United States Department of Agriculture

Luna Restoration Project

Final Environmental Impact Statement

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

Quemado Ranger District Publication # MB-R3-06-13 April 2019
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations 

and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering 

USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender 

identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, 

income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights 

activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). 

Remedies and complaint filing deadlines vary by program or incident.

Persons with disabilities who require alternative means of communication for program information (e.g., 

Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or 

USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay 

Service at (800) 877-8339. Additionally, program information may be made available in languages other than 

English.

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, 

AD-3027, found online at Filing a Program Discrimination Complaint 

(http://www.ascr.usda.gov/complain_filing_cut.html) and at any USDA office or write a letter addressed to 

USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint 

form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of 

Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, 

D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov.

USDA is an equal opportunity provider, employer and lender.

We make every effort to create documents that are accessible to individuals of all abilities; however, limitations 

with our word processing programs may prevent some parts of this document from being readable by computerassisted reading devices. If you need assistance with this document, please contact the Quemado Ranger District 

at 575-773-4678.

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

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

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

Quarters.
Luna Restoration Project

Final Environmental Impact Statement

Catron County, New Mexico

Lead Agency: USDA Forest Service

Responsible Official: Adam Mendonca, Forest Supervisor

Gila National Forest

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

For Information Contact: Emily Irwin, District Ranger

Quemado Ranger District

P.O. Box 159, Quemado, NM 87829

575-773-4678

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

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

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

modified proposed action, proposes forest, woodland, fuels, watershed, motorized transportation, and 

range and wildlife habitat activities, which includes mechanical treatments and prescribed fire. 

Alternative C includes all of the same proposed in alternative B, but adds the use of herbicides for 

vegetation treatments of rabbitbrush and alligator juniper. Alternative D includes all of the same 

activities proposed in alternative B with the exception of not adding closed and user-created routes to 

the motorized transportation system. This exception does not include the routes required by Tucson 

Electric Power for utility line maintenance. The Gila National Forest has identified alternative C as 

the preferred alternative. A description of the preferred alternative may be found in chapter 2 of this 

document.

This final environmental impact statement and the draft record of decision are subject to objection 

pursuant to 36 Code of Federal Regulations 218.8, Subparts A and B. Objections will only be 

accepted from those who have previously submitted specific written comments regarding the 

proposed project during scoping or other designated opportunity for public comment in accordance 

with §218.5(a). For more information on how to comment or file objections, see the project website at

https://www.fs.usda.gov/detail/gila/home/?cid=STELPRD3828973 or contact Lisa Mizuno, 

Environmental Coordinator, at 575-388-8267.
Luna Restoration Project 

Final Environmental Impact Statement

i

Summary

Background

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

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

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

proposal includes the western portion of the Quemado Ranger District around the area of Luna, New 

Mexico. Within the planning area, there are electronic and communication sites, the community of Luna 

and private inholdings, active grazing allotments and associated infrastructure, and natural and cultural 

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

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

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

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

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

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

Gila and Apache-Sitgreaves national forests responded by proposing ecological restoration treatments 

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

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

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

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

products, and outdoor recreation opportunities.

Public Involvement

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

2015 and periodically updated. The Quemado Ranger District staff hosted two open houses and a 

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

stakeholders on identifying issues, concerns, and restoration and recreation opportunities. Between the 

open houses, over 200 letters were sent to individuals, tribes, organizations, and agencies introducing 

the planning area and providing opportunity to provide input. The notice of intent was published in the 

Federal Register on May 19, 2016. Gila National Forest staff received 27 comments during the scoping 

period. Twelve tribes were consulted with and provided the opportunity to participate in the planning 

process. Gila National Forest staff will continue to engage in tribal consultation.

The notice of availability for the draft environmental impact statement was published in the Federal 

Register on May 11, 2018. The draft environmental impact statement comment period was open for 45 

days, which ended on June 25, 2018. The draft environmental impact statement was mailed to 190 

individuals, organizations, tribes, and local, state, and federal agencies. The Gila National Forest 

published a news release announcing the availability of the draft environmental impact statement and 

posted the release in and around the community of Luna. In response, we received 12 comment letters 

on the draft environmental impact statement.

Significant Issues

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

identified from the scoping comment letters:

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

alligator juniper may not be effective treatment methods.
Summary

Luna Restoration Project 

Final Environmental Impact Statement

ii

2. Fuels treatments: Treatment of mixed conifer stands east of Highway 180 may result in highseverity fires impacting wildlife; and limited burning and thinning may not improve or protect 

Mexican spotted owl habitat.

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

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

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

of roads and trails.

Alternatives

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

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

of significant issues related to fuels treatments and motorized transportation system.

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

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

juniper.

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

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

trails.

Conclusions Related to Impacts

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

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

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

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

16 percent of the project area.

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

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

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

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

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

126 miles in alternative D.

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

stand health and improve wildlife habitat, including habitat for threatened, endangered, and sensitive 

species. There would be reduction in the risk of large uncharacteristic wildfires and their impacts to the 

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

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

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

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

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

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

to include in the final decision.
Luna Restoration Project 

Final Environmental Impact Statement

iii

Contents

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

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

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

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

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

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

Acronyms........................................................................................................................................ vi

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

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

Introduction ................................................................................................................................. 2

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

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

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

Purpose and Need for Action..................................................................................................... 13

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

Modified Proposed Action......................................................................................................... 14

Decision Framework ................................................................................................................. 15

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

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

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

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

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

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

Alternatives Considered but Eliminated from Detailed Study .................................................. 39

Comparison of Alternatives....................................................................................................... 40

Chapter 3. Affected Environment and Environmental Consequences........................................... 61

Introduction ............................................................................................................................... 61

Vegetation.................................................................................................................................. 62

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

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

Air Quality............................................................................................................................... 106

Watershed and Soils................................................................................................................ 108

Roads....................................................................................................................................... 141

Range....................................................................................................................................... 145

Recreation................................................................................................................................ 147

Recreation – Inventoried Roadless Areas................................................................................ 150

Heritage Resources.................................................................................................................. 157

Social and Economics.............................................................................................................. 163

Short-term Uses and Long-term Productivity.......................................................................... 168

Unavoidable Adverse Effects.................................................................................................. 168

Irreversible and Irretrievable Commitments of Resources...................................................... 169

Preparers and Contributors .......................................................................................................... 171

List of Preparers ...................................................................................................................... 171

List of Contributors ................................................................................................................. 172

Federal, State, and Local Agencies ......................................................................................... 173

Tribes....................................................................................................................................... 173

Others ...................................................................................................................................... 173

Distribution of the Environmental Impact Statement .................................................................. 174

Glossary ....................................................................................................................................... 175
Contents

Luna Restoration Project 

Final Environmental Impact Statement

iv

References.................................................................................................................................... 177

Appendices................................................................................................................................... 183

Appendix A: Response to Comments on the Draft Environmental Impact Statement............ 183

Appendix B: Comment Letters from Federal and State Agencies and Tribes......................... 212

Index ............................................................................................................................................ 221

List of Tables

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

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

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

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

project area............................................................................................................................... 7

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

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

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

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

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

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

Table 6. Existing and desired old growth structural attributes by cover type group expressed in 

percentage of area within the Luna planning area ................................................................. 10

Table 7. Acres by fire type within the Luna planning area............................................................ 11

Table 8. Existing fuel conditions by vegetation type within Luna planning area.......................... 11

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

Table 10. Sixth-code watersheds in the Luna planning area. Summary of the 2015 watershed 

condition rating and number of streams in nonattainment of New Mexico State water quality 

standards. ............................................................................................................................... 12

Table 11. Acres of vegetation treatments by action alternative and map reference number ......... 20

Table 12. Acres of rabbitbrush, alligator juniper, and herbicide use by alternative and map 

reference number ................................................................................................................... 22

Table 13. Acres of prescribed fire only and activity fuels treatments by alternative and map 

reference number ................................................................................................................... 25

Table 14. Rangeland improvements proposed under alternative B, C, and D by allotment and 

pasture; map symbols correspond to labels found on MAP 7................................................ 28

Table 15. Summary of range improvements by type per allotment............................................... 28

Table 16. Miles and types of treatments to the motorized transportation system common to 

alternatives B, C, and D, and map reference number for each alternative............................. 30

Table 17. Changes to road system in miles by alternative............................................................. 31

Table 18. Summary of the type, number and location, including MAP 10 reference symbols, in [ 

], of stream and riparian treatments for all action alternatives............................................... 32

Table 19. Comparison of the vegetation resources by alternative ................................................. 40

Table 20. Comparison of the fire and fuels resources by alternative............................................. 43

Table 21. Comparison of the wildlife resources by alternative ..................................................... 45

Table 22. Comparison of management indicator species resources by alternative........................ 51

Table 23. Comparison of the air quality resources by alternative.................................................. 53

Table 24. Comparison of the watershed and soils resources by alternative................................... 54

Table 25. Comparison of the National Forest System roads by alternative................................... 57

Table 26. Comparison of the range resources by alternative ......................................................... 57

Table 27. Comparison of recreation resources by alternative........................................................ 57

Table 28. Comparison of heritage resources by alternative........................................................... 59
Contents

Luna Restoration Project 

Final Environmental Impact Statement

v

Table 29. Comparison of the social and economic resources by alternative ................................. 59

Table 30. Average width of roads and trails by type or maintenance level ................................... 61

Table 31. Forest cover type acres and percentage change in 20 and 40 years under alternative A, 

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

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

A, no action............................................................................................................................ 65

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

action, from existing to 20 and 40 years compared to desired condition; where canopy 

density class A = open (0–39%), B = moderately closed (40–59%), and C = closed (60% +)

............................................................................................................................................... 65

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

from existing to 20 and 40 years compared to desired condition; where canopy density class 

A = open (0–39%), B = moderately closed (40–59%), and C = closed (60% +)................... 65

Table 35. Vegetation structural stages by percentage of area for ponderosa pine cover type for 

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

no action................................................................................................................................. 66

Table 36. Percentage of designated 20% (identified) old growth area meeting minimum criteria of 

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

action...................................................................................................................................... 67

Table 37. Percentage change from existing forest cover type acres at 1 year, 20 years, and 40 

years post-harvest compared to range of desired percentage for alternatives B, C, and D.... 68

Table 38. Percentage of maximum stand density index (SDI) 1 year, 20 years, and 40 years postharvest for alternatives B, C, and D compared to desired percentage of the landscape......... 69

Table 39. Ponderosa pine percentage of area by canopy density class under alternatives B, C, and 

D; 1, 20, and 40 years post-harvest compared to desired condition; where canopy density 

class A = open (0–39%); B = moderately closed (40–59%); and C = closed (60% +).......... 71

Table 40. Woodlands percentage of area by canopy density class under alternatives B, C, and D; 

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

A = open (0–39%); B = moderately closed (40–59%); and C = closed (60% +) .................. 71

Table 41. Vegetation structural stages by percentage of area for ponderosa pine cover type for 1-

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

to desired conditions.............................................................................................................. 72

Table 42. Percentage of designated 20% (identified) old growth area meeting minimum criteria of 

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

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

Table 43. Summary of fire regime groups within the Luna planning area .................................... 77

Table 44. Vegetation condition class distribution in the Luna planning area ................................ 77

Table 45. Summary comparison of all alternatives for fire-related concerns in the Luna planning 

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

Table 46. Vegetation treatment acres, type, and implementation date in the last 12 years within 

the Luna planning area........................................................................................................... 80

Table 47. Summary of federally listed species (endangered, threatened, and experimental) within 

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

Table 48. Gila National Forest management indicator species with associated habitat type and 

rational for including or excluding from analysis.................................................................. 93

Table 49. List of migratory bird species that occur or have the potential to occur within the Luna 

planning area and associated habitat types .......................................................................... 104

Table 50. Summary of watersheds and condition ratings that overlap the Luna planning area. 

Watershed condition ratings are Class 1 = functioning properly, Class 2 = functioning at 

risk, and Class 3 = impaired function. ................................................................................. 111

Table 51. Summary of general ecosystem survey soil condition within the Luna planning area 113
Contents

Luna Restoration Project 

Final Environmental Impact Statement

vi

Table 52. Summary of general ecosystem survey erosion hazard within the Luna planning area

............................................................................................................................................. 113

Table 53. Acres of disturbance by alternative from motorized transportation treatments........... 123

Table 54. Existing Gila National Forest System roads by operation maintenance level and general 

description of each maintenance level ................................................................................. 142

Table 55. Roads under other jurisdiction within the Luna Restoration Project area ................... 142

Table 56. Existing National Forest System roads within the Luna Restoration Project area broken 

down by operation maintenance level and general description of each maintenance level. 142

Table 57. Changes to National Forest System road miles by alternative..................................... 143

Table 58. Grazing allotments located within the Luna planning area.......................................... 145

Table 59. Racial and ethnic breakdown of counties within the analysis area.............................. 164

Table 60. Per capita income and percentage of labor or non-labor source and unemployment for 

counties in the analysis area, state, and nation..................................................................... 165

Table 61. Median household income and percentage of persons in poverty in 2015 .................. 165

List of Figures

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

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

the Apache-Sitgreaves and Gila national forests ..................................................................... 4

Acronyms

CFR Code of Federal Regulations

GIS geographical information 

system

Infra infrastructure database

SDI stand density index

SNOTEL snow telemetry

USDA United States Department of 

Agriculture

USDI United States Department of 

the Interior

U.S.C. United States Code

VSS vegetation structural stage
Luna Restoration Project 

Final Environmental Impact Statement

1

Chapter 1. Purpose of and Need for Action

Structure of this Document

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

National Environmental Policy Act and other relevant Federal and State laws and regulations. 

This document discloses the direct, indirect, and cumulative environmental impacts that would 

result from the proposed action and alternatives. This document consists of the following:

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

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

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

responded.

• Chapter 2. Alternatives, Including the Proposed Action: This chapter describes in detail 

the proposed action and alternatives—including no action. These alternatives were 

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

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

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

describes in detail the environmental effects of each alternative.

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

consulted with during its development. It also includes a list of agencies, organizations, and 

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

• Glossary

• References

• Appendices

• Index

In addition to this document, we produced a separate series of large-size maps to display the 

proposed activities by alternative, and we refer to these maps in chapters 1 and 2. The maps are 

included on a compact disc (CD) accompanying the print version of the final environmental 

statement. The maps also can be viewed online at the project website 

https://www.fs.usda.gov/detail/gila/home/?cid=STELPRD3828973.

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

found in the project planning record located at the Gila National Forest Supervisor’s Office, 3005 

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

provisions of the Freedom of Information Act.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

2

Introduction

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

planning, the Gila and Apache-Sitgreaves national forests have responded by proposing 

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

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

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

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

the Gila and Apache-Sitgreaves national forests (figure 2). The two national forests worked 

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

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

transportation, range, and wildlife habitat activities.

Beginning in 2014, the Quemado Ranger District reached out to the public and county, state, and

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

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

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

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

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

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

Location and Description of Planning Area

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

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

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

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

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

planning area. The project lies within the area of townships 2 through 7 south and ranges 19 

through 21 west.

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

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

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

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

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

interstate has two transmission lines that extend through the entire length of the project area. The 

El Paso Electric interstate transmission line runs approximately 3 miles northeast of the planning 

area. A local service line managed by Navopache Electric Cooperative extends in and around 

Luna.

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

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

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

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

Luna Restoration Project 

Final Environmental Impact Statement

3

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

Luna Restoration Project 

Final Environmental Impact Statement

4

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

the Apache-Sitgreaves and Gila national forests
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

5

Background

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

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

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

some hazardous fuels reduction projects around Luna which included prescribed burning, 

thinning of ponderosa pine stands, and construction of a 300-feet fuelbreak on the south and west 

sides of the community. Beginning in 2009 there was concern regarding the risk of wildfire to the 

community of Luna and surrounding private inholdings, which initiated inventories of the 

surrounding area to determine the vegetation condition. Inventories indicated the presence of high 

tree densities in both large continuous areas and smaller patches, which confirmed the concerns 

regarding the risk of high-intensity wildfire.

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

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

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

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

across the fire area were silted in.

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

acres were burned during the Wallow Fire. Post-fire satellite imagery indicates 1,757 acres were 

burned by high-severity fire and 4,039 were burned by moderate-severity fire. Areas that burned 

with low-severity fire resulted in little or no change to the density of trees or amount of fuels on 

the ground. The impacts of the Wallow Fire in moderate to high-severity burn areas resulted in 

degraded watershed conditions on thousands of acres; substantially altering future yields of clean 

water and future vegetative communities. Land use opportunities, especially on the heavily 

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

successional stages of recovery.

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

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

wildfires on stakeholders and land managers.

Existing and Desired Conditions

Vegetation

Forest Cover Types

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

types are grassland, Douglas fir, oak woodland, piñon pine-juniper woodland, ponderosa pine and 

white fir (table 1).

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

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

desired to favor Gambel oak, aspen, and southwestern white pine within individual stands, 

increase the herbaceous, forb, and shrub components within individual stands and manage for 

uneven-aged characteristics (multistoried) across the majority of the landscape with the exception 

being areas having high levels of insect infestations, disease (white pine blister rust or mistletoe) 

and areas adjacent to private land.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

6

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

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

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

Forest Cover Type Existing Acres

Desired Percentage Change 

from Existing Condition

Grassland/Meadow 21,941 +0-2 %

Douglas fir 6,323 +0-2 %

Engelmann Spruce 109 +0-2 %

Oak Woodland 1,414 ± 2 %

Piñon pine-Juniper 41,713 ± 5 %

Ponderosa pine 87,195 ± 5 %

Riparian 784 Not applicable

Southwestern White Pine 69 +0-2 %

White Fir 6,887 +0-2 %

Reforestation Area 3,954 Not applicable

Rocky Area 942 Not applicable

Total acres 171,3311 Not applicable

1 Acreage does not include private land.

Stand Density Index

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

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

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

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

supported on an acre, or maximum stand density index.

The stratification of stand density index provides a useful means for discussing stand dynamics 

relative to species composition, and the impacts of different tree densities. Long (1985) divided 

the stand density index into four zones based on the percent of the overall density of a tree stand 

relative to the biological maximum density. Regeneration of desired species can be initiated by 

maintaining stand density in zone 1, based on maximum stand density index. Open canopy stands 

with grassy understories and large diameter trees with long, heavy-limbed crowns can be

developed by targeting densities in zones 1 and 2. Stands of moderate crown closure and 

intermediate sized trees with thrifty, well-pruned crowns can be developed by targeting densities 

in the upper half of zone 2 and the lower half of zone 3. Clumpy, irregular stands containing 

groups of varying ages can be developed through managing for a mix of zones 1, 2, and 3. 

Avoiding density related mortality and maintaining forest vigor can be achieved by maintaining 

densities at or less than the lower half of zone 3.

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

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

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

ranges. The existing condition for zone 2 is slightly above the desired range, while zone 1 is 

within the desired range.

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

objectives. To reduce standing fuel loadings within the project area densities should be distributed 

among zone 2 and lower end of zone 3 (with an emphasis on lower densities adjacent to private 
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

7

land holdings and along identified Forest System Roads to increase defensible space for 

firefighters in the event of a wildfire. There would also be an emphasis on low densities in 

grassland and savannah areas to increase herbaceous vegetation and reduce conifer tree 

encroachment. Areas managed for northern goshawk vegetation structural stages 4–6, Mexican 

spotted owl, protected habitat and protected activity centers, Mexican spotted owl threshold 

stands, and areas that are designated for old-growth development should be managed to achieve 

zones 2–4. Maintaining areas in zones 3 and 4 would provide for wildlife requiring higher tree 

densities and canopy cover, and promote development of old growth characteristics in areas 

designated as old growth.

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

area

Zone

Maximum 

SDI 

(percent)

Existing 

Percentage of 

Landscape

Desired 

Percentage of 

Landscape Biological Implications

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

No competition among trees, little crown 

differentiation

Maximum individual tree diameter and volume 

growth

Minimum whole stand volume growth

Shade intolerant seedlings favored

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

forage

Onset of competition among trees, onset of 

crown differentiation

Intermediate individual tree diameter and 

volume growth

Intermediate whole stand volume growth

Shade-tolerant and intolerant seedlings favored

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

Active competition among trees, active crown 

differentiation

Declining individual tree diameter and volume 

growth

Maximum whole stand volume growth

Shade-tolerant seedlings favored

Upper range marks the threshold for the onset 

of density-related mortality

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

Severe competition among trees, active 

competition induced mortality

Minimum individual tree diameter and volume 

growth, stagnation

Declining whole stand volume growth due to 

mortality

Shade-tolerant seedlings favored

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

respective upper and lower thresholds for zones 3 and 4 for the Luna Analysis.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

8

Vegetation Structural Stage

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

northern goshawk. Vegetation structural stage is the metric used to show how the treatments 

move ponderosa pine stands toward the desired conditions (table 3).

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

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

deficit to varying degrees (table 3).

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

of ponderosa pine cover type in the Luna planning area

Vegetation Structural Stage (VSS)

(diameter class in inches)

Existing Condition

(percent acres)

Desired Condition

(percent acres)

VSS 1 (0.0–0.9) 22 10

VSS 2 (1.0–4.9) Less than 1 10

VSS 3 (5.0–11.9) 30 20

VSS 4 (12.0–17.9) 25 20

VSS 5 (18.0–23.9) 16 20

VSS 6 (24 +) 8 20

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

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

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

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

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

both being deficit in uneven-aged structure, means both are exceeding their even-aged structures 

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

structure.

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

percent

Canopy Density 

Class Class Description

Existing Condition

(percent)

Desired Condition

(percent)

A Open (0–39%) 36 40

B Moderately closed (40–59%) 51 40

C Closed (60% +) 12 20

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

Canopy Density 

Class Class Description

Existing Condition

(percent)

Desired Condition

(percent)

A Open (0–39%) 13 55

B Moderately closed (40–59%) 63 30

C Closed (60% +) 24 15
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

9

Old Growth Stand Structural Attributes

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

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

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

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

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

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

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

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

20,177 acres of the ponderosa pine group.

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

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

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

to determine old growth for each cover type for the Luna planning area is displayed in table 6. 

Presently, approximately 12 percent of the ponderosa pine group; 19 percent of the mixed-species 

group; and 87 percent of the woodland group designated as old growth simultaneously meet all 

minimum criteria of the structural attributes (table 6). For the remaining areas, the structural 

attributes are met to varying degrees.

In addition to the old growth direction found in the Gila forest plan, for this project it is desired 

that treatments would be designed to retain old and young large trees whenever possible unless 

they must be cut for threats to human health, safety, and property, and where the removal of an 

old tree is necessary for forest health concerns (high populations of insect or severe disease), or 

where removal is needed to reduce tree density to achieve project desired conditions. Information 

on old and large tree descriptions and instances in which old and/or large trees may need to be 

removed is located in the appendix 3 Luna Restoration Project Old and Large Tree 

Implementation Strategy of the vegetation report.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

10

Table 6. Existing and desired old growth structural attributes by cover type group expressed in 

percentage of area within the Luna planning area

Old Growth Group

Minimum Criteria of Structural 

Attributes1

Percentage 

Existing 

Condition of 

Designated 

20% Old 

Growth Area

Percentage 

Desired 

Condition of 

Designated 

20% Old 

Growth Area

Ponderosa pine 20 live trees in main canopy at least 14

inches in diameter at breast height (DBH)

68 100

Ponderosa pine 1 standing dead tree per acre at least 14

inches DBH and at least 15 feet

46 100

Ponderosa pine 70 to 90 square feet per acre total basal 

area

98 100

Ponderosa pine 40 to 50% total canopy cover 34 100

Ponderosa pine Percent area simultaneously meeting all 

attributes2

12 100

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

inches DBH

45 100

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

inches DBH and at least 20 feet

85 100

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

area

100 100

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

Mixed-species Percent area simultaneously meeting all 

attributes2

19 100

Woodland 12 to 30 live trees in main canopy at least 9

inches in diameter at root collar (DRC)

99 100

Woodland 1 standing dead tree per acre at least 9

inches DRC and at least 8 feet

88 100

Woodland 6 to 24 square feet per acre total basal 

area

100 100

Woodland 20 to 35% total canopy cover 97 100

Woodland Percent area simultaneously meeting all 

attributes2

87 100

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

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

Fuels and Fire

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

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

severe (table 7, MAP 11

). Vegetation and fuel conditions across the planning area include dense 

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

8).

 1 To view MAP 1 through MAP 10, see “Structure of this Document” on page 1.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

11

Table 7. Acres by fire type within the Luna planning area

Fire Type Description Acres at Risk

Surface Fire Fire that burns predominately across the 

surface litter and undergrowth

44,183

Torching/Passive 

Crown Fire

Type of crown fire in which the crowns of 

individual trees or small groups of trees 

burn, but solid flaming in the canopy cannot 

be maintained except for short periods

86,842

Active Crown Fire Also referred to as running crown fire or 

continuous crown fire. An active crown fire 

presents a solid wall of flame from the 

surface through the canopy fuel layers

36,566

Table 8. Existing fuel conditions by vegetation type within Luna planning area

Vegetation Type

Surface Fuel 

Loading1

(tons per acre)

Coarse Woody 

Debris2

(tons per acre)

Canopy Base 

Height3

(feet)

Canopy Bulk 

Density4

(kg/m3)

Piñon-juniper 5 4 5 0.08

Ponderosa pine 5 3 11 0.07

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

1

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

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

2

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

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

3

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

4

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

The desired conditions for fuels and fire are to:

• reduce the number of acres at risk to crown fires (table 7);

• use wildland fire as a disturbance agent;

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

mixed conifer stands; and

• move the planning area fuel conditions towards values or ranges described in table 9.

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

Vegetation Type

Surface Fuel 

Loading1

(tons per acre)

Coarse Woody 

Debris2

(tons per acre)

Canopy Base 

Height3

(feet)

Canopy Bulk 

Density4

(kg/m3)

Piñon-juniper 5 5–10 4–6 Less than 0.05

Ponderosa pine 7–14 5–7 Greater than 18 Less than 0.05

Mixed conifer 2–4 10–15 Greater than 5–10 Less than 0.08

1

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

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

2

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

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

3

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

4

Canopy bulk density is the mass of the available canopy fuel. Canopy bulk density is used to predict crown fire.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

12

Watershed and Aquatics

All or portions of nine 6th-code watersheds are in the Luna planning area (table 10). In 2015,

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

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

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

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

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

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

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

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

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

stream conflicts.

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

loads and temperatures, lack of woody debris in the channel, lack of mature, multistory riparian 

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

The desired conditions for watershed and aquatics are:

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

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

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

Table 10. Sixth-code watersheds in the Luna planning area. Summary of the 2015 watershed 

condition rating and number of streams in nonattainment of New Mexico State water quality 

standards.

6th-Code Watershed1

2015 Watershed 

Condition Rating(*)

Number of Streams / Stream Name 

in Nonattainment of State Water 

Quality Standards (**)

Trout Creek Class 2 0

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

SA Creek Class 2 0

Outlet Centerfire Creek Class 3 1 / Centerfire Creek

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

Headwaters Centerfire Creek Class 2 1 / Centerfire Creek

Spur Draw Class 2 0

Dry Blue Creek Class 2 0

Canovas Creek-Coyote Creek Class 2 0

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

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

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

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

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

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

sedimentation and siltation, specific conductance, water temperature, and turbidity.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

13

Wildlife

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

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

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

stem density, multilayered canopies within the stand, numerous snags, and downed woody 

material.

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

uncharacteristic wildfire (U.S. Fish and Wildlife Service 2012). Crown fire potential was 

analyzed, approximately 68 percent of the planning area is at risk to torching and passive and 

active crown fire (table 6).

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

spotted owl recovery habitat (restricted or protected) in mixed conifer, ponderosa pine Gambel 

oak, and riparian vegetation, and for northern goshawk habitat in other ponderosa pine forest 

types and woodlands. Home range for the northern goshawk is called post-fledgling family area

and includes the nest sites and habitat most likely to be used by fledglings during their early 

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

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

torching, passive, and active crown fire.

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

provide forage for wildlife.

The desired conditions for wildlife are:

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

• improving habitat for threatened or endangered species

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

acres identified for treatment;

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

and

• increasing diversity, productivity, and abundance of browse species (for example, mountain 

mahogany, Gambel oak, and gray oak) for wildlife game species.

Purpose and Need for Action

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

landscape and watersheds capable of delivering benefits to the public including reduced threat of 

high-intensity fire, clean air and water, habitat for native fish and wildlife, forest products, and 

outdoor recreation opportunities. There is a need to:

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

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

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

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

• implement treatments in watersheds that are not properly functioning;
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

14

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

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

tradition and livelihoods of local communities;

• protect and restore threatened and endangered species and habitats;

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

community of Luna;

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

• improve rangeland, wildlife, aquatic and riparian habitat.

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

amendments specifically applicable to the Luna Restoration Project.

Previous Decisions

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

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

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

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

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

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

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

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

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

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

reflected on a motor vehicles use map pursuant to section 212.56.

Modified Proposed Action

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

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

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

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

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

designations for all-terrain vehicle and utility-task vehicle use; no heavy maintenance on level 2

roads; and reopening roads, decommissioning roads, or both.

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

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

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

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

will take place over the next 8 to 10 years, extending up to 20 years or until objectives are met.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

15

Restore the Structure, Function, and Resilience of Forests

• Mechanically treat (cut and/or remove) trees to reduce tree density, treat insect and disease,

and provide species, age, structure, and size class diversity within the stands.

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

natural and activity fuels.

• Enhance and promote browse species including Gambel oak, gray oak, and mountain 

mahogany for wildlife through cutting, burning, or both.

Improve the Function of Riparian Areas and Streams, Vegetative 

Diversity, and Water Quality

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

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

streambanks.

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

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

• Develop waters to improve livestock and wildlife distribution.

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

increase meadow habitat.

• Reduce density of rabbitbrush to improve grassland habitat.

Reduce Impacts from Roads and Project-Related Access

• Decommission roads.

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

• Construct temporary roads and decommission them after use.

• Reopen existing closed roads and close or decommission them after use.

Forest Plan Amendments

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

Decision Framework

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

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

• whether to select the no-action alternative;

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

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

• which forest plan amendments to include in the final decision.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

16

Public Involvement

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

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

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

actions.

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

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

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

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

sent to individuals, tribes, organizations, and agencies introducing the planning area and 

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

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

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

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

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

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

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

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

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

response, we received 27 letters and emails. The content of the letters and emails formed the basis 

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

The notice of availability for the draft environmental impact statement was published in the 

Federal Register on May 11, 2018. The draft environmental impact statement comment period 

was open for 45 days; which ended on June 25, 2018. The draft environmental impact statement

was mailed out to 190 individuals, organizations, tribes, and local, state, and federal agencies. 

The Forest published a news release announcing the availability of the draft environmental 

impact statement and posted the release in and around the community of Luna. In response, we 

received 12 comment letters on the draft environmental impact statement.

Tribal Consultation

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

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

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

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

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

1978), National Environmental Policy Act of 1969 (Public Law 91-190, 42 U.S.C. 4321-4347, 1 

January 1970), Native American Graves Protection and Repatriation Act of 1990 (Public Law 

101-601, 16 November 1990), and National Forest Management Act of 1976 (Public Law 94-588, 

22 October 1976, codified in 36 CFR 219). Executive orders and memoranda include a 1994 

memorandum on government-to-government relations with Native American Tribal Governments 

(59 Federal Register 85, 4 May 1994), Executive Order 13007 on accommodation of sacred sites 

(61 Federal Register 104, 29 May 1996), and Executive Order 12898 on environmental justice 

(59 Federal Register 32, 16 February 1994).
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

17

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

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

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

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

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

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

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

• Alamo Navajo Chapter

• Fort Sill Apache Tribe

• Mescalero Apache Tribe

• Pueblo of Acoma

• Pueblo of Laguna

• Pueblo of Zuni

• Ramah Navajo Chapter

• The Hopi Tribe

• The Navajo Nation

• San Carlos Apache Tribe

• White Mountain Apache Tribe

• Ysleta Del Sur Pueblo

Issues

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

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

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

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

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

factual evidence. The Council on Environmental Quality National Environmental Policy Act 

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

the issues which are not significant or which have been covered by prior environmental review 

(Section 1506.3)....” A list of non-significant issues and reasons regarding their categorization as 

non-significant may be found in the project record.

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

Vegetation Treatments

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

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

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

juniper and rabbitbrush treatment areas.

Fuels Treatments

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

impacting wildlife travel routes. (Comment 27.16)

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

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

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

fire only. Burning prescriptions will include high-moisture and low-intensity parameters.
Chapter 1. Purpose of and Need for Action

Luna Restoration Project 

Final Environmental Impact Statement

18

Routes 1

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

25.1)

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

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

Routes 2

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

20.7)

Result: Modify the proposed action to provide access for Tucson Electric Power to perform 

powerline maintenance activities.

Routes 3

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

(Comment 26.12; 26.14)

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

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

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

disturbance and multiple drainage crossings. (Comment 27.30)

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

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

powerline.
Luna Restoration Project 

Final Environmental Impact Statement

19

Chapter 2. Alternatives, Including the

Proposed Action

Introduction

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

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

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

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

the alternatives will be described in the following manner:

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

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

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

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

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

Alternatives Considered in Detail

Alternative A – No Action

The no-action alternative is required by 40 Code of Federal Regulations 1502.14(d). There would 

be no changes in current management and the forest plan would continue to be implemented. 

There are currently no ongoing vegetation or other restoration type projects within the planning 

area. Activities such as road maintenance, recreation, prescribed fires, and fuelwood gathering 

would continue. Activities that have been authorized in separate decisions such as special use 

permits (for example, powerline corridors, and communication towers), travel management 

implementation, and authorized livestock grazing would continue. Alternative A is the baseline 

for assessing and comparing effects of the action alternatives B, C, and D.

Alternatives B, C, and D by Proposed Activity Types

Activities Common to all Action Alternatives

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

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

line officer on a case-by-case basis.

Vegetation Treatments

The following vegetation treatments are the same for alternatives B, C, and D (table 11, MAP 2

and MAP 3). There are no differences in the location, acres, or proposed treatments between 

alternatives.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

20

Table 11. Acres of vegetation treatments by action alternative and map reference number

Vegetation Treatments Alternative B Alternative C Alternative D

MAP 

Number

Woodland (juniper and piñon pine) 

mechanical and/or hand treatments 

[acres]

20,328 20,328 20,328 MAP 2

Forested (ponderosa pine and mixed 

conifer) mechanical and/or hand

treatments [acres]

53,529 53,529 53,529 MAP 2

Total acres mechanical and/or hand 

treatments

73,856 73,856 73,856 Not 

applicable

Grassland tree removal (ponderosa 

pine, juniper spp.) [acres]

20,283 20,283 20,283 MAP 3

Grassland wet/upland meadow and 

valley bottoms tree removal 

(ponderosa pine, juniper spp.) [acres]

2,842 2,842 2,842 MAP 3

Total acres grassland treatments

23,125 23,125 23,125 Not 

applicable

Mexican spotted owl protected activity 

centers – thin trees less than 9 

inches, pile or broadcast burn [acres]

1,319 1,319 1,319 MAP 2

Treat Gambel, gray oak and mountain 

mahogany stands by cutting and/or 

prescribed burning

Yes Yes Yes Not 

applicable

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

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

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

or mechanized equipment. Implementation prescriptions will vary based on wildlife habitat 

(Mexican spotted owl restricted or northern goshawk) due to differing habitat requirements. More 

detailed information is located in appendix 1 Luna Restoration Project Treatment Details for 

Vegetation Treatments of the vegetation report.

Group Selection with Thinning is one uneven-aged forest management system. The objective is to 

achieve multiple age (canopy stories) classes of trees within each stand of trees. Dominant tree 

species to treat are ponderosa pine, Douglas fir, piñon pine, Gambel oak, gray oak, and all species 

of juniper. Minor species include white fir, aspen, and southwestern white pine. In the ponderosa 

pine and mixed conifer forests, a mix of species would be maintained. Healthy aspen clones, 

individual and healthy Gambel oak motts, and southwestern white pine would be favored as leave

species where they occur. Otherwise, the most dominant tree species suited to the site would be 

favored. Group selection of excess size classes and diseased patches would be used to regenerate 

20 percent of the area. Additional seed trees of desirable species and characteristics would be 

retained when openings are greater than one acre. Newly created openings will be irregular 

shaped and generally range from one-tenth to three-quarter acre in size, but groups may be less 

than one-tenth acre and occasionally greater than one acre in size. Smaller openings are 

preferable. When openings exceed one acre in size, 5 to10 desirable seed trees per acre will be 

retained. The remaining 80 percent of the area would be thinned to increase the resiliency, health 

and vigor of the remaining trees. Sprouting tree species may be pruned in conjunction with 

thinning to raise crown height of ladder fuels in lieu of cutting when appropriate in wildlandurban interface areas.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

21

Improvement Thinning/Woodland Transition is a treatment designed to restore and maintain 

mixed conifer and ponderosa pine forests and woodlands having a ponderosa pine component by 

cutting trees to move the area toward the desired condition for Mexican spotted owl restricted 

recovery habitat and restricted threshold recovery nest/roost habitat, or northern goshawk habitat. 

No regeneration openings would be created. In forested areas, species as discussed under Group 

Selection with Thinning would be favored. In the woodland, piñon pine and juniper would be 

favored as leave tree species to encourage and maintain dominance in the woodland vegetation 

transition. With the exception of juniper, this treatment would focus on thinning trees up to 12 

inches diameter at breast height or diameter at root collar. Sprouting tree species may be pruned 

in conjunction with thinning to raise crown height of ladder fuels in lieu of cutting when 

appropriate in wildland-urban interface areas.

Woodland/Ponderosa Pine Transition treatment is an improvement thinning designed to restore 

and maintain areas currently dominated by piñon pine and juniper species by cutting trees. No 

regeneration openings would be created, similar to the Improvement Thinning/Woodland 

Transition treatment. Dominant tree species to treat are ponderosa pine, piñon pine, Gambel oak, 

gray oak and all species of juniper. In the ponderosa pine forests, where vegetation is or has 

transitioned from ponderosa pine dominance to piñon pine and juniper dominance, if ponderosa 

pine is present it would be favored as a leave tree species to encourage increasing this species 

component and shifting the composition back to forest based on soil type. In the piñon pine and 

juniper woodland, piñon pine and juniper would be favored as leave tree species. Sprouting tree 

species may be pruned in conjunction with thinning to raise crown height of ladder fuels in lieu of 

cutting when appropriate in wildland-urban interface areas.

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

activities.

Grassland – Maintenance and Restoration: Grassland maintenance and restoration treatments 

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

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

cutting ponderosa pine and piñon-juniper by hand or mechanized equipment, to reduce tree 

canopy cover to less than 10 percent in grasslands. Treatments located in upland wet meadows 

and valley bottoms primarily associated with Jenkins Creek, Badger Creek, Romero Creek, Stone 

Creek, Dry Blue, San Francisco River, Dillman Creek, and Trout Creek areas.

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

bottoms.

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

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

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

Wildlife Habitat: Cut and/or prescribe burn a portion of the Gambel oak, gray oak, aspen, and 

mountain mahogany components within the woodland and forest to promote new growth and 

sprouting in various locations across the planning area. This would occur in conjunction with 

other vegetation and fuel treatments.

Design Features Common to Vegetation Treatments

• Follow appropriate best management practices for vegetation management activities (for 

example, forestry, logging, and roads).
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

22

• Minimize damage to hardwood trees that are designated for retention during operations.

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

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

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

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

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

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

habitat.

• Monitoring will occur before and after implementation of projects for federally listed and 

sensitive species. Mitigations such as breeding season restrictions would be used to lessen 

effects to wildlife.

• Notify and coordinate with Tucson Electric Power and Navopache Electric Cooperative 

during design and layout of vegetation treatments areas near or within their powerline 

rights-of-ways.

Vegetation Treatments – Herbicide Treatments

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

using herbicide (table 12, MAP 3 and MAP 4). There are differences in proposed treatments in 

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

Table 12. Acres of rabbitbrush, alligator juniper, and herbicide use by alternative and map reference 

number

Vegetation Treatments Alternative B Alternative C Alternative D

MAP 

Number

Rabbitbrush treatment with mowing 

only [acres]

20,283 0 20,283 MAP 3 1

Rabbitbrush herbicide application with 

or without mechanical assistance 

(for example, mowing) [acres]

0 Up to 20,283 0 MAP 4

Alligator juniper herbicide application 

in grassland meadows [acres] 2

0 30 0 MAP 4

Alligator juniper herbicide application 

in forests and woodlands [acres] 2

0 Up to 8,000 0 MAP 4

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

2 Acres for alligator juniper are a subset of the acres in table 11 describing acres of vegetation treatments.

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

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

treatment of rabbitbrush under all of the action alternatives. Green and rubber rabbitbrush are 

native shrubs that grow widely across Western United States rangelands. Though they can appear 

as a weedy monoculture (especially following disturbance), they are early colonizers, and their 

presence can be reduced under improved management regimes (USDA Forest Service 2015). The 

objectives of the proposed treatments are to manage rabbitbrush and reduce the occurrence of 

dense stands or monocultures of rabbitbrush, not to eliminate rabbitbrush across the planning 

area. The objectives can be met by treating existing stands to allow for the replacement of 

rabbitbrush by desired herbaceous vegetation and shrubs, and through management of grasslands 
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

23

to prevent the establishment of dense stands of rabbitbrush. The majority of the 20,283 acres of 

grassland identified, the proposed herbicide use would be to maintain the grassland characteristics 

if needed. Individual rabbitbrush treatment projects within the proposed 20,283 acres of grassland 

are not likely to exceed 1,000 acres.

Alternatives B and D

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

alternatives, dense stands of rabbitbrush would be identified for mowing and reseeding to break 

up these communities and allow for replacement by vegetation that is more desirable. Mowing 

alone could require multiple entries into the site to deplete the plants energy stores enough to 

achieve limited mortality in rabbitbrush. Single entry mowing would only suppress top growth in 

rabbitbrush and would not result in long-term alteration of the plant community. Mowing would 

be limited to those areas that are accessible to mowing equipment and where mowing would not 

result in resource concerns.

Alternative C

Alternative C would incorporate the application of herbicide on rabbitbrush in grasslands and 

alligator juniper in forest and woodland areas. Pretreatment of vegetation may be needed before 

application of herbicide using such things as chainsaws, mowing, or other type of mechanical 

equipment to assist in exposing the part of the plant recommended for effective treatment. For 

alligator juniper, herbicide could be applied on identified acres in conjunction with mechanical 

and/or hand treatments. Herbicide applications in forest and woodland would be used to treat 

alligator juniper in areas where current treatments are not meeting objectives due to re-sprouting. 

For rabbitbrush, herbicide could be used in conjunction with mowing or on its own in locations 

where mowing is not feasible. The herbicide selected, timing of application, species and 

subspecies treated, and soil type are important factors for success.

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

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

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

on the Gila National Forest (USDA Forest Service 2000a).

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

hand spreading (granular or powder), or broadcast using a small tractor or all-terrain or utilitytask vehicle towing a spreader. Rubber-tired mechanical equipment will be used.

Design Features Specific to Herbicide Treatments

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

herbicide:

• Prior to implementation, an interdisciplinary team will develop a forestwide Vegetation 

Management Plan for herbicide treatments on rabbitbrush and alligator juniper. The plan 

would include such things as objectives, techniques, and monitoring elements as well as the 

design features identified in the environmental impact statement and appropriate best 

management practices, permitting, and handling of materials.

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

complying with all label instructions and restrictions required for legal use.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

24

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

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

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

avoid impacting vegetation on private lands. This buffer can be removed or reduced upon 

request by the private landowner.

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

signing.

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

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

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

• Do not direct spray toward any open water.

• Mixing and loading would not occur near streams or other standing water.

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

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

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

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

habitat.

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

and in accordance with equipment manufactures specifications. To reduce the risk of nontarget species being impacted, all spraying should occur with winds less than 10 miles per 

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

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

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

limitations have been exceeded.

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

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

residual activity.

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

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

chemical treatment areas.

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

to avoid or minimize surface water and groundwater contamination.

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

local regulations, including label directions.

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

individual treatment area.

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

all known archaeological sites.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

25

Prescribed Fire Treatments

Alternatives B, C, and D propose the same treatment (table 13, MAP 5 and MAP 6). There are no 

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

Table 13. Acres of prescribed fire only and activity fuels treatments by alternative and map reference 

number

Prescribed Fire Treatments Alternative B Alternative C Alternative D MAP Number

Prescribed fire only – mixed 

severity [acres]

11,996 11,996 11,996 MAP 5

Prescribed fire only – low severity 

[acres]

24,026 24,026 24,026 MAP 5

Prescribed fire only (total) 36,022 36,022 36,022 Not applicable

Mexican spotted owl protected 

activity centers – broadcast burn 

(subset of prescribed fire only 

total)

8,399 8,399 8,399 Not applicable

Prescribed fire and mechanical 

treatments – low and mixed 

severity [acres]

70,000 –

100,000

70,000 –

100,000

70,000 -

100,000

MAP 6

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

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

highly variable pattern of mortality on the landscape that fosters development of diverse 

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

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

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

Prescribed Fire – Low Severity: Low-severity prescribed fire is proposed on approximately 

24,026 acres on the north aspect of the San Francisco Divide, and southwest of Luna in the Dry 

Blue and Frieborn Canyon areas extending south to the planning area boundary. This area has 

limited access, steep topography, sensitive soils, high fuel loads, and potential for high-severity 

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

objective of implementing prescribed fire is to create a mosaic of burned and unburned patches of 

vegetation, of varying acreages, on the landscape to protect values at risk.

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

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

season; fall and early spring when low temperatures, high humidity, and residual snow patches 

limit fire growth. Ignitions would be patterned after a lightning storm; a number of ignitions 

(dots) scattered across an area. Desired results would be reduction of surface and canopy fuels. 

The end state would be areas treated with prescribed would eventually merge and breakup the 

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

objectives.

Prescribed fire would be initiated using aerial-ignition devices (helicopter – ping-pong balls), 

hand-ignition devices (drip torches, fusees, pen flare or very pistol, terra torch, matches), or both.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

26

Design Features Specific to Low-severity Prescribed Burning Activities

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

around the snow telemetry (SNOTEL) site.

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

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

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

Design Features Common to All Prescribed Burning Activities

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

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

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

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

severity within the watershed.

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

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

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

residual heat, to minimize the effects on soils.

• Firelines would be used to facilitate broadcast burns or pile burning operations as needed.

• Notify and coordinate with Tucson Electric Power and Navopache Electric Cooperative at 

least 2 weeks in advance, when burning near or within their powerline rights-of-way.

• For public and firefighter safety, federal and state highways, county and national forest 

roads, and national forest trails within or adjacent to the project area would be signed when 

prescribed fire activities are taking place.

• Landowners would be notified at least one week prior to implementation.

• Public notices will be posted within the local communities and local agencies contacted 

(for example, sheriff’s department and local volunteer fire departments) at least one week 

prior to ignition.

• Contact Catron County Clinic two weeks prior to planned ignition.

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

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

• Notify and coordinate with allotment permittees when scheduling and implementing 

treatments.

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

Environmental Department, Air Quality Bureau smoke management rule. Emission 

reduction techniques would be utilized when possible to minimize impacts to sensitive 

receptors.

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

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

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

within and adjacent to protected activity centers which result in low-severity prescribed 
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

27

fire. No activities would take place from March 1 to August 31 to avoid disturbance to owls 

during the breeding season.

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

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

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

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

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

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

habitat.

Range Management

Alternatives B, C, and D propose the same range improvements (table 14, MAP 7). There are no 

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

quantity of improvements are summarized by allotment in table 15.

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

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

wildlife distribution to benefit rangeland conditions, including watershed, soils, and stream 

resources. A pasture division fence is proposed on the Spur Lake allotment. The proposed 

improvements would improve livestock distribution, forage utilization and management 

flexibility. This proposal would not alter the management (livestock kind, class, number or season 

of use) or desired conditions outlined in each allotment’s corresponding grazing analysis.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

28

Table 14. Rangeland improvements proposed under alternative B, C, and D by allotment and 

pasture; map symbols correspond to labels found on MAP 7

Allotment Pasture

Map 

Symbols on 

MAP 7 Rangeland improvement description

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

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

Centerfire Freeman 

Mountain 

CF5 Install 2 new trick tanks.

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

Dillman/Trout 

Creek 

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

1 mile of pipeline

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

pipeline. Install 1 new well in section 12.

Luna Sawmill, 

Kiehne, Adair 

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

and 2.75 miles of pipeline.

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

.75 miles of pipe.

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

2.5 miles of pipeline.

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

.5 miles of pipeline.

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

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

2 miles of pipeline.

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

2 miles of pipeline.

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

2.5 miles of pipeline.

* Additional storage tanks may be placed with drinkers if needed to improve functionality of water systems.

Table 15. Summary of range improvements by type per allotment

Allotment

Wells

(number)

Storage

Tanks

(number)*

Drinkers

(number)

Trick 

Tanks

(number)

Pipeline 

(miles)

Fence 

(miles)

Centerfire Allotment 2 4 2 2 0.75 0

Dillman/Trout Allotment 1 1 2 0 1 0

Luna Allotment 4 4 10 0 7.25 0

Mangitas Allotment 1 1 2 0 0.5 0

Spur Lake Allotment 3 3 8 0 6.5 2.25

Total 11 13 24 2 16 2.25

* Additional storage tanks may be placed with drinkers if needed to improve functionality of water systems.

Eleven of the proposed water systems include the installation of new wells (table 15). Installation 

of these improvements is contingent on the Gila National Forest’s ability to meet the 

requirements of the New Mexico Office of the State Engineer. The improvements would require 

the appropriate licenses or water use agreements prior to implementation. In the event the Gila 

National Forest is unable to obtain a license, an alternative water source could be considered 
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

29

provided the effects of using that water source do not differ from the effects disclosed in this 

analysis.

Storage tanks are available in a variety of sizes and construction materials. For the purposes of 

this project, one storage tank refers to approximately 10,000 gallons of storage capacity. This can 

be achieved through a single tank or multiple smaller tanks. Additional storage capacity may be 

necessary for the water system to function properly. Design will be reviewed prior to 

implementation. Drinkers or troughs located away from the water source and primary storage 

could have an associated 3,000 to 5,000 gallon storage to improve functionality of the water 

system.

All pipelines proposed within this analysis would be buried unless resource concerns or terrain 

would not allow for the ability to bury the lines below the frost level. Pipelines are buried to 

improve the functionality of the system and reduce maintenance needs. To reduce impacts to 

wildlife during trenching operations, where possible, the following guidelines would be 

implemented construction:

• Attempt to keep trenching and back-filling activities as close together to minimize the 

amount of area and time the trench is open.

• Avoid leaving trenches overnight. If left open, place escape ramps no more than 300 feet 

apart. Ramps should be sloped less than 45 degrees. Trenches should be inspected and any 

wildlife removed prior to resuming work.

• Attempt to conduct trenching operations during cooler months.

Drinkers would have wildlife escape ramps securely installed and would be maintained to provide 

a year-round water source to wildlife except:

• where the possibility of freezing could compromise the integrity of the water system;

• where the water source is limited and not adequate to support year-round use;

• for resource management purposes; limit water or availability so livestock, wildlife, or both

have to disperse; or

• for general maintenance needs.

Implementation of proposed improvements will require using motorized equipment. Motorized 

equipment will vary depending on improvement type, ranging from all-terrain vehicles and 

utility-task vehicles, full-size vehicles, large trucks, up to small dozers. A helicopter may be used 

to deliver materials into some locations.

Fence construction or reconstruction will be wildlife-compatible; that is, constructed in a manner 

to facilitate wildlife access over, under, or through the fence while minimizing chances of 

becoming entangled. The following specifications (or the most current Forest Service 

specifications) would be used during construction, where needed:

• a top wire or rail preferably no more than 38 inches above the ground, and absolutely no 

more than 42 inches

• at least 12 inches between the top two wires

• at least 16 inches between the bottom wire or rail and the ground

• smooth wire on the bottom
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

30

• posts 16 to 20 feet intervals

• utilize gates, drop-downs, or other passages where wildlife concentrate and cross

Motorized Transportation System

Alternatives B, C, and D

The following transportation activities are the same for alternatives B, C, and D (table 16, MAP 8 

and MAP 9). There are no differences in the location, miles, or proposed treatments between 

alternatives.

Table 16. Miles and types of treatments to the motorized transportation system common to 

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

Transportation Treatments Alternative B Alternative C Alternative D

MAP Number MAP 8 MAP 8 MAP 9

Road decommissioning 116 116 116

Change Admin/Written Authorization road 

segments from open to decommissioned 

(Tucson Electric Power) (miles subset of 

decommissioning)

1.7 1.7 1.7

Leave horse, hiking and foot trail tread during 

decommissioning of roads

4.23 4.23 4.23

Reopen maintenance level 1 closed roads for 

administrative or permitted use for proposed 

treatment activities and close or 

decommission after activities are completed

34.5 34.5 34.5

Maintenance level 1 administrative or 

permitted use roads to be closed after 

activities completed

22.6 22.6 22.6

Maintenance level 1 administrative or 

permitted use roads to be decommissioned 

after activities completed (miles are subset of 

total road decommissioning)

12 12 12

Add user-created route and designate as 

administrative use or written authorization 

only (Tucson Electric Power)

0.5 0.5 0.5

Construct temporary roads - obliterate after 

vegetation treatments are completed

3–5 3–5 3–5

Reopen closed roads for periodic 

administrative use or written authorization 

only (Tucson Electric Power)

3.5 3.5 3.5

Road decommissioning are activities that result in the stabilization and restoration of unneeded 

roads to more natural states (36 CFR section 212.1). Decommissioning includes utilization of

heavy equipment to install signs, gates, rock barriers, or ripping and recontouring of slopes and 

installing drainage features such as water bars. Routes that have established vegetation may need 

minimal treatment while others may need to be entirely ripped, seeded, and slopes recontoured.

A trail tread for horse and hiking or foot access would be maintained on National Forest System 

roads 4023 V, 4029 E, and 4030 W during design and implementation of decommissioning.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

31

Heavy equipment would be used to reopen closed roads for project activities or administrative 

uses. These roads would be returned to closed status once activities are completed expect for 

those needed by Tucson Electric Power Company to access powerlines. To restrict motorized 

access such things as berms, gates, or other barriers would be installed.

Add user routes as part of the national forest road system to facilitate Tucson Electric Power 

Company to access lines. These roads would be designated administrative use only.

Construct temporary roads to access treatment activity areas and obliterate after treatments are 

completed. Obliteration is a full restoration of entire temporary roadbed, utilizing the same 

equipment and methods described in decommissioning.

Alternative D

Alternatives B and C provide the same motorized transportation opportunities to address 

recreation and public motorized uses (table 16, MAP 8). Alternative D was developed in response 

to a scoping comment to not increase miles of National Forest System roads (table 17, MAP 9). 

The decision for reopening of 0.2 mile of National Forest System road 3050 was made in the 

2013 travel management record of decision, so it remains in alternative D unlike the other routes 

(table 17). The type of work and equipment to reopen 3050 is the same as described in 

alternatives B and C.

Under alternative D, the 13.6 miles of maintenance level 1 road will be added to the 

decommissioning miles, bringing the total miles of roads to be decommissioned to 130 miles for 

alternative D.

Table 17. Changes to road system in miles by alternative

Transportation Treatments Alternative B Alternative C Alternative D

Reopen national forest system 

maintenance level 1 closed roads to 

open to all motor vehicle types

13.8 13.8 0.2

Add user-created routes and designated 

as National Forest System roads open 

to all motor vehicle types

4.2 4.2 0

Construct motorized 4x4 trail (Dillman 

Creek reroute)

0.3 0.3 0

The Dillman Creek reroute is a 4x4 motorized trail, to be constructed to a maximum trail tread 

width of 60 inches, with an obstacle clearing limit width of 72 inches, utilizing mechanized 

equipment. Barriers would be installed at each end of the 4x4 trail segment to limit vehicle size 

access.

Design Features Common to All Road Activities

• All roads, temporary or permanent, will be located sufficiently far from streams or other 

water bodies (except for portions of such roads which must cross water bodies) to minimize 

discharges of dredged or fill material into waters.

• All temporary roads would be designed to minimize impacts to natural resources.

• Follow appropriate best management practices for roads management.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

32

Stream and Riparian Treatments

Alternatives B, C, and D propose the same stream and riparian treatments (table 18, MAP 10). 

There are no differences in the type, number or location of treatments between alternatives.

Although route LATV-9 would not be implemented under alternative D, work is still proposed on 

the crossing in alternative D to address sedimentation concerns.

Table 18. Summary of the type, number and location, including MAP 10 reference symbols, in [ ], of 

stream and riparian treatments for all action alternatives

Type of Work Number Location

Crossing 10 National Forest System road 882 Head of Ditch CG; [Map Symbol 

X2]

Dry Blue Trail #61 (6 crossings); [Map Symbol DB1-DB6]

County Road B-012; [Map Symbol X1]

National Forest System road 4127U; [Map Symbol X3]

LATV-9; [Map Symbol X4]

Diversion 1 Luna Ditch Diversion point in Head of Ditch Campground; [Map 

Symbol X2]

Exclosure 4 Stone Creek

Centerfire Creek

Spur Lake Draw

Adair Spring

Barriers 2 Construct motor vehicle barriers Frieborn Trail [Map Symbol DB7]

Construct motor vehicle barriers Blue Spring Trail; [Map Symbol 

DB8]

Riparian 2 Centerfire Creek, Spur Lake Draw

Erosion Control

Maintenance

157 Existing erosion control features located across the planning area

[Map symbol yellow triangles]

Seeding multiple Spur Lake Draw

Stream and bank 

structures

10 streams, 

multiple

Instream structures, bank stabilization, or both: Bishop Canyon, 

Romero Creek, Dry Blue, Pace Creek, Centerfire Creek, San 

Francisco River, Stone Creek, Spur Lake Draw, Jenkins Creek,

Canovas Creek

Surface erosion 

reduction

2 Head of the Ditch Campground roads; [Map Symbol X2]

Trout Creek dispersed camping area; [Map Symbol Trout Creek]

Crossings: Within the Dry Blue, harden six motorized trail crossings to reduce impacts to aquatic 

habitat and improve water quality. Hardening of crossing may consist of such things as 

interlocking concrete blocks, concrete planks, prefabricated bridges, rock riprap, or other 

engineered design. Equipment such as a Kabota or small backhoe may be used to dig footings for 

bridge type structures or carrying in construction materials. A helicopter may be used to transport 

pre-fabricated structures.

Road crossings at County Road B-012, National Forest System road 4027 U, LATV-9 will be 

designed to facilitate adequate water passage and reduce erosion. Work may include such things 

as replacement or upgrade of existing structures or material or placement of structures or material 

(for example, culverts, rock, riprap, and fill). All work will utilize some type of heavy equipment 

such as dozers, backhoe, and trucks.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

33

National Forest System road 882 (Head of Ditch campground road) will be relocated due to being 

located within the proposed Luna Irrigation Ditch diversion facility project area. The new 

crossing will be located downstream of its current location and hardened to provide safe ingress

and egress for the public and landowners, and improve aquatic habitat and water quality. All work 

will utilize some type of heavy equipment such as dozers, backhoe, and trucks.

Diversion: The Luna Irrigation Ditch Association owns water rights on the San Francisco River, 

which allows them to store water in Luna Lake, upstream in Arizona, and release this water 

downstream into New Mexico during irrigation season. The diversion is located in the Head of 

Ditch Campground downstream of National Forest System road 882.

The current diversion is a “push-up” style native soil dam located on the Gila National Forest that 

requires frequent maintenance by heavy equipment, particularly following flood events. The 

diversion takes all of the stream flow (except for floods) from May 1 to September 30 of each 

year, leaving no water in the main channel until the stream reaches the first tributary downstream.

The proposal is to construct a permanent diversion facility in the same location, replacing the 

existing diversion, out of durable material, such as concrete, steel, etc. The base would extend the 

width of the stream channel and be tied into the stream banks and protected with concrete wings, 

riprap, or both. The facility would be a dual channel system with easy to move and install panels 

for easy channel switching between irrigation and non-irrigation periods. The proposal includes 

construction of a sediment retention pool upstream of the facility. Construction of the diversion 

facility, sediment retention pool and any other associated activities would require use of heavy 

equipment (for example, backhoe and dozer). There would be activities within and adjacent to the 

stream channel to implement this project. Best management practices and design features will be 

implemented to reduce impacts to stream resources and appropriate permitting obtained to 

conduct instream work.

Exclosures: Exclosure fences are proposed to be constructed along segments of Stone Creek, 

Centerfire Creek, Spur Lake Draw, and Adair Spring. Exclosures would exclude both wildlife and 

livestock providing time for proposed riparian, stream and bank restoration projects to establish. 

Exclosures would be from 0.5 acres up to 200 acres. Once the area stabilizes or vegetation 

becomes established, the exclosure could be relocated or expanded to continue restoration work.

Where access to water is needed for livestock management, Gila National Forest personnel and 

permittees will coordinate to identify appropriate location(s) for water access points or off-water 

sites.

Fencing would be 8 feet or taller to exclude both wildlife and livestock. Motor vehicles may be 

needed to haul fencing materials. A small drill rig or hand drill rig may be used for digging 

postholes.

Barriers: The Frieborn and Blue Spring Trails are designated and constructed for use by hikers 

and horses. These trails intersect the Dry Blue Trail, which is designated for all-terrain vehicle 

use. Motorized vehicles off the Dry Blue Trail have been accessing the nonmotorized Frieborn 

and Blue Spring Trails causing resource concerns and conflict of recreational uses.

Barriers are proposed to block access by motorized vehicle to these trails. Access for hikers and 

horses would be maintained.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

34

Motor vehicles may be needed to haul barrier construction materials. A hand drill rig (auger) may 

be used for digging postholes.

Riparian: Proposed riparian restoration includes planting riparian species in Spur Lake Draw in 

areas above Centerfire Bog and in Centerfire Creek near the vicinity known as Pinpoint 40 and 

within perennial headwater reaches. Planting would provide bank stabilization, improve water 

temperature, and enhance overall water quality. Other stream and bank treatments that will be 

implemented will also serve to enhance riparian resources.

Motor vehicles may be needed to haul equipment and plants. Most planting activities would 

utilize handtools, but there may be a need for a small backhoe to dig trenches.

Erosion Control Features: Numerous erosion control or stabilization structures exist within the 

planning area. It is proposed to conduct maintenance on existing structures. Maintenance of 

structures will vary depending on condition of the structure. Work may include such things as 

removing accumulated sediment, repairing or replacing breeched sections where new headcuts 

and gullies are developing.

Seeding: Improve water quality and quantity by seeding the uplands in multiple locations in Spur 

Lake Draw. The objective is to increase herbaceous ground cover to slow down overland flow

and reduce erosive processes. Sourcing of seed material will follow Region 3 (Southwestern 

Region) guidance on weed free materials. Seeding activities would be by hand or trailer type 

seeders pulled behind motorized vehicles appropriately sized for the trailer type.

Stream and Bank Stabilization Structures: Structures in the uplands may be constructed out of 

on-site native material, rock riprap, rock and wire riprap, or other proven methods. In-channel 

structures may be constructed utilizing on-site native material, rock riprap, rock weirs, bendway 

weirs, wooded material or other proven methods.

Surface Erosion Reduction: To reduce surface erosion, gravel would be placed on roads within 

Head of Ditch Campground and on the access route to the dispersed camping area along Trout 

Creek. Heavy equipment would be used to transport and spread gravel over the proposed 

locations.

Design Features Common to Stream and Riparian Treatments

• Surveys for loach minnow and narrow-headed and northern Mexican gartersnakes will 

occur prior to implementation of stream and riparian treatments within Dry Blue Creek and 

its tributaries, where applicable. Appropriate methods to reduce impacts to the species 

would be applied prior to implementation if detected.

• Surveys for narrow-headed and northern Mexican gartersnakes will occur prior to 

implementation of stream and riparian treatments within the San Francisco River and its 

tributaries, where applicable. Appropriate methods to reduce impacts to the species would 

be applied prior to implementation if detected.

Forest Plan Amendments

Alternatives B, C, and D propose the same forest plan amendments. There are no differences in 

amendments between alternatives.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

35

Project-specific amendments to the Gila forest plan will be prepared under the 2012 Planning 

Rule. These project-specific amendments are a one-time amendment to the Gila forest plan for 

related activities proposed and to be implemented under the Luna Restoration Project only. These 

project-specific amendments include:

• Allow a one-time, project-specific amendment to the forest plan to allow the Gila National 

Forest to deviate from forest plan standard and guidelines for management areas 3B (pages 

105–106), 3C (page 112), and 3D (page 118) to exceed the acres per decade for the amount 

of activity fuels treated (10,000, 4,000, and 12,000 respectively) and fuels treated with 

prescribed fire (10,000, 3,000, and 10,000 respectively).

♦ Replace with: “No more than 25 percent of a 6th-code watershed within a 3-year period 

would be treated. Percentage may be adjusted up or down based on monitoring and 

assessment of watershed conditions, after treatments.”

• Allow a one-time, project-specific amendment to the forest plan to allow the Gila National 

Forest to deviate from forest plan standard and guidelines in Management Area 3D (page

115) to exceed the amount of wildlife habitat development numbers (water developments –

1 structure; wetland developments – 8 structures; brush pile development – 10 structures; 

prescribed burns – 1,000 acres; planting browse/riparian – 10 acres; control of habitat 

access – 10 miles).

♦ The standard and guidelines will be removed and will not be replaced with another.

• Allow a one-time, project-specific amendment for Mexican spotted owl protected activity 

center fuel accumulation treatments to abate fire risk (page 29a 1995 Mexican spotted owl 

recovery plan elements).

♦ Select for treatment 10 percent of the protected activity centers where nest sites are 

known in each recovery unit having high fire risk conditions. Also select another 10

percent of the protected activity centers where nest sites are known as a paired sample 

to serve as control areas.

♦ Select and treat additional protected activity centers in 10 percent increments if 

monitoring of the initial sample shows there were no negative impacts or there were 

negative impacts that can be mitigated by modifying treatment methods.

 Replace with 2012 Mexican spotted owl recovery plan (page 74, U.S. Fish and 

Wildlife Service 2012): Conduct restoration and fuels treatments in up to 20

percent of the protected activity center’s within each ecological management unit

that exhibits high fire risk conditions.

♦ Designate a 100-acre “no-treatment” area around the known nest site of each selected 

protected activity center. Habitat in the no-treatment area should be as similar as 

possible in structure and composition as that found in the activity center.

♦ Use light prescribed burns in nonselected protected activity centers on a case-by-case 

basis. Burning should avoid a 100-acre “no-treatment” area around the activity center.

 Replace with 2012 Mexican spotted owl recovery plan (page 263, U.S. Fish and 

Wildlife Service 2012): Planned ignitions (prescribed fire) and unplanned 

ignitions (wildland fire) should be allowed to enter core areas only if they are 

expected to burn with low fire severity and intensity. Fire lines, check-lines, 

backfiring, and similar fire management tactics can be used to reduce fire effects 
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

36

and to maintain key habitat elements (for example, hardwoods, large downed 

logs, snags, and large trees).

Design Features Common to All Action Alternatives

The Forest Service also developed the following design features to be used as part of all of the 

action alternatives. The following were developed to protect and enhance various resources 

during and after proposed activities.

Forest Stakeholders

• Project activities will be coordinated with all affected stakeholders including grazing permit 

holders, private landowners, federal, state, and local governments.

• Advanced notification of projects, especially prescribed fire, will be completed through 

methods such as letters, emails, flyers, newspaper or worldwide web publications.

Watershed, Water Quality, Riparian, and Soils

• Appropriate best management practices would be properly implemented for all project 

activities to prevent or minimize impacts to soil and water resources and to maintain or 

improve water quality on National Forest System lands.

• Limit ground disturbance by all heavy equipment work when soils are wet or are saturated 

to reduce compaction and soil displacement (rutting).

Invasive and Noxious Weeds

• Prevent the spread of potential and existing noxious or invasive weeds by vehicles used in 

management activities by incorporating weed prevention and control into project contracts, 

layout, design, and implementation.

• Avoid existing noxious or invasive weeds during soil disturbing activities to reduce the risk 

of spread.

Wildlife

• Strive to retain snags of various size and condition for various wildlife species.

• Mitigate loss of individuals and groups of sensitive plants during management activities by 

avoiding or buffering known locations. If found during implementation, plants will be 

avoided or buffered.

• Mexican gray wolf

♦ The U.S. Forest Service will coordinate with the Mexican gray wolf field team on wolf 

activity, especially denning detection during implementation of projects.

♦ If denning activities are detected within vicinity of projects, appropriate actions would 

be implemented in coordination with Mexican gray wolf field team to minimize or 

avoid impacts. Actions may include such things as temporarily suspending work or 

moving activities to another part of the treatment area.

• Mexican spotted owl protected activity centers – Avoid noise disturbing or other activities 

within protected activity centers during the breeding season (March 1–August 31).

• Northern goshawk post-fledging family areas – Avoid noise disturbing or other activities 

within post-fledging family areas during the breeding season (March 1–September 30).
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

37

• Helicopter operations will be coordinated with wildlife biologist.

Cultural Resources

• Archaeological surveys will be conducted on projects and areas in accordance with the 

Luna Planning Area Survey Sampling Plan (USDA Forest Service 2017a, HR 2017-06-

029/NMCRIS No. 137925).

• All archaeological sites will be avoided and protected to avoid potential impacts.

• Avoid piling slash or activity fuels on sites. For prescribed burning, no ignition points will 

be within archaeological sites.

• If cultural or historic sites are discovered during implementation, work will cease until 

appropriate treatment is identified and consultation with the State Historic Preservation 

Office is completed.

• Use of mechanical treatments for all project types will avoid all known cultural and historic 

sites.

Recreation and Scenery Management

• Closure and information signs will be placed on all trail access points and along the trail 

where activities are occurring.

• Shape of individual units, edges of individual units, and patterns created by multiple units 

will appear natural when viewed by forest visitors.

• Character trees and trees that define the trail corridor would be retained wherever feasible.

• Minimize both short and long-term impacts to recreation infrastructure and use. Keep 

temporary roads, skid trails, and landing construction to a minimum. Minimize the longterm visual impact of access roads, skid trails, and landings along trail corridors.

• Where feasible activity slash will be piled 150 feet from system trails.

• Minimize “leave tree” marking along Highway 180 corridor, County roads, National Forest 

System roads and trails, and Head of the Ditch Campground.

• When trails are temporarily closed due to harvesting, trail tread will be cleared of all slash. 

Changes to trail alignment and surfacing will be minimized; the trail will not be 

straightened nor its surface be changed with an alternate material unless such actions are 

needed to enhance the trail and protect resources.

• When skid trails intersect national forest system trails, after implementation skid trails will 

be obscured with slash. If skid trails do not revegetate naturally, then ripping and seeding 

would be considered.

• Stump heights within 150 feet of trails will be cut to 6 inches or less. Ideally, stumps 

immediately adjacent to trail would be flush cut.

• Where the trail tread crosses the transmission line corridor, a distinguishable trail tread 

across the corridor would be maintained to ensure users stay on the trail system. If activities 

involving mechanized equipment or ground disturbance obscures or alters the trail tread, 

the trail tread will be restored to maintain its trail class design parameters. Additionally, any 

access used to cross a system trail will be maintained at right angles to the trail.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

38

Implementation

Implementation is estimated to begin in late 2018 with initial treatments over the next 8 to 10 

years and extending 20 years or until objectives are met, including maintenance. Amount, 

frequency and duration of work would occur as funding, favorable conditions, or both allow.

Monitoring

• Conduct implementation and effectiveness monitoring for best management practices.

Review of a selection of effectiveness monitoring sites will be accomplished as a part of 

either the annual project review or Gila National Forest activity review by Gila National 

Forest watershed personnel.

• Conduct implementation and effectiveness monitoring for proposed vegetation and 

prescribed fire activities, including ensuring compliance of contract specifications.

• Monitoring projects, including effectiveness monitoring for best management practices, 5-

year review of forestwide watershed condition classification documentation, or both, would 

be reviewed to determine if the limitation of landscape treatment acres to no more than 25

percent of a 6th-code watershed within a 3-year period could be adjusted. Documentation 

and consensus by review team and approval by the district ranger is required for percentage 

adjustment.

• Mexican spotted owl habitat implementation and effectiveness monitoring – In 

coordination with U.S. Fish and Wildlife Service personnel, monitoring of treatments will 

be accomplished to determine the effects of treatments on constituent elements of Mexican 

spotted owl habitat.

• Surveys to detect presence of loachminnow and narrow-headed gartersnake, and New 

Mexico meadow jumping mouse will occur prior to implementation of stream and riparian 

treatments. Appropriate methods to minimize impacts to species will be applied during 

implementation.

• Conduct surveys or monitoring of threatened and endangered species outlined in biological 

opinion issued by U.S. Fish and Wildlife Service for this project.

• Monitor riparian exclosures for response and modification. Modifications include such 

things as expanding, moving, reducing, or removal.

• Additional riparian and aquatic monitoring for 6th-code watersheds within the planning area 

is found in the Escudilla Landscape Watershed Restoration Action Plan (USDA Forest 

Service 2018).

• After treatments are completed, areas will be periodically monitored for detection of 

invasive and noxious weed infestations and the effectiveness of implementing weed 

prevention and control measures during activities.

• Conduct implementation and effectiveness monitoring of avoidance and protection design 

features for heritage resources. If sites are found to be impacted, appropriate mitigation 

measures will be developed in coordination with the appropriate agencies and applied to 

relative remaining project implementations.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

39

Alternatives Considered but Eliminated from Detailed Study

This section describes the alternatives considered but eliminated from detailed study and the 

reasons why. These are presented in no particular order. Some suggestions from the public were 

not fully developed alternatives.

Use of Mechanical Treatments only within Defined Wildland-Urban 

Interfaces in the Planning Area

Limiting mechanical treatments to just wildland-urban interfaces would benefit the community of 

Luna and some smaller identified areas around private land inholdings (statewide wildland-urban 

interface layer). Luna is one of the communities considered under the project’s need for reducing 

impacts of high-severity fires. Limiting the use of mechanical treatments to just urban-interface

areas, would limit possible implementation methods, reduce the ability to treat a larger number of 

acres in a timely manner, add to the timelines for implementation over the entire project area, 

potentially limit treatments due to contract economics, and reduce efficiency of moving toward 

meeting desired conditions. Therefore, use of mechanical treatments only within defined 

wildland-urban interfaces does not meet the purpose and need.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

40

Comparison of Alternatives

This section provides a summary of the effects of implementing each alternative. Information in table 19 through table 29 is focused on activities 

and effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives.

Table 19. Comparison of the vegetation resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Forest Composition –

Forest Cover Type

No vegetation management 

activities would occur under 

this Alternative. Tree densities 

would continue to increase and 

there would be an associated 

decline in understory species 

diversity and herbaceous 

growth, which may lead to 

increased conifer 

encroachment in 

grassland/meadow areas. 

Without disturbance, activecompetition induced mortality 

could occur in high-density

areas and predispose areas to 

bark beetle outbreaks. Fuels 

would continue to build and 

could increase the fire hazard 

within the project area.

Group Selection, thinning and 

prescribed burning treatments 

would reduce density, and 

create more open forest 

conditions, with increased 

herbaceous, forb, and woody 

vegetation production. These 

treatments would favor seral 

species retention and would 

create conditions conducive for 

seral species regeneration 

establishment in openings. 

Grassland and meadow 

treatments would also see 

increased grass and forb 

production. Change in 

vegetation composition will 

increase diversity at both the 

stand- and landscape-scale.

In addition to activities listed in 

alternative B, herbicide use is 

proposed to treat rabbitbrush in 

grassland/meadow restoration 

treatments, and sprouting 

juniper in forested and 

woodland areas. Herbicide use 

will increase treatment 

effectiveness by creating 

growing space for desirable 

species to regenerate such as 

grasses and forbs in 

grassland/meadow treatments, 

and conifer seedlings in 

forested areas. Herbicide 

application would also be 

targeted within the wildland 

urban interface where 

sprouting of juniper postthinning could create ladder 

fuels. In this case, herbicide 

treatment will help increase the 

effectiveness of fuel reduction

treatments with treatments 

lasting longer than with tree 

cutting alone.

Effects same as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

41

Resource Element Alternative A Alternative B Alternative C Alternative D

Forest Diversity and 

Structure – Relative 

Stand Density

No vegetation management 

activities would occur under 

alternative A. in the absence of 

disturbance stand density 

levels would continue to 

increase over time. A large 

portion of the project area will 

be at or above 55% of stand 

density index max in the long 

term and there will be active 

competition induced mortality. 

Stand growth and individual 

tree vigor will decline as 

density increases as there is 

increased competition for site 

resources. Risk of loss from 

bark beetles could also 

increase at high densities.

Vegetation management 

activities under alternative B 

will move the landscape 

towards the desired condition 

more than the no-action 

alternative over time. Stand 

density will be reduced, 

individual tree vigor and stand 

growth would be enhanced in 

forested areas. Stand structural 

complexity and heterogeneity 

would be increased at both the 

stand-and landscape-scale 

under alternative B. This will 

help create more resilient 

ecosystems that are better 

suited to future disturbances.

Effects are mostly the same as 

alternative B except for 

treatment of rabbitbrush and 

alligator juniper.

Under alternative C, herbicide 

use will increase the length of 

time targeted species are 

controlled reducing competition 

related tree mortality more 

effectively than alternative B.

Same effects as alternative B.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

42

Resource Element Alternative A Alternative B Alternative C Alternative D

Forest Diversity and 

Structure for Wildlife 

Habitat Improvement 

(northern goshawk) –

Vegetation Structural 

Stage

No vegetation management 

activities would occur under 

alternative A. The existing 

distribution of vegetation 

structural stages for ponderosa 

pine and woodland cover types 

would change slowly through 

time without disturbance and 

would trend towards denser 

stages and canopy density 

classes. The risk of loss of 

trees and possibly entire 

stands from insect epidemic or 

wildfire could increase as stand 

densities within the project area 

continue to increase. Over 

time, tree mortality from 

disturbance or competitioninduced mortality would create 

large enough openings for 

regeneration establishment and 

representation of the 

vegetation structural stages1 

and A canopy density class.

There are approximately 

76,218 acres of proposed 

treatments within forested and 

woodland areas managed for 

northern goshawk under 

alternative B. A variety of 

treatments are proposed 

including thinning, group 

selection-thin and/or prescribed 

burning. These treatments will 

help promote uneven-aged 

structure and increase 

heterogeneity at the stand- and 

landscape-scale. This will help 

move the project area towards 

desired conditions, which is to 

create diverse stand structures 

at both the stand- and 

landscape-scale for northern 

goshawk management.

Effects are the mostly the same 

as alternative B except for

treatment of rabbitbrush and 

alligator juniper.

Under alternative C, herbicide 

use will increase the length of 

time targeted species are 

controlled reducing competition 

related tree mortality more 

effectively than alternative B.

Same effects as alternative B.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

43

Resource Element Alternative A Alternative B Alternative C Alternative D

Old Growth – Stand 

Density, Canopy 

Cover, and Snag 

Density

There would be no vegetation 

management activities under 

alternative A. As a result as 

stand densities continue to 

increase over time there would 

be a high risk of loss of dead 

and down material, dead 

standing material, and live 

vegetation from disturbance(s) 

for example, wildfire 

occurrence due to the high 

average tree densities. 

Individual tree growth and vigor 

would also decline and could 

predispose areas with high 

densities to competitioninduced mortality and other 

biotic agents such as bark 

beetle outbreaks.

Alternative B proposes to treat 

approximately 24,780 acres of

areas designated to be 

managed to develop old growth 

characteristics with a variety of 

treatments including thinning, 

regeneration treatments and/or 

prescribed burning. Density 

reduction would increase 

residual tree vigor and increase 

old-growth characteristics at a 

faster rate than untreated 

areas. Density reduction would 

lower the average basal area 

and provide a reduction of 

fuels, which may reduce 

potential damage to old growth 

components in the event of a 

wildfire. Treatments would 

increase structural

heterogeneity with project 

design features emphasizing 

clumps, gaps and openings.

Alternative C proposes to treat 

a maximum of 333 acres of 

stands designated to be 

managed toward an old growth 

condition with herbicide in 

ponderosa pine and woodland 

areas. Herbicide use when 

needed to control juniper 

sprouting in openings will 

increase the length of time 

sprouting is controlled more 

effectively than alternative B. 

Effects of this alternative in the 

remaining 24,447 acres 

designated for management 

toward an old growth condition 

would be the same as 

alternative B.

Same effects as alternative B.

Table 20. Comparison of the fire and fuels resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Reduce Impact of 

High-Severity Fire –

Percentage of 

modeled crown fire 

(passive and active) 

67% 16% 16% 16%

Reduce Impact of 

High-Severity Fire –

Percentage of 

modeled surface fire

24% 84% 84% 84%
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

44

Resource Element Alternative A Alternative B Alternative C Alternative D

Restore Departed 

Landscapes that are 

at Risk of Fire – Total 

acres treated in fire 

regime group I

0 116,000 116,000 116,000

Fire and Fuels 

Management

Fuel conditions and crown fire 

potential in the project area 

would continue to be of 

concern and may be 

exacerbated by on-going insect 

and disease activity, natural 

disturbances, and the 

progression of forest growth 

and change. Canopy and 

ladder fuels and surface fuel 

loading levels would continue 

to increase throughout the 

project area. There would be 

no reduction in potential fire 

behavior and it would be 

expected crown fire potential 

would increase. No progress 

would be made toward 

reducing the impact of highseverity fire. This alternative 

would not assist in returning 

fire as a natural process in firedependent ecosystems. It 

would not allow land managers 

to help to restore or maintain 

desired conditions. 

Ecosystems, that are not 

adapted to high-intensity/highseverity wildfires, would remain 

at risk.

Treatments would decrease 

potential crown fire activity, 

reduce fuel-loading levels and 

understory ladder fuels thereby 

reducing the impacts of highseverity wildfire on resources. 

Approximately 36,022 acres 

would be prescribed burned. 

Additionally, 95,997 acres 

would receive mechanical 

treatments, of which may also 

include a subsequent 

prescribed burning treatment 

(pile, under burning). Potential 

crown fire behavior and the 

threat of high-severity fire 

would be reduced. Modeling 

results show approximately 

16% of the project area would 

exhibit crown fire and 84% 

would exhibit surface fire, as 

compared to 67% and 24% 

respectively with the existing

condition. Approximately 

115,926 acres would be treated 

in fire regime group I. Initiating 

prescribed burning on the 

landscape will help initiate the 

restoration of ecological 

processes in fire-dependent 

ecosystems.

Same effects as alternative B Same effects as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

45

Table 21. Comparison of the wildlife resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Mexican gray wolf No project activities would be 

implemented and therefore 

there would be no effect to the 

Mexican gray wolf.

Under all action alternatives, 

disturbance to potential 

denning sites are minimized 

through avoidance or other 

features developed in 

coordination with the field team 

in relation to the activity being 

implemented. There are 

beneficial effects to the species 

and its habitat through 

reduction of habitat 

fragmentation through road 

decommissioning and 

improvement of native ungulate 

(prey species) habitat. A 

determination of “not likely to 

jeopardize” is made for all 

action alternatives.

Same effect as alternative B Same effect as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

46

Resource Element Alternative A Alternative B Alternative C Alternative D

Mexican spotted owl No project activities would be 

implemented and therefore 

there would be no effect to the 

Mexican spotted owl. However 

the habitat would continue to 

be at risk of being impacted by 

wildfires.

Thinning and burning activities 

will reduce basal area in 

protected activity centers 

during the short term (but not 

drop below threshold values)

and will adjust the structure 

and thermal characteristics. 

Reducing fuel loading in 

designated critical habitat could 

impact prey species in the 

short term. Reducing juniper 

could reduce food sources for 

prey species. Performing 

actions outside of the breeding 

season, or after confirming 

non-breeding status, will 

prevent disturbing nesting owls.

The Luna Restoration Project 

would reduce habitat needs in 

protected activity centers in the 

short term, but improve 

conditions in the long term;

therefore, the Luna Restoration 

Project may affect, likely to 

adversely affect the Mexican 

spotted owl.

Treatments in designated 

critical habitat would align with 

the forest plan, which 

complements the 1995 

Mexican spotted owl recovery 

plan, therefore the Luna 

Restoration Project may affect, 

not likely to adversely affect the 

designated critical habitat for 

the Mexican spotted owl.

Same effect as alternative B Same effect as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

47

Resource Element Alternative A Alternative B Alternative C Alternative D

Southwestern willow 

flycatcher

There will be no effect to the 

species due to southwestern 

willow flycatchers not being 

observed within the project 

area for the last 10 years and 

the designated critical habitat 

within the planning area does 

not contain the primary 

constituent elements to support 

the birds. No activities are 

being implemented; therefore,

there will be no effect to 

designated critical habitat.

There will be no effect to the 

species due to southwestern 

willow flycatchers not being 

observed within the project 

area for the last 10 years and 

the designated critical habitat 

within the planning area does 

not contain the primary 

constituent elements to support 

the birds. The removal of 

riparian vegetation and shortterm disturbances from other 

stream restoration activities 

and decommissioning within 

designated critical habitat 

would be insignificant and 

discountable. These sites are 

small and localized, but have 

the potential to provide longterm benefits, although would 

not greatly improve or change 

the primary constituent 

elements of the critical habitat. 

Project activities may affect, 

not likely adversely affect the 

designated critical habitat.

Same effect as alternative B. 

Application of design feature 

for buffering the critical habitat 

from herbicide treatments 

would not change the habitat 

constituents or alter the 

vegetation.

Same effect as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

48

Resource Element Alternative A Alternative B Alternative C Alternative D

Narrow-headed 

gartersnake

No activities are being 

implemented; therefore, there 

will be no effect to the narrowheaded gartersnake or its 

proposed critical habitat.

The removal of riparian 

vegetation and short-term 

disturbances from other stream 

restoration activities and 

decommissioning within 

proposed critical habitat would 

be insignificant and 

discountable. These sites are 

small and localized, but have 

the potential to provide longterm benefits. Surveying for the 

gartersnake prior to 

implementation and moving 

individuals upstream from 

project sites will reduce the risk 

of disturbance and harm. 

Project activities may affect, 

not likely adversely affect the 

narrow-headed gartersnake, 

and may affect, likely to 

adversely affect its proposed 

critical habitat.

Same effect as alternative B. 

Application of applicable design 

features for water related 

resources and the buffer for 

proposed critical habitat from 

herbicide treatments would 

minimize risk of impacts to the 

narrow-headed gartersnake 

and its proposed critical 

habitat.

Same effect as alternative B.

New Mexico meadow 

jumping mouse

No activities are being 

implemented; therefore, there 

will be no effect to the New 

Mexico meadow jumping 

mouse.

The removal of riparian 

vegetation and short-term 

disturbances from other stream 

restoration activities and 

decommissioning are small and 

localized, but have the potential 

to provide long-term benefits. 

Surveying for the jumping 

mouse prior to implementation 

and reconsulting with U.S. Fish 

and Wildlife Service if found 

around projects in habitat will 

reduce the risk of disturbance 

and harm. Project activities 

may affect, not likely adversely 

affect the New Mexico meadow 

jumping mouse.

Same effect as alternative B. 

Application of applicable design 

features for water related 

minimizes the risk of impacts to 

the New Mexico meadow 

jumping mouse.

Same effect as alternative B.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

49

Resource Element Alternative A Alternative B Alternative C Alternative D

Loach minnow No activities are being 

implemented, therefore there 

will be no effect to loach 

minnow or its designated 

critical habitat, but the risk of 

being impacted by wildfires 

would continue.

Project activities will cause 

short-term negative impacts to 

loach minnow and its critical 

habitat. Stream, riparian, and 

hardening crossings activities, 

and reducing the risk 

sedimentation, ash, and debris 

from uncharacteristic wildfires 

through vegetation and 

prescribed fire, will provide 

long-term benefit to the specie 

and habitat. The project will 

result in a may affect, likely to 

adversely affect to the loach 

minnow and its designated 

critical habitat.

Same effect as alternative B. Same effect as alternative B. 
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

50

Resource Element Alternative A Alternative B Alternative C Alternative D

Spikedace There will be no effect to 

spikedace. Spikedace have not 

been found occupying streams 

within the planning area.

No activities are being 

implemented, therefore there 

will be no effect to designated 

critical habitat, but the risk of 

being impacted by wildfires 

would continue.

Spikedace have not been 

found occupying streams within 

the planning area. Spikedace 

does occur downstream of the 

planning area. Implementation 

of conservation measures will 

reduce the potential for

adverse effects to spikedace. 

The project will result in a may 

affect, not likely to adversely 

affect the spikedace.

Project activities will cause 

short-term negative impacts to 

spikedace critical habitat. 

Stream, riparian, and 

hardening crossings activities, 

and reducing the risk 

sedimentation, ash, and debris 

from uncharacteristic wildfires 

through vegetation and 

prescribed fire, will provide 

long-term benefit to the habitat. 

The project will result in a may 

affect, likely to adversely affect 

to the designated critical 

habitat.

Same effect as alternative B. Same effect as alternative B.

Region 3 Sensitive 

Species

No activities are being 

implemented, therefore there 

will be no impact to Region 3 

sensitive species that occur or 

may occur within the planning 

area, in addition to previously 

permitted actions.

Implementation of activities 

result in a determination of may 

impact individuals or habitat, 

but will not likely contribute to 

trend in federal listing for 

Region 3 sensitive species that 

occur or may occur within the 

planning area.

Same effect as alternative B. Same effect as alternative B.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

51

Resource Element Alternative A Alternative B Alternative C Alternative D

Migratory Bird 

Species

For migratory bird species that 

occur or potential to occur in 

the planning area, there would 

be no change to the habitat or 

disturbance to the species, but 

there still exists the risk of 

wildfire impacts to forested and 

woodland cover types. A 

determination of “no impact” for 

migratory bird species.

Individuals may be disturbed by 

project equipment noise and 

human presence in the short 

term. Proposed treatments 

would improve habitat and 

reduce wildfire threat in long 

term. There may be short-term 

impacts to individual migratory 

birds, but alteration to their 

habitats or being disturbed 

during treatments, will not 

negatively affect population 

levels.

Same effect as alternative B. 

Herbicide application may 

disturb individuals by noise and 

human presence in the short 

term. Rabbitbrush and alligator 

juniper would be reduced, 

providing opportunity for growth 

and increase of herbaceous 

plants in treatment areas.

There may be short-term 

impacts to individual migratory 

birds, but alteration to their 

habitats or being disturbed 

during treatments, will not 

negatively affect population 

levels.

Same effect as alternative B. 

Not adding user-proposed 

routes would not impact habitat 

nor disturb the species. There 

would be beneficial effects by 

not having routes crossing 

through habitats causing 

fragmentation. Although routes 

are not added under this 

alternative, other activities are 

still being implemented, 

therefore there may be shortterm impacts to individual 

migratory birds, but alteration 

to their habitats or being 

disturbed during treatments, 

will not negatively affect 

population levels.

Table 22. Comparison of management indicator species resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Mule deer No activities are being 

implemented within associated 

vegetation types; therefore,

there would be no impact to 

mule deer, in addition to 

previously permitted actions.

Foraging would be disrupted in 

the short term, but there would 

be long-term improvement of 

habitat conditions for this 

species. Individuals may be 

affected, but at the forest level, 

these affects would not 

adversely affect population 

trends on the Gila National 

Forest.

Same effect as alternative B. 

Applying design features and 

best management practices 

pertaining to herbicide 

treatments will reduce or 

prevent impacts to the species.

Same effect as alternative B. 

Also, not adding routes would 

result in less habitat 

fragmentation.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

52

Resource Element Alternative A Alternative B Alternative C Alternative D

Mearn’s quail No activities are being 

implemented within associated 

vegetation types; therefore,

there would be no impact to 

Mearn’s quail, in addition to 

previously permitted actions.

Forage, nesting, and hiding 

cover would be reduced in the 

short term, but would increase 

in the long term. Individuals 

may be affected, but at the 

forest level, these affects would 

not adversely affect population 

trends on the Gila National 

Forest.

Same effect as alternative B. 

Additional forage may be 

established in treated areas for 

Mearn’s quail. Applying design 

features and best management 

practices pertaining to 

herbicide treatments will 

reduce or prevent impacts to 

the species.

Same effect as alternative B. 

Not adding routes would result 

in less habitat fragmentation.

Long-tailed vole No activities are being 

implemented within associated 

vegetation types; therefore,

there would be no impact to the 

long-tail vole, in addition to 

previously permitted actions.

Some long-tail voles may be 

inadvertently crushed during 

implementation, but proposed 

activities will improve 

conditions in and surrounding 

habitat in the long term for this 

species. Individuals may be 

affected, but at the forest level, 

these affects would not 

adversely affect population 

trends on the Gila National 

Forest.

Same effect as alternative B.

Applying design features and 

best management practices 

pertaining to herbicide 

treatments will reduce or 

prevent impacts to the species. 

Wet meadows will be buffered 

300 feet, and no herbicide 

would be used in the buffer 

zone, reducing risk to the 

species.

Same effect as alternative B. 

Not adding routes would not 

impact the species.

Beaver No activities are being 

implemented within associated 

vegetation types; therefore,

there would be no impact to 

beaver, in addition to 

previously permitted actions.

Some disturbance and loss of 

riparian vegetation in the short 

term, but will have improved 

habitat conditions in the long 

term for this species. 

Individuals may be affected, 

but at the forest level, these 

affects would not adversely 

affect population trends on the 

Gila National Forest.

Same effect as alternative B. 

Applying design features and 

best management practices 

pertaining to herbicide 

treatments and water and 

aquatic resources will minimize 

effects to beaver.

Same effect as alternative B. 

Not adding routes would not 

impact the species.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

53

Resource Element Alternative A Alternative B Alternative C Alternative D

Plain titmouse No activities are being 

implemented within associated 

vegetation types; therefore,

there would be no impact to 

plain titmouse, in addition to 

previously permitted actions.

Since fire has the potential to 

increase the number of snags, 

there would be long-term 

improvement of habitat 

conditions for this species. 

Individuals may be affected, 

but at the forest level, these 

affects would not adversely 

affect population trends on the 

Gila National Forest.

Same effect as alternative B. 

Herbicide utilization may affect 

some food sources in the short 

term. Applying design features 

and best management 

practices pertaining to 

herbicide treatments will 

reduce or prevent impacts to 

the species.

Same effect as alternative B. 

Not adding routes would not 

impact the species.

Hairy woodpecker No activities are being 

implemented within associated 

vegetation types; therefore,

there would be no impact to 

hairy woodpecker, in addition 

to previously permitted actions.

Since snags will primarily be 

retained and fire has the 

potential to increase the 

number of snags, there would 

be long-term improvement of 

habitat conditions for this 

species. Individuals may be 

affected, but at the forest level, 

these affects would not 

adversely affect population 

trends on the Gila National 

Forest.

Same effect as alternative B. 

Herbicide utilization may affect 

some food sources in the short 

term. Applying design features 

and best management 

practices pertaining to 

herbicide treatments will 

reduce or prevent impacts to 

the species.

Same effect as alternative B. 

Not adding routes would not 

impact the species.

Table 23. Comparison of the air quality resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Air Quality – Clean 

Air Act Compliance

Compliance with Clean Air Act. 

No activities are being 

implemented, so no air quality 

impacts from fugitive dust. But 

still higher risk of air quality 

impacts from uncharacteristic 

high-intensity wildfire.

Overall, compliance with Clean 

Air Act is maintained. For 

vegetation and prescribed fire 

activities, short-term additional 

particulate matter, but longterm benefit form reduced 

wildfire risk. Short-term fugitive 

dust from road-related 

treatments.

Same effect as alternative B. 

No additional impacts from 

herbicide use.

Same effect as alternative B.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

54

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

Resource Element Alternative A Alternative B Alternative C Alternative D

Soil Resources No short-term disturbance and 

no long-term benefit to soil 

condition or trend.

For treatments excluding 

decommissioning, there would 

be short-term impacts to soils 

resources, but long-term 

benefit to soil condition and 

trend. Short-term impacts to 

soils resources from 

decommissioning; long-term 

localized impacts from 

increased routes. Projectwide 

long-term benefits to soil 

condition and trend outweigh 

minor localized impacts.

Same effects as alternative B; 

no additional impacts from 

herbicide use.

Same effects as alternative B.

Short-term impacts to soils 

resources from 

decommissioning. Projectwide 

long-term benefits to soil 

condition and trend. Slightly 

better than alternatives B and

C.

Riparian Areas and 

Wetlands / Wet 

Meadows

No short-term or long-term 

benefit to riparian functionality. 

Without vegetation and 

prescribed fire treatments, no 

long-term benefit to riparian 

functionality; higher risk of 

downward trend in event of 

uncharacteristic wildfire.

With vegetation and prescribed 

fire implementation, there 

would be no negative impacts 

with implementation of best 

management practices; longterm benefit to riparian 

functionality with reduced risk 

of uncharacteristic wildfire.

With stream, riparian, and 

erosion control treatments, 

there will be positive benefits to 

riparian functionality, upward 

trend, and improved conditions.

With range management 

treatments, there would be no 

benefit to riparian functionality.

With motorized transportation 

treatments, there will be minor 

impacts to riparian areas that 

will be mitigated with 

implementation of best 

management practices. 

Projectwide long-term benefits 

to riparian areas, wetlands, wet 

meadows outweigh minor 

localized impacts

Same effects as alternative B; 

no additional impacts from 

herbicide use.

Same effects as alternative B.

Motorized transportation 

treatments – projectwide longterm benefits to riparian areas, 

wetlands, wet meadows. 

Slightly better than alternatives 

B and C.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

55

Resource Element Alternative A Alternative B Alternative C Alternative D

Water Quality and 

Quantity

Without vegetation and 

prescribed fire treatments – no 

short-term disturbance; no 

changes in compliance with 

Clean Water Act, no long-term 

benefit to water quality; 

continuation of potentially less 

stable hydrologic regime.

Without stream, riparian, and 

erosion control treatments – no 

short-term disturbance; no 

changes in compliance with 

Clean Water Act, no long-term 

benefit to water quality; 

continuation of unstable 

hydrologic regimes

Without range management –

no changes in compliance with 

Clean Water Act, no changes 

to water quality; no changes to 

hydrologic regime

Without motorized 

transportation treatments – no 

short-term disturbance, no 

changes in compliance with 

Clean Water Act, and no long 

term benefit to water quality.

With vegetation treatments –

short-term additional sediment, 

long-term benefit to water 

quality and hydrologic regime 

with reduced risk of 

uncharacteristic wildfire and no 

changes in compliance with 

Clean Water Act.

With prescribed fire – short 

term added sediment and ash, 

long-term benefit to water 

quality and hydrologic regime 

with reduced risk of 

uncharacteristic wildfire and no 

changes in compliance with 

Clean Water Act.

With stream, riparian, and 

erosion control treatments –

short-term additional sediment,

long-term benefit to water 

quality, and improved 

hydrologic regime. Improved 

compliance with Clean Water 

Act. Potential to meet State 

water quality standards.

Range management 

treatments would result in no 

changes in compliance with 

Clean Water Act.

With motorized transportation 

treatments – short-term 

impacts to water quality from 

decommissioning, long-term 

localized impacts from 

increased routes. Projectwide 

long-term benefits to water 

quality and quantity outweigh 

minor localized impacts.

Same effects as alternative B; 

no additional impacts from 

herbicide use.

Same effects as alternative B. 

Short-term impacts to water

quality from decommissioning; 

projectwide long-term benefits 

to water quality. Slightly better 

than alternatives B and C.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

56

Resource Element Alternative A Alternative B Alternative C Alternative D

Watershed 

Cumulative Effects

Without vegetation and 

prescribed fire treatments – no 

change to watershed condition 

classification, and higher risk of 

downward trend in event of 

uncharacteristic wildfire.

Without other treatments – no 

change to watershed condition 

classifications.

With vegetation and prescribed 

fire treatments – improvement 

in terrestrial biological 

indicators resulting in minor 

upward trend in watershed 

condition classification in 

multiple watersheds, and

reduced risk of downward trend 

resulting from potential 

uncharacteristic wildfire.

With stream, riparian, and 

erosion control treatments –

improvement in aquatic 

biological and aquatic physical 

indicators resulting in upward 

trends and improved watershed 

condition classifications in 

multiple watersheds.

Range management 

treatments would result in no 

change to watershed condition 

classification.

With motorized transportation 

treatments – improvement in 

terrestrial physical indicators 

resulting in upward trends and 

improved watershed condition 

classifications in multiple 

watersheds.

Same effects as alternative B Same effects as alternative B. 

With motorized transportation 

treatments, slightly more 

improvement in terrestrial 

physical indicators than 

alternatives B and C.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

57

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

Resource Element Alternative A Alternative B Alternative C Alternative D

Miles added to the 

national forest road 

system on the Gila

0 22 22 4

Net reduction in miles 

of National Forest 

System roads on the

Gila

0 94 94 126

Table 26. Comparison of the range resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Range Resources No activities are being 

implemented; therefore, there 

are no effects to range 

resources. Without vegetation 

and prescribed fire treatments, 

there would be continued 

encroachment into grasslands 

and risk of wildfire would 

continue.

With vegetation and prescribed 

fire activities, there may be a 

need to rest all or part of 

pastures for a short duration. 

Long-term benefit from 

grassland restoration and water 

improvement.

Effects same as alternative B. 

Herbicide application would 

move the landscape toward 

desired conditions in a shorter 

timeframe compared to only 

mowing in alternatives B and 

D.

Effects same as alternative B.

Table 27. Comparison of recreation resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Recreation 

Opportunity – Quality 

of national forest 

system trails

0 miles constructed 4.5 miles of trail is constructed 

through road to trail conversion 

and 0.3 mile of new 

construction connecting 

motorized trail in Dillman Creek 

area

4.5 miles of trail is constructed 

through road to trail conversion 

and 0.3 mile of new 

construction of connecting 

motorized trail in Dillman Creek 

area

4.2 miles of trail is constructed 

through road to trail 

conversion. No new 

construction of connecting 

motorized trail (0.3 mile)

Recreation 

Opportunity –

Increased opportunity 

for motorized 

recreation for offhighway vehicles

0 miles added to the motorized 

transportation system

18 total miles of national forest 

system roads (13.8 miles) and 

user-created routes (4.2 miles) 

added to the motorized 

transportation system

18 total miles of closed national 

forest system roads (13.8 

miles) and user-created routes 

(4.2 miles) added to the 

motorized transportation 

system

0.2 mile added to the motorized 

transportation system from 

previous travel management 

decision
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

58

Resource Element Alternative A Alternative B Alternative C Alternative D

Inventoried Roadless 

Areas

No activities would be 

implemented; therefore, current 

roadless character would be 

unchanged. Without prescribed 

fire, the risk of wildfire would 

continue. The potential of a 

wildfire could impact 

naturalness and/or recreation 

values of roadless areas.

With low-severity prescribed 

fire there would be some shortterm effect to the undeveloped, 

natural, and opportunities for 

solitude or primitive unconfined 

recreation attributes of the 

Nolan and Mother Hubbard 

inventoried roadless areas; but 

would result in a long-term 

beneficial effect. Temporary 

effects to solitude and 

recreation could occur along 

the roadless boundaries, by 

such things as sights and 

sounds of people working, 

chainsaws, dust, and smoke.

Approximately 0.46 miles of 

road would be changed to trail 

during decommissioning in 

Frisco Box Inventoried 

Roadless Area, improving 

undeveloped quality.

Same effect as alternative B.

No herbicide treatments are 

located in any of the roadless 

areas.

Same effect as alternative B.
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

59

Table 28. Comparison of heritage resources by alternative

Resource Element Alternative A Alternative B Alternative C Alternative D

Heritage Resources –

Relative Risk

No activities would be 

implemented, therefore would 

be no relative risk of potential 

impact to sites. Without 

vegetation and prescribed fire 

treatments, the risk of wildfire 

and erosion episodes following 

fire events would continue. 

With that, the probability that 

heritage resources may be 

adversely affected in the future 

increases.

The relative risk of potential 

impacts to sites based on acres 

of archaeological inventory is 

approximately 76,554 acres of 

projects using heavy 

equipment; a subtotal of 

prescribed fire acres (130,000 

to 160,000 acres) determined 

by high site probability; and 

approximately 20,283 acres of 

mowing rabbitbrush. There is a 

potential for direct and indirect 

effects to heritage resources 

with implementation of the 

various types of projects and 

associated equipment. Effects 

would be minimized or 

prevented through application 

of design features and best 

management practices.

The relative risk is the same as 

alternative B. Herbicide acres 

are the same as rabbitbrush 

mowing area. Plus, an 

additional 8,030 acres may be 

treated with herbicide for 

alligator juniper. Effects are 

same as alternative B.

The relative risk and effects are 

the same as alternative B.

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

Resource Element Alternative A Alternative B Alternative C Alternative D

Environmental 

Justice – Economics

No activities would be 

implemented; therefore, there 

would be no change from the 

current condition and therefore 

no disproportionate adverse 

economic effects to minority or 

low-income populations.

With implementation of various 

projects there is potential for 

economic benefit to local 

contractors or industries and 

increased employment 

including timber or other forest 

products, fire, or other 

restoration projects that could 

be contracted. With potential 

increase in employment 

opportunities, there would be 

no disproportionate adverse 

economic effects to minority or 

low-income populations.

Same effects as alternative B Same effects as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Luna Restoration Project 

Final Environmental Impact Statement

60

Resource Element Alternative A Alternative B Alternative C Alternative D

Environmental 

Justice – Health and 

Quality of Life 

Without implementation of 

prescribed burning, smoke 

emissions would not have 

health and quality of life 

consequences to vulnerable 

populations such as children, 

the elderly, and individuals with 

health and respiratory issues.

The risk of wildfire would 

continue and the intensity and 

duration of smoke emissions 

will be greater than prescribed 

burning treatments and will 

have consequences to 

vulnerable populations.

With prescribed fire treatments, 

vulnerable populations will be 

affected by smoke emissions. 

But intensity and duration of 

smoke emissions will be 

minimized with implementing 

burn prescriptions, coordination 

with the state Air Quality 

Department and advanced 

notification to allow individuals 

to engage other methods of 

reducing smoke impacts.

Same effects as alternative B Same effects as alternative B

Environmental 

Justice – Fuelwood 

as Household Heat 

Source

Without vegetation treatments, 

opportunities for fuelwood 

collection would continue and 

would not affect low-income

families who depend on 

fuelwood for primary heat 

source.

With vegetation treatments, the 

opportunity for additional 

sources of fuelwood would 

become available. Families 

who depend on fuelwood for 

primary heat source would not 

be affected.

Same effects as alternative B Same effects as alternative B
Luna Restoration Project 

Final Environmental Impact Statement

61

Chapter 3. Affected Environment and 

Environmental Consequences

Introduction

This chapter summarizes the physical, biological, social, and economic environments of the 

project area and the effects of implementing each alternative on that environment. The complete 

analysis documents are part of the project record. It also presents the scientific and analytical 

basis for comparing alternatives as presented in chapter 2. Analyses looked at changes from the 

no-action alternative (alternative A).

Notes on Effects Analysis

This final environmental impact statement examines effects on a landscape scale.

Specialists presented any limitations and assumptions in their analyses in accordance to the 

Council on Environmental Quality; Regulations for Implementing the National Environmental 

Policy Act; 40 Code of Federal Regulations section 1502.22; and incomplete or unavailable 

information [51 Federal Register 15625, Apr. 25, 1986].

There may be variations in values displayed by some of the resource areas for alternatives. The 

numbers may vary due to resource spatial data compared to planning area data not matching 

perfectly. Also, depending on the resource area and measure for analysis of effects, the resource 

area of consideration may be more, less, or a subset of the planning area.

Assumptions and Limitations Common to All Resources

For analysis purposes, the average width of roads and trails by type or maintenance level used 

were as shown in table 30.

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

Existing and Proposed Roads and Trails Average Width (feet)

Decommissioned* 0

Operation maintenance level 1 – Closed 12

Operation maintenance level 2 12

Operation maintenance level 3 14

Operation maintenance level 4 20

Operation maintenance level 5 20

Unauthorized roads 16

4x4 trail 6

Temporary roads 10

*Decommissioned is defined as a route in its natural (pre-road) condition.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

62

Vegetation

Assumptions and Limitations

Model Limitations

For the purpose of this project the analysis used a 40-year timeframe. Since common stand exam 

data was collected in various years, the common start year of 2015 was used for the existing 

condition. Forest Vegetation Simulator model simulated growth to the common start year for the 

437 data collection stands. A subset of these inventoried stands was randomly selected and 

modeled in Forest Vegetation Simulator for each alternative. Since wildlife habitat requirements 

for Mexican spotted owl and northern goshawk apply to all forest and woodland communities, the 

subset of inventoried stands were grouped by wildlife habitat and dominant cover type for the 

simulations. A total of 240 stands were modeled to obtain vegetation trends in growth for each 

alternative.

Modeling outputs are known to have some variation in their modeling processes, but this is 

normal for all modeling efforts. Limitations to modeling are as follows:

1) The effects of the alternatives are based on Forest Vegetation Simulator projections and are 

representative of average stand conditions. Since there are spatial limitations of Forest Vegetation 

Simulator, stand conditions on the ground may vary from the average stand conditions interpreted 

from the sample plot data. For example, outputs do not adequately display where openings within 

forest and woodland canopies occur.

2) Modeling is based upon a subset of stands inventoried for this analysis. The stand inventory 

although representative of the area did not collect data within every stand since resources are 

limited, but used data collection stands to represent other stands with similar characteristics.

Forest Vegetation Simulator and Fire and Fuels Extension model results and interpretations must 

be tempered with professional judgment for full analysis of effects. Professional judgement based 

on local experience has verified that model outputs are reasonable with values and indicators 

aligned with desired conditions. All numbers, acres, and percentages used throughout this 

document are strictly estimates, but provide a baseline to compare alternatives.

Analysis Assumptions

There are basic assumptions associated with modeling silvicultural prescriptions and stand 

growth. It is important to understand that parameters describing stand conditions and the 

underlying growth of stands are outcomes of an empirical growth model (Forest Vegetation 

Simulator). These outcomes are statistical in nature and are an attempt to represent future stand 

conditions over time. Outputs from the modeling represent an average of “what” might occur 

over time and interpretation should consider the modeling a tool in understanding ecological 

processes. The output data reflects silvicultural assumptions (model’s underlying equations) and 

the variability inherent in the input data (common stand exam inventory plots).

• Assumption 1: The collected inventory plot data (common stand exam) represent the 

current “average” stand conditions in the project area.

• Assumption 2: The Forest Vegetation Simulator model and the underlying equations of the 

chosen variant statistically represent future tree and stand growth and mortality. The 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

63

model’s output of stand conditions provides a statistically nonbiased representation of 

silvicultural activities and stand conditions over time.

• Assumption 3: The modeled outputs from Forest Vegetation Simulator should not be 

assumed to be exact for all stands where the outputs are applied due to limitations in data 

collection. The results are meant to be interpreted as general trends on the landscape. 

During implementation, site-specific stand-level prescriptions will be written for each stand 

and will be in compliance with authorized activities.

• Assumption 4: Forest Vegetation Simulator was used to model the first entry for treatments 

however, some stands may require subsequent entries to move towards or attain desired 

conditions. Anticipated effects are displayed 20 and 40 years post-harvest; however, it is 

plausible and likely that future planning efforts will overlap with the project area and could 

identify areas needing re-treatment to maintain or move towards desired conditions.

Data Limitations

Stand exam data collection was designed to capture representative conditions for the vegetation 

across the project area. Site-specific data was collected for this analysis in woodland and forest 

vegetation types. Stand Exam data was first collected in 2009 with 901 data collection plots 

within the planning area to determine conditions of the vegetation. In 2011, the Wallow Fire

burned with varying levels of severity on approximately 15,400 acres in New Mexico. Some of 

the stand exam data collected in 2009 within Wallow Fire area became invalid. In 2014 the 

project boundary was expanded in response to emphasis on all-lands restoration level planning in 

which the Gila National Forest responded by proposing ecological restoration treatment across a 

large landscape. Additional data was collected with 228 data collection plots to supplement data 

collected in 2009 and to verify changed vegetation conditions in the Wallow Fire area.

Plots followed the common stand exam protocol. Data collection occurred on approximately 

42,800 acres or 29.8 percent of the woodland and forested area throughout the planning area. For 

stands in which data was not collected, data from stands exhibiting similar characteristics based 

upon imagery from the National Agriculture Imagery Program in geographic information systems 

was used for analysis.

Environmental Consequences

The vegetation affected environment is described in chapter 1, “Existing and Desired Condition”

section.

Alternative A

Forest Cover Types

Forest cover type changes would occur over time as trees die through natural mortality and 

disturbance events from insect, disease, or wildfire. Tree growth, sprouting, regeneration of other 

species, and climatic variation may also cause a change in the forest cover type.

Under the no-action alternative, there would not be an increase in growing space and conditions 

would remain the same in the short term. In the long term, where existing density levels are 

currently high, competition-induced mortality would occur as densities continue to increase. 

Depending on the extent of the mortality, newly created growing space would either create 

openings large enough for new regeneration to establish or be quickly occupied by residual trees. 

Many of the forest cover types within the Luna project area will not persist at high densities for 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

64

long periods as they are generally affected by natural disturbance events such as insects, disease 

and wildfire.

Under the no-action alternative, the grassland cover type would experience a decline from the 

existing acreage by about 1 percent in 20 years as woody vegetation continues to regenerate into 

the grassland and meadow edges (table 31). The grassland would undergo little or no change over 

the remaining 40-year period due to the slow rate of regeneration and tree canopy closure. All 

other cover types would be within desired ranges over the 20- and 40-year periods. Ponderosa 

pine and piñon-juniper woodlands would experience a slight decrease. Oak woodland, southwest 

white pine and white fir cover types would experience a slight increase over the 20- and 40-year 

periods. There would also be a slight decrease in 20 years and overall increase in the 40-year 

period for the Douglas fir cover type.

Table 31. Forest cover type acres and percentage change in 20 and 40 years under alternative A,

no action

Forest Cover Type Acres

Percentage Change

in 20 years

Percentage Change

in 40 years

Grassland/Meadow 21,941 -1 -1

Douglas fir 6,323 -0.4 +0.2

Engelmann Spruce 109 0 0

Oak Woodland 1,414 +1.3 +1.7

Piñon-Juniper 41,713 -0.2 -0.1

Ponderosa pine 87,195 -0.4 -1.2

Riparian 784 Not applicable Not applicable

Southwestern White Pine 69 +0.4 +0.4

White Fir 6,887 +0.2 +0.2

Reforestation Area 3,954 Not applicable Not applicable

Rocky Area 942 Not applicable Not applicable

Total acres 171,3311 Not applicable Not applicable

1 Acreage does not include private land.

Stand Density Index

As density continues to increase, competition among trees would result in density-induced 

mortality. Health and vigor of the trees would also decline as density increases and stands 

approach maximum stand density index. Existing grasses, shrubs, and forbs would decline in 

vigor and growth and individual trees would begin to die creating small openings in the tree 

canopy as stands reach the threshold of density dependent mortality. Minimum forage would 

likely be produced under tree canopies without a large-scale disturbance and existing trees would 

quickly capture the newly available growing space.

Under the no-action alternative, in 20 years, approximately 70 percent of the Luna project area 

would reach full site occupancy in zones 3 and 4 (table 32). In 40 years, approximately 80 percent

of the landscape would reach full site occupancy in zones 3 and 4 (table 32). The percent of the 

landscape in zones 1 and 2 do not meet desired conditions over the 40-year period.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

65

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

no action

Zone

Maximum 

SDI 

(percent)

Percentage of 

Landscape

Existing

Percentage of 

Landscape in 

20-years

Percentage of 

Landscape in 

40-years

Percentage of 

Landscape

Desired

1 0–25 19 12 9 10–20

2 25–35 33 18 11 20–30

3 35–55 38 46 41 30–50

4 551–100 10 24 39 10–20

1 Zones 3 and 4 upper and lower ranges vary between 55 and 60 percent based on review of the existing research 55

percent was used as the respective upper and lower thresholds for zones 3 and 4 for the Luna analysis.

Vegetation Structural Stage

With the no-action alternative, the existing distribution of vegetation structural stages within the 

analysis area for ponderosa pine and woodland cover types would change as trees grow. Barring 

any natural disturbances, both stand density index (table 32) and canopy density (table 33 and

table 34) would continue to increase until site capacity is reached. Over a long period (more than 

40 years), vegetation structural stage 1 and canopy density class A percentages may increase 

slowly as older trees die and deteriorate leaving large openings for regeneration. Also, openings 

may come from mortality from tree competition at high densities, or from abiotic and or biotic 

causes such as insect or disease infections, wildfire, or other damaging agents.

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

from existing to 20 and 40 years compared to desired condition; where canopy density class A = 

open (0–39%), B = moderately closed (40–59%), and C = closed (60% +)

Canopy 

Density Class

Desired Condition

(percent)

Existing 

Condition

(percent)

Condition at

20 Years

(percent)

Condition at

40 Years

(percent)

A 40 36 31 25

B 40 51 43 27

C 20 12 25 48

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

from existing to 20 and 40 years compared to desired condition; where canopy density class A = 

open (0–39%), B = moderately closed (40–59%), and C = closed (60% +)

Canopy 

Density Class

Desired Condition

(percent)

Existing 

Condition 

(percent)

Condition at

20 Years

(percent)

Condition at

40 Years

(percent)

A 55 13 3 3

B 30 63 43 26

C 15 24 55 71

Based on modeling the no-action alternative, canopy density for ponderosa pine and woodland 

cover types would become less open (class A) over 20 and 40 years (table 33 and table 34). Over 

the 40-year period, open and moderately closed classes will drop below desired conditions, with 

the open category displaying the greater departure. Canopy density for both cover types would 

greatly exceed desired conditions for the closed class (class C) over the 40 years (table 33 and 

table 34), following the trend of the stand density index (table 32).
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

66

Within the Luna planning area, the model for vegetation structural stages shows changes in 

percent acres in all diameter classes of ponderosa pine cover type from existing through 20 and 

40 years (table 35). In year 20, diameter classes 1 and 5 for ponderosa pine decline and are 

deficient when compared to desired conditions, unlike vegetation structural stage diameter classes

2, 3, and 4, which are in surplus (table 35). In 40 years, vegetation structural stage classes 1 and 2

are both deficit compared desired conditions. As trees grow over the 20 to 40 years, the percent 

acres in vegetation structural stage classes 3, 4, and 5 increase, exceeding desired conditions. 

Vegetation structural stage 6 percent acres does not change over the 40-year modeling period.

Table 35. Vegetation structural stages by percentage of area for ponderosa pine cover type for 

existing, 20-year and 40-year conditions compared to desired conditions under alternative A, no 

action

Vegetation Structural 

Stage (VSS)

(diameter class

in inches)

Desired 

Condition

(percent acres)

Existing 

Condition

(percent acres)

Condition at

20 Years

(percent acres)

Condition at

40 Years

(percent acres)

VSS 1 (0.0–0.9) 10 22 <1 0

VSS 2 (1.0–4.9) 10 <1 20 <1

VSS 3 (5.0–11.9) 20 30 26 30

VSS 4 (12.0–17.9) 20 25 38 34

VSS 5 (18.0–23.9) 20 16 7 27

VSS 6 (24 +) 20 8 8 8

The existing condition of uneven-aged stand structure for both ponderosa pine and woodland 

cover types are deficit, 46 percent and 40 percent respectively, compared to desired conditions 

(90 percent and 100 percent). Over the 20 and 40-year period, the percent for each increase from 

the existing condition, 53 percent and 43 percent, respectively, at year 40. It is only a small 

increase and still far below desired conditions of 90 percent and 100 percent.

Old Growth Stand Structural Attributes

Under the no-action alternative, the percentage of area simultaneously meeting the minimum old 

growth stance structural attributes (excluding down dead trees, which is unknown) would begin to 

move toward the desired condition during the 40-year period (provided a large-scale disturbance 

such as wildfire does not occur). Under this alternative, all minimum old growth variables would 

be simultaneously met in 20 years in 15 percent of the interior ponderosa pine group, 12 percent 

of the mixed-species group, and 96 percent of the woodland species group (table 36). Compared 

to the existing condition the percentage of the ponderosa pine group simultaneously meeting old 

growth conditions remains would remain unchanged, decreasing slightly for the mixed-species 

group by 7 percent and increasing for the woodland species group by 8 percent (table 36).

In 40 years, all minimum old growth variables would be simultaneously met over 31 percent of 

the interior ponderosa pine group, 12 percent of the mixed-species group, and 95 percent of the 

woodland species group. The degree to which the old growth groups meet various stand structural 

attributes fluctuates throughout the 40-year period, and tends to increase for all attributes except 

for meeting the standing dead tree requirements for a give old growth group. Although the 

minimum variable of down dead is unknown for the various groups, given the amount of standing 

dead in the area it is concluded that this variable would be met as the other variables are 

simultaneously met. There would be a high risk of loss of dead and down material, dead standing 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

67

material, and live vegetation through wildfire occurrence due to the increasing tree densities over 

time.

Overall, table 36 shows the trend for old growth under the no-action alternative from existing to 

20 and 40 years, with no treatments and no disturbances. All stands are moving towards desired 

conditions over the 40-year period, with the exception being the mixed species group. Model 

outputs suggest the degree to which the old growth groups meet various stand structural 

attributes, fluctuates throughout the 40-year period, and tends to increase for all attributes except 

for meeting the standing dead tree requirements.

Table 36. Percentage of designated 20% (identified) old growth area meeting minimum criteria of 

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

Old Growth 

Group

Minimum Criteria of Structural 

Attributes1

Percentage of 

Identified Old 

Growth Area –

Existing 

Condition

Percentage

of Identified 

Old Growth 

Area –

20 years

Percentage

of Identified 

Old Growth 

Area –

40 years

Ponderosa pine 20 live trees in main canopy at 

least 14 inches in diameter at 

breast height (DBH)

68 91 98

Ponderosa pine 1 standing dead tree per acre at 

least 14 inches in diameter at 

breast height and at least 15 feet

46 36 61

Ponderosa pine 70 to 90 square feet per acre total 

basal area

98 99 100

Ponderosa pine 40 to 50% total canopy cover 34 48 70

Ponderosa pine Percent area simultaneously 

meeting all attributes2

12 15 31

Mixed-species 12 to 16 live trees in main canopy 

at least 18 inches in diameter at 

breast height

45 59 75

Mixed-species 2.5 standing dead tree per acre at 

least 14 inches in diameter at 

breast height and at least 20 feet

85 40 19

Mixed-species 80 to 100 square feet per acre 

total basal area

100 100 100

Mixed-species 50 to 60% total canopy cover 43 51 64

Mixed-species Percent area simultaneously 

meeting all attributes2

19 12 12

Woodland 12 to 30 live trees in main canopy 

at least 9 inches in diameter at 

root crown

99 100 100

Woodland 1 standing dead tree per acre at 

least 9 inches in diameter at root 

crown and at least 8 feet

88 99 96

Woodland 6 to 24 square feet per acre total 

basal area

100 100 100

Woodland 20 to 35% total canopy cover 97 97 99

Woodland Percent area simultaneously 

meeting all attributes2

87 96 95

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

2 Age and down dead trees are unknown for the group.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

68

Effects Common to Alternatives B, C, and D

Forest Cover Types

As in the no-action alternative, changes in tree growth, sprouting, regeneration of other species, 

and climatic variation may cause a change in the forest cover type acreage within the Luna 

project area. Under all action alternatives, there would not be a decline in the grassland cover 

type, at 20 years, as woody vegetation is cut and burned through grassland maintenance 

treatment. Restoration of the grasslands currently regenerating into piñon pine-juniper woodlands 

and ponderosa pine forests would increase the grassland component in the Luna project area by 1

percent in the first 20 years. Continued grassland maintenance would retain the 1 percent increase 

in the grassland cover type forty years post-harvest (table 37).

The majority of the species would fall within the desired percent range for management over the 

40-year period (table 37). There would be slight increases for several of the mixed-species cover 

types including Douglas-fir, white fir and southwest white pine for both the 20- and 40-year 

periods. These cover types fall within Mexican spotted owl recovery habitat in the Luna project 

area where it is desirable to have a variety of species present. Piñon-juniper and oak woodlands 

would also increase in the 20-year period by approximately 0.9 and 0.8 percent, respectively. This 

increase would be sustained through the 40-year period. The ponderosa pine cover type would 

sustain the largest decline in cover type decreasing by 4 percent at 20 years, and 6.2 percent at 40 

years. This is slightly outside of the desired range for management at 40 years post-harvest.

Table 37. Percentage change from existing forest cover type acres at 1 year, 20 years, and 40 years

post-harvest compared to range of desired percentage for alternatives B, C, and D

Forest Cover Type

Acres

(range of desired 

percentage change)

Percentage 

Change

1-Year

Post-Harvest

Percentage 

Change

20-Years

Post-Harvest

Percentage 

Change

40-Years

Post-Harvest

Grassland/Meadow 21,941 (+0-2%) +1% +1% +1%

Douglas fir 6,323 (+0-2%) +0.4 +0.2% +2.2%

Engelmann Spruce 109 (+0-2%) 0% 0% 0%

Oak Woodland 1,414 (+/-2%) +0.2% +0.9% +0.9%

Piñon-Juniper 41,713 (+/-5%) +1.6% +0.8% +0.8%

Ponderosa pine 87,195 (+/-5%) -3.9% -4.0% -6.2%

Riparian 784 (not applicable) Not applicable Not applicable Not applicable

Southwestern White Pine 69 (+0-2%) 0% +0.3% +0.3%

White Fir 6,887 (+0–2%) +0.7% +0.8% +0.9%

Reforestation Area 3,954 (not applicable) Not applicable Not applicable Not applicable

Rocky Area 942 (not applicable) Not applicable Not applicable Not applicable

Total acres 171,3311 Not applicable Not applicable Not applicable

1 Acreage does not include private lands.

Note: The summarization of results includes all stands as part of the modified proposed action alternative including no 

treatment stands and prescribed burn-only stands. Prescribed burn only stands were not directly modeled in Forest 

Vegetation Simulator and were modeled as no action stands.

Results were given 1 year post-harvest since mortality was not modeled for the prescribed burning modeled post-thinning 

treatments.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

69

The decrease in the ponderosa pine cover type is predicted through modeling, but actual 

prescriptions would be implemented to favor ponderosa pine in the ponderosa pine cover type and 

where ponderosa pine has transitioned to woodlands. There might be a slight decrease in the 

ponderosa cover type in some areas due to favoring of other species in Mexican spotted owl 

recovery habitat, transition from ponderosa pine to Douglas-fir in no-treatment areas, and also in 

removing encroaching conifers in grassland and meadow restoration treatments. Therefore, while 

model outputs and professional experience show a net overall reduction in the ponderosa pine 

cover type under various thinning regimes, the actual amount is largely dependent on the 

individual stand conditions pre-treatment and how the treatment is applied.

Forest stands would be treated, following principles described in the Rocky Mountain Research 

Station general technical report GTR-310 (Reynolds et al. 2013) where applicable. 

Implementation of principles provided in GTR-310, where appropriate, that restore the 

composition and structure of frequent-fire forests will result in a more open forest structure with a 

decreased potential for stand-replacing wildfire and epidemic outbreaks of insects and diseases 

(Fitzgerald 2005; Fulé et al. 2002, 2004; Graham et al. 2004; Roccaforte et al. 2008; Strom and 

Fulé 2007, as cited in Reynolds et al. 2013).

Stand Density Index

Under all action alternatives, 1 year post-harvest, zones 1 and 2 would be above the desired range 

(table 38), while 23 percent of the landscape in zones 3 and 4 would be at full site occupancy, but 

are below the desired range.

Modeling for changes in stand density over 20- and 40-year periods show a transitioning of the 

landscape from zone to zone over time (table 38). The model does not include the possibility of 

re-entry into areas for treatment activities. Within 20 years, all zones would be within or very 

close to desired percent of the landscape. Zone 1 would be in surplus by roughly 1 percent, and 

zone 2 would be at the upper end of the desired range. In 40 years, the percent of the landscape at 

full site occupancy would increase to roughly 67 percent, with zone 3 still being with the desired 

range, but zone 4 would be 10 percent in surplus.

Table 38. Percentage of maximum stand density index (SDI) 1 year, 20 years, and 40 years postharvest for alternatives B, C, and D compared to desired percentage of the landscape

Zone

Maximum 

SDI 

(percent)

Desired 

Percentage of 

Landscape

Percentage of 

Landscape 

1 year

Post-Harvest

Percentage of 

Landscape 

20 years

Post-Harvest

Percentage of 

Landscape 

40 years

Post-Harvest

1 0–25 10–20 35 21 16

2 25–35 20–30 42 30 18

3 35–55 30–50 17 32 37

4 55–100 10–20 6 16 30

The decreases to the stand density indicator are in alignment with recommendations for the 

management of southwestern forests (Reynolds et al. 2013) because increased density levels 

create conditions for wildland fires or insects and disease outbreaks. Drought is also a significant 

stressor to vegetation communities in this area of the United States; the effects of drought are 

amplified by higher vegetation density levels, as the need for moisture is increased by greater 

numbers of plants.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

70

Thinning and creation of small group openings would reduce tree competition and release 

residual trees. The direct effects of thinning would be increased stand and landscape level 

resistance and resiliency to fire, insects, and disease. Additionally, decreased stand densities 

would maintain healthy forest conditions during drought cycles. These effects would be apparent 

immediately following thinning. The majority of the trees removed would be suppressed and 

intermediate trees with the co-dominant and dominant trees favored for retention. Although some 

thinning would occur in larger size classes, most thinning would occur in smaller size classes 

between 1 to 18 inches diameter at breast height. Some harvest areas under this alternative will be 

limited to less than or equal to 23.9 inches diameter at breast height. In designated Mexican 

spotted owl habitat stands, growth is expected to be slightly slower than the stands with no 

diameter limit. Stand density in pockets of larger trees would not be reduced.

Grassland maintenance or meadow restoration treatments would result in a decrease in tree 

density, which would allow for an increase in native grasses and forbs. There would also be an 

increase in grasses and forbs in forested areas as the canopy would be open allowing light and 

moisture to reach the forest floor. The restoration of grass-forb-shrub interspaces and resultant 

separation of tree canopies and increase in herbaceous plant cover will provide fuels to carry 

frequent surface fires. Restoration of the characteristic fire regimes should sustain forest 

composition, structure, processes, and functions (Reynolds et al. 2013).

The direct effects to vegetation from thinning and subsequent fuels treatments would be a 

reduction to the stand density indicator. Active management, through forest thinning, maintains 

healthy trees that are less susceptible to high levels of mortality. Individual or small groups of 

trees may die, but the forest would be retained. Forests managed with appropriate residual density 

are able to withstand the effects of fire (Agee and Skinner 2005).

Additionally, aside from the changes to the indicator measures for vegetation, fuels reduction 

work would create landscapes with residual fuel loadings closer to desired conditions. Subsequent 

prescribed burning treatments post-thinning would result in less surface, ladder, and canopy fuels. 

This would change the fuel content within the stands and across the landscape, which would 

affect future wildland fires. These stand and landscape level changes in the thinned stands will 

result in a discontinuous canopy and decreased crown bulk densities. Research has shown that 

this along with a reduction in surface fuels and increase in canopy base height from prescribed 

fire will help create fire resilient landscapes (Agee and Skinner 2005). Maintenance treatments 

including prescribed fire and mechanical treatments would be needed to maintain or move 

towards desired conditions.

Stands that will be left untreated with this alternative will continue to get denser and decrease in 

vigor and health. Grass and forb growth will continue to decline. No openings would be created 

for seedling regeneration. Growth of trees into the larger size class will be slower than the treated 

stands.

Vegetation Structural Stage

The action alternatives would result in more uneven-aged ponderosa pine and woodland stands 

through thinning, burning, and group selection silvicultural treatments. Thinning and prescribed 

burning stands would reduce competition and release trees to grow at faster rates, than stands that 

are left untreated. Increases in vegetation structural stage class from one structural stage to the 

next would occur at a slightly more rapid rate than with the no-action alternative. Creating small 

openings (regeneration groups up to 4 acres in size outside northern goshawk post-fledging 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

71

family areas and up to 2 acres in size within northern goshawk post-fledging family areas) by tree 

cutting and removal and burning would provide an opportunity for regeneration of small clumps 

of trees and increase the percentage of the landscape in vegetation structural stage 1. Treatments 

would be designed to promote structural heterogeneity, leaving a mosaic of groups of trees 

providing areas of higher basal areas and canopy cover, in addition to scattered individual trees

and openings.

One year post-harvest, canopy density within the ponderosa pine cover type would be more open 

(67 percent in class A) (table 39). Over time, canopy density would progress towards moderately 

closed and closed classes (table 39). Based on modeling, the ponderosa pine canopy density 

would near desired conditions over 40 years.

For the woodland cover type, the open (class A) and closed (class C) canopy density classes are 

deficit from desired conditions (table 40). Moderately closed density class (class B) is the 

condition over majority of the area. Over 20 to 40 years post-harvest would progress towards 

more percentage area of closed canopy density (class C), but would not near desired conditions 

(table 40).

Table 39. Ponderosa pine percentage of area by canopy density class under alternatives B, C, and D;

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

open (0–39%); B = moderately closed (40–59%); and C = closed (60% +)

Canopy 

Density Class

Desired Condition

(percent)

Condition at

1-year

Post-Harvest

(percent)

Condition at

20-Years

Post-Harvest

(percent)

Condition at

40-Years

Post-Harvest

(percent)

A 40 67 51 43

B 40 31 45 45

C 20 1 4 11

Table 40. Woodlands percentage of area by canopy density class under alternatives B, C, and D; 1, 

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

(0–39%); B = moderately closed (40–59%); and C = closed (60% +)

Canopy 

Density Class

Desired Condition

(percent)

Condition at

1-year

Post-Harvest

(percent)

Condition at

20-Years

Post-Harvest

(percent)

Condition at

40-Years

Post-Harvest

(percent)

A 55 2 3 2

B 30 93 70 50

C 15 5 27 47

Structural stages for ponderosa cover type for 1 year, 20 years, and 40 years post-harvest are 

shown in table 41. In year one post-harvest, vegetation structural stages 1 and 5 are surplus of 

desired conditions. Immediately post-treatment, there would be an increase in vegetation 

structural stage 1 from established openings. Over time, this acreage would progress to vegetation 

structural stages 2 through 6. Prescribed burning in the surplus categories in vegetation structural 

stages 4 and 5 would reduce the amount of smaller trees and enhance the growth and vigor of 

residual trees promoting their ascendancy into larger size classes over time. This would facilitate 

stand structural development while also enhancing stand health and vigor through reducing tree 

density. Stand would become more resilient to disturbances, like insect and diseases. Post-harvest,
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

72

there would be an increase in the percentage of acres in uneven-aged structure for ponderosa pine 

from 46 percent to 64 percent and only a slight increase for woodland 40 percent to 41 percent.

Table 41. Vegetation structural stages by percentage of area for ponderosa pine cover type for 1-

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

desired conditions

Vegetation Structural 

Stage (VSS)

(diameter class in 

inches)

Desired 

Condition

(percent acres)

Condition at

1 Year

Post-Harvest

(percent acres)

Condition at

20 Years

Post-Harvest

(percent acres)

Condition at

40 Years

Post-Harvest

(percent acres)

VSS 1 (0.0–0.9) 10 34 10 3

VSS 2 (1.0–4.9) 10 <1 23 4

VSS 3 (5.0–11.9) 20 21 14 34

VSS 4 (12.0–17.9) 20 19 27 21

VSS 5 (18.0–23.9) 20 24 20 26

VSS 6 (24 +) 20 1 6 12

In 20 years post treatment, vegetation structural stages 1 and 5 would meet the desired condition, 

and classes 2 and 4 would be surplus of desired conditions. Vegetation structural stages 3 and 6 

would be below desired conditions (table 41). For uneven and even aged stand structure, the 

ponderosa pine and woodland cover type remain relatively the same as 1 year post treatment, 67

percent and 40 percent respectively.

In 40 years post treatment, vegetation structural stages 1, 2 and 6 would be deficit; vegetation 

structural stages 3 and 5 would be surplus; and vegetation structural stage 4 would be almost at 

desired conditions (table 41). For uneven-aged structure, ponderosa pine remains unchanged from 

20 years at 67 percent and the woodland group would increase slightly to 44 percent.

Over the 40-year period, the landscape supports a forest composed of uneven aged stands with 

larger diameter trees. However, the amount of forest openings are reduced.

Old Growth Stand Structural Attributes

Under the action alternatives, the percentage of area simultaneously meeting the minimum old 

growth variables (excluding down dead trees, which is unknown) would begin to move toward 

the desired condition during the 40-year period (providing a stand-replacing disturbance does not

occur).

After the one year post treatment (table 42) there would be a slight decrease in stand densities and 

for some of the other structural attributes in comparison to the no-action alternative (table 36). 

However, the percentage of groups meeting all minimum old growth minimum criteria changed 

from none to the most 2 percent from no-action alternative.

In 20 and 40 years post treatment under the action alternatives, all minimum old growth variables 

would trend towards desired conditions for all vegetation groups. However, the mixed-species 

group stays relatively static. Individual structural attributes would increase for all old growth 

variables to varying degrees. Although the minimum variable of down and dead trees is unknown 

for the interior ponderosa pine group, the mixed-species group, and the woodland species group, 

given the amount of standing dead in the area it is concluded that this variable would also be met 

as the other variables are simultaneously met.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

73

Although the area would be managed with low to moderate average basal areas across the 

landscape, project design would provide high basal areas and tree canopy cover retaining clumps 

of dense trees throughout the area. Openings would also be enhanced where feasible and would 

lower the average basal area and provide a reduction of fuels to reduce potential damage to old 

growth components in the event of a wildfire. There would be a low to moderate risk of loss of 

dead and down material, dead standing material, and live vegetation in treated areas through 

wildfire occurrence due to the low to moderate average tree densities.

Table 42. Percentage of designated 20% (identified) old growth area meeting minimum criteria of 

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

Old Growth 

Group

Minimum Criteria of Structural 

Attributes1

Percentage

of Identified 

Old Growth 

Area –

1 year

post-harvest

Percentage

of Identified 

Old Growth 

Area –

20 years

post-harvest

Percentage

of Identified 

Old Growth 

Area –

40 years

post-harvest

Ponderosa 

pine 

20 live trees in main canopy at 

least 14 inches in diameter at 

breast height (DBH)

68 89 95

Ponderosa 

pine 

1 standing dead tree per acre at 

least 14 inches DBH and at least

15 feet

46 37 62

Ponderosa 

pine 

70 to 90 square feet per acre total 

basal area

95 95 96

Ponderosa 

pine 

40 to 50 percent total canopy cover 31 41 55

Ponderosa 

pine 

Percent area simultaneously 

meeting all attributes2

13 16 30

Mixed species 12 to 16 live trees in main canopy 

at least 18 inches DBH

46 59 75

Mixed species 2.5 standing dead tree per acre at 

least 14 inches DBH and at least

20 feet

45 48 55

Mixed species 80 to 100 square feet per acre total 

basal area

53 100 100

Mixed species 50 to 60 percent total canopy cover 22 52 64

Mixed species Percent area simultaneously 

meeting all attributes2

10 12 12

Woodland 12 to 30 live trees in main canopy 

at least 9 inches diameter at root 

crown (DRC)

99 100 100

Woodland 1 standing dead tree per acre at 

least 9 inches DRC and at least 8 

feet

88 95 97

Woodland 6 to 24 square feet per acre total 

basal area

100 100 100

Woodland 20 to 35 percent total canopy cover 97 93 99

Woodland Percent area simultaneously 

meeting all attributes2

87 89 96

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

2 Age and down dead trees are unknown for the group.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

74

Alternative C – Herbicide Utilization

All other effects are the same as alternative B and D.

Under this alternative, the direct effect to vegetation would be a reduced amount of shrub and 

woodland tree species. Reducing the presence of these species would have the indirect effect of 

creating growing space for grass and forb species in grasslands, and also for conifer seedlings in 

forested areas. The objective of this treatment would be to remove competing species in grassland 

restoration treatments and to create ideal conditions for grass and forb species to regenerate. 

Herbicides would also be applied to sprouting alligator juniper in forested areas, which would 

create growing space for conifer establishment and growth. By decreasing plant competition, the 

planted and naturally regenerated conifer species would have increased growth rates as they 

would have more available soil moisture, nutrients and sunlight.

Herbicide application would increase treatment effectiveness and help set back succession of 

competing shrub and juniper species, which should help, maintain grassland treatments for a 

longer period of time, and also help facilitate conifer establishment and growth in forested areas. 

Herbicide application would also be targeted within the wildland urban interface where sprouting 

of juniper post-thinning could create ladder fuels. In this case, herbicide treatment would help 

increase the effectiveness of fuel reduction treatments to meet fuels objectives, with treatments 

lasting longer than with tree cutting alone.

Cumulative Effects

The 185,586-acre Luna planning area is part of the larger Escudilla Landscape, a 279,470-acre 

landscape planning area that extends across both the Apache-Sitgreaves and Gila national forests. 

Twenty-five years was chosen as a benchmark for assessing cumulative effects as this allows 

adequate time for vegetation to respond to forest vegetation treatment activities such as timber 

harvest and pre-commercial thinning. There have been numerous vegetation management 

activities, including mechanical treatments and prescribed fire treatments, within the Luna 

Restoration Project area over the past 25 years.

Overall, the number of treatments has decreased in the last 25 years compared to the amount of 

treatments occurring in the 1980s. This decline can be partially attributed to reduction in 

commercial timber activities across the Gila National Forest and throughout the Southwestern 

Region. Timber harvest activities across the Gila have declined by over 50 percent, going from an 

average of 25,000 CCF (100 cubic feet) per year in the early 1980s, to a current average of 

10,000 CCF per year. This reduction in timber harvest has in turn reduced the number of roads 

constructed in support of these activities.

Current activities range from fuelwood collection, commercial thinning, salvage cutting, precommercial thinning for wildlife, watershed, vegetation and forest health improvement, overstory 

removal, and road closures. In recent years (2006 to current), timber sale activities have included 

the decommissioning of non-system roads following completion of harvest operations. Current 

and future planning projects also analyze the closure of non-system roads following completion 

of harvest activities. In addition, incorporation of best management practices and design features 

is required on all vegetation management projects. Best management practices address Gila 

National Forest staff responsibilities to implement the Clean Water Act, which is accomplished 

through implementation and monitoring of best management practices.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

75

On the adjacent Apache-Sitgreaves National Forest, there are 35,105 acres of vegetation 

improvement, thinning, and prescribed burning projects planned. A recent decision was signed for 

the 68,000-acre West Escudilla Restoration Project, which includes thinning trees and prescribed 

fire on the Alpine, and Springerville ranger districts along the New Mexico-Arizona state line. In 

addition, it is likely there is “Firewise” hazardous fuels reduction work occurring on private lands 

within and adjacent to the project area. This project would be important to the success of future 

fire suppression efforts and complements past treatments and those currently occurring or being 

proposed on adjacent federal, state, and private lands.

Cumulatively, the above activities in combination with prescribed fire would facilitate restoring 

and sustaining ecological processes in fire-dependent ecosystems and move vegetation and fuel 

conditions towards their historic fire regimes. Treatments would reduce density, creating more 

open forest conditions, with increased herbaceous, forb, and woody vegetation production. These 

treatments would also facilitate regeneration in openings and increase stand structural complexity 

and diversity at both the stand- and landscape-scale. Change in vegetation composition, stand 

density, and structure would help create more resilient ecosystems that are better suited to future 

disturbances. These combined treatments would complement the purpose and need goals for 

vegetation restoration and fire and fuels management by restoring departed vegetation 

communities, and reducing the impact of high-severity fire on private inholdings, communities, 

infrastructure, cultural resources, and livelihoods within the planning area. It should be noted 

there would be no effects to vegetation outside of the analysis area boundary as a result of this 

project.

Fire and Fuels

Assumptions and Limitations

Assumptions

A number of assumptions were made in this analysis and are listed below:

• Current forest plan and other management direction would continue in the future.

• No major disturbance, such as wildfire, blow down or insect epidemics would occur from 

the baseline year of 2016 until implementation is completed. This analysis discusses future 

risk and probable effects if a disturbance occurs; it is not a future projection of the 

occurrence.

• The project area is sufficient to analyze and discuss effects to fire and fuels.

♦ The low-intensity prescribed burning treatments were not modeled in this analysis as 

they are not within a delineated unit or stand boundary, and due to the uncertainty of 

the exact location of where the prescribed burns would occur and the size of burn units.

♦ Where appropriate, the vegetation characteristics (canopy base height, canopy cover, 

stand height, crown bulk density, and fuel model) were modified in treatment units to 

reflect the expected vegetation conditions after treatment.

♦ Acres of private land and lands of other ownership that lie within the Luna Restoration 

project area boundary were included in the discussion.

♦ Weather data was obtained for the past 20 years from Luna remote automated weather 

station. Spatial data including slope, elevation, aspect, crown height, canopy base 

height, canopy bulk density and fire behavior fuel models were utilized.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

76

Limitations of the Models

“It should be noted a model is a simplification or approximation of reality and hence will not 

reflect all of reality” (Stratton 2006). The use of models depends upon sample data, validity of the 

model itself, and assumptions made by the modeler. All three affect the results. The use of 

FlamMap 5 in this analysis is to generally characterize and display existing conditions and the 

nature and magnitude of treatment effects to inform decisions to be made. The modeling results 

are not to be taken as reality. Fire models are tools to help depict relative change in fire behavior 

and growth across the landscape. Although there are limitations to fire behavior modeling, the 

model outputs provide useful information for planning, assessing and prioritizing fuel treatments 

(Stratton 2004, 2006). While we have a good general understanding of the factors that govern fire 

behavior, the interactions among these factors and the way in which fire behaves on the landscape 

are highly complex. As a result, fire behavior and severity can be understood and predicted in 

general terms, but exact predictions are not possible. Different models have been developed that 

are widely used and useful to assist in managing fires and developing fuel treatment plans. 

However, there are key uncertainties in how the simplifying assumptions of models affect their 

accuracy and as well as uncertainties that result from difficulties of providing adequate input data 

to operate the models (Graham et al. 2004). Given the uncertainty of any modeling exercise, the 

results are best used to compare the relative effects of the alternatives, rather than as an indicator 

of absolute effects (Graham et al. 2004).

Affected Environment

Fire regime groups and acres of each for the Luna planning area is displayed in table 43. A fire 

regime is the pattern, frequency, and intensity of the wildfires that prevail in an area over long 

periods of time. A fire regime describes the spatial and temporal patterns and ecosystem impacts 

of fire on the landscape.

Fire regime data was acquired from LANDFIRE (2010) version 1.2.0 data2

. It is an interagency 

vegetation, fire, and fuels characteristics mapping program, sponsored by the Wildland Fire 

Leadership Council that provides nationally consistent and seamless geospatial data products for 

use in wildland fire analysis and modeling. LANDFIRE data is used as the basis for geospatial 

wildland fire modeling. It produces a comprehensive, consistent, scientifically credible suite of 

more than 20 geospatial layers for the United States. LANDFIRE was used to conduct this 

assessment of fire regime groups within the project area. Approximately 83 percent of the project 

area is classified as fire regime group I with a 0 to 35 years fire return interval and low to mixed 

fire severity. Approximately 2 percent of the project area is classified as fire regime group II with 

0 to 35 years fire frequency and replacement severity. Seven percent is classified as fire regime 

group III with a 35 to 200 years fire frequency and mixed to low severity. Almost eight percent of 

the project area is classified as fire regime group IV with a 35 to 200 year frequency and stand 

replacement severity, and less than one percent is classified as fire regime group V with 200+ 

year frequency and replacement to any type of severity.

 2 Fire regime groups used in the current LANDFIRE databases. These groups have been modified from earlier versions (Hardy et al. 

2001, Schmidt et al. 2002 ) to include low-severity fires in fire regime III and fires of any severity in fire regime V. Adapted from Fire 

Regime Condition Class Guidebook, Version 1.2.1 (Anon 2010 as cited in Somers et al. 2010).
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

77

Table 43. Summary of fire regime groups within the Luna planning area

Fire 

Regime 

Group Frequency Severity Severity Description

Acres of 

Project Area

Approximate 

percentage 

of Project 

Area

Group I 0 to 35 years Low/mixed Generally low-severity 

fires replacing less than 

25% of the dominant 

overstory vegetation; can 

include mixed-severity 

fires that replace up to 

75% of the overstory.

153,800 83

Group II 0 to 35 years Replacement High-severity fires 

replacing greater than 

75% of the dominant 

overstory vegetation.

3,592 2

Group III 35 to 200 

years

Mixed/low Generally mixed severity; 

can also include lowseverity fires.

12,890 7

Group IV 35 to 200 

years

Replacement High-severity fires 14,292 8

Group V 200+ years Replacement/

any severity

Generally replacementseverity; can include any 

severity type in this 

frequency range.

444 Less than 1

Condition classes are used to categorize how much key ecosystem components such as species 

composition, structural stage, and stocking level, have changed in an area due to changing fire 

regimes. One or more activities, such as fire exclusion, insects and disease, and past management 

activities, can cause a change in fire regimes (Schmidt et al. 2002).

LANDFIRE (2012) version 1.4.0, data was used for the vegetation departure assessment.

Vegetation condition class distribution in the project area is shown below in table 44. 

Approximately 38 percent of the project area is within vegetation condition class Ia and Ib and 

has a low departure from the reference condition. Approximately 18 percent is classified as 

vegetation condition class IIa and IIb and is moderately departed from the reference condition; 

and approximately 43 percent is classified as vegetation condition class IIIa and is highly 

departed from the reference condition.

Table 44. Vegetation condition class distribution in the Luna planning area

Vegetation Condition Class 

(VCC) Acres*

Approximate Percentage of 

Project Area

VCC Ia, Very Low 1,034 Less than 1

VCC, Ib Low 69,455 37

VCC IIa, Moderate-Low 20,408 11

VCC IIb, Moderate -High 12,835 7

VCC, IIIa, High 80,565 43

VCC IIIb, Very High 0 0

*Unburnable acres were not included; lands of other ownership within the Luna project area boundary 

are included.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

78

Environmental Consequences

Alternative A

There would be no changes in current management and forest plan would continue to be 

implemented. There would be no direct effect to fuels under this alternative and no reduction of 

potential fire behavior. There are no foreseeable vegetation projects or prescribed fire projects 

proposed within the next five years. The no-action alternative would not move the project area 

towards desired conditions, nor would it meet the purpose and need; to reduce the impacts of 

high-severity fire and to implement vegetative treatments to restore departed landscapes at risk of 

fire.

In the absence of human-caused or natural disturbance such as vegetation treatment activities and 

wildfire, there would be an increased accumulation of surface and ladder fuels from insect and 

disease activity, storm damage, and the progression of forest succession, growth and change. 

Structural changes in vegetation may lead to increase departure from historic fire regimes and 

ecosystem function. Vegetation condition class departure would be expected to continue away 

from the desired condition. The result would be increased surface and ladder fuels that affect 

flame length, surface fuel loading levels (tons per acre) that affect fire intensity and severity, as 

well as increased tree crown density that make crown fire initiation more likely. Denser crown 

spacing and ladder fuels may contribute to uncharacteristic wildfire events. Increased fuel loading 

levels would continue to pose a threat to adjacent private land and ecosystems as fire suppression 

becomes more difficult. It is likely the ability of firefighters to suppress wildland fire safely and 

effectively would become more difficult as fire behavior characteristics intensify. Once wildfire 

transitions to the tree crowns, direct suppression tactics are not effective. Wildfires burning under 

these conditions would have greater potential to become large and have adverse effects.

Modeling results suggest the majority of the planning area is at risk to crown fire (table 7, MAP 

1). In alternative A, the percent of the landscape susceptible to crown fire activity would increase 

over time.

Wildfires may impact private lands and other resources. Direct suppression tactics by firefighting 

forces may not be as effective in the project area under the no-action alternative. Tree mortality 

because of insect and disease activity and natural forest succession would continue into the future 

and would exacerbate the amount of standing and downed fuels in the project area.

Effects Common to Alternatives B, C, and D

Implementing Alternative B, C or D would result in a reduction in fuel loading and decrease fire 

behavior characteristics when compared to the existing condition. Treatments will help to 

maintain or shift areas towards the desired condition; reducing crown fire potential (table 45).

Crown fire potential refers to the conditions that allow fire to spread through the forest canopy. 

Modeling results suggest crown fire potential would be reduced to 16 percent of the project area

compared to 67 percent under alternative A. Also, model results show 84 percent of the project 

would transition to surface fire, as compared to 24 percent under the no-action alternative (table 

45).

Approximately 83 percent (153,800 acres) of the project area is classified as fire regime group I 

with a 0 to 35 years fire frequency (low to mixed fire severity) (table 43). With implementation of 

alternatives B, C, or D, approximately 116,000 acres classified in fire regime group 1 would be 

treated, moving towards restoring the natural and historical fire regime (table 45). Additionally 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

79

approximately 19,000 acres would be treated in areas classified as fire regime groups II through 

V. The project area would benefit from the proposed treatments with respect to ecosystem 

function, forest health, resiliency and reduction in potential fire behavior.

Table 45. Summary comparison of all alternatives for fire-related concerns in the Luna planning area

Concern Indicator/Measure Alt A Alt B,C,D

Reduce impact of highseverity firePercentage of modeled crown fire 

(passive and active)

67% 16%

Reduce impact of highseverity fire

Percentage of modeled surface fire 24% 84%

Restore departed landscapes 

that are at risk of fire

Approximate acres treated in fire regime 

group I

0 116,000

Implementation of low-severity prescribed fire in the Dry Blue and along the San Francisco

Divide is expected to result in mortality of smaller diameter understory trees, brush (ladder fuels), 

and consumption of dead and down fuels. Single tree torching, isolated group tree torching, or 

both may occur. After multiple entries, it is anticipated there would be open interspaces of various 

sizes, groups of trees with interlocking crown, multistoried canopies, and retention of largerdiameter over story trees. Overall, the treatments would move towards the ability to reintroduce 

fire into a fire-adapted ecosystem.

Mixed-severity prescribed burns are expected to create a mosaic of burned and unburned patches 

of vegetation. Prescribed burns would result in multistoried canopies, and early seral 

grass/forb/shrub openings.

It is expected mechanical and prescribed fire treatments would reduce surface, ladder and crown 

fuels and change the fuel model profile. Raising canopy base heights and reducing tree density in 

mechanical thinning units would reduce ladder fuels and potential for crown fire initiation.

According to Peterson et al. (2005) the most appropriate fuel treatment strategy is often thinning 

(removing ladder fuels and decreasing crown density) followed by prescribed fire, piling and 

burning fuels, and mechanical treatments. These treatments would increase protection from 

severe fires in the future.

Cutting trees for vegetation health and reduction of canopy closure would initially result in 

increased surface fire intensity and spread rate due to residual activity fuels contributing to 

existing surface fuel loadings. Treatments would begin to restore ecological processes, including 

the frequent low- to mixed-severity fire regimes. Proposed treatments are expected to reduce fire 

behavior potential and the risk of wildfire impacting adjacent private lands, natural resources, and 

infrastructure.

The resulting treatments would allow the increased use of wildfires to maintain this landscape. 

The risk of wildfire impacting private lands, natural resources, and infrastructure would be 

reduced; the landscape would become more resilient.

National Forest System land and adjacent private land would be positively affected from the 

reduction of hazardous fuels and subsequent modification of potential fire behavior.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

80

Forest Plan Amendment

Amending the forest plan to allow a one-time exceedance in the amount of activity fuels treated 

and prescribed burning implemented would beneficially benefit fire and fuels management. 

Allowing a greater amount of acres to be treated is correlated to a larger reduction in potential fire 

behavior across the project area, and acres treated to facilitate restoration towards desired 

conditions and historic fire regimes.

Cumulative Effects

The cumulative effects analysis area was determined to be the area within the project analysis 

boundary, because it is of sufficient size to manage vegetation, fire behavior and effects on a 

landscape level. Past, current, and future activities include such things as use and maintenance of

trails; developed and dispersed recreation; and administrative facilities, motorized vehicle use, all 

range management activities, rural and urban development, prescribe burning, fuelwood cutting, 

and mechanical vegetation management.

For analyzing cumulative impacts to fire and fuels management, only those activities including 

vegetation treatments and prescribed burning will be used in the analysis. Within the Luna 

planning area approximately 25,000 acres have received mechanical or burning treatments in the 

past 25 years. Over 6,000 acres has been treated in the last 12 years (table 46).

Table 46. Vegetation treatment acres, type, and implementation date in the last 12 years within the 

Luna planning area

Name Acres Type of Treatment Year(s) Treated

East Centerfire 

Prescribed Burn

5,420 Broadcast burn 2006, 2011, 2012

Wallow Site Preparation 181 Piles 2014

Tucson Electric Power 

Company Transmission 

Vegetation Project

192 Thinning 2014

Canovas Thinning 636 Thinning 2006

The Wallow Fire in 2011 burned approximately 15,000 acres within the Luna Restoration Project. 

In 2016, two wildfires totaling 2,394 acres burned within the planning area.

On the Apache-Sitgreaves National Forests, there are 35,105 acres of vegetation improvement, 

thinning, and prescribed burning projects planned. A recent decision was signed for the 68,000-

acre West Escudilla Restoration Project, which includes thinning trees and prescribed fire on the 

Alpine and Springerville ranger districts along the New Mexico-Arizona state line. In addition, 

hazardous fuels reduction work occurring on private lands within and adjacent to the project area.

Cumulatively, these activities result in reductions in fire behavior potential to a greater degree 

than described in the effects of the action alternatives. Activities discussed would cumulatively 

break up fuel continuity (surface, ladder, and crown fuels) across the landscape. These combined 

activities would greatly facilitate restoring and sustaining ecological processes in fire-dependent 

ecosystems and move vegetation and fuel conditions toward their historic frequent low- to mixedseverity fire regimes. These combined treatments would complement the purpose and need goals 

for fire and fuels management by reducing the impact of high-severity fire on private inholdings, 

communities, infrastructure, cultural resources and livelihoods within the planning area. It would 

also support the reintroduction of fire into fire-dependent ecosystems.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

81

Past wildland fire events and management activities have affected the landscape and would 

continue into the future. The existing condition was influenced by events including; wildfires, fire 

suppression, fire exclusion, insects and disease, prescribed burning and past timber management 

activities.

The effects of future wildland fires in the analysis area was not analyzed in detail because it is 

impossible to predict when and where a wildfire may occur in the future, or the subsequent 

effects of that fire.

Wildlife

Species assessed for this project include:

• federally listed endangered, threatened, or proposed (Forest Service Manual 2672.4), and 

designated critical habitat for these species

• Region 3 regional forester sensitive species (Forest Service Manual 2670.5)

• Gila National Forest management indicator species as listed in the Gila forest plan as 

amended (1986)

• migratory bird species that occur within the planning area.

Federally Listed Species

The U.S. Fish and Wildlife Service county list of endangered and threatened species were 

reviewed to determine the federally listed species that would need to be considered in this 

evaluation. Table 47 lists the threatened and endangered species and their critical habit, if 

applicable, that may be within the planning area. Consultation was formally initiated on June 4, 

2018, and amended on September 18, 2018 for the newly discovered New Mexico meadow 

jumping mouse.

The following species were analyzed and found to have no effect from the Luna Restoration 

Project: least tern (endangered), yellow-billed cuckoo (threatened, and designated critical 

habitat), Chiricahua leopard frog (threatened, and designated critical habitat), Gila trout 

(threatened), and Zuni fleabane (threatened). The no effect determinations were due to not being 

present in the project area.

Table 47. Summary of federally listed species (endangered, threatened, and experimental) within 

Catron County and within the Luna planning area

Scientific Name Common Name Status

Critical 

Habitat

Canis lupus baileyi Mexican gray wolf Endangered 

Experimental

Not 

applicable

Strix occidentalis lucida Mexican spotted owl Threatened Yes

Empidonax traillii extrimus Southwestern willow flycatcher Threatened Yes

Thamnophis rufipunctatus Narrow-headed gartersnake Threatened Proposed

Zapus hudsonius luteus New Mexico meadow jumping mouse Endangered Not 

applicable1

Tiaroga cobitis Loach minnow Threatened Yes

Meda fulgida Spikedace Threatened Yes

1

There is designated critical habitat for New Mexico meadow jumping mouse, but none is located within or adjacent to the 

planning area.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

82

Mexican Gray Wolf

The Mexican gray wolf is in the process of being reintroduced on the Gila National Forest in New 

Mexico and on the Apache-Sitgreaves National Forest in Arizona. These wolves have been 

designated as a nonessential experimental population, pursuant to section 10(j) of the Endangered 

Species Act as amended.

Re-introduced wolves have been located periodically in the planning area. Multiple wolf packs 

have used the area for denning and single wolves have been detected moving through the area. 

The planning area has suitable habitat for hunting and reproducing for the Mexican gray wolf. 

Key prey species, elk and deer, for the wolf are present in the planning area.

Environmental Consequences

Alternative A

Under alternative A, no project activities would be implemented; therefore, there would be no 

effect to the Mexican gray wolf in addition to the ones from currently permitted activities.

Effects Common to Alternatives B, C, and D

As defined in the Endangered Species Act section 10 (j) rule for the Mexican gray wolf, 

“disturbance causing land use activity” means any land use activity that the U.S. Fish and 

Wildlife Service determines could adversely affect reproductive success, natural behavior, or 

survival of Mexican gray wolves. The following activities are specifically excluded from this 

definition under the Endangered Species Act section 10 (j) rule for the Mexican gray wolf:

• legally permitted livestock grazing and use of water sources by livestock

• livestock trailing or drives (only if no reasonable alternative route exists)

• vehicle access over established roads to private property and to areas on public land where 

legally permitted (only if no reasonable alternative route exists)

• use of lands within the national park or national wildlife refuge systems as safety buffer 

zones for military activities

• prescribed fire and associated management actions (except in the vicinity of wolf release 

pens)

• any authorized, specific land use that was active and ongoing at the time wolves chose to 

locate a den or rendezvous site nearby

Project activities would not preclude occupancy of the area by the Mexican gray wolf. Human 

disturbance to the Mexican gray wolf as a result of the proposed activities at this time seems 

unlikely. However, there have been documented wolf dens in the project area. If wolves are found 

denning during implementations of projects, the Quemado Ranger District staff will coordinate 

with the Mexican gray wolf field team to minimize or eliminate adverse effects to denning 

activities.

The decommissioning of roads across the planning area will decrease habitat fragmentation for 

both the wolf and native ungulates. Implementation of the alternatives may indirectly affect 

wolves through disturbance to their primary prey base, native ungulates like elk and deer.

Activities may cause native ungulates to move temporarily to other locations or further from 

denning locations, therefore resulting in greater distances to forage.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

83

One of the goals of this project is to improve wildlife habitat conditions through improving 

browse components for wild ungulates. In the short term, while vegetation is responding to 

treatments, the change to native ungulates may be relatively undetectable. Compared to the 

potential long-term benefits to native ungulates and the wolf prey base.

Rationale for determination: Under all action alternatives, disturbance to potential denning sites 

are minimized through avoidance or other features developed in coordination with the field team 

in relation to the activity being implemented. There are beneficial effects to the species and its 

habitat through reduction of habitat fragmentation through road decommissioning and 

improvement of native ungulate (prey species) habitat. A determination of “not likely to 

jeopardize” is made for all action alternatives.

Mexican Spotted Owl

The Luna Restoration Project is located in the Upper Gila Mountains Recovery Unit/Ecological 

Management Unit. Primary constituent elements of Mexican spotted owl critical habitat are high 

basal area (square footage of trunk) of large-diameter trees; moderate to high canopy closure; 

wide range of tree sizes (uneven-age stands); multilayered canopy with large overstory trees of 

various species; high snag basal area; high volumes of fallen trees and other debris; high plant 

species richness, including hardwoods; adequate levels of plant cover to maintain fruits, seeds, 

and regeneration to provide for the needs of Mexican spotted owl prey species within mixed 

conifer, pine-Gambel oak, and riparian forest types.

Currently, Mexican spotted owl habitat on the Gila National Forest is managed according to the 

direction in the Gila forest plan, which was amended by elements of the 1995 recovery plan for 

the Mexican spotted owl. With two exceptions, current forest plan direction will be followed. 

Mexican spotted owl habitat discussed in this report are analyzed using the current forest plan and 

two project-specific amendments to the forest plan from the 2012 Mexican spotted recovery plan. 

These two amendments will be as follows:

• 1995 Mexican spotted owl recovery plan precludes cutting conifers in the protected activity 

centers. This amendment will follow the 2012 Mexican spotted owl recovery plan and 

allow cutting conifers in protected activity centers, while leaving a 100-acre core area 

untreated in the protected activity center. A fire risk analysis was done showing the 

potential for high-intensity wildfire that could severely affect protected activity centers.

• 1995 Mexican spotted owl recovery plan, as incorporated and amended into the forest plan

allows for treating up to 10 percent of protected activity centers in a recovery unit. This 

amendment will follow the 2012 Mexican spotted owl recovery plan to allow for more 

treatments in protected activity centers.

Within the Luna Restoration Project boundaries, there are 64,293 acres of designated Mexican 

spotted owl critical habitat. Approximately 17,003 acres are within protected activity centers. 

Outside protected activity centers, 6,984 acres have been identified as protected habitat under the 

1995 recovery plan consisting of mixed conifer (4,725 acres of slopes greater than 40 percent) 

and ponderosa pine-Gambel oak (2,259 acres of slopes greater than 40 percent). There is 

approximately 21,816 acres of restricted habitat consisting of mixed conifer (3,018 acres), 

riparian (784 acres), and ponderosa pine-Gambel oak (18,014).

For the Mexican spotted owl, reducing risk of high-intensity wildfire and reintroducing a fire 

regime into the ecosystem to maintain fuel loadings at a low level is desirable. The desired future 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

84

conditions in areas identified as habitat for Mexican spotted owl include reduction of risk of highintensity wildfire while maintaining key habitat components.

Within the acres of protected activity centers, “prescribed burning only” treatment is proposed on 

approximately 8,399 acres and an additional 1,319 acres treated with a combination of prescribed 

burning, thinning, and associated slash treatments to reduce fire risk. Approximately 31 percent 

(1,489 acres) of mixed conifer protected (potential recovery) habitat and 19 percent (428 acres) of 

ponderosa pine-Gambel oak protected habitat would be managed toward threshold habitat 

conditions within the Luna Restoration Project area. Twenty-nine percent (1,212 acres) of mixed 

conifer restricted (potential recovery) habitat, and 5 percent (1,033 acres) of ponderosa-Gambel 

oak restricted (potential recovery) habitat will be designated to be managed toward threshold 

habitat conditions.

Outside protected activity centers, of the 25,058 acres of restricted (potential recovery) habitat 

associated with the project, 923 acres have prescribed burning proposed. Within the restricted or 

recovery habitat associated with the Luna Restoration Project area, treatment of these areas will 

be managed to promote the primary constituent elements for nesting, roosting, foraging, and 

dispersing. The remaining 24,135 acres of Mexican spotted owl restricted or recovery habitat will 

be managed according to the Mexican spotted owl recovery plan recommendations that call for 

management of the landscape to maintain and create replacement owl habitat, while providing a 

diversity of stand conditions and stand sizes across the landscape.

Other activities associated with the Luna Restoration Project in Mexican spotted owl protected 

activity centers include 6.2 miles of road decommissioning, 0.9 mile of fence construction, 1.2 

miles of pipeline, 0.1 mile of a trail reroute (with culvert) to eliminate 2 stream crossings, and 1 

well with storage and drinkers. In Mexican spotted owl designated critical habitat, other activities 

would include 47.2 miles of road decommissioning, 2.0 miles of temporary roads for thinning 

activity access, 4.5 miles of pipeline, 1.1 miles of fence, 0.1 mile of a trail reroute (with culvert) 

to eliminate 2 stream crossings, 5 wells with storage and drinkers, hardening of 2 stream 

crossings, 1 French drain sediment structure, and 1 trail barrier to prevent motorized use.

Environmental Consequences

Alternative A

Taking no action would have no effect to Mexican spotted owls in addition to the ones from 

currently permitted activities, but the habitat would continue to be at risk of being impacted by 

wildfires.

Effects Common to Alternatives B, C, and D

All activities in Mexican spotted owl protected activity centers will be performed outside of the 

breeding season (March 1 to August 31). If activities need to be done during the breeding season, 

survey protocols would be implemented to determine if there are owls present or are not breeding 

before work is allowed to proceed. All activities in Mexican spotted owl habitat are subject to the 

forest plan amendment in regards to not treating more than 25 percent of a 6th-code watershed in a 

3-year period, which may be adjusted as monitoring dictates.

Mechanical and hand thinning are proposed in Mexican spotted owl habitat. Thinning trees less 

than 9 inches in diameter at breast height would reduce basal area in protected activity centers, 

which in turn would reduce thermal properties. Thinning trees less than 9-inches in protected 

activity centers would allow the remaining trees to grow at a more rapid pace, increasing the 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

85

percentage of basal area in the larger trees. Thinning in designated restricted or recovery habitat, 

the threshold would be managed to obtain levels of 150 basal area in ponderosa pine-Gambel oak, 

and 150 to 170 basal area in mixed conifer. Proposed treatments in protected and restricted 

habitats would help restore the forest to a fire-adapted ecosystem, lessening the probability of a 

damaging wildfire. The treatments in protected and restricted habitats would leave appropriate 

percentages for meeting primary constituent elements in the future. Thinning would allow 

herbaceous plants to establish, providing a food source for prey species. Human activity and noise 

associated with chainsaws or other mechanized equipment could disturb nesting owls. Performing 

these actions outside the breeding season will prevent disturbing nesting owls. The potential for 

vehicles to collide with owls has a very low possibility. This would be minimized due to 

motorized activity would be occurring during daylight hours when owls are less likely foraging.

Prescribed fire in Mexican spotted owl protected activity centers and designated critical habitat is

proposed to be low intensity. This low intensity would remove excess fuels from the forest floor, 

raising the low-live limb on remaining trees, thus reducing the threat of devastating wildfire to 

Mexican spotted owl habitat. Some snags might burn up during implementation, while others 

may be created to take their place. Removing some of the fuels from the forest floor, would allow 

herbaceous plants to establish, providing additional food sources for prey species. Smoke from 

prescribed burning might cause owls to leave the nest, possibly putting nestlings at risk. Human 

activity and noise associated with chainsaws or other mechanized equipment could disturb 

nesting owls. Implementing these actions outside the breeding season will prevent disturbances to 

the owls.

Long-term effects would include a reduction of fuel loading which would lessen wildfire 

intensities, and thinning and prescribed fire would allow for healthier habitat.

For all other proposed treatments, noise and human presence may disturb individual owls, 

movement of prey species, or modify habitat components for either the owl or their prey species 

within critical habitat. Activities such as maintenance of sediment control features, road 

decommissioning, stream and riparian projects within critical habitat would improve and restore 

habitat conditions and improve watershed conditions. These activities would cause short-term 

impacts, but there would be long-term benefits to habitat for both Mexican spotted owl and its 

prey species as areas stabilize and recover.

Alternative C – Herbicide Utilization

Herbicide treatments are proposed on approximately 1,270 acres of designated critical habitat for 

the Mexican spotted owl in conjunction with thinning of juniper. Treating juniper with herbicide 

would reduce competition with ponderosa pine and mixed conifer species, which in turn would 

allow for more rapid growth. Reducing juniper would reduce feed for prey species. The 

Environmental Protection Agency states, “When used properly, pesticides can play a valuable role 

in controlling weeds, insects, and other pests. On the other hand, they can harm wildlife if the 

user does not follow label directions.” (Environmental Protection Agency 2018). Herbicide 

manufacturers produce label processes on application to prevent effects to general wildlife.

Manufacturer labels will be followed to prevent effects to Mexican spotted owls and their prey. 

Human activity and noise associated with mechanized equipment could disturb nesting owls. 

Performing these actions outside of the breeding season will prevent disturbance to nesting owls.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

86

Cumulative Effect:

Short-term cumulative impacts are anticipated to come from reduced basal area in protected 

activity centers and a reduction in snags, with ongoing activities coupled with proposed projects. 

Projects that will decrease basal area short term include thinning conifers (less than 9 inches 

diameter) in protected activity centers and prescribed fire. Prescribed fire would also reduce 

snags. Over time, the cumulative impacts from lowered basal area and fewer snags would 

improve. This improvement would occur because the implementation of these projects are 

projected to accelerate growth in remaining trees, and prescribed fire would create new snags.

Rationale for determination: Thinning and burning activities associated with the Luna 

Restoration Project will reduce basal area in protected activity centers during the short term (but 

not drop below threshold values) and will adjust the structure and thermal characteristics. 

Reducing fuel loading in designated critical habitat could impact prey species in the short term. 

Reducing juniper could reduce food sources for prey species. Performing actions outside the 

breeding season or after confirming non-breeding status will prevent disturbing nesting owls. 

Core areas of 100 acres have been identified, and will not receive mechanical treatment and will 

not have prescribed fires ignited within them. Modeling has shown thinning treatments in 

protected activity centers would increase the growth in larger-diameter trees, which in turn would 

increase the basal area in the larger size classes over the long term.

The Luna Restoration Project would reduce habitat needs in protected activity centers in the short 

term, but improve conditions in the long term; therefore, the Luna Restoration Project may affect, 

likely to adversely affect the Mexican spotted owl.

Treatments in designated critical habitat would align with the forest plan, which complements the 

1995 Mexican spotted owl recovery plan; therefore, the Luna Restoration Project may affect, 

likely to adversely affect the designated critical habitat for the Mexican spotted owl.

Southwestern Willow Flycatcher

The southwestern willow flycatcher is federally listed and a migratory bird species.

Environmental Consequences

Alternatives A, B, C, and D

There will be no effect to the species due to southwestern willow flycatchers not being observed 

within the project area for the last 10 years. Also, the designated critical habitat within the 

planning area does not contain the primary constituent elements to support the birds.

Designated Critical Habitat

There are 208 acres of designated southwestern willow flycatcher critical habitat within the 

planning area, located along the San Francisco River. The designated critical habitat does not 

contain the primary constituent elements to support southwestern willow flycatchers. Willow 

species are in small quantities and not densely grouped. Tree canopy does not fall within the 

density range of 50 percent to 100 percent. Also, the area does not have open water or marsh 

openings meeting the one-quarter-acre minimum size.

Alternative A

There will be no effect to southwestern willow flycatcher critical habitat, in addition to the ones 

from currently permitted activities, due to no activities being implemented under this alternative.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

87

Effects Common to Alternatives B, C, and D

No impacts would occur to critical habitat with the implementation of vegetation and prescribed 

burning treatments and herbicide utilization under alternative C. By applying the design feature of 

buffering the critical habitat from project implementation activities, no treatments would occur 

within critical habitat. Therefore no changes to the habitat constituents or vegetation would be 

altered.

The following activities would occur within critical habitat: construction of new road crossing in 

Head of Ditch campground, applying rock to roads within Head of Ditch campground, irrigation 

ditch diversion construction, road decommissioning, and stream restoration activities within San 

Francisco River and Stone Creek.

The irrigation ditch construction and campground new road stream crossing would remove 

riparian vegetation during implementation altering the vegetative components in the critical 

habitat at those specific locations. Those areas would be permanently void of vegetation. The 

placement of a permanent diversion structure compared to the multiple disturbances to the stream 

channel from maintenance of the earthen diversion berm; provides an opportunity for the banks to 

stabilize and over the long term allow recruitment and establishment of vegetation.

Approximately 0.2 mile of road that runs along and crosses the San Francisco River would be 

decommissioned under the action alternatives. Road decommissioning and other stream 

restoration activities within critical habitat would cause short-term disturbances but in the long 

term would have improved stream habitat components and an increase in riparian through 

planting and natural recruitment.

The removal of riparian vegetation and short-term disturbances from other stream restoration 

activities and decommissioning within designated critical habitat would be insignificant and 

discountable. These sites are small and localized but have the potential to provide long-term 

benefits, although the benefits would not greatly improve or change the primary constituent

elements of the critical habitat. Project activities may affect, likely adversely affect the designated 

critical habitat.

Narrow-Headed Gartersnake

The narrow-headed gartersnake is federally listed as a threatened species. Critical habitat for the 

narrow-headed gartersnake is proposed. There are approximately 2,781 acres of proposed critical 

habitat in the Luna planning area located on the San Francisco River and Dry Blue Creek.

Surveys for narrow-headed gartersnake were conducted at the Head of the Ditch campground 

along the San Francisco River (July 25–28, 2016). None of these species were caught or observed 

during the survey. Also, very few prey fish were caught. During the surveys, other terrestrial and 

checkered gartersnakes were found.

Environmental Consequences

Alternative A

There will be no effect to the narrow-headed gartersnake and its proposed critical habitat, in 

addition to the ones from currently permitted activities, due to no activities being implemented 

under this alternative.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

88

Effects Common to Alternatives B, C, and D

The risk of impacts would be minimized to the narrow-headed gartersnake and its proposed 

critical habitat with the implementation of vegetation and prescribed burning treatments and 

herbicide utilization under alternative C. By applying the design feature of buffering the proposed 

critical habitat from project implementation activities, no treatments would occur within proposed 

critical habitat, therefore no disturbance to the stream or shoreline habitat would be altered.

The following activities would occur within proposed critical habitat: construction of new road 

crossing in Head of Ditch campground, applying rock to roads within Head of Ditch campground, 

irrigation ditch diversion construction, road decommissioning, hardening of motorized trail 

crossings in Dry Blue Creek, and variety of stream restoration activities within San Francisco 

River and Dry Blue Creek.

During the implementation of these activities, the potential risk to gartersnakes is being harassed 

by human presence and various machinery sounds or vibrations or crushed between rocks as 

material is moved or run over by vehicles. Implementation could generate fine sediment 

impacting proposed critical habitat and also prey species habitat. This is expected to be a shortterm impact.

The placement of the irrigation ditch diversion would continue to alter natural flows during 

periods of irrigation water usage, but reduces fine sediment input and habitat disturbances that 

result from the multiple entries to maintain the earthen diversion berm. Some fine sediment 

would still be produced during periodic clean out of the sediment trap but to a lesser degree than 

previous activities.

The irrigation ditch construction and the new road-stream crossing in the campground would 

remove riparian vegetation during implementation, altering the vegetative components along the 

shoreline of the proposed critical habitat at those specific locations. Those areas would be 

permanently void of vegetation.

Approximately 0.2 mile of road that runs along and crosses the San Francisco River would be 

decommissioned under the action alternatives. Road decommissioning and other stream 

restoration activities within proposed critical habitat would cause short-term disturbances but in 

the long term would have improved stream habitat components and an increase in riparian 

through planting and natural recruitment.

The removal of riparian vegetation and short-term disturbances from other stream restoration 

activities and decommissioning within proposed critical habitat would be insignificant and 

discountable. These sites are small and localized, but have the potential to provide long-term 

benefits. Surveying for the two gartersnake species prior to implementation and applying buffer 

around habitat will reduce the risk of disturbance and harm. Project activities may affect, not 

likely adversely affect the narrow-headed gartersnake and may affect, likely to adversely affect its 

proposed critical habitat.

Spikedace

Spikedace is federally listed as a threatened species. Critical habitat has been designated and 

designation included both spikedace and loachminnow.

The Luna Restoration Project will have no effect to spikedace under alternative A. Spikedace 

have not been found occupying streams within the planning area and closest they have been 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

89

detected is 16 miles downstream in the Blue River. Effects to spikedace and its designated critical 

habitat will be discussed with loachminnow.

Loachminnow

Loachminnow is federally listed as a threatened species. Critical habitat has been designated and 

designation included both spikedace and loachminnow.

Loachminnow have been found within Dry Blue Creek but have not been found in the since the 

Wallow Fire in 2011. It is thought that after the fire, ash, debris, and sediment entering the system 

impacted the fish and its habitat (personal communication: Dustin Myers, fish biologist and Jerry 

Monzingo, wildlife program manager, Gila National Forest). Loachminnow are located 

approximately 2 miles downstream of the planning boundary on the San Francisco River.

Environmental Consequences

Alternative A

Under the no-action alternative, there would no effect from project activities to loachminnow or 

to designated critical habitat for spikedace and loachminnow, in addition to the ones from

currently permitted activities. The risk of the loachminnow and the designated critical habitat 

being impacted by wildfires would continue.

Effects Common to Alternatives B, C, and D

On the San Francisco River, loachminnow and the spikedace and loachminnow designated critical 

habitat would be indirectly impacted from project activities related to vegetation treatments, 

prescribed fire, road decommissioning, and stream and riparian treatments. Impacts would

primarily relate to runoff of sediment or ash from upland sources or sedimentation directly related 

to activities within the stream channels. Implementation of design features and best management 

practices will reduce the amounts of material entering the system and flowing downstream. 

Compared to alternative A, the amount of sediment, ash, and debris would be much less than the 

potential impacts after a wildfire.

Within Dry Blue Creek, loachminnow and the designated critical habitat would be directly and 

indirectly impacted from project activities. As in the San Francisco River, vegetation treatments, 

prescribed fire, and some stream and riparian treatments may introduce sediment, ash, or debris 

causing indirect impacts to loachminnow and the critical habitat. Hardening of motorized 

crossings and stream and riparian projects will have direct impacts. If fish are present, there is a 

risk of being crushed while rocks are being moved or by equipment driving across the channel. 

Fine sediment would be suspended for a short while during work; the sediment could impact fish 

and fill or cover habitat niches for the fish or its prey species. Spikedace may receive some 

amount of sediment from implementation of these projects.

The impacts would be minimized with the application of the design feature to survey prior to 

implementing instream activities. If fish are found, they would be captured and held upstream or 

off-site until work is completed. Also if fish are detected, block nets would be set-up to keep fish 

from entering the active work site.

Project activities will cause short-term negative impacts to loachminnow and spikedace and 

loachminnow critical habitat. Stream, riparian, and hardening crossings activities, and reducing 

the risk sedimentation, ash, and debris from uncharacteristic wildfires through vegetation and 

prescribed fire, will provide long-term benefits to the species and habitat. The project will result 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

90

in a may affect, likely to adversely affect to the loachminnow and to designated critical habitat for 

loachminnow, and no effect to the spikedace, with a may affect, likely to adversely affect its 

designated critical habitat.

New Mexico Meadow Jumping Mouse

The New Mexico meadow jumping mouse is federally listed as an endangered species. There is 

no designated critical habitat located in the planning area. There have been mice found along or 

adjacent to Dry Blue Creek.

On July 3, 2018, two jumping mice were found drowned in minnow traps while surveying for 

narrow-headed gartersnakes. Surveys for the New Mexico meadow jumping mouse were 

conducted along Dry Blue Creek (September 5–8, 2018). No jumping mice were caught during 

this survey attempt, and very few other rodents were detected.

Environmental Consequences

Alternative A

There will be no effect in addition to the ones from currently permitted activities to the New 

Mexico meadow jumping mouse due to no activities being implemented under this alternative.

Effects Common to Alternatives B, C, and D

The risk of impacts would be minimized to the New Mexico meadow jumping mouse with the

implementation of vegetation and prescribed burning treatments and herbicide utilization under 

alternative C. By applying the design feature of implementing projects outside of the active 

season, there would be little risk of mortality to the jumping mouse.

The following activities would occur within suitable habitat: road decommissioning, hardening of 

motorized trail crossings in Dry Blue Creek, and a variety of stream restoration activities along 

Dry Blue Creek.

During the implementation of these activities, the potential risk to jumping mice is losing some 

riparian vegetation habitat in the long term. Project implementation would occur outside of the 

active season to reduce risks to jumping mice.

Road decommissioning and other stream restoration activities within suitable habitat would cause 

short-term disturbances but in the long term would have improved stream habitat components and 

an increase in riparian through planting and natural recruitment.

The removal of riparian vegetation and short-term disturbances from other stream restoration 

activities and decommissioning within suitable habitat would be small in scale and short in 

duration. These sites are small and localized, but have the potential to provide long-term benefits. 

Surveying for the jumping mouse prior to implementation and applying buffer around habitat will 

reduce the risk of disturbance and harm. Project activities may affect, not likely adversely affect 

the New Mexico meadow jumping mouse.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

91

Region 3 Sensitive Species

Sensitive species are defined as “those plant and animal species identified by a Regional Forester 

for which population viability is a concern, as evidenced by: (a) significant current or predicted 

downward trends in population numbers or density, or (b) significant current or predicted 

downward trends in habitat capability that would reduce a species’ existing distribution (Forest 

Service Manual 2670.5(19)).”

Environmental Consequences

Alternative A

Under alternative A, there would be no activities implemented; therefore, there would be no risk 

of disturbance and therefore no impact to any Region 3 sensitive species. Risk of disturbance 

from ongoing activities and risk of wildfire would continue.

Effects Common to Alternatives B, C, and D

The following Region 3 sensitive species occur or may occur within the Luna planning area:

• northern goshawk

• burrowing owl

• common blackhawk

• American peregrine falcon

• bald eagle

• gray vireo

• desert sucker

• Rio Grande sucker

• pale Townsend’s big-eared bat

• Gunnison’s prairie dog

• Allen’s lappet-browed bat

• Arizona montane vole

• Arizona gray squirrel

• Goodding’s onion

• villous groundcover milkvetch

• Mogollon clover

Implementation of the Luna Restoration Project activities results in a determination for each of 

these species: may impact individuals or habitat, but will not likely contribute to trend toward 

federal listing or loss of viability.

In general, the fauna species may be impacted from the increase in human presence and 

equipment use and noise. This may cause a change in the species behavior and if applicable, its 

prey base. Prey species may move away from areas of work causing increased forage distances or 

times. If species forage on vegetation or seeds, these sources may be reduced from vegetation and 

prescribed fire treatments. Noise effects will be of short duration, but vegetation and prescribed 

fire effects may be longer. Overall, in the long term vegetation conditions would improve.

Currently northern goshawk habitat within ponderosa pine cover type is departed from desired 

conditions. Modeling of the treatments within the ponderosa cover type shows that the vegetation 

structural stages after 1 year post-harvest begin to move toward desired conditions over 20 years 

(see Vegetation section of this chapter), displaying the potential for treatments to improve habitat 

conditions for the goshawk.

If any of the sensitive plants species are found during project implementation, they will be 

avoided, removing the risk of any disturbance. The risk of disturbance to these plant species 

include such things as being crushed, pulled from the ground, or habitat changes from vegetation 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

92

or prescribed fire treatments resulting in unfavorable conditions for survival. In the long term,

restoration activities would improve conditions and depending on the species has the potential of 

increasing preferred habitat types.

Management Indicator Species

Management indicator species are identified in the Gila National Forest Plan as amended (USDA 

Forest Service 1986). Management indicator species are addressed in order to implement 

National Forest Management Act regulations. They are selected because their population changes 

are believed to indicate the effects of management activities (36 CFR 219.19(a) (1). The 

management indicator species approach is designed to function as a means to provide insight into 

effects of forest management on plant and animal communities. Species are selected to represent 

several categories, such as commonly hunted or fished species, non-game species, and threatened 

and endangered species. They may be used as a tool for assessing changes in specialized habitats, 

formulating habitat objectives, and establishing standards and guidelines to provide for a diversity 

of wildlife, fish, and plant habitats.

The Gila forest plan amendment #10 for management indicator species amended the management 

indicator species list for the Gila National Forest to represent the major vegetation types 

potentially affected by management actions. Table 48 identifies the management indicator species

for the Gila National Forest and rationale for including or eliminating them from the Luna 

Restoration Project analysis.

Mule Deer

The mule deer is a management indicator species for desert shrub, piñon-juniper shrub, and shrub 

oak woodland communities. However, there can be other limiting factors to deer population 

levels other than vegetative conditions. New Mexico’s climate and weather patterns are extremely 

important to deer survival. Periods of significant rainfall produce ample forage and vegetative 

cover, which improves fawn survival. However, harsh winters or prolonged periods of drought 

can have devastating effects on fawn survival and overall deer numbers. Other limiting factors 

such as lack of water, predation, and competition with other species also contribute to the 

decreasing trend in the mule deer population. The New Mexico Department of Game and Fish 

manages mule deer populations through annual hunting permits, which also affects population 

levels. The department is currently striving to achieve increased deer survival, and higher 

population numbers.

The Luna Restoration Project proposes to treat piñon-juniper, ponderosa pine, and associated 

grasslands within the project area utilizing a variety of methods. Primary objectives of this project 

are to improve watershed condition, wildlife habitat, and to reduce accumulated fuels. The 

desired condition is restored grasslands and more open and healthier forests having a mix of tree 

species and tree sizes. Uneven aged structural characteristics having low to moderate tree 

densities are desirable throughout the area. These structural characteristics are important to mule 

deer because they provide forage that are readily available, critical winter range, and travel 

corridors.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

93

Table 48. Gila National Forest management indicator species with associated habitat type and

rational for including or excluding from analysis

Management Indicator

Specie Vegetation Type

Analysis 

(Yes/No)

Rationale for Elimination or 

Inclusion

Mule deer

(Odocoileus hemionus)

Desert shrub, piñonjuniper, shrub oak 

woodland communities

Yes Habitat exists for this species

Mearn’s quail

(Cyrtonyx montezumae 

mearnsi)

Plains and mountain 

grassland communities

Yes Habitat exists for this species

Long-tailed vole

(Microtus longicaudus)

Wet meadows and 

wetlands

Yes Habitat exists for this species

Beaver

(Castor candensis)

Low and mid elevation 

riparian areas

Yes Habitat exists for this species

Plain [Juniper] titmouse

(Baeolophus ridgwayi)

Piñon-juniper and shrub 

oak woodlands

Yes Habitat exists for this species

Hairy woodpecker

(Picoides villosus)

Ponderosa pine and 

mixed conifer snag 

component

Yes Habitat exists for this species

Mexican spotted owl

(Strix occidentalis lucida)

Mixed conifer community Yes1 Habitat exists for this species

Black hawk

(Buteogallus anthracinus 

anthracinus)

Riparian habitat at low 

and mid elevations

Yes2 Habitat exists for this species

Northern goshawk

(Accipiter gentiles)

Ponderosa pine 

community

Yes2 Habitat exists for this species

Gila trout

(Oncorhynchus gilae)

Riparian habitat at high 

elevations

No Habitat for this species does 

not exist in the planning area. 

San Francisco River and its 

tributaries are not considered 

for recovery areas for Gila 

Trout. Currently there is no plan 

to re-establish Gila Trout in 

perennial streams within the 

planning area.

Rio Grande cutthroat

(Oncorhynchus clarki 

virginalis)

Riparian habitat at high 

elevations

No Habitat for this species does 

not exist in the planning area.

Also, the planning area is not 

within the historical range of the 

species.

1 Analysis for Mexican spotted owl is located under the “Federally Listed Species” section of this document.

2 Analysis for black hawk and goshawk are located under “Region 3 Sensitive Species” section of this document.

Alternative A

Under alternative A, no treatments would be implemented within associated vegetation types;

therefore, there would be no impact to mule deer population from this project.

Effects Common to Alternatives B, C, and D

For all treatment activities, the presence of human activity and mechanized equipment use and 

noise could disturb mule deer foraging, distribution patterns, and rearing of young. These 

disturbances would be over short periods. Treatments would not occur within the various mule 

deer habitat at the same time, therefore providing the opportunity to utilize other areas without 

disturbances to the species or its habitat. Disturbances to mule deer from each treatment activity 

would be short term.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

94

Mechanical Thinning and Hand Thinning: The result of the mechanical treatments, such as 

slash on the ground, ground disturbance, and piles, could disrupt the available forbs for deer for a 

short period of time.

Prescribed Burning: The project will have fire take place on all units but not at the same time. 

This could result in a short-term disturbance to the mule deer. Fire can effectively alter vegetation 

structure and composition thereby affecting foraging habitat. The short-term effects of fire are 

likely to be unfavorable as plant foraging species are initially being reduced; however, mule deer 

have long evolved with fire and the long-term effects of prescribed fire will help reduce 

devastating wildfire and would improve foraging habitat.

Sediment Control: Installing and maintaining sediment control features would create a shortterm disturbance to foraging mule deer through noise and human presence. These activities are 

spaced out across the project area and would not all occur at the same time, giving mule deer 

opportunities to utilize other areas in the project.

Road and All-terrain Vehicle Trail: Installing user-proposed routes and decommissioning roads 

would create a short-term disturbance to foraging mule deer through noise and human presence. 

These activities are spaced out across the project area and would not all occur at the same time, 

giving mule deer opportunities to utilize other areas in the project. Decommissioning roads would 

reduce habitat fragmentation, and increase forage where bare dirt currently exists.

Fences and Water Improvement: Installing fences and water improvements would create a 

short-term disturbance to foraging mule deer through noise and human presence. These activities 

are spaced out across the project area and would not all occur at the same time, giving mule deer 

opportunities to utilize other areas in the project. Water improvements would improve habitat for 

deer, allowing them to forage in previously un-watered areas.

Summary of Effects: Short-term disturbances will occur during implementation through human 

presence and reduction of forage. Long-term habitat conditions will improve.

Alternative C – Herbicide Utilization

Herbicide application would cause short-term disturbances to foraging mule deer through human 

presence. These activities are spaced out across the project area and would not all occur at the 

same time, giving mule deer opportunities to utilize other areas in the project. Forage would 

increase in the long term, due to decreased canopy closure. Manufacturer labels would be 

followed to prevent impacts to wildlife.

Alternative D

Not implementing the user-proposed routes would result in less habitat fragmentation to mule 

deer.

Cumulative Effect:

This project and the Escudilla West Project located in Arizona would increase short-term 

disturbances to foraging mule deer through thinning and prescribed burning. Both projects would 

lead to improved habitat conditions for mule deer in the long term. Livestock grazing activities, 

fuelwood collection, road maintenance, and recreation activities could increase disturbance to 

foraging mule deer.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

95

Determination of Impact to the Species

Foraging would be disrupted in the short term, but there would be long-term improvement of 

habitat conditions for this species. For alternatives B, C, and D, individuals may be affected, but 

at the forest level, the activities proposed under these alternatives would not adversely affect 

population trends on the Gila National Forest.

Mearn’s (Montezuma) Quail

The Mearn’s quail was picked as a management indicator species for plains and mountain 

grassland communities because good Mearn’s habitat reflects the herbaceous conditions in these 

communities that the Gila National Forest is striving to attain and maintain; based on the types of 

management that is occurring today under the direction of the forest plan.

There can be other limiting factors to Mearn’s population other than vegetative conditions. Quail 

populations fluctuate from year to year for a number of reasons, primarily local weather 

conditions and predators. Limiting factors for quail populations include predation, habitat 

modification and annual precipitation. Annual population fluctuations are positively correlated 

with the amount of summer precipitation in any given year. The New Mexico Department of 

Game and Fish manages quail through annual small game hunting licenses. The species is hunted 

in New Mexico from November through February, which is another factor affecting Mearns’ 

quail population levels.

Spatial arrangement of both grassland and woodland cover types is very important for this species 

due to its survival strategy, small home range, dispersal distances, and food habits. Adequate 

horizontal and vertical grass cover must be well distributed across the landscape to meet the cover 

needs of this species. Excessive cover removal can affect the species by limiting nest building 

habitat and escape cover.

Alternative A

Implementing the no-action alternative would have no impact to Mearn’s quail.

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Thinning would increase herbaceous plants in the 

long term, providing additional food sources for Mearn’s quail. Some hiding and nesting cover

could be removed, displacing Mearn’s quail. Thinning activities would not occur across the entire 

project area at the same time. This gives Mearn’s quail the opportunity to utilize other areas until 

treatments are done.

Prescribed Burning: The prescribed burn vegetative treatments would decrease forage and 

nesting and hiding cover in the short term. The project will have fire take place on the majority of 

the project area, but not at the same time. This would allow Mearn’s quail to utilize other areas 

during implementation. Mearn’s quail has long evolved with fire and the long-term effects of 

prescribed fire will help reduce devastating stand-replacing wildfire and would overall improve 

forage and nesting and hiding cover.

Irrigation Ditch Diversion: The diversion structure and associated road reroute do not occur in 

Mearn’s quail habitat.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

96

Sediment Control: Installing and maintaining sediment control features could reduce forage and 

nesting and hiding cover in the short term but would lead to better habitat conditions in the long 

term due to improved watershed conditions.

Road and All-terrain Vehicle Trail: Installing user-proposed routes could create habitat 

fragmentation, and a slight reduction in forage and nesting and hiding cover. Decommissioning 

roads would decrease habitat fragmentation, and lead to more forage and nesting and hiding cover 

in the long term. These activities are spaced out across the project area, and would not all occur at 

the same time, giving Mearn’s quail opportunities to utilize other areas in the project.

Fences and Water Improvement: Installing fences and water improvements would not impact 

Mearn’s quail and its habitat.

Summary of Effects: Forage and nesting and hiding cover will decrease over the short term.

Forage and nesting and hiding cover will increase over the long term.

Alternative C – Herbicide Utilization

Utilizing herbicide on alligator juniper and rabbitbrush will create conditions that will allow 

herbaceous plants to establish, providing additional forage for Mearn’s quail. Manufacturer labels 

will be followed in applying herbicide.

Alternative D

Not implementing the user-proposed routes would not increase habitat fragmentation, nor remove 

forage and nesting and hiding cover.

Cumulative Effect:

This project and the Escudilla West project located in Arizona would remove forage and nesting 

and hiding cover in the short term, but both are expected to improve habitat conditions in the long 

term. Livestock grazing activities, fuelwood collection, road maintenance, and recreation 

activities could decrease available forage and nesting and hiding cover for Mearn’s quail.

Determination of Impact to the Species

Forage and nesting and hiding cover would be reduced in the short term but would increase in the 

long term. For alternatives B, C, and D, individuals may be affected, but at the forest level, the

activities proposed under these alternatives would not adversely affect population trends on the 

Gila National Forest.

Long-tailed Vole

The long-tailed vole is an indicator of wet meadows and wetlands. Within the Gila National 

Forest, there are estimated 1,710 acres of wet meadows and wetlands. Distribution of the longtailed vole across the Gila is likely to be larger than delineated wet meadow and wetland 

vegetation types because the species is also found in moist habitats and along the edges of 

spruce/fir vegetation and some mixed conifer habitats. On the Gila National Forest, the longtailed vole has previously been found near Willow Creek in the Mogollon Mountains and in the 

Mimbres. More recently, surveys conducted by Frey (2005) included a number of additional 

observations. Long-tailed voles have a very small home range, generally less than 100 meters.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

97

Devastating fire also has the potential to be a major impact on the long-tailed vole since fire 

within the spruce-fir/mixed-conifer landscape is often stand replacing and thus has dramatic and 

moderate duration effects to surrounding ecosystem.

Alternative A

Implementing the no-action alternative would have no impact to the long-tailed vole.

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Limited thinning activities are anticipated to occur 

in long-tailed vole habitat. Long-tailed voles could be inadvertently crushed by humans or 

equipment during implementation. Thinning would reduce the threat for devastating wildfire 

surrounding long-tailed vole habitat, which could lead to habitat losing moisture. Loss of 

moisture could occur through increased sunlight and increased sediment.

Prescribed Burning: Prescribed burning would trend current vegetative conditions towards 

desired conditions. Moving towards desired conditions would improve watershed conditions, 

which in turn should allow moist conditions in long-tailed vole habitat.

Irrigation Ditch Diversion: The diversion structure and associated road reroute do not occur in 

long-tailed vole habitat.

Sediment Control: Sediment control structures do not occur in long-tailed vole habitat.

Road and All-terrain Vehicle Trail: Decommissioning roads could result in Long-tail voles 

being inadvertently crushed. Decommissioning roads would allow the areas to heal naturally and 

increase habitat. User-proposed routes do not occur in long-tailed vole habitat.

Fences and Water Improvement: Fences and water improvements do not occur in long-tailed

vole habitat.

Summary of Effects: Long-tailed voles may be crushed during implementation. Long-tailed vole 

habitat would have a lower chance of being impacted by devastating wildfire.

Alternative C – Herbicide Utilization

Herbicide is proposed to be used to treat alligator juniper. Wet meadows will be buffered 300 feet, 

and no herbicide will be used in the buffer zone. Manufacturer labels will be followed to prevent 

impacts to wildlife.

Alternative D

Not implementing the user-proposed routes would have no impact to the long-tailed vole.

Cumulative Effect

This project and the Escudilla West project located in Arizona could inadvertently run over longtailed voles. Both projects would lead to improved watershed conditions. Livestock grazing 

activities, fuelwood collection, road maintenance, and recreation activities could increase 

disturbance to long-tailed voles.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

98

Determination of Impact to the Species

Some long-tailed voles may be inadvertently crushed during implementation, but proposed 

activities will improve conditions in and surrounding habitat in the long term for this species. For 

alternatives B, C, and D, individuals may be affected, but at the forest level, the activities 

proposed under these alternatives would not adversely affect population trends on the Gila 

National Forest.

Beaver

The beaver was selected as a management indicator species for the mid elevation riparian areas 

that occur in the project area.

Beaver are semiaquatic. They prefer streams and small lakes having nearby growths of willow, 

aspen, cottonwood, birch or alder. They often are thought of as the “engineers” of the animal 

kingdom, because they build dams, lodges, and canals. A dam provides an area of still, deep water 

where a lodge can be conveniently constructed and protected from terrestrial predators, and where 

building materials and food supplies can be easily floated and kept from being washed away. The 

impounded water may form ponds many hectares in area.

Beavers are active throughout the year. They feed on the bark, cambium, twigs, leaves, and roots 

of deciduous trees and shrubs, such as willow, alder, birch, and aspen, and on various parts of 

aquatic plants, especially the young shoots of water lilies. Beavers anchor sticks and logs 

underwater to feed on during winter.

North American beavers were among the most widely distributed of mammalian species. Beavers 

declined drastically in recent centuries, mainly because of excessive human hunting for their 

valuable pelts. By the early 1900s, only scattered and greatly reduced populations remained. 

Subsequent programs of regulated harvesting and transplantation have resulted in large-scale 

reestablishment of the beaver in many parts of the United States and Canada, though not always 

of the subspecies native to the areas involved.

Observations by Quemado District personnel and New Mexico Department of Game and Fish 

personnel indicate a drop in beaver population with fewer occupied sites. In part, this may be due 

to drought conditions that have reduced stream flow and pond retention below levels that are 

comfortable for beaver security. In addition, many watershed gradient control structures, when 

first built, provided habitat for beaver have now silted in. Silt catches in these structures 

decreased the potential reservoir below levels acceptable to beaver. Beaver continue to be trapped 

and relocated from private land and irrigation ditches to locations on Gila. Few of these 

relocations have resulted in permanent occupancy of new sites, probably due to the lower 

potential of the habitat present in these relocation sites.

Alternative A

Implementing the no-action alternative would have no impact to the beaver.

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Thinning would increase the occurrence of human 

presence and could cause a disturbance to the beaver. The disturbances will be short term and will 

not occur across the entire project area at the same time.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

99

Prescribed Burning: Prescribed burn vegetative treatments would increase the occurrence of 

human presence and could cause a disturbance to the beaver. The disturbances will be short term 

and will not occur across the entire project area at the same time. The short-term effects of fire are 

likely to be unfavorable as fire could potentially impact the riparian vegetation. The beaver has 

long evolved with fire and the long-term effects of prescribed fire will help reduce devastating 

stand replacing wildfire and would overall improve the riparian habitat.

Irrigation Ditch Diversion: The diversion structure and associated road reroute would remove 

some riparian vegetation and increase human presence that could disturb beaver. The vegetation 

removal is anticipated to be minimal and not have a noticeable impact to the beaver.

Sediment Control: Installing and maintaining sediment control features such as hardening 

stream crossings would create a short-term disturbance to beavers through human presence.

Road and All-terrain Vehicle Trail: Installing user-proposed routes and decommissioning roads 

would create a short-term disturbance to beavers through noise and human presence. These 

activities are spaced out across the project area and would not all occur at the same time.

Fences and Water Improvement: Installing fences and water improvements would not occur in 

beaver habitat.

Summary of Effects: Beavers will be disturbed from human presence and have a loss of some 

riparian vegetation in the short term during project implementation. Risk of devastating wildfire 

would be lowered in and around beaver habitat.

Alternative C – Herbicide Utilization

Herbicide is proposed to be used to treat alligator juniper. Human presence may disturb beavers. 

No live waters will be sprayed. Manufacturer labels will be followed to prevent impacts to 

wildlife.

Alternative D

Not implementing the user-proposed routes would have no impact to beaver.

Cumulative Effect

This project and the Escudilla West Project located in Arizona would increase disturbance to 

beaver, and would result in loss of riparian vegetation in the short term. Both projects would lead 

to improved habitat conditions for beaver in the long term. Livestock grazing activities, fuelwood 

collection, road maintenance, and recreation activities could increase disturbance to beaver and 

result in loss of riparian vegetation.

Determination of Impact to the Species

Some disturbance and loss of riparian vegetation in the short term, but will have improved habitat 

conditions in the long term for this species. For alternatives B, C, and D, individuals may be 

affected, but at the forest level, the activities proposed under these alternatives would not 

adversely affect population trends on the Gila National Forest.

Plain [Juniper] Titmouse

The plain [juniper] titmouse was selected as management indicator species for the piñon-juniper

and shrub oak woodlands habitat found on the Gila National Forest.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

100

Plain titmouse, also known as juniper titmouse, is a resident of deciduous or mixed woodlands, 

favoring oak and piñon-juniper. The plain titmouse inhabits evergreen trees in dry woodlands of 

the Southwest. It usually builds nests in natural cavities or old woodpecker holes, primarily in oak 

trees, but it is capable of excavating its own cavity in rotted wood. Current estimates of habitat 

indicate approximately 1,630,930 acres of piñon-juniper/shrub oak woodland on the Gila 

National Forest.

The juniper titmouse is omnivorous preferring insects, but uses fruits and seeds in the fall and 

winter. The species mates for life and defends territories year-round.

Alternative A

Implementing the no-action alternative would have no impact to the juniper titmouse.

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Thinning would increase the occurrence of human 

activity, trucks and chainsaws for example, could cause a disturbance in the nesting and roosting 

of the juniper titmouse. Each of the disturbances will be short term and will not occur in all of the 

project area at once. This gives the juniper titmouse the opportunity to nest and roost in other

areas until treatments are completed. The removal of snags that pose a hazard during 

implementation may also cause the temporary loss of some nesting habitat.

Prescribed Burning: The prescribed burn vegetative treatments would increase the occurrence 

of human activity and could cause a disturbance in the nesting and roosting of the juniper 

titmouse. The project will have fire take place on the majority of the project area but not at the 

same time. This could result in disturbance to the juniper titmouse. The short-term effects of fire 

are likely to be unfavorable as nesting and roosting species can initially be reduced. Fire activity 

has the potential to reduce the amount of snags in which the titmouse nests but prescribed burning 

could promote the hardening of other snags suitable for nesting and create new snags. The juniper 

titmouse has long evolved with fire and the long-term effects of prescribed fire will help reduce 

devastating stand-replacing wildfire and would overall improve nesting and roosting habitat.

Irrigation Ditch Diversion: The diversion structure and associated road reroute do not occur in 

juniper titmouse habitat.

Sediment Control: Installing and maintaining sediment control features would create a shortterm disturbance to nesting and roosting for the juniper titmouse through noise and human 

presence. These activities are spaced out across the project area and would not all occur at the 

same time, giving the titmouse opportunities to utilize other areas in the project.

Road and All-terrain Vehicle Trail: Installing user-proposed routes and decommissioning roads 

would create a short-term disturbance to nesting and roosting for the juniper titmouse through 

noise and human presence. These activities are spaced out across the project area and would not 

all occur at the same time, giving the titmouse opportunities to utilize other areas in the project.

Fences and Water Improvement: Installing fences and water improvements would create a 

short-term disturbance to nesting and roosting for the juniper titmouse through noise and human 

presence. These activities are spaced out across the project area and would not all occur at the 

same time, giving the titmouse opportunities to utilize other areas in the project.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

101

Summary of Effects: Snags will be removed, reducing habitat for the juniper titmouse. Shortterm disturbances will occur during implementation. New snags are expected to be created 

through prescribed burning activities.

Alternative C – Herbicide Utilization

Herbicide would not affect snags utilized by the juniper titmouse, but may temporarily affect 

some food sources in the short term. Manufacturer labels would be followed to prevent impacts to 

wildlife.

Alternative D

Not implementing the user-proposed routes would have no impact to the juniper titmouse.

Cumulative Effect

This project and the Escudilla West Project located in Arizona would remove snags, but both are 

expected to create new snags in prescribed burning. Both projects would lead to improved habitat 

conditions for the juniper titmouse. Fuelwood collection and road maintenance could lead to more 

snag removal.

This project and the Escudilla West Project located in Arizona could impact the juniper titmouse 

through noise or human presence. Livestock grazing activities, fuelwood collection, road 

maintenance, and recreation activities could increase disturbance to the juniper titmouse, and 

result in more snag removal.

Determination of Impact to the Species

Since fire has the potential to increase the number of snags, there would be long-term

improvement of habitat conditions for this species. For alternatives B, C, and D, individuals may 

be affected, but at the national forest level, the activities proposed under these alternatives would 

not adversely affect population trends on the Gila National Forest.

Hairy Woodpecker

The hairy woodpecker was selected as management indicator species for the ponderosa pine and 

mixed conifer forest snag component habitat found on the Gila National Forest.

It nests in holes dug mostly by the male in live or dead trees or shrubs, at an average height of 30

feet above ground. In most areas, it favors dying parts of live trees, especially where fungal heart 

rot has softened the heartwood. Limiting factors for the hairy woodpecker include predation and 

habitat modification. Snags (10 inches or more in diameter at breast height) and an average of 

five snags per hectare are assumed optimal for woodpecker reproduction, but may not be 

adequate for foraging. With over 1,341,662 acres of ponderosa pine and mixed conifer vegetation 

on the Gila National Forest, snag habitat is abundant for this species.

The hairy woodpecker is omnivorous, preferring insects but using fruits and seeds in fall and 

winter.

Alternative A

Implementing the no-action alternative would have no impact to the hairy woodpecker.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

102

Effects Common to Alternatives B, C, and D

Mechanical Thinning and Hand Thinning: Thinning would increase the occurrence of human 

activity, trucks and chainsaws for example, could cause a disturbance in the nesting and roosting 

of the hairy woodpecker. Each of the disturbances will be short term and will not occur in all of 

the project area at once. This gives the hairy woodpecker the opportunity to nest and roost in 

other areas until treatments are done. The removal of snags that pose a hazard during 

implementation my also cause the temporary loss of some nesting habitat.

Prescribed Burning: The prescribed burn vegetative treatments would increase the occurrence 

of human activity and could cause a disturbance in the nesting and roosting of the hairy 

woodpecker. The project will have fire take place on the majority of the project area, but not at 

the same time. This could result in disturbance to the hairy woodpecker. The short-term effects of 

fire are likely to be unfavorable as nesting and roosting species can initially be reduced. Fire 

activity has the potential to reduce the amount of snags in which the woodpecker nests, but 

prescribed burning could promote the hardening of other snags suitable for nesting and create 

new snags. The hairy woodpecker has long evolved with fire, and the long-term effects of 

prescribed fire will help reduce devastating stand replacing wildfire and would overall improve 

nesting and roosting habitat.

Irrigation Ditch Diversion: The diversion structure and associated road reroute do not occur in 

hairy woodpecker habitat.

Sediment Control: Installing and maintaining sediment control features would create a shortterm disturbance to nesting and roosting hairy woodpeckers through noise and human presence. 

These activities are spaced out across the project area and would not all occur at the same time, 

giving the woodpecker opportunities to utilize other areas in the project.

Road and All-terrain Vehicle Trail: Installing user-proposed routes and decommissioning roads 

would create a short-term disturbance to nesting and roosting hairy woodpeckers through noise 

and human presence. These activities are spaced out across the project area and would not all 

occur at the same time, giving the woodpecker opportunities to utilize other areas in the project.

Fences and Water Improvement: Installing fences and water improvements would create a 

short-term disturbance to nesting and roosting hairy woodpeckers through noise and human 

presence. These activities are spaced out across the project area and would not all occur at the 

same time, giving the woodpecker opportunities to utilize other areas in the project.

Summary of Effects: Snags will be removed, reducing habitat for hairy woodpeckers. Short-term

disturbances will occur during implementation. New snags are expected to be created through 

prescribed burning activities.

Alternative C – Herbicide Utilization

Herbicide would not affect snags utilized by hairy woodpeckers, but may temporarily affect some 

food sources in the short term. Manufacturer labels would be followed to prevent impacts to 

wildlife.

Alternative D

Not implementing the user-proposed routes would have no impact to hairy woodpeckers.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

103

Cumulative Effect

This project and the Escudilla West Project located in Arizona would remove snags, but both are 

expected to create new snags in prescribed burning. Both projects would lead to improved habitat 

conditions for hairy woodpeckers. Fuelwood collection and road maintenance could lead to more 

snag removal.

Determination of Impact to the Species

Since snags will primarily be retained and fire has the potential to increase, the number of snags 

there would be long-term improvement of habitat conditions for this species. For alternatives B, 

C, and D, individuals may be affected, but at the forest level, the activities proposed under these 

alternatives would not adversely affect population trends on the Gila National Forest.

Migratory Bird Species

This assessment identified migratory bird species that occur or have the potential to occur within 

the Luna planning area. The Forest Service memorandum of understanding with the U.S. Fish and 

Wildlife Service (December 8, 2008) identifies specific activities for bird conservation, pursuant 

to Executive Order 13186, signed January 10, 2001, including striving to protect, restore, 

enhance, and manage habitat of migratory birds, and prevent the further loss or degradation of 

remaining habitats on National Forest System lands. This includes identifying management 

practices that impact populations of high priority migratory bird species on National Forest 

System lands. Agencies shall identify potential impacts to migratory birds and their habitats, 

avoid or minimize adverse impacts, restore and enhance habitats, and evaluate the effects of 

actions on migratory birds. Table 49 identifies the species considered in this analysis.

The analysis for following migratory birds:

• Mexican spotted owl and southwestern willow flycatcher are located under the 

“Federally Listed Species” section of this document.

• Gray vireo, burrowing owl, peregrine falcon, bald eagle, and black hawk are located 

under the “Region 3 Sensitive Species” section of this document.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

104

Table 49. List of migratory bird species that occur or have the potential to occur within the Luna 

planning area and associated habitat types

Species Habitat Association

Bendire’s thrasher Inhabits sparse desert shrubland and degraded grassland vegetation. 

It may also occur in open woodland with scattered shrubs.

Black-chinned sparrow Moderately dense shrubs from 3-7 feet tall mixed with rocky 

outcroppings, a large grass component, and scattered large shrubs or 

trees.

Black-throated gray warbler Primarily piñon-juniper and, in the far southwest, pine-oak woodland. 

Prefers large, closed canopy woodland stands, but it often uses edge 

habitat.

Cassin’s finch Associated with mature coniferous forests and woodlands.

Chestnut-collared longspur Uses level to rolling mixed-grass and shortgrass uplands, and, in drier 

habitats, moist lowlands. Prefers open prairie and avoids excessively 

shrubby areas.

Clark’s nutcracker Inhabits montane forests where preferred, large-seeded pines are 

locally abundant.

Common nighthawk Associated with open woodlands, clearings, and fields.

Evening grosbeak Occupies mature and second-growth coniferous forests including 

spruce-fir, pine-oak, piñon-juniper, and aspen forests.

Flammulated owl Associated with open ponderosa pine forest. At higher elevations, the 

species may be found in mixed conifer habitat, in association with 

Douglas-fir, white fir, or blue spruce.

Grace’s warbler Prefers park-like stands of mature tall pines.

Juniper titmouse Open, mixed woodland areas at mid-elevations, and is most common 

where juniper is dominant. May be present where piñon-juniper is 

interspersed with oaks, and occurs in largely pine-oak habitat.

Lewis’s woodpecker Requires open canopy forests with large dead or decaying trees for 

nesting. It breeds in both lowland riparian and montane forest 

habitats. In New Mexico, breeding occurs most commonly in riparian 

woodland with large, mature cottonwoods. At higher elevations, 

Lewis’s Woodpecker occurs in ponderosa pine forests with large trees 

and an open canopy.

Loggerhead shrike Associated with open country and with short vegetation, including 

desert grasslands and shrublands and open woodlands or juniper 

savannahs.

Mexican whip-poor-will Piñon-juniper woodlands, ponderosa/oak forests, and mixed conifer 

forests.

Mountain bluebird Piñon-juniper woodlands, mountain meadows, and sagebrush 

shrublands. Associated with high open habitats with a scattered tree 

or shrub component, including savannahs, prairie-forest ecotones, 

and meadow and alpine tundra edges, and cool desert shrublands.

Mountain plover Prefers large, flat grassland expanses with sparse, short vegetation, 

and bare ground.

Olive-sided flycatcher Associated with openings and edges in coniferous forest habitat. It is 

generally more abundant in mixed conifer, late-successional forest 

with less than 40% canopy cover.

Painted redstart Middle- and upper-elevation riparian woodlands, and adjacent pineoak woodlands, generally prefers areas with rugged slopes and 

deeply shaded canyon bottoms.

Piñon jay Associated with piñon-juniper habitat.

Pygmy nuthatch Occurs in forests of pine mixed with oak, quaking aspen, maple, 

Douglas-fir, or white fir.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

105

Species Habitat Association

Red-faced warbler Mixed conifer and ponderosa pine forests, typically with a Gambel oak 

or other deciduous tree component.

Red-headed woodpecker Associated with both deciduous woodlands and open areas with 

surrounding trees or isolated woodlots. Prefer woodlands and areas 

with tall trees with large circumferences, high basal area, and low 

density of stems in understory

Vesper sparrow Found in open habitats, including old fields, shrub-steppe, grasslands, 

and cultivated crop fields. Generally prefers short, sparse, and patchy 

herbaceous vegetation with some bare ground, and low to moderate 

shrub or tall forb cover.

Virginia’s warbler Occurs at middle elevations, where coniferous woodland or forest

mixes with deciduous shrubs or trees.

Whiskered screech-owl Occupies canyon areas in montane forests.

Williamson’s sapsucker Inhabits open, mixed coniferous and deciduous forests in mountain 

areas up to 10,000 feet in elevation.

Environmental Consequences

Alternative A

For all migratory bird species listed in table 49, there would be no change to the habitat or 

disturbance to the species, but there still exists the risk of wildfire impacts to forested and 

woodland cover types. A determination of “no impact” is made for alternative A.

Effects Common to Alternative B, C, and D

For all migratory bird species listed in table 49, individuals may be disturbed by project 

equipment noise and human presence in the short term. Proposed treatments would improve 

habitat and reduce wildfire threat in long term. Some habitat elements may decline such as the 

amount of bare ground, juniper cover types or increase such as amount of larger and mature tree 

stands, grasslands. Depending on the bird species and their habitat preference, this may be either

a positive or a negative impact. During implementation, not all associated habitat types will be 

treated at the same time, providing opportunity for birds to utilize adjacent or nearby habitat, and 

therefore reducing disturbance and impacts to individuals from activities and habitat treatments.

There may be short-term impacts to individual migratory birds, but alteration to their habitats or 

being disturbed during treatments, will not negatively affect population levels.

Alternative C – Herbicide Utilization

All other effects are the same as alternative B.

Herbicide application may disturb individuals by noise and human presence in the short term. 

Rabbitbrush and alligator juniper would be reduced, providing opportunity for growth and 

increase of herbaceous plants in treatment areas. During implementation, not all associated 

habitat types will be treated at the same time, providing opportunity for birds to utilize adjacent or 

nearby habitat, therefore reducing disturbance and impacts to individuals from activities and 

habitat treatments. To further reduce impacts manufacturer labels will be followed during 

application. There may be short-term impacts to individual migratory birds, but alteration to their 

habitats or being disturbed during treatments, will not negatively affect population levels.

Alternative D

All other effects are the same as alternative B.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

106

Not adding user-proposed routes would not impact habitat nor disturb the species. There would 

be beneficial effects by not having routes crossing through habitats causing fragmentation. 

Although routes are not added under this alternative, other activities are still being implemented, 

therefore there may be short-term impacts to individual migratory birds, but alteration to their 

habitats or being disturbed during treatments, will not negatively affect population levels.

Air Quality

Incomplete or Unavailable Information

The following discusses incomplete or unavailable information and its relevance to the 

environmental effects analysis.

Air Quality: Smoke analysis was unavailable for prescribed burning treatments.

Gila National Forest personnel did not attempt any smoke modeling related to prescribed burning 

treatments. A review was done of smoke monitoring information during past prescribed fires to 

ascertain length of smoke disturbance. Gila National Forest personnel would also follow the New 

Mexico smoke management program guidelines to determine burning windows that allow for 

proper ventilation and dispersion of smoke to protect air quality and human health. This existing 

information and mitigation is adequate to determine the effects of the action alternatives.

Air quality modeling of smoke, depends on meteorological inputs from current forecasts (2 to 3

days in the future) to be most useful. Prospective modeling, as suggested, without current 

forecasts to predict smoke months or years in advance, is not a useful predictor of impacts from 

an individual burn.

Alternative A – No Action

This alternative has no direct effect on air quality because no treatment activities are proposed.

Under this alternative, no treatments would occur and there would be no anthropogenic emission 

contribution to degrade air quality. However, this alternative could lead to increased accumulation 

of ground fuel due to insect and disease activity and continuous natural forest succession. This 

accumulation of ladder and ground fuels may lead to an increased probability of high-intensity 

wildfire in the future, which could result in air quality degradation. Air quality can be degraded 

by smoke from wildfires to the point of human illness in some instances. Hardy et al. (2001) 

noted emissions from wildfire are typically greater than emissions from a prescribed fire on the 

same acreage due to greater emission factor, fuel consumption, and fire intensity. Wildfires are 

also known to result in high levels of emissions, and associated violations of national ambient air 

quality standards. Smoke from wildfire can cause visual impacts to the surrounding area and 

create hazardous driving conditions on adjacent state, county, and Forest Service roads for 

extended periods of time. Should a wildfire occur, dust emissions from fire suppression 

equipment could also increase. In the short term, air quality impacts from alternative A would be 

less because prescribed burning treatments and project activities would not occur. In the long 

term, the no-action alternative would not meet the purpose and need of this project. Previous 

wildfire activity, natural forest succession and increasing conifer mortality due to insect and 

disease can influence the amount of material available for consumption in the event of a future 

wildfire.

Emissions sources contributing to particulate matter and other pollutants would continue to be 

present. These sources include wood burning stoves, vehicle exhaust, emissions from recreational 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

107

campfires, emissions associated with prescribed fire, fugitive dust, and wildfires within or near 

the project area. Wildfire frequency is expected to continue as it has been observed in the past. A 

wildfire could lead to negative cumulative effects and would be dependent upon the size and 

intensity of the wildfire. Visibility impairment and human health impacts due to sudden and 

dramatic pollutant release are likely with a large wildfire event. Cumulative effects of smoke are 

unknown because the intensity and size of a wildfire is unknown. Research indicates wildfires 

can produce nearly twice the amount of smoke as prescribed fire (Huff et al. 1995).

Alternatives B, C, and D

A small amount of fugitive dust is likely to be generated from project activities. This dust is 

expected to settle quickly and result in minimal short-term impacts to air quality.

Prescribed burning treatments would have direct, short-term impacts on air quality in the project 

area. All proposed prescribed burning would occur when weather conditions and dispersion 

forecasts are favorable. Transitory smoke as a result of implementing alternative B, C, or D could 

produce some smoky days in the local area, and nuisance smoke (smell, see, or haze). Smoke 

would also be expected to settle into the lower draws and drainages during the evening hours 

following ignition. The Forest Service will coordinate with New Mexico Environment 

Department prior to all burning. Air quality management and emissions regulation is the 

responsibility of the U.S. Environmental Protection Agency and the New Mexico Environment 

Department, Air Quality Bureau.

The project is 24 air miles northeast of the Gila Wilderness Class I airshed and is not within a 

recognized area of nonattainment for particulate matter 10, carbon monoxide, sulfur dioxide, 

ozone or total suspended particulates. Therefore, no analysis is necessary or provided to 

determine conformity with the State implementation plan for air quality.

Smoke generated from prescribed fire is likely to impact human populations towards the 

northeast and east, due to predominant wind direction. Some wind variability would occur due to 

the surrounding topography. If the winds follow the prevailing direction during burning, smoke 

would drift and disperse over mostly unsettled portions of the Gila National Forest.

The communities of Luna, Cruzville, Apache Creek, Aragon, Reserve, Rancho Grande Estates, 

and Alpine, Arizona are all within approximately 8 to 15 miles of the Luna Restoration Project

and would likely experience the greatest impact from prescribed burning and pile burns. There are 

other communities greater than 15 miles in any direction in which residents could see, smell, and 

experience smoke and haze.

In contrast to wildfire, prescribed fires follow a written prescription that allows managers to 

minimize smoke impacts. Emission reduction techniques can reduce the impacts to air quality 

while meeting fire-related objectives. These techniques are outlined in New Mexico’s smoke 

management program guidance document (State of New Mexico 2005). The Gila National Forest 

personnel are responsible for following the State’s smoke management requirements. The current 

Smoke Management regulation in New Mexico is part of the State’s Regional Haze Rule, 

Environmental Protection Air Quality (Statewide) Smoke Management. Title 20 Chapter 2 Part 

65 of the 20.2.65.103. The requirements are listed at the New Mexico Environment Department

website: https://www.env.nm.gov/air-quality/smp.

Overall, there are no measurable differences in regards to air quality between the alternatives.

One aspect of the purpose and need for this project is to reduce the impacts of high-severity fire.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

108

Smoke from wildfires can present a risk to public health. Wildfires often result in high levels of 

emissions, poor visibility, and associated violations of national ambient air quality standards. 

Vegetation management treatments provide the opportunity on a long-term basis to reduce the 

magnitude of wildfire air quality concerns. According to Wiedinmyer and Hurteau (2010) widescale prescribed fire application can reduce carbon dioxide fire emissions for the Western United 

States by 18 to 25 percent. The total amount of pollutants released by prescribed burning under 

alternative B, C or D would be spread out over several years and would occur when emissions 

would be unlikely to have adverse effects on human health and visibility. After implementation, it 

is estimated that subsequent wildfires in the project area would produce less pollutants due to less 

fuel available to burn.

Fugitive dust may be generated in areas where mechanical operations are occurring and with 

associated vehicle travel. These impacts are expected to stay within the analysis area as dust from 

roads settles out relatively quickly. There is no measurable difference expected between 

alternatives as related to dust generated from restoration activities. Best management practices 

should be effective in retaining protective ground cover, reducing exposed soil susceptible to 

wind erosion and creation of dust in all action alternatives. This project is not within a Statedesignated nonattainment area; therefore, no conformity assessment was necessary or completed. 

Compliance with Clean Air Act would continue.

Air quality as a result of implementing alternatives B, C, or D would result in a short-term 

increase in pollutants from prescribed fire smoke emissions and fugitive dust. When considering 

past, present, and reasonably future activities, the activities proposed in the alternatives are not 

anticipated to result in cumulative effects to air quality.

Watershed and Soils

General Assumptions

• No more than 25 percent of a 6th-code watershed within a 3-year period would be treated. 

This percentage may be adjusted up or down based on monitoring and assessment of 

watershed conditions, after treatments.

• The reduction or elimination of vehicle traffic on a road or trail near a stream will result in

less sediment delivered from the road to the stream over time. This relates to the reduction

of the amount of loose material on the road surface and also the increase in the amount of 

vegetative litter and other cover on the road surface. Erosion rates from a closed road may 

decrease to near background levels as the density of vegetation on the surface of the road

increase (Dissmeyer 2000).

• Closed routes without fixed barriers are expected to revegetate minimally. These routes will 

not disappear from the landscape until decommissioned, and will continue to be a source of 

sediment and erosion to some degree. They will still be included in road density 

calculations.

• Best management practices would be properly implemented to aid in mitigating negative 

impacts to water quality and quantity, soil resources, riparian and wetland resources, and air 

resources.

• Existing road system has already committed soil resources to loss of productivity.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

109

• Routes that are connected to the drainage network provide some level of sediment 

transport, regardless of whether drainage is perennial, intermittent, or ephemeral. These 

sediment inputs vary based on duration and frequency of flow events. During short 

duration, high-intensity storm events, ephemeral drainages can carry a considerable amount 

of sediment, some of which is generated by roads.

• The 2015 watershed condition classification incorporated management activities and 

watershed events that occurred in the past or that are ongoing. The final assessment of 

watershed condition in 2015 constituted a culmination of these activities, events, or both

leading to current watershed condition. The condition classification of each 6th-code 

watershed is considered a result of cumulative watershed effects up to 2015.

Incomplete or Unavailable Information

The following discusses incomplete or unavailable information and its relevance to the

environmental effects analysis.

Soils: The general ecosystem survey map and associated soil interpretations were partially used to 

evaluate soils within the Luna Restoration Project.

The general ecosystem survey is mapped at a scale of 1:250,000 and was designed for general 

assessments and evaluation of projects at the landscape or forestwide level similar to the scope of 

the proposed action. It is key to acknowledge the general ecosystem survey is a very broad scale 

survey (1 inch equals approximately 4 miles) and many differences in soils, geology and 

topography can occur within very short distances. The draft forest terrestrial ecosystem survey 

map was used to identify erosive soils formed from volcanic sediments. Currently no soil map 

unit interpretations have been developed to accompany the draft terrestrial ecosystem survey 

map.

Gila National Forest personnel did not attempt any sedimentation modeling by alternative due to 

incomplete data. Although complete data was unavailable, ongoing survey information and past 

ecosystem survey data were evaluated. Best professional judgment was applied to determine the 

likelihood of soil disturbance from treatments as well as review of best available science and 

current literature related to vegetation treatments. Best management practices were developed by 

the interdisciplinary team to mitigate any expected impacts to soils. Therefore, the existing 

information is adequate to determine the effects of the action alternatives.

Riparian: Some riparian systems within the project area did not have recent or completed proper 

functioning condition assessments.

These include Romero Creek, Centerfire Creek, and some reaches of the San Francisco River.

Design for stream stabilization treatments will occur following completion of environmental 

analysis. Site-specific disturbance related to design implementation is unavailable.

Field inspections, photographic documentation, or both for all riparian systems within the project 

area had been made within the past three years by members of the project’s interdisciplinary 

team. Best professional judgment was applied to determine resource conditions, trends, proposed 

treatments, and effects from proposed treatments. The existing information is adequate to 

determine the effects of the action alternatives.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

110

Affected Environment

Watershed Condition

This analysis will address effects at the 6th-code watershed level, which range in size from 

approximately 7,000 to 38,000 acres within the project area.

Watershed condition encompasses both aquatic and terrestrial processes and functions as the 

quality of water and aquatic habitat are inseparably linked to the integrity of uplands and riparian 

areas within a watershed. Aspects of a watershed related to geomorphic integrity can be defined 

in terms of attributes such as slope stability, soil productivity, channel morphology and other 

upslope, riparian and aquatic habitat characteristics. Hydrologic integrity of a watershed is related 

primarily to flow, sediment and water quality attributes. Biological integrity can be defined by the 

aquatic characteristics that influence the diversity and abundance of species. In each case, 

integrity must be evaluated in the context of the natural disturbance regime, geoclimatic setting 

and other important factors. The geomorphic, hydrologic, and biologic components are then 

combined and evaluated as a whole to assess watershed integrity and health.

Three classes are used to describe watershed condition (USDA Forest Service 2004, Forest 

Service Manual 2521.1):

• Class 1 watersheds exhibit high geomorphic, hydrologic, and biotic integrity relative to 

their natural potential condition.

• Class 2 watersheds exhibit moderate geomorphic, hydrologic, and biotic integrity relative 

to their natural potential condition.

• Class 3 watersheds exhibit low geomorphic, hydrologic, and biotic integrity relative to their 

natural potential condition.

In March 2011, watershed condition classification was initially completed across the Gila 

National Forest at the subwatershed level (6th code). A review and reclassification of all Gila 

National Forest watersheds was completed in December 2015. The watersheds were classified as 

being in one of the three condition classes noted above, as translated to functionality.

• Class 1 = Functioning properly,

• Class 2 = Functioning at risk, and

• Class 3 = Impaired function.

The Luna Restoration Project occupies a portion of nineteen 6th-code watersheds, however the 

majority (98 percent) of the project area falls within 11 of the following 6th-code watersheds: 

Canovas Creek-Coyote Creek, Trout Creek, Stone Creek-San Francisco River, Dry Blue Creek, 

Spur Draw, SA Creek, Headwaters Centerfire Creek, Outlet Centerfire Creek, Big Canyon-San 

Francisco River, Hay Vega, Cow Springs Draw. Table 50 provides the percentage of the project 

area found in all of the 6th-code watersheds along with the 2015 watershed condition 

classification rating.

Watersheds with less than 2 percent of the area in the project will not be evaluated further. 

Activities in the Luna Restoration Project will not affect all of the indicators used to derive the 

watershed condition rating.

Current watershed conditions are the culmination of historical activities since the late 1800s and 

early 1900s, ongoing management activities, climate fluctuations, roads, and recent wildfire.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

111

Table 50. Summary of watersheds and condition ratings that overlap the Luna planning area. 

Watershed condition ratings are Class 1 = functioning properly, Class 2 = functioning at risk, and 

Class 3 = impaired function.

6th-Code 

Watershed / 

Hydrologic Unit 

Code

Acres in 

Watershed

Project Acres 

in Watershed 

(includes 

private land 

acres)

Percentage

of Project 

within 

Watershed

Percentage

of Watershed 

Occupied by 

Project

Watershed 

Condition 

Rating

Hay Vega

150200010301

7,091 3,236 2% 46% Class 1

Canovas CreekCoyote Creek

150200010302

32,466 10,834 6% 33% Class 2

Cow Springs 

Draw

150200030703

31,273 6,568 4% 21% Class 1

Mangitas Creek

150200030505

23,062 2,235 1% 10% Class 1

Campbell Blue 

Creek

150400040503

34,218 617 Less than 1% 2% Class 3

Trout Creek

150400040302

20,934 13,174 7% 63% Class 2

Stone Creek-San

Francisco River

150400040303

35,769 24,276 13% 68% Class 2

Spur Draw

150400040304

26,179 26,179 14% 100% Class 2

SA Creek

150400040305

22,560 22,560 12% 100% Class 2

Headwaters

Centerfire Creek

150400040306

18,536 18,536 10% 100% Class 2

Outlet Centerfire

Creek

150400040307

20,591 20,591 11% 100% Class 3

Big Canyon-San

Francisco River

150400040308

16,418 16,418 9% 100% Class 2

Dry Blue Creek

150400040502

25,048 19,104 10% 76% Class 2

Starkweather 

Canyon

150400040309

25,279 636 Less than 1% 3% Class 2

Cienega CanyonSan Francisco 

River

150400040311

36,089 188 Less than 1% 1% Class 2

Centerfire CreekBlue River

150400040504

17,311 329 Less than 1% 2% Class 1

Headwaters Saliz 

Canyon

150400040401

26,228 98 Less than 1% Less than 1% Class 1
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

112

6th-Code 

Watershed / 

Hydrologic Unit 

Code

Acres in 

Watershed

Project Acres 

in Watershed 

(includes 

private land 

acres)

Percentage

of Project 

within 

Watershed

Percentage

of Watershed 

Occupied by 

Project

Watershed 

Condition 

Rating

Steeple CanyonBlue River

150400040506

37,760 5 Less than 1% Less than 1% Class 2

Upper Pueblo 

Creek

150400040601

21,554 3 Less than 1% Less than 1% Class 2

In 2011, the Wallow Fire burned across acres of the Gila National Forest, within the Luna 

Restoration Project boundary. This fire originated on the adjacent Apache-Sitgreaves National 

Forests, and burned during drought conditions, resulted in severe negative impacts to watershed 

conditions on both national forests along the state line.

Watershed conditions have improved over the last century across the project area, and within the 

last several years within the Wallow Fire burn scar. However, there are still many localized areas 

throughout the project area where restoration of ecosystem health and watershed functionality is 

necessary. Headcuts and gullies are still active in many of the streams, ephemeral drainages, and 

low-lying swales. A great effort was placed on restoration of these sites in the 1980s. More than 

150 erosion control structures were constructed, however little maintenance has occurred on these 

sites to date. Additional areas have since been identified for erosion control measures and other 

restoration treatments. The Escudilla Landscape watershed restoration action plan has been 

developed concurrently with this analysis that details many specifics related to the watershed 

condition rating for eight of these watersheds and four on the adjacent Apache-Sitgreaves 

National Forests (USDA Forest Service 2018).

Effects of the 2018 Owl Fire in the Dry Blue 6th-code Watershed

The Owl Fire was a lightning caused fire that started on June 30, 2018 in the vicinity of Aspen 

Mountain in the San Francisco Mountain Range of the Gila National Forest. It burned into midJuly until monsoon rains put out the fire. A Burned Area Reflectance Classification map was not 

attainable for this fire due to frequent afternoon cloud build up. Burn severity mapping was done 

by two helicopter flights and the goal of the mapping was to map only areas of high burn severity. 

No attempt was made to map moderate, low or unburned areas of the fire. The fire did burn into 

the Dry Blue 6th-code watershed and backed down into Frieborn Canyon with mixed severity 

covering 792 acres. The slope it backed down on is comprised of mixed conifer vegetation and 

soils were derived from Gila Conglomerate that tends to be highly erosive. Of the 792 acres of 

burn in this watershed approximately 61 acres of high-severity burn was seeded with annual 

barley to try to assist in reducing erosion. From a vantage point on National Forest System road 

209 a majority of the burn was visible that occurred in Frieborn Canyon. It is estimated that there 

was several hundred acres of moderate burn severity that occurred on the slope above the canyon 

bottom.

Of the 25,047-acre 6th-code Dry Blue watershed, only 792 acres or 3.1 percent was affected by 

the Owl Fire. Areas of high and moderate burn severity on the very steep slope of Frieborn 

Canyon did experience sheet, rill and small gully erosion. Sediment and ash did make its way into

Frieborn Canyon, so short term localized negative effects are occurring. At the 6th-code watershed 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

113

scale the Owl Fire will not cause a long-term negative effect or downward trend to current 

watershed condition.

Soils

Soils within the Luna Restoration Project can be characterized as highly variable. They have been 

formed primarily from volcanic sediments, basalt, rhyolite, sandstone, and recent alluvium. The 

soils range from shallow to deep and stable to unstable in nature, with varying amounts of surface 

and subsurface rock fragments. The topography within the project area ranges from gently 

sloping elevated plains, valley bottoms, and hills to steep mountains and scarp slopes.

The project area has many acres of soils that were formed from volcanic sediments that are 

oftentimes referred to as Datil soils. These soils are highly erosive and are typically not very 

productive.

Table 51 and table 52 display acres and percent of project area by soil condition and erosion

hazard rating.

Table 51. Summary of general ecosystem survey soil condition within the Luna planning area

Soil Condition Satisfactory Unsatisfactory Unsuited

Acres 155,550 27,560 3,927

Percent 83% 15% 2%

Table 52. Summary of general ecosystem survey erosion hazard within the Luna planning area

Erosion Hazard Slight Moderate Severe

Acres 78,422 79,502 27,113

Percent 42% 43% 15%

Aquatic Resources

Water resources within the project area include streams, wetlands, riparian areas, ponds, and 

numerous stock ponds and tanks. There are approximately 75 miles of perennial streams and 39 

miles of intermittent streams in the project area. The remaining drainages are considered 

ephemeral, of which there are approximately 634 miles of these systems. There are approximately

205 surface acres of open water within the project area. These acres are mainly associated with 

stock ponds, and other larger storage reservoirs, when filled to capacity.

The major drainages within the project area are San Francisco River, Stone Creek, Jenkins Creek, 

Romero Creek, SA Creek, Trout Creek, Canovas Creek, Spur Draw, Centerfire Creek, and Dry 

Blue Creek. The San Francisco River, Dry Blue Creek, and Stone Creek have experienced direct 

or indirect effects from the 2011 Wallow Fire. These effects included increased stream flow 

volumes and peak flow magnitudes, with accompanying excess channel erosion and 

sedimentation. Spring discharge, a source of perennial water for a number of streams, has 

increased from the decreased transpiration associated with the loss of over story vegetation. 

Recovery of the hydrologic regime following wildfire generally occurs within a 5 to 10 year 

period however, it can take longer.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

114

Riparian, Wetlands, and Upland Wet Meadows

Riparian areas found within the Luna Restoration Project were evaluated using site visits by 

members of the interdisciplinary team, proper functioning condition surveys (USDI Bureau of 

Land Management 1993), or both to determine both riparian potential and functionality. Areas 

evaluated within the project area are Jenkins Creek, Trout Creek, San Francisco River, Stone 

Creek, Centerfire Creek, SA Creek, Pace Creek, Dillman Creek, Adair Canyon, Spur Basin Draw, 

Romero Creek, Dry Blue Creek, and Canovas Creek. Most of the drainages within the planning 

area are ephemeral in nature, and only flow in response to precipitation or runoff events.

Water Quality

The potential adverse effects from most forest management activities are non-point sources, as 

opposed to point sources of water pollution. To ensure compliance with the Clean Water Act, 

water quality standards are set by the New Mexico Water Quality Control Commission. New 

Mexico’s surface water quality standards define water quality goals by designating uses for 

waterbodies, setting criteria to protect those uses, and establishing provisions to preserve water 

quality. These water quality standards are examined for changes on a 3-year rotating basis. The 

current standards are documented in the New Mexico Administrative Code Title 20, Chapter 6,

Part 4 “New Mexico Standards for Interstate and Intrastate Surface Waters” (New Mexico Water 

Quality Standards). Under section 303(d)(1) of the Clean Water Act, States are required to 

develop a list of waters within a state that are not in compliance with water quality standards and 

to establish a total maximum daily load for each pollutant. Reaches of streams that are in some 

state of nonattainment are documented in “2016–2018 State of New Mexico Clean Water Act 

Section 303(d)/Section 305(b) Integrated Report Appendix B – Integrated List” (State of New 

Mexico 2016). Currently there are two waterbodies within the project area included in this report.

Headwaters Centerfire Creek and Outlet Centerfire Creek 6th-code watersheds

Centerfire Creek (San Francisco River upstream to headwaters) is in nonsupport of its designated 

use of “high quality coldwater aquatic life” and “primary contact.”

• Probable causes of impairment are identified as nutrient/eutrophication, 

sedimentation/siltation, specific conductance, water temperature, turbidity, and E. coli.

• Probable sources of impairment include low water crossings, channelization, recreational

pollution sources, source unknown, drought-related impacts, silviculture, fire suppression, 

silviculture activities, road and bridge runoff, rangeland grazing, natural sources, and 

streambank modifications and destabilization.

• Total maximum daily loads for plant nutrients and conductivity were completed in 2002. 

Total maximum daily loads for turbidity and E. coli were scheduled in 2014. Water 

temperature standards are currently under review.

Stone Creek—San Francisco River and Big Canyon—San Francisco River 6th-code 

watersheds

San Francisco River (Centerfire Creek upstream to Arizona State Line) is in nonsupport of its 

designated use of coldwater aquatic life.

• Probable cause of impairment is identified as water temperature and benthic macroinvertebrate community.

• Probable sources of impairment are silviculture, fire suppression, rangeland grazing, and 

source unknown.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

115

• Total maximum daily loads for temperature and plant nutrients were completed in 2002. 

The reach was delisted for nutrients during the 2010 listing cycle. Water temperature 

standards are currently under review.

Water quality related to stream temperature is of major concern in the perennial and intermittent 

streams located in the Luna project area. Often related to riparian health, temperature is important 

because it governs the kinds and types of aquatic life that can be present in the stream, regulates 

the maximum dissolved oxygen concentration of the water, and influences the rate of chemical 

and biological reactions. Seasonal variations in stream temperature may be caused by changing 

air temperature, solar angle, meteorological events, and a number of physical aspects related to 

the stream and watershed. These physical features include upland watershed condition, velocity, 

vegetation types and canopy cover, stream configuration, and land use.

Summary of Resource Conditions

Existing stream crossings – Negative impacts to riparian areas is occurring as current stream 

crossings go directly through riparian areas and wetlands. Negative impacts to vegetation in these 

areas include rutting of wetlands, damage to riparian woody and herbaceous vegetation, and 

increased sedimentation downstream of crossings.

Encroaching conifers in riparian areas and upland wet meadows – Conifers are currently 

encroaching into floodplains, riparian areas, and fringes of the wet meadows, taking available 

water, nutrients, and energy that would otherwise be available to riparian and wetland species. 

Continuation of this encroachment will eventually lead to an ecological conversion of the site to 

more upland vegetation species, thus reducing wetland and riparian habitat within the project 

area. This would limit water quantity, in particular, from being available for valuable wetland and 

riparian habitats.

Ungulate utilization in degraded riparian and uplands – Several degraded riparian areas and 

upland sites have been identified for restoration needs. Water quality impairments have been 

identified by the State as a result of rangeland grazing with some of the probable causes of 

impairment notes as sedimentation or siltation and temperature. These causes can be both a direct 

and indirect result of inadequate woody and herbaceous vegetation, both in uplands and on 

streambanks.

Stream and wet meadow stabilization structures – Stream reaches throughout the project area 

that have been experiencing increased water flows and sediment delivery due to wildfire and 

flood events would not receive any treatments. These streams would have to continue to recover 

at a natural rate. In some of these streams, such as Stone Creek and Centerfire Creek, slow to no 

recovery is currently occurring. It would take decades for these systems to move towards upward 

trends without multiple treatments.

Riparian tree planting – There are riparian areas and stream systems that currently have 

excessive sedimentation, unstable banks, lack of vegetation, and high temperatures. Areas that are 

currently not functioning or in downward trends would maintain this condition and in areas where 

there are temperature and siltation impairments, these would not improve without improvement to 

riparian vegetation.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

116

Head of Ditch irrigation diversion reconstruction – The current diversion has negative impacts 

on the adjacent riparian area as heavy equipment is in the channel several times every year, 

constructing and deconstructing the push-up dam. This disturbance does not allow long-term 

recovery of riparian woody species, and results in excessive sedimentation at the site and 

downstream.

Wet meadows – Currently there are locations in wet meadows that receive motorized traffic 

several times throughout the year, even though the routes are closed. Motorized use in wet 

meadows poses a threat to soil productivity and vegetation. Repeated motorized use can cause 

soil compaction in these areas, which may result in long-term adverse effects to riparian and wet 

meadow conditions.

Erosion stabilization structures – Currently, the effectiveness of a majority of the existing 

erosion control structures has diminished over the years or they are no longer functional. Several 

of these structures have breached, and new headcuts have formed. This has caused excessive 

sediment that ultimately moves downstream and into riparian areas and wet meadows. Some of 

the structures are located in upland wet meadows and resultant new headcuts are proceeding to 

dewater these areas.

Degraded uplands – Downstream negative impacts to riparian areas are occurring with excessive 

sedimentation being generated from degraded uplands. These areas will continue to produce

sediment and higher overland flows if herbaceous vegetation is not restored.

Campgrounds – Existing road and campsite drainage leads directly to the adjacent waterways of 

San Francisco River and Trout Creek, thus providing a direct input of sediment. This influx of 

sediment will continue to hamper improvement of riparian conditions in these areas as it impacts 

bank stability and riparian vegetation growth.

Range Management – Livestock would continue to provide the same pressure at existing water 

sources including where water source is spring-fed with associated riparian vegetation.

Motorized Transportation – There are negative impacts occurring where motorized routes 

coincide with riparian areas and wetlands/wet meadows. Closed routes continue to discharge 

runoff and sediment to adjacent waterways. Some closed roads are located in the drainage 

bottoms of perennial streams, with associated riparian vegetation, where unauthorized use is 

occurring. Other closed roads cross or are adjacent to wet meadow areas. These routes still 

receive some amount of unauthorized use and cross-country travel, although unauthorized.

Environmental Consequences

Soil Resources

Alternative A

Mechanical Vegetation Treatments

The existing condition of soils and soil loss rates will continue under the no-action alternative. 

Trends would remain stable in vegetation types where there is adequate vegetative ground cover 

and canopy cover. Organic soil carbon will accumulate at potential rates and soil fertility will 

slowly improve if accumulation of organic matter continues at its present rate. Existing amounts 

of coarse woody material would remain constant, with an increasing amount likely within the 

Wallow Fire scar as dead trees begin to topple. There would be no disturbance to soils from 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

117

vegetation treatments, as vegetative ground cover would remain intact, with no disturbance from 

landings, skid trails, heavy equipment, or other treatment related impacts. No mowing of 

rabbitbrush would occur, thus canopy cover in these areas would remain high with very little 

herbaceous understory in impacted rangelands. No herbicide treatment would occur on either 

rabbitbrush or alligator juniper, there would be no risk to the soil resource or soil crusts from 

potential chemical interactions. Infiltration rates would remain the same, as there would be no 

increase in surface runoff from soil disturbing activities.

Tree encroachment will continue in grasslands and meadows. A study on the Cibola National 

Forest concluded competition for limited site resources (nutrient stock, water, sunlight, etc.) from 

a relatively dense juniper overstory was the principal cause for decline in understory productivity 

and deterioration of soil quality at their study site (Brockway et al. 2001). As woody species 

encroachment occurs, grass biomass and cover decrease as woody species biomass and cover 

increase. Additionally, herbaceous species richness and diversity tends to decline as woody 

species density increases (Van Auken 2009). If site conditions such as this persist, infiltration 

rates may gradually decrease as water-compacted, bare soil increases and organic matter 

accumulation decreases.

Ponderosa pine and mixed conifer vegetation types will remain at risk for future soil loss as high 

tree density and heavy fuel loading in forested stands increases the risk of uncharacteristic highintensity wildfire. High-severity fire can result in large areal extents of high soil burn severity that

can pose negative impacts to soil productivity and site stability. High tree densities can also create 

conditions where herbaceous ground cover is out-competed for sunlight, precipitation, and 

nutrients. A reduction in grass under these thick canopies could result in less favorable site

conditions over the long term.

Overall, in the no-action alternative there would be no long-term benefit to soil resources, 

resulting in a potential downward trend in soil condition.

Prescribed Fire Treatments

Ponderosa pine and mixed conifer vegetation types that have high tree densities and canopy cover 

tend to exhibit heavy fuel loading in the understory. As surface and ladder fuels increase, and tree 

density increases, the probability of high-intensity uncharacteristic wildfire increases resulting in 

the potential for high soil burn severity. The loss of canopy cover, ground cover, and organic 

debris on the soil surface, together with the possible occurrence of hydrophobic soil layers in 

these areas, would likely lead to considerable increases in soil erosion, loss of soil organic matter, 

and reduction in long-term soil productivity. This would result in a greater risk of negative 

impacts to the soil resource under alternative A compared to all action alternatives.

Soils under dense, closed canopy, stands piñon-juniper and in heavily encroached meadows 

would not realize any increase in herbaceous ground cover or site productivity. Soil condition in 

these areas would likely stay the same or experience a downward trend. Similar to ponderosa pine 

and mixed conifer vegetation, if heavy surface fuel loading are present, these areas would be at a 

higher risk to high soil burn severity in the event of a wildfire.

Soils in grassland and meadow vegetation types would not be affected under alternative A since 

surface fuel loading is relatively low in these areas. Soils would remain in their existing 

conditions with the same trends.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

118

Stream, Riparian, and Erosion Control Treatments

Restoration activities would not occur in alternative A. Degraded soil conditions, including 

excessive erosion and destabilization would continue at their current rate.

In areas where conifers are beginning to encroach into upland wet meadows and riparian areas, 

soil conditions would likely remain stable for a period of time. However, conifer encroachment 

would continue to compete with riparian, wetland, and wet meadow species for sunlight, water 

and nutrients.

In areas where degraded soils are negatively impacting riparian areas, streams, wetlands, and wet 

meadows, these conditions would continue and cause further detriment to water quality. Sediment 

control structures would not be cleaned or maintained, and those that are breached would 

continue to headcut upstream. Soil stability would lessen, stream bank stability would decrease, 

and erosion rates would continue or worsen.

At the Head of Ditch diversion site, ground disturbance would persist multiple times per year as 

native soil push-up dams would be installed and removed repeatedly to accommodate irrigation 

season and in response to flooding events.

The potential for a downward trend in areas currently having negative soil resource issues would 

occur with implementation of alternative A.

Range Management Treatments

New range improvements consisting of storage tanks, wells, drinkers, pipeline, and pasture 

division fences would not occur under the no-action alternative. Currently, isolated areas around 

existing water points receive heavier use from livestock and wildlife, resulting in less herbaceous 

vegetation and soil compaction. These areas would remain the same, as there would be no 

improvement in distribution of livestock and wildlife. However, the acres associated with these 

areas are minimal across the project area. No soil disturbance would occur under this alternative. 

Soil conditions and trend would remain the same.

Motorized Transportation Treatments

There would be no change to the motorized vehicle transportation system.

This alternative results in the least amount of soil disturbance related to motorized transportation 

system. However, the absence of road improvements, decommissioning, or reroutes under this 

alternative would result in negative soil impacts to occur in many locations across the project 

area. With no road decommissioning, closed routes would continue to provide a pathway for 

erosion to occur and for sediment to enter the waterway.

Negative impacts to the soil resource would continue at locations where current road conditions 

are poor and where motorized stream crossings are creating both erosion and water quality issues. 

Some locations currently have impaired site conditions due to instability and erosion problems 

resulting from structural crossing issues, heavy ground disturbance from motorized traffic, or 

both. If these conditions persist in these locations, a downward trend in soil conditions is likely.

Effects Common to Alternatives B, C, and D

In the development of these alternatives, sensitive soils were identified and considered.

Vegetation treatments were excluded from these areas. Prescribed fire was excluded from most 

areas with sensitive soils, with the exceptions being the north aspect of the San Francisco Divide
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

119

and southwest of the community of Luna in Dry Blue Creek and Frieborn Canyon, extending 

south to the planning boundary. In these areas, low-severity fire may be introduced when fuel 

conditions, weather conditions, or both lessen fire spread across the landscape.

Mechanical Vegetation Treatments

In these alternatives, where soils are in satisfactory condition, they would continue to be 

maintained or improved with implementation of best management practices. Vegetation with 

dense canopies and heavy coarse woody debris fuel loading would see enhancement from 

vegetation treatments. Vegetative ground cover would be reduced and/or spatially rearranged by 

proposed vegetation treatments.

Restoration thinning would reduce the risk of forests and woodlands to intense, high-intensity 

uncharacteristic wildfire behavior that would increase the potential for high soil burn severity. 

Thinning would also help reduce competition for light, nutrients and water by creating gaps in 

canopies and reducing woody vegetation basal area. This would aid in restoring an herbaceous 

component to the understory, which would help carry low-intensity fires.

Heavy equipment used in vegetation treatments will cause varying degrees of soil compaction 

which can temporarily increase water runoff and delay, reduce, or both the establishment and 

growth of desired herbaceous vegetation. Short-term increases in soil loss related to ground cover 

and soil disturbance are expected from mechanical thinning and skidding operations, as well as 

from the use of existing roads by logging equipment.

Long-term negative impacts to the soil resource from compaction or soil loss are not expected.

Site stability and long-term soil productivity are expected to be maintained. Skid trails, staging 

areas, and landing sites will be scarified and seeded as necessary to reestablish vegetative cover. 

This should reduce the potential for erosion and sedimentation that could originate from these 

areas. Roads that are currently adding sediment to the stream system could receive additional 

erosion control treatments during project implementation. Activity slash can help mitigate some 

impacts from ground disturbance on site stability and productivity and activity slash would 

provide long term soil nutrient cycling.

Mowing of rabbitbrush under this alternative is not expected to have any adverse impacts to the 

soil resource. This activity will be done with rubber-tired equipment, with organic matter 

generated from mowing left largely in place, serving as organic matter and mulch across the soil 

surface. These areas of treatment are fairly flat, thus little soil movement is expected to be 

generated.

It is anticipated that overall soil condition and trends across the project area will be maintained,

and over the long term, the trend will improve.

Prescribed Fire Treatments

Proposed prescribed fire treatments within ponderosa pine, mixed conifer, and piñon-juniper 

vegetation types across the project have the potential to help maintain and/or improve soil 

conditions. Prescribed fire treatments would reduce surface and ladder fuels. These treatments 

would reduce the severity of future wildfires that could impact soils.

Pile burning will likely result in localized, negative effects including soil sterilization and total 

consumption of fine organic materials which can result in loss of litter layer, oxidation of soils, 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

120

hydrophobic soils, loss of soil structure, minimal return of native grasses, and an increase in 

forbs. These effects could also cause a localized decrease in infiltration and an increase in runoff.

Soil conditions in riparian areas, wetlands, and wet meadows would be maintained, as these areas 

would be buffered. Buffer distances are designed to provide adequate distance for ash and 

mobilized sediment to drop out prior to reaching riparian and water resources.

Designed low-intensity wildfire in the areas of Dry Blue Creek, Frieborn Canyon, and the San 

Francisco Divide will limit the severity of impacts to soil resources. Soil conditions are expected 

to remain the same, with a lessening of risk to high-severity wildfire. High-severity wildfire often 

results in negative effects to the soil resource. Upward trends would occur over the long term if 

canopy covers are reduced and more herbaceous ground cover can be restored in these areas.

Prescribed fire can also stimulate more vigorous growth of grass and forb vegetation as well as 

reduce fuel loading. This can lead to overall improvements in herbaceous cover and maintenance 

of coarse woody debris into the future. These benefits would not occur under alternative A.

The prescribed fire activities proposed under these action alternatives would help reduce fuel 

loading and ladder fuels and reduce the risk of future high-severity wildfire; providing for longterm soil protection and soil productivity.

Stream, Riparian, and Erosion Control Treatments

Proposed riparian, stream, and erosion control treatments would maintain satisfactory soils and 

have the potential to improve impaired soils and reduce current soil loss rates.

These treatments are designed to restore areas where site conditions are currently degraded. The 

treatments described in chapter 2 of this document would improve infiltration rates and bank 

stabilization, increase residence time of water in the system, control erosion, reduce sediment 

movement into the stream, increase vegetation diversity along stream channels, increase 

herbaceous ground cover in the uplands, reduce direct motorized impacts on riparian and stream 

channels, and reduce sediment movement into stream channels from motorized crossings.

The action alternatives provide for the improvement of impaired soil conditions as well as help in 

maintaining satisfactory soil conditions in riparian areas, wetlands, upland wet meadows, and 

degraded uplands. Upward trends are expected in all of these restoration areas.

Range Management Treatments

Additional watering sites in selected grazing allotments within the project area are anticipated to 

improve livestock and wildlife distribution. Improvements would not completely eliminate 

concentrated use at existing watering locations. At new sites, some soil compaction and loss of 

herbaceous vegetation is likely to occur.

Motorized Transportation Treatments

Road improvements, reroutes, and decommissioning activities proposed under the action 

alternatives are designed to improve the soil resource over the long term. Road improvements are 

planned in areas where current routes are leading to erosion and contributing to movement of 

sediment into the stream system.

Reroutes have been planned in areas where the current route crosses live streams, riparian areas, 

or both. Reroutes would be in more stable locations with less water and soil resource impacts.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

121

Approximately 116 miles of decommissioning is planned where currently closed routes are no 

longer necessary for forest management activities. In the short term, approximately 104 miles 

would be available for decommissioning, while an additional 12 miles could be decommissioned

following vegetation and prescribed fire treatments.

Currently, these closed routes continue to provide a pathway for sediment delivery into the stream 

system and remain a source of ongoing erosion. Decommissioning would provide a barrier thus 

allowing the roaded area to return to its natural state. In these areas, there would be an increase in 

vegetation, infiltration rates, soil stability, and a reduction in overland flow and soil loss. Soil 

conditions that are currently unsatisfactory within the roadbed would improve, with upward 

trends over the long term.

These alternatives provide for several other motorized transportation treatments, for which the 

following direct and indirect effects would be realized.

Construction of 3 to 5 miles of temporary roads that would be obliterated following vegetation 

treatments. Short-term temporary road construction would have negative impacts to the soil 

resource with removal of herbaceous vegetation and compaction during use. Subsequent 

obliteration should return the temporary road scar to its natural state. Construction and 

decommissioning of these temporary roads would result in 3.6 to 6.1 acres of new soil 

disturbance.

Approximately 4.2 miles of trail tread (3 feet wide) would remain on roads that are scheduled for 

decommissioning. This motorized treatment would have short-term impacts to the soil resource 

during decommissioning, long term impacts would remain from the trail tread. This would result 

in approximately 1.4 acres of long-term disturbance with possible connectivity to waterways.

Reopening of 13.8 miles of motorized routes to all vehicle types would result in long term

continued negative impacts to the soil resource. These closed routes are not currently 

decommissioned, with only a signed closure in place. Compaction, lack of infiltration, loss of soil 

productivity, and lack of vegetative ground cover would persist in the long term. This results in 

approximately 20.1 acres of continue commitment of the soil resource.

Addition of 4.2 miles of user-created routes to the motorized system would result in long-term 

impacts to the soil resource, similar to the above-mentioned reopening of motorized routes. This 

results in approximately 6.1 acres of continued commitment of the soil resource.

Reopen then close and/or decommission 34.5 miles of currently closed routes for vegetation 

and/or prescribed fire treatments (22.5 miles would be reclosed and 12 miles would be 

decommissioned) – This motorized treatment would have short-term negative impacts to the soil 

resource. Reopening a currently closed route would subject it to renewed compaction and 

removal of any vegetation gains it might have seen during its closure. Follow-up closure would 

negate these impacts; however, it may be a few years before this occurs. The roadbed scar would 

continue to result in some level of soil disturbance in the long term. Roads that would be 

decommissioned following treatments would see more benefit to the soil resource as they would 

be returned to their natural state, with an increase in vegetation, infiltration, and some restoration 

of soil fertility and productivity over the long term. This would affect approximately 51.6 total 

acres. Approximately 32.7 acres would realize benefits of being reclosed while 17.5 acres would 

realize benefits of decommissioning.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

122

Construction of 0.3 mile of all-terrain vehicle routes would have both positive and negative

impacts to the soil resource. The new routes are being constructed to avoid riparian areas, stream 

crossings, and perennial water. The reroutes would improve the soil and water resources in these 

areas over the long term. However, there would be 0.3 mile of new construction and commitment 

of 0.2 acre of the soil resource to the all-terrain vehicle routes. Overall, the positive outweighs the 

negative for soil and water resources as the soil, riparian, and water quality benefits are greater 

than the 0.2 acre of new disturbance across the landscape.

Reopening of 3.5 miles of previously closed routes for administrative use or single purpose use 

(Tucson Electric Power line access) would have negative impacts on soil resources over the long 

term, as these roads would not be decommissioned in the future. Compaction, lack of vegetation, 

reduce infiltration, and loss of soil productivity would persist on these routes. This amounts to 5.1 

acres of continued commitment of the soil resource.

Alternative B would have negative impacts between 87.5 to 90 acres to the soil resource, some of 

which may be mitigated by decommissioning. The same amount of acres would be impacted in 

alternative C. The 87.5 to 90 acres is more than alternative A and 27.2 acres more than alternative 

D.

Alternative C – Herbicide Utilization

Mechanical Vegetation Treatments

Alternative C vegetation treatments are similar to alternative B, with the exception of the 

following treatments:

• Herbicide may be used on 30 acres of meadow treatment that is currently proposed under 

alternative B for mechanical treatment.

• Herbicide may be used in lieu of, or in addition to, all 20,283 acres of rabbitbrush treatment 

areas proposed under alternative B, dependent on the site.

• Herbicide may be used on up to 8,000 acres of juniper that is currently proposed under 

alternative B for mechanical treatment.

Herbicide use is proposed in grasslands with rabbitbrush and woodlands with alligator juniper. 

Herbicides can persist in soils from a few months up to three years depending on soil type and 

environmental conditions such as soil moisture and temperature. The mobility of herbicides in the 

soil is determined by the adsorption capacity of the soil, soil moisture, and post application 

rainfall. Residence time in soils is also dependent soil texture and on the amount of microbial 

activity occurring in the soil. Soils associated with the rabbitbrush treatments have relatively high

clay contents, which will limit the mobility of the herbicide in the soil profile. Herbicide labels 

and application rates will be adhered to strictly. No negative effects to the soil condition or trend 

is anticipated with herbicide use in this alternative.

Direct and indirect effects are the same as described in the common to all alternative section, 

above for prescribed fire, stream, riparian, and erosion control, range management, and motorized 

transportation.

Alternative D

Direct and indirect effects are the same as described in the common to all alternative section, 

above for mechanical vegetation; prescribed fire; stream, riparian, and erosion control; and range 

management treatments.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

123

Motorized Transportation Treatments

Alternative D motorized transportation treatments are similar to alternative B, with the exception 

of the following treatments:

• There would be no reopening of 13.6 miles (19.8 acres) of motorized routes to all vehicle 

types under this alternative (0.2 mile would be reopened). Instead, these 13.6 miles would 

be added to road decommissioning miles, bringing the total decommissioned miles to 

approximately 130 (189 acres) in alternative D. One hundred and eighteen miles would be 

immediately available for decommissioning, while 12 miles would be ready for 

decommissioning following vegetation and prescribed fire treatments. There would be an 

increased benefit to the soil resource under alternative D, compared to alternatives B and C, 

with almost 14 more miles of road or approximately 20 acres returned to a natural state.

• There would be no addition of 4.2 miles of user-created routes to the motorized system. 

There would no long-term impacts to the soil resource from continued use of these routes. 

Currently, all user-created routes are planned to be returned to their natural state. 

Alternative D has more positive benefits to soil resources under this activity than do 

alternatives B and C.

• There would be no construction of 0.3 mile of all-terrain vehicle routes. There would be 

continued negative impacts to the soil resource at the crossing locations of Dillman Creek. 

However, no construction of a reroute would occur that would negatively impact soil 

resources in a new roadbed. This area would remain undisturbed and soil productivity, 

stability, and fertility would remain the same. The current location of the route would 

continue to have negative impacts over the long term to soil resources. Overall, the 

negative impacts of leaving this route in the same location would be greater than the 

negative impacts that 0.3 mile of new motorized trail would have, as the small disturbance 

of the landscape in uplands would not cause as lasting and continued harm as motorized 

stream crossings have to multiple resources.

Alternative D provides close to 30 more acres of positive benefit to the soil resource than 

alternatives B or C, but allows from between 60.6 to 63.1 more acres soil disturbance than 

alternative A.

Table 53 provides a comparison of acres of disturbance from motorized transportation treatments 

by alternative. These acres were derived from miles of road and assumed road widths (table 25).

Table 53. Acres of disturbance by alternative from motorized 

transportation treatments

Alternative

Total Acres of Disturbance Related to 

Motorized Transportation Treatments

Alternative A 0

Alternative B 86.7–89.2

Alternative C 86.7–89.2

Alternative D 60.6–63.1
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

124

Riparian Areas and Wetlands/Wet Meadows

Alternative A

Mechanical Vegetation Treatments

This alternative would not provide for any mechanical vegetation treatments to reduce heavy fuel 

loadings and promote conditions that reduce risk of uncharacteristic high-intensity wildfire. High 

soil burn severities are often a result of uncharacteristic wildfire, leading to severe negative 

effects to downstream water resources, including riparian areas, wetlands, and wet meadows. 

Increased overland flow as a result of hydrophobic soils and high soil burn severities can produce 

excessive flood flows in channels, from even minor precipitation events. Increased runoff 

volumes and velocities in streams lead to damaged streambanks and riparian areas, often 

changing channel geometry. Riparian vegetation can be severely damaged during these flood 

events and often take years to recover. Repeated flooding until watershed stabilization occurs in 

burned areas will continually set back riparian recovery. This was evident during field review of 

several streams on the western boundary of the Luna Restoration Project. These streams are 

currently experiencing increased water flows and sediment delivery from the effects of the 2011 

Wallow Fire. The increased flows are causing both vertical and lateral stream instabilities, which 

have led to tremendous losses of riparian vegetation and have compromised floodplain access.

These channels have experienced losses to much of their riparian habitat, with full recovery not 

expected for decades without restoration efforts. Without vegetation treatments, riparian areas 

will be placed at high risk for loss and associated downward trends in functionality in the event of 

an uncharacteristic wildfire.

The existing condition of riparian areas, wetlands, and wet meadows would continue and 

potentially decline under the no-action alternative. In areas where overstory densities are high, 

little long-term improvement in hydrologic flow regime will occur without mechanical treatment 

or other vegetation treatment methods. Wildfires in untreated areas pose a greater risk of negative 

impacts to riparian areas, wetlands, and wet meadows than wildfire occurring after 

implementation of vegetation treatments in alternatives B, C, and D.

Prescribed Fire Treatments

Lack of prescribed fire treatments would result in effects similar to those noted above in the

“Mechanical Vegetation Treatments” section. Not implementing prescribed fire treatments will 

continue to allow heavy fuel loading in the understory. As understory fuels build up and tree 

density and cover increases, the risk of higher intensity, uncharacteristic wildfire increases as well 

as the potential for high soil burn severity. The resultant loss of canopy cover, ground cover, and 

organic debris on the soil surface, together with the possible occurrence of hydrophobic soil 

layers in these areas, would likely lead to considerable increases in soil erosion, storm runoff 

response, and sediment movement into waterways. This would result in a greater risk of negative 

impacts to riparian areas, wetlands, and wet meadows under alternative A compared to all action 

alternatives.

Stream, Riparian, and Erosion Control Treatments

Restoration activities to address ongoing negative impacts to streams and riparian areas would not 

be implemented under alternative A.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

125

Effects Common to Alternatives B, C, and D

Mechanical Vegetation Treatments

Current conditions of riparian areas, wetlands, and wet meadows would be maintained or 

improved with the proper implementation of best management practices.

Similar to the “Soils” and “Water Quality and Quantity” sections, areas across the project area 

with dense canopies and heavy coarse woody debris loading in the understory would see 

enhancement from vegetation treatments. Restoration thinning would reduce the risk of 

uncharacteristic wildfire that harms riparian function. Meadow thinning treatments are planned in 

upland meadows and terraces adjacent to riparian areas. These treatments are designed to thin out 

conifers that are encroaching upon riparian systems and not for commercial purposes. Limited 

equipment would be used in these area with no conifers removed that provide for bank stability. 

Piles would be located outside floodplains.

Heavy equipment used in vegetation treatments is not expected to be used near riparian areas or 

within wetlands or wet meadows. There may be some temporary increases in runoff and soil 

movement related to ground cover and soil disturbance from mechanical thinning and skidding 

operations, as well as from the use of existing roads by logging equipment. Skid trails, staging 

areas and landing sites will be scarified and seeded as necessary to reestablish vegetative cover. 

This should reduce the potential for erosion and sedimentation that could originate from these 

areas and move downstream. Buffer strips have been incorporated into the Best Management 

Practices and design features to provide protection of waterways and riparian areas. Mowing of 

rabbitbrush under this alternative is not expected to have any adverse impacts to riparian or 

wetland resources. These activities are not proposed near these sensitive resources. With proper 

implementation of best management practices and design features, riparian and wetland resources 

would be protected from both short-term and long-term negative impacts.

It is anticipated that current conditions of riparian areas, wetlands, and wet meadows would be 

maintained with implementation of mechanical vegetation treatment, with a lowered risk for 

long-term negative impacts as a result of uncharacteristic wildfire and encroachment of tree 

species.

Prescribed Fire Treatments

Prescribed fire treatments would result in effects similar to those noted in the “Mechanical 

Vegetation Treatments” section. Heavy fuel loading would be reduced in the understory, lowering 

the risk of uncharacteristic wildfire, and reducing the possibility for high soil burn severity.

Best management practices and design features restrict the location of pile sites from waterways, 

riparian areas, and wetlands. Pile burning would not impact these resources. This treatment would 

not impact riparian areas or wet meadows. Buffer distances are designed for landings and staging 

areas to provide adequate distance for ash and mobilized sediment to drop out prior to reaching 

stream courses.

Designed low-intensity wildfire in the areas of Dry Blue Creek, Frieborn Canyon, and the San 

Francisco Divide will limit the severity of impacts to soil resources in these locations. There are 

not expected to be negative impacts to downstream riparian resources, with a lessening of risk to 

high-severity, uncharacteristic wildfire in these areas.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

126

The prescribed fire activities would help reduce fuel loading in the understory, thus reducing the 

risk from uncharacteristic wildfire, providing for long-term protection for riparian and wetland 

resources.

Stream, Riparian, and Erosion Control Treatments

Under all action alternatives, a suite of restoration activities to improve water quality and quantity 

are planned in streams, riparian areas, and uplands to improve degraded conditions. The 

following would be the effects to riparian areas, wetlands, and wet meadows with implementation 

of proposed projects:

• Upgrading, relocating, or hardening of existing stream crossings – Implementation of these 

actions will provide positive benefits to riparian areas, wetlands, and wet meadows. Similar 

to positive benefit to water quality and quantity, hardening of crossings will help to 

alleviate impacts to native vegetation growing on the approaches. Less sediment and 

gravels will be transported downstream of the crossing, which impacts vigor of different 

types of vegetation. While riparian woody plants may prefer coarser substrate, herbaceous 

vegetation may not. Several of the proposed crossings include small bridge designs and 

French drains that will enhance wet meadow habitats or avoid them altogether. This activity 

poses a positive benefit to riparian areas, wetlands, and wet meadows.

• Removal of encroaching conifers in riparian areas and upland wet meadows – Removal of 

conifers that are currently encroaching into floodplains, riparian areas, and fringes of the 

wet meadows would free up available water, nutrients, and energy that could be used by 

riparian and wetland species. This would also lower the risk these sites currently have for 

ecological conversion to upland vegetation species, which would reduce wetland and 

riparian habitat within the project area. This activity protects riparian areas, wetlands, and 

wet meadows.

• Construction of ungulate exclosures in riparian areas and degraded uplands – This activity 

will have positive benefits to riparian areas and wetland/wet meadows in the degraded 

riparian areas and upland sites that have been identified for restoration needs. Effects are 

similar to those under “Water Quality and Quantity.” The areas proposed for exclusion have 

a suite of additional restoration activities (riparian planting, stream stabilization, seeding) 

that will be implemented to improve resource conditions. By alleviated grazing pressure 

within these areas, it will provide a needed period of rest and recovery for riparian woody 

and herbaceous vegetation to grow, upland vegetation to recover, and stream banks to 

stabilize. These restoration efforts, combined, will aid in reversing erosion, lack of ground 

cover, and destabilized channels. Riparian areas, wetlands, and wet meadows will benefit 

over the long term. It will likely take several years for these improvements to be realized.

• Construction of stream and wet meadow stabilization structures – This activity would allow 

stabilization techniques to be employed on several degraded stream reaches and meadows 

throughout the project area. These activities will aid in restoring stream banks, and channel 

shape, form, and function back to proper functioning conditions. Sediment input from 

eroding banks would be reduced, channels would narrow, and flows would be reduced, 

allowing for an increase in productivity and vigor of riparian and wetland vegetation.

• Riparian tree planting – Riparian tree planting is proposed in locations where there is 

currently lack of riparian woody vegetation and streambank instability, leading to higher 

water temperatures and movement of sediment into the stream. By restoring riparian 

vegetation to these areas, the increased shade would help to reduce stream temperatures. 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

127

The increased deep root system provided by these types of plants would aid in bank 

stability, helping to improve channel shape, form, and function, thus providing for stream 

stabilization and moving these systems in an upward trend and closer to proper functioning 

condition.

• Reconstruction of Head of Ditch irrigation diversion – A permanent diversion is planned at 

the current location for Head of Ditch to eliminate the need for repeated implementation of 

a native soil push-up dam that diverts all of the water from the San Francisco River (spring 

to fall). The new facility design would minimize activity in the active channel once it is 

constructed, thus reducing impacts to riparian vegetation in the immediate vicinity. The 

current diversion takes all of the stream flow for much of the summer months, with 

exception of flooding events. The new diversion would provide an opportunity for water 

right owners to leave their share of water in the river if they do not need it for irrigation. 

While this may not occur immediately, the new design provides the opportunity for some 

water to remain in the channel yearlong, thereby increasing water availability for riparian 

species yearlong.

• Construction of all-terrain vehicle barriers to protect wet meadows – This activity is 

planned to deter motorized traffic into sensitive resource locations where the road is 

currently closed but unauthorized traffic persists. The barriers would help protect wet 

meadows that are currently receiving subject to rutting and disturbance of associated hydric 

soils. Wet meadow conditions would improve fairly quickly with elimination of 

unauthorized use, as compaction and rutting would be eliminated, infiltration and 

percolation would be improved, and movement of sediment would be reduced. This activity 

would move these systems quickly in an upward trend towards proper functioning 

condition.

• Maintenance and implementation of new erosion stabilization structures – There are 

currently more than 160 erosion control structures that were constructed within the Luna 

Restoration Project area over the last several decades. Many of these are in upland areas, 

away from riparian areas, wetlands, and wet meadows, however, there are several located 

in upland wet meadows. Maintenance, reconstruction, or both of these upland wet meadow 

structures would ensure the longevity of the structures and lower the risk of them breaching 

which could result in headcutting and subsequent dewatering of the meadow. This activity 

will be a benefit to these fragile ecosystems and maintain functional conditions, improve

functional conditions, or both.

• Native grass seeding in degraded uplands – These activities are planned primarily in 

uplands that would be adjacent to riparian systems. Improvement in these upland areas 

would benefit the downstream riparian areas by restoring herbaceous vegetation, which will 

slow down overland flows and filter water. A reduction in flow velocities and dropping out 

of sediment prior to reaching the channels will aid in improving riparian condition and 

moving these areas in an upward trend towards proper functioning condition.

• Water quality improvements in campgrounds – Existing road and campsite drainage that 

leads directly to the adjacent waterways of San Francisco River and Trout Creek would be 

improved, thus reducing or eliminating a direct input of sediment. This would also provide 

a buffer for riparian vegetation from excessive flows off roads and campsites, thus 

providing riparian protection. This activity would provide improvement to riparian 

conditions.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

128

Range Management Treatments

The action alternatives propose 14 additional watering sites within the project area. While this 

activity is expected to improve livestock distribution in allotments within the project areas, there 

are not expected to be any impacts to riparian areas, wetlands, and wet meadows. New water sites 

are planned in upland locations and no streamside watering sites are being eliminated.

Motorized Transportation Treatments

Road improvements, reroutes, and decommissioning activities proposed under the action 

alternatives are designed to protect and improve riparian areas, wetlands, and wet meadows. Road 

improvements are planned in areas where current routes are leading to erosion and contributing to 

movement of sediment into the stream system. Reroutes have been planned in areas where the 

current route crosses live streams and/or riparian areas. Reroutes would be in more stable 

locations with less water and soil resource impacts. Decommissioning is planned where currently 

closed routes are no longer necessary for forest management activities. Currently, these closed 

routes continue to provide a pathway for sediment delivery into the stream system and remain a 

source of ongoing erosion. Local traffic continues to use these closed routes as they lack an 

effective closure barrier. Decommissioning would provide the necessary barrier and serve as a 

deterrent for continued use, thus allowing the roaded area to return to its natural state. In these 

areas, there would be an increase in vegetation on these former routes, an increase in infiltration 

rates, and increase in soil stability, and a reduction in overland flow and soil loss. Soil conditions 

that are currently unsatisfactory within the roadbed would improve, with upward trends over the 

long term.

There are several other motorized transportation treatments, for which the following direct and 

indirect effects would be realized for riparian areas, wetlands, and wet meadows.

• Construction of 3-5 miles of temporary roads which would be obliterated following 

vegetation treatments – These motorized treatments are not planned to occur in riparian 

areas, wetlands, and wet meadows. Best management practices and design features are 

incorporated into the project that would prevent indirect impacts from these temporary 

roads from impacting downstream riparian areas and wetlands. There would be no change 

to riparian functional condition as a result of this treatment.

• Approximately 4.2 miles of trailhead would be left on roads that are scheduled for 

decommissioning, with a trail tread of approximately 3 feet in width remaining– This 

motorized treatment would not have detrimental impacts to riparian areas, and wetland/wet 

meadows. Decommissioning of a majority of the roadbed would lessen direct connections 

to riparian areas. The remaining tread would be designed with best management practices 

and design features that would mitigate water flow from the trail. This treatment is not 

anticipated to have any measurable impact to the functionality of riparian areas, wetlands, 

or wet meadows.

• Reopening of 13.8 miles of motorized routes to all vehicle types – This motorized treatment 

would result in little negative impact to riparian resources. One of the routes proposed 

crosses a small wetland area of Dillman Creek. This crossing is proposed for hardening, 

with uninhibited water passage through the crossing. These two treatments, implemented in 

tandem will minimize negative impacts to this riparian area. The crossing is currently 

receiving unauthorized use so this treatment will be an improvement over alternative A. 

The other routes included in the 13.8 miles do not cross riparian areas, wetlands, or wet 

meadows, thus would have no negative impacts to this resource area.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

129

• Addition of 4.2 miles of user-created routes to the motorized system – The user-created 

routes proposed for addition in this alternative were all evaluated in the field by Gila 

National Forest watershed personnel for resource concerns. None of these routes cross 

riparian areas, wetlands, or wet meadows. The addition of these miles is not anticipated to 

impact these resources.

• Reopen then close and/or decommission 34.5 miles of currently closed routes for 

vegetation and/or prescribed fire treatments (22.5 miles would be reclosed and 12 miles 

would be decommissioned) – This motorized treatment may have short-term minor impacts 

to riparian resources, where the current roadbed and riparian resources coincide. Reopening 

a currently closed route would subject it to renewed compaction and removal of any 

vegetation gains it might have seen during its closure, thus increasing flow velocities down 

the roadbed and possibly into downstream waterways. Follow-up closure would negate 

these impacts, however it may be a few years before this occurs. The roadbed scar would 

continue to result in some level of disturbance in the long term. Roads that would be 

decommissioned following treatments would see more benefit to the soil resource as they 

would be returned to their natural state, with an increase in vegetation, increase in 

infiltration, and some restoration of soil fertility and productivity over the long term. While 

long-term impacts are not expected with this treatment, until the roads are decommissioned, 

benefits to riparian areas, wetlands and wet meadows would not occur.

• Construction of 0.3 mile of all-terrain vehicle routes – This motorized treatment would 

have positive impacts to riparian resources. The locations of these miles are in Dillman 

Creek where the current route path crosses several times. The reroute will avoid several 

stream crossings, thus eliminating direct effects to the riparian resource. A reduction in 

stream crossings will help improve riparian resource functionality. The new reroute is being 

constructed to avoid riparian areas, stream crossings, and perennial water.

• Reopening of 3.5 miles of previously closed routes for administrative use (Tucson Electric 

Power line access) – This motorized treatment is not anticipated to have negative impacts 

to riparian areas, wetlands, and wet meadows as the locations do not coincide.

Alternative C - Herbicide Utilization

Mechanical Vegetation Treatments

This alternative’s vegetation treatments are common to all action alternatives with the exception 

applying herbicide treatments on 30 acres of meadow; appropriate areas of 20,283 acres of 

rabbitbrush; and up to 8,000 acres of juniper.

Herbicide use is proposed in upland rangelands and woodlands. Riparian areas, wetlands and wet 

meadow areas are not expected to be impacted by use of herbicide, as their locations will not 

coincide. Application of best management practices will avoid negative effects to waterways. 

These include mitigation measures such as buffering waterways, avoiding precipitation events, 

limit use to low winds, and identification and avoidance of any drinking water supplies and 

sensitive aquatic species locations. No negative impacts to riparian areas and wetlands/wet 

meadows are anticipated with implementation of alternative C.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

130

Alternative D

Motorized Transportation Treatments

This alternative’s motorized transportation treatments are similar to all action alternatives with 

the exception of the following treatments:

• There would be no reopening of 13.6 miles of motorized routes under this alternative. Only

0.2 mile would be reopened. Instead, these 13.6 miles would be added to road 

decommissioning miles, bringing the total decommissioned miles to approximately 130 in 

alternative D. Approximately 118 miles would be immediately available for 

decommissioning, while 12 miles would be ready for decommissioning following 

vegetation and prescribed fire treatments. There would be an increased benefit, although 

minor, to the riparian areas, wetlands, and wet meadows under alternative D, compared to 

alternatives B and C. Although almost 14 more miles of road would be returned to a natural 

state, very few of these miles currently are within or adjacent to riparian areas or wet 

meadows.

• There would be no addition of 4.2 miles of user-created routes to the motorized system. 

There would no long-term impacts to the riparian areas, wetlands, and wet meadows from 

continued use of these routes. Currently, all user-created routes are planned to be returned 

to their natural state. Some short-term impacts may occur during obliteration of these routes 

where they are within or adjacent to riparian areas or wet meadows. Alternative D has more 

positive benefits to these resources under this activity than do alternatives B and C;

however, only approximately one-quarter mile of these proposed additions are within a 

riparian area in Dillman Creek.

• There would be no construction of 0.3 mile of all-terrain vehicle routes. There would be 

continued negative impacts to the riparian areas, wetlands, and wet meadows crossing 

locations of Dillman Creek. The proposed reroute is outside of drainages with no impacts to 

riparian areas, wetlands, and wet meadows. Leaving this route in the same place would 

continue to provide long-term negative impacts to these resources.

Water Quality and Quantity

Alternative A

Mechanical Vegetation Treatments

This alternative would not provide for any mechanical vegetation treatments to reduce heavy fuel 

loadings and promote conditions that reduce risk of uncharacteristic high-intensity wildfire. High 

soil burn severities are often a result of uncharacteristic wildfire, leading to severe negative 

effects to water quality and quantity.

Post fire effects would result in increased runoff volumes and velocities in streams leading to 

damaged streambanks and riparian areas, and pose risks to downstream values such as in-channel 

structures and infrastructure adjacent to and/or within floodplains. Several streams on the western 

boundary of the Luna Restoration Project area are currently experiencing increased water flows 

and sediment delivery from the effects of the 2011 Wallow Fire. The increased flows are causing 

both vertical and lateral stream instabilities, which contribute negatively to water quality, in 

particular, temperature and turbidity. Stream flows are not able to dissipate effectively, thus runoff 

rates and velocities are high. Stabilizing riparian vegetation has been scoured away causing 

detachment and movement of channel and bank material.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

131

In addition, within the project area, Centerfire Creek and the San Francisco River do not meet 

New Mexico State water quality standards. Any future high-intensity wildfires would hamper any 

water quality improvement to these streams.

The existing condition of water quality and quantity would continue and potentially decline under 

the no-action alternative. In areas where overstory densities are high, little long-term 

improvement in hydrologic flow regime will occur without mechanical treatment or other 

vegetation treatment methods. Wildfires in untreated areas pose a greater risk of negative impacts 

to water quality, channel stability, and changes to hydrologic regimes than wildfire occurring after 

implementation of vegetation treatments in alternatives B, C, and D.

Prescribed Fire Treatments

Lack of prescribed fire treatments would result in effects similar to those noted above under 

“Mechanical Vegetation Treatments.” Not implementing prescribed fire treatments will continue 

to allow heavy fuel loading in the understory. As understory fuels build up and tree density and 

cover increases, the risk of higher intensity, uncharacteristic wildfire increases as well as the 

potential for high soil burn severity. The resultant loss of canopy cover, ground cover, and organic 

debris on the soil surface, together with the possible occurrence of hydrophobic soil layers in 

these areas, would likely lead to considerable increases in soil erosion, storm runoff response, and 

sediment movement into waterways. This would result in a greater risk of negative impacts to 

water quality under alternative A compared to all action alternatives, with potential for 

destabilized hydrologic regime.

Stream, Riparian, and Erosion Control Treatments

Restoration activities to address ongoing negative impacts to streams and riparian areas would not 

be implemented under alternative A.

Motorized Transportation Treatments

This alternative results in the least amount of new disturbance related to motorized transportation 

as equipment would not be used for road-related ground-disturbing activities. However, the 

absence of road improvements, road decommissioning, or reroutes under this alternative would 

continue to allow negative impacts to water quality and water quantity to occur in many locations 

across the project area over the long term.

The lack of road decommissioning would continue to allow currently closed routes to remain on 

the landscape. Current road closures do not immediately eliminate hydrologic impacts, especially 

when unauthorized use continues to occur. Rather, the disturbed surface takes years to stabilize, 

which depends on the level of success in the closure, underlying soils, vegetative regrowth, and 

other factors. Roads, including those behind gates and dropped from inventories, continue to 

produce sediment until they are totally revegetated. The primary effect to water quality related to 

roads is sedimentation originating from road erosion. Roads are a major source of sediment and 

contribute more off-site sediment than any other land management activity (Gibbons and Salo 

1973, Meehan 1991). Numerous researchers have established that roads are a major source of 

sediment delivered to streams in otherwise relatively undisturbed watersheds, such as forests and 

rangelands. Because routes intercept and concentrate water the closer they are to a drainage 

channel, the quicker water is delivered to the stream channel, potentially increasing runoff 

response. Roads can also disrupt a watershed’s natural hydrologic flow by capturing surface and 

subsurface runoff on hillslopes. Unmitigated, the captured runoff can be delivered to stream 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

132

systems more rapidly, at higher rates of flow, and can impact the timing and magnitude of natural 

stream flows. Stream channels will respond to increases in flow rates by widening or deepening 

in order to carry these greater flow rates. Roads directly alter natural sediment and hydrologic 

regimes by changing streamflow patterns and amounts, sediment loading, transport, and 

deposition, channel morphology and stability, water quality and riparian conditions within a 

watershed (Gibbons and Salo 1973, Dunne and Leopold 1978, Copstead et al. 1997). This can 

lead to higher peak flows, which may then lead to a higher risk of channel erosion.

The closed routes that are proposed for decommissioning in all action alternatives would continue 

to discharge runoff and sediment to adjacent waterways in this alternative, in particular where the 

roadbed is within 300 feet of a stream, or has inadequate drainage features, or is hydrologically 

connected to the stream network. Road densities would not be decreased thereby reducing 

potential for improved hydrologic flow regimes. This alternative provides the least benefit to 

water quality and quantity than any of the action alternatives due to lack of decommissioning 

alone.

Effects Common to Alternatives B, C, and D

Mechanical Vegetation Treatments

For all action alternatives, where water quality and quantity are currently meeting State water 

quality standards and display a stable flow regime, these indicators would continue to be 

maintained or improved with the proper implementation of best management practices and design 

features.

Similar to the “Soils” discussion for all action alternatives, areas across the project area with 

dense canopies and heavy coarse woody debris loading in the understory would see enhancement 

from vegetation treatments. Vegetative ground cover would be reduced, spatially rearranged, or 

both by proposed vegetation treatments. Restoration thinning would reduce the risk of highseverity wildfire that can have severe impacts to water quality as described in alternative A.

Heavy equipment used in vegetation treatments will cause varying degrees of soil compaction 

which can temporarily increase water runoff and delay, reduce, or both the establishment and 

growth of desired herbaceous vegetation. Short-term increases in soil loss related to ground cover 

and soil disturbance are expected from mechanical thinning and skidding operations, as well as 

from the use of existing roads by logging equipment, which can pose a threat to water quality. 

Project-specific best management practices and design features are designed to mitigate negative 

impacts from these activities. There is not expected to be long-term negative impacts to water 

quality or quantity as a result of mechanized vegetation treatments.

Mowing of rabbitbrush is not expected to have any adverse impacts to water quality and quantity. 

This activity will be done with rubber-tired equipment, with organic matter generated from 

mowing left largely in place, serving as organic matter and mulch across the land surface. These 

areas of treatment are fairly flat, thus there is not expected to be increases in runoff generated 

from these treatments.

It is anticipated that overall water quality condition and trends and hydrologic regimes across the 

project area will be maintained and the risk lowered for long-term negative impacts as a result of 

uncharacteristic wildfire.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

133

Prescribed Fire Treatments

Prescribed fire treatments would result in effects similar to those noted above under “Mechanical 

Vegetation Treatments.” Heavy fuel loading would be reduced in the understory, lowering the risk 

of uncharacteristic wildfire, and reducing the possibility for high soil burn severity. Prescribed 

fire would initially reduce the level of organic debris and mobilize some sediment and nutrients.

However careful attention to burning conditions during a prescribed fire is designed to limit the 

potential of short-term loss of soils and nutrients.

Pile burning will likely result in localized, negative effects to soil resources as described under 

the “Soils” section. Some effects of pile burning could also cause a localized decrease in 

infiltration and an increase in runoff. Buffer distances are designed for landings and staging areas 

to provide adequate distance for ash and mobilized sediment to drop out prior to reaching stream 

courses.

Designed low-intensity wildfire in the areas of Dry Blue Creek, Frieborn Canyon, and the San 

Francisco Divide will limit the severity of impacts to soil resources in these locations. There are 

not expected to be negative impacts to water quality and quantity, with a lessening of risk to highseverity, uncharacteristic wildfire in these areas.

The prescribed fire activities would help reduce fuel loading in the understory, thus reducing the 

risk from uncharacteristic wildfire, providing for long-term protection for water quality and 

hydrologic regimes.

Stream, Riparian, and Erosion Control Treatments

A suite of restoration activities to improve water quality and quantity are planned to improve 

currently degraded conditions in streams, riparian areas, and uplands. The following would be the 

effects to water quality and quantity with implementation of proposed projects.

• Upgrading, relocating, or hardening existing stream crossings – Implementation of these 

actions will provide positive benefits to water quality and quantity. Hardening of crossing 

will help to alleviate the short-term negative impacts of vehicle tires disturbing and 

mobilizing stream bottom sediments. Improvement at these crossings will also aid 

hindering the direct flow path of water into the stream by either filtering out some of the 

sediment or relocating the crossing to a more stable location. Crossings will not be 

eliminated thus there will still be a hydrologic connection of water and sediment into the 

stream systems, at a reduced rate. This will be an improvement to water quality and water 

quantity from alternative A.

• Removal of encroaching conifers in riparian areas and upland wet meadows – Removal of 

conifers that are currently encroaching into floodplains, riparian areas, and fringes of the 

wet meadows would free up available water, nutrients, and energy that could be used by 

riparian and wetland species. This would also lower the risk these sites currently have for 

ecological conversion to upland vegetation species, which would reduce wetland and 

riparian habitat within the project area. This activity protects hydrologic regimes in these 

areas.

• Construction of ungulate exclosures in riparian areas and degraded uplands – This activity 

will be a positive benefit to water quality and quantity in the degraded riparian areas and 

upland sites that have been identified for restoration needs. The areas proposed for 

exclusion have a suite of additional restoration activities (riparian planting, stream 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

134

stabilization, seeding) that will be implemented to improve resource conditions. By 

alleviating grazing pressure within these areas, it would provide a needed period of rest and 

recovery for riparian woody and herbaceous vegetation to grow, upland vegetation to 

recover, and stream banks to stabilize. All of these restoration efforts, combined, will aid in 

reversing erosion, lack of ground cover, and destabilized channels. Water quality and 

quantity will benefit over the long term. Streams currently not meeting New Mexico’s State 

water quality standards would improve over the long term, in particular where the probable

causes for listing have been identified as sedimentation, siltation, and temperature. 

Increased vegetation within these areas will also reduce runoff rates, allowing more 

subsurface water to remain in place, improving water quantity and stabilizing hydrologic 

regimes. It will likely take several years for these improvements to be realized.

• Construction of stream and wet meadow stabilization structures – This activity would allow 

stabilization techniques to be employed on several degraded stream reaches and meadows 

throughout the project area. These activities will aid in restoring stream banks, and channel 

shape, form, and function back to proper functioning conditions. Sediment input from 

eroding banks would be reduced, channels would narrow, and flows would be reduced, 

allowing for improvement in water quality (decreased temperature and sedimentation) and 

water quantity (reduction in flow velocities).

• Riparian tree planting – Riparian tree planting is proposed in locations where there is 

currently lack of riparian woody vegetation and streambank instability, leading to higher 

water temperatures and movement of sediment into the stream. By restoring riparian 

vegetation to these areas, the increased shade would help to reduce stream temperatures. 

The increased deep root system provided by these types of plants would aid in bank 

stability, helping to improve channel shape, form, and function, thus providing for stream 

stabilization. Water quality and quantity under this alternative would improve with this 

activity.

• Reconstruction of Head of Ditch irrigation diversion – A permanent diversion is planned at 

the current location for Head of Ditch to eliminate the need for repeated implementation of 

a native soil push-up dam that diverts all of the water from the San Francisco River (spring 

to fall). The new facility is planned to minimize maintenance, provide an easy way to 

switch flows from the main channel to the diversion, minimize effects on the stream and 

aquatic biota, and to eliminate water ponding behind the facility. The current diversion 

takes all of the stream flow for much of the summer months, with exception of flooding 

events. The new diversion would provide an opportunity for water right owners to leave 

their share of water in the river if they do not need it for irrigation. While this may not 

occur immediately, the new design provides the opportunity for some water to remain in the 

channel yearlong, thereby improving water quality and water quantity. In addition, the 

improvement to the diversion structure will improve stream channel geometry and reduce 

negative impacts to the site caused by repeated rebuilding of the push-up dam.

• Construction of all-terrain vehicle barriers to protect wet meadows – This activity is 

planned to deter motorized traffic into sensitive resource locations where the road is 

currently closed but unauthorized traffic persists. The barriers would help protect wet 

meadows that are currently receiving loss of soil productivity and soil compaction due to 

this unauthorized use. Water quality and water quantity would benefit from these barriers, 

as compaction and rutting would be eliminated, infiltration and percolation would be 

improved, and movement of sediment would be reduced. This ongoing threat to the 

identified wet meadows would be removed.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

135

• Maintenance and implementation of new erosion stabilization structures – There are 

currently more than 160 erosion control structures that were constructed within the Luna 

Restoration Project area over the last several decades. Lack of maintenance on these 

structures has led them to reach storage capacity, breach, new headcuts and gullies, or a 

combination of these things. Maintenance of existing structures and construction of new 

structures will reduce erosion, control headcutting and gullying, and stabilize uplands 

where lack of stability and excessive flows have led to severe erosion issues. This activity 

will reduce sedimentation and siltation downstream into waterways and provide for 

favorable conditions of flow, thereby improving both water quality and water quantity.

• Native grass seeding in degraded uplands – Negative impacts to water quality and quantity 

in currently degraded uplands would be reversed if herbaceous ground cover increases on 

these sites. Herbaceous cover would slow down overland flow, thereby improving 

infiltration and reducing erosive processes. Some of these sites are severely denuded of 

vegetation so this would be a slow process, with improvement over the long term to water 

quality and quantity.

• Water quality improvements in campgrounds – Existing road and campsite drainage that 

currently leads directly to the adjacent waterways of San Francisco River and Trout Creek, 

would be improved, thus reducing or eliminating a direct input of sediment. This 

interrupted connection to the drainage would slow down storm-generated runoff to these 

streams, providing for a stable hydrologic flow regime and reducing the opportunity for 

runoff related erosion. This activity would provide improvement to water quality and 

hydrologic regimes under this alternative.

Range Management Treatments

There are 14 additional watering sites proposed within the project area. In watering locations 

where the water source is spring fed, less pressure on these springs may occur. The proposed 

treatments, however, do not provide fencing any of these areas, but rather provide alternate water 

sources to reduce pressure. This may relieve some water quality and quantity impacts; however,

they may not be measurable. Effects to water quality and quantity are expected to improve 

slightly or not at all under all action alternatives.

Motorized Transportation Treatments

Road improvements, reroutes, and decommissioning activities are designed to improve water 

quality and quantity over the long term. Road improvements are planned in areas where current 

routes are leading to erosion and contributing to movement of sediment into the stream system. 

Reroutes have been planned in areas where the current route crosses live streams, riparian areas, 

or both. Reroutes would be in more stable locations with less water and soil resource impacts. 

Approximately 116 miles of decommissioning is planned where currently closed routes are no 

longer necessary for forest management activities, with 104 miles being immediately available 

for decommissioning. The additional 12 miles would be ready for decommissioning following 

vegetation and prescribed fire treatments. Currently, these closed routes continue to provide a 

pathway for sediment delivery into the stream system and remain a source of ongoing erosion. 

Local traffic continues to use these closed routes as they lack an effective closure barrier. 

Decommissioning would provide the necessary barrier and serve as a deterrent for continued use, 

thus allowing the roaded area to return to its natural state. Proper road obliteration or 

decommissioning, which returns the road bed and fill slope to the contours of the land and 

replaces culverts with natural stream channels, offers the best opportunity to restore health to 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

136

heavily roaded watersheds and to aquatic habitat downstream. In these areas, there would be an 

increase in vegetation on these former routes, an increase in infiltration rates, and increase in soil 

stability, and a reduction in overland flow and soil loss. Long-term sediment reduction would 

benefit from these activities. Sediment production from roads diminishes over time after proper 

closure and nonuse. Water quality would see improvements and hydrologic regimes would no 

longer be influenced by water flow from the roadbeds’ unnatural flow paths.

There are several other motorized transportation treatments, for which the following direct and 

indirect effects would be realized:

• Construction of 3 to 5 miles of temporary roads which would be obliterated following 

vegetation treatments – This motorized treatment would have negative short-term impacts 

to water quality and water quantity with removal of herbaceous vegetation and compaction 

during use. These temporary roads can provide a conduit for surface flows to be directed 

down the roadbed rather than dissipated across the land surface. Subsequent obliteration 

should return the temporary road scar to its natural state within a short period of time with 

proper implementation of best management practices and design features.

• Approximately 4.2 miles of trailhead would be left on roads that are scheduled for 

decommissioning, with a trail tread of approximately 3 feet in width remaining – This 

motorized treatment would have benefits to water quality and quantity with 

decommissioning of a majority of the roadbed. Some impacts to water quality and quantity 

may occur as flows may be directed down the remaining trail bed. However, proper 

implementation of trail tread and drainage should alleviate these impacts. There would be 

minimal long-term disturbance related to the trail tread that may have possible connectivity 

to waterways.

• Reopening of 13. 8 miles of motorized routes to all vehicle types – This motorized 

treatment would result in some long-term negative impacts to water quality and quantity, 

somewhat similar to what is occurring under alternative A. These closed routes are not 

currently decommissioned, with only a signed closure in place. Unauthorized use continues

on closed routes, albeit less than an open route receives. The current condition of these 

routes still provides a conduit for surface water to travel down these routes into waterways. 

Field review in 2015 determined that most of these routes were in upland areas, with little 

impacts to water quality and quantity. One route, however, does cross Dillman Creek in a 

perennial location. This crossing is proposed for hardening under alternatives B and C, 

which would mitigate concerns to water quality and quantity. Soil compaction and a lack of 

vegetation would still be present on all of these routes. None of these routes would realize 

the improvements to water quality and quantity that decommissioning would offer. 

Compaction, lack of infiltration, loss of soil productivity, and lack of vegetative ground 

cover would persist in the long term.

• Addition of 4.2 miles of user-created routes to the motorized system – This motorized 

treatment would result in some long-term impacts to water quality and water quantity. A 

field review of these roads determined that little water resource issues were currently 

occurring on these routes. They were located in upland locations, and would have effects 

similar to those in the above-mentioned reopening of motorized routes.

• Reopen then close and/or decommission 34.5 miles of currently closed routes for 

vegetation and/or prescribe fire treatments (22.5 miles would be reclosed and 12 miles 

would be decommissioned) – This motorized treatment would have some short-term and 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

137

long-term negative impacts to water quality and quantity. Reopening a currently closed 

route would subject it to renewed compaction and removal of any vegetation gains it might 

have seen during its closure. Follow-up closure would negate these impacts; however, it 

may be a few years before this occurs. The roadbed scar would continue to result in some 

level of water transport down its surface over the long term if it is not decommissioned. 

Roads that would be decommissioned following treatments would see long-term benefits to 

water quality and quantity as they would be returned to their natural state, with an increase 

in vegetation, increase in infiltration, and disconnected paths to waterways over the long 

term. Unauthorized use remains a concern on closed roads that would not be 

decommissioned.

• Construction of 0.3 mile of all-terrain vehicle routes – This motorized treatment would 

have positive impacts to water quality and quantity. The new route is being constructed to 

avoid riparian areas, stream crossings, and perennial water of Dillman Creek. Local riding 

groups have expressed support in using an alternative route if available rather than 

continuing unauthorized use of Dillman Creek. The reroute provides alternate access to 

desirable locations without negative resource effects to the stream.

• Reopening of 3.5 miles of previously closed routes for administrative use (Tucson Electric 

Power line access) – This motorized treatment would have minor negative impacts to water 

quality and water quantity over the long term as these roads would not be decommissioned 

in the future. Compaction, lack of vegetation, reduced infiltration, and loss of soil 

productivity would persist on these routes.

Alternative C – Herbicide Utilization

Mechanical Vegetation Treatments

This alternative’s vegetation treatments are common to all action alternatives with the exception 

applying herbicide treatments on 30 acres of meadow; appropriate areas of 20,283 acres of 

rabbitbrush; and up to 8,000 acres of juniper.

Herbicide use is proposed in upland rangelands and woodlands. Best management practices and 

design features have been incorporated into the Luna Restoration Project to protect water quality. 

These include mitigation measures such as buffering waterways, avoiding precipitation events, 

limit use to low winds, and identification and avoidance of any drinking water supplies and 

sensitive aquatic species locations. No negative impacts to water quality are anticipated with 

implementation of alternative C.

No changes are anticipated to water quantity with the implementation of herbicide. Water use by 

rabbitbrush and juniper would be replaced with water use by herbaceous plants, if the herbicide 

treatment is effective. There would be no measurable change to water quantity; hydrologic 

regimes would remain unchanged.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

138

Alternative D

Motorized Transportation Treatments

This alternative’s motorized transportation treatments are similar all action alternatives with the 

exception of the following treatments:

• There would be no reopening of 13.6 miles of motorized routes to all vehicle types under 

this alternative (0.2 mile would be reopened). Instead, these 13.6 miles would be added to 

road decommissioning miles, bringing the total decommissioned miles to approximately 

130 in alternative D. One hundred and eighteen miles would be immediately available for 

decommissioning, while 12 miles would be ready for decommissioning following 

vegetation and prescribed fire treatments. There would be an increased benefit to the water 

quality and quantity under alternative D, compared to alternatives B and C, with almost 14 

more miles of road returned to a natural state.

• There would be no addition of 4.2 miles of user-created routes to the motorized system –

There would be no possible long-term impacts to water quality and quantity from continued 

use of these routes. Impacts currently are minor on these routes, with the exception of one 

crossing of Dillman Creek. This route would be obliterated as all user-created routes are 

planned to be returned to their natural state. Alternative D has more positive benefits to 

water quality and quantity under this activity than do alternatives B and C.

• There would be no construction of 0.3 mile of all-terrain vehicle routes – There would be 

continued negative impacts to water quality and water quantity at the crossing locations in 

Dillman Creek, similar to alternative A. The Dillman Creek route is currently closed 

however unauthorized use continues to occur.

Watershed Cumulative Effects

Watershed cumulative effects analyses are focused on the 6th-code watersheds of Canovas CreekCoyote Creek, Trout Creek, Stone Creek-San Francisco River, Dry Blue Creek, Spur Draw, SA 

Creek, Headwaters Centerfire Creek, Outlet Centerfire Creek, Big Canyon-San Francisco River, 

Hay Vega, and Cow Springs Draw as more than 2 percent of the project area was within these 

watersheds.

The existing conditions related to water quality, water quantity, aquatic habitats and biota, 

riparian areas, roads and trails, soils, range vegetation, forest cover, forest health, fire regime 

condition class, and invasive species within the Luna Restoration Project area contribute, in 

whole or part, to cumulative impacts on watershed condition. In 2015, 6th-code watershed 

condition classifications incorporated information related to twelve watershed indicators. This 

recent assessment provides a “baseline” at which to assess all of the action alternatives versus the 

alternative A.

Alternative A

Under alternative A, there would be no implementation of mechanical vegetation treatments; 

prescribed fire treatments; stream, riparian, and erosion control treatments; range management 

treatments; or motorized transportation treatments. Current watershed condition classifications 

(table 50) would remain the same, with no improvements to any of the watershed indicators. 

Watersheds with high concentrations of fuel loading would remain at risk of negative impacts to 

watershed health if uncharacteristic wildfire occurs.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

139

Implementation of alternative A would result in no change in cumulative impacts to watershed, 

soil and aquatic condition at the 6th-code level, and thus no change to watershed condition 

classification of any watershed.

Alternative B

Alternative B proposes implementation of mechanical vegetation treatments; prescribed fire 

treatments; stream, riparian, and erosion control treatments; range management treatments; or 

motorized transportation treatments. This alternative addresses forest and watershed health issues 

at a landscape scale. These activities do result in varying amounts of ground disturbance. Impacts 

related to mechanical vegetation and prescribed fire treatments, including construction of 3 to 5 

miles of temporary roads and temporary reopening and then closing or decommissioning of 34.5 

miles of roads and skid trails are expected to be short-lived, with implementation of 

recommended best management practices and design features, and would not result in negative 

cumulative impacts. Localized short-term impacts to water quality and soils would occur during 

implementation of stream, wetland, and upland stabilization projects, as well as disturbance to 

soils during construction of range improvements. These short-term impacts would result in longterm benefits by stabilizing these degraded systems, thus resulting in positive cumulative impacts. 

The addition of 0.3 mile of all-terrain vehicle route would have long-term impacts to the soil 

resource in its location, however the long-term positive cumulative impacts the relocation of 

routes provides to stream systems would outweigh the localized negative soil impacts. The 

addition of 4.2 miles of user-created routes, reopening of 3.5 miles of closed routes for 

administrative use, and reopening of approximately of 13.8 miles of currently closed routes 

would continue long-term impacts related to these roadbeds that are currently in place. While 

these road activities would provide no positive cumulative effects to watershed resources, there 

would be no additional negative impacts as the disturbance currently exists.

Overall, implementation of alternative B with all of the restoration activities planned to benefit 

watershed, soil, riparian and aquatic resources would result in positive cumulative impacts to 

watershed conditions. The limited amount of road disturbance remaining would not negatively 

impact cumulative effects. The treatments projectwide would result in upward trends in watershed 

condition classification to all of the watersheds with proposed restoration treatments, with some 

watersheds likely moving to an improved condition class.

Alternative C – Herbicide Utilization

Alternative C would have the same cumulative effects as alternative B. The only difference in this 

alternative is the use of herbicide on rabbitbrush and juniper trees, in addition to, or in lieu of, 

mechanized removal of these species. There would be no additional positive or negative 

cumulative effects to watershed conditions with the added use of herbicide to vegetation.

Alternative D

Alternative D is similar to alternatives B and C, minus 4.2 miles of user-created routes added to 

the system, minus construction of 0.3 mile of all-terrain vehicle routes, and minus reopening of 

13.6 miles of closed routes (which would instead be decommissioned). The absence of these 

activities provides the least amount of disturbance to soils of any action alternative over the long 

term. The 13.6 miles of closed routes would be decommissioned and the 4.2 miles of user routes 

would receive restoration treatments. Long-term impacts related to these road beds would be 

reduced and positive cumulative effects would result. The absence of the 0.3-mile reroute would 

result in existing negative impacts remaining in Dillman Creek related to stream crossings. As this 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

140

disturbance currently exists, there would be no additional negative impacts, but no positive benefits 

to the stream resource. Similar to alternatives B and C, this alternative would receive all of the other 

restoration activities planned to benefit watershed, soil, riparian and aquatic resources, which 

would result in positive cumulative impacts to watershed conditions. This alternative provides the 

most positive cumulative effects of all action alternatives by reducing the proposed motorized 

transportation treatments. However, considering the scale of the project area and the reduced 

number of proposed routes and disturbed acreage between alternatives B, C, and D, the difference 

in positive cumulative effects is minor.

Summary of Cumulative Effects

Past and ongoing activities on the Gila National Forest include a variety of actions such as 

fuelwood harvest, timber sale activities, mining, prescribed burns, fires, road and trail 

construction and maintenance, rangeland grazing, hunting and camping, wildlife use, off-highway 

vehicle use, other recreational uses, and water impoundments. Current timber sale activities have 

been minimal and small, and fuelwood cutting has been dispersed and would continue that way. 

Mining activities are minimal to nonexistent within the eleven watersheds.

Existing National Forest System roads receive periodic maintenance designed to improve 

drainage and reduce excessive runoff and sediment into connected drainages. Future runoff and 

sediment are not expected to increase on existing improved National Forest System roads.

The average road density within the watersheds is fair, ranging between 1 and 2.4 miles per 

square mile. Roads remain one of the larger contributors of sediment to the drainage network. All 

action alternatives propose to reduce road densities, mostly through decommissioning of 

maintenance level 2, high-clearance routes. As noted prior, two stream reaches are currently not 

attaining State water quality standards. With many roads across the Gila National Forest lacking 

adequate drainage features, roads have been identified by the State as being one probable source 

of impairment for Centerfire Creek. Water quality issues would continue to be a concern in these 

watersheds for stream reaches that are impaired and for those that have designated or occupied 

habitat for threatened, endangered, and sensitive species. While other perennial streams are not 

listed as impaired, many of these stream reaches have not yet been assessed by the State of New 

Mexico. Sediment input would be reduced by decommissioning of routes under all action 

alternatives but would remain a concern in all perennial and intermittent streams impacted by 

remaining routes. Motorized crossing will be reduced under all action alternatives, as well as a 

reduction in stream miles adjacent to perennial, intermittent, ephemeral, and impaired water 

bodies.

Livestock grazing across the Gila has seen reductions, with added measures taken to either 

exclude riparian areas or implement riparian specific management along streams. Future impacts 

should be consistent with current impacts. Fires managed for benefit of natural resources and 

vegetation treatments would continue to play a role in these watersheds, when possible, in 

attempts to restore ecosystem health. There are several localized areas within the project area at 

high risk for current and future resource degradation without attention to best management 

practices and design features. In particular, those areas having sensitive soils, riparian areas, and 

wetlands would be most vulnerable.

Reasonable foreseeable actions that are expected to occur include reauthorization of livestock 

grazing permits, vegetation management projects, and watershed and road/trail improvement 

projects. In addition, the adjacent Apache-Sitgreaves National Forests are conducting the similar 

West Escudilla Restoration Project, and are expected to improve watershed conditions at a 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

141

landscape scale via vegetation, watershed, and motorized transportation treatments. This 

neighboring Forest shares four sixth code watersheds with the Gila National Forest, and 

improvements on its adjacent National Forest System lands would have beneficial cumulative 

impacts, watershedwide.

Existing watershed, soil, and aquatic conditions were used to determine current watershed 

condition classification, which can be viewed as a collective assessment of all prior activities, 

both natural and human, caused, that have cumulatively impacted watershed, soil, and aquatic 

resources. Careful planning should occur in watersheds that are functioning at risk or impaired, to 

ensure that future projects are distributed over space and time. Some programs and activities in 

the project area have localized, short term, adverse effects to watershed, soil, and aquatic 

resources, however the cumulative effects of past, present and reasonable foreseeable future 

activities, including the implementation of the Luna Restoration Project, would be beneficial.

In comparison to alternative A, selection of any of the action alternatives would result in positive 

cumulative effects to watershed condition classification as they provide for the benefit and 

restoration of multiple watershed resources. Several watersheds are anticipated to move to an 

improved watershed condition classification over the life of the project due to restoration 

activities.

Roads

Transportation Specific Assumptions

• Motor vehicle use authorized by state law is occurring on National Forest System roads 

unless there are Gila National Forest-specific prohibitions. Analysis assumes compliance.

• There is some cost for maintenance that will have to be borne by the Forest Service for all 

National Forest System roads.

• There will be implementation costs regardless of the alternative selected.

Affected Environment

National Forest System roads are managed for the use and administration of National Forest 

System lands. Although generally open and available for public use, that use is at the discretion of 

the Secretary of Agriculture. Through authorities delegated by the Secretary, the Forest Service 

may restrict or control traffic to meet specific management direction (USDA Forest Service 

2008). Roads in the National Forest Transportation System are not public roads in the same sense 

as roads under the jurisdiction of state and county road agencies. National Forest System roads

are designed, constructed, and maintained to provide access for the utilization and management of 

the national forest and are tracked in the Gila National Forest transportation atlas. National Forest 

System roads are managed in one of three ways: as closed long term to motor vehicles (closed 

roads), roads maintained for high-clearance vehicles only (high-clearance roads), and roads 

maintained for passenger car vehicles.

As of January 1, 2017, the Gila National Forest fully implemented the record of decision for the 

Travel Management Rule (USDA Forest Service 2005a). Across the entire national forest, there 

are 3,657 miles of National Forest System roads designated open (operation maintenance levels 2 

through 5) to motor vehicle use by the public or by written authorization and 1,407 miles of roads 

closed to motor vehicle use (operation maintenance level 1) (table 54).
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

142

Table 54. Existing Gila National Forest System roads by operation maintenance level and general 

description of each maintenance level

Operation Maintenance Level Miles

1 - Intermittent service roads during the time they are closed to vehicular traffic 1,407 

2 - Roads open for use by high-clearance vehicles 3,261 

3 - Roads open and maintained for travel by prudent drivers in standard passenger cars 247

4 - Roads that provide a moderate degree of user comfort and convenience at moderate 

travel speeds 

125 

5 – Roads that provide a high degree of user comfort and convenience 24 

Total Miles 5,064 

Miles open to motor vehicle use (operation maintenance level 2-5) 3,657 

There are approximately 587 miles of roads that lie within the Luna Restoration Project area 

(table 55). The majority, 478 miles, are under Forest Service jurisdiction, of which approximately 

298 miles are open to all motor vehicle use (table 56). The remaining 109 miles are a mix of 

federal, county, or private jurisdiction. Many of these roads provide access for local communities 

as well as access to and through the area for recreational and business purposes. National Forest 

System roads within the project area are also used for research, fish and wildlife habitat 

management, range management, timber harvesting, fire protection, mining, insect and disease 

control, and private land use.

Table 55. Roads under other jurisdiction within the Luna Restoration Project area

Road Jurisdiction Miles

National Forest System 478

County 76

Private 20

U.S. Highway 14

Total miles 587

Source: Infra, GIS.

Table 56 depicts the breakdown of the existing 478 miles of National Forest System roads by 

operational maintenance level within the Luna Restoration Project area.

Table 56. Existing National Forest System roads within the Luna Restoration Project area broken 

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

Operation Maintenance Level Miles

1 - Intermittent service roads during the time they are closed to vehicular traffic 180 

2 - Roads open for use by high-clearance vehicles 250

3 - Roads open and maintained for travel by prudent drivers in standard passenger cars 35

4 - Roads that provide a moderate degree of user comfort and convenience at moderate 

travel speeds

13

5 – Roads that provide a high degree of user comfort and convenience 0 

Total miles 478

Miles open to motor vehicle use (operation maintenance level 2 through 5) 298

Source: Infra, GIS.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

143

Environmental Consequences

Alternative B and C are the same in regards to proposed changes to National Forest System roads. 

The differences between all of the alternatives are summarized in table 57.

Table 57. Changes to National Forest System road miles by alternative

Proposed Changes Alt A Alt B Alt C Alt D

Road decommissioning 0 116 116 130

Reopen operation maintenance level 1 closed National Forest 

System roads for permitted use for proposed treatment activities 

and decommission after activities are completed (included in road 

decommissioning above)

0 12 12 12

Total road miles removed from national forest road system 0 116 116 130

Reopen operation maintenance level 1 closed National Forest 

System roads to all vehicle types

0 13.8 13.8 0.2

Add unauthorized roads to National Forest System roads open to 

all vehicle types

0 4.2 4.2 0

Total additional road miles open to all vehicle types 0 18 18 0.2

Reopen operation maintenance level 1 closed National Forest 

System roads for permitted use for proposed treatment activities 

and close after activities are completed (no net change to national 

forest road system mileage)

0 22.6 22.6 22.6

Construct 3 to 5 miles of temporary roads for proposed treatment 

activities and decommission upon completion of activities (no 

change to system miles as temporary roads are not tracked in the 

forest transportation atlas)

0 3 to 5 3 to 5 3 to 5

Add unauthorized road to National Forest System roads for 

administrative use or by written authorization only (Tucson 

Electric Power Company)

0 0.5 0.5 0.5

Reopen operation maintenance level 1 closed National Forest 

System roads for administrative use or by written authorization 

only (Tucson Electric Power Company)

0 3.5 3.5 3.5

Total additional road miles for administrative use or by written 

authorization only

0 4.0 4.0 4.0

Total road miles added to national forest road system 0 22 22 4.0

Net reduction in National Forest System road miles 0 94 94 126

Tucson Electric Power Company has a main transmission line that runs through the project area 

that they need to access for maintenance, emergency repair, and structure replacements. To 

accommodate Tucson Electric Power Company needs, all action alternatives (B, C, and D) would 

reopen 3.5 miles of closed roads and add 0.5 miles of unauthorized roads to the national forest 

transportation atlas.

Other publics provided comments requesting additional access for recreational activities. Those 

comments resulted in proposals to reopen 13.8 miles of closed National Forest System roads and 

add 4.2 miles of unauthorized roads under alternatives B and C. In alternative D, the 13.8 miles 

are proposed for decommissioning, putting the decommissioning total miles at 130 miles while 

the 4.2 miles of unauthorized roads would be subject to decommissioning.

Table 57 does not address the decommissioning of unauthorized roads as they are not recognized 

as National Forest System roads and are not tracked in the Gila National Forest transportation 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

144

atlas. The same can be said for the 3 to 5 miles of proposed temporary roads (common to all 

action alternatives). Temporary roads are not tracked, as they are not intended to become part of 

the national forest road system. Temporary roads are used for a short period for a specific purpose 

and then obliterated.

The proposal to reopen 22.6 miles of National Forest System roads in alternatives B, C, and D is

to access proposed treatment sites. Reopening these roads will not result in an increase of miles to 

the road system because these roads would be closed as treatments are completed.

Trends

Under alternatives B and C, the proposal is to decommission 116 of the 180 existing miles of 

operation maintenance level 1 roads within the planning area (table 57). Decommissioning 116 

miles of roads would be completed once all landscape treatments have been accomplished. The 

same 116 miles plus an additional 13.8 miles would be decommissioned in alternative D.

The reopening of previously closed roads and adding unauthorized roads to the national forest’s 

transportation atlas would result in more flexibility and increased opportunity for the recreating 

public. Alternatives B and C would add 18 miles to the existing 298 open miles (table 53) within 

the planning area. The additional 18 miles would result in an increase of approximately 6 percent

of open National Forest System roads within the planning area. The 4 miles that would be added 

on behalf of Tucson Electric Power Company in all action alternatives would assist them in 

operating and managing their transmission line. These 4 miles would seldom see traffic as they 

would be under written authorization to Tucson Electric Power Company and would not be added 

to the motorized vehicle use map.

Regardless of which action alternative is selected, the reduction to the overall national forest road 

system is negligible and would do little to help align the Gila National Forest road budget with 

the maintenance needs. Alternatives B and C would reduce the overall system by 94 miles, 

approximately 2 percent of the existing national forest road system, and alternative D would 

reduce the mileage by 126 miles or nearly 2.5 percent. Even though these reductions are small, 

the watersheds they reside in would benefit (less sediment migration from roadbeds, better water 

quality, reduced road density, etc.) as well as wildlife habitat (less fragmentation). The Travel 

Management Rule (USDA Forest Service 2005a) provides flexibility when designating the 

motorized system. Roads previously closed may be reopened and roads designated for motorized 

use may be closed at a later date. Even though all the action alternatives propose to reopen roads 

and add unauthorized routes, the proposals net effect to the national forest road system would 

result in a mileage reduction due to the decommissioning proposals in all the action-alternatives. 

There would be some implementation costs associated with the use of the National Forest System 

roads within the planning area including National Forest System road 3050 (0.2 mile) where 

drainage features would be maintained and existing berms would be removed or reworked to 

allow passage (applicable to all action alternatives).

There are also several bridges within the project area that may be used if any of the action 

alternatives are selected. Six are located on Catron County Road B007 and one is located along

National Forest System road 220 at Romero Creek. All these bridges have been evaluated and 

approved for highway legal loads. The additional traffic associated with proposed treatments 

(including logging trucks and semi tractors hauling heavy equipment) could also result in the 

need for additional maintenance on roads operated and maintained by Catron County, specifically 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

145

Catron County Roads B007, B080, and B024. Some of the roads on the Apache-Sitgreaves 

National Forests could also see additional traffic associated with proposed treatments.

There are no measureable maintenance cost savings associated with any of the action alternatives. 

The Gila National Forest will continue to seek opportunities to better balance the national forest 

road system with available funding. The more significant benefit is likely to be seen over time 

once the decommissioned roads identified in any of the action alternatives have been fully 

reclaimed by the natural landscape. Some of the anticipated benefits include reduced habitat 

fragmentation, better watershed conditions, and reduced road density.

Range

Range Resources

The Luna Restoration Project area includes portions of eight range allotments. Table 58 indicates 

how many acres of each allotment are located within the project area and have the potential to be 

impacted by project activities. The Centerfire, Dillman/Trout Creek, Luna, Spur Lake and 

Underwood Lake allotments are located entirely or almost entirely within the analysis area. The 

Laney and Mangitas allotments have large portions of the allotment within the analysis area and 

the Toriette allotment has minimal acres located within the analysis area.

Table 58. Grazing allotments located within the Luna planning area

Allotment Name

Total 

Allotment

Acres

Acres Within the Luna 

Analysis Area

Percentage of Allotment 

within the Luna Analysis 

Area

Centerfire 20,551 20,307 99%

Dillman/Trout Creek 9,589 9,589 100%

Laney 26,449 13,343 50%

Luna 44,927 44,927 100%

Mangitas 25,116 6,144 24%

Spur Lake 74,457 62,874 84%

Toriette 39,442 256 Less than 1%

Underwood Lake 13,053 13,053 100%

Environmental Consequences

Alternative A

Under the no-action alternative, none of the proposed treatments or activities would be 

implemented within the planning area. There would be no direct effects to the range resource.

Indirect effects associated with the no-action alternative would include continued encroachment 

of woody vegetation into neighboring grasslands and canopy closure of forested and woodland 

vegetation types that could lead to the decrease in the amount and diversity of herbaceous 

vegetation on the landscape. The fuels reduction projects and prescribed fire activities would not 

occur, increasing the opportunity for high-severity fire to occur across the landscape and 

negatively impact the range resource. The proposed watershed treatments would not be 

implemented allowing for continued degradation of these systems. This could present negative 

effects to the range resource through continued erosion and loss of soil productivity in these 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

146

systems. Water availability to vegetation, livestock and wildlife could be reduced by down cutting 

of stream banks that can cause the water table to recede and decrease the duration in which 

precipitation is available for infiltration and use by the surrounding vegetation.

There would be no cumulative effects to the range resource under this alternative.

Effects Common to Alternatives B, C, and D

The direct effects of action alternatives would include disturbance to the herbaceous vegetation 

and soils during implementation of the proposed projects that could require rest of a pasture or 

portion of a pasture. These effects are expected to persist for a short duration and have minimal 

impacts through the proposed mitigations. This effect is mitigated through the coordination of 

activities with the range management specialist and the affected permittee to allow for adaptive 

management to be incorporated into the allotment management plan and to ensure the timing and 

scale of the project would not place an undue burden on the range resource and livestock 

management. Adaptive management actions that may occur to mitigate effects include 

adjustments in pasture rotation schedules, herding, salting and reduced numbers.

The indirect effects of the action alternatives would primarily be of benefit to the range resource. 

The proposed vegetation, prescribed fire and watershed activities would increase the opportunity 

for the occurrence and diversity of herbaceous vegetation throughout the analysis area. This, 

along with the proposed water developments and pasture division, would lead to the improvement 

of livestock distribution and use across the landscape, allowing for improved livestock 

management and resilience of the rangeland vegetation during times of drought and unforeseen 

climate conditions. With any soil disturbing activity the opportunity exists for noxious weeds to 

become established. The proposed activities would implement strategies to reduce or eliminate 

the opportunity for introducing weed seed through the implementation of proposed projects. 

Reseeding when necessary and appropriate would also occur within disturbance sites to decrease 

the opportunity for noxious weeds to establish and to reduce the exposure of soils to erosion. If 

noxious weeds immerge within the analysis area, they would be addressed through the 

environmental assessment for noxious weed management (USDA Forest Service 2000a and 2015 

supplement plant list).

Alternatives B and D

In alternatives B and D, rabbitbrush treatment by mowing alone would likely require several 

consecutive years of reentry to achieve measurable mortality of rabbitbrush within a given 

treatment area and has the potential to expose the soils and associated vegetation to increased 

disturbance. Single entry mowing would likely change the physical structure of the plant 

community allowing for the growth of herbaceous vegetation for a short duration until the 

rabbitbrush becomes reestablished. Some acres identified for rabbitbrush treatment cannot be 

accessed with mowers exclusively; therefore, desired conditions may not be reached on these 

acres.

Cutting of alligator juniper from grasslands will initially result in increased herbaceous ground 

cover. This species re-sprouts and within a decade may be of size where it competes with 

herbaceous ground cover.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

147

Alternative C

The use of herbicides to treat rabbitbrush and alligator juniper will move the landscape towards

desired conditions in a shorter timeframe than alternatives B and D. Herbicide treatments would

increase mortality in rabbitbrush and alligator juniper therefore, minimizing re-sprouting of these

species. More acres of rabbitbrush treatments could be accomplished utilizing herbicides versus

mowing in alternatives B and D, due to access not being limited by topography or other features.

The use of herbicides reduces the potential for increased ground disturbance from the need of

repeated mowing.

Cumulative Effects

There would be an increase in herbaceous cover, acres of grassland, and water availability and 

distribution from implementing alternatives B, C, or D. When considering past, present, 

reasonably future activities, and activities proposed in the alternatives it is anticipated to result in 

a positive cumulative effect for range management.

Recreation

Affected Environment

The primary recreational opportunities, as identified in the 2011 Gila national visitor use 

monitoring data and district staff, are dispersed in nature and include; driving to view scenery and 

wildlife, dispersed camping, big game hunting, hiking cross country and on system trails, 

horseback riding, off-highway vehicle riding, shed hunting, photography, night sky viewing, bird 

watching, botanizing, and general nature observation.

There is one developed recreation site in the project area: Head of the Ditch Campground. The 

campground offers an easily accessible rustic streamside camping experience. It is located 

approximately 1.5 miles west of Luna, New Mexico on U.S. Highway 180. Its proximity to this 

major thoroughfare makes it popular with tourists traveling through the region. The campground 

also receives substantial use during the hunting seasons.

Dispersed camping and picnicking are popular in the Stone Creek, San Francisco River and Trout 

Creek corridors.

There are fifteen National Forest System trails in the planning area, totaling approximate 39.4 

miles. Most trails are restricted to horses, hiking and mountain biking. Two motorized trails are 

located in the Dry Blue drainage.

Off-highway vehicle riding is popular in the Luna area. Roads provide opportunities for all 

vehicle types; this includes off-highway vehicles greater than 50 inches in width. The popular 

utility-task vehicles, which provide side-by-side operation, fall into the greater-than-50-inches

category. Low maintenance level roads (maintenance level 2) provide the opportunity for this 

width of vehicle class as well as the unimproved trail-like experience desired by the off-highway 

vehicle rider.

Hunting is a major recreational use in the Luna planning area. Hunting seasons and restrictions 

are administered by the New Mexico Department of Game and Fish. Big game is the primary 

type of hunting: elk, bear, mountain lion, and deer. Wild turkey hunting is also popular. There are 

24 special use permits for outfitter and guides in the project area. Hunting is dispersed in nature; 

however, some hunting parties revisit the same areas annually.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

148

Environmental Consequences

Alternative A – No Action

Under the no-action alternative, there would not be any decommissioning of unauthorized roads 

and trails. There would continue to be approximately 39.4 miles of National Forest System trail. 

Head of the Ditch Campground would remain open. Visuals would mostly remain unchanged due 

to being constrained by existing vegetation conditions, such as tree densities. Hunting and other 

recreational pursuits would continue. The motorized transportation network would not change 

from the 2013 travel management decision. Driving for pleasure would continue. Off-highway 

vehicle recreation would continue on low-level maintenance roads open to the public.

Without vegetation and prescribed fire treatments the potential risk for high-severity wildfires, 

such as the Wallow Fire, would continue. These fires adversely could affect recreation by 

damaging infrastructure, including damaging trail networks and accessibility; and heavily 

modifying the recreational setting.

Low-water fords on the Dry Blue Creek (trails #61 and #64) and Head of the Ditch would remain 

in their current state and location. Issues with sedimentation and aquatic resource damage would 

continue.

Cumulative Effects

There are no cumulative effects to recreation due to no activities proposed under the no-action 

alternative.

Effects Common to Alternatives B, C, and D

In the short term, there would be some inconvenience to visitors to the Luna Restoration Project 

area during implementation. Areas or facilities may be temporarily closed to help ensure public 

safety. It is an expectation that project implementation would result in a more aesthetically 

pleasing recreational setting.

Thirteen of the 15 trails are located within active treatment areas or would be worked on. 

Treatments would alter the visuals in the immediate foreground. Affected portions of the trails 

would be temporarily closed to help ensure public safety. Prescribed fire may result in the 

creation of snags along trails. If snags fall, they could impact the accessibility along the trail.

People recreating within the planning area could encounter the sights and sounds of equipment 

and workers during implementation. There would likely be temporary effects to the flow of traffic 

on these travel ways, such as delays or detours. Treatments would alter the visuals in the 

immediate foreground such as; slash, piles, landings, skid trails and disturbed ground would be 

evident in the short term. In the long term, scenic integrity would be improved by restoring 

structure to vegetation communities, with sight lines becoming more open.

Implementation would temporarily displace opportunities for recreation and hunting. However, 

implementation would be localized; while work is implemented in one area, other areas within 

the project area would be open. Some visitors may choose to avoid the area entirely.

Head of the Ditch Campground would temporarily close during construction of the low-water 

crossing and diversion to help ensure public safety. This is the only developed campground within 

the project area. During implementation, there are no other opportunities for developed camping 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

149

within the planning boundary. Relocation of the low-water crossing would improve access to 

campground sites located across the San Francisco River. 

Motorized trails in the Dry Blue Creek (trails #61 and #64) would be improved through design 

and construction of six water crossing and rerouting 0.1 mile of trail. This would move towards 

reducing impacts to threatened and endangered species and their habitat, and reducing 

sedimentation.

Decommissioned roads would be available to the public to hike, bike, or ride horses on. This 

recreational experience would likely be enhanced due to the absence of motorized vehicles. In 

addition 4.2 miles would be added to the foot and horse trail system by leaving a trail tread on 

National Forest System roads 4023 V; 4029 E, and 4030 W during decommissioning.

Roads open for administrative use only are available to the public for nonmotorized uses, 

allowing hiking, biking, and equestrian activities.

Roads and trails could be temporarily closed during prescribed fire activities to help ensure public 

safety. The presence of active fire and smoke could cause some visitors to change their travel 

plans. Smoke could linger for days in some areas, causing visitors to avoid those locations. 

Smoke from prescribed fires may have a direct effect to the quality of the recreation experience 

by temporarily reducing air quality and visibility.

Effects Common to Alternatives B and C

In collaboration with the Luna Riders, 18.0 miles of closed and user-created routes were 

identified to be added to motorized transportation system. These select closed system roads and 

user-created routes were identified for provide access from the community of Luna, access into 

Arizona, loop opportunities, and to access favorite spots for scenic views and picnicking. 

Opening existing closed and user-created routes would enhance recreational opportunities 

through improving connectivity of the road system and enhancing riding experience.

The proposed action during scoping limited the 18.0 miles of road to all-terrain and utility-task 

vehicles less than 50 inches in width. As proposed in alternative B, these 18.0 miles would be 

open to all motorized vehicle types; which includes popular utility-task vehicles that allow for 

side-by-side riding. Therefore, adding roads of this class provides more opportunity for this type 

of recreation.

In collaboration with the Luna Riders, a new route was identified to connect an open road in the 

Luna rodeo grounds to a system of open roads in the Stone Creek area. Construction of a 0.3 mile

4x4 trail addresses sensitive riparian resource concerns in Dillman Creek and enhances 

connectivity of road systems for recreational opportunities. The tread width of 60 inches would 

provide utility-task vehicle opportunities.

Alternative C – Herbicide Utilization

The use of herbicides to increase effectiveness of restoration would have a few effects to 

recreation opportunities. The sights and sounds of herbicide application would be apparent during 

implementation. Following manufacture instructions and design features related to notification 

and posting, would minimize any potential negative impacts to Gila National Forest visitors 

during or from herbicide applications.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

150

Herbicide treatment activities may temporarily displace visitors. Visitors may choose to avoid an

area where herbicide treatments have been applied.

Proposed herbicide treatments would likely have an overall beneficial effect to visual quality. 

Short-term impacts from chemical treatments would include dying vegetation that could be 

visible. Long-term effects would be beneficial through the enhancement and restoration of areas 

of grasslands, forested, and woodland areas.

Alternative D – No Addition of Motorized Routes

The 18.0 miles of closed and user-created routes that were identified in collaboration with the 

Luna Riders would not be added to motorized transportation system under this alternative to 

address an issue identified from scoping comments. Therefore, access from the community of 

Luna, access into Arizona, loop opportunities, and access to favorite spots for scenic views and 

picnicking would not be provided. Connectivity of the road system to enhance riding experience 

would remain a public concern, including the connection between the Luna rodeo grounds to a 

system of open roads in the Stone Creek area.

Cumulative Effects

Recreation opportunities and scenic quality as a result of implementing alternative B, C, and D

would result in cumulative impacts, when considering past, present, reasonably future activities, 

activities proposed in this alternative, and activities identified in the West Escudilla Project on the 

Apache-Sitgreaves National Forests.

Recreation opportunities could be cumulatively impacted due to the increased management 

activities. Road networks along the state line of New Mexico and Arizona could be utilized by 

both national forests for implementation of projects. This could result in traffic, dust, and noise 

that could lead to a slight inconvenience and displacement of visitors. This would be of episodic 

and extent is dependent upon what activity treatment(s) are being implemented.

Cumulative impacts to scenic quality are possible if evidence of multiple activities are visible 

during the same season. Similar vegetation treatments are planned in the West Escudilla Project. 

Cumulative impacts to visual resources along the state line would likely only last during 

implementation. Long-term cumulative impacts are likely to be beneficial as healthy forest 

conditions are restored.

Climate Change

Climate change influences environmental factors including the weather, vegetation, habitat, 

water, and wildlife across the landscape. Depending on the changes to these resources due to 

climatic change, recreational opportunities or users may change or alter those opportunities and 

uses. But determining the relation of climate change and recreation uses is not realistically 

identifiable within the context of this site-specific and project-level environmental analysis.

Recreation – Inventoried Roadless Areas

Inventoried roadless areas are designated pursuant to 36 Code of Federal Regulations section 294,

subpart B, section 294.11. Inventoried roadless areas are identified in a set of maps contained in 

Forest Service Roadless Area Conservation, final environmental impact statement, and volume 2

(USDA Forest Service 2000b).
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

151

This analysis describes the existing condition of the three inventoried roadless areas within the 

Luna Restoration Project area. This includes all of the Mother Hubbard and portions of the Nolan 

and Frisco Box inventoried roadless areas.

Low-severity prescribed fire is proposed in the Mother Hubbard and Nolan inventoried roadless 

areas. There is none prescribed within the Frisco Box Inventoried Roadless Area, but a short 

section of trail is proposed to be enhanced by reducing its width from a road to single-track trail. 

This roadless analysis also describes the potential effects to the roadless characteristics and 

wilderness attributes of the inventoried roadless areas from the proposed treatment activities 

identified in the alternatives.

The recreational opportunity spectrum classes are not mapped and therefore unavailable. The Gila 

forest plan prescribes a forestwide standard to manage the three inventoried roadless areas to 

semiprimitive spectrum of recreation opportunities.

Affected Environment

The inventoried roadless area contain a variety of vegetation types including piñon-juniper, 

riparian, ponderosa pine, and mixed conifer at higher elevations. There are no municipal 

watersheds, but there are perennial water features such as Blue and Colyer Springs, and reaches 

of Pace, Dry Blue, and Centerfire Creeks in these areas. All roadless areas contain habitat for 

threatened and endangered species such as Mexican spotted owl, Mexican grey wolf, narrowheaded and northern Mexican gartersnakes and loachminnow but is not the only habitat for these 

species on the Gila National Forest. Dispersed recreation, such as hiking, hunting, and observing 

nature, are the main recreational uses.

Nolan Inventoried Roadless Area

The Nolan Inventoried Roadless Area is 13,050 acres in size with 8,912 acres situated along the 

southwestern boundary south of the Dry Blue Canyon with a portion of the San Francisco 

Mountains of the planning area. This roadless area also extends across the state line into the 

Apache-Sitgreaves National Forests.

Summary of the roadless area characteristics and wilderness attributes of Nolan Inventoried 

Roadless Area:

• Natural – The extent to which long-term ecological processes are intact and operating: 

Due to decades of fire suppression, ecological processes have departed from historical 

norms. Forest stand densities have high crown fire potential, which promotes high-severity

fire. Long-term ecological processes are impaired, currently.

• Undeveloped – The degree to which development and uses are apparent to most 

visitors: Evidence of human activity is present across much of the area but is subtle in 

appearance. Fuelwood cutting, recreation use, private land and road building are a few 

examples of what has contributed to defining the degree to which development and uses are 

apparent to most visitors and departure from the undeveloped characteristic within the 

roadless area.

• Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation:

Solitude is a personal, subjective value defined as the isolation from sights, sounds, and 

presence of others and from developments and evidence of humans. Primitive recreation is 

characterized by meeting nature on its own terms, without comfort and convenience of 

facilities.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

152

Nolan includes areas with more potential for solitude. Topographically constrained areas 

such as Frieborn and Colyer Canyons provide more isolation from the sight and sounds of 

civilization than do areas near U.S. Highway 180 or the motorized Dry Blue Creek Trail, 

where noise associated with motorized vehicles are common.

The area is managed for semiprimitive recreation per the Gila forest plan (USDA Forest 

Service 1986). A substantial area would likely qualify for semiprimitive nonmotorized 

(interior) and the periphery would likely qualify for semiprimitive motorized or roaded 

natural (areas near Horse Mesa and Dry Blue Creek Trail).

• Special Features: Colyer Spring is a perennial source of water, which is considered special 

in this arid region.

• Manageability: Nolan Inventoried Roadless Area within the planning area is demarcated 

mostly by landform and the presence of road and motorized trail. This geography renders it 

easily manageable. The portion of the roadless area outside the planning area was not 

considered for manageability.

Mother Hubbard Inventoried Roadless Area

The Mother Hubbard Inventoried Roadless Area is 5,895 acres in size and is situated entirely 

within the planning area along the southwestern boundary north of Dry Blue Canyon.

Summary of roadless area characteristics and wilderness attributes of Mother Hubbard 

Inventoried Roadless Area:

• Natural - The extent to which long-term ecological processes are intact and operating: 

Due to decades of fire suppression, ecological processes have departed from historical 

norms. Forest stand densities have high crown fire potential, which promotes high-severity 

fire. Long-term ecological processes are impaired, currently.

• Undeveloped - The degree to which development and uses are apparent to most

visitors: Evidence of human activity is present across much of the area but is subtle in 

appearance. Fuelwood cutting, recreation use, private land, and road building are a few 

examples of what has contributed to defining the degree to which development and uses are 

apparent to most visitors and departure from the undeveloped characteristic within the 

roadless area.

• Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation: 

Mother Hubbard has areas with more potential for solitude. Topographically constrained 

areas such as Pace Creek and Dry Blue Creek canyons provide more isolation from the 

sight and sounds of civilization than do areas near the north boundary or the motorized Dry 

Blue Creek Trail, east boundary, where noise associated with motorized vehicles are 

common.

The area is managed for semiprimitive recreation per the Gila forest plan (USDA Forest 

Service 1986). A substantial area would likely qualify for semiprimitive nonmotorized

(interior) and the periphery would likely qualify for semiprimitive motorized or roaded 

natural (areas near north, east and Dry Blue Creek Trail).

• Special Features: Blue Spring is a perennial source of water that is considered special in 

the arid region.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

153

• Manageability: Mother Hubbard Inventoried Roadless Area is demarcated mostly by 

landform and the presence of road and motorized trail. This geography renders it easily 

manageable. The exception would be the northern and eastern boundaries might be difficult 

to locate on the ground.

Frisco Box Inventoried Roadless Area

The Frisco Box Inventoried Roadless Area is 38,977 acres in size with 8,312 acres situated within 

the eastern boundary of the planning area. The roadless area contains the Centerfire Creek Valley 

and contains Upper Cottonwood, Joshua, Howell, and Curio Canyons.

Summary of roadless area characteristics and wilderness attributes of Frisco Box Inventoried 

Roadless Area:

• Natural - The extent to which long-term ecological processes are intact and operating: 

Due to decades of fire suppression, ecological processes have departed from historical 

norms. Forest stand densities have high crown fire potential which promotes high-severity 

fire. Long-term ecological processes are impaired, currently.

• Undeveloped: The degree to which development and uses are apparent to most visitors.

Evidence of human activity is present across much of the area but is subtle in appearance. 

Fuelwood cutting, recreation use, private land and road building are a few examples of 

what has contributed to defining the degree to which development and uses are apparent to 

most visitors and departure from the undeveloped characteristic within the inventoried 

roadless area.

• Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation: 

Frisco Box has areas that have more potential for solitude. Topographically constrained 

areas such as Upper Cottonwood, Joshua, Howell, and Curio Canyons provide more 

isolation from the sight and sounds of civilization than do areas near the northern boundary

where noise associated with motorized vehicles are more common.

The area is managed for semiprimitive recreation per the Gila forest plan (USDA Forest 

Service 1986). A substantial area would likely qualify for semiprimitive nonmotorized 

(interior) and the periphery would likely qualify for semiprimitive motorized or roaded 

natural (areas near Centerfire Creek Valley and northern boundary).

• Special Features: Centerfire Creek is a perennial stream, which is considered special in the 

arid region.

• Manageability: The Frisco Box Inventoried Roadless Area is demarcated mostly by 

landform and the presence of road. This geography renders it easily manageable. The 

exception is the northern boundary, which is difficult to locate on the ground.

Environmental Consequences

The effects to the inventoried roadless areas were analyzed using the duration and trend of the 

effect on roadless area characteristics and wilderness attributes.

Alternative A – No Action

Under alternative A, no activities would occur. Consequently, fuel loading would continue to 

increase over the project area. This would create an increased risk of wildfire. The potential event 

of an uncharacteristic wildfire could impact the naturalness, recreation values, or both in the area.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

154

Alternative A would leave the current roadless character and potential wilderness values

unchanged. Any direct or indirect effects of this alternative would be the result of continued 

natural processes in the area.

• Natural – The extent to which long-term ecological processes are intact and operating: 

Prescribed fire and vegetation treatments would not be reintroduced. The existing 

downward trend of species diversity, age diversity, and tree density diversity would 

continue. High-severity wildfire could result in large homogenous-burned areas and 

elimination of ponderosa pine stands, as can be seen in other cases of severe wildfire in the 

southwest region.

• Undeveloped – The degree to which development and uses are apparent to most 

visitors: No treatments would occur under this alternative, and no new development or 

uses would become apparent to visitors.

• Outstanding opportunities for solitude or primitive unconfined recreation: The 

existing condition for solitude would not be immediately affected under this alternative. 

However, over time conditions could become challenging for visitors to recreate due to 

forest stand conditions. Forest stand conditions could increase opportunities for solitude,

for those who are able and willing to negotiate an increasingly dense and inaccessible area.

Wildfires could dramatically change the landscape, changing how people access or recreate 

in the roadless areas. In the case of wildfires, sight distance and topography screening could 

be changed for decades, impacting solitude, as sights and sounds of visitors in the area as 

well as activities on adjacent lands would more easily be seen and heard.

• Special Features: The existing springs and perennial water sources would not be affected 

under this alternative. However, existing stand conditions would render them susceptible to 

the effects of high-severity fire.

• Manageability: Choosing the no-action alternative would not change the manageability of 

the area.

Cumulative Effects

Since there are no activities being implemented under alternative A, current activities (for 

example, grazing, hunting, and hiking) would continue, but there would be no cumulative effects 

to roadless characteristics and wilderness attributes.

Effects Common to Alternatives B, C, and D

There are no differences in proposed activities between the alternatives B, C and D within the 

three inventoried roadless areas. Each alternative proposes low-severity prescribed fire within the 

Mother Hubbard and Nolan inventoried roadless areas and a road to trail conversion in the Frisco 

Box Inventoried Roadless Area. All alternatives would have some short-term effect to the 

undeveloped, natural, and opportunities for solitude or primitive unconfined recreation attributes 

of the area but would result in a long-term beneficial effect.

In summary, the effects from low-severity prescribed fire are expected to be minor and short term. 

Few characteristics such as plant and animal communities, habitat for threatened and endangered 

species, and recreation opportunities would expect slightly degrading effects in the short term and 

then improving in the long term. Prescribed fire may cause direct short-term impacts to air 

resources from smoke.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

155

Temporary effects to solitude and recreation could occur along roadless boundaries from the 

greater Luna Restoration Project activities, including sights and sounds of people working, 

chainsaws, dust and smoke; however, long-term impacts to recreation and opportunities for 

solitude are not expected to occur.

• Natural – The extent to which long-term ecological processes are intact and operating: 

Prescribed fire would begin modifying the trends caused from past fire suppression and 

reduce the potential probability of severe wildfires. Prescribed fire would enhance the 

characteristic of “naturalness” throughout the area, by re-establishing forest characteristics 

typical of frequent fire ecosystems.

Low intensity prescribed fire would be classified as a type of human manipulation with

methods of ignition emulating a lightning fire. No fire line is expected to be constructed. 

Fire behavior is expected to be low creeping through the understory. The resulting pattern 

on the landscape would be small patch sizes of burned area (mosaic) with irregular shapes. 

Over time, as multiple entries are made to meet fuel objectives, vegetation communities 

within the Nolan and Mother Hubbard roadless areas would begin to move towards 

conditions that include mosaic of various size and age classes which and more resilient to 

changing environmental conditions and stressors.

The road to trail conversion in Frisco Box roadless area would restore the subsurface 

hydrology to the existing road prism that trail number 119 currently uses. Portions of the 

decommissioned road would revegetate through successional processes.

• Undeveloped – The degree to which development and uses are apparent to most 

visitors: In the short term, visitors to the areas would see isolated patches of blackened and 

charred vegetation and soils. Although these visible effects of prescribed burning can 

mimic natural fire disturbances, the public often perceives such blackened landscapes 

negatively. In the long term, the prescribed burning actions would reduce fuel loading and 

promote regeneration of trees, shrubs, wildflowers, and other herbaceous plants. This 

activity would diversify the mosaic of vegetation.

Soil and vegetation disturbance associated from road to trail conversion would be evident 

to visitors. However, this would be a short-term effect, as the disturbed area would revegetate, leaving single-track trail that is appropriate for the design use (pack and saddle 

and hiking).

• Outstanding opportunities for solitude or primitive unconfined recreation: It is likely 

portions of the Mother Hubbard and Nolan inventoried roadless areas may be temporarily 

closed during prescribed fire implementation to ensure public safety and welfare. This 

would be a short-term effect. Visitors that are temporarily displaced would find comparable 

opportunities within and outside of the planning area. The degree of primitive recreation is 

not expected to be affected.

Multiple prescribed fire entries over time would be needed to achieve objectives of 

reducing the probability of high-severity fire. With multiple entries over time, the sight 

distance may change from current; but this change would not be to the extent of the 

potential effects of a wildfire.

Solitude of segments of trail # 119 would be affected during implementation while work is 

completed. This is a short-term effect, as solitude would quickly be restored after

implementation.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

156

It is possible that visitors to, and outside, the inventoried roadless areas would experience 

the sights and sounds of on-the-ground staff and aerial operations implementing the 

prescribed fires. Smoke emissions from prescribed fires across the planning area. The 

duration is expected to be short term and solitude would be restored shortly after 

implementation.

• Special Features: Springs, perennial water sources, and cultural resources are the only 

known special features in the three inventoried roadless areas. It is not expected that there 

would be impacts to these features during implementation.

• Manageability: All action alternatives would not affect the existing manageability of the 

roadless areas. Roadless boundaries are not clearly definable on the ground; therefore, the 

issue of manageability along boundaries is anticipated to continue.

Cumulative Effects

Cumulative effects to roadless resources from all action alternatives would generally be short

term and related to an increased presence of people, noise that may affect solitude. These effects 

would be more evident along the boundaries of the roadless areas where treatments are both 

inside and outside the areas. In some of the units, there would be a greater sight distance than 

existing conditions. For several years, visitors could become more aware of other activities in the 

area as well as on private lands. This effect would not be as great as potential effects from a large 

wildfire, which would likely denude the landscape of all vegetation. An indirect effect of 

proposed prescribed fire activities could be displacement of visitors to untreated areas for 

recreation, mostly because of visuals however, this effect would last for about 1 to 2 years after 

prescribed fire activities when green-up would occur.

The long-term forest health and resiliency would be most improved under the action alternatives 

than the no-action alternative due to the development of a less homogenous forest, more diversity 

of species, and a mosaic of age classes. In the long term, treated areas would be more resilient to 

wildfire and other natural disturbances, which would more likely maintain the quality of soil, 

water, and air in the future.

Climate Change

The effects of climate change were considered during the effects analysis of proposed actions to 

roadless resources. It is expected that climate change effects would increase the length of fire 

season and increase likelihood of high-severity fire. As discussed in the no-action alternative, the 

existing vegetation conditions within the roadless areas have potential for a high-severity fire

with high crown fire potential. Roadless resources could be at risk to irretrievable outcomes 

including species and habitat loss until vegetation becomes re-established.

Roadless Rule Consistency

All alternatives comply with the Roadless Area Conservation Rule and applicable forest plan 

standards as amended by this rule. All action alternatives are within the exceptions identified in 

36 Code of Federal Regulations section 294.13(b)(1), in paragraphs (b)(2) through (b)(4), or both. 

Management activities focus on restoring the characteristics of ecosystem composition and 

structure, such as to reduce the risk of uncharacteristic wildfire effects, within the range of 

variability that would be expected to occur under natural disturbance regimes of the current 

climatic period.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

157

Heritage Resources

Gila National Forest History

The Gila National Forest has a rich archaeological and cultural history. The Gila National Forest 

includes lands that have been used and occupied by humans through the prehistoric era, 

beginning with the Paleoindian period (circa 10000 B.C. to 5500 B.C.), into the Archaic period 

(circa 5500 B.C. to A.D. 200). Both the Paleoindian and Archaic period peoples were relatively 

mobile on the landscape. However, during the Archaic period the transition from a huntergatherer lifeways to agricultural lifeways occurred.

Over time, Archaic period peoples began to develop cultural lifeways that would come to be 

known as the Mogollon Culture. The Mogollon Culture spans two broad time periods: the 

Pithouse period (circa A.D. 200 to 1000) and the Pueblo period (circa A.D. 1000 to 1450). As the 

name implies, Pithouse period structures were at least partially subterranean, and dug sub-grade 

below the surrounding surface. The beginning of the Pueblo period (circa A.D. 1000 to 1400) is 

marked primarily by the appearance of above ground architecture.

The historic period began in New Mexico with Spanish contact in 1539. On the Gila National 

Forest and elsewhere in New Mexico, the historic period is divided by the rise and fall of political 

control by the Spanish (A.D. 1539 to 1821), Mexican (A.D. 1821 to 1848), and American (A.D. 

1848 to present) governments (Opler 1983).

Contemporary and historic land uses include mining, ranching, grazing, logging, frontier 

settlement, frontier military activities, and government land management. Evidence of these 

activities persists in the archaeological record today. Since the establishment of the Gila National 

Forest in 1905, ranger stations, administrative sites, lookouts, and recreational areas have been 

built as well. Finally, Civilian Conservation Corps camps and their constructed infrastructure (for 

example, roads, bridges and campgrounds) are found across the Gila.

Today, land use in the Gila National Forest continues to follow the multiple use mission of the 

Forest Service, including grazing, mining, ranching, and vegetation and fuels management. 

Native American Tribes also continue to use the Gila intermittently for traditional activities 

including plant gathering and visits to special places. Tribes have not identified any traditional 

cultural properties or sacred sites within the Luna Restoration Project area through consultation, 

nor have any been identified as being affected by other projects within the planning area.

Affected Environment

For around the past 50 years, Forest Service cultural resource specialists, in compliance with 

sections 106 and 110 of the National Historic Preservation Act of 1966, as amended, have 

inventoried approximately 17,415 (10 percent) of the 185,586 acre Luna planning area to current 

professional standards. An additional 50,638 acres have been inventoried within the Luna 

planning area; these inventories do not meet current standards.

For the Gila National Forest and the Southwest Region (Region 3) of the Forest Service, a 

cultural resource site is defined as “a locus (location) of purposeful human activity which has 

resulted in a deposit of cultural material beyond one or a few accidentally lost artifacts” (USDA 

Forest Service 1987). In practical terms, cultural resource sites include such entities as prehistoric 

surface structures (pueblos); concentrations of broken pottery sherds, stone tool waste flakes, 

grinding implements, or a combination of these things; or the remains of historic structures or 

mines.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

158

The survey endeavors discussed above have recorded 513 heritage resource sites within the 

planning area. No properties listed in the National Register of Historic Places are located within 

the Luna planning area. About 209 sites located in the planning area have been determined to be 

eligible for inclusion in the National Register of Historic Places, and about 37 sites have been 

determined to be not eligible. About 278 sites remain unevaluated and will require further study 

before a formal determination of eligibility for inclusion in the National Register of Historic 

Places can be made. For this project, only sites considered eligible for inclusion in the National 

Register of Historic Places, and those sites whose eligibility is undetermined, will require 

treatments to protect them from potentially adverse effects associated with project activities.

Analysis

The National Environmental Policy Act analysis considers only the change to the existing 

condition. Changes include proposals for vegetation treatment through mechanical means, hand 

thinning, prescribed burning, herbicide application, or a combination of these treatments. Other 

treatments include the construction of temporary roads; the decommissioning of roads; the 

construction, installation, or both of various range management features (wells, fences, storage 

tanks, etc.); and watershed improvement activities (construction of hardened crossings, erosion 

control features, riparian exclosure areas, etc.).

For the intent of the current analyses, the area of potential effect for the Luna planning area 

environmental analysis is considered to be those areas where:

• heavy equipment will be used to implement project activities (vegetation thinning, 

watershed restoration treatments, range management treatments, treatments to the 

transportation system, etc.);

• there is a high probability of site location for prescribed burning activities (if these areas 

fall outside of those where heavy machinery will be used during implementation);

• there is a high probability of site location for areas to be opened up for personal fuelwood 

collection (if these areas are greater than 500 acres in size); or

• there is a high probability of site location for other methods of herbicide application (with 

hand pumps, spread from back of all-terrain and utility-task vehicles, etc.).

Gila National Forest personnel believe this area of potential effect adequately measures and 

addresses the potential direct, indirect, and cumulative effects of the proposed undertakings and 

are in agreement with those identified in section I, appendix J, of the Region 3 amended 

programmatic agreement (USDA Forest Service, Region 3 2010).

Relative Risk Analysis

This report uses a relative risk analysis to compare alternatives. Relative risk is considered the 

potential impact that can result from one action (alternative) measured against the potential 

impact that might result from a different action (alternative).

For cultural resources, the measure for direct and indirect effects for all actions will be based on 

the total survey acres needed by different proposed project activities. Since only 10 percent of the 

Luna planning area has been intensively surveyed, simply using the number of sites potentially 

affected by undertakings would leave vast areas unaccounted for in the planning area. However, 

the number of known sites is positively correlated with the miles or acreage of survey, as one 

increases so does the other. Therefore, the alternatives proposing more miles or acres per action 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

159

will pose a higher risk of direct and indirect effects to cultural resources. Conversely, those 

posing fewer miles or acres per action will pose a lower risk of these effects.

Background Assumptions

Only 25 percent of 6th-code watershed will be treated within a three-year period. While this 

stipulation is posed in efforts to lessen direct, indirect, and cumulative effects to watersheds, it 

provides a maximum amount of work that can be conducted within each 6th-code watershed 

within a three-year span. This stipulation also allows for areas to be monitored for treatment 

effects to resources and lessen the potential for adverse cumulative effects to various program 

resources.

We assume all areas listed within a particular treatment category (for example, grassland 

maintenance and restoration, group select commercial and noncommercial thinning, 

woodland/ponderosa pine transition maintenance and restoration vegetation treatments; 

decommissioning of roads; and pipeline installation) will receive treatments. This assumption is 

made due to uncertainties concerning local conditions within the larger planning area. Thus while 

an area may be listed to receive group select commercial and noncommercial thinning, local 

conditions may not favor these activities across the entire proposed treatment area.

Measures

The measure for determining the relative risk of different alternatives is the total acres of 

archaeological survey needed for different activities associated with the different proposed 

alternatives. Over much of the larger Luna planning area, there is general correlation between the 

proportion of an area that has been covered by intensive cultural survey and the proportion of 

known sites within the planning area. ArcGIS was used to determine how many acres of 

inventory were needed for the different alternatives.

Environmental Consequences

Alternative A

No activities would be implemented under this alternative; therefore, no acres of archaeological 

inventory are required and therefore no relative risk of potential impact to sites.

The main concern with respect to heritage resources under the no-action alternative is the 

potential for high-severity wildfire to affect deposits associated with archaeological sites within 

the proposed project area. Under this alternative, fuel loads within the project area would be 

allowed to accumulate, increasing the severity and duration of fires that may spread into the area. 

These concerns are potentially exacerbated if one considers the possibility of increased fire 

susceptibility brought about by disease and deterioration, which could occur if treatments are not 

implemented in the project area. If a wildland fire does not spread into the area, these concerns 

could still adversely affect heritage resources, as trees within site boundaries are more prone to 

decay, uprooting, partially collapsing on or within deposits, or a combination of these things. 

Similarly, poorly functioning watershed in the planning area are more prone to severe erosion 

episodes. Such episodes have the potential to adversely affect heritage resources due to arroyo 

headcutting and channel cut-bank scouring. These effects will be allowed to continue under the 

no-action alternative. In short, the no-action alternative increases the probability heritage 

resources will be adversely affected in the foreseeable future.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

160

Effects Common to Alternatives B, C, and D

Amount of Archaeological Inventory Needed per Alternative

In general, all action alternatives will require extensive survey for heritage resources and most

proposed activities are common to all action alternatives. All areas where heavy machinery will 

be used in project implementation will require 100 percent intensive inventory. Mechanical 

treatments shared by all action alternatives include roughly 73,856 acres of mechanical vegetation 

treatments. The following acres may require heavy machinery for implementation:

• approximately 344 acres of range management treatments

• roughly 1,354 acres of treatments to the transportation system

• in excess of 1,000 acres of watershed restoration treatments

The implementation of treatments using traditional hand tools may require additional inventory 

especially if these activities require substantial ground disturbance (for example, construction of 

prescribed fire control line and construction of fence lines) or if they are located in areas 

determined to contain a high probability for archaeological site location. Hand thinning of 

vegetation may require additional inventory if heavy machinery (for example, skidder and 

masticator) will be used afterwards to treat activity fuels. Approximately 25,400 acres of 

grassland and portions of Mexican spotted owl protected activity centers may be treated by hand 

thinning. Likewise, areas that are to be burned by prescription will require inventory if these 

locales are determined to contain a high probability of site location and if these areas were not 

inventoried previously for other treatments. Roughly 36,000 acres in all action alternatives are 

planned to be treated solely by prescribed burning. An additional 70,000 to 100,000 acres will be 

burned by prescription following mechanized treatments in all action alternatives.

The amount of survey needed for the implementation of the different action alternatives is the 

same with respect to the proposed treatments. The main difference between action alternatives is 

the potential for additional inventory to implement the treatment of vegetation by the application 

of herbicide as proposed in alternative C. In alternative C, there is the potential need to survey 

areas where herbicide will be applied if these areas are determined to contain a high probability of 

site location. At present, areas where herbicide may potentially be applied cover an area of 

roughly 43,000 acres. Within this approximately 43,000-acre area, roughly 28,000 acres have 

been determined to be high site probability areas. Under alternatives B and D, roughly 20,283 

acres of grassland will be mowed to treat rabbitbrush. These treatments may require additional 

inventory depending on the type of equipment used during implementation. Alternative C may 

actually require only 8,000 more acres of inventory for areas where herbicide will be applied to 

treat juniper encroachment than alternatives B and D. However, this depends on where 

implementation will occur within the larger 43,000-acre potential herbicide treatment area.

Under alternatives B and C, roughly 13.8 miles of level 1 closed roads will be reopened to all 

motor vehicles types, roughly 4 miles of user-created roads will be designated as National Forest 

System roads and opened to all motor vehicle use, and roughly one-half mile of 4x4 trail will be 

constructed. These changes are not proposed under alternative D. However, under alternative D, 

the 13.8 miles of level 1 closed roads that are proposed to be reopened under alternatives B and C 

will be decommissioned. Under these circumstances, alternative D may require an additional 167 

acres of inventory for the additional 13.8 miles of road. However, maintenance work may need to 

be conducted along the road sections that will be reopened under alternatives B and C to make 

them operable. Thus, the discrepancies with respect to treatments to the transportation system 

under all action alternatives amount to negligible changes in the amount of inventory needed prior 

to implementation.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

161

Direct Effects

Direct effects to heritage resources associated with the proposed undertakings under all action 

alternatives include those brought about ground-disturbing activities, those potentially associated 

with the increased visibility of archaeological sites on the landscape, and those potentially 

associated with the introduction of either prescribed fire or riparian woody species within the 

planning area. These activities all have the potential to adversely affect deposits associated with 

heritage resources.

To mitigate the effects associated with the proposed undertakings heritage resources within the 

different project areas; such things as flagging may be utilized to avoid sites or other alternative 

methods depending on the activity being performed. In most instances, avoidance of sites will be 

the preferred mitigation measure. However, in certain circumstances like vegetation thinning and 

the prescribed burning of areas, other measures may be implemented, such as hand thinning of 

vegetation within archaeological sites following mechanized treatments or removing additional 

fuels from archaeological sites. This will increase the likelihood that treatment measures will 

attain the desired outcome. This is particularly true for areas where high site densities are 

avoided. This will increase the likelihood that prescribed fire treatments will not adversely affect 

heritage resources. Hand treatments (for example, cutting rabbitbrush, herbicide application, and 

other similar activities) would pose no adverse effect to heritage resources.

In the event new heritage resources are discovered during the implementation of any of the 

activities outlined above, work would cease in the area and a Forest Service archaeologist notified 

as to its presence. Work may resume in the area surrounding the newly identified archaeological 

site once appropriate treatment measures have been identified and consulted upon.

Indirect Effects

The primary indirect effects associated with proposed undertakings with respect to heritage 

resources are the potential for increased erosion rates within or near heritage resources resulting 

from the loss of canopy and ground cover; the increased visibility of archaeological sites during 

and after treatment implementation, which could lead to increased looting; and the potential for 

increased cattle grazing within archaeological sites due to changes in vegetation communities and 

ground cover. However, because the proposed action stipulates activities will be conducted in 

stages (for example, in units or individual stands within units), the indirect effects of previous 

treatments can be monitored to determine if heritage resources are being adversely impacted.

Cumulative Effects

As stated above, cumulative effects refer to the impact of an action on the environment which 

results from the incremental impact of the action when added to other past, present, and 

reasonably foreseeable future actions. Since the National Historic Preservation Act was fully 

implemented in the 1970s, cultural resource surveys have been conducted and potential effects to 

cultural resources addressed through consultation between the Gila National Forest staff, State 

Historic Preservation Officer, the Tribes, Advisory Council on Historic Preservation personnel, 

and interested members of the public. Future projects occurring on National Forest System lands 

will require appropriate compliance with National Historic Preservation Act including cultural 

resources inventories and evaluation of effects of the undertaking. If effects are identified, they 

will be addressed under the section 106 process of the act. Adverse effects will be minimized 

through avoidance or mitigation measures, as appropriate.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

162

To date, approximately 400 previous projects have been conducted within the planning area and 

cover a variety of resource areas (for example, engineering, timber, range, heritage, and 

recreation). Those that have been conducted within the past five years have dealt with impacts 

associated with the Wallow Fire of 2011 (for example, hazard tree salvage sales and prescribed 

burning of hazardous fuel loads), those associated with implementation of the Travel 

Management Rule, and those seeking to improve the rangeland management infrastructure (for 

example, water systems and tank cleaning). At present, the only projects slated for the foreseeable 

future are those proposed as part of the current landscape restoration proposal.

Implementation of the proposed treatments, combined with past, present, and reasonably 

foreseeable activities is not expected to negatively impact heritage resources within the project 

area. The greatest potential for cumulative impacts to heritage resources in the area come from 

the potential for increased erosion rates associated with decreased canopy and ground cover. 

However, archaeological sites in the larger Mogollon area are, more often than not, located on 

stable landforms which do not experience sediment transfer rates greater than five tons per acre 

per year regardless of the canopy, ground cover conditions, or both (Toney 2012, Toney and 

Taliaferro 2009). This value (five tons per acre per year) was that determined to be the extreme 

erosion rate based on Z-score values for areas on the Gila National Forest and surrounding lands 

(Toney 2012, Toney and Taliaferro 2009). The majority of heritage resources tend to be located 

on landforms that experience less than this amount of erosion in a year.

Beneficial Effects

As stated in the analysis of effects associated with the no-action alternative (alternative A), if 

current conditions are allowed to continue, heritage resources stand a greater chance of being 

adversely affected by severe erosion episodes as well as wildland fire. The proposed treatments 

will mitigate the possibility of a catastrophic wildland fire affecting heritage resources, and the 

proposed watershed restoration treatments will lessen the probability that heritage resources are 

adversely affected by arroyo headcutting and stream channel scouring within the treatment areas. 

Similarly, the changes to the transportation system will decrease the probability that motorized 

travel will impact heritage resources because more miles of road are slated for decommissioning 

than are being added to the road system.

Effects of Climate Change on Cultural Resources

The Intergovernmental Panel on Climate Change posits that if emission of greenhouse gasses (for 

example, carbon dioxide, methane, and nitrous oxide) continues along its current trajectory, that 

global temperatures will continue to rise (IPCC 2014). This will lead to a decrease in cold 

temperature extremes, an increase in warm temperature extremes, an increase in extreme high sea 

levels, and an increase in the number of heavy precipitation events in some regions of the world. 

In some portions of the world, heat waves are expected to increase in frequency and duration and 

precipitation events are expected to increase in intensity though will become sporadic in their 

frequency of occurrence (IPCC 2014). All of these general trends have the potential to adversely 

affect heritage resources in the planning area.

Perhaps the greatest threat that climate change poses to heritage resources is the increased threat 

of erosion. As temperatures rise, vegetation communities are likely to be affected. Elevational 

shifts in vegetation communities, extreme fire events, or both could lead to reduced canopy cover 

available to intercept precipitation and reduce raindrop impact energies and loss of vegetative 

ground cover (basal area plus litter). This loss of vegetative ground cover combined with more of 

the precipitation falling in higher intensity storms increases the risk of erosion. This erosion risk 

can lead to increased sediment delivery to stream channels and potentially altered flow regimes 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

163

and stream channel dynamics such as degradation (downcutting) or aggradation. Channel 

downcutting events, increased arroyo formation, and shifts in stream channel dimension or 

location have the potential to destroy or damage heritage resources located in the Luna planning 

area.

Social and Economics

Affected Environment

The Luna Restoration Project is located entirely within Catron County. The main community 

within the planning area is Luna, New Mexico, a nonincorporated area of Catron County with a 

population of 158 (U.S. Census Bureau 2010). The project is adjacent to Apache and Greenlee 

counties in Arizona along the state line. These three counties form the social and economic 

analysis area. County-level data are used for the analysis, since reliable demographic and 

economic data are readily available.

Population and Demographics

Each of the counties have experienced positive population growth between 2000 and 2015. 

Catron County had the smallest estimated change of 1.1 percent over that period compared to 

Apache County at 3.9 percent and Greenlee County, 5.6 percent. But all are far below the national 

growth of 12.5 percent (Economic Profile System 2017a).

The median age of the population in Catron County and the community of Luna is approximately 

57. The median age of the population in Catron County is much older compared to the other two 

Arizona counties (median age 33), both states (median age 37), and the nation (median age 37) 

(Economic Profile System 2017a).

The racial and ethnic composition of the study area offers context for the social analysis. Table 59

shows the racial and ethnic breakdown of the counties and their respective states. The majority of 

the residents self-identify as white in Catron and Greenlee counties. Apache County differs with 

having a higher percentage of American Indians than the other counties. Greenlee County almost 

half of their population self-identified as Hispanic or Latino. Racial identification within Catron 

and Greenlee counties are similar, but for ethnic composition Catron and Apache counties had 

similar trends.

Compared to state information, different ethnic and racial compositions of the counties varied 

from state percentages. Noticeable differences between each of the states and their respective 

counties are the variability of the ethnic breakdowns and the difference in percent population in 

White and American Indian populations across the analysis area (table 59).
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

164

Table 59. Racial and ethnic breakdown of counties within the analysis area

Area

Ethnicity 

NonHispanic

Ethnicity 

Hispanic

Race 

White

Race 

African 

American

Race 

American 

Indian

Race 

Asian 

Pacific 

Islander

Race 

Other

Catron County 82% 18% 96% Less than 

1%

Less than 

1%

0% 1%

Greenlee County 53% 47% 89% 2% 4% Less than 

1%

1%

Apache County 94% 6% 23% 1% 72% Less than 

1%

2%

New Mexico 52% 48% 39% 2% 9% 1% 2%

Arizona 70% 31% 56% 4% 4% 3% 2%

Note: Ethnicity relates to identification as either Hispanic/Latino or not. Hispanic/Latino individuals may identify as any

members of any racial groups. The “Other” group includes two or more races.

Source: Economic Profile System 2017a.

Lifestyles, Values, Beliefs, and Attitudes

Firewood gathering on the Gila National Forest is particularly tied to livelihoods in some of the 

communities. Wood for fires continues to be widely used either aesthetically or as the primary 

heat source within homes. Approximately 46 percent of the housing units in Catron County rely 

on wood as their primary heat source (U.S. Census Bureau 2000). In comparison, the community 

of Luna, New Mexico within Catron County estimates 60 percent of the housing units rely upon 

wood (U.S. Census Bureau 2006–2010 American Community Survey). Apache County also has a 

high reliance of wood as heat source at 50 percent. In contrast, Greenlee County reports more 

than 75 percent of the housing units rely on utility gas as primary heat source (U.S. Census 

Bureau 2000). The use of wood for heating homes may be tied to long-term customs, traditions,

and culture of the community.

The Gila National Forest is currently undergoing forest plan revision. Participants relayed 

concerns regarding the forest and natural resource management (USDA Forest Service 2017b):

• there is a desire for the maintenance of quality recreational experiences

• there is wide recognition of the overgrown conditions of many of the forest types and 

juniper encroachment of the grasslands

• there is concern about the increased risk of uncharacteristic wildfire, and threats to 

private property and adjacent communities

• there is broad interest in fuel management strategies such as thinning and prescribed fire

• many people would like to see more timber harvesting and grazing to support local

economies

• there is concern about diminishing water supplies and water quality, and conditions of the 

forest, wildlife habitat and watershed health

Employment and Income

Per capita income in the study area is lower than the per capita income per state and nation. 

Apache County has the lowest per capita income compared to other two counties (table 60).
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

165

Table 60. Per capita income and percentage of labor or non-labor source and unemployment for 

counties in the analysis area, state, and nation

Geographic Area

Per Capita 

Income

(2015 dollars)

Labor

(2015)

Non-Labor 

(2015)

Unemployment 

(2016)

Catron County $20,685 38% 62% 8.2%

Greenlee County $21,994 77% 23% 7.6%

Apache County $13,011 62% 38% 11.3%

New Mexico $24,012 75% 25% 5.3%

Arizona $25,848 75% 25% 6.7%

United States $28,930 78% 22% 4.9%

Source: Economic Profile System 2017a.

The percentage of people below the poverty level in Catron County is 17 percent, which is less 

than the New Mexico level of 21 percent. Poverty level in Greenlee County is 14 percent and 

Apache County 37 percent, with Arizona being at 18 percent. Apache County has the highest 

percentage of people below the poverty line. Catron and Greenlee counties are comparable to the 

national level of 16 percent (table 61).

Table 61. Median household income and percentage of persons in poverty in 2015

Geographic Area Median Household Income

Percentage of persons below 

poverty line

Catron County $42,973 17%

Greenlee County $51,628 14%

Apache County $31,757 37%

New Mexico $44,963 21%

Arizona $50,255 18%

United States $53,889 16%

Source: Economic Profile System 2017a.

Forest Products Related Employment

According to the Gila National Forest Assessment Report (USDA Forest Service 2017b):

...the mill in Reserve, New Mexico employs eight people at the mill and up to ten people 

on timber sales. There are also approximately five active smaller mills that purchase 

timber to produce rough-cut lumber and other forest products on a limited scale and at 

least seven fuelwood businesses based upon sales of permits. The number of employees 

in these businesses is not known and many may be self-employed businesses with no paid 

employees. In 2013, timber-related jobs accounted for less than one percent of private 

sector employment within the four counties: Catron, Sierra, Grant and Hidalgo; that the 

Forest is situated (Headwaters Economics 2016). Catron County has the largest percent 

of the total timber-related employment due to the number of permits sold and the location 

of these businesses.

Employment in timber related jobs for 2015 (Economic Profile System 2017b) in Catron County 

was approximately 3.5 percent of the total private employment and 1.3 percent in Apache County. 

No timber-related employment comprised private employment in Greenlee County.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

166

Environmental Consequences

Alternative A

There would be no change in management within the planning area. Fuelwood gathering would 

still be allowed, access on the current motorized road and trail transportation system would 

continue. However, no restoration projects would occur. If a high-severity wildfire were to occur 

in the area, there is a potential for temporary impacts to recreational uses or enjoyments such as 

hunting, scenery or visual conditions. Smoke emissions generated would be greater and 

unplanned, causing impacts to those sensitive to smoke. Damage to infrastructure such as power 

lines, communication systems, etc. within the planning area as well as property damage could 

result in substantial costs for repair, replacement, or restoration.

With no proposed vegetation treatments, there would be no opportunity generated for economic 

benefit to local contractors or industries and employment associated with timber or other forest 

products that could be contracted. This lack of opportunity would be the same for not 

implementing any of proposed treatments.

Cumulative Effects

There are no activities being implemented under alternative A, current activities (for example, 

grazing, hunting, and hiking) would continue. There are currently no other management activities 

within the planning area that would improve forest and watershed health relative to existing 

conditions. The Apache-Sitgreaves National Forests is currently implementing the West Escudilla 

Project, which includes vegetation management projects, prescribed burning, and other 

restoration activities. Since alternative A would not prescribe additional treatments, it would not 

cause cumulative effects related to smoke emissions from prescribed fire. However, the risk of 

uncharacteristic wildfire and associated smoke emissions would be highest under this alternative.

Effects Common to Alternatives B, C, and D

The supply and demand for timber is driven by regional and national needs and markets. Demand 

for woody material is largely driven by fuelwood needs and other local demand for woody 

material for rough-cut lumber, fuelwood, and other specialty products from local mills. With 

approximately 74,000 acres of forest and woodland to be treated, the Gila National Forest would 

be able to contribute to the demand for forest products and needs of local mills located in or 

adjacent to the planning area. There is the potential for economic benefit to local contractors or 

industries and increased employment associated with timber or other forest products that could be 

contracted.

The range of projects to be implemented under all action alternatives of the Luna Restoration 

Project have the potential for providing various employment and economic opportunities for local 

individuals, contractors, or industries.

Activities such as herbicide utilization under alternative C, smoke from prescribed fires, increased

vehicle traffic on roads, and increased noise from equipment and vehicles have the potential for

social consequences. Activities would be periodic and occurring across differing locations across 

the planning area. This may prevent individuals from partaking in various outdoor activities or 

recreating in their favorite places; and may be displaced for short periods and may have less 

pleasure in their alternate locations.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

167

Under alternative D, there would be a loss of motorized recreational opportunity compared to 

alternatives B and C. Alternative D does not add to the motorized transportation system closed 

and user-created routes that would provide loop and access in and around the community of Luna. 

This would not be favorable for members of the community who collaboratively worked with the 

Forest Service to identify these routes.

Environmental Justice

The goal of environmental justice is for agency decision makers to identify impacts that are 

disproportionately high and adverse with respect to minority and low-income populations and 

identify alternatives that will avoid or mitigate those impacts. None of the alternatives would 

reduce employment and income relative to current conditions, therefore, no disproportionate 

adverse economic effects would occur.

Smoke emissions from prescribed fire or wildfire can have health and quality of life 

consequences and is most likely to affect vulnerable populations—children, the elderly, and 

individuals with health or respiratory issues. The intensity and duration of emissions are variable, 

but prescribed fires follow a written prescription that allows managers to minimize smoke 

impacts. The Forest Service is also required to work with the New Mexico Environmental 

Department, Air Quality Bureau to ensure smoke impacts to human health are avoided or 

minimized. The advance notice associated with prescribed burns allows individuals with 

sensitivity to smoke to engage in averting behavior, reducing the negative quality of life impacts.

Households that rely upon fuelwood as their primary heat source would be able to continue to 

collect fuelwood and with vegetation treatments, the opportunity for additional sources may be 

realized. None of the alternatives are expected to adversely affect low-income families who 

depend on fuelwood.

Forest Plan Amendments

The amendments to exceed acres per decade to treat activity fuels with prescribed fire; wildlife 

habitat improvement structures and acres; vegetation treatments in Mexican spotted owl habitat 

would have both negative and beneficial impacts on social and economic considerations and 

environmental justice. The ability to treat more acres of activity fuels with prescribed fire will 

contribute to negative impacts of smoke emissions on social and environmental justice 

considerations but would contribute to the associated vegetation treatments by reducing the risk 

of wildfire. The amount and type of restoration activities and employment and income would not 

change from previously described under alternatives. Amendments would assist in accomplishing 

restoration efforts across the landscape.

Cumulative Effects

Within the planning area, current activities (for example, grazing, hunting, and hiking) would 

continue. There are no other ongoing vegetation or prescribed burning activities within the Luna 

planning area, but restoration efforts within the larger Escudilla Landscape have started on the 

Apache-Sitgreaves National Forests with implementation of the West Escudilla Project. There is a 

potential for increase in employment and income, but it is not expected to significantly change the 

current percentages of forest product related employments in the three counties.

Ongoing prescribed fires from the Apache-Sitgreaves National Forests and Luna Restoration 

Project will contribute to smoke emissions, potentially affecting the health and quality of life of 

individuals who live near or visit the Gila National Forest. Together, both could cause cumulative 
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

168

effects to health and quality of life for individuals who are sensitive to smoke. However, the 

cumulative effect of these treatments would go toward decreasing the risk of a wildfire, 

decreasing the impacts of smoke emissions from that type of event.

Short-term Uses and Long-term Productivity

The National Environmental Policy Act requires consideration of “the relationship between shortterm uses of man’s environment and the maintenance and enhancement of long-term 

productivity” (40 CFR 1502.16). As declared by the Congress, this includes using all practicable 

means and measures, including financial and technical assistance, in a manner calculated to foster 

and promote the general welfare, to create and maintain conditions under which man and nature 

can exist in productive harmony, and fulfill the social, economic, and other requirements of 

present and future generations of Americans (National Environmental Policy Act section 101).

The implementation of any of the treatments within the action alternatives does not jeopardize the 

long-term productivity of the Gila National Forest. As described in chapter 3, implementing the 

action alternatives would improve forest and woodland stands health and improve wildlife 

habitat, including habitat for threatened, endangered, and sensitive species. There would be 

reduction in the risk of large uncharacteristic wildfires and its impacts to the landscape, 

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

overall implementation of the action alternatives would improve resources such as range 

condition, wildlife and aquatic habitat, soil conditions, and others. Actions like erosion control 

and reducing risk of wildfire would reduce impacts to sensitive resources like water quality, 

cultural resources, and air quality.

Unavoidable Adverse Effects

For all action alternatives, smoke emissions are unavoidable adverse impacts that have the 

potential to affect health and quality of life for individuals who are sensitive to smoke. The 

potential impacts of smoke are addressed in the “Air Quality,” “Recreation,” and “Social and 

Economics” sections. The adverse effect would be reduced or minimized with Gila National 

Forest personnel following written prescriptions for prescribed fires, working with State Air 

Quality Departments, and advance notice, allowing individuals with sensitivity to smoke to 

engage in averting behavior, to reduce the negative impacts of smoke.

There is a risk of introduction, establishment and spread of invasive plants to new locations with 

ground disturbing activities with mechanical equipment, prescribed fires, and adding new 

motorized routes. Implementation of design features and monitoring were included to reduce this 

risk.

Adding motorized routes to the system may cause a loss of soil productivity under all alternatives. 

Alternative B and C with 13.8 miles of roads being added to the system will result in more bare 

ground than alternative D, which adds 0.2 mile of road. There will be a loss of soil productivity in 

varying degrees and time for the other motorized transportation activities like temporary roads, 

reopening roads and then closing again, and decommissioning.
Chapter 3. Affected Environment and Environmental Consequences

Luna Restoration Project 

Final Environmental Impact Statement

169

Irreversible and Irretrievable Commitments of Resources

Irreversible commitments of resources are those that cannot be regained, such as the extinction of 

a species or the removal of mined ore. Irretrievable commitments are those lost for a period of 

time, such as the temporary loss of timber productivity in forested areas that are kept clear for use 

as a power line rights-of-way or road.

All resources were evaluated to determine if there would be irreversible or irretrievable 

commitment of resources. Except for following resources, no other resources identified 

irreversible or irretrievable commitments.

Watershed and Soils

Alternative A already possesses an intrinsic commitment of the soil resource from closed roads 

that are not decommissioned. Continuation of closed roads, without attempts to decommission 

would allow this commitment to continue, with little possibility of soil conditions returning to 

their natural state.

The selection of any of the action alternatives allows for decommissioning of between 114 and 

130 miles of travel routes, which would aid in reversing and retrieving soil resource conditions.

Timeframes for recovery will vary, dependent on type of decommissioning implemented and site 

conditions, including parent material, soil depth, available nutrients, climatic conditions, and 

herbaceous recovery.

The addition of roads for administrative and recreation opportunities range from 4.2 to 17.8 miles 

for the action alternatives. Impacts to soil conditions on these miles would result in additional 

area of irreversible and irretrievable commitment of soil resources.

Heritage

There is a relatively low risk of irreversible commitment of heritage resources across all action 

alternatives. This risk of irreversible commitment primarily arises from the potential for ground 

disturbing activities to completely destroy archaeological sites. In general, this risk of irreversible 

commitment of resources is the same across all action alternatives as they essentially share 

similar proposed ground disturbing activities.

Inventoried Roadless Areas

Irreversible or irretrievable commitments of roadless resources could occur under alternative A. 

In the event of a wildfire due to continuing existing stand conditions (crown fire potential), the 

roadless resources could be at risk to irretrievable outcomes, including species and habitat loss,

until vegetation becomes established. Special features, such as perennial water sources, could be 

affected by post-fire erosion and debris flows. There are no irreversible commitments.

There would be no irreversible or irretrievable commitments to roadless resources with action 

alternatives B, C, or D. The likelihood of severe wildfire and the associated impacts would be 

reduced in the treated areas, lowering the risk of an irretrievable effect.

Luna Restoration Project 

Final Environmental Impact Statement

171

Preparers and Contributors

List of Preparers

T. H. Buhl – Fire Management Specialist, USDA Forest Service, Enterprise Program. 

Education: Undergraduate education in Fire Technology, American River College and Range 

Science, Montana State University. Experience: Fire Management Specialist (2009 to present) 

Enterprise Program; Assistant Fire Management Officer (2006–2009). Other Forest Service 

experience includes fire operations positions on national forests in Region 1 and Region 2 (2000–

2006), and timber and range management (1998–2000).

Ralph Fink - District Range Staff, USDA Forest Service, Quemado Ranger District, Gila 

National Forest. Education: B.S. Secondary Education, Natural Sciences from Chadron State 

College and M.S Range Science, Plant Systematics and Floristics from New Mexico State 

University. New Mexico Licensed Pesticide Applicator. Experience: 10 years as a Forest Service 

Range Management Specialist in Southern New Mexico, Forest Botanist (1 year) and District 

Range Staff (2016 to present).

David Fothergill – Forest Landscape Architect, USDA Forest Service, Enterprise Program. 

Education: B.S. Biology, University of Kentucky; Master of Landscape Architecture, University 

of Oregon. Experience: 15 years public land management in recreation planning and ecological 

restoration.

Kathleen Hawkos – GIS Specialist, USDA Forest Service, Gila National Forest. Education: 

M.S. Geography with emphasis in GIS. Experience: Technical background in GIS spatial 

analysis, special management areas needs assessments, ABV survey; GIS data collection, 

organization, maintenance and distribution; GIS and Infrared Imagery Interpretation for fire 

support; Southwestern Regional cartographic map production and technical support; project lead 

on Quad Atlas production for Southwestern Region forests; development and maintenance of the 

Southwestern Region Motor Vehicle Use Map website. GIS Specialist (2004–2012; 2016 to 

present) and Cartographic specialist (2012–2016) with the Forest Service, Southwestern Region.

Timothy Hendricks – District Wildlife Biologist, USDA Forest Service, Gila National Forest, 

Quemado Ranger District. Education: B.S. Forestry and Wildlife Management with a minor in 

chemistry. Experience: Firefighter (2 years); Fuels Specialist (9 years); Wildlife Biologist (4 

years) working on habitat and endangered species management, species consultation, and 

National Environmental Policy Act projects.

Emily Irwin – Quemado District Ranger, USDA Forest Service, Gila National Forest, 

Quemado Ranger District. Education: B.S. Forestry Northern Arizona University. Experience: 30 

years of service with the Forest Service in the Southwestern Region, with 3 years as the Quemado 

District Ranger. Background in fire and fuels management.

Carolyn Koury – Hydrologist, USDA Forest Service, Gila National Forest. Education: B.S. 

Speech Communication, Northern Arizona University; M.S. Hydrology, University of Arizona. 

Experience: hydrologist on the Apache-Sitgreaves National Forest (1994–2002); forest 

hydrologist (2002 to present) on the Gila National Forest.
Preparers, Contributors, and Distribution

Luna Restoration Project 

Final Environmental Impact Statement

172

Natalie Morgan – Silviculturist, USDA Forest Service, Enterprise Program. Education: B.S. 

Forest Resource Management and B.A. in Spanish Literature from the University of Montana; 

M.S. Forestry, Northern Arizona University. Experience: 11 years in the Forest Service in 

Regions 1 and 2. Forester trainee (2008–2011); Forester (Silviculture) (2011–2016); Silviculturist 

(2016 to present) with the Enterprise Program.

Lisa Mizuno – Environmental Coordinator, USDA Forest Service, Gila National Forest. 

Education: B.S. Oceanography with a minor in biology, Humboldt State University; M.S. 

Interdisciplinary degree in fisheries and estuaries, Humboldt State University. Experience: 

fisheries biologist on the Six Rivers (1991 to 1999) and San Bernardino (1999 to 2003) national 

forests. Interdisciplinary planner and assistant National Environmental Policy Act coordinator 

(2003 to 2011) and environmental coordinator (2011 to present) on the Gila National Forest,

assisting, reviewing, and leading team on various forest projects.

Michael Natharius – Soil Scientist, USDA Forest Service, Gila National Forest. Education: B.S. 

Agriculture with major in soil science. Experience: terrestrial ecological unit inventory, riparian 

inventory, vegetation inventory and monitoring, burned area emergency response team leader and 

member, and interdisciplinary team specialist. Soil scientist (1991 to present) with the Forest 

Service, Southwestern Region.

Rex A. Null – Civil Engineer, USDA Forest Service, Gila National Forest. Education: B.S. Civil 

Engineering, New Mexico State University. Experience: project manager for Burn Construction 

(2 years) and Civil Engineer (1991 to present) on the Gila National Forest.

Matthew Taliaferro - Archaeologist USDA Forest Service, Gila National Forest. Education: 

B.A. Anthropology; M.A. Anthropology; Ph.D. Anthropology. Experience: 15 years of Section 

106 and 110 CRM work in the Southern United States, geographic information sciences, peerreview process, lithic analysis, ceramic analysis. Archaeologist (2010 to present) with the Forest 

Service.

List of Contributors

Jason Cress – Fuels, USDA Forest Service, Tonto National Forest (Formerly Gila National 

Forest, Quemado Ranger District).

Colleen Nicholas – District Archaeologist, USDA Forest Service, Gila National Forest, Reserve 

and Quemado ranger districts.

Brian Park – GIS Coordinator, USDA Forest Service, Gila National Forest.

Gabe Partido – Timber and Fuels Program Manager, USDA Forest Service, Gila National 

Forest.

Laura Vallejos – Resource Forester, Silviculturist, USDA Forest Service, Gila National Forest.

Roger A. Williams - District Natural Resource Officer, USDA Forest Service, Gila National 

Forest, Quemado Ranger District.

Wayne Witty – Range Technician, USDA Forest Service, Malheur National Forest (formerly 

Range Management Specialist, Gila National Forest, Quemado Ranger District).
Preparers, Contributors, and Distribution

Luna Restoration Project 

Final Environmental Impact Statement

173

The Forest Service consulted the following federal, state, and local agencies, tribes and other 

organizations during the development of this environmental impact statement:

Federal, State, and Local Agencies

Apache-Sitgreaves National Forests

Bureau of Land Management, Socorro Field Office

Catron County Commission, County Manager, and Emergency Manager

New Mexico Department of Game and Fish

New Mexico Environmental Department

New Mexico State Forestry Division

U.S. Fish and Wildlife Service

Tribes

Alamo Navajo Chapter

Fort Sill Apache Tribe

Mescalero Apache Tribe

Pueblo of Acoma

Pueblo of Laguna

Pueblo of Zuni

Ramah Navajo Chapter

The Hopi Tribe

The Navajo Nation

San Carlos Apache Tribe

White Mountain Apache Tribe

Ysleta Del Sur Pueblo

Others

Luna Irrigation Ditch Association

Luna OHV Riders
Preparers, Contributors, and Distribution

Luna Restoration Project 

Final Environmental Impact Statement

174

Distribution of the Environmental Impact 

Statement

The draft environmental impact statement was distributed to 190 individuals, organizations, 

tribes, and local, state, and federal agencies who specifically requested a copy of the document

and those who submitted comments during public comment opportunities. The final 

environmental impact statement was distributed to individuals, organizations, tribes, and agencies 

who requested a copy or commented during public involvement opportunities. The environmental 

impact statement is available on the Gila National Forest website at Luna Restoration Project and 

available for review at the Quemado Ranger District office.

Copies of the draft and/or final environmental impact statements were mailed or provided 

electronically to the following federal agencies, federally recognized tribes, state and local

governments, and organizations:

Advisory Council on Historic Preservation

Alamo Navajo Chapter

Apache-Sitgreaves National Forests

Bureau of Land Management

Catron County

Center for Biological Diversity

Ecological Restoration Institute

Federal Aviation Administration

Federal Highway Administration

Fort Sill Apache Tribe

Mescalero Apache Tribe

New Mexico Department of Agriculture

New Mexico Department of Game and Fish

New Mexico Department of Transportation

New Mexico Environmental Department

New Mexico Environmental Department, 

Air Quality Bureau

New Mexico Environmental Department, 

Surface Water Quality Bureau

New Mexico Farm and Livestock Bureau

New Mexico State Forestry Division

New Mexico Wilderness Alliance

NOAA Fisheries Service

Pueblo of Acoma

Pueblo of Laguna

Pueblo of Zuni

Ramah Navajo Chapter

Salado Soil and Water Conservation District

San Carlos Apache Tribe

San Francisco Soil and Water Conservation 

District

State Historic Preservation Office

The Hopi Tribe

The Nature Conservancy

The Navajo Nation

The Quivera Coalition

U.S. Army Corps of Engineers

U.S. Coast Guard

U.S. Department of Energy

U.S. Department of the Navy, Energy and 

Environmental Readiness Division

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

USDA Animal and Plant Health Inspection 

Service, Policy and Program Development

USDA National Agricultural Library

USDA Natural Resources Conservation 

Service

USDI Office of Environmental Policy and 

Compliance

White Mountain Apache Tribe

WildEarth Guardians

Ysleta Del Sur Pueblo
Luna Restoration Project 

Final Environmental Impact Statement

175

Glossary

Administrative use - Authorized motor vehicle use on roads or trails to carry out forest 

management activities. This also includes use by permittees as authorized by permit or written 

authorization to conduct authorized activities.

Decommission - Demolition, dismantling, removal, obliteration, disposal, or a combination of 

these things of a deteriorated or otherwise unneeded asset or component, including necessary 

cleanup work. This action eliminates the deferred maintenance needs for the fixed asset. Portions 

of an asset or component may remain if they do not cause problems nor require maintenance. 

(Financial Health – Common Definitions for Maintenance and Construction Terms, July 22, 

1998).

Forest Transportation Atlas - A display of the system of roads, trails and airfields of an 

administrative unit. (36 CFR 212.1, Forest Service Manual 7705)

National forest transportation system - The system of National Forest System roads, National 

Forest System trails, and airfields on National Forest System lands. (36 CFR 212.1, Forest 

Service Manual 7705)

Maintenance levels - Defines the level of service provided by, and maintenance required for, a 

specific road, consistent with road management objectives and maintenance criteria. (Forest 

Service Handbook 7709.59, 62.32)

• Level 1 - These are roads that have been placed in storage between intermittent uses. The 

period of storage must exceed 1 year. Basic custodial maintenance is performed to prevent 

damage to adjacent resources and to perpetuate the road for future resource management 

needs. Emphasis is normally given to maintaining drainage facilities and runoff patterns. 

Planned road deterioration may occur at this level. Appropriate traffic management

strategies are “prohibit” and “eliminate” all traffic. These roads are not shown on motor 

vehicle use maps. Roads receiving level 1 maintenance may be of any type, class, or 

construction standard, and may be managed at any other maintenance level during the time 

they are open for traffic. However, while being maintained at level 1, they are closed to 

vehicular traffic but may be available and suitable for nonmotorized uses.

• Level 2 - Assigned to roads open for use by high clearance vehicles. Passenger car traffic, 

user comfort, and user convenience are not considerations. Warning signs and traffic 

control devices are not provided with the exception that some signing, such as W-18-1 “No 

Traffic Signs,” may be posted at intersections. Motorists should have no expectations of 

being alerted to potential hazards while driving these roads. Traffic is normally minor, 

usually consisting of one or a combination of administrative, permitted, dispersed 

recreation, or other specialized uses. Log haul may occur at this level. Appropriate traffic 

management strategies are either to:

♦ discourage or prohibit passenger cars; or

♦ accept or discourage high clearance vehicles.

• Level 3 - Assigned to roads open and maintained for travel by a prudent driver in a 

standard passenger car. User comfort and convenience are not considered priorities. The 

Manual on Uniform Traffic Control Devices is applicable. Warning signs and traffic control 

devices are provided to alert motorists of situations that may violate expectations. Roads in 
Glossary

Luna Restoration Project 

Final Environmental Impact Statement

176

this maintenance level are typically low speed with single lanes and turnouts. Appropriate 

traffic management strategies are either "encourage" or “accept.” “Discourage” or 

“prohibit” strategies may be employed for certain classes of vehicles or users.

• Level 4 - Assigned to roads that provide a moderate degree of user comfort and 

convenience at moderate travel speeds. Most roads are double lane and aggregate surfaced. 

However, some roads may be single lane. Some roads may be paved and/or dust abated. 

Manual on Uniform Traffic Control Devices is applicable. The most appropriate traffic 

management strategy is “encourage.” However, the “prohibit” strategy may apply to 

specific classes of vehicles or users at certain times.

• Level 5 - Assigned to roads that provide a high degree of user comfort and convenience. 

These roads are normally double lane, paved facilities. Some may be aggregate surfaced 

and dust abated. Manual on Uniform Traffic Control Devices is applicable. The appropriate 

traffic management strategy is “encourage.”

Motor vehicle - Any vehicle that is self-propelled, other than: (1) A vehicle operated on rails; 

and (2) Any wheelchair or mobility device, including one that is battery-powered, that is designed 

solely for use by a mobility-impaired person for locomotion, and that is suitable for use in an 

indoor pedestrian area. (36 CFR 212.1, 36 CFR 261.2, Forest Service Manual 7705, Forest 

Service Handbook 2309.18.05)

National Forest System road - A forest road other than a road which has been authorized by a 

legally documented right-of-way held by a state, county or other local public road authority. (36 

CFR 212.1, 36 CFR 251.51, 36 CFR 261.2, Forest Service Manual 7705, Forest Service 

Handbook 7709.56.40.5)

Road decommissioning (1) - Activities that result in the stabilization and restoration of unneeded 

roads to a more natural state. (36 CFR 212.1)

Road decommissioning (2) - Activities that result in restoration of unneeded roads to a more 

natural state. (Forest Service Manual 7705, Forest Service Manual 7734)

Temporary road or trail - A road or trail necessary for emergency operations or authorized by 

contract, permit, lease, or other written authorization that is not a forest road or trail and that is 

not included in a national forest transportation atlas. (36 CFR 212.1, Forest Service Manual 7705)

Unauthorized road or trail - A road or trail that is not a forest road or trail or a temporary road 

or trail and that is not included in a national forest transportation atlas. (36 CFR 212.1, Forest 

Service Manual 2353.05, Forest Service Manual 7705)

Written authorization - A written document that authorizes specific activities; may be a permit, 

letter or other written document.
Luna Restoration Project 

Final Environmental Impact Statement

177

References

36 CFR 212. Travel Management, Title 36 Code of Federal Regulations, Part 212. 2018 

electronic ed.

36 CFR 218. Project Level Predecisional Administrative Review Process, Title 36 Code of 

Federal Regulations, Part 218. 2018 electronic ed.

36 CFR 219. Planning, Title 36 Code of Federal Regulations, Part 219; Planning, Subpart A; 

National Forest System Land Management Planning, published April 9, 2012 (77 FR 

21162). 2018 electronic ed.

36 CFR 294. Special Areas, Title 36 Code of Federal Regulations, Part 294, Special Areas, 

Subpart B, State Petitions for Inventoried Roadless Management Area Management. 2018 

electronic ed.

40 CFR 1501. NEPA and Agency Planning, Title 40 Code of Federal Regulations, Part 1501. 

2018 electronic ed.

40 CFR 1502. Environmental Impact Statement, Title 40 Code of Federal Regulations, Part 1502.

2018 electronic ed.

Agee, J. K., and C. N. Skinner. 2005. Basic principles of forest fuel reduction treatments. Forest 

Ecology and Management 211:83-96.

Brockway, D.G., Gatewood, R.G., and Paris, R.B. 2001. Restoring grassland savannahs from 

degraded pinyon-juniper woodlands: effects of mechanical overstory reduction and slash 

treatment alternatives. Journal of Environmental Management (2002) Vol. 64, pages 179-

197.

Catron County community wildfire protection plan. 2005. Catron County, New Mexico.

Copstead, R., Moore, K., Ledwith, T., Furniss, M. 1997. Water/road interaction: an annotated 

bibliography. USDA Forest Service, Technology Development Program, San Dimas, CA.

Dissmeyer, D.E. (editor). 2000. Drinking water from forests and grasslands. a synthesis of the 

scientific literature. General Technical Report SRS-39. Asheville, North Carolina: U.S. 

Department of Agriculture, Forest Service, Southern Research Station. 246 p.

Dunne and Leopold. 1978. Water in environmental planning. W.H. Freeman and Company, New 

York. 818 p.

Economic Profile System. 2017a. A Profile of demographics, county region: Catron County, NM; 

Greenlee County, AZ; Apache County, AZ; Navajo County, AZ. Headwaters Economics 

Economic Profile System (https://headwaterseconomics.org/tools/economic-profilesystem/about/) June 1, 2017.

Economic Profile System. 2017b. A profile of timber and wood products, county region: Catron 

County, NM; Greenlee County, AZ; Apache County, AZ; Navajo County, AZ. 

Headwaters Economics Economic Profile System

(https://headwaterseconomics.org/tools/economic-profile-system/about/) June 1, 2017.
References

Luna Restoration Project 

Final Environmental Impact Statement

178

Frey, J.K. 2005. Status assessment of the Arizona montane vole (Microtus montanus arizonensis) 

in New Mexico, Final Report (Professional Services Contract 04-516.75). Submitted to: 

New Mexico Department of Game and Fish, Conservation Services Division, Santa Fe,

NM. 39 p.

Gibbons, D.R. and Salo, E.O. 1973. An annotated bibliography of the effects of logging on fish in 

the Western United States and Canada. U.S. Department of Agriculture. Forest Service. 

Portland, Oregon. Gen. Tech. Rep. PNW 10. 144 p.

Graham, R.T.; McCaffrey, S.; Jain, T.B. (tech. eds.) 2004. Science basis for changing forest 

structure to modify wildfire behavior and severity. Gen. Tech. Rep. RMRS-GTR-120. 

Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Research Station. 43 p.

Hardy, C.C., Schmidt, K.M., Menakis, J.M., Samson, N.R. 2001. Spatial data for national fire 

planning and fuel management. International Journal of Wildland Fire 10:353-372.

Huff, M.H.; Ottmar, R.D.; Alvarado, E.; Vihnanek, R.; Lehmkuhl, J.; Hessburg, P.; Everett, R.L. 

1995. Historical and current forest landscapes in eastern Oregon and Washington. Part II: 

Linking vegetation characteristics to potential fire behavior and related smoke 

production. Gen. Tech. Rep. PNW-GTR-355. Portland, OR: U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. 

10.13140/RG.2.1.1178.3449.

IPCC (Intergovernmental Panel on Climate Change). 2014. Climate change 2014: synthesis 

report. Contribution of Working Groups I, II, and III to the Fifth Assessment Report of 

the Intergovernmental Panel on Climate Change. Edited by R. K. Pachauri and L. A. 

Meyer, Geneva, Switzerland. 151 p.

Long, J.N. 1985. A practical approach to density management. Forestry Chronicle 61: 23-27.

Luna Community Wildfire Protection Plan. 2006. A supplement to the Catron County 

Community wildfire protection plan. Catron County, New Mexico.

Meehan, W.R. 1991. Influences of forest and rangeland management on salmonid fishes and their 

habitats. American Fisheries Society Special Publication 19. Bethesda, Maryland, 751 p.

Opler, M.E. 1983. Mescalero Apache. In Handbook of North American Indians: Southwest, Vol. 

X, edited by A. Ortiz, p. 419-439. Smithsonian Institution Press, Washington, DC. 

Peterson, D.L., Johnson, M.C., Agee, J.K., Jain, T.B., McKenzie, D., Reinhardt, Ed. 2005.Forest 

structure and fire hazard in dry forests of the Western United States. USDA Forest 

Service, General Technical Report PNW-GTR-628.

Reynolds, R.T., Sanchez Meador, A.J., Youtz, J.A., Nicolet, T., Matonis, M.S., Jackson, P.L., 

DeLorenzo, D.G., Graves, A.D. 2013. Restoring composition and structure in 

southwestern frequent-fire forests: A science based framework for improving ecosystem 

resiliency. USDA Rocky Mountain Research Station. General Technical Report RMRSGTR-310. 86 p.

Schmidt, K.M.; Menakis, J.P.; Hardy, C.C.; Hann, W.J.; Bunnell, D.L. 2002. Development of 

coarse-scale spatial data for wildland fire and fuel management. Gen. Tech. Rep. RMRS-
References

Luna Restoration Project 

Final Environmental Impact Statement

179

GTR-87. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky 

Mountain Research Station. 41 p.

State of New Mexico. 2005. New Mexico smoke management program: guidance document. 

New Mexico Environment Department, Air Quality Bureau. May 25, 2005. 25 p.

State of New Mexico. 2016. 2016-2018 State of New Mexico Clean Water Act §303(d)/§305(b) 

Integrated Report, Appendix A, List of Assessed Waters. New Mexico Environment 

Department. Surface Water Quality Bureau, Santa Fe, New Mexico

https://www.env.nm.gov/swqb/303d-305b/2016-2018/documents/EPAAPPROVED2016APPA--IntegratedList.pdf

Stratton, R.D. 2004. Assessing the effectiveness of landscape fuel treatments on fire growth and 

behavior. Journal of Forestry. October/November 2004.

Stratton, R.D. 2006. Guidance on spatial wildland fire analysis: models, tools, and techniques. 

Gen. Tech. Rep. RMRS-GTR-183. Fort Collins, CO: U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Research Station. 15 p.

Toney, E.M. 2012. Small sites in the Mimbres Region: a GIS and landscape theory approach.

Unpublished MA Thesis, Department of Anthropology, University of Oklahoma, 

Norman.

Toney, E.M. and M.S. Taliaferro. 2009. Small site analysis in the Mimbres area of southwestern 

New Mexico. Paper presented at the 74th Annual Society for American Archaeology 

Meeting in Atlanta, GA.

U.S. Census Bureau. 2000. American FactFinder, Profile of selected housing characteristics –

Catron County. Census 2000 Summary File 3.

U.S. Census Bureau. 2010. American FactFinder, Profile of general population and housing 

characteristics: 2010; 2010 Demographic Profile Data for Luna CDP, New Mexico.

U.S. Environmental Protection Agency. 2018. Tips for Reducing Pesticide Impacts on Wildlife. 

Available online at https://www.epa.gov/safepestcontrol/tips-reducing-pesticide-impactswildlife.

USDA Forest Service. 1986. Gila National Forest Plan as amended. USDA Forest Service, 

Southwestern Region, September 1986.

USDA Forest Service. 1987. Forest Service Handbook 2309.24, Southwestern Region, cultural 

resources handbook. Chapter 10 – survey standards. R3 amendment 2309.24-1987-1. 

Albuquerque, NM.

USDA Forest Service. 2000a. Environmental assessment for noxious weed management, Gila 

National Forest, Supplemented 2015. Unpublished report available from Gila National 

Forest, Silver City, NM.

USDA Forest Service. 2000b. Forest Service roadless area conservation, final environmental 

impact statement. United States Department of Agriculture, Forest Service, Washington 

Office.
References

Luna Restoration Project 

Final Environmental Impact Statement

180

USDA Forest Service. 2004. Forest Service Manual 2500 – Watershed and air management: 

chapter 2520 – watershed protection and management. Forest Service Manual, National 

Headquarters (WO), Washington, DC.

USDA Forest Service. 2005a. Travel management; designated routes and areas for motor vehicle 

use; Final rule. 36 CFR Parts 212, 251, 261, and 295. Federal Register Vol. 70 No. 216. 

November 9, 2005.

USDA Forest Service. 2005b. Forest Service Manual 2600 – Wildlife fish, and sensitive plant 

habitat management: chapter 2670 – threatened, endangered and sensitive plants and 

animals. Forest Service Manual. National Headquarters (WO), Washington, DC.

USDA Forest Service. 2008. Forest Service Manual 7700 – travel management: chapter 7730 –

road operation and maintenance. Forest Service Manual, National Headquarters (WO), 

Washington, DC.

USDA Forest Service. 2015. Field guide for managing rabbitbrush in the Southwest. 

Southwestern Region TP-R3-16-31, February 2015. 12 p.

USDA Forest Service. 2017a. Luna Planning Area Survey Proposal. Heritage Report No. 2017-

06-029/NMCRIS No. 137925. Report prepared by Matthew Taliaferro, Gila National 

Forest. 

USDA Forest Service. 2017b. Gila National Forest final assessment report of ecological/social/ 

economic sustainability conditions and trends. Forest Service, Gila National Forest, 

Silver City, New Mexico.

USDA, Forest Service. 2018. Escudilla Landscape Watershed Restoration Action Plan and 

Watershed Based Plan. Prepared by: Southwest Native Ecosystems Management, 

Apache-Sitgreaves National Forests, Gila National Forest, and New Mexico 

Environmental Department. Unpublished document located at Gila National Forest 

Supervisor’s Office. July 31, 2018.

USDA Forest Service and New Mexico Environmental Department. 2017. Memorandum of 

Understanding between U.S. Department of Agriculture, Forest Service, Southwestern 

Region and the State of New Mexico Environment Department, Surface Water Quality 

Bureau, 2017.

USDA Forest Service, Region 3. 2010. First amended programmatic agreement regarding historic 

property protection and responsibilities among New Mexico Historic Preservation 

Officer, Arizona State Historic Preservation Officer, Texas State Historic Preservation 

Officer, Oklahoma State Historic Preservation Officer, the Advisory Council on Historic 

Preservation, and the United States Department of Agriculture, Forest Service Region 3. 

Manuscript on file at the Gila National Forest, Supervisor’s Office, Silver City, New 

Mexico.

USDI Bureau of Land Management. 1993. Riparian area management; process for assessing 

proper functioning condition. Tech. Ref. 1737-9. 51 p.
References

Luna Restoration Project 

Final Environmental Impact Statement

181

U.S. Fish and Wildlife Service. 2012. Final recovery plan for the Mexican spotted owl (Strix 

occidentalis lucida), first revision. U.S. Fish and Wildlife Service, Albuquerque, New 

Mexico, USA. 413 p.

Van Auken, O.W. 2009. Causes and consequences of woody plant encroachment into western 

North American grasslands. Journal of Environmental Management 90(10): 2931-2942.

Wiedinmyer, C., and M. Hurteau. 2010. Prescribed fire as a means of reducing forest carbon 

emissions in the Western United States. Environmental Science and Technology 44 (6): 

1926-1932.

Luna Restoration Project 

Final Environmental Impact Statement

183

Appendices

Appendix A: Response to Comments on the Draft 

Environmental Impact Statement

This appendix documents the Gila National Forest responses to comments received during the 45-

day comment period for the draft environmental impact statement (DEIS) for the Luna 

Restoration Project.

The following is the list of agencies, tribes, groups, and individuals who provided substantive 

comments to the DEIS. The comment identification (ID) code and sequential comment number(s) 

were used for tracking between this appendix and the original comment, which can be found in 

the project record.

Comment ID Code Commenter

CBD Center for Biological Diversity; Joe Trudeau

EPA Environmental Protection Agency, Region 6; Keith Hayden

FC Faith Capps

HOPI The Hopi Tribe; Stewart B. Koyiyumptewa

JP Jean Public

NMDA New Mexico Department of Agriculture; Jeff M. Witte

NMDGF New Mexico Department of Game and Fish; Mark Watson

OEPC Office of Environmental Policy and Compliance, Department of the Interior; 

Stephen Spencer

TEP Tucson Electric Power; Jasmine Rucker

TN Todd North

TP Thomas Paterson

WEG Wild Earth Guardians; Madeleine Carey

In some cases, the Forest Service response to a comment refers to analysis documents, which are

included in the project record. Detailed reports of all resources analyzed are part of the project 

record and available upon request.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

184

Air Quality

Smoke Management

Comment 1: Concern that smoke generated from prescribed burning would have impacts to air 

quality and impact health of individuals or population in surrounding areas. Concern that there 

are not adequate smoke mitigation measures to avoid or minimize smoke impacts. (EPA-1, TN5)

Response: In the EIS under the Environmental Justice section, it states that the Forest 

Service is required to work with the State Air Quality Department, that is, New Mexico 

Environment Department, Air Quality Bureau. This corresponds to the design feature on 

EIS page 25 which states: “All burning would be coordinated and conducted in 

accordance with New Mexico Environmental Department, Air Quality Bureau smoke 

management rule. Emission reduction techniques would be utilized when possible to 

minimize impacts to sensitive receptors.”

The New Mexico Environment Department’s air quality bureau has authority over air 

quality in all areas of New Mexico except Bernalillo County and Tribal Lands. Prior to 

implementing prescribed burning, several requirements must be met including: 

registering the burn at least two weeks prior to planned ignition, and the Gila National 

Forest must notify New Mexico Environment Department by 10 a.m. the day prior to 

ignition. Burns are required to be timed when atmospheric conditions promote smoke 

dispersion to minimize impacts to the public. A complete list of requirements prior to 

burning can be found at the New Mexico Environment Department website: 

https://www.env.nm.gov/air-quality/smp.

Advance notices would be implemented to aid individuals in reducing or altogether 

avoiding smoke from prescribed fires (EIS page 167). Additional design features 

describing the advance notices were added to the Design Features Common to All 

Prescribed Burning Activities section.

Comment 2: Concern that implementation of prescribed fire treatments would increase or 

cause impacts to such things as air pollutants, haze, visibility and not stay within compliance 

with regulations (EPA, Clean Air Act, air quality standards). (TN-1)

Response: The current Smoke Management regulation in New Mexico is part of the 

state’s Regional Haze Rule, Environmental Protection Air Quality (Statewide) Smoke 

Management. Title 20 Chapter 2 Part 65 of the 20.2.65.103. The requirements are listed 

at the New Mexico Environment Department website: https://www.env.nm.gov/airquality/smp.

Prior to implementing prescribed burning several requirements must be met, including 

the requirement that the Gila National Forest uses emission reduction techniques. Each 

prescribed fire could use a host of emission reduction techniques on any individual burn, 

depending on the timing and individual unit. A list of approved emission reduction 

techniques are listed at the New Mexico Environment Department website: 

https://www.env.nm.gov/air-quality/smp.

When there are multiple burns going on in New Mexico and Arizona that have the 

potential to impact the same airsheds, there will be coordination calls hosted by New 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

185

Mexico Environment Department and the Gila National Forest staff participates to 

coordinate burning.

Permission to burn is based on air quality, dispersion forecasts. Public announcements are 

posted at nmfireinfo.com. Prescribed fire would occur when weather conditions and 

smoke dispersion forecasts are favorable as forecasted by the National Weather Service 

and the New Mexico Environment Department. All prescribed fire operations are 

conducted under the guidelines set forth in a prescribed fire plan developed by fire 

managers specifically for units in the project area. Prescribed fire plans address 

parameters for weather, air quality and contingency resources. Prescribed fire would 

occur when emissions are unlikely to have adverse effects on human health and visibility.

The Gila National Forest cannot guarantee that an exceedance would never, as weather 

situations may change unexpectedly. In the event that adequate ventilation does not occur 

as expected, the Gila National Forest would seek remedy that could include temporary 

shutdown of operations, relocation of personnel, consultation with New Mexico Air 

Quality Bureau or other mitigation measures.

Comment 3: Concern that implementation of prescribed burn treatments would not cause 

visibility impacts to designated Class 1 areas including the Gila Wilderness. (TN-2)

Response: The current Smoke Management regulation in New Mexico is part of the 

state’s Regional Haze Rule, Environmental Protection Air Quality (Statewide) Smoke 

Management. Title 20 Chapter 2 Part 65 of the 20.2.65.103. The requirements are listed 

at the New Mexico Environment Department website: https://www.env.nm.gov/airquality/smp.

The purpose of this rule is to protect visibility at Class 1 Areas in New Mexico, and it is 

assumed that by following the requirements visibility is protected at Class 1 Areas. 

Further, modeling would be inappropriate in this case. Air quality modeling of smoke, 

depends on meteorological inputs from current forecasts (2 to 3 days in the future) to be 

most useful. Prospective modeling, as suggested, without current forecasts to predict 

smoke months or years in advance, is not a useful predictor of impacts from an individual 

burn.

See also Air Quality, Smoke Management Comment 3 for more information.

Comment 4: Concern that best available sciences was not used due to the lack of modeling for 

smoke emissions in the analysis of prescribed fire treatments to determine achievement of air 

quality regulations. (TN-3)

Response: The Forest Service will coordinate with New Mexico Environment 

Department prior to all burning. Air quality management and emissions regulation is the 

responsibility of the U.S. Environmental Protection Agency and the New Mexico 

Environment Department, Air Quality Bureau. The current Smoke Management 

regulation in New Mexico, is part of the state’s Regional Haze Rule, Environmental 

Protection Air Quality (Statewide) Smoke Management; Title 20 Chapter 2 Part 65 of the 

20.2.65.103. The requirements are listed at the New Mexico Environment Department 

website: https://www.env.nm.gov/air-quality/smp.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

186

Air quality modeling of smoke, depends on meteorological inputs from current forecasts 

(two to three days in the future) to be most useful. Prospective modeling, as suggested,

without current forecasts to predict smoke months or years in advance, is not a useful 

predictor of impacts from an individual burn.

Comment 5: Request by commenter to know what smoke monitoring network exists in the 

surrounding New Mexico counties to ensure compliance with air quality standards. (TN-4)

Response: New Mexico Environmental Department operates current air quality monitors 

in Dona Ana County. The Gila National Forest often deploys temporary air quality 

monitors to assess the impacts of individual burns in the areas affected including, Grant, 

Catron, Socorro, and Sierra counties. Other smoke monitors are located at Deming 

Airport, Luna County and Los Lunas monitor in Valencia County (http://nmaqinow.net/).

Comment 6: Concern that smoke from the implementation of prescribed fire treatments will 

interfere with the use and enjoyment of private land near the project area. (TN-7)

Response: Prescribed fire would be used when weather conditions and dispersion 

forecasts are favorable (that is, how fast smoke dissipates). All prescribed fire operations 

are conducted under the guidelines set forth in a prescribed fire plan developed by fire 

managers specifically for units in the project area. Prescribed fire plans address 

parameters for weather, air quality and contingency resources. Prescribed fire would 

occur when emissions are unlikely to have adverse effects on human health and visibility 

or adjacent property. The potential effects of smoke are discussed in the Air Quality 

section of the EIS (pages 106–108).

Smoke produced during prescribed fire operations may have temporary impacts as 

described in the EIS. Landowners will be notified when activities will be initiated and the 

Gila National Forest will follow State Air Quality regulations during implementation.

See also Air Quality, Smoke Management Comment 1 for more information.

Clean Water Act

Comment 1: The Forest Service must ensure compliance with the Clean Water Act. (WEG-23)

Response: The State of New Mexico Environment Department is responsible for

assessment of waterbodies to determine if they are meeting state water quality standards. 

The Gila National Forest reviewed the 2016–2018 State of New Mexico Clean Water Act 

Section 303(d)/Section 305(b) Integrated Report Appendix B – Integrated List. Two

waterbodies were identified from the list that occur within the planning area: Centerfire 

Creek and San Francisco River (EIS page 114).

The Gila National Forest worked closely with the New Mexico Environment Department 

Surface Water Quality Bureau to develop projects within the Luna Restoration Project 

area that aimed to improve water quality. The New Mexico Environment Department coauthored the Escudilla Landscape Watershed Restoration and Protection Strategy to 

ensure that it met the requirement of the Environmental Protection Agency’s Watershed 

Based Planning elements.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

187

Climate Change

Comment 1: Concern is the impact to the forest’s capacity for carbon storage should the 

desired condition for tree density per acre is achieved. (TN-6)

Response: Forests are in continual flux, emitting carbon into and from the atmosphere, 

and storing carbon as biomass. The primary influence on biomass carbon stock are plant 

growth, which increases carbon stock, decay, and decomposition which slowly decreases 

carbon stock, and disturbances in the form of fire and harvest. As forest and grassland 

ecosystems are constantly changing through natural succession and disturbance, biomass 

carbon stock also changes through time. It is recognized that some land management 

activities such as vegetation treatments and prescribed fires may reduce carbon storage 

even while moving toward the objectives. But the reduction of carbon storage or uptake 

is short term. As stands develop and vegetation regenerates, carbon uptake would slowly 

increase.

Carbon removed from forests as harvested wood can also remain stored rather than 

returning to the atmosphere for a long time, depending on the mix of wood products 

produced or burned as a substitute for fossil fuels (Heath et al. 2011). The net annual 

contribution to the total forest carbon budget depends on harvest and the use or disposal 

of harvested materials. It is recognized that some land management actions may reduce 

carbon storage even while moving toward restoring an ecosystem.

The current overall biomass carbon stock over the entire Gila National Forest is about 

116 percent of reference conditions for vegetation types across the forest (USDA Forest 

Service, Gila National Forest 2017). The Luna Planning area is only about 5 percent of 

the entire forest. Vegetation and prescribed fire treatments planned in the Luna Planning 

area would not be implemented all at one time, but scattered over the project area over 

the next 8 to 10 years, extending up to 20 years or until objectives are met (EIS page 14). 

A project this size, broken down into smaller treatment units and implemented over a 

period of multiple years; would for a short period in localized treatment units have 

reductions in carbon storage and uptake. But as vegetation in these areas begin to develop 

and become more productive and diverse, carbon uptake would increase slowly, which 

has the potential to offset carbon stock reduction in subsequent later treatments across the 

planning area. Overall, the potential for this project to have an impact on total forest 

carbon stock is negligible.

Comment 2: The DEIS must analyze the impacts of the project on climate change and effects 

of climate change on the project area. (WEG-18)

Response: Climate change is addressed in the EIS on pages 150, 156, 162 and in cultural, 

fuels, recreation, vegetation, and watershed/soils reports.

As previously mentioned, carbon removed from forests as harvested wood can also 

remain stored rather than returning to the atmosphere for a long time, depending on the 

mix of wood products produced or burned as a substitute for fossil fuels (Heath et al. 

2011). The net annual contribution to the total forest carbon budget depends on harvest 

and the use or disposal of harvested materials. It is recognized that some land 

management actions may reduce carbon storage even while moving toward restoring an 

ecosystem. While treatments such us group selection thinning from all age classes may 

encourage more trees in some areas, other areas within the planning area will be 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

188

maintained as grasslands and meadows. Overall, the restoration goals of the project will 

greatly reduce the potential for large amounts of carbon stock to be consumed in large 

wildfires such as the Wallow Fire (2011) and White Water-Baldy Fire (2012).

See Climate Change Comment 1 for more information.

Cultural Resources

Comment 1: The Hopi Tribe requested the forest ensure that appropriate notification and 

documentation be provided to The Hopi Tribe and State Historic Preservation Office for sites 

that may be adversely affected or discovery of remains, cultural features or deposits. (HOPI-1)

Response: The Gila National Forest thanks Hopi Cultural Preservation Office for their 

review and comments. In accordance with Section 106 and Native American Graves 

Protection and Repatriation Act, the Gila National Forest will notify The Hopi Tribe if any 

inadvertent discoveries or identification of adverse impacts are made during the course of 

the project implementation.

Invasive and Noxious Weeds

Comment 1: Concern treatment sites may be overrun with cheatgrass. (CBD-25)

Response: Cheatgrass has been documented to occur within the project area for over 30 

years. Within this timeframe, this grass has not become a dominant species in these 

ecosystems.

There are design features common to all activities to reduce the potential of introduction 

or spread of invasive and noxious weeds on page 36 of the EIS. Page 38 of the EIS 

includes a monitoring element to periodically monitor implementation sites for detection 

and effectiveness of design features to prevent spread or introduction.

Comment 2: Concern non-native grass and herb seeds will be used in stream restoration 

activities; and needs to be analyzed. (CBD-26)

Response: Page 34 of the EIS states: “Sourcing of seed material will follow Region 3 

(Southwestern Region) guidance on weed free materials.”

Motorized Transportation System

Comment 1: Tucson Electric Power appreciates access solutions provided in all action 

alternatives, facilitating access for management of the powerlines. (TEP-3)

Response: Thank you. The Forest Service values the ongoing coordination with Tucson 

Electric Power to ensure the continued maintenance and management of the powerlines 

in conjunction with forest management.

Comment 2: Concern the closure of National Forest System Road 4127 W off of 4127 U in the 

Steel Flat area does not allow access into Arizona via connection to route 8372. (FC-1)

Response: National Forest System Road 4127 W is a short route off of 4127 U which 

leads to the New Mexico-Arizona stateline connecting to 8372. At the stateline, the 

landownership becomes private. The Gila National Forest inquired whether the ApacheSitgreaves National Forests had an easement or right-of-way through the private land 

during its travel management planning. The Apache-Sitgreaves National Forests 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

189

responded that they had no easement or right-of-way. So based on the negative response, 

4127 W was closed under the Gila National Forest’s Travel Management Record of 

Decision in 2013.

During recent discussions with the Apache-Sitgreaves National Forests regarding route 

comments received on this project, another review of their records discovered a deed for 

a right-of-way dating back to 1952 through the private property along road 8372.

Based on this new information, the Gila National Forest will make a correction to the 

route designation and making it a road open to all motorized vehicles and reflect the 

correction in the next version of the motor vehicle use map.

Comment 3: Concern the closure of National Forest System Road 4127 Y/4019 U off of 4127 

U does not allow access into Arizona via connection to route 8378. (FC-2)

Response: National Forest System Road 4019 U is designated for administrative or 

written authorization use only to access the private land. The closed spur 4127 Y that 

connects to 8378 at the stateline has been closed for a long period of time. This route is 

also within critical habitat for the Mexican spotted owl.

During recent discussions with the Apache-Sitgreaves National Forests, 8378 crosses in 

and out of parcels of private land for which they do not have any easements or right-ofways through.

Based on the long-term closure of the road and no legal access on the Arizona side, the 

Gila National Forest is not going to consider opening 4127 Y and 4019 U to public 

motorized access at this time.

Comment 4: Concern that the implementation of motor vehicle barricades and road 

decommissioning will impact the ability to use motorized vehicles for management of range 

allotments. (TP-2)

Response: The Gila National Forest values our relationship with our stakeholders and is 

committed to working with permitted livestock producers to develop design features that 

would minimize the burden placed on them. Permittees are encouraged to be involved in 

the design and implementation process to ensure their concerns are addressed.

The access permitted for off road travel to permitted livestock producers is not unlimited. 

The permittee must demonstrate a specific need that cannot be addressed through 

alternative forms of access in order to justify an alternative course of action. This would 

occur through coordination with the permittee during annual operating meetings or at 

other times as needed.

The following text is included in the annual operating instructions regarding motorized 

uses:

Gila National Forest Travel Management Decision signed in September 2013 was 

implemented in 2016 on the Quemado Ranger District. This rule prohibits cross 

country motorized travel and has restricted all motorized vehicle travel on the Gila 

National Forest to authorized motorized routes only on Gila National Forest Plan.

Some motorized uses are exempt from the prohibitions of the designation process (36 

CFR 212.51(a)): “Motor vehicle use that is specifically authorized under a written 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

190

authorization issued under Federal law or regulation” (CFR 212.51(a)(8)) is one of the 

exempted uses. The permittees and/or their employees must comply with all Gila 

National Forest Travel Management regulations, except those allowed under this 

authorization as described below:

i. The permittees and/or their employees will be authorized for off road or 

unauthorized travel routes on their specific grazing allotment(s) to carry out the 

necessary activities for grazing and livestock management. This includes range 

improvement maintenance and/or reconstruction as designated in their grazing 

permit, placement of salt or other supplements, and for emergency livestock 

health purposes.

ii. It is prohibited to operate any vehicle off National Forest System lands, State or 

County roads in a manner which damages or unreasonably disturbs the land, 

wildlife, or vegetative resources (36 CFR 261.15(h)). Moist soils are especially 

susceptible to damage through rutting or compaction; therefore, use of motorized 

vehicles on saturated soils should be avoided.

iii. Utilize roads or trails designated for motor vehicle use to access range 

improvements, salting grounds, or livestock emergencies where possible. This 

includes trails and roads open for public use, those specified as “administrative 

use only,” and keeping within fence rights-of-way while accomplishing fence 

maintenance where possible.

Comment 5: Develop an action alternative that foregoes road building on steep slopes and 

sensitive, erodible soils where it may increase erosion or impair ecosystem productivity. (CBD28)

Response: The Luna Water-Air-Soils Report (USDA Forest Service, Gila National Forest 

2018) includes a map of the sensitive soils and discusses that the Draft Terrestrial 

Ecosystem Survey was used to identify sensitive Datil soils and used in the early stages 

of project development for consideration during restoration activity development. Page 

119 of the EIS states: “In the development of these alternatives, sensitive soils were 

identified and considered. Vegetation treatments were excluded from these areas. 

Prescribed fire was excluded from most areas with sensitive soils, with the exceptions 

being the north aspect of the San Francisco Divide, and southwest of the community of 

Luna in Dry Blue Creek and Frieborn Canyon, extending south to the planning boundary. 

In these areas, low-severity fire may be introduced when fuel conditions, weather 

conditions, or both lessen fire spread across the landscape.” Temporary and new route 

construction would follow best management practices to mitigate soil erosion concerns.

Comment 6: Concern DEIS fails to adequately analyze the travel management system, 

including baseline conditions, direct, indirect and cumulative impacts the Gila National Forest’s 

travel analysis report, the minimum road system, and additional decommissioning 

opportunities. (WEG-16)

Response: The Gila National Forest, including the Quemado Ranger District, has already 

implemented the motor vehicle use map based on the 2013 decision implementing the 

2005 Travel Management Rule. The road system as it is has already been assessed and 

the existing road system was included in cumulative effects analysis and the changes 

proposed by alternatives to the motorized system was assessed.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

191

The travel analysis process for the Gila National Forest is not a decision process. The 

travel analysis process provides the framework and the explanation of the Gila National 

Forest process from which recommendations for designation are outlined that may be 

examined in the environmental analysis process. The travel analysis process indicates that 

appendix L and summary table 4 identified the minimum road system. But the minimum 

road system may be changed by adding or removing routes to address other issues or 

opportunities that may arise during an environmental analysis process and thus refining 

the minimum road system. Per the Travel Management Rule (2005) “Designations of 

National Forest System roads, National Forest System trails, and areas on National Forest 

System lands pursuant to § 212.51 may be revised as needed to meet changing 

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

for public involvement in § 212.52, the requirements for coordination with governmental 

entities in § 212.53, and the criteria in § 212.55...”

Opportunities for all-terrain vehicle and utility-terrain vehicle use identified as part of the 

purpose and need and routes proposed in alternatives B and C were result of a series of 

meetings and field visits with members of the Luna Community (2015).

The Travel Management Rule alternatives did not include decommissioning opportunities 

but under Other Recommendations and Opportunities included: “Review roads 

recommended for non-motorized use, for the potential to decommission (Appendix N). 

Give priority to those roads identified by the coarse filter – stream buffer analysis and 

threatened and endangered species and their habitat.” All closed roads in the planning 

area were reviewed by an interdisciplinary team for consideration of decommissioning 

and over 100 miles were identified to be included in the proposed action for this project.

Comment 6: Concern that request and inquiries regarding the management and definition of 

temporary roads was not provided. (WEG-17)

Response: The definitions of temporary and administrative use are provided in the 

glossary of the EIS. A temporary road is not a forest road or trail and is not included in a 

forest transportation atlas (36 CFR 212.1, Forest Service Manual 7705).

Temporary road construction utilization, and decommissioning is based on when the unit 

is ready for treatment. Treatment may done by the Gila National Forest, agreement, 

contract, or other means. The duration and decommissioning of a temporary road is based 

on the treatment type and specifications of the agreement, contract, etc. regarding 

construction, maintenance, and decommissioning.

National Environmental Policy Act

Comment 1: The Department of Interior has no substantive comments at this time. Bureau of 

Land Management and U.S. Fish and Wildlife Service has requested to stay informed during 

the planning process. (OEPC-1)

Response: Thank you for your comments on the Luna Restoration Project. We will 

maintain the Bureau of Land Management and U.S. Fish and Wildlife Service on the 

mailing list of future notifications on this project.

Comment 2: Supports alternative D with modifications. (CBD-8, WEG-17)

Response: Thank you for your comment.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

192

There are differing opinions regarding which alternative the Forest Supervisor should 

select. The forest supervisor will select an alternative based on the analysis presented 

within the final EIS and public input.

Comment 3: Concern that proposed treatments are not thoroughly refined or provide sitespecific baseline conditions and would require additional environmental analysis to implement 

projects. (CBD-9, CBD-23, WEG-6)

Response: The project maps display where specifically activities would occur and are 

referenced to in the proposed activity tables in chapter 2 of the analysis. The analysis 

completed by resource specialists utilized the points and polygons for assessing each of 

the particular activities. The analysis for vegetation and fuels except where noted, is site 

specific based on data from individual plots and stands across the project area. Actions 

proposed and design features apply either throughout the project area or to specific 

locations or areas (chapter 2).

Individual treatments sites or activities would be reviewed by specialists as outlined in 

design features prior to implementation to ensure appropriate application of actions 

proposed as well continue the interdisciplinary coordination which went into developing 

the entire restoration project. The concern that surveys are required for wildlife and 

aquatic species prior to implementation is not for determining the location of the activity. 

Species habitat and distribution are known to be within or may be influenced by proposed 

activities. Surveys would indicate presence or absence and appropriate techniques to 

employ reduce impacts to the species and/or its habitat during project implementation.

Site-specific data was collected for the analysis, for example, weather data was obtained 

for the past 20 years from the Luna remote automated weather station and individual 

plots and stands were collected across the project area in woodland and forest vegetation 

types.

Site-specific data was collected for this analysis in woodland and forest vegetation types. 

The Forest Vegetation Simulator was used to model a representative sample of the data 

collected. The Forest Vegetation Simulator is the USDA Forest Service’s nationally 

supported framework ensuring consistency among forests in vegetation growth and yield 

modeling. The Forest Vegetation Simulator is an individual-tree, distance-independent, 

growth and yield model (Dixon 2002). It has been calibrated for specific geographic areas 

(variants) of the United States. The Central Rockies variant is used in New Mexico. A 

Forest Vegetation Simulator Steering Team monitors and guides requests for system 

refinement. The fifteen member Forest Vegetation Simulator Steering Team includes a 

mix of Forest Service field and research personnel, other agencies, and various other 

personnel with the purpose of providing strategic guidance to the Forest Vegetation 

Simulator group in development, enhancement, and application of the model using best 

available science. For more information and documentation about the Forest Vegetation 

Simulator model https://www.fs.fed.us/fvs/documents. For additional references and 

background information for Forest Vegetation Simulator model.

Comment 4: Concern that factors for baseline conditions are not included, particularly the 

condition of rabbitbrush and alligator juniper. (CBD 16)

Response: Rangeland vegetation condition is an element under the watershed condition 

and part of the rating for the watersheds. There is close interrelationship between soils, 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

193

hydrology, and vegetation condition. Rangelands reflect native or desired non-native 

plant composition and cover (USDA Forest Service 2011). Baseline watershed 

cumulative effects were addressed in the 2015 Watershed Condition Classification. These 

results were considered as part of watershed cumulative effects which included effects to 

soil conditions and range vegetation. Terrestrial Ecological Unit Inventory information 

was used as part of vegetation treatment planning for suitable project areas. The 

rangeland vegetation condition is described as: function/structural groups and number of 

species are slightly to moderately reduced; the reproductive capacity of perennial native 

or naturalized plants to produce seeds or vegetative tillers is somewhat reduced but is still 

sustainable over the long term.

Terrestrial Ecological Unit Inventory coverage was used in identifying historic grasslands 

that are in need of restoration including areas associated with woody encroachment.

Comment 5: Concern all past activities are not being included or is inconsistent in the 

cumulative effects analysis such as livestock grazing, fire suppression, chaining, herbicide use, 

and other vegetation treatments. (CBD-10, WEG-5, WEG-19)

Response: Thank you for identifying that prescribed fire is missing from the list of 

activities that would continue in the no-action description. This was an error as the East 

Centerfire project is still active as well as districtwide pile burning activities. In regards 

to the list of activities other than prescribed fire, activities for cumulative effects will vary 

depending on the resource by how they bound their cumulative effects analysis by time 

and extent. Ongoing vegetation treatments are occurring on the Apache-Sitgreaves 

National Forests just across the stateline from the Luna Restoration Project.

Chapter 3 of the EIS for the Luna Restoration Project documents the required hard look 

at environmental consequences. The analysis in chapter 3 includes a summary of each 

resource report’s direct, indirect, and cumulative effects of the proposed project. 

Literature cited is listed in the EIS reference section and additional literature for each 

resource may be found in the analysis reports.

Comment 6: Concern that a paragraph on page 5 of the DEIS appears to make the entirety of 

the Wallow Fire appear destructive and cause for landscape scale issues. (CBD-15)

Response: On page 5 of the EIS, the 2011 Wallow Fire being the most recent fire was 

included in the background discussion related to the community of Luna and describes 

impacts to forest resources from the fire and post-fire events. The purpose to include the 

Wallow Fire is displayed in the last paragraph of the Background section (page 5 EIS):

“The Wallow Fire and postfire impacts on the landscape, watersheds, habitat, forest 

facilities, infrastructure, and community of Luna highlights the range of possible future 

impacts from wildfires on stakeholders and lands managers.”

The planning area existing conditions are displayed on pages 5–13 of the EIS. This 

includes vegetation, fuel conditions, watershed, aquatics, and wildlife. Various resource 

issues are described that have no relation to or have incorporated the Wallow Fire or postfire impacts into the existing condition.

Comment 7: Monitoring and adaptive management requirements are needed that are robust 

and have qualitative triggers for adaptive management elements. Not having these are not 

meeting National Environmental Policy Act requirements. (CBD-30, WEG-24)
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

194

Response: We understand that these systems are in flux and can be influenced by both 

natural and human disturbances including proposed activities across the landscape. 

Desired conditions presented in chapter 1 of the EIS are presented as range of values or 

percent, which allows a level of adjustment in implementation across the identified 

treatment areas and over time. Should there be a need to alter implementation, change to 

policy, or change in conditions, the Gila National Forest will review the changes and 

existing environmental analysis and determine if a supplemental environmental impact 

statement is needed per National Environmental Policy Act requirements.

Chapter 2 of the EIS includes design features common to all implementation activities 

and design features specific to the type of activities, which are to minimize or avoid 

impacts to resources. Monitoring is outlined on pages 37–38 of the EIS which includes 

best management practices monitoring and implementation and effectiveness monitoring. 

The Escudilla Landscape Watershed Restoration and Protection Strategy includes a 

section that details project monitoring and evaluations. The monitoring section of the 

watershed restoration and protection strategy is referenced in the EIS.

Monitoring and surveys for federally listed wildlife species will implemented as outlined 

in biological opinion issued by U.S. Fish and Wildlife for this project.

Comment 8: The DEIS articulates a flawed statement of purpose and need. (WEG-3)

Response: Chapter 1 describes the existing and desired conditions from which the 

purpose and need for the project was established. Per section 1502.13, the Purpose and 

Need Statement “shall briefly specify the underlying purpose and need to which the 

agency is responding in proposing the alternatives including the proposed action.” We 

feel that the purpose and need frames up what the Gila National Forest is trying to 

accomplish and why the project is necessary, which is reflected in the proposed action 

and subsequent alternatives developed from public comments.

For clarification, the “need” statement “improve water quality by hardening stream 

crossings and performing road maintenance” would not limit other road related activities 

to improve water quality. There are other statements such as “implement treatments in 

watersheds that are not properly functioning” and “improve rangeland, wildlife, aquatic 

and riparian habitat” which allows for other activities.

Comment 9: The DEIS lacks a reasonable range of alternatives. (WEG-4)

Response: Comments generated from scoping centered around the issues (EIS pages 17–

18) of vegetation management related to treatments on juniper and rabbitbrush; fuels 

treatments within mixed conifer and Mexican spotted owl habitat; and routes regarding 

motor vehicle types and access. Alternatives were developed based on significant 

comments. Alternatives within the EIS meet the stated purpose and need. The final 

reasonable range of alternatives was approved by the Forest Supervisor on 2/12/2017.

Based on information provided in the comments from WildEarth Guardians, an 

alternative was considered but eliminated from detailed study and added to the final EIS.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

195

Comment 10: The DEIS cumulative effects states “current activities range from fuelwood 

collection, commercial thinning, salvage cutting, pre-commercial thinning for wildlife, 

watershed vegetation and forest health improvement, pre-commercial thinning, over story 

removal, road closures, and fuels reduction thinning.” However the no-action alternative states 

there are currently no ongoing vegetation, prescribed fire, or other restoration type projects 

within the panning area. These two statements are contradictory and must be clarified. The 

DEIS does not provide sufficient baseline data and fails to take a “hard look” at the direct, 

indirect, and cumulative impacts. (WEG-5)

Response: Thank you for identifying that prescribed fire is missing from the list of 

activities that would continue in the no-action description. This was an error as the East 

Centerfire project is still active as well as districtwide pile burning activities and was 

corrected in the final EIS. In regards to the list of activities other than prescribed fire, 

activities for cumulative effects will vary depending on the resource by how they bound 

their cumulative effects analysis by time and extent. Ongoing vegetation treatments are 

occurring on the Apache-Sitgreaves National Forests just across the stateline from the 

Luna Restoration Project.

Chapter 3 of the EIS for the Luna Restoration Project documents the required hard look 

at environmental consequences. The analysis in chapter 3 includes a summary of each 

resource report’s direct, indirect, and cumulative effects of the proposed project. 

Literature cited is listed in the EIS references section and additional literature for each 

resource is listed in the resource specialist reports.

Comment 10: DEIS does not ensure the integrity of the models used, the data used in the 

models, and accuracy of the model’s assumptions. (WEG-7)

Response: The Forest Vegetation Simulator was used to model a representative sample of 

the data collected. The Forest Vegetation Simulator is the USDA Forest Service’s 

nationally supported framework ensuring consistency among forests in vegetation growth 

and yield modeling. The Forest Vegetation Simulator is an individual-tree, distanceindependent, growth and yield model (Dixon 2002). It has been calibrated for specific 

geographic areas (variants) of the United States. The Central Rockies variant is used in 

New Mexico. A Forest Vegetation Simulator Steering Team monitors and guides requests 

for system refinement. The fifteen member Forest Vegetation Simulator Steering Team 

includes a mix of Forest Service field and research personnel, other agencies, and various 

other personnel with the purpose of providing strategic guidance to the Forest Vegetation 

Simulator group in development, enhancement, and application of the model using best 

available science. For more information and documentation about the Forest Vegetation 

Simulator model go to: https://www.fs.fed.us/fvs/documents.

The Fuels Report describes the methodology, data, and models for the analysis. Fire 

regime data was acquired from LANDFIRE (2010) version 1.2.0 data. It is an interagency 

vegetation, fire, and fuels characteristics mapping program, sponsored by the Wildland 

Fire Leadership Council that provides nationally consistent and seamless geospatial data 

products for use in wildland fire analysis and modeling. LANDFIRE data is used as the 

basis for geospatial wildland fire modeling. It produces a comprehensive, consistent, 

scientifically credible suite of more than 20 geospatial layers for the United States. 

LANDFIRE (2012) version 1.4.0, data was used for the Vegetation Departure assessment.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

196

Forest Plan Consistency

Comment 1: The DEIS fails to explain how the project complies with the existing Forest Plan 

and also how it relates to the Gila forest plan revision process. (WEG-1)

Response: The Gila National Forest is required to be under a forest plan at all times.

Until the revised forest plan is completed, the 1986 Gila forest plan will be followed and 

projects will be developed within the existing standard and guidelines. We cannot predetermine what elements will be approved or changed under the revision process in the 

development of the Luna Restoration Project. Also, it would not be practical or prudent 

for the Gila National Forest to not continue moving forward with planning and 

implementation of identified areas of concern and needed management.

When the new forest plan is implemented there will be a transition, but it is not expected 

that the revised plan be used to re-evaluate or change decisions that have been made 

under the previously existing forest plan. A smooth and gradual transition to the new 

forest plan is anticipated, rather than one that forces an immediate reexamination or 

modification of all contracts, projects, permits, and other activities that are already in 

progress. As new project decisions, contracts, permits, renewals, and other activities are 

considered, conformance to the new plan direction is expected.

Comment 2: The Project is inconsistent with the 1986 Gila Forest Plan including the 

following: DEIS fails to meet the standard of being in compliance with recovery plans as it 

pertains to the analysis of project impacts on Mexican spotted owl and Mexican grey wolf; 

DEIS did not analyze the impacts of projects on wild turkey habitat (CO2); DEIS fails to give 

site-specific information in the projects impacts on sensitive soils or analyze the direct, indirect, 

or cumulative impacts; DEIS fails to discuss whether proposed water development will be 

utilizing newly, or legally, appropriable waters; and DEIS fails to analyze or provide monitoring 

information for insect and disease outbreaks; current or predicted and their impacts. (WEG-2)

Response: The project is consistent with the 1986 Gila forest plan except for those 

standard and guidelines outlined on EIS pages 34–35 for which project specific 

amendments were identified to better implement the Luna Restoration Project. The 

comment addresses the following specific plan elements:

Compliance with recovery plans: The Gila National Forest has prepared a biological 

assessment for the Luna Restoration Project in consultation with U.S. Fish and Wildlife

Service and applicable recovery plans were referenced during preparation of the 

document including Mexican gray wolf and Mexican spotted owl. The biological 

assessment and the environmental impact statement (EIS pages 81–90) present the 

analysis of impacts to federally listed species.

Wild turkey habitat: There are additional species in the Gila forest plan to manage habitat 

for, which include deer, elk, squirrel, etc. Planning area is within management areas 3B, 

3C and 3D of the Gila forest plan. The forest plan provides direction to support 

populations of these species and integrate habitats to provide primary components 

(nesting, roosting, foraging 3B (page 102), 3C (page 108) and 3D (page 114)).

Although the turkey and other species are not specifically addressed in the analysis, 

implementation of the project will improve nesting and foraging habitat for wildlife 

species similar to those wildlife species analyzed. Species may be displaced during 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

197

implementation due to human activity, but not all suitable areas will be treated at the 

same time, which would allow movement to adjacent areas. Habitat components would 

improve in the long run with treatment and the reduced risk of wildfire.

Sensitive soils: The Luna Water-Air-Soils Report includes a map of the sensitive soils and 

discusses that the Draft Terrestrial Ecosystem Survey was used to identify sensitive Datil 

soils and used in the early stages of project development for consideration during 

restoration activity development. Page 119 of the EIS states: “In the development of these 

alternatives, sensitive soils were identified and considered. Vegetation treatments were 

excluded from these areas. Prescribed fire was excluded from most areas with sensitive 

soils, with the exceptions being the north aspect of the San Francisco Divide, and 

southwest of the community of Luna in Dry Blue Creek and Frieborn Canyon, extending 

south to the planning boundary. In these areas, low-severity fire may be introduced when 

fuel conditions, weather conditions, or both lessen fire spread across the landscape.”

Acquisition of Water Rights: Page 28 of the EIS discloses the procedures and 

contingency of implementing the proposed water developments. The EIS states: 

“Installation of these improvements is contingent on the Gila National Forest’s ability to 

meet the requirements of the New Mexico Office of the State Engineer. The 

improvements would require the appropriate licenses or water use agreements prior to 

implementation. In the event the Gila National Forest is unable to obtain a license, an 

alternative water source could be considered provided the effects of using that water 

source do not differ from the effects disclosed in this analysis.”

Monitoring of insect and disease activities: Insect and disease monitoring occurs at a 

regional level which includes flights and analysis. The Gila National Forest coordinates 

with region on flights and provides specific locations that include sites of concern from 

field observations, vegetation treatment areas, or large burn areas. The restoration project 

purpose is to move toward a healthy and resilient system. The Vegetation (Silviculture) 

Report appendix 1 Luna Restoration Project Treatment Details for Vegetation Treatments 

provides optional treatments where insect and/or disease infestation is found in the unit.

Prescribed Burning

Comment 1: Tucson Electric Power requests advanced coordination and at least 2 weeks 

advance notification of any prescribed fire activities near or within the powerline corridor. 

(TEP-2)

Response: Design features for prescribed fire activities on page 26 of the EIS includes 

notification and coordination with Tucson Electric Power and Navopache Electric 

Cooperative. Wording was added for notification “at least 2 weeks in advance.”

Comment 2: Opposed to prescribed burning proposal which impacts air quality and the 

associated health impacts to individuals. (JP-1)

Response: The Forest Service will coordinate with New Mexico Environment 

Department prior to all burning. Air quality management and emissions regulation is the 

responsibility of the U.S. Environmental Protection Agency and the New Mexico 

Environment Department, Air Quality Bureau.

See Air Quality; Smoke Management, Comment 1, for additional information.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

198

Comment 3: Opposed to burning vegetation, which removes habitat, kills habitat, and removes 

food sources for wildlife. (JP-2)

Response: The general goal is to introduce low or mixed intensity fires into the area to 

mimic nature’s methods for producing healthy forests and reducing fuel loading that can 

contribute to larger scale wildfire that can cause longer-term negative effects to wildlife 

habitat. There are desired conditions (EIS page 13) and the project’s purpose and need 

(EIS pages 13–14) that reflect the importance of wildlife habitat and fire risk. The effects 

of prescribed fire treatments are described in the wildlife section of the EIS and within 

wildlife analysis documents located in the project record.

Comment 4: Fuel treatments (mechanical and prescribed fire) should be limited to WUI. 

(WEG-8)

Response: Fire researchers, Finney and Cohen (2003), suggest that wildland fuel 

management extending perhaps many kilometers away from urban locations is critical to 

reducing the likelihood that wildland fires will spread to urbanized areas and pose 

ignition threats.

Research has also determined that treatments intended to reduce fuels around 

communities at risk, rather than individual structures, need to go beyond the home 

ignition zone (Graham 2004). While individual home-by-home treatments can help 

reduce the risk of loss of individual homes, relying solely on such treatments would 

forego strategic opportunities for controlling fires within this wildland urban interface 

area.

Range Management

Comment 1: Concern that allotments within the Luna planning area have not gone through 

Section 7 consultation with U.S. Fish and Wildlife Service. (CBD-19)

Response: All allotments within the Luna planning area have undergone Endangered 

Species Act Section 7 consultation with U.S. Fish and Wildlife Service.

Water Systems

Comment 1: Concern that open trenches can trap and cause mortality of wildlife during 

construction of trenches and installation of pipelines for water systems and that the final EIS 

incorporate best management practices to reduce impacts. (NMDGF-4)

Response: We agree with the New Mexico Department of Game and Fish concerns 

regarding trenches and possible impacts to wildlife. We will incorporate the provided 

guidelines from the Department’s letter into the project design features.

Comment 2: Concern about wildlife mortality associated with water tanks and proposed new 

tanks should be required to have wildlife escape ramps installed. (NMDGF-6)

Response: Wildlife escape ramps are part of the Gila National Forest’s design criteria for 

all water troughs located on the national forest. We will add to the design features for 

drinkers, troughs or tanks that wildlife escape ramps would be installed.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

199

Comment 3: Concern the request for a new well and storage tank in Hi Clark corral to provide 

water to stock held in the trap and corral; was not included as one of the range improvements 

addressed in the DEIS. (TP-3)

Response: The range improvement in the Hi Clark corral was not included, as it does not 

meet the purpose and need of the Luna Restoration Project. Although it would meet the 

need to “provide permanent water supplies to support wildlife and livestock” (EIS page 

14); it does not meet the need to “improve rangeland, wildlife, aquatic and riparian 

habitat” (EIS page 14). While Gila National Forest personnel do not disagree that this 

improvement would be beneficial from a livestock production standpoint, improvements 

to livestock handling facilities would not meet the need or intent of the larger restoration 

proposal and would need to be addressed through a range management analysis.

Comment 4: Concern regarding the increase in water improvements and what alternative water 

sources would be authorized if wells are not permitted and associated impacts to public lands. 

(CBD 31, WEG-15)

Response: The Luna Restoration Project proposes new range water developments under 

all action alternatives. The proposed water developments would aid in livestock 

distribution, thus providing relief from grazing pressure in several areas and decrease 

dependence on riparian habitat as a water source.

“Additional tanks could be installed as needed to improve functionality” was in reference 

to storage tanks only not water troughs. The placement of additional storage tanks could 

be necessary to insure proper function of the water system and availability of water year 

round to the troughs.

All water developments within the Gila/San Francisco River and Little Colorado River 

basins must be approved by the New Mexico Office of the State Engineer who ensures 

the development is without detriment to existing surface water rights or impairment to 

existing ground water rights, and is not contrary to the conservation of water within the 

state nor detrimental to the public welfare of the state. Should other types of water 

developments be needed if wells are found to be not feasible, separate environmental 

analysis would be required.

Restoration Project Support

Comment: Supports restoration efforts of restoring forest, woodland, and grasslands to reduce 

catastrophic wildfire and increase ecological resilience. Supports restoring riparian areas and 

watersheds, improving water quality; and benefitting wildlife and wildlife habitat. (NMDA-1; 

NMDGF-1, CBD-1)

Response: Thank you for your comments, interest, and support for the variety of 

restoration proposals within the Luna Restoration Project.

Riparian Exclosures

Comment 1: Concern the responsibility of construction and maintenance of riparian exclosures 

will be placed on allotment permittees. (NMDA-2)

Response: The Gila National Forest values our relationship with our stakeholders and is 

committed to working with permitted livestock producers to develop design features that 

would minimize the burden placed on them. We would encourage them to be involved in 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

200

the design and implementation process to ensure their concerns are addressed. This 

includes maintaining access to water resources for livestock operations, such as water 

gaps and alternative waters.

The Forest Service is responsible for the construction and major maintenance of these 

proposed exclosures. The Gila National Forest is looking at installing effective, but low 

maintenance designs, such as pipe and cable fencing.

Some minor maintenance responsibility would be necessary on the part of the permittee 

to ensure livestock safety and permit compliance and functionality.

Comment 2: Opposed to all exclosures due to limiting the ability of elk to roam. (JP-3, WEG9)

Response: The purpose of the exclosure proposals are to allow time for riparian, stream 

and bank restoration projects to establish (EIS page 33). During scoping (Scoping 

Content Analysis document), a commenter pointed out that exclosures would need to be 

of adequate height to keep elk out of riparian areas, due to being able to cause damage to 

riparian and impact stream systems. In order to have an effective treatment it is necessary 

to exclude wildlife such as elk. Most exclosures will be small in size. These are 

temporary exclosures and are not meant to permanently exclude livestock and wildlife 

from riparian areas.

Stone Creek, Centerfire Creek, Spur Lake Draw, and Adair Spring are drainages 

identified for proposed exclosures (EIS table 18 on page 32). These drainages are spread 

across the planning area except for Spur Lake Draw and Centerfire Creek. These two 

drainages at their closest points are about a mile apart (EIS MAP 10). The distance 

between and the varying size of exclosures should not limit wildlife (elk) movement 

during implementation.

Comment 3: Opposed to exclosures which will impact the ability of cattle to have access to 

water. (TP-1)

Response: The Gila National Forest values our relationship with our stakeholders and is 

committed to working with permitted livestock producers to develop design features that 

would minimize the burden placed on them. We would encourage them to be involved in 

the design and implementation process to ensure their concerns are addressed. This 

includes maintaining access to water resources for livestock operations, such as water 

gaps and alternative waters.

At Adair Spring, the proposal is protect the spring itself and surrounding vegetation. The 

exclosure would be concentrated around the spring and livestock would still have access 

to water flowing down Adair Canyon from the spring. If needed, alternative water source 

near the spring could be developed for livestock management needs.

See Riparian Exclosures Comment 1 for additional information.

Comment 4: Exclosures should be maintained to keep livestock from accessing stream and 

riparian areas. (CBD-18)

Response: The purpose of the exclosure proposals are to allow time for riparian, stream 

and bank restoration projects to establish (EIS page 33). During scoping (Scoping 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

201

Content Analysis document), a commenter pointed out that exclosures would need to be 

of adequate height to keep elk out of riparian areas, due to being able to cause damage to 

riparian and impact stream systems. In order to have an effective treatment it is necessary 

to exclude wildlife such as elk. These are temporary exclosures and are not meant to 

permanently exclude livestock and wildlife from riparian areas.

Comment 5: Concern that riparian exclosures may affect southwestern willow flycatcher, loach 

minnow, narrow-headed garter snake, northern Mexican gartersnake (CBD-27), and beaver. 

(WEG-14)

Response: Southwestern willow flycatchers are not known to be present in project area. 

The primary constituent elements needed for Southwestern willow flycatchers are not 

present. Exclosures are not proposed in loach minnow, narrow-headed gartersnake, nor 

northern Mexican gartersnake habitat.

Beaver was selected as a management indicator species for the mid-elevation riparian 

areas that occur in the project area, but there are no known beaver within the project area. 

Mid-elevation riparian, as defined by the management indicator species update for the 

forest plan area, do not occur in areas where riparian exclosures are proposed to be 

constructed.

Vegetation Treatments

Comment 1: Request to the forest to ensure that resulting woodland vegetation and grassland 

restoration treatments adjacent to Tucson Electric Power transmission line discourages growth 

into the line and corridor. (TEP-1)

Response: The Gila National Forest will coordinate with Tucson Electric Power as well 

as other partners during development and implementation of treatment prescriptions in 

areas adjacent to infrastructure to maintain or move toward vegetation management goals 

of each party.

Comment 2: Concern vegetation management projects will not be coordinated with permittee 

regarding timing and pasture rest/rotation of cattle. (TP-4)

Response: Permittee coordination is identified as a design feature in the EIS (page 25 for 

prescribed fire; page 35 common to all action alternatives) to minimize effects to the 

range resource and effects are analyzed in EIS page 146 in the Range section.

Comment 3: Request for the forest to incorporate the collaboratively developed products and 

design features from 4FRI. (CBD-2)

Response: The Vegetation (Silviculture) Report includes appendix 3 Luna Restoration 

Project Old and Large Tree Implementation Strategy. This strategy will follow direction 

found in the Gila National Forest Plan, which provides direction on the minimum criteria 

for the structural attributes used to determine old growth by forest cover type name.

Additional old and large trees may be retained when not in conflict with meeting the 

desired conditions for this project. Protection measures for old and large trees in logging 

operations are incorporated into the sale contract. The Gila normally designates trees for 

either removal or leaving by painting the tree. If it is a cut tree mark, large trees that will 

not be cut would not be painted. In a leave tree mark, large trees that would be left would 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

202

be painted. Other protections include felling trees away from leave trees and pulling slash 

back away from the trees.

Comment 4: Concern the DEIS did not include detailed prescriptions for the various 

vegetation types. (CBD-4)

Response: Text was added to the final EIS in chapter 2 under the Vegetation Treatments 

section to provide details regarding the treatment of various vegetation types in the 

project area. Also, the Vegetation (Silviculture) Report appendix 1 Luna Restoration 

Project Treatment Details for Vegetation Treatments includes example summaries of 

typical treatment prescriptions. Specific treatment prescriptions will vary based on 

individual on-site evaluation by a certified Silviculturist coordinating with Forest Service 

resource specialists (soils, wildlife, recreation, fuels, and timber), partners such as New 

Mexico State Forestry, New Mexico Game and Fish, and stakeholders such as adjacent 

landowners, permittees, and utilities during implementation prescription development. 

This coordination would continue throughout treatment implementation to insure design 

features listed in the environmental impact statement and decision and appropriate best 

management practices are applied.

Comment 5: Concern there is a lack of information explaining the “four zones” concept under 

the Stand Density Index section. (CBD-5)

Response: Text was added to the final EIS in chapter 1 under the Stand Density Index 

section to provide an explanation of the four zones.

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

thought of in terms of the degree of crowding among trees in a stand. This can be 

measured in trees per acre, square feet of basal area, or expressed as an index of stocking, 

such as stand density index. The four zones refer stand density index which is the 

resource indicator used in the Luna Restoration project analysis. Long (1985) divided the 

stand density index into four zones based on the percentage of the overall density of a 

tree stand relative to the biological maximum density, a species-specific value (Triepke et 

al. 2011).

The stratification of stand density index in table 2 (EIS page 7) provides a useful means 

for discussing stand dynamics relative to species composition and the implications of 

varying the timing, scale, and intensity of density management to affect the variety of 

stand and tree characteristics (Long 1985, Long et al. 2004, Shaw and Long 2010 as cited 

in Triepke, Higgins et al. 2011). Regeneration of desired species can be initiated by 

maintaining stand density in zone 1, based on maximum stand density index of desired 

species; open canopy stands with grassy understories and large diameter trees with long, 

heavy-limbed crowns can be developed by targeting densities in zones 1 and 2; stands of 

moderate crown closure and intermediate sized trees with thrifty, well-pruned crowns can 

be developed by targeting densities in the upper half of zone 2 and the lower half of zone 

3; clumpy, irregular stands containing groups of varying ages can be developed through 

periodic creation of canopy openings (zone 1), where growing space for tree regeneration 

is made available for seedling establishment; longevity of existing large diameter trees 

could be enhanced by thinning adjacent smaller trees to create zone 2 or 3 growing 

conditions; and avoiding density related mortality and maintaining forest vigor can be 

achieved by maintaining densities at or less than the lower half of zone 3.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

203

For the Luna Restoration Project, four zones are used to depict a generalized relationship 

between growth and relative density across the landscape. Percentage of maximum stand 

density index for zones 1 and 2 are as described by Long 1985 as cited in Triepke, and 

Higgins et al. 2011. Percentage of maximum stand density index for the upper limit zone 

3 and lower limit zone 4 ranges between 55–60 percent. Fifty-five percent was used as 

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

about 55 percent of maximum stand density index, some trees in a stand will begin to die 

from competition (Drew and Flewelling 1979). Also, when modeling the alternatives, the 

defaults for density related mortality was used. By default in the Forest Vegetation 

Simulator model, density related mortality begins when the stand density index is above 

55 percent of maximum stand density index, and stand density peaks at 85 percent of 

maximum stand density index. The 55 percent value is referred to as the lower limit of 

density related mortality, and the 85 percent value is the upper limit (Dixon 2002; 

Vegetation (Silviculture) Report).

Since this is a measure of density and not an action, best management practices do not 

apply.

Comment 6: Concerned there is uncertainty regarding historic range of variability for dry and 

wet mixed conifer forests. Concerned that regionally derived management directives (GTR) are 

not tailored to the Luna area and are not associated with the Terrestrial Ecosystem Units in the 

project area. (CBD-6)

Response: The Vegetation (Silviculture) Report appendix 1 Luna Restoration Project 

Treatment Details for Vegetation Treatments includes example summaries of typical 

treatment prescriptions. During prescription development, site-specific parameters and 

modifications to these example prescriptions occur following site visits. Prescriptions 

developed for mixed conifer forest and ponderosa pine-Gambel oak forest and riparian 

will follow the Gila forest plan direction for Mexican spotted owl. Woodland and 

ponderosa pine forests not within Mexican spotted owl protected activity centers will 

follow the Gila forest plan direction for northern goshawk.

Comment 7: Concern that ongoing livestock grazing and the outcome of proposed treatments are 

assessed. (CBD-14; CBD-17)

Response: As stated in the EIS on page 14, this environmental analysis will not change 

previous range management decisions. The moderate to conservative utilization 

guidelines within the grazing decisions have not been shown to contribute to the 

displacement of native grass communities by rabbitbrush. The removal of rabbitbrush

would aid in promoting diversity and vigor of more desired rangeland plants in selected 

areas. All vegetation and prescribed fire treatments will be coordinated with range 

permittees to appropriately manage grazing activities during and after implementation 

stages. Coordination may occur during annual operating instruction meetings.

See Vegetation Treatments Comment 2 for more information.

Comment 8: Concern that piñon-juniper is intentionally being removed “en masse” to meet 

restoration goals and that treatment of piñon-juniper ecosystems would result in an even aged 

stand condition. (CBD-21)

Response: The Gila forest plan gives direction to maintain all species of native trees in 

the landscape. The Forest Service is not planning to remove all piñon-juniper from the 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

204

area. Thirty-seven percent of woodland will not receive any treatment. Twenty-seven 

percent of woodland would be treated with prescribed fire only (no mechanical, hand, or 

herbicide). Thirty-six percent of woodland would be treated following Gila National 

Forest Plan guidelines for northern goshawk habitat. The intent is to leave a mosaic of 

vegetation densities (overstory and understory), age classes, and species composition well 

distributed across the landscape.

Appendix 1 Luna Restoration Project Treatment Details for Vegetation Treatments in the 

Vegetation (Silviculture) Report includes example summaries of typical treatment 

prescriptions including treatments for woodland.

It is not the intention to manage all piñon-juniper in an uneven aged condition. The 

desired condition of uneven aged condition for woodland is specific to northern goshawk 

habitat to manage for uneven age conditions to sustain a mosaic of vegetation densities 

(overstory and understory), age classes, and species composition well distributed across 

the landscape (Gila forest plan). This is achieved primarily through tree cutting 

prescriptions, which are more selective than prescribed burning. Within the Luna 

landscape, 60 percent of the piñon-juniper woodland is currently in an even-aged 

structure, 21 percent of the piñon-juniper woodland designated old growth will receive no 

treatment and 13 percent would be burned with no tree cutting. With the no-action 

alternative, 59 percent would be even-aged structure in 20 years and 57 percent would be 

even-aged structure in 40 years. With the action alternatives, 60 percent would be evenaged structure in 20 years and 56 percent would be even-aged structure in 40 years 

(Vegetation (Silviculture) Report).

Comment 9: Concern a robust site-specific review of landscape-scale patterns was not included 

in the DEIS. Specifically shift and transition in vegetation extent to ensure treatments are 

designed in line with ecological trends. (CBD-22)

Response: Based on the existing information for the Luna Project area, treatments are 

designed to increase the resiliency of the vegetation to future disturbances such as insect, 

disease, fire, drought, and other climatic changes across the landscape.

More information is provided in in the Vegetation (Silviculture) Report appendix 1 Luna 

Restoration Project Treatment Details for Vegetation Treatments and appendix 3 Luna 

Restoration Project Old and Large Tree Implementation Strategy.

Comment 10: Provide a map of past chaining treatments on the Luna landscape. Use this map to 

determine best site-specific management strategies. (CBD-24)

Response: Chaining treatments to improve forage production occurred in the late 1950s 

through the 1970s and were deemed not effective in controlling smaller trees (Gila forest 

plan page 32). The status of any maps or information being available for locations of 

chaining activities during that time period is unknown.

Herbicide Treatments

Comment 1: Concern herbicide treatments are being applied over large area; become airborne; 

and impact non-target plant and animal species. (JP-4, TN-8, CBD-11)

Response: The proposal for the use of herbicide to treat alligator juniper and rabbit brush 

is not a broad application across 30,000 acres. The proposal is to address areas within the 
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

205

30,000 acres of grassland, woodland, and forested vegetation types that have been 

encroached by these species; and to avoid undesirable vegetation states that lack diversity 

or dominated by single species. The EIS page 22 describes the objective of rabbitbrush 

treatment to be: “...manage rabbitbrush and reduce the occurrence of dense stands or 

monocultures of rabbitbrush; not to eliminate rabbitbrush across the planning area. For 

alligator juniper, locations would be identified where allowing the juniper to re-sprout 

would not meet vegetative treatment objectives, such as, but not limited to, wildland 

urban interfaces.”

Only herbicide products that have been registered with the Environmental Protection 

Agency for rangeland, forestland, or aquatic use and have a Forest Service human health 

and ecological risk assessment, and are approved through the 2000 environmental 

analysis would be considered for this project. It is required to follow the product label 

during implementation and includes such things as use around water sources, soil types, 

and under what weather conditions. Following product label reduces risk to resources. 

Design features and best management practices were compiled by the interdisciplinary 

team (EIS pages 23–24) that include additional guidelines and requirement for proper 

wind speeds during application to reduce the potential for herbicide drift, and to minimize 

risks and spread within waterways, specified soil types, and impacts to wildlife species. 

Applications would be done by hand sprayer for liquids, hand spreader for granules or 

powder, or spreader or sprayer operated off a small tractor or all-terrain vehicle; there 

would be no aerial applications.

A vegetation management plan implementing the utilization of herbicides would be 

developed to identify site-specific activities designed and effectiveness monitoring for an 

individual treatment area.

Comment 2: Concern there is no evidence linking chemical treatment of rabbitbrush & juniper 

to improve biodiversity, grassland health, or improvement in watershed condition. (CBD-13)

Response: The purpose of herbicide treatments is not to remove these species from the 

landscape but to decrease the abundance of these species within grassland ecosystems to 

allow for competition by other species and return these areas lacking of diversity and 

dominated by single species to a more desirable and functional state.

Comment 3: It is unclear how the use of herbicides was brought forward in an alternative and 

factors that determine the buffer zone and being able to identify and apply appropriate 

mitigation measures to reduce impacts to sensitive resources. Concern that specific herbicides 

for use are not identified and impacts to resources are not disclosed. (CBD-20)

Response: Page 17 of the EIS identifies the issues that were generated by scoping 

comments. Cutting of juniper and rabbitbrush was considered not to be an effective 

means of treating and managing these vegetation types. Based on interdisciplinary team 

discussion of options of potential effective treatment methods to treat these vegetation 

types and meet objectives (page 5, 6, 12, and 13 of Scoping Comment Analysis) 

herbicide and pushing (for juniper sp.) were some methods discussed. The team decided 

to look at the option of herbicides. The New Mexico State University Circular 597 –

Chemical Weed and Brush Control for New Mexico Rangelands (5/2014) was reviewed 

as part of the decision process.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

206

Buffers are a mitigation that was included to further reduce the opportunity of herbicide 

drift onto private lands, as well as avoiding surface waters. Several other mitigations 

were identified in the EIS (pages 23–24) to address potential drift on National Forest 

System lands.

Similar to burn plans that are developed prior to implementing prescribed fires, a 

vegetation management plan implementing the utilization of herbicides would be 

developed by an interdisciplinary team to include such things as objectives, techniques, 

and monitoring elements as well as the design features identified in the environmental 

impact statement and appropriate best management practices, permitting, and handling of 

materials.

The State of New Mexico licenses all certified herbicide applicators applying herbicide in 

the state. Region 3 (Southwestern Region) of the Forest Service requires that anyone 

applying herbicide be directly supervised by a certified applicator and that any contract 

herbicide application be overseen by a certified applicator within the agency.

See Herbicide Treatments Comment 1 for more information.

Wildlife

Comment 1: Concern the Arizona montane vole, which is known to be in 2 locations within 

the planning area, was not included in the analysis as part of the U.S. Forest Service Region 3 

sensitive species analysis. There is concern that projects could adversely affect the Arizona 

montane vole. (NMDGF-2)

Response: Thank you for identifying that the Arizona montane vole was missing from 

the document. It does occur in the project area and we corrected this in the final EIS.

Implementation of this project would improve Arizona Montane Vole habitat within the 

project area. The project does have the potential to cause short-term impacts to this 

species for all action alternatives, but will not cause a trend toward federal listing or 

affect the viability of the species.

Comment 2: Baseline condition and authorized activities need to analyzed for impacts of 

fragmentation on wildlife habitat by alternative. (CBD-29)

Response: Impacts to wildlife from motorized routes include mortality from collisions 

with vehicles, modification of animal behavior (for example, displacement and avoidance 

of roads by wildlife, human-caused disruption of breeding), Alteration of terrestrial 

habitat (for example, edge creation and habitat fragmentation), and increased contact and 

exploitation by humans. Decommissioning roads would have the reverse impacts to 

wildlife after the use ceased, and the area revegetated itself over time. Fragmentation is 

addressed in the EIS in the wildlife section pages 81–106 and roads section pages 141–

145. Decommissioning of roads in the planning area would improve habitat and 

connectivity for wildlife while also assist in moving watersheds toward properly 

functioning conditions, both of which are part of the purpose and need for the Luna 

Restoration Project (EIS pages 13–14).
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

207

Comment 3: Concern regarding the treatment methods on Gambel oak, which is an important 

browse and acorn source for multiple wildlife species. The Department requests the forest 

consider Gambel oak treatments include: retain mosaic of all sizes and age classes; retain treeform Gambel oak 30-36 cm; and retain patches of pole-sized Gambel oak 7-15 cm. (NMDGF3)

Response: The Gila National Forest looks forward to ongoing coordination with New 

Mexico Department of Game and Fish on wildlife habitat management. The Gila 

National Forest will coordinate site visits with the Department to develop appropriate 

Gambel oak treatment prescriptions across the project area.

In most cases, Gambel oaks are retained in cut units therefore meeting the treatment 

prescriptions provided in the comment. Example silvicultural prescriptions and guidelines 

related to various vegetation stands and Gambel oak may be found in the Vegetation 

(Silviculture) Report appendix 1: Luna Restoration Project Treatment Details for 

Vegetation Treatments.

Comment 4: Concern that forest treatment guidance is lacking for the northern goshawk. (CBD7)

Response: Implementation prescriptions will follow established northern goshawk 

guidelines in areas outside Mexican spotted owl habitat outlined in the Gila forest plan. 

The Vegetation (Silviculture) Report appendix 1 Luna Restoration Project Treatment 

Details for Vegetation Treatments includes example summaries of typical treatment 

prescriptions, including treatments for northern goshawk habitat.

Comment 5: Concern the DEIS does not provide information on the existing status and condition 

of sensitive species nor direct, indirect or cumulative effects. Agency should also consider 

impacts to species of conservation concern that has been developed during the Forest Plan 

Revision process. (WEG-12)

Response: Information on existing status and condition of sensitive species, along with 

direct, indirect and cumulative impacts are included in the biological evaluation (pages. 

15-48).

The list of species of conservation concern is still draft and we are not required to analyze 

those species until the revised forest plan has a decision and is being implemented. But 

the list was reviewed and was comparable to the sensitive species list for species within 

the planning area.

Comment 6: Concern the DEIS does not provide information on the existing status and condition 

of management indicator including mule deer. (WEG-13)

Response: Baseline data and impacts are shown in the Management Indicator Species 

and Migratory Bird Report.

Mule deer is a management indicator species for desert shrub, piñon-juniper shrub, and 

shrub oak woodland communities because good mule deer habitat conditions reflect the 

vegetative conditions in these communities. Mule deer habitat for this project is on 

approximately 32,908 acres. Overall mule deer habitat for the Gila National Forest is 

approximately 1,679,402 acres.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

208

Short-term disturbances for mule deer would be associated with avoiding areas during 

implementation due to human presence and noise associated with work. These short-term 

avoidance factors would also cause a shift in foraging areas for mule deer.

Known fawning areas would be avoided during the fawning season.

Installing user proposed routes, and decommissioning roads would create a short-term 

disturbance to foraging mule deer through noise and human presence. New user routes 

that are proposed would result in habitat fragmentation. These activities are spaced out 

across the project area, and would not all occur at the same time, giving mule deer 

opportunities to utilize other areas in the project. Decommissioning roads would reduce 

habitat fragmentation, and increase forage where bare dirt currently exists.

This project and the Escudilla West project located in Arizona would increase short-term 

disturbances to foraging mule deer through thinning and prescribed burning. Both 

projects would lead to improved habitat conditions for mule deer in the long term. 

Livestock grazing activities, fuelwood collection, road maintenance, and recreation 

activities could increase disturbance to foraging mule deer.

Comment 6: Concern the DEIS dos not disclose why the southwestern willow flycatcher has 

disappeared from the area and what the Forest Service is doing to restore its habitat. (WEG-21)

Response: There are no records of occurrence for Southwestern willow flycatcher in the 

project area. The designated critical habitat lacks the primary constituent elements 

required for Southwestern willow flycatchers. Vegetation treatments proposed would 

improve habitat conditions. The Southwestern willow flycatcher is fully addressed in the 

biological assessment (June 2018) and submitted to U.S. Fish and Wildlife Service for 

formal consultation.

Consultation

Comment 1: The Forest Service fails to provide information regarding consultation and 

conference efforts. There is no description of consultation or conference processes it has been 

involved with to date to assess the effects of project on ESA-listed species and habitat in project 

area. (WEG-22)

Response: On October 10, 2017, the Forest Service began coordinating the consultation 

process with U.S. Fish and Wildlife Service staff from the office in Albuquerque, New 

Mexico regarding the Luna Restoration Project. Main discussion points included an 

overview of the proposed project activities and general discussion regarding possible 

effects. The U.S. Fish and Wildlife Service indicated that consultation on this project was 

a high priority, and that additional meetings may be necessary to review specific elements 

of the project proposal such as where adverse effects might occur, and how to reduce the 

potential for take. The Gila National Forest worked with Shaula Hedwall, U.S. Fish and 

Wildlife Service, on developing the Mexican spotted owl monitoring plans related to 

treatments in protected activity centers.

An official species list was requested on April 24, 2017, an updated list was requested on 

September 12, 2017, January 23, 2018, and again on May 3, 2018.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

209

Formal consultation (Cons. # 02ENNM00-2017-F-0491) was initiated June 4, 2018, and 

amended on September 19, 2018 for the New Mexico meadow jumping mouse. The Gila 

National Forest is awaiting a final biological opinion.

Mexican Gray Wolf

Comment 1: The DEIS does not provide information on the habitat conditions and 

requirements of the Mexican Gray Wolf or potential impacts to the species, its habitat, or its 

prey. (WEG-10)

Response: The Mexican gray wolf is fully addressed in the biological assessment (June 

2018) that was submitted to U.S. Fish and Wildlife Service for formal consultation on the 

Luna Restoration Project. Effects are summarized in the EIS on pages 82–83.

Wolf groups (or packs), usually consist of a set of parents (alpha pair), their offspring 

from the current year and previous years, and possibly unrelated wolves that have been 

accepted into a pack. Den sites can be used year after year by the same wolves. Wolf 

packs usually live within a specific territory that they defend to the exclusion of other 

wolves and often non-specifics, such as coyotes. Territories range in size from 84.5 km2 

(50 mi2) to greater than 1,609 km2 (1,000 mi2) and is dependent on how much prey is 

available and the prey’s seasonal movements. Their ability to travel over large areas to 

seek out vulnerable prey, and their social structure makes wolves good hunters. Wolves 

are habitat generalists and typically only require adequate prey to survive. Historically, 

Mexican wolves were associated with montane woodlands characterized by sparsely- to 

densely-forested mountainous terrain and adjacent grasslands in habitats where ungulate 

prey were numerous. Today, elk (Cervus elaphus) are the preferred prey of Mexican 

wolves in the Blue Range Wolf Recovery Area. Other sources of prey include deer 

(Odocoileus virginianus and Odocoileus hemionus), small mammals, and occasionally 

birds.

There are wolves in the project area. The Forest Service will work with the Mexican gray 

wolf field team to avoid disturbing dens through forest management activities, including 

thinning, burning, roads/trails, herbicide application, sediment control, fencing and water 

improvements. If a wolf pack or individual wolves begin denning within the project area, 

active mitigation will help minimize any direct effect to Mexican gray wolves from the 

proposed action. These elements are included as design features common to all action 

alternatives in the EIS page 36.

Implementation of the preferred alternative may indirectly affect, through disturbance, 

Mexican gray wolves that may occur in the project area. This project has the potential to 

have an impact on the wolves’ primary prey base. Since one of the goals of this project is 

to improve wildlife habitat conditions for wild ungulates, effect to wolves primary prey 

base will be relatively undetectable in the short term and or likely beneficial in the long 

term.

Mexican Spotted Owl

Comment 1: The Department supports experimental thinning of trees less than 9 inches DBH 

and application of low intensity prescribed burns to reduce the potential of high severity fires in 

treated Mexican spotted owl protected activity centers. (NMDGF-5, CBD-3). Management 

treatments should be consistent with the U.S. Fish and Wildlife Service Biological Opinion 

(CBD-3).
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

210

Response: Thank you for your comment and support for the treatment proposals within 

Mexican spotted owl protected activity centers within the Luna Restoration Project.

The Gila National Forest is in consultation with the U.S. Fish and Wildlife Service. The 

Biological Assessment for the Luna Restoration Project was submitted to the Service on 

June 4, 2018. Applicable recovery plans were referenced during preparation of the 

biological assessment and treatments proposed within the EIS. The EIS and record of 

decision reference the U.S. Fish and Wildlife Service Biological Opinion and 

implementation will be consistent with and follow the reasonable and prudent measures 

and corresponding terms and conditions along with conservation measures outlined 

within the document, including survey and monitoring for threatened and endangered 

species.

Comment 2: Concern that herbicide treatments in Mexican spotted owl critical habitat (1,270 

acres) will reduce food for prey species. (CBD-12)

Response: Treating juniper with herbicide would reduce competition with ponderosa 

pine and mixed conifer species, which in turn would allow for more rapid growth thus 

improving some Mexican spotted owl habitat components over time. Reducing juniper 

would reduce feed for prey species and therefore may potentially in the short-term 

indirectly impact Mexican spotted owl through the impacts to prey species.

The Environmental Protection Agency states, “When used properly, pesticides can play a 

valuable role in controlling weeds, insects, and other pests. On the other hand, they can 

harm wildlife if the user does not follow label directions.” (EIS page 85). Herbicide 

manufacturers produce label processes on application to prevent effects to general 

wildlife. Manufacturer labels will be followed to prevent impacts to Mexican spotted 

owls, and their prey.

Human activity and noise associated with mechanized equipment could disturb nesting 

owls. Performing these actions outside of the breeding season will prevent disturbance to 

nesting owls.

Comment 3: The DEIS does not provide monitoring information on the Mexican spotted owl 

nor provide sufficient analysis of current habitat conditions and effects. (WEG-11, WEG-20)

Response: The Mexican spotted owl is fully addressed in the biological assessment (June 

2018) that was submitted to U.S. Fish and Wildlife Service for formal consultation on the 

Luna Restoration Project. Effects are summarized in the EIS on pages 83–86.

The ecology and status for Mexican spotted owls is located in the biological assessment . 

Monitoring has been conducted in the project area in 2016 and 2017 (Biological 

Assessment for the Luna Restoration Project).

Modeling using the Forest Vegetation Simulator predicts the primary constituent 

elements will improve under the action alternatives, versus the no action. This data is 

shown in appendix A of the biological assessment. The assumptions and data limitations 

of the modeling is provided in the EIS (pages 62–63) and the Vegetation (Silviculture) 

Report. A summary of the Habitat Features for Mexican Spotted Owl (Threshold Stands)

is located in the EIS pages 72–73.
Appendix A: Response to Comments on the Draft Environmental Impact Statement

Luna Restoration Project 

Final Environmental Impact Statement

211

Thinning and prescribed fire would allow herbaceous plants to establish, providing food 

sources for owl prey species. Herbicide use may remove some food sources for prey 

species; however, where herbicide is proposed for use is within piñon-juniper stands and 

rabbitbrush stands that do not contain the primary constituent elements of critical habitat. 

Fences and water improvements would lead to better distribution of grazing ungulates 

and improved ground cover for owl prey species. However, these range improvements 

will require disturbance to vegetation, may reduce snags in the vicinity of the 

improvement, and impact hardwoods if they occur at site of improvement. Road 

decommissioning would reduce habitat fragmentation of habitat and allow revegetation 

of the road tread, which would lead to better habitat for Mexican spotted owl prey species 

and reduce motorized noise disturbance. Fences and water improvements would lead to 

better distribution of grazing ungulates, in turn improving habitat for prey species.

Proposed activities within protected activity centers including thinning, prescribed 

burning, road decommissioning, fence construction, and motorized trail re-alignment may 

indirectly affect the Mexican spotted owl by altering habitat components for both the owl 

and owl prey base within protected activity centers. Prescribed burning may remove 

hardwoods, snags, and downed woody debris. The effects from prescribed burning to the 

species are neither insignificant nor discountable. Prescribed fire will reduce owl prey 

base habitat (food and cover) during the short term and will likely reduce large woody 

debris over a longer period (replacement period). The effects to individual owls will 

likely not be measurable and will not likely rise to the level of harm or harassment. 

However, the effects to habitat and subsequent impacts to owls are likely to occur. 

Maintaining low-intensity and low-severity fire will reduce these impacts but they are 

likely to occur at some level. Thinning of conifer trees less than 9 inches diameter at 

breast height in a manner that maintains threshold conditions will allow for development 

of larger trees and increased basal area in larger diameter classes and will allow for 

increased herbaceous ground cover and improve owl prey base habitat. Road 

decommissioning will return existing closed roads to a more natural state over time. 

Initial response on decommission roads will include increased herbaceous cover and 

eventually the establishment of trees. Returning closed roads to conditions that are more 

natural will improve habitat conditions for Mexican spotted owl in the long term. 

Construction of fences will potentially require the removal of vegetation within the path 

of the new fence and future maintenance will include the removal of downfall or snags on 

or near the fence.

All of these activities could indirectly affect the owl through changes to habitat features 

such as reduction in large woody debris on the forest floor, reduction in the number of 

snags, short-term decreases in ground cover where the activity occurs. These indirect 

effects to the owl in designated critical habitat are likely to occur, however they are likely 

not measurable and actual harm or harassment of owls will not be detectable. Indirect 

effects to the Mexican spotted owl are likely to adversely affect individuals inhabiting 

protected activity centers, where treatments are proposed. These protected activity center 

treatments would reduce habitat needs to individual nesting owls in the short term, until 

remaining vegetation responded and grew into larger trees.

Current livestock grazing has conservative utilization rates that are considered light to moderate. 

This utilization has little to no impact on prey species. Cumulatively, prey species could have 

lower amounts of available forage available outside of the breeding season (seasonal restriction 

for implementation).
Luna Restoration Project

Final Environmental Impact Statement

212

Appendix B: Comment Letters from Federal and State 

Agencies and Tribes

In compliance with section 102(c) of the National Environmental Policy Act, which states, 

“...comments and views of the appropriate Federal, State and local agencies, which are 

authorized to develop and enforce environmental standards, shall be made available to the 

President, the Council of Environmental Quality and to the public...” the following comment 

letters are provided in this appendix:

Commenter’s Name Organization

Stewart B. Koyiyumptewa The Hopi Tribe

Jeff M. Witte State of New Mexico, Department of Agriculture, 

Stephen R. Spencer, PhD United States Department of the Interior, Office of 

Environmental Policy and Compliance

Matt Wunder, PhD State of New Mexico, Department of Game and Fish

Cheryl T. Seager United States Environmental Protection Agency, Region 6

Many of the letters received were scanned images, which makes them inaccessible to users of 

assistive reading devices. Therefore, to accommodate all readers, we reproduced the primary 

text of each letter here, omitting logos and stylized letterheads. Letters are arranged in order 

by the date received. Copies of the original letters are available for viewing from the project 

record.
Appendix B. Comment Letters from Federal and State Agencies and Tribes

Luna Restoration Project

Final Environmental Impact Statement

213

Letter from The Hopi Tribe

Timothy L. Nuvangyaoma

Chairman

Clark W. Tenakhongva

Vice-Chairman

May 18, 2018

Adam Mendonca, Forest Supervisor

Attention: Lisa Mizuno, Environmental Coordinator Gila National Forest

3005 East Camino Del Bosque

Silver City, New Mexico 88061

Re: Luna Restoration Project, Draft Environmental Impact Statement

Dear Supervisor Mendonca,

This letter is in response to your correspondence dated May 2, 2018, with an enclosed draft 

Environmental Impact Statement regarding the 185,586-acre Luna Restoration Project on the 

Quemado Ranger District. The Hopi Tribe claims cultural affiliation to earlier identifiable cultural 

groups in New Mexico. The Hopi Cultural Preservation Office supports the identification and 

avoidance of prehistoric archaeological sites and Traditional Cultural Properties, and we consider the 

archaeological sites of our ancestors to be "footprints" and Traditional Cultural Properties. Therefore 

we appreciate the Forest’s continuing solicitation of our input and your efforts to address our 

concerns.

In the enclosed letter dated May 31, 2016, the Hopi Cultural Preservation Office reviewed the 

Scoping Action. We have now reviewed the enclosed draft Environmental Impact Statement and 

understand approximately 10% of the planning area has been surveyed for cultural resources and 513 

sites have been identified. We also understand a1l alternatives will require extensive survey including 

73,856 acres of mechanical treatments.

Therefore, if the cultural resource surveys of the areas of potential effect identify prehistoric 

sites that may be adversely affected by project activities, please provide us with copies of the cultural 

resources survey report and any proposed treatment plans for review and comment. In addition, we 

recommend that if any cultural features or deposits are encountered during project activities, these 

activities will be discontinued in the immediate area of the remains, and the State Historic 

Preservation Office will be consulted to evaluate their nature and significance. If any Native American 

human remains or funerary objects are discovered during construction they shall be immediately 

reported as required by law.

If you have any questions or need additional information, and please contact Terry Morgart at 

the Hopi Cultural Preservation Office at tmorgart@hopi.nsn.us or 928-734-3619. Thank you for your 

consideration.

Respectfully,

Stewart B. Koyiyumptewa, Interim Manager

Hopi Cultural Preservation Office

Enclosure: May 31, 2016 letter

xc: New Mexico State Historic Preservation Office

Emily Irwin, District Ranger, Quemado Ranger District, P.O. Box 159, Quemado, NM 87829
Appendix B. Comment Letters from Federal and State Agencies and Tribes

Luna Restoration Project

Final Environmental Impact Statement

214

Letter from the State of New Mexico, Department of Agriculture

Susana Martinez

Governor

Jeff M. White

Secretary

May 23, 2018

Mr. Adam Mendonca, Forest Supervisor

ATTN: Luna Restoration Project

3005 East Camino del Bosque

Silver City, NM 88061

Dear Mr. Mendonca:

New Mexico Department of Agriculture (NMDA) respectfully submits the following comments in 

response to the Draft Environmental Impact Statement for the Luna Restoration Project (EIS) in the 

Quemado Ranger District of the Gila National Forest (Gila NF).

NMDA maintains a strategic goal to promote responsible and effective use and management of natural 

resources, which is specific to our mission within state government: dedication to the promotion and 

enhancement of New Mexico’s agriculture; natural resources; and social, economic, and cultural 

agricultural heritage.

NMDA supports efforts to improve forest health by reducing high tree densities, restoring riparian 

areas and watersheds, and returning lands to a more productive state. Overly dense stands of woody 

vegetation impede herbaceous forage production to the detriment of livestock and some wildlife and 

increase the likelihood of catastrophic wildfire. Water quality can be impacted by degraded riparian 

areas and watersheds.

Stream and Riparian Restoration

Our comments are specific to the potential effects this project may have on livestock grazing 

allotments in the area. We are concerned with how parts of the EIS will be implemented, specifically 

stream and riparian restoration. According to the EIS, the Gila NF intends to construct multiple 

riparian exclosures for the purpose of restoring riparian vegetation and improving watershed 

conditions. We encourage the use of exclosures to be site-specific to the restoration area in order to 

minimize the impact on grazing allotment permittees. Construction and maintenance of exclosures 

could increase costs to allotment permittees. We encourage implementation of projects be done in 

consultation and coordination with affected grazing allotment permittees to ensure low cost access to 

water for cattle while restoring riparian areas and streams.

Conclusion

NMDA agrees with the need for this EIS and recognizes the value of vegetation treatments; range

improvements; and riparian, stream, and watershed restoration to the health of the national forest. 

Thank you for the opportunity to comment on this proposal. NMDA requests you continue to keep us 

informed about the Luna Restoration Project. Please contact Gizelle Hurtado, Ph.D., (575) 646-8024, 

if there are any questions pertaining to these comments.

Sincerely,

Jeff M. Witte
Appendix B. Comment Letters from Federal and State Agencies and Tribes

Luna Restoration Project

Final Environmental Impact Statement

215

Letter from the United States Department of the Interior,

Office of Environmental Policy and Compliance

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance 1001 Indian School Road NW, Suite 348 

Albuquerque, New Mexico 87104

ER 18/0220

File 9043.1

June 25, 2018

Adam Mendonca

Forest Supervisor

ATTN: Luna Restoration Project

3005 East Camino del Bosque

Silver City, NM 88061

Dear Mr. Mendonca:

Thank you for the opportunity to review and comment on the U.S. Forest Service’s Draft 

Environmental Impact Statement (DEIS) for the Luna Restoration Project, in Catron County, New 

Mexico.

The Department of the Interior has no substantive comments at this time. However, the Bureau of 

Land Management (BLM) and the Fish and Wildlife Service (FWS) have requested to be kept 

informed during the planning process.

Should you have any questions, please contact Catie Brewster, Planning and Environmental 

Assistant, BLM (505.954.2044; cbrewster@blm.gov), and Ted Koch, Assistant Regional Director, 

Ecological Services, FWS (505.248.6671; ted_koch@fws.gov).

Sincerely,

Stephen R. Spencer, PhD

Regional Environmental Officer
Appendix B. Comment Letters from Federal and State Agencies and Tribes

Luna Restoration Project

Final Environmental Impact Statement

216

Letter from the State of New Mexico, Department of Game and Fish

Susana Martinez

GOVERNOR

Alexandra Sandoval

DIRECTOR AND SECRETARY TO THE COMISSION

Donald L. Jaramillo

DEPUTY DIRECTOR

June 25, 2018

Mr. Adam Mendoca, Forest Supervisor

ATTN: Luna Restoration Project

Gila National Forest

3005 E. Camino del Bosque

Silver City, NM 88061

RE: Luna Restoration Project Draft Environmental Impact Statement; NMDGF No. 18445

Dear Mr. Mendoca:

The Department of Game and Fish (Department) has reviewed the Luna Restoration Project Draft 

Environmental Impact Statement (DEIS) and conducted a planning area site visit with Quemado 

Ranger District staff.

The Department supports the Quemado Ranger District's efforts to Implement the Luna 

Restoration Project, which includes a wide variety of proposed types of projects including 

wildland urban interface (WUI), thinning only, prescribed fire only, thinning and prescribed fire, 

riparian vegetation restoration, spring, and stream protection using pipe rail and 8-foot fence, 

stream bank stabilization, hardening of motorized stream crossings, motorized vehicle barriers, 

and motorized trail reroutes. The Department believes that implementing these projects will 

increase ecological resilience and benefit wildlife and wildlife habitats on the Quemado Ranger 

District. The DEIS uses best available science to achieve desired future conditions for forest 

woodlands, grasslands, riparian and aquatic habitats.

In New Mexico, riparian and aquatic habitats are critical to the survival of many species of 

wildlife. Approximately 80% of all sensitive and special-status vertebrate species In New Mexico 

depend upon riparian or aquatic habitat at some time during their life cycle (Biota Information 

System of New Mexico 2000). During the field visit, Department and Quemado Ranger District 

staff observed multiple impaired riparian and aquatic habitats across the planning area. Page 12 of 

the DEIS states “Aquatic and riparian obligate species are being impacted by impaired 

watersheds. High sediment loads and temperatures, lack of woody debris in the channel, lack of 

mature, multi-story riparian vegetation, and exotic species are some of the conditions present.” 

Therefore, the Department strongly supports Implementing the multiple aquatic and riparian 

habitat restoration proposals included in the DEIS. Examples include the proposed work at Adair 

Springs to protect springs and spring runs from livestock trampling by installing pipe rail or cable 

fence, while still providing nearby locations for livestock watering. These actions will promote 

re-establishment of mesic vegetation to stabilize banks and protect native Rio Grande suckers 

(Catostomus plebeius), longfin dace (Agosia chrysogaster) and amphibians that were observed in 

Adair Springs.
Appendix B. Comment Letters from Federal and State Agencies and Tribes

Luna Restoration Project

Final Environmental Impact Statement

217

Mr. Adam Mendoca

25 June 2018

Page-2-

The Department also supports riparian restoration projects such as on Stone Creek, where 

polygons of 8-foot tall wildlife exclusion fencing will be constructed to protect native willow and 

cottonwood plantings from livestock and ungulate browsing. Exclosures of 0.5 to 200 acres in 

size will be constructed to allow establishment and survival of the riparian vegetation plantings.

Research has shown high-severity fire to be detrimental to Mexican spotted owls (MSO) when 

bums within protected activity centers (PACs). The Department supports experimental thinning of 

trees ≤ 9 inches diameter and breast height and application of low intensity prescribed fire within 

a portion of PACs in the planning area. One hundred acre core areas will remain untreated within 

each treated PACs. Effects of treatments on MSO occupation will be compared against untreated 

control PACs and, if beneficial, will be applied to additional PACs. Thinning and prescribed fire 

should significantly reduce the potential for high severity fire in treated PACs. To minimize 

disturbance to MSO, treatments will not occur during the nesting period of 1 March to 31 August.

Page 20 of the DEIS, Wildlife Habitat, states “Cut and prescribe burn Gambel oak and 

mountain mahogany stands to promote new growth and sprouting in various locations across the 

planning area”. As stated in our 29 June 2016 comments on the Proposed Action, Gambel oak 

(Quercus gambelii) is an important component of productive wildlife habitat. Gambel oak 

provides browse and acorn mast crops for deer, turkey, and many other game and non-game 

mammals and birds; and cover and nesting structure for wildlife (Reynolds et al. 1970). 

Southwestern ponderosa pine forests with Gambel oak are documented to support higher bird 

diversity and abundance than ponderosa pine forests without Gambel oak (Jentsch et al. 2008). 

The Department requests that all Gambel oak treatments include the following measures.

• Emphasize retaining a mosaic of all sizes and age classes of Gambel oak.

• Retain tree-form Gambel oak in the 30-36 cm diameter range to maximize acorn 

production for game and non-game wildlife (Clary and Tiedemann 1992), and largediameter Gambel oak for nesting and roosting habitat for game and non-game wildlife 

(Clary and Tiedemann 1992).

• Retain patches of pole-sized Gambel oak in the 7-15 cm diameter at breast height range for 

nongame bird Species of Greatest Conservation Need. Increased bird diversity has been 

documented in ponderosa pine forests with Gambel oak stands of this size class (Jentsch et 

al. 2008).

The Department requests that oak treatment prescriptions are clarified within the final EIS.

Page 27, Range Management, discusses burying pipelines that will be installed to facilitate 

better distribution of livestock. Open trenches can trap and cause mortality to wildlife, especially 

small mammals, amphibians and reptiles, .and can cause Injury to large mammals. Periods of 

highest activity for many of these species include nighttime, summer months and wet weather. To 

avoid unnecessary mortality of wildlife, the Department recommends implementing the following 

guidelines when constructing trenches and installing new water lines.

• Keep trenching and back-filling crews close together, minimizing the amount of open 

trench at any given time. Utilize concurrent trenching and backfilling when possible.
Appendix B. Comment Letters from Federal and State Agencies and Tribes

Luna Restoration Project

Final Environmental Impact Statement

218

Mr. Adam Mendoca 

25 June 2018

Page-3-

• Avoid leaving trenches open overnight. Where trenches cannot be back-filled immediately, 

escape ramps should be constructed at least every 300 feet. Escape ramps can be short 

lateral trenches or wooden planks sloping to the surface. The slope should be less than 45 

degrees (1:1). Trenches that have been left open overnight should be inspected and animals 

removed prior to backfilling, especially where endangered species occur.

• Trench during the cooler months (October–March)

The Department requests that an explanation be provided within the final EIS regarding how 

trenching activities will be mitigated to reduce potential mortality to wildlife.

Arizona montane vole (Microtus montanus arizonensis) is known from only two locations in New 

Mexico: Centerfire Bog, and a meadow 1.2 miles west of the junction of Forest Road 385 and 

Jenkins Creek. The Arizona montane vole is state-listed as Endangered under the New Mexico 

Wildlife Conservation Act and is a U.S. Forest Service Region 3 sensitive species. In New 

Mexico, this species is restricted to dense, tall grass and sedge wet meadow habitats. Although the 

Arizona montane vole is not analyzed in the DEIS, the long-tailed vole (Microtus longicaudus) is 

analyzed as an indicator species, and occupies similar wetland and wet meadow habitats. As with 

the long-tailed vole, projects could adversely affect the Arizona montane vole through direct 

mortality from motorized vehicles, and/or short-term habitat destruction. However, the 

Department believes that proposed restoration projects will ultimately improve habitat conditions 

for these vole species by reducing conifer encroachment into meadows, reducing potential for 

high severity wildfire and associated watershed degradation and restoring streams, springs and 

wet meadow habitats. The proposed use of plantings, along with pipe rail and 8-foot fencing to 

exclude livestock and foraging ungulates, will facilitate riparian and wetland vegetation recovery.

Department staff are aware of, and have documented, a small steel tank at Bill Knight Springs 

that has caused mortality to bats attempting to drink. Installation of new water tanks are proposed 

in the DEIS, although no commitment is made to install wildlife escape ramps within these tanks. 

We therefore recommend that all new water tank installations be required to include wildlife 

escape ramps, and exclude support wires or other features that create collision hazards for volant 

wildlife. Old tanks should be retrofitted to include these features whenever possible, and such 

language be added to the DEIS to reflect this commitment.

We appreciate the opportunity to comment on your project. If you have any questions, please 

contact Mark Watson, Habitat Specialist, of my staff at (505) 476-8115, or 

mark.watson@state.nm.us.

Sincerely,

Matt Wunder, Ph.D.

Chief, Ecological and Environmental Planning Division

cc: USFWS NMES Field Office

Jacob Davidson (Habitat Manager, NMDGF)

Daniel Lusk (Southwest Regional Habitat Biologist, NMDGF)

Jim Stuart (Non-game Mammologist, NMDGF)

Erin Duvuvuei (Non-game Ornithologist, NMDGF)

Leland Pearce (Herpetologist, NMDGF)
Appendix B. Comment Letters from Federal and State Agencies and Tribes

Luna Restoration Project

Final Environmental Impact Statement

219

Mr. Adam Mendoca

25 June 2018

Page-4-

Literature Cited

Clary, W.P., and A.R. Tiedemann. 1992. Ecology and values of Gambel oak woodlands. Pp. 87-95 

in P.F. Ffolliott et al., Technical Coordinators. 1992. Ecology and management of oak and 

associated woodlands: Perspectives in the Southwestern United States and Northern 

Mexico. 1992 April 27–30; Sierra Vista, AZ. General Technical Report RM-218. Fort 

Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Forest and 

Range Experiment Station. 224 pp.

Jentsch, S., R.W. Mannan, B.G. Dickson, and W.M. Block. 2008. Associations among breeding 

birds and Gambel oak in Southwestern ponderosa pine forests. Journal of Wildlife 

Management 72: 994-1000.

Reynolds, H.G., W. Clary, and P. Ffolliott. 1970, Gambel oak for Southwestern wildlife. Journal 

of Forestry 68:545-547.
Appendix B. Comment Letters from Federal and State Agencies and Tribes

Luna Restoration Project

Final Environmental Impact Statement

220

Letter from the United States Environmental Protection Agency, 

Region 6

June 28, 2018

Adam Mendonca

Forest Supervisor

Attn: Luna Restoration Project

3005 E. Camino del Bosque

Silver City, NM 88061

Subject: Luna Restoration Project, Draft Environmental Impact Statement, Gila National Forest, 

Luna, New Mexico (CEQ# 20180092)

Dear Mr. Mendonca:

The U.S. Environmental Protection Agency (EPA) has reviewed the Draft Environmental Impact 

Statement (DEIS) for the Luna Restoration Project. Our review is provided pursuant to the 

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

regulations (40 CPR Parts 1500 - 1508), and our NEPA review authority under Section 309 of the 

Clean Air Act.

Based on our review of the DEIS, we have rated all Alternatives with Environmental Concerns 

(EC-2) (see enclosed “Summary of Rating Definitions”). Our review has identified potential 

environmental impacts in Chapter 3 of the DEIS that should be considered in the decision making 

process. The smoke from prescribed fires could impact the EJ population in the adjacent counties. 

The USDA should collaborate with the New Mexico Environment Department to avoid or 

minimize the smoke impact to human population. We recommend that the USDA provide the 

necessary mitigation assistance and/or coordination to protect individuals with sensitivity to 

smoke from adverse impacts associated with the proposed project. Responses to EPA comments 

should be placed in a dedicated section of the FEIS and should include the specific location where 

the revision was made. If no revision was made, please provide an explanation.

EPA appreciates the opportunity to review this DEIS. When the Final Environmental Impact 

Statement is released, please send one CD to the address above (mail code: 6EN-WS). If you 

have any questions, please contact Gabe Gruta, the lead reviewer for this project, at (214) 665-

2174 or gruta.gabriel@epa.gov.

Sincerely,

Cheryl T. Seager Director

Compliance Assurance and Enforcement Division

Enclosures: Summary of the EPA Rating System
Luna Restoration Project

Final Environmental Impact Statement

221

Index

6th-code watersheds, 12, 38, 110, 114, 138

action alternatives

design features, 35, 36, 37

effects on air quality, 107

effects on aquatic resources, 125, 127, 

128, 129, 130, 134

effects on fire and fuels, 78, 79

effects on heritage resources, 160, 161

effects on inventoried roadless areas, 154

effects on management indicator species, 

94, 95, 97, 98, 99, 100, 102

effects on Mexican gray wolf, 44, 83

effects on Mexican spotted owl, 86

effects on migratory birds, 105

effects on narrow-headed gartersnake, 88

effects on old growth, 72

effects on range resources, 146

effects on recreation, 149

effects on roads, 143, 144

effects on sensitive species, 91

effects on social and economic resources, 

166

effects on soils, 119, 120, 121, 122, 123

effects on southwestern willow flycatcher, 

87

effects on spikedace and loachminnow, 89

effects on vegetation, 68, 69, 70, 72

effects on water quality and quantity, 126, 

127, 132, 134, 135, 136, 137, 138

monitoring, 22, 37, 38

vegetation treatments, 19, 21

alligator juniper, 22, 23

allotments, 145

alternative C

effects of herbicide use, 74

effects of herbicide use on management 

indicator species, 97, 99, 101, 102

effects of herbicide use on Mexican 

spotted owl, 85

effects of herbicide use on migratory 

birds, 105

effects of herbicide use on range 

resources, 146

effects of herbicide use on recreation, 150

alternative D

effects on recreation, 149, 150

aquatic resources, 113

beaver, 51, 93, 98, 99

birds

migratory, v, 50, 81, 86, 103, 104

climate change, 150, 156, 162, 178

cumulative effects

to watersheds, 138, 140

Dillman Creek reroute, 31

ecological restoration treatments, i, 2, 63

employment and income, 165

environmental justice, 16, 167

Escudilla Landscape, vi, 2, 4, 5, 38, 74, 112, 

167, 180

fire regime groups, v, 76, 77, 79

fire return interval, 11, 76

firewood gathering, 164

fish

threatened, 38, 49, 88, 89, 151

forest plan

amendments, ii, 15, 34

fuel conditions, iv, 10, 11, 25, 26, 75, 80, 

119

Gila National Forest

heritage resources, 158

history, 157

hairy woodpecker, 52, 101, 102, 103

herbicide treatments

design features, 23, 24

inventoried roadless areas

Frisco Box, 153

Mother Hubbard, 152, 153

Nolan, 151

juniper titmouse, 100, 101

landscape-scale restoration, i, 2, 63

loachminnow, 38, 88, 89, 151

long-tailed vole, 96, 97, 98

management indicator species, iv, v, 50, 81, 

92, 93, 95, 98, 99, 101

meetings, i, iii, 16

Mexican gray wolf, 36, 44, 81, 82

Mexican spotted owl, 13

Mexican spotted owl critical habitat, 83

migratory birds, v, 50, 81, 86, 103, 104

modeling

fire, 76

Forest Vegetation Simulator, 62

vegetation structural stage, 66
Index

Luna Restoration Project

Final Environmental Impact Statement

222

modified proposed action, i, ii, 14, 15, 19, 

68

motor vehicle use map, 14, 175

motorized transportation system, 30

design features, 31

mule deer, 50, 92, 93, 94

narrow-headed gartersnake, 22, 24, 26, 38, 

47, 87, 88, 90

National Forest System roads, 142

no-action alternative

description, 19

effects on air quality, 106

effects on aquatic resources, 124, 125, 

131

effects on fire and fuels, 78

effects on heritage resources, 159

effects on inventoried roadless areas, 154

effects on management indicator species, 

51, 93, 95, 97, 98, 100, 101

effects on Mexican gray wolf, 82

effects on Mexican spotted owl, 84

effects on migratory birds, 105

effects on narrow-headed gartersnake, 87

effects on old growth, 66

effects on range resources, 145

effects on recreation, 148

effects on sensitive species, 91

effects on social and economic resources, 

166

effects on soils, 116, 117, 118

effects on southwestern willow flycatcher, 

86

effects on spikedace and loachminnow, 89

effects on vegetation, 64, 66

effects on water quality and quantity, 131

northern Mexican gartersnake, 34, 151

old growth, iv, v, 7, 9, 10, 42, 66, 67, 72, 73

plain titmouse, 52, 100

population growth, 163

prescribed fire treatments, 24, 25

design features, 25, 26

project area

description, 2

location, 2

public involvement, i, iii, 2, 16

rabbitbrush, 22, 23

race and ethnicity, 163

range improvements, 27

drinkers, 28

fences, 29

wells, 28

recreation

hunting, 147

off-highway vehicles, 147

trails, 147

riparian areas, 114

riparian treatments, 33

road decommissioning, 30, 44, 83, 84, 85, 

87, 88, 89, 90, 118, 123, 130, 131, 138, 

143, 176

roads, 142

road-stream crossings, 32

scoping comments, i, iii, 16

sensitive species, ii, 22, 49, 81, 91, 140, 168

significant issues, i, ii, 1, 17, 19

smoke emissions, 59, 108, 166, 167, 168

soils, 113

southwestern willow flycatcher, 22, 24, 26, 

46, 86, 103

spikedace, 49, 88, 89

stand density index, iv, v, vi, 6, 7, 40, 64, 

65, 69

stream and riparian treatments, 31

design features, 34, 38

erosion control, 34

exclosures, 33

irrigation diversion, 32, 173

seeding, 34

stream and bank stabilization, 32, 34

total maximum daily load, 114, 115

Travel Management Rule, 14, 141, 144, 162

Tribal consultation, 16

Tucson Electric Power, i, ii, 2, 18, 22, 26, 

30, 31, 80, 122, 129, 137, 143, 144

vegetation condition class, v, 77, 78

vegetation structural stage, iv, v, vi, 7, 8, 41, 

65, 66, 70, 71, 72, 91

vegetation treatments

design features, 22

herbicide use, 22

Wallow Fire, 5, 14, 63, 80, 89, 112, 113, 

117, 124, 131, 148, 162

water quality

total maximum daily load, 114, 115

water quality standards, iv, 12, 54, 114, 131, 

132, 134, 140

watershed condition classification, 38, 55, 

109, 110, 138, 139, 141

watershed condition rating, iv, 12, 110, 112

wildland fire, 11, 35, 69, 70, 76, 78, 81, 159, 

162, 178, 179
Index

Luna Restoration Project

Final Environmental Impact Statement

223

wildlife management indicator species, iv, v, 

50, 81, 92, 93, 95, 98, 99, 101

Mexican gray wolf, 36, 44, 81, 82

narrow-headed gartersnake, 22, 24, 26, 

38, 47, 87, 88, 90

northern Mexican gartersnake, 34, 151

sensitive species, ii, 22, 49, 81, 91, 140, 

168

southwestern willow flycatcher, 22, 24, 

26, 46, 86, 103

threatened and endangered species, 81