Prescribed fire would increase the amount of herbaceous vegetation within the ponderosa pine 

and dry mixed conifer forest types. There would also be an increase in species diversity, 

abundance, and distribution of herbaceous vegetation (Covington et al. 1997; Webster and 

Halpern 2010). Similar effects on herbaceous vegetation are likely to occur in other forest types, 

including aspen (USDA 1989) and piñon-juniper (Covington et al. 1991). The seeds of some 

plants stay dormant in the soil until the hard seed coat is softened or broken (scarified). Fire 

scarifies these seeds so they can germinate. 

The use of prescribed fire would result in adverse short-term effects (1-3 years) on livestock 

grazing, allotment management, and individual permittees. After a prescribed fire is completed, 

there is a rest period of 1-2 years. This rest period is needed to let the soil stabilize and for grasses 

and forbs to reestablish themselves and grow. Perennial grasses13 that lose their leaves, as through 

grazing, in the first growing season after a fire produce less forage and do not grow as well. They 

are also more likely to die (Jirik and Bunting 1994; Bunting et al 1998). 

Permittees may be required to temporarily reduce their authorized livestock numbers, shorten the 

season of use, or do a combination of both to allow herbaceous vegetation to recover and 

regenerate during the 1-2 year rest period. These permittees would be economically impacted. 

These impacts are described in the socioeconomic section of this chapter. Design features and 

mitigation measures (see appendix A) would be used to help permittees to the extent possible 

before and after using prescribed fire. The timing and location of the restoration treatments would 

be done to minimize impacts on the permittees. 

The short-term impacts on grazing and permittees discussed above would be reduced with 

maintenance or re-entry burning. Livestock can be moved around an allotment to take advantage 

of the improved forage while another part of the allotment is undergoing a maintenance burn. 

Reentry burns would also burn with less intensity because the amount of fuel would be greatly 

reduced during the initial burn, thus allowing for more flexibility in adaptive management. 

Prescribed fire could potentially have greater effects on an allotment if there is a drought in the 

year before the burn. The drought would slow reestablishment of native herbaceous vegetation. In 

this scenario, reductions of authorized livestock numbers, season of use, or a combination of both 

could compound the effects on livestock grazing, allotment management, and the permittees in 

order to align livestock grazing numbers with resource conditions. 

The long-term benefit of increased forage production would outweigh the short-term impacts 

from using prescribed fire. The increase in forage production from these treatments would 

 

13 Grasses that produce flowers and seeds year after year.
Chapter 3. Affected Environment and Environmental Consequences

112 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

improve allotment conditions and allow for a more flexible grazing management scheme because 

livestock distribution would improve and livestock utilization rates would decrease. Range 

capability is also expected to increase. These benefits would allow for a sustainable range 

program through drought years, and for low-intensity surface fires to occur on the landscape, 

further sustaining forage production. 

Mechanical Treatments and Stand Improvement Thinning

Reducing tree density with mechanical treatments would increase the diversity and abundance of 

understory plants- grasses, forbs and shrubs. Removing trees opens up the canopy and allows 

more light and precipitation to reach the forest floor, and reduces competition between plants for 

soil moisture and nutrients. These conditions improve growing conditions for understory plants in 

dry forest types including piñon-juniper (Bates et al. 2000; Brockway et al., 2002), ponderosa 

pine (Covington et al. 1997; Griffis et al. 2001), and mixed conifer (Collins et al. 2007). The 

combination of mechanical treatments followed by prescribed fire often has an additive effect- the 

increase in understory vegetation is greater after the two treatments than either one by itself 

(Griffis et al. 2001; Laughlin et al. 2008). 

The wet mixed conifer and piñon-juniper vegetation types would receive little or no prescribed 

fire, but would be mechanically treated. These areas would also have an increase in range 

capability and forage production. Mechanical treatments would be done at different intensitiesmore trees would be removed in some areas than in others- to achieve specific management 

objectives. Because of this, the increase in herbaceous vegetation would vary across the treated 

areas. It may also take longer to occur in areas that are treated less intensely (fewer trees are 

removed). Impacts of increased vegetation are discussed above under prescribed fire. 

Mechanical treatments would increase range capability- livestock could use areas that were 

previously inaccessible or had limited forage availability- and with similar effects. Mechanical 

treatments, with or without prescribed fire, would also reduce fuel loads and lower the potential 

for an uncharacteristically severe wildfire that could cause significant damage to rangeland 

resources.

Mechanical treatments and stand improvement thinning would have some minor short-term 

impacts (1-3 years) on livestock grazing, grazing management, and the permittees. These include 

the loss of available forage or use of pastures and damage to range infrastructure (fences, water 

tanks, etc.). These impacts could result from the activity of harvesting equipment, vehicle traffic, 

use of skid trails, and construction of landings (staging areas). 

Mechanical treatments have been implemented in the general area in the past with few impacts on 

livestock grazing, allotment management, and permittees. For this project, mitigation measures 

and design features are expected to reduce impacts on livestock grazing before and during these 

treatments (see appendix A). Even so, it may be necessary in some instances to limit or delay 

grazing in areas where treatments are actively occurring. 

The long-term effects of mechanical treatments outweigh the undesirable short-term effects. It is 

expected that over a 10-year period, the increase in forage production from these treatments 

would improve allotment conditions and livestock distribution, decrease utilization rates and 

allow for a more flexible grazing management scheme. These benefits would allow for a 

sustainable range program through drought years, and for low-intensity ground fires to occur on 

the landscape.
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FEIS for the Southwest Jemez Mountains Landscape Restoration Project 113

Meadow Treatments

The extent of conifer encroachment or invasion into mountain meadows is clearly seen in figure 

1, which compares aerial photos from 1935 and 2009. Over the last 75 years, meadows 

throughout the Southwest have shrunk (Moore and Huffman 2004). Meadows provide important 

habitat for wildlife, add to biological diversity, and are pleasing to look at. A meadow opening has 

four to five times the herbaceous production and plant richness of the forest understory (Moore 

and Huffman 2004). These grasses and other plants are lost as trees invade and meadows shrink. 

Forage capacity and availability is then also reduced.

Figure 33. Tree invasion of two large meadows in the Las Conchas grazing allotment. The photo on 

the left was taken in 1935; the one on the right was taken in 2009. The meadow is outlined in yellow. 

The smaller meadow on the right is almost completely filled with trees. The large meadow on the left 

is over half filled with trees. Lack of fire and a warmer climate have let trees slowly take over the 

meadows in these mountains (Coop and Givnish 2007).

The proposed removal of encroaching trees from historic meadows would increase the amount of 

herbaceous plants. Tree removal in dry montane meadows in the Cascade Range (Oregon) led to a 

47 percent increase in herbaceous cover. Dry montane meadows exist in the Southwest Jemez 

project area. Tree removal here could result in more forage and a more even distribution of cattle 

across the pastures where treatments are implemented, leading to better grazing management. 

Meadow treatments may have a relatively short (1 year or less) adverse effect on livestock, 

allotment management, and permittees. Depending on location, topography, size of treatment, and 

time of year the treatment is implemented, there may be a need to defer grazing in some areas. 

This type of deferment would mostly occur within riparian meadows and/or riparian pastures and 

is not likely to affect the management of an entire allotment.

Enhancement of Seeps and Springs

Removal of trees from around seeps and springs would reduce water use by trees. This water 

could be used by nearby grasses and herbaceous plants. Some of this water may also end up as 

groundwater or surface water. 

Some seeps and springs directly supply water troughs and drinkers used by livestock. Treatments 

may increase water availability and/or increase the amount of time water is available at these 

livestock water sources. Some springs and seeps would be fenced off from livestock access, but 

these areas are very small in size compared to the area of an allotment. These treatments would 
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114 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

benefit livestock grazing, allotment management, and the permittees, and no adverse impacts are 

expected. 

Headcut Treatments

Headcuts can lead to a decline in rangeland health and soil stability. As soil is eroded, herbaceous 

vegetation declines and sediment is deposited downstream. 

The use of heavy equipment to repair headcuts is expected to have adverse short-term effects on 

herbaceous vegetation. Project vehicles and equipment would crush vegetation and disturb the 

soil. Recontouring the area may have greater impacts because a larger area of vegetation and soil 

would be disturbed. Seeding these areas with native grasses would help these areas recover and is 

one way to mitigate impacts (see appendix A for more measures). 

Livestock may be kept out of recently treated areas, especially those on hillsides, to help 

recovery. Otherwise, headcut treatments are not expected to have adverse impacts on livestock 

grazing, allotment management, or the permittees, and would be beneficial over the long term. 

Treating these areas would stabilize the soil, promote an increase in herbaceous vegetation, and 

improve rangeland condition.

Treatments to Rehabilitate Dispersed Campsites and Plant Native Riparian Vegetation

Most of these dispersed campsites are found in stream corridors. The vehicles and equipment 

used in the treatments would disturb the soil and damage sensitive vegetation along the stream 

corridor. These effects are short term, and treated areas are expected to recover within one year. 

Newly planted herbaceous vegetation and woody species would also mitigate the initial impacts 

caused by the treatments. 

Some areas would be fenced off to protect newly planted vegetation. Exclosures are not 

permanent and would be removed after 7-10 years, when vegetation is well-established and is 

capable of withstanding grazing and browsing. Building these exclosures would have short termeffects on livestock grazing and permittees, because these areas would not be available for 

grazing. The expected increase in pasture forage from using prescribed fire and mechanical 

treatments would offset these effects. 

Treatment of Nonnative and Invasive Plants

This is an ongoing activity within all allotments. The treatments and their effects are discussed in 

the nonnative and invasive species section in this chapter. Right now, nonnative and invasive 

plant species can be treated with hand pulling or grubbing, prescribed grazing, and/or prescribed 

fire. Without treatments, native vegetation would be lost. The quality, quantity, and availability of 

forage for livestock grazing would be reduced. 

The treatment methods listed above would not have an adverse effect on livestock grazing, 

allotment management, or the permittees. Usually, areas that are burned to control or contain 

plant populations would be no larger than 3 acres. Prescribed grazing with goats can occur 

concurrently with livestock grazing. None of these methods would interfere with permitted 

livestock grazing on any allotment. Treating these plant species would increase desirable native 

herbaceous vegetation and forage availability.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 115

Building New Water Sources for Wildlife

Most of the existing upland water sources are available to wildlife and livestock. Providing 

additional water sources improves the distribution of grazing animals (elk, deer, cattle) on mesa 

tops and reduces the need for animals to travel long distances to find water. They also spend less 

time in sensitive riparian, seep, and spring areas.

Short-term adverse effects would result from this activity. Small areas of soil and vegetation 

would be disturbed during the construction of water sources. Vegetation at the site of the 

development would be damaged or destroyed by the heavy equipment and vehicles needed to 

install earthen dams, water catchments, trick tanks, drinking troughs, or guzzlers. Vegetation loss 

would occur on small localized areas. Vegetation is expected to recover within one year, based on 

past experiences with this type of project. 

Additional water sources would benefit livestock grazing, allotment management, and the 

livestock permittees because these new water sources may also be available to livestock. Range 

capability would be increased because the areas that do not have water sources now would be 

available for grazing. A decrease in authorized numbers, season of use, deferment of grazing, or 

resting of pastures or allotments would not be necessary. 

Creating Snags

Snags naturally occur on the landscape due to fire, insects, disease, wildlife, or lightning. They do 

not contribute to forage production, or compete with native vegetation for water and nutrients as 

they are no longer living organisms. 

Snags would be created by girdling trees with hand tools to improve wildlife habitat. This would 

not result in a loss or increase of forage or range capability. There would be no adverse effects on 

livestock grazing, allotment management, or permittees. 

Cultural Site Protection

Cultural sites have been considered in the environmental analyses for each allotment and/or range 

improvement construction. 

Cultural site treatments would not have an adverse effect on livestock grazing, allotment 

management, or the permittees. Some cultural sites presently have mitigation measures in place to 

limit the impacts of grazing to those sites. 

Road Maintenance

Existing roads do not produce forage; however, they do facilitate allotment management by 

providing a way to travel throughout each allotment. 

Road maintenance would benefit allotment management and livestock permittees. Improved road 

conditions would allow for easier travel with pickup trucks and livestock trailers. Road 

maintenance would also improve access to infrastructure such as livestock waters, pipeline 

systems, corrals, fencelines, wells, and other improvements used to manage livestock.

Opening Closed Roads, Constructing Temporary Roads, and Road Decommissioning 

Treatments

Opening existing closed roads or constructing temporary roads would result in a loss of 

herbaceous vegetation in these areas. This is a short-term negative effect. These effects would last 
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116 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

during construction and while the roads are in use. As treatments are completed, roads would be 

re-closed or decommissioned and returned to their natural state.

Roads may be decommissioned with signs, physical barriers, vegetation, or eliminating the road 

bed. Road decommissioning treatments would benefit livestock grazing, allotment management, 

and the permittees. Native vegetation would be reestablished and fill in the road beds. Over time, 

the amount of available forage and species diversity would increase. Rangeland condition would 

gradually improve. Roads used to manage livestock or access fencelines, water tanks, and other 

range infrastructure would not be decommissioned, and so there would be no effects. Mitigation 

measures and design features (see appendix A) would minimize effects or damage to range 

infrastructure (such as fencelines and water tanks). 

Gravel Pits 

Gravel pits would not exceed 5 acres in size per pit. Allotments are significantly larger in size. 

The loss of 5 acres would be outweighed by the benefits of the other treatments. Roads used to 

access these gravel pits would be improved and maintained. These roads may improve the ability 

of the permittees to access corrals, storage tanks, pipelines, and fences. Gravel pits would not 

have an adverse effect on livestock grazing, allotment management, or the permittees.

Alternative 2 

Permitted livestock numbers would stay the same. Ecosystem conditions would continue to 

decline. Tree densities would continue to increase. The probability of uncharacteristically severe 

wildfires would increase. Such a fire could leave the soil severely burned and sterile, as found in 

the Las Conchas burn scar. Conifer encroachment would continue and meadows would shrink or 

disappear. Native herbaceous species would continue to decline. Species abundance and diversity 

would continue to decrease resulting in a lack of available forage for livestock. Range capability 

is currently declining because of tree encroachment and would continue to do so. 

Under this alternative, some areas would receive mechanical treatment or prescribed fire. 

However the amount of acres being treated within these projects is considerably less than those 

being proposed for this project.

Mexican spotted owl habitat or protected activity centers would not be treated. In these areas, 

herbaceous vegetation density or diversity would not increase and rangeland condition or forage 

production would not improve. 

Alternative 3 

Under this alternative, the effects would be somewhat different (with respect to grazing) on those 

areas that are burned rather than mechanically treated and then burned Also, there would be no

effects from temporary roads because they would not be built. Without temporary roads, about 

1,900 acres would not be mechanically treated and would receive prescribed fire only. The effects 

of mechanical treatments would be the same in this alternative as in alternative 1, but on fewer 

acres. All other treatments and their effects would remain the same as under alternative 1. 

Alternative 4 

The effects would be the same as under alternative 1, except for the effects from prescribed fire. 

Fewer acres would be burned because areas that are mechanically treated would not be burned. 

Instead, slash would be chipped or masticated. Some of it may be left on the ground or removed 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 117

as firewood or other wood products. In some areas slash and woody debris would remain on site. 

In accessible areas, chipping or masticating material may occur. Large volumes of fuel would be 

on the ground. A wildfire burning through this fuel could damage the soil. These types of fuel 

beds retain heat for longer periods of time, allowing the soil to burn hotter. This can sterilize the 

soil and suppress vegetation growth (Busse et. al. 2005). 

Layers of chipped or masticated material retain moisture and nutrients and keep them from 

reaching the soil where they can be used by trees and other vegetation. Trees, herbaceous 

vegetation, forbs, and shrubs are then suppressed. Heavy fuel beds keep grass and plant seeds 

from sprouting. An increase in herbaceous vegetation density and diversity, forage productions, 

and rangeland condition would occur at a much slower rate compared to areas that are treated 

with prescribed fire.

Alternative 5

The effects under this alternative would be similar to alternative 1. The reduction in acres burned 

in core areas, construction of fire control lines, and use of a 9-inch diameter cap in protected 

activity centers would not affect range management in those areas. The protected activity centers 

are considered as non-capable range and would be still considered as non-capable range 

regardless of whether they are treated. No range improvement structures exist within the core 

areas or in the areas of potential control lines. 

Forest Plan Amendments 

The proposed amendments would have little effect on range management under any alternative. 

The amendments allowing activities to occur during breeding season of some birds would be 

beneficial because there would be more time to complete infrastructure maintenance and new 

range projects.

Cumulative Effects 

The area considered for the cumulative effects analysis is the entire project area because most of 

the allotments do not fall entirely within the entire project area. The cumulative effects analysis 

considered past, present, and reasonably foreseeable future non-project activities and their effects, 

in combination with the proposed action. These other activities are listed in appendix B. 

The proposed activities listed in appendix B are not predicted to result in any long-term adverse 

impacts on current livestock grazing permit holders. Activities in appendix B are not expected to 

cumulatively add to project effects.

Cumulative effects would be the same for all action alternatives because the activities are the 

same, except for small differences in acreages for mechanical treatments and prescribed fire. 

Alternative 2 (no action) includes mechanical treatments and prescribed fire projects only, but at a 

much smaller scale. 

Past, present, and future active forest management activities have the potential to increase the 

quantity and quality of available forage, improve range condition, and increase range capability. 

Wildfire could add to the cumulative effects for grazing allotments within the project area where 

treatments are being planned, ongoing, or have been completed. 
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118 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The Valles Caldera National Preserve is located to the north of the project boundary. The Preserve 

is currently proposing restoration treatments similar to the ones analyzed in this FEIS.

Conclusions about the Effects of the Alternatives 

This section responds to the analysis questions at the beginning of this section. The questions 

were developed in response to concerns raised during scoping.

What effect would the proposed activities have on herbaceous vegetation? 

• The treatments that reduce tree density and fuels would increase the diversity and 

abundance of herbaceous vegetation, including forage plants: mechanical treatments, 

prescribed fire, meadow treatments, spring and seep treatments, headcut treatments, and 

treatments to control nonnative and invasive plants. Reducing tree density allows more 

light and moisture to reach the forest floor and stimulate plant growth. Mechanical 

treatments and prescribed fire would have the greatest effects.

• Gravel pits and associated access roads would result in a permanent loss of vegetation. 

The area involved is very small as compared to the entire allotment and would not be an 

adverse effect. Prescribed fire and activities that use heavy equipment and vehicles would 

damage vegetation. This would be a short-term effect and vegetation would recover in 1-

3 years. The design features and mitigation measures (appendix A) would reduce impacts 

on permittees. 

What effect would the proposed activities have on grazing and allotment management? 

• Range capability would increase because more of the area would be accessible and 

usable. Cows would be distributed over a larger area instead of being concentrated in 

riparian areas, openings, or areas with fewer trees. Reducing tree density and increasing 

water sources have the largest effect on this because they result in increased forage 

production and better distribution of cows. Road maintenance activities would also 

improve allotment management. With better roads, it would be easier for permittees to 

get to and maintain fences, corrals, water sources and other improvements used to 

manage livestock. 

• Some areas would not be available for grazing during or after treatments because 

vegetation, soil, or other resources would need time to recover. These effects would last 

1-3 years. Exclosures to protect newly planted riparian vegetation would be in place for 

7-10 years. The rest periods after prescribed fire treatments would have the biggest 

impact on the ability to continue grazing. The areas that would be closed are also much 

larger, covering one pasture or the greater part of an allotment. 

• In general, effects on livestock grazing, allotment management or the permittees would 

be beneficial. Long-term benefits would outweigh short-term adverse effects.

How would the proposed activities affect the permittees? 

• Prescribed fire treatments would have the greatest impact on permittees because of the 

rest period needed after a pasture or allotment is burned. Permittees may have to rest 

pastures or allotments, reduce livestock herds, reduce the season of use, or a combination 

of two or more of these actions. Alternate grazing opportunities are scarce or non-existent 

and some permittees could experience severe economic impacts. They would have less 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 119

income because they cannot graze their cows and/or have to pay higher grazing fees to 

use alternate pastures. 

• Other activities would increase forage production and improve livestock distribution. In 

the long term, there could be a small increase in income. Treatments would also reduce 

the potential for an uncharacteristically severe wildfire. This would reduce the risk of loss 

or damage of forage and range infrastructure and death or injury to livestock. 

How would impacts on grazing be minimized? 

• The district range staff have been meeting and consulting with the permittees about the 

project and its potential impacts. This will continue throughout the planning and 

implementation phases. This is also being addressed through the design features and 

mitigation measures (see appendix A). These would minimize the amount of restoration 

treatments affecting an allotment at any given time.

Recreation 

The recreation specialist report (Harris 2013) is incorporated by reference. See the report for 

detailed information on data sources, methodology, assumptions, and limitations. The roads and 

engineering specialist report has more information on dust, noise, safety, and traffic. The social 

science, economics, and environmental justice specialist report has information on economic 

impacts related to recreation.

Affected Environment 

Recreation Use and Visitation

The Jemez Mountains are often called the “backyard of Albuquerque;” there are nearly 1 million 

people within 50 miles of the area. The nearness to a diverse and desirable outdoor recreation 

destination area attracts many types of recreationists. The project area has many developed 

recreations sites, and dispersed14 recreation areas (figure 27). The local demand for forest 

recreation is expected to grow in proportion to the growth of the Albuquerque metro area. 

An estimated 591,000-676,000 people visited the Jemez Ranger District in 2012. Holiday 

weekend visitation can increase dramatically. For example, on Memorial Day weekend in 2003, 

visitation was 163 percent above the average weekday (MRCOG 2006). The majority of forest 

recreation users travel New Mexico (NM) Highway 4 from the Albuquerque Metro area. Almost 

all of the Jemez Ranger District developed recreation sites are found along NM Highway 4 and 

126. The notable exception is Paliza Family and Group campgrounds, which are located off 

Forest Road 10 on the east side of the project area.

Recreational visits and activities vary by season. In early spring (April and May) there is a 

dramatic increase in day use hikers. Trailhead parking is full during weekends and mostly full 

during the week days. Forest roads are opened to the public in mid-April and visitors begin to use 

the dispersed camping areas. By early May the developed sites are open to the public and are 

busy throughout the summer months. Campgrounds and dispersed camping areas continue to be 

 

14 Dispersed recreation is recreating (camping, picnicking) away from developed sites. These areas usually 

do not have Forest Service facilities: picnic tables, a water supply, or toilets. Fees are not usually charged to 

use these sites.
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120 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

used during the fall big game hunting seasons. As winter approaches the most developed sites are 

winterized and closed. Forest roads typically close in early January and are used as cross country 

ski and snow mobile trails. 

Developed recreation sites are heavily used during the summer months, Memorial Day weekend 

through Labor Day. Use spikes on summer holidays (Memorial Day, July 4th and Labor Day) and 

on weekends in all developed recreation sites. Camping sites in San Antonio Campground can 

only be reserved online, and this campground is normally full throughout the summer. Vista 

Linda Campground is open year-round, and is mostly used during the spring and fall months. 

Figure 34. San Antonio Campground is one of the most popular campgrounds in 

the area.

Many forest recreation users prefer a more primitive recreational experience than the developed 

campgrounds and picnic areas provide. Motor vehicle dispersed recreation corridors are located 

along the major proposed transportation routes that would access implementation sites. Forest 

Road 376 goes through the most used motor vehicle dispersed recreation area in the project area 

and on the forest. An estimated 97,000-110,000 people travel on this road every year. Forest Road 

10 is another highly used motor vehicle recreation corridor; 93,000-107,000 people travel through 

and recreate along this road every year. Forest Road 10 provides primary access to other 

dispersed recreation areas along Forest Roads 266, 270, and 269.The dispersed camping corridor 

along Forest Road 144 serves as an overflow area for the Forest Road 376 recreation area when it 

is full 

The 10-mile East Fork Trail (Forest Trail 137) runs from Las Conchas to Battleship Rock Picnic 

Area receives high use from late April through October (figure 35). Segments of the trail parallel 

the East Fork Jemez Wild and Scenic River and users access the trail from several trailheads and 

the Jemez Falls Campground. Other trails within the project area receive minimal use throughout 

the season. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 121

Recreational Sites and Activities 

Several congressionally designated recreation areas are within the project area: the East Fork 

Jemez Wild and Scenic River, the Jemez National Recreation Area, and the Jemez Mountain Trail 

National Scenic Byway (figure 36). The Jemez National Recreation Area covers 57,650 acres, 

including about 9,400 acres of private lands. About 30 percent of the project area (32,900 acres) 

is within the national recreation area. The East Fork Jemez Wild and Scenic River corridor runs 

11 miles along the southern boundary of the Valles Caldera National Preserve. The Jemez 

Mountain Trail National Scenic Byway follows State Highways 4 and 126. State Highway 4 is 

also a popular one-day loop drive connecting Albuquerque with Los Alamos and Santa Fe and is 

the main access to the developed campgrounds, picnic areas, and trailheads. 

Figure 35. Aspen and ponderosa pine along the East Fork Jemez Trail. This is the 

most popular trail on the district. 

Except for one picnic area (Seven Springs) all of the developed15 recreational fee sites on the 

Jemez Ranger District are located within the project boundary. There are 6 campgrounds, 5 picnic 

sites, and 7 fishing sites. There are also 4 trailheads, a scenic overlook, and two hot springs site. 

Most developed sites are open April to October. Forest roads and motorized trails are open from 

mid-April through December.

People prefer to use areas along the rivers, streams, and recreation sites along State Highway 4 in 

the Jemez National Recreation Area. The Jemez River and East Fork Jemez River corridors have 

long been a recreation destination for visitors from the region and from around the country. Other 

streams and rivers located within the national recreation area include San Antonio River, and Rio 

Cebolla in the Forest Road 376 dispersed recreation corridor. 

 

15 Developed recreation sites have Forest Service facilities such as picnic tables, a water supply, and toilets. 

Fees are usually charged to use these sites.
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122 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Local users focus their recreation activities around family gatherings where there is water. This 

means camping and picnicking along or near rivers and streams. Other popular activities are 

hiking, fishing, photography and sightseeing. Riding motorcycles and all-terrain vehicles (ATV) 

on forest roads and motorized trails is popular. The mesas, especially Virgin Mesa, are favorite 

areas for motorcycle and ATV riding. 

In the winter, popular activities include cross-country skiing, snowmobiling, snowshoeing, and 

family snow play days. Forest Road 144, when snow-covered, is used extensively for 

snowmobiling and cross-country skiing. The Los Griegos cross-country ski touring area is 

another popular winter destination. Most snow play occurs near the highways, where families can 

be closer to their vehicles. 

Hunting is a popular activity in the fall. Most hunters set up camps in dispersed recreation areas 

along Forest Roads 144 and 376. Jemez Falls Campground is the only developed site open during 

the hunting season. Hunters with permits for the Valles Caldera National Preserve game units also 

camp in the area because camping is not allowed on the Preserve.

Recreation Opportunity Spectrum

The Recreation Opportunity Spectrum (ROS) classifies a range of outdoor recreation settings, 

activities, and opportunities from those with a very high probability of solitude, self-reliance, risk, 

and challenges, to a very social experience where self-reliance, challenge, and risk are relatively 

unimportant. Four of the six ROS settings are found in the project area: Roaded Natural (49,815 

acres); Semi-Primitive Motorized (48,670 acres); Semi-Primitive Non-Motorized (384 acres) and 

Rural (10,057acres) (figure 37). The Roaded Natural and Semi-Primitive Motorized ROS settings 

comprise approximately 90 percent of the project area.

Methods 

Information from the National Visitor Use Monitoring surveys (USFS 2012c) and traffic counts 

from the New Mexico Department of Transportation (2013) were used to estimate the number of 

visitors to the area. Information on the type and frequency of recreation activities was provided 

by the Statewide Comprehensive Outdoor Recreation Plan (New Mexico State Parks 2009). 

Information on recreation site use and fee revenues comes from Jemez Ranger District records 

(SNF 2012b) and was used to estimate monthly use at developed fee sites.

Analysis Questions

The main purpose of the project is to create forest resiliency to catastrophic wildfire and improve 

ecosystem processes. The purpose and need does not directly address recreation. One comment 

from the public involvement effort addressed recreational opportunities and concerns: 

displacement of hunters and hunting camps from dispersed recreation areas. Because there were 

few comments related to recreation, we used forest plan direction and the possibility of creating 

positive recreation opportunities and experiences to develop the analysis questions: 

• Are proposed project treatments consistent with the direction for recreation in the Santa 

Fe National Forest Land and Resource Management Plan (1987, as amended)? 

• Would project treatments disrupt or displace recreational visitors? 

• Would implementation activities enhance the variety and range of recreation 

opportunities and settings after the project is completed? 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 123

Figure 36. Locations of developed recreation areas and roads. Most of the developed sites are along 

the Jemez River and Highway 4.
Chapter 3. Affected Environment and Environmental Consequences

124 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 37. Recreation Opportunity Spectrum Settings. Most of the area is classified as Roaded 

Natural or Semi-Primitive Motorized.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 125

Summary of Effects 

Alternatives 1, 3, 4, and 5

Impacts from project activities include increased dust and noise from vehicles and equipment use, 

temporary closures of recreation areas and roads, increased traffic on highways and forest roads, 

and smoke from prescribed fires. These would disrupt recreation opportunities and displace 

visitors. These effects are short term and the degree of disruption to recreation site users would 

vary, depending on time of year, and the location, timing, and intensity of treatments. Increased 

traffic on roads and smoke could affect public health and safety. There would be fewer impacts 

from smoke under alternative 4. 

Alternative 2

There would be fewer impacts on recreational users and opportunities under alternative 2. 

Without the treatments, the risk of accidents from falling trees and snags and woody debris on the 

forest floor would increase in dispersed areas and along trails. Some recreation opportunities and 

experiences may become more limited as forest conditions decline.

Environmental Consequences 

Effects Common to Alternatives 1, 3, and 4, and 5

Developed Recreation Sites 

There would be an increase in traffic and road noise from logging trucks and other vehicles used 

to implement the restoration treatments16. Heavy equipment (logging trucks, skidders, bulldozers) 

traveling on the highways would likely cause traffic to slow down. Vehicle noise would be 

audible in campgrounds and picnic areas located adjacent to the transport routes. 

Noise and dust from mechanical treatments taking place next to developed recreation sites during 

the summer months when concentrated use occurs would have a greater impact on visitors. Use of 

tree harvesting equipment, vehicles, and related traffic at staging areas close to developed 

recreation sites would disrupt recreational experiences.

Traffic noise may disrupt the experience of people staying in campgrounds and picnic areas along 

Highways 4 and 126. Evening and night traffic from log trucks and project equipment would be 

light. But traffic noise from evening and night travel would have a greater impact on campers 

because visitors are in the campgrounds at this time. Daytime travel may have fewer impacts 

because many campers are elsewhere during the day. Picnic area users, however, would be more 

affected during the day because these sites are only open during the daytime. 

People camping, fishing, or picnicking at the developed recreation sites along the lower Jemez 

River would not be affected by traffic noise because there are no proposed mechanical treatment 

and prescribed fire sites within Lower San Diego Canyon. People recreating at Vista Linda 

Campground, Spanish Queen Picnic Area, and several fishing access sites might be affected by 

additional traffic noise from project equipment and logging and gravel trucks using Highway 4. 

Dust and traffic noise from project vehicles should not impact people using the Jemez Falls 

Recreational Complex because these sites are well off the highway. 

 

16 An estimated 12, log truck round trips per day may be associated with mechanical treatments, according 

to the roads and engineering specialist report.
Chapter 3. Affected Environment and Environmental Consequences

126 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Project vehicles using Forest Roads 604 and 376 to Virgin Mesa and areas north of La Cueva 

would pass by San Antonio Campground and La Cueva Picnic Area. Vehicles going to treatments 

sites on the east side of the project area would likely use Forest Road 10, which goes through the 

community of Ponderosa and passes directly by the Paliza Family Campground. Numerous side 

roads lead to specific treatment sites. Dust from passing truck traffic would affect campers at the 

Paliza Family Campground because it is close to Forest Road 10. Activities at nearby treatment 

sites might also affect campground visitors with traffic noise. No traffic related impacts are 

expected at the Paliza Group Campground because it is set well off the road. 

Effects from noise and dust would be short term and would vanish when treatments are 

completed. These impacts would be incremental to existing issues with road dust and noise, 

especially along the Forest Road 376 dispersed recreation corridor. 

Dispersed Camping Corridors and Hiking Trails

There are 22 miles of motorized dispersed camping corridors located along Forest Roads 376, 

604, 144, and 10. These are also popular roads for ATV and motorcycle riders. These roads would 

also be the main access roads to treatment sites. Visitors camping in these corridors or riding on 

the road would be impacted by trucks and other vehicles traveling to and from treatment sites. 

Traffic noise and road dust would impact people recreating in the motor vehicle dispersed 

recreation corridors along Forest Roads 376, 604, 144, and 10. These effects would be short term, 

perhaps lasting as long as 15 minutes while the dust settles, but could happen several times per 

day.

People who want to camp on Virgin Mesa during the summer would be displaced because these 

areas would be closed to camping while the mechanical treatments and other project activities are 

taking place. Most of these treatments would take place during the summer months, but hunters 

may also be displaced during the spring and fall. 

Hunters may be displaced from their traditional camping sites by treatment activities. They would 

need to find a different place to camp or stay in a developed campground. Hunters camping along 

Virgin Mesa (Forest Road 604) are most likely to be displaced. There are not many treatments 

planned in the motorized dispersed camping and big game retrieval corridor along Forest Road 

144 and users would probably not be displaced. On the east side of the project area displacement 

can be expected in the area around the junction of Forest Road 266 and Forest Road 137. 

The East Fork Trail (Forest Trail 137) is the most highly used hiking trail in the project area. 

Project treatments would have short-term impacts on hikers using that trail. Noise from 

mechanical treatments (vehicles, chainsaws) would lower the quality of the expected experience; 

hikers would not be able to hear the sounds of nature, such as bird songs, running water, or 

rustling leaves. As treatments are completed, the open forest conditions may be more desirable for 

dispersed recreation use, thus expanding the dispersed recreation opportunities. 

Other Recreation Uses

Some visitors to the forest and project area have a more passive recreation experience; they drive 

for pleasure, view wildlife or simply relax and get away from the Albuquerque heat for a couple 

of hours. Many people drive the Jemez Mountains Trail National Scenic Byway loop. Projectrelated truck traffic would add more vehicles to the highways and forest roads. This extra traffic 

may affect the driving or riding experience. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 127

Temporary roads would provide additional motor vehicle access into the forest. The additional 

access would not be consistent with the Travel Management Decision. Temporary gates to restrict 

public access or active patrolling might mitigate public access issues and provide for greater 

public safety. 

The open forest conditions resulting from mechanical treatments would improve seasonal 

recreation activities and have beneficial effects. The driving and sightseeing experience would be 

enhanced by the open viewsheds and scenery. Cross-country skiing and other winter recreation 

would be enhanced by easier access and travel. Wildlife would be easier to view and photograph 

in open forest areas. Hunting would also be enhanced by easier foot travel through forested areas. 

All Activities

Longer term beneficial effects include a reduced risk of wildfire and the creation or enhancement 

of current forest recreation opportunities such as winter recreation, hiking, and camping. Wildlife 

habitat improvement projects would enhance hunting and fishing opportunities. 

Prescribed fire smoke may reduce visibility as it is transported down drainages and could possibly 

cause respiratory issues to some recreational users. Smoke would have fewer effects on users of 

developed sites because burning would occur in the spring and fall when few recreation users are 

present in the project area and developed sites are closed. Smoke would affect people using the 

area in the off-season. These impacts would be short term. Please see the air quality specialist 

report for more information on smoke impacts. 

Alternative 2 

Over the short term, there would be much less disturbance to the recreational user. Benefits from 

the treatments would not occur. The risk of accidents from falling trees and snags and woody 

debris on the forest floor would increase in dispersed areas and along trails. Some recreation 

opportunities and experiences may become more limited as forest conditions decline. 

If an uncharacteristically severe wildfire occurred, recreational activities could be adversely 

impacted. Large areas of the district could be closed to public access after a wildfire and would 

displace dispersed campers, hunters, and day use visitors. The trail system, developed sites, and 

dispersed camping sites could be damaged or destroyed by a wildfire and/or post-fire flooding. In 

the short term, the dispersed sites may be lost due to post-fire flooding. Depending upon the 

severity and extent of the wildfire, nearly all recreational activities would be greatly affected for 

many years after the event. For example, large parts of the district were closed after the Las 

Conchas fire in 2011. Although the closure order has been lifted, recreation use has not recovered 

to pre-fire levels. 

Alternative 3

Temporary roads would not be built under this alternative, and 1,900 acres would not receive 

mechanical treatments. This may have positive impacts on forest recreation. This would eliminate 

the opportunity for additional unauthorized motor vehicle access routes into the forest and limit 

potential recreation user conflicts. It would also limit unauthorized use under the Travel 

Management Decision. There would be no effects on recreation because the untreated areas are 

located in remote areas away from existing roads and removed from most forest recreation 

opportunities. Other effects, such as noise, dust, displacement, and enhanced recreation 

opportunities, would be the same as those described for alternative 1. 
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128 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Alternative 4

Prescribed fire treatments would be implemented on approximately 31,600 fewer acres than 

under the proposed action. This would reduce the total amounts of smoke by one-third over the 

life of the project. Smoke impacts on off-season recreationists would be reduced as compared to 

other alternatives. 

Slash from mechanical treatments would be masticated, chipped, or lopped and scattered and left 

on the forest floor instead of burned. There would be more woody debris and fuel on the forest 

floor. These areas would be more susceptible to wildfire and the debris and slash would limit 

recreation user access and safety in these areas. Other effects from the treatments would be the 

same as those described for alternative 1. 

Alternative 5

Approximately 700 fewer acres would be treated with prescribed fire under this alternative. The 

reduction in smoke would not be noticeable. The effects from smoke would be the same as 

described for alternative 1. Under this alternative, more acres are treated in Mexican spotted owl 

restricted habitat. These areas are remote and the additional noise, dust, and duration of 

treatments are insignificant and would not affect recreational use or recreationists. The diameter 

cap would also have no impacts on forest recreation. Other effects from the treatments would be 

the same as those described for alternative 1. 

Forest Plan Amendments

All of the proposed site-specific forest plan amendments would be needed for alternatives 1, 3, 

and 4. The proposed plan amendments would have no effect on sustainable forest recreation in 

the project area. 

Alternatives 1, 3, and 4

The amendments regarding treatments in Mexican spotted owl habitat would have no effect 

because most protected activity centers are not located near any developed recreation sites. One 

protected activity center is located along a motor vehicle dispersed recreation corridor, but there 

would be no effect because no implementation is proposed in that corridor. 

Alternatives 1, 3, 4, and 5

The amendments related to interspaces in goshawk habitat and conducting surveys in peregrine 

falcon areas would have no effects on recreation use or activities. There would be no effects from

forest plan amendments related to northern goshawk or peregrine falcon because these raptors 

coexist with developed and dispersed sites and areas. 

The amendments allowing activities to occur during wildlife breeding seasons may increase noise 

disturbances to visitors depending on time of year. 

The amendment regarding changing the Visual Quality Objective to “High” would not change 

how recreation is managed within the project area.

Cumulative Effects 

Cumulative consider the interaction of effects from the project activities and foreseeable impacts 

from other planned and unplanned activities in the project(see appendix B for past and planned 

projects). 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 129

Over the last 20 years, numerous wildfires have affected forest recreation in the project area. 

These fires have displaced and closed areas to forest recreation, both in developed sites and 

dispersed areas. Fire restrictions and closures in early summer months range from campfire 

prohibitions to forest closure to any public entry. Prescribed fires have temporarily closed areas to 

recreation use, however prescribed fire treatments are scheduled only when wildfire risk is low in 

the late fall and early spring when few recreation users are on the forest. Prescribed fire would 

open the forest understory and clean the forest floor, which positively impacts recreational user 

access during all seasons for years to come.

Completed projects have benefited and improved forest recreation facilities and experiences. 

Mechanical treatments next to developed recreation sites (e.g., Jemez Falls, Paliza Family and 

Redondo Campgrounds) have reduced the risk of campfire caused fires while improving scenery 

and forest access. Trail bridges on the East Fork Trail and over the San Antonio River keeps 

hikers dry while maintaining the integrity of the stream bottoms. Parking areas at Spence and San 

Antonio Hot Springs have benefited the public by providing structured parking and trailhead 

information to the springs. Moving parking areas away from riparian and streams improves water 

quality. Rehabilitating back country camping sites along the rivers enhances hiker experiences 

while keeping sediment from entering the streams. Range allotment fences keep livestock away 

from campgrounds and picnic areas. 

Cumulative effects on forest recreation would be mostly positive and beneficial. Implementation 

of restoration treatments on the Preserve, adjacent forest lands, and Jemez Pueblo would reduce 

the risk of high-severity wildfire and/or insect outbreaks which would reduce the likelihood of 

summer time forest closures to the public. 

Conclusions about the Effects 

This section answers the analysis questions and how well the alternatives address the purpose and 

need and the relevant issues. 

Are proposed project treatments consistent with the direction for recreation in the Santa Fe 

National Forest Land and Resource Management Plan (1987, as amended)? 

• Proposed treatment activities would be consistent with recreation management under the 

ROS classification across the project area. The Roaded Natural and Semi-Primitive 

Motorized ROS settings comprise approximately 90 percent of the project area and 

proposed implementation treatments would be in short term and mostly consistent with 

the values associated with each setting. There are approximately 300 acres of mechanical 

treatments proposed in the Semi Primitive Non-Motorized ROS setting in the in the East 

Fork Jemez Wild and Scenic River; motor vehicles are not permitted in that setting. Noise 

from mechanical treatments would possibly conflict with the recreational experience 

values, but this would be a short-term effect. Effects from treatments are similar under all 

action alternatives. 

Would treatment activities disrupt or displace recreational visitors? 

• Project activities would disrupt recreation opportunities and displace visitors under all 

action alternatives (1, 3, 4, and 5). Equipment noise and dust from mechanical treatments 

taking place next to developed recreation sites would have greater impacts during the 

summer, when recreation use is heaviest. These effects are short term and the degree of 
Chapter 3. Affected Environment and Environmental Consequences

130 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

disruption to recreation site users would vary, based on the specific location of treatment 

sites, timing of activities, and intensity of treatments. Activities taking place during the 

summer (Memorial Day to Labor Day) would have greater effects on the recreating 

public because this is when the most people are visiting and recreating in the area. Fewer 

visitors would be affected at other times of the year. For example, mechanical treatments 

occurring close to developed recreation sites would have a greater impact during the 

summer when these facilities are heavily used. The time of traffic activity is important; 

traffic noise between 6 p.m. and 7 a.m. would have a greater impact on overnight 

campers. 

• Some dispersed recreation areas and corridors and forest roads may be closed for public 

safety while treatments are being implemented. Displaced recreationists would have to go 

somewhere else on the district or go to another area. Traffic and other transportation 

related impacts would be incremental to existing conditions and would affect both 

developed and dispersed recreation users. Currently, road dust is a nuisance and 

congestion on forest roads and vehicle accidents are an issue on holidays and summer 

weekends. 

• Effects from smoke would be short term and limited, as most prescribed fire treatments 

would be done in the off-season when developed sites are closed and fewer recreation 

users are on the forest. 

Would treatment activities enhance the variety and range of recreation opportunities and settings 

after the project is completed?

• As treatments are completed the open forest conditions may be more desirable for 

dispersed recreation use, thus expanding the dispersed recreation opportunities. 

• Forest recreation opportunities and experiences would be enhanced. Wildlife habitat and 

stream treatments would improve fishing, hunting, and wildlife viewing opportunities. 

Treatments that reduce fire hazard would reduce the likelihood of forest closures during 

the summer. A more open forest would improve seasonal recreation. Cross-country 

skiing, snowshoeing, and other winter recreation would be enhanced by easier access and 

travel through less dense forested areas. 

• Long-term effects would be beneficial and positive. Reducing the fire hazard would result 

in fewer forest closures and other disruptions to recreation use during the summer season. 

A more open forest with openings and edge habitat would improve scenic quality, 

wildlife viewing, hunting, and winter recreational activities. Aquatic habitat and 

watershed treatments would enhance fishing and streamside recreation. 

• Although short-term impacts would occur there would be other unaffected recreation sites 

and opportunities in the area that the public may use. Most impacts related to noise and 

fugitive dust in motor vehicle dispersed recreation corridors would be incremental to 

existing conditions. Road dust from unpaved forest roads already is a nuisance and 

inconvenience many dispersed recreational users. Forest road congestion and vehicle 

accidents are an issue on summer holidays and weekends.

Roads and Engineering 

The roads and engineering specialist report (Holliday 2013) is incorporated by reference. See the 

report for detailed information on data sources, methodology, assumptions, and limitations.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 131

Affected Environment 

The Existing Road System

There is a well-established road system in the project area. Figure 38 shows the roads in the area 

needed for project activities. The road density is high, averaging 3 to 6 miles of road per square 

mile in some areas. This is well above the forest plan standard of 2 to 3 miles of road per square 

mile. Some of these are user-created roads, made when people drive a vehicle off the main road to 

get to a campsite, hunting spot, or other place. These user-created roads are not maintained and 

are in poor condition. Most of the forest system roads are in fair to poor condition especially at 

stream crossings and some have severe impacts on riparian areas and water quality. There are no 

open or active gravel pits in the area. There are a few closed pits on forest land that could be 

reopened and there also some areas with suitable rock where we could build new pits. 

Traffic

Traffic counts are ongoing17. Currently, traffic on most forest roads in the area is low. Table 20 

lists the annual average daily traffic for some of the major forest roads in the project area. We use 

traffic counts to rank the roads from busiest to least busy. Forest Road 376 is the busiest road in 

the project area and on the entire forest. This is a very popular recreation area and traffic on forest 

roads and state highways is heaviest on the weekends, as described in the recreation section of 

this chapter. 

Table 20. Traffic on forest roads in the project area

Road

Number

Location of Traffic Counter Average 

Annual

Daily Traffic

376 Before tunnels 581

376 After tunnels 207

376 Porter Landing 193

10 Before Paliza Campground 185

10 Above Paliza Campground 35-50

604 Beginning of road 50

Impacts of Roads on Resources in the Project Area

The high road density and poor road conditions are impacting forest resources. The high density 

of roads lowers the quality of wildlife habitat and disturbs wildlife. Some roads go through 

sensitive breeding and nesting habitat. Other roads go through or near cultural resource sites. 

These sites are damaged when vehicles drive over or next to them and by erosion runoff from 

roads. Sediment from road erosion gets into streams and impacts fish habitat and water quality. 

Roads facilitate the spread of nonnative and invasive plant species; vehicles carry and spread 

seeds around the area. The wildlife, cultural resources, and nonnative invasive plants sections of 

this chapter have more details on the adverse impacts of roads on these resources.

 

17 The recreation specialist report also has information on traffic counts. In that report, traffic counts are 

measured in vehicles per day.
Chapter 3. Affected Environment and Environmental Consequences

132 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 38. Roads in the project area that would be used to access treatment sites.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 133

Methods Used to Analyze Effects from Road Treatments 

We looked at the road system using field visits and observations, maps produced from the forest 

Geographic Information System (GIS) database, the Infra database18 (USFS 2010a), personal 

consultation with other forest employees who are familiar with the area, and professional 

judgment based on past experience. The coverage count method19 was used to calculate the 

annual average daily traffic amount of traffic on forest roads. 

Analysis Questions

The analysis questions were derived from the purpose and need and the issues that arose during 

scoping as described in chapter 1. The relevant analysis questions are: 

What are the effects of increased traffic on the human environment? 

Would impacts from roads on the environment be reduced by the road treatments? 

What are the effects on the environment of opening roads and building temporary roads? 

Summary of Effects 

Effects from roads, construction of temporary roads, and gravel pits on other resources are also 

discussed in these sections of chapter 3: cultural resources, nonnative and invasive plant species, 

recreation, scenery, soil and water resources, and wildlife, fish, and rare plants. 

Road treatments would occur under all alternatives, including the no action, as shown below. 

Table 21. Amount and type of road work, by alternative

Type of Treatment Alternatives 1, 4, and 5 Alternative 2 Alternative 3

Temporary roads built 12 miles 0 miles 0 miles

Roads re-opened, 

reconstructed if 

necessary, and then 

closed after use

20 miles 0 miles 11 miles

Roads re-opened, 

maintained, and then

closed after use

87 miles 0 miles 85 miles

Open roads maintained 242 miles 47 miles 242 miles

Roads decommissioned Up to 100 miles 2 miles Up to 100 miles

Effects from road maintenance include noise, dust, and increased traffic, which could disturb 

wildlife and forest visitors. The greatest increase in traffic would occur on Forest Roads 10, 376, 

and 604. These effects would be minor, localized, and short term under all alternatives. Other 

effects include soil disturbance and erosion. 

 

18 The Infra database is an inventory of constructed features (buildings, campgrounds, trails, etc.) and land 

units, and permits sold to the public and to partners.

19 To calculate traffic on a road, we count traffic for two weeks, take the 30th highest hour of traffic, and 

divide that by 0.14. The result is approximately equal to the annual average daily traffic.
Chapter 3. Affected Environment and Environmental Consequences

134 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Decommissioning roads would also have similar short-term, localized effects. Over the long term, 

adverse effects on wildlife, cultural resources, and water quality would be greatly reduced or 

disappear. These effects are similar for all alternatives. 

Effects from temporary road construction and use include noise, dust, and soil disturbance. These 

effects are the same under alternatives 1, 4, and 5. There are no effects under alternatives 2 and 3 

because temporary roads would not be built. 

The effects of gravel pit development include noise, dust, traffic, and soil disturbance. These 

effects are the same under all action alternatives. Gravel pits would not be built under alternative 

2, so there are no effects. 

All alternatives have the potential to increase the establishment and spread of nonnative and 

invasive plants. This potential is highest under alternatives 1, 4, and 5. It is slightly less under 

alternative 3 because no temporary roads would be built, and lowest under alternative 2 because a 

smaller area is being treated and there is less soil disturbance and vehicle traffic. 

Beneficial effects, such as reduced soil erosion, lower amounts of sediment in streams, and 

protection of cultural resources, would be highest under alternatives 1, 3, 4, and 5 and lowest 

under alternative 2 because fewer miles of road would treated and only 2 miles of road would be 

decommissioned under this alternative. See the soil and water resources section of this chapter for 

more on beneficial effects on water quality. 

Environmental Consequences

Effects Common to Alternatives (1, 4, and 5)

Changes in Traffic

Increases in traffic related to wood product removal are about the same under each of the action 

alternatives. It is slightly lower under alternative 3 because fewer acres are treated, but the 

difference is minor. 

Alternatives 1, 4, and 5 would generate approximately 12 round trips each day over the life of the 

project. Alternative 3 would generate approximately 11 round trips per day over the life of the 

project. The increase in traffic would occur in one unit of the project area. There would be no 

increase in traffic over most of the rest of the area. Noise and dust from the additional traffic 

would be localized in the area where project activities are occurring. 

The other restoration treatments would also generate additional traffic road use. Heavy equipment 

would be hauled in and out for the mechanical treatments, road work, and instream habitat work. 

People and equipment would be brought in for the prescribed fires. There would also be 

equipment doing road work and trucks hauling gravel to work sites. These trips are of short 

duration, lasting a few days to a week while the project activities are being implemented. 

Traffic would also increase on non-Forest Service roads. The heavy equipment and log trucks 

would travel on State Highways 4, 126, 290, or 485. Depending on where material is processed, 

some of this traffic would pass through Jemez Springs, Ponderosa, La Cueva, and Vallecitos de 

los Indios, and nearly all of it would pass through Jemez Pueblo and San Ysidro. The amount of 

additional traffic that would pass through these communities would depend on where the work is 

occurring and the destination of the vehicles. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 135

Noise, Dust, and Safety

Increased traffic, especially from the larger, heavier vehicles used for treatments, would increase 

noise and dust. The effects from noise and dust are expected to be minor, and would not be 

confined to one area. Noise and dust from the additional road use would be in the area where 

project activities are occurring and would be scattered over the project area over the life of the 

project. As a result, these impacts would not be excessive in any one area.

The amount of noise would depend on the number of and type of vehicles; eighteen-wheelers are

louder than pick-up trucks. Most of the mechanical treatments are along or near Forest Roads 10, 

376, and 604. People living and recreating in those areas would hear more noise. The noise of a 

passing truck may be noticeable for a few minutes, and would be about as loud as an airplane or 

an ATV. The ATV might even be louder than the logging truck (Grubb et al. 201220) 

The heavy equipment and vehicles traveling on dirt roads could raise a lot of dust, depending on 

the road surface and condition. Dust created by vehicle traffic would not travel far, but could 

settle in recreation sites and residential areas adjacent to the road. The amount of dust from the 

project is expected to be minor, localized, and of short duration. Dust would reduce visibility, 

which could result in accidents. The areas along roads 376 and 10 are popular camping areas and 

people using those areas would potentially experience more problems with dust. 

Public safety may be affected by dust and heavy equipment traveling on forest roads. There is 

heavy truck traffic on the highway now. Although not operating now, pumice mines operated 

along Forest Road 10 for many years. The pumice trucks hauled along the state highways without 

any accidents. In areas where treatments are occurring, signs would warn visitors about the heavy 

truck traffic. Hauling would not take place on weekends during the high recreation use season 

(Memorial Day to Labor Day). This would minimize noise, dust, and safety concerns in high 

recreation use areas near treatment areas. Other design features and mitigation measures 

(appendix A) would also limit the impacts of noise, dust, and traffic. 

Road Maintenance 

Cleaning road drainage structures- culverts and lead-out ditches- would allow water to flow more 

easily in the designed runoff channels. This would reduce soil erosion and reduce the amount of 

sediment in streams. Removing hazard trees that might fall on the road or trees that reduce sight 

distance for drivers would improve safety. These road maintenance activities would also create 

noise, dust, and traffic with effects as discussed above. 

Opening Roads

Some roads are currently closed to public use, but we would open them to implement project 

activities. The extent of work needed to open a road would depend on how it was closed and how 

long it has been closed. Some roads may only require removal of berms, rocks, or other barriers, 

while others would require extensive work, similar to heavy road maintenance. Roads would be 

maintained during use and then closed after activities are completed. During the process of re-

 

20 Grubb et al. 2012 is a study looking at the effects of logging truck noise on northern goshawks. The 

paper contains a table showing noise, measured in decibels, of various types of vehicles. Road maintenance 

equipment- 100 decibels; ATVs- 90-100 decibels. In the study, empty logging trucks on a dirt road ranged 

from 55-67 decibels; aircraft flying overhead, 59-68 decibels.
Chapter 3. Affected Environment and Environmental Consequences

136 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

opening these roads, culverts would be cleaned and drainage problems would be corrected. This 

would reduce impacts on other resources. 

Re-opening and using these roads would create more noise and dust while activities are being 

carried out. These effects are discussed above. The opening and closing of these roads will be 

defined in detail by contract specifications with the objective of minimizing impacts on soil and 

water, wildlife, recreation and cultural resources. 

Decommissioning Roads

The effects from this activity would be different depending on what we do to decommission a 

road: removing the road and re-grading it, or leaving it alone and letting it revegetate naturally, or 

installing barriers. 

Removing the road and re-grading it would have effects similar to road construction. The heavy 

equipment would create noise and dust. Ground disturbance could lead to erosion and create 

opportunities for invasive plant species to spread. The effects from noise and dust are similar to 

those talked about previously. Effects of road decommissioning on other resources are discussed 

throughout this chapter.

Temporary Roads

A temporary road is a road authorized by contract, permit, lease, or other written authorization 

that is not a forest system road and that is not included in a forest transportation atlas. Temporary 

roads for the stewardship contract will be constructed by the contractor at their cost. Temporary 

roads would be short spurs, generally no longer than 0.4 miles. These roads would be adequate 

for logging equipment and trucks to get from treatment sites to a landing or main road. They 

would not be suitable for passenger cars. Temporary roads would be decommissioned after use.

Construction and use of temporary roads would increase noise and dust as discussed above. 

Impacts on public safety would not occur because the temporary roads would not be open to 

public use and would not be suitable for passenger cars. No temporary roads would be built under 

alternatives 2 and 3, so there would be no effects from temporary roads under these alternatives. 

Construction of these roads and the decommissioning of these roads will be defined in detail by 

contract specifications with the objective of minimizing impacts on soil and water, wildlife, 

recreation and cultural resources.

Gravel Pits

The sites for the gravel pits have not yet been located, but they will likely be on the western side 

of the project area. The rock in that area is of good enough quality to use on the roads. The 

pumice rock found along Forest Road 10 is not good for road work because it breaks apart easily. 

Newly constructed pits would not be located in the inventoried roadless areas, the Jemez Wild 

and Scenic River Corridor, the Jemez National Recreation Area, the Monument Canyon Research 

Natural Area, Management Area I, Mexican spotted owl protected activity centers, Jemez 

Mountains salamander critical habitat, areas with a Visual Quality Objective level of Retention or 

Partial Retention.

Effects from the construction of gravel pits and access roads include dust, noise, and ground 

disturbance, displacement of wildlife, changes to natural drainage patterns, and changes in the 

visual landscape. Ground disturbance is the most serious. Each pit would be up to 5 acres in size 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 137

and would have an access road. Vegetation would be cleared from the site, and surface dirt would 

be removed from the rock source. Using gravel from Forest Service gravel pits would allow us to 

provide a better road surface, and we could do more miles of road maintenance for less cost. We 

could also improve more miles of road. The improved road surfaces would result in fewer 

impacts on soil and water resources. Surfacing the roads with gravel would reduce the need for 

future maintenance, and would reduce adverse effects on water quality for a longer time. 

Explosives would be used to break up the rock, and the blasting would generate noise and dust for 

a short period of time. The blast itself would create noise lasting a short time. Rock crushers 

would also create noise and dust. 

Figure 39.Gravel does not last forever. To keep 

gravel roads in good condition we need to 

regularly replace the gravel as we’re doing with 

this road.

The noise would disturb wildlife as well as any forest visitors in the area. Effects from noise and 

dust would be short term, localized, and minor, as discussed previously. Because these gravel pits 

are not commercial gravel pits, the rock blasting and crushing would happen on an irregular, asneeded basis. 

Blasting and crushing would affect public safety, but these would be minimized by the design 

features. The roads to the gravel pits would be adequate for construction equipment, but not 

passenger cars. Access roads to the pits would not be maintained in good condition to discourage 

public use. Access roads would not be open to the public. 

Gravel pits would not compete with commercial gravel pits in the area. Our gravel pits are 

intended for use on the forest only. They would also be small and because of their remote 

locations, hauling to and from the pits would be inconvenient for new commercial operators. 

The effects of constructing gravel pits and access roads on other resources are discussed 

throughout this chapter. Design features and rehabilitation measures for gravel pits are found in 

appendix A.

Alternative 2

Under the no action alternative, we would not build any gravel pits or access roads, or temporary 

roads. We would not decommission roads, other than the 2 miles with approved NEPA decisions. 
Chapter 3. Affected Environment and Environmental Consequences

138 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The remaining roads would continue to deteriorate and have adverse effects on water quality and 

cultural resource sites. We would continue to do road maintenance within the project area, 

although fewer miles would be maintained than under the action alternatives (see table 21). This 

maintenance would have the same noise and dust effects we described earlier in this section. 

Road use and traffic would be about the same as it is currently. 

Alternative 3

The effects from increased road use, road maintenance, opening of roads, and gravel pits would 

be the same as those described for alternatives 1, 4, and 5. Impacts from roads would be slightly 

higher because fewer miles of road would be maintained and fewer miles of road would be reopened (see table 21). There would be no effects from temporary roads because they would not be 

built under this alternative.

Cumulative Effects 

Roads closed with the implementation of the forest travel management decision along with the 

roads closed after treatments are finished would reduce open road density. The forest designated 

motor vehicle use on the forest and traffic did not change. 

Conclusion of Effects 

In this section, we answer the analysis questions to see how well the road activities address the 

issues, concerns, and purpose and need. 

What are the effects of increased traffic on the human environment? 

• There would be increases in noise, dust, and traffic along forest roads from project 

vehicles, road treatments, and heavy trucks. These are effects would be localized and 

temporary. 

Would impacts from roads on the environment be reduced by the road treatments? 

• Yes. Decommissioning roads would have the greatest impact. The roads we selected for 

decommissioning were prioritized by the impacts they have on wildlife and habitat, water 

quality, and cultural resources. We would decommission the worst roads first. If we do 

not decommission the entire amount of roads we hope to do, we would still reduce 

impacts on these important resources. 

• Maintenance and road surfacing with rock provided by the rock pits would also reduce 

road-related impacts on water quality.

What are the effects on the environment of opening roads and building temporary roads? 

• See the other resource sections of this chapter for more information on the extent of 

effects from temporary roads on soil and water resources, cultural resources, and wildlife. 

Effects from opening roads and building of temporary roads include small increases in 

dust, and noise. Effects are limited because temporary roads would be decommissioned 

after use and the re-opened roads would be closed.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 139

Scenery 

The scenery specialist report (Bueno 2013) is incorporated by reference. See the report for 

detailed information on data sources, methodology, assumptions, and limitations. 

Affected Environment 

The landscape character describes the aesthetic, social and biophysical features that give the place 

its identity. The Jemez Mountains have a variety of dramatic landscapes from meadows and deep 

valleys to sheer cliffs with breathtaking views. The scenic character is a natural-appearing 

landscape of mountains with rounded and smoothed crests, flat-topped mesas, and steep canyons. 

Elevations range from 5,500 feet in the valleys to 10,109 feet at the top of Cerro Pelado. 

Landslides and exposed rock formations are common features. Geologic activity continues to 

change the landscape. 

Ponderosa pine and dry mixed conifer forests dominate the lower mountain slopes. Wet mixed 

conifer and spruce-fir forests are found on the upper mountain slopes. Aspen and mountain 

meadow grasslands are also found here. Piñon-juniper woodland, riparian, sagebrush and chamisa 

(rabbitbrush) dominate the lower elevations.

The area has several moderately-sized perennial (year-round) streams and rivers. The Jemez 

River flows through the middle of the project area. Other waterways include San Antonio Creek, 

Rio Guadalupe, and Rio Cebolla. The wet meadows found within the project area are also highly 

valued scenery attributes. 

The Jemez Mountains are highly valued for scenery and recreation. There are numerous meadow 

corridors, areas that are typically considered rare and treasured landscapes in New Mexico. The 

East Fork of the Jemez River is a nationally designated Wild and Scenic River with outstanding 

and remarkable scenery. Hot and warm springs are found throughout the Jemez Mountains and 

are popular cultural and recreation destinations.

Currently, there are limited views and little vegetative diversity because of the dense, even-aged, 

forests with closed canopies. The forests have lost their diversity because of past logging and fire 

suppression. There are too many small and mid-size trees and not enough mature and old-growth 

trees and a sparse surface cover of grass. There are fewer aspen groves and mountain meadows as 

a result of fire suppression. 

The current landscape has a very low scenic stability or resilience to changes caused by 

ecological disturbances or stressors. These stressors include drought, increased stand density, 

uncharacteristically severe wildfire, and intensive recreational use. Some of the main scenery 

features such as the mountains, mesas, and canyons are likely to be unchanged by stressors. Other 

features, including large trees, meadows, and forests, may be seriously affected.

The existing scenic integrity21, the intactness or completeness of the landscape, as seen from the 

most sensitive areas ranges from Moderate to High, which does not quite meet the Scenic 

 

21 Scenic integrity is a measure of visual quality. It is the degree to which the landscape is seen by the 

viewer as complete. Landscapes with a high scenic integrity have all or most of the landscape features 

valued by people who live in and/or use the area.
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140 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Integrity Objective of High. Although the scenic character has changed from its historical 

condition, the changes are not generally noticed by most visitors. Within the Jemez National 

Recreation Area (NRA, Management Area X), the existing scenic integrity ranges from Moderate 

to High. Outside of the Jemez NRA, the existing scenic integrity tends to match the Visual 

Quality Objectives levels prescribed in the forest plan. Figure 40 shows these VQO and SIO 

levels within the project area.

Methods Used to Analyze Effects 

The forest plan was written when scenery was managed under the Visual Management System 

(VMS) (USFS 1974). Forestwide Visual Quality Objectives (VQOs) were established in the plan. 

The Jemez NRA and the Jemez Wild and Scenic River management plans use the updated 

Scenery Management System (SMS), which establishes Scenic Integrity Objectives (SIOs). The 

forest plan has not yet been revised to reflect this change. To maintain consistency with the forest 

plan, the term VQO is used throughout this report. Visual quality and scenic integrity are 

measured by levels that described the degree to which the landscape appears intact, complete, and 

natural. The levels of each system are generally used interchangeably, including in this analysis. 

The visibility of the effects from the proposed action and the alternatives were determined using 

field visits, photos, geographical information system (GIS) data, digital elevation models (DEMs) 

from the Santa Fe National Forest and from Google Earth, and simulations in Adobe Photoshop 

and Illustrator. A visual inventory was conducted by a landscape architect specializing in visual 

resources assessment. The visual inventory identified and mapped visually sensitive areas, 

viewsheds, key viewpoints, and their sensitivity or concern levels. 

Sensitivity or concern levels measure the degree of public importance placed on views of the 

landscape (figure 41). There are three levels of sensitivity, and level 1 is the most important. It is 

associated with major roads, trails and areas of concentrated use, where users have a high degree 

of concern for scenery. Levels 2 and 3 are of progressively lesser importance. Views from the 

National Scenic Byway (State Highways 4 and 126), views from developed recreation areas 

within the Jemez National Recreation Area, views from concentrated recreation corridors (FR 10 

and FR 376) and views from access points within the South Fork Jemez Wild and Scenic River 

corridor are all Level 1 areas. Here, they are referred to as sensitive areas. Key viewpoints were 

chosen as representative views from these sensitive areas. The effects on scenery are analyzed 

from the viewpoints. There are 17 key viewpoints; most of them are located along Highway 4 and 

Highway 126. Others are located along Forest Roads 10 and 376. A map and table of the key 

viewpoints is found in the scenery specialist report. 

All areas within Management Area X have an SIO level of High, including the Monument 

Canyon Research Natural Area and The East Fork Jemez Wild and Scenic River (see figure 42). 

Other locations with a level of High are the Paliza Campground area in Management Areas S and 

R, and the San Antonio River area within Management Areas E and N. Other areas within the 

project boundary along drainages and slopes popular for dispersed recreation have a VQO of 

Moderate.

The more remote areas to the east have VQO of Low. The mesa tops, which are screened from 

most middle and background views, have a VQO of Very Low. Areas with missing scenery data 

were treated similarly to adjacent lands. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 141

Figure 40. Visual Quality Objective and Scenic Integrity Objectives levels in the project area. Scenic 

Integrity Objectives only apply to the Jemez National Recreation Area. Visual Quality Objectives 

apply to the rest of the project area.
Chapter 3. Affected Environment and Environmental Consequences

142 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 41. Sensitivity Level 1 areas, travelways and use areas are located along highways and major 

forest roads. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 143

The following indicators were used to measure the effects on scenery: (1) a description of 

changes to the natural landscape character, and (2) scenic integrity; the changes in the degree of 

apparent scenery intactness. Activities that lead to change from the natural landscape character, 

adversely impacting scenic integrity, would have a negative effect. Activities that do not change 

the landscape character would have a neutral effect. Activities that enhance scenery and fully 

express the landscape character, such as the opening of vistas and the reduction of undergrowth to 

improve depth of view into the forest, would have a beneficial effect. Short-term effects are those 

that last 1-5 years after implementation. Long-term effects are those that last 5-25 years after 

implementation.

Analysis Questions

The analysis questions were derived from the purpose and need and the issues that arose during 

scoping as described in Chapter 1. The purpose and need does not address scenery, but restoring 

ecosystems and increasing resiliency would benefit the scenic quality in the area. There were no 

scoping comments specific to scenery, but it was indirectly addressed in some of the comments 

about the scale of the mechanical treatments. People expressed concern that the forest landscape 

would change drastically and resemble a meadow. Others wanted more large trees on the 

landscape, mainly for wildlife habitat. Responses to these and related topics are in the scoping 

report in the project record. 

The relevant analysis questions are:

• Would there be negative effects on scenery, and to what extent would the landscape be 

free from visible disturbances during implementation of the project? 

• Would the scenic stability (the ability for scenery to be sustained over time), especially of 

the forested landscape, be maintained?

Summary of Effects 

Under alternatives 1, 3 and 4, there would be short-term, negative effects on scenery from 

mechanical treatments and prescribed fire. The effects include:

Mechanical treatments:

• Sights of slash, stumps, ground disturbance, woody debris piles, and skid trails 

• Temporary roads created during implementation would insert new, unnatural-appearing 

lines into the landscape on a temporary basis

• Trees would be removed, soil exposed, and roadbeds constructed 

• Existing vegetative screening of management activities or other disturbances such as 

roads would be decreased or eliminated 

Prescribed fire:

• Burn scars, a blackened understory, burnt soil, and dead and dying vegetation from low 

intensity prescribed fire. 

• Low intensity smoke, causing a temporary lack of visibility and obscuring of scenery. 

This type of smoke only occurs for the duration of the burn and dissipates into the 
Chapter 3. Affected Environment and Environmental Consequences

144 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

atmosphere, as opposed to smoke from a high-intensity wildfire, which can heavily 

impact air quality and landscape visibility for weeks and months. 

The effects from mechanical treatments would be most visible from the foreground (300 feet to 

1/2 mile) and middleground (1/2 to 4 miles) views. Steep topography would hide the effects when 

viewed from sensitive areas in valleys and canyon bottoms, but would highlight effects in 

middleground distances when seen from vista points and overlooks. Fence exclosures would be 

temporary and negative effects on scenery would be greatly reduced by following the design 

criteria and mitigation measures. 

The long-term effects on scenery would be beneficial. Having a more open tree canopy would 

improve the views into the forest and the views to the horizon. The diversity of species, texture, 

color and form would be increased, adding to the level of scenic integrity. While the area would 

appear quite open compared to current views, the area would maintain its forested character, and 

would not resemble a meadow. 

Treatments would improve the scenic stability of the area because the landscape would be more 

resilient to wildfire, disease and drought. The high level of stability would ensure that the scenic 

integrity would be preserved over time. 

The long and short-term effects of alternatives 3 and 4 are very similar to those of alternative 1, 

with some differences. Under alternative 3, there would be no effects from the construction of 

temporary roads and fewer effects associated with mechanical treatments. Under alternative 4, 

there would be fewer effects from prescribed fire treatments, but more negative effects from the 

sight of slash and woody debris. Under both alternatives, the potential for a severe wildfire would 

increase because of higher fuel loads in untreated areas. A severe fire would have long-term 

negative impacts on scenery. 

Design criteria and mitigation measures in appendix A would help to minimize the short-term, 

negative effects of the treatments for all alternatives 1, 3, and 4. 

Under alternative 2, most of these treatments would result in minimal improvements in scenic 

integrity. Scenic integrity would decline as ecosystem conditions decline, and the area would not 

meet forest plan scenery guidelines.

Environmental Consequences 

Alternative 1

The main treatments proposed are mechanical treatments and prescribed fire. These treatments 

would have short-term negative effects during and immediately following implementation: 

Scenic integrity in sensitivity level 1 areas would be negatively impacted during and immediately 

following implementation. The short-term visibility of effects in foreground22 and middleground 

views as seen from these areas would be temporary. The lack of detail visible in background 

views would allow the effects on visually blend into the landscape when seen from this distance. 

 

22 Distance zones are measured from key viewpoints and are divided into categories: Immediate 

Foreground (0 to 300 feet); Foreground (300 feet to 1⁄2 mile); Middleground (1⁄2 to 4 miles); and 

Background (4 miles to the horizon). 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 145

Steep topography would screen effects from treatments when viewed from sensitive areas in 

valleys and canyon bottoms. 

Some key viewpoints are vista points with middleground views towards areas of potential 

mechanical treatments. Treatments along slopes at middleground distances tend to be more 

visible and would reduce the scenic integrity. Overall, the short-term visibility of effects from 

sensitivity level 1 areas would be kept to a minimum with use of the design criteria and 

mitigation measures (appendix A).

Figure 42. Representative view of prescribed fire and aspen treatments from Key Viewpoint D, along 

Forest Road 376. This viewpoint represents open views of meadow, aspen and prescribed fire

treatments along a sensitive dispersed recreation corridor. Existing scenic integrity is High. Shortterm effects would lower scenic integrity to Moderate during and immediately following 

implementation. Long-term effects would enhance the valued landscape attributes and restore the 

scenic integrity to meet or exceed the scenic integrity level of High.

Long-term effects would be beneficial to scenery, both aesthetically and ecologically. The 

proposed mechanical and prescribed fire treatments would have the immediate and long-term 

effect of opening the tree canopy and improving the depth of view into the forest and views to the 

horizon. Research has shown that viewers prefer forests that are more open over forests with 

dense vegetation (Ryan 2005). 

The current vegetative screening provided by the dense forests would be reduced, allowing views 

to penetrate through the forest. Management activities that are currently screened by dense 

vegetation would become more visible. Vegetative screening in dispersed recreation areas may 

decrease in the short term, but may actually improve over time as new understory vegetation 

grows into the area. Treatments could be planned to enhance scenery by opening and/or framing 

vistas. Other long-term effects include increases in the landscape’s visual diversity because of age 

and species diversity in the vegetation.

Overall, the proposed treatments would improve the landscape’s scenic integrity. Ecologically, the 

treatments would increase the landscape’s resilience to wildfire, disease and drought, thus 

improving the likelihood of long-term scenic integrity. 
Chapter 3. Affected Environment and Environmental Consequences

146 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Alternative 2

There are a few prescribed fire and mechanical treatments projects currently approved. Most of 

these treatments would result in minimal improvements in scenic integrity, but these 

improvements would not be visible from sensitive areas. Untreated areas would remain at the 

existing scenic integrity level and start to decline due to the lack of visual diversity, meadow 

encroachment, screening of vistas, and increased risk of uncharacteristically severe wildfire. As 

the risk of insect and disease outbreaks and uncharacteristically severe wildfire increases, the 

likelihood that scenic integrity would be sustained over the long term would be reduced. The 

blackened landscape that remains after an uncharacteristically severe wildfire reveals a drastically 

altered landscape character, with many of the valued landscape attributes obliterated for decades. 

A decrease in scenic integrity would not meet forest plan guidelines.

Alternative 3

The effects from alternative 3 would be very similar to those of alternative 1. The main difference 

would be that temporary roads would not be built. About 1,900 acres would not be mechanically 

treated, and would be treated with prescribed fire only. 

This would reduce the short-term negative impacts from the use of heavy machinery in the areas 

that would not be mechanically treated such as scarring of trees, creating direct views into skid 

trails and landings from sensitive areas, and views of slash piles, soil disturbance and compaction. 

There would be no need to rehabilitate the landscape because temporary roads would not be built. 

This alternative leaves areas that would not be mechanically treated more vulnerable to an 

uncharacteristically severe wildfire and the long-term, negative impacts on scenery that follow

such fires. 

Alternative 4

The effects from alternative 4 are also similar to those of alternative 1, except that mechanically 

treated areas would not be treated with prescribed fire. Reducing the use of prescribed fire would 

primarily affect immediate foreground and foreground views. The sight of smoke, haze, and 

blackened trunks and soil associated with burning would be reduced. The short-term, negative 

effects caused by prescribed fire would be slightly reduced, but these reductions would be 

negligible because of the extent of prescribed fire in the project area. 

The visibility of scattered slash and woody debris would increase. Scattered woody debris is 

generally less noticeable to the casual observer than the dark scars left following a burn, 

particularly when viewed from middleground and background distances. From these distances, 

the negative effects of scattered woody debris would be negligible. 

When viewed from foreground distances, slash and scattered woody debris are obvious to the 

casual observer and appear unnatural. The woody debris detracts from scenic integrity until it 

decomposes in a few years. This would cause a short-term, negative effect on scenic integrity. If 

an uncharacteristically severe wildfire burned in the area that was recently mechanically treated, 

there could be long-term, negative impacts on scenery. 

Alternative 5

The effects from alternative 5 would be very similar to those of alternative 1. Under alternative 5, 

prescribed fire would not be used in core areas of protected activity centers, and fire control lines 

would be built to keep prescribed fire out of the core areas. The bulk of the core areas would be 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 147

located outside of sensitive viewsheds and therefore, control lines would generally not be visible, 

except in two cases where core areas could fall within the viewsheds of sensitive recreation 

corridors, one in the foreground and one in the middleground. 

Control lines would be visible from foreground distances, but because hand-cut lines tend to 

follow existing breaks and the natural contours of the landscape, they would remain subordinate 

to the overall landscape. This would cause a minor, short-term adverse effect on scenic integrity. 

Fire control lines would not be evident from middleground distances. Under this alternative, the 

short-term, negative effects caused by prescribed fire would be slightly reduced because fewer 

acres (700) would be burned. These reductions would be negligible because of the extent of 

prescribed fire in the surrounding project area. The intensity and duration of effects would be the 

same as those described for prescribed fire under alternative 1. Other short and long-term effects 

would be similar to those described in Alternative 1. 

Forest Plan Amendments

The amendments regarding vegetation treatments in Mexican spotted owl habitat would have a 

long-term beneficial effect on scenery because limited treatment in those areas would help trend 

the entire landscape towards the desired conditions for vegetation, fully expressing the natural 

landscape character. 

The amendments related to interspaces in goshawk habitat, conducting surveys in peregrine 

falcon areas, allowing activities to occur during wildlife breeding seasons, and those related to 

scenery would have positive effects because more of the forest would be treated in a shorter time 

period. Reducing tree density would have the immediate and long-term effect of opening the tree 

canopy and improving the depth of view into the forest and views to the horizon. 

Cumulative Effects 

Cumulative effects are the impacts resulting from the incremental impact of the proposed action 

when added to other past, present, and reasonably foreseeable future actions. The cumulative 

effects analysis for all alternatives includes projects located within the project boundary. 

Cumulative effects include those from prescribed fire and mechanical treatments in and around 

recreation destinations and the construction of parking facilities and fences for resource 

protection (see appendix B). 

The cumulative effects for all alternatives (1, 2, 3, and 4) are very similar. The prescribed fire 

projects and most of the thinning projects either would complement the proposed action or are not 

visible from sensitivity level 1 areas, indicating that there would be no negative cumulative 

change to scenery. Two thinning projects, Vallecitos and Banco Bonito, are adjacent to the project 

area and would increase short-term impacts from mechanical treatments. However, the long-term 

effects from both would visually enhance the landscape character while improving the long-term 

resilience of the forest. 

Cumulative effects from existing fence exclosures are short term, and would benefit scenery over 

the long term by increasing species diversity through the protection of young and delicate 

meadow vegetation from domestic and wild herbivores and overuse by visitors. Short term, 

negative effects would be minimized if the exclosure projects followed the design criteria and 

mitigation guidelines included in the proposed action. Two parking areas were built in high use 
Chapter 3. Affected Environment and Environmental Consequences

148 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

areas, and both minimize the visual impact of cars seen parked along roads and, thus improving 

views of scenery.

Conclusions About the Effects 

Would there be negative effects on scenery, and to what extent would the landscape be free from 

visible disturbances during implementation of the project? 

• There would be negative effects on scenery from the restoration treatments. The 

mechanical treatments and prescribed fire would have the most visual effects. These 

effects would be short term and would be more noticeable at closer distances. Visitors 

would see temporary signs of disturbance such as tree stumps, skid trails, machinery, and 

bare or blackened soil. Design criteria and mitigation measures were developed to 

minimize these short-term negative effects, as the landscape transitions to be more open, 

scenic and ecologically sound. Treatment areas would shift over time, and effects would 

fade as time passes. Also, some areas would be closed while mechanical treatments are 

occurring and visitors would not experience the immediate impacts of treatments. Most 

of the prescribed fire would take place in the fall, and fewer visitors would see or 

experience the immediate effects. New understory plant growth in the spring would cover 

some of the burn effects, such as blackened soil and help screen the lopped and scattered 

debris following some mechanical treatments. 

Would the scenic character and stability, especially of the forested landscape, be maintained?

• The scenic character and stability of the forests and other landscape features would be 

maintained over time. The topographic features- mountains, canyons, mesas- would not 

change. Other features of the scenic character would improve and the landscape would 

have more of its natural character. There would be more large trees and more aspen 

groves. Meadows and grasslands would provide an important contrast to the forested 

landscape. Understory grasses and flowering plants would also add diversity. Streams and 

riparian areas would appear more natural because there would be fewer campsites, less 

trash, and fewer areas of bare dirt. Streams would have less sediment and the water 

would be clearer. 

• The treatments would increase resiliency of the landscape to wildfire, disease and 

drought; the forests would not be lost to a severe wildfire. This would ensure that the 

scenic integrity would be preserved over time. 

Social Science, Economics, and Environmental Justice 

The socioeconomic and environmental justice specialist report (Cohn 2014) and the economic 

analysis report (Dobb 2013) are incorporated by reference. See the reports for detailed 

information on data sources, methodology, assumptions, and limitations. 

Affected Environment 

Demographic and economic data used in this section were obtained from the 2010 U.S. Census 

and also generated from the Economic Profile System-Human Dimensions Toolkit (Headwaters 

Economics 2011).

The Southwest Jemez Mountains Restoration project area is entirely within Sandoval County. The 

local area for the analysis includes Sandoval, Los Alamos, Bernalillo, and Santa Fe Counties. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 149

Sandoval County is the focus of the analysis. The other counties are included because they are 

close to the project area and have interested stakeholders. The communities nearest the project 

area are Jemez Pueblo, Jemez Springs Village, Cañon, Ponderosa, Thompson Ridge, and Sierra 

los Pinos. Jemez Pueblo is a federally recognized tribe and sovereign nation. Nearby cities are 

Los Alamos, Santa Fe, Rio Rancho, and Albuquerque. 

Jemez Springs, closest to the project area, is ‘rural residential and agricultural’, and most 

residents commute outside the area for work (Sandoval County 2008). The town has many small 

businesses that service the small communities in the Jemez Valley. The Jemez Pueblo and several 

other pueblo communities in the area have used the Southwest Jemez Mountains for many 

generations and have a deep spiritual connection to the land. The local pueblos rely on the water, 

wildlife, and vegetation resources for sustenance, including hunting and plant gathering. 

About 34 percent of Sandoval County land ownership is tribal land, 42 percent is federal 

government, 21 percent private, and 3 percent state government land. The Navajo Nation, 

Jicarilla Apache tribes, and nine pueblos own land in the county (Sandoval County 2008). Within 

the project boundary, there are 9,710 acres of private land, 281 acres of state land, and 3,485 acres 

of Jemez Pueblo land. 

What is now the national forest has a long history of resource use including farming, subsistence 

use, mining, logging, and grazing. Use of the forest has shifted from subsistence and commercial 

uses to recreation, wildlife watching, and other non-consumptive uses. Recognition and 

appreciation of the ecosystem services provided by the forest is increasing. People are aware of 

how the forest benefits and enhances the quality of life for individuals and the community 

(Russell and Adams-Russell 2006).

Population

The population of Sandoval County in 2010 was 131,561, an increase of 46.3 percent since the 

2000 census, making it the fastest growing county in the state. The average population growth in 

the state for the same period was 13.2 percent (U.S. Census 2010). Population of the nearby 

communities is: Jemez Pueblo- 1,788; Jemez Springs Village, 250; and Ponderosa, 387. Jemez 

Pueblo and Jemez Springs Village have declined in population since the 2000 census. 

Income and Employment

Within Sandoval County, economic and employment statistics are quite variable. The median 

income is $57,158; more than $15,000 higher than the state figure. Median income levels for 

nearby communities are also higher than the statewide average (U.S. Census 2012). 

Most jobs in Sandoval County are in government (19.4 percent), manufacturing (10.7 percent), 

and retail sectors (10.3 percent) (Headwaters Economics 2012). Natural resource-related jobs are 

less than 1 percent of the total jobs. Most of the timber jobs are in wood products manufacturing. 

Jemez Springs and Jemez Pueblo show 5 and 12 jobs respectively in natural resource fields (ACS 

2007-2011). The few natural resource jobs are important to local residents as these jobs contribute 

to a traditional and cultural way of life (Raish et al. 2003). As resource-dependent jobs have 

declined, service-oriented jobs in retail, travel, and tourism have become more important to 

residents in this area. The number of tourism jobs in Sandoval County has increased from 

approximately 3,115 jobs in 1998 to 4, 815 jobs in 2010. A few of those jobs, 17, are in Jemez 

Springs (U.S. Census 2012). This is a drop from 40 jobs before the recent recession started in 

2007. 
Chapter 3. Affected Environment and Environmental Consequences

150 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Environmental Justice

Environmental justice is the fair treatment and meaningful involvement of people of all races, 

cultures, and incomes, with respect to the development, implementation, and enforcement of 

environmental laws, regulations, and policies. 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 (USDA 1997). Race and ethnicity in the affected counties and the state is shown in table 

22. 

Table 22. Population by race and ethnicity, 2011

New Mexico Los Alamos 

County

Sandoval

County

Santa Fe

County

Bernalillo 

County

U.S.

White 72.0% 88.1% 70.5% 83.1% 69.8% 74.1%

African

American 

2.0% 0.5% 2.8% 0.8% 2.8% 12.5%

American 

Indian 

9.3% 0.4% 12.9% 3.0% 4.6% 0.8%

Asian 1.3% 5.1% 1.3% 1.2% 2.3% 4.7%

Other races 15.4 5.9 12.5 12.0 20.5 7.8

Hispanic

(any race)

45.9% 14.5% 34.8% 50.4% 47.3% 16.1%

In Sandoval County, whites are 70.5 percent of the population, nearly equal to the statewide 

figure of 72 percent. The Native American population comprises 12.9 percent of the county, 

again, higher than the state figure. Hispanics23 make up 34.8 percent of the Sandoval County 

population, lower than the statewide figure of 45.9 percent. Combined, Hispanic and Native 

Americans are over 50 percent of Bernalillo and Santa Fe Counties. At the community level, 

American Indians make up, as expected, nearly 100 percent of the Jemez Pueblo population. The 

Hispanic population in Jemez Springs Village and Ponderosa are near or above the percentage for 

Sandoval County. 

The percentage of people below the poverty level in Sandoval County is 15.1 percent. The 

statewide figure is 20.4 percent (U.S. Census 2012). In New Mexico, poverty is linked with race 

and ethnicity (Sierra 2004), and county level poverty figures vary by race or ethnicity. The 

percentage of people below poverty level in Jemez Pueblo is 15.3 percent; in Sandoval County, 

23 percent of American Indians live below the poverty level, somewhat lower than the statewide 

figure of 31.5 percent. In Sandoval County, 13.5 percent of Hispanics are below the poverty level 

(U.S. Census 2012). These county level poverty percentages for Hispanics and American Indians 

are consistent with state and national figures, but slightly higher than that for Sandoval County 

(U.S. Census 2012). 

Based on the minority status and poverty level figures presented above, Sandoval County appears 

most at risk for environmental justice issues. 

 

23 Hispanic or Latino refers to a cultural identification, such as Mexican, Puerto Rican, or Spanish; it is not 

race (U.S. Census 2011). Hispanics can be of any race and are not included as a separate category in the 

race distribution. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 151

Methods Used to Analyze Effects 

The economic impacts of the project on the area’s employment, production, income and natural 

resource base were calculated using IMPLAN (IMpact analysis for PLANning). Quick-Silver 

Version 7 was used for the cost-benefit analysis. Data on use and production for each alternative 

were provided by the resource specialists from the Santa Fe National Forest. Changes in use were 

based on their professional expertise. Social impacts were analyzed using the information on 

social and demographic conditions in the Affected Environment section and the Santa Fe National 

Forest Economic and Social Sustainability Assessments (Russell and Adams-Russell 2006; BBER 

2007). Quality of life factors that may be affected by the treatments were identified through 

public involvement. 

Analysis Questions

The analysis questions were derived from the purpose and need and the issues that arose during 

public involvement. Part of the purpose and need is to “use the forest restoration byproducts to 

offset treatment costs and provide economic opportunity to the local rural communities” by 

providing a “source of wood products for commercial and personal use.” The relevant issues are 

(1) the economic effects of smoke from prescribed fires, and (2) the effects of smoke on minority 

and/or low-income communities. 

• Would the smoke from prescribed fires affect minority and/or low-income communities 

disproportionately? 

• What are the costs associated with avoiding or treating the adverse health effects of 

smoke from prescribed fires? 

• To what extent would the sale of forest restoration byproducts offset costs of the 

restoration treatments? 

• What type and amount of economic opportunity, including employment, would be 

created?

• What type and amount of wood products would be generated? 

Summary of Effects 

Impacts from smoke would occur under any alternative, including the no action alternative. Costs 

associated with avoiding smoke or treating adverse health effects from prescribed fire smoke are 

likely to be higher under alternatives 1, 3 and 5 than under alternatives 2 and 4. Economic 

impacts from a severe wildfire would be highest under alternative 2. 

Alternatives 1, 3, 4, and 5 are estimated to support similar numbers of jobs and similar amounts 

of total labor income (table 23). Nonmarket and social benefits (resiliency, reduced wildfire risk, 

ecosystem services wildlife habitat, scenic and recreational values, etc.) would be similar under 

alternatives 1, 3 and 5. There would be fewer of these benefits under alternative 4 because there is 

less prescribed fire and least under alternative 2 because a smaller area is treated. The amount and 

type of wood products for commercial and personal use would be about the same under 

alternatives 1, 3, 4, and 5 and substantially less under alternative 2 (no action). Alternatives 1, 3, 

and 5 have similar costs to the government; costs are lowest under alternative 4. The relatively 

small differences in jobs, labor income, and costs are due to the amount of acres treated by 

prescribed fire and the potential, temporary restrictions on grazing. 
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152 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Table 23. Estimated annual amount of total jobs and labor income 

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Jobs 229-249 164-181 226-246 218-237 229-252

Labor income 

in thousands of 

dollars $6,073 - $6,614 $4,040 - $4,550 $5,982-$6,523 $5,865 - $6,406 $6,073-$6,076

Negative, short to medium term impacts to grazing permittees would occur under alternatives 1, 

3, 4, and 5 in the form of reduced grazing opportunities and higher costs associated with grazing. 

Over the long term (greater than 5 years) there would be positive impacts as forage quality and 

quantity increases because of more open forest conditions. There are potential long-term negative 

impacts under alternative 2 as the forest canopy becomes denser and forage quantity and quality 

decrease and the risk of a severe wildfire increases. 

There is a high potential for adverse impacts from smoke on the county and communities most at 

risk for environmental justice issues: Sandoval County, Jemez Springs, Jemez Pueblo, Cañon, and 

Ponderosa under all alternatives. Beneficial impacts exist under all action alternatives: (1) jobs; 

(2) wood products for personal use; and (3) restoration of forests and protection of cultural sites. 

These benefits would be much less under alternative 2, especially for jobs, because less area is 

treated.

Environmental Consequences 

Economic and social effects on tribal and at-risk communities are discussed in the Environmental 

Justice section.

Alternatives 1, 3, 4, and 5 - Economic Effects

Economic impact analysis measures how project activities would affect employment, income, and 

economic activity in the regional economy. Employment and labor income generated annually by 

each alternative are displayed in tables 24 and 25. Alternative 2 is used as the baseline and 

represents the current condition. Alternatives 1, 3, 4, and 5 show a temporary reduction of jobs 

and income because grazing is reduced after prescribed fire treatments. There is an increase in 

employment and income generated by increased harvesting and wood processing activities. 

Table 24. Estimated annual number of jobs created annually for each alternative. Alternatives 1, 3, 4, 

and 5 create about the same number of total jobs.

Resource Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Recreation 116-133 116-133 116-133 116-133 116-133

Grazing 31-34 38 31-34 32-34 31-34

Timber 30 1 27 29 30-33

Restoration 

Treatments 52 8 51 41 52

Total Contribution 229-249 164–181 226–246 218-237 229-252
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 153

Table 25. Estimated amount of labor income by resource for each alternative, in thousands of 

dollars. Alternatives 1, 3, 4, and 5 generate about the same amount of labor income. 

Resource Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Recreation $3,540 - $4,050 $3,540 - $4,050 $3,540-$4,050 $3,540 - $4,050 $3,540-$4,050

Grazing $248 - $279 $310 $248 - $279 $248 - $279 $248-$279

Timber $993 $31 $917 $993 $1,055

Restoration 

Treatment $1,292 $159 $1,277 $1,064 $1, 094

Total Income $6,073 - $6,614 $4,040 - $4,550 $5,982-$6,523 $5,865 - $6,406 $5,937-$6, 478

The mechanical treatments and prescribed fire treatments are expected to have negative effects on 

recreation quality and the number of visits (see recreation section of this chapter). Overall, 

visitation is expected to stay the same over the life of the project. Visitors to the project area 

support an estimated 116-133 jobs and $3.5 and $4 million in labor income annually in the local 

economy. This contribution is not expected to change under any of the alternatives. 

Rangeland Resources

Grazing activities currently support an estimated 38 jobs and $310,000 in labor income annually. 

Under alternatives 1, 3, 4, and 5 there are fewer jobs and less income from grazing. This is 

because authorized livestock numbers and/or season of use would be reduced for 1-2 seasons to 

allow vegetation to recover after prescribed fire treatments. The reductions are temporary. At the 

end of the project, grazing levels would return to pre-project levels, and jobs and income are also 

expected to recover. 

The reduction in grazing is a short-term impact. Permittees would have time to adapt to the 

changes. To reduce impacts on permittees, prescribed fire would not be used on all the pastures in 

an allotment at the same time, and permittees could move livestock to the untreated pasture. 

Some permittees may incur additional expenses including the purchase of private forage or 

pasture or transportation costs, and those with a few head of livestock would be impacted more. 

Over the long term, improved ecosystem conditions would improve forage quality and quantity 

and ranching viability. Such increases in grasses and forbs after prescribed fire and thinning have 

been well-documented (Arnold 1950; Covington et al. 1997; Laughlin et al. 2006; Bartuszevige 

and Kennedy 2009; McIver et al. 2012). Permittees and the Forest Service may also benefit from 

reduced administrative and management costs.

Other Restoration Treatments

These treatments include prescribed fire, meadow restoration, headcut treatments, wildlife habitat 

improvement, and so on. Under alternatives 1, 3, and 5, about 50 jobs would be created, resulting 

in nearly 1.3 million dollars in labor income. These amounts are slightly less under alternative 4 

because less prescribed fire is used. No increases in employment or income are expected if this 

work is done by Forest Service employees. There would be some small benefit to local 

communities from the purchase of supplies and services regardless of who does the work. 

Wood Products

Restoration treatments produce commercially valuable forest products. Table 26 shows the 

expected wood product volumes under each alternative. These are the total volumes over the life 
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154 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

of the restoration project. An average of about one-tenth of the volume would be harvested and 

processed each year. The actual amounts and types of products produced each year would vary. 

Table 26. Estimated total production of forest products removed from the forest over the life of the 

project. Alternatives 1, 3, 4, and 5 have about the same amounts of products. 

Alternative 1 Alternative 2 Alternative 3 Alternative 4 Alternative 5

Softwood 

Sawtimber 

(CCF) 23,700 900 22,000 23,700 26,400

Poles (CCF) 800 100 700 800 800

Posts (CCF) 1,800 0 1,700 1,800 1,800

Firewood 

(CCF) 3,300 100 3,100 3,300 3,300

All Other 

Products 

(Green tons) 28,700 800 26,400 28,700 28,700

Thirty percent of the pole, post, and firewood volume would be available for personal use, and 70 

percent would be available for commercial use. Alternatives 1, 4, and 5 produce the same amount 

of material. Fewer acres are treated under alternative 3, so wood product volumes are slightly 

lower.

Economic Efficiency

The economic efficiency analysis measures the ratio of benefits to costs resulting from project 

activities. In other words, does the value of products and services from the treatments offset the 

costs of the treatments? We are doing restoration treatments and expect positive benefits. But it is 

difficult to put a value on some benefits such as ecosystem services or a reduced risk of wildfire. 

The net present value24 of the action alternatives over the 9-year treatment period is shown in 

table 27. 

Table 27. Net present value of the restoration treatments for each action alternative

Alternative 1 Alternative 3 Alternative 4 Alternative 5

Net Present Value $104 million $103 million $66 million $104 million*

*Estimated value

The net present value represents the value of the benefits received from the restoration treatments, 

including income, wood products, and forgone wildfire suppression costs. The value of the 

benefits received from alternative 4 is lower than the other action alternatives because less 

prescribed fire is used, and the value of the benefits is lower. Fewer jobs, helicopter time, and 

other goods would be needed to implement the prescribed fire treatments. These expenditures by 

the government generate additional value to the local economy, and are included in the 

calculation of the net present value. There are also fewer savings from forgone wildfire 

suppression costs under alternative 4. 

 

24 Net present value is the present value of revenues (income or benefits) minus the present value of costs 

(expenses). This figure can be viewed as a proxy for the economic value of the treatments. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 155

Although a simple comparison of treatment costs to wood product value may show that 

treatments are not cost effective, including the value of ecosystem services changes the equation 

and can show a positive economic benefit. Thus, the proposed vegetation, prescribed fire, habitat, 

watershed, and other restoration treatments would yield long-term positive economic benefits. 

These benefits are discussed below.

Wood Products and Treatment Costs

Using or selling wood products is a way to offset costs. To get economic benefits from wood 

products it is important to have harvesting and processing facilities nearby (Nielsen-Pincus et al. 

2012). When facilities are close to the woods, there are fewer losses due to increased 

transportation costs and local contractors can be used to do the work (Hjerpe and Kim 2008). 

There are no large-capacity lumber mills in the area, but there are several smaller woodprocessing plants. Past experience demonstrates that material from the Jemez Mountains can be 

efficiently transported to locations within about a 120-mile radius (USFS and VCNP 2010). This 

includes Albuquerque, Española, Raton, Grants, Taos, and Las Vegas. Hauling costs are an 

important consideration for small diameter wood products. Hauling small diameter wood material 

to facilities farther from the project area would increase costs to contractors. The value of wood 

materials would also depend on market conditions and the type of contract used. 

Doing landscape-scale restoration treatments (approximately 15,000 acres per year), as we are 

proposing, is supported by research. Economies of scale can be gained with large prescribed fires 

and thinning treatments. The cost per acre for treatments is lower when more acres are treated 

(Hesseln 2000; Calkin and Gebert 2006; Thompson et al. 2013). Most of the savings for 

prescribed fire treatments are in planning costs, which stay the same regardless of acres burned. 

Wildfire Costs

Landscape-scale treatments may result in reduced future costs for wildfire suppression because 

the severity and intensity of potential wildfires is reduced (Reinhardt et al. 2008; Thompson et al. 

2013). Consideration of other values may reduce or eliminate these cost savings (Reinhardt et al. 

2008). In this area, values include tourism, protecting communities, private land, and Los Alamos 

National Laboratory, and reducing impacts on human health from smoke. We would suppress 

some future wildfires to protect these values. Treatments would lower wildfire hazard and 

severity (see fuels section of this chapter), and it would likely cost less to suppress these fires. 

Ecosystem Services

Ecosystem resilience and ecosystem services (air and water quality, soil productivity, habitat), 

have economic value (Loomis and González-Cabán1998; Loomis et al. 2002, 2003; Venn and 

Calkin 2011; Wu and Kim 2013). Placing a value on these services is difficult and complex. But 

economists have been able to illustrate the increased economic value or price of restored forests 

over untreated forests, including southwestern ponderosa pine forest ecosystems (Wu and Kim 

2013). 

Communities and organizations that use water produced on public lands are recognizing the value 

of this ecosystem service. Denver, Colorado, Flagstaff, Arizona, Santa Fe, New Mexico, and 

irrigators in the Verde Valley (Arizona) have or would consider paying for restoration treatments 

on public lands to improve water quality and quantity (Mueller et al. 2013; Denver Water 2013; 

City of Santa Fe 2013; City of Flagstaff 2012).
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156 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Prescribed Fire

As presented in the air quality section of this chapter, total smoke emissions from highest to 

lowest are: (1) a severe wildfire occurring on the same treatment footprint; (2) alternatives 1, 3, 

and 5; (3) alternative 4; and (4) alternative 2. 

The economic consequences of smoke from prescribed fires on individuals and businesses are 

difficult to quantify (Viers 2005). They would be higher under alternatives 1 and 3 because more 

smoke is produced. Smoke sensitive individuals may incur costs for medical treatment and/or 

costs related to leaving the area to avoid smoke. 

Most of the prescribed fire treatments would take place after Labor Day and would likely have 

fewer impacts on recreation and tourism-based businesses than burns that occur during the spring 

season. Burning at the beginning of the tourist and recreation season may have a larger negative 

impact on businesses that need this early season income after the slow winter season. Other local 

businesses would benefit, regardless of season of activity. The prescribed fire treatments would 

contribute employment and labor income to forest workers as well as small businesses that would 

supply these workers with food, lodging, and supplies. 

Recreation 

The restoration treatments may lead to more visits by mountain bikers and hikers and could lead 

to a small increase in tourism-related income for local businesses. A study of recreation use in 

New Mexico found that people took slightly more trips to areas where a low-intensity prescribed 

fire had occurred (Starbuck et al. 2006). Thinned forests were more attractive to hikers and 

mountain bikers because the openness made for a more pleasant experience. People were likely to 

take fewer trips to areas burned in a catastrophic wildfire. 

Private Property 

Property values may be improved because the risk of severe wildfires is reduced (Kim and Wells 

2005). Private landowners should also benefit by the increase in biological diversity and quality 

of wildlife habitat, scenic values, water quality, and other ecosystem amenity values. Private 

residents in the project area would be temporarily inconvenienced for 5-7 days during prescribed 

fire treatments. The timing of the burns may affect activities at the two private camps in the area. 

If a prescribed fire escaped, it could damage homes, fences, and other private property. The 

design features and mitigation measures described in appendix A, have been shown to be highly 

effective in reducing the risk of an escaped prescribed fire. 

Alternatives 1, 3, 4, and 5 - Social Consequences

The action alternatives are expected to increase or improve nonmarket and social benefits such as 

spiritual, recreational, and scenic values. 

Successful implementation of prescribed fire treatments could bring about increased trust and 

confidence in the Forest Service by the local communities and the Southwest Jemez Collaborative 

Forest Landscape Restoration partners. Improvement in rangeland conditions for permittees 

would help the small Hispanic communities retain their traditions and maintain ties to the land. 

Tribal land uses and other traditional or cultural land uses, including subsistence hunting and 

firewood gathering would be affected by proposed activities. Some areas may not be accessible 

while treatments are being conducted; these are short-term effects. The mechanical treatments and 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 157

prescribed fire treatments would improve growing conditions for medicinal and ceremonial plants 

used by the tribes. The treatments would also protect those important plants from being burned up 

in a severe fire. The cultural site protection treatments would also protect sites from damage or 

loss due to severe wildfire. Other social consequences affecting tribal communities are found in 

the environmental justice section below. 

The mechanical treatments and prescribed fire activities could potentially cause serious injuries to 

forest workers. However, the risk of serious injuries or fatalities from these types of vegetation 

treatments and prescribed fire activities is extremely low, especially when mandatory safety 

procedures are followed.

Alternative 2 

The previously approved resource management activities would continue to occur in the area over 

8-10 years. Forest conditions would continue to decline and the potential for an 

uncharacteristically severe wildfire is expected to increase. Wildlife habitat, streams, and forest 

and riparian ecosystems would continue to decline and the sustainability of environmental and 

cultural resources would be at risk. 

There would be less smoke from prescribed fires and thus lower healthcare and travel costs for 

smoke-sensitive individuals. A severe wildfire, however, is more likely and would produce more 

smoke. Smoke-sensitive people and other residents who evacuate for health or safety reasons 

would incur expenses for transportation, lodging, and other living expenses, as well as health care 

(Kochi et al. 2010). Depending on the severity and length of the wildfire, these costs could be 

higher than similar costs to avoid smoke from prescribed fires. 

In the event of a severe wildfire, businesses in the Jemez Springs area would likely suffer. 

Visitation would be reduced during the wildfire because of smoke, forest closures, and perceived 

danger. Businesses may close during evacuations, and lose all revenue during that time. After the 

fire, visitation would be reduced due to damage or loss of forest resources, wildlife habitat, 

recreational facilities, and scenic quality. Gross receipts taxes and property tax receipts could be 

lower, depending on the extent of damage and amount of time the area is closed. 

Economic benefits to the local economy from a severe wildfire would be temporary, lasting only 

a few weeks or months as a result of the increase in jobs and income from the fire suppression 

and post-fire rehabilitation efforts. If salvage logging took place after the fire, it would create 

additional logging and manufacturing jobs and additional income for individuals and local 

businesses that support those workers. 

Rangeland Resources

Over most of the area, a dense canopy cover would remain and understory vegetation would 

continue to decline. There would be less forage for cattle and possible reductions in the number 

of permitted livestock. This would reduce the income of permittees. The approved prescribed fire 

treatments, however, may result in a small benefit for some permittees because of improved 

forage conditions once the area has recovered. 

Permitted grazing could be greatly impacted by a severe wildfire. Livestock would be removed 

from the allotments and grazing would be suspended during suppression and rehabilitation 

activities. Severely burned portions of allotments would be changed to non-use until vegetation 

recovered. Permittees could have increased costs for leasing alternative pastures, transporting 
Chapter 3. Affected Environment and Environmental Consequences

158 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

cattle, and purchasing feed. (Lemhi County 2006). Other impacts include the death of livestock, 

loss of or damage to fences and other range improvements, and costs of caring for injured 

animals. Permittees could also lose income while caring for sick and injured animals (Riggs et al. 

2001; Lemhi County 2006). After a few years, most of the wildfire area should experience a 

substantial increase in the abundance of herbaceous forage vegetation (depending on the severity 

of the fire), which would be beneficial for livestock grazing.

Recreation

No changes to visitor spending or recreational use are expected; the level of resource activity 

would be about the same as in other years. Some areas may not be accessible while treatments are 

implemented, but most visitors would likely stay in the general area. The duration of effects 

resulting from an uncharacteristically severe wildfire would be variable, depending on the extent 

of damage and loss to recreation sites and facilities. There would likely be a temporary loss of 

recreational visitation, tourism, and business services due to forest closures. Fire-related damage 

to and loss of recreational facilities, trails, and community buildings, equipment, and 

infrastructure may also occur. 

Other Economic and Social Consequences

A large, uncharacteristically severe wildfire is more likely under this alternative. Post-fire 

mudslides and flooding commonly cause even more substantial damage than the fire itselfdamaging homes, businesses, forest resources, and community water supplies- as happened after 

the Las Conchas wildfire. After Las Conchas, the cities of Santa Fe and Albuquerque, which get 

part of their municipal water from the Rio Grande, were forced to switch to alternate water 

sources because of high amounts of ash in the river water. The ash affected water quality and 

could have damaged water plant equipment (Fleck 2011). Damage to water supplies for 

Ponderosa, Jemez Pueblo, San Ysidro, and Jemez Springs could be quite severe. 

Costs of repairing, restoring or replacing the natural resources and properties damaged or lost 

would be most significant. Federal agency costs for suppression of the 2000 Cerro Grande fire 

were $33.5 million, with a total cost of nearly $1 billion, including emergency land rehabilitation, 

loss of property, infrastructure, and natural resources. Suppression costs for the Las Conchas 

wildfire exceeded $41 million; the 2005 Dome Fire cost $7.5 million. Suppression costs for all 

wildfires on the Santa Fe National Forest over a 20-year period averaged $911 per acre, or over 

$9 million for a 10,000-acre crown fire (SNF 2005). 

Indirect economic costs to the agencies and the public include costs resulting from the loss of tax 

revenue, property values, mental and physical health, water supplies, and other ecosystem 

services (Viers 2005; WFLC 2010). Individuals may incur unexpected expenses such as food and 

lodging if they are evacuated, medical expenses for injuries or illness, pet and livestock boarding 

costs, and lost income (Viers 2005). 

Even if no severe wildfire occurred, the elevated hazard of a wildfire would have negative 

consequences. Fire restrictions and forest closures would likely reduce tourism spending in local 

communities. The forest may incur overtime costs for employees to patrol when restrictions or 

closures are in place and would lose campground fee revenue during forest closures. A severe 

wildfire or temporary forest closures due to fire risk would result in a temporary loss of plant 

gathering areas and affect other traditional cultural land uses by local tribes. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 159

There would be little or no effect on community services (police, fire, medical), or existing land 

uses. In the event of a severe fire, effects include reduced availability of local emergency 

resources (police, fire, medical) during the fire episode; short-term increases in traffic and noise 

in local communities from fire suppression vehicles and aircraft. Some residents and businesses 

could be asked to evacuate the area during such a wildfire; and often there are some people who 

are unable or unwilling to evacuate the danger zone in a timely manner (Halvorson 2002).

Environmental Justice 

This section addresses environmental justice issues for all alternatives. 

There is a high potential for adverse impacts on low-income and/or minority communities due to 

smoke from prescribed fires under all alternatives. These impacts would be short term, lasting 5-7 

days. The areas most at risk are: Sandoval County, Jemez Springs, Jemez Pueblo, San Ysidro, 

Cañon, and Ponderosa. Smoke would travel down the Jemez River Canyon and into the above 

communities and would be heaviest in the evening. Smoke from prescribed fires could affect the 

health of elderly residents and those with respiratory problems in these at-risk communities, as 

well as residents and visitors living or staying near the project area. Similarly, smoke from an 

uncharacteristically severe wildfire would likely affect all residents and visitors living near the 

wildfire area. 

The use of smoke reduction techniques and mitigation measures described in appendix A would 

reduce the amount of smoke produced by prescribed fires. These techniques would also reduce 

the potential for large accumulations of smoke to settle in Jemez Pueblo or other local 

communities for any length of time. Mitigation measures also include notification of potentially 

affected communities before and during prescribed fire treatments. Please see the air quality and 

fuels sections of this chapter for more discussion on prescribed fire management and smoke.

Economic Consequences

The mechanical treatments would create jobs under all action alternatives (1, 3, and 4). Some of 

these jobs may be filled by residents in the pueblos and at-risk communities (see also 

Environmental Justice section below). Businesses in these communities may benefit by providing 

services and equipment. There would be fewer employment opportunities under alternative 2. 

Forest Products

Under alternatives 1, 3, 4, and 5, vegetation management projects would provide wood products 

for personal use, including firewood. Wood fuel is used by many residents to heat their houses. In 

Jemez Pueblo, 41 percent of the housing units heat with wood; in Jemez Springs, 31 percent. This 

is a beneficial effect. There would be fewer wood products under alternative 2. 

Social Consequences

Forest restoration treatments implemented under alternatives 1, 3, 4, and 5 would enhance and 

protect traditional cultural properties and uses and cultural sites important to Native American 

communities. Fewer cultural sites would be treated under alternative 2. Cultural sites and 

properties would be at risk from an uncharacteristically severe wildfire, and forest resources 

would continue to decline. 
Chapter 3. Affected Environment and Environmental Consequences

160 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Forest Plan Amendments

The amendments related to developing viewshed corridor plans and clarifying interspaces for the 

goshawk guidelines would have no effects on social and economic considerations or 

environmental justice. These amendments would not affect the amount and type of wood products 

produced, number of jobs, implementation costs, or labor income. 

The amendments related to vegetation treatments in Mexican spotted owl habitat would have 

beneficial impacts on social and economic considerations and environmental justice. With these 

amendments in place, the risk of an uncharacteristically severe wildfire would be reduced. The 

amount and type of wood products, number of jobs, implementation costs, and income as 

previously described for alternatives 1, 3, 4, and 5 would not change. The amount of smoke 

emissions produced by prescribed fires would be slightly greater than under alternative 5, but this 

is an insignificant amount (see air quality specialist report). Alternative 4 has the lowest amount 

of smoke emissions, but the potential for impacts on health from PM2.5 under all action 

alternatives would be similar (see air quality section of this chapter). 

Traditional uses, traditional cultural properties, and archaeological sites would be enhanced and 

protected as described in the environmental justice section below and in the cultural resources 

section of this chapter. More archaeological sites would be treated than under alternative 5. 

Communities in the Jemez River Valley would benefit from jobs and labor income related to the 

restoration treatments. 

The other amendments regarding changing the scenery objective in the Jemez NRA and 

conducting surveys in peregrine falcon nesting habitat would have beneficial impacts on social, 

economic, and environmental justice concerns under all action alternatives (1, 3, 4, and 5). More 

of the area would receive restoration treatments. The use and sustainability of traditional uses, 

traditional cultural properties, and cultural sites would also be enhanced. The social, economic, 

and environmental justice consequences are similar to those previously described for alternatives 

1, 3, 4, and 5. 

Cumulative Effects 

The area of consideration for cumulative effects of the action alternatives is Sandoval County, 

including the communities of Jemez Springs, Jemez Pueblo, and Ponderosa. Most of the social 

and economic effects discussed would be expected to occur within this county.

Restoration activities would occur on adjacent public lands. Restoration treatments would also 

increase ecosystem resilience in the Southwest Jemez Mountains. Mechanical treatments and 

other restoration activities on the Valles Caldera National Preserve and potential pumice mine 

development on the forest would further increase economic benefits and opportunities and social 

benefits.

Overall, the increase in jobs and income from the proposed action would not have a significant 

effect on the regional economy. Individuals and households, however, would benefit from the 

increase in jobs and income. Manufacturing would continue to be the dominant industry in this 

economy. The other economic sectors would likely remain relatively unchanged regardless of the 

minor additive effects of restoration activities in the area.

Recent past, ongoing, and planned fuel reduction projects would continue to occur on adjacent 

tribal lands and other Federal, State, and private lands surrounding the project area. These would 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 161

have a short-term cumulative impact on forestry-related employment and jobs. Fire hazard would 

be further reduced throughout the area. 

The Landscape Strategy (USFS and VCNP 2010) projected that the Preserve would use 

prescribed fire on nearly 58,000 acres over 10 years. Bandelier National Monument, The Los 

Alamos National Laboratories, Los Alamos County, and Jemez Pueblo may also implement 

prescribed fires Because of the small windows of opportunity for burning that exist in the 

Southwest Jemez, it is possible that the these agencies would have concurrent or consecutive 

prescribed fires. The effects of these burns on air quality would be reduced to the extent possible 

through coordination with the New Mexico Environment Department. 

Conclusions of Effects 

This section answers the analysis questions and how well the alternatives address the purpose and 

need and the relevant issues. 

Would the smoke from prescribed fires affect minority and/or low income communities 

disproportionately? 

• Yes, minority and/or low income communities would be affected by smoke from 

prescribed fires. This is a short-term impact lasting 5-7 days. The areas most at risk are: 

Sandoval County, Jemez Springs, Jemez Pueblo, San Ysidro, Cañon, and Ponderosa. 

Prescribed fire management techniques and other measures (appendix A) would reduce 

impacts from smoke. Communities would be notified before prescribed fire treatments 

are implemented. Prescribed fire and other treatments would also benefit these 

communities and help sustain traditional uses and resources. 

What are the costs associated with avoiding or treating the adverse health effects of smoke from 

prescribed fires? 

• Smoke-sensitive individuals may have costs for travel, lodging, medication, and 

healthcare. People may lose income because they are ill and cannot work or because they 

leave the area. These costs are variable and affected by a person’s sensitivity to smoke, 

financial state, job, or desire to stay or go. Conditions at and during burning will affect 

the amount of smoke produced and thus its impacts.

To what extent would the sale of wood products offset treatment costs of the restoration 

treatments? 

• We expect that the sale of wood products would offset treatments costs, but we do not 

know by how much. It’s not likely to be a positive net benefit because most of these types 

of treatments will cost more than the value of the wood removed. This is especially true 

here in the Southwest where product value is quite low. Other benefits of these treatments 

provide enormous value, but are difficult to quantify. These benefits include ecosystem 

services and reduced wildfire suppression costs. Pricing these types of benefits and 

including them in the cost-benefit analysis changes the equation and often shows a 

positive economic benefit. 
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162 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

What type and amount of economic opportunity, including employment, would be created? 

• All alternatives would create employment and labor income (see tables 24 and 25). These 

would be highest under alternatives 1, 3, 4, and 5. Timber activities and restoration 

treatments provide the most opportunities. 

What type and amount of wood products would be generated? 

• The mechanical treatments would produce sawtimber, posts, poles, firewood, and other 

biomass. Thirty percent of the pole, post, and firewood volume would be available for 

personal use, and 70 percent would be available for commercial use.

Soil and Water Resources 

The soil and water resources specialist report (Snyder 2013) is incorporated by reference. See the 

report for detailed information on data sources, methodology, assumptions, and limitations. The 

Landscape Assessment (USFS 2010b) also has detailed information about soil and water 

resources in the Southwest Jemez Mountains and is incorporated by reference. 

Affected Environment 

The resource areas that would be affected by the proposed treatments are streams (ephemeral, 

intermittent, perennial), water quality, upland function, soil resources, and riparian area 

conditions. 

Hydrology and Water Quality

The climate in this area varies because of the mountain and canyon topography and the wide 

range of elevation. Average precipitation, rain and snow combined, is 18.3 inches per year. Most 

of the precipitation falls during the summer rainy season, July through October in the form of 

high-intensity, short duration thunderstorms. A second wet season extends from December to 

March.

The project area lies within twelve HUC12s (hydrologic unit code) subwatersheds: Cañon de la 

Cañada, Church Canyon-Jemez River, East Fork Jemez River, Headwaters Borrego Canyon, 

Outlet Borrego Canyon, Outlet Rio Cebolla, Outlet San Antonio Creek, Rio Guadalupe, Sulphur 

Creek, Vallecito Creek, Vallecito Creek-Jemez River, and Virgin Canyon. Outlet San Antonio 

Creek is a priority watershed25 for the Santa Fe National Forest. All water from this area drains to 

the south towards the Jemez and Rio Grande Rivers and into the water system for the entire 

Albuquerque-Rio Rancho area. All of these subwatersheds were rated as good (functioning 

properly) or fair (functioning- at risk) under the forest’s watershed condition assessment.

There are 113 miles of perennial (year-round) streams and 394-miles of intermittent streams 

(flows in response to precipitation) (figure 43). Most streams are partly perennial and partly 

intermittent. There are no New Mexico Outstanding Natural Resource Waters streams or wetlands 

in the project area. The following streams or sections of streams in the area do not meet water 

quality standards under the Clean Water Act and are called impaired waters: Redondo Creek, San 

 

25 The forest is concentrating restoration activities in priority watersheds to maintain or improve watershed 

condition. The Outlet San Antonio was selected as a priority watershed in part because of its importance to 

downstream domestic water supplies.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 163

Antonio Creek, Jemez River, Rio Guadalupe, East Fork Jemez River, Sulphur Creek, Vallecito 

Creek, and Rio Cebolla. Problems include high water temperatures, high turbidity (cloudy water), 

high pH, and high levels of aluminum and dissolved oxygen (NMED 2012). Natural conditions 

contribute to the high aluminum levels (NMED 2012), lack of shading along streams contributes 

to higher water temperatures. Natural conditions contribute to high aluminum concentrations 

throughout the Jemez Mountains area; impacts on aquatic life are unclear. Criteria for aluminum 

are under review to identify the appropriate and/or attainable levels. 

Stream channels in the project area are primarily affected by roads and trails (authorized and 

unauthorized), as well as past grazing and timber harvests. There are 14 miles of system trails and 

many unauthorized off-road vehicle trails, livestock trails, and old logging trails in the project 

area. Unsurfaced (dirt) roads cut through some streams or are directly adjacent to streams and add 

sediment to streams.

High densities of trees have altered the hydrologic regime (water cycle) of the streams in these 

watersheds. Rain and snow are caught in the tree canopy, and so less water is absorbed into the 

soil (Baker 1999; Dore et al. 2010). Eventually, less water reaches the aquifer and stream flows 

are lower, especially later in the year. Piñon-juniper stands are also too dense, and understory 

plants, which keep the soil in place, are absent or sparse. 

The water supplies of several communities are downstream of the project area: the Village of 

Ponderosa, which gets its water from springs near the Paliza Campground; Village of Jemez 

Springs, Jemez Pueblo, and San Ysidro. The spring source and infiltration gallery of the 

Ponderosa water supply are located near the Paliza Campground. 

Wetlands, Riparian Areas, Seeps, and Springs

There are 41 wetlands totaling nearly 100 acres and nearly 4,600 acres of riparian areas. There are 

about 4,500 acres of floodplains in the area, which almost exactly overlay the riparian areas. 

Forty-three (43) springs and seeps are also located here. We have very little information about 

historic flow or water quality from these springs. Many of the springs have been adversely 

affected by human activities including recreation, grazing by domestic livestock and ungulates 

(elk, deer), and piping water offsite to spring boxes and water troughs. Many springs are now in a 

declining or degraded condition. Most of these features are in a degraded condition or function 

right now, and will continue to decline. 

Topography and Soil Quality

The project area consists of rugged, forest covered terrain at elevations from 5,000 to 10,000 feet. 

Soils in the area are formed about equally from volcanic ash flows and lavas, or from sandstones, 

siltstones, shales, and carbonates. Deeper, moister soils are found at higher elevations and have 

more organic matter. They are productive growing environments for trees. Soils on the mesa tops 

are more arid and have deep clay layers. The intense monsoon rains contribute to sheetwash 

erosion (a film or sheet of water that covers the ground) and soil creep (slow movement of soil 

and rock). The volcanic soils are highly erosive. 
Chapter 3. Affected Environment and Environmental Consequences

164 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 43. Perennial and intermittent streams in the project area.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 165

Soil loss rate (erosion) is an indicator of soil condition, productivity, and sustainability26. Soils in 

the assessment area are generally in satisfactory condition in terms of soil loss rate, particularly in 

the ponderosa pine, mixed conifer, aspen and riparian vegetation types. The satisfactory condition 

means that long-term soil productivity is being maintained and the soil will nourish and support 

tree and plant growth. The piñon-juniper woodlands have a greater percentage of soils that can 

easily erode. High soil loss rates often mean that too much soil is getting into the streams; this 

degrades water quality. 

There are small, localized areas with higher soil loss rates in areas where people camp, drive, or 

park, and where livestock use is concentrated. In other areas, the soil is naturally unstable and 

erodible. Most of the soils in the piñon-juniper woodlands erode easily, especially when the tree 

cover is at or over 40 percent. This is because there are fewer grasses and other herbaceous 

understory plants to hold the soil in place. In these areas soil erosion and loss are high and the 

long-term productivity of the soil is at risk. 

Livestock grazing reduces herbaceous ground cover, which can contribute to accelerated soil loss, 

soil compaction, and declined soil productivity, especially during periods of drought. The current 

livestock grazing and other ungulate grazing in some areas is not improving or maintaining 

proper watershed function.

Roads and off-road vehicle use contribute the most to loss of soil productivity and impacts on 

water quality. There are approximately 1,330 miles of roads throughout the total area of the 

subwatersheds (HUC 12s). Road density exceeds the forest plan standard in many areas. Most of 

the roads in the area are primitive dirt roads with little or no drainage control. Many roads run 

along canyon bottoms, and criss-cross stream channels. The travel management analysis (USFS 

2012a) found that most of these roads pose a risk to water quality, soil, wildlife, and other 

resources.

Erosion hazard is another way to rate soil condition. Erosion hazard measures the likelihood that 

soil loss will exceed tolerable levels if there is a complete removal of vegetation and topsoil, as 

might happen after a severe wildfire or flood. About 35 percent of the soils in the assessment area 

have an erosion hazard rating of severe (figure 44). Sulphur Creek and Outlet San Antonio Creek 

subwatersheds have the greatest percentages of highly erosive soils, each at about 75 percent. 

Methods Used to Analyze Effects 

The environmental consequences will be described qualitatively and quantitatively at the HUC12 

(subwatershed) level and are supported by past studies and observations. The primary tool used 

for this analysis is the Equivalent Disturbed Area (EDA), also known as the Equivalent Roaded 

Area (ERA) (Seidelman 1981; USFS 1988). The EDA/ERA analysis calculations will determine 

potential risk to watershed functions and water and soil resources. The EDA/ERA measures the 

acres of disturbed soil in a watershed that would result from the proposed actions. It assumes that 

these disturbed acres are bare soil. 

 

26 Soils are rated as Satisfactory, Unsatisfactory or Unsuited by comparing current soil loss rate to a 

tolerance condition. Soil loss is rated as satisfactory where the soil loss rate is less than the soil tolerance 

threshold defined for each soil type (TEUI unit).
Chapter 3. Affected Environment and Environmental Consequences

166 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Figure 44. Areas with an erosion hazard rating of severe. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 167

Information and data sources used are (1) Terrestrial Ecosystem Survey (TES) for the Santa Fe 

National Forest (Miller et al. 1993); (2) Watershed Restoration Action Plan-Outlet San Antonio 

(SNF 2011); (3) the Santa Fe National Forest Plan, (USFS 1987b); (4) the Landscape Assessment 

(USFS 2010b) and (5) agency reports and scientific literature. Resource specialists from the forest 

and the New Mexico Environment Department, and other collaborators and cooperators also 

contributed. Soil and watershed conditions were assessed using Geographic Information Systems 

(GIS) data obtained from the Santa Fe National Forest GIS corporate database. 

Effects on HUC12 subwatersheds were assessed quantitatively by comparing predicted effects 

from major ground-disturbing activities including mechanical treatments, prescribed fire, 

wildfires, and livestock grazing. The threshold of concern was set at 15 percent; this is less than 

the 20 percent threshold in the forest plan. This means that 15 percent of the acres in the project 

area can be disturbed before additional protective measures are needed. Some of the treatments 

would take place in HUC12 subwatersheds that currently exceed the 15 percent threshold of 

concern. The additional protective measures in appendix A would be used when treatments are 

started. 

Analysis Questions

The analysis questions were derived from the purpose and need and the issues that arose during 

scoping as described in chapter 1. The relevant analysis questions are:

• Would project activities improve the function of riparian ecosystems and streams? 

• Would there be less erosion, bare soil, and unstable or bare streambanks? 

• Would there be less erosion and fewer headcuts and gullies in upland areas? 

• Would there be fewer impacts from roads?

• What are the effects of the mechanical treatments and landscape burning on water 

quality? 

Other concerns related to soil and water resources came up during scoping: impacts of prescribed 

fire ignition devices on water quality, effects of cutting trees on water quantity, and effects of 

prescribed fire treatments on soils and watersheds. These concerns were addressed in the scoping 

report, which is in the project record.

Summary of Effects 

Effects common to all alternatives: 

• The amount of sediment getting into streams would be reduced by these treatments: road 

decommissioning, streambank stabilization, instream habitat and channel work, campsite 

rehabilitation, and improvement of roads and road-stream crossings. 

• The heavy machinery used for the instream work would produce short-term increases in 

sediment and turbidity in the sections of streams downstream from the work site. Heavy 

machinery used in the mechanical treatments would have short-term effects (0-3 years). 

Treatments would leave areas of bare soil that is prone to erosion. 

• Protecting seeps and springs from grazing animals would allow native vegetation to 

return. The vegetation would stabilize and shade the area and maintain spring and seep 

function. 
Chapter 3. Affected Environment and Environmental Consequences

168 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

• Water yields and water storage capacity of the soil would increase because of prescribed 

fire and mechanical treatments. 

• None of the action alternatives would contribute enough sediment or other pollutants to 

intermittent drainages to result in impairment of any downstream waterbodies. 

• The difference among the alternatives in the EDA/ERA indicator used to measure effects 

is minor. This difference is minor, but the risks associated with alternatives 3 and 4 are 

much larger. The untreated acres are at risk of a severe wildfire that would damage soils 

and watersheds more severely than if mechanical treatments or prescribed fires were 

used. 

The EDA/ERA indicator shows that there is only a slight difference in soil disturbance among the 

action alternatives (tables 28 and 29). An additional 531 acres of soil would be disturbed under 

alternatives 1 and 4 than under alternative 3 because more acres are being treated. The additional 

1,830-acres treated under alternatives 1 and 4 would move more quickly toward a functional fireadapted ecosystem.

Table 28. Equivalent disturbed area/equivalent roaded area (EDA/ERA) values for mechanical 

treatments across the landscape. There is only a 0.2% difference in disturbed acreage between 

alternative 3 and alternatives 1 and 4. 

Alternative 1 Alternative 3 Alternative 4 Alternative 5

EDA/ERA* 4.8% 4.6% 4.8% 5.0%

Acres Treated** 46,745 acres 44,915 acres 46,745 acres 48,065 acres

Potential 

EDA/ERA 

Disturbed

13,556 acres 13,025 acres 13,556 acres 13,949 acres

Table 29. Equivalent disturbed area/equivalent roaded area (EDA/ERA) values for prescribed fire use 

across the landscape. There is only a 0.9 percent difference in disturbed acreage between alternative 

4 and alternatives 1, 3, and 5. This is because fewer acres are disturbed by prescribed fires under 

alternative 4. 

Alternative 1 Alternative 3 Alternative 4 Alternative 5

EDA/ERA* 2.2% 2.2% 1.3% 2.2%

Acres Treated 76,888 acres 76,888 acres 45,300 acres 76,382 acres

Potential EDA/ERA 

Disturbed

1, 692 acres 1,692 acres 589 acres 1, 611 acres

Environmental Consequences 

Alternative 1

Mechanical Treatments

Mechanical treatments (including aspen regeneration and meadow enhancement) have the 

potential to adversely affect watershed response27 and water quality. Heavy machinery would 

 

27 The watershed response is the interaction between the vegetation and precipitation, and whether rain and 

snow are absorbed into the soil or not.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 169

disturb the soil, which could lead to soil detachment and transport. This would have a short-term, 

adverse effect on water quality. Use of the design criteria, mitigation measures, and BMPs (see 

appendix A) would limit the amount of soil lost. There would be some short-term effects on soil 

detachment and transport (erosion), but the location and magnitude would not adversely affect 

long-term water quality.

Mechanical treatments would reduce basal areas and canopy cover. With fewer trees, more 

precipitation would reach the ground and be absorbed into the soil. Understory vegetation would 

also increase after trees are cut (Baker 1999, Brown et al. 1974, Rich et al. 1976). This in turn 

would slow the overland flow of water and improve water absorption into the soil. With more 

surface vegetation, the organic layer of the soil would increase over time. This thicker organic 

layer would allow the soil to hold more water (Shepperd et al. 2006). Treatments in piñon-juniper 

and aspen would have similar effects, but these effects would be greater in aspen (Calkin et al. 

2010). Regenerating aspen stands may also result in increased soil carbon storage (Woldeselassiea 

et al. 2012) and increased water yields (Harper et al. 1981). Finally, removing encroaching 

conifers from meadows may increase water yield for 6-10 years (Baker 1982). This effect 

diminishes as conifers grow back.

Prescribed Fire

Prescribed fire would likely help increase available soil moisture by reducing evapotranspiration 

by overstory trees (Springer and Stevens 2008). With fewer trees, more rain and snow would 

reach the ground and be absorbed into the soil. It would not get caught in the tree canopy and 

evaporate. 

Prescribed fire would remove the existing layer of pine needles, small branches, and other litter 

and duff. This would increase understory vegetation and lead to improvements in water 

absorption, like the mechanical treatments do (Kaufmann 1985; Ffolliott et al. 1989; Baker 1999; 

Bartos 2001; Baker 2003; Dore et al. 2010). Prescribed fire would also create a source of large 

woody debris and improve soil nutrient cycling. Burning would release nutrients in the pine 

needles and other fine fuels, which would move into the soil.

Riparian areas next to ponderosa pine forest are adapted to minor pulses of sediment and ash in 

stormwater runoff after low-severity fires. The sediment and ash provide nutrients that support 

riparian vegetation. Riparian areas are expected to respond positively to low-severity prescribed 

fire as a result of increases in available water and nutrients.

Prescribed fire that burns with a high intensity (hotter) could damage the soil, especially in areas 

where there is more fuel, like riparian areas. A lighting pattern that allows fire to back down into 

riparian areas would prevent soil damage. Protective measures are found in appendix A.

Other Treatments

The road treatments, instream work, headcut treatments, campsite rehabilitation, and streambank 

stabilization would improve water quality by reducing the amount of sediment that goes into 

streams. Estimated reductions in sediment over the entire project area for some of these 

treatments are: 

• Road decommissioning- 29,430 tons of soil

• Campsite rehabilitation- 19 tons of soil
Chapter 3. Affected Environment and Environmental Consequences

170 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

• Instream work and streambank stabilization- 623 tons of soil

These reductions would occur over the life of the project. 

Alternative 2

Over the short term, there would be less soil disturbance because there would be fewer types of 

ground-disturbing treatments and fewer acres would be treated. Watershed conditions, however, 

would continue to decline because most of the area would be covered by dense stands of trees. 

Most of the snow and some of the rain would be intercepted by the canopy and evaporate or 

transpire. Less water would be absorbed into the soil and there would be less surface water and 

groundwater quantities in the watersheds. This would result in a long-term decrease in watershed 

function and resiliency. 

Short-term water quality would remain about the same as it is now. Stream channel and 

floodplain conditions would continue to decline. It is likely that the Rio Cebolla would be 

redesignated28 as an impaired stream because of sediment and turbidity. 

If an uncharacteristically severe wildfire occurred, the trees, ground vegetation, woody material, 

and organic matter on the forest floor would be lost over much of the area. The surface would be 

bare soil covered by ash. The high heat intensity of a wildfire would cause some soils to be 

hydrophobic, meaning water would run off rather than infiltrate the soil. Studies comparing fuel 

reduction thinning projects and wildfires in the Southwest show that wildfires typically produce 

about 70 times as much sediment as thinning treatments (Neary et al. 2005). 

There would be severe soil erosion on steep slopes (over 40 percent) after a severe wildfire. After 

a severe rainstorm, there would likely be areas of mass erosion, excessive water and sediment 

runoff, gully formation, and some flooding of the streams just downstream from the project area. 

These are effects similar to the flooding in Santa Clara and Cochiti Canyons after the Las 

Conchas wildfire. Water quality and drinking water supplies of downstream communities could 

be affected for decades (Rhoades et al. 2011).

Using the EDA/ERA indicator, a severe wildfire would cause an unacceptable increase in soil 

disturbance. Watershed recovery from such a wildfire could take years, decades, or even centuries 

(Rhoades et al. 2011). Severe fires like Rodeo Chediski, Cerro Grande, Wallow, Las Conchas and 

others leave watersheds and large areas of soil severely burned. Some watersheds may not be able 

to recover and the landscape would take many years to recover, if at all (Neary et al. 2012).

Alternative 3

Effects from prescribed fires and other treatments are similar to those discussed under 

Alternatives 1 because the same amount of acres would be treated. Effects on water quality would 

be similar to those discussed under alternative 1 if a severe wildfire does not occur on the 

untreated acres. A severe wildfire burning on the untreated acres could have a long-lasting 

negative impact on water quality. Some streams could be listed as impaired.

About 1,900 fewer acres would be mechanically treated because temporary roads would not be 

built. Effects would vary depending on where the untreated acres are located, but a wildfire or 

 

28 Rio Cebolla was delisted for sedimentation in 2008.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 171

prescribed fire would burn more severely in the areas that are not mechanically treated because 

there is more fuel. If these areas are located near the headwaters of a stream, stream reaches could 

become dysfunctional, as described under alternative 1. Observation of wildfires throughout 

Arizona and New Mexico has demonstrated that when a minimum of 300 acres located in the 

headwaters of a watershed has a moderate to high soil burn severity, the stream channel cannot 

respond properly (Snyder 2013). The water runoffs would downcut the stream channel to the 

point where water cannot flow out on the floodplain. 

Alternative 4

Effects from mechanical treatments and the other restoration treatments are similar to those 

discussed under alternative 1 because the same amount of acres would be treated. Effects on 

water quality would be similar to those discussed under alternative 1 if a severe wildfire does not 

occur on the untreated acres. A severe wildfire burning in an area that was not treated with 

prescribed fire could have a long-lasting negative impact on water quality. Some streams could be 

listed as impaired. 

Effects from prescribed fire would be different under this alternative because fewer acres are 

treated. The areas not treated by prescribed fire would have more fuels. Ecosystem conditions on 

those untreated acres would decline and watershed function and response would decrease. Soil 

nutrient cycling would be less effective, and understory plants would be less abundant. With 

fewer plants, more water would run off instead of being absorbed. A wildfire would be more 

intense (hotter) because of the higher amount of fuels and soils would be severely burned. This 

could result in the loss of 3,158,800 tons of soil. 

Alternative 5

Under this alternative, there would be no prescribed fire in the core areas of Mexican spotted owl 

habitat. All other treatments would remain the same. Approximately 700 fewer acres would be 

treated with prescribed fire than under alternatives 1 and 3. 

The EDA/ERA values are approximately equivalent to alternatives 1 and 3 (see table 29). 

Reducing the amount of acres treated with prescribed fire makes only a negligible difference in 

the amount of soil disturbance (.005 percent less than alternatives 1 and 3). There is a slight shortterm improvement in EDA/ERA in the core areas. Over the long term, however, the lack of 

treatment in core areas would result in higher fuel loads and fewer understory plants, which 

would put the core areas at risk of experiencing an uncharacteristically severe wildfire. 

There would be minor, short-term improvements in water quality and soil condition under 

alternative 5 due to the lack of prescribed fire treatments in the core areas. Water quality would 

likely decline over the long term because of the decline or loss of understory plants that usually 

slow, intercept, or filter overland water flows (Rhoades 2011). Soil condition would also likely 

decline over the long term because the dense tree canopy would inhibit understory plant growth 

and nutrient cycling (Neary et al. 2012; Woldeselassiea et al. 2012).

Forest Plan Amendments 

• The amendments related to vegetation treatments in Mexican spotted owl habitat, 

removing breeding season restrictions, and clarifying interspace treatment in goshawk 

habitat would have slight effects on soils and water. Without these amendments, fewer 
Chapter 3. Affected Environment and Environmental Consequences

172 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

acres would be treated with prescribed fire, and fewer acres would be treated to a lower 

density (basal area). Stand density would remain slightly higher resulting in: 

• Fewer grasses and forbs in the understory

• Less soil nutrient recycling

• Reduced interception and absorption of precipitation and overland water flow

• Increased evapotranspiration and greater interception of rain and snow fall in the tree 

canopy, resulting in less soil moisture and decreasing groundwater recharge. 

• Soil condition would also decline sooner because the dense tree canopy would inhibit 

understory plant growth and nutrient cycling 

Cumulative Effects 

The area analyzed for cumulative effects on soils and watersheds includes all of the HUC12 

subwatersheds that intersect the project area. The projects considered in the analysis are found in

appendix B. 

The cumulative effects combined with alternative 2 (no action) and a severe wildfire would 

produce an unacceptable risk of watershed disturbance. This disturbance could easily lead to or 

produce an ecosystem type change or desertification (Rhoades et al. 2011; Neary et al. 2012). If 

there is no wildfire, ecosystem conditions would continue to decline the potential for an 

uncharacteristically severe wildfire would increase. This would be an unacceptable watershed 

function trajectory throughout the project area.

The effects of the action alternatives, when added to the effects of recent fires immediately 

outside the project area and on the Valles Caldera Preserve would not create a significant 

cumulative effect on watershed disturbances. The design criteria and best management practices

in appendix A would reduce the amount of soil detachment and transport associated with the 

treatments in all the action alternatives. This will maintain and improve water quality.

Conclusions About the Effects 

The action alternatives would meet the purpose and need as stated in the analysis questions:

• Riparian ecosystem and stream functions would improve

• Using prescribed fire in riparian areas would create potential source of large woody 

debris for streams. Streams would eventually have more large woody debris and there 

would be more native riparian vegetation

• There would be less erosion, bare soil, and unstable or bare streambanks

• Roads would have fewer impacts on stream sedimentation

• Long-term soil productivity would decline under alternative 2 

• Some short-term adverse effects for soil erosion and water quality would occur as a 

consequence of the restoration actions. An overall long term gain is expected to offset 

these consequences. 

The road treatments, especially road maintenance and improvement of road-stream crossings, 

would have the most impact on reducing the amount of sediment that gets into streams. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 173

Alternatives 3 and 4 disturb less soil than alternatives 1 and 5 because prescribed fire and 

mechanical treatments are used on fewer acres (see table 3 in chapter 2). This difference between 

alternatives 3 and 4 and alternatives 1 and 5 is minor, but the risks associated with alternatives 3 

and 4 are much larger. The untreated acres or acres with a higher tree density are at risk of a 

severe wildfire that would damage soils and watersheds more than if prescribed fires or 

mechanical treatments were used. Alternatives 1 and 5 have similar effects.

Vegetation 

The silviculture specialist report (Schantz and Harrelson 2013) is incorporated by reference. See 

the report for detailed information on data sources, methodology, assumptions and limitations. 

The terms mechanical treatment and harvest are used in this section. Mechanical treatment refers 

to cutting and/or removing trees with chainsaws, feller-bunchers, skidders, masticators, or other 

equipment. Harvest or harvesting is also known as logging. This is the cutting, removal, and 

loading of trees or logs onto log trucks (SAF 2008). 

Affected Environment 

Description of the Forest Cover Types

The Southwest Jemez Mountains landscape is noted for its diversity and includes mainly 

ponderosa pine, piñon-juniper, and mixed conifer forest cover types. Grasslands, meadows, 

wetlands and riparian areas are also found across the landscape. The amount of the major cover 

types (vegetation types) found in the area is shown in table 30 below. The discussion will focus 

on the cover types that would be mechanically treated and/or harvested: ponderosa pine, dry 

mixed conifer, piñon-juniper and wet mixed conifer. All of these cover types and features are 

described in more detail in the Landscape Assessment (USFS 2010b). The existing condition of 

the cover types is described in chapter 1.

Table 30. Percent and acres of vegetation types in the analysis area. Ponderosa pine is the most 

common vegetation type.

Cover Type Acres Percent of Area

Ponderosa Pine 43,591 39.9%

Piñon-Juniper 34,497 31.6%

Dry Mixed Conifer 21,950 20.1%

Wet Mixed Conifer 3,910 3.6%

Burned Area (Las Conchas 

recent fires)

and other 3,616 2.4%

Grassland 938 0.9%

Aspen 755 0.7%

Oak Woodland 379 0.3%

Gambel Oak (Shrub) 208 0.2%

Rockland, Talus, Scree 241 0.2%

Juniper Woodland 118 0.1%

Strip Mines, Quarries, Gravel Pit 57 0.1%
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174 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Ponderosa Pine

Ponderosa pine is the dominant forest type in the area. It ranges from lower elevation, dry sites 

where it is mixed with piñon-juniper woodlands up to higher elevation, moist sites where it 

grades into mixed conifer. Overstory tree species found with ponderosa include Douglas-fir, 

white fir, aspen, juniper and limber pine. Understory vegetation includes shrubs, Gambel oak, and 

bunchgrasses. Ponderosa pine regenerates most successfully in openings with bare soil. 

Ponderosa pine stands are established and maintained by low-intensity surface fires, logging, or 

other disturbances that favor shade-intolerant species. 

Dry and Wet Mixed Conifer

Mixed conifer forests are complex, highly variable, and have of a variety of species including 

Douglas-fir, white fir, ponderosa pine, blue spruce, aspen, and limber pine. For consistency with 

the wildlife habitat analysis, we use the definition of mixed conifer in the Mexican spotted-owl 

recovery plan (USFWS 1995). This definition includes stands within Douglas-fir, white fir, 

limber pine, and blue spruce habitat series29. 

Most of the mixed conifer in the project area is dry mixed conifer and is typically found at lower 

elevations than wet mixed conifer. Ponderosa pine and Douglas-fir are the main species. In some 

areas, shade-tolerant species such as white fir are becoming dominant in the understory due to 

past fire suppression and past management practices. Historically, dry mixed conifer stands were 

uneven-aged due to disturbances. Heavy regeneration events, harvesting, and fewer natural 

disturbances have created stands that are dominated by one or two age classes. This forest type 

now has an understory of shade tolerant tree species and is much denser than 100 years ago. 

Conditions then were much more open than they are today, with a more productive and diverse 

understory of grasses and non-woody plants. 

In wet mixed conifer forests Douglas-fir, limber pine, and white fir are the main species. Blue 

spruce, Englemann spruce, and aspen are also found in wet-mixed conifer stands. Aspen is the 

early seral stage of wet mixed conifer. The composition of these stands has not changed 

drastically from historic conditions, but in general, more stands are in a late seral stage.

Aspen

Aspen is found in patches associated with disturbance. When a fire, landslide, insect outbreak, or 

other disturbance kills conifer trees, aspen quickly sprouts and grows. Over time, conifers 

establish in the shade of the aspen and eventually grow to overtop and shade out the aspen. Aspen 

remains as clumps or individual trees until the next disturbance. Aspen will frequently grow in the 

sunny gap created by a single tree that dies and falls over. Some of the aspen groups in the project 

area are young, dating to wildfires in the 1970s. However, most of the aspen is mature or 

overmature, with a heavy component of conifers succeeding in its place. 

The amount of aspen in the area had been decreasing due to drought and the absence of large 

scale disturbance, until the recent large fires. This is the case across much of the West. In fact, the 

total acreage of aspen in the Southwest is decreasing yearly, as the more shade tolerant mixed 

conifer species, such as white fir, become established and eventually replace the aspen stands. 

 

29 The definition of mixed conifer is found in part II. C, page 56, of the recovery plan.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 175

Figure 45a. Dry mixed conifer forest. This stand has a few large 

trees. Many of the small trees need to be thinned.

Figure 45b. Wet mixed conifer forest. These forests have not 

changed drastically.

Piñon-Juniper

Piñon-juniper woodlands are a prominent vegetation type here and are found in the southern part 

of the project area. It is a diverse type that ranges from open savannas to dense woodlands. The 

two types of piñon-juniper found here are shrub woodlands and persistent woodlands (Romme et 

al. 2009). Shrub woodlands are dominated by trees, but have a high cover of shrubs such as 

turbinella oak, mountain mahogany, and sumac. Persistent woodlands are found on shallow 

upland soils that favor piñon and juniper over grasses. Sparse grasses, forbs, and/or shrubs 

interspersed with bare ground make up the understory.
Chapter 3. Affected Environment and Environmental Consequences

176 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Although a large portion of the project area is covered with piñon-juniper, few treatments are 

planned there. Much of the area is steep, or inaccessible, or is already close to desired condition. 

There may be some places where treatments would be beneficial and would be implemented. 

Snags and Old Growth

Snags (dead, standing trees) are a key component of wildlife habitat. They are used for roosting 

and nesting by birds and mammals, and insects in the bark serve as a food source. The current 

snag population is dominated by the 12 to 18 inch size class (table 31), which reflects the current 

dominance of small trees in the project area. The number of snags 10-inches diameter and larger 

meets the general forest plan standard. The number of snags 18-inches diameter and larger, 

however, is slightly below the forest plan guideline for goshawk habitat, but it has been 

increasing over the past decade due to mortality from fires, insects and diseases, and dense stand 

conditions. 

Table 31. Average number of snags per acre by cover type

Cover Type 12+ Inches

Diameter

18+ Inches

Diameter

24+ Inches* 

Diameter

Piñon-Juniper 2.0 0.5 0.0

Ponderosa Pine 2.7 0.8 0.2

Dry Mixed Conifer 5.6 1.5 0.5

Wet Mixed Conifer 7.8 1.9 0.7

The diameter classes are non-exclusive, so 12+ includes all snags greater than 12 inches, 18+ includes all 

snags 18 inches and larger, and 24+ includes all snags 24 inches and larger. The forestwide management 

direction calls for managing for 2 natural snags per acre on a minimum of 40 percent of the ecosystem area.

The forest plan defines old growth as a condition of the forest having structural attributes based 

on the number of large trees per acre, basal area, canopy cover percent, dead standing trees, and 

down logs. Old growth is analyzed at three scales: the ecosystem management area (EMA) scale

and one scale above and below the EMA in accordance with forest plan direction and definitions 

(USFS 1987b). Because the project area is quite large, the interdisciplinary team defined the 

EMA as the entire project area. The Jemez Mountains were used as the scale above the EMA, and 

forest stands were used as the scale below. 

The vegetation types for allocating old growth in the EMA are ponderosa pine and mixed conifer. 

Old growth standards require allocating at least 20 percent of each vegetation type as old growth 

in blocks of 40 acres or more, if possible. In ponderosa pine, 8,716 acres were allocated as old 

growth; in dry mixed conifer, 5,171 acres. Old growth was not allocated in other forest vegetation 

types because there are few treatments planned in those areas.

Insects and Disease

The level of insect activity has varied over the years. Western spruce budworm has been the most 

chronic and widespread pest in the Southwest Jemez Mountains area, affecting over 2,000 acres 

in some years. Within the project area, Paliza Canyon has seen repeated outbreaks. Ponderosa 

pine mortality from bark beetles spiked last year, mostly due to effects from the Las Conchas fire. 

Bark beetle hazard is high over most of the area. High stand density increases susceptibility to 

bark beetle activity and mortality.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 177

Dwarf mistletoe and root diseases are common pathogens in the area. They are slow-acting and 

their effects are difficult to measure. Root diseases are a chronic condition and spread slowly, and 

in this area, do not require any special treatment at this time. Based on stand exam data, about 57 

percent of ponderosa stands have some degree of dwarf mistletoe infection. On a stand-level 

basis, these are light to moderate infections, with isolated spots of heavy infections. 

Habitat for Northern Goshawk and Mexican Spotted Owl

This analysis will focus on forest cover types identified in the forest plan (USDA 1987, as 

amended in 1996) for Mexican spotted owl and northern goshawk habitat and the revised 

recovery plan (USFWS 2012) for the Mexican spotted owl, namely ponderosa pine and mixed 

conifer. There is no pine-oak habitat in the project area. All forested habitat was stratified to meet 

analysis requirements in the forest plan for Mexican spotted owl and northern goshawk (see the 

wildlife and silviculture specialist reports). There are 25,960 acres of Mexican spotted owl habitat 

in the project area (mixed conifer). There are 43,491 acres of northern goshawk habitat, 

(ponderosa pine). 

Mexican spotted owl habitat would be managed using direction in the revised recovery plan 

(alternatives 1, 3 and 4), or using the current forest plan standards and guidelines (alternative 5). 

Under both the revised recovery plan and the forest plan, 25 percent of restricted or recovery 

habitat would be managed to meet the target/threshold or nest/roost values. Under the revised 

recovery plan, 3,733 acres currently meet these values, and an additional 2,031 acres could be 

managed toward these values. Under the forest plan guidelines, 1,717 acres currently meet these 

values; an additional 2,792 acres could be managed toward meeting these values. The remaining 

seventy-five percent of owl habitat could be managed toward an uneven-age condition 

Stands that are not being managed for the owl will be managed to comply with the forest plan 

standards and guidelines for northern goshawk (USFS 1987b as amended). This is a large portion 

of the project area, approximately 43,500 acres. The objective is to manage for uneven-aged stand 

conditions over the long term. Currently, 89 percent of the area classified as goshawk habitat is in 

an even-aged stand condition. 

In the forest plan, uneven-aged stand conditions are described in terms of vegetation structural 

stages (VSS). The VSS should be balanced within the stand and across the landscape. The desired 

distribution of vegetation structural stages is: 10 percent each in VSS 1 and VSS 2 and 20 percent 

each in VSS 3, 4, 5, and 6. This is described as an uneven-aged mix of tree sizes distributed with 

variable spacing, mostly in groups across the landscape. The forest structure should be more like 

a mosaic than a homogenous, closed canopy forest, like it is now. 
Chapter 3. Affected Environment and Environmental Consequences

178 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Existing VSS distribution in goshawk forest habitats was analyzed at three scales: plot-level 

(fine-scale), stand-level (mid-scale), and landscape-level (ecosystem management area- the 

project area). The plot-level is the most relevant because treatments are applied at the fine scale, 

and the objective is to develop within-stand variability over time. Tables showing the distribution 

of VSS classes at each scale are found in the silviculture specialist report.

Most of the goshawk foraging habitat is in an even-aged stand condition. Stands are dominated by 

young trees 5 to 12 inches diameter (VSS 3). This shows that the forest is fairly homogenous and 

lacks regeneration openings (VSS 1), seedlings and saplings (VSS 2), and large trees (VSS 5, 6). 

Goshawk nest stands and post-fledging family areas are also dominated by small trees in VSS 3 

and 4. Conditions are similar at the landscape and plot levels. Other classes, particularly VSS 1, 

2, 5, and 6 (mature forest and old trees) are well below the desired condition. 

Stand Density

Stand density is a quantitative measure of stocking as measured by the number of trees, basal 

area, or volume per unit area, or relative to some standard condition (SAF 2008). One measure of 

density is basal area (BA). This is the cross-sectional area of all the stems in a stand. A higher 

basal area usually means a higher canopy cover or tree density, less ground cover, and more tree 

competition. A stand with high basal area could have a few large trees, or many small trees. 

Hence, it is also useful to know the number of trees per acre, to get a picture of the stand. Trees 

per acre (TPA) is another measure of density and is the number of standing trees on an acre. 

Within the project area, in all habitat strata for both the Mexican spotted owl and the northern 

goshawk, basal area is higher than desired. This indicates that the stands could be experiencing 

tree mortality and are vulnerable to beetle attacks.

Effects of Past Human and Natural Events on Forest Conditions

The ecosystems throughout this area have been radically altered by past management. Since the 

late 1800s logging, livestock grazing, and fire suppression have changed the structure, density, 

and species composition of the forests in the area. Much of the area was selectively logged in the 

early to mid-1900s. Ponderosa pine was the commercially favored species for removal, and most 

Vegetation Structural Stages (VSS)

The VSS class is based on the majority of trees in the specific diameter distribution. 

There are six classes:

• VSS 1: grass/forb/shrub

• VSS 2: less than 5-inches diameter- seedling-sapling 

• VSS 3: 5-12 inches diameter- young forest 

• VSS 4: 12-18 inches diameter- mid-aged forest

• VSS 5: 18-24 inches diameter- mature forest

• VSS 6: greater than 24-inches diameter old trees 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 179

Figure 46. This is the type of opening that forests in the area used to have, 

where grasses and flowers can grow. Treatments in the proposed action 

would create more such openings.

of the large ponderosa were cut. Other species, such as Douglas-fir and white fir, were often left 

in the stands.

The natural fire regime has been interrupted since the late 1800s. High numbers of sheep and 

cattle that grazed in the Jemez Mountains reduced the native grasses that carried surface fires. 

The Forest Service suppressed wildfires, even those that would have benefited the landscape. 

Without fire to control their numbers, seedlings and saplings thrived. As a result, the forests are 

currently dominated by dense thickets of pole-size trees (5-16 inches in diameter). Understory 

grasses and plants, large, thick-barked pine trees, and old growth are lacking. The species 

composition has shifted, and ponderosa pine forests now resemble mixed conifer forests with 

more Douglas-fir, white fir, and limber pine. 

Insects and diseases are a natural and common occurrence in all forest types in the Jemez 

Mountains. In the overly dense forests, trees compete for light, moisture and nutrients. Tree 

growth and vigor are reduced and forest stands are more susceptible to outbreaks of insects or 

diseases. Bark beetles, defoliators (leaf eaters), and dwarf mistletoes have had widespread 

impacts, and their activity has increased in the last year. Nearly 90 percent of the ponderosa pine 

and dry mixed conifer forests are in a density condition that makes them susceptible to mortality 

from bark beetle activity.

Methods Used to Analyze Effects 

Data on the existing condition of vegetation came from the following sources: stand exams for 

nearly half of the area covered by ponderosa pine and mixed conifer forest types; the Forest 

Service GIS Corporate Data (SNF 2012a); aerial photos; and field surveys. 
Chapter 3. Affected Environment and Environmental Consequences

180 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The methods used to analyze the effects of the mechanical treatments were: 

• Nearest Neighbor. This computer program was used to assign stand exam data (reference 

stands) to the stands without stand exam data (Crookston et al. 2002). 

• Forest Vegetation Simulator (FVS). This is a modeling program used for predicting forest 

stand dynamics. The Central Rockies variant of the FVS model was used for this project 

(Keyser and Dixon 2008). 

The stand exam information, field surveys, and aerial photo interpretation were used to determine 

forest cover types, size classes, and density. Mexican spotted owl restricted habitat was computed 

using the FVS model. All forested habitat was stratified to meet analysis requirements in the 

forest plan for Mexican spotted owl and northern goshawk. 

In relation to forest vegetation, we identified two main measures:

• Restore spatial pattern, processes, resiliency, structure, and species composition by 

creating generally open, uneven-aged forests in ponderosa pine and dry mixed conifer 

types. 

♦ Indicators: Forest stand conditions including stand density, acres treated, and change in 

proportion of VSS classes

• Offset treatment costs and provide economic opportunity. 

♦ Indicators: Amount and type of merchantable sawlogs, firewood, biomass, and other 

forest products generated. 

Analysis Question

The analysis question was derived from the purpose and need of the project as related to forest 

vegetation: 

• Would the mechanical treatments restore spatial patterns, processes, resiliency, structure, 

and species composition in ponderosa pine and dry mixed conifer types? 

This would be measured using indicators of forest stand conditions including basal area, trees per 

acre, acres treated, and change in proportion of VSS classes.

Summary of Effects 

The effects are summarized using the indicators above. 

Acres treated

• Alternatives 1, 4, and 5: 31,400 acres would receive mechanical treatments

• Alternative 2: 800 acres are mechanically treated 

• Alternative 3: 29,500 acres of mechanical treatments 

Resilience, Processes, and Patterns

• Alternatives 1 and 5 are most effective at promoting ecosystem resiliency because more 

acres would receive restoration treatments, including prescribed fire. Alternative 3 is 

almost as good. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 181

• The beneficial effects of the treatments in Mexican spotted owl habitat would last longer 

under alternatives 1, 3, and 4 than under alternative 5 because treatments are heavier 

(more trees are cut). These areas would also grow larger trees slightly faster under these 

alternatives than under alternative 5 because of the reduced density. 

• Under alternative 2, resiliency would not improve. The forest would remain overstocked 

and vulnerable to an uncharacteristically severe fire, insect outbreaks, and heavy dwarf 

mistletoe infections. 

• The 1,900 acres that are not mechanically treated would remain overstocked and 

vulnerable to disturbances. 

• Under alternative 4, resilience is improved on all treated acres, but not as much as 

compared to alternatives 1, 3, and 5. Effects in areas that only receive mechanical 

treatments would differ depending on how the slash is treated. Slash that is left on site 

could increase fire hazard. Masticating the slash would be better than leaving it, but 

stands would still be at some increased risk of wildfire, and fire effects are likely to be 

more severe. This alternative provides the ecological benefits of fire on 45,400 acres; 

however, this is far less than alternatives 1, 3, and 5. 

Forest Stand Conditions (Stand Density and VSS)

• Alternatives 1 and 5 restore forest structure and species composition and move the forest 

toward uneven-aged stand conditions as outlined in the forest plan. Alternative 3 also 

meets the restoration objectives, but on slightly fewer acres. Alternative 4 meets desired 

stand conditions, but it would be harder to maintain these conditions over time without 

fire. Tables 32-35 show changes in stand density indicators and VSS classes, before and 

after treatment. Both basal area and trees per acre are lowest after treatment and are still 

below pre-treatment levels after 20 years. VSS classes would be better balanced than they 

are now and eventually reach equilibrium. 

• Alternative 2 leaves the forest overstocked and vulnerable to an uncharacteristically 

severe fire and insect outbreaks and heavy dwarf mistletoe infections.

Economic Opportunity

• Alternatives 1, 3, 4, and 5 create economic opportunity, and alternative 2 does not. 

Alternative 5 provides a slightly higher volume of wood products. 
Chapter 3. Affected Environment and Environmental Consequences

182 FEIS of the Southwestern Jemez Mountains Landscape Restoration Project

Table 32. Changes in density indicators for alternatives 1, 3, and 4, by Mexican spotted owl habitat strata. Both basal area and trees per 

acre are lowest after treatment and are still below pre-treatment levels after 20 years.

Habitat Strata* Treatment Basal Area Basal Area Basal Area 20 TPA before TPA after TPA 20 Years 

Acres before after Years after Treatment Treatment after 

Treatment Treatment Treatment Treatment

MSO PAC 410 135 92 108 634 155 139

MSO 1,680 178 104 126 1,893 301 288

Nest/Roost

Table 33. Changes in density indicators for alternative 5 by Mexican spotted owl habitat strata. Both basal area and trees per acre are 

lowest after treatment and are still below pre-treatment levels after 20 years

Habitat Strata* Treatment 

Acres

Basal Area 

before 

Treatment

Basal Area 

after 

Treatment

Basal Area 20 

Years after 

Treatment

TPA before 

Treatment

TPA after 

Treatment

TPA 20 Years 

after 

Treatment

MSO PAC 410 135 105 121 634 224 205

MSO 

Target/Threshold

360 192 128 153 1,856 256 245

MSO Protected 30 163 71 88 1,166 77 73

Table 34. Changes in density indicators for alternatives 1, 3, 4, and 5 by goshawk habitat strata. Both basal area and trees per acre 

lowest after treatment and are still below the pre-treatment level after 20 years

Habitat Strata Treatment 

Acres

Basal Area 

before

Treatment 

Basal Area 

after Treatment

Basal Area 20 

years after 

Treatment

TPA before 

Treatment

TPA after 

Treatment

TPA 20 years 

after Treatment

Goshawk Nest 330 163 71 87 561 59 56

Goshawk PFA 1,220 153 66 83 601 62 58

Goshawk 

Foraging

20,940 143 58 75 612 62 58
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 183

Table 35. Changes in VSS Class percentages at the stand level with proposed treatments for 

alternatives 1, 3, 4, and 5. VSS classes are better balanced after treatments and are approaching 

equilibrium. 

All Foraging Areas Even-age Foraging 

Areas

Uneven-age 

Foraging Areas

Post-fledging Family 

Areas

VSS 

Class

Existing After 

Treatment

Existing After 

Treatment

Existing After 

Treatment

Existing After 

Treatment

1 <1 % 10 % 1% 10 0 10 2 10

2 1% 10% 1% 10 1 10 1 10

3 52% 19% 53% 19 45 15 47 17

4 35 % 44% 35% 50 35 41 33 42

5 9 % 12% 8% 10 14 13 10 10

6 2 % 5% 2% 2 4 10 7 11

Desired conditions are: VSS 1- 10%; VSS 2- 10%; VSS 3- 20%; VSS 4- 20%; VSS 5- 20%; VSS 6- 20 %

Other Effects

Alternatives 1, 3, and 5

• Improves habitat for Mexican spotted owl and northern goshawk. There are small 

differences between alternatives 1 and 5 resulting from the treatments in Mexican spotted 

owl habitat. 

• Reduces potential for uncharacteristically severe fire throughout the area and creates 

forest conditions that promote low-intensity surface fires

• Retains the large trees and old-growth forest structure necessary to manage for the 

desired condition objectives across the landscape

• Provides economic opportunity and wood products 

• Manages for the sustainable presence of aspen across the landscape.

• Alternative 3 accomplishes the same as alternatives 1 and 5, but on fewer acres 

Alternative 2 

• Habitat for Mexican spotted owl, Jemez Mountains salamander, northern goshawk, and 

other wildlife would continue to decline

• Aspen continues to decline 

• The forest structure of old growth stands would remain susceptible to damage and loss 

from uncharacteristically severe fires

• Treats fewer acres and reduces the overall scale of mechanical and prescribed fire 

treatments. The currently approved projects would be implemented. These projects focus 

on hazardous fuels reduction and not forest ecosystem restoration. 

Alternative 4 

• Improves habitat for Mexican spotted owl and northern goshawk, but on fewer acres than 

alternatives 1 and 3 

• Retains the large trees and old-growth forest structure necessary to manage for the 

desired condition objectives across the landscape
Chapter 3. Affected Environment and Environmental Consequences

184 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

• Untreated slash could elevate fire hazard. Does not create conditions that promote lowintensity surface fires in mechanically treated areas 

• Higher fuel loads resulting from mastication would result in increased fire intensity and 

higher fire residual time that would heat up the soil and kill the roots of the trees.

• Fewer acres would receive the ecological benefits of fire 

• Fewer acres of aspen regeneration

Environmental Consequences

Alternative 1

Mechanical Treatments

The mechanical treatments would restore ecosystem function and structure in ponderosa pine and 

dry mixed conifer forests by reducing tree density and creating openings, and interspaces between 

groups of trees. This natural condition is healthy and sustainable over time. These forests would 

then be more resistant to uncharacteristically severe fires and stressors such as climate change. 

Treatments in aspen would reinvigorate existing stands and increase the amount of aspen on the 

west side of the project area.

Effects on Forest Structure and Function

• Reducing tree density and creating openings and spaces between groups of trees would 

have positive effects on structure and function

• A more diverse forest structure with trees of all ages and sizes across the landscape that is 

sustainable over time. There would be intermingled patches of different sizes and ages. 

As older trees die, younger ones would grow in behind them

• Groups of trees with interlocking crowns and spaces between the groups, which reduce 

the potential for crown fires 

• Trees that grow to a larger size more quickly because there is more room to grow and less 

competition for water and nutrients

• A heterogeneous landscape, with varying tree densities. North-facing slopes would have 

denser forests than south-facing slopes. Stands that are not treated would also add to the 

overall diversity

• Improved old-growth conditions are reached more quickly because of reduced tree 

density. Trees grow to larger sizes more quickly and reach desired conditions sooner

• Small groups and stands of aspen would be common and well distributed across the 

landscape. 

• Openings provide full sun for ponderosa pine seedlings to regenerate (sprout)

• Oak trees receive more sunlight and are free to grow to larger sizes that produce more 

acorns, thus benefiting wildlife 

• Grasses and forbs increase in amount and diversity, providing more cover and food 

sources for wildlife

• Increased resistance to large insect outbreaks because of increased tree vigor. Mistletoe 

would be at natural levels because the space between groups of trees would make it 

harder to spread. Prescribed fire would help control infestations
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 185

Effects on VSS Classes

Mechanical selection cutting treatments would improve northern goshawk habitat by starting the 

development of uneven-aged forest stands. In stands that are currently uneven-aged, these 

treatments would also move the proportion of VSS classes closer to the desired condition. All 

VSS classes would be present on the landscape and would be better balanced than they are now. 

Over time, more trees would grow into the larger classes. More free-to-grow regeneration would 

become established and move toward the desired proportion of the younger age classes. 

Table 36 compares the VSS distribution before and after treatments in goshawk foraging habitat. 

Treatments would emphasize maintaining VSS 2, 5, and 6 (saplings, large, and old trees), which 

are in short supply, and reducing VSS 3 and 4 (young and mid-age trees) that are overabundant. 

Right after treatments, the forest has moved toward the desired balance of VSS classes. There 

would still be too much forest in VSS 4, but VSS 3 would be closer to meeting the objective of 20 

percent, dropping from 52 percent to 19 percent in goshawk foraging areas. VSS 5 and 6 would 

also move closer to the desired condition. Over time, more trees would be recruited into the larger 

classes. The openings created by treatments would increase VSS 1. As tree seedlings eventually

sprout in the created openings a VSS 2 class would then be created. Results are similar in other 

goshawk habitat strata (see the silviculture specialist report for these tables).

Table 36. Distribution of VSS classes in northern goshawk foraging habitat before and after 

mechanical treatments. VSS classes are better balanced after treatment.

VSS 1 VSS 2 VSS 3 VSS 4 VSS 5 VSS 6

Pretreatment<1% <1% 52% 35% 9% 2%

Posttreatment10% 10% 19% 44% 12% 5%

Desired 

Condition

10% 10% 20% 20% 20% 20%

Effects on Stand Density

Changes in the indicators of stand density (basal area and trees per acre) were modeled before 

treatment, one year after treatment and 20 years after treatment30. We find that stand density is 

greatly reduced. For Mexican spotted owl habitat, basal area ranges from 135-178 before 

treatment and from 92-104 after treatment. After 20 years, the trees have grown and basal area 

has increased, ranging from 108-126, and basal area has increased, but is still lower than before 

treatment. The increased basal area also indicates that tree size has increased. 

It might seem that there is no need to treat some areas because the current basal area is at or 

below the target level. These numbers are averages, however, and density is variable across the 

landscape. During implementation, there would be flexibility in cutting to the desired level. 

Stands that already have a low basal area may not be treated, for example, and dense stands 

would change the average post-treatment basal area. 

 

30 The treatment modeled was cutting, piling and burning slash, and prescribed fire one year later. The 

modeled prescribed fire would kill additional trees. In actual practice, we could modify the burn 

prescriptions to achieve desired tree mortality levels.
Chapter 3. Affected Environment and Environmental Consequences

186 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Trees per acre also changes. In Mexican spotted owl habitat, before treatment, the number of trees 

per acre ranges from 634 to 1,893; after treatment, the range is 155-301 TPA. After 20 years, the 

number has dropped slightly. This is due to the prescribed fire treatments, which control the 

number of seedlings that survive.

The mechanical treatments reduce stand density, and density stays at lower levels over a 20-year 

period. Detailed tables showing the changes in these and other indicators are found in the 

silviculture specialist report. 

Large Trees

Page 5 of this FEIS states that the desired condition is to have a mix of tree sizes and ages, 

including old growth. This is consistent with the CFLRP legislation which states “carry out any 

forest restoration treatments that reduce hazardous fuels by: (i) focusing on small diameter trees, 

thinning, strategic fuel breaks, and fire use to modify fire behavior, as measured by the projected 

reduction of uncharacteristically severe wildfire effects for the forest type (such as adverse soil 

impacts, tree mortality or other impacts); and, (ii) maximizing the retention of large trees, as 

appropriate for the forest type, to the extent that the trees promote fire-resilient stands;

Our analysis and field modeling indicates that the vast majority of the trees that would be cut are 

in the smaller diameter classes- 5-12 inches. Very few trees above 16-inches diameter would be 

cut. Detailed tables showing the diameter distributions of the cut and leave trees are found in the 

silviculture specialist report.

Amount and Type of Wood Products Created

The mechanical treatments and associated timber harvest would create jobs in the woods and the 

mills and offset treatment costs. The mix of wood products is not certain at present; it would 

depend on the wood products industry and contractors. The product mix could include firewood, 

mulch, pellets, fencing, vigas, and lumber for personal and commercial use. The economic effects 

are described in detail in the social-economics section of this chapter and in the corresponding 

specialist report. 

An estimate of how much tree volume would be removed over the life of the project for all 

alternatives is shown in table 37. Volume estimates are approximate and would vary because of 

access, removal methods, transportation costs, and merchantability.

Table 37. Approximate volume harvested by alternative over the life of the project. Alternative 5 

produces the most amount of material; alternative 2, the least.

Alternative Acres Harvested Total MBF* from 

Trees Greater 

than 9- inches 

Diameter

Total CCF**from 

Trees Greater 

than 5-inches 

Diameter

Total CCF from 

Trees 5-8 inches 

Diameter

1 31,400 114,000 342,900 115,000

2 800 4,600 12,500 3,300

3 29,500 105,600 317,100 105,900

4 31,400 114,000 342,900 115,000

5 31,400 118,700 357,200 119,800

* MBF: one-thousand board feet. A board foot is the amount of wood in an unfinished board 1 inch thick, 

12 inches long, and 12 inches wide.

* CCF: 100 cubic feet. A piece of wood measuring 12 inches by 12 inches by 12 inches is one cubic foot.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 187

Effects on Fire and Fuels

Stands would be more resistant to high intensity (hot) wildfires, because there is more space 

between groups of trees and there are fewer ladder fuels. Under these conditions, it is harder for a 

fire to move from the ground to the tree canopy. Prescribed fire treatments would also help reduce 

potential wildfire intensity by burning down wood. Fires (wild or prescribed) would generally 

burn on the ground and be cool (low intensity) because there would be less fuel after the 

mechanical treatments. Fires may thin within groups of trees by killing a few trees and creating 

small openings. Most large trees would be able to survive these fires. Most of the trees killed by 

fire would be seedlings and saplings, which would help maintain lower tree densities over time. 

(see the fuels section of this chapter and the associated specialist report for more details on 

treatment effects)

Alternative 2

No stand improvement thinning or restoration cutting would occur, except in a few areas with 

previously approved NEPA. The trees outside these small treatment areas would continue to grow 

and stand conditions would continue to decline. Many stands are at maximum carrying capacity, 

so trees in those areas would continue to die as the stands self-thin. This would create fuel ladders 

and an elevated fire hazard. Stands that are below capacity would grow until capacity is reached. 

Because of competition for light, water, and nutrients, trees would be small and stunted and 

would not be able to reach their potential. Spacing would be dense and fairly uniform. Trees in 

VSS 5 and 6 would grow slowly. There would continue to be too many trees in VSS 3 and 4 

classes, a shortage of VSS 2 seedlings-saplings, and a shortage of VSS 1 openings. 

The landscape would become more homogenous over time as stands get older. There would be 

fewer young and middle-aged stands. The diversity of ages and sizes of trees would decrease over 

time. It would take a long time for trees to grow to a large size, and many never would. 

The existing old-growth stands would remain fairly stable, and trees would grow slowly. The total 

acres of old growth would increase very slowly because tree growth is suppressed and it would 

take longer to get large trees. Old-growth stands would be vulnerable to high-intensity fires 

because of the high density and high fuel loading. We would not be able to manage stands to 

develop more old growth. 

Oaks would be suppressed, short, and shrubby. They would not be able to attain their tree form 

and produce abundant acorns. Because of the closed canopy, there would be little regeneration of 

new oaks, and there would be fewer shrubs and much less grass and forbs. The forest floor would 

eventually consist of pine needles, and dead wood would continue to build up. Meadows and 

openings would shrink in size, and new openings would not be created. Aspen stands would 

eventually be overtopped by conifers and continue to decline, further reducing forest diversity. 

There would be no regeneration of new or young aspen unless a severe wildfire occurred. 

Ladder fuels would remain and have the potential to carry a wildfire into the crowns of the trees. 

Such a fire could be carried through the dense canopy and kill most of the trees over a large area. 

It could take decades for the forest to reestablish, if it did at all. After such a fire, the area would 

be more likely to convert to brush fields or grasslands (Fleck 2011; Savage and Mast 2005).

Mistletoe would spread more easily under dense stand conditions and infestations would increase. 

Without the effects of cutting and prescribed fire to control mistletoe, more trees would be stunted 

and deformed by mistletoe. Stands would also be susceptible to insect outbreaks, particularly by 
Chapter 3. Affected Environment and Environmental Consequences

188 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

bark beetles. Since the trees are dense and stressed, they would be less able to ward off an attack, 

and tree cover on many acres could be lost. 

There would be no new economic opportunities and only small amounts of wood products would 

be generated.

Alternative 3

Under this alternative, about 1,900 fewer acres would be mechanically treated than under 

alternative 1. The effects on untreated stands would be the same as described for alternative 2. 

The effects on treated stands would be the same as described under alternative 1 (proposed 

action). In the remainder of the area, the effects from prescribed fire would be similar to those 

under alternative 1. 

Alternative 4

The areas that are treated with prescribed fire would receive the benefits of fire as described for 

alternative 1. In the mechanical treatment areas, the forest structure would be the same as 

alternatives 1, 3 and 5, with groups of trees and spaces and trees of all sizes. The amount and type 

of wood products produced would also be about the same as alternatives 1, 3 and 5. 

The slash treatment would result in different effects on fire behavior and forest ecology in areas 

that are only mechanically treated because the slash is not burned. Instead of using prescribed 

fire, slash could be chipped, shredded, or masticated. The effects of these types of slash 

treatments are just now being studied and we are not certain about the results. Based on this 

research, mechanical treatment of slash may have the following effects: 

• Severe soil damage may occur if a fire burns when the soil is dry, or if there is a deep fuel 

bed (branches, twigs, needles, masticated material). There may be less damage if burning 

is done on wet soils. Trees may die from scorch (needles and bark are injured by 

excessive heat) or by overheating the roots (Busse et al. 2005; JFSP 2009; Reiner et al. 

2012). 

• Flame length, rate of spread, torching, and the risk of crown fire may be reduced after 

mastication, but surface fires may be more difficult to control (Reiner et al. 2012).

The research is not consistent, but overall it appears that mastication can reduce fire hazard by 

putting all of the woody material on the ground, which reduces fuel ladders. A deep bed of chips 

could slow the nutrient recycling process, resulting in slower tree growth. This chip layer could 

also suppress the growth of grasses and other understory plants There would also be few, if any, 

areas of bare soil to serve as seed beds for new trees. There would also be fewer acres of aspen 

regeneration, as aspen would have a difficult time sprouting or suckering through the chip layer. 

Fire and fuels managers on the Santa Fe National Forest have experience with the effects of 

mastication on fuels and fire behavior. Mastication does not stop a wildfire from burning through 

an area and in some situations, results in a hotter fire with more severe effects. 

To some extent, mechanical treatments can take the place of fire. Mechanical treatments alone 

can change the stand structure and reduce fire hazard, but they cannot produce the other 

ecological effects of fire: patchiness, an abundant understory, and animal species richness 

(McIver et al. 2012). For more information on the effects of slash treatment, see the fuels section 

of chapter 3 and the fuels specialist report.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 189

Alternative 5

The effects are similar to alternative 1, except in Mexican spotted owl protected activity centers, 

target/threshold habitat, and protected habitat. Some of this difference results from the diameter 

cap (trees larger than 9-inches diameter would not be cut in Mexican spotted owl protected 

activity centers) and lack of prescribed fire in core areas. This alternative produces the highest 

volume of wood products because more acres in “restricted” owl habitat are treated. 

Tree density as measured by basal area and trees per acre would be higher after treatments than 

under alternative 1 in PACs, target/threshold, and protected habitat. This is due to the diameter 

cap and higher basal areas in the forest plan. Values for other habitat strata are the same as 

alternatives 1, 3, and 5. This higher density could increase the fire hazard and risk of an insect 

outbreak. With these denser stand conditions, trees would not be able to grow as large as under 

alternative 1. Target/threshold stands would be thinned or maintained at a higher basal area- 150-

170 instead of 120. This is fairly dense and trees would be competing with each other and so 

would not grow as well. There would be a minimal understory. 

Forest Plan Amendments

The amendment regarding the development of viewshed corridor plans would have no effect on 

forestry activities. The amendment regarding paired monitoring of protected activity centers 

would have no effect on forest stands.

The other proposed amendments would have beneficial effects on forest stands:

• Allowing prescribed fire in Mexican spotted owl core areas would reduce fire hazard in 

these areas and allows the positive effects of fire to occur on more acres.

• Allowing more comprehensive vegetation treatments in protected activity centers would 

reduce fire hazard and allow some restoration activities that would preserve these areas, 

on more acres.

• Using the direction regarding diameter size and basal area in the revised MSO recovery 

plan would help us meet the objectives of growing bigger trees faster and reducing fire 

hazard. 

• Removing trees of all sizes instead of thinning from below would allow us to create more 

balanced, uneven-aged stands by removing small and medium-size trees. 

• Clarifying the language for interspaces in goshawk stands would clarify the intent of the 

desired condition for goshawk habitat.

• Allowing activities during wildlife breeding seasons and conducting surveys in peregrine 

falcon nesting habitat would allow us to reach our restoration goals sooner. 

• Changing the visual quality objective in the Jemez National Recreation area would allow 

restoration work to occur in an area that needs restoration. 

Cumulative Effects 

Projects and activities considered in the cumulative effects analysis are listed in appendix B. Past 

tree cutting, grazing, and fire suppression have created a forest that is unnaturally dense. 

Currently, the Valles Caldera National Preserve and neighboring districts and national forests 

(Carson and Cibola) are also doing restoration work, including mechanical treatments and 
Chapter 3. Affected Environment and Environmental Consequences

190 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

prescribed fire. There is also thinning on some of the adjacent private land. Overall, the effects of 

the action alternatives would not result in adverse cumulative effects. 

Conclusion about the Effects of the Treatments 

This section answers the analysis questions and how well the alternatives address the purpose and 

need. 

Would the mechanical treatments restore spatial patterns, processes, resiliency, structure, and 

species composition in ponderosa pine and dry mixed conifer types? 

Alternatives 1 (the proposed action) and 5, takes us the furthest toward restoration and meeting 

the purpose and need of this project regarding ecosystem health and resiliency. Although the VSS 

classes would not be completely balanced as described in the forest plan, they would be greatly 

improved and close to the desired condition. The proposed treatments would achieve the 

following: 

• Initiate treatments that move much of the forest from an even-aged condition toward the 

desired uneven-aged structure and set up the forest to be more self-sustaining. 

• Manage existing uneven-aged stands toward the desired uneven-aged forest structure 

proportions and provide more structural diversity 

• Create a mosaic of forest types across the landscape, including old growth, meadows, and 

aspen stands. 

• Protect habitat for the northern goshawk, Mexican spotted owl, and Jemez Mountains 

salamander from uncharacteristically severe wildfire. 

• Reduce the potential for uncharacteristically severe wildfire by reducing stand density 

and ladder fuels. 

• Provide economic opportunity through the commercial use of forest products. 

The differences between alternatives 1 and 5 are related to the number of acres treated in 

target/threshold habitat or nest/roost habitat and restricted or recovery habitat. Please see the 

silviclture specialist report for details. Mechanical treatments reduce tree densities more and 

create a more balanced age class distribution alternative 1 and so the beneficial effects would last 

longer. The heavier treatments also create better conditions for growing large trees because of the 

lower density. 

Alternative 2 leaves the forest overstocked and vulnerable to disturbances, such as insect 

outbreaks. There is a high probability of an uncharacteristically severe fire. Wildlife habitat would 

decline in quantity and quality, both for rare and common species. This is the least desirable 

alternative.

Alternatives 3 and 4 also improve ecosystem health and resiliency, but to a lesser extent than 

alternative 1. Alternative 3 achieves the results described above, but on slightly fewer acres.

Alternative 4 restores forest structure on all the mechanically treated areas, which reduces fire 

hazard to some degree. This alternative, however, does not restore the beneficial processes of fire 

on the mechanically treated acres. Alternative 4 would require us to treat slash some other way. 

We would probably use mastication, which can have negative effects on the remaining trees, 

soils, and the understory vegetation. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 191

Wildlife, Fish, and Rare Plants 

The following reports are incorporated by reference: threatened and endangered species (Amy 

and Sanchez 2013); management indicator species and migratory birds (Sanchez and Wargo 

2013), and sensitive species (Sanchez and Orr 2013). See these reports for detailed information 

on data sources, methodology, assumptions, and limitations. This section briefly summarizes 

detailed information from the Southwest Jemez Mountains Landscape Assessment Report (USFS 

2010b), which describes existing conditions and ecological departures from desired conditions. It 

also briefly summarizes detailed information in resource specialist reports such as the vegetation 

report located in the project record. The cumulative effects disclosures for threatened, 

endangered, and proposed species rely in part on information in the Biological Assessment, found 

in the project record. 

This section of chapter 3 describes the affected environment and the effects of the alternatives on 

wildlife species as follows: (1) federally listed as threatened or endangered under the Endangered 

Species Act; (2) listed as sensitive by the Southwestern Region regional forester; (3) classified as 

management indicator species (MIS) under the Santa Fe National Forest Land and Resource 

Management Plan; and (4) analyzed under the Migratory Bird Treaty Act. Each category has its 

own requirements and standards for analysis.

Threatened, Endangered, and Proposed Species 

This following analysis focuses on disclosing the potential effects of the alternatives on 

threatened, endangered, and proposed species and their critical habitats. The determination of 

effects for each species was determined by evaluating the expected outcome of implementing 

project design features, mitigations, and Best Management Practices (BMPs) for the projects 

listed in appendix A.

A biological assessment (Amy and Sanchez 2013) was prepared for this project and can be found 

in the project record. This section of chapter 3 will address effects on the following categories of 

species:

• Federally listed species: (1) Mexican spotted owl (threatened) and its designated habitat, 

(2) Jemez Mountains salamander (endangered) and its designated critical habitat, and (3)

New Mexico meadow jumping mouse (endangered) and its proposed critical habitat. 

• Proposed species: (1) wolverine (proposed 10 (j))

• Candidate species: (1) Western yellow-billed cuckoo; (2) Rio Grande cutthroat trout, and 

(3) Canada lynx 

Table 38. Federal threatened, endangered, and proposed species analyzed

Is There Is the 

Designated Species 

What is the Critical or Known to 

Status of Proposed Occur in 

the Habitat in the Project 

Species and Latin Name Where is it Found? Species? Project Area? Area?

Mexican Spotted Owl (Strix Mixed conifer and Threatened Yes Yes

occidentalis lucida) associated forests; 

nests in mature forests
Chapter 3. Affected Environment and Environmental Consequences

192 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Species and Latin Name Where is it Found?

What is the 

Status of 

the 

Species?

Is There 

Designated 

Critical or 

Proposed 

Habitat in the 

Project Area?

Is the 

Species 

Known to 

Occur in 

Project 

Area?

Jemez Mountain 

Salamander (Plethodon 

neomexicanus)

Mesic (wet) conifer 

forests, wet understory

Endangered Yes Yes

New Mexico Jumping 

Mouse (Zapus hudsonius 

luteus) 

Open wet meadow, 

riparian complex, 

sedges, emergent water

Endangered Yes Yes

Wolverine (Gulo gulo 

luscus)

Tree line, high elevation Proposed No No

Western Yellow Billed 

Cuckoo (Coccyzus 

americanus occidentalis)

Cottonwood galleries Candidate No No

Rio Grande Cutthroat Trout 

(Oncorhynchus clarkii 

virginalis)

Streams occupied by 

nonnative fish; 

genetically pure 

populations are found in 

isolated headwaters 

Candidate No Yes

Canada Lynx 

canadensis)

(Lynx High elevation spruce 

forests; may migrate 

from Colorado

Candidate No No

Affected Environment

Ponderosa pine is the predominant forest type in the area, followed by piñon-juniper woodland, 

mixed conifer, and small patches of spruce-fir and aspen at higher elevations. The less 

represented habitat types are riparian areas, streams, wet meadows, seeps and springs, and aspen 

stands. These environmental communities are critical to some species that are dependent on one 

or more of these habitat types at least once in their life history.

The tree canopy is overly dense, nearly all of it is closed-canopied, so it is lacking in the canopy 

gaps and openings needed to support understory plants. The ponderosa pine forest covering most 

of the project area is dominated by small to mid-size trees 5 to 12-inches diameter, 

uncharacteristically dense and homogenous. There is a lack biological diversity needed for 

quality wildlife habitat, and the area does not support the surface fires typical of southwestern 

ponderosa pine forests. Historical meadows, aspen patches, and riparian vegetation have also 

greatly diminished from pre-settlement conditions because of conifer encroachment in the 

absence of a frequent surface fire regime. 

Fire frequency and fire behavior have changed also, with the greatest changes occurring in the dry 

forest types- ponderosa pine and dry mixed conifer (Covington and Moore 1994b; Arno et al. 

1997). Fire exclusion and past land management practices have led to dense forest canopies with 

high levels of surface and ladder fuels. As a result, there is an increased potential for 

uncharacteristically severe wildfires. Instead of high frequency, low-intensity surface fires, the 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 193

conditions of the dry forests we find today are more likely to support crown fires (Scott and 

Reinhardt 2001). Please refer to the fuels and silviculture specialist reports and sections of 

chapter 3 for more details on fuels, fire regimes, and forest conditions. 

Affected Species and Critical Habitat

Mexican Spotted Owl

The forest plan standards and guidelines for the Mexican spotted owl (MSO) would be amended 

where appropriate under alternatives 1, 3, and 4 to meet the purpose and need of the project (see 

table 1). The natural history and distribution of the owl is covered in detail in the original and 

revised Mexican spotted owl recovery plans (USFWS 1995; 2012). Since the revised recovery 

plan was published, information regarding the natural history or distribution of the owl has not 

changed. We incorporate these recovery plans by reference. The project area is within the 

Southern Rocky Mountains–New Mexico Recovery Unit for the owl, which covers the Santa Fe 

National Forest (USFWS 1995; 2012). 

In the Jemez Mountains, many owls are found in the rocky canyons that cut into volcanic tuff at 

lower elevations. These canyons provide many potholes, ledges, and small caves that the owl uses 

for roosting and nesting. The canyon habitat often has mature Douglas-fir, white fir, and 

ponderosa pine in canyon bottoms and on the north- and east-facing slopes. Rocky cliffs and 

canyon rims can modify the amount of sunlight reaching the inner-canyon habitats, so that 

vegetation communities and microclimates may vary greatly (USFWS 2012).

Nesting and roosting habitat for the owl is regarded as mature and old growth mixed conifer 

forest with a relatively closed canopy and a complex, uneven-aged structure (USFWS 1995). 

Mexican spotted owls appear to use a wider variety of cover types for foraging than for roosting 

or nesting. Forage or prey species habitat occurs where there are openings in the tree canopy and 

the owls can see their prey: wood rats, deer mice and voles (Ward 2001). Forage habitat is sorely 

lacking in the project area and should include high numbers of fallen trees and logs and a 

diversity of tree and plant species (USFWS 1995; 2005; 2012). 

The greatest threat to Mexican spotted owl habitat in the project area is the high potential for a 

large, uncharacteristically severe wildfire similar to the 2011 Las Conchas fire. Human-managed 

alteration of forests in the Southwestern U.S. has resulted in extensive areas of Mexican spotted 

owl habitat that is now more vulnerable to the effects of stand-replacing wildfires. Other key 

problems affecting the owl habitat in this area are the lack of large, mature trees and lack of small 

forage openings. 

Population trends for the owl remain unclear across its range. The Southern Rocky Mountain 

Ecological Management Unit has 74 Mexican spotted owl sites located in Colorado and Northern 

New Mexico, including the Jemez Mountains. Population trends in New Mexico appear to be 

declining slightly, but the population on the Santa Fe National Forest appears stable (USFS 

2012a), even though the forest experienced large areas of habitat loss due to the Las Conchas fire 

in 2011. 

The forest plan calls for managing mixed conifer forests toward irregular tree spacing and various 

patch sizes; horizontal structural variation with natural canopy gaps; species diversity with all 

species of native trees represented including early seral species; and at least 3 snags, 5 down logs, 

and 10 to 15 tons of woody debris per acre. The primary constituent elements of owl habitat are 

described in detail in the biological assessment; the main features are: forest structure, 

maintenance of adequate prey, and canyon habitat. Current conditions do not meet reference 
Chapter 3. Affected Environment and Environmental Consequences

194 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

conditions identified in the recovery plan (USFWS 1995) primarily due to the lack of structural 

and vegetative species diversity, large trees, and understory plants. 

The 1995 recovery plan defines three levels of owl habitat management: protected areas, 

restricted areas, and other forest and woodland types. Protected habitat consists of protected 

activity centers (PACs), which are occupied nesting and roosting areas of about 600 acres around 

the nest site; and areas outside of PACs containing mixed conifer forest on slopes over 40 percent 

where timber harvest has not occurred in the last 20 years31. Also, within each PAC, a 100-acre 

core area is designated around the nest site. About 2,900 acres are designated as PACs. Restricted 

habitat consists of mixed conifer forest on slopes less than 40 percent outside of a PAC. The 

restricted habitat does not meet the desired condition for MSO based on the forest plan because if 

it lacking large trees and should have at least 20 trees per acre over 18-inches in diameter. Other 

forest and woodland types includes threshold habitat and consists of a minimum percentage of the 

restricted habitat managed for nesting and roosting characteristics over time. 

There are 6 PACs in the project area. Survey results and the establishment dates for these PACs 

are shown in table 39. 

Table 39. Year of establishment and survey results for the six PACs in the project area. No 

responses have been detected in four PACs in recent years

PAC Name Year 

Established

Survey Results

Hummingbird 1992 Two surveys have been conducted since 2003 (2008 and 

2013) with no response detected.

Lake Fork 2009 Owls were detected in 2009. There was no response to 

surveys in 2013.

Paliza 2006 No response to surveys conducted each year from 2007 

through 2013.

San Juan 2004 One unidentified individual detected in 2005. No response to 

surveys conducted in 2009 and 2013. 

Virgin 1989 This PAC was determined to be occupied from 1990 through 

1996 and again in 2003. No response to surveys conducted in 

2009 and 2013. 

West Mesa 1998 PAC was determined to be occupied in 1992, 1995, and again 

in 2008. There was no response to surveys in 2013.

Western Yellow-billed Cuckoo

In the Southwest, the yellow-billed cuckoo is usually found in mature riparian cottonwoodwillow woodlands and dense mesquite associations. These birds prefer areas with a closed canopy 

and a sub-canopy layer (USFS 2011). 

The main threats to this bird are loss of riparian habitat from conversion to farmland, dams and 

river flow management, stream channelization and stabilization, and livestock grazing. The 

replacement of native riparian habitats by invasive nonnative plants, particularly tamarisk has 

affected breeding habitat. 

 

31 Classification of mixed conifer on the Santa Fe National Forest requires that only 20 percent of the dominant 

overstory trees consist of mixed conifer species, which differs from how mixed conifer is defined in the Forest Service 

FSVeg database. Thus, some designated protected habitat consists of predominantly ponderosa pine.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 195

In New Mexico, the Western yellow-billed cuckoo is currently restricted to the San Juan, Rio 

Grande, Pecos, Canadian, San Francisco, Mimbres, and Gila River valleys (USFWS 2011). On 

the forest, the Western yellow-billed cuckoo is generally restricted to the Rio Grande and its 

tributaries. Populations of the Western distinct population of the yellow-billed cuckoo may exist 

on the Jemez and Española Ranger Districts, but the cuckoo is not known to occur in the project 

area. There are about 632 acres of potential cottonwood habitat for the cuckoo on the Forest; a 

total of 7 acres is along the Jemez River. Most of the cuckoo habitat on the forest is found along 

the Rio Grande, Pecos, and Jemez Rivers. 

Jemez Mountains Salamander 

The Jemez Mountains salamander is native to north-central New Mexico and is only found in the 

Jemez Mountains in Los Alamos, Rio Arriba, and Sandoval Counties. This lungless salamander is 

found primarily in mixed conifer habitats that have abundant rocks and surface logs, especially on 

steep north-facing slopes. These habitats are relatively moist and have soils that contain deep 

igneous subsurface rock that is fractured (has cracks). The fractures allow the salamander to 

retreat below the frost line. These salamanders spend most of their life underground, and are 

active on the surface during a brief period of the summer when conditions are warm and wet. 

Even then, they stay inside rotted coniferous logs or under rocks. The humidity and moisture 

level at and below the surface is probably the most important ecological factor for this species. It 

needs a moist environment because it breathes through its skin.

Approximately 75 percent of their diet includes ants; other prey items include beetles, mites, 

spiders, earthworms, and other small invertebrates (USFWS 2013b). There is no aquatic life stage 

for this salamander. Activity above the ground is likely associated with summer monsoon rains. 

A full description of threats to the salamander is found in the proposal for listing (USFWS 

2013b), which is incorporated by reference. The primary threats are: historical fire exclusion and 

suppression; uncharacteristically severe wildfire; changes in and conversions of forest 

composition and structure; forest and fire management; post-wildfire rehabilitation; residential 

development; roads, trails, habitat fragmentation; recreation, and climate conditions. 

Nearly all of Jemez Mountains salamander habitat is on federally-managed lands. The project 

area contains about 21 percent of the critical habitat for the species, though not all of that is 

suitable habitat. Much of the critical habitat around the San Antonio southwest of the Valles 

Caldera appears to be unsuitable because numerous surveys have not found salamanders. 

The salamander has been on the Regional Forester’s Sensitive Species list since 1990. In 2000, 

the interagency New Mexico Endemic Salamander Team finalized a conservation plan for the 

salamander. In 2012, the U.S. Fish and Wildlife Service (USFWS) proposed to list the salamander 

as endangered, and it was listed in September 2013 (USFWS 2013a). The Fish and Wildlife 

Service amended the proposed critical habitat designation and modified some of the primary 

habitat elements in 2013 (USFWS 2013a). These elements include moderate to high tree canopy 

cover, moderate to high volumes of large fallen trees and other woody debris at least 10- inches 

diameter, and underground habitat in forest or meadow areas with spaces made by fractured rock, 

rodent burrows, or rotted tree root channels. 

Long-term population trends are not known because most surveys have only determined the 

presence or absence of the species (USFS 2011). Recent numbers of individuals seem to be much 

lower than numbers reported in 1970, and there appears to be a decreasing trend in areas that used 

to be occupied (USFWS 2013b). Detecting overall trends is difficult for this species because of 
Chapter 3. Affected Environment and Environmental Consequences

196 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

data limitations, the cost of comprehensive surveys, and the likelihood of natural, annual, and 

spatial variations (USFWS 2013b). 

The project area has 32 occupied sites, some of which were burned during the Las Conchas fire 

and nearly 11,800 acres of designated critical habitat. 

Canada Lynx 

In 2009 the Fish and Wildlife Service listed the lynx as a distinct population segment in New 

Mexico because it was documented in the state as a result of a reintroduction effort in Colorado. 

Lynx released in Colorado drifted into New Mexico, and these animals are not considered 

essential to the survival or recovery of the lynx. The Canada lynx is not known to occur in the 

project area. The threats to the lynx in New Mexico from human-caused mortality are low and are 

not a significant threat. The amount of suitable habitat for lynx in the state is considered marginal 

relative to the amount of habitat within the species range. 

New Mexico Meadow Jumping Mouse

The jumping mouse is a habitat specialist that nests in dry soil but also uses tall, dense, 

herbaceous riparian vegetation (Frey 2007). Its habitat is limited to riparian wetland habitats with 

plants that are at least 24-inches high. The jumping mouse needs this vegetative cover for 

movement, nesting, or burrowing. Other key habitat features are extensive channels, ponds, 

shallow flooded areas, and other similar wet habitats created by beavers. 

Threats to the mouse are related to habitat. Risk factors include excessive grazing pressure from 

livestock, water use and management, highway reconstruction, development, and recreation. 

These activities reduce or destroy the tall vegetation and wetland or riparian habitat needed by the 

mouse and influence species persistence across the landscape.

The New Mexico meadow jumping mouse was listed as an endangered species June 2014 

(USFWS 2013e). Critical habitat for the jumping mouse was proposed in June 2013. The 

proposed critical habitat encompasses historical jumping mouse locations along the San Antonio, 

Rio Cebolla, and Rio de las Vacas on the Jemez and Cuba Ranger Districts. There are 3 areas or 

subunits of critical habitat in the Jemez Mountain Range. For planning and analysis purposes, we 

have identified 2,167 riparian acres in the project area as potential jumping mouse habitat. The 

San Antonio watershed was identified as having potential habitat for the species and it is a 

priority watershed for restoration (USFS 2012). 

Wolverine

In North America, wolverines are found within a wide range of alpine, boreal, and arctic habitats. 

They favor areas that are cold and receive enough winter precipitation to maintain snow into the 

warm season. They generally occur in high ridgetop mountainous areas. The wolverine is not 

known to occur in the project area. 

The wolverine in northern New Mexico was proposed as a nonessential experimental population 

(USFWS 2013c). It has been proposed for Federal listing as a threatened species in the Sothern 

Rockies. The proposed rule published in the federal register (USFWS 2013) provides a plan for 

establishing nonessential experimental population areas and allows for legal incidental take of the 

wolverine in these areas. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 197

Rio Grande Cutthroat Trout 

Rio Grande cutthroat trout are found primarily in clear, cold mountain lakes and streams at 

elevations above 6,000 feet in Colorado and New Mexico within the Rio Grande Basin (Sublette 

et al. 1990). In New Mexico, this trout lives mostly in mountain streams in the Sangre de Cristo 

and Jemez Mountain ranges on the Carson and Santa Fe National Forests. Isolated populations 

are found in southern New Mexico. Side channels, undercut banks and overhanging vegetation or 

exposed roots along the streams provide habitat for juvenile fish. Adult fish need pools deeper 

than 12 inches in order to survive harsh winter conditions (Harig and Fausch 2002).

The biggest threats are habitat loss and interbreeding. The historical range of Rio Grande 

cutthroat trout has been greatly reduced over the last 150 years because of water diversions, 

stream drying, dams, habitat degradation, and changes in hydrology. Interbreeding with rainbow 

trout and competition with brown and brook trout have also reduced populations (Pritchard and 

Cowley 2006). Also, ash and debris flows that occur after wildfires can eliminate populations of 

fish from a stream (Rinne 1996; Brown et al. 2001; USFS 2006; Patten et al. 2007). On the Santa 

Fe National Forest, four conservation populations were lost to wildfires in 2010 and 2011. 

The Rio Grande cutthroat trout is a Forest Service Southwestern Region Sensitive Species and is 

managed by the New Mexico Department of Game and Fish as a protected species. It is also 

considered a species of greatest conservation need32 (NMGF 2006). In 2008, Rio Grande 

cutthroat trout was listed as a candidate for federal protection under the Endangered Species Act. 

As of 2011, 44 conservation populations had been identified on the Santa Fe National Forest, 

totaling 128.7 miles of occupied stream (SNF 2012a). These populations tend to be in small, 

isolated segments of stream high up in the backcountry in both the Pecos and Jemez areas. 

There are no conservation populations in the project area, but four streams in the project area are 

stocked with surplus hatchery fish: East Fork Jemez River, San Antonio Creek, Rio Cebolla, and 

Rio Guadalupe. They are considered experimental populations and have been found in very low 

numbers. 

Methods

This analysis used the best available information and included habitat variables such as 

vegetation, slope, and elevation. Potential habitat is based on the presence of habitat 

characteristics as described in available scientific literature, previous wildlife surveys, recorded 

wildlife observations, and from other credible sources of natural biotic information. 

The Santa Fe National Forest has developed spatially defined databases that include variables 

related to forest structure, forest health, and the information listed above. This analysis does not 

represent all occupied habitat for the species addressed here, only potential habitat and then only 

based on the available information for the physical and biological attributes available in current 

forest databases. This provides a means to compare existing conditions with the alternatives in a 

quantitative manner. The timeframe for this analysis is 10 years from the proposed 

implementation date of 2014. 

 

32 These are species that are indicative of the diversity and health of the state’s wildlife that are associated 

with key habitats, including low and declining populations, and species of high recreational, economic, or 

charismatic value.
Chapter 3. Affected Environment and Environmental Consequences

198 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The following indicators were used to measure project effects on species habitat: 

• Vegetation- potential changes in forest structure and composition 

• Acres of occupied or potential habitat

• Stream miles treated

• Road miles 

Summary of Effects

Effects of the proposed action on threatened, endangered, and proposed species and critical 

habitats are described below. Conservation measures that would avoid or minimize effects are 

found in appendix A and in the biological assessment, which is in the project record. 

Mexican Spotted Owl

Alternatives 1, 3, and 4 may result in short-term, adverse effects on the Mexican spotted owl and 

its designated critical habitat. These effects would result from changes in forest structure 

associated with mechanical treatments and prescribed fire. Management guidance from the 2012 

revised recovery plan would be used and will likely improve vegetative diversity, which should 

improve prey abundance and availability for the owl. In the long term, the proposed action would 

reduce the potential for degradation or loss of Mexican spotted owl critical habitat from an 

uncharacteristically severe wildfire. Under alternative 5, effects on the owl are likely to be 

discountable and insignificant due to the more restrictive management guidance in the forest plan. 

Alternative 5 would not likely result in adverse effects on the owl.

Project related activities may impact individuals through changes in habitat quality. Short term 

impacts will likely result in long-term benefits to the species through building habitat resilience to 

large high severity wildfire. It is difficult to quantify the number of individuals that may be 

disturbed by project activities because individuals not paired for breeding are difficult to find. 

Alternative 1 would likely provide better resilience to severe wildfire than alternative 5 because 

the resulting forest structure would be more resilient to severe wildfire for a longer time. 

Alternative 1 would also better achieve the desired forest structure and diversity as described in 

the revised MSO recovery plan to provide for future habitat.

Implementation of the project is expected to retain the range of tree species and size classes 

intended for critical habitat. Some loss of trees, of all types and diameter size classes, will occur 

from actions such as removal of hazard trees along prescribed fire control lines, prescribed 

burning, and removal of trees up to 18-inches diameter during mechanical treatments. Removal of 

tree size classes may occur as part of the development of new temporary road construction and 

maintenance of roads. These effects should be small in extent and intensity.

Tree canopy would be reduced following fireline preparation, forest stand improvement thinning, 

prescribed burning, and mechanical treatments. Canopy cover is not anticipated to be reduced 

below 40 percent in groups and clumps across the project while managing for higher basal area. 

Reduction in canopy cover may shift or increase prey species distribution as understory 

vegetation reestablishes in currently high-density stands. 

Prescribed fire would result in a decrease in plant cover in the short term but provide conditions 

suitable for increasing herbaceous plant growth over the long term by removing the thick layer of 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 199

litter on the forest floor. As a result, critical habitat quality will improve as vegetation conditions 

change to favor small rodents, thus promoting greater prey diversity and availability.

Prescribed fire and maintenance burning treatments would likely reduce the high volume of down 

trees and logs and other woody debris, which would affect prey habitat. This could result in shortterm adverse effects on MSO prey animals, but as discussed above understory vegetation and 

food availability for prey species would likely improve. Understory vegetation would seasonally 

replace cover for prey while increasing forage that will likely result in an increase of prey 

available to MSO during the breeding season. Some short-term loss of cover is likely to occur 

based on the shift in plant species.

A determination of may affect, likely to adversely affect was made for the owl and for its critical 

habitat for alternatives 1, 3, and 4 because of short-term effects from vegetation treatments. 

Western Yellow-Billed Cuckoo

Instream restoration work and riparian planting may occur in potential habitat and will likely 

improve conditions for riparian-dependent birds such as the cuckoo. All action alternatives (1, 3, 

4, and 5) would not jeopardize the western yellow-billed cuckoo and may affect, but is not likely 

to adversely affect the cuckoo. 

Jemez Mountains Salamander 

All action alternatives (1, 3, 4, and 5) may result in adverse effect on the Jemez Mountains 

salamander and its designated critical habitat. These effects would stem from changes in forest 

structure as well as surface disturbance associated with mechanical treatments and prescribed fire, 

but these effects are expected to be short term. The design features and mitigation measure would 

minimize the effects on individual salamanders and critical habitat. The proposed action would 

reduce the elevated hazard of high-severity fire. The effects of the prescribed fire treatments are 

largely beneficial and in line with historical fire effects. Mechanical treatments would impact 

surface habitat, but are not anticipated to affect subsurface habitat. 

A determination of may affect, likely to adversely affect was made for the salamander and for its 

critical habitat for all action alternatives because of short-term effects from vegetation treatments. 

Canada Lynx

There is no documented detection of lynx in the project area. None of the action alternatives are 

likely to rise to the level of effects that would result in take of the species. 

A determination of may affect, not likely to adversely affect was made for the Canada lynx for all 

of the action alternatives. 

New Mexico Meadow Jumping Mouse 

The proposed treatments under all action alternatives would move jumping mouse habitat towards 

recovery in San Antonio and Rio Cebolla streams systems. Effects from instream work and 

construction of exclosures may adversely affect the jumping mouse, but will result in long-term 

benefits by improving riparian vegetation and stream function. The effects will be minimized 

through the design features and mitigation measure listed in appendix A. 

Effects from all of the action alternatives would not likely jeopardize the New Mexico meadow 

jumping mouse. A determination of may affect, likely to adversely affect was made for the 
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200 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

jumping mouse and for its proposed critical habitat for all action alternatives because of shortterm effects from aquatic and riparian restoration treatments.

Wolverine (proposed non-essential experimental population)

There are no documented records of wolverine present in the project area. Project activities are 

not expected to impact wolverine habitat. 

Effects from all action alternatives would not jeopardize the wolverine. 

Rio Grande Cutthroat Trout

Under all action alternatives (1, 3, 4, and 5) the riparian area restoration and instream treatments 

would improve habitat conditions for Rio Grande cutthroat trout in the project area. Instream 

work would restore or enhance key habitat components. Short-term, localized impacts could 

include an increase in sediment and turbidity in streams due to mechanical equipment working in 

or near the stream. The effects will be minimized through the design features and mitigation 

measure listed in appendix A.

Effects from the action alternatives would not likely jeopardize the Rio Grande cutthroat trout.

Environmental Consequences

Alternative 1

Mexican Spotted Owl

Determination of effect (Species): May Affect, Likely to Adversely Affect, with long-term 

benefits 

Determination of effects (Critical Habitat): May Affect, Likely to Adversely Affect, while 

providing long-term benefits

The revised recovery plan (USFWS 2012) for the owl was used to guide us in the project design 

and effects of the action on the owl and its habitat. It was also used to guide development of the 

proposed forest plan amendments (see chapter 2). The forest plan, however, is more restrictive in 

managing habitat for the owl. The spotted owl habitat analysis in the silviculture specialist report 

was also used for this effects analysis and is incorporated by reference. 

Project-related activities may impact individual owls due to changes in habitat quality. Short-term 

impacts will likely result in long-term benefits to the species by increasing habitat resilience to 

large, high-severity wildfires. It is difficult to quantify the number of individual owls that may be 

disturbed by project activities because individuals not paired for breeding are difficult to find. It is 

not certain that owls are nesting and roosting in areas outside of protected activity centers (PACs) 

in any given year.

The following table lists potential treatments by acres within PACs and critical habitat. These are 

the potential acres that may be treated; not all of the acres identified will actually be treated. As 

an example, there are 2,210 acres of aspen in critical habitat, but only 1,800 of aspen treatments 

would be treated under the proposed action, and only 414 acres within PACs are suitable for 

mechanical treatments.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 201

Table 40. Type and amount of proposed treatments in Mexican spotted owl critical habitat and 

protected activity centers

Treatment Type Amount in Critical Habitat Amount in Protected 

Activity Centers

Aspen Enhancement 2,210 acres 43 acres

Meadow Restoration 2,232 acres 129 acres

Piñon-Juniper 

Treatments

936 acres 0 acres

Riparian Restoration 538 acres 235 acres

Old Growth 3,134 acres 2,604 acres

Invasive Plant Control 39 acres 0 acres

Headcuts 263 sites 48 sites

Dispersed Campsite 

Rehabilitation

50 sites 10 sites

Road Decommissioning 38 miles 7 miles

Mechanical Treatments 12,455 acres 401 acres

Prescribed Fire 22,365 acres 3,112 acres

Roads Used to Access 

Treatment Sites

177 miles 19 miles

Landings 297 sites 13 sites

Effects on the Species

The mechanical treatments are anticipated to result in minimal direct impacts on the owl. 

Activities in PACs would be avoided during the breeding season unless the PAC has been 

adequately surveyed by qualified personnel according to the most recent survey protocol 

approved by the U.S. Fish and Wildlife Service and determined to be unoccupied for that year. 

Prescribed fire treatments could occur in all six PACs and would be used in the entire PAC area, 

including the core. We would not separate prescribed fire in PACs from that of the surrounding 

project area. This approach minimizes disturbance from fire containment actions (handline 

construction) and other activities that would be needed to keep prescribed fire from entering the 

core areas. Fire managers could use techniques to minimize burn severity (using a backing fire) 

within core areas while gaining the benefits of removing fine fuels within the core.

The prescribed fire treatments would result in about 15 percent mortality of trees within the PACs 

due to the higher percentage of fire intolerant tree species, such as white fir, within the mixed 

conifer stands. The effects on the owl would largely be beneficial as dead trees become snags and 

create canopy gaps, which are important for maintaining diverse tree and understory species. 

Prescribed fire is unlikely to affect nesting in the project area because the owl usually nests in 

rock or cliff faces. Cultural site treatments are likely to have similar effects as the prescribed fire 

and mechanical treatments.

Riparian treatments would move riparian corridors toward the desired function and improve 

connectivity for a diversity of species including prey animals for the owl. 
Chapter 3. Affected Environment and Environmental Consequences

202 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The gravel pit sites have not yet been identified. They will likely be on the western side of the 

project area because the rock in that area is of good enough quality to use on the roads. Future 

gravel pits would not be established in areas where effects on the owl are anticipated.

Effects on Critical Habitat

The proposed treatments would result in an overall benefit to critical habitat by enhancing 

riparian and meadow habitat, promoting aspen stands, and moving towards a resilient landscape, 

while reducing habitat loss from environmental stressors such as wildfire. See table 40 above for 

a list of planned treatments in critical habitat.

The mechanical treatments are expected to retain the range of tree species and size classes needed 

for quality critical habitat. Species and size diversity would promote cover, forage habitat, and 

promote recovery of the owl in the project area over the long term by increasing resiliency. Some 

loss of trees of all types and diameter size classes would occur from hazard tree removal along 

prescribed fire control lines, prescribed fire, temporary road construction, and road maintenance. 

Trees up to 18-inches diameter could be cut as part of the mechanical treatments. The effects 

from tree removal should be small in extent and intensity.

Tree canopy would be reduced following hazard tree removal along prescribed fire control lines, 

forest stand improvement thinning, prescribed fire, and mechanical treatments. Canopy cover is 

not anticipated to be reduced below 40 percent in groups and clumps across the landscape, and 

would be managed for higher basal areas. The reduction in canopy cover may shift or increase 

prey species distribution as understory vegetation is reestablished in what are now high-density 

stands. 

Prescribed fire treatments would result in a short-term decrease in understory plant cover, but 

provide conditions that would increase plant growth in the long term by removing the thick layer 

of litter on the forest floor. As a result, critical habitat quality would improve because the change 

in vegetation would favor small rodents, promoting greater prey diversity and availability, 

particularly during the breeding season. These treatments would likely reduce the high volume of 

fallen trees and woody debris also. This would result in in short-term, adverse effects on prey 

species, but as discussed above, would likely improve habitat and food availability for prey 

species. Some short-term loss of cover is likely to occur based on the shift in plant species.

Large snags are limited across the project primarily due to past harvesting that removed large 

trees. Prescribed fire and hazard tree removal may further reduce snag distribution across the 

project area, but prescribed fire is likely to create snags through tree mortality. Drought, disease, 

and insect infestations are other ways that may promote adequate snag densities across the 

landscape though the project is expected to also improve resilience to disease and insects. If snags 

are limited in the project area after treatments, snags may be created by using fire or other 

mechanical methods. 

Forest Plan Amendments

Site-specific forest plan amendments are needed to implement prescribed fire and other 

restoration treatments within the PACs. These amendments are also needed to address the 

differences between the forest plan guidance for the management of Mexican spotted owl habitat 

and the revised MSO recovery plan (USFWS 2012), which was updated to reflect the current 

science. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 203

The effects of the amendments are the same as the effects described above. The amendments are 

intended to facilitate restoration treatments, which are designed to implement the most current 

scientific information on the species and its habitat requirements. The amendments also have the 

effect of allowing the Forest to treat all of the PACs within the project area. Under the current 

forest plan, not all of the PACs within the project area could be treated without monitoring to 

determine the effects of the treatments before treating all of the PACs. This was an issue also 

addressed in the revised recovery plan for the owl as recovery units were broadened to encompass 

larger areas. 

ESA Cumulative Effects

Cumulative effects under the Endangered Species Act joint regulations are those effects of future 

State or private activities, not involving Federal activities that are reasonably certain to occur 

within the action area subject to consultation. Non-National Forest System lands within the 

project area total about 13,836 acres: Jemez Pueblo- 3,845 acres; State- 281 acres, and private or 

other lands- 9,710 acres. We are not proposing to do any treatments on non-national forest land. 

The Forest is not aware of any major actions proposed on State or private lands. Ongoing 

activities in subdivisions, private and State road maintenance, private mining activities, and 

recreation may increase disturbance and influence quality or quantity of Mexican spotted owl 

habitat on those lands. 

Western Yellow-Billed Cuckoo

Determination of Effect (Proposed Species): Not Likely to Jeopardize 

Determination of Effect (if listed): May Affect, Not Likely to Adversely Affect 

Critical Habitat: Not applicable 

Approximately 630 acres of potential habitat were identified on the Santa Fe National Forest. 

Seven acres (about 1.1 percent) is in the project area along the Jemez River. Riparian and 

instream habitat treatments may occur in cuckoo habitat. Instream restoration and stabilization 

and riparian planting may occur in potential habitat as part of the project but are expected to be 

minimal in the cottonwood galleries. Project activities are not likely to affect the cuckoo. 

Site-specific forest plan amendments will likely have no effect on the Western yellow-billed 

cuckoo as the areas for which the amendments apply do not overlap in time or space with cuckoo 

habitat. The amendments pertaining to woodland and cliff-swelling species, (peregrine falcon), 

and changes in management for visual quality and would not affect cuckoo habitat. 

ESA Cumulative Effects

Much of the habitat along the lower Jemez River where potential cuckoo habitat exists is 

privately owned. The Forest is not aware of any plans to further develop these lands or of other 

State actions that may cumulatively affect the cuckoo.

Jemez Mountains Salamander

Determination of Effect (Species): May Affect, Likely to Adversely Affect 

Determination of Effect (Critical Habitat): May Affect, Likely to Adversely Affect 

Table 41 displays the type and amount of treatment planned for salamander critical habitat. No 

temporary roads would be constructed in salamander critical habitat. Not all acres identified in in 
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204 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

the table would be treated. For example, only about 10 acres of aspen treatments would occur in 

critical habitat, but over 3,000 acres are available for such treatments. This is also true for 

headcut, riparian, and meadow treatments. Most of the acres being treated with mechanical 

treatments and prescribed fire would receive treatment.

Table 41. Amount and type of proposed treatments in Jemez Mountains salamander critical habitat 

Treatment Type Amount in Critical Habitat

Aspen Enhancement 3,322 acres

Meadow Restoration 553 acres

Piñon-juniper 

treatments 0 acres

Riparian Restoration 592 acres

Salamander Habitat 

Enhancement 131 acres

Old Growth 1,592 acres

Invasive Plant Control 29 acres

Headcut Treatments 159 sites

Dispersed Campsite 

Rehabilitation 7 sites

Road 

Decommissioning 6 miles

Mechanical treatments 3,709 acres

Prescribed fire 11,724 acres

Roads Used to Access 

Treatment Sites 83 miles

Landings 152 sites

Effects on the Species

The proposed mechanical treatments are expected to result in impacts on surface habitat, but 

these impacts are not anticipated to affect subsurface habitat where the species likely lives most 

of the year. Effects on surface habitat would result from movement of some surface rocks and 

changes in down log availability and abundance. Existing down logs would be avoided as much 

as possible. Occupied stands fall within designated critical habitat and would receive different 

mechanical treatments (see below).

Control of invasive and nonnative plants would promote a healthier habitat for wildlife but could 

have adverse effects if conducted during the monsoon season when salamanders are at or near the 

surface. The areas with these plants are small, and areas along roads are not suitable salamander 

habitat, so effects on salamanders are likely to be minimal. These plants, however, may reduce the 

quality of salamander habitat, adversely affecting microhabitat and controlling the spread and 

establishment of these plants would have a positive effect in the long term. 

Effects on Critical Habitat

Creating a more resilient landscape would reduce the threat of wildfire to critical habitat and 

prevent loss of habitat elements such as down logs and snags. Reducing the elevated hazard of 

high-severity fire would reduce salamander mortality from excessive drying of the soil due to the 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 205

total loss of canopy cover. This loss of canopy cover would occur in a stand-replacing fire. 

Reducing tree density overstocked stands would decrease evaporation of snow from tree branches 

and improve the surface snow pack and improve infiltration of water into the soil (Hedstrom and 

Pomeroy 1998; Hood et al 1999; Storck et al 2002). Higher soil moisture following snow-melt 

would improve salamander habitat conditions into early summer and reduce the time of low 

moisture availability between snowmelt and the start of the monsoons. Ultimately, moisture is 

dependent on climatic conditions and climate change may reduce snowfall and worsen drying of 

habitat. 

The mechanical treatments would reduce tree canopy coverage, allowing more sunlight to reach 

the ground. Understory vegetation would increase over the long term, but in the short term, there 

may be short term drying of the soil until understory vegetation is established. Some areas of 

habitat may experience periods of increased warmth and dryness, which would influence 

salamander activities and microhabitat distribution. This effect could be offset by increases in the 

snowpack as described above. Regardless, a treated forest would provide year-round shade as 

compared to the deciduous shading provided by shrubs that grow after a stand-replacing fire.

Mechanical treatments would leave most of the existing down wood logs and stumps but 

prescribed fire would likely reduce log and stump availability. Additional logs from thinning 

treatments and cutting of hazard trees may also improve log recruitment. 

Machinery and other equipment may cause direct mortality of salamanders by crushing and 

compacting the soil or surface rocks where salamander maybe sheltering. This impact is likely 

minimal because heavy equipment would be used when conditions are dry and salamanders are 

not likely to be at the surface. 

The use of hand crews to reduce ladder fuels in occupied stands would reduce the chance of 

injury or mortality to individual salamanders as compared to machinery. Mortality is not likely 

because prime microhabitat sites (logs, stumps, and rock piles) would be avoided, and some sites 

may be too dry for salamander use. 

Road closure and rehabilitation may reduce any ongoing road impacts on surrounding salamander 

habitat. Road maintenance would have no significant effect because it occurs in the existing road 

footprint, which is not suitable habitat. Road treatments would likely reduce sediment runoff. 

Riparian zones, seeps, springs and wetlands are generally not suitable salamander habitat, as 

salamanders generally do not directly occupy riparian zones. Nearby offsite logs and stumps at 

the edge of riparian zones, however, may provide suitable microsites. 

ESA Cumulative Effects

Cumulative effects under the Endangered Species Act joint regulations are those effects from 

future State or private activities, not involving Federal activities that are reasonably certain to 

occur within the project area of the Federal action subject to consultation. The ongoing activities 

in subdivisions, roads, mining, and recreation, may increase disturbance and influence quality and 

quantity of habitat on State and private land. 

Canada Lynx (All Action Alternatives) 

Determination of Effect (Proposed Species): Not Likely to Jeopardize 

Determination of Effect (if listed): May Affect, Not Likely to Adversely Affect 
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206 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Critical Habitat: Not applicable 

Recovery Plan: Not applicable 

There is no documented detection of lynx in the project area. None of the action alternatives are 

likely to rise to the level of effects that would result in take of the species. 

New Mexico Jumping Mouse 

Determination of Effect (Species): May Affect, Likely to Adversely Affect 

Determination of Effect (Proposed Critical Habitat): May Affect, Likely to Adversely Affect 

Effects on the Species and Proposed Critical Habitat

The riparian plant species needed to support habitat for the jumping mouse are limited or absent. 

Treatments would likely move jumping mouse habitat toward a desired condition and function for 

the species’ recovery in San Antonio and Rio Cebolla streams systems. Proposed treatments to 

enhance riparian areas, the instream habitat work, and exclosures would improve jumping mouse 

habitat. 

Riparian and channel restoration may result in short-term impacts on the mouse through ground 

disturbance in riparian areas to promote willow and other woody riparian vegetation growth. 

Long-term effects are anticipated from project activities as they are intended to improve riparian 

vegetation and restore wetlands by improving floodplain connectivity. Instream channel 

restoration actions would generate short-term increases in sediment and turbidity in sections of 

the stream downstream of the activity.

Wolverine 

Determination of Effect: Not Likely to Jeopardize

There are no documented records of wolverine present in the project area. Project activities are 

not expected to impact wolverine habitat. 

Rio Grande Cutthroat Trout

Determination of Effect (Proposed Species): Not Likely to Jeopardize 

Determination of Effect (if listed): May Affect, Likely to Adversely Affect, and may benefit.

Critical Habitat: Not applicable 

Recovery Plan: Not applicable 

The proposed riparian area restoration, aquatic habitat improvement, and instream treatments 

would improve habitat conditions for the trout in San Antonio Creek, Rio Cebolla, East Fork of 

the Jemez River, and the Rio Guadalupe. All streams are currently lacking key habitat 

components, including quality pool habitat. Streams are too wide and shallow. Many streams also 

have an overabundance of fine sediment, bank erosion, and a lack of large woody debris (USFS 

2010b). In addition, several reaches are downcut, and as a result, the streams are no longer 

connected to their floodplain. This connectivity helps to dissipate large flood and runoff events. 

Aquatic habitat improvement and other treatments to enhance pool habitat, reduce stream width, 

reconnect channels and floodplains, repair headcuts and reduce sediment input, and stabilize 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 207

streambanks would all greatly improve habitat quality. Overall, the effects of these watershed 

treatments are beneficial to the trout. Short-term impacts could include an increase in 

sedimentation and turbidity due to mechanical equipment working in or near the stream during 

habitat and channel restoration projects. These impacts are expected to be of short duration and 

very localized. Fish will be able move out of the area and seek refuge in other parts of the stream. 

Prescribed fire and mechanical treatments would create a more resilient landscape and would 

reduce impacts on trout habitat by reducing the potential for a high-severity, stand-replacing 

wildfire. In addition, the proposed action is consistent with strategies to reduce the predicted 

effects of climate change on cutthroat trout by creating more resilient landscapes and addressing 

the issues of water quality and water quantity (Zeigler et al. 2013; Wenger et al. 2011). Reducing 

the forest canopy cover would decrease sublimation of snow and increase infiltration of 

snowmelt, which would ensure a prolonged snowmelt runoff. This may increase the base flow of 

streams (Baker and Ffolliott 2003). 

Overall, the effects of mechanical treatments and prescribed fire are beneficial; however, shortterm impacts could include runoff and sedimentation from temporary road construction, skid 

trails, and landings. These impacts are expected to be of short duration and very localized. Fish 

would be able move out of the area and seek refuge in other areas of the stream. Some ash runoff 

from prescribed fire may find its way into a perennial stream during monsoon storm events. Fish 

mortality could occur because ash and debris flows can be lethal to fish (Rinne 1996, Brown et al. 

2001, USFS 2006, Patten et al. 2007). 

ESA Cumulative Effects

Cumulative effects under the Endangered Species Act joint regulations are those effects of future 

State or private activities, not involving Federal activities that are reasonably certain to occur 

within the action area of the Federal action subject to consultation. The ongoing activities in 

subdivisions, roads, mining, and recreation, may increase disturbance and influence water quality 

and quantity of spawning habitat on State and private land. 

Alternative 3 

This applies to the following species: Mexican spotted owl, Western yellow-billed cuckoo, Jemez 

Mountains salamander, Canada lynx, New Mexico meadow jumping mouse, wolverine, and Rio 

Grande cutthroat trout.

About 1,900 fewer acres would be mechanically treated than under alternative 1. The effects on 

treated stands would be the same as under alternative 1. In the remainder of the area, the effects 

from prescribed fire would be similar to alternative 1. Affects from all other actions are 

anticipated to be the same as identified under Alternative 1. 

Alternative 4

This applies to the following species: Mexican spotted owl, Western yellow-billed cuckoo, Jemez 

Mountains salamander, Canada lynx, New Mexico meadow jumping mouse, wolverine, and Rio 

Grande cutthroat trout.

The forest structure would be as described in the proposed action (alternative 1), with groups, 

interspaces and all sizes of trees. The slash treatment would be different and have different 

effects. The large wood could be hauled out as product and firewood. The remaining wood, less 
Chapter 3. Affected Environment and Environmental Consequences

208 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

than 4-inches diameter, would remain on site. If not disposed of, it would be a fire hazard. If it is 

not burned, it would have to be chipped, masticated, or shredded. 

While research results are not consistent, overall it appears that mastication can reduce fire hazard 

by putting all the woody material on the ground, reducing ladder fuels. However, if there is a 

great quantity of material (branches, twigs, needles), and we expect there would be, it can create a 

deep fuel bed. If the chips burn when the soil is dry, they will hold heat for a long time, heating 

and sterilizing the soil, and killing some of the remaining trees by overheating their roots. The 

mulch that is created will protect the soil and decompose over time, which is good for the soil. 

However, while it is breaking down, it will tie up soil nutrients, such as nitrogen, which will not 

be available for plant and tree use. In addition, a deep bed of chips can suppress grass growth. 

Understory vegetation would be sparse, seedbeds for new trees would not be created, mistletoe 

would not be held in check, and various sizes of down wood would not be present. The stands 

would not be as fire-resistant as in the proposed action. For more information on the effects of 

slash treatment and mastication, see the fuels specialist report. The benefits of prescribed fire 

would be realized outside the area of mechanical treatments.

There would be fewer acres of aspen regeneration. Aspen stands in the prescribed fire areas 

would be stimulated and maintained. However, aspen would have a hard time sprouting in the 

treated areas because of the thick chips. 

Old growth could be enhanced by light thinning in appropriate stands. However, stands would 

remain susceptible to uncharacteristically severe wildfires, because they would be outside the 

normal fire regime and would still have ladder fuels and low branches. Burning in untreated 

stands would require a narrow window of conditions and be difficult to achieve. 

Alternative 5

The effects on Western yellow-billed cuckoo, Jemez Mountains salamander, Canada lynx, New 

Mexico meadow jumping mouse, wolverine, and Rio Grande cutthroat trout under alternative 5 

are anticipated to be similar to the effects identified under alternative 1 with the exception that 

long-term benefits would likely be reduced where salamander habitat overlaps with MSO habitat. 

Short-term effects on salamander critical habitat may also be reduced due to higher residual 

canopy cover associated with maintaining a higher basal area in MSO habitat.

This alternative would reduce the total area treated with prescribed fire by 700 acres. This 

alternative would comply with the current forest plan standards and guidelines for Mexican 

spotted owl habitat. The proposed forest plan amendments related to treatments in Mexican 

spotted owl habitat would not be needed to implement this alternative. The remaining proposed 

forest plan amendments would be needed to implement this alternative. 

All other treatments remain the same including mechanical treatments and prescribed fire in 

ponderosa pine and dry mixed conifer, invasive plant control, aquatic, riparian, and wildlife 

habitat improvement, cultural resource protection, road closure and decommissioning, 

construction of temporary roads, construction of gravel pits, and road maintenance. Therefore, 

affects from all other actions are anticipated to be the same as identified under alternative 1. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 209

Mexican Spotted Owl

Under this alternative, the Forest would adhere to the current forest plan standards and guidelines 

applicable to activities in MSO habitat (USFS 1987b, Appendix D). No forest plan amendments 

regarding MSO would be proposed. 

It may be necessary to construct handline to prevent prescribed fire from entering the core area. 

Natural features and roads would also be used as fire control lines, and this would minimize the 

amount of handline construction needed. All activities in PACs would be conducted outside of the 

breeding season unless adequately conducted surveys indicate that the PAC is not occupied.

It is my determination that selection of Alternative 5 “May Affect, and is Not Likely to Adversely 

Affect” MSO. Beneficial effects would be short term (5-10 years).

Mexican Spotted Owl Critical Habitat

Effects on critical habitat for the owl are not likely to change the determination to “may affect, 

likely to adversely affect”. This is because current forest plan standards and guides direct 

maintaining a high canopy cover and proposed activities are not likely to result in changes to 

forest structure or prey habitat. Forest composition would likely remain the same and prey habitat 

may improve, but not to the extent expected under alternative 1. This is due to the higher basal 

area required to be maintained under the current forest plan (150 versus 120 under the revised 

recovery plan). Snags meeting the required size would be retained except where hazardous to 

human safety. Prescribed fire may reduce snags and woody debris, but it is not anticipated that 

this would cause a significant effect. Overall, implementing alternative 5 would reduce adverse 

effects on the Mexican spotted owl in the short term. However, the PACs and other restricted 

habitats would be less resilient to disturbance or other threats over time.

Sensitive Species 

Affected Environment

The goal is to manage sensitive species habitat to maintain viable populations and prevent a trend 

toward listing under the Endangered Species Act. 

The plants and animals on the regional forester’s sensitive species list (USFS 2013) that occur in 

the area, have habitat in the area, or could otherwise be affected by proposed activities are: 

• Small mammals- pale Townsend’s big-eared bat 

• Forest carnivores- American marten 

• Riparian33 - masked shrew, northern leopard frog, Preble’s shrew, spotted bat, and water 

shrew 

• Plants- Springer’s blazing star, yellow lady’s slipper, and wood lily 

• Birds- American peregrine falcon, northern goshawk, gray vireo, boreal owl 

• Fish- Rio Grande chub and Rio Grande sucker 

Springer’s blazing star, robust larkspur, and the wood lily are suspected, and likely to occur in the 

area based on habitat availability to support individuals or groups within the forest boundary. The 

 

33 Riparian habitat was evaluated as a unit, so plant and animal species are included in this grouping.
Chapter 3. Affected Environment and Environmental Consequences

210 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

other species are documented to exist, meaning there is a reliable, recorded observation in 

appropriate habitat within the forest boundary. 

Forest Sensitive Species with “No Effect” determination

Sensitive species that may be affected by the proposed treatments were identified by evaluating 

the habitat needs of the listed species against the habitat in the project area that may be affected 

by proposed activities. Known occupancy or use by sensitive species was also considered. 

As a result, some of the Region 3 sensitive species were excluded from further analysis because 

one or more of the following criteria apply: (1) the project is outside the species range, (2) the 

project area does not contain essential habitat, or (3) species is not known to occur in the project 

area. For example, the prescribed fire actions would not be expected to substantially burn or alter 

vegetative conditions in cool-wet habitat or in cliff or cave habitat, so the species associated with 

those habitats would not likely be impacted. 

It was determined that for all action alternatives (1, 3, 4, and 5) the proposed treatments would 

have “no effect” on the following species: white tailed ptarmigan, burrowing owl, bald eagle, 

Lilljeborg’s pea-clam, American pika, Goat Peak pika, Gunnison’s prairie dog, Canada lynx, 

tufted sand verbena, Greene’s milkweed, Chaco milkvetch, Pecos mariposa lily, Pecos fleabane, 

Chama blazing star, Heil’s alpine whitlowgrass, and Arizona willow. The reasons for excluding 

these species from analysis are found in the biological evaluation, which is found in the project 

record.

Methods Used to Analyze Effects 

This analysis used the specialist reports and other information developed for the Southwest Jemez 

Landscape Strategy, stand exam data, aerial photo interpretation, and Forest GIS databases for 

vegetation and wildlife. The vegetation and soils and water resources specialist reports prepared

for this FEIS were also used to analyze effects. These databases include variables related to forest 

structure and forest health, i.e., wildlife habitat such as snags, down logs, tree density, sizeclasses, and species, old growth, and wildlife habitat classifications. The Las Conchas fire was 

used to evaluate what a landscape looks like when it is departed from the historical fire regimes. 

Effects on species and their habitats were evaluated at multiple scales. This project was analyzed 

and assessed with consideration of the best available science, forest plan standards and 

guidelines, research and life history literature, approved survey protocols, and professional 

judgment. The assumptions about the proposed restoration treatments that were used to make the 

determination of effect for the species and habitat are found in the biological evaluation. 

Summary of Effects

General effects on the sensitive species listed previously are summarized below. A detailed 

analysis by species follows. The proposed treatments would have some level of adverse effects on 

sensitive species under all alternatives. These effects would be short term and the intensity is 

anticipated to be low to moderate depending on a species’ specific habitat requirements. Noise, 

smoke, and other effects would disturb or displace animals.

The long-term benefit is improved habitat for sensitive species and expansion of those benefits 

across a broader landscape. Habitat would also become increasingly structurally complex and 

biologically diverse, with abundant herbaceous plants in scattered openings and greater 

dominance by large, fire-adapted trees. There would be improvements in nesting, roosting, and 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 211

prey-base foraging habitat for the goshawk, and peregrine falcons would expand into more of 

their available habitat. Overall there would be a healthier ecological condition and a more 

resilient landscape to disturbance events. 

The determinations of effects by alternative are as follows:

• Alternatives 1, 3, 4, and 5 may impact individuals but is not likely to result in a trend 

toward federal listing or loss of viability 

• Alternative 2 would not result in a trend toward federal listing or loss of viability

Environmental Consequences

Effects on the Mexican spotted owl, New Mexico meadow jumping mouse, Jemez Mountains 

salamander, western yellow-billed cuckoo, and Rio Grande cutthroat trout are found in the 

previous section on threatened, endangered, and proposed species. Effects of the mechanical 

treatments on goshawk habitat are also discussed in the vegetation section of chapter 3 and the 

silviculture specialist report. 

Alternative 1

This alternative may affect individuals, but is not likely to result in a trend toward federal listing 

or loss of viability for the sensitive species in the project area. Project activities may impact 

individuals by disturbing them during the breeding and nesting seasons, changing existing habitat 

characteristics, or by temporarily displacing them from their habitat. Project activities would 

impact species in the short term, but would be beneficial in the long term. In the case of plants 

and slow moving wildlife species, there may be some direct mortality as a result of restoration 

activities. 

It is difficult to quantify the number of individual animals that might be affected by project 

activities because a particular species may be difficult to survey and detect. Additionally, the 

status of a species could change over time as they move within their habitat and through the loss 

or creation of habitat. 

None of the sensitive species are confined solely to the project area. Thus, the restoration actions 

would have limited effects on overall habitat relative to the availability of habitat for these 

sensitive species on the district and the forest. The degree of the change in habitat components 

could be larger in some areas because treatment effects may build on each other. For example, 

mechanical treatments would be followed by a low to moderate-intensity prescribed fire. 

Compared to using prescribed fire only, mechanical treatments and prescribed fire would likely 

remove more trees more quickly than prescribed fire alone. Using only prescribed fire would not 

damage or kill most of the dominant and co-dominant (larger) trees, large down logs, and 

overstory canopy cover, but would consume most of the smaller trees and fine surface fuels. 

Mechanical Treatments

The restoration of fire-adapted ponderosa pine and Douglas-fir forests would make the area more 

resilient to disturbances such as stand-replacing wildfire. Low-intensity surface fires would be 

sustainable. Removing the tree canopy coverage would allow more sunlight to reach the ground 

and increase growth of understory plants. This should result in improved forest conditions and 

improved forage, nesting, and cover habitat for sensitive species. Prey availability for raptors and 

carnivores, such as northern goshawk and marten, should also improve. 
Chapter 3. Affected Environment and Environmental Consequences

212 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Mechanical treatments would reduce canopy cover and likely change small mammal distribution 

and abundance in the short term. Increased noise from chainsaws and other equipment during the 

breeding season would disturb or flush birds from roosting and nesting sites. Adult birds may not 

nest and may abandon their nests if they are disturbed by noise or other activities. Mechanical 

treatments are more likely to prevent or disturb nesting in any given area. There would be little or 

no disturbance to nesting birds during the winter months. Additionally, removal or selective 

placement of large down logs at archeological sites could cause displacement of small mammals 

and amphibians. Machinery and vehicles may cause direct mortality by crushing individual 

animals or plants or by compacting surface rocks and soil and destroying habitat. Plants and small 

mammals and amphibians and other animals that have underground habitat would be the most 

affected. 

Prescribed Fire

Conducting prescribed fires during the breeding season may create short-term adverse effects on 

sensitive species, these treatments are more likely to take place in the fall because of more 

favorable burning conditions. This is also outside of most breeding seasons. Adult animals may 

abandon their young and leave the area if they are disturbed by noise, smoke, or other activities. 

In other cases, birds or mammals may not successfully raise their young. Trees may be cut to 

improve fireline safety before a prescribed fire and this may cause mortality of some individuals. 

The likelihood of this occurring is very small. 

Prescribed fire would create scattered openings that would fill in with understory plants such as

grasses, forbs, and other herbaceous plants. Burning would likely be uneven across the area 

creating a mosaic of vegetation types that mimic historical conditions. The patchiness of burn 

patterns in interspaces and openings created by mechanical treatments would stimulate aspen 

growth. Little or no burning would occur on the cooler, north-facing slopes that have wet mixed 

conifer forests. The burning would modestly improve the structural complexity and habitat 

diversity that typically happens with these types of surface fires (Pilliod et al. 2006). Prescribed 

fire would also reduce the high amount of seedlings, saplings, young trees, and fine fuels. As 

stand structure changes and the canopy becomes more open, prey habitat availability would 

improve for raptor and carnivore species (Bagne and Finch 2009).

Prescribed fire combined with mechanical treatments would preserve forest habitat for species by 

reducing the likelihood of an uncharacteristically severe wildfire that would damage or destroy 

the forest.

Other Treatments

Riparian areas, seeps, springs, and wetlands are generally suitable habitat for a number of species 

because of the diversity of vegetation and availability of water. Logs and stumps at the edge of 

riparian areas may also provide suitable microhabitats for those species that transition between 

riparian and upland forests like the long-tailed weasel or the shrew(s). Meadow, riparian, and 

stream channel restoration activities would likely increase forage availability for rodents, restore 

wetlands, and wetland obligate species, and improve aquatic conditions for fish and macroinvertebrates. Species that depend on riparian areas may not use or be able to occupy areas that 

have nonnative and invasive plants. Controlling or eliminating these plants would conserve 

riparian habitat and improve habitat quality for sensitive species.

Heavy equipment may disturb the ground and compact soils when it is used in or next to 

meadows and riparian areas and cause direct mortality of individual small mammals, amphibians, 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 213

and plants. Headcut treatments and instream aquatic habitat work could increase sediment flow 

into streams that may affect fish and the macro-invertebrates they feed on while the work is being 

done. These adverse effects are expected to be short term. 

Treatments that enhance riparian habitat, seeps and springs, and instream aquatic habitat would 

greatly improve habitat in all perennial streams, especially San Antonio Creek and Rio Cebolla 

where many treatments would occur. Currently, stream channels lack connectivity to their 

floodplain at many locations and this limits water retention in streamside areas. As a result, 

vegetation needed by riparian-dependent species is limited. The improvement of habitat quality 

and connectivity in riparian areas would be beneficial to many species and restore aquatic 

functions. When watershed treatments such as instream channel work occur in streams where Rio 

Grande chub and Rio Grande sucker occur, it is likely that fish would be displaced or may not 

survive in a site specific location. Sediment and debris flows created by project activities may 

impact individual fish in the stream.

Road decommissioning may result in the recovery of habitat for sensitive species. Currently, the 

Forest is in the process of implementing the Travel Management Decision, which designates 

routes available for public travel. The implementation is an ongoing process that will reduce 

wildlife impacts from vehicle travel. Road maintenance may have minor effects through the use 

of heavy equipment to maintain lead out ditches that keep water from eroding away the road’s 

surface.

Noise, smoke, and other disturbances from project activities would likely cause raptors and other 

birds to temporarily avoid areas when activities are taking place. The length and intensity of the 

disturbance would depend on the particular activity and amount of time it takes to complete it. 

The effects of noise vary by species of wildlife. For example, a study looking at the effects of 

traffic noise from logging trucks on nesting goshawks found that there were no negative effects 

on the birds (Grubb et al. 2012). 

Project activities could adversely impact habitat for sensitive species such as goshawk, peregrine 

falcon, Rio Grande chub, and Rio Grande sucker. When watershed treatments such as instream 

channel work are done in streams where Rio Grande chub and Rio Grande sucker occur, it is 

likely that fish would be displaced or may not survive in a specific location. Sediment and debris 

flows created by project activities may impact individual fish in the stream.

Alternative 2

This alternative would not result in a trend toward federal listing or loss of viability for the 

sensitive species described because the proposed treatments would not be implemented. Current 

conditions would persist, and forested areas would be vulnerable to uncharacteristically severe 

wildfires. Riparian areas would remain degraded and in poor functioning condition. Vegetation 

and fuel conditions, described in the vegetation and fuels sections of the FEIS, would continue to 

limit the availability of prey species for some small mammals, birds, and forest carnivores. 

A severe wildfire is more likely under this alternative and would adversely impact habitat for all 

of the sensitive species. In severely burned areas there would be a long-term loss of large trees 

and tree canopy, large down logs, mature stands, nesting and roosting habitat, and other key 

habitat features for the goshawk, peregrine, salamander, and other sensitive species. Such fires 

can also cause widespread mortality of less mobile sensitive species. 
Chapter 3. Affected Environment and Environmental Consequences

214 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Alternative 3

This alternative may affect individuals but is not likely to result in a trend toward federal listing 

or loss of viability. About 1,900 acres would not be mechanically treated because temporary roads 

would not be built to access those acres. These acres would be treated with prescribed fire only. 

This is not a large area compared to the total number of acres planned for mechanical treatments, 

and the effects would remain nearly the same as alternative 1. 

Soil compaction and disturbance would not occur on sites where access with temporary roads is 

needed. The plant, animal, and riparian groups of species would experience less noise disturbance 

and fewer habitat impacts from ground disturbance and soil compaction. The intensity of the 

effects of prescribed fire may be higher because fuels are not mechanically treated on those acres. 

On the 1,900 acres that are not mechanically treated, the intensity of the activities would be less 

than doing both mechanical and prescribed fire treatments in the same footprint. The effects from 

the other treatments would be the same.

Alternative 4

This alternative may affect individuals but is not likely to result in a trend toward federal listing 

or loss of viability. This alternative would limit the amount of prescribed fire used as compared to 

alternative 1. Effects on sensitive species would vary depending on the species. Effects from 

mechanical treatments and heavy machinery used to treat the slash and forest floor fuels may be 

greater than if the slash and fuels were treated with prescribed fire.

Fewer acres would be treated with prescribed fire and both the beneficial and adverse effects of 

prescribed fire would not occur on those acres. The acres that are not burned may be less resilient 

and the diversity and abundance of understory plants would likely be lower. The short-term 

adverse effects on sensitive species from prescribed fire (as described for alternative 1) would not

occur. 

Dense even-aged stands would be treated using other methods such as wood chippers or 

masticators in areas planned for harvest. The wood chips may interrupt the movement of species 

living underground and may disrupt plant growth. Species such as aspen may not sprout due to 

the layer of chips, and there would be no bare mineral soil available for ponderosa pine seeds to 

germinate. Effects from all other proposed treatments would be the same as alternative 1. 

Alternative 5

This alternative may impact individuals but is not likely to result in a trend toward federal listing 

or loss of viability for any sensitive species in the project area. Effects would be the same as those 

described for alternative 1, except that there would be no effects on approximately 700 fewer 

acres of the core areas of Mexican spotted owl protected activity centers. Trees greater than 9-

inches diameter would not be cut in Mexican spotted owl PACs. As a result, PACs could be more 

vulnerable to the effects of wildfire as more fuel would accumulate over time. These areas would 

also provide undisturbed areas for sensitive species that use forested areas outside of adjacent 

disturbed areas until the activities are completed.

Forest Plan Amendments

Amendments eliminating activity restrictions during wildlife breeding seasons and clarifying the 

language regarding interspaces would allow us to meet the desired future condition in goshawk 

habitat. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 215

Amendments regarding site plans for peregrine falcons would provide more flexibility and would 

allow for the timely implementation of restoration treatments.

Cumulative Effects

Reasonably foreseeable forest activities that may contribute to the cumulative effects from this 

restoration project are listed in appendix B. The Valles Caldera National Preserve will also be 

implementing restoration activities. Because of the shared boundary between the forest and the 

Preserve, actions may overlap in time and space and add to the effects on sensitive species and 

their habitats. Bandelier National Monument may also carry out restoration activities within the 

same timeframe as our project and those actions may also cumulatively add to project affects. 

Foreseeable future forest restoration activities in the Southwest Jemez Mountains should alter the 

current trend of increasingly large and severe wildfires. The primary cumulative effect would be 

the reduced probability of a large, severe crown fire and the return of periodic low to moderateintensity surface fires that improve habitat for species that evolved in these fire-adapted forests. 

Several foreseeable future actions should improve habitat conditions, including implementation 

of forest and riparian restoration treatments in the surrounding area, and treatment of invasive 

plant species (USFS 2010b). These treatments would magnify the improvement to sensitive 

species habitat and expand those across the broader landscape. Habitat would become structurally 

complex and biologically diverse. Improvements in nesting, roosting, and prey-base foraging 

habitat for the goshawk and peregrine falcon would be found across their habitat. 

Implementation of the travel management decision and road decommissioning would result in 

less off-highway vehicle use and reduce vehicle interaction with sensitive species. None of these 

are expected to cause a significant adverse impact. Foreseeable future pumice mining would 

slightly add to habitat disturbance. Population growth in nearby communities, firewood gathering, 

and recreational activities would create short-term disturbance impacts on habitat and add to 

disturbance effects from the proposed activities when they overlap in time and location. 

We do not anticipate any other habitat altering or major disturbance activities occurring in 

goshawk habitat at the same time as the proposed project. No significant adverse cumulative 

effects on sensitive species or their habitat is expected.

Effects on Individual Species 

Summary of Effects

Tables showing the amount and type of treatment under each alternative are in the biological 

evaluation prepared for this FEIS. These tables were used in the effects analysis and 

determination of effects. Descriptions of the species and their habitats are also found in the 

biological evaluation. Effects determinations were made for each of the sensitive species. The 

proposed action has the greatest level of effects on species across the landscape. Alternatives 1, 3, 

4, and 5 may impact individuals but are not likely to result in a trend toward federal listing or loss 

of viability for the Santa Fe National Forest sensitive species evaluated below. 

Rio Grande Chub and Rio Grande Sucker

In the project area, Rio Grande chubs are found in the Rio Cebolla, Rio Guadalupe, East Fork 

Jemez River, and in the main stem Jemez River. Rio Grande suckers are found in the Rio Cebolla, 

Rio Guadalupe, San Antonio Creek, East Fork Jemez River, and in the main stem Jemez River. 
Chapter 3. Affected Environment and Environmental Consequences

216 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Projects occurring within streams, including the installation, replacement, or removal of stream 

crossing structures, and instream habitat improvements, would result in the direct mortality of Rio 

Grande chubs and suckers or the destruction or elimination of their habitat. Other effects would 

result in changes to fish habitat as a result of changes in the aquatic environment over time. These 

changes include alteration of stream channel sediment or woody debris delivery rates and 

amounts; modification of stream temperature regimes by reducing riparian shading, or changes in 

stream bank stability due to activities near stream banks. 

There may be some short-term, localized impacts on these fish or their habitat under alternative 1. 

The proposed treatments, however, are designed to improve landscape conditions, which would 

benefit Rio Grande chubs in the long term. Instream habitat restoration would improve channel 

geomorphology and riparian treatments would increase stream shading and stream bank stability. 

These result in cooler water temperatures, deeper pools, and improved water quality. Upland 

treatments (mechanical treatments and prescribed fire), which reduce the risk of severe wildfire, 

would protect these stream systems from post-fire ash and debris flows, which destabilize streams 

and impact fish populations. 

Selection of alternative 1 may impact individuals, but is not likely to result in a trend toward 

Federal listing or loss of viability for Rio Grande chub and Rio Grande sucker.

Northern Leopard Frog

The northern leopard frog has been documented on the Jemez Ranger District, and there are about 

3,900 acres of habitat in the project area. 

The set of riparian vegetation species needed to support leopard frog habitat is currently limited 

or absent. Treatments that enhance wetlands (riparian areas, seeps, and springs) such as 

exclosures, rechannelization, and stream bank stabilization, would likely move riparian areas 

toward functional state and improve habitat for the frog. 

Machinery and equipment may cause direct mortality of frogs as well as compaction of soil in 

riparian habitat. Using hand crews to reduce ladder fuels in areas that are not accessible to 

machinery would likely reduce the chance of direct impacts on individuals. Removal or reduction 

of tree canopy cover would allow more sunlight to reach the ground enhancing riparian 

vegetation response. After mechanical treatments, some areas of habitat may experience periods 

of increased warmth and dryness, which would influence plant distribution. 

The selection of any of the action alternatives may affect individuals, but is not likely to result in 

a trend toward federal listing or loss of viability for northern leopard frog. 

Northern Goshawk

There are 14 known post-fledging family areas (PFAs) wholly or partially within the project area. 

There are 40 PFAs on the Forest. Approximately 2,400 acres of post-fledging family area habitat 

and nearly 40,500 acres of forage habitat occur within the project area. The post-fledging habitat 

would be managed towards 40 percent large tree structure for old growth.

Project related activities may impact species through disturbance during the breeding season in 

the short term, but would benefit the species in the long term. It is difficult to quantify the number 

of individual goshawks that would be disturbed by project activities because individuals that are 

not paired for breeding are difficult to find. Northern goshawks are sensitive to noise disturbance 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 217

near nest sites during breeding season, but a study on the effects of logging truck noise on nesting 

goshawks, done in northern Arizona, found no negative effects on these birds (Grubb et al. 2012). 

Mechanical treatments would improve habitat by increasing herbaceous plant growth and 

providing the clumpy forest structure that provides nesting and foraging habitat. Prescribed fire 

would decrease in plant cover in the short term while promoting a mosaic of small patches of 

forests and openings and increase plant species diversity. These conditions would improve habitat 

conditions for some of the small mammals and bird species that make up the prey base for the 

goshawk. 

Short-term adverse effects on northern goshawk may occur from prescribed fire, including noise 

from human activity, a short-term decrease in plant cover, and a reduction in forage plants or 

seeds for prey species. Goshawks have been observed hunting along the edge of a burn for small 

birds or mammals moving away from the smoke. Plant species richness and community structure 

would likely increase after mechanical treatments and prescribed fire. Some short-term loss of 

foraging habitat could occur based on the shift of plant species distribution. Prescribed fire would 

create snags and increase snag retention; however, it may not create potential nest trees due to 

existing stand age and structure. 

Based on the recent fires, northern goshawk habitat under alternative 2 is likely not sustainable 

over the long term, except where existing treatments have been conducted or are planned to 

minimize uncharacteristically severe wildfire. 

Alternative 3 would likely result in fewer short-term effects because less area would be treated 

mechanically, resulting in less disturbance. Alternative 3 would not allow any temporary roads, 

and fewer acres would be mechanically treated. Effects are similar to alternative 1. 

Alternative 4 would likely provide fewer long-term benefits because less prescribed fire is used. 

This may have negative impacts on the prey base. Mechanical treatment of the slash to reduce the 

fuel hazards would increase the intensity and duration of disturbance compared to alternatives 1 

and 5. The effects resulting from chipping or masticating slash may reduce forage availability for 

prey species. The intensity and duration of the activities would be less than using both mechanical 

treatments and prescribed fire in the same footprint under alternative 4 as compared to 

alternatives 1 and 5. 

The selection of any of the action alternatives may affect individuals, but is not likely to result in 

a trend toward federal listing or loss of viability for northern goshawk. 

American Peregrine Falcon

There are ten designated suitable breeding habitat zones completely within the project area and 

two that are partially within the project area. There are 174 falcon sites in the state of New 

Mexico; about 6 percent of the total sites in the State would be affected by project activities. 

The effects of project activities are consistent with those described in the effects section at the 

beginning of the sensitive species section. A proposed site-specific forest plan amendment would 

permit restoration activities during the breeding season near falcon eyries. The proposed 

amendment would not change management direction on the rest of the forest. 

Prescribed fire would be used to treat fuels and reduce the risk of severe wildfire throughout the 

project area, including falcon habitat. Suitable nesting habitat is usually located in steep and 

rocky terrain without much fuel. Reducing fuel loads by use of prescribed fire would likely 
Chapter 3. Affected Environment and Environmental Consequences

218 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

minimize disturbance from wildfire suppression activities in falcon habitat and minimize 

mortality and loss of habitat during wildfires.

Road maintenance is not likely to cause disturbance of more than a day. The construction of 

temporary roads and road reconstruction may cause disturbance of a few days to a week or more. 

This can be minimized by scheduling road construction and reconstruction activities after May 

15. 

Effects from mechanical treatments may result in changes to foraging habitat due to vegetation 

removal, disturbance to prey, or displacement or avoidance from mechanical treatments and 

increased human interactions. Noise impacts on wildlife would likely result in changes in habitat 

use, increased stress response, decreased immune response, and reduced reproductive success 

(Blumstein et al. 2003, Brumm 2004, Delaney et al. 1999, Gaines et al. 2003). Under certain 

circumstances, however, some species may become habituated to human disturbance and noise, 

especially where hunting pressure is reduced (Singer and Doherty 1985). 

The proposed action would enhance habitat for prey for the peregrine falcon in the long term and 

may disturb individuals in the short term. Selecting any of the action alternatives may disturb 

individuals in the short term, but would provide for long term sustainability of falcon and its prey 

habitat as the landscape becomes more fire resilient. Selection of alternative 1 may affect 

individuals, but is not likely to result in a trend toward federal listing or loss of viability for the 

American peregrine falcon.

Boreal Owl

The boreal owl is resident in very small numbers in spruce-fir habitat in the Jemez Mountains. 

Since 1996, no boreal owls have been observed south of the Valles Caldera. There are about 600 

acres of boreal owl habitat in the project area, and approximately 193,600 acres of potential 

habitat on the forest. Due to a low number of observations, it is uncertain how much potential 

habitat is currently occupied. 

Few project activities would take place in boreal owl habitat, which is found in high elevation 

spruce-fir and wet mixed conifer forests. These areas are not proposed for mechanical treatments. 

Prescribed fire is not excluded from these forest types, but these are not fire-adapted forests, and 

prescribed fire is not likely to be used. 

Project related activities including mechanical treatments, prescribed fire, road treatments, and 

cultural site protection may impact this species through disturbance during the breeding season in 

the short term, and benefit the species in the long term. 

Alternative 2 has the least amount of effects on the species and its habitat because there are fewer 

treatments than under any of the action alternatives. Under alternative 3, fewer acres would be 

treated with prescribed fire and, and fewer acres would not receive the benefits of fire.

Selection of the proposed action may affect individuals, but is not likely to result in a trend 

toward federal listing or loss of viability.

Gray Vireo

There are approximately 178,400 acres of potential habitat for gray vireo on the forest and nearly 

24,000 acres of that are in the project area. Due to low numbers of observations of these birds, it 

is uncertain how much potential habitat is currently occupied. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 219

Short-term adverse effects on the gray vireo would occur from treatments using mechanical 

equipment and prescribed fire, temporary road construction, treatments using hand crews, water 

development, and cultural site protection. Prescribed fire treatments would reduce plant cover in 

the short term, but would likely improve habitat quality in the long term by improving fire 

resilience and vegetative diversity. 

Selection of the proposed action may impact individuals, but is not likely to result in a trend 

toward Federal listing or loss of viability for gray vireo.

Cinereus (masked) Shrew

There are about 262,000 acres of potential habitat for Cinereus shrew on the Forest. A total of 

about 2,700 acres of modeled habitat are located in the project area.

The desirable set of riparian vegetation (plant and forb) species vigorous enough to support 

habitat for this species in areas planned for treatment is currently limited or absent. Treatments 

designed to enhance riparian areas, seeps, and springs and the instream work would move shrew 

habitat towards restoration by connecting the stream channel to the floodplain and improving 

riparian vegetation. Down-cut stream channels in the project area are no longer connected to the 

floodplain, which limits water retention and wetland formation that supports riparian vegetation 

along stream banks. In their current condition, streams cannot support habitat for riparian 

dependent species such as shrews. 

Machinery and equipment activities may cause direct mortality (death) of individuals in riparian 

habitat. This impact is expected to be minimal because of the localized nature of the aquatic 

riparian restoration activities. The use of hand crews to reduce ladder fuels or remove 

encroaching conifers would reduce the chance of direct impact on individuals as compared to 

machinery. 

Removal or reduction of tree canopy coverage would allow more sunlight to reach the ground. 

After mechanical treatments, some areas of habitat may experience periods of increased warmth 

and dryness, which would influence plant micro-habitat distribution. 

No mitigation measures were specifically identified for this shrew, but the measures developed to 

protect watersheds and riparian areas (e.g. 100-foot riparian buffer) may benefit the shrew. 

Selection of the proposed action may affect individuals, but is not likely to result in a trend 

toward federal listing or loss of viability for the cinereus shrew.

Water Shrew 

The water shrew has been documented on all ranger districts on the forest. They are widespread, 

but not common, in the Jemez Mountains. Known capture sites on the Jemez District include the 

Fenton Lake area, Rio Cebolla, and San Antonio Creek. There are about 60, 200 acres of potential 

habitat for water shrew on the forest and nearly 3,900 acres in the project area. 

The water shrew is reliant on riparian areas. This habitat type would be the most limited on the 

forest for these species. Treatments designed to enhance riparian areas, seeps, and springs would 

move riparian areas towards a desired functional state for riparian associated species in and near 

stream systems.
Chapter 3. Affected Environment and Environmental Consequences

220 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Machinery and equipment activities may cause direct mortality of the shrews by crushing and 

compaction of soil in riparian areas. The use of hand crews to reduce ladder fuels or remove 

encroaching conifers would reduce the chance of direct impact on individuals as compared to 

machinery. Removal or reduction of tree canopy coverage would allow more sunlight to reach the 

ground. 

The desirable set of riparian vegetation (plant and forb) species vigorous enough to support 

habitat for this species in areas planned for treatment is currently limited or absent. Treatments 

designed to enhance riparian areas, seeps, and springs and the instream work would move shrew 

habitat towards restoration by connecting the stream channel to the floodplain and improving 

riparian vegetation. Down-cut stream channels in the project area are no longer connected to the 

floodplain, which limits water retention and wetland formation that supports riparian vegetation 

along stream banks. In their current condition, streams cannot support habitat for riparian 

dependent species such as shrews. 

Instream and rechannelization work would improve aquatic and riparian habitat. However, this 

work may result in direct mortality of individuals by crushing and compaction of soils by heavy 

machinery. Potential flooding may displace individuals in the immediate site and adjacent to the 

construction site. The greatest amount of sediment inputs would come from a tractor being used 

in or near the stream or crossing the stream. 

Prescribed fire would result in a decrease in plant cover in the short term. Prescribed fire would 

also create patches of small openings that would enhance plant species diversity. Plant species 

community richness or diversity would increase following burning creating small canopy gaps. 

Short-term adverse effects on plant communities would also occur as a result of burning. Some 

level of short-term loss could occur based on the shift of plant species distribution. These shortterm effects should be small in extent and intensity on individual shrews foraging during project 

implementation. Foraging opportunities may be limited in the home range of individuals shortly 

after implementation starts.

Road closure and decommissioning may result in the recovery of plant habitat. Road maintenance 

activities would have no significant effect because they occur in the existing roadway footprint. 

Road maintenance would likely reduce sediment runoff in conjunction with the watershed best 

management practices outlined in appendix A. Control of invasive plants would promote a 

healthier habitat for native plant communities.

Selection of the proposed action may affect individuals, but is not likely to result in a trend 

toward federal listing or loss of viability for the water shrew.

Preble’s Shrew

The amount and type of habitat for Preble’s shrew is the same as that for the water shrew. Preble’s 

shrew has been documented on the Cuba and Jemez Ranger Districts and is suspected to occur on 

the Espanola, Coyote, and Pecos/Las Vegas Ranger Districts.

Machinery and equipment activities may cause direct mortality of the shrews by crushing and 

compaction of soil in riparian areas. The use of hand crews to reduce ladder fuels or remove 

encroaching conifers would reduce the chance of direct impact on individuals as compared to 

machinery. Removal or reduction of tree canopy coverage would allow more sunlight to reach the 

ground. After mechanical treatments, some areas of habitat may experience increased warmth and 

dryness, which would influence plant micro-habitat distribution. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 221

The desirable set of riparian vegetation (plant and forb) species vigorous enough to support 

habitat for this species in areas planned for treatment is currently limited or absent. Treatments 

designed to enhance riparian areas, seeps, and springs and the instream work would move shrew 

habitat towards restoration by connecting the stream channel to the floodplain and improving 

riparian vegetation. Down-cut stream channels in the project area are no longer connected to the 

floodplain, which limits water retention and wetland formation that supports riparian vegetation 

along stream banks. In their current condition, streams cannot support habitat for riparian 

dependent species such as shrews. 

Prescribed fire would result in a decrease in plant cover in the short term. Prescribed fire would 

also create patches of small openings that would enhance plant species diversity. Plant species 

community richness or diversity would increase following burning creating small canopy gaps. 

Short-term adverse effects on plant communities would also occur as a result of prescribed fire. 

Some level of short-term loss could occur based on the shift of plant species distribution. These 

short-term effects should be small in extent and intensity on individual shrews foraging during 

project implementation. Foraging opportunities may be limited in the home range of individuals 

shortly after implementation starts.

Road closure and decommissioning may result in the recovery of plant habitat. Road maintenance 

activities would have no significant effect because they occur in the existing roadway footprint. 

Road maintenance would likely reduce sediment runoff in conjunction with watershed best 

management practices. Control of invasive plants would promote a healthier habitat for native 

plant communities. Preparation of fire control lines is not likely to take place during the monsoon 

period with the potential exception of hand thinning. 

Selection of the proposed action may affect individuals, but is not likely to result in a trend 

toward federal listing or loss of viability for Preble’s shrew.

Spotted Bat

Due to the rarity of the spotted bat, information is lacking about its habitat needs and life history. 

Approximately 77,000 acres of spotted bat habitat were modeled for this analysis. It is uncertain 

how much potential habitat is currently occupied. 

The desirable set of riparian vegetation (plant and forb) species vigorous enough to support 

habitat for this species in areas planned for treatment is currently limited or absent. Treatments 

designed to enhance riparian areas, seeps, and springs and the instream work would move shrew 

habitat towards restoration by connecting the stream channel to the floodplain and improving 

riparian vegetation. Down-cut stream channels in the project area are no longer connected to the 

floodplain, which limits water retention and wetland formation that supports riparian vegetation 

along stream banks. In their current condition, streams cannot support habitat for riparian 

dependent species such as this bat. 

Prescribed fire would result in a short-term decrease in plant cover. Prescribed fire would also 

create patches of small openings that would enhance plant species diversity. Plant species 

community richness or diversity would increase following burning creating small canopy gaps. 

Some level of short-term loss could occur based on the shift of plant species distribution. These 

short-term effects should be small in extent and intensity. 

Road closure and decommissioning may result in the recovery of plant habitat. Road maintenance 

activities would have no significant effect because they occur in the existing roadway footprint, 
Chapter 3. Affected Environment and Environmental Consequences

222 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

and existing roads are not suitable plant habitat. Road maintenance would likely reduce sediment 

runoff in conjunction with watershed best management practices. Control of invasive plants 

would promote a healthier habitat for native plant communities. Preparation of fire control lines is 

not likely to take place during the monsoon period with the potential exception of hand thinning. 

Plant diversity affects the abundance and richness of insect populations. Short-term effects 

resulting from prescribed fire could create a shift of the prey species available for foraging and in 

canopy gaps created by mechanical treatments. Once these communities respond and adjust to the 

treatments, a change or shift of the plant diversity would then enhance forage opportunities for 

spotted bat. 

Selection of the proposed action may affect individuals, but is not likely to result in a trend 

toward federal listing or loss of viability for the spotted bat.

Pale Townsend’s Big-eared Bat

There are about 302,600 acres of potential habitat for the Pale Townsend’s big-eared bat on the 

forest. It is uncertain how much potential habitat is currently occupied. The status of this species 

could change over time as it moves between forage habitat and roosting habitat or through loss or 

creation of habitat. 

Short-term adverse effects on bat would occur as a result of mechanical treatments prescribed 

fire, road treatments, water source development, treatments using hand crews, and cultural site 

protection. Use of prescribed fire would result in a short-term decrease in plant cover. Plant 

species community richness or diversity would increase from the creation of small canopy gaps 

and patches. The patchiness of the forest would improve habitat for the prey base. 

Prescribed fire treatments could cause a loss of large logs resulting in short-term adverse effects 

on foraging habitat due to localized impacts on insect prey species distribution. A short-term loss 

of plant diversity could also cause a shift in plant species distribution. Prescribed fire and hazard 

tree removal actions (fire control line preparation) would reduce large snag distribution. The loss 

of large logs would reduce the amount of insects available for foraging. The shift in snag 

distribution would also reduce roosting habitat in the forest. Forested habitat near cave openings 

could be changed by project activities. 

Selection of the proposed action may affect individuals, but is not likely to result in a trend 

toward federal listing or loss of viability for Pale Townsend’s big-eared bat.

American Marten

There are about 263,900 acres of potential habitat for the American marten on the Forest. About 

2,800 acres of modeled habitat are in the project area. Marten have not been documented in the 

project area, but they are suspected to exist on the Jemez Ranger District. Due to no documented 

observations, it is uncertain how much potential habitat is currently occupied. 

Mechanical treatments would increase herbaceous plant growth in the long term by removing the 

thick layer of dead plant debris on the forest floor. Prescribed fire would result in a decrease in 

plant cover in the short term, but would also improve habitat for the prey base by creating gaps 

and openings in the tree canopy and increasing plant species diversity. Short-term adverse effects 

on marten would occur as a result of prescribed fire, which would likely reduce the high volume 

of fallen trees and woody debris on the forest floor. This loss of large logs could result in short-
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 223

term adverse effects on forage, cover, and breeding activities due to localized impacts on tree 

species distribution. 

Prescribed fire and hazard tree removal actions would also reduce large snag distribution in the 

project area. This may reduce or shift prey species abundance and distribution. Large snags are 

limited or rare across the project area, and snags created by prescribed fire may not be large 

enough to support the recruitment of down logs for marten. Individual martens can dig 

underneath logs for food or underneath highly logs for den sites. Typically, these down logs are 

important for thermal cover or protection from the weather during winter months. Prescribed fire 

may create more snags to provide forage habitat for marten. The recruitment of snags may also 

provide for den site opportunities in the long term.

Tree shade canopy would be reduced following hazard tree removal, mechanical treatments, and 

prescribed fire. Canopy cover in marten habitat is not expected to be reduced below 40 percent in 

groups and clumps across the project area. Reduction in canopy cover may shift or increase prey 

species distribution in these open areas or in areas where canopy cover is reduced.

Some loss of trees of all types and diameter size classes would occur from actions such as 

prescribed fire, and mechanical treatments. The area is expected to maintain a range of tree sizes 

and species needed to maintain habitat across the landscape. Removal of tree size classes may 

occur as part of temporary road construction and road maintenance. The effects created by

changed in tree size class should be small in extent and intensity, occurring near disturbed sites, 

access roads, and other areas that are not typically occupied by martens or that provide 

opportunities for den sites. 

The effect of the project activities on forest carnivores for each alternative is documented in the 

project record. Alternative two had fewest effects on modeled habitat because there are fewer 

projects. The effects of the activities on modeled habitat did not show any significant difference

between alternatives one and two. 

Selection of any of the action alternatives may affect individuals, but is not likely to result in a 

trend toward federal listing or loss of viability for the American marten.

Yellow Lady’s Slipper

There are about 30,600 acres of habitat modeled on the Forest and zero acres of habitat in the 

project area. There are no known populations in the Jemez Mountains. 

The desirable set of riparian vegetation species vigorous enough to support habitat for this species 

in areas planned for treatment is currently limited or absent. Treatments designed to enhance 

riparian areas, seeps, and springs and the instream work would move habitat towards restoration 

by connecting the stream channel to the floodplain and improving riparian vegetation. Down-cut 

stream channels in the project area are no longer connected to the floodplain, which limits water 

retention and wetland formation that supports riparian vegetation along stream banks. In their 

current condition, streams cannot support habitat for riparian dependent species. Treatment 

strategies to enhance riparian areas, seeps and springs, and instream work would move habitat for 

this plant towards restoration. Use of exclosures would also help support habitat for this species.

Prescribed fire would result in direct mortality of the yellow lady’s slipper. This is a short-term 

effect. Plant species community richness or diversity would increase from the creation of small 

canopy gaps and patches of trees. If colonies of this plant exist in aspen stands, short-term 
Chapter 3. Affected Environment and Environmental Consequences

224 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

adverse effects on this species would also occur as a result of prescribed fire. Plant species may 

increase in the environment it grows in following prescribed fire. 

Machinery and equipment activities may cause direct mortality of lady’s slipper plants by 

crushing and compaction of soil in riparian areas. Removal or reduction of tree canopy coverage 

would allow more sunlight to reach the ground. After mechanical treatments, some areas of 

habitat may experience increased warmth and dryness, which would influence plant micro-habitat 

distribution. The response of this plant to project activities could shift or stunt the flowering of 

plants if prescribed fire treatments occurred prior to flowering or during the peak of the growing 

season.

Road closure and decommissioning may result in recovery of plant habitat. Road maintenance 

activities would have no significant effect because they occur in the existing roadway. Road 

maintenance would likely reduce sediment runoff in conjunction with watershed best 

management practices outlined in appendix A. Construction of temporary roads may compact the 

soil and reduce rooting of plants. Control of invasive plants would promote a healthier habitat for 

plant communities.

Selection of any of the alternatives may affect individuals, but is not likely to result in a trend 

toward federal listing or loss of viability for the yellow lady’s slipper.

Wood Lily

There are about 52,200 acres of modeled habitat on the forest and nearly 3,600 acres of habitat in 

the project area. The wood lily has been reported on the Jemez Ranger District, but there have 

been no observations in the project area. 

Mechanical or prescribed fire treatments would increase herbaceous plant growth in the long term 

by removing the thick layer of dead plant debris on the forest floor. Prescribed fire would result in 

short-term adverse effects on plant communities, including a decrease in plant cover. The richness 

and diversity of plant species would increase after burning from the creation of small canopy gaps 

and patches of trees. Short-term loss of the wood lily could occur based on the shift of the 

distribution of plant species. 

Machinery and equipment activities may cause direct mortality of the plants by crushing and 

compaction of soil in riparian areas. Removal or reduction of tree canopy coverage would allow 

more sunlight to reach the ground. After mechanical treatments, some areas of habitat may 

experience increased warmth and dryness, which would influence plant micro-habitat 

distribution. 

Road closure and decommissioning may result in recovery of plant habitat. Road maintenance 

activities would have no significant effect because it occurs in the existing roadway, and roads are 

not suitable plant habitat. Road maintenance would likely reduce sediment runoff in conjunction 

with watershed best management practices Control of invasive plants would promote a healthier 

habitat for plant communities. 

The short-term effects from mechanical treatments should be small in extent and intensity and 

would affect the wood lily only during the flowering season of June and July each year. A seed 

source may be available prior to prescribed fire treatments outside the peak flowering months. If 

burning occurs during June and July, it may disrupt the next flowering season and affect the 

ability of the plants to provide an annual seed source. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 225

Selection of any of the alternatives may affect individuals, but is not likely to result in a trend 

toward Federal listing or loss of viability for the wood lily.

Springer’s Blazing Star

Nearly 14,000 acres of potential habitat are found on the Forest; about 6,400 acres of modeled 

habitat are in the project area. The Springer’s blazing star has not been documented on the Forest 

but is suspected to be on the Jemez and Espanola Ranger Districts. Due to a low number of 

observations, it is uncertain how much potential habitat is currently occupied. 

Over the long term, treatments would promote conditions suitable for increasing herbaceous plant 

growth by removing the thick layer of dead plant debris on the forest floor. Prescribed fire would 

result in short-term adverse effects on plant communities, including a decrease in plant cover. The 

richness and diversity of plant species would increase after burning from the creation of small 

canopy gaps and patches of trees. Short-term loss of the blazing star could occur due to 

mechanical treatments. These should be short term and small in extent and intensity because of 

the type of substrate where the plant is found. 

Road closure and decommissioning may result in recovery of plant habitat. Road maintenance 

activities would have no significant effect because it occurs in the existing roadway, and roads are 

not suitable plant habitat. Road maintenance would likely reduce sediment runoff in conjunction 

with watershed best management practices. Control of invasive plants would promote a healthier 

habitat for plant communities. 

The effect of the project activities on sensitive plant species for each alternative is documented in 

the project record. Alternative 2 had the least amount of effects because there are fewer projects.

Selection of any of the alternatives may affect individuals, but is not likely to result in a trend 

toward Federal listing or loss of viability for Springer’s blazing star. 

Management Indicator Species 

Affected Environment

The forest has eight management indicator species (MIS): Rocky Mountain bighorn sheep, Rocky 

Mountain elk, Mexican spotted owl, Merriam’s turkey, hairy woodpecker, Rio Grande cutthroat 

trout, pinyon jay, and mourning dove (USFS 1987b). 

Seven of the eight management indicator species occur or have habitat in or adjacent to the 

project area; the Rocky Mountain bighorn sheep does not. All streams contain nonnative trout 

species such as rainbow, brown, and brook trout. There are no known genetically pure occupied 

Rio Grande cutthroat trout populations in the project area. 

Table 42 shows the habitat association for each MIS in the project area based on information in 

the EIS for the forest plan (USFS 1987a) and the Management Indicator Species Assessment 

(USFS 2012b). The table also shows the total acres of each habitat association forestwide and 

within the project area and population and habitat trends based on the latest MIS assessment for 

the forest (USFS 2012b). 

The declining habitat trend for pinyon jay is due to the beetle-caused piñon tree mortality in the 

early 2000s. The lack of water, foraging habitat, and vegetative diversity limits habitat for elk, 

Merriam’s turkey, and mourning dove. The lack of openings in the forest canopy also limits elk 
Chapter 3. Affected Environment and Environmental Consequences

226 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

habitat. Some key problems affecting the owl habitat in this area are the lack of large, mature 

trees and small forage openings.

Table 42. Management indicator species, habitat, and population and habitat trends. For most 

species, population and habitat trends are stable or increasing. Habitats for Mexican spotted owl 

and pinyon jay are declining.

Species Habitat 

Association

Forestwide 

Acres or 

Stream Miles 

Project Area 

Acres or 

Stream Miles

Population 

Trend

Forestwide 

Habitat Trend

Rocky 

Mountain Elk

Mid-elevation 

Grasslands, 

Meadows, and 

Forest 

1,287,640 

acres

109,686 acres Increasing Stable

Merriam’s 

Turkey

Mature 

Ponderosa 

Pine Forest

603,23 acres 44,810 acres Stable to 

Increasing

Stable

Mourning Dove Mid and Low 

Elevation 

Grasslands, 

Woodlands, 

and Pine

581,419 acres 56,094 acres Stable Stable to 

Increasing

Hairy 

Woodpecker

Mature Forest 

and Woodland

80,174 acres 7,258 acres Abundant Increasing

Pinyon Jay Piñon-Juniper 

Woodlands

232,204 acres 4,650 acres Stable to 

Downward

Declining

Mexican 

Spotted Owl

Late Seral 

Stage Mixed 

Conifer, 

Coniferous 

Riparian 

630,191 acres 31,590 acres Stable Slightly 

Declining

Rio Grande 

Cutthroat Trout 

Riparian, 

Stream Habitat 

128.7 stream 

miles

11 stream 

miles

Precariously 

Upward 

Stable

Rocky 

Mountain 

Bighorn Sheep

Alpine Meadow 7,810 acres 0 acres Stable Stable

Summary of Effects

There would be no reduction in the number of acres of available habitat for any of the MIS, and 

there is no potential for population decline under all alternatives. 

Effects from project activities are similar under all action alternatives (1, 3, 4, and 5). There 

would be short-term disturbance effects from noise, smoke, and human activity. There would also 

be the long-term benefit of habitat enhancement for all MIS. Differences between the proposed 

action and alternatives 3, 4, and 5 are:

• Under alternative 3, there would be less soil compaction and more vegetation would be 

retained because temporary roads are not built. The amount and intensity of disturbance 

effects from project activities would be lower because fewer acres receive both 

mechanical treatments and prescribed fire. 

• Under alternative 4, there would be fewer effects from smoke because fewer acres are 

treated by prescribed fire. Some temporary disturbance effects on management indicator 

species (MIS) may be magnified under this alternative depending on the method used to 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 227

treat slash and woody debris. Long-term benefits such as nutrient recycling and snag 

creation would not occur. 

• Under alternative 5, there would be a temporary disturbance from the construction of fire 

control lines near core areas. There would be less potential to enhance understory plant 

growth and prey habitat because PACs and target/threshold areas would have a higher 

density of trees. The fire hazard would not be reduced as much as compared to alternative 

1. 

Under alternative 2, habitat conditions would remain the same in the short term, but would 

continue to decline and be less resilient to wildfire over time. This alternative would not decrease 

the potential of an uncharacteristically large wildfire. A wildfire could result in a reduction of 

habitat acres for some MIS species. Short-term effects from noise and other disturbances would 

be less but would continue at a lesser degree than the other action alternatives. Long-term 

benefits, such as habitat improvement, would not occur. The prey base for the Mexican spotted 

owl would not be enhanced.

Environmental Consequences

Alternative 1

There would be no reduction in the number of acres of available habitat for any MIS and no 

potential for population decline. Long-term benefits are expected due to increased forage and 

water and the decreased potential for uncharacteristic wildfire. All proposed activities would have

temporary, short-term effects including noise and visual disturbance (heavy equipment use, 

chainsaws), human activity, and smoke from prescribed fire. Management indicator species may 

temporarily avoid areas where activities are being conducted. 

Mechanical treatments, prescribed fire, and meadow restoration would create openings in the tree 

canopy, enhancing the production of understory forage plants for elk, turkey, and mourning doves 

over a large portion of the project area. Forage plant palatability and nutrient content would be 

expected to improve. With increased forage, competition with livestock for forage would 

decrease. There would be no reduction of the overstory canopy within Mexican spotted owl core 

areas. 

The current abundance of thermal and hiding cover for elk and turkey would be modified. More 

open tree groups resulting from mechanical treatments would reduce cover until understory shrub 

and tree species (e.g. New Mexico locust, Gambel oak) move into the openings. Understory trees 

killed by prescribed fire would gradually fall over in random patterns, so hiding cover would 

remain quite variable across the area until all the understory trees are down. 

Mechanical treatments in piñon-juniper woodlands would reduce the numbers of trees available 

for nesting, forage, and roosting by pinyon jay over about 1,000 acres (about 3% of available 

piñon-juniper in the project area). Piñon-juniper would still be available on these treated sites and 

on the approximately 33,500 acres of piñon-juniper woodlands that would not be treated. 

Reducing tree density in piñon-juniper stands would reduce competition among trees for water 

and increase the vigor of the remaining trees, resulting in more seed production. 

Enhancement of seeps and springs, construction of new artificial water sources (earthen dams, 

trick-tanks) and screening of water sources would increase the availability and distribution of 

water. All land-based MIS would benefit from these treatments. 
Chapter 3. Affected Environment and Environmental Consequences

228 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Road treatments, including opening existing closed roads and building new temporary roads 

would increase disturbance along those roads for all land-based species. Disturbance is expected 

to extend up to about 0.3-mile along both sides of the road during project activity periods (USDA 

2011). Disturbance from recreational activities such as mountain biking and hiking may continue 

after project activities are completed, even if roads are closed. 

Proposed activities would maintain desired habitat components such as large snags, trees, and 

down wood, benefiting turkey and hairy woodpecker, and increasing habitat for the prey base of 

the spotted owl. Mechanical treatments would reduce tree density, but large trees would still be 

present to provide nest sites. The number of snags for the hairy woodpecker would increase, as 

prescribed fire would be expected to create more snags throughout the project area. 

Implementing prescribed fire treatments would reduce fuel loading which would minimize soil 

temperatures and the acreage of high-intensity fire in watersheds and, in turn, protect aquatic 

ecosystems from soil loss and run-off resulting from large wildfires. In addition, prescribed fires 

are not typically set within riparian areas, but are allowed to creep into the area for a low-intensity 

burn. These burns would increase and enhance understory herbaceous vegetation, which in the 

long term, would improve water quality in streams. Some activities, particularly mechanical 

treatments, would increase the amount of run-off and sediment into streams; this is a short-term, 

temporary effect. Best management practices, design features, and mitigation measures would 

minimize runoff from roads and skid trails. 

Some treatments are designed to enhance riparian and stream channel conditions. These would 

increase the amount and diversity of instream habitat and overstory vegetation and would 

improve habitat conditions for Rio Grande cutthroat trout. Turkey would also benefit from 

increased nesting habitat in riparian areas. Instream restoration activities may negatively impact 

some individuals or their habitat in the short term, the results would be beneficial in the long 

term.

Alternative 2 

There would be no reduction in the number of acres of available habitat for any MIS and no 

potential for population decline. Because this alternative would not reduce the potential for 

uncharacteristic wildfire, future wildfires could result in a reduction of habitat acres for some 

MIS species. There would be no benefits of increased forage and water availability and no 

enhancement of riparian quality. 

Habitat conditions, however, would not improve overall due to the continued lack of diversity. 

Large trees, snags, and down logs would continue to be lacking, affecting hairy woodpecker and 

other species that need these components. The abundance and quality of shrubs, seeds, nuts, 

acorns, fruits, berries, and tall young grasses and forbs would all continue to decline and reduce 

habitat quality for all MIS. There would be no treatments in owl habitat to enhance prey numbers 

and distribution. 

This alternative would result in fewer effects on MIS habitat trends because the proposed 

activities would not be implemented. There would be fewer noise or visual disturbances to 

management indicator species. The area would be more vulnerable to, and could increase food 

sources (insects and fungi) for turkeys and other birds, such as insects and fungi. Insect and 

disease outbreaks would also result in premature tree mortality, thus creating more snags for the 

hairy woodpecker. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 229

Alternative 3 

There would be no reduction in the number of acres of available habitat for any MIS and no 

potential for population decline. Long-term benefits are expected because of increased forage and 

water and a decreased potential for uncharacteristic wildfire. 

Soil compaction would be reduced and vegetation for MIS habitat would be maintained on the 

1,900 acres that are not mechanically treated. Disturbance from project activities, such as noise 

and human activity, would be less than under alternative 1. The potential for increased 

recreational use on temporary roads would be eliminated. Prescribed fire would be used on the 

same footprint as alternative 1, with similar effects. The intensity of the disturbance from 

treatments would be less than doing both mechanical treatment and prescribed burning in the 

same footprint. All other project level effects on MIS habitat would be the same as under 

alternative 1. 

Alternative 4 

There would be no reduction in the number of acres of available habitat for any MIS and no 

potential for population decline. Long-term benefits are expected because of increased forage and 

water and a decreased potential for uncharacteristic wildfire.

Under this alternative, prescribed fire would not be used in areas that are mechanically treated. 

The short-term, adverse effects of fire (smoke, soil heating) would not be present 29,900 acres of 

the project area. Long-term benefits of fire such as recycling of nutrients and snag creation would 

not occur. All other proposed treatments and project effects would be the same as alternative 1. 

Alternative 5 

There would be no reduction in the number of acres of available habitat for any MIS and no 

potential for population decline. Long-term benefits are expected because of increased forage and 

water and a decreased potential for uncharacteristic wildfire.

Project level effects on MIS habitat would be the same as Alternative 1 with the following 

exceptions:

Within MSO protected activity centers, no trees over 9-inches diameter would be cut. There 

would be no treatments in the core area (about 100 acres) surrounding the known or best 

estimated nest site. To keep prescribed fire out of core areas, fire control lines would be built and 

we might need to remove more ladder fuels and down woody debris, and small trees and shrubs 

along the fire control lines. This would create a temporary disturbance and have a short-term 

impact on understory vegetation over a small area. Effects would be negligible on MIS. 

Target/threshold habitat for the owl would be maintained at a higher tree density. This would 

result in reduced openings or gaps in the tree canopy in PACs and target/threshold acres as 

compared to alternatives 1, 3 and 4. These less intense mechanical treatments could result in a 

slightly higher risk of fire hazard within the PACs as compared to the other alternatives. Because 

of the denser tree canopy, there would be less potential to enhance understory vegetation, and 

prey habitat would not improve as much as compared to the other alternatives. 

Lighter mechanical treatments in PACs, core areas, and target/threshold habitat would reduce the 

potential for improvements in forage for elk, turkey, and mourning dove within these owl habitat 

types as compared to other alternatives. This reduction is negligible when compared to overall 
Chapter 3. Affected Environment and Environmental Consequences

230 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

number of acres in the project area that would have improved forage conditions. Detailed 

information on the type and amount of acres treated in owl habitat is the biological assessment. 

Forest Plan Amendments

The forest plan amendments related to vegetation treatments in PACs would result in lower tree 

densities with more canopy gaps, more large trees in the long term, and increased understory 

vegetation and prey habitat resulting in enhanced habitat for most MIS, including elk, turkey, 

MSO, hairy woodpecker, and mourning dove. The greatest benefit would be the reduction in the 

risk of severe wildfire that could cause widespread loss of forested habitat across the project area, 

especially in areas such as Virgin Canyon. A wildfire in that area could burn through three 

adjoining PACs. 

The effects from the forest plan amendment allowing treatments to occur during wildlife breeding 

seasons and in peregrine falcon zones would remove the protection that some MIS nesting birds 

(turkey, mourning dove, and woodpecker) would have been afforded in these areas. This could 

result in increased unintentional take of nesting MIS birds. 

The effects of the forest plan amendment clarifying the language about interspaces would be 

beneficial to turkey, mourning dove, and elk by creating additional canopy opening, increasing 

ground vegetation, food sources (seeds and insects), and shrubs for food, cover and nesting. 

These treatments would be done in conjunction with other vegetation treatments, and so there 

would be no appreciable increase in direct disturbance effects. Long term, the treatments would 

result in more large trees across the landscape, which would enhance habitat for the hairy 

woodpecker. 

The effects of the forest plan amendment regarding scenery would allow more vegetation 

treatments to occur in those areas. The resulting changes in vegetation in those areas would have 

negligible effects on MIS habitat. 

Cumulative Effects

No significant adverse cumulative impacts on population or habitat trends are expected to result 

from the proposed action or other alternatives in combination with other projects or activities. 

Potential activities include foreseeable future forest activities on forest lands (appendix B). These 

activities would add to the effects on MIS predicted to result from the proposed action and other 

action alternatives. Management indicator species population and habitat trends would not be 

altered by direct, indirect or cumulative effects of the proposed action. 

The primary cumulative effects would be the reduced probability of a large, uncharacteristically 

severe wildfire and the return of periodic low- to moderate-intensity surface fires that improve 

habitat for species that evolved in these fire-adapted forests. Foreseeable future forest restoration 

activities in the Valles Caldera Preserve and adjacent areas of the Jemez Mountains would likely 

alter the current trend of increasingly large and severe wildfires. 

Future mechanical treatments, riparian, in stream habitat, stand improvement thinning, and 

prescribed fire activities would magnify the improvements to sensitive species habitat expected 

from the proposed actions. These treatments may also expand these benefits to the broader 

landscape. 

Temporary cumulative effects could result in areas where treatments covered by this FEIS overlap 

with each other or with activities such as pumice mining. Increased noise and visual disturbance 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 231

could result from increased vehicle activity on roads and project activities. These temporary 

effects would not be expected to impact overall populations or habitat trends. 

Migratory Birds 

Affected Environment

Migratory birds and their habitats are protected under the Federal Migratory Bird Treaty Act of 

1918. This section addresses requirements in Migratory Bird Treaty Act Executive Order 13186. 

Habitat conditions for migratory birds have been altered from historical conditions and are 

degraded, mainly due to long-term fire exclusion. Frequent surface fires once maintained healthy 

and diverse fire-adapted ecosystems, and migratory birds using this area evolved under frequent 

surface fire regimes. Many of the birds need surface plant cover underneath the conifer trees or as 

edge habitat in openings next to clumps of trees. The quality of migratory bird habitat in the area 

is limited because there are not enough grasses, forbs, and shrubs. Thinning dense pine stands, 

leaving snags and some older trees, and restoring historical fire regimes would improve habitat 

conditions significantly (NMPIF 2007). 

Another limiting factor is water. Water sources are scarce in the project area and limited to 

streams and springs that have experienced lower flows during the drought. Some springs have 

stopped flowing altogether. Riparian areas have become dewatered due to stream downcutting 

and are experiencing encroachment from conifers, in part, due to a lack of fire and loss of wetland 

habitat. 

Methods

This evaluation addresses general effects on migratory birds and effects on Highest Priority 

species for the main habitat types found in the project area (NMPIF 2013). 

The Forest Service currently analyzes effects on migratory birds in the following manner: 

• Effects on Highest Priority species listed by New Mexico Avian Conservation Partners 

• Effects on Important Bird Areas (IBAs) 

• Effects on Important Overwintering Areas (IOAs)

The National Partners in Flight list was used for the species selected from New Mexico list of 

priority species. All highest priority species were reviewed for vegetation types found in the 

project area. The analysis also used Audubon New Mexico’s designated IBAs and IOAs for 

migratory birds (ANM 2013). The Valles Caldera IBA is within one mile of the project area, and 

it would not be affected by the proposed actions. No other IBA would be affected by project 

activities, and no IOAs are documented within a mile of the project area.

Summary of Effects

Unintentional take of some individual birds may occur under alternatives 1, 3, 4, and 5, but no 

long-term impacts on bird populations are expected. Bird communities may shift at specific sites 

where habitat modifications occur; for example, meadow restoration may increase populations of 

open grassland bird species, and riparian enhancement may increase riparian species. Restoration 

projects are anticipated to benefit birds in many areas by reducing the thickets of small trees, 
Chapter 3. Affected Environment and Environmental Consequences

232 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

which would result in future growth of shrubs, forbs, and grasses. This in turn would increase 

food sources (seeds, berries, insects) and cover. 

Because alternative 2 will not implement projects that could result in the reduction of risk of large 

wildfires, there could be long-term impacts to bird populations because of widespread loss of 

forest stands in the event of a large wildfire. 

Environmental Consequences 

Alternative 1

All proposed activities would have effects on migratory birds from noise and visual disturbance, 

human activity, and smoke. Most of these effects would be short-term, and it is likely that adult 

birds would avoid these disturbances while activities are taking place. However, there could be 

unintentional take (mortality) of some individuals, especially ground-dwelling species or nesting 

birds if activities take place during the breeding season. The measures listed in appendix A would 

minimize impacts. Long-term benefits are expected because of the decreased potential for 

uncharacteristic wildfire and the associated reduction of risk of habitat loss. 

Mechanical treatments, prescribed fire, and meadow restoration would create canopy openings, 

resulting in increased ground cover, shrubs, and increased distribution of aspen. There would be 

no reduction of overstory canopy in Mexican spotted owl core areas. Birds would benefit from an 

increase in types of food (berries, seeds, insects), nesting sites, and cover over a large portion of 

the project area. The prey base for owls and hawks should increase with enhancement of habitat. 

Birds would also benefit from increased availability and distribution of water resulting from the 

enhancement of seeps and streams, construction of new artificial water sources (earthen dams and 

trick-tanks), and screening of water sources from human disturbance. The riparian enhancement 

projects would increase nesting and foraging habitat along streams and rivers for riparian species. 

Vegetation treatments in piñon-juniper woodlands would reduce tree density, and there would be 

fewer trees available for nesting, food, and roosting on about 1,000 acres. About 33,500 acres of 

piñon-juniper woodlands in the project area would not be treated and would be available for bird 

use. Treatments of piñon-juniper stands would reduce competition among trees for water and 

increase the vigor of remaining trees. 

There would be no impacts on cliff or cave dwelling birds other than temporary effects of smoke 

from prescribed burns, or some possible noise disturbance depending on distance from project 

activities. There would be few impacts on birds living in spruce-fir habitat because there are few, 

if any project activities in that cover type. Smoke from prescribed fire could have short-term, 

temporary effects.

Opening existing closed roads or building new temporary roads would increase disturbance along 

those roads, and could disrupt some nesting behavior. Disturbance is expected to extend up to 

about 0.3 mile from either side of roads during the project period (USDA 2011). After activities 

are completed and roads are closed, there could be increased disturbance because of recreational 

use or unauthorized off-road vehicle use. 

Alternative 2 

This alternative would have fewer effects on birds because many of the proposed treatments 

would not be implemented. The activities listed in appendix B would have fewer noise or visual 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 233

disturbance effects on birds. Food sources, particularly insects, for woodpeckers, flycatchers and 

other birds would increase due to insect or disease outbreaks. Premature tree mortality resulting 

from dense stand conditions or insect and disease, would increase snags for cavity nesters.

Habitat conditions, however, would not improve across the area due to the continued lack of 

diversity. Large trees, snags and large down logs would continue to be lacking. The abundance 

and quality of shrubs, seeds, nuts, acorns, berries, and tall young grasses and forbs would 

continue to decline and habitat quality would be reduced. The potential for increases in prey 

numbers and distribution for raptors would also be reduced. 

This alternative would not implement projects that could reduce the risk of large, severe wildfires. 

Stand-replacing wildfires could result in the long-term loss of habitat acres for some species or 

habitat conversion that influences migratory bird communities. 

Alternative 3 

Disturbance from project activities and equipment use would be less than under alternative 1 

because fewer acres would be mechanically treated and temporary roads would not be built. The 

potential for increased recreation use on decommissioned temporary roads would be eliminated. 

Those acres not treated mechanically would be treated only with prescribed fire. The intensity of 

the activities would be less than doing both mechanical treatments and prescribed fire in the same 

footprint. The area that is not mechanically treated (1,900 acres) is not large in comparison to the 

total number of acres mechanically treated under alternative 1. All other project level effects on 

migratory birds would remain the same as alternative 1. 

Alternative 4 

Prescribed fire would not be used in areas that are mechanically treated. Chipping, mastication or 

other methods would be used to treat slash. The short-term adverse effects of prescribed fire 

(smoke, soil heating) would not occur in mechanically treated areas. Long-term benefits such as 

nutrient recycling and snag creation would not occur in areas not treated with fire. All other 

project level effects to birds would remain the same as described for alternative 1. 

Alternative 5 

Project level effects on migratory bird habitat would be the same as described for alternative 1, 

except as described below. 

Within Mexican spotted owl PACs, trees over 9-inches diameter would not be cut, and no 

activities would occur in the core areas of PACs. There would be temporary disturbance from 

construction of fire control lines around core areas and the removal of ladder fuels, shrubs, and 

woody debris to keep fire out of core areas. This would have a temporary impact on understory 

vegetation over a small area with negligible effect to migratory birds. Mexican spotted owl 

target/threshold habitat would be maintained at a higher tree density level. This would result in 

fewer openings in the overstory canopy in PACs and target/threshold habitat as compared to 

alternatives 1, 3 and 4. The fire hazard would also be slightly higher as compared to the other 

action alternatives. Because of the denser canopy cover, the abundance and diversity of 

understory shrubs, grasses, forbs would be lower, resulting in lower quality prey habitat for 

hawks and owls. Lighter treatments would also reduce the potential for improvements to cover 

and other foods sources (seeds, insects) in PACs and target-threshold habitat. This reduction is 
Chapter 3. Affected Environment and Environmental Consequences

234 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

negligible when compared to the total number of acres that would have increased understory 

vegetation in the project area.

Forest Plan Amendments

The effects of the proposed forest plan amendments to allow treatments in goshawk PFAs and

peregrine falcon and turkey nesting habitats during the breeding season would remove the 

protection that migratory birds would have been afforded within these acres, which could result in 

increased unintentional take of some migratory birds. 

The effects of the proposed forest plan amendment clarifying the language for interspaces would 

be beneficial to migratory birds by creating additional canopy openings, increasing ground 

vegetation for seeds and insects, and shrubs for cover and nesting. Treatments would be done in 

conjunction with other vegetation management activities in same areas, and there would be no 

appreciable increase in direct disturbance effects. Over the long term, the treatments would result 

in more large trees across the landscape and that would enhance nesting and foraging habitat. 

The effects of the forest plan amendments regarding scenery would allow some management 

activities to take place. The resulting changes to forest vegetation in those areas would have 

negligible effects on migratory bird habitat, but there would be temporary disturbance effects and 

the potential for unintentional take of some individual birds.

Cumulative Effects

Foreseeable future restoration projects in the Jemez Mountains in combination with restoration 

activities on adjacent forested land would add to the beneficial effects for migratory birds 

predicted to result from the project activities. Project activities under all action alternatives (1, 3, 

4, and 5) would be spread across the project area, occurring in different locations at different 

times with no resulting permanent cumulative effects on migratory birds. 

Foreseeable future forest restoration projects in the Southwest Jemez Mountains are expected to 

alter the current trend of increasingly large and severe wildfires. Future projects including 

mechanical treatments, riparian, and instream habitat improvement, and prescribed fire would 

magnify the improvements to habitat expected from the proposed actions and expand those 

benefits in a broader landscape. Habitat conditions would become increasingly more structurally 

complex and biologically diverse, with abundant herbaceous plants in scattered openings and 

greater dominance by large, fire-adapted trees. Improvements in nesting, roosting, prey base, and 

foraging habitat would be better distributed across the landscape. 

The primary cumulative effects would be the reduced probability of a large, severe crown fire and 

the return of periodic low to moderate-intensity surface fires that improve habitat for species that 

evolved in these fire-adapted forests. There could be some temporary cumulative effects in areas 

where proposed landscape restoration projects occur in conjunction with other forest projects or 

activities, such as pumice mining. There could be a temporary increase in vehicle activity on 

roads resulting in increased noise and visual disturbance. These are short-term temporary effects 

and would not be expected to impact overall populations or habitat trends. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 235

Bald and Golden Eagle Protection Act

Affected Environment 

The Bald and Golden Eagle Act (Eagle Act), passed in 1940, prohibits the take, possession, sale, 

purchase, barter, offer to sell, purchase, or barter, transport, export, or import, of any bald or 

golden eagle, alive or dead, including any part, nest, or egg, unless allowed by permit (16 U.S.C 

668(a); 50 CFR Part 22)). All golden and bald eagles are protected under the Eagle Act. 

Environmental Consequences 

All Alternatives

This analysis must determine if take is likely to occur with implementation of the action 

alternatives. Effects on bald and golden eagles from each of the alternatives would be the same as 

the effects previously described for the threatened, sensitive, and MIS bird species. Alternative 2 

would have little to no effect because the proposed activities would only be implemented in the 

Paliza area. 

No unintentional take would occur from project activities because eagles are not currently 

roosting or nesting in the project area. The action alternatives would likely increase foraging 

habitat and habitat complexity without reducing the mature tree component. Short-term effects 

are anticipated to be minimal because sufficient habitat exists on neighboring forest and Valles 

Caldera National Preserve lands. 

Short-term Uses and Long-term Productivity 

NEPA requires consideration of “the relationship between short-term uses of man’s environment 

and the maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared 

by 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 

(NEPA Section 101). 

Implementation of any of the action alternatives does not jeopardize the long-term productivity of 

the Santa Fe National Forest. As described throughout chapter 3, implementing any of the action 

alternatives would improve soil condition, watershed condition, forest sustainability, herbaceous 

plant growth, and other conditions favorable to productivity. 

Unavoidable Adverse Impacts 

Given the mitigation measures included with the action alternatives, implementing any of the 

action alternatives would result in no long-term adverse impacts to resources in the project area. 

Short-term adverse impacts that cannot be avoided are:

• Sedimentation to streams, which is predicted to be minimal but unavoidable. 

• Adverse impacts to air quality from prescribed burning, which are also expected to be 

short term and localized. 
Chapter 3. Affected Environment and Environmental Consequences

236 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

• Adverse effects to Mexican spotted owls are also projected but will be minimized to the 

extent possible. Habitat conditions following treatments will enhance the protection of 

the owl in the long term. 

• Adverse effects are also possible to the Jemez Mountain Salamander. These impacts will 

be minimized to the extent possible but conditions following treatments will enhance the 

protection of the salamander in the long term. 

• Short-term adverse effects to the visual quality of the Jemez National Recreation Area 

and the East Fork Wild and Scenic River are also expected. These effects are unavoidable 

but post-treatment conditions will enhance scenic integrity and stability in the long term

• Short-term adverse impacts to recreation use would occur because of mechanical 

treatments, but these would be of limited duration. Design features would limit conflicts 

by avoiding mechanical treatments on weekend days during the heaviest recreation 

season. 

• Adverse effects on grazing permittees are expected. Authorized grazing numbers would 

be reduced to allow vegetation to recover after prescribed burns. 

Irreversible and Irretrievable Commitments of Resources 

An irreversible commitment of a resource is one that cannot be regained, such as the extinction of 

a species. An irretrievable commitment is one where the value of the resource is lost for a period 

of time, such as the loss of soil productivity. Based on analysis found in chapter 3 of this 

document, none of the action alternatives would make any irreversible and irretrievable 

commitments of resources. Soil and watershed conditions would be improved. Wildlife habitat 

would be improved for the Mexican spotted owl and species such as the goshawk that prefer open 

forests. Visual quality would become more diverse. 

A likely result of the no action—alternative 2—is an uncharacteristically severe wildfire. The 

effects of such a fire as described in chapter 3 would result in long-term changes to the landscape 

that would be both irreversible and irretrievable. 

Compatibility with Local Plans, Policies, and Controls

As part of the collaborative effort during the development of the landscape strategy (USFS and 

VCNP 2010), the Forest engaged over 15 government entities including local, state, federal, and 

tribal governments. Several federal agencies and tribal governments sent letters supporting the 

landscape strategy. Community, county, and tribal governments were contacted during the 

development of the EIS and were invited to meetings, field trips, and other events. Conflicts with 

other land use plans, policies, and controls were not raised by other federal, tribal, state, county or 

local governments during scoping, the DEIS comment period, meetings, or other comment 

opportunities. Some agencies requested clarifications or corrections to the DEIS; please refer to 

appendix C for our responses. 

During the scoping period and comment period for the DEIS, we received no comments 

regarding potential conflicts with the plans, policies and controls of regional, State, and local 

government entities. Some agencies requested clarifications or corrections to the DEIS; please 

refer to appendix C for our responses. Sandoval County sent a letter supporting the project, noting 

that the County’s business strategy includes Southwest Jemez as one of its economic development 

initiatives.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 237

Project vegetation treatments are in alignment with the collaboratively developed Community 

Wildfire Protection Plan for Sandoval County (Sandoval County 2008) regarding reducing the 

risk of high-severity fire and protecting community watersheds. The State Historic Preservation 

Office (SHPO) and Pueblo of Jemez representatives expressed strong support related to 

implementing fuels and erosion reduction treatments on archaeological sites. The New Mexico 

Environment Department agreed that project activities would achieve benefits to water resources 

and water quality in the area (appendix F, letter # 11). 

Other Required Disclosures 

NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft 

environmental impact statements concurrently with and integrated with other environmental 

review laws and executive orders.” This environmental impact statement has been prepared in 

accordance with the National Historic Preservation Act, which governs ground disturbance in 

historical places, and the Endangered Species Act, which covers projects that have threatened or 

endangered species in its boundaries. Other legal and regulatory findings are found in appendix F.

In accordance with the legal requirements set forth under Section 7 of the Endangered Species 

Act ([ESA] 16 U.S.C. 1536 (c)), formal consultation was conducted with FWS and a biological 

opinion was received in July 2015. Continue coordination with the U.S. Fish and Wildlife Service 

throughout project implementation as treatments are completed and effects monitored. 

Concurrence from New Mexico State Historic Preservation Office (NM SHPO) was received in 

accordance with Section 106 of the National Historic Preservation Act. This covers all Phase One 

activities. Per the Programmatic Agreement with NM SHPO, there will be continued coordination 

and clearances conducted for each action proposed during implementation.

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 239

Chapter 4. Consultation and Coordination

Preparers and Contributors 

Following is a list of the key interdisciplinary team of specialists who substantially contributed to 

the preparation of this Final Environmental Impact Statement.” There were many other specialists 

who provided valuable assistance in preparation of this document, as reviewers, consultants and 

administrative support staff.

Name Position Contribution Education Years of 

Relevant 

Experience

Amy, William Wildlife Program 

Manager 

Wildlife B.S. Natural 

Resource Sciences

16

Armstrong, Bill Fuels Specialist Fuels B.S. Forestry

B.S. Fire Ecology

40

Bremer, Mike Forest Heritage 

Program Manager 

Heritage and Cultural 

Resources 

B.A. Anthropology

M.A. Anthropology

36

Bueno, Anita Landscape Architect Scenery MLA Landscape 

Architecture 

9 

Carabajal, Abie Fire Ecologist Fuels B.S. Biology 11

Cohn, Patricia Writer-Editor Writing and Editing, 

Social Science,

Environmental 

Justice, Climate 

Change 

B.S. Forestry

M.S. Natural 

Resource Sciences

12

Constan, Connie Assistant 

Archaeologist

Cultural Resources B.A. Anthropology, 

M.A. Anthropology

Ph.D Anthropology

11

Cook, Chantel Forest Fish Biologist Fisheries and Aquatic B.A. Biology

M.S. Fisheries

23

Cramer, Jennifer Forest Planner Forest plan 

amendments

B.A. Biology, Ph.D. 

Plant Biology

5 

Carril, Dennis Forest Ecologist Fuels B.S. Forestry 13

Dobb, Jennifer Economist Economic Analysis B.S. Economics 

M.S. Agricultural, 

Environmental, and 

Resources 

Economics

2 

Downing, Tim GIS Specialist Geographic 

Information Systems, 

Databases, and 

Mapping

B.S. Environmental 

Science

3 

Dyer, Jennifer Archaeologist Cultural Resources B.A. Anthropology

M.A. Anthropology

Ph.D. Anthropology

17

Dykstra, Elizabeth NEPA Specialist NEPA process and 

compliance

B.S. Natural 

Resource 

Management

M.S. Natural 

Resource Planning

24

Gallegos, Alicia Range Specialist Rangeland 

Resources, 

B.S. Range Science

B.S. Wildlife Science

11
Chapter 4. Consultation and Coordination

240 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Name Position Contribution Education Years of 

Relevant 

Experience

NonNative and 

Invasive Plant 

Species

Hall, Joshua State Air and Water 

Quality Liaison 

Air Quality M.S. Environmental

Science

M.A. Environmental 

Policy and Natural 

Resource 

Management

8 

Harrelson, Lee Forest Engineer Roads and 

Engineering

B.S. Civil 

Engineering

30

Harrelson, Sue Silviculturist Vegetation B.S. Biology

M.S. Forestry

22

Harris, Jeff Recreation Staff Recreation B.S. Forestry

M.S. Natural 

Resources and 

Environmental 

Planning

25

Holliday, Kiernan Civil Engineer Roads B.S. Civil 

Engineering

J.D.

32

Kelardy, Shannon Natural Resource 

Specialist

Assistant Team 

Leader

B.A. J.D. Political 

Science

2 

Lawrence, David Forestry Program 

Manager, 

Silviculturist

Vegetation B.S. Forest 

Resource 

Management

15

Luetzelschwab, 

Julie 

Forest Resource 

Information 

Coordinator 

Geographic 

Information Systems, 

Databases, and 

Mapping 

B.A. Resource and 

Environmental 

Geography

M.A. Geosciences

18

Napp, Chris Forester Team Leader B.S. Forest Science 30

Orr, Mary Wildlife Biologist Wildlife, Fish, Rare 

Plants

B.S. Wildlife Biology 34

Sanchez, Raul Wildlife Biologist Wildlife, Fish, Rare 

Plants

B.S. Fish and 

Wildlife Science

16

Schantz, Rob Silviculturist Vegetation B.S. Forest 

Management

M.F. Silviculture

25

Snyder, Jim Hydrologist Soil and Water 

Resources

B.S. Geology 29

Wargo, Jo Wildlife Biologist Wildlife B.S. Biology

M.S. Wildlife Biology

24

Federal, State, and Local Agencies Consulted: 

U.S. Fish and Wildlife Service 

New Mexico State Historic Preservation Office 
Chapter 4. Consultation and Coordination

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 241

Tribes

The following tribal governments, representatives, and allied government organizations were 

consulted with and include: 

Governor, Pueblo of Cochiti

Governor, Pueblo of Jemez

President, Jicarilla Apache Nation

Tribal Historic Preservation Officer, Jicarilla Apache Nation

President, Mescalero Apache Nation

Governor, Pueblo of Nambe

Governor, Pueblo of Picuris

Governor, Pueblo of Pojoaque

Governor, Pueblo of San Felipe

Governor, Pueblo of San Ildefonso

Cultural Resources Officer, Pueblo of San Ildefonso

Governor, Ohkay Owingeh

Governor, Pueblo of Santa Clara

Governor, Kewa Pueblo

Governor, Pueblo of Taos

Governor, Pueblo of Tesuque

Cultural Resources Director, The Hopi Tribe

Governor, Pueblo of Zia

Governor, Pueblo of Zuni

Chairman, The Hopi Tribe

Chairman, Apache Indian Tribe of Oklahoma

Chairman, Comanche Nation

Chairman, Kiowa Tribe of Oklahoma

Chairman, Cheyenne-Arapaho Tribes of Oklahoma

President, Wichita and Affiliated Tribes
Chapter 4. Consultation and Coordination

242 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Chairman, Fort Sill Chiricahua-Warm Springs Apache Tribe

Chairman, Southern Ute Tribe

Chairman, Ute Mountain Ute Tribe

President, The Navajo Nation

Tribal Historic Preservation Officer, The Navajo Nation

Executive Director, Eight Northern Indian Pueblo Council

Executive Director, Five Sandoval Indian Pueblos

Chairman, All Indian Pueblo Council

Speaker Pro Tem, Navajo Nation Council

Tribal Historic Preservation Officer, Pueblo of Zuni

Tribal Historic Preservation Officer, Mescalero Apache Tribe

List of Agencies, Organizations, and Persons to Whom 

Copies of the FEIS Were Sent

Federal

Advisory Council on Historic Preservation, Director, Planning and Review, Washington, DC

Animal and Plant Health Inspection Service, Policy and Program 

Development/Environmental Analysis and Documentation, Riverdale, MD

Natural Resources Conservation Service, National Environmental Coordinator, Washington, 

DC

National Agricultural Library, Acquisitions and Serials Branch, Beltsville, MD

National Oceanic and Atmospheric Administration Fisheries Service, Southwest Region, 

Long Beach, CA

U.S. Army Corps of Engineers, San Francisco CA

Chief of Naval Operations and Environmental Readiness Division

U.S. Environmental Protection Agency, Region 6, Dallas, TX

OEPC, Department of Interior, Director, Washington, DC

U.S. Coast Guard, Office of Environmental Management, Washington, DC

Federal Aviation Administration, Southwest Region, Worth, TX

Federal Highways Administration, Division Administrator, Santa Fe, NM
Chapter 4. Consultation and Coordination

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 243

Department of Energy, NEPA Policy and Compliance, Washington, DC

U.S. Department of Interior, Fish and Wildlife Service, Flagstaff, AZ

National Oceanic and Atmospheric Administration, Office of Policy and Strategic Planning, 

Washington, DC

U.S. Geological Survey, Jemez Mountains Field Station, Los Alamos, NM

Los Alamos National Lab, Los Alamos, NM

Bandelier National Monument, Los Alamos, NM

Natural Resource Conservation Service, Cuba, NM

Valles Caldera Trust, Jemez Springs, NM

Bureau of Indian Affairs, Albuquerque, NM

State

New Mexico State Forestry, Santa Fe, NM

New Mexico Environmental Department, Santa Fe, NM

New Mexico Department of Game and Fish, Santa Fe, NM

Fenton Lake State Park, Jemez Springs, NM

New Mexico Air Quality Bureau, Santa Fe, NM

New Mexico House of Representatives, Jeff Hall, Santa Fe, NM

New Mexico State Legislature, Nick Salazar, Santa Fe, NM

Local 

Village of Jemez Springs, Mayor, Jemez Springs, NM

Sandoval County Manager and Commissioners, Bernalillo, NM

Rio Arriba County, Espanola, NM

Individuals

Numerous individuals on the project mailing list will receive notification of the availability of the 

FEIS. The mailing list is in the project record.

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 245

Glossary

Adaptive management: provides an implementation tool that goes beyond the “predict-mitigateimplement” model and incorporates an “implement-monitor-adapt” strategy that provides 

flexibility to account for inaccurate initial assumptions, to adapt to changes in environmental 

conditions or to respond to subsequent monitoring information that indicates that desired 

conditions are not being met (Forest Service 1909.14.1). 

Age class: a distinct aggregation (grouping) of trees originating from a single natural event or 

regeneration activity commonly consisting of trees of similar age. SAF

Aspect: the direction in which a slope faces.

Basal area (BA): the area of a cross-section of a tree, including bark, at breast height. Basal area 

of a forest stand is the sum of the basal areas of all individual trees in the stand, usually given as 

square feet per acre or square meters per hectare. It is a measurement of how much of a site is 

occupied by trees. SAF

Best management practices (BMPs): guidelines or minimum standards for proper application of 

forestry operations, designed primarily to prevent soil erosion and water pollution, and to protect 

certain wildlife habitat values in riparian and wetland areas. 

Biodiversity: the variety, distribution and abundance of living organisms in an ecosystem. 

Maintaining biodiversity is believed to promote stability, sustainability and resilience of 

ecosystems.

Biomass: the wood product obtained (usually) from in-the-forest chipping of all or some portion 

of trees including limbs, tops, and unmerchantable stems, usually for energy production.

Board foot: a unit of unfinished wood 1 inch thick, 12 inches long, and 12 inches wide. A 

traditional unit for measuring and selling solid wood products (e.g., lumber). One board foot 

contains 144 cubic inches of wood.

Bole: the main stem of a tree.

Broadcast burn: a type of prescribed fire where the burn is intentionally lit so that the fire will 

spread across the surface of the landscape, sometimes under residual trees, to meet resource 

objectives.

Browse: woody vegetation that animals use for food.

Brush: usually refers to shrubs and similar low-growing vegetation.

Buffer: an area of specified width where certain activities may not occur. Buffers are usually 

defined around special sensitive resources such as rare plants or archeological sites, or along each 

side of a stream, or near other features to be protected from human disturbance.

Canopy: the more or less continuous cover of leaves and branches in a forest, usually formed by 

the crowns of the dominant and co-dominant trees.

Canopy base height: the vertical distance from the lowest live branch or whorl on a tree to the 

ground. 
Glossary

246 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Canopy cover or closure (percent): the percentage of a given ground area that is covered by the 

vertical projection of the crowns of trees. Also, the amount that tree canopies interlock and cover 

the ground surface with shade.

Closed road: A road placed in storage between intermittent uses. The period of storage must 

exceed 1 year. These roads are not shown on motor vehicle use maps. They are closed to all 

vehicular traffic but may be available and suitable for nonmotorized uses. A closed road is not the 

same as an obliterated or decommissioned road. A closed road may be opened again for use at 

some time in the future. (Southwestern Region Transportation Glossary)

Clump: A tight cluster of two to five trees of similar age and size originating from a common 

rooting zone that typically lean away from each other when mature. A clump is relatively isolated 

from other clumps or trees within a group of trees. A stand-alone clump of trees can function as a 

tree group.

Co-dominant tree: a tree with its crown in the upper level of the canopy of surrounding trees and 

receiving direct sunlight from above and comparatively little sunlight from the sides. See also 

dominant and suppressed.

Community: an assemblage of plant or animal species, dependent on each other, and constituting 

an organized system or population.

Competition: the process in which organisms with similar requirements contend for resources—

light, water, nutrients, and space—that are in limited supply.

Conifer: any tree that produces seeds in cones, with no fruit structure around the seed. Leaves are 

usually needles, scales, or narrow and linear in shape, and evergreen.

Conservation measure: a mitigation measure designed to address effects on wildlife.

Cover (wildlife): the protective element within an animal’s habitat, which provides concealment 

from predators (hiding cover) and shelter from the weather (thermal cover). Cover takes many 

forms, including patches of dense brush, tall grasses, the forest canopy, or other landscape 

features.

Crown: the portion of an individual tree above the main stem, consisting of live branches and 

foliage.

Crown fire (crowning): a fire that burns and moves through the uppermost branches (crowns) of 

trees and spreads from crown to crown. Fire burning in the crowns of trees is an indicator of a 

high intensity wildfire.

Crown spacing: the distance between the uppermost branches of individual mature trees within a 

stand. Crown spacing distance, along with the pattern in which trees are spaced (even vs. 

uneven), are indicators of how easily a crown fire can spread within a stand.

Design features: a list of existing conditions and management actions designed to guide 

implementation of on the ground activities to achieve desired conditions while minimizing 

adverse effects.
Glossary

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 247

Desired condition: a portrayal of the land and resource conditions that are expected to result if 

goals and objectives are fully achieved.

Diameter at breast height (dbh): diameter of the tree bole at 4.5 feet above ground level.

Disturbance: any relatively discrete event in time that disrupts ecosystem, community, or 

population structure and changes resources, substrate availability, or the physical environment, 

such as a wildfire, windstorm, insect or disease attack, or flooding.

Duff: the layer of decomposing organic materials lying below the litter layer of the freshly fallen 

twigs, needles and leaves, and above the mineral soil.

Ecological restoration: The process of assisting the recovery of resilience and adaptive capacity of 

ecosystems that have been degraded, damaged, or destroyed. Restoration focuses on establishing 

the composition, structure, pattern, and ecological processes necessary to make terrestrial and 

aquatic ecosystems sustainable, resilient, and healthy under current and future conditions (USDA 

Forest Service 2008).

Ecosystem: a complex of interacting organisms (plants, animals, fungi, bacteria, etc.) together

with its environment, considered as a unit.

Ecosystem sustainability: the capacity of an ecosystem for long-term maintenance of ecological 

processes and functions, biological diversity, and productivity.

Encroachment: expansion of coniferous forests into meadows or aspen stands due to fire 

exclusion, grazing, climate change or other disturbance or management practice that disrupts 

natural succession processes.

Endangered: in danger of extinction throughout all or a significant portion of its range.

Erosion: the wearing away of the land surface by rain or irrigation water, wind, ice, or other 

natural or anthropogenic agents that abrade, detach and remove geologic parent material or soil 

from one point on the earth's surface and deposit it elsewhere.

Even-aged stand: A stand of trees composed of a single age class in which the range of tree ages 

is usually about 20 percent of rotation age (SAF 2008). 

Escaped fire: a fire that has exceeded or is expected to exceed the prescribed fire prescription.

Exclosure: a fenced area, generally of limited extent, enclosing vegetation and keeping out 

livestock or wildlife.

Felling: the cutting of standing trees.

Fine fuels: fast-drying fuels usually less than 1⁄4 inch in diameter and having a timelag of one hour 

or less. These fuels readily ignite and are rapidly consumed by fire when dry.

Fire-adapted ecosystem: an associated group of plant and animals that have made long term 

genetic changes in response to the presence of fire in their environment.

Fire break: a natural or constructed barrier or discontinuity of fuels used to stop or check fires or 

that provides a control line from which to work in managing a fire.
Glossary

248 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Fire intensity: a term related to the heat energy released during a fire.

Fireline: a linear fire barrier that is scraped or dug to mineral soil that is used to stop or control 

the spread of fires. 

Fire regime: long-term pattern of fire behavior across a given landscape and vegetation 

community. Fire regimes are classified in terms of frequency (average number of years between 

fires) and severity (amount of replacement of the overstory vegetation). 

Fire Regime Condition Class (FRCC): a measure of the degree of departure (gap) between 

existing conditions and reference conditions in relation to fire regimes. 

Fire severity: a term related to the environmental impacts caused by a fire.

Flame length: the height of flames from a wildfire or prescribed fire, above the ground surface.

Forage: Browse and herbage that is available and can provide food for animals or be harvested for 

feeding, or to search for or consume forage. 

Forage: woody or non-woody vegetation such as grasses, forbs and shrubs that are eaten by 

wildlife and/or livestock.

Forb: a plant with a soft rather than woody stem that is not a grass.

Forest cover type: a classification of forest land named after the most dominant tree species.

Fragmentation: the splitting of forest lands into smaller, detached areas as a result of road 

building, farming, suburban development, and other activities.

Fuel: combustible living and dead material including vegetation such as trees, shrubs, grasses, 

snags, down logs, tree needles, and other leaf litter that feeds a fire.

Fuel model: a description of fuels within an area that helps managers describe or simulate how a 

fire might behave, given other factors that can influence fire behavior (weather and topography). 

Fuel Models 1 and 2 describe areas where grasses are the dominant ground fuels. Fuel Model 6 

describes an area dominated by understory and mid-story shrubs and immature trees. Fuel Model 

9 describes a stand where ground fuels are dominated by forest litter (pine needles and leaves).

Gap: small opening created in a forest canopy, generally from windthrow. Gaps may result from 

loss of a single tree, or from a larger group of down trees. Gap formation is an important aspect of 

change and regeneration in many forests.

GIS (Geographic Information Systems): computer system used to store, organize and display 

geographic information spatially, such as roads, streams, soil types, or any other feature that can 

be mapped on the ground.

Ground cover: all herbaceous plants and low growing shrubs in a forest or open area.

Group: A cluster of two or more trees with interlocking or nearly interlocking crown as maturity 

surrounded by an opening. The size of tree groups is variable and depends on the forest 

community and sited conditions. Trees within groups are not uniformly spaced and trees may be 

tightly clumped. 
Glossary

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 249

Habitat: the environment in which a plant or animal lives.

Habitat diversity: the variety of wildlife habitat features and types in a specific area.

Habitat type: A system of site classification using the floristic composition of plant communities 

(understory species as well as trees) as an integrated indicator of those environmental factors that 

affect species reproduction, growth, competition and, therefore, community development.

Harvest: cutting and gathering a tree crop for utilization. In a forest harvest, trees are felled and 

moved to a central location (landing) for final transport by trucks.

Herbaceous vegetation: non-woody plants, for example, grasses, forbs, wildflowers and ferns.

Herbicide: a chemical for killing unwanted plants.

Home range: the area an animal uses to satisfy its normal requirements for food, water, and cover.

Hydrologic Unit Code (HUC): a sequence of letters or numbers that identifies a hydrological 

feature such as a lake, river reach or watershed. Hierarchical classification system that identifies a 

particular hydrologic drainage basin.

Interspaces: the open space between tree groups intended to be managed for grass-forb-shrub 

vegetation during the long term. Interspaces may include scattered single trees.

Invasive plants or noxious weeds: plants that possess one or more of the following attributes: 

aggressive and difficult to manage, poisonous, toxic, parasitic, a carrier of serious insect or 

disease, and may or may not have been part of a native plant community.

Ladder fuels: vegetation fuels that provide vertical continuity, thereby allowing fire to carry from 

surface fuels into the crowns of trees with relative ease. They help initiate and assure crowning.

Landing: a central location where logs are gathered for transport to the mill.

Litter: the uppermost layer of organic debris on a forest floor, composed mainly of fresh or 

slightly decomposed leaves, bark, twigs, flowers, fruits, and other vegetable matter.

Log: section of the main stem of a harvested tree.

Mastication: reducing forest vegetation in the stand by grinding, shredding, or chopping woody 

material. Typically done with a masticator, shredder, or chipper machine. 

Mature tree: a tree that has attained most of its potential height growth.

Mechanical treatment: cutting and removing trees using chainsaws, feller-bunchers, and skidders

MBF: abbreviation signifying 1,000 board feet of wood volume.

Mitigation measure: an activity or limitation placed upon a project activity to avoid or minimize 

adverse effects.
Glossary

250 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Monitoring measure: physical and biological evaluation of project activities to determine how 

well objectives are being met and if the effects of the activities are within those projected during 

the analysis.

Montane: referring to the climate, ecosystems, or species found in mountains.

Mosaic: the spatial arrangement of habitat where there is stand heterogeneity—measured at many 

spatial scales from the patch, the stand, and the vegetative community

NEPA: National Environmental Policy Act.

Nonnative invasive species: plant or animal species that are not native to a particular place and 

are causing disruption of the natural process of that place, displacing native plant and animal 

species, and degrading natural communities, among other disruptions.

Non-point source (NPS) pollution: effluent sediments or chemicals that enter a water body in a 

diffuse manner (e.g., runoff or leaching from farms, forestry operations, or urban areas), rather 

than from a specific point such as a pipe. Use of BMPs or filter strips helps prevent NPS 

pollution.

Old growth: a late stage of forest succession beyond the age of biological maturity, or stands that 

contain old growth characteristics including numerous large trees, large snags, and logs on the 

ground (attributes defined in the forest plan).

Operational road maintenance levels: level of service provided by, and maintenance required for, 

a specific road, consistent with road management objectives and maintenance criteria (FSH 

7709.58, 12.3). There are five levels: 

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. 

Level 2: Assigned to roads open for use by high-clearance vehicles. Passenger car traffic, user 

comfort, and user convenience are not considerations. 

Level 3: Assigned to roads open and maintained for travel by a prudent driver in a standard 

passenger car. 

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. 

Level 5. Assigned to roads that provide a high degree of user comfort and convenience. These 

roads are normally double lane, paved facilities.

Out-of-Whack: something is out of order or alignment, not in proper condition.

Over-mature tree: a tree that has reached that stage of development when it is declining in vigor 

and health and reaching the end of its natural life span. Indications of later life stages in 

southwestern ponderosa pine include yellowing bark, large limbs, dead and/or dying limbs, flat 

tops, snag tops, lightning scars, and burn scars (cat face).
Glossary

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 251

Overstocked: a stand in which trees are so closely spaced that they are competing for required 

resources, resulting in less than full growth potential for individual trees.

Overstory: the trees in a forest of more than one story that form the upper canopy layer.

Particulate matter: the microscopic particles that are part of smoke.

Perennial stream: a stream that flows throughout most (greater than 50 percent) of the year

Pole: a tree of a size between a sapling and a mature tree.

Prescribed fire: a fire ignited by management actions under specified environmental conditions 

and following appropriate precautionary measures to achieve specific objectives. Prescribed fires 

are typically conducted in the spring or fall when temperatures are cool, humidity is high, and fire 

behavior is moderate. Prescribed fires are monitored by firefighters to ensure they remain within

the area designated for burning.

Prescription: a schedule of activities for a stand or forest property which, when carried out, 

should produce the outcome desired by the landowner.

Protected habitat (Mexican spotted owl) – Protected habitat consists of projected activity centers 

(PACs), slopes greater than 40 percent where timber harvest has not occurred in the last 20 years 

(steep slopes), reserved lands which include wilderness, research natural areas, wild and scenic 

rivers, and congressionally recognized wilderness study areas. The primary objective for 

protected habitat is the protection of the best available habitat for Mexican spotted owls while 

retaining management flexibility to abate high fire risk and to improve habitat conditions for the 

owl and its prey.

Regeneration: the replacement or renewal of a forest stand by natural or artificial means. Also, the 

term “regeneration” may refer to the young tree crop itself.

Release: freeing a tree or group of trees from competition by removing trees or shrubs that 

overtop or crowd them.

Residual stand: trees remaining uncut following any cutting operation.

Resiliency: the capacity of a (plant) community or ecosystem to maintain or regain normal 

function and development following a disturbance. 

Restoration: the process of returning ecosystems or habitats to their original structure and species 

composition.

Riparian zone or ecosystem: the land and vegetation bordering flowing or standing water, 

identified by distinctive saturated soil characteristics and vegetation that require water (streams, 

lakes, ponds).

Road decommissioning. (1) Activities that result in the stabilization and restoration of unneeded 

roads to a more natural state (36 CFR 212.1). (2) Activities that result in restoration of unneeded 

roads to a more natural state (FSM 7705, FSM 7734). 
Glossary

252 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Road obliteration. To deconstruct, decommission, deactivate, or dismantle a road; the denial of 

use, elimination of travelway functionality, and removal of the road from the forest development 

road system; return of the road corridor to resource production by natural or designated means 

(“A Guide for Road Closure and Obliteration in the FS,” June 1996, T and D Publication 9677

1205).

Sapling: a tree that is no longer a seedling but not yet a pole, usually at least 4.5 feet tall and 1 to 

4.9 inches in diameter.

Sawtimber: trees, or logs cut from trees, with a minimum dbh of 8 inches, and with stem quality 

suitable for conversion to lumber. Small sawlog trees (dbh 8 to 14 inches) and large sawlog trees 

(dbh over 14 inches) sometimes are distinguished.

Sedimentation: the filling-in of stream channels or water bodies with soil particles, usually as a 

result of erosion on adjacent land.

Seedling: a young tree, usually less than 3 feet high and less than 1 inch in diameter.

Sensitive species: plant and animal species identified by a regional forester for which population 

viability is a concern as evidenced by significant current or predicted downward trends in 

population or habitat capability that would reduce a species' distribution.

Seral: a temporal and intermediate stage in the process of succession.

Shade tolerance: the ability of a tree species to survive in relatively low light conditions, although 

it may not thrive. Shade-intolerant species require sunlight to establish and grow. Shade-tolerant 

trees grow well in shady conditions.

Silviculture: the art, science, and practice of establishing, tending, and reproducing forest stands.

Site: the combination of biotic, climatic, topographic and soil conditions of an area.

Skidder: specialized logging equipment used to slide logs from stump to landing. Skidders are 

typically rubber tired or track mounted. Some are modified tractors equipped with either cable 

and winch, or a hydraulic grapple.

Skidding: moving trees from the felling site to a landing, using tractors or other logging 

equipment.

Slash: branches, treetops, bark, and other woody material left on the ground as a byproduct of 

thinning (activity produced slash).

Snag: a standing dead or dying tree that has lost most of its branches.

Soil productivity: the capacity of a soil to produce a specific plant or sequence of plants under a 

specific system of management.

Stand: a group of trees sufficiently uniform in species composition, structure and spatial 

arrangement to be distinguished from surrounding groups of trees.

Stand density: a quantitative measure of how completely a stand of trees occupies a site, usually 

expressed in terms of number of trees, or tree basal area per acre or per hectare.
Glossary

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 253

Stand density index (SDI): a relative measure of competition in a forest stand based on number of 

trees per unit area and average tree size.

Stand structure: the presence, size, and physical arrangement of vegetation in a stand. Vertical 

structure refers to the variety of plant heights from the canopy to the forest floor. Horizontal 

structure refers to distribution of trees and other plants across the land surface.

Succession: the ecological process of sequential replacement by plant communities on a given 

site as a result of reproduction and competition.

Suppressed trees: trees with crowns below the general level of the canopy and receiving no direct 

sunlight. Suppressed trees are characterized by low growth rate and low vigor due to competition 

with overtopping trees.

Surface fire: a fire that burns over the forest floor, consuming litter, killing aboveground parts of 

herbaceous plants and shrubs, and typically scorching the bases and crowns of trees. 

Surface fuel: fuels lying on or near the surface of the ground, consisting of leaf and needle litter, 

dead branch material, down logs, bark, tree cones, and low stature living plants. 

Sustainability: a characteristic of a process or state that can be maintained indefinitely. 

Sustainable land management has often been defined as that which meets the needs of the present 

without compromising the ability of future generations to meet their own needs.

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).

Thinning: removing some trees in a forest stand to provide growing space for other trees, and/or 

to remove dead or dying trees to reduce pest problems. 

Thinning from below: a method of thinning that involves cutting the smallest trees in the stand up 

to a specified diameter limit. Also called “low thinning.”

Threatened: likely to become an endangered species within the foreseeable future throughout all 

or a significant portion of its range. 

Torching: fires igniting and flaring up from the bottom to the top of a tree or group of trees.

Treatment: any silvicultural practice or procedure.

Understory: trees and other vegetation that grows beneath the overstory of a forest stand. 

Understory vegetation usually consists of grasses, forbs, and herbs; shrubs, bushes and brush; and 

small immature trees (saplings).

Uneven-aged stand: a group of trees of a variety of ages and sizes and often of different species.

Upland: areas away from coastlines and the floodplains of streams, creeks, rivers, and other 

bodies of water.

Upland function: the ability of the uplands to allow for the retention of precipitation and maintain 

and improve soil condition
Glossary

254 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Wildlife habitat: the arrangement of food, water, cover and space required to meet the biological 

needs of an animal. Different wildlife species have different habitat requirements.

Waterbar: a ditch or hump constructed diagonally across trails or roads to reduce soil erosion by 

diverting surface water runoff into adjacent ditches or vegetation.

Watershed: the total land area from which water drains into a particular stream or river.

Wetlands: lowlands covered with shallow, and sometimes temporary, water. The frequency and 

duration of inundation is sufficient to support plant communities that typically are adapted for life 

in saturated soils.

Wildlife corridors: strips of trees, shrubs, and understory vegetation that provide cover and habitat 

for wildlife and that serve as travel lanes for movement across open areas and between isolated 

patches of habitat.

Woodland: a forest with low tree densities, often defined as less than 20 to 30 percent crown 

cover when trees are mature.
FEIS for the Southwest Jemez Mountains Landscape Restoration Project 255

References

Abella, S.R., P.Z. Fulé and W.W. Covington. 2006. Diameter caps for thinning southwestern 

ponderosa pine forests: viewpoints, effects, and tradeoffs. Journal of Forestry 104: 407-

414.

Agee, J.K. 1993. Fire ecology of Pacific Northwest forests. Washington, D.C.: Island Press.

Agee, J.K. 2002. Fire behavior and fire-resilient forests. In S. Fitzgerald (ed.), Fire in Oregon’s 

forests: Risks, effects, and treatment options. Portland, OR: Oregon Forest Resources 

Institute. Pp. 119-126.

Agee, J.K., and C.N. Skinner. 2005. Basic principles of forest fuel reduction treatments. Forest 

Ecology and Management 211:83–96.

Allen, C.D. 1989. Changes in the landscape of the Jemez Mountains, New Mexico. Dissertation. 

Berkeley, CA: University of California, Berkeley.

Allen, C.D. 2001. Fire and vegetation history of the Jemez Mountains. Los Alamos, NM: U.S. 

Geological Survey. 

Allen, C.D., R.S. Anderson, R.B. Jass, J.L. Toney, and C.H. Baisan. 2008. Paired charcoal and 

tree-ring records of high-frequency Holocene fire from two New Mexico bog sites. 

International Journal of Wildland Fire 17: 115-130.

Allen, C.D. M. Savage, D.A. Falk, K.F. Suckling, T.W. Swetnam, T. Schulke, P.B. Stacey, P. 

Morgan, M. Hoffman, and J.T. Klingel. 2002. Ecological Restoration of southwestern 

ponderosa pine ecosystems: A broad perspective. Ecological Applications 12(5): 1418-

1433.

Allen, C.D., R. Touchan, and T.W. Swetnam. 1995. Landscape-scale fire history studies support 

fire management action at Bandelier. Park Science (Summer):18-19.

Arno, S.F. and S. Allison-Bunnell. 2002. Flames in our forest: Disaster or renewal? Washington, 

D.C.: Island Press.

Arno, S.F., H.Y. Smith, and M.A. Krebs. 1997. Old growth ponderosa pine and western larch 

stand structures: Influences of pre-1900 fires and fire exclusion. Research Paper INT-RP495. Ogden, UT: USDA Forest Service Intermountain Research Station.

Arnold, J.F. 1950. Changes in ponderosa pine bunchgrass ranges in northern Arizona resulting 

from pine regeneration and grazing. Journal of Forestry 48:118-126.

Audubon New Mexico (ANM). 2013. Site profile, Valles Caldera/Jemez Mountains Important 

Bird Area http://netapp.audubon.org/iba/Site/1973. Accessed 23 July 2013.

Bagne, K.E. and D.M. Finch. 2009. Small-scale response in an avian community to a large-scale 

thinning project in the Southwestern United States. In T.D. Rich, C. Arizmendi, D. 

Demarest, and C. Thompson (eds.), Proceedings of the Fourth International Partners in 

Flight Conference: Tundra to Tropics, pp. 669-678. Partners in Flight. 

Baker, M.B., Jr. 1982. Hydrologic regimes of forested areas in the Beaver Creek watershed. Gen. 

Tech. Rep. RM-90. Fort Collins, CO: USDA Forest Service, Rocky Mountain Research 

Station.
References

256 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Baker, M.B., Jr. 2003. Chapter 10: Hydrology. In Ecological restoration of southwestern 

ponderosa pine forests. Washington, D.C.: Island Press. Pp. 161-174.

Baker, M. B., Jr. and P.F. Ffolliott. 1999. Interdisciplinary land use along the Mogollon Rim. In: 

Baker, M. B., Jr., comp. History of watershed research in the central Arizona highlands. 

Gen. Tech. Rep. RMRS-GTR-29. Fort Collins, CO: USDA Forest Service, Rocky 

Mountain Research Station. Pp. 27-34.

Baker, M.B. Jr. and P.F. Ffolliott. 2003. Role of snow hydrology in watershed management. 

Journal of the Arizona-Nevada Academy of Science. 35(1): 42-47.

Baker, M.B., Jr., (compiler). 1999. History of watershed research in the Central Arizona 

Highlands USDA Forest Service Gen. Tech. Rep. RMRS-GTR-29. Ft. Collins, CO: 

USDA Forest Service, Rocky Mountain Research Station.

Baker, R.J., R.D. Bradley, and L.R. McAliley, Jr. 2003. Pocket gophers, Geomyidae. In Wild 

mammals of North America, biology, management, and conservation, 2nd Edition (G.A. 

Feldhamer, B.C. Thompson, and J.A. Chapman, Eds.). Baltimore, MD: The Johns 

Hopkins University Press.

Baker, W.L. 2012. Implications of spatially extensive historical data from surveys for restoring 

dry forests of Oregon’s eastern Cascades. Ecosphere 3(3): article 23.

Ballard, T.M. 2000. Impacts of forest management on northern forest soils. Forest Ecology and 

Management 133:37-42.

Bartos, D.L. 2001. Landscape dynamics of aspen and conifer forests. In: Shepperd, W.D., D. 

Binkley, D.L. Bartos, T.J. Stohlgren, and L.G. Eskew ( comps.). Sustaining aspen in 

western landscapes: Symposium proceedings. Gen. Tech. Rep. RMRS-P-18. Fort Collins, 

CO: USDA Forest Service, Rocky Mountain Research Station. Pp. 5-14.

Bartuszevige, A.M. and P.L. Kennedy. 2009. Synthesis of knowledge on the effects of fire and 

thinning treatments on understory vegetation in U.S. dry forests. Special Report 1095. 

Corvallis, OR: Oregon State University, Extension and Experiment Station 

Communications. 

Bates, J.D., R.F. Miller, and T.J. Svejcar. 2000. Understory dynamics in cut and uncut western 

juniper. Journal of Range Management 53(1): 119-126.

Brockway, D.G., R.G. Gatewood, and R.B. Paris. 2002. Restoring grassland savannas from 

degraded pinyon-juniper woodlands: effects of mechanical overstory reduction and slash 

treatment alternatives. Journal of Environmental Management 64 (2): 179–197.

Brook, R.D., B Franklin, and W. Cascio and eight others. 2004. Air pollution and cardiovascular 

disease: A statement for healthcare professionals from the expert panel on population and 

prevention science of the American Heart Association. Circulation 109: 2655–2671.

Brown, D.K., A.A. Echelle, D.L. Propst, J.E. Brooks, and W.L. Fisher. 2001. Catastrophic 

wildfire and number of populations as factors influencing risk of extinction for Gila trout 

(Oncorhynchus gilae). Western North American Naturalist 61: 139-148.

Brown, H. E.; M.B. Baker Jr., J.J. Rogers, W.P. Clary, J.L. Kovner, F.R. Larson, C.C. Avery, and 

R.E. Campbell. 1974. Opportunities for increasing water yields and other multiple use 
References

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 257

values on ponderosa pine forest lands. Res. Pap. RM-129. Fort Collins, CO: USDA 

Forest Service, Rocky Mountain Research Station.

Brown, J.K., E.D. Reinhardt, and K.A. Kramer. 2004. Coarse woody debris: Managing benefits 

and fire hazard in the recovering forest. Gen. Tech. Rep. RMRS-GTR-105. Ogden, UT: 

USDA Forest Service, Rocky Mountain Research Station. 

Bunting, S.C., R. Robberecht, and G.E. Defosse. 1998. Length and timing of grazing on postburn 

productivity of two bunchgrasses in an Idaho experimental range. International Journal 

of Wildland Fire 8(1): 15-20.

Bureau of Business and Economic Research (BBER). 2007. Santa Fe National Forest 

socioeconomic assessment. Report prepared for USDA Forest Service Southwestern 

Region. Albuquerque, NM: USDA Forest Service Southwestern Region.

Burnham, K. P., and D. R. Anderson. 1998. Model selection and inference: A practical 

information-theoretic approach. New York: Springer.

Busse, M.D., K.R. Hubbert, G.O. Fiddler, C.J. Shestak, and R.F. Powers. 2005. Lethal soil 

temperatures during burning of masticated forest residues. International Journal of 

Wildland Fire 14(3): 267-276.

Busse, M.D., C.J. Shestak, and K.R. Hubbert. 2013. Soil heating during burning of forest slash 

piles and wood piles. International Journal of Wildland Fire 22: 786-796.

Calkin, D.E., A.A. Ager, and J. Gilbertson-Day. 2010. Wildfire risk and hazard: Procedures for 

the first approximation. Gen. Tech. Rep. RMRS-GTR-235. Fort Collins, CO: USDA 

Forest Service, Rocky Mountain Research Station.

Calkin, D. and K. Gebert. 2006. Modeling fuel treatment costs on Forest Service lands in the 

Western United States. Western Journal of Applied Forestry 21(4): 217-221.

City of Flagstaff. 2012. Flagstaff Watershed Protection Project: Executive summary and 

implementation plan. Flagstaff, AZ: City of Flagstaff. 

City of Santa Fe. 2013. Santa Fe municipal watershed investment program. Santa Fe, NM: City 

of Santa Fe.

Collins, B.M., J.J. Moghaddas, and S.L. Stephens. 2007. Initial changes in forest structure and 

understory plant communities following fuel reduction activities in a Sierra Nevada 

mixed conifer forest. Forest Ecology and Management 239: 102–111.

Coop, J.D., and T.J. Givnish. 2007. Spatial and temporal patterns of recent forest encroachment in 

montane grasslands of the Valles Caldera, New Mexico, USA. Journal of Biogeography

34: 914-927.

Cooper, C.F. 1960. Changes in vegetation, structure, and growth of southwestern pine forest since 

white settlement. Ecological Monographs 30(2): 129-64. 

Covington, W.W., L.F. DeBano, and T.G. Huntsberger. 1991. Soil nitrogen changes associated 

with slash pile burning in pinyon-juniper woodlands. Forest Science 37(1): 347-355.

Covington, W.W., P.Z. Fulé, M. M. Moore, S. C. Hart, T.E. Kolb, J.N. Mast, S.S. Sackett, and 

M.R. Wagner. 1997. Restoring ecosystem health in ponderosa pine forests of the 

Southwest. Journal of Forestry 95 (4): 23-29.
References

258 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Covington, W.W. and M.M. Moore. 1994a. Postsettlement changes in natural fire regimes and 

forest structure. Journal of Sustainable Forestry 2(1-2): 153-181.

Covington, W.W. and M.M. Moore. 1994b. Southwestern ponderosa forest structure: Changes 

since Euro-American settlement. Journal of Forestry 92 (1): 39-47.

Crookston, N.L., M. Moeur, and D. Renner. 2002. Users guide to the most similar neighbor 

imputation program version 2. Gen. Tech. Rep. RMRS-GTR-96. Fort Collins, CO: 

USDA Forest Service, Rocky Mountain Research Station. 

Deal, K. 2012. Fire Effects on flaked stone, ground stone, and other stone artifacts. In Wildland 

fire in ecosystems: Effects of fire on cultural resources and archaeology, editors K.C. 

Ryan, A.T. Jones, C.L. Koerner, and K.M. Lee, pp.97-111. Gen. Tech. Rep. RMRS-GTR42-vol.3. Fort Collins, CO: USDA Forest Service, Rocky Mountain Research Station.

Delfino, R.J., S. Brummel, J. Wu, and H. Stern, and seven others. 2009. The relationship of 

respiratory and cardiovascular hospital admissions to the southern California wildfires of 

2003. Occupational and Environmental Medicine 66: 189-197.

Denver Water. 2013. From forests to faucets: U.S. Forest Service and Denver Water Watershed 

Management Partnership. Denver, CO: Denver Water.

Dixon, G.E. (compiler). 2002. Essential FVS: A user's guide to the forest vegetation simulator. 

Fort Collins, CO: U.S. Forest Service, Forest Management Service Center.

Dore, S.; T.E. Kolb; M. Montes-Helu; S.E. Eckert; B.W. Sulivan; B.A. Hungate; J.P. Kaye; S.C. 

Hart; G.W. Koch; and A. Finkral. 2010. Carbon and water fluxes from ponderosa pine 

forests disturbed by wildfire and thinning. Ecological Applications 20(3): 663-683.

Dore, S., M. Montes-Helu, S.C. Hart, B.A. Hungate, G.W. Koch, J.B. Moon, A.J. Finkral, and 

T.E. Kolb. 2012. Recovery of ponderosa pine ecosystem carbon and water fluxes from 

thinning and stand-replacing fire. Global Change Biology 18:3171-3185.

Earles, J.M., M.P. North, and M.D. Hurteau. 2014. Wildfire and drought dynamics destabilize 

carbon stores of fire-suppressed forests Ecological Applications 24(4): 732-740.

Edmonds, R.L., J.K. Agee, and R.I. Gara. 2000. Forest health and protection. Long Grove, IL: 

Waveland Press, Inc. 

Elliott, C.T., S.B. Henderson, and V. Wan. 2013. Time series analysis of fine particulate matter 

and asthma reliever dispensations in populations affected by forest fires. Environmental 

Health 12:11.

Elliott, M.L. 1999.The Dome Fire archeology project of 1996-1997: A summary report. Los 

Alamos, NM: National Park Service, Bandelier National Monument.

Everett, R.L., R. Schellhaas, D.Keenum, D. Sprubeck, and P. Ohlson. 2000. Fire history in the 

ponderosa pine/Douglas-fir forests on the east slope of the Washington Cascades. Forest 

Ecology and Management 129: 207-225.

Federal Land Managers’ Air Quality Related Values Work Group (FLAG). 2002. Federal land 

managers' air quality related values workgroup, phase 1 report. December 2000.

Fiedler, C.E., and C.E. Keegan. 2003. Reducing crown fire hazard in fire-adapted forests of New 

Mexico. Pp. 29-38 in: P.N. Omi and L.A. Joyce (Tech. Eds.). Fire, fuel treatments, and 
References

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 259

ecological restoration: Conference proceedings. 2002 April 16-18, Fort Collins, CO. 

Proceedings RMRS-P-29. Fort Collins, CO: USDA Forest Service Rocky Mountain 

Research Station.

Finney, M.A. 2001. Design of Regular landscape fuel treatment patterns for modifying fire 

growth and behavior. Forest Science 47(2): 219-228.

Finney, M.A. 2006. An overview of FlamMap fire modeling capabilities. In: Andrews, P.L. and 

B.W. Butler (comps.). Fuels management-how to measure success: Conference 

proceedings. 28-30 March 2006; Portland, OR. Proceedings RMRS-P-41. Fort Collins, 

CO: USDA Forest Service, Rocky Mountain Research Station. Pp. 213-220.

Ffolliott, P. F., G.S. Gottfried, and M.B. Baker, Jr. 1989. Water yield from forest snowpack 

management: research findings in Arizona and New Mexico. Water Resources Research

25:1999–2007.

Finkral, A.J., and A.M. Evans. 2008. The effects of a thinning treatment on carbon stocks in a 

northern Arizona pine forest. Forest Ecology and Management 255:2743–2750.

Fleck, J. 2011. Ponderosa: Gone in Jemez Mountains? Durango (CO) Herald. 12 October. Np.

Fowler, J.F., C.H. Sieg, B.G. Dickson, and V.Saab. 2008. Exotic plant species diversity: Influence 

of roads and prescribed fire in Arizona ponderosa pine forests. Rangeland Ecology & 

Management 61(3): 284-293.

Frey, J.K. 2007. Santa Fe Zapus final report. Survey for the New Mexico meadow jumping mouse 

(Zapus hudsonius luteus) at selected locations in the Jemez Ranger District, Santa Fe 

National Forest. Professional Services Contract AG-839-P-06-0055). Jemez Ranger 

District, Jemez Springs, NM.

Friedlander, E. and P.J. Pinyan. 1980. Indian use of the Santa Fe National Forest: A 

determination from ethnographic sources. Ethnohistorical Report Series No. 1. 

Albuquerque, NM: Center for Anthropological Studies.

Fulé, P.Z. 2008. Does it make sense to restore wildland fire in changing climate? Restoration 

Ecology 16 (4): 526-531.

Fulé, P.Z., W.W. Covington, and M.M. Moore. 1997. Determining reference conditions for 

ecosystem management of southwestern ponderosa pine. Ecological Applications. 7(3): 

895-908.

Fulé, P.Z., J.E. Crouse, J.P. Roccaforte, and E.L. Kalies. 2012. Do thinning and/or burning 

treatments in western USA ponderosa or Jeffrey pine-dominated forests help restore 

natural fire behavior? Forest Ecology and Management 269: 68–81.

Gelbard, J.L. and J. Belnap. 2003. Roads as conduits for exotic plant invasions in a semiarid 

landscape. Conservation Biology 17(2): 420–432.

Graham, R.T. 2003. Hayman Fire case study. Gen. Tech. Rep. RMRS-GTR-114. Ogden, UT: 

USDA Forests Service, Rocky Mountain Research Station.

Graham, R.T., A.E. Harvey, M.F. Jurgensen, T.B. Jain, J.R. Tonn, and D.S. Page-Dumroese. 1994. 

Managing coarse woody debris in forests of the Rocky Mountains. Res. Pap. INT-RP477. Ogden, UT: USDA Forest Service, Intermountain Research Station. 
References

260 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Graham, R.T.; S. McCaffrey, and T.B. Jain. 2004. Science basis for changing forest structure to 

modify wildfire behavior and severity. Gen. Tech. Rep. RMRS-GTR-120. Fort Collins, 

CO: USDA Forest Service, Rocky Mountain Research Station. 

Griffis, K.L., J.A. Crawford, M.R. Wagner, and W.H. Moir. 2001. Understory response to 

management treatments in northern Arizona ponderosa pine forests. Forest Ecology and 

Management 146: 239–245.

Grubb, T.G., A.E. Gatto, L.L. Pater, and D.K. Delaney. 2012. Response of nesting northern 

goshawks to logging truck noise: Kaibab National Forest, Arizona. Final Report to 

Southwest Region (R-3), U.S. Forest Service. Flagstaff, AZ: USDA Forest Service, 

Rocky Mountain Research Station.

Halvorson, S.J. 2002. The fires of 2000: Community response and recovery in the Bitterroot 

Valley, Western Montana. Quick Response Report no. 151. Boulder, CO: Natural Hazards 

Research and Applications Information Center. 

Hardy, C.C. 2005. Wildland fire hazard and risk: Problems, definitions, and context. Forest 

Ecology and Management 211(1-2): 73-82.

Hardy, C.C., R.D. Ottmar, J.L. Peterson, J.E. Core, P. Seamon. (eds.). 2001. Smoke management 

guide for prescribed and wildland fire: 2001 edition. PMS 420-2. NFES 1279. Boise, ID: 

National Wildfire Coordination Group. 

Harig, A.L. and K.D. Fausch. 2002. Minimum habitat requirements for establishing translocated

cutthroat trout populations. Ecological Applications 12: 535-551.

Harper, K.T., R.A. Woodward, and K.B. Knight. 1981. Interrelationships among precipitation, 

vegetation and streamflow in the Uinta Mountains, Utah. In: Harper, K.T., ed. Potential 

ecological impacts of snowpack augmentation in the Uinta Mountains, Utah. Denver, 

CO: Water and Power Resources Service, Office of Atmospheric Resource Management 

Engineering Research Center.

Harpold, A.A., J.A. Biederman, K. Condon, M. Merino, Y. Korgaonkar, T. Nan, L.L. Sloat, M. 

Ross, and P.D. Brooks. 2014. Changes in snow accumulation and ablation following the 

Las Conchas forest fire, New Mexico, USA. Ecohydrology 7: 440-452.

Headwaters Economics. 2011. EPS-HDT: Socioeconomic Profiles. Bozeman, MT: Headwaters 

Economics.

Headwaters Economics. 2012. A profile of socioeconomic measures: Sandoval County, NM. 

Excel file produced by EPS-HDT, 02 May 2012.

Hedstrom, N. R., and J. W. Pomeroy. 1998. Measurement and modelling of snow interception in 

the boreal forest. Hydrological Processes 12: 1611-1625.

Hesseln, H. 2000. The economics of prescribed burning: A review. Forest Science 46(3): 322-334.

Hessburg, P.F., J.K. Agee, and J.F. Franklin. 2005. Dry forests and wildland fires of the inland 

Northwest USA: Contrasting the landscape ecology of he pre-settlement and modern 

eras. Forest Ecology and Management 211: 117-139.

Hjerpe, E.E., and Y-S. Kim. 2008. Economic impacts of Southwestern National Forest fuels 

reductions. Journal of Forestry (September):311-316.
References

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 261

Hurteau, M.D., G.W. Koch, and B.A. Hungate 2008. Carbon protection and fire risk reduction: 

toward a full accounting of forest carbon offsets. Frontiers in Ecology and the 

Environment 6: 493–498.

Hurteau, M., and M. North. 2009. Fuel treatment effects on tree-based carbon storage under 

modeled wildfire scenarios. Frontiers in Ecology and the Environment 7: 409–414. 

Hurteau, M.D., M.T. Stoddard, and P.Z. Fulé. 2011. The carbon costs of mitigating high-severity 

wildfire in southwestern ponderosa pine. Global Change Biology 17:1516-1521.

Honig, K.A., and P.Z. Fulé. 2012. Simulating effects of climate change and ecological restoration 

on fire behavior in a southwestern USA ponderosa pine forest. International Journal of 

Wildland Fire 21: 731-742.

Intergovernmental Panel on Climate Change (IPCC). 2013. Climate change 2013: The physical 

science basis. Contribution of Working Group I to the Fifth Assessment Report of the 

Intergovernmental Panel on Climate Change. Cambridge, UK and New York: Cambridge 

University Press.

Jaffe, D.A. and N.L. Widger. 2012. Ozone production from wildfires: A critical review. 

Atmospheric Environment 51: 1-10.

Jenkins, S.E., C.H. Sieg, D.E. Anderson, D.S. Kaufman, and P.A. Pearthree. 2011. Late Holocene 

geomorphic record of fire in ponderosa pine and mixed-conifer forests, Kendrick 

Mountain, northern Arizona, USA. International Journal of Wildland Fire 20: 125-141.

Jirik, S.J. and S.C. Bunting. 1994. Postfire defoliation response of Agropyron spicatum and 

Sitanion hystrix. International Journal of Wildland Fire 4(2): 77-82.

Joint Fire Science Program (JFSP) 2009. Chewing the landscape: Masticated fuelbeds pose novel 

challenges. Fire Science Brief 70 (September). 

Kaufmann, M.R. 1985. Annual transpiration in subalpine forests: Large differences among four 

species. Forest Ecology and Management. 13: (3-4) 235-246.

Keeley, J.E. 2006. Fire management impacts on invasive plants in the Western United States. 

Conservation Biology 20(2): 375-384. 

Keifer, M.B., N.L. Stephenson, and J. Manley. 2000. Prescribed fire as the minimum tool for 

wilderness forest and fire regime restoration: a case study from the Sierra Nevada, 

California. In: Cole, D.N., S.F. McCool, W.T. Borrie, and J. O’Loughlin, comps. 2000. 

Wilderness science in a time of change conference-Volume 5: Wilderness ecosystems, 

threats, and management; 1999 May 23–-27; Missoula, MT. Proceedings RMRS-P-15-

VOL-5. Ogden, UT: USDA Forest Service, Rocky Mountain Research Station. Pp. 266-

269.

Keifer, M. B., J. W. van Wagtendonk, and M. Buhler. 2006. Long-term surface fuel accumulation 

in burned and unburned mixed-conifer forests of the central and southern Sierra Nevada, 

CA (USA). Fire Ecology 2: 53-72.

Keyser, C.E. and G.E. Dixon. 2008. Central Rockies (CR) Variant overview – Forest Vegetation 

Simulator (revised 2011). Internal Rep. Fort Collins, CO: USDA Forest Service, Forest 

Management Service Center. 
References

262 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Kim, Y.S. and A. Wells. 2005. The impact of forest density on property values. Journal of 

Forestry April/May 146-151.

Kochi, I., G.H. Donovan, P.A. Champ, and J.B. Loomis. 2010. The economic cost of adverse 

health effects from wildfire-smoke exposure: A review. International Journal of Wildland 

Fire 19:803-817. 

Kolb, T.E., J.K. Agee, P.Z. Fulé, N.G. McDowell, K. Pearson, A. Sala, and R.H. Waring. 2007. 

Perpetuating old ponderosa pine. Forest Ecology and Management 249:141–157.

LaBat-Anderson International. 2002. Residues of fire accelerant chemicals Volume 1: Risk 

assessment. Report prepared for USDA Forest Service, Intermountain Region. McLean, 

VA: LaBat-Anderson International.

Laughlin, D.C., J.D. Bakker, M.L. Daniels, M.M. Moore, C.A. Casey, and J.D. Springer. 2008. 

Restoring plant species diversity and community composition in a ponderosa pine–

bunchgrass ecosystem. Plant Ecology 197: 139–151.

Laughlin, D.C., M.M. Moore, J.D. Bakker, C.A. Casey, J.D. Springer, P.Z. Fulé, and W.W. 

Covington. 2006. Assessing targets for the restoration of herbaceous vegetation in 

ponderosa pine forests. Restoration Ecology 14 (4):548-560.

Lee, D.C. and L.L. Irwin. 2005. Assessing risks to spotted owls from forest thinning in fireadapted forests of the western United States. Forest Ecology and Management 211: 191-

209.

Lemhi County. 2006. Lemhi County wildland fire mitigation plan. Salmon, ID: Lemhi County 

Wildland Fire Interagency Group.

Lentz S.C., J.K. Gaunt, and A.J. Willmer. 1992. A study of the effects of fire on archaeological 

resources, Phase I: The Henry Fire, Holiday Mesa, Jemez Mountains, New Mexico. 

Archaeology Notes 93. Santa Fe, NM: Museum of New Mexico Office of Archaeological 

Studies.

Levine, F. 1996. Ethnographic uses of the Santa Fe National Forest. In Scheick, C.L. (ed.). A 

study of pre-Columbian and historic uses of the Santa Fe National Forest: Competition 

and alliance in the Northern Middle Rio Grande. Southwestern Region Report No. 18. 

Albuquerque, NM: USDA Forest Service. Pp. 347-354.

Lissoway, J. and J. Propper. 1990. Effects of fire on cultural resources. In Krammes, J.S. (ed.). 

Effects of fire management of Southwestern natural resources: Proceedings of the 

Symposium, November 15-18, 1988, Tucson, AZ. Pp. 1-10. Gen. Tech. Rep. RM-GTR191. Fort Collins, CO: USDA Forest Service Rocky Mountain Research Station. 

Loomis, J.B. and A. González-Cabán. 1998. A willingness-to-pay function for protecting acres of 

spotted owl habitat from fire. Ecological Economics 25: 315-322. 

Loomis, J., D. Griffin, E. Wu, and A. González-Cabán. 2002. Estimating the economic value of 

big game habitat production from prescribed fire using a time series approach. Journal of 

Forest Economics 8: 119-129.

Loomis, J., P. Wohlgemuth, A. González-Cabán, and D. English. 2003. Economic benefits of 

reducing fire-related sediment in southwestern fire-prone ecosystems. Water Resources 

Research 39(9): 1260, doi:10.1029/2003WR002176.
References

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 263

Malm, William C. 2000. Introduction to visibility. Fort Collins, CO: Cooperative Institute for 

Research in the Atmosphere.

Marlon, J.R., P.J. Bartlein, M.K. Walsh, S.P. Harrison, K.J. Brown, M.E. Edwards, and 16 others. 

2009. Wildfire responses to abrupt climate change in North America. Proceedings of the 

National Academy of Science 106 (8): 2519–2524.

McIver, J., K. Erickson, and A. Youngblood. 2012. Principal short-term findings of the national 

fire and fire surrogate study. Gen. Tech. Rep. PNW-GTR-860. Portland, OR: USDA

Forest Service, Pacific Northwest Research Station. 

Mid-Region Council of Governments (MRCOG). 2006. Jemez Valley Corridor Assessment. 

Albuquerque, NM: MRCOG.

Miller, G., V. Andrews, M. Edwards, J. Phillips, J. Redders, S. Sebring, R. Stein, and C. 

Vaandrager. 1993. Terrestrial Ecosystems Surveys of the Santa Fe National Forest. 

Albuquerque, NM: USDA Forest Service, Southwestern Region.

Moghaddas, J.J., B.M. Collins, K. Menning, E.E.Y. Moghaddas, and S.L. Stephens. 2010. Fuel 

treatment effects on modeled landscape-level fire behavior in the northern Sierra Nevada. 

Canadian Journal of Forest Research 40: 1751-1765.

Moore, M.M and D.W. Huffman. 2004. Tree encroachment on meadows of the North Rim, Grand 

Canyon National Park, Arizona, U.S.A. Arctic, Antarctic, and Alpine Research 36 (4): 

474-483.

Moore, M.M., D.W. Huffman, P.Z. Fulé, W.W. Covington, and J.E. Crouse. 2004. Comparison of 

historical and contemporary forest structure and composition on permanent plots in 

southwestern ponderosa pine forests. Forest Science 50(2): 162-176.

Mueller, J.M., W. Swaffar, E.A. Nielsen, A.E. Springer, and S.M. Lopez. 2013. Estimating the 

value of watershed services following forest restoration. Water Resources Research 19: 

1773-1781.

National Wildfire Coordinating Group (NWCG). 2008. Glossary of wildland fire terminology.

Available online at: NWGC glossary.

Neary, D.G., S.T. Overby, and S.C. Hart. 2002. Soil carbon in arid and semiarid forest 

ecosystems. In: Kimble, J.M., L.S. Heath, R.A. Birdsey, and R. Lal, eds. The potential of 

U.S. forest soils to sequester carbon and mitigate the greenhouse effect. Boca Raton, FL: 

CRC Press.

Neary, D.G., K.C. Ryan, and L.F. DeBanoF. 2005. Wildland fire in ecosystems: effects of fire on 

soils and water. Gen. Tech. Rep. RMRS-GTR-42-vol.4. Ogden, UT: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Research Station. 

Neary, D.G., K.A. Koestner, A. Youberg, and P.E. Koestner. 2012. Post-fire rill and gully 

formation, Schultz Fire 2010, Arizona, USA. Geoderma 191:97-104.

New Mexico Department of Agriculture (NMDA). 2009. New Mexico noxious weed list. Las 

Cruces, NM: NMDA. 

New Mexico Department of Game and Fish (NMGF). 2006. Comprehensive wildlife conservation 

strategy for New Mexico. Santa Fe, NM: NMGF.
References

264 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

New Mexico Department of Transportation. 2013. New Mexico annual average daily traffic 

report.

New Mexico Environment Department (NMED). 2003. New Mexico counties and airsheds map; 

New Mexico Environment Department, Air Quality Bureau.

New Mexico Environment Department (NMED). 2012. 2012-2014 State of New Mexico Clean 

Water Act §303(d)/§305(b) Integrated Report. Appendix A: List of assessed surface 

waters. Santa Fe, NM: NMED Surface Water Quality Bureau.

New Mexico Partners in Flight (NMPIF). 2007. New Mexico bird conservation plan v. 2.1. C. 

Rustay and S. Norris, compilers. Albuquerque, NM.

New Mexico Partners in Flight (NMPIF). 2013. List of New Mexico habitat types with associated 

species.

New Mexico State Parks. 2009. Statewide comprehensive outdoor recreation plan (SCORP) 

2010-2014. Santa Fe, NM: New Mexico State Parks.

Nielsen-Pincus, M., S. Charnley, and C. Moseley. 2012. The influence of market proximity on 

national forest hazardous fuel treatments. Forest Science. Published online 6 December. 

DOI 10.5849/forsci.11-096.

Odion, D.C., C.T. Hanson, A. Arsenault, W.L. Baker, D.A. DellaSala, R.L. Hutto, W. Klenner, 

M.A. Moritz, R.L. Sherriff, T.T. Veblen, and M.A. Williams. 2014. Examining historical 

and current mixed-severity fire regimes in ponderosa pine and mixed-conifer forests of 

western North America. PLoS One (9)2: e87852.

Omi, P.N. and E.J. Martinson. 2002. Effects of fuels treatment on wildfire severity, Final report 

submitted to the Joint Fire Science Program Governing Board. Fort Collins, CO: Western 

Forest Fire Research Center, Colorado State University. 

Ottmar, R.D., S.J. Prichard, R.E. Vihnanek, and D.V. Sandberg. 2006. Modification and 

validation of fuel consumption models for shrub and forested lands in the Southwest, 

Pacific Northwest, Rockies, Midwest, Southeast and Alaska. Final Report. JFSP Project 

98-1-9-06. Seattle, WA: USDA Forest Service, Pacific Northwest Research Station, 

Pacific Wildland Fire Sciences Laboratory.

Pearson, G.A. 1950. Management of ponderosa pine in the Southwest: As developed by research 

and experimental practice. Agriculture Monograph No. 6. Washington, D.C.: USDA, 

Forest Service. 

Pilliod, D.S., E.L. Bull, J.L. Hayes, and B.C. Wales. 2006. Wildlife and invertebrate response to 

fuel reduction treatments in dry coniferous forests of the western United States: A 

synthesis. Gen. Tech. Rep. RMRS-GTR-173. Fort Collins, CO: USDA Forest Service, 

Rocky Mountain Research Station.

Pope, C.A. III, R.T. Burnett, M.J. Thun, E.E. Calle, D. Krewski, K. Ito, and G.D. Thurston. 2002. 

Lung cancer, cardiopulmonary mortality, and long-term exposure to fine particulate air 

pollution. Journal of the American Medical Association 287: 1132-1141.

Pope, C.A. III, R.T. Burnett, G.D. Thurston, M.J. Thun, E.E. Calle, D. Krewski, and J.J. 

Godleski. 2004. Cardiovascular mortality and long-term exposure to particulate air 
References

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 265

pollution: epidemiological evidence of general pathophysiological pathways disease. 

Circulation 109: 71-77.

Prather, J.W., R.F. Noss, and T.D. Sisk. 2008. Real versus perceived conflicts between restoration 

of ponderosa pine forests and conservation of the Mexican spotted owl. Forest Policy and 

Economics 10 (2008): 140-150.

Pritchard, V.L. and D.E. Cowley. 2006. Rio Grande cutthroat trout (Oncorhynchus clarkii 

virginalis): A technical conservation assessment. Denver, CO: U.S. Forest Service Rocky 

Mountain Region.

Raish, C. and A.M. McSweeny. 2003. Economic, social, and cultural aspects of livestock 

ranching on the Espanola and Canjilon Ranger Districts of the Santa Fe and Carson 

National Forests: A pilot study. Gen. Tech. Rep. RMRS-GTR-113. Fort Collins, CO: 

USDA Forest Service, Rocky Mountain Research Station.

Raish, C.B., and A.M. McSweeney. 2012. Social, cultural, and economic aspects of livestock 

ranching on the Santa Fe and Carson National Forests. Gen. Tech. Rep. RMRS-GTR276. Fort Collins, CO: USDA Forest Service, Rocky Mountain Research Station.

Raish, C., A.M. McSweeney, and A.R. Baldwin. 2003. Small-scale ranching and traditional 

economic practices in northern New Mexico. In: Allsopp, N., A.R. Palmer, S.J. Milton, 

K.P. Kirkman, G.I.H. Kerley, C.R. Hurt, and C.J. Brown. Proceedings of the VIIth 

International Rangeland Congress, Rangelands in the New Millennium 26 July-1 August. 

Durban, South Africa. Pp.1689-1690.

Reap, R.M. 1986. Evaluation of cloud to ground lightning data from the western United States for 

the 1983-1984 summer seasons. Journal of Climatology and Applied Meteorology. 25: 

785-799. 

Reiner, A.L., N.M. Vaillant, and S.N. Dailey. 2012. Mastication and prescribed fire influences on 

tree mortality and predicted fire behavior in ponderosa pine. Western Journal of Applied 

Forestry 27(1): 36-41.

Reinhardt, E.D. and N.L. Crookston (eds.). 2003. The fire and fuels extension to the forest 

vegetation simulator. Gen. Tech. Rep. RMRS-GTR-116. Ogden, UT: USDA Forest 

Service, Rocky Mountain Research Station.

Reinhardt, E.D., R.E. Keane, D.E. Calkin, and J.D. Cohen. 2008. Objectives and considerations 

for wildland fuel treatment in forested ecosystems of the interior western United States. 

Forest Ecology and Management 256: 1997-2006.

Reynolds, R.T., R.T. Graham, and M.H. Reiser. 1992. Management recommendations for the 

northern goshawk in the southwestern United States. Gen. Tech. Rep. RM-GTR-217. Fort 

Collins, CO: USDA Forest Service, Rocky Mountain Research Station.

Reynolds, R.T., A.J. Sanchez-Meador, J.A. Youtz, T. Nicolet, M.S. Matonis, P.L. Jackson, D.G. 

DeLorenzo, and A.D. Graves. 2013. Restoring Composition and Structure in 

Southwestern frequent-fire forests: A science-based framework for improving ecosystem 

resiliency. Gen. Tech. Rep. RMRS-GTR-310. Fort Collins, CO: USDA Forest Service, 

Rocky Mountain Research Station.
References

266 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Rhoades, C.C., D. Entwistle, and D. Butler. 2011. The influence of wildfire extent and severity on 

streamwater chemistry, sediment and temperature following the Hayman Fire, Colorado. 

International Journal of Wildfire Science. 20: 430-442

Riggs, W., D. Breazeale, and G. Myer. 2001. Measuring the economic impacts from wildland fire. 

Journal of the ASFMRA 64(1): 39-42. 

Rinne, J.N. 1996. Short-term effects of wildfire on fishes and aquatic macroinvertebrates in the 

southwestern United States. North American Journal of Fisheries Management 16:653-

658.

Ritchie, M.W., B.M. Wing, and T.A. Hamilton. 2008. Stability of the large tree component in 

treated and untreated late-seral interior ponderosa pine stands. Canadian Journal of 

Forestry Research 38: 919–923. 

Roccaforte, J.P., P. Z. Fulé, and W.W. Covington. 2008. Landscape-scale changes in canopy fuels 

and potential fire behavior following ponderosa pine restoration treatments. International 

Journal of Wildland Fire 17: 293-303.

Romme, W., C.D. Allen, J.D. Bailey, W.L. Baker, B.T. Bestelmeyer, P.M. Brown, and 9 others. 

2009. Historical and modern disturbance regimes, stand structure, landscape dynamics in 

piñon-juniper vegetation of the western United States. Rangeland Ecology and 

Management 62(3): 203-222.

Russell, J.C. and P. Adams-Russell. 2006. Values, attitudes and beliefs toward National Forest 

System lands: The Santa Fe National Forest. Report prepared for Santa Fe National 

Forest and USDA Forest Service Southwestern Region. Albuquerque, NM: USDA Forest 

Service Southwestern Region.

Ryan, R.L. 2005. Social science to improve fuels management: A synthesis of research on 

aesthetics and fuels management. Gen. Tech. Rep. NC-261. St. Paul, NM: USDA Forest 

Service, North Central Research Station. 

Ryan, M.G., M.E. Harmon, R.A. Birdsey, C.P. Giardina, L.S. Heath, R.A. Houghton, and 6 

others. 2010. A synthesis of the science on forests and carbon for U.S. forests. Ecological 

Society of America: Issues In Ecology. 13: 1-16.

Sackett, S.S. 1979. Natural fuel loadings in ponderosa pine and mixed conifer forests of the 

Southwest. Res. Pap. RM-213. Fort Collins, CO: USDA Forest Service, Rocky Mountain 

Forest and Range Experiment Station. 

Sandoval County. 2008. Sandoval County community wildfire protection plan. Bernalillo, NM: 

Sandoval County.

Santa Fe National Forest. (SNF). 2005. Fire and Aviation. Old Flames Revisited. Archived web 

page. http://www.fs.fed.us/r3/sfe/fire/flamesRevisited.html.

Santa Fe National Forest. (SNF). 2009. Threatened, Endangered, Candidate and Sensitive Species 

of the Santa Fe National Forest. Santa Fe, NM: Santa Fe National Forest.

Santa Fe National Forest (SNF). 2011. Watershed restoration action plan-Outlet San Antonio. 

Jemez Springs, NM: USDA Forest Service, Southwest Region, Santa Fe National Forest, 

Jemez Ranger District.
References

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 267

Santa Fe National Forest (SNF). 2012. Management indicator species assessment. Santa Fe, NM: 

Santa Fe National Forest.

Santa Fe National Forest (SNF). 2012a. GIS corporate data. Santa Fe, NM: Santa Fe National 

Forest. 

Santa Fe National Forest (SNF). 2012b. Recreation fee data for the Jemez Ranger District. On file 

at the Jemez Ranger District office, Jemez Springs, NM.

Savage, M., and J.N. Mast. 2005. How resilient are southwestern ponderosa pine forests after 

crown fires? Canadian Journal of Forest Research 35:967-977.

Schmidt, D. A., A.H. Taylor, and C.N. Skinner. 2008. The influence of fuels treatment and 

landscape arrangement on simulated fire behavior, southern Cascade Range, California. 

Forest Ecology and Management 255: 3170-3184.

Scott, J.H. and E.D. Reinhardt. 2001. Assessing crown fire potential by linking models of surface 

and crown fire behavior. Res. Pap. RMRS-RP-29. Fort Collins, CO: USDA Forest 

Service, Rocky Mountain Research Station.

Seidelman, P.J. 1981. Methodology for evaluating cumulative watershed impacts. San Francisco, 

CA: USDA Forest Service, Watershed Management Staff, Pacific Southwest Region.

Sheppard, P.R., A.C. Comrie, G.D. Packin, K. Angersbach, and M.K. Hughes. 2002. The climate 

of the US Southwest. Climate Research 21: 219-238.

Sheppard, L, D. Levy, G. Norris, T.V. Larson, and J.Q. Koenig. 1999. Effects of ambient air 

pollution on nonelderly asthma hospital admissions in Seattle, Washington, 1987-1994. 

Epidemiology 10: 23-30.

Shepperd, W.D., P.C. Rogers, D. Burton, and D.L. Bartos. 2006. Ecology, biodiversity, 

management, and restoration of aspen in the Sierra Nevada. Gen. Tech. Rep. RMRSGTR-178. Fort Collins, CO: USDA Forest Service, Rocky Mountain Research Station. 

Sherriff, R.L. and T.T. Veblen. 2007. A spatially explicit reconstruction of historical fire 

occurrence in the ponderosa pine zone of the Colorado Front Range. Ecosystems 10: 311-

323.

Sherriff, R.L., R.V. Platt, T.T. Veblen, T.L. Schoennagel, and M.H. Gartner. 2014. Historical, 

observed, and modeled wildfire severity in montane forests of the Colorado Front Range. 

PLoS One 9(9) e106971.

Siders, M.S. and P.L. Kennedy. 1996. Forest structural characteristics of accipiter nesting habitat: 

Is there an allometric relationship? The Condor 98(1): 123-132.

Sierra, C.M. 2004. “We’re a poor state.” A glimpse at poverty in New Mexico. The New Mexico 

Report. Southwest Hispanic Research Institute. Academic year 2003-2004: 1-4.

Snyder, J. 2013. Field observations. USDA Forest Service, Southwestern Region BAER 

Assessments, 2009-2013.

Society of American Foresters (SAF). 2008. The dictionary of forestry. Available online at: 

http://dictionaryofforestry.org/
References

268 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Sorensen, C.D., A.J. Finkral, T.E. Kolb, and C.H. Huang. 2011. Short- and long-term effects of 

thinning and prescribed fire on carbon stocks in ponderosa pine stands in northern 

Arizona. Forest Ecology and Management 261: 460-472.

Springer, A.E. and L.E. Stevens. 2008. Spheres of discharge of springs. Hydrogeology Journal 

(2009) 17: 83–93. 

Squires, J.R. and Kennedy P. L. 2006. Northern goshawk ecology: An assessment of current 

knowledge and information needs for conservation and management. Studies in Avian 

Biology 31:8-62.

Squires, J.R. and Reynolds R.T. 1997. Northern goshawk (Accipiter gentilis). In: The birds of 

North America, No. 298 (A. Poole and F. Gill, Eds.). Philadelphia, PA: The Academy of 

Natural Science and Washington, D.C.: The American Ornithologists’ Union.

Starbuck, C.M., R.P. Berrens, and M. McKee. 2006. Simulating changes in forest recreation 

demand and associated economic impacts due to fire and fuels management activities. 

Forest Policy and Economics 8: 52-56. 

Steffen, A. 2005. The Dome Fire obsidian study: Investigating the interaction of heat, hydration, 

and glass geochemistry. PhD dissertation. Albuquerque, NM: Anthropology Department, 

University of New Mexico.

Stephens, S.L., J.D. McIver, R.E.J. Boerner, C.J. Fettig, J.B. Fontaine, B.R. Hartsough, P. 

Kennedy, and D.W. Schwilk. 2012 Effects of forest fuel reduction treatments in the 

United States. BioScience 62, 549-560.

Storck, P., D.P. Lettenmaier, and S.M. Bolton. 2002. Measurement of snow interception and 

canopy effects on snow accumulation and melt in a mountainous maritime climate, 

Oregon, United States. Water Resources Research 38(11): 5-1 to 5-16.

Stratton, R.D. 2006. Guidance on spatial wildland fire analysis: Models, tools, and techniques. 

Gen. Tech. Rep. RMRS-GTR-183. Fort Collins, CO: USDA Forest Service, Rocky 

Mountain Research Station.

Strom, B.A. and P.Z. Fulé. 2007. Pre-wildfire fuel treatments affect long-term ponderosa pine 

forest dynamics. International Journal of Wildland Fire 16:128-138. 

Sublette, J.E., M.D Hatch, M. Sublette. 1990. The fishes of New Mexico. Albuquerque, NM: 

University of New Mexico Press.

Swanson, F.J., J.A. Jones, D.O. Wallin, and J.H. Cissel. 1994. Natural variability: Implications for 

ecosystem management. In Ecosystem management: Principles and applications, edited 

by M.E. Jensen and P.A. Bourgeron. Gen. Tech. Rep. PNW-GTR-318. Portland, OR: 

USDA Forest Service, Pacific Northwest Research Station.

Swetnam, T. and C. Baisan. 1996. Historical fire regime patterns in the southwestern United 

States since AD 1700. In: In Fire effects in Southwestern forests: Proceedings of the 

second La Mesa Fire Symposium, March 29-31, Los Alamos, NM, pp. 11-32, edited by 

C. D. Allen. Gen. Tech. Rep. GTR-RM-286. Fort Collins, CO: USDA Forest Service, 

Rocky Mountain Forest and Range Experiment Station. 
References

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 269

The Nature Conservancy (TNC). 2008. A climate change vulnerability assessment for 

biodiversity in New Mexico, part I: Implications of recent climate change on 

conservation priorities in New Mexico. Santa Fe, NM: The Nature Conservancy.

Thompson, M.P., N.M. Valliant, J.R. Haas, K.M. Gebert, and K.D. Stockmann. 2013. Quantifying 

the potential impacts of fuel treatments on wildfire suppression costs. Journal of Forestry

111 (1):49-58.

Touchan, R., C.D. Allen, and T.W. Swetnam. 1996. Fire history and climatic patterns in 

ponderosa pine and mixed-conifer forests of the Jemez Mountains, Northern New 

Mexico. In Fire effects in southwestern forests: Proceedings of the second La Mesa Fire 

Symposium, March 29-31, Los Alamos, NM, pp. 33-46, edited by C. D. Allen. Gen. Tech. 

Rep. GTR-RM-286. Fort Collins, CO: USDA Forest Service, Rocky Mountain Forest and 

Range Experiment Station. 

Touchan, R., and T.W. Swetnam. 1995. Fire history in ponderosa pine and mixed-conifer forests 

of the Jemez Mountains, northern New Mexico. A final report submitted to the USDA 

Forest Service, Santa Fe National Forest and USDI National Park Service, Bandelier 

National Monument. Tucson, AZ: Laboratory of Tree-Ring Research, University of 

Arizona.

Touchan, R., T.W. Swetnam, and H.D. Grissino-Mayer. 1995. Effects of livestock grazing on presettlement fire regimes in New Mexico. In Brown, J.K., R.W. Mutch, C.W. Spoon, R.H. 

Wakimoto, tech. coords. Proceedings: Symposium on fire in wilderness and park 

management; 1993 March 30-April 1, Missoula, M.T. Gen. Tech. Rep. INT-GTR-320. 

Ogden, UT: USDA Forest Service, Intermountain Research Station. Pp. 268-272.

Triepke, F.J., B.J. Higgins, R.N. Weisz, J.A. Youtz, and T. Nicolet. 2011. Diameter caps and 

forest restoration: Evaluation of a 16-inch cut limit on achieving desired conditions. FRR3-16-3. Albuquerque, NM: USDA Forest Service Southwestern Region.

U.S. Census. 2007-2011a. American Community Survey 5-year estimates for the geography of 

Jemez Pueblo. Table DP-03, Selected Economic Characteristics. Washington, D.C.: U.S. 

Census Bureau. 

U.S. Census. 2007-2011b. American Community Survey 5-year estimates for the geography of 

Jemez Springs Village. Table DP-03, Selected Economic Characteristics. Washington, 

D.C.: U.S. Census Bureau. 

U.S. Census. 2010. Profile of General Demographic Characteristics: 2000. Table DP-1 for 

geographies Jemez Pueblo CDP, Jemez Pueblo ZCTA, Jemez Springs Village, Jemez 

Springs ZCTA, Ponderosa CDP, Ponderosa ZCTA. Washington, D.C.: U.S. Census 

Bureau. 

U.S. Census. 2012. State and County QuickFacts for Bernalillo, Los Alamos, Sandoval, and 

Santa Fe Counties, NM. Washington, D.C.: U.S. Census Bureau.

U.S. Department of Agriculture (USDA). 1989. Forage quality in burned and unburned aspen 

communities. Research Paper RP-INT-404. Ogden, UT: Intermountain Research Station.

U.S. Department of Agriculture (USDA). 1997. Departmental Regulation 5600-002, 

Environmental Justice. Washington, D.C.: USDA. 
References

270 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

USDA Forest Service. (USFS). 1974. USDA Forest Service, Agricultural Handbook. National 

forest landscape management, Volume 2, Chpt. 1. AH 478. Washington, D.C.: U.S. 

Government Printing Office.

USDA Forest Service (USFS). 1988. Cumulative offsite watershed effects analysis. Forest 

Service Handbook (Section 2509.22, Ch. 20, July 1988). San Francisco, CA: Region 5 

Regional Office, Forest Service, U.S. Department of Agriculture.

USDA Forest Service (USFS). 1987a. Environmental Impact Statement, Santa Fe National Forest 

Plan. Santa Fe, NM: USDA Forest Service.

USDA Forest Service (USFS). 1987b. Santa Fe National Forest Plan, as amended. Albuquerque, 

NM: USDA Forest Service.

USDA Forest Service. (USFS). 2006. Santa Fe National Forest management indicator species 

assessment. Santa Fe, NM: Santa Fe National Forest.

USDA Forest Service (USFS). 2007. Regional Forester’s sensitive species list. Animals. Region 

3. Albuquerque, NM: Santa Fe National Forest.

USDA Forest Service (USFS). 2009. Climate change considerations in project level NEPA 

analysis. Washington, D.C.: USDA Forest Service.

USDA Forest Service (USFS). 2010a. Infra database. Santa Fe, NM: Santa Fe National Forest.

USDA Forest Service. (USFS). 2010b. SW Jemez Mountains Landscape Assessment Report. 

Albuquerque, NM: USDA Forest Service.

USDA Forest Service (USFS). 2010c. Southwestern Region climate change trends and forest 

planning. Unpublished report. Albuquerque, NM: USDA Forest Service, Southwestern 

Region.

USDA Forest Service (USFS). 2011. Standard procedures for reporting USFS terrestrial wildlife 

program accomplishments. Washington, D.C.: USDA Forest Service.

USDA Forest Service (USFS). 2012a. Final environmental impact statement for travel 

management on the Santa Fe National Forest. Santa Fe, NM: USDA Forest Service, 

Southwestern Region.

USDA Forest Service (USFS). 2012b. Santa Fe National Forest management indicator species 

assessment. Santa Fe, NM: Santa Fe National Forest. 

USDA Forest Service (USFS). 2012c. National Visitor Use Report, Santa Fe National Forest. 

Washington, D.C.: USDA Forest Service.

USDA Forest Service (USFS). 2013. Regional Forester’s sensitive species list. Plants and 

animals, Region 3. Albuquerque, NM: USDA Forest Service, Southwestern Region.

USDA Forest Service (USFS). 2014. Guidance for invasive species management in the 

Southwestern Region. TP-R3-16-26. Albuquerque, NM: USDA Forest Service, 

Southwestern Region.

USDA Forest Service, New Mexico Historic Preservation Office, Arizona State Historic 

Preservation Office, Texas State Historic Preservation Office, Oklahoma State Historic 

Preservation Office, and Advisory Council on Historic Preservation (USFS et al.). 2010. 
References

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 271

First amended programmatic agreement regarding historic property protection and 

responsibilities. Albuquerque, NM: Southwestern Regional Office, USDA Forest Service.

USDA Forest Service and Valles Caldera National Preserve (USFS and VNCP). 2010. Southwest 

Jemez Mountains Collaborative Forest Landscape Restoration Strategy. Proposal for 

Funding. Albuquerque, NM: USDA Forest Service.

U.S. Department of Agriculture, Natural Resources Conservation Service (NRCS). 2013. 

National soil survey handbook, title 430-VI. Available online. 

http://www.nrcs.usda.gov/wps/portal/nrcs/detail/soils/survey/geo/?cid=nrcs142p2_05424

2

U.S. Environmental Protection Agency (USEPA). 2004. Unit conversions, emissions factors, and 

other reference data. Washington, D.C: USEPA.

U.S. Environmental Protection Agency (USEPA). 2012a. EPA currently designated nonattainment 

areas for all criteria pollutants; As of December 14, 2012. 

U.S. Environmental Protection Agency (USEPA). 2012b. Health effects of ozone in the general 

population.

U.S. Environmental Protection Agency (USEPA). 2013a. Air quality guide for particle pollution.

U.S. Environmental Protection Agency (USEPA). 2013b. Air quality index (AQI)- a guide to air 

quality and your health.

U.S. Environmental Protection Agency (USEPA). 2014. Greenhouse gas equivalencies 

calculator. Available on line at: http://www.epa.gov/cleanenergy/energyresources/calculator.html#results Last accessed 9 June 2014.

US Federal Highway Administration (FHWA). 2003. Standard specifications for the construction 

of roads and bridges on federal highway projects: FP-03. U.S. Customary Units. 

Publication number FHWA-FLH-03-002. Washington, D.C.: U.S. Department of 

Transportation.

U.S. Fish and Wildlife Service (USFWS). 1995. Recovery plan for the Mexican spotted owl: Vol. 

I. Albuquerque, NM: USFWS.

U.S. Fish and Wildlife Service (USFWS). 2005. Programmatic biological and conference 

opinion. The continued implementation of the Land and Resource Management Plans for 

the eleven National Forests and National Grasslands of the Southwestern Region. 

Phoenix, AZ: Region 2 U.S. fish and Wildlife Service. Cons. No. 2-22-03-F-366.

U.S. Fish and Wildlife Service (USFWS). 2011. U.S. Fish And Wildlife Service species 

assessment and listing priority assignment form. Yellow-billed cuckoo, Western United 

States Distinct Population Segment. Sacramento, CA Region 2 U.S. Fish and Wildlife 

Service.

U.S. Fish and Wildlife Service (USFWS). 2012. Mexican spotted owl recovery plan. First 

revision. Albuquerque, NM: USFWS. 

U.S. Fish and Wildlife Service (USFWS). 2013a. Endangered and threatened wildlife and plants; 

endangered status and designation of critical habitat for the Jemez Mountains salamander. 

Federal Register 78 (29): 12 February 2013.
References

272 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

U.S. Fish and Wildlife Service (USFWS). 2013b. Endangered status and designation of critical 

habitat for the Jemez Mountains salamander. Federal Register 78 (175): 55600-55626 12 

September 2013.

U.S. Fish and Wildlife Service (USFWS). 2013c. Establishment of a nonessential experimental 

population of the North American wolverine in Colorado, Wyoming, and New Mexico. 

Federal Register 78(23): 7890-7900.

U.S. Fish and Wildlife Service (USFWS). 2013e. Proposed Designation of critical habitat for the 

New Mexico meadow jumping mouse; Listing determination for the New Mexico 

meadow jumping mouse; Proposed rules. Federal Register 78(119): 37328-37363.

Van Mantgem, P.J., N.L. Stephenson, J.C. Byrne, L.D. Daniels, J.F. Franklin, P.Z. Fulé, M.E. 

Harmon, A.J. Larson, J.M. Smith, A.H. Taylor, and T.T. Veblen. 2009. Widespread 

increase of tree mortality rates in the western United States. Science 323:521–524.

Veblen, T.T. 2003. Key issues in fire regime research for fuels management and ecological 

restoration. In P. Omi and L. Joyce (technical eds). Fire, Fuel Treatments and Ecological 

Restoration: Conference proceedings, 2002 16-18 April. RMRS-P-29. Fort Collins, CO: 

USDA Forest Service, Rocky Mountain Research Station. 

Venn, T.J., and D.E. Calkin. 2011. Accomodating non-market values in evaluation of wildfire 

management in the United States: Challenges and opportunities. International Journal of 

Wildland Fire 20:327-339.

Viers, J. 2005. Smoke from prescribed burning- Issues on public forestlands of the Western 

United States. In ERI- Issues in Forest Restoration. Flagstaff, AZ: Ecological Restoration 

Institute, Northern Arizona University.

Von der Lippe, M. and I. Kowarik. 2007. Long-distance dispersal of plants by vehicles as a driver 

of plant invasions. Conservation Biology 21(4): 986-996.

Ward, J.P. Jr. 2001. Ecological responses by Mexican spotted owls to environmental variation in 

the Sacramento Mountains, NM. PhD. Dissertation. Department of Biology, Colorado 

State University, Fort Collins, CO.

Webster, K. M., and C. B. Halpern. 2010. Long-term vegetation responses to reintroduction and 

repeated use of fire in mixed-conifer forests of the Sierra Nevada. Ecosphere 1(5): Article 

9.

Wenger, S.J., D.J. Isaak, C.H. Luce, H.M. Nevill, K.D. Fausch, J.B. Dunham, D.C. Dauwalter, 

M.K. Young, M. M. Elsner, B. E. Rieman, A.F. Hamlet, and J.E. Williams. 2011. Flow 

regime, temperature, and biotic interactions drive differential declines of trout species 

under climate change. Proceedings of the National Academy of Sciences 108(34): 14175-

14180.

Westerling, A.L., H.D. Hidalgo, D.R. Cayan, and T.W. Swetnam. 2006. Warming and earlier 

spring increases western U.S. forest wildfire activity. Science 313:940–943.

Western Forestry Leadership Coalition (WFLC). 2010. The true cost of wildfire in the western 

U.S. Lakewood, CO: WFLC.
References

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 273

Wiedinmyer, C., and M.D. Hurteau. 2010. Prescribed fire as a means of reducing forest carbon 

emissions in the western United States. Environmental Science and Technology 44:1926–

1932.

Williams, A.P., C.D. Allen, C.I. Millar, T.W. Swetnam, J. Michaelsen, C.J. Still, and S.W. Leavitt. 

2010. Forest responses to increasing aridity and warmth in the Southwestern United 

States. Proceedings of the National Academy of Sciences 107: 21289–21294.

Williams, M.A. and W.L. Baker. 2012a. Comparison of higher-severity fire regime in historical 

(A.D. 1800s) and modern (A.D. 1984-2009) montane forests across 624,156 ha of the 

Colorado Front Range. Ecosystems 15: 832-847. 

Williams, M.A. and W.L. Baker. 2012b. Spatially extensive reconstructions show variableseverity fire and heterogeneous structure in historical western United States dry forests. 

Global Ecology and Biogeography 21: 1042-1052.

Williams, M.A. and W.L. Baker. 2013. Variability of historical forest structure and fire across 

ponderosa pine landscapes of the Coconino Plateau and south rim of the Grand Canyon 

National Park, Arizona, USA. Landscape Ecology 28: 297-310.

Williamson, J.R. and W.A. Neilsen. 2000. The influence of forest site on rate and extent of soil 

compaction and profile disturbance of skid trails during ground-based harvesting. 

Canadian Journal of Forest Research 30: 1196-1205.

Woldeselassiea, M., H. Van Miegroet, M.-C. Gruselle and N. Hambly. 2012. Storage and stability 

of soil organic carbon in aspen and conifer forest soils of northern Utah. Soil Science 

Society of America Journal 76(6): 2230-2240. 

Woods, K.W., J. Langer, K. Mesaros, and S. Plumb. 2012. Carbon commodities funding forest 

restoration. Final Report. Flagstaff, AZ: Grand Canyon Trust. 

Woolsey, T.S. 1911. Western yellow pine in Arizona and New Mexico. Forest Service - Bulletin 

101. Washington, D.C.: USDA.

Wu, T., and Y.S. Kim. 2013. Pricing ecosystem resilience in frequent fire ponderosa pine forests. 

Forest Policy and Economics 27:8-12.

Zeigler, M.P., A. S. Todd, and C.A. Caldwell. 2012. Evidence of recent climate change within the 

historic range of Rio Grande cutthroat trout: implications for management and future 

persistence. Transactions of the American Fisheries Society 141(4): 1045-1059.

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 275

Index

Air quality, 56

components of smoke, 57

conclusions about effects, 69, 72

effects of wildfires, 59

emissions, 63, 67

particulate matter, 57, 63

pollutants, 58

smoke sensitive areas, 56

visibility, 58

Alternatives

alternative 1, iii, 22

alternative 2, iii, 33

alternative 3, iii, 33

alternative 4, iii, 38

alternative 5, iii, 38

comparison of, vi, 51

descriptions, iii, 22

eliminated from detailed study, 49

Climate change, vi, 69, 72, 187, 208

conclusions about effects, 77

threats to resources, 72

Consultation, iii, 17, 26, 43, 80, 81, 82, 84, 

89, 206, 208, 210, 240, 241

Cultural resources, ix, x, 12, 16, 73, 78, 80, 

163, 281

archaeological sites, i, 12, 13, 15, 73, 82, 

83, 85, 240

conclusions about effects, 88

protection of, 25

traditional cultural properties, sacred sites, 

i, 12, 15, 82, 79, 83, 88, 89

Desired conditions, vi, 4, 5-14

Diameter limit, 49

Economic opportunity, i, 15, 154, 165, 183, 

190, 328

Ecosystem structure and function, i, vi, 1, 

14, 70, 328, 319, 333, 365, 386

Environmental justice, 74, 151, 153, 155, 

162, 163, 342, 425

erosion, 8, 13, 15, 16, 24, 52, 134, 136, 168, 

170, 175, 240, 287-9, 291, 296-7, 306 

Fire and fuels, 89

conclusions about effects, 93, 103

costs of wildfires, 158

fire regimes, 90

forest plan amendments

description, 43-46

effects, 67, 86, 101, 109, 119, 131, 150, 

163, 174, 192, 205-206, 211, 217, 233, 

236, 328-329

Forest types

description, 5-9, 176-179

Gravel pits, ii, v, 16, 26, 32, 53, 118, 139, 

205

effects, 136, 139-141

Income and employment, 152

Issues and concerns, ii, 17-19, 38, 49 

Jemez Mountains salamander, i, vi, 11-12, 

54, 76, 186, 193-195, 198, 312-317

effects, 202, 206-208, 210-214, 239

Meadows, 9, 24, 115

Mexican spotted owl

effects determination, 202, 203

critical habitat, 196, 201, 212

PACs, 197, 203-204

treatments, 24, 180, 185

Mitigation measures, 41, 279

Monitoring, 43, 44, 55, 279

New Mexico meadow jumping mouse, 194, 

202, 317

critical habitat, 199, 202, 209

effects determination, 209

Northern goshawk

effects, 219

habitat, 180

treatments, 24, 180, 185

Old growth, 

allocation, 9, 24, 52, 179

Permits, 17, 43, 111, 358, 368

Prescribed fire, 

ecologial effects, 22-23, 91, 93

Proposed action, iii, 1, 15, 22

changes, 17, 422-423

Public involvement, 17-18

Resilience, 1, 5, 14, 16, 70, 77

Stand density, 6-7, 11, 75, 181, 182, 184

Snags, 9, 16, 25, 117, 179, 205, 382

Temporary roads, 1, 17, 18, 26, 29, 33, 51

effects, 136, 141

Tribes

consultation, 17, 43, 80, 81, 89, 240, 243, 

369, 431

tribal relations, 80
Index

276 FEIS of the Southwest Jemez Mountains Landscape Restoration Project

Water quality, 9, 14, 52, 75, 165, 166, 168, 

259, 356, 367

effects, 170, 175, 240, 406, 432

Wildlife

effects, 54, 192, 239, 429-431

habitat, 11, 195, 213, 229, 234

management indicator species, 228

migratory birds, 234

sensitive species, 212

threatened and endangered species, 194, 

332 

Wood products, 15, 17, 154, 156, 158, 164, 

189
FEIS for the Southwest Jemez Mountains Landscape Restoration Project 277

Appendix A. Design Features, Best 

Management Practices, Mitigations and 

Monitoring

This section contains additional detail regarding how the various project activities will be 

implemented on the ground. They include Design Features, Best Management Practices, 

Mitigation Measures, Conservation Measures and Monitoring Measures: 

Design Features: a list of existing conditions and management actions designed to guide 

implementation of on the ground activities to achieve desired conditions while minimizing 

adverse effects.

Best Management Practices (BMPs): guidelines or minimum standards for proper application 

of forestry operations. These are designed primarily to prevent soil erosion and water 

pollution and to protect certain wildlife habitat values in riparian and wetland areas. 

Mitigation Measure: an activity or limitation placed upon a project activity to avoid or 

minimize adverse effects.

Conservation Measure: a mitigation measure designed to address effects on wildlife.

Monitoring Measure: physical and biological evaluation of project activities to determine 

how well objectives are being met and if the effects of the activities are within those 

projected during the analysis.

All Activities

Design Features

Purpose: The cumulative watershed effects analysis will provide the 

“hard look” required by NEPA and provide the decisionmaker with the best available science.

1. Use suitable tools to analyze the potential for cumulative watershed effects to occur from 

the additive impacts of the proposed project and past, present, and reasonably foreseeable 

future activities on National Forest System and neighboring lands within the project 

watersheds. This analysis will use the Equivalent Disturbed Area-Equivalent Roaded 

Area (EDA/ERA) method.

Best Management Practices

Purpose: To minimize impacts to soil and water resources, to minimize 

non-point source pollution, to adhere to the Clean Water Act, 

and to adhere to the agreement between the Southwestern 

Region of the Forest Service and the New Mexico 

Environment Department.

2. Implement best management practices (BMPs) and design criteria for those actions 

requiring non-point source and point source water quality through the iterative process of 

monitoring and adjusting BMPs and water quality standards.
Appendix A. Design Features, Best Management Practices, 

Mitigations and Monitoring for Alternatives 1, 3, 4, and 5

278 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Air Quality and Smoke Management

Design Features

Purpose: To reduce emissions

For Prescribed Fires:

3. Follow all requirements listed in the New Mexico State Smoke Management Regulations, 

including coordination requirements with New Mexico Environmental Department’s Air 

Quality Bureau (AQB). The AQB will facilitate coordination with agencies to ensure that 

burning does not occur on the same days as other prescribed fires that may impact the 

same areas, and to avoid exceeding air quality or visibility standards, in accordance with 

Clean Air Act requirements. 

4. Notify potentially affected communities, other agencies, fire departments, campground 

visitors, Jemez Pueblo, and others, in advance of and during the burn activities. 

5. Include specific smoke management (emission reducing) objectives and measures in burn 

plans, including the use of backing fires, aerial ignitions, and other methods known to 

reduce emissions (Hardy et al. 2001). 

6. Burning will occur during times of relatively high fuel moistures in the larger fuels so 

that they are not consumed; this can reduce emissions by 43% (Hardy et al. 2001). 

7. Do not burn when ventilation is considered poor, below 20,000 knot-feet, for the entire 

day34. Stop ignitions before nightfall to allow for good ventilation and smoke clearing at 

night. Avoid situations that lead to overnight active fire behavior.

8. Monitor meteorological conditions, smoke dispersion and emissions, before and during 

prescribed fire treatments, and coordinate with the State Environment Department to 

determine whether to stop ignitions or take other corrective actions if air quality 

standards are exceeded or public health or safety is compromised by smoke. 

9. Plan individual burn blocks so that ignitions will not exceed 3 days, not including 

blacklining.

Mitigation Measures

Purpose: To reduce fugitive dust

For Road Construction, Maintenance, and Decommissioning:

10. Where no requirements exist, dust control measures will be considered according to the 

standards and specifications for federal road construction (FHWA 2003).

 

34 Ventilation is the atmospheric potential to disperse airborne pollutants. It is calculated by multiplying the 

mixing height by the transport wind speed. 20,000 knot-feet is approximately 23,000 mph-ft. 
Appendix A. Design Features, Best Management Practices, 

Mitigations and Monitoring for Alternatives 1, 3, 4, and 5

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 279

Cultural Resources

Design Features

Purpose: These are overall design features for all sites and are derived 

from typical practices.

For all sites:

11. Sites listed on the National Register of Historic Properties will receive priority for 

treatment. Sites that are not eligible for listing on the National Register of Historic

Properties will be documented, but not treated.

12. The existing road system will be used to access sites.

13. Prescribed fire treatment of archaeological sites will be implemented at the same time as 

the landscape restoration burning, provided heavy fuels are removed from sites prior to 

burning.

Purpose: These design features are specific to archaeological sites in 

ponderosa pine and mixed conifer forests. They are derived 

from typical practices used in fuels removal from cultural 

sites and resources. 

For archaeological sites in ponderosa pine and mixed conifer vegetation types:

14. Remove dead and down logs that are lying on the site, especially those in direct contact 

with rubble mounds. Old, decomposing logs will not be removed during monsoon season 

or when the ground is wet.

15. Cutting will be done with chainsaws. Do not use mechanical ground disturbing 

equipment. 

16. Use directional felling to keep trees from falling on rubble mounds.

17. On rubble mounds, cut all trees less than 16-inches diameter. Use professional judgment 

on trees 16-24-inches in diameter. Leave most trees greater than 24-inches diameter, 

which would survive a fire. 

18. Cut stumps flush to the ground. On artifact scatter around the rubble mounds, thin trees to 

a 20-foot spacing. Favor leaving trees larger than 16-inches diameter.

19. In ponderosa pine and mixed conifer, favor leaving ponderosa pine over other tree 

species. 

20. In ponderosa pine and mixed conifer, cut all piñon and juniper. 

21. Prune trees up to 4 feet above ground level.

Slash Treatments:

22. Generally, do not make slash piles within site boundaries unless directed by the district 

archaeologist. 
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280 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

23. Slash will be hand-carried outside of the site boundary or to an area designated by the 

district archaeologist. 

24. If there is a small amount of slash, scatter it so that the slash is less than 2-feet high. If 

there is too much slash to scatter, pile slash in a location determined by the district 

archaeologist. Slash piles will be burned at a later time or chipped. 

25. Utility vehicles (UTVs) may be used outside the site boundary and on existing 2-track 

roads or UTV trails within the site boundary if approved by the district archaeologist. Do 

not create new UTV trails or 2-track roads.

26. Spread slash in areas with active erosion. Place logs on the contour and away from site 

features or areas with artifacts. Remove branches so that the log will be in contact with 

the ground surface and decompose more quickly.

Purpose: These design features are specific to archaeological sites in 

the piñon-juniper woodlands. They are derived from typical 

practices of fuels removal from cultural sites and resources 

and erosion prevention techniques.

Archaeological sites in piñon-juniper vegetation types:

27. Cut all trees on rubble mounds except datum tree. Prune the datum tree to 4-feet above 

ground level.

28. Cutting will be done with chainsaws. Do not use mechanical ground-disturbing 

equipment. Use directional felling to keep trees from falling on rubble mounds. 

29. Around the rubble mounds, cut trees using a 10-foot spacing (between outside edge of 

crowns).

Slash:

30. Place slash over rills, headcuts, erosional areas, sheeting outside the site boundary. Small 

amounts of slash can be strategically placed in headcuts inside site boundaries as directed 

by district archaeologist. When possible, scatter slash instead of making piles. Chipping 

is acceptable.

31. Follow UTV guidelines for ponderosa pine and mixed conifer vegetation types above

Mitigation Measures

Purpose: Items 32-34 are standard mitigations for all work in areas 

that contain archaeological sites. Item 35 is part of the 

phased approach that is allowed through the Region 3 

Programmatic Agreement. Items 36 and 37 are mitigation

measures specific to the Southwest Jemez Landscape 

Restoration Project.

Items 38-39 are derived from Appendix J of the Region 3

Programmatic Agreement, which is the standard protocol for 

large-scale fuels reduction, vegetation treatment, and habitat 

improvement projects. 
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Items 40-44 are derived from Appendix E of the Region 3 

Programmatic Agreement, which is the standard protocol for 

routine road maintenance, road closure, and road 

decommissioning. 

Items 45-50 are associated with the design criteria for 

treatments in archaeological sites also presented in this table. 

These mitigations are specific to the treatment of 

archaeological sites, but will be conducted in parallel with 

prescribed fire and mechanical treatments.

For all activities:

32. Mark all archaeological sites on-the-ground for identification purposes using white 

flagging tape or white paint to delineate the boundary to ensure that all mitigation 

measures can be applied. The site datum or reference tree will be marked with three 

horizontal bands.

33. Within archaeological site boundaries, avoid any ground-disturbing activity, including 

commercial thinning (i.e. timber sales), construction of firelines, mop-up actions, slash 

piling, staging or turnaround of heavy equipment, staging of materials, or use of 

mechanized or ground-disturbing equipment.

34. If previously unidentified cultural materials are discovered during implementation, cease 

working in the area until Forest Service archaeologists have been notified and approve 

restarting the work.

35. Initiation of work in any phase of the project will be contingent upon completion of the 

identification and protection of historic properties and compliance with applicable 

provisions of the National Historic Preservation Act in accordance with the Standard 

Consultation Protocol, including consultation with Native American Tribes.

36. In areas where only prescribed fires or only mechanical thinning may occur, brush and 

remove dead fuels for a distance beyond site boundaries in order to reduce the intensity 

of prescribed fires or wildfires in the area. The treatment would be sufficient to reduce 

fire effects to cultural resources to the level of a low intensity fire depending on site 

specific conditions as determined by a professional archaeologist with experience in fuels 

treatment to reduce fire effects.

37. After prescribed fire is used, monitor the areas around sites for fire-killed trees that need 

to be felled away from the archaeological sites.

For prescribed fires:

38. Avoid fire ignition points within boundaries of fire-sensitive archaeological sites (i.e. 

sites with wooden features, rock art, cliff dwellings, etc.). Provide aerial ignition pilots 

with GPS locations of specific fire-sensitive sites and large pueblo sites to avoid when 

conducting aerial ignitions.

39. Protect fire-sensitive sites using the following methods: lining, back burning, foaming, 

and/or otherwise insulating wooden features, in addition to removing heavy fuels. 

Monitor fire-sensitive sites subsequent to burning and modify protection measures if 

effects are documented. 
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282 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

For road maintenance and road decommissioning:

40. Conduct limited testing within the road prism to determine whether the road has cut 

below the cultural deposits of a known archaeological site.

41. Restrict vehicular traffic to the existing road prism within known archaeological sites to 

protect intact cultural deposits that lie outside the road prism.

42. Place temporary fencing to keep equipment out of known archaeological site boundaries.

43. Close or gate roads to protect archaeological sites.

44. Prohibit road maintenance activities within site boundaries unless limited testing 

demonstrates the road has cut below cultural deposits and consultation on effect has been 

completed.

For treatments conducted within archaeological site boundaries:

45. All treatments will be conducted with district or forest archaeologist oversight and/or 

monitoring.

46. Cut trees using chainsaws only.

47. Fell large diameter trees away from all features.

48. Remove fuels from sites by hand carrying.

49. Do not drag logs, trees, or thinned materials across or through sites and features. 

50. Allow prescribed fire to burn over non-fire-sensitive sites, provided heavy fuels are 

removed prior to burning.

Monitoring Measures

Purpose: Effectiveness monitoring

51. Additional monitoring for the effectiveness of treatments would be done throughout the 

life of the project. Long-term site monitoring would focus on public visitation and 

vandalism of sites.

Purpose: Consultation

52. Consult with the tribes to identify traditional cultural properties and traditional use areas 

before treatments are implemented in a particular area.

Fire and Fuels

Design Features

Purpose: To maintain long-term soil productivity and minimize 

sediment delivery from containment lines.

53. If containment lines are put in place, rehabilitate lines after use by either rolling the berm 

back over the entire fireline, spreading slash across the fireline or installing waterbars on

the fireline. If the line is only to be rehabilitated with waterbars, disguise the first 400 feet 

or past straight line of sight of line to discourage use as a trail
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FEIS for the Southwest Jemez Mountains Landscape Restoration Project 283

Purpose: To maintain long-term soil productivity.

54. On areas to be treated with prescribed fire, fire prescriptions should be designed to 

minimize soil temperatures over the entire area. High intensity fire should occur on 10% 

or less of the entire area. Fire prescriptions should be designed so that soil and fuel 

moisture are such that fire intensity is minimized and soil health and productivity are 

maintained. 

55. On areas to be treated with prescribed fire, manage for 5-7 tons per acre of coarse woody 

debris in ponderosa pine to be left on site after burning to maintain long-term soil 

productivity. 

56. Within the piñon-juniper cover type, snags and large woody debris generated as a result 

of the prescribed fire treatments will be left on site as a resource benefit.

Purpose: In accordance with Forest Service National Core BMPs 

(2012), Aquatic Management Zones will be used in project 

planning, analysis, and decision making and will further 

incorporate BMPs and design features to improve water 

quality.

To minimize sediment and/or ash delivery into drainages and 

maintain water quality

57. In areas to be treated with prescribed fire, establish filter strips (also known as Aquatic 

Management Zones). These stream reaches will be designated as protected streamcourses

and wetlands. Do not ignite fuels within this buffer area. Fire is allowed and expected to 

creep into the buffer. The following are recommendations to protect streamcourses and 

wetlands. 

Riparian streamcourses and wetlands:

Severe erosion hazard: 120 feet on each side of streamcourse and wetland.

Moderate erosion hazard: 100 feet on each side of streamcourse and wetland.

Slight erosion hazard: 70 feet on each side of streamcourse and wetland.

Non-riparian streamcourse: 

Severe erosion hazard: 100 feet on each side of streamcourse.

Moderate erosion hazard: 70 feet on each side of streamcourse.

Slight erosion hazard: 35 feet on each side of streamcourse.

Purpose: To minimize sediment and/or ash delivery into drainages and 

maintain water quality and maintain soil productivity.

58. Construct drainage structures (waterbars, rolls, dips, armor) along fire containment lines

as needed to prevent erosion and runoff. 

Best Management Practices

Purpose: To reduce soil loss and sediment input to streams. Maintain 

soil productivity and channel function.
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Mitigations and Monitoring for Alternatives 1, 3, 4, and 5

284 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

For all prescribed fire treatments:

59. Conduct prescribed fires to minimize the residence time on the soil while meeting the 

burn objectives. Manage fire intensity to maintain target levels of soil temperature and 

duff and residual vegetative cover within the limits and at locations described in the 

prescribed fire plan. Conduct prescribed fire treatments, including pile burning for slash 

disposal, in a way that encourages efficient burning to minimize soil impacts while 

achieving project objectives. 

Gravel Pits

Design Features

Purpose: To minimize effects on recreation use. 

60. Conduct exploratory drilling to determine extent and quality of rock source.

61. The maximum size of a single pit will not exceed 5 acres. 

62. To the extent possible rock pits will be located near existing system roads to minimize the 

need for road construction and reconstruction.

63. Newly constructed pits will not be located in inventoried roadless areas, the Jemez Wild 

and Scenic River Corridor, the Jemez National Recreation Area, the Monument Canyon 

Research Natural Area, Management Area I, Mexican spotted owl protected activity 

centers, Jemez Mountains salamander critical habitat, areas with a Visual Quality 

Objective level of Retention or Partial Retention. 

64. Access roads will not exceed one-half mile (0.5 miles) in length. 

Purpose: To reduce emissions

65. Contract provisions for quarrying operations will require operators to obtain the 

appropriate air quality permits under NMAC 20.2.72, as applicable, for gravel quarrying, 

crushing, and screening operations.

Purpose: Gravel pit rehabilitation

66. Save as much soil as possible during mine operations. If the soil has a well-developed 

profile and there is room for a stockpile, it is best to create a discrete stockpile. If there is 

not much soil and it does not have an A-B-C profile, and there is no room to stockpile, 

the use the soil to create berms to prevent off-site runoff. Silt fencing would also be 

installed outside the berms. Plant saved topsoil with native shrubs, trees, legumes, or 

grasses. 

67. Contour to blend into the surrounding area.

68. Limit drainage out of the site to reduce sedimentation.

69. Excess waste materials will be spread evenly over the bottom of the area excavated.

70. Restore slopes in excess of 1:2 to less than 1:2 (50% slope). 

71. After restoration, the graded or backfill area shall not allow polluted water to collect or 

remain in the area. 
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FEIS for the Southwest Jemez Mountains Landscape Restoration Project 285

72. Stabilization shall be accomplished by surfacing with soil of a quality that is at least 

equal to the topsoil of land areas immediately surrounding the gravel pit. 

73. Such topsoil, as required in item 13, will be planted with native shrubs, trees, legumes, or 

grasses.

Harvesting Operations

Design Features

Purpose: To minimize loss of soil productivity and limit erosion.

74. The timber sale administrator or contracting officer representative will contact the 

watershed staff prior to proposed unit closeout to ensure that mechanical equipment 

remains onsite to implement erosion control measures.

Purpose: To minimize sediment detachment and to minimize impacts 

on severe erosion soils.

75. Do not blade roads when the road surface is too dry. If the road surface is too dry, use a 

water truck to apply water, or the project can be scheduled for when adequate moisture 

occurs to complete the project.

Purpose: To minimize impacts to streams and soils in meadows from 

tree harvesting operations.

76. In meadow restoration sites where wood is being removed, designate skid trails in order 

to limit disturbance from skidding. Where material is not being removed, lop and scatter 

or manually remove slash from meadow; these are the preferred methods of treating 

slash. 

77. No skidding over wet meadows or across live streams or stream channels.

78. Leave sufficient numbers of cut trees (large woody debris) onsite for needed surface flow 

grade control. Forest watershed personnel will identify locations for large woody debris 

before works starts and/or inspect large woody debris placement work done by the timber 

sale administrator or contracting officer representative at unit closeout. 

79. Do not machine pile slash and woody debris within meadows.

Purpose: To minimize soil erosion, maintain soil productivity, and to 

minimize impacts on severe erosive soils.

80. Place slash on or cross-ditch (waterbar) skid trails and obliterated roads to break the 

energy flow of water. Placing slash on skid trails is the preferred method. Waterbars are 

only to be built using equipment with an articulating blade (no skidders) or by hand.

81. Do not design a long, straight skid that would direct water flow. Locate skid trails outside 

of filter strips

Purpose: To minimize ground disturbance from skidding operations 

and minimize impacts on severe erosive soils.
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Mitigations and Monitoring for Alternatives 1, 3, 4, and 5

286 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

82. Require felling to the lead to minimize ground disturbance from skidding operations. 

Felling to the lead is cutting trees in a predetermined direction within a certain area of the 

unit based on terrain and the skid road system. This makes it is easier for the skidders to 

gather and remove the logs and has fewer impacts on the soil.

Purpose: To minimize soil loss and sedimentation of streamcourses 

from skidding operations and to minimize noxious weed 

spread and re-establish native vegetation and to minimize 

impacts on severe erosive soils.

83. Outline the timing and application of erosion control methods in the sale contract. Seed 

mix will include certified weed-free native species. 

84. Use the Santa Fe National Forest Terrestrial Ecosystem Survey to identify potential 

vegetation for individual sites and seed type needed for revegetation. 

85. Use the design features in Forest Service Handbook (FSH 2509.22, Chapter 20.24.22) to 

minimize soil loss and sedimentation. The preferred erosion control method on skid trails 

in the harvest areas is spreading slash. Other acceptable erosion control measures include, 

but are not limited to, waterbarring, removing berms, seeding, mulching and crossripping. Waterbars should not be more than two feet deep and need at least a ten-foot 

leadout. Erosion control after skidding operations must be timely to minimize the effects 

of log skidding.

Purpose: To minimize soil movement, maintain water quality, and to 

minimize impacts on severe erosion soils.

86. Control road drainage with the following methods including, but not limited to: rolling 

the grade, insloping, outsloping, crowning, water spreading ditches, and contour 

trenching. Reduce sediment loads at drainage structures by installing sediment filters, 

rock and vegetative energy dissipaters, and settling ponds. Include road designs in the 

transportation plan of the task order.

87. As part of the contract and task order, require prehaul and post haul maintenance on all 

local roads used for hauling.

Purpose: In accordance with Forest Service National Core Design 

Criteria (2012), aquatic management zones will be used in 

project planning, analysis, decision making, and 

implementation to improve water quality.

To provide sediment filtering ability and/or to provide bank 

stability on all streamcourses and wetlands and minimize 

impacts on erosive soils.

88. The designation of filter strips (also known as Aquatic Management Zones) minimizes 

onsite soil movement from timber harvest activities along streamcourses and wetlands. 

These stream reaches and wetlands will be designated as protected streamcourses and 

wetlands. Include locations of protected streamcourses and wetlands in the individual 

Task Order Maps, and mark these streamcourses and wetlands with a protected 

streamcourse designation.
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89. The following are recommendations to protect streamcourses and wetlands within the 

proposed tree harvest units in relation to riparian streamcourses and wetlands and nonriparian streamcourses. The guidelines for filter strip designations are as follows:

Riparian streamcourses and wetlands:

Severe erosion hazard: 120 feet on each side of streamcourse and wetland.

Moderate erosion hazard: 100 feet on each side of streamcourse and wetland.

Slight erosion hazard: 70 feet on each side of streamcourse and wetland.

Non-riparian streamcourse: 

Severe erosion hazard: 100 feet on each side of streamcourse.

Moderate erosion hazard: 70 feet on each side of streamcourse.

Slight erosion hazard: 35 feet on each side of streamcourse.

90. Do not cut any tree contributing to shade on the stream in the primary shade zone (this 

zone represents any tree providing shade to a perennial stream during greatest solar 

inputs, 1000 hours through 1400 hours. Do not cut any tree that will destabilize the 

streamcourse bank. Manual cutting and hand dragging of trees is allowed. No mechanical 

entry in aquatic management zones.

91. Should a perennial steam crossing be needed, the timber sale administrator or the 

contracting officer representative will contact the Supervisor’s Office watershed staff for 

pre-planning and field visits.

Purpose: To filter sediment and/or provide bank stability on all 

drainage courses and to minimize impacts on drainage 

courses.

For all intermittent drainages:

92. Establish a 30-foot filter from the channel center.

93. Do not cut trees cut that will destabilize the drainage course. 

94. Do not operate mechanical equipment within the filter area.

95. Obtain onsite approval for any needed crossing from the timber sale administrator, 

contracting officer representative, or Supervisor’s Office watershed staff. Crossings will 

have sufficient armoring. 

96. Allow handcutting and hand-dragging of trees within the filter if cutting them does not 

destabilize the drainage course.

97. Allow chain-dragging trees out of the 30-foot filter on dry or frozen soil. The heavy 

equipment doing the dragging is NOT allowed in the 30-foot filter area. 

98. Do not place any slash pile within the filter boundaries. 

99. Do not allow construction of landings within the filter area.

For all ephemeral drainages:

100. Establish a 15-foot filter from the channel center. 
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288 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

101. Do not cut trees cut that will destabilize the drainage course. 

102. Do not operate mechanical equipment within the filter area. 

103. Obtain onsite approval for any needed crossing from the timber sale administrator, 

contracting officer representative, or Supervisor’s Office watershed staff. Crossings will 

have sufficient armoring. 

104. Allow handcutting and hand-dragging of trees within the filter if cutting them does not 

destabilize the drainage course.

105. Allow chain-dragging trees out of the 15-foot filter on dry or frozen soil. The heavy 

equipment doing the dragging is NOT allowed in the 15-foot filter area. 

106. Do not place any slash pile within the filter boundaries. 

107. Do not allow construction of landings within the filter area.

Purpose: To promote long-term soil productivity.

108. Manage for a minimum of 5 to 7 tons per acre of boles on ponderosa pine sites.

Purpose: To minimize and mitigate impacts from activities that 

compact sites and restore long-term soil productivity and to 

minimize impacts on .severe erosion soils.

109. Identify landings and staging areas for heavy equipment and any in-woods processing 

sites outside of filter strips and meadows. Rehabilitate sites after use by methods such as, 

but not limited to: 1) ripping to remove compaction; and 2) seeding with certified weed 

free native seed to 5 pounds per acre; and 3) spreading of slash to disguise the site and 

provide a mulch for seeds. Use the Santa Fe National Forest Terrestrial Ecosystem 

Survey to identify species for seed mix.

Purpose: To promote long-term soil productivity.

110. Because operating during wet or soil saturated conditions is the top condition leading to 

resource damage, suspend task order unit activities when wet or saturated operating 

conditions are identified by the timber sale administrator, contracting officer 

representative, Supervisor’s Office watershed staff, the timber sale administrator, 

contracting officer representative, or Supervisor’s Office watershed staff or operators.

111. Manage for all slash in piñon-juniper sites to be spread effectively and sufficiently in 

order to slow overland flows of water.

112. Allow mechanical crushing of lopped slash only on slopes of 0-25%.

Design Feature and Monitoring Measure

Purpose: EDA/ERA validation monitoring. The project offers an 

opportunity to test the EDA/ERA cumulative effects 

indicator with real world data collected through the CFLR 

program. Through this monitoring, along with data collected 

by the New Mexico Environment Department and watershed 

condition surveys, EDA/ERA may be correlated to the 

modeled EDA/ERA effects. The interdisciplinary team used a 
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threshold of concern of 15% to model cumulative effects for 

HUC 12s. By comparing these projections against the data 

collected, we can determine if the threshold modeled is too 

high or too low. 

113. For HUC 12s with an EDA/ERA existing condition of less than 15%: recalculate the 

EDA/ERA and compare it with the monitoring data every two years. 

114. For HUC 12s with an EDA/ERA existing condition of greater than 15%, including 

Church Canyon-Jemez River, East Fork Jemez River, Outlet Rio Cebolla and Outlet San 

Antonio, recalculate the EDA/ERA and compare it with the monitoring data every year. 

Headcut Treatments

Design Features

Purpose: To minimize loss of soil productivity and limit erosion.

115. Headcuts accessed by existing roads with surrounding non-erosive soils are candidates 

for mechanical treatment (placing of materials by machinery). Headcuts not accessed by 

existing roads or that are on erosive soils can receive mechanical treatment if done when 

dry or frozen soil conditions exist.

116. Conditions or timing may limit treatments by hand crews.

Purpose: To minimize loss of soil productivity and limit erosion. 

Prevent further loss of soil due to headcut migration.

117. Mechanical treatments include using a dump truck, backhoe, and a small staging area. 

118. Place staging area on the road or immediately adjacent to the road. 

119. Use locally available material when feasible.

120. Use hand treatments at those locations without road access or those areas needing less 

(mechanical) disturbance due to resource concerns (soils, cultural, wildlife). 

121. Hand treatments may include mechanical staging of fill material. 

122. Prioritize treatment locations with respect to current sediment inputs into perennial 

streams and those perennial streams that are 303-d listed for sediment and/or turbidity

Best Management Practices

Purpose: To reduce soil detachment and transport.

123. Repair degraded channel function (headcut) and improve water quality and soil 

stability. 
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290 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Instream Habitat Restoration, Bank Stabilization, and Stream 

Channel Treatments

Design Features

Purpose: Design feature specific to project. 

124. For all activities, use local materials and native plants when available. 

Purpose: To prevent sediment inputs into the stream; prevent 

increasing of width-to-depth ratio and entrenchment ratio. 

Create aquatic habitat.

125. Bank stabilization treatments may include the following: 1) mechanical actions (i.e. use 

of a dump truck for staging material and backhoe for placing material); 2) installing or 

placing post-vanes, bank armor, or grade control large woody debris or boulders; 3) key 

rootwad placement, or 4) gravel or bedload augmentation. 

126. Use bank stabilization treatments on those perennial streams needing actions to improve 

a 303-d listing or those needed for aquatic habitat improvement. 

Purpose: To prevent sediment inputs into the stream; prevent 

increasing of width-to-depth ratio and entrenchment ratio. 

For all bank stabilization treatments (including removal of failed fish structures):

127. Use silt fences or waddles, if needed, to stop localized soil disturbance. 

128. Plant native riparian vegetation to further stabilize the bank work. 

129. Install fencing to protect the bank work. 

130. Work will take place during base-flow conditions and dry or frozen soil conditions.

131. When feasible, use manual labor in the placing of post-vane, armor, bed-load additions 

or other similar structures

Purpose: To prevent sediment inputs into the stream; prevent 

increasing of width-to-depth ratio and entrenchment ratio. 

Create aquatic habitat. Create wetland habitat.

132. Stream re-channelization will be used only in stream reaches meeting the qualifying 

stream channel physical characteristics. The primary technique will be plug and pond. 

133. This action may take place on 2 identified locations, one each on San Antonio Creek 

and the Rio Cebolla, with each reach not to exceed 200-yards of stream course. 

For all stream re-channelization:

134. A 401/404 permit from the U.S. Army Corps of Engineers is required.

135. Mechanical equipment may be used and includes the use of dump trucks and backhoes. 

Use silt fences and/or waddles, if needed, to keep sediment out of streams.

136. Actions will not take place during periods of bankful flow. Actions will take place 

during periods at or near base-flow.
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137. Install fencing around both the old and new stream channels in each of the selected 

stream reaches.

138. Plant native riparian vegetation for bank stabilization. 

Best Management Practices

Purpose: To prevent soil detachment and transport, reduce 

sedimentation, stabilize streambanks and provide aquatic 

habitat.

To reconnect flow to floodplain, create riparian and aquatic 

habitat, and reduce soil loss and sedimentation.

For all bank stabilization treatments:

139. Design and implement stream channel projects in a manner that increases the potential 

for success in meeting project objectives and avoids, minimizes, or mitigates adverse 

effects to soil, water quality, and riparian resources. 

For all stream re-channelization activities:

140. Design channels with natural stream pattern and geometry and with stable beds and 

banks; provide habitat complexity where reconstruction of stream channels is necessary.

Nonnative and Invasive Plants

Mitigation Measures

Purpose: To prevent spread and establishment of nonnative and

invasive plants.

For harvesting operations:

141. Prior to moving off-road equipment onto the sale area, purchaser shall identify the 

location of the equipment’s most recent operation. Purchaser shall not move any off-road 

equipment that most recently operated in an area infested with one or more invasive 

species of concern onto the sale area without having cleaned such equipment of seeds, 

soil, vegetative matter, and other debris that could contain or hold seeds, and having 

notified the Forest Service. 

142. Prior to moving any off-road equipment subject to cleaning requirements, the purchaser 

will advise the Forest Service of its cleaning measures and make the equipment available 

for inspection. The Forest Service will have two days, excluding weekends and Federal 

holidays, to inspect the equipment after it has been made available. After satisfactory 

inspection or after the 2-day period, the purchaser may move the equipment as planned. 

Equipment will be considered clean when a visual inspection does not disclose seeds, 

soil, vegetative matter, and other debris that could contain or hold seeds. The purchaser 

will not be required to disassemble equipment unless so directed by the Forest Service 

after inspection. 

143. If the purchaser desires to clean off-road equipment on National Forest land, such as at 

the end of a project or prior to moving to, or through an area that is free of invasive 
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species of concern, Purchaser shall obtain prior approval from Contracting Officer as to 

the location for such cleaning and measures, if any, for controlling impacts. 

For road maintenance:

144. Clean and carefully inspect all earth-moving or tree-masticating equipment prior to 

entry onto forest land to ensure removal of all dirt, plants, and other foreign material that 

may transport noxious weed seeds. 

145. Treatment may be deferred on a particular weed species when a reason is stated.

Private Property and Structures

Mitigation Measures

Purpose: To protect flammable structures

146. Notify landowners in advance of prescribed burning. 

147. Protect flammable structures in the project area from fire-related damage by removing 

fuels, building firelines, burning blacklines, or other methods.

Rangeland Resources

Mitigation Measures

Purpose: To protect range infrastructure. Monitor resource conditions.

For prescribed burning:

148. Protect fire-sensitive range infrastructure (corrals, pipelines, water storage tanks, water 

troughs, fences, and cattleguards) from fire damage. Methods may include pre-burn fuel 

removal, fire containment lines around structures, strategic ignition patterns, or other 

methods. 

149. Fencelines will be used as burn area boundaries when possible. 

150. Fire and timber personnel will coordinate with district range staff on prescribed burn 

operations and harvesting activities at least one year prior to implementation.

For all activities:

151. Existing rangeland monitoring sites will be located prior to treatments. Monitoring sites 

will not be excluded from treatments; however, sites will not be used for landing areas, 

skid trails, slash piles, gravel pits or roads.

152. Timber operations will consult with the district range staff to determine pasture use 

during harvest activities.

153. All fences will be protected from harvesting activities. Temporary cattleguards will be 

installed if needed. Skid trails, and temporary roads will be laid out so as to avoid cutting 

fences.

154. All water facilities (earthen dams, trick tanks, storage tanks, pipelines, drinkers, etc.) 

should not be removed or excluded by harvesting or prescribed burning operations.
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Purpose: To minimize economic effects on grazing permittees.

155. No single grazing allotment will be treated with prescribed fire for two consecutive 

years. 

156. When and where possible, take advantage of natural barriers and existing roads to limit 

soil disturbance and construction of new fires lines.

Recreation

Mitigation Measures

Purpose: To maintain consistency with Forest Plan in regard to tree 

cutting in wild segment of the East Fork Jemez River Wild 

and Scenic River. (p. 2002-4).

To provide resource protection on trails within project area.

To minimize impacts on majority of visitors, who use the 

forest during summer season. 

Protect trail amenities.

To avoid mechanical treatments in the Semi-Primitive NonMotorized ROS setting within wild segment of the East Fork 

Jemez River Wild and Scenic River. 

157. Avoid using trails as skid trails or temporary roads. If a trail, or section of trail, is used 

as a skid trail or temporary road, include trail clean up and rehabilitation in the contract. 

This shall include restoring the trail to its original width.

158. Avoid conducting initial entry prescribed burns in the Jemez National Recreation Area 

(JNRA) during peak recreational season (Memorial Day weekend through Labor Day). 

159. Avoid treatment implementation on weekends and during holiday weekends. 

Riparian Area Restoration

Design Features

Purpose: Design features specific to project. To reduce ungulate use in 

riparian areas and impacts along streambanks.

160. Dispersed recreation areas needing treatment will be identified by the district recreation 

staff and the forest watershed specialist. 

161. Close sites by placing soil, rock, and boulders on and around the site. Exclosures may 

be built to limit access by livestock and people.

162. Best effort will be made to use immediate, locally available material and plants.

163. Gaps between exclosures should be a sufficient length to spread out livestock and 

wildlife water access use to reduce concentrated stream and streambank impacts. Gaps 

along the stream between exclosures should be at least double the size of the exclosures.
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164. Where vegetation has been severely impacted, planting of riparian shrubs, i.e., willow, 

and transplanting of sedges may be done within the exclosures. 

Road Decommissioning and Rehabilitation Treatments

Design Features

Purpose: To reduce effects from roads.

165. Intensity of treatment will depend on what resources are in the area, length of the road, 

soil conditions, slope of the roads, and resource being damaged. 

166. Use the following methods: installing signs, blocking entrances, restoring vegetation, 

eliminating the road bed, and other methods described in Forest Service Manual 7734.1.

167. Roads causing damage to hydrological resources, cultural resources or threatened 

endangered, and sensitive species habitat are a priority for decommissioning. 

Purpose: To minimize soil erosion and minimize spread of noxious 

weeds.

For site rehabilitation on stream-crossing projects where ground disturbance occurs:

168. Seed with native, certified weed-free seed mix at rate and composition needed for each 

site. Use the Santa Fe National Forest Terrestrial Ecosystem Survey to identify species to 

be seeded at individual sites. Where feasible, spread slash across the disturbed area to 

create microclimates and protect from grazing ungulates. 

Purpose: To minimize soil erosion and minimize spread of noxious 

weeds.

169. Install silt fences and/or waddles downstream from ground-disturbing activities in 

stream channels to minimize sediment delivery into the stream during construction. 

Remove silt fences when revegetation is completed. 

Purpose: To comply with state and federal water quality standards by 

minimizing sediment delivery to drainages and to create 

microclimate for regeneration of grass and forb communities 

and minimize spread of noxious weeds.

170. Use hydromulch, mulch, erosion mats, slash, or other methods to protect newly 

disturbed soils (e.g.) at stream-crossing sites as needed and where feasible. Use only 

certified weed-free straw. 

Purpose: To comply with state and federal water quality standards by 

minimizing soil erosion through the stabilizing influence of 

vegetation ground cover. Minimize spread of noxious weeds.

Site rehabilitation at stream crossing sites:

171. Use one of the following revegetation methods for site rehabilitation such as, but not 

limited to: 1) Store sod removed from the initial ground disturbance and replace the sod 

from the top of the bank on the disturbed site; 2) Seed with a native seed mix (see above) 
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3) Protect site with slash spread across the disturbed area to create microclimates and 

protect from grazing ungulates. Limit slash placement to the upper 2/3 of the streambank 

to limit downstream transport of woody material; 4) Fence out ungulates until the site has 

reestablished); 5) use mycorhizal inoculum on severely disturbed sites where no topsoil is 

left; and 6) install erosion mats. 

Purpose: To minimize disturbance in drainage systems and minimize 

sediment production within channel.

172. Do not borrow road fill or embankment materials from the stream channel or meadow 

surface on road maintenance or stream crossing projects. Compact (compress) the fill 

dirt. 

Purpose: To minimize sediment delivery into drainage and to minimize 

disturbance in drainage systems and minimize sediment 

production within channel.

173. Relocate roads out of filter strips to an upland location where feasible. If this is not 

feasible, use riprap or velocity checks to stabilize or disperse water outfall on road 

maintenance projects when roads are located within filter strips. 

Purpose: To comply with state and federal water quality standards by 

minimizing soil erosion through stabilization of ground 

cover. Minimize noxious weed spread.

174. At stream crossing sites, restore riparian-dependent grasses by 1) seeding native 

species, and 2) planting plugs of rushes and sedges to improve success of regeneration 

efforts. Fence with ungulate proof fencing until plants are established. 

Best Management Practices

Purpose: To comply with Clean Water Act provisions and to reduce 

channel sedimentation.

Roads not stabilized or maintained contribute to excessive 

soil loss and degraded channel function.

175. Coordinate stream crossing rehabilitation (channel, shoreline, lake, pond, and wetland 

activities) with appropriate state and federal agencies. Incorporate Clean Water Act 404 

permit requirements and other federal, state, and local permits or requirements into the 

project design and plan.

176. Road decommissioning includes a variety of treatments to block the road, revegetate the 

road surface, restore surface drainage, remove crossing structures and fills, mitigate road 

surface compaction, re-establish drainage-ways, remove unstable road embankments, and 

recontour the surface to restore natural slopes. One or more treatments are applied to 

decommission the road depending on resource objectives and cost.

177. Roads not needed for access for long periods (more than 1 year) may be put into 

“storage” to reduce maintenance costs. Level 1 roads receive basic custodial maintenance 

focusing on maintaining drainage facilities and runoff patterns to avoid or minimize 

damage to adjacent resources and to perpetuate the road for future use. The integrity of 

the roadway is retained to the extent practicable and measures are implemented to reduce 
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sediment delivery from the road surface and fills and reduce the risk of crossing failure 

and stream diversion. 

Road Maintenance Treatments

Design Features

Purpose: To reduce channel sedimentation

178. Mechanized equipment would not be used within clearly defined drainages (perennial, 

intermittent, or ephemeral) or riparian areas. 

179. Restrict ground-based equipment from operating when soils are saturated or 

approaching saturation. 

180. Roads will receive maintenance as needed throughout the life of the project or duration 

of the contract. 

Scenery

Design Features

Purpose: Achieve a level of scenic integrity consistent with direction 

established in the Forest Plan

All activities within the viewshed of Sensitivity Level 1 travelways and use-areas (the most 

sensitive area) as shown on Sensitivity map in the scenery specialist report.

181. The viewsheds, or areas visible, from the Sensitivity Level 1 areas will be managed to 

meet or exceed a scenic integrity level of High within five years after implementation: the 

landscape appears natural; management activities are present but not evident. 

182. A landscape architect or forest recreation specialist will be involved with the unit layout 

strategy in Sensitivity Level 1 areas. The extent of viewsheds from Sensitivity Level 1 

areas will be confirmed in the field. Portions of the project area that are representative of 

the various treatments proposed will be used to convey specific resource instructions and 

overall marking strategies.

183. For prescribed fire, use existing barriers (roads) and natural barriers as control lines 

whenever possible.

184. Protect large mature trees where possible, particularly those with a diameter over 26 

inches and with yellow bark features. 

All activities within Management Area F (East Fork Jemez Wild and Scenic River):

185. Existing groupings of gamble oak and other understory vegetation will be retained and 

encouraged to promote visual diversity.

186. Seeding mixtures will contain a high percentage of berry-producing shrubs, colorful 

plants, and wildflowers, as prescribed in the Jemez Wild and Scenic River Plan.
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Purpose: To reduce visibility of treatments

Mechanical treatments visible from Sensitivity Level 1 travelways and use-areas:

187. All created openings will be in scale with the surrounding landscape features. Openings 

will be strategically located to maintain or create distant views of scenery.

188. Mechanical treatments will be designed to enhance the visual diversity within the 

landscape by providing for a variety of tree sizes, spacing, and densities. 

Purpose: To reduce visibility of fences seen from Sensitivity Level 1 

travelways and use-areas.

189. Design fences that complement the natural and cultural setting by either blending 

visually into the landscape or reflecting the cultural history of the area. Dark colored 

metal posts, split-rail, or buck and pole fencing are recommended in areas visible from of 

Sensitivity Level 1 travelways and use areas.

Purpose: To reduce visibility of meadow treatments, instream work, 

and headcut treatments seen from Sensitivity Level 1 

travelways and use-areas:

190. Areas where heavy machinery will be used will be restored to a natural-appearing state. 

Re-grade and re-vegetate around earthen dams and constructed pools and channels to 

simulate the natural terrain of the area and blend into existing contours.

Mitigation Measures

All activities within East Fork Jemez Wild and Scenic River

Purpose: Consistency with management direction in the forest plan.

191. In the East Fork Jemez WSR, any tree harvest decks and landings will be located 

outside of the immediate foreground zone (300 feet) of the river, roads, trails, and 

recreation areas. Landings will be restored to original or characteristic contours and revegetate within one year of project completion.

192. Within the East Fork Jemez WSR, dispose of activity-generated slash in the immediate 

foreground zone (300 feet) of the river, trail and recreation areas within one year of 

project completion, with the exception of a maximum of five logs per acre with a 

minimum 12-inch diameter and 15-foot length for wildlife. 

Purpose: To reduce visibility of treatments 

Road skid trail and landing construction activities visible from Sensitivity Level 1 

travelways and use-areas:

193. Rehabilitate all equipment staging areas, log landings, skid trails, temporary roads and 

firelines at the end of the project so as to not be visually evident from Sensitivity Level 1 

areas immediately following implementation. Rehabilitation will include returning the 

ground to natural contours, implementing decompaction and erosion control measures as 

needed, pulling slash and rocks across firelines, disguising entrances and covering bare 

soil with slash, chips, needles or cut brush as necessary. Restore proper drainage and 
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reseed as needed with native species. Reseed and mulch landings according to applicable 

BMPs (see soil and water resources specialist report) as soon as possible to speed 

recovery. If trails are used, rehabilitate trails to original width, condition, and designated 

class level.

194. Align temporary roads to use topography and vegetation where possible to help screen 

them from vista points and Sensitivity Level 1 travelways.

195. Minimize the distance you can see down temporary roads and skid trails from 

intersections with Sensitivity Level 1 roads and trails. Efforts should be made to have 

them intersect at a right angle, then curve the temporary road or skid trail soon after the 

junction to limit the distance seen down the temporary road.

196. Avoid using machinery within the dripline of leave-trees to prevent scarring by 

equipment.

Purpose: To reduce impacts on scenic integrity

For Mechanical Treatments Visible from Sensitivity Level 1 Travelways and Use-areas

197. The size of created openings visible within foreground distances (1⁄2 mile) from the 

Sensitivity Level 1 areas will range up to 4 acres. Openings in middleground distances (1⁄2 

mile to 4 miles) will range up to 10 acres.

198. Maintain free-form shapes and edges that reflect the natural, open-space patterns of the 

desired landscape character. Create openings in the canopy that vary in size and shape 

while leaving groups or clumps of uneven-aged trees. The shape will relate to the 

topography and will flow with the contours, following natural lines of the slopes, mesas, 

ridges, drainages and rock outcrops.

199. Stump heights shall be cut as low as possible, with the cut angled away from the viewer. 

Flush cut stumps within 4 inches of the uphill side of the stump where possible.

200. Avoid unnatural-looking (straight) lines by undulating edges of the treatment areas 

horizontally and establishing a diverse height of leave trees.

201. Feather the edges of mechanical treatments to blend into the surrounding landscape. 

Where the treatment unit is adjacent to denser forest, the percent of thinning within the 

transition zone is progressively reduced toward the denser edges of the unit. Similarly, 

where the treatment unit interfaces with an opening (including meadows and other natural 

openings) the transition zone is progressively increased toward the open edges of the unit.

202. Mark trees that are to be removed on the backs of trunks, away from the primary 

viewing point, so marks do not detract from the landscape character.

203. If machine piling is used in areas visible from Sensitivity Level 1 areas, then special 

brush rakes or grapples are recommended to minimize damage to existing groundcovers.

Purpose: To reduce visibility of treatments

Slash Treatments Readily Visible from Sensitivity Level 1 Travelways and Use-areas:

204. Pile and burn, or masticate woody debris visible from Sensitivity Level 1 use-areas as 

soon as possible after project implementation. 
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205. No residual material should be left after pile burning. Excess slash to be burned will be 

piled in irregularly-spaced intervals. Do not build piles in straight lines. Care must be 

taken to create irregularly shaped burn piles so as to not leave a circular burn footprint.

206. Scatter burned slash on control lines to reduce the color contrast of the exposed soil.

Purpose: To reduce visibility of fences seen from Sensitivity Level 1 

travelways and use-areas

207. In areas visible from Sensitivity Level 1 travelways and use-areas, use dark colored 

steel posts for elk exclosure fences (8 feet tall).

Purpose: To reduce visibility of meadow treatments seen from 

Sensitivity Level 1 travelways and use-areas.

208. Avoid machine piling in meadow areas.

209. Construct concrete barriers, retaining walls, and/or highly visible headwalls and 

endwalls of box culverts with color and/or texture qualities that blend into the existing 

landscape.

210. Use native plants characteristic to the area to screen tanks and drinkers from roads and 

trails.

211. If slash is not removed in meadow treatment areas, then the preferred treatment is to lop 

and scatter to 24-inches high.

Seep and Spring Treatments

Design Features

Purpose: To reduce effects on soil and water resources, limit ungulate 

access to seep and spring areas, and to retain large trees. 

212. No operation of mechanical (harvest/thin) equipment within the spring-seep complex. 

No mechanical equipment will be allowed within the spring-seep complex unless the soil 

is frozen. Cut and remove conifers less than 16-inches diameter that are within 100 feet 

of identified seeps or springs. 

213. Do not cut trees that will lead to destabilization of the spring, seep, or channel. Cutting 

or falling of conifers is allowed. Drag trees from site only when soil is frozen. Do not 

drag trees if the drag path crosses or destabilizes a seep, spring, channel or other feature.

214. If possible, pile slash along the 100-ft boundary to limit ungulate access. 

215. Large trees may be cut and removed or cut and left in place. 

Purpose: To comply with state and federal water quality standards by 

minimizing soil erosion through stabilization of ground 

cover. Minimize spread of noxious weeds.

216. Obtain Supervisor’s Office approval and selection of an onsite spring and seep 

protection specialist(s). This specialist will be onsite during ground-disturbing activities. 
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Purpose: To improve hydrologic function of seeps and springs.

217. Cutting and/or removal of conifers is allowed if spring or seep has an existing nonconifer woody or riparian component. If no riparian component exists, remove trees less 

than 16-inches diameter leaving only those that will improve hydrologic function. If site 

has all smaller age-classes, leave an appropriate number of trees that will improve 

hydrologic function. 

218. Remove livestock grazing access at spring or seep complexes with fencing. Use 

material cut onsite or pile (jackstraw) cut material

Purpose: Sufficient quantities of water needed for spring and wetland 

function will have equal priority to water needed for 

livestock.

219. If a spring or seep with a water trough or other water structure is being used by 

livestock, relocate the water structure away from spring or seep complex. 

Purpose: To improve hydrologic function of seeps and springs.

220. Slash and cut trees can be used (placed) to improve spring or seep hydrologic function. 

Use manual methods to drag excess fuels offsite, and place in burn piles not exceeding 6-

feet diameter and 5-feet high.

Purpose: To improve success of regeneration efforts.

221. At spring restoration sites, restore riparian-dependent plants by seeding native species 

and/or planting plugs or cuttings of native plants (trees, shrubs, grasses, forbs, etc.).

Best Management Practices

Purpose: To restore spring and seep habitat to improve function and 

water quality and quantity.

222. Consider how existing water quality and quantity and habitat conditions at the project 

site have been affected by past habitat alterations, hydrologic modification, and riparian 

area changes in the watershed.

Silviculture Treatments

Design Features

Purpose: To meet forest plan direction for vegetation management. 

Uneven-aged management using selective cutting in ponderosa pine:

223. A target basal area 50-70 within groups of trees or about 20-70 overall (including 

interspaces).

224. Groups are 0.1 to 4 acres, averaging 0.5 acres, and generally consist of 2 to 14 

dominant and co-dominant trees per 0.1 acre.

225. Approximately 10% of the area would be in openings (grasses and forbs), and 

approximately another 10% in regeneration (seedlings and saplings). 
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226. Crown spacing between groups of trees (interspace) would vary depending on 

treatment intensity. Interspaces would be 30-60 feet between groups of trees. A total of 

30-60% of the area would not be treed because of openings and interspaces. There would 

be more openings where the site index is lower.

227. Openings are up to 4 acres in size and placed in VSS 3 and 4 stands, or stands with 

heavy mistletoe, or around existing openings. 

228. Size classes would be balanced as much as possible.

229. Species composition would be primarily ponderosa pine with Gambel oak and juniper. 

Douglas-fir and limber pine are incidental.

230. Leave 5-7 tons per acre of woody debris and 2 snags per acre.

231. Prescribe burn every 5-10 years.

Purpose: To move stands toward desired condition. 

Stand improvement thinning and burning in ponderosa pine:

232. Thin, primarily from below, to improve growth and vigor.

233. Thin tree groups to free-to-grow conditions to allow for rapid growth and development.

234. Establish interspaces between remaining tree groups.

235. Establish crown spacing between groups that would vary from 30 to 60 feet depending 

on treatment intensity.

236. The priority for establishing openings would be in currently non-stocked areas and in 

areas that have moderate to severe dwarf mistletoe infection. 

237. We would use this type of thinning in young, even-aged stands such as plantations, 

stands with light to moderate dwarf mistletoe, along some prescribed burn firelines, and 

in remote and/or steep stands.

238. Use prescribed fire to treat slash.

Purpose: To meet forest plan direction. 

Uneven-aged management using selective cutting in dry mixed conifer:

239. Target basal area of 60-80 within groups, or about 30-80 overall (including 

interspaces).

240. Groups are 0.1 to 2.5 acres, averaging less than 1 acre. 10% of the area would be in 

openings, another 10% in regeneration. A total of 10-50% of the area would not be treed 

because of openings and interspaces. Interspaces are 30-60 feet between groups of trees.

241. Size classes would be balanced as much as possible.

242. Species composition is a mix of ponderosa pine, Douglas-fir, limber pine, white fir, and 

aspen.

243. Leave aspen as individual trees or small groups.

244. Leave 10-15 tons per acre of down logs greater than 12-inches diameter and 3 snags 

per acre, on average. 

245. Prescribe burn every 7-12 years.
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Purpose: To move toward desired condition.

Stand improvement thinning and burning in dry and wet mixed conifer:

Dry mixed conifer:

246. Treatments are similar to those described for ponderosa pine stand improvement.

247. Create groups and openings, but smaller than in ponderosa pine. Higher stand density 

than in ponderosa pine. 

248. Prescribe burn to reduce slash.

Wet mixed conifer:

249. Individual tree selection, light thinning if needed to reduce fire hazard. Burn only if fire 

backs into stand from an adjacent burn.

250. Possible reasons for treatment are: proximity to endangered species habitat, WUI, 

springs, insects, disease, or other special need areas, or as small inclusions of wet mixed 

conifer within other cover types. 

251. Treatments would be uneven aged, individual tree selection across size classes with 

small (0.1 acre) openings for regeneration. 

252. Balance successional stages. If early succession (aspen) is lacking (less than 20% of the 

cover type), cut patches to stimulate regeneration.

Purpose: To move toward desired condition, create diversity across the 

landscape.

Treatments to maintain or increase aspen cover type:

253. To maintain acres in aspen, cut invading conifers in stands. Cut trees may be removed.

254. To create new acres of aspen, stimulate regeneration by cutting conifers where they 

have overtopped aspen stands. 

255. Focus on stimulating new aspen stands on the north and west portions of the project 

area, because the eastern portion is near the Las Conchas burn which has lots of new 

aspen. 

256. Create patches of 5-40 acres, spread across the landscape, to provide vegetative 

diversity and fire breaks. 

257. Put patches in existing conifer stands of VSS 3 and 4. Focus patches on places where 

conifers have mistletoe, budworm, high bark beetle risk, etc.

258. Leave conifers larger than 24-inches diameter 

Purpose: To maintain and enhance cover type.

Treatments in piñon-juniper:

259. Desired residual tree densities are between 50-200 trees per acre. 

260. Leave a range of tree sizes.
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261. Prioritize areas for treatment to reduce erosion, protect heritage sites, or to increase 

habitat for songbirds.

262. Firewood may be gathered where roads allow. 

263. Scatter slash to provide ground cover or pile and burn. 

Purpose: To maintain and enhance stands with old-growth 

characteristics for forest diversity and wildlife habitat.

Old growth treatments:

264. Prioritize stands within or adjacent to Mexican spotted owl protected activity centers, 

goshawk post-fledging family areas, Jemez Mountains salamander locations, and 

visually-sensitive areas for old growth management. 

265. Select stands classified as VSS 5 and 6 for inclusion in the old growth allocation.

266. Thin primarily small trees and create gaps in the overstory with group or individual tree 

selection. 

267. Leave trees larger than 24-inches diameter. 

268. Burn slash from mechanical treatments, but avoid reducing the amount of large woody 

debris.

Mitigation Measures

Purpose: To control bark beetles. 

In ponderosa pine:

269. Slash greater than 3-inches in diameter that is created between January and June must 

be removed, burned, cut to short lengths, chipped, or otherwise treated, within 21 days. 

Material cut in winter may be left on site until March 15. These measures may be 

modified by a silviculturist based on weather and specific stand conditions.

Soil and Watershed Health and Function

Design Features

Purpose: Conduct operations that reduce erosion, compaction, soil 

detachment, transport, and rutting.

270. Cumulative and proposed actions and their combined proposed soil impacts exceeding 

15% of the Huc12 will require additional design criteria as listed in the watershed 

specialist’s report.

Purpose: Conduct operations that reduce erosion, compaction, soil 

detachment, transport, and rutting. These actions will 

produce less detached sediment and less sediment delivery 

into all drainage types, thus improving water quality and soil 

productivity.
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304 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

271. Winter logging on frozen soil is preferred to mitigate surface disturbance and accelerate 

vegetative recovery.

272. Conduct logging operations using the least surface-disturbing equipment. The preferred 

equipment is a harvester-forwarder with an articulating boom and a harvester head, and 

wide, rubber-tracked wheels that are used on designated skid trails. 

273. Attempt to make no more than 3 passes on a skid trail as research shows compaction 

greatly increases after a third pass. 

274. Do not operate in wet or saturated soil conditions.

For all treatments on Mollisol soils (TEU units 156, 630, 631, 641, 642, and 652):

275. Do not exceed a 5 percent increase per year in existing bare soil conditions (see the 

Watershed and Soils Specialist Report).

276. If possible, avoid locating new landings within these units. If unavoidable, use an older 

or formerly existing landing. If no suitable prior area of disturbance can be located within 

the Mollic unit, consult with the watershed staff person. Landings must be ripped, seeded, 

and covered with adequate slash to minimized erosion, but allow for vegetative recovery.

277. Minimize construction of new skid trails, and use existing trails, routes, and roads 

instead. 

278. Roads and skid trails used in treatment polygons within the Mollisol soil units will be 

hydrologically stabilized within 24 hours of the unit or polygon closeout. This will be 

verified by the Supervisor’s Office watershed staff, timber sale administrator, contracting 

officer representative, or personnel approved by the watershed staff.

Purpose: Low soil severity burn on Mollisol soils will reduce vegetative 

recovery times and improve overland flow or infiltration, 

and reduce soil detachment and transport.

279. Grinding or chipping operations on the Mollisol soil units will not exceed a 2-inch or 

one-layer thickness of chip-grind material.

Purpose: Monitoring

280. For vegetation and prescribed fire treatments, implement the Forest Soil Disturbance 

Monitoring Protocol (FSDMP) and the Soil Disturbance Field Guide. Pre-disturbance 

data (baseline data) will represent all ecotypes and treatments and further provide a 

seamless transition into BMP monitoring. Implement proper functioning condition (PFC) 

monitoring on the streams within the project area. The pre-treatment PFC monitoring will 

provide a baseline to determine post-treatment effectiveness in the project area streams 

and associated riparian corridors.

281. The timber sale administrator will monitor the implementation of BMP’s during timber 

harvesting activities. Forest watershed specialists will employ those BMPs necessary to 

the riparian, stream, springs and seeps actions. 

282. The timber sale administrator will verify that the timber sale purchaser has implemented 

all erosion control measures prior to the closure of the timber sale. Primary responsibility 

will be that of the timber sale administrator and the Forest watershed staff.
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283. The district fire management officers will verify that all BMPs associated with all 

burning activities have been implemented and monitored. 

284. Within the first 5 years after timber sale closure, BMP’s are evaluated for effectiveness. 

Monitoring will concentrate on such items as erosion control measures for skid trails, log 

landing or decking areas, road maintenance, road obliteration, and burned areas. Conduct 

a soil condition and disturbance evaluation within treatment units, focusing on vegetative 

ground cover, coarse woody debris, soils erosion, soil compaction, and soil displacement. 

285. Documented information from monitoring is used to adjust BMPs as necessary, to 

improve implementation and effectiveness of BMPs. This information will be made 

available to the New Mexico Environmental Department for review as specified in the 

intergovernmental agreement.

Best Management Practices

Purpose: To maintain and improve watershed function and soil 

productivity.

286. Avoid, minimize, or mitigate adverse effects to soil, water quality, and riparian 

resources by implementing measures to control surface erosion, gully formation, mass 

slope failure, and resulting sediment movement before, during, and after mechanical 

vegetation treatments.

Temporary Road Construction and/or Opening Existing 

Closed Roads

Design Features

Purpose: To reduce impacts from temporary roads and other road 

work.

287. Temporary roads will be of the lowest design specification possible while providing 

adequate access for product removal. 

288. Locate temporary roads to avoid excessive skidding distances, skidding on steeper 

slopes, adverse skids and to go around wet areas or meadows.

289. For opening existing closed roads, use design features for road maintenance treatments. 

290. Temporary roads will receive maintenance as needed throughout the life of the project 

or duration of the contract.

291. Existing closed roads will receive maintenance as needed throughout the life of the 

project or duration of the contract. Close these roads after use.

Purpose Decommissioning measures for temporary roads.

292. Temporary roads will be decommissioned as part of the closing work.

293. Remove any berm on the road edge that would hold or channel water.

294. If compaction is evident, road will be ripped before seeding.

295. Install waterbars to prevent water from following the decommissioned road.
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306 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

296. Seed areas of bare soil with certified, native plant rehab mix.

297. Slash may be pulled onto the road.

298. Closure may be a berm, rocks, or stumps to block motorized access.

299. Decommissioned temporary roads will be monitored every other year for six years. If 

there is evidence that unauthorized use has occurred, use other measures to ensure that 

they stay closed. This may include using larger berms, rocks or other barriers to block 

access.

300. People using decommissioned temporary roads would be in violation of the closure 

order created under the Travel Management Decision and may be cited. 

Threatened and Endangered Species

Mexican Spotted Owl

Design Features

Purpose: Conservation measures to avoid or minimize effects on 

species and habitat.

301. Adhere to the Forest Plan, as amended, applicable to proposed activities in Mexican

spotted owl habitat (USFS 1987b, Appendix D, pp.1-6).

302. In Mexican spotted owl protected activity centers avoid nest areas during prescribed fire 

operations to the extent possible. Plan ignitions away from the nest area. 

303. All PACs within the project area will be monitored for occupancy and reproduction.

304. Implementation activities will occur in no more than half of the PACs per year. In 

addition, the Forest will attempt to minimize the amount of time that it is operating in 

PACs to reduce disturbance to owls. For example, if trees are cut in January-February, 

then burning will occur in the fall. If cutting occurs in September, then burning would 

occur in the fall of the following year. 

305. All activities within PACs will be avoided during the breeding season unless adequately 

surveyed to determine occupancy for the season.

306. Plan ignitions away from the nest area but allow prescribed fire to burn through the nest 

area. 

Silvicultural Treatments

307. No thinning/mechanical treatments in nest areas.

308. Thin if owl habitat can be improved to reduce fire risk. This will move the stands 

toward having larger trees and a multi-storied canopy. 

309. Thin primarily small trees (less than 18-inches diameter) and crate gaps in the overstory 

using group or individual tree selection. 

310. Leave trees larger than 18-inches diameter.

311. Burn slash from treatments. 
Appendix A. Design Features, Best Management Practices, 

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FEIS for the Southwest Jemez Mountains Landscape Restoration Project 307

Mitigation Measures

Purpose: Maintain consistency with the forest plan

312. Prior to implementation of activities where owls or their habitat might be affected by 

management actions, survey all areas that contain forested recovery habitat, riparian 

forest, and canyon habitat, or that might support owls. In general, the survey area should 

include the survey area (area of project activities) and an 800-meter (0.5 mile) area from 

its exterior boundaries. These areas will be surveyed as defined in the Revised Recovery 

Plan for the owl (USFWS 2012).

Purpose: Comply with the terms and conditions as outlined in the 

USFWS Biological Opinion

The Santa Fe National Forest (Forest) will implement the following terms and conditions as 

outlined in the Biological Opinion unless the U.S. Fish and Wildlife Service (USFWS) approves 

deviation from these terms and conditions through site-specific project consultation. 

The following terms and conditions will implement reasonable and prudent measure 1:

313. Avoid activities within 0.25 mile of PACs during the breeding season (March 1 to 

August 31) that could result in disturbance to nesting owls. If the Forest determines 

through protocol surveys that spotted owls are not nesting the year of the proposed 

project or locates a nest and is able to buffer the breeding owls from noise throughout the 

breeding season, then this restriction would not apply. Other options include documenting 

topographic buffers in specific PACs or using a noise tampering technology to reduce 

noise impacts. 

314. Management activities within PACs and restricted habitat shall be coordinated and 

implemented to reduce potential disturbance to Mexican spotted owls. For example, 

where possible, thinning and/or burning activities associated with habitat adjacent to 

PACs will be coordinated with overall PAC thinning and/or burning activities in order to 

minimize the frequency and duration of operations within and immediately adjacent to 

these areas.

315. The Forest, in coordination with the USFWS, shall develop contingency plans in the 

event of new PACs being established or PAC boundary modifications due to owl 

movement or habitat changes. Flexibility shall be built into the project (including task 

orders) so that as owls move or new sites are located, project activities can be modified to 

accommodate these situations.

316. The Forest shall ensure that all contractors associated with thinning and burning 

activities, transportation of equipment and forest products, research, or restoration 

activities are briefed on the Mexican spotted owl, know to report sightings and to whom, 

avoid harassment of the owl, and are informed as to who to contact and what to do if a 

Mexican spotted owl is incidentally injured, killed, or found injured or dead on the Santa 

Fe National Forest. If an owl fatality is discovered, the USFWS Mexican spotted owl lead 

will be contacted as soon as possible.

317. Haul trucks will not exceed 25 miles per hour on Forest Service System Roads in the 

project area.
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308 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The following terms and conditions will implement reasonable and prudent measure 2:

318. The Forest shall coordinate management activities within PACs and restricted habitat in 

order to reduce effects to habitat from multiple entries that can disturb owls and result in 

adverse effects to habitat. 

319. The Forest shall meet annually with the USFWS to discuss the upcoming year’s 

thinning and burning plans in Mexican spotted owl habitat and review the past year’s 

thinning and burning activities in owl habitats. 

The following terms and conditions will implement reasonable and prudent measure 3:

320. The Forest shall monitor the effects of mechanical thinning and prescribed burning on 

owl occupancy and reproduction, and key habitat components (as defined in the Revised 

Mexican spotted owl Recovery Plan, table C.2) in all six PACs. Owl occupancy and 

reproductive data shall be collected for at least two years prior to treatment and two years 

post-treatment. Vegetation data should be collected pre-treatment and at defined intervals 

post-treatment. The specific plan development, selection of PACs, and monitoring 

framework, shall be developed in coordination with the USFWS (including the Mexican 

spotted owl lead) and Santa Fe National Forest Staff to ensure coordination with other 

projects and monitoring efforts. This monitoring plan shall be designed and implemented 

to evaluate the effects of thinning and prescribed fire on owl occupancy and reproduction, 

and retention of or movement toward desired habitat conditions within PACs.

321. The Forest shall monitor the impacts of incidental take resulting from implementation 

of the proposed action and report these findings to the USFWS. Incidental take 

monitoring shall include information such as when the project was implemented, whether 

the project was implemented as proposed and analyzed in this BO (including 

conservation measures and best management practices), breeding season(s) over which 

the project occurred, relevant owl survey information, and any other pertinent 

information about the project’s effects on the species.

322. Annual reports will describe actions taken under this proposed action and impacts to the 

owl and its critical habitat. The annual report shall be sent to the New Mexico USFWS 

Ecological services field office and the USFWS Mexican spotted owl species by March 1

of each year. 

Conservation Measures

Purpose: Conservation measure to avoid, improve, or minimize effects 

on species and habitat.

323. The Forest will work with the USFWS to conduct Mexican spotted owl surveys over 

the next several years to attempt to determine how owls modify their territories in 

response to wildland fires on the Santa Fe National Forest. This information will aid in 

understanding the short- and long-term impacts of fire on the owl, and its subsequent 

effect on the status of the species in the SRM EMU. Surveys would be coordinated with 

the USFWS prior to implementation of any project.

324. The Forest will continue to work with the USFWS to design forest restoration 

treatments across the Santa Fe National Forest that protects existing nest/roost habitat 
Appendix A. Design Features, Best Management Practices, 

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FEIS for the Southwest Jemez Mountains Landscape Restoration Project 309

from high-severity, stand-replacing fire, and enhance existing or potential habitat to aid in 

sustaining Mexican spotted owl habitat across the landscape. PACs can be afforded 

substantial protection from wildland fire by emphasizing fuels reduction and forest 

restoration in surrounding areas outside of PACs and nest/roost habitat.

Jemez Mountains Salamander

Design Features 

Purpose: Conservation measures to avoid, improve, or minimize 

effects on species and critical habitat.

325. Springs or seeps found in wet mixed conifer in Jemez Mountains salamander critical 

habitat will not be treated.

326. Burning during the salamander restriction period will be conducted when most or all 

salamanders would not be surface active because salamanders are only surface active 

when environmental conditions are wet enough to keep their skin moist, which generally 

is too wet to carry fire.

327. General habitat elements will be monitored before and after treatment implementation 

through fire effects monitoring plots. The Forest is currently collecting this information 

using the fire ecology crew at Bandelier National Monument.

328. The Forest is working with Rocky Mountain Research Station, Fire Sciences 

Laboratory on a project designed to evaluate prescribed fire burn intensities near 

archeological sites and its influence on large logs. The Forest will look for opportunities 

to use these data where feasible to reduce impacts to salamander habitat features from 

prescribed burning activities.

329. The Forest will target some salamander survey efforts in aspen stands to assess 

salamander occupancy in this forest type.

330. Slash in aspen treatment areas will be managed to generate only enough slash to burn at 

low to moderate fire intensities to achieve desired results in aspen stands. Approximately 

5-7 tons per acre will be left onsite. Excess wood will be removed to prevent a hot fire 

from damaging the soil.

331. With the exception of aspen treatments, creation of openings in mixed conifer in 

designated critical habitat for the salamander will be one acre or smaller.

332. Roads causing damage to hydrological resources, cultural resources or threatened, 

endangered, and sensitive species habitat are a priority for decommissioning.

333. The Forest will work with the USFWS during annual meetings to identify the locations 

of road decommissioning and the level of effort that will be needed to protect 

salamanders. 

334. The Forest will rehabilitate all equipment staging area, log landings, skid trails, 

temporary roads, and firelines at the end of the project. Rehabilitation may include 

returning the ground to natural contours, implementing decompaction and erosion control 

measures as needed, pulling slash and rocks across firelines, disguising entrances, and 

covering bare soil with slash, chips, needles, or cut brush as necessary, and reseeding 

with native seeds as needed. Any rehabilitation that disturbs the soil, rocks, woody debris, 
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310 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

or potential cover objects in designated critical habitat for the salamander will occur 

when conditions are dry or frozen, or outside of the surface activity season for the 

salamander. 

335. On areas to be prescribed burned, fire prescriptions will be designed to minimize soil 

temperatures over the entire area. High intensity fire should occur on 10% or less of the 

entire area. Fire prescriptions will be designed so that soil and fuel moisture are such that 

fire intensity is minimized and soil health and productivity are maintained. Fire effects 

monitoring plots will be used to assess percentage of high intensity fire that occurred over 

prescribed burn areas.

336. Areas for old growth management will be prioritized stands within or adjacent to owl 

protected activity centers; goshawk post-fledging family area; Jemez Mountains 

salamander locations, salamander designated critical habitat, and visually-sensitive areas.

337. The Forest will work with the USFWS to identify how to best implement silviculture 

treatments in wet mixed conifer. 

338. Disturbance of soil, rocks, boulders, and large woody debris in designated critical 

habitat will be avoided to the greatest extent practical.

339. Any activity that uses heavy machinery will only occur in designated critical habitat for 

the salamander when soils are dry or frozen unless there is an exemption. Working when 

soils are dry or frozen will reduce the risk of crushing salamanders, as they are unlikely 

to be impacted when soil is dry of frozen, and will minimize compaction of soil.

340. For road maintenance and decommissioning activities, heavy machinery may be used at 

times when the soil is not dry or frozen, but will be kept strictly to existing compacted 

road surfaces (and will not enter the shoulder of the road) in designated critical habitat for 

the salamander unless otherwise agreed upon and documented between the Forest and 

USFWS.

341. As much as practicable, ignite prescribed fire in in a manner to minimize torching 

within occupied salamander habitat.

Critical Habitat:

342. Implement meadow treatments as described in the proposed action. 

343. Implement cultural resource protection treatments as described in the proposed action. 

344. Treat seeps and springs at the upper end of the basal area range based on vegetation 

type in ponderosa pine and dry mixed conifer. 

345. Implement riparian treatments as described in the proposed action. 

346. Do not build temporary roads in critical habitat. 

347. No new ground disturbance in potential road decommissioning sites. 

348. In ponderosa pine, leave a residual stand with a basal area of 60 to 80.

349. In dry mixed conifer, leave a residual stand with a basal area of 80 to 100.
Appendix A. Design Features, Best Management Practices, 

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FEIS for the Southwest Jemez Mountains Landscape Restoration Project 311

Mitigation Measures

Purpose: Conservation measures to avoid, improve, or minimize 

effects on the Jemez Mountains salamander and its critical 

habitat.

350. Do not cut Douglas-fir for bank stabilization treatments in critical or occupied habitat 

for the Jemez Mountains salamander.

351. Avoid building or making jackpot piles of slash on top of existing large logs.

352. Burn jackpot piles as soon as possible, preferably within one year of creation, to 

minimize salamander colonization and use of piles as habitat, in critical habitat. 

353. Burn piles before broadcast burning to reduce fire intensity and heat penetration into the 

soil within critical habitat. 

354. Firelines for prescribed fires will not be constructed in critical habitat during the 

salamander restrictive season of June 15 through October 30. 

355. Use of heavy machinery, and other activities, with the exception of burning, that could 

directly affect salamanders that are active above ground (surface active) will only be 

conducted when ground is frozen or dry, and outside of the salamander restriction period, 

June15 through October 30. If seasonal rains begin earlier than June 15, any activity that 

could directly affect salamanders will not occur in designated critical habitat. Exemptions 

to implementing activities (except burning) during the salamander restriction period (June 

15 through October 30), or when salamanders may be surface active that could directly 

affect salamanders that are surface active will only be done with coordination and

agreement between the Forest and USFWS.

356. Soil and watershed BMPs in this appendix will be followed to protect salamander 

habitat.

357. Disturbance around road decommissioning sites will attempt to stay in the compacted 

footprint of the road except where re-establishment of contours or re-connecting natural 

drainages are required to address water quality or watershed issues. New ground 

disturbance along the edges will be minimized.

358. The Forest will leave 10-15 tons per acre of downed logs greater than 12-inches 

diameter in dry mixed conifer and 3 snags per acre, on average. Douglas fir trees will be 

favored for placement in designated critical habitat for the salamander.

359. The Forest will limit new landings in salamander critical habitat to 0.25 acres.

360. The Forest will attempt to make no more than three passes on a skid trail, as research 

shows compaction greatly increases after a third pass.

Purpose: Comply with the terms and conditions as outlined in the 

USFWS Biological Opinion. 

The Forest will implement the following Terms and Conditions as outlined in the Biological 

Opinion unless the USFWS approves deviation from these terms and conditions through sitespecific project consultation. 
Appendix A. Design Features, Best Management Practices, 

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312 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The following terms and conditions will implement reasonable and prudent measure 1:

361. The Forest shall ensure that all contractors associated with thinning and burning 

activities, transportation of equipment and forest products, research, or restoration 

activities are briefed on the Jemez Mountains salamander, important habitat features to 

avoid when practicable, and are informed of the conditions salamander are typically 

surface active (moist soil at about 12 degrees C or 54 degrees F), and who to contact and 

what to do if a Jemez Mountains salamander is observed or incidentally injured, killed, or 

found injured or dead on the Santa Fe National Forest. If a salamander injury or fatality is 

discovered, the USFWS Jemez Mountains salamander lead will be contacted as soon as 

possible. 

362. When seeking an exemption to the salamander restriction period, June 15 through 

October 30, the Forest shall develop a methodology or protocol that will be used to assess 

site specific environmental conditions and criteria used for determining suitability for 

surface activity for conducting work in salamander critical habitat. The coordination 

between the Forest and USFWS should be documented for the project record.

The following terms and conditions will implement reasonable and prudent measure 2:

363. The Forest shall demonstrate that treatments that affect Jemez Mountains salamander or 

its designated critical habitat will be implemented in a staged manner so that effects can 

be dispersed over time and space, learning can take place, and new information can be 

applied to future treatments to minimize adverse effects to those species and habitat. The 

staged implementation may be coordinated and documented with the USFWS at annual 

meetings, or presented as an entire detailed implementation schedule prior to project 

implementation.

364. The Forest shall apply soil and watershed health and function design features stated on 

page 298 of the DEIS to salamander critical habitat to minimize effects to salamander 

primary constituent elements.

365. The Forest shall limit aspen treatments to 2 acres in size in designated critical habitat 

until the Forest is able to collect and present information regarding effects of the 

treatments on the salamander or its habitat. Subsequent to receiving this information, the 

Service may approve in writing conducting aspen treatments up to 10 acres in size in 

designated critical habitat.

366. Material (e.g. rocks, boulders, logs) used for any treatment such as instream habitat 

restoration, headcut, or stabilization treatments, and site closings will not be removed 

from designated critical habitat.

367. The Forest will assess soil compaction resulting from heavy machinery using the first 

two treatment blocks in designated critical habitat and determine affects to salamander 

PCEs. Soil compaction data should include soil type or types, pre-treatment compaction 

data, equipment type used and, and relevant environmental or biophysical parameters 

present during treatment. The Forest shall report to the USFWS findings of compaction 

assessment in salamander critical habitat and any potential mitigations or BMPs that are 

developed to reduce effects of compaction. 

368. The Forest shall develop BMPs, or work with the Service to develop BMPs, on how to 

best rehabilitate areas that have been impacted by new firelines in designated critical 
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FEIS for the Southwest Jemez Mountains Landscape Restoration Project 313

habitat. Development of BMPs and rehabilitation of new firelines shall occur within one 

year burn.

369. The Forest will use the data collected from the before and after treatment 

implementation fire effects monitoring plots to better understand how structural habitat 

features such as woody debris may be affected by burning activities. Results will be 

assessed and reported, with any potential BMPs or mitigation that may be developed 

within one year of collection to the USFWS.

370. The Forest will continue to work with the USFWS to develop additional BMPs to 

minimize impacts to the salamander, its designated critical habitat, and potential critical 

habitat.

371. Heavy machinery or other equipment used for treatments to restore instream habitat or 

used in aquatic systems will be cleaned of all soil, mud, and debris followed by 

disinfection with approved chemicals prior to moving equipment into undisturbed areas 

(e.g. outside of existing road beds) occupied or potentially occupied by salamanders to 

minimize the risk of spreading or introducing amphibian pathogens.

372. The Santa Fe National Forest shall meet annually with the USFWS to discuss the 

upcoming year’s implementation schedule for the proposed action, including thinning 

and burning plans in Jemez Mountains salamander critical habitat and potential habitat 

and review the past year’s thinning and burning activities in salamander habitat and 

review the development of an occupancy model or other scientifically sound equivalent.

The following terms and conditions will implement reasonable and prudent measure 3:

373. The Forest shall monitor the impacts of incidental take resulting from implementation 

of the proposed action and report these findings to the USFWS. Incidental take 

monitoring shall include information such as when the project was implemented, whether 

the project was implemented as proposed and analyzed in this BO (including 

conservation measures and best management practices), acreages of habitat affected and 

how, salamander survey information, and any other pertinent information about the 

project’s effects on the species or its habitat.

374. Annual reports will describe actions taken under this proposed action and impacts to the 

salamander and its critical habitat. The annual report shall be sent to the New Mexico 

USFWS Ecological Services field office by March 1 of each year.

Conservation Measures

Purpose: Conservation measure to avoid, improve, or minimize effects 

on species and habitat.

375. The Forest will work with the USFWS to develop a strategy that provides for long term 

management and recovery of the salamander. This includes:

a. not avoiding treatments in designated critical habitat for the salamander or potential 

salamander habitat, but rather continue to pursue how to best implement treatments to 

minimize impacts to salamanders and their habitat while improving habitat

conditions and reduction of risk of high severity wildfire throughout the range of the 

salamander on Forest Service lands;
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314 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

b. continuing to work with the USFWS in identifying the occupied range of the species 

in potential habitat; and

c. continuing to work with the USFWS to conduct targeted salamander surveys in 

potential habitat. 

376. The Santa Fe National Forest will work with the USFWS to develop an occupancy 

model or scientifically sound equivalent that can be used to assess occupancy or changes 

in occupancy through time while taking into account factors that affect the probability of 

detection of the salamander.

Meadow Jumping Mouse

Design Features

Purpose: Conservation measures to avoid or minimize effects on 

species and habitat.

377. Install fencing to protect the bank on instream habitat restoration and stream channel 

treatments around both the new and old channel and native riparian planting (for bank 

stabilization).

378. Riparian restoration on San Antonio Creek and Rio Cebolla, will be prioritized to 

improve habitat at known jumping mouse locations.

379. Bank stabilization will be selected for those perennial streams needing actions to 

improve a 303-d listing or needed for aquatic habitat improvement. 

380. Project activities with heavy equipment will take place outside of the jumping mouse 

active season. Use of locally available material will be considered.

381. Follow riparian streamcourse buffers within proposed Critical Habitat:

a. Severe erosion hazard: 120 feet on each side of streamcourse.

b. Moderate erosion hazard: 100 feet on each side of streamcourse.

c. Slight erosion hazard: 70 feet on each side of streamcourse.

Fire and Fuels management within proposed Critical Habitat: 

382. In areas to be prescribed burned, establish filter strips (also known as Aquatic 

Management Zones). These stream reaches will be designated as a protected 

streamcourse.

383. Fuels will not be ignited within this buffer area, though fire would be allowed and is 

expected to creep into the buffer.

384. Avoid, minimize, or mitigate adverse effects of prescribed fire and associated activities 

on soil, water quality, and riparian resources that may result from excessive soil 

disturbance as well as inputs of ash, sediment, nutrients, and debris into waterways.

Headcut Treatments within proposed Critical Habitat: 

385. Use hand treatments at those locations without road access or those areas needing less 

(mechanical) disturbance due to resource concerns (soils, cultural, wildlife).
Appendix A. Design Features, Best Management Practices, 

Mitigations and Monitoring for Alternatives 1, 3, 4, and 5

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 315

Riparian Area Restoration within proposed Critical Habitat:

386. Best effort will be made to use immediate, locally available material and plants.

387. Where vegetation has been severely impacted, planting of riparian shrubs (i.e., willow) 

and transplanting of sedges may be done within the exclosures.

Road Decommissioning within proposed Critical Habitat:

388. Roads causing damage to jumping mouse proposed Critical Habitat are a priority for 

decommissioning.

Conservation Measures

Purpose: Conservation measures to avoid, improve, or minimize 

effects on species and habitat.

389. The Forest will work with the USFWS to develop a strategy that provides for long-term 

management and recovery of the meadow jumping mouse. This includes: 

Completion of comprehensive jumping mouse surveys within areas that have not been 

surveyed since 2005 and 2006, but also in areas that contain suitable habitat. Surveys 

should also be conducted within areas where riparian vegetation is restored to document 

project success. This information will greatly assist all parties in gaining a better 

understanding of the current status and whether habitat restoration leads to additional 

populations of the species. The USFWS will discourage the Forest from assuming future 

projects within potential jumping mouse habitat are occupied or continued to be occupied 

in lieu of conducting up-to-date survey.

Wildlife Habitat Treatments

Design Features

Purpose: Conservation measures to avoid or minimize effects on 

species and habitat.

390. Monitor the effects on peregrine falcon through occupancy surveys during the breeding 

season. 

For all treatments to screen water sources from human disturbance:

391. Plant vegetation at existing developed water sources near roads or in open (visible) 

areas throughout the project area. 

392. Use hand or mechanical methods for planting. 

For all treatments to increase water sources for wildlife:

393. Water sources may include trick tanks, earthen tanks, drinkers, and other types of 

developed water sources. 

394. Earthen dams would not be placed in stream channels.
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316 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

395. Screen water sources where necessary using design features listed above.

396. Provide ramps in water tanks, as necessary, to allow small animals to escape.

For all treatments to create snags:

397. Work would be done throughout project area in stands lacking large diameter (greater 

than 16 inches) snags or that do not meet forest plan standards.

398. Create snags by girdling trees or other means. 

Purpose: To minimize effects on neotropical migratory birds.

399. When designing site-specific projects, consider avoiding vegetation disturbance during 

the peak breeding season: May 15 through July 31 (estimated peak bird breeding season 

at higher elevations in this project area).

Mitigation Measures

Purpose: Conservation measures to avoid, improve, or minimize 

effects on species and habitat.

400. Around active elk wallows and seeps, preferentially select groups of understory trees to 

provide desired screening.

401. All work within the channel of Rio Grande cutthroat trout (RGCT) occupied streams 

will be avoided from March 1 to July 15th to minimize effects to spawning fish. 

402. In-stream and riparian restoration activities will take place after RGCT spawning during 

base-flow conditions, and on dry or frozen riparian soil conditions where possible. 
FEIS for the Southwest Jemez Mountains Landscape Restoration Project 317

Appendix B. List of Projects for Assessing 

Cumulative Effects

Project Name General Location Description

San Juan Prescribed Burn Northern San Juan Mesa Prescribed fire 

(7,306 acres)

Thompson Ridge Prescribed 

Burn 

Around Thompson Ridge 

community

Prescribed fire 

(1,161 acres)

Stable Prescribed Burn On Stable, Holiday, and 

Schoolhouse Mesas

Prescribed fire 

(6,200 acres)

San Diego Prescribed Burn Gilman and Peggy Mesa area Prescribed fire (14,521 acres)

San Antonio Well San Antonio Canyon Water well re-drill

Cebolla Riparian Fence East of FR376, along Upper 

Rio Cebolla

Buck and pole fence construction

Virgin Mesa Pipeline Virgin Mesa Pipeline repair project

Lake Fork Pipeline Lake Fork Mesa Pipeline repair project

Cebolla Cross Fences Upper Rio Cebolla Fence construction

Las Conchas Meadow 

Restoration

Las Conchas picnic area 

vicinity

Small area – cut edges of meadow

Cat Mesa Tank Cleanout Located on Cat Mesa Tank is a small area, already disturbed

Vallecitos Area Thinning Around Sierra Los Pinos 

community

Thinning (~800 acres)

Chaparral Thinning and 

Burning

West of Rio Guadalupe along 

district boundary

Project footprint is 20,619 acres

East Fork Trailhead (CFRP) 

Thinning

Trailhead is along NM 

HWY 4

State Tree thinning outside and inside of developed 

trailhead area (2.5 acres)

Redondo Campground 

Thinning

Campground is along NM 

State HWY 4

Thinning 

(125 acres)

Jemez Falls Campground 

Thinning

Campground is along NM 

State HWY 4

Thinning 

(210 acres)

Paliza Campground Thinning Campground along FR 10 Thinning 

(106 acres)

Thompson Ridge 

Mastication and Thinning 

Around Thompson Ridge 

community

Mechanical thinning (233 acres)

Virgin Mesa Thinning East side of Virgin Mesa above 

Jemez Springs

Thinning 

(317 acres)

Monument Canyon 

Mastication

Research section on San Juan 

Mesa

Mechanical thinning (~230 acres)

Area Closures FR376 corridor, San Diego 

Canyon urban interface, East 

Fork of the Jemez River

Primarily to restrict dispersed overnight 

camping

San Antonio Hot Springs 

Parking Lot

Hot Springs along FR 376 

north

Constructed eight vehicle parking area

New Bridge across San 

Antonio Creek

San Antonio Creek at San 

Antonio Hot Springs

Replaced deteriorated vehicle bridge with 

pedestrian bridge for trail crossing

Bridges along East Fork of 

the Jemez River

Bridges associated with Trail 

137

Installation of nine new bridges along 

established hiking trail
Appendix B. List of Projects for Assessing Cumulative Effects

318 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Project Name General Location Description

Spence Hot Springs Parking 

Lot

On NM State HWY 4 Constructed seven vehicle parking area 

Respect the Rio Rio Guadalupe corridor Restoration and education program focused 

on water quality

Rebuilt Campgrounds at San 

Antonio and Paliza

San Antonio CG located on 

NM State HWY 126; Paliza CG 

located on FR 10, about two 

miles north of Ponderosa

Renovated (rebuilt campgrounds)

Paving of NM State HWY 

126

Fenton Lake to the Rio de las 

Vacas

Paving of state highway for approximately 10 

miles, section was not previously paved

East Fork Trailhead Parking 

Area 

Trailhead along NM State 

HWY 4

Constructed 28 vehicle parking area

Oat Pony and Hay Canyon 

Thinning/Meadow 

Restoration

Canyons along Rio Cebolla Thinning 

(314 acres in project area – meadows were 

open already, smaller actual area of thinning) 

Maintenance of 

Earthen/Trick Tanks

Throughout the analysis area Tank is a small area, already disturbed

Redondo and San Antonio 

Exclosures

Along Redondo and San 

Antonio Creeks

Linear fences

Meadow Thinning in Peralta Peralta Canyon Small area – cut edges of meadows in 20 acre 

project area

Mistletoe Thinning Jemez Pueblo land on Borrego 

Mesa

Thinned 60 acres on the Pueblo land within 

the SWJ boundary

Banco Bonito Thinning and 

Prescribed Burn 

SW corner of the Valles 

Caldera NP

Thinning and prescribed burning (352 acres)

FR 10 and 376 Maintenance Length of FR10 and southern 

FR 376

Routine road maintenance in the existing road 

prism within previously maintained surfaces, 

ditches, culverts, etc.

Pumice Mining El Cajete Mine, El Cajete 

Expansion (future), Utility 

Block Mine and Cerro del Pino 

Rehabilitations, Boone-Duran 

2010 (future), South Pit 

Rehabilitation, South Pit 

Expansion (future)

The pumice mines currently cover 83 acres. 

The proposed expansions will include 122 

acres.

There have been 22 acres rehabilitated.
FEIS for the Southwest Jemez Mountains Landscape Restoration Project 319

Appendix C. Response to Comments on the 

DEIS

This appendix is a summary of public and agency comment received by the Santa Fe National 

Forest (the Forest) regarding the Southwest Jemez Mountains Landscape Restoration Project 

Draft Environmental Impact Statement (DEIS), and responses to those comments prepared by the 

Forest. The comment period was February 28, 2014 to April 15, 2014. We received 25 comment 

letters. Two letters were submitted after the deadline and were analyzed, but are not included in 

the responses. 

How We Analyzed the Comments 

All comments were entered into the Comment Analysis and Response Application (CARA), an 

online database used for managing and storing comments. The comment letters are available in 

the Public Comment Reading Room for this project. 

Next, the interdisciplinary team read and coded the comments. The comments were defined as (1) 

comments, (2) requests for action, and (3) opinions. Each specialist reviewed and responded to 

the comments related to their resource. 

We identified several common themes in the comments and developed a concern statement and 

response for each theme. Responses to the common themes are intended to avoid repeating the 

same or similar answer. Responses to these common themes are presented first and are followed 

by detailed responses to individual comments. 

The individual responses are arranged by letter number. Letter numbers were assigned by the 

CARA program and are based on the order the letters were received. Comment numbers were 

also assigned by the CARA program. Some comments are paraphrased, and others are taken 

directly from the text of the letter. The individual letters are found in the project record and on the 

Web, in the public comment reading room (http://go.usa.gov/BUVh). 

Comments were received as follows:

Letter 1 Mary Nelson

Letter 2 Delores Kincaide

Letter 3 J. Wasilewski

Letter 4 Charles Cassagnol

Letter 5 Dick Artley

Letter 6 Michael Tompson

Letter 7 Nancy Kings

Letter 8 Susan Ostile, Great Old Broads for Wilderness
Appendix C. Response to Comments on the DEIS

320 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Letter 9 Chris Zebrowski 

Letter 10 Randy Crutcher 

Letter 11 Morgan R. Nelson, New Mexico Environment Department 

Letter 12 Deborah Post 

Letter 13 Steve Spencer, U.S. Department of Interior 

Letter 14 Sue Gunkel, Great Old Broads for Wilderness 

Letter 15 William Lawrence Baker, University of Wyoming

Letter 16 Rhonda Smith, U.S. Environmental Protection Agency 

Letter 17 Mary Peck

Letter 18 Arthur Firstenberg 

Letter 19 Jan Boyer, Once a Forest

Letter 20 Anne Bradley, The Nature Conservancy

Letter 21 Jose J. Varela Lopez, New Mexico Forest Industry Association

Letter 22 Bryan Bird, WildEarth Guardians 

Letter 23 Colston Chandler, University of New Mexico

Letter 24 Jay Lininger, Center for Biological Diversity

Letter 25 Virginia Seiser
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 321

Responses to Common Themes 

Large Trees

Comments 4.4, 7.1, 8.4, 8.9, 10.2, 12.4, 12.5, 14.3, 17.3, 17.4, 19.3, 20.1, 

22.29, 24.9, 24.11, 24.12, 24.27, 25.4 

Concern 1 

The DEIS does not indicate whether, or to what degree, the Forest Service may have considered 

implementation of the Old Growth Protection and Large Tree Retention Strategy (LTRS) which 

was collaboratively developed by public stakeholders for implementation in the Four Forest 

Restoration Initiative(4FRI). Given the rarity of large trees and the overabundance of small trees, 

a high burden of justification applies to a proposed action that would remove trees larger than 16-

inches diameter in a project framed around the need for ecological restoration. 

We recommend you clarify the existing distribution of larger trees more specifically. The DEIS 

on page 184 states “We estimate that less than 10 percent of the trees larger than 16 inches would 

be removed to create openings and group structure.” 

Response

The Forest did consider an LTRS, similar to the one developed for 4-FRI. We found, however, 

that an LTRS would be a cumbersome administrative process that focused on what is removed, 

not what is left on the ground, to meet the ecological restoration needs of the landscape. Retaining 

large trees and old growth is built into our purpose and need (DEIS, p. 13). It describes a 

landscape with a mosaic of age and size classes. The large and old growth trees would occur in 

groups well distributed across the landscape.

The table below displays the existing diameter distribution of trees at the stand level throughout 

the area. It shows that there is an abundance of medium size trees (5-18-inches diameter) and less 

than the desired distribution for trees greater than 18 inches. The desired diameter distribution for 

VSS 5 and 6 (larger trees) includes 40% (20% in each class) on all acres throughout the 

landscape. Our mechanical treatments are designed to retain, or if they are lacking, promote large 

and old growth trees (greater than 18-inches diameter). Additionally within all age classes, 

including the mid-sized trees (12-18- inches diameter), the design criteria call for retaining 

dominate and co-dominate trees. 

VSS 1 VSS 2 VSS 3 VSS 4 VSS 5 VSS 6

Pretreatment<1% <1% 52% 35% 9% 2%

Posttreatment10% 10% 19% 44% 12% 5%

Desired 

Condition

10% 10% 20% 20% 20% 20%

Given the above landscape objectives and the current size distribution of trees in the project area, 

few large trees would be cut. There is an abundance of medium size trees (5-18-inches diameter), 

so that is mostly what would be cut. Because there are fewer large trees (greater than 18-inches 

diameter), most of them would be left unless there was a reason to cut one here or there. In 
Appendix C. Response to Comments on the DEIS

322 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

response to these comments, we have added information to clarify the other factors that we will 

consider when making decisions about large trees (see the silviculture specialist report, pp. 5-6).

We have also described the diameter distribution of the larger trees more specifically. In order to 

display the diameter distribution of the trees that would be left after treatments, we established 

and marked plots in the project area. We established 5-acre plots in four stand conditions and used 

the design criteria described in the FEIS to guide the marking. The chart below shows both the 

cut and leave trees from the plot data collected on the four stands. Most of the trees that are cut 

are in the smaller diameter classes- 5-12 inches. Some large trees are removed, but most of those 

are the smallest of the large trees. Very few trees above 16-inches diameter are cut.

Finally, the Forest will continue to work with its collaborative partners during project 

implementation and to share information about how specific treatment decisions comply with the 

design criteria of the Proposed Action. 

Another aspect of the treatments related to large trees is vegetative diversity at the landscape, 

stand, and group scales. 

Landscape Scale: The landforms are quite diverse, with canyons and mesas running in different 

directions, some north-south; others, east-west, at all angles. This creates a variety of slope 

aspects that affects the vegetative composition and diversity. South-facing slopes are generally 

more open, and north-facing slopes are fairly dense. The north-facing slopes will be kept denser 

than average. East- and west-facing aspects are in-between. Denser forests tend to be found at 

higher elevations. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 323

Disturbance also affects landscape diversity. Previous fires over the last 45 years have created 

varying forest conditions; some areas are meadows, some have oak and aspen patches, and others 

have young pine. These conditions will remain- there is nothing we can do to change them. 

Prescribed fire or managed wildfires will burn over large areas and will create varying conditions. 

Slopes over 40% will not receive restoration treatments and will remain dense.

Stand Scale: Our treatment prescriptions are also variable and based on different parameters, 

such as denser groups with smaller interspaces in dry mixed conifer than in ponderosa pine. The 

dry mixed conifer is often interspersed amidst the pine, creating existing variability that we will 

work with and keep. These prescriptions will result in denser forests on steep hills, more open on 

the flat ground areas, and very open in the swales, thus creating a meadow feel. Tree groups will 

vary in size and openings will range from 0.1 to 4 acres. These tree groups will also vary in 

shape, determined by where trees are growing now. The existing forest will influence the 

treatment. Tree density and pattern will be fitted to the topography. 

Within each treatment unit, 10-15% of the area will be in openings, about 10% in aspen, if 

present, 10% in seedlings and saplings, and, as much as possible, 10-20% in large trees. The 

remainder will be medium-sized trees. These areas will also be broken up by interspaces and 

openings so they are less homogenous. Oaks with a “tree form” will be released to grow larger. 

All tree species, including white fir and limber pine, are being kept to maximize diversity. 

Areas with dwarf mistletoe will be less dense and have larger openings. We will also select for 

species not affected by mistletoe. This will increase species diversity within the stand. After the 

cutting treatments, prescribed fire will be used to dispose of slash; this might kill additional 

scattered trees. Natural ignitions could be allowed to burn, and this may create even more 

heterogeneity. See the table above for the VSS distribution. 

Group Scale: Groups will range from 0.1 to 4 acres, and will have different shapes (round, linear, 

odd) and densities (50-70 basal area, with variation based on existing density). Species 

composition will also vary, with all four conifer species represented. The increased openness will 

allow oak and aspen to thrive where they are present. We will incorporate natural variation. Gapcreating processes, such as lightning-struck trees or pockets of root rot or bark beetle-killed trees 

will continue to create small openings both within and outside the treated stands. 

Climate Change

Comments 4.3, 4.4, 8.9, 12.1, 12.2, 12.3, 17.2, 17.3, 19.1, 19.3, 20.2, 22.1, 

22.18, 22.19, 22.20, 22.22, 22.23, 22.24, 22.25, 22.26, 25.5 

Concern 1

The DEIS does not include the emissions from proposed treatment operations in each action 

alternative. The Forest Service failed to conduct a meaningful analysis of these impacts and 

instead avoided a substantive discussion by simply stating that the project “[t]he amount of 

greenhouse gases produced under any alternative is small on a global scale and calculating its 

impact would be very complex and is beyond the scope of this analysis.” 

The climate change analysis “does not evaluate the “incremental impact” that these emissions 

will have on climate change or on the environment more generally in light of other past, present, 

and reasonably foreseeable actions such as other light truck and passenger automobile CAFE 
Appendix C. Response to Comments on the DEIS

324 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

standards. This non-discussion is an abdication of the Forest Service’s statutory duties under 

NEPA. 

Response

Table 3 in chapter 2 of the DEIS summarizes emissions from prescribed fire proposed for each 

action alternative. Chapter 3 of the EIS includes a section on air quality and includes estimated 

carbon dioxide (CO2) emissions for each alternative. Prescribed burning represents 99%of the 

CO2 equivalent emissions under each alternative. We have updated the FEIS to include CO2

emissions from treatments other than prescribed fire. The analysis shows that fossil fuel 

emissions associated with mechanical harvesting, timber hauling, gravel pit operations, and road 

maintenance and construction total 2,100 metric tons over the life of project, or less than one 

percent (.09%) of the total CO2 emissions over the entire life of the project. This is equivalent to 

1.5 hours of carbon dioxide emissions from an average coal-fired power plant in the U.S. or 

approximately 473 passenger vehicles per year (USEPA 2014). For more, details see the Air 

Quality section of the FEIS and the air quality specialist report. 

The air quality specialist report has been updated to provide a discussion on the level of emissions 

in context of past, present, and foreseeable future projects. The analysis discloses the relative 

magnitude of the emissions contribution to climate change and found that direct effects over the 

life of the project would be insignificant. Therefore the incremental impact of the project and 

coupled with the emissions mentioned by the commenter would be extremely difficult if not 

impossible to measure. 

Concern 2 

The DEIS and Climate Change specialist report do not adequately address the issue of climate 

change and carbon budgets. The NEPA analysis should start with an accurate and up-to-date 

inventory of carbon storage and carbon flows on federal land. 

The project should be modified to include a mathematical model that maximizes carbon 

sequestration by manipulating ponderosa pine size distributions. Recently, it has been determined 

that large diameter trees fix larger amounts of carbon than small diameter trees. 

At a minimum, the forest must mitigate for atmospheric carbon loading by retaining large trees 

because they sequester larger amounts of carbon than smaller trees. 

Response

Carbon flows are often compared to a leaky bucket. There tends to be a dynamic balance over the 

long term- carbon flowing into the system equals carbon flowing out of the system- the leaky 

bucket. Vegetation absorbs carbon during its lifetime and releases it to atmosphere when it 

decays. But when carbon from fossil fuels flows into the system, much of it cannot be absorbed, 

and the bucket overflows. We expect an initial loss of carbon following treatments such as 

prescribed fire and mechanical thinning (Dore et al. 2012; Fulé 2012; Honig and Fulé 2012; 

Stephens et al. 2012). After a few years, however, we expect the treated forest to serve as a 

carbon “sink”, absorbing more carbon dioxide from the atmosphere than released (Earles et al. 

2014; Sorensen et al. 2011). 

Maximizing carbon sequestration is not a part of the purpose and need for this project. Our 

overarching goal at the landscape level is to restore ecosystem structure and function and increase 

resilience to undesirable, large-scale disturbances such as uncharacteristically severe wildfire, 

insect outbreaks and climate change in the Southwest Jemez Mountains. Hurteau and North 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 325

(2008) and Hurteau et al. (2008) concluded that management of carbon in fire-prone and fireadapted forests is more complex than simply minimizing wildfire carbon emissions and 

maximizing stored carbon in individual stands. We believe that a resilient forest is better able to

capture and store carbon efficiently as compared to a landscape that is vulnerable to the 

catastrophic loss of both stored carbon and carbon sequestration potential. 

Concern 3 

The DEIS does not take into adequate account climate change forecasts for the Southwest or

consider the dramatic effects we are experiencing due to climate change in the Southwest. 

Therefore the analysis should use a mathematical model that addresses sustainability of the forest. 

There is a concern that climate change may prevent regrowth of large-diameter trees in the cutover areas. 

Response

Climate change research appropriate for the Southwest Jemez Mountains was considered over 

research that was either more general or representative of other ecosystems both globally or in 

North America (Pacific Northwest and Canada). The research on climate forecasts we used is 

summarized in Southwestern Region Climate Change Trends and Forecasts (USFS 2010c).

Climate change was considered to the extent that the project was designed to improve the 

resiliency of the project area to future disturbances associated with climate change (and which 

have occurred in the recent past in the Jemez Mountains), which is consistent with the purpose 

and need of the project. 

Our treatments will create a sustainable mosaic with a range of all sizes and ages of trees. This 

will be done by creating groups of different size and age trees at a fine scale. Size classes will be 

balanced as much as possible so the forest sustains itself over time, with younger trees growing 

up to replace old trees as they die, and new tree seedlings sprouting in openings. 

Forest Plan Amendments 

Comments 7.1, 8.4, 10.3, 12.5, 14.3, 14.4, 17.4, 19.5, 22.4, 22.5, 22.6, 

22.31, 22.33, 22.34, 24.18, 24.19, 24.20 

Concern 1 

We strongly oppose these forest plan amendments. These amendments are unnecessary. The plan 

as written does not include protections for Mexican spotted owl, Jemez Mountain salamander, 

and northern goshawk. 

Response

The current forest plan includes protection for the goshawk and spotted owl. The proposed 

amendments are necessary to update the protections for those species. The reasons for each 

amendment are shown in tables 1 and 2 of the DEIS (pp. 41-45).

Implementation of these amendments will help achieve the purpose and need for the proposed 

project by incorporating the revised recovery plan for the Mexican spotted owl and the latest and 

best available science associated with improving habitat for northern goshawks. In addition the 

EIS incorporates design criteria for protecting and improving habitat for the Jemez Mountains 

Salamander.
Appendix C. Response to Comments on the DEIS

326 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The current forest plan (1987) would be amended to include provisions from the revised recovery 

plan (USFWS 2012) for the Mexican spotted owl (MSO). The provisions would apply to this 

project only. Timing restrictions will be observed during the MSO breeding season. Also, 

treatments will be timed so that there is at least one breeding season with no activity between 

treatment disturbances. 

Much of the forest in the project area falls below standards for MSO as described in the 2012 

MSO recovery plan. Forest stand conditions throughout much of the project area fall within the 

VSS 3 to VSS 4 categories. These are young to middle-aged forests (under 18-inches diameter) 

and much of that is even-aged. Therefore, the project will move the forest, including owl habitat 

toward the desired condition and a more resilient landscape using mechanical treatments and 

prescribed fire (DEIS, pp. 4-12).

Although we propose to treat goshawk areas during the breeding season, activities will be limited 

to no more than two consecutive years during the breeding season (March 1 to September 30, see 

Forest Plan amendment). Monitoring of goshawks in the project area will be conducted 

throughout the implementation of the project. Additionally, the project will use Reynolds et al. 

(2013) as a guide for restoring ponderosa pine to improve habitat for goshawk.

Wild turkey is a game species and turkey populations on the Forest and in the project area are 

secure. It is not feasible to identify all turkey nesting sites. Restoration of ponderosa pine is 

anticipated to improve habitat quality for turkey by providing more understory vegetation for 

forage and promoting future roosting habitat. 

Under the current forest plan, site plans for falcon eyries (nesting sites) typically established 

avoidance zones, which extended up to four miles outward from the eyrie to avoid disturbance of 

falcons. These were established at a time when the falcon was federally listed under the 

Endangered Species Act. In 1999, the U.S. Fish and Wildlife Service determined that those 

protections were no longer necessary. Adhering to such restrictions would significantly delay 

restoration work and inhibit the Forest’s ability to meet the purpose and need. The forest will do 

project level surveys within one-half mile of peregrine falcon nesting habitat (the A zone) before 

and after project activities to assess how these activities affect occupancy and nest use. 

There are no amendments specific to salamanders, but we have included provisions for treatments 

within Jemez Mountains salamander critical habitat. This information on treatments and effects is 

available in the Biological Evaluation and the revised Biological Assessment, which are found in 

the project record. Additionally, project activities in occupied salamander stands, such as 

mechanical treatments, would not take place when soils are wet. This will reduce the likelihood 

of soil compaction as well as protect the Jemez Mountains salamander when it is likely to be at 

the soil surface. 

Concern 2 

The Forest Service is proposing virtually identical forest plan amendments in every project-level 

analysis throughout the Southwestern Region. Thus, the impacts on wildlife are not being 

considered in any comprehensive analysis under the National Environmental Policy Act (NEPA) 

nor Forest Service rules or directives.

Response 

The amendments pertaining to the Mexican spotted owl (MSO) were proposed to bring forest 

plan direction in line with the revised recovery plan (USFWS 2012). The existing forest plan 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 327

direction was incorporated into all forest plans in the Southwestern Region in 1996. In November 

of 2012, the U.S. Fish and Wildlife Service published the revised recovery plan for the MSO. 

Every forest provides a Biological Assessment to the Service outlining project activities and their 

effects on the MSO. The U.S. Fish and Wildlife Service issued a biological opinion (BO) of the 

project that considered the effects of the particular project as well as other projects within the 

spotted owl’s range. This is the first time the Santa Fe National Forest has amended its Forest 

Plan to incorporate the revised recovery plan. 

Recommendations from Northern Goshawk in the Southwestern United States (Reynolds et al. 

1992) were outlined in the Record of Decision for the 1996 Amendment of Forest Plans for the 

National Forests in Arizona and New Mexico (Plan Amendment). Reynolds et al. (2013) 

incorporates the latest scientific information on the ecology of ponderosa pine and mixed conifer 

forests in the southwestern part of the United States. This is the first time the Santa Fe National 

Forest has amended its Forest Plan to incorporate Reynolds et al. 2013. 

Restoring the composition and structure of the forest as described in Reynolds et al. (2013) will 

increase resilience and promote processes like fire to function as they did historically. As a result, 

habitat for goshawk will improve throughout its range. 

The analysis presented in chapter 3 of the FEIS provides an estimate of impacts on threatened, 

endangered, and sensitive species.

Temporary Roads 

Comments 5.9, 5.19, 6.1, 8.1, 8.2, 9.6, 14.2, 22.3, 23.1, 23.2, 25.2 

We received numerous comments about temporary roads. The comments focused on whether 

temporary roads were needed, how they would be decommissioned, and the effectiveness of the 

decommissioning in preventing their use in the future. 

Concern 1 

Many of the commenters on this issue indicated that they were not in favor in creating temporary 

roads because they would cause excessive resource damage. 

Response

We appreciate opinions regarding the need for temporary roads. However, part of the purpose and 

need for the project is to provide a source of wood products for personal and commercial use. 

With temporary roads, woody by-products resulting from restoration treatments can be removed 

at a lower cost and with fewer environmental impacts than permanent roads. Alternative 3 

showed the effects of not constructing temporary roads. Table 3 in the DEIS (p. 48) compared the 

environmental effects of each alternative.

The project area is well-roaded. The temporary roads are needed to help us avoid resource 

damage, especially on soil and water resources. In general, temporary roads would be short spurs

averaging 0.4 miles in length. These roads would be built by the operator, at their cost, and are 

generally at the lowest design. They are not graveled, and are “built” to allow a log truck to pass. 

Sometimes, stumps are not removed and the surface is not scraped. 
Appendix C. Response to Comments on the DEIS

328 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Concern 2 

Temporary roads cannot be rehabilitated appropriately. The plan should be more specific about 

the measures that will be taken to restore the surface area when these temporary roads are 

decommissioned.

Response

Temporary roads will be decommissioned as part of the operators’ closing work. Closing work 

occurs when work is completed in a particular area and the road is no longer needed. The operator 

will be required to decommission the road to our specifications before final payments are made. 

We will take steps to remove the road from the landscape and return the land to a more natural 

state. As described in chapter 2, decommissioning methods include installing signs, blocking 

entrances, restoring vegetation, eliminating the roadbed, and other methods described in Forest 

Service Manual (FSM) 7734.1. The most appropriate decommissioning methods will vary by site. 

See appendix A in the FEIS for the design criteria. 

When we decommission roads we take steps to block access to the road. In some cases, we make 

it difficult for people to see the decommissioned road from the road that they are driving on. 

What we do on each road will depend on the conditions on the road, the terrain, the number of 

trees, and the soil conditions. 

To address the concerns regarding unauthorized use of decommissioned temporary roads, we 

added a monitoring provision to appendix A. Decommissioned temporary roads will be monitored 

every other year for six years. If there is evidence that they have been used, we would use other 

measures to ensure that they stay closed. In additions people using decommissioned temporary 

roads would be in violation of the closure order created under the Travel Management Decision 

and may be cited.

Gravel Pits

Comments 8.6, 8.7, 9.5, 25.3 

Concern

There is not enough information about the location and rehabilitation of the gravel pits. 

Response

Additional design features, mitigation measures, and rehabilitation plans for gravel pits have been 

added to appendix A in the FEIS. A map showing potential gravel pit locations has been added to 

chapter 2. Yes, the gravel would be used for road maintenance during the life of the project and 

afterward. 

Monitoring for Mexican Spotted Owl 

Comment 22.36, 22.37, and 24.30 

Concern 

The Forest Service has failed to comply with the monitoring requirements set forth in the terms 

and conditions of the biological opinion, and/or likely exceeded the allowable incidental take for

the Mexican spotted owl. This cannot be allowed to continue where new proposed actions “may 

affect” the species and/or critical habitat. The Forest Service has no idea what the population 

trends are of this species nor do they have any evidence to validate the justification for the forest 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 329

plan amendments for management of spotted owl habitat. In summary, data on trends in 

populations or occupancy are sparse, and methods and sample sizes differ among studies, making 

comparisons difficult. In general, however, results suggest that most populations of Mexican 

spotted owls studied either have declined in the recent past or are still declining.

The complete monitoring plan, including study design and analysis protocols, should be made 

available for public review and comment before a decision is made to implement the project.

Response 

The Forest agrees that its monitoring has been less than comprehensive. However, we do not 

agree that the Forest has exceeded its allowable take due to its management activities. Under the 

proposed action, the Forest will monitor Mexican spotted owls (MSO) annually. This should add 

to the body of information for the MSO, assist us with MSO conservation, and assist the U.S. 

Fish and Wildlife Service in assessing the status of the species in the future. 

Recent survey data was collected on Mexican spotted owls within, as well as outside of, the 

project area. Data for nesting areas (protected activity centers) within the project area are

displayed in the Biological Assessment. The Forest has completed consultation with the U.S. Fish 

and Wildlife Service regarding the proposed project. 

The decline in MSO populations as mentioned by the commenters is partly due to wildfire. The 

Las Conchas wildfire burned over 46,000 acres within 14 hours of its start, burning through ten 

MSO protected activity centers (PACs) and likely killed many nesting owls. This is one example 

that highlights the need of this project to restore forest structure and function in an attempt to 

reduce the adverse effects of large wildfires.

We will follow the monitoring protocol outlined in the revised recovery plan (USFWS 2012). We 

plan on monitoring each PAC in the project area every year. The project-specific monitoring plan 

is being created jointly with the U.S. Fish and Wildlife Service as part of the biological opinion 

and includes additional stipulations or monitoring requirements. 

Purpose and Need 

Comment 5.1, 5.5, 5.15, 15.1, 15.5, 15.8, 15.9, 19.3, 19.6, 20.3, 22.22, 

24.3, 24.4, 24.7, 24.8 

Concern

A number of commenters requested consideration of actions or changes to the purpose and need 

of the project. These include: (1) shifting focus from forest restoration to fuel reduction and fire 

prevention in wildland-urban interface (WUI) areas; (2) modifying treatments to enhance 

snowpack retention; and (3) modifying project activities to maximize carbon sequestration in 

response to climate change.

Response

Chapter 1 describes the desired conditions and the purpose and need of the project. Our 

overarching goal at the landscape level is to restore ecosystem structure and function and increase 

resilience to undesirable, large-scale disturbances such as uncharacteristically severe wildfire, 

insect outbreaks and climate change in the Southwest Jemez Mountains.

The project is not just a fuel hazard reduction project, but a restoration project. Forest restoration 

focuses on returning key processes and functions to ecosystems and encouraging a structure and 
Appendix C. Response to Comments on the DEIS

330 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

species composition based on the idea that ecosystems are the most resilient and healthy when 

they are within the range of conditions to which their species have adapted (Swanson et al. 1994), 

otherwise known as the historical range of variability. At times restoration and wildfire hazard 

reduction objectives may overlap, at other times not. 

Treatments in the WUI, snowpack retention, and carbon sequestration are expected outcomes of 

our actions, but are not specifically a part of the purpose and need for the landscape restoration. 

The focus on these individual outcomes would fall short of meeting our desired conditions for the 

landscape as a whole. 

Responses to Individual Comments 

Letter 1, Mary Nelson 

Comment 1.1 

Concern

Supports the project.

Response

Thank you for your support of the Southwest Jemez Mountains Landscape Restoration Project. 

Letter 2, Dolores Kincaide

Comment 2.1 

Concern

Supports the project.

Response

Thank you for your support of the Southwest Jemez Mountains Landscape Restoration Project. 

Letter 3, J. Wasilewski

Comment 3.1 

Concern

Supports the project.

Response

Thank you for your support of the Southwest Jemez Mountains Landscape Restoration Project. 

Letter 4, Charles Cassagnol

Comment 4.1 

Concern

In assessing soils USFS has excluded two critical components of soil health: Soil chemistry and 

Biology (mycorrhizal fungi health and invertebrate activity). EPA recently recognized soil health 

to be a cross-section of physical characteristics, chemistry and biology.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 331

Response

Our overarching goal at the landscape level is to restore ecosystem structure and function and 

increase resilience to undesirable, large-scale disturbances such as uncharacteristically severe 

wildfire, insect outbreaks and climate change in the Southwest Jemez Mountains. To that end, we 

have conducted comprehensive effects analyses including detailed analysis of soils (see the Soils 

and Watershed Specialist Report, Snyder 2014). The components of soil that relate to “chemistry” 

and “biology” are components that exist in particular delineating variables found in the National 

Soil Survey Handbook, part 627.02, (USDA NRCS 2003b) described the delineation used in soil 

mapping. We believe that our examination of potential effects on soils does adequately address 

the chemical and biological aspects. 

Analyses for environmental consequences to soil and water resources that are a result of

implementation of each alternative were conducted using information contained in the Terrestrial 

Ecosystem Survey of the Santa Fe National Forest (Miller et al. 1993), the Watershed Restoration 

Action Plan-Outlet San Antonio (2011), the Santa Fe National Forest Plan, as amended (1987), as 

amended (2010), Southwest Jemez CFLRP Landscape Assessment (USFS 2010b), information 

obtained from other forest resource specialists, the New Mexico Environment Department, other 

agency reports, available literature, and input from collaborators and cooperators.

Geospatial analysis was used to quantitatively and qualitatively assess soils and watershed 

conditions using Geographic Information Systems data obtained from the Santa Fe National 

Forest GIS corporate database. The Terrestrial Ecosystem Survey for the Forest is available at the 

Santa Fe National Forest Supervisor’s Office.

The Terrestrial Ecosystem Survey is the result of the systematic analysis, mapping, classification 

and interpretation of terrestrial ecosystems, also known as terrestrial ecological units that are 

delineated and numbered to form an inventory known as the Terrestrial Ecological Unit Inventory 

(TEUI) database. A Terrestrial Ecosystem Survey represents the combined influences of climate, 

soil and vegetation, and correlates these factors with soil temperature and moisture along an 

environmental gradient. It is an integrated survey and hierarchical with respect to classification 

levels and mapping intensities. It is the only seamless mapping of vegetation and soils available 

across the SFNF that includes field visited, validated and correlated sites with a stringent 

Regional and National protocol stemming from decades of work. 

The Santa Fe National Forest TEUI database delineates all forest soils. As an example, the 

difference in a TEUI mapped unit classified as a Mollisol has a much greater organic (biologic) 

component than a Alfisol or Entisol (Miller et. al 1993).

Soil health is specifically addressed and analyzed in the EIS Watershed Specialist’s Report. The 

watershed specialist report’s discussion on soil health can be found pages 13-17 and 18-21. 

Analysis of the soil health can be found in the specialist report on pages. 61-62, 67, 70, 70-78, 80, 

82-85, and 88. 

The watershed specialist report uses analysis of existing TEUI data and further analysis using an 

EDA/ERA (Equivalent Disturbed Area/Equivalent Roaded Area) model. The data collected for a 

Forest TEUI are very complete. Not only does TEUI data include soil survey data but also the 

corresponding vegetative ecological assemblage. Specific soil health issues are addressed in the 

watershed specialist report, pages 74-77, and as Design Criteria (DC 46-50) on pages 59-60. Soil 
Appendix C. Response to Comments on the DEIS

332 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

condition areas of concern were identified and given appropriate resource protection measures 

identified in the specialist report on pages 13-21 and 45-59. 

Comment 4.2 

Concern

“A revegetation plan that includes nitrogen fixing legumes ( a forest is more that grasses, forbs, 

shrubs and trees ) is essential to forest health, compaction reduction, regeneration, and can serve 

as a guide to seeding and erosion control efforts.” 

Response

We do not think that a revegetation plan that includes nitrogen fixing legumes is essential for 

forest health or for fulfilling the project’s purpose and need and reaching our objectives. The 

design criteria for revegetation are listed in the watershed specialist report pages 50, 51, 52, 56, 

57, and 58-59. We will use native weed-free certified seed mixes and native, locally available

plants to revegetate areas disturbed by project activities. 

Natural revegetation will also occur due to the improved vegetative structure resulting from 

mechanical treatments and prescribed fire. This includes nitrogen-fixing native sedges. Less 

competition and increased solar inputs (sunshine) into the treated areas will allow for a natural 

recovery of the existing and potential plant communities. 

Comment 4.3 

Concern

The DEIS does not take into adequate account climate change forecasts for the Southwest. Only 

cursory effort was made to address it in the DEIS.

Response

Please see the response to comments regarding Climate Change.

Comment 4.4 

Concern 

It has been determined that large diameter trees fix larger amounts of carbon than small diameter 

trees. This relationship is exponential so a single large diameter tree (16”dbh) fixes substantially 

more carbon than a 12-inch diameter tree. For this reason old growth and larger diameter 

Ponderosa must not be removed as part of this Stewardship Plan Response

Response

Please see the responses to comments regarding Climate Change and Large Trees.

Letter 5, Dick Artley

Comment 5.1

Concern

NEPA requires you to describe the environmental effects of project implementation in Chapter 3 

accurately and honestly (emphasis added). NEPA requires you to weigh the adverse effects of 

project implementation against the benefits you claim the timber sale will produce as stated in the

Purpose and Need. Your tragically flawed DEIS fails to satisfy this basic requirement of the law.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 333 

Why? You fail to accurately and honestly disclose the resource damage the sale will cause and 

your P and N does not discuss goals that will benefit the general public or the environment in and 

near the proposed SW Jemez timber sale.

Response

Section 102(2)(A) of the National Environmental Policy Act requires all agencies to use an 

interdisciplinary approach to analysis, which will ensure the integrated use of the natural and 

social sciences and the environmental design arts in planning and decision making which may 

have an impact on the human environment (42 U.S.C. 4332(2)(A)). The CEQ regulations at 40 

CFR 1502.6 require that the disciplines of the preparers shall be appropriate to the scope and 

issues identified in the scoping process (§1501.7). 

We believe we have fulfilled the above NEPA requirements. Chapter 3 in the DEIS has the effects 

analysis prepared for each resource area. Resource specialists used the best available science in 

these analyses.

See also the response to comments regarding Purpose and Need.

Comment 5.2 

Concern

The following link contains the results of more public polls assessing their approval of logging on 

national forest land. The polls randomly sampled of people in Georgia, Ohio, Kentucky and 

Indiana. The percentages of people who opposed commercial logging in national forests are 

displayed below: 

Georgia - 72.3% oppose logging Ohio -73.5% oppose logging Kentucky - 72.8% oppose logging 

Indiana - 69% oppose logging

Poll link: http://www.johnmuirproject.org/resources-summary-of-polling-data-1998.html 

How does this timber sale serve the public? Don’t say the wood is needed for whatever reason. 

Only 3.8 % of raw materials for domestic wood products and paper originate on national forests. 

Response

The research cited is a national survey of public opinions regarding commercial logging on 

National Forest System lands conducted in 1998. It does not necessarily reflect opinions related 

to this project, which focuses on forest restoration. Further, the commenter did not demonstrate 

the relevance of this survey to the Southwest Jemez project. 

Comment 5.3 

Concern

Comment 1: Supervisor Garcia, several years ago the forest service prepared and sold something 

called a “timber sale.” Now, it’s impossible to find a proposed timber sale referred to as a “timber 

sale.” Clearly, the leadership of the USFS grew tired of dealing with the increasing public 

opposition to logging in the national forests. The Chief responded with deception and trickery 

when he/she decided to euphemize the term “timber sale” and call it a “restoration project.” When 

did you first become aware that you name timber sales restoration projects? Please answer 

honestly. 
Appendix C. Response to Comments on the DEIS

334 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

The U.S. Southwest, including the Jemez Mountains, has been the focus of ecological research on 

forest ecosystems. The ecosystem changes have been documented in numerous landscape and 

resource assessments produced by land management agencies and conservation groups. These 

assessments identified the area as a critical conservation area. The Southwest Jemez Mountains 

Landscape Restoration Project was awarded funding in 2010 through the Collaborative Forest 

Landscape Restoration Program, which encourages collaborative, science-based ecosystem 

restoration of forest landscapes. 

Our overarching goal at the landscape level is to restore ecosystem structure and function and 

increase resilience to undesirable, large-scale disturbances such as uncharacteristically severe 

wildfire, insect outbreaks and climate change in the Southwest Jemez Mountains. We do believe 

that our approach and the treatments we proposed will be ecologically beneficial. Mechanical 

thinning would be variable, to suit the particular landscape, stand history, topography, and 

wildlife needs. 

Timber harvesting is one of several types of treatments are proposed to move the landscape 

toward the desired conditions. Treatments are described in chapter 2 of the DEIS. Appendix A in 

the DEIS appendix A lists the design features, best management practices, and mitigations for the 

proposed treatments.

Comment 5.4 

Concern

Comment 2: Supervisor Garcia, why do you choose to ignore the USDA Inspector General 

conclusion the timber sales do not restore the forest and still claim the SW Jemez timber sale will 

restore the forest? What’s different about your sale that is missing from the hundreds of sales 

examined by the USDA for their report? If you still believe logging restores and improves the 

forested ecosystem, please see Opposing Views Attachment #21.

Response

The commenter referenced a report but did not provide any discussion regarding the relevance of 

the information to this project. The commenter also did not provide any interpretation as to how 

the provided material would influence the proposal, the analysis, or the decision within the 

context of the purpose and need of the project. Citing a report and requesting that it be considered 

in the analysis is not required by NEPA. 

Please see the responses to comments 5.2 and 5.3. 

Comment 5.5 

Concern

Comment 3: Supervisor Garcia, please don’t reject the recommendations of a fire damage 

reduction expert from your own agency. Indeed, Dr. Cohen has chosen to speak the truth! He is a 

real public servant because he refuses to lie to the American people as so many other USFS lineofficers do to trick the national forest owners into believing logging large trees (that are least 

likely to burn) will protect them. The claim by the USFS that ladder fuels reduction is necessary 

is a joke.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 335

Request for changes to be made to the final NEPA document: Analyze a Dr. Cohen methods 

alternative in detail. If the P and N was written to exclude alternatives to the Proposed Action that 

do not involve logging modify it too. The goal as described in the P and N should not be fuels 

reduction. It must be to take action to reduce the risk of damage to homes and the risk of injury in 

the area. Fuels reduction logging would be one action alternative. 

Response

Dr. Cohen’s work focuses on fuel reduction in and near wildland-urban interface communities in 

order to reduce or eliminate damage to and/or loss of human-built structures. This is not a fuels 

reduction project. Treatments are not designed to reduce the risk of damage to homes and the risk 

of injury in the area. The commenter did not provide any specifics as to how the references he 

provided would influence the proposal, the analysis, or the decision within the context of the 

purpose and need of the project. There was no new information or information that could 

otherwise inform the analysis.

See also the response to comments regarding Purpose and Need.

Comment 5.6 

Concern

Comment 4: Supervisor Garcia, there is no “timber famine” as the USFS has been so fond of 

predicting for many decades. There is no shortage of raw materials for paper and wood products 

in the United States, therefore there is no reason to have commercial timber sales in the national 

forests. The USFS could stop logging today and the market would never react. 

Response

The enabling legislation (Title IV of the Omnibus Lands Act, PL 111-11) authorized the use of 

forest restoration by-products to offset treatment costs. This project has a commercial component, 

which involves the removal of forest restoration by-products. Restoration treatments are designed 

to meet ecosystem objectives and not to maximize wood product outputs. Using wood products 

from this area will reduce the amount of wood material that needs to be burned, thereby reducing 

smoke production and prescribed burning costs. 

Comment 5.7 

Concern

Comment 5: Request for changes to be made to the final NEPA document: Include a discussion 

and supporting data showing whether the majority of the people in the area support or reject 

logging in the Santa Fe National Forest. If the Responsible Official ignores the will of the people 

and continues to spend their tax dollars on something they don’t want, then include a discussion 

justifying why it’s necessary to do so. 

Response

Your opinion has been noted. Public involvement for this project was extensive and is discussed 

in the DEIS, pages iv and 16-17. Public involvement for the Southwest Jemez Mountains 

Restoration Project included scoping and a 45-day comment period as required by the NEPA. 

This restoration strategy, which is the basis for this project was developed collaboratively by over 

40 community and non-profit groups and agencies in 2009-2010. The foundation for 

collaborative forest restoration was built over a 10-year period starting after the Cerro Grande fire 

in 2000.This long-term collaborative effort, along with research efforts, are strengths of the 

restoration strategy. 
Appendix C. Response to Comments on the DEIS

336 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 5.8 

Concern

Comment 6: Members of the public who submit comments on a draft NEPA document make the 

effort to read the NEPA document closely and take the time to compose comments that reflect 

their issues. Supervisor Garcia, unless you respond to these comments and allow the public to 

read your responses they don’t know if their comments were read and “considered.” 

Request for changes to be made to the final NEPA document: Supervisor Garcia, if you choose 

not to allow the public to read your responses to their comments online then consider this a FOIA 

for these responses. Please assure that I receive them (hardcopy or preferably electronic) within a 

day or 2 of the date the final EA is released and the objection period begins. Consider this an 

official FOIA request. 

Response

This appendix constitutes the responses to public comments and will be posted on the project web 

page (http://go.usa.gov/BUVh). Posting this appendix on the web page serves as the response to 

your FOIA request. 

Comment 5.9 

Concern

Comment7: Since best science and Chief Dombeck agree that “There are few more irreparable 

marks we can leave on the land than to build a road," this is a valid reason to analyze a no new 

temporary or system road alternative in detail.

Request for changes to be made to the final NEPA document: Please analyze an alternative in 

detail in the final NEPA document that does not construct any new roads (temp or system). If you 

choose not to honor my request, please include an analysis comparing the adverse effects of a 

minor volume reduction v. the benefits to the ecosystem if no roads are constructed. 

Response

Alternative 3 is intended to show the effects of not constructing new temporary roads (see DEIS, 

p. 30). Please see also the response to comments regarding Temporary Roads. 

Comment 5.10 

Concern

Request for changes to be made to the final NEPA document: Please survey the streams that 

might be affected by timber sale activity and include the information in the final NEPA document. 

If you decide not to do these surveys, then please explain how you will determine accurate effects 

of implementing this timber sale on stream turbidity and temperature without recent “before” 

measurements. 

Response

Comprehensive stream condition inventory reports and hydrologic condition assessments were 

completed by the Santa Fe National Forest and are available on the forest’s website. These reports 

were used to develop the Landscape Strategy (USFS and VCNP 2010), to describe existing 

conditions, and were also used in the effects analysis in the watershed specialist report. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 337

The watershed specialist report discusses implementation of Proper Functioning Condition (PFC) 

or similar riparian assessment protocol for the streams within the project area. The pre-treatment 

PFC or similar monitoring will provide a baseline to determine post-treatment effectiveness in the 

project area streams and associated riparian corridors.

The specialist report further describes the function of native vegetation, landforms, soil condition, 

and debris when the ecological sites are function properly or are showing a trend towards an 

improving PFC, (watershed specialist report, p. 42).

A summary of the effects of the alternatives was in provided in table 3 of the DEIS. It is brief and 

allows for comparison of different alternatives. Please refer to the Wildlife, Fish, and Rare Plants 

section of chapter 3 of the DEIS for a complete analysis of the effects. The section specifically 

addresses the effects of each alternative on the Rio Grande cutthroat trout, a candidate species and 

the Rio Grande chub and Rio Grande sucker, sensitive species.

The New Mexico Environment Department is responsible for conducting monitoring, assessment, 

and reporting under the CWA (Clean Water Act) sections 303(d) and 303(b) and total maximal 

daily load (TMDL). 

Comment 5.11

Concern

Comment 8: The treatment costs will not be offset by the revenues paid by the purchaser for this 

timber sale. Timber sale revenues are deposited in the United States Treasury and are in no way 

earmarked for future use on the forest where they were received. This is not a salvage sale.

Response

This project is focused on landscape restoration; it is not a timber sale. Revenues from 

stewardship contracts can be returned to the forest. The economic efficiency analysis in chapter 3 

of the DEIS displayed the net value of the treatments. See also the response to comment 5.3. 

Comment 5.12 

Concern

Comment 9: The damage inflicted by logging and road construction described in Opposing Views 

Attachment #1 will necessitate real restoration work in the future to repair the ecosystem damage. 

This is expensive and will likely exceed the revenues generated by this timber sale.

Response

The commenter provided references but did not provide any discussion regarding the relevance of 

the information to this project. The commenter also did not address how the provided material 

would influence the proposal, the analysis, or the decision within the context of the purpose and 

need of the project. Citing a reference and requesting that it be considered in the analysis without 

specifics on how we should consider it is not particularly helpful. 

See also the responses to comment 5.11 and 5.24. 
Appendix C. Response to Comments on the DEIS

338 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 5.13 

Concern

Comment 10: Please see Opposing Views Attachment #1. This attachment contains statements by 

241 Ph.D. scientists who describe how natural resources in the forest are harmed or destroyed by 

logging activity. They describe how some natural resources will never function again after being 

subjected to repeated abuse by 30,000 pound industrial equipment with spinning wheels and 

tracks. Please keep in mind that these 241 scientists are just a small sample of independent 

scientist not affiliated with the USFS who feel this way and publically voice their opinions. 

Response

The commenter provided references but did not provide any discussion regarding the relevance of 

the information to this project. The commenter also did not address as to how the provided 

material would influence the proposal, the analysis, or the decision within the context of the 

purpose and need of the project. Citing a reference and requesting that it be considered in the 

analysis without specifics on how we should consider it is not particularly helpful. 

See also the response to comment 5.24. 

Comment 5.14 

Concern

Supervisor Garcia, if you were really concerned about local community stability and local job 

creation you would off this sale as an SBA sale. Otherwise its likely the sale will be purchased by 

a lage timber corporation, logged using their own labor and the logs hauled many miles to be 

processed at a mill far removed from the small communities you claim to help. 

Supervisor Garcia, Dr. Power conducted research to validate or disprove whether increased 

timber harvest will enhance and strengthen the economic stability of communities located near 

national forests in Washington state. His research shows that logging levels are inversely 

proportional to community stability. 

Request for changes to be made to the final NEPA document: Please either: remove the following 

statement from the P&N:

“Offset treatment costs and provide economic opportunity through wood product removal.” OR 

include the following papers (referenced above) in their entirety in an Appendix to the NEPA 

document. Line officers should not withhold such important information before describing the 

selected alternative in the decision document.

“The Economic Impact of Trails-Forest Recreation’s Growing Impact” 

“Seeing Forests for their Green: Economic Benefits of Forest Protection, Recreation, and 

Restoration”,

“The Economic Impact of Preserving Washington’s Roadless National Forests”

Response

The Social Science, Economics, and Environmental Justice section of chapter 3 in the DEIS, has 

a comparison by alternative of estimated total production of forest products removed from the 

forest and a net present value of the restoration treatments for each action alternative. This section 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 339

also describes the forest products industry in northern New Mexico. There are no large purchasers 

or timber corporations in the region. This project will provide wood products for personal use, as 

stated in the purpose and need. The commenter provided references but did not provide any 

discussion regarding the relevance of the information to this project. The commenter also did not 

address as to how the provided material would influence the proposal, the analysis, or the 

decision within the context of the purpose and need of the project.

Comment 5.15 

Concern

Comment 13: The forest is infinitely more than conifer trees. A properly functioning forest 

contains some decadent, dying, unhealthy trees. A logged forest differs dramatically from a 

natural forest. A healthy, natural forest has an abundance of dead trees. All healthy groups of 

living things have unhealthy and dying individuals. Removing certain trees from the forest to 

increase vigor and diameter growth harms the biodiversity of the area. Taking action to increase 

vigor and diameter growth is the goal of private industrial tree farm managers not professional, 

competent national forest managers.

Request for changes to be made to the final NEPA document: Please remove all text from the 

NEPA document that infers action should be taken as part of the SW Jemez timber sale to reduce 

the occurrence of natural disturbance events (fire, insect activity, disease etc.).

Please tell the public why you believe pheromone treatment will be ineffective and cite references 

supporting your conclusion. 

Response

We agree. As stated earlier, this project is not a timber sale; it is focused on restoration. See also 

the response to comments regarding Purpose and Need. 

Comment 5.16 

Concern

The DEIS does not indicates herbicides will be used to treat non-native and invasive plant 

species. It says the types of herbicides to be applied won’t be known until an SEIS for non-native 

invasive plant treatment is completed. Please use the information in this section as reference 

material for the SEIS.

Please cite the information in your invasive plant control SEIS contained in Attachments #9a and 

#18. 

Request for changes to be made to the final NEPA document: 

Include a disclosure in Chapter 3 that there is scientific disagreement about the safety of 

herbicides containing glyphosate. This would discuss the fact that research conducted by 

independent Ph.D. chemists indicates exposure to glyphosate-containing herbicides may cause 

major health problems in birds, fish and mammals (including humans ? especially in children) 

and list the problems shown above. 

Include the information contained in Attachments #9a and #18 submitted by this as part of these 

comments in an appendix to the final EIS. Please be public servants and don’t withhold this life 

or death information from the people who may visit the Santa Fe National Forest. 
Appendix C. Response to Comments on the DEIS

340 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Include information about alternatives to herbicides and why these alternatives were not used in 

lieu of herbicides to control non-native and invasive plant. If the alternatives to herbicides 

weren’t used because of extra cost, indicate the cost difference between the alternatives and 

herbicides. If the alternatives are less effective than herbicides include data and information 

supporting the claim. 

Include a link to the final SEIS in the final EIS that the Responsible Official used to conclude that 

herbicides containing glyphosate were safe to apply where humans might congregate. Another 

option would be to include this document in its entirety in an Appendix.

Response

The commenter refers to the Supplement to the Final Environmental Impact Statement (SEIS) for 

the Invasive Plant Control Project, Santa Fe and Carson National Forests, and suggests literature 

to be considered for the SEIS analysis. The analysis and decision regarding which herbicides may 

be used to treat non-native invasive plants within the Santa Fe National Forest is not part of the 

proposed action, and so is outside the scope of the Southwest Jemez Mountains Landscape 

Restoration Project. Use of herbicides to treat nonnative plants will be addressed in the SEIS for 

the Invasive Plant Control Project, Santa Fe and Carson National Forests. 

Comment 5.17 

Concern

Request for changes to be made to the final NEPA document: Please redo the maps at a scale 

large enough for the public to locate their favorite recreation areas in the sale area. These larger 

scale maps should show the location of developed campgrounds and the names of the streams in 

the area. Public disclosure and understanding is the reason to display accurate, useable maps. 

Response

Maps were provided in chapter 2 of the DEIS. The electronic (CD) format is available to the 

public and allows the user to zoom in or print the maps at an appropriate scale. Larger scale maps 

can also be requested by contacting the Santa Fe Forest Supervisor’s Office.

The Recreation section of chapter 3 in the DEIS discloses the effects of the alternatives on 

recreation use and visitation. The Scenery section discloses the effects of the alternatives on the 

scenery and landscape character.

Comment 5.18 

Concern

Comment 21 : Supervisor Garcia, simply making a general statement that amenity resource 

values have been considered in the NEPA document is not enough. The public wants to read 

about how they were considered, thus they want the page numbers shown. 

Request for changes to be made to the final NEPA document: Please identify and discuss the 

methods and procedures used by the Responsible Official to insure that presently unquantified 

environmental amenities and values are given appropriate consideration. So the lay public can 

find this important information, please include this information under an easily identifiable 

heading. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 341

Response

Amenities and values of concern were considered in the analysis of the project. See the 

Recreation, Scenery, Social Science, and Cultural Resources sections in chapter 3 of the DEIS. 

The associated specialist reports and resource sections of chapter 3 of the DEIS describe the 

methods used for the analysis and discuss project effects on these resources. 

For example the Recreation section of chapter 3 of the DEIS (pages 117-128) discloses the effects 

of the alternatives on recreation use and visitation. The Scenery section of chapter 3 of the DEIS 

(pages 136-146) discloses the effects of alternatives on the scenery and landscape character.

Ecosystem services are discussed in the Social Science, Economics, Environmental Justice 

section (pages 147-160). Other considerations of such amenities and values include smoke from 

prescribed burning associated with fuel reduction activities, and the economic effects on the local 

communities during and project implementation.

Comment 5.19 

Concern

Supervisor Garcia, if you were really concerned about aquatic species health you would indicate 

in the final EA that all newly constructed temporary roads will be obliterated after use.

Supervisor Garcia, at page 24 you indicate temporary roads will be decommissioned after use. 

The DEIS does not indicate how they will be decommissioned. 

Comment 22: Since temporary roads are outsloped with no ditch, sediment that is generated 

during precipitation events, find its way to streams and harms the aquatic resources for decades 

after initial construction unless the road is obliterated. No other decommissioning method is as 

effective at eliminating damage to aquatic resources and subsurface water flow as obliteration. 

Comment 23: Anyone who seriously wants to enhance the health of aquatic ecosystems (DEIS at 

page 8) wouldn’t think of constructing new roads. 

Comment 24: Links to science showing complete obliteration is more effective at reducing longterm sediment generation than any other closure methods are included below: 

Request for changes to be made to the final NEPA document: Please indicate all temporary roads 

will be obliterated after use and tell the public this will be done in the draft decision document, or 

provide scientific information authored by independent scientists in the response to comments 

that indicates there are other methods as effective at long term sediment elimination as 

obliteration. 

Please define road obliteration using the statement below (or something similar) in the draft 

decision document to eliminate confusion:

When roads are obliterated the road is completely eliminated from the landscape. Full 

recontouring is accomplished by recovering all available fill and burying the cutbank until the 

surrounding terrain is fully matched. 

Also, please assure the final NEPA document describes the road obliteration monitoring plan to 

assure the sediment is being reduced as expected. The resulting draft decision documents should 

indicate the USFS will provide funding for the monitoring and accomplish the monitoring. 
Appendix C. Response to Comments on the DEIS

342 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Whatever decommissioning method is chosen it should be monitored over time to assure 

sediment is not generated. The DEIS contains no such monitoring plan. 

Response

The commenter provided several references to various state and federal agency sources defining 

the term “road obliteration”. The proposed action will follow the Forest Service standards found 

in Forest Service Handbook 1909.15, 23.3 and the design features, best management practices,

mitigations and monitoring described in appendix A of the FEIS. 

Each resource specialist has analyzed the effects of the proposed action activities of constructing, 

maintaining and decommissioning temporary roads. The summary of effects can be found within 

each resource section of the DEIS, Chapter 3.

See also the response to comments regarding Temporary Roads. 

Comment 5.20 

Concern

Request for changes to be made to the final NEPA document: Supervisor Garcia, please review 

this project in light of the Opposing Viewpoint Attachments and respond to the science 

conclusions contained in the attachments as they relate to the proposed SW Jemez timber sale. 

Include these responses with the final NEPA document for all to see. Then evaluate the draft ROD 

(and modify it) if the Proposed Action will cause resource harm that was not acknowledged in the 

final NEPA document. 

Response

The DEIS disclosed the affected environment and the summary of the effects in chapter 3 of the 

DEIS. Appendix A of the DEIS lists the design features, best management practices, mitigations 

and the monitoring that would be implemented during all actions associated with the proposed 

action. 

The commenter provided some references and opposing opinions but did not provide any 

discussion regarding the relevance of the information to this project. The commenter also did not 

provide any interpretation as to how the provided material would influence the proposal, analysis 

or the decision within the context of the purpose and need of the project. 

Comment 5.21 

Concern

Request for changes to be made to the final NEPA document: Please include a discussion of the 

Energy requirements and conservation potential of various alternatives and mitigation measures 

in final NEPA document. 

Response

The commenter did not provide the name or a reference for a particular law, policy, or regulation. 

Comment 5.22 

Concern

Request for changes to be made to the final NEPA document: Supervisor Garcia, please review 

this project in light of the Opposing Viewpoint Attachments and assure that the final EIS reflects 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 343

sale modifications that eliminate the predicted adverse effects on wildlife, aquatic resources and 

recreation described in Chapter 3. 

Indeed, information authored by hundreds of respected scientists describing the damage caused 

by activities that will occur as part of the SW Jemez timber sale is before you now. If you believe 

the science contained in the Attachments is not valid or does not apply to this timber sale please 

discuss your logic and reasons in the body of the final EA EIS.

If site specificity is an issue with the Attachment Opposing Views, then please describe why it’s

acceptable for the References section to be non site-specific, but literature submitted by the public 

must be site-specific.

Response

The DEIS disclosed the affected environment and the summary of the effects in Chapter 3 of the 

DEIS. Appendix A of the DEIS listed the design features, best management practices, mitigations 

and the monitoring that would be implemented during all actions associated with the proposed 

action. 

The commenter provided some references and opposing opinions but did not provide any 

discussion regarding the relevance of the information to this project. The commenter also did not 

provide any interpretation as to how the provided material would influence the proposal, analysis 

or the decision within the context of the purpose and need of the project. 

Comment 5.23 

Concern

Request for changes to be made to the final NEPA document: Supervisor Garcia, please modify 

the proposed timber sale to comply with the existing Forest Plan. 

Response

The Southwest Jemez Mountains Restoration project is tiered to the Santa Fe National Forest 

Land and Resources Management Plan. The report documenting the consistency of the action 

alternatives with the Forest Plan is located in the project record. Forest plan consistency was 

discussed on page 19 of the DEIS.

Comment 5.24 

Concern

The commenter provided hundreds of examples of “opposing viewpoints”. 

Response

The commenter provided research articles, magazine and newspaper articles, opinion pieces, blog 

posts, and other material, but did not provide any discussion regarding the relevance of the 

material to this project. The commenter also did not provide any interpretation as to how the 

provided material would influence the proposal, the analysis, or the decision within the context of 

the purpose and need of the project. Citing a reference and requesting that it be considered in the 

analysis is not particularly helpful.
Appendix C. Response to Comments on the DEIS

344 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Letter 6, Michael Tompson 

Comment 6.1 

Concern

I am not in favor of constructing access roads, temporary or not. I do not think a temporary access 

road can be rehabilitated appropriately. It would be too costly and shortcuts would be taken 

during the rehabilitation process. 

Response

Please see the response to comments regarding Temporary Roads. 

Letter 7, Nancy Kings

Comment 7.1 

Concern 

Please reinstate all the forest plan’s protections for goshawk, spotted owl, and the Jemez 

Mountains salamander and cut only small diameter trees. 

Response

Protections are still in place for the goshawk and spotted owl. The proposed changes to the 

protections for this project reflect the updated and best available science for recovery of these 

species. Additional protections were put in place for the Jemez Mountains salamander through 

work done with the U.S. Fish and Wildlife Service. 

Please see the responses to comments regarding Amendments and Large Trees. 

Comment 7.2 

Concern 

The Jemez River watershed is a crucial source of water for recreation, wildlife, and downstream 

farmers and communities. This cherished place needs care and recognition of its unique 

environment. 

Response

Thank you for your interest in this project and recognition of the value of the landscape. Meeting 

the objectives of this project will help protect the Jemez River watershed. 

Letter 8, Susan Ostile, Great Old Broads for Wilderness 

Comment 8.1 

Concern 

We would like to comment that alternative 3 with no temporary roads might be a preferable 

alternative, if there was scientific data available on the difference between soil disturbance and 

compaction when the thinning products are removed by skidding, rather than by the creation and 

decommissioning of temporary roads. 

Response

Thank you for your opinion. We did not model the suggested comparison for two reasons. Costs 

to the operator increase when skidding distances are longer than 1,320 feet. This makes a 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 345

potential contract less appealing. More importantly, we did not model the effects of yarding 

(hauling cut timber to a landing) distances greater than 1,320 feet because the compaction from 

the additional trips on a skid trail simply leads to more soil compaction than is acceptable. 

After a few passes with the skidder, the soil has reached 85-90 percent of maximum compaction 

(Williamson and Neilsen 2000). Without temporary roads, skid trails would have more traffic and 

soil compaction would be more than recommended. We would need more skid trails and landings 

to avoid excess compaction. This, in turn, would create more soil disturbance and compaction

over a larger area. Williamson and Neilsen (2000) recommend using a defined skid trail system 

that confines traffic to a smaller area. The long-term reduction in soil productivity over a smaller 

area outweighs the risk of substantial damage over a larger area. 

See also the response to comments regarding Temporary Roads. 

Comment 8.2 

Concern

Unauthorized users may not be easily deterred in using decommissioned temporary roads.

Response

Please see the response to comments regarding Temporary Roads and the response to comment 

23.1. 

Comment 8.3 

Concern

Alternative 4 with no prescribed fire in mechanical treatment areas is not an alternative that we 

would want to see implemented. The fire load on mechanically treated areas after a couple of 

years for recovery of small ponderosas and firs in cleared areas appeared to us on our field trip in 

2012 to be unacceptably heavy. 

Response

Thank you for your comment regarding concern increased fuel loading as described for 

alternative 4. The DEIS outlined five alternatives; the proposed action is alternative 1. Alternative 

4 would reduce the acres burned from 77,000 to 45,400. The analysis of alternative 4 showed an

increased fire risk and increased crown fire potential as compared to alternatives 1, 3, and 5. This 

information can be found in fuels section of chapter 3 of the DEIS and FEIS. 

Comment 8.4 

Concern

Large trees in the Mexican spotted owl (MSO) nesting areas and protected activity centers (PACs) 

need to be retained with the exception of large trees in the nesting sites and PACs that are 

threatening cultural resource sites.

Response

Please see the response to comment 14.3 and the responses to comments regarding Large Trees 

and Forest Plan Amendments.
Appendix C. Response to Comments on the DEIS

346 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 8.5 

Concern

It also appears that up to 25 percent of the nesting/roosting areas on the landscape could be 

allowed to fall below the lower stand condition thresholds for basal area. We feel that this 25 

percent threshold is too high; given the implications of potential climate change on endangered 

species like the Mexican Spotted Owl, a threshold of 10 percent to 15 percent is more desirable.

Response

One of the needs for the proposed project is to move toward desired forest conditions that are

consistent with those described in the 2012 Mexican spotted owl (MSO) recovery plan (USFWS 

2012). While the mechanical treatments decrease total basal area (BA) in the short term, they are 

designed to increase the amount of BA in larger trees (greater than 18 inches) in the long term. 

Reducing the existing tree density will allow the remaining trees to grow larger. Modeling shows 

that within 20 years after treatment, the BA will surpass the minimum BA recommended in table 

1b of the DEIS. 

Much of the project area does not meet the standards for nest/roost MSO as described in the 2012 

recovery plan. Forest stand conditions throughout much of the project area fall within the VSS 3 

to VSS 4 categories. These are young to middle-aged forests with trees less than 18-inches 

diameter, and much of that is even-aged classification. The intent of the project is to start the 

moving the forest toward the desired condition and toward a more resilient landscape by using 

mechanical treatments and prescribed fire. 

As with all protected species, we consult with the U.S. Fish and Wildlife Service. The Fish and 

Wildlife Service has issued a biological opinion on the impacts and benefits of the proposed 

treatments on these species. 

The proposed project is designed to move the forest toward the desired forest conditions 

described in the 2012 recovery plan. The plan states that 25 percent of a planning area should be 

managed for threshold conditions (see table 1b in the DEIS). The recovery plan addresses climate 

change. 

Comment 8.6 

Concern

Commenter would like to see a rehabilitation plan for the gravel pits. 

Response

Please see the response to comments regarding Gravel Pits. 

Comment 8.7 

Concern

Gravel materials used from other local sources, rather than National Forest system lands, may 

provide additional income for the local community.

Response

It would be possible to buy gravel from commercial sources off the forest; indeed, we do that 

now. Having our own gravel pits, however, would save money. Because we don’t have crushing 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 347

equipment and a large number of trucks to haul the gravel, we would likely hire contractors for 

the crushing and hauling, thus giving the local economy a boost. 

See also the response to comments regarding Gravel Pits. 

Comment 8.8 

Concern

Grazing management and a reduction in animal unit months (AUMs) would be beneficial in 

meeting landscape objectives.

Response

Reduction of AUMs is outside the scope of this project. 

The Rangeland Resources section of chapter 3 of the DEIS (pages 106-115) discussed treatments 

that would result in short-term effects on livestock grazing allotment management; treatments 

included a rest period of 1-2 years after certain treatments. The rest period would let the soil 

stabilize and for the grasses and forbs to reestablish themselves and grow.

Design features and mitigation measures described in appendix A of the FEIS would reduce 

ungulate impacts in riparian areas, along stream banks, and at spring or seep complexes. 

Comment 8.9 

Concern

There is not enough discussion of how the project activities will affect the largest trees in light of 

climate change and cyclical drought.

Response

Please see the responses to comments regarding Climate Change and Large Trees. 

Letter 9, Chris Zebrowski

Comment 9.1 

Concern

I am all for the Santa Fe National Forest recommended proposal.

Response

Thank you for your support and interest in this project. 

Comment 9.2 

Concern

Alternative 4 will leave too much fuel on the ground. 

Response

Please see the response to comment 8.3. 
Appendix C. Response to Comments on the DEIS

348 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 9.3 

Concern

Mention is made in the Plan that some of the downed trees will be made available to citizens as 

firewood. Will this available wood be tied to the firewood permit program? 

Response

Some of the wood will be available for firewood; there is not a plan for specifically how much, 

but we would expect that we can supply enough to satisfy personal use demand for firewood. 

When a person buys a wood permit, they would be directed to areas where recent cutting has 

occurred and where wood may be available. Firewood would probably be found in piles of slash 

scattered across a wide area or at a landing. 

Comment 9.4 

Concern

Will crews live on site while working? Or will there be morning and evening travel of workers 

along with the day travel of logging trucks, etc.? Will their guidelines be to work “green”- 

keeping trash contained and removed from the forest? 

Response

It is possible crews may wish to camp near where they are working, and that would be allowed. It

is more likely that they will travel to the site each day. They are required to pick up their garbage 

and keep the work area clean.

Comment 9.5 

Concern

I would like to know where the new temporary gravel pits would be located- in the “western 

area” is not very specific. I would also like to know if some of these will continue to be used in 

the upkeep of open forest roads. 

Response

A map showing the potential locations of gravel pits has been added to the FEIS, chapter 2. See 

also the response to comments regarding Gravel Pits. 

Comment 9.6 

Concern

Hopefully when roads are decommissioned they will be done so aggressively. A bulldozed dirt 

hill or downed trees across a road doesn’t stop anyone. I do not mind, hikers, bicyclists, ATVs, or 

even motorcycles back in the woods. I do not like how the big 4-wheeled trucks tear up the forest 

roads. 

Response

Additional design features, mitigation measures, and rehabilitation plans for gravel pits and 

temporary roads have been added to the appendix A of the FEIS. A discussion about road 

decommissioning and rehabilitation treatments is in chapter 3 of the FEIS in the Roads and 

Engineering section. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 349

As part of this planning process we considered two alternatives (alternatives 2 and 3) that did not 

include construction of temporary roads. Alternatives 1, 4, and 5 each include 12 miles of 

temporary road construction (see table 3 of the FEIS). When possible, existing roads would be 

used to implement project activities. All of the temporary roads will ultimately be 

decommissioned. 

We understand that roads have impacts on the land and these were described in the Roads and 

Engineering section of chapter 3 of the DEIS as well as in other sections: Wildlife, Fish, and Rare 

Plants, Cultural Resources, Nonnative and Invasive Plants, Soil and Water Resources, Recreation, 

and Scenery. When we design and maintain roads, we conduct the work in a way that reduces 

these impacts (see appendix A). As part of this project we propose to decommission unnecessary 

roads and all temporary roads; that is, we will take steps to remove the road from the landscape 

and return the land to a more natural condition. As described in chapter 2, decommissioning 

methods include installing signs, blocking entrances, restoring vegetation, eliminating the 

roadbed, and other methods described in Forest Service Manual (FSM) 7734.1. 

See also the response to comments regarding Temporary Roads.

Comment 9.7 

Concern

Of the communities’ gravel/dirt roads that are used during treatment implementation, will these 

roads be repaired of heavy vehicle damage when project work is completed?

Response

Appendix A of the DEIS described the design features, best management practices, mitigations 

and monitoring for alternatives 1, 3, 4, and 5. Road maintenance treatments were discussed on 

page 289 of the DEIS. Roads will be maintained throughout the life of the project. 

Letter 10, Randy Crutcher

Comment 10.1 

Concern

It has come to my attention that your proposed alternatives in this watershed and fire protection 

project do not include preserving forest canopy that protects soil and sensitive habitat. 

Response

The impression that treatments would eliminate the forest canopy is incorrect. Tree density would 

be reduced over much of the project area, especially in the ponderosa pine and dry mixed conifer 

forest. Our desired condition is to have a forest mosaic with openings, shrubs, and groups of trees 

of various sizes and ages. Canopy cover would vary depending on the forest type and habitat 

guidelines for northern goshawk and Mexican spotted owl. Please see the Vegetation and Soil and 

Water Resources sections of chapter 3 of the FEIS and the associated specialists’ reports for 

details on treatment intensities and effects. 

Closed (very dense) tree canopies have more vegetative surface area that intercepts or captures 

more rain and snow. This water then evaporates and returns to the atmosphere instead of being 

absorbed into the ground. Also, a functional grass component in the understory will hold more 

moisture and prevent erosion (Ffolliott et al. 1989; Baker and Ffolliott 1999).
Appendix C. Response to Comments on the DEIS

350 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 10.2 

Concern

Logging larger trees has not been substantiated as part of watershed protection and there is 

science that shows clear benefits to keeping larger healthy trees for multiple reasons.

Response

Please see the response to comments regarding Large Trees.

Comment 10.3 

Concern 

I urge you to reinstate provisions in forest plans to protect goshawk, spotted owl, and the Jemez 

Mountains salamander confining forest treatments to removal of small diameter trees.

Response

Protections are in place for the goshawk and spotted owl. The proposed changes to the protections 

for this project reflect the updated and best available science for recovery of these species. 

Additional protections were put in place for the Jemez Mountains through work done with the 

U.S. Fish and Wildlife Service. 

Please see the response to comments regarding Forest Plan Amendments.

Letter 11, Morgan R. Nelson, New Mexico Environment Department 

Comment 11.1

Concern

Expresses support of the Proposed Action - alternative .1

Response

Thank you for your interest. 

Comment 11.2

Concern

There is mention of planting and protecting the riparian zone in all alternatives, and this is 

certainly of great importance to water quality. The benefits of a healthy/functioning riparian zone 

are many. A healthy riparian corridor would reduce surface water temperature on many of these 

streams. Decrease in temperature would improve the trout and benthic macroinvertebrate 

populations.

Response

We agree. 

Comment 11.3

Concern

NMED does not fully agree with the statement in the first paragraph on page 161 that “high 

temperature and high levels of aluminum are probably due to the rock type that underlies the 

area”. Water quality criteria for aluminum are under review for several streams in the project area 

(Sulphur Creek, the East Fork Jemez River, San Antonio Creek, Vallecito Creek, and several 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 351

sections of the Jemez River), as indicated for all of the Jemez watershed streams in Category 5B 

in the 2012-2014 New Mexico Clean Water Act Section 303(d)/305(b) Integrated Report. 

We recommend that making progress towards water quality standards attainment be specifically 

included among the goals of the project. Total Maximum Daily Loads (TMDLs) or the methods 

used to develop the TMDLs may be useful for quantifying these goals or comparing the expected 

effectiveness of different alternatives towards meeting water quality goals. 

We appreciated reading the load reductions (DEIS page 168) expected from major categories of 

work proposed under Alternative 1. 

Response

The 2012 NMED 303-d impaired waters report lists probable sources of dissolved aluminum for 

several drainages in the project area as naturally occurring (NMED 2012, pp. 262-288). We

understand that the New Mexico Environment Department continues to review aluminum criteria 

for attainable levels and we look forward to any new information regarding potential sources of 

aluminum in the Jemez Mountains landscape. 

The watershed specialist report has been revised; comments concerning aluminum impairments 

are noted and state “Natural conditions contribute to high aluminum concentrations throughout 

the Jemez and impacts to aquatic life are unclear; aluminum criteria are under review to identify 

the appropriate or attainable level.” In the FEIS, the statement regarding aluminum has also been 

revised.

The NMED is correct that the Forest Service may have mischaracterized the source of high 

stream temperatures and that we failed to recognize that a stream shading or cover issue exists. To 

address this concern, we have developed design criteria and Best Management Practices to 

maintain or enhance stream shading and cover. 

Improved water quality that move towards or meets State standards is a desired conditions and 

part of the purpose and need of the project (DEIS, pp. 9, 13).The proposed action (alternative 1) 

has significant riparian and stream channel actions intended to improve water quality, including 

minimizing stream temperature including:

• Channel restoration (23-miles)

• Dispersed recreation site rehabilitation (28 sites)

• Improvement or removal of road-stream crossings 

• Headcut treatments (288 identified at road intersections with 303-d listed stream and 

tributary crossings listed in table i of the watershed specialist report).

Most of these treatments have a seeding or planting component combined with protective fencing 

that will increase shading along streams. Improvements in the riparian woody vegetation 

assemblage would eventually create an improved width-to-depth ratio and eventually moderate 

stream temperatures by reducing solar inputs. These treatments would also help mitigate the 

slightly warmer stream temperatures that may occur with a changing climate. 

The SSTEMP model currently exists in useful locations and is expected to provide useful project 

effectiveness data. The New Mexico Environment Department is responsible for conducting 
Appendix C. Response to Comments on the DEIS

352 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

monitoring, assessment, and reporting under the CWA (Clean Water Act) sections 303(d) and 

303(b) and total maximal daily load (TMDL). 

Comment 11.4 

Concern

Information about the location and types of treatments, such as work done to ameliorate head cuts 

and instream treatments that include channel restoration, is lacking in the DEIS, but to some 

degree is detailed in the specialist report. More narrative description of locations and types of 

treatments would be appropriate in the DEIS. We appreciate the design features for BMPs 

mentioned in Appendix A.

Response

The general locations of the headcut treatments are shown in figure 12 in chapter 2 of the DEIS.

The text describing the instream channel treatments (DEIS, page 23) lists the perennial streams 

where work will be done. Actual sites will be determined on the ground using the design criteria 

outlined in appendix A (pages 281-283) and the toolbox approach described on 53. San Antonio 

Creek is a priority watershed on the forest and restoration activities would be concentrated there 

to maintain or improve watershed condition (DEIS, page 165).

Comment 11.5

Concern

In Appendix A, a statement under “Riparian Area Restoration” on page 286 is included that “gaps 

between exclosures should be a sufficient length to spread out livestock and wildlife water access 

use to reduce concentrated stream and streambank impacts. Gaps along the stream between 

exclosures should be at least double the size of exclosures.” The biological basis for this guidance 

(including a reference) should be provided. The Surface Water Quality Bureau has supported 

projects where the exclosures are close to each other without negative effects or impacts reported. 

Response

This is a management recommendation and not a biological provision. It is intended to allow 

sufficient access to water by livestock and wildlife because our proposal may implement 

exclosures that are tall enough to keep wildlife and livestock out of streams. 

Comment 11.6

Concern

The commenter suggested several editorial corrections. 

Response

Thank you for providing the edits. We made the corrections. 

Comment 11.7

Concern

Implementation of the project may involve the use of heavy equipment, thereby leading to a 

possibility of contaminant releases (e.g., fuel, hydraulic fluid, etc.) associated with equipment 

malfunctions. The GWQB advises all parties involved in the project to be aware of notification 

requirements for accidental discharges contained in 20.6.2.1203 NMAC. Compliance with the 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 353

notification and response requirements will further ensure the protection of ground water quality 

in the vicinity of the project.

Response

We will obtain all applicable permits before commencing work regulated by the Clean Water Act. 

We will make contractors and other operators aware of the requirements of NMAC 20.6.2.1203. 

Timber sale contract provisions (as well as other service contracts) require a spill response plan 

be included in the contract. Such provisions are part of our standard operating procedures and 

contracting language when operations include the use of heavy equipment. 

Comment 11.8

Concern

To ensure air quality standards are met, applicable local or county regulations requiring noise or 

dust control must be followed for the duration of this project. If none are in effect, dust control 

measures should be considered to minimize the release of particulates due to vehicular traffic, 

construction equipment and significant ground disturbances; extra care should be taken during 

high wind events. All areas disturbed by construction activities resulting in significant ground 

disturbance within and adjacent to the project should be reclaimed to avoid long-term problems 

with soil erosion and fugitive dust. Our particular concern is the impact due to smoke from 

prescribed burns. State smoke management rules, 20.2.60, 20.2.61 and 20.2.65 NMAC must be 

followed at all times.

Response

New Mexico Smoke Management Rules will be followed (See DEIS page 40 and appendix A 

page 269). All regulations regarding fugitive dust associated with road construction, maintenance 

and decommissioning, and gravel pit operations will be followed, as applicable. Where no 

requirements exist, dust control measures will be considered according to the standards and 

specifications for federal road construction (FHWA 2003). 

Comment 11.9

Concern

Current and proper air quality permits are required for all asphalt, concrete, quarrying, crushing 

and screening, tree-cutting, chipping and shredding, and tilling equipment or facilities contracted 

in conjunction with the proposed project.

Response

We will follow the requirements under NMAC 20.2.72, as applicable, and have updated the FEIS 

to include the requirements to obtain the appropriate air quality permits for the activities listed in 

the comment. The requirement for the permits is also listed in appendix A of the FEIS. 

Letter 12, Deborah Post 

Comment 12.1

Concern

The DEIS did not take into adequate account climate change forecasts for the Southwest.
Appendix C. Response to Comments on the DEIS

354 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

Please see the response to comments regarding Climate Change. 

Comment 12.2

Concern

Forests must mitigate for atmospheric carbon loading.

Response

Please see the response to comments regarding Climate Change. 

Comment 12.3

Concern

In order to draft a management plan a mathematical model must be generated to determine how a 

sustainable mosaic with target Ponderosa size distributions must be generated. Recently, it has 

been determined that large diameter trees fix larger amounts of carbon than small diameter trees.

Response

Please see the response to comments regarding Climate Change. 

Comment 12.4 

Concern

There is no size distribution data present in the report on which a determination of location of 

such trees.

Response

Large trees are scattered throughout the project area. The distribution of size classes is shown in 

tables 10 and 14 of the silviculture specialist report. The methods section of the specialist report 

describes the sources of information and analysis methods used to determine the various 

attributes and to analyze the alternatives. 

See also the response to comments regarding Large Trees. 

Comment 12.5 

Concern

The plan as it is written now does not include protections for the goshawk, spotted owl and the 

Jemez Mountains salamander. All of these species are essential pieces for a living forest.

Response

Protections are in place for the goshawk and spotted owl. The proposed changes to the protections 

for this project reflect the updated and best available science for recovery of these species. 

Additional protections were put in place for the Jemez Mountains through work done with the 

U.S. Fish and Wildlife Service. 

Please see the response to comments regarding Forest Plan Amendments and Large Trees.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 355

Letter 13, Steve Spencer, U.S. Department of Interior 

Comment 13.1 

Concern

U.S. Department of Interior has reviewed the DEIS and has no comment. 

Response

Thank you for reviewing the DEIS. 

Letter 14, Sue Gunkel, Great Old Broads for Wilderness 

Comment 14.1 

Concern

I wish to lend my support to your preferred alternative, Alternative 1. As noted above, Alternative 

2 of no action, is not acceptable. However, I would like to see some aspects or variations of 

Alternatives 3 and 5 taken into the final plan of action. 

Response

Thank you for your support and interest in this project. 

Comment 14.2 

Concern

While I realize that “skidding” would require skidding routes to be created, I believe if these 

would be less inviting to off-road use by motorized vehicles and I would like to see the Forest 

Service study this and build no or significantly fewer temporary roads than proposed in 

Alternative 1. If no less impactful means of extracting thinned is found, it is important that your 

plan includes funds to decommission and obliterate those roads immediately after the thinning 

activity.

Response

Please see the response to comment 8.1 and the response to comments regarding Temporary 

Roads. 

Comment 14.3 

Concern

It seems that while 9 inches might be too small a limit for effective management thinning, taking 

nearly 18-inch diameter trees in nesting and PACs is too large of a diameter tree than should be 

taken. The only exception to this distinction might be when larger trees in the nesting sites and 

PACs are threatening cultural resource sites.

Response

Within nesting habitat, only prescribed fire will be used; no tree-cutting will occur. The revised 

2012 Mexican spotted owl recovery plan (USFWS 2012) recognized the need for this type of 

restoration within protected activity centers (PACs) and allows trees up to 18-inches diameter to 

be cut. We don’t anticipate that we would cut many of these larger trees (up to 18-inches 

diameter) to meet objectives for owl habitat within PACs. Design criteria for mechanical 

treatments in PACs are found in appendix A of the FEIS. 
Appendix C. Response to Comments on the DEIS

356 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Please see the responses to comments regarding Large Trees and Forest Plan Amendments.

Comment 14.4 

Concern

It also appears that up to 25% of the nesting/roosting areas on the landscape could be allowed to 

fall below the lower stand condition thresholds for basal area. I feel that this 25% threshold is too 

high; given the implications of potential climate change on endangered species like the Mexican 

Spotted Owl, a threshold of 10% to 15% is more desirable 

Response

Please see the responses to comment 8.5 and the response to comments regarding Forest Plan 

Amendments. 

Comment 14.5 

Concern

The amount of grazing in the area should be decreased. 

Response

Please see the response to comment 8.8. 

Letter 15, William Baker

Comment 15.1 

Concern

The document provides sufficient scientific evidence that ecological restoration is warranted in 

the project area, but I am sorry to have to explain why I think the scientific evidence about 

reference conditions does not support the main thrust of the proposed project, which is to lower 

fuel loads to reduce uncharacteristic high-severity fire. 

Response

The DEIS (chapter 1 page 5) states that desired conditions come from a number of sources, 

including the forest plan and research on reference conditions. It is also stated that our desired 

condition is not an attempt to restore reference conditions, but to use these conditions as a 

baseline for evaluating current conditions. The desired condition is more than merely lowering 

fuel loads within the fire-adapted forest types. By moving these forests to the desired condition 

this project creates a resilient landscape better equipped to handle disturbances including climate 

change. 

See also the response to comments regarding the Purpose and Need. 

Comment 15.2 

Concern

The scientific reference information that will guide restoration needs to be much more prominent 

in the actual DEIS, not just in a Specialist Report. Wherever it is, it needs improvement to 

adequately demonstrate that available scientific evidence has been subjected to a hard look and 

that it was directly used to guide the restoration framework for the project.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 357

Response

Thank you for your opinion. It is difficult to include all of the scientific reference information 

into a concise environmental assessment as is an EIS. As we discussed above, reference 

conditions were not the only science that led to the development of our desired conditions. Our 

desired conditions were developed from a number of scientific references, including some of the 

references provided by the commenter. The references provided also imply a greater 

heterogeneity in the reference conditions as influenced by the fire regime and severity. None of 

these studies included the Jemez Mountains, where a high degree of heterogeneity exists due to 

the highly broken topography of the landscape. Mixed-severity wildfire was likely the norm as

compared to the study areas in Arizona referenced by the commenter. The landscape resulting

from the implementation of our proposal will be equally heterogeneous with watersheds and subwatersheds that have varying densities and species composition. Please see the response to 

comment 15.1 for the discussion on the use of reference conditions in developing the project 

objectives and proposed action. 

Comment 15.3 

Concern

SDI (stand density index) is not based on reference data at all. SDI is all about timber 

management for wood production, not about restoring historical forest structure, which may 

historically have varied substantially in SDI. If the project is to be labeled as restoration, it needs 

to omit the SDI approach and instead be based on reference data about historical forest structure 

to guide restoration.

Response

Stand density index was not used as an indicator for reference conditions, density, or forest 

management. Tables 32-34 (DEIS, p. 180) display changes in density indicators by alternative. 

Basal area (BA) and trees per acre (TPA) are listed as indicators. We chose not to use stand 

density index as an indicator in the vegetation section of the DEIS because it is a difficult concept 

to explain and did not add much to the discussion. Table 1a (DEIS, p. 43) includes stand density 

index in a table from the forest plan showing standards and guidelines for the Mexican spotted 

owl and northern goshawk. 

Regardless of which measure is used to display existing and pots-treatment densities, there is a 

high degree of agreement in the forest reconstruction studies showing that historical tree densities 

were much lower than those found in the Jemez Mountains today. 

See also the response to comment 15.1.

Comment 15.4 

Concern

Provide primary scientific sources for each number provided in this Desired Conditions section of 

the document, along with an evaluation of the reliability of the evidence, its applicability to the 

study area (how far away was it collected, what are the limitations of the method of 

reconstruction etc.), so that readers can find the original source, understand its limitations, and 

also be assured that USFS has taken a hard look at the primary evidence. 
Appendix C. Response to Comments on the DEIS

358 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

The desired conditions for this area come from a number of sources, including the Santa Fe 

National Forest Plan (forest plan) and ecological research on reference conditions35. Our desired 

conditions are more than just an attempt to duplicate reference conditions. Reference conditions 

act as a baseline for evaluating current conditions, and they also guide the development of 

treatments (Fulé et al. 1997). Ecosystems function best in the conditions to which they adapted 

over time (Swanson et al. 1994). For example, open forests, a grassy understory, and lowintensity surface fires are the key features of ponderosa pine forests. Moving the ponderosa pine 

forests toward these conditions increases resilience and the forests will be better equipped to 

handle disturbances, including climate change (Fulé 2008).

Ecological research over the past 15 years indicates that a great deal of variability in fire regimes 

and fire severity exists in ponderosa pine and mixed conifer forests. Evidence of mixed and high 

severity fires has been found in the ponderosa pine type in Colorado (Sherriff and Veblen 2007; 

Williams and Baker 2012a), Oregon and Washington (Arno and Allison-Bunnell 2002; Hessburg 

et al. 2005; Baker 2012), Northern Rockies (Arno and Allison-Bunnell 2002), and Arizona 

(Jenkins et al. 2011), and Southwestern forests (Graham 2003; Graham et al. 2004; Williams and 

Baker 2012b). These mixed and high severity fires occurred at intervals or rotations of 200-600 

years and shaped the landscape of ponderosa pine and dry mixed conifer forests in the western 

United States (Jenkins et al 2011; Williams and Baker 2012b). 

Landscape scale research states that both forest structure and fire severity were historically more 

variable in dry forests (ponderosa pine and dry mixed conifer) in the western United States than 

originally thought (Williams and Baker 2012a,b; Odion et al. 2014). These latter studies used 

forest reconstruction methods to estimate historical tree densities. Densities in these newer studies 

averaged 141-145 trees per acre in dry forests of the Southwest (Williams and Baker 2012b), 

versus 15-56 trees per acre found in other studies. Regardless, existing tree densities of 500 trees 

per acre far exceed either set of densities.

See also the response to comment 15.1.

Comment 15.5 

Concern

The DEIS needed to review and evaluate new peer-reviewed scientific evidence and published 

studies that were missed in the DEIS. I am sending pdfs of these studies as an attachment to this 

letter. Please enter these four studies into the record. The studies by Williams and Baker 2012, 

2014) and Odion et al. (2014) show that the entire reference framework for historical fire in 

ponderosa pine and mixed conifer forests in the DEIS is incorrect and the proposed project is misdirected and will have very significant negative ecological consequences for these ecosystems. 

These studies show that historical ponderosa pine and dry mixed conifer forests in the Southwest 

and other areas of the western United States were strongly shaped by historical high-severity fires 

and mixed-severity fires with high-severity components. Because the DEIS did not review this 

scientific evidence in formulating the proposed project, it incorrectly labels high-severity fire as 

 

35 Reference conditions typically refer to the state of an ecosystem before human influences. They provide 

a reference baseline of conditions that scientists can compare to current conditions.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 359

“uncharacteristic” and seeks to reduce the occurrence of high-severity fire, when high-severity 

fire was likely characteristic of these ecosystems.

Response

We reviewed the references. Some of these were not available at time we were developing the 

proposed action or the DEIS. We did, however, look at these and other available references while 

discussing reference conditions and to formulate our response to this comment. 

None of the above studies provided were conducted in the Jemez Mountains area. Site-specific 

studies done in the Jemez Mountains do indeed document low-intensity, high frequency fires over 

hundreds of years, as far back as the late 1400s (Allen 1989, 2001; Touchan et al. 1995, 1996; 

Allen et al. 1995; Touchan and Swetnam 1995; Swetnam and Baisan 1996). There is some 

evidence that mixed or high-severity fires occurred in the area. Allen (1989) also found that 

patchy crown fires were part of the mixed conifer fire regimes on wetter sites. Charcoal evidence 

from bogs in the Jemez Mountains indicates a mixed severity fire regime on wetter sites 7,000-

5,000 years before the present (Allen et al. 2008). The complex terrain found here- canyons, steep 

slopes, mesas- may have created patch scale or larger areas of mixed and high severity fire “as 

part of the natural fire regime,” (Jenkins et al. 2011, p. 139), as opposed to severe wildfire events 

separated by long periods without any wildfires. 

Topography, slope, aspect, climate influences, fuel continuity, invasive plants, and herbivore 

grazing (domestic and native animals) are among the factors that may result in localized areas of 

mixed and high severity fires within a low-severity fire regime landscape (Everett et al. 2000; 

Arno and Allison-Bunnell 2002; Jenkins et al. 2011; Veblen 2003). These factors can result in 

different fire regimes in different locations of the same forest type (Veblen 2003; Everett et al. 

2000). Among the factors influencing fire type and severity in the Jemez Mountains are the 

complex terrain, a high level of lightning activity, and the effects of the El Niño Southern 

Oscillation (El Niño-La Niña effect) and the American monsoons (Allen 1989).

Moderate and high severity fires create diversity in the forest landscape and create habitat for 

some wildlife and plant species. When we look at the greater Jemez Mountains landscape, there 

have been several large (and small) wildfires that burned with moderate or high severity or with 

crown fire behavior since the 1970s: La Mesa, Dome, Cerro Grande, Las Conchas, Thompson 

Ridge, Porter, Cebollita, Lakes, Virgin, Henry, Hondo, Nicole, and Labor. Across the greater 

landscape, these moderate and severe wildfires have contributed to the pattern of mixed and high 

severity fires in ponderosa pine noted in the more recent research (Jenkins et al. 2011; Odion et 

al. 2014; Williams and Baker 2012b). See also the discussion on large trees and vegetative 

diversity under “Large Trees” at the beginning of this appendix. 

The forest structure described by all these sources (Woolsey 1911, Pearson 1950; Covington and 

Moore 1994; Swetnam and Baisan 1996; Covington et. al. 1997, Williams and Baker 2012a, b; 

Reynolds et al. 2013; William and Baker 2013) is very similar to that described by our desired 

conditions. The stand structure and densities vary from study to study but the densities described 

in the EIS fall well within range described.

Uncharacteristic wildfire is a term used throughout the analysis. Hardy 2005 defines 

uncharacteristic fire as wildfires which occur outside the time, place and severity parameters of 

the historic natural fire regime. While researchers generally agree that there was mixed and/or 

high severity fire in ponderosa pine (Williams and Baker 2013; Roccaforte et al. 2008), there are 
Appendix C. Response to Comments on the DEIS

360 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

some unresolved questions about the amount, pattern, and distribution of these fires. The 

historical presence of high and/or mixed severity fire in ponderosa pine is understood and the 

term uncharacteristic mainly refers to the scale at which high severity fire has recently impacted 

the landscape. Proposed action alternatives ultimately account for variability of fire severities. 

Predominantly low severity fire is desired in ponderosa pine with inclusions of forest that will 

still be susceptible to mixed and high severity. 

See also the response to comments regarding the Purpose and Need and the response to comment 

15.1. 

Comment 15.6 

Concern

The proposed reasons to reduce tree density in these woodlands are at best controversial and have 

a weak scientific foundation, based on this key scientific review. This should certainly be 

revealed in the EIS and I would think the proposed pinyon-juniper treatments would accordingly 

be removed as a project goal. Please cite and review this study and the evidence about fire 

severity that it presents: Romme, W. H. et al. 2009. “Historical and modern disturbance regimes, 

stand structure and landscape dynamics in piñon-juniper vegetation of the western United States.” 

Rangeland Ecology and Management 62:203-222. 

Response

This study was reviewed and cited on pages 17-18 of the silviculture specialist report. Only a 

small portion of the piñon-juniper type is proposed for treatment (1,000 acres out of 34,500 

acres). Treatments would be done if there was a compelling reason, such as wildland-urban 

interface protection or watershed improvement. 

See also the response to comment 15.1.

Comment 15.7 

Concern

The Specialist Fuels report unfortunately uses FlamMap, which has known errors that mean it 

significantly underpredicts the probability of crown fire initiation by a factor of 2.5 to 3.0. There 

are potentially serious issues associated with using FlamMap, given that its errors are very high 

and are documented in peer-reviewed science. In my scientific opinion, the estimates of crown 

fire shown in this report are wrong and should not be used at all to avoid misleading the public 

about what can be achieved with the proposed project. Here is the peer-reviewed scientific 

publication that shows this, and proposes an alternative validated model that can be downloaded 

and used instead. I am attaching a pdf of this study to this letter and would like to have this 

publication entered into the record: Cruz, M.G., Alexander, M.E., 2010. “Assessing crown fire 

potential in coniferous forests of western North America: A critique of current approaches and 

recent simulation studies.” International Journal of Wildland Fire 19: 377-398. 

Response

The FlamMap metrics of potential fire behavior (fire type), and fireline intensity were used to 

evaluate and compare treatment alternatives for meeting the purpose and need of the project: to 

restore ecosystem structure and function and increase resiliency to undesirable, large-scale 

disturbances such as high-severity wildfire, climate change, or insect outbreaks in the Southwest 

Jemez Mountains. The purpose of the modeling analysis was not to exactly identify the behavior 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 361

of a potential fire, but rather to compare the potential effects between treatment alternatives. This 

is important, as all models are a simplification or approximation of reality (Burnham and 

Anderson 1998) based on fire model systems that link multiple empirical and deterministic 

models or sets of mathematical equations to predict fire behavior (Stratton 2006). All models 

have assumptions and limitations. The landscape characteristics (fuels and stands) were modified 

to more accurately reflect reality and compensate for the limitations, such as the one you have 

identified, but will never be completely accurate despite the model used. 

Comment 15.8 

Concern

The obvious emergency and problem, based on the recent fires, to me seems pretty obviously to 

be largely people and their infrastructure, not so obviously the forests themselves. This is an 

important matter that the EIS should directly address. Perhaps a significant portion of the 

proposed funding from the CFLRP should go toward making infrastructure much less vulnerable 

to igniting fires near public forests, and towards minimizing the possibility a fire that is ignited on 

private land or in an easement will not burn into public forests. 

Response

We disagree. The project is about more than addressing wildfire regardless of how such fires are 

ignited. See also the response to comments regarding Purpose and Need. 

Comment 15.9 

Concern 

I was dismayed to see the DEIS set aside a discussion of the important role of fire in the WUI for 

the proposed project. This is not scientifically defensible, as there is abundant and compelling 

scientific evidence that many fires that are burning in public forests, including the project area, 

begin in the WUI or on private or public easements (e.g., transmission lines, roads) that go 

through the project area. The EIS needs to take a hard look at the role of human-set fires on the 

project area and the scientific evidence that shows that human-set fires are increasingly 

dominating fire regimes on western public lands. 

Response

Please see the response to comment 15.8 and the response to comments regarding Purpose and 

Need.

Letter 16, Rhonda Smith, Environmental Protection Agency 

Comment 16.1 

Concern

EPA rates the DSEIS as “EC-2” i.e., EPA has “environmental concerns and requests additional 

information” in the Final PEIS (FPEIS). The “EC” rating is based on the potential for adverse 

impacts to protected species, wild and scenic rivers, and waters of the U.S. (WUS). The “2”

indicates the DSEIS does not contain sufficient information to fully assess protected species, wild 

and scenic rivers, and WUS. Responses to comments should be placed in a dedicated section of 

the FEIS and should include the specific location where the revision, if any, was made. 
Appendix C. Response to Comments on the DEIS

362 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

Thank you for your review of the DEIS. This constitutes a dedicated section of responses to your 

comments. Information listed as being found in the DEIS will also be found in the FEIS, but page 

numbers are not yet available for the FEIS. See also the responses to comments 16.2 and 16.7. 

Comment 16.2 

Concern

Identify all jurisdictional WUS (waters of the United States), including wetlands, and show them 

on a map. Discuss how water sources will be protected, restored, and enhanced. 

Response

Jurisdictional Waters of the United States will be determined at the time of application for the 404 

permit for the proposed instream channel work. Intermittent and perennial streams are displayed 

in figure 43 in the DEIS (page 162). The watershed specialist report shows these streams in miles 

by each Huc12 (p. 103). Wetlands, seeps, springs, and streams are described and discussed in the 

specialist report (p. 39) and chapter 3 of the DEIS (p. 161) and the FEIS. Map coordinates of 

seeps, springs, and wetlands locations are found in the soils and watershed specialist report (pp. 

104-105). Best Management Practices, mitigation measures, and design criteria that were

specifically developed for this project to prevent adverse impacts on water sources are found in 

appendix A of the FEIS. 

Resource protection measures are implemented to minimize non-point source pollution as 

outlined in the intergovernmental agreement between the New Mexico Environment Department 

and the Southwestern Region of the Forest Service (NMED 2008). BMPs are expected to lead to 

attainment of water quality standards and maintain or improve water quality and quantity, as well 

as watershed function. Design criteria for riparian streamcourses have been modified to include 

wetlands. These changes were made to afford the same protections given to perennial streams will 

also be given to wetlands. , 

The following treatments for riparian areas and stream channels are intended to improve water 

quality: 

Channel restoration (23-miles)

• Dispersed recreation site rehabilitation (28 sites)

• Road-stream crossing removal or improvement (minimum of at least 35 existing and 

identified sites) 

• Headcut treatments (288 identified at road intersections with 303-d listed stream and 

tributary crossings listed in the appendix of the soils and watershed specialist report, table 

i) 

The above treatments would improve water quality by reducing erosion and sediment transport 

into streams. All of the channel restoration, recreation site rehabilitation, and stream-road 

crossing restoration actions listed above have a seeding or planting component combined with 

protective fencing. This will increase shading due to actions that maintain, introduce, and 

improve a functional riparian woody vegetative assemblage and create an improved width-todepth-ratio/entrenchment ratio and therefore moderate temperature regimes by reducing solar 

inputs. Mechanical treatments and prescribed fire are expected to increase water storage capacity 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 363

and water yield. The expected treatment outcomes and effects are summarized and discussed in 

chapter 3 of the FEIS. These treatments would also help mitigate the slightly warmer stream 

temperatures that may occur with a changing climate.

Comment 16.3 

Concern

Although the DEIS states that residents would be notified of prescribed burn activities, USFS 

should provide more specific information regarding the notification process, timing, and potential 

health or environmental monitoring in these communities during prescribed burn events. USFS 

should include additional outreach and education measures to address concerns from low income 

or minority communities. 

Response

The Forest recognizes the importance of notifying the public, including low income and minority 

communities, about prescribed fire activities and the associated public health impacts from 

smoke. The Forest has guidance for developing communication plans for prescribed fires, which 

are a requirement included in all burn plans. Each communications plan is unique, based on the 

communities potentially affected as well as the potential for impacts from any prescribed fire. 

Potential communications methods that could be included in a communications plan are notifying

individuals who have expressed interest for more information about individual burns; contacting 

TV, radio, print and online news media; outreach to smaller communities by phone, or in person; 

public meetings; mailings; flyers posted in prominent locations within communities; and 

providing public information officers during a prescribed burn to answer questions and share 

information in the community, both at designated locations as well as going to targeted locations. 

For larger prescribed fires, the Forest, working with NMED and communities, will deploy air 

quality monitors in communities that may be impacted. One of the potentially impacted 

communities and a partner in this project is the Jemez Pueblo. The Pueblo also sets up air quality 

monitors a in the Pueblo during prescribed fires. 

Appendix A of the FEIS (air quality section) will include a design feature to notify communities 

in advance of prescribed fires. Detailed communications plans, however, are tailored to the 

particular prescribed fire and potentially affected communities and will be included the burn plan. 

Specific outreach and education measures will be listed in the burn plans, not the FEIS. 

Comment 16.4 

Concern

The following permits are required: 

• Clean Water Act § 404 permit from U.S. Army Corps of Engineers 

• Clean Water Act § 401 water quality certification from the New Mexico Environment 

Department

• Clean Water Act § 402 National Pollutant Discharge Elimination System (NPDES) from 

EPA 
Appendix C. Response to Comments on the DEIS

364 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

The Forest will obtain all applicable permits before commencing work regulated by the Clean 

Water Act. The requirement for these permits is stated in chapter 2 of both the DEIS and the FEIS 

under the heading “Required Permits, Approvals, and Consultation”. Appendix A also addresses 

permit requirements. 

Comment 16.5 

Concern

Wild and Scenic River consultation with the National Park Service is required. 

Response

We assessed project effects on the East Fork Jemez River Wild and Scenic River in chapter 3 of 

the DEIS (pages127) and FEIS. The project is in compliance with the Comprehensive River 

Management Plan. The Forest Service is the administrating agency for the East Fork Jemez Wild 

and Scenic River; therefore, no consultation or review by the National Park Service is needed. 

Comment 16.8 

Concern

National Historic Preservation Act Section 106 consultation with the State of New Mexico 

Historic Preservation Office is required. 

Response

National Historic Preservation Act Section 106 requirements and consultation efforts with the 

State of New Mexico Historic Preservation Officer are identified on pages 40, 77, and 273 of the 

DEIS. The Section 106 compliance report for Phase I activities was completed and submitted to 

the New Mexico State Historic Preservation Office (SHPO) Documentation of Tribal 

Consultation was included in this report. SHPO concurred with the findings of the report. 

Comment 16.9 

Concern

Endangered Species Act, Section 7 (ESA) and Migratory Bird Treaty Act consultation with the 

U.S. Fish and Wildlife Service is required. 

Response

The Forest Service complies with the Migratory Bird Treaty Act (MBTA) but there is no 

regulatory requirement to consult with U.S. Fish and Wildlife Service regarding the MBTA. The 

Endangered Species Act Section 7 consultation with the U.S. Fish and Wildlife Service was

completed and the Forest has received the final, signed biological opinion. 

Letter 17, Mary Peck

Comment 17.1 

Concern

The plan is missing a more extensive soil assessment and a contribution to the complexity of the 

forest. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 365

Response

Please see the response to comment 4.1. 

Comment 17.2 

Concern

The DEIS does not allow for the dramatic effects that we are already experiencing due to climate 

change in the Southwest. Of paramount importance is the USFS management response to climate 

change.

Response

Please see the response to comments regarding Climate Change. 

Comment 17.3 

Concern

Old growth and large diameter tree survival are of critical importance in fixing more carbon, 

helping to maintain soil stability, and are less likely to be impacted by fire.

Response

Please see the responses to comments regarding Climate Change and Large Trees.

Comment 17.4 

Concern

The plan as it is written now does not include protections for the goshawk, spotted owl and the 

Jemez Mountains salamander.

Response

Protections are still in place for the goshawk, spotted owl, and the Jemez Mountains salamander.

Please see the response to comments regarding Amendments and Large Trees.

Comment 17.5 

Concern

The Jemez watershed is a crucial source of water for recreation, wildlife and downstream farmers 

and communities. 

Response

Water quality and quantity will be maintained through accomplishment of the project goals. 

Please see the response to comment 7.2. 

Letter 18, Arthur Firstenberg 

Comment 18.1 

Concern

Treatments are counterproductive and will achieve the opposite of their stated purpose.

Response

We appreciate your comment. The commenter offers no real evidence of the cause and effect 

relationship or supporting studies. 
Appendix C. Response to Comments on the DEIS

366 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 18.2 

Concern

I am resubmitting these comments in their entirety because neither the substance nor specifics of 

those comments is adequately addressed in the DEIS, and those comments are still fully valid.

Response

Thank you for your interest in the project. Your comments were addressed in the Scoping Report 

for the Southwest Jemez Mountains Restoration Project of February 2013. 

In summary, the project does not violate any of the laws, policies, or regulations listed by the 

commenter. The DEIS did address climate change in chapter 3 of the DEIS. Our ability to control 

prescribed burns was addressed in the scoping report (page 12), and measures to prevent escaped 

prescribed fires will be listed in the operations plans for the prescribed burns. The effects of an 

escaped prescribed fire on private property were discussed on page 154 of the DEIS. Design 

features and mitigation measures that have been shown to be highly effective in reducing the risk 

of an escaped prescribed fire are described in appendix A of the DEIS. We also reviewed the 

literature provided by the commenter in his first letter. 

Letter 19, Jan Boyer, Once a Forest 

Comment 19.1 

Concern

According to Environment Canada, if you burn 110,000 acres, that will release 529,100 tons of 

carbon, and about 1,590,000 tons of CO2. Aren’t you mandated to protect us from making global 

warming worse?

Response

As noted in the air quality specialist report, carbon dioxide is not a regulated emission. 

See also the response to comments regarding Climate Change. 

Comment 19.2 

Concern

Please do not use potassium permanganate for start the fires. This is a neurotoxin and your plan 

says you will put 3.6 tons of it in watersheds. The MSDS says to never allow potassium 

permanganate to get in streams or waterways.

Response 

The issue of using potassium permanganate to ignite fires using aerial ignition was identified 

during the public scoping period. The full response to this scoping comment can be found in the 

Scoping Report for the Southwest Jemez Mountains Restoration, February 2013. 

Potassium permanganate is a chemical used in aerial ignition devices commonly known as pingpong balls. Ping-pong balls and other prescribed burning ignition devices were assessed for 

human health and ecological risks in Residues of Fire Accelerant Chemicals (LaBat-Anderson 

International 2002). This report found that there were no risks to human health or general wildlife 

species. This is because the amounts of chemicals are very small and they are spread over a large 

area. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 367

Comment 19.3 

Concern

Please do not kill, sell, or burn the big old trees, bigger than 9 inches, really, but at least don’t kill 

the ones bigger than 16”. They do not catch fire in most wildfires, and they are extremely 

valuable for future generations as well as for storing CO2.

Response

Please see the responses to comments regarding Purpose and Need, Climate Change, and Large 

Trees.

Comment 19.4 

Concern

The size of this project is way too big. You are meant to manage these resources to be sustainable 

over a long time, not to be used up in one decade.

Response

The issue regarding the scale of the project was identified during the public scoping period. The 

full response to this scoping comment can be found in the Scoping Report for the Southwest 

Jemez Mountains Restoration, February 2013. 

The project is part of the nationwide Collaborative Forest Landscape Restoration Program 

(CFLRP). The CFLRP encourages restoration treatments at larger scales. Working at a landscape 

scale captures the complex relationships that exist at different levels in an ecosystem. Past 

treatments in the area were more narrowly focused on hazardous fuel reductions or single 

resource needs and conducted on small, disconnected parcels of land. 

Land management agencies, conservation organizations, and researchers have recognized the 

need for landscape-scale treatments to restore the ecological functions. The landscape scale of the 

Southwest Jemez Mountains project is appropriate to move the project area towards the desired 

conditions. 

The project will not deplete natural resources in the Southwest Jemez Mountains. By improving 

and increasing resilience, natural resources in the area will persist in face of climate change and 

other disturbances. 

Comment 19.5 

Concern

Do not do these projects during nesting season. It is bad enough that your firebombing kills all the 

animals and birds, but to call it an amendment when you break the law is maddening. Do not kill 

the songbirds. 

Response

The purpose of and need for this project is to restore forest structure and function and build 

resiliency to landscape level disturbances such as wildfire, insect and disease outbreaks. It is our 

practice to conduct the treatments outside of the migratory bird breeding season to the extent 

possible; however, prescribed fire treatments conducted at any time will likely cause incidental 

injury or mortality of small animals and potentially some nesting neotropical birds. This 

unintentional loss of wildlife is expected to be much less than that experienced during large 

wildfires. 
Appendix C. Response to Comments on the DEIS

368 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Also, the proposed treatments are not expected to negatively affect the viability of wildlife 

populations. Work during the breeding season may be necessary to attain longer term ecological 

gain and will result in net benefits to avian species and other wildlife. Appendix A of the FEIS 

lists design features and other measures to minimize impacts. 

See also the response to comments regarding Forest Plan Amendments.

Comment 19.6 

Concern

Put more emphasis on creating defensible spaces rather than prescribed burns. Even a city 

counselor said, “Why not protect with buffer zones and clearing defensive space?” 

Response

Please see the response to comment 15.1 and the response to comments regarding Purpose and 

Need. 

Letter 20, Anne Bradley, The Nature Conservancy 

Comment 20.1 

Concern

We recommend you clarify the existing distribution of larger trees more specifically. The DEIS 

on page 184 states “We estimate that less than 10 percent of the trees larger than 16 inches would 

be removed to create openings and group structure.” 

Response

Please see the response to comments regarding Large Trees. 

Comment 20.2 

Concern

Incorporating climate change adaptation into project design. During project implementation, we 

recommend including in forest prescriptions the emerging Jemez Mountains science on effects of 

openings and shading on snowpack retention (Veatch, et al. 2009, Harpold, et al., 2014). 

Response

Snowpack retention is not a specific objective of the project. The proposed design criteria will 

create stands of variable density and include the flexibility to adapt to climate change and 

emerging science. Increasing forest resilience to canopy loss in a catastrophic fire would provide 

greater snowpack retention, which is supported by Harpold et al. (2014, p. 451). Harpold et al. 

(2014) found that although the snowpack was deeper in the study site burned by the Las Conchas 

fire, less snow was available for melt than in areas covered by tree canopy. A single snowfall 

event yielded significantly larger snow depths in the post-burn area versus the unburned area. The 

unburned area had roughly 10% more water available for melt than the post-burn area, with 

winter season ablation reducing snowpacks by nearly 50% prior to melt in the post-burn area (p. 

451). 

See also the response to comments regarding Climate Change.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 369

Comment 20.3 

Concern

Where thinning is being considered, snowpack retention would be a beneficial objective to 

include along with wildlife habitat improvement and reduction of crown fire risk. 

Response

We believe that the proposed treatments will enhance snowpack retention; however, snowpack 

retention is not a specific objective of the project. 

See also the response to comments regarding Purpose and Need. 

Comment 20.4 

Concern 

We recommend that you include in the toolbox some guidance that will enhance and maintain the 

collaboration required for the project. As an example, you could include how the design features 

being applied for an individual project should be documented, for the benefit of collaborators and 

forest staff in out years. You could also provide guidance for evaluating project specific 

monitoring information to allow adaptive learning for subsequent projects. 

Response

We are encouraged by the work our partners and the collaborative provided during the 

development of the CFLRP proposal and landscape strategy. We would welcome specific ideas on 

how we might create more effective collaboration as the project transitions from NEPA planning 

to implementation and post treatment monitoring. 

Letter 21, Jose J. Varela Lopez, New Mexico Forest Industry 

Association 

Comment 21.1 

Concern

It is the position of the New Mexico Forest Industry Association (NMFIA) that the proposed 

action (Alternative 1) would be of most benefit to the Forest in reaching its long term goals. 

Response

Thank you for your support and interest in the project. 

Comment 21.2 

Concern

Alternative 5 is expected to produce the largest amount of wood products due to additional 

treatments in “restricted” Mexican owl habitat.

Response

It is correct that alternative 5 is expected to produce the largest amount of wood products. No 

alternative will be implemented in Mexican spotted owl habitat until Endangered Species Act 

consultation with the U.S. Fish and Wildlife Service is completed. 
Appendix C. Response to Comments on the DEIS

370 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 21.3 

Concern

With regard to the “Comparison of Effects of the Different Alternatives” in table 3 of the DEIS, 

the objectives and issues enumerated in the table are instructive to the reader in understanding the 

project in a more detailed manner among the various alternatives. However, we believe that it is 

inappropriate to include the “Roads and engineering” items in this DEIS given that fire or other 

unforeseen circumstances may dictate a change in hauling times and dates.

Response

The proposed action includes road treatments (maintenance, temporary road construction, 

decommissioning, etc.) and development of gravel pits. These components of the proposed action 

are described in chapter 2. Details such as hauling times and dates and circumstances that could 

affect hauling are not specified and are typically addressed in future operating or implementations 

plans or contracts. The roads and engineering section of chapter 3 displays the effects of these 

road treatments and gravel pit development on traffic, noise, and dust. The section also 

acknowledges that the road treatments and gravel pit development may result in effects on 

wildlife, fish, cultural resources, recreation, scenery, and soil and water resources which have 

been described in those particular sections within chapter 3. 

Comment 21.4 

Concern

There should be a substantive narrative, following the table [table 3], which reminds the reader 

that the issues are generally of a short-term duration associated with the implementation of the 

restoration. 

Response

A summary of the effects of the alternatives was provided in table 3 of the DEIS. It is brief and 

allows for comparison of different alternatives. Please refer to chapter 3 for a complete analysis 

of the effects. On a temporal scale, effects of the project range from short term to long term. 

Comment 21.5 

Concern

NMFIA would like to state that we are not in agreement with the statement that “There are no 

harvesting and processing facilities near the project area”, on page 153. While the facilities are 

limited and will require additional capacity to meet the pace and scale of the Southwest Jemez 

Project we do not believe that either transportation costs nor the availability of local contractors 

will be an impediment to the overall project nor substantially increase contractor costs.

Response

We have changed that sentence in the FEIS and added text that better describes wood processing 

facilities in the area, transportation, and hauling costs. 

Comment 21.6 

Concern

If we are to diminish the risks associated with wildfire and tree mortality resulting from our 

overly dense forests it is in our best interest to do as much as we can to restore resiliency.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 371

Response

We agree. Thank you for your support and interest in this project. 

Letter 22, Bryan Bird, WildEarth Guardians 

Comment 22.1 

Concern

The Forest Service failed to conduct a meaningful analysis of these impacts and instead avoided a 

substantive discussion by simply stating that the project “[t]he amount of greenhouse gases 

produced under any alternative is small on a global scale and calculating its impact would be very 

complex and is beyond the scope of this analysis.” 

Response

Please see the response to comment 22.22 and the response to comments regarding Climate 

Change. 

Comment 22.2 

Concern

We were interested that Alternative 3 would result in a difference in only 1,600 acres of 

mechanical treatments, just a half a percent difference, and there would be virtually the same 

change in fire type as the proposed action. We were also intrigued that Alternative 5, which would 

retain the forest plan standards and guidelines for Mexican spotted owl habitat, would actually 

result in more acres of mechanical treatment and the difference in change in fire type nearly 

imperceptible. We hope this will encourage the Santa Fe National Forest to select a modified 

alternative that combines these two and adds no goshawk habitat management amendments.

Response

The Santa Fe National Forest Supervisor is the Forest Service responsible official. She will make 

her decision based on the environmental analysis, public comments (such as this one), and the 

supporting documents in the project record. The Draft Record of Decision will document the 

rationale for the decision of whether or not the proposed action should be implemented as 

proposed, modified by another action alternative, or not implemented at all, and whether to 

amend the forest plan.

Comment 22.3 

Concern

We do not believe that any new temporary roads should be constructed. Any modern, ecological 

restoration project can and should be planned using the existing infrastructure and where thinning 

is absolutely necessary and there are no existing roads, foot-based, hand crews can and should be 

deployed.

Response

Alternative 3 provides the analysis without construction of temporary roads. Table 3, on page 3 of 

the DEIS provides a comparison of the environmental effects of each of the alternatives. Part of 

the purpose and need was to provide wood products for personal and commercial use. 
Appendix C. Response to Comments on the DEIS

372 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

See also comment 9.6 and the response to comments regarding Temporary Roads. 

Comment 22.4 

Concern

Specifically, we strongly oppose these forest plan amendments: (1) Allow treatments in 20 

percent of the MSO protected activity centers rather than 10 percent. (2) Revise paired 

monitoring so that treatment may occur in all six PACs within the project area and better achieve 

desired conditions. (3) Revise treatment within MSO PACs to allow cutting trees up to 18-inches 

diameter, mechanical fuel removal, and prescribed fire to treat fuel accumulations to abate fire 

risk from the 2012 Mexican spotted owl recovery plan (USFWS 2012). (4) Remove language 

specifying the use of thinning from below. Allows for the removal of intermediate size class trees 

for uneven-aged management. (5) Allow treatments to occur during the northern goshawk 

breeding season. (6) Add language to allow for interspaces between vegetative groups in northern 

goshawk habitat. (7) Remove restrictions for turkey nesting areas to allow for treatments to occur 

within the breeding season. (8) Revise the forest plan direction for peregrine falcon management. 

These amendments are unnecessary and in fact several have been a topic of recent litigation 

between WildEarth Guardians, the Center for Biological Diversity and the U. S. Forest Service.

Response

We can appreciate the fact that you oppose proposed site-specific Forest Plan amendments; 

however, we respectfully do not agree that the amendments are unnecessary. 

Please see the response to comments regarding Forest Plan Amendments. 

Comment 22.5 

Concern 

As discussed in detail below, some of these amendments are being invoked on a site-specific 

basis on projects across the Southwest Region and thus the impacts on wildlife are not being 

considered in any comprehensive analysis under the National Environmental Policy Act (NEPA) 

nor Forest Service rules or directives. 

Response

Please see the response to comments regarding Forest Plan Amendments. 

Comment 22.6 

Concern

NFMA requires “one integrated plan” for each national forest, incorporating in one document or 

one set of documents, available to the public, all the features required by NFMA. 16 U.S.C. § 

1604(f)(1). After a Forest Plan is adopted, the Forest Service may only amend the Plan pursuant 

to specific public notice participation requirements. Id. at § 1604(f)(4). 

Response

These are site-specific amendments. Please see the response to comments regarding Forest Plan 

Amendments. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 373

Comment 22.7 

Concern

The SWJM project appears to implement the new goshawk guidelines, including how it measures 

canopy cover and vegetation classes. The Forest Service, however, has not amended the Forest 

Plan to incorporate the new guidelines. The Forest Service also did not prepare either an 

environmental assessment or impact statement regarding the New Guidelines, and also failed to 

amend the Forest Plans in Region 3 to properly adopt them before implementing the Guidelines 

in site-specific projects such as this one.

The Forest Service also did not prepare either an environmental assessment or impact statement 

regarding the New Guidelines, and also failed to amend the Forest Plans in Region 3 to properly 

adopt them before implementing the Guidelines in site-specific projects such as this one.

Response

There are no new goshawk guidelines. Please see the response to comment 22.32. 

Comment 22.8 

Concern

Until such time as these changes in goshawk habitat management are considered in a regionwide 

NEPA process, we believe the forest is in violation of NEPA, NFMA and Forest Service rules and 

directives

Response 

Please see the response to comment 22.7. 

Comment 22.9 

Concern

We referenced the work of Prather et al. (2008) and Dr. Don Falk in our 2012 comments on the 

proposed action but it appears the forest ignored this science. Prather, in particular, concludes 

“within the areas where conflicts might be expected, the majority of the forest could be managed 

in ways that would reduce fire hazard without eliminating owl habitat.”

Response

The commenter mentioned references by Dr. Don Falk, and NAU forestry scientists, but did not 

provide the citations or any discussion as to the relevance to this project. The commenter also did 

not provide any interpretation as to how the provided material would influence the proposal, 

analysis or the decision within the context of the purpose and need of the project. 

We cited Prather et al. (2008) in chapter 2 of the DEIS. The article discusses both fuel reduction 

treatments and restoration treatments. The quote from the article in the commenter’s letter refers 

to fire hazard reduction treatments and is not relevant because this is not a fire hazard reduction 

project. 

We believe that Prather et al. 2008 offers support for the Southwest Jemez landscape restoration 

project, “Although aggressive thinning may reduce owl habitat quality in a specific location, 

when examined from a landscape perspective, well-placed thinning and prescribed fire can 

enhance overall owl habitat quality, both through improving the quality of marginal stands and 

reducing the likelihood of large losses of habitat from stand-replacing fire,” (p. 148); and 
Appendix C. Response to Comments on the DEIS

374 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

“Arguments that treatments within owl habitat are generally unnecessary are short-sighted,” (p. 

148). 

Comment 22.10 

Concern

The federal Administrative Procedure Act, 5 U. S. C. 706 (2) (A), prohibits an agency from acting 

in an arbitrary and capricious fashion. Fair and honest procedures are also an element of 

complying with NEPA. Under NEPA regulations, an EIS “shall provide full and fair discussion of 

significant environmental impacts.” 40 C.F.R. 1502.1. To assure that a “fair discussion” occurs, 

agencies are required to obtain “high quality” information, including “(a)ccurate scientific 

analysis.” 40 C.F.R. 1500.1(b). The regulations are explicit that: “Agencies shall insure the 

professional integrity, including scientific integrity, of the discussions and analyses in 

environmental impact statements.” 40 C.F.R. 1502.24. In particular the DEIS and specialists 

reports are rife with omissions, false assumptions and arbitrary conclusion. The most significant 

flaws rendering all of the findings in the DEIS and specialists reports arbitrary and capricious 

concern forest conditions, fire history, silviculture, fire behavior effects and climate change. The 

DEIS and specialists reports assume that the no action alternative is equivalent to a single large 

fire event in which all above ground vegetation is consumed entirely across much of the planning 

area. Not only is this not realistic as borne out in the best available science, it’s next to 

impossible, but it entirely skews all of the findings.

Response

We conducted our NEPA process and prepared our NEPA documents for the Southwest Jemez 

Mountains Landscape Restoration Project pursuant to the NEPA statute (42 U.S.C 4321 et seq.), 

the NEPA implementing regulations promulgated by the Council on Environmental Quality (40 

CFR Parts 1500-1508), the Forest Service NEPA regulations (36 CFR part 220), Forest Service 

NEPA policy (FSM 1900 Chapter 1950), and the Forest Service NEPA Handbook (FSH 1909.15). 

We stand behind the analyses conducted by our specialists, the specialists’ reports and the 

information presented in the DEIS. A review of table 3 in chapter 2 of the DEIS summarizes and 

compares effects of the four action alternatives and the no action alternative will reveal that your 

allegation regarding the no action alternative is unwarranted. We estimate that the percent of area 

in surface fire is less under the no action alternative (about 50 percent) than under the other 

alternatives (about 72-79 percent).

The no action alternative, similar to the other alternatives, analyzes the potential fire behavior 

effects under the identified fire weather conditions (fuels specialist report, p.11, figure 3) for the 

entire analysis area. This analysis was not meant to imply that a single large wildfire event is 

going to burn across the entire landscape. It tells us about the potential fire behavior under the 

identified fire weather conditions if a wildfire were to burn across a location on the landscape and 

how it compares across the alternatives. 

FlamMap was not used to model fire spread; the data themes that make up the landscape data file 

(fuels specialist report, p. 9) act independently of any adjacent cell’s resulting fire behavior. This 

means active crown fire cannot “spread” cell to cell and cells are not influenced by neighboring 

cells. Spotting is not modeled in FlamMap. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 375

Comment 22.11 

Concern

The Silviculture Report (pp. 25-26) for instance bases its assumptions about “reference” 

conditions in these forests upon an unpublished report from the Ecological Restoration Institute 

(ERI) that selected locations for a mere 41 plots, ostensibly to estimate pre-1880 forest density, 

using stumps and downed logs. The unpublished report claimed that historical forests only had 

25-41 trees per acre in ponderosa pine forest and only 30-50 per acre in dry mixed--conifer forest, 

and asserted that current forest density is 200-1000 trees per acre. There are three major problems 

with this. First, the unpublished report from the ERI only used a very small number of plots that 

cannot adequately represent the natural range of variability of such a large landscape. Second, 

there is no scientifically valid way to determine the pre-1880 density of smaller trees (which are 

generally the most numerous) from stumps and logs, for the simple reason that any smaller trees 

that died pre-1880 would have long since decayed into soil and no evidence would remain (only 

evidence of the smaller number of larger trees would remain). The claim regarding current 

densities of 200-1000 trees per acre include saplings, and pre-1880 sapling density cannot be 

estimated using current stumps and logs. Third, when a vastly larger sample size of plots is used, 

and the plots were surveyed in the late 1800s (i.e., they are actual historical data), the data show 

that historical ponderosa pine and mixed--conifer forests of the southwestern U.S. often had 

densities 2-3 times higher than the ERI report estimates-not including trees under 4 inches in 

diameter (Williams and Baker 2012).

Response

Reference conditions have been established for southwestern forests; there are many papers in the 

literature that describe these conditions. Some of this research was reviewed by Reynolds et al. 

2013. The results from the ERI report were included in detail because it is a site-specific study. 

Pages 26-30 of the silviculture specialist report describe the complexity of reference conditions in 

various forest types including basal area, size and structure, spatial patterns, group size, and 

openings. We are not attempting to re-create reference conditions with this project. 

See also the response to comment 15.1. 

Comment 22.12 

Concern

The Fire and Fuels Report’s assessment is based upon several assumptions that are now 

scientifically outdated, and have been proven to be incorrect by multiple lines of scientific 

evidence. First, the Report assumes, based upon older studies and studies that merely speculated 

about historical fire severity without empirically testing assumptions (pp. 2--3), that historical fire 

in ponderosa pine and mixed--conifer forest in the southwestern U.S. was overwhelmingly low--

severity, and that current proportions and amounts of high--severity fire are “uncharacteristic” in 

these forests. However, current data, based upon multiple lines of evidence, including numerous 

historical U.S. government surveys and mapping, modern reconstructions of historical fire 

severity, and stand age class analyses in unmanaged forests, demonstrate that the ponderosa pine 

and mixed--conifer forests of the southwestern U.S. had a mixed--severity fire regime-one that 

included substantial moderate-- and high--severity fire, and both small and large patches of high--

severity fire-and stand structure was highly variable, and included some open stands and many 

moderately to very dense forests (Williams and Baker 2012, Odion et al. 2014). Paleoecological 

studies also support mixed--severity fire regimes for the ponderosa pine and mixed--conifer 
Appendix C. Response to Comments on the DEIS

376 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

forests in the southwestern U.S., including specifically in the Jemez Mountains (Brunner Jass 

1999, Allen et al. 2008, Jenkins et al. 2011). These studies have found charcoal depositions from 

major fire episodes in these forest types occurring for millennia. These major episodes are 

generally interpreted as large, severe fire events (Brunner Jass 1999, Allen et al. 2008, Jenkins et 

al. 2011).

Response

Please see the response to comment 15.1.

Comment 22.13 

Concern

In fact, the historical high-severity fire proportions in southwestern ponderosa pine and mixed--

conifer forests ranged from 15-55%, and even the larger, more intense of current fires are well 

within this natural range of variability (Williams and Baker 2012 [Table 2]). Further, contrary to 

the assumption in the Report about uncharacteristically high amounts of high-severity fire 

currently, the most extensive analysis of historical high-severity fire occurrence ever conducted 

recently found, based upon multiple lines of scientific evidence, that southwestern U.S. forests 

now have substantially less high-severity fire than they did prior to fire suppression (Odion et al. 

2014). The Report (p. 14), predicts that, under extreme fire weather, approximately 14,415 acres 

of the 69,319 acres of ponderosa pine and mixed--conifer forest in this landscape (21% overall, 

and 14% in ponderosa pine forest specifically) will experience high-severity fire (active crown 

fire), and the Report claims much lower levels of high-severity fire for the action alternatives. 

However, a high-severity fire proportion of 21% is well within the natural range of variability in 

these forests, as discussed above. The action alternatives, in contrast, seek to create 

overwhelmingly lower-severity fire effects/conditions that, if they occurred as claimed in the 

report, would create unnatural conditions.

Response

Please see the response to comment 15.1. 

Comment 22.14 

Concern

Second, the Report (pp. 8-11) bases its fire effects assessment upon outdated modeling 

assumptions about the effectiveness of fuel treatments in preventing high-severity fire in high and 

extreme fire weather conditions. More current data indicate that active crown fire can and will 

occur in high/extreme fire weather even in very open forests. Based on direct observations of fire 

behavior, high winds (generally 10 m open wind speeds greater than 32-35 kilometers/hr) may 

subject virtually any conifer forest, regardless of fuel density, to crown fire (Cruz and Alexander 

2010). Thus, the assumption in the Report that the thinned forests-even in high/extreme fire 

weather-will be almost completely resistant to crown fire is erroneous (the Report, on p. 14, 

assumes only about 3 to 4 percent high-severity fire in the thinning alternatives within mixedconifer and ponderosa pine forest in high/extreme fire weather). Fire intensity increases with 

winds, and at winds of greater than 30 km/hr, spot fires may be ignited over 1 km ahead of the 

fire front (Albini 1983). The coalescing of separate spot fires with the fire front can further 

energize wind-driven fire (Cheney 1981, Finney and McAllister 2011). Severe droughts also 

intensify fires by reducing fuel moisture to extremely low levels, allowing crown fire under less 

windy conditions (Cruz et al. 2004, Cruz and Alexander 2010). Severe drought years throughout 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 377

much of western North America occurred from 1856 to 1865, 1870 to 1877, and 1890 to 1896 

(Herweijer et al. 2006), and periodically such droughts will continue to occur. 

Response

Yes, as you stated, under extreme weather events active crown fire still can occur even in open 

stands. As indicated on page two of the fuels specialist report, a landscape scale approach, such as 

proposed for this project, helps ensure fuel reduction treatments affect wildfire behavior and 

reduce the extent of uncharacteristically severe wildfire (Schmidt et al. 2008). If the treatments 

are too small they will be overwhelmed in a high severity wildfire (Moghaddas et al. 2010) and 

will do little to influence large fire behavior or spread. 

The Southwest Jemez Mountains Landscape Restoration Project however is not just a fuel hazard 

reduction project but a restoration project. Forest restoration focuses on returning key processes 

to ecosystems and encouraging a structure and species composition based on the idea that 

ecosystems are the most resilient and healthy when they are within the range of conditions to 

which their species have adapted (Swanson et al. 1994), otherwise known as the historical range 

of variability (HRV). 

See also the responses to comments 15.7 and 22.10. 

Comment 22.15 

Concern

For the foregoing reasons, the DEIS’s proposal, in all action alternatives, to mechanically thin 

approximately 30,000 acres of forest in the project area, is unnecessary, would be ineffective, and 

would create novel, and unnaturally homogeneous conditions that would not reflect natural 

disturbance regimes to which native biodiversity in these forests is adapted. Third, the Report is 

inherently based upon the assumption that the mechanical thinning of approximately 30,000 acres 

of forest in order to prevent 21% high-severity fire effects would be ecologically beneficial, and 

that the 21% predicted high-severity fire effects in the no action alternative (under high/extreme 

fire weather) would be ecologically harmful. If the historic record of fire is accurate, the 

ecological effects are not only normal, but also perhaps beneficial. The post-fire habitat created 

by high-severity fire (known as “snag forest habitat”) is one of the rarest and most biodiverse of 

all forest habitat types, and many wildlife species depend upon this habitat (Kotliar et al. 2002, 

Swanson et al. 2011).

Response

We do believe that our approach and the treatments we proposed will be ecologically beneficial. 

Mechanical thinning would be variable, to suit the particular landscape, stand history, topography, 

and wildlife needs. Chapters 2 and 3 of the DEIS present the proposed action and alternatives and 

the environmental consequences of each.

We agree that some early succession habitat is desirable, and plan to have all successional stages 

represented on the landscape (pp. 27-28 of the silviculture specialist report). As fire plays its 

natural role, openings and snags will be created. We think that in the ponderosa and dry mixed 

conifer vegetation types, these openings should occur at the fine scale (tens of acres) rather than 

the landscape scale (thousands of acres). In wet mixed conifer, early successional openings may 

occur at the mid-scale (hundreds of acres). We intend to follow the Forest Plan in leaving at least 

2 snags per acre; some areas will have more. Also, burned patches will have groups of snags. 
Appendix C. Response to Comments on the DEIS

378 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

See also the response to comment 22.14.

Comment 22.16 

Concern

Finally, we request that the FEIS consider a quantitative risk assessment that would clarify 

whether or not managing the area with mechanical thinning treatments is the best approach for 

risk management. Additionally, there are often severe consequences to resources associated with 

mechanical thinning which could be avoided with a more efficient prescribed burn program. We 

request that the Santa Fe National Forest consider closing or at very least resting the grazing 

allotments within the planning area to assure that costly fuels treatments are effective. Unless the 

livestock are removed from the planning area, “ecological functionality of fire [in] fire adapted 

ecosystems” is practically impossible and this reality must be addresses in an EIS. It is critical 

that the FEIS consider a statistically-valid risk (note that risk in this context should not be 

confused with hazard) of catastrophic fire as well as the required maintenance schedule and costs 

to keep that risk low against the impacts from logging on other non-timber resources such as 

wildlife viability, soil conditions and water quality. The transient effects of treatments on fuels, 

coupled with the patchy nature of fire, greatly limit their potential effectiveness. As a result, in the 

majority of treated areas, treatments will only have negative watershed effects without providing 

any compensatory benefits from reduced fire severity. Rhodes and Baker (2008) provide a 

“framework for quantitatively bounding the potential effectiveness of fuel treatments and the 

likelihood of fire affecting untreated watersheds, based on the probability of fire and the duration 

of treatment effects on fuels.” For example, Rhodes and Baker (2008) estimate the probability of 

a moderate to high intensity fire in any given area of Southwestern ponderosa pine forests as 

.0025% per year, or 15% over 60 years. Such an assessment using local fire risk data is not 

complicated; the equations are provided in Rhodes and Baker (2008) and should be a fundamental 

component of the EIS.

Response

Focusing project activities solely on mitigating wildfire risk or wildfire risk management would 

not meet the purpose and need. The purpose and need is about more than risk reduction; it is 

focused on restoration. One goal is to create conditions that would allow low-intensity surface 

fires to burn through the landscape. Please refer to chapter 1 of the FEIS for the purpose and need 

statement. 

See also the response to comments regarding Purpose and Need and comment 8.8 regarding 

grazing. 

Comment 22.17 

Concern

Due to the transient effects of treatments on fuels, because of natural vegetative regrowth, 

treatments likely will have to be repeated over time, thereby increasing cumulative effects and 

fiscal commitment, which must be accounted for in an EIS. For instance, “the treatment of 20 

percent of a watershed’s area twice over a twenty-year period contributes as much or more 

sediment delivery than treating 40 percent of a watershed in a single entry.” (Rhodes 2007).

Response

The action alternatives considered repeated prescribed fire treatments and those effects have been 

disclosed (see chapter 3 of the DEIS). The watershed specialist report analyzed the effects of 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 379

prescribed fire with an initial prescribed fire and maintenance burns through the EDA/ERA 

calculations, (table 14, pp. 64-65). The costs of repeating treatments were included in the 

economic efficiency analysis (DEIS, pp. 152-153). Treatments that reduce the watershed impacts 

from severe fire outweigh the impacts and damage from implementing the treatments.

Comment 22.18 

Concern

The DEIS and climate change specialist report on climate change are fatally unsophisticated and 

fail entirely to understand or treat the issue of climate change and carbon budgets adequately, 

failing entirely to make use of or consider the best available science. The analysis is predicated on 

the false assumption that a wildfire would burn every acre of the planning area in a single event 

and completely transfer all of the carbon from biomass to the atmosphere. “The analysis also 

demonstrated that the amount of carbon dioxide and greenhouse gases produced by a wildfire that 

burned the entire project area would be greater than any of the alternatives.” (Emphasis ours). 

Climate Change specialist report at 3. This is an untenable assumption and is countered by fire 

behavior and burn severity distribution in recent fires in the Jemez Mountains. The Climate 

Change report, throughout, assumes that hotter and drier conditions will occur in southwestern 

U.S. forests, and that there will be more fire. This is, of course, a possibility. However, the 

Climate Change report neglects to divulge that most of the major current climate modeling 

studies predict less fire (Krawchuk et al. 2009), a mix of modest increases and decreases 

(Gonzalez et al. 2010), or no change (Moritz et al. 2012) in future decades in southwestern U.S. 

forests under climate change, not simply more fire. The failure to honestly divulge the uncertainty 

in current climate projections-including projections that contradict the assumptions used in the 

DEIS to promote landscape-level mechanical thinning-undermines the scientific credibility of the 

analysis.

Response

The emissions analysis for air quality and the fire behavior modeling did not assume that all acres 

were burned in a single wildfire event. They modeled the potential fire behavior on emissions 

produced by fire on the land within the project area given certain fuel, weather, and other 

conditions. The parameters and assumptions used in the both models are discussed in the air 

quality and fuels specialist reports and related material in the project record. The statement 

referred to by the commenter has been clarified in the climate change report and climate change

section of the FEIS. 

We agree that there is uncertainty regarding future climate conditions under all scenarios. 

Creating landscape conditions that increase resilience would be beneficial regardless of the nature 

of future conditions.

The current climate modeling studies provided by the commenter are not applicable. The studies 

address net changes in wildfire on a global scale and did not specifically mention Southwestern 

U.S. forests. Gonzalez et al. 2010 note that their study is appropriate for global or regional 

planning. Applying these results to the local scale of our project is misleading. 

See also the response to comments regarding Climate Change and the responses to comments 

15.1 and 22.22. 
Appendix C. Response to Comments on the DEIS

380 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 22.19 

Concern

The DEIS does not include the emissions from treatment operations proposed in each action 

alternative.

Response

Table 3 in chapter 2 of the DEIS summarizes emissions from prescribed fire proposed for each 

action alternative. Chapter 3 of the DEIS includes a section on air quality and includes estimated 

CO2 emissions for each alternative. Prescribed burning represents 99% of the CO2 equivalent 

emissions from each alternative. We have updated the FEIS this to include CO2 emissions from 

treatments other than prescribed fire. The analysis shows that fossil fuel emissions associated 

with mechanical harvesting, timber hauling, gravel pit operations, and road maintenance and 

construction total 2,100 metric tons over the life of project, or less than one percent (.09%) of the 

total CO2 emissions over the entire life of the project. This is equivalent to 1.5 hours of carbon 

dioxide emissions from an average coal fired power plant. For more, details see the Air Quality 

section of the FEIS and the air quality specialist report. 

See also the response to comments regarding Climate Change. 

Comment 22.20 

Concern

Nearly all of the conclusions and assertions in the project record are either not consistent with the 

best available science or contradict that science. (Climate Change specialist report at 3.)

Response

Please see the response to comments regarding Climate Change. 

Comment 22.21 

Concern

The National Environmental Policy Act of 1969 (“NEPA”), 42 U.S.C. § 4321 et seq., and 

applicable regulations require the agency to analyze the cumulative impact of a proposed project 

“when added to other past, present, and reasonably foreseeable future actions” regardless of the 

source of the future actions. 40 C.F.R. § 1508.7.

Response

The definition of cumulative impact is defined in the NEPA regulations (40 CFR 1508.7) as “the 

impact on the environment which results from the incremental impact of the action when added to 

other past, present, and reasonably foreseeable future actions regardless of what agency (Federal 

or non-Federal) or person undertakes such other actions. Cumulative impacts can result from 

individually minor but collectively significant actions taking place over a period of time.” The 

Forest Service NEPA Handbook includes the following additional information regarding 

cumulative effects analysis: “Spatial and temporal boundaries are the two critical elements to 

consider when deciding which actions to include in a cumulative effects analysis. Spatial and 

temporal boundaries set the limits for selecting those actions that are most likely to contribute to a 

cumulative effect. The effects of those actions must overlap in space and time for there to be 

potential cumulative effects.” 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 381

Comment 22.22 

Concern

The new USDA Strategic Plan for 2010-1015 sets a departmental goal to “Ensure our national 

forests and private working lands are conserved, restored, and made more resilient to climate 

change, while enhancing our water resources.” As a measure of this goal, all National Forests are 

to come into compliance with a climate change adaptation and mitigation strategy. To guide the 

Forest Service in achieving this goal, a Roadmap for Responding to Climate Change was 

developed. The Roadmap integrates land management, outreach, and sustainable operations 

accounting. “..... increase the amount of carbon sequestered on U.S. lands, and bring all National 

Forests into compliance with a climate change adaptation and mitigation strategy...Planning units 

are expected to include a basic analysis of conditions and trends of carbon stocks and fluxes on 

the planning unit and greenhouse gas emissions influenced by the management of the planning 

unit,” (USFS Planning Rule).

Response

We believe that our project is consistent with the USDA Strategic Plan for 2010-1015. Our 

treatments would restore and enhance resilience. We disagree that project level analysis is subject 

to the planning rule. Analysis of carbon stocks is a requirement of the planning rule, and not 

project level NPEA. When the forest plan is revised, the conditions and trends of carbon stocks 

and fluxes will be evaluated. 

We have complied with agency guidance addressing climate change considerations in projectlevel NEPA analysis (USFS 2009). The basic concepts and how we addressed them are: 

• Consider two types of climate change effects (1) the effect of a proposed project on 

climate change and (2) the effect of climate change on a proposed project. For our 

project, effects were disclosed and presented in chapter 3. 

• The Agency may propose projects to increase the adaptive capacity of ecosystems it 

manages, mitigate climate change effects on those ecosystems, or to sequester carbon. 

For our project, the purpose of our project is to restore ecosystem structure and function 

and increase resilience to undesirable, large-scale disturbances to such as severe wildfires 

and climate change. The Southwest Jemez Mountains addresses the first two points. 

• It is not currently feasible to quantify the indirect effects of individual or multiple 

projects on global climate change and therefore determining significant effects of those 

projects or project alternatives on global climate change cannot be made at any scale. For 

our project, the climate change analysis in chapter 3 of the DEIS stated this (page 68). In 

response to comments on the DEIS, however, we did calculate and analyze CO2

emissions from project activities other than prescribed fire. These results are discussed in 

the air quality and climate change sections of chapter 3. 

• Some project proposals may present choices based on quantifiable differences in carbon 

storage and GHG emissions between alternatives. This was not applicable to this project 

because it is a restoration project, not a carbon sequestration project. 

Climate change has been consideration throughout the NEPA process and the pre-NEPA analysis 

as well. Increasing resilience to climate change was part of the Landscape Strategy (USFS and 

VCNP 2010) proposal developed for the CFLRP. 
Appendix C. Response to Comments on the DEIS

382 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

See also the responses to comments regarding Climate Change and Purpose and Need. 

Comment 22.23 

Concern

This conclusion is arbitrary and capricious on its face, and even more so in view of NEPA’s 

requirement that an agency consider cumulative impacts by analyzing the incremental effect of an 

action in light of other “past, present, and reasonably foreseeable actions.” Ctr. for Biological 

Diversity v. NHTSA, 508 F.3d 508, 549 (9th Cir. 2007) (concluding agency’s NEPA analysis of 

cumulative effects inadequate where it related to global warming impacts because the agency 

“does not evaluate the ‘incremental impact’ that these emissions will have on climate change or 

on the environment more generally in light of other past, present, and reasonably foreseeable 

actions such as other light truck and passenger automobile CAFE standards”). This non--

discussion is an abdication of the Forest Service’s statutory duties under NEPA. “A cumulative 

effects analysis must be more than perfunctory; it must provide a useful...

Response

Please see the response to comments regarding Climate Change.

Comment 22.24 

Concern

The DEIS and climate change specialists report should have at very least utilized the forest 

carbon calculator, an interface and set of carbon models to help you examine how carbon stores in 

the forest sector change over time. The forest carbon calculator was developed by scientists at 

Oregon State University and the USDA Forest Service and allows for selection of different 

regions, past histories of disturbance and management as well as alternative futures. Calculations 

can be done for a single stand or for an entire landscape. Reports and time trend graphs on stores 

in the forest, in wood products and disposal can be generated.

Response

The model suggested by the commenter was developed for the east and west sides of the Cascade 

Mountains in Oregon. This model is not appropriate for use on our project because it does not 

have parameters developed for areas outside of the Cascades. 

See also the response to comments regarding Climate Change.

Comment 22.25 

Concern

The NEPA analysis should start with an accurate and up-to-date inventory of carbon storage and

carbon flows on federal land. This is required by both the National Forest Management Act (16 

USC §1601(a)(1) and (2)) and the Federal Land Policy and Management Act (43 USC §1711(A)). 

The NEPA analysis should disclose and consider that logging has several adverse consequences 

on GHG pools and flows. Fuel treatments can reduce both tree mortality and emissions from 

wildfire, but heterogeneous burn environments, variability in post-fire ecosystem response, and 

uncertainty in future fire frequency and extent complicate assessments of long term (decades to 

centuries) C dynamics across large landscapes. Logging kills growing trees that would otherwise 

continue to capture and sequester carbon through photosynthesis. Killing the trees also stops them 

from pump carbon into the soil where a lot of carbon is stored. Forests deliver massive amounts 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 383

of carbon into the soil as photosynthate that supports a vast below-ground ecosystem and as 

course woody debris. Logging kills the food supply for the below-ground ecosystem. “Contrary 

to commonly accepted patterns of biomass stabilization or decline, biomass was still increasing in 

stands over 300 years old in the Coast Range, the Sierra Nevada and the West Cascades, and in 

stands over 600 years old in the Klamath Mountains.” Hudiburg et al. 2009.

Response

Neither law specifically requires the analysis of carbon storage and flows. 

See also response to comments regarding Climate Change. 

Comment 22.26 

Concern

The following is an excerpt from Ron Bass’s presentation, “NEPA and Climate Change: What 

Constitutes a Hard Look?” The recommended 10-step approach takes into consideration the 

existing provisions of the NEPA regulations, recent court decisions, and various state programs. 

The steps conform to the main elements of a NEPA document. Affected Environment Step 1 - 

Describe the existing global context in which climate change impacts are occurring and are 

expected to continue to occur in the future. Step 2 - Summarize any relevant state laws that 

address climate change. Step 3 - Describe any relevant national, statewide, and regional GHG 

inventories to which the project will contribute. Environmental Consequences Step 4 - Quantify 

the project’s direct and indirect GHG emissions. Step 5 - Convert the GHG emissions into carbon 

equivalents using an established “carbon calculator.” Step 6 - Discuss whether the project would 

enhance or impede the attainment of applicable state GHG reduction. Step 7 - Describe the 

cumulative global climate change impacts to which the proposed action would contribute, i.e., the 

impacts of the project on climate change. (This may use the same information as in Step 1.) Step 

8 - Describe how the impacts of global climate change could manifest themselves in the 

geographic area in which the project is proposed, and therefore potentially affect the project, i.e., 

the impacts of climate change on the project (e.g., sea level rise could affect a coastal project). 

Alternatives Step 9 - Include alternatives that would meet the project objectives but would also 

reduce GHG emissions. Mitigation Measures Step 10 - Identify mitigation measures that would 

reduce GHG emissions, including both project design or operational changes and potential 

compensatory mitigation (e.g., carbon offsets). (Emphasis ours).

Response

We appreciate your opinion. We believe we have complied with NEPA regarding climate change. 

See also the response to comment 22.22 and the response to comments regarding Climate 

Change. 

Comment 22.27 

Concern

The DEIS failed to consider reasonable alternatives. Informed consideration of alternatives is the 

“heart” of the National Environmental Policy Act (“NEPA”) because it allows sharp definition of 

relevant issues for environmental analysis and provides a clear basis for choice among options by 

the decision maker and the public. 40 C.F.R. § 1502.14. NEPA requires that federal agencies 

consider alternatives to proposed actions whenever those actions “involve[] unresolved conflicts 

among alternative uses of available resources.” U.S.C. § 4332(2)(E). A “rule of reason” guides 
Appendix C. Response to Comments on the DEIS

384 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

both the choice of alternatives as well as the consideration of “reasonable alternatives.” City of 

Carmel--by-- the--Sea v. U.S. Dept. of Transportation, 123 F.3d 1142, 1149 (9th Cir. 1997). 

Further, the requirement to consider alternatives applies equally to environmental assessments as 

to environmental impact statements. “‘[A]ny proposed federal action involving unresolved 

conflicts as to the proper use of resources triggers NEPA’s consideration of alternatives 

requirement, whether or not an EIS is also required.” Bob Marshall Alliance v. Hodel, 852 F.2d 

1223, 1229 (9th Cir. 1988); see also Environmental Protection Information Center v. U.S. Forest 

Service, 234 Fed. Appx. 440, 442 (9th Cir. 2007) (“NEPA requires an agency to consider a 

reasonably full range of alternatives to its project action, even when an [EIS] is not required”). A 

forthright comparison of reasonable alternatives would permit informed consideration by the 

decision maker and the public of what activities are required to meet the purpose and need for 

action. “The purpose of NEPA is to require disclosure of relevant environmental considerations 

that were given a ‘hard look’ by the agency, and thereby to permit informed public comment on 

proposed action and any choices or alternatives that might be pursued with less environmental 

harm.” Lands Council v. Powell, 395 F.3d 1019 (9th Cir. 2005). Dismissal of reasonable 

alternatives from detailed study, without reference to site--specific data, is arbitrary and 

capricious. See Idaho Sporting Congress v. Thomas, 137 F.3d 1146 (9th Cir. 1998) (NEPA 

requires the public to receive the underlying environmental data from which the Forest Service 

experts derive their opinions and conclusions).

Response

According to CEQ’s Regulations for Implementing NEPA (NEPA regulations) Section 

1502.14(a), agencies shall “Rigorously explore and objectively evaluate all reasonable 

alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the 

reasons for their having been eliminated.” 

Consistent with Section 1502.13 of the NEPA regulations, which state that the environmental 

impact statement “shall briefly specify the underlying purpose and need to which the agency is 

responding in proposing the alternatives including the proposed action,” the DEIS described our 

underlying purpose and need for action (pp. 12-14 of the DEIS). We developed the proposed 

action and alternatives to be responsive to this purpose and need. The interdisciplinary team used 

comments from the public and within the Forest Service along with modeling and field surveys to 

modify the proposed action and formulate alternatives to the proposed action. Five alternatives 

were analyzed in detail in the DEIS:

• alternative 1, the proposed action 

• alternative 2, no action 

• alternative 3, no temporary roads 

• alternative 4, no prescribed fire in mechanical treatment areas, and 

• alternative 5, implement restoration treatments while conforming to the existing forest plan 

standards and guidelines for managing Mexican spotted owl habitat (Amendment 6, 

1996). 

Alternatives 3 and 5 were developed based on public comments. This is a reasonable range of 

alternatives that included major differences in proposed treatments (for example, no construction 

of temporary roads and no prescribed fire in mechanical treatment areas). Alternatives that would 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 385

not meet or that were found to be inconsistent with our purpose and need were not considered 

further, with the exception of the no action alternative (alternative 2).

Effects of the five alternatives were objectively evaluated. Table 3 in the DEIS (pp. 48-51) 

summarized the environmental consequences and showed the differences between alternatives. 

Detailed information on analysis methods and environmental consequences of each alternative is 

provided in the multiple resource specialist reports and in chapter 3 of the DEIS. The specialists’ 

reports were incorporated by reference into the DEIS.

Consistent with Section 1502.14(a) of the NEPA regulations, on pages 46-47 of the DEIS, we 

presented three alternatives that were considered but eliminated from detailed analysis and briefly 

discussed the reasons for their having been eliminated.

Comment 22.28 

Concern

The Forest eliminated several reasonable alternatives arbitrarily. In particular the “16-inch 

diameter cap” alternative and the “reduce mechanical treatments in Jemez Mountains salamander 

habitat” alternative. 

Response

These alternatives were considered but eliminated from detailed study. The reasons for 

eliminating from further study are described in the DEIS (chapter 2, pp. 46 and 47). 

Comment 22.29 

Concern

The Old Growth Protection and Large Tree Retention Strategy (“strategy”) collaboratively 

developed by public stakeholders for implementation in the Four Forest Restoration Initiative is 

an “agreement-based outcome and product” recognizing that “translation of such agreement 

greatly enhances chances for success, and reduces the risk of conflict.” It defines the “social 

license” for ecological restoration requested by the Regional Forester. More, on July 2, 2013, the 

Forest Supervisor of the Apache-Sitgreaves National Forests committed to implement the strategy 

in the Rim Lakes Project. It is a reasonable alternative for this project.

Response

See also the response to comments regarding Large Trees.

Comment 22.30 

Concern

The DEIS reasons that the reason mechanical treatments in Jemez Mountains salamander habitat 

alternative was eliminated because design criteria were added to all the action alternatives to 

address “the primary threat to the salamander (uncharacteristically severe wildfire).” DEIS at 47. 

This statement completely ignores the other threats identified for the salamander, arbitrarily

Response

Additional information addressing the threats and effects from project activities is available in the 

revised Biological Assessment. The Forest Service has completed ESA consultation with the U.S. 

Fish and Wildlife Service. 
Appendix C. Response to Comments on the DEIS

386 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 22.31 

Concern

The agency simultaneously proposes the same or similar plan amendments in concurrent projects 

across the region including on the Kaibab and Coconino national forests. Their cumulative effect 

is to render meaningless existing forest plans and invalidate biological opinions and associated 

incidental take statements on implementation of forest plans

Response

Please see the response to comments regarding Forest Plan Amendments. 

Comment 22.32 

Concern

It is our opinion that the Forest Service has not allowed any public input, notice, or participation 

regarding the “New Guidelines” during their development or prior to their implementation. The 

Forest Service is therefore violating NFMA by either (1) implementing a de facto amendment of 

the northern goshawk standards and guidelines for the Santa Fe Forest Plan without compliance 

with the NFMA procedures for Forest Plan amendments or (2) failing to properly amend the 

Forest Plan before implementing the New Goshawk Guidelines, without public notice, and in 

violation of NFMA. See Oregon Natural Resources Council v. Forsgren, 252 F.Supp.2d 1088, 

1096-- 97 (D. Or. 2003). The Forest Service must ensure that the project will not adversely affect 

goshawk or contribute to a trend toward listing under the Endangered Species Act. In using the 

Management Recommendations for the Northern Goshawk in the Southwestern United States 

(Reynolds et al. 1992), which quantifies structural attributes of habitat for northern goshawk and 

14 of the hawk’s prey species, the Forest Service establishes a habitat--proxy relationship of 

ponderosa forest structure and viability of northern goshawk, and applied a proxy--on--proxy 

assumption to its analysis of population viability for 14 vertebrate prey species.

Response

The Forest Service is not implementing “New Guidelines”. The document referred to by the 

commenter is titled Implementation Guide, Region 3, Northern Goshawk Standards and 

Guidelines. This guide is an internal document that is “...designed to help project developers 

understand the importance and mechanics of how to design projects to meet the standards and 

guidelines for the northern goshawk. It is no longer used in the region. It is a companion 

document to The Management Recommendations for the Northern Goshawk in the Southwestern 

United States (Reynolds et al. 1992), which is outlined in the Record of Decision (ROD) 1996 

Amendment of Forest Plans for the National Forests in Arizona and New Mexico (Plan 

Amendment). The project does include a site specific amendment for the northern goshawk that 

clarifies direction regarding interspaces in goshawk habitat. This revision is meant to reduce 

ambiguity regarding the terms openings and interspaces. 

The text of the proposed site-specific amendment was provided in the DEIS (page 44). Notice of 

this proposed change and opportunity for public input, and participation were available during 

scoping, and the comment period for the DEIS. The DEIS analyzed and disclosed the effects of 

incorporating standards and guidelines for goshawk management including the amendment. The 

analysis also looked at the recommended VSS (vegetation structural stage) classifications, 

interspaces, and canopy cover that would promote habitat for at least 14 goshawk prey species. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 387

Therefor the notice and comment requirements of NEPA and NFMA have been met for this sitespecific forest plan amendment. 

Comment 22.33 

Concern

Finally, the Forest Service is proposing virtually identical forest plan amendments in every 

project-level analysis throughout the Southwestern Region. It should account for the cumulative 

effect of its coordinated, but piecemeal, effort to unravel current management direction for 

northern goshawk habitat.

Response

On the contrary, the Forest Service has collected and synthesized all the available scientific 

information related to ponderosa pine and mixed conifer in Reynolds et al. 2013. This document 

provides the basis for management of these forested systems not only for the northern goshawk, 

but for all of the goshawk’s prey species as well as other species dependent on these forest types. 

For more discussion on the other proposed amendments, see the response to comments regarding 

Forest Plan Amendments.

Comment 22.34 

Concern

The proposed action would mechanically disturb nest core areas of the threatened Mexican 

spotted owl, remove nesting--quality protected habitat. It is not consistent with recommendations 

of the 2012 Mexican Spotted Owl Recovery Plan, First Revision (USDI 2012a). Moreover, the 

project shirks protective standards and guidelines in the Santa Fe forest plan, and is likely to 

adversely affect spotted owl and its critical habitat, harm and/or harass individual birds causing 

incidental take, and undermine recovery. Combined, the proposed amendments to the forest plan 

would eliminate standards and guidelines that protect occupied Mexican spotted owl nesting and 

roosting habitat from destruction and/or adverse modification by logging operations. The 

proposed action would take Mexican spotted owl (USDI 2012b: 29) (defining “incidental take” as 

“harm and/or harassment of owls associated with one PAC due to long-- term or chronic 

disturbance, or habitat degradation or loss over the life of the project”); also see id. (“We expect 

that actions that could result in this type of harm or harassment would be very rare under the 

existing LRMP due to the protective standards and guidelines and other conservation measures 

included in the forest plan for the MSO”) (Emphasis ours)

Response

First, the 100-acre core areas would not be mechanically treated under the proposed action. We 

would only treat about 400 acres in the protected activity areas (PACs) because those acres do not 

meet the desired conditions for quality owl habitat as described in the revised recovery plan. 

See also the response to comments regarding Forest Plan Amendments.

Comment 22.35 

Concern

Monitoring in the proposed action is controversial because the Forest Service admitted in an 

October 2008 Annual Report to the U.S. Fish and Wildlife Service (FWS), and in litigation, that it 

lacked funding and personnel to conduct required monitoring of Mexican spotted owl habitat and 
Appendix C. Response to Comments on the DEIS

388 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

populations to ensure that its actions would not jeopardize the continued existence of the species 

nor adversely modify critical habitat.

Response

Under the proposed action, the Forest proposes to monitor Mexican spotted owls (MSO)

annually. Having acquired funding under the authority of the Collaborative Forest Lands 

Restoration Act, the Forest now has the ability to adequately monitor MSO protected activity 

centers and reproduction.

Comment 22.36 

Concern

In October 2008, the Forest Service provided its Annual Report to the FWS for the period of June 

10, 2005, through June 10, 2007, regarding the Programmatic Biological Opinion on the Land 

and Resource Management Plans for the 11 National Forests in the Forest Service Southwestern 

Region. In it, the Forest Service acknowledged that it failed to comply with the monitoring 

requirements set forth in the biological opinion’s terms and conditions, and/or likely exceeded the 

allowable incidental take for a number of listed species, including Mexican spotted owl. The 

Forest Service typically monitored only 20-25% of PAC during 2005-07. Moreover, the agency 

monitored that sample of PAC for owl occupancy but not reproduction. The Forest Service stated 

in the Annual Report that personnel and funding levels were inadequate to meet the monitoring 

requirements set out in Term and Condition 3.1 of the biological opinion. As a result, in many 

cases, monitoring has not been accomplished. The Forest Service has failed to “monitor changes 

in owl populations and habitat needed for delisting,” as required by the Santa Fe forest plan, in 

violation of NFMA. The Forest Service has no idea what the population trends are of this species 

nor do they have any evidence to validate the justification for the forest plan amendments for 

management of spotted owl habitat. In the most recent iteration of the MSO Recovery Plan - the 

2012 Recovery Plan - the FWS acknowledges the lack of information as to how Forest Service 

management practices affect the MSO: “Empirical data on the effects of thinning and other 

mechanical forest treatments on Mexican spotted owls are nonexistent. This is unfortunate, 

because thinning and other mechanical forest treatments are emphasized heavily in plans for 

landscape restoration of southwestern forests. Consequently, understanding how these treatments 

affect Mexican spotted owls is one of the major questions faced in integrating recovering this owl 

with plans for restoring southwestern forests.” USDI 2012a. In its 2012 Recovery Plan, the FWS 

also discusses the fact that Forest Service efforts to manage the MSO are confused - two decades 

after listing - by the absence of any landscape--level population trend monitoring: “In summary, 

data on trends in populations or occupancy are sparse, and methods and sample sizes differ 

among studies, making comparisons difficult. In general, however, results suggest that most 

populations of Mexican spotted owls studied either have declined in the recent past or are still 

declining. Further some evidence suggests that owls may be slow to re--colonize areas where 

such declines have occurred.” USDI 2012a.

Response

This is a good comment. First, under the proposed action the Forest proposes to monitor Mexican 

spotted owls (MSO) annually. The monitoring being done for this project will add to the body of 

information about the owl, assist us with MSO conservation, and assist the U.S. Fish and Wildlife 

Service in assessing the status of the species in the future. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 389

Secondly, MSO population declines are partly due to wildfire. The Las Conchas wildfire burned 

over 46,000 acres in about 14 hours from its start on June 26, 2011. This wildfire burned through 

ten MSO protected activity centers and likely killed many nesting owls. This is one example that 

highlights the need of this project to restore forest structure and function in an attempt to reduce 

adverse effects of large wildfires.

See also the response to comments regarding Monitoring for the Mexican Spotted Owl at the 

beginning of this appendix. 

Comment 22.37 

Concern

The Forest Service is required by NEPA to disclose scientific controversy and uncertainty 

regarding effects of the project to Mexican spotted owl and its critical habitat. The complete 

monitoring plan, including study design and analysis protocols, should be made available for 

public review and comment before a decision is made to implement the project.

Response

The requested information is disclosed in the DEIS and biological assessment. It was available 

for review and comment. 

See also the response to comments regarding Monitoring for Mexican Spotted Owl at the 

beginning of this appendix. 

Letter 23, Colston Chandler, University of New Mexico, Department of 

Physics and Astronomy 

Comment 23.1 

Concern

Adequate physical and monitoring measures need to be employed to prevent this illegal ORV 

usage on the decommissioned and temporary roads.

Response

When we decommission roads we take steps to block access to the road. In some cases, we make 

it difficult for people to see the decommissioned road from the road that they are driving on. 

What we do on each road will depend on the conditions on the road, the terrain, the number of 

trees, and the soil conditions. It is, of course, impossible to absolutely prevent people from 

driving on decommissioned roads, but we believe that the steps we take will be adequate.

We have added design criteria for the construction and decommissioning of temporary roads, and 

for monitoring after they are decommissioned. These are found in appendix A of the FEIS. 

See also the response to comments regarding Temporary Roads. 

Comment 23.2 

Concern

Decommissioning and restoration of the gravel pits is not adequately treated. Old gravel pits can 

be a public hazard.
Appendix C. Response to Comments on the DEIS

390 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

The Forest Service will follow all applicable state and Federal requirements for the design, use, 

and closure of the gravel pits. Each pit will have an operating plan. The gravel pits that we might 

build for this project could be used for decades. That means that the decommissioning and 

restoration may not happen for 30 or 40 years. During that time regulations regarding operation 

and closure may change. The actions that we may take for closure and restoration will depend on 

where the pit is located and the conditions around the pit. We will follow all applicable Federal, 

state, and local laws and best management practices regarding the operation and closure of the 

pits. We have added design criteria for the gravel pits to appendix A of the FEIS. These criteria 

address the location, construction, and operation of the pits. 

It would be possible to buy gravel from commercial sources off the forest; indeed we do that now. 

Having our own gravel pits, however, would save money, and we would be able to maintain more 

roads. Because we don’t have crushing equipment and a large number of trucks to haul the gravel, 

we would likely hire contractors for the crushing and hauling, thus giving the local economy a 

boost. 

See also the response to comments regarding Temporary Roads and the response to comment 9.6. 

Comment 23.3 

Concern 

This draft EIS does not include a strong enough statement of the possible challenges and the 

possible need for significant project modifications (and the procedures that must be followed to 

make those modifications).

Response

We appreciate your opinion. If significant changes occur or if there is new information after the 

decision is made, we would conduct a “section 18 review”. The responsible official will review 

and consider whether or not the changed circumstances or new information fall within the range 

of the original analysis. If not, a correction, supplement, or revision to the EIS will be made. An 

interdisciplinary team will analyze the effects given the new information or changed 

circumstances, and a new decision will be issued. 

Comment 23.4 

Concern

Though this draft EIS includes treatment of head cuts, it is essentially silent on dealing with 

grazing when it is a possible cause. Perhaps grazing allotments can be allowed to remain fallow 

during years to drought (without ranchers losing the allotments) or a means devised to allow the 

retirement of allotments.

Response

Please see the response to comment 8.8. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 391

Letter 24, Jay Lininger, Center for Biological Diversity 

Comment 24.1 

Concern

We encourage the Forest Service to design the project to promote active use of fire for resource 

benefits and appropriate management responses to unplanned ignitions. Adverse effects of fire 

control practices are well documented (Backer et al. 2004) and should be analyzed and disclosed 

where proposed treatments are designed to increase the effectiveness of fire suppression.

Response

Thank you for your comments regarding the adverse effects of fire control practices and the use 

of unplanned ignitions for resource benefits. Current fire policy on the entire Santa Fe National 

Forest allows for the use of unplanned ignitions to be managed for resource benefits. Mechanical 

and prescribed fire treatments associated with this project will break up the landscape and provide 

additional options when managing unplanned ignitions. Consistent with the purpose and need of 

this project, treatments will ultimately facilitate the use of unplanned ignitions and will continue 

to be an integral part of fire management within the project area as well as the entire Santa Fe 

National Forest. In addition, fire suppression effectiveness was addressed in the fuels specialist 

report in terms of fireline intensity and resistance to control that is broken down by alternative 

and associated acreage. 

Comment 24.2 

Concern

Restoration is an appropriate management objective for the planning area, and we recommend 

application of the Society for Ecological Restoration’s definition of “restoration” as “the process 

of assisting the recovery of an ecosystem that has been degraded, damaged, or destroyed” (SER 

2004: 3). The word “assisting” is central to the meaning of this definition. Historical fire 

exclusion, livestock grazing and logging have altered ecological conditions such that existing 

systems are vulnerable to catastrophic loss and require active management to reduce fuels and 

restore adapted ecological processes including fire. However, this idea is controversial because 

there is evidence that stand-replacing fires are part of the historic range of variability for the 

planning area (e.g., Odion et al. 2014).

Response

Thank you for your recommendation. Forest Service Manual 2020.5 is the source for the 

definition of restoration used in this project, see the DEIS, page 1. See also the response to 

comment 15.1. 

Comment 24.3 

Concern

In many cases, passive restoration including cessation of activities that degrade ecosystems (e.g., 

fire exclusion and livestock grazing) may be sufficient to accomplish restoration, particularly in 

roadless areas where historical management has had little, if any, direct impact to forest 

ecosystems (DellaSala et al. 2004).
Appendix C. Response to Comments on the DEIS

392 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

We do not believe that passive restoration would provide for the level of restoration needed for 

this critical conservation area that has been ranked as a top priority for restoration (DEIS, p. 4). 

See also the response to comments regarding Purpose and Need. 

Comment 24.4 

Concern

The proposed action suggests a comprehensive approach to management of forest structure above 

the ground and overlooks fuel bed structure on the ground surface.

Response

Fuel bed structure and fuel loading were considered. In addition to mechanical treatments, which 

address the above-ground structure, the proposal includes treating natural fuels through the 

application of prescribed fire. See the fuels specialist report for the discussion on fuels and fuel 

loading, and how the effects were modeled. 

Please see the response to comments regarding Purpose and Need and the response to comment 

15.1. 

Comment 24.5 

Concern

The environmental analysis should ensure professional and scientific integrity with site-specific 

information based on field observations rather than relying on estimates and assumptions fed into 

computer models (Weatherspoon and Skinner 1995).

Response

Please see the responses to comments 15.7 and 22.10. 

Comment 24.6 

Concern

To accurately assess fuel treatment effects on crown fire initiation and spread potential, it is 

necessary to consider: (1) surface fuel density and arrangement; (2) canopy base height; (3) site 

topography; and (4) local weather patterns (Graham et al. 2004, Hunter et al. 2007). The former 

two factors can be actively managed in ponderosa pine forest to significantly decrease the 

likelihood of crown fire initiation and spread without resort to large tree removal in most cases 

(Fielder and Keegan 2002, Keyes and O’Hara 2002, Omi and Martinson 2002, Perry et al. 2004, 

Pollett and Omi 2002).

Response

That is correct. As stated in the fuels specialist report, page 8 and the silviculture specialist report 

starting on page 6, site-specific field data was used to define the current condition. 

See also the responses to comments 15.7 and 22.10. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 393

Comment 24.7 

Concern

Perry and others (2004) investigated how forest structure influences fire effects in ponderosa pine 

forests of the eastern Cascade Range. Even in areas far departed from historical conditions, 

“[T]here may be a great deal of landscape heterogeneity in the degree of risk and the treatments 

required to lower risk ...” (Perry et al. 2004: 923; also see Odion et al. 2014). Fuel treatments that 

reduced surface fuel volume by fifty percent (50%) without any tree thinning prevented torching 

behavior in 13 out of 14 experimental plots with modeled wind speeds exceeding 90th percentile 

conditions for the study area. A “light thinning” of trees smaller than 12-inches diameter at breast 

height coupled with surface fuel reduction prevented torching in the fourteenth plot (Perry et al. 

2004: 924). Those results agree with Forest Service observations from the 2002 Hayman fire in 

Colorado, where active crown fire dropped to the ground upon encountering areas that had been 

treated with prescribed fire to reduce surface fuels and kill small trees (Graham 2003). Omi and 

Martinson (2002) measured the effect of fuel treatments on fire severity in highly stratified forest 

sites in the western United States and reported a strong correlation of canopy base height with 

“stand damage” by fire. Notably, canopy bulk density and continuity did not strongly correlate 

with fire effects to vegetation. Instead, height to live crown, the variable that determines crown 

fire initiation rather than propagation, had the strongest correlation to fire severity in the areas we 

sampled ... [W]e also found the more common stand descriptors of stand density and basal area to 

be important factors. But especially crucial are variables that determine tree resistance to fire 

damage, such as diameter and height. Thus, “fuel treatments” that reduce basal area or density 

from above (i.e., removal of the largest stems) will be ineffective within the context of wildfire 

management. Omi and Martinson (2002: 22). Keyes and O’Hara (2002: 107) agreed that raising 

canopy base height is an important factor in reducing fire hazard and noted, “[P]runing lower 

dead and live branches [of large trees] yields the most direct and effective impact.” They also 

noted the incompatibility of open forest conditions created by “heavy” thinning treatments 

designed to maximize horizontal discontinuity of forest canopies with management objectives to 

conserve threatened wildlife populations and prevent rapid understory initiation and ladder fuel 

development. Understory growth following treatments that create open forest conditions may 

undermine their long-term effectiveness without commitments to maintenance treatments (e.g., 

prescribed fire). Further, the observation that large trees promote fire resistance is supported by 

Forest Service research (e.g., Arno 2000, Graham et al. 2004) as well as a variety of leading 

scientists (e.g., Agee and Skinner 2005, Brown et al. 2004, DellaSala et al. 2004). A key 

implication for the proposed action is the importance of treating fuels from below to reduce fire 

hazard.

Response

Please see the response to comment 15.1 and the response to comments regarding Purpose and 

Need. 

Comment 24.8 

Concern

The environmental analysis should clearly demonstrate that fuel treatments in the proposed action 

will be oriented with prevailing spatial patterns of fire spread and local landscape features to 

ensure maximum effectiveness in addressing the purpose and need. It will be most helpful to the 

decision-maker and the public if the analysis includes detailed study and development of action 

alternatives that propose different treatment locations and intensities to compare effects on 
Appendix C. Response to Comments on the DEIS

394 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

potential fire behavior and the environment. It will be very useful, indeed, if the analysis 

compares treatment effects under different weather scenarios (e.g., 70th percentile versus 90th 

percentile conditions) to gauge the relative effectiveness of the action alternatives.

Response

Please see the response to comments regarding Purpose and Need. 

Comment 24.9 

Concern

Given the rarity of large trees and the overabundance of small trees, a high burden of justification 

applies to a proposed action that would remove trees larger than 16-inches diameter in a project 

framed around the need for ecological restoration.

Response

Please see the response to comments regarding Large Trees. 

Comment 24.10 

Concern

See 40 C.F.R. § 1502.14. The agency is required to “[r]igorously explore and objectively evaluate 

all reasonable alternatives.” Id. § 1502.14(a); 42 U.S.C. § 4332(2)(E) (agencies required to 

“study, develop, and describe appropriate alternatives to recommended courses of action in any 

proposal which involves unresolved conflicts concerning alternative uses of available resources”).

Response

Please see the response to comment 22.27. 

Comment 24.11 

Concern

The DEIS considers but eliminates from detailed study an action alternative that would impose a 

strict “diameter cap” and retain all trees larger than 16-inches diameter in all project treatments. 

See DEIS at 46 (“The 16-inch diameter limit was selected because it was often cited as an upper 

limit for tree cutting in the scoping comments. This alternative would apply to all of the 

vegetation treatments and design criteria outlined in the proposed action. All other treatments 

involving tree cutting would include the cap”).

Response

Yes, this alternative was considered but eliminated from detailed study. The reasons for 

eliminating from further study are described in the DEIS (chapter 2, page 46). 

See also the response to comments regarding Large Trees. 

Comment 24.12 

Concern

The DEIS does not indicate whether, or to what degree, the Forest Service may have considered 

implementation of the collaborative Strategy for large tree retention in this project in spite of the 

Center’s good-faith suggestion that it do so to meet the purpose and requirements of NEPA.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 395

Response

Please see the response to comments regarding Large Trees. 

Comment 24.13 

Concern

This information should be clearly displayed in a manner that is easily understood by public. 

Removal of old growth structure may be a cumulatively significant environmental impact. Old 

growth forest exists in the project area and the proposed action would remove some of it, through 

exactly how much is not clearly stated. See Biological Evaluation of Sensitive Species (“BE”) at 

21-22 (Table 9 indicates the proposed action includes logging on up to 355 acres of ponderosa 

pine and mixed conifer old growth in riparian areas). The environmental analysis must analyze 

and disclose the spatial extent of old growth stands that meet Forest Plan criteria at each of the 

prescribed analysis scales. This information should be clearly displayed in a manner that is easily 

understood by public. The assessment should clearly depict the number of acres meeting and not 

meeting old growth criteria within each analysis scale. It should clearly state direct, indirect and 

cumulative effects of the proposed action to this significant resource.

Response

We used the definition of old growth as described in this table from the Forest Plan, The minimum 

criteria for the structural attributes used to determine old-growth (replacement page 69-A). 

Enhancing old growth is part of the objectives and purpose and need of the project (DEIS, p. 13), 

and this project meets the 20 percent allocation in the Forest Plan.

The commenter refers to table 9 in the BE. This table was not intended to describe effects on old 

growth. See the response to comment 24.15 for a response to effects on old growth. Table 9 of the 

BE was removed and replaced by a discussion about the effects of riparian restoration treatments 

on sensitive species. 

Comment 24.14 

Concern

In this project, the Forest Service must allocate no less than 20 percent of each forested 

“ecosystem management area” to old growth habitat. In order to properly determine old growth 

habitat, the Forest Service must refer to a specific table included sets forth detailed minimum 

numeric criteria for various forest types, including the size, age and number of live and dead 

trees, down trees and canopy cover. Forested sites must meet or exceed these numeric structural 

attributes in order to be considered old growth habitat. In addition, the amended Forest Plan 

requires the agency to analyze old growth habitat at multiple scales: (1) the ecosystem 

management area; (2) one scale above the ecosystem management area; and (3) one scale below 

the ecosystem management area. The amount of old growth that can be provided and maintained 

must be evaluated at the ecosystem management level and be based on forest type, site capability 

and disturbance regimes.

Response

The old growth allocation for this project is described on pages 24-25 of the silviculture specialist 

report and on pages 174-175 of the DEIS. See also the response to comment 24.15 below. 
Appendix C. Response to Comments on the DEIS

396 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 24.15 

Concern

The Forest Service also must analyze and disclose how many acres within the ecosystem 

management area currently meet the minimum numeric criteria for old growth habitat set forth in 

the Forest Plan; assess potential impacts to old growth habitat at the required scales; allocate no 

less than 20 percent of each management area to old growth as depicted in the Forest Plan; and 

must not log any of the remaining large trees within the project area until it meets these 

mandatory requirements.

Response

The silviculture specialist report discusses old growth in several places: forest plan old growth 

parameters (table 1); existing conditions (pp.11-23); old growth allocation for this project and the 

three scales in which to consider old growth (pp. 24-25); and effects on old growth (pp. 36-44). In 

the DEIS, existing conditions, desired conditions, and treatments for old growth are discussed on 

pages 8 and 22. A map showing the location of old growth is in the project record. 

To meet the Forest Plan requirements, the project analyzes old growth at the required three scales: 

stand, EMA, and landscape. The Jemez Mountains are used as the landscape scale. The 

silviculture specialist report, page 25, describes in detail how old growth is considered and would 

be allocated. Past actions most likely contributed to the existing deficit. This project meets the 20 

percent allocation in the Forest Plan. The projects in the foreseeable future that have the potential 

to affect old growth will be analyzed at the same three scales. Adverse cumulative effects would 

be avoided in order to meet the forest plan. 

We have met the forest plan requirements for old growth. See the response to comments on Large 

Trees and the responses to comments 24.13 and 24.14. 

Comment 24.16 

Concern

The project area contains between nine and 13 post-fledging family areas (“PFA”) of northern 

goshawk. See BE at 25 (stating contradictory information). In general, the Forest Service 

allocates insufficient acres to PFA, out of compliance with the amended Forest Plan. See id. 

(Table 12 describes 2,412 acres of “PFA habitat” in project area). On average, PFA in the project 

area are between 268 acres (if there are nine PFA) and 185 acres (if there are 13 PFA) each, far

less than the guideline of “approximately 600 acres” specified by the Forest Plan.

Response

The biological evaluation (BE) and FEIS have been revised to show the correct number and/or 

acreage of PFAs. There are 13 PFAs wholly or partially within the project area. All the PFAs have 

sufficient acres to meet the amended Forest Plan requirements. In the BE, the total acres of each 

PFA were not displayed if the acres fell outside of the project area or were not on National Forest 

System land. The table in the BE has been revised to display acres within the project area and 

acres on non-National Forest System land. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 397

Comment 24.17 

Concern

In addition, the Forest Service presents confusing data to portray the overall amount of goshawk 

habitat in the project area and the national forest as a whole.

Response 

Please see the response to comment 24.16. 

Comment 24.18 

Concern

In addition to shifting implementation of the canopy cover requirement from stand to group 

scales, the Forest Service also proposes to fundamentally alter management direction for goshawk 

habitat in the following ways: * Define “interspaces” as open space between tree groups intended 

to be managed for grass-forb-shrub vegetation during the long term (i.e., no conifer regeneration 

in permanent created openings). * Distinguish interspaces from the six Vegetative Structural 

Stages (“VSS”) of uneven-aged forest established by the amended Forest Plan. * Double the 

maximum extent of open conditions in uneven-aged forest above what is currently allowed by the

Forest Plan.

Response

The amendment related to goshawks would implement guidelines intended to restore forest 

conditions for the northern goshawk and move forest structure toward reference conditions,

which are more resilient to the effects of wildfire than current conditions. Moving the forest 

toward reference conditions as described in Restoring composition and structure in the 

Southwestern frequent fire forests: A Science-Based Framework for Improving Ecosystem 

Resiliency (Reynolds et al. 2013) will promote processes like fire to move toward reference 

conditions and function as it did historically. This will be a benefit to all wildlife species, not just 

the goshawk. The display of effects on goshawks, including the effects of implementing the 

amendments, is found in chapter 3 of the FEIS and the biological evaluation. 

See also the response to comments regarding Forest Plan Amendments. 

Comment 24.19 

Concern

According to the Forest Service, high canopy cover in nest areas and PFA is especially important 

to goshawk viability. See id. (“At the nest tree/stand level, nests typically occur in mature to oldgrowth forests composed primarily of large trees, with high canopy closure, near the bottom of 

moderate hill slopes, with sparse ground cover (Squires and Reynolds 1997 and Squires and 

Kennedy 2006). Goshawks nested 2.5 times more often than expected in stands with 70-79 

percent canopy coverage and 5.8 times more often than expected in stands with 80 percent or 

greater canopy coverage (Squires and Reynolds 1997)”). The agency acknowledges that the 

action alternatives would amend the Forest Plan to shift implementation of canopy cover 

guidelines to small group scales. The Center previously commented regarding this project that 

changing the spatial scale of application of the canopy cover guidelines for goshawk habitat to 

the tree group level “has the potential to significantly reduce the amount of forest cover within 

treated areas.”
Appendix C. Response to Comments on the DEIS

398 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

Goshawks nest in stands with varying stand structure and composition. Goshawks prefer mature 

forests with large trees, relatively closed canopies (50-90 percent), and open understories (Squires 

and Kennedy 2006). Siders and Kennedy (1996) described the range of stand conditions used by 

goshawks in northern New Mexico. They reported that goshawks used nest trees ranging from 

25–31 m in height and 43.3– 56.7 cm diameter. Canopy closure at the nest tree was 58-74 percent

and 60-70 percent at nest areas. Nest areas had 31–40 m2/ha basal area, with an overall area 

density of 800–1,400 trees per hectare and overstory trees were spaced 4.8–6.8 m apart. Nest 

areas were composed of 2.8–8.0 percent mature, 2.1–11.1% large, 5.2–32.8 percent pole, and 

16.8–85.6 percent sapling trees. Tree densities by age class were 460–970 sapling trees/ha, 130–

370 pole trees/ha, 55–115 large trees per hectare and 53-90 mature trees per hectare (Squire and 

Kennedy 2006).

Forests that provide adequate populations of major prey species are predicted to have welldeveloped herbaceous and shrubby understories associated with small to medium openings that 

provide cover and food for many small mammals and birds in the form of seeds, berries, and 

foliage. Please refer to Reynolds et al. 2013. 

See also the response to comments regarding Forest Plan Amendments. 

Comment 24.20 

Concern

Virtually all concurrent Forest Service proposed action in the Southwestern Region apply the 

same plan amendments. Therefore, the agency’s characterization of the proposed amendments as 

applying “only to this project” is deliberately misleading. The EIS should disclose potentially 

significant direct, indirect and cumulative effects of the plan amendments to goshawk and prey 

species whose viability the Forest Service previously stated are assured by implementation of the 

existing standards and guidelines.

Response

Please see the response to comments regarding Forest Plan Amendments. 

Comment 24.21 

Concern

The project analysis fails to support a finding that the proposed action is not likely to result in a 

trend toward federal listing or loss of viability for any sensitive species. It presents no information 

whatsoever about sensitive species populations in the project area or the national forest as a 

whole. Indeed, it admits uncertainty regarding population status and habitat associations of most 

sensitive species. Therefore, use of habitat as a proxy for analysis of effects to sensitive species is 

arbitrary and capricious.

Response

There is no requirement to monitor populations of sensitive species. The standards for Biological 

Evaluations (BEs) can be found in FSM 2672.4. Generally, the Biological Evaluation identifies 

the amount of habitat on the Forest compared to the amount of habitat in the project area for any 

given sensitive species. The effects of project activities on sensitive species habitat are displayed 

in the BE and support the biologist’s determinations regarding trend for federal listing or loss of 

viability
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 399

Comment 24.22 

Concern

The Center recommends limiting fuel treatments in mixed conifer forest to the driest sites (i.e.,

south and west aspects) where fire exclusion is somewhat more likely to have caused long-term 

change in forest composition and structure.

Response

Thank you for the information. We propose to do treatments in wet mixed conifer only if there is 

a compelling reason (such as wildland-urban interface). Most proposed treatments will be done in 

dry mixed conifer, defined as having ponderosa pine as part of the stand. 

Comment 24.23 

Concern

More aggressive treatments in mixed conifer forest, particularly at mesic locations (e.g., north 

aspects and riparian zones), are almost certain to degrade critical habitat of threatened Mexican 

spotted owl with uncertain benefits to the conservation and recovery of the species (USDI 1995, 

USDI 2012b). The DEIS contains no site-specific justification for proposed mechanical 

treatments of “wet” mixed conifer forest.

Response

Possible reasons for doing work in wet mixed conifer are listed on page 34 of the silviculture

specialist report. Possible work in springs and seeps areas is described on page 35 of the DEIS 

and in the watershed specialist report. 

Comment 24.24 

Concern

Management activities that may affect federally protected species require consultation with the 

U.S. Fish and Wildlife Service (“FWS”) to ensure they will not jeopardize the continued 

existence of Mexican spotted owl or adversely modify critical habitat, and to secure an exemption 

for incidental “take,” which is otherwise prohibited by the Endangered Species Act (“ESA”).

Response

The Forest has completed the ESA consultation process with the U.S. Fish and Wildlife Service. 

Comment 24.25 

Concern

Opening closed roads and/or deployment of logging equipment. See USDI (2012a: 23) (“[B]oth 

motorized and non-motorized vehicles may degrade MSO habitat, particularly meadow and shrub 

habitat vital to the MSO’s prey”).

Response

The analysis for threatened and endangered species quantified and assessed the effects on the 

Mexican spotted owl and its critical habitat. The Forest has completed consultation with the U.S. 

Fish and Wildlife Service regarding those effects and has received a final, signed biological 

opinon 
Appendix C. Response to Comments on the DEIS

400 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Comment 24.26 

Concern

We have not been able to assess the effects of classic uneven-aged management on Mexican 

spotted owl habitat because we were unable to acquire data for most areas where uneven-aged 

management is practiced on a large scale. However, based upon our understanding of the 

application of uneven-aged systems, stand density is often kept at a fairly low level, seldom 

exceeding 18 m2/ha (80 ft2/acre) of basal area. These low residual stand densities allow for 

regeneration and growth of ponderosa pine. Uneven-aged systems, whether they retain individual 

trees or groups of trees, allow for the development of multiple canopy levels, a key component of 

Mexican spotted owl habitat. However, Ganey and Dick (1995) demonstrate clearly that owl 

habitat typically also includes significant numbers of large trees. These large trees may not be 

retained where uneven-aged management is applied in this fashion. In summary, uneven-aged 

management has some promise for providing stands exhibiting characteristics of spotted owl 

habitat. As currently practiced, however, uneven-aged management results in large acreages of 

low-density stands, numerous road openings, and the eventual eradication of large diameter 

stems. Although neither the short or the long-term effects of these applications on spotted owls 

are known, this type of application may not be the best option for producing spotted owl habitat.

Response

Much of the forest falls below standards for the Mexican spotted owl (MSO) as described in the 

2012 MSO recovery plan (USFWS 2012). Forest stand conditions through much of the project 

area fall within the VSS 3 to VSS 4 categories. These are young to middle-aged forests (under 18-

inches diameter) and much of that is classified as even-aged. The proposed treatments will

promote more desirable uneven-aged conditions while promoting the future growth of larger 

trees. We believe that the proposed project would implement guidelines intended to restore forest 

condition and trend forest structure toward reference conditions, which are more resilient to the 

effects of wildfire. It is also believed that moving the forest toward reference conditions as 

described in Reynolds et al. 2013 will promote processes such as fire to trend toward reference 

condition and function as it did historically.

See also the responses to comments 8.5 and 14.4. 

Comment 24.27 

Concern

Past timber harvest caused significant decline of large tree density in the project area and 

throughout the range of MSO. The environmental analysis should clearly describe effects of the 

proposed action to large tree PCE (primary constituent element of habitat).

Response 

The post-treatment density and distribution of large trees is discussed in the response to 

comments regarding Large Trees.

Comment 24.28 

Concern

The environmental analysis should present up-to-date survey information to demonstrate that the 

project will avoid incidental take of MSO. Lacking timely protocol surveys for MSO within or 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 401

adjacent to the project area, the analysis must assume that suitable habitat is occupied, and that 

the project may affect MSO. See USDI (2012a: 32).

Response

Recent survey data was collected on Mexican spotted owls within and outside of the project area. 

Data for nesting areas (protected activity centers) within the project area are displayed in the 

Biological Assessment. Currently, the Forest has completed consultation with the U.S. Fish and 

Wildlife Service on the proposed project. We anticipate adverse effects on individual owls and on 

designated critical habitat. We do not expect to avoid all harm or harassment that is incidental to 

our proposed action. 

Comment 24.29 

Concern

(“Actions outside PACs will generally not result in incidental take because we are not reasonably 

certain the MSOs are nesting and roosting in areas outside of PACs. We may modify this 

determination in cases when areas that may support MSOs have not been adequately surveyed 

and we are reasonably certain MSOs may be present”).

Response

Please the see the revised Biological Assessment for our analysis of effects on the species and its 

designated critical habitat. We anticipate some incidental take as a result of implementing the 

proposed project. The Forest has completed ESA Section 7 consultation with the U.S. Fish and 

Wildlife Service.

Comment 24.30 

Concern

The Forest Service routinely deflects monitoring to populations and habitat to one scale above or 

below its present analysis, and has never accomplished it at any scale. Its systematic failure to 

monitor MSO cannot be allowed to continue where new proposed actions “may affect” the 

species and/or critical habitat.

Response

Recent survey data was collected on Mexican spotted owls in the project area as well as outside 

of the project area. Data for nesting areas (PACs) within the project area is displayed in the 

Biological Assessment. Currently, the Forest is consulting with the U.S. Fish and Wildlife Service 

on the proposed project. 

See also the response to comments regarding Monitoring for the Mexican Spotted Owl and the 

responses to comments 24.25, 24.36, and 24.37. 

Comment 24.31 

Concern

The environmental analysis should disclose the location of roads to be constructed in this project 

and site-specifically assess potentially significant direct, indirect and cumulative effects to soil 

and riparian resources including water quality and aquatic species. 
Appendix C. Response to Comments on the DEIS

402 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

Potential locations of temporary roads were shown in figure 11 in the DEIS. The Soils and Water 

Resources section of the DEIS and the watershed specialist report discuss the effects of road 

construction on soil and riparian resources and water quality. The equivalent disturbed area 

(EDA) and equivalent roaded area (ERA) analysis calculations were used to determine potential 

risk to watershed functions, water and soil resources from past, present and foreseeable future 

projects. This method was also used for the cumulative effects analysis. The Wildlife, Fish, and 

Rare Plants section of the DEIS addresses effects on riparian and aquatic species. Effects of

temporary roads on other resources were described in chapter 3 of the DEIS and the associated 

specialist reports. 

The 12 miles of temporary roads were determined by the harvest plan for the entire area. If there 

were planned harvest areas that had no existing roads (closed or open) available to provide 

access, then a temporary road was proposed. As stated in the roads and engineering specialist 

report, temporary roads will be decommissioned at the close of the project. Design criteria for 

constructing and decommissioning temporary roads are found in appendix A of the FEIS. 

Comment 24.32 

Concern

The DEIS and supporting analyses give no attention whatsoever to effects of proposed road 

construction or reconstruction to sensitive fishes. See BE at 23-24 (Rio Grande chub and Rio 

Grande sucker).

Response

The DEIS (p. 215) identified that sediment from road erosion may enter into streams and impact 

fish habitat and water quality. Some proposed projects occurring within or near streams, such as 

installation, replacement, or removal of stream crossing structures and instream habitat 

improvements, would also have adverse consequences to fish species in the near term. 

Decommissioning roads will reduce the magnitude of sediment loss from road erosion over time. 

Design features and best management practices (DEIS, appendix A) for the proposed roadwork 

are designed to limit effects on aquatic resources. We also want to point out that the action 

alternatives would not contribute enough sediment or other pollutants into intermittent drainages 

to result in impairment of any downstream waterbodies (DEIS, p. 166). 

Comment 24.33 

Concern

More, the analysis should take a hard look at the condition, location and extent of roads to be 

opened and/or reconstructed in the project. Effects including soil erosion, runoff channelization 

and suspended sediment delivery merit a hard look.

Response

We did in fact conduct a comprehensive analysis of potential environmental consequences of 

implementing the road treatments. The Equivalent Disturbed Area/Equivalent Roaded Area 

(EDA/ERA) model was used to analyze effects from road treatments and other activities on soil 

and water resources. The model and parameters used are discussed in detail in the specialist 

report, and results or effects are summarized in the DEIS. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 403

The EDA/ERA modeling included all Huc12 watersheds intersecting or completely within the 

project boundary. Past actions, existing conditions, and proposed actions on the Valles Caldera 

National Preserve (VCNP) were included in the effects analysis. Parts of three Huc12 watersheds 

in the project area are also within the VCNP (East Fork Jemez River, Outlet San Antonio, and 

Sulphur Creek). Existing and proposed roads were included in the EDA/ERA analysis. 

Best Management Practices and design criteria were developed for the road treatments, including

haul roads, skid trails, decks, landing areas, and road-stream crossings. These measures are found 

in appendix A of the DEIS and FEIS. Additional design criteria for construction and 

decommissioning of temporary roads were added to appendix A in the FEIS. 

Comment 24.34a 

Concern

Project design features and so-called best management practices (“BMP”) may fail to mitigate 

significant cumulative effects resulting from road use (Endicott (2008: 93) (noting lack of science 

to validate effectiveness of many BMPs related to forest roads). 

Response

Appendix A in the DEIS listed the Best Management Practices (BMPs) that would be used during 

implementation of the project. Measures for road treatments are included. 

The sources for the BMPs are listed in the watershed specialist report, pages 41-42 and 46-48. 

Best Management Practices are applied nationally throughout the Forest Service as part of normal 

operating procedures and are considered to be effective. The monitoring and design features 

section (DEIS, page 299) notes that BMPs would be evaluated for effectiveness and adjusted as 

necessary to improve implementation and effectiveness. Results would be shared with the New 

Mexico Environment Department for review as specified in the intergovernmental agreement.

Comment 24.34b 

Concern

Roads indirectly contribute to biological invasions of non-native or noxious weeds (Gucinski et 

al. 2001).

Response

The Non-Native and Invasive Plants section in chapter 3 of the DEIS addressed the increased 

opportunity for the spread and establishment of invasive plants associated with roads (pages 99-

106). Mitigation measures that would reduce the potential for the spread of non-native and 

invasive plants were developed for both harvesting and road maintenance operations; these 

measures are described in appendix A of the DEIS and FEIS. 

Comment 24.35 

Concern 

The Forest Service should take a hard look at cumulative effects rather than list potential causes 

or mention that some risk may exist.

Response

The list of projects for assessing cumulative effects (DEIS appendix B) includes past, present, or 

foreseeable projects considered by the interdisciplinary team resource specialists. The actual 
Appendix C. Response to Comments on the DEIS

404 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

cumulative effects considered varied by resource. The analysis of the cumulative effects of those 

projects listed is in each specialist report. 

The analysis of the effects is in each specialist report and summarized in each resource section of 

the DEIS, chapter 3. For example, the watershed specialist report analyzes the effects of 

prescribed burning using the EDA/ERA calculations (table 14, pages 64-65). The analysis 

considered the cumulative effects of the projects listed both within and outside of the project area 

and how they could contribute effects on our action. The Soils and Water Resources section of 

chapter 3, (page 170), describes the cumulative effects within all of the Huc12 watersheds that 

intersect the project area. The cumulative effects are presented in context of watershed function 

and water quality. 

Comment 24.36 

Concern

Potentially significant cumulative effects to soil productivity, plant communities, fire regime and 

wildlife may result from fuel management in combination with livestock grazing and other 

activities, such as road building and motorized vehicle use, which disturb soils and spread exotic 

plant species. Livestock disturb soil, enable seeds of exotic species to spread, and reduce the 

competitive and reproductive capacities of native species. Exotic plant species, once established, 

can displace native species, in part, because native grasses are not adapted to frequent and close 

grazing in combination with fire disturbance (Mack and Thompson 1982, Melgoza et al. 1990, 

Belsky and Gelbard 2000).

Response

Chapter 3 of the DEIS disclosed the short-term negative effects that would occur during or 

immediately after treatments. However, the overall long-term effects are expected to be beneficial 

as the project area moves towards the desired conditions. The effect on all these resources 

mentioned above, including grazing, were considered. The analysis considered the interaction of 

project activities on a resource and those of the project. Specialists also considered combined 

effects of project activities on their resource. 

Grazing data was included in both the analysis and cumulative effects analysis for soil and water 

and other resources. As an example, for watershed effects, a disturbance coefficient was identified 

for all project activities, and existing conditions were used to assess effects on soil resources. The 

analysis looked at the combined effects of all activities, including grazing, on soil productivity, 

plant communities and other resources. Details of the analysis methods are in the watershed 

specialist report. 

Comment 24.37 

Concern

Exotic plant invasion is a potentially significant cumulative effect of the proposed action. 

Treatments similar to the proposed action in northern Arizona left forest sites overrun with 

cheatgrass (Bromus tectorum) (McGlone et al. 2009). Exotic grass invasion is foreseeable and has 

important long-term implications for native plant communities in fire-adapted ecosystems and 

wildlife.
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 405

Response

We acknowledge that the project activities have the potential to encourage the spread and 

establishment of nonnative invasive plants (DEIS, pp. 99-106). Appendix A of the DEIS and FEIS

describes measures that should minimize the spread and establishment of nonnative and invasive 

plants. The Nonnative and Invasive Plants section of the DEIS, table 18, (pages 100-101), lists 

the species found in the project area. Cheatgrass (Bromus tectorum) is labeled a class C species 

(NMAD 2009). These invasive weed species are widely distributed across the forest, district, or 

else within a particular watershed but do not pose additional threats to watershed condition, TES 

species, wilderness, or other natural and economic resources. 

Class C weed species generally receive the lowest priority for control or restoration as compared 

to species in other classes. Management emphasis is to use a control strategy with an adaptive 

management approach on a local basis only when necessary to achieve desired goals and/or 

objectives and to limit overall impacts. (USFS 2014)

Additional infestations would be addressed under the FEIS for Invasive Plant Control on the 

Santa Fe and Carson National Forests. 

Comment 24.38 

Concern

In conclusion, the Center views the project as potentially beneficial if it observes the sciencebased recommendations provided above, but has significant questions regarding the necessity of 

proposed amendments to the Forest Plan. We strongly encourage you to consider alternatives to 

the proposed action. Please timely notify me of all developments with the project. I wish to be 

involved at every opportunity.

Response

Thank you for your support and interest in this project. 

Letter 25, Virginia Seiser 

Comment 25.1 

Concern

Alterative 1 Proposed Action is my preferred alternative, but I have concerns about it.

Response

Thank you for your interest in the project. 

Comment 25.2 

Concern

Alternatives 1, 4 and 5 include the building of short segments of new temporary roads, to reduce 

surface damage during logging operations. However, road building itself is a form of surface 

damage. The plan should be more specific about the measures that will be taken to restore the 

surface area when these temporary roads are decommissioned. For instance, is the gravel going to 

be removed, the soil replaced and the road bed replanted?”
Appendix C. Response to Comments on the DEIS

406 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Response

We propose to build as few roads as possible while meeting project objectives. The proposed 

temporary roads would be constructed of dirt and would not have a gravel surface. The 

consequences of building temporary roads have been described in the Roads and Engineering 

section of chapter 3 as well as in other sections: Wildlife, Fish and Rare Plants, Cultural 

Resources, Nonnative and Invasive Plants, Soil and Water Resources, Recreation, and Scenery.

The temporary roads will be decommissioned at the close of the project, and we will 

decommission many other roads, too. This means we will take steps to remove the road from the 

landscape and return the land to a more natural state. As described in chapter 2 of the FEIS, 

decommissioning methods include installing signs, blocking entrances, restoring vegetation, 

eliminating the roadbed, and other methods described in Forest Service Manual (FSM) 7734.1. 

The most appropriate decommissioning methods will vary by site. Some methods involve the use 

of heavy equipment and could cause more damage than allowing the road to rehabilitate itself. As 

an example, using equipment to decommission roads might damage Jemez Mountain salamanders 

and their habitat. 

See also the responses to comment 9.6 and the response to comments regarding Temporary 

Roads. 

Comment 25.3 

Concern

The plan should be revised to obtain the needed gravel from commercial sources outside the 

forest.

Response

The total cost of road surfacing has not been examined because the locations of the gravel pits 

have not been determined. Without specific locations, it is not possible to provide an accurate cost 

estimate for pit development. 

The costs of gravel pit development, operation plans, and closure plans are dependent upon 

topography, ground slope, drainages, solar orientation, vegetation, access by existing roads, the 

need to build new access roads, and/or other considerations, all dependent on location. Once the 

locations are established, then costs can be determined. See also the response to comments 

regarding Gravel Pits. 

Comment 25.4 

Concern

I am concerned about protecting the largest trees from cutting in the rest of the areas to be 

thinned, and I had trouble determining what size trees would be allowed to be cut under the plan 

as written. I am concerned that desire for commercial profit will result in removal of the largest 

trees.

Response

Please see the response to comments regarding Large Trees. 
Appendix C. Response to Comments on the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 407

Comment 25.5 

Concern

I worry that climate change may prevent regrowth of large-diameter trees in the cut-over areas.

Response

Please see the response to comments regarding Climate Change. 

Comment 25.6 

Concern

It is good under all alternatives, grazing will be suspended in treated areas to allow the land to 

recover. It is also good that stream restoration will include building exclosures to keep livestock 

from damaging delicate areas, I hope that there will be further review about whether cattle should 

be allowed back into restored areas at all.

Response

Thank you for your comment. Please see the response to comment 8.8. 
408 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Appendix D. Comment Letters Received from 

Federal and State Agencies 

This appendix provides the comment letters and emails submitted by Federal and State agencies 

during the comment period for the DEIS. This is in accordance with Forest Service Handbook 

1909.15.25.1, stating “as a minimum, include in an appendix of the final EIS copies of all 

comments received on the draft EIS from Federal, State, and local agencies and elected offices.”

We received three letters from Federal and State agencies:

 Morgan R. Nelson, New Mexico Environment Department 

 Stephen Spencer, U.S. Department of Interior 

 Rhonda Smith, U.S. Environmental Protection Agency
Appendix D. Comment Letters Received from State and Federal Agencies

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 409

Letter 11, Morgan R. Nelson, New Mexico Environment 

Department 
Appendix D. Comment Letters Received from Federal and State Agencies

410 FEIS for the Southwest Jemez Mountains Landscape Restoration Project
Appendix D. Comment Letters Received from State and Federal Agencies

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 411
Appendix D. Comment Letters Received from Federal and State Agencies

412 FEIS for the Southwest Jemez Mountains Landscape Restoration Project
Appendix D. Comment Letters Received from State and Federal Agencies

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 413

Letter 13, Stephen Spencer, U.S. Department of the Interior 
Appendix D. Comment Letters Received from Federal and State Agencies

414 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Letter 16, Rhonda Smith, U.S. Environmental Protection 

Agency 
Appendix D. Comment Letters Received from State and Federal Agencies

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 415
Appendix D. Comment Letters Received from Federal and State Agencies

416 FEIS for the Southwest Jemez Mountains Landscape Restoration Project
FEIS for the Southwest Jemez Mountains Landscape Restoration Project 417

Appendix E. Changes Made Since the Draft 

Environmental Impact Statement 

Abstract

The text was updated to reflect the selected alternative and text was added about the objection 

process. 

Summary

Minor edits were made to improve clarity and correct misspellings and grammatical errors. 

The wording of the fourth “purpose” of the project was revised to be consistent with the text of 

the CFLRP legislation.

Under the heading “Actions Common to Alternatives 1, 3, 4, and 5”, the second bullet point 

regarding aspen treatments was revised and now reads; “... treatments are intended to maintain 

existing aspen stands.” Also, under the heading “Treatments to Enhance Seeps and Springs, the 

term “Cut trees” was changed to “Cut conifers”. 

Under the heading “Major Conclusions of the Analysis”, additional details about the effects on 

human health from prescribed fires were added.

Chapter 1 

Minor edits were made to improve clarity and correct spelling and grammatical errors. 

Minor changes to the wording of the description of the existing and desired conditions and the 

purpose and need were made to improve clarity and eliminate duplicate text. 

Under the heading “Purpose and Need”, the third purpose (wood products), was revised to be 

consistent with the text of the CFLRP legislation.

Under the heading “Proposed Action”, item 'Improve function of riparian...', the text under bullet 

point 8, was changed from “Remove trees” to “Remove conifers”. Under the item “Reduce 

Impact from Roads”, bullet point 1, the last part of sentence after unneeded roads, was deleted for 

clarity. 

Under the heading “Decision to be Made” item 4 was revised to be consistent with the text of the 

CFLRP legislation. 

Added a new section titled “Tribal Consultation”. This section provides information about the 

consultation process and concerns raised by the tribes during the NEPA process. The consultation 

discussion under “Public Involvement Efforts” was moved to the Tribal Consultation section. 

Under the headings “Forests and Woodlands” and “Ponderosa Pine and Dry Mixed Conifer 

Forests”, the text was revised to incorporate newer research on forest density and fire severity and 

frequency in dry forests. 
Appendix E. Changes Made Since the DEIS

418 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Removed the section titled “Changes to the Proposed Action”. This section covered changes 

made between scoping and the DEIS. It is no longer needed. 

Chapter 2 

Minor edits were made to improve clarity and correct spelling and grammatical errors. 

Minor changes to the wording of the description of the proposed action and other alternatives 

were made to improve clarity and eliminate duplicate text.

The following changes were made under the heading “Required Permits, Approvals, and 

Consultation”: (1) added text listing State and Federal law and regulation regarding air quality; 

(2) added the need to obtain an air quality permit from NMED for gravel pit operations; and (3) 

clarified the policy and regulations regarding tree cutting in inventoried roadless areas.

Figure 13a, which shows the potential gravel pit locations, was added. 

In table 3, under “Road Treatments”, a new category was added: “Roads re-opened, reconstructed 

if necessary, and closed after use”. This category had been combined with “Roads re-opened, 

maintained, and closed after use”. The new category more accurately describes the road 

treatments. The mileages for the new category were taken from the other category; mileage totals 

are the same as in the DEIS. 

In table 3, under “Air Quality”, the amounts of emissions were changed from English tons to 

metric tons. 

In table 3, under “Visual Quality”, the effects statement for alternative 3 was modified to be

consistent with similar effects statements. 

Chapter 3 

Minor edits were made throughout the chapter to improve clarity and consistency and to correct 

spelling and grammatical errors. 

The term “prescribed burn(ing)” was replaced with “(use) prescribed fire” to be consistent with 

fire terminology. 

Changes to resource sections in this chapter:

All Chapters

References to ESA Section 7consultation with the U.S. Fish and Wildlife Service and the 

biological opinion were updated to reflect that they have been completed. References to 

consultation with the New Mexico State Historic Preservation Office were updated to reflect that 

consultation and concurrence regarding Phase I activities have been completed. 

Air Quality

The figures and text addressing amounts of emissions produced were changed from English tons 

to metric tons
Appendix E. Changes Made Since the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 419

Under the heading “Methods”, additional text was added explaining why some pollutants and 

emissions were not analyzed. The text was revised to further clarify and explain the wildfire 

scenario used in the emissions modeling. 

Under the heading “Amount of Particulate Matter and Carbon Dioxide Produced”, the analysis of 

emissions was expanded to include those from project activities other than prescribed fire, 

including mechanical treatments and timber hauling, road treatments, and gravel pit operations. 

The caption and the discussion about figure 26 were expanded to further explain the differences 

among the alternatives and the uncertainty regarding the prescribed fire treatment footprints. 

The section “Emissions from Other Treatments” was revised in response to comments on the 

DEIS. The analysis was expanded to include emissions from project activities other than 

prescribed fire, including mechanical treatments and timber hauling, road treatments, and gravel 

pit operations. Figure 26a, which displays the amount of emissions from these activities, was also 

added. 

In response to comments from NMED, we added a statement under the “Cumulative Effects” 

saying that prescribed burns would be conducted in compliance with the New Mexico Smoke 

Management Program.

Climate Change 

In response to comments on the DEIS the effects analysis was expanded to include emissions of 

carbon dioxide from project activities other than prescribed fire, including mechanical treatments 

and timber hauling, road treatments, and gravel pit operations. Table 4a, showing the results, was 

also added. This is the same change made in the Air Quality resource section as described above. 

Under the heading Environmental Consequences, Air Quality, the text was revised to further 

clarify and explain the wildfire scenario used in the emissions modeling. This is the same change 

made in the Air Quality resource section as described above. 

Rangeland Resources

Under “Affected Environment” the text describing adaptive management was changed to provide 

clarity. 

Roads and Engineering

Table 21 was revised. The column listing types of road treatments was changed to more 

accurately describe the proposed treatments. The mileages treated under each category also 

changed, but the totals are the same as in the DEIS. This is the same change made in table 3, as

described above.

In response to comments on the DEIS, new text listing the areas where gravel pits would not be 

located was added. 

Under the heading “Temporary Roads”, the text describing the length of the temporary roads was 

clarified. 
Appendix E. Changes Made Since the DEIS

420 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Scenery

In the methods section, the description of the systems used for scenery management has been 

updated. The terminology used to describe scenery objectives was changed from MSI to VQO to 

improve clarity and to be consistent with the language in the forest plan. The third paragraph 

describing the scenery management approach used when the forest plan was developed was 

moved for clarity and readability; it is now the first paragraph in that section. The fourth 

paragraph describing scenery objectives in the Jemez NRA was revised to address all of 

Management Area X. 

Under the heading “Effects, All Alternatives”, the text was revised and expanded to improve 

clarity and to better describe the effects and the link between effects and actions. 

Social Science, Economics, and Environmental Justice

Under the heading “Analysis Questions”, the text was revised for consistency with the purpose 

and need. 

Under the heading “Economic Efficiency”, the definition of “net present value” in the text and in 

footnote 24 was revised to improve clarity of that analysis and the results presented in table 27.

This was done in response to internal and external comments on the DEIS. 

Under the heading “Wood Products and Treatment Costs”, the text discussing hauling costs and 

lumber mills in the area was expanded to include other wood-processing facilities and efficient 

hauling distances. This was done in response to comments on the DEIS. 

The caption for Table 26 was revised to clarify the time period of total wood product production. 

Under the heading “Forest Plan Amendments”, text was added to describe the effects of the 

amendments under alternative 4. 

Soil and Water Resources

The terms “6th code watershed”, 6th HUC or HUC6 were updated to “HUC12” throughout this 

section. HUC 6 is an older classification. 

The number and acreage of wetlands was updated. 

Under the heading Hydrology and Water Quality, the statement regarding the source of aluminum 

in areas streams was revised in response to comments on the DEIS by NMED. 

The term “protected streamcourse(s)”was changed to “protected streamcourses and wetlands” in 

response to comments on the DEIS by the EPA. 

Vegetation 

Under the heading “Effects on VSS Classes” text explaining table 36 was added. The additional 

text better describes the effects resulting from openings created by mechanical treatments. 

Under the heading “Large Trees”, the text was revised to explain the CFLRP legislation regarding 

large trees. Also, the analysis of the amount or number of large trees that would be removed was 

revised in response to comments on the DEIS. 
Appendix E. Changes Made Since the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 421

Wildlife, Fish, and Rare Plants

The term ‘hazard tree removal” was changed to “removal of hazard trees along prescribed fire 

control lines”; this term better describes the treatment. 

In the Threatened and Endangered Species section, under the headings “Affected Species and 

Critical Habitat, Mexican Spotted Owl”, the paragraph above table 39 was revised for clarity and 

readability. 

In the Threatened and Endangered Species section, under the headings “Environmental 

Consequences, Alternative 1, Mexican Spotted Owl”, the location of the potential gravel pits was 

described more clearly.

In the Threatened and Endangered Species section, under the heading “Effects on Critical 

Habitat”, the text was revised to clarify actions, effects, and/or treatment locations. 

In the Threatened and Endangered Species section, the section “Jemez Mountains Salamander, 

Occupied Stands” was deleted in response to the biological opinion. 

In the Threatened and Endangered Species section, the status of the New Mexico Meadow 

Jumping Mouse was updated from “Proposed” to “Endangered”. 

In the Sensitive Species section, under the heading “Effects on Individual (Sensitive) Species, 

Northern Goshawk”, the number of PFAs was revised from the number entirely within the 

boundary (9) to the number within or partially within the project area (14). The total number of 

PFAs on the forest and acres of habitat were added to provide context. The changes were made to 

improve clarity in response to comments on the DEIS. 

In the Migratory Birds section, under “Forest Plan Amendments”, the text was changed to reflect 

changes in the biological evaluation. 

Other

The sections “Short-Term Uses and Long-Term Productivity”, “Other Required Disclosures”, and 

“Compatibility with Goals of Other Local, State, Tribal, and Federal Governments” were added to 

the FEIS. They were inadvertently deleted from the DEIS during the pre-publishing phase. The 

glossary and references were updated. 

Chapter 4 

The lists were updated. 

Appendices

Appendices C, D, E, and F were added. 

The following changes were made to appendix A: 

The numbering scheme for the protective measures was changed for ease of reading. Measures 

are now numbered consecutively from beginning to end. 
Appendix E. Changes Made Since the DEIS

422 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Definitions of the terms design features, best management practices, mitigation measures, 

conservation measures, and monitoring measures were added. 

Throughout appendix A, the term “protected streamcourse(s)” was changed to “protected 

streamcourses and wetlands” in response to comments on the DEIS by the EPA. 

Under Air Quality and Smoke Management, the requirement to obtain air quality permits for 

gravel pit operations, as applicable under NMAC 20.2.72 was added. Also, a new mitigation 

measure to reduce fugitive dust was added.

Under, Fire and Fuels, the term “maintain soil productivity” was changed to “maintain water 

quality and soil productivity” in response to internal and external comments. The two mitigation 

measures were moved to Rangeland Resources.

Under Gravel Pits, new design features addressing emissions and pit rehabilitation in response to 

internal and external comments were added. 

Under Harvesting Operations, the design features and monitoring measures addressing EDA/ERA 

validation monitoring were revised. The EDA/ERA was used as a threshold of concern for 

modeling cumulative effects. This element was revised to incorporate the Forest’s watershed 

monitoring to validate the model and the threshold of concern set by the interdisciplinary team. 

Also under Harvesting Operations item 8 (DEIS) was deleted because it was a duplicate. Design 

feature 90 (FEIS), addressing cutting trees in the primary shade zone was revised. The filter zone 

for ephemeral drainages was changed from 30 feet to 15 feet (design features 100 and 105). 

Under Fire and Fuels and Harvesting Operations, design criteria for riparian streamcourses were 

modified to include wetlands in response to comments on the DEIS by the EPA. 

Under Silviculture Treatments, the following changes were made to match values in the 

silviculture specialist report: (1) design features 225 and 241 under “Uneven-aged management 

using selective cutting in ponderosa pine” and “Uneven-aged management using selective cutting 

in dry mixed conifer”, target basal areas were changed to match the values in the specialist report; 

and (2) design feature 246 under “Uneven-aged management using selective cutting in dry mixed 

conifer”, the amount of tons per acre of down logs left on the ground was changed. Under 

“Treatments in Mexican spotted owl protected activity centers”, design feature 270, the diameter 

of leave trees was changed to match the specialist report. 

Under Scenery, the first sentence of design feature 183 was modified slightly to read “unit layout 

strategy” instead of “initial unit layout strategy.”

Under “Soil and Watershed Health and Function”, design features 283 and 284 were modified to 

allow landings in areas with Mollic soils under certain conditions. 

Under Temporary Road Construction and/or Opening Existing Closed Roads, additional design 

features were added along with a monitoring provision addressing unauthorized use. These are 

items 300-308. These measures were added in response to internal and external comments on the 

DEIS. A new design feature (item 296) was added to address the location of temporary roads. 

Under Wildlife Habitat Treatments, the conservation measure for higher elevation migratory bird 

habitats is now a design feature (item 408) addressing neotropical migratory birds. The change 
Appendix E. Changes Made Since the DEIS

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 423

was made based on the biological evaluation. The second paragraph of design feature 1 in the 

DEIS was deleted because it was redundant with measures resulting from the biological opinion. 

This item is now found as item 311 under the Threatened and Endangered Species section. 

Protective measures related to threatened and endangered species are now under a new heading 

“Threatened and Endangered Species”. In this new section, a mitigation measure (item 320) 

pertaining to Mexican spotted owl surveys was added in response to internal and external 

comments on the DEIS. The protective measures identified in the biological opinion were added 

for the Mexican spotted owl, Jemez Mountains salamander, and meadow jumping mouse. Text 

referring to treatments in Occupied Stands of Jemez Mountains salamander habitat (DEIS, page 

301) was removed to reflect changes based on the biological opinion.

The BMPs and Design Features for soils and watersheds were revised to coincide with final 

watershed and soils specialist report in the following sections: All Activities, Fire and Fuels, 

Harvesting Operations, Headcut Treatments, Instream Habitat Restoration, Bank Stabilization, 

and Stream Channel Treatments, Road Decommissioning and Rehabilitation, Seeps and Springs, 

and Soil and Watershed Health and Function. 

FEIS for the Southwest Jemez Mountains Landscape Restoration Project 425

Appendix F. Legal and Regulatory Findings

Federal laws and Executive Orders pertaining to project-specific planning and environmental 

analysis on Federal lands are listed below. It is not an all-inclusive listing, but summarized 

conformance with the laws and regulations most relevant to this decision.

National Forest Management Act

I find that this decision, including the nonsignificant amendments to the Santa Fe National Forest 

Land and Resource Management plan, as amended, is consistent with the goals and objectives of 

the forest plan. This decision also complies with the management direction and standards and 

guidelines for all relevant management areas described in the plan.

National Environmental Policy Act (NEPA)

The NEPA requires Federal agencies to consider and disclose the effects of proposed actions that 

significantly affect the quality of the human environment. The Southwest Jemez Mountains 

Landscape Restoration Project FEIS analyzes the alternatives and displays the effects in 

conformance with NEPA (40 CFR 1500 to 1508 and FSH 1909.15). 

Endangered Species Act

This decision is consistent with the Endangered Species Act of 1973. The FEIS discloses 

potential impacts to the Federally-listed terrestrial species in the SWJM project area- the Mexican 

spotted owl (threatened) and the Jemez Mountains salamander (endangered) (pages 189-208). 

The analysis concludes that the Proposed Action may affect, and is likely to adversely affect the 

Mexican spotted owl and its critical habitat. Short-term impacts will likely result in long-term 

benefits to the species by increasing habitat resilience to large, high-severity wildfires. Also, 

vegetative diversity will likely improve, which would improve prey abundance and availability 

for the owl. For the Jemez Mountains salamander, the analysis concludes that the Proposed 

Action may affect, and is likely to adversely affect, the salamander and its critical habitat. The 

adverse effects are short term. For both species, the design features and mitigation measures listed 

in appendix A would minimize effects on individual animals and their habitats. 

The analysis for threatened and endangered species also included proposed and candidate species 

that may become federally protected within the life of the project. These species are the New 

Mexico meadow jumping mouse (endangered) and its proposed critical habitat; wolverine 

(proposed 10(j)); and the following candidate species: Western yellow-billed cuckoo, Rio Grande 

cutthroat trout, and Canada lynx. The determinations are shown in the table below. 

Table 1. Summary of determination for federally protected and candidate species in the Southwest 

Jemez Mountains Landscape Restoration Project area

Species Status Determination

Jemez Mountains salamander Endangered May affect, likely to adversely affect

Mexican spotted owl Threatened May affect, likely to adversely affect

New Mexico meadow jumping 

mouse

Endangered May affect, likely to adversely affect

North American wolverine Proposed experimental 

population

May affect, not likely 

affect

to adversely 
Appendix F. Legal and Regulatory Findings

426 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

Species Status Determination

Western yellow-billed cuckoo Proposed threatened May affect, not likely to adversely 

affect

Rio Grande cutthroat trout Candidate May affect, likely to adversely affect

Since we have determined that the Proposed Action may adversely affect Rio Grande cutthroat 

trout, this species was considered as through it were a proposed species for the purpose of the 

analysis.

Formal consultation occurred with the U.S. Fish and Wildlife Service. The USFWS has 

completed the biological opinion for this project. The findings regarding effects are found in the 

biological opinion. The USFWS issued a letter of concurrence on the findings. 

The site-specific amendments related to treatments in owl habitat are designed to meet the 

guidance within the 2012 Revised Recovery Plan for the owl and are therefore consistent with 

recovery objectives for the owl.

Forest Service Sensitive Species 

Federal law and direction applicable to Forest Service sensitive species are included in the 

National Forest Management Act and the Forest Service Manual (2670). The Regional Forester 

has developed the sensitive species list for plants and animals for which population viability is a 

concern. We prepared a biological evaluation on species designated as sensitive by the Regional 

Forester. It was determined that the Proposed Action may affect individuals, but will not cause a 

trend toward federal listing for the following sensitive species: pale Townsend’s big-eared bat, 

American marten, masked shrew, northern leopard frog, Preble’s shrew, water shrew, American 

peregrine falcon, northern goshawk, gray vireo, boreal owl, Rio Grande chub, Rio Grande sucker, 

Springer’s blazing star, yellow lady’s slipper, and wood lily. 

It was determined that the Proposed Action would have no effect on the following sensitive 

species: white-tailed ptarmigan, burrowing owl, bald eagle, Lilljeborg’s pea-clam, American pika, 

Goat Peak pika, Gunnison’s prairie dog, Canada lynx, tufted sand verbena, Greene’s milkweed, 

Chaco milk vetch, Pecos mariposa lily, Pecos fleabane, Chama blazing star, Heil’s alpine 

whitlowgrass, and Arizona willow. These species are not known to occur in the project area, the 

project area is not within the range of the species, or the project area does not have essential 

habitat for the species.

Management Indicator Species 

Effects on management indicator species (MIS) are disclosed in the FEIS (pages 225-230). 

Wildlife MIS within the project area include Rocky Mountain elk, Merriam’s turkey, mourning 

dove, hairy woodpecker, pinyon jay, Mexican spotted owl, and Rio Grande cutthroat trout. 

Project activities will have short-term effects on these species. I find that the Proposed Action is 

consistent with the standards and guidelines pertaining to MIS. Additionally, based on the limited 

effects to any MIS, the Proposed Action does not result in a reduction in the number of acres of 

available habitat for any of the MIS, and does not contribute towards a negative trend in viability 

on the Forest.
FEIS for the Southwest Jemez Mountains Landscape Restoration Project 427

Migratory Bird Treaty Act and Executive Order 13186

The Proposed Action, with the design features, mitigation measures, and best management 

practices described in appendix A of the FEIS and DROD, provides for adequate conservation 

measures for migratory birds. Unintentional take of some individual birds may occur under the 

Proposed Action, but no long-term impacts on bird populations are expected (FEIS, pages 231-

235).

National Historic Preservation Act

The National Historic Preservation Act (NHPA) and the NEPA both require that consideration be 

given to the potential effects of federal undertakings on historic resources (including historic and 

prehistoric cultural resource sites). The guidelines for assessing effects and for consultation are 

outlined in the Region 3 programmatic agreement with the New Mexico State Historic 

Preservation Office and section 106 of the NHPA. Cultural resource surveys have been conducted 

for upcoming ground-disturbing activities requiring inspection and are documented in the cultural 

resources clearance report. Because the project will be conducted over more than one year, 

clearance of future activities will be accomplished using a phased approach as defined in 

appendix J of the programmatic agreement.

The potential effects from this project are not considered to be adverse. The recommended 

protective measures will adequately protect the known cultural resources. The site protection 

measures were developed to be consistent with the NHPA and adapted for use across the Forest. 

Concurrence from New Mexico State Historic Preservation Office (NM SHPO) was received in 

accordance with Section 106 of the National Historic Preservation Act for all Phase One 

activities. Contracts will contain provisions for the protection of known and new sites found 

during project activities.

Clean Water Act

The Clean Water Act of 1948, as amended, establishes as Federal policy the control of point and 

nonpoint pollution and assigns the States the primary responsibility for control of water pollution. 

Compliance with the Clean Water Act by National Forests in New Mexico is achieved under State 

law. The Proposed Action will not result in long-term, adverse impacts to water quality within or 

downstream from the area (FEIS, pages 166-167). The Proposed Action is expected to result in 

minor first year increases in sediment delivery to the low gradient, perennial, intermittent and/or 

ephemeral stream channels resulting from the use of heavy machinery for mechanical treatments 

and instream work. Use of the site-specific design features, mitigation measures, and best 

management practices, this alternative meets the laws and associated regulations designed to 

protect water quality. Based on this analysis, I find that the Proposed Action is consistent with the 

Clean Water Act.

Clean Air Act

The Clean Air Act, as amended, is the comprehensive Federal law that regulates air emissions 

from stationary and mobile sources. This law authorizes the Environmental Protection Agency to 

establish National Ambient Air Quality Standards (NAAQS) to protect public health and public 

welfare and to regulate emission of hazardous air pollutants. The FEIS (pages 54-65) has a 

thorough analysis of the Proposed Action’s potential impacts on air quality, including compliance 

with NAAQS.
Appendix F. Legal and Regulatory Findings

428 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

The Proposed Action is designed to be consistent with the provisions of the Clean Air Act, its 

implementing regulations, and associated State and Federal air quality standards. The Proposed 

Action meets all conditions of the New Mexico Smoke Management Program (SMP), which 

meets the requirements of the Clean Air Act and the Regional Haze Rule (40 CFR 51.309). The 

primary concern with this project in regard to air quality is smoke emissions from prescribed 

fires. No exceedance of Federal or State NAAQS is expected from the operation of vehicles 

(including exhaust and fugitive dust) or prescribed fire treatments. There is a potential for 

significant health impacts because of exposure to PM2.5. Prescribed fires will be planned, 

designed, and implemented to achieve good smoke dispersal and minimize adverse smoke effects 

on air quality and public health and safety, complying with the New Mexico SMP. As such, I find 

that the Proposed Action is consistent with the Clean Air Act.

Executive Orders 11990 and 11988 - Wetlands and 

Floodplain Management

Appendix A of the FEIS (pages 269-303) lists the mitigation measures and best management 

practices. Wetlands and floodplains will be avoided and protected by streamside management 

zones. There will be minor pulses of sediment and ash into wetlands and riparian areas resulting 

from use of heavy machinery and prescribed fire treatments. Treatments for roads and headcuts, 

streambank stabilization, and instream work would reduce the amount of sediment into streams 

and wetlands. The riparian and channel restoration treatments will create additional wetland areas 

and increase connected and functional floodplain areas. The Proposed Action protects floodplains 

and water quality adjacent to wetlands.

Executive Order 12898 - Environmental Justice

Executive Order 12898 governs Federal actions to address environmental justice in minority and 

low-income populations. The provisions also apply to programs involving Native Americans. 

This decision will result in disproportionate impacts on minority, low-income, and/or Native 

American population as a result of smoke emissions from prescribed fires. There are also 

beneficial effects on these populations from the creation of jobs in the wood products industry, 

generation of wood products for personal use, and protection of cultural resources.

Prescribed fire management techniques and other measures described in appendix A of the FEIS 

will reduce impacts from smoke. Mitigation measures include notification of potentially affected 

minority, low-income, and/or Native American communities before and during prescribed fire 

treatments. Also, in accordance with Forest Service policy, contracting procedures will be 

advertised and awarded in a manner that gives proper consideration to minority and womenowned business groups.

Local tribes were consulted throughout the development of this project and they will continue to 

be involved throughout the decision-making and implementation processes.

Wild and Scenic Rivers Act

The project actions were assessed for potential effects on the East Fork Jemez Wild and Scenic 

River to determine compliance with Section 7 of the Wild and Scenic Rivers Act. All activities 

were assessed for their effects on free flow, water quality, and the Outstandingly Remarkable 

Values for which the East Fork was designated. No adverse effects on the East Fork are expected. 
FEIS for the Southwest Jemez Mountains Landscape Restoration Project 429

The project is in compliance with the Comprehensive River Management Plan, as amended into 

the forest plan.

Inventoried Roadless Areas

The 2001 Roadless Area Final Rule (36 CFR 294) established protections for Inventoried 

Roadless Areas. The rule prohibits road construction, reconstruction, and timber harvest except 

for other than stewardship purposes. The proposed treatments meet the criteria for stewardship 

purposes; approval from the Regional Forester is required to cut trees.

The project record contains an analysis of the effects of the restoration treatments on each of the 

nine values or features that often characterize inventoried roadless areas, as identified in the 

Roadless Area Final Rule. The analysis found that the proposed treatments, including the 

mechanical treatments, would improve or have no adverse effect on the nine values or features. 

Therefore, this project is consistent with the 2001 Roadless Rule.

Jemez National Recreation Area 

The analysis of effects on the Jemez National Recreation Area (JNRA) found that effects are 

largely positive. Proposed project implementation is consistent with the JNRA Management Plan 

Amendment.

Consistency with the Forest Plan

The Proposed Action is consistent with Forest Plan goals and objectives, and standards and 

guidelines as documented in the resource sections in chapter 3 of the FEIS and the Forest Plan 

Consistency report in the project record. The Proposed Action incorporates forest plan 

amendments that are not significant. The amendments are listed in appendix B of this record of 

decision to the 1987 Santa Fe National Forest Plan and were analyzed and presented in the FEIS 

in chapters 2 and 3.

The amendments adopt language that allows treatment of vegetation within Mexican spotted owl 

protected activity centers; that is consistent with the revised recovery plan for the Mexican 

spotted owl; eliminates activity restrictions during wildlife breeding seasons; that clarifies

vegetation needs for northern goshawk habitat, that eliminates language referring to other plans 

that do not exist, and that temporarily downgrades the scenery objective. These amendments are 

necessary to assure that we meet the purpose and need of this project while assuring consistency 

with the forest plan.

All amendments are not significant. Regulations guide development, revision, and amendment of 

land management plans. The amendments were initiated as part of the notice of intent in July 

2012, using the 1982 planning rule provision to amend the plan as allowed by the transition 

language of the 2012 planning rule (36 CFR 219.17(b)(3)). On amending a forest plan, the 1982 

planning regulations state: “If the change resulting from the amendment is determined not to be 

significant for the purposes of the planning process, the Forest Supervisor may implement the 

amendment following appropriate public notification and satisfactory completion of NEPA 

procedures (36 CFR 219.10(f)(1982)).”

The amendments are not significant because they (1) do not significantly alter the multiple-use 

goals and objectives for long-term land and resource management, (2) consist of adjustments of 
Appendix F. Legal and Regulatory Findings

430 FEIS for the Southwest Jemez Mountains Landscape Restoration Project

management area boundaries or management prescriptions resulting from further on-site analysis 

when the adjustments do not cause significant changes in the multiple-use goals and objectives 

for long-term land and resource management, or (3) are minor change in standards and guidelines 

(FSM 1926.51).

These amendments do not change the goals, objectives, or outputs of the forest plan and do not 

constitute significant amendments to the forest plan. The amendments also provide a better means 

of achieving the desired ecological conditions described in the forest plan for northern goshawk 

and Mexican spotted owl habitats as well as the purpose and need.