Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 585

Appendix A. Public

Comments and Responses

Table of Contents

Introduction ........................................................................................................................................587

Content Analysis Process ...................................................................................................................587

General Comments.............................................................................................................................588

Plan Process........................................................................................................................................591

Plan and EIS - General .......................................................................................................................597

Alternatives.........................................................................................................................................601

EIS - General ......................................................................................................................................609

Coordination .......................................................................................................................................611

Air.......................................................................................................................................................612

Soil......................................................................................................................................................613

Watershed ...........................................................................................................................................616

Water Resources.................................................................................................................................619

Riparian ..............................................................................................................................................623

Fisheries and Aquatic Habitat.............................................................................................................630

Vegetation...........................................................................................................................................637

Wildland Fire Management ................................................................................................................659

Wildlife and Rare Plants.....................................................................................................................667

Invasive Species .................................................................................................................................689

Recreation...........................................................................................................................................693

Motorized and Nonmotorized Opportunities......................................................................................696

Eligible and Suitable Wild and Scenic Rivers....................................................................................704

Inventoried Roadless Areas................................................................................................................709

Wilderness Resources.........................................................................................................................711

Research Natural Areas ......................................................................................................................725

Scenic Resources................................................................................................................................727

Lands and Special Uses......................................................................................................................727

Cultural Resources..............................................................................................................................729

American Indian Rights and Interests.................................................................................................729

Forest Products...................................................................................................................................730

Livestock Grazing...............................................................................................................................736

Minerals and Energy...........................................................................................................................748

Socioeconomic Resources..................................................................................................................749

Landscape Scale Disturbance Events .................................................................................................752

Conservation Education......................................................................................................................754

Overall Ecosystem Health ..................................................................................................................754

Management Areas.............................................................................................................................756

Suitability ...........................................................................................................................................758

Monitoring..........................................................................................................................................768

Appendix D – Relevant Laws, Regulations, Policies, and Agreements .............................................773

Glossary..............................................................................................................................................774

Commenter Codes ..............................................................................................................................775

References ..........................................................................................................................................780
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Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 587

Introduction

This appendix documents the Apache-Sitgreaves NFs’ responses to substantive comments 

received during the 90-day comment period for the Proposed Land Management Plan (proposed 

plan) and Programmatic Draft Environmental Impact Statement (DEIS). The proposed plan and 

DEIS, along with supporting documents were made available on the Apache-Sitgreaves NFs’ Web 

site in late January 2013. A notice of availability was posted in the Federal Register on February 

15, 2013, by the Environmental Protection Agency under the title “EIS No. 20130028, Draft EIS, 

AFS, AZ, Programmatic—Apache-Sitgreaves National Forests Land Management Plan.” This 

notice initiated the comment period which ended May 17, 2013. The Forest Service received 

comment letters or emails from individuals, organizations, and agencies; these comments were 

received by email, in person, and via the U.S. Post Office. Letters from government agencies and 

tribes are included in appendix H. A total of 41,288 comment letters, of which 145 contained 

unique and substantially different comments. In addition, there were 7 different form letters 

received. The original comments are included in the plan set of documents and are available at the 

Apache-Sitgreaves NFs Forest Supervisor’s Office, 30 S. Chiricahua Drive, Springerville, 

Arizona. Many of the electronic documents from the plan set of documents can be found on the 

forests’ Web site at http://www.fs.usda.gov/main/asnf/landmanagement/planning.

Content Analysis Process

The comment content analysis followed a systematic process of reading, coding, and 

summarizing the comments that were submitted. This process ensured that every comment was 

read, analyzed, and considered. 

Each unique letter was assigned a commenter code (see list of commenter codes at the end of this 

appendix). Each comment within a letter or email was assigned a unique comment tracking 

number and coded by subject and category. Comments were then sorted by topic in a spreadsheet. 

Similar or identical comments were summarized into a single concern statement. The concern 

statements are found in this appendix beginning in the next section. The unique commenter code 

followed by the comment tracking number can be found in parenthesis at the end of the concern 

statement (commenter code  127.9  comment tracking number). For example, 127.9 would 

be comment number 9 of letter number 127. The comments and tracking spreadsheet are 

available in the plan set of documents.

The interdisciplinary planning team prepared responses for each concern statement based on its 

merits, regardless of the source or whether expressed by many people or by one person. This 

appendix documents the Apache-Sitgreaves NFs responses to substantive comments, which are 

addressed as prescribed in 40 CFR § 1503.4 in the following ways:

• Modifying the proposed plan (alternative B) and alternatives;

• Developing or analyzing alternatives not given detailed consideration in the DEIS;

• Supplementing, improving, or modifying the analysis that the DEIS documented;

• Making factual corrections; and/or

• Explaining why the comments need no further agency response.
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588 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

General Comments

Concern Statement: The DEIS fails to establish a need for change based on existing 

conditions and is not clear regarding "revision topics." Recommend the purpose and need 

chapter be revised in accordance with NEPA. (108.7)

Response: The purpose and need for change are discussed in the “Purpose and Need” section in 

chapter 1 of the DEIS. As noted in the DEIS, the need for change is based on public and 

employee collaboration and the Analysis of the Management Situation. The revision topics (three

primary focus areas where there are priority needs for change in program direction) and need for 

change are also described under the “Summary of the Analysis of the Management Situation” 

section in chapter 1 of the plan. 

Concern Statement: Explain how the Forest Service Handbook and the travel management 

plan relate to the plan and projects. (109.1, 132.6)

Response: The introduction to appendix D (“Relevant Laws, Regulations, and Policies”) in the 

plan describes the relationship between national and regional management direction (e.g., Forest 

Service Handbook), forestwide management direction (e.g., plan), and project-level management 

direction (e.g., travel management decisions). 

The Forest Service Directive System consists of the Forest Service Manual (FSM) and Handbook 

(FSH), which codify the agency's policy, practice, and procedure. The system is the primary basis 

for the internal management and control of all programs and the primary source of administrative 

direction to Forest Service employees. The plan’s programmatic guidance was developed to be

consistent with both FSM and FSH direction. Although the plan is in alignment with FSM and 

FSH direction, it does not repeat that direction as plan decisions. 

As forest managers carry out the mission of the Forest Service through the implementation of 

projects and activities, they follow direction as described in the FSM, FSH, and plan. As stated in 

chapter 1, the “plan provides broad guidance and information for project and activity 

decisionmaking.” 

The implementation of the Travel Management Rule (36 CFR §212) is a future project that will 

be implemented following FSM, FSH, and plan guidance. The purpose of the project is to identify 

a designated system for motorized vehicle use. The plan provides the framework (e.g., desired 

conditions, standards, guidelines) for implementing the Travel Management Rule. In particular, 

the “Motorized Opportunities” section in chapter 2 contains standards that would limit motorized 

vehicle travel to a designated system of NFS roads and motorized trails, and designated 

motorized areas. In addition, the “Motorized Uses Suitability” in chapter 4 describes the 

suitability of areas for motorized uses. 

Concern Statement: Any roads in the state of Arizona should fall under the jurisdiction of 

the county and sheriff where they are located. (129.2)

Response: Jurisdiction of roads is beyond the scope of the plan and plan revision process. 

However the Forest Service refers the commenter to applicable laws providing for Federal 

jurisdiction over NFS lands including the Property Clause of the U.S. Constitution (Article IV, 

section 3, clause 2), the Supremacy Clause of the U.S. Constitution (Article VI, clause 2) the 

Organic Act of 1987 (codified at 16 USC 551, et. seq.). The National Forest Roads and Trails Act 
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Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 589

of October 13, 1964, as amended (16 U.S.C. 532-538), authorizes road and trails systems for the 

national forests. Forest Service Manual 7703.3 describes the types of roads under Forest Service 

jurisdiction and those roads that may be under jurisdiction of other parties.

The plan provides direction for managing motorized roads and trails in the “Motorized 

Opportunities” section in chapter 2 and the “Motorized Uses Suitability” section in chapter 4 of 

the plan.

Concern Statement: The Forest Service has limited jurisdiction in Greenlee County as 

proved by affidavit, supporting court cases and references including: (1) Jurisdiction 

Affidavit Pertaining to Federal Jurisdiction over Areas Acquired by the United States in the 

county of Greenlee, state of Arizona, (2) 16 U.S.C 480 Civil and criminal jurisdiction, (3) 

U.S. Supreme Court, United States v. County of Fresno, 429 U.S. 452 (1977), (4) The 

Doctrine of Retroactivity and Prospectivity is being violated by the DOJ in attempting to 

enforce the Organic Act of 1897, Taylor Grazing and FLPMA upon the pre existing right of 

property., (5) Union Pacific R. Co. v. Laramie Stock Yards Co., 231 U.S. 190 (1913), (6) 16 

USC 472 - Laws affecting forest lands, (7) U.S. Supreme Court Wilcox v. Jackson, 38 U.S. 13 

Pet. 498498 (1839) ], (8) U.S. Constitution - Amendment 10, (9) 16 USC 534 - Termination 

and cancellation of easements; notice; hearing, (10) 40 USC 1314 – Easements. (119.1, 116.1, 

117.1, 118.1)

Response: Forest Service jurisdiction over federally owned lands within the National Forest 

System in Greenlee County is beyond the scope of the plan and plan revision process. However 

the Forest Service refers the commenter to applicable laws providing for Federal jurisdiction over 

NFS lands including the Property Clause of the U.S. Constitution (article IV, section 3, clause 2), 

the Supremacy Clause of the U.S. Constitution (article VI, clause 2) the Organic Act of 1897

(codified at 16 USC 551, et. seq.), the National Forest Roads and Trails Act of October 13, 1964, 

as amended (16 U.S.C. 532-538), and the legal principles of concurrent jurisdiction.

Concern Statement: National forest lands should be State forest lands. (24.7)

Response: The jurisdiction of National Forest System land is beyond the scope of the plan and 

plan revision process. Only Congress may decide what entity will manage federally owned lands 

within the National Forest System.

Concern Statement: Our national forests need to be protected. The Forest should be 

managed to emphasize ecological sustainability. The Forest Service should emphasize 

protection of biodiversity, endangered species and other animals, habitat, and old growth. 

(106.1, 15.1, 53.1, 49.1, 13.1, 85.2, 21.1, 21.2, 33.1, 60.4, 83.1, 80.1, 8.5)

Response: As noted in chapter 1, the plan provides broad guidance and information for project 

and activity decisionmaking. These protections provide a framework to sustain native ecological 

systems by managing toward desired conditions that support native plant and animal diversity. 

One of the primary focus areas, or revision topics, for the plan is “Maintenance and Improvement 

of Ecosystem Health.” As a whole, the plan provides direction that contributes to ecological, 

social, and economic sustainability. The plan provides specific direction (see the “Overall 

Ecosystem Health,” “Aquatic Habitat and Species,” “All PNVTs,” and “Wildlife and Rare Plants” 

sections) to provide for biodiversity (i.e., biological diversity) and protect endangered species and 

other animals, habitat, and old growth.
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590 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: The Forest Service should make special effort regarding the restoration 

of watersheds and ecosystem health. (146.1)

Response: See response above. In addition, as part of the focus on ecosystem health, there is a 

concerted effort to restore priority 6th level HUC watersheds (see the “Overall Ecosystem Health” 

section), and the plan contains an objective, 

“During the planning period, improve the condition class on at least 10 priority 6th level HUC 

watersheds by removing or mitigating degrading factors.”

Concern Statement: There is a need to protect our forests from deforestation and pollution. 

(60.5)

Response: The plan provides protections (see standards for the “Forests: All Forested PNVTs” 

section) to regulate timber harvests and restock trees to prevent deforestation. The plan also 

provides protections to minimize or prevent air pollution (see “Air” section) and is consistent 

with the Clean Air Act of 1972 and State of Arizona air quality standards for visibility and public 

health. 

Concern Statement: The Forest Service should protect the forests and wildlife by forbidding 

uses including: (1) logging, (2) mining, (3) drilling, and (4) road construction. (91.1, 8.1, 

89.1)

Response: Alternatives that would prohibit logging, mining, drilling, and road construction were 

considered during the development of the plan and EIS. It was determined that an alternative to 

eliminate timber harvesting would be inconsistent with legal mandates, including the Multiple 

Use-Sustained Yield Act of 1960. Each of the action alternatives contains desired conditions, 

standards, guidelines, and suitability determinations to protect forest resources when designing 

logging activities. 

It was determined that an alternative to eliminate mining and drilling would be inconsistent with 

legal mandates, including the Mining and Minerals Policy Act of 1970. In addition, the Forest 

Service does not have the discretionary authority to prevent mining of locatable minerals on 

public domain lands as prescribed by the 1872 Mining Law (as amended). Each of the action 

alternatives contain desired conditions, guidelines, and suitability determinations for minerals and 

geology related projects and activities, including surface occupancy stipulations.

An alternative to forbid road construction was also considered, however it was considered not to 

be feasible. For example, new road construction may be required when access to a particular 

resource or private inholding is needed. All of the action alternatives contain desired conditions, 

standards, guidelines, and suitability determinations that address the impacts of road construction. 

For more detail, see the “Alternatives Considered but Eliminated from Detailed Study” section in 

chapter 2 of the EIS.

Concern Statement: Forest uses that reduce water quality and quantity or degrade aquatic 

ecosystems should not be allowed. (9.9)

Response: The plan provides direction to projects and activities to eliminate or minimize impacts 

to water quality, water quantity, and aquatic ecosystems (see “Water Resources,” “Aquatic 

Habitat and Species,” and “Water Uses” sections). In addition, one of the primary focus areas, or 
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Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 591

revision topics, for the plan is “Maintenance and Improvement of Ecosystem Health,” and the 

plan contains specific objectives to improve aquatic resources (see “Overall Ecosystem Health,” 

“Aquatic Habitat and Species,” and “Riparian Areas” sections).

Concern Statement: There should be no more national monuments or national parks. (22.3)

Response: The addition of national monuments or national parks is beyond the scope of the plan 

and the plan revision process. It is not within the authority of the Forest Service to designate these 

types of areas; the authority resides with the Congress and the President.

Concern Statement: The forest should be managed for the benefit of humans including: (1) 

current and future generations, (2) provision of goods and services, (3) balance ecological 

sustainability with economic uses and social sustainability, (4) multiple use. (108.40, 138.3, 

151.8, 93.1, 93.2)

Response: The plan contributes to ecological, social, and economic sustainability focused on 

meeting the needs of the present generation without compromising the ability of future 

generations to meet their needs. The plan gives direction to manage the forest consistent with the 

Multiple Use-Sustained Yield Act of 1960 and provides goods and services including outdoor 

recreation, timber, range, watershed, wildlife, and fish. 

Concern Statement: Why does the Forest Service close areas for administrative use during 

hunting and horn hunting season but Forest Service employees are allowed behind the 

locked gates at those times? (157.2)

Response: Site specific area closures are outside the scope of the plan. Site closure orders may 

have specific exemptions pursuant to 36 CFR § 261.50(e) that allow entry by Federal, State, or 

local officer, or member of any organized rescue or fire fighting force in the performance of 

official duty.

Concern Statement: We don't know enough about how forests work and what all they do 

for us to be damaging them in the ways we are. Let them be. (72.2)

Response: A minimum management (no or minimal human intervention) alternative was 

considered but eliminated from detailed study (see chapter 2 of the EIS). If the Forest Service 

provided no management, it would not meet the legal direction of the National Forest 

Management Act or Multiple Use–Sustained Yield Act which direct that forests will be managed 

using multiple use, sustained yield principles. Active management is also needed to maintain or 

move toward desired conditions, including restoring forest ecosystems, maintaining recreation 

opportunities, reducing the threat of uncharacteristic wildfires to communities, and maintaining 

the availability of forest products.

Plan Process

Concern Statement: The DEIS considers an inadequate range of alternatives because: (1) 

the alternatives are too similar, (2) there are not enough alternatives, or (3) the alternatives 

do not address the purpose and need or issues. (127.45, 108.13, 108.12, 125.16, 108.14)

Response: The DEIS evaluates a range of reasonable alternatives that were developed to address 

the significant issues raised. The alternatives differ in the way they address the issues that were 
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592 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

raised during scoping. The “Issues that Served as the Basis for Alternative Development” section 

of the DEIS describes these issues. Chapter 2 describes the alternatives developed in response to 

these issues. Forest Service National Environmental Policy Act (NEPA) regulations at 36 CFR 

§220.5(e) states, 

“no specific number of alternatives is required or prescribed.” 

It is noted in chapter 2 of the DEIS, the proposed plan (alternative B) was developed iteratively in 

a collaborative manner to address the needs for change. This is consistent with the Forest Service 

NEPA regulations at 36 CFR §220.5(e)(1) stating, 

“The responsible official may modify the proposed action and alternative(s) under 

consideration prior to issuing a draft EIS. In such cases, the responsible official may 

consider the incremental changes as alternatives considered.” 

As a result of public comments on the DEIS, an additional 8 alternatives (to the original 10 

alternatives eliminated from detailed study that were addressed in the DEIS) were considered but 

eliminated from detailed study. See the “Alternatives Considered but Eliminated from Detailed 

Study” section in chapter 2 of the EIS for rationale for how these alternatives were considered 

and addressed.

The purpose of the DEIS was achieved by evaluating different programmatic strategies (or 

alternatives) for revising the 1987 plan and disclosing the potential environmental consequences 

of those alternatives. The need for the DEIS was accomplished by providing alternatives that: 

(1) guide natural resource management activities on the forests for the next 10 to 15 years, 

(2) address public issues and the need for change as summarized in the three revision topics, and 

(3) meet the legal direction of the National Forest Management Act of 1976 and the provisions of 

the 1982 Planning Rule to revise the plan every 10 to 15 years.

Concern Statement: Remove the reference to or inclusion of lands outside the ApacheSitgreaves NFs from the scope, analysis, justification, and recommendations or change the 

name of the DEIS to demonstrate the inclusion of lands outside the Apache-Sitgreaves NFs. 

(108.4)

Response: The plan does not apply to lands outside the Apache-Sitgreaves NFs. As described at 

the beginning of chapter 1 of the plan, the “Land Management Plan for the Apache-Sitgreaves 

National Forests” covers the National Forest System (NFS) lands within the boundary of the 

Apache-Sitgreaves NFs. Plan direction only applies to the 2.1 million acres of NFS land 

administered by the Apache-Sitgreaves NFs. 

The EIS does consider activities on non-NFS ownerships to describe the potential cumulative 

environmental consequences on a particular resource. This is consistent with CEQ National 

Environmental Policy Act (NEPA) regulations 1508.7, 

“Cumulative impact is the impact on the environment which results from the incremental impact 

of the action when added to other past, present, and reasonably foreseeable future actions 

regardless of what agency (Federal or non-Federal) or person undertakes such other actions.”
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 593

Concern Statement: Explain why the decision on the land management plan is left up to one 

supervisor. (157.3)

Response: The decisionmaker for plans revised under the 1982 Planning Rule is not the forest 

supervisor, but rather the regional forester. The provisions of the 1982 Planning Rule identify one 

position as the decisionmaker for the plan, it states the, 

“Regional Forester shall review the proposed plan and the final environmental impact statement 

and either approve or disapprove the plan.” 

Concern Statement: Explain how the Forest Service can implement rules. (157.1)

Response: Congress grants agencies the authority to issue and implement rules and regulations 

through law. For example, the National Forest Management Act of 1976 (Sec. 6(g)) states,

“as soon as practicable, but not later than two years after enactment of this subsection, the 

Secretary shall in accordance with the procedures set forth in section 553 of title 5, United States 

Code, promulgate regulations, under the principles of the Multiple-Use, Sustained-Yield Act of 

1960, that set out the process for the development and revision of the land management plans, 

and the guidelines and standards prescribed by this subsection.”

Regulations are issued by federal agencies, boards, or commissions to explain how an agency 

intends to carry out a law. Regulations have the force and effect of law.

When an agency decides that a regulation needs to created, changed, or deleted, it goes through a 

rulemaking process which is governed by the Administrative Procedure Act (5 U.S.C. Chapter 5). 

The agency proposes a proposed rule in the Federal Register to ask the public for comments. 

After the agency considers public feedback and makes applicable changes, it then publishes a 

final rule in the Federal Register that states when the regulations will become effective and 

enforceable. For more information, see the “Office of the Federal Register’s A Guide to the 

Rulemaking Process” at 

http://www.federalregister.gov/uploads/2011/01/the_rulemaking_process.pdf. 

Concern Statement: Include a commitment to implement the mitigation strategies identified 

in the plan's Appendix A (Climate Change Trends and Apache-Sitgreaves NFs Land 

Management Planning) into the final EIS and record of decision (ROD). (159.5)

Response: The mitigation strategies identified in the plan’s appendix A are not plan decisions, 

and therefore, they are not analyzed in the EIS and are not referenced in the record of decision. 

The appendix is intended to be used as a reference for land managers and contains options that 

managers may use to respond to change. The Apache-Sitgreaves NFs is committed to taking steps 

to incorporate climate change considerations in its management and planning. For example, the 

plan does address climate change by incorporating adaptive management strategies and 

describing ecological conditions that are resilient to change, and the EIS analyzed the 

environmental consequences of climate change on forest resources.

Concern Statement: The proposed plan should be revised because it is not consistent with 

law, policy, or regulation because the Forest Service did not: (1) discuss costs or net public 

benefits, (2) prepare a variety of alternative management strategies that address alternative 

objectives and discuss associated benefits or costs, (3) establish standards and guidelines to 

meet minimum management requirements, and (4) consider an alternative and disclose how 
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594 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

"decisions based on it will or will not achieve the requirements of ... environmental laws 

and policies.” (127.52, 127.6, 162.150)

Response:

(1) Costs and net public benefits were discussed and considered within the plan, EIS, and plan 

process to provide for multiple use and sustained yield of goods and services in a way that 

maximizes long term net public benefits in an environmentally sound manner (1982 Planning 

Rule section 219.1(a)). The plan is designed to contribute to ecological, social, and economic 

sustainability. The environmental consequences, including long term net public benefits, are 

described in the resource and topic sections in chapter 3 of the EIS. The plan, EIS, and plan 

revision process meet the requirements of the provisions of the 1982 Planning Rule. For 

example:

• A summary of the Analysis of the Management Situation (AMS) is discussed in chapter 1 

of the plan. The AMS, including the “Comprehensive Evaluation Report” (Forest Service, 

2008a) and “CER Supplement” (Forest Service, 2010b), describes benchmark analysis 

and the demand and supply conditions for resources and potential management 

opportunities. In addition, the “Background” sections in the plan and the “Affected 

Environment” sections of the EIS for each resource area provide information about 

resource conditions. (1982 Planning Rule sections 219.11(a) and 219.12(e)(1))

• A broad range of reasonable alternatives was developed by the interdisciplinary team to 

provide an opportunity to maximize net public benefits. Four of those alternatives were 

analyzed in detail in the EIS. See chapter 2 in the EIS for more information about 

alternatives. (1982 Planning Rule sections 219.4(a)(1) and 219.12(f))

• The EIS estimates effects of alternatives, including benefits and costs, in the 

“Environmental Consequences” sections of chapter 3. In particular, the EIS discusses the 

expenditures, revenues, and present net values by alternative and program area in the 

“Socioeconomic Resources” section of chapter 3. (1982 Planning Rule section 

219.12(g)(3))

(2) The EIS (chapter 3) analyzed the effects (both positive and negative) of a range of reasonable 

alternatives (or management strategies) that contain varying objectives. The associated 

benefits and costs are discussed in the “Environmental Consequences” sections of chapter 3 

of the EIS.

(3) The plan provides plan decisions (desired conditions, objectives, standards, guidelines, 

suitability determinations, and a monitoring strategy) that integrate minimum management 

requirements (1982 Planning Rule section 219.27). Forestwide desired conditions, objectives, 

standards, and guidelines are located in chapter 2. Management area specific desired 

conditions, objectives, standards, and guidelines are found in chapter 3. Suitability 

determinations are located in chapter 4 and the monitoring strategy is in chapter 5. For 

example, the requirement to maintain air quality (1982 Planning Rule section 219.27(a)(12)) 

is addressed in the “Air” section of the plan with desired conditions to maintain air quality 

related values and meet state air quality standards, a guideline that requires smoke to be 

monitored during extended periods of burning, and the monitoring strategy question that asks, 
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Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 595

“are management activities contributing to desired conditions or improving air quality across the 

forests...?”

(4) Chapter 2 of the DEIS states that all four alternatives comply with applicable laws, 

regulations, and policies that meets National Environmental Policy Act (NEPA) regulations 

(40 CFR §1502.2(d)). The EIS has been corrected to explain that alternative C does not 

comply with the 2001 Roadless Area Conservation Rule. The National Environmental Policy 

Act (NEPA) allows for the consideration of alternatives that an agency may not legally 

implement but which address public concerns (40 CFR §1502.14(c)). The Forest Service 

included consideration of no IRAs and no IRA management in alternative C in response to 

public comments that requested full multiple use of IRAs.

Concern Statement: The plan should be aligned with Forest Service Manual guidance and 

direction, the Forest Service mission, and congressional expectations. (152.4, 152.1, 152.9)

Response: The plan is aligned with Forest Service Manual guidance and direction but does not 

repeat the guidance in the plan. The Forest Service mission is listed in chapter 1 of the plan and 

the plan decisions collectively contribute to sustaining the health, diversity, and productivity of 

the Nation’s forests to meet the needs of present and future generations. The plan is aligned with 

congressional expectations because it complies with applicable laws enacted by Congress.

Concern Statement: The plan should not repeat the appropriate acts, laws, regulations, or 

policies as desired conditions, standards, and/or guidelines. (152.8)

Response: During the development of the plan, the intent was not to repeat law, regulation, or

policy. Those relevant laws, regulations, or policies are listed in appendix D (“Relevant Laws, 

Regulations, Policies, and Other Sources of Information”) of the plan.

Concern Statement: The Forest Service should not conduct site specific NEPA analysis to 

classify areas (e.g., wilderness, wild and scenic rivers) as part of the plan. (152.10)

Response: The EIS is a programmatic analysis of plan alternatives and does not conduct site 

specific National Environmental Policy Act (NEPA) analysis. The plan only makes preliminary 

administrative recommendations (e.g., recommended wilderness). Congress has reserved the 

authority to make final decisions on wilderness designation and the inclusion of rivers into the 

National Wild and Scenic Rivers System. When Congress indicates a desire to act further on the 

recommendations identified in the plan, the Forest Service would initiate the site specific NEPA 

analysis for these areas following Forest Service Handbook 1909.12, chapters 70 and 80.

The plan contains plan decisions (e.g., desired conditions, standards, guidelines) that will 

maintain the character of the recommended areas until such time as Congress chooses to act on 

those recommendations.

Concern Statement: The plan should meet the intent of NFMA to be an integrated 

document addressing all the various functions that make up a forest and its operation, 

which includes range, timber, water, minerals, wildlife, and recreation. (132.5)

Response: Although the plan and EIS are organized by individual resources or uses, the 

development of the plan and EIS used an interdisciplinary process (see “List of Preparers” 

chapter in the plan and the “Preparers and Contributors” section in chapter 4 of the EIS)

considering input from a wide range of stakeholders and resource specialists with the intent of 
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596 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

providing direction for all forest natural resource management activities. Where appropriate, the 

plan contains crosswalks (“Related Plan Content” sections) to other relevant resource or use 

sections. The result is a plan and EIS that are better integrated and easier to navigate than the 

1987 plan.

Concern Statement: There is a need for a discussion of the funding necessary to implement 

the alternatives (desired conditions will not happen without adequate funding). (132.3)

Response: The “Socioeconomic Resources” section in chapter 3 of the EIS describes the program 

costs (expenditures) by alternative. The action alternatives were developed to be realistic and able 

to be implemented within anticipated future budgets (expected to be similar to current budgets). 

Chapter 1 of the plan acknowledges that objectives to achieve desired conditions are strongly 

influenced by recent trends, past experiences, and anticipated staffing levels and short term 

budgets. 

Concern Statement: The Forest Service should not have formulated a preferred alternative. 

(155.1)

Response: The CEQ National Environmental Policy Act (NEPA) regulations at 40 CFR 

§1502.14(e) requires the EIS to,

“identify the agency's preferred alternative if one or more exists, in the draft statement, and 

identify such alternative in the final statement unless another law prohibits the expression of such 

a preference.”

The preferred alternative, alternative B, was identified in the DEIS in chapter 2, “Alternatives 

Analyzed in Detail” section.

The preferred alternative was developed iteratively in a collaborative manner to address the needs 

for change identified in chapter 1. It is designed to address the demand for wildlife habitat, 

community protection, commodity outputs, and recreation opportunities with an emphasis on 

ecological restoration.

Concern Statement: There are concerns that only alternative B was mentioned in handouts, 

flyers, and during February 2013 public meetings - violating CEQ regulations at section

1502.2€. (104.5, 147.2)

Response: Handouts and flyers announcing the release of the proposed plan and DEIS referenced 

information about all alternatives evaluated in the DEIS. Information, including maps, of all four 

alternatives was made available at the 2013 public meetings held in Show Low (February 26), 

Springerville (February 27), and Duncan (February 28). 

Concern Statement: Explain how Forest Service personnel could legally provide input 

during the wildlife public discussion group held in 2007. (133.1)

Response: At the beginning of the revision process (2006 to 2007), two focus groups were 

assembled by interested publics to focus on the topics of wildlife and livestock grazing. 

Consistent with Federal Advisory Council Act (FACA), these groups were not managed or 

controlled by the Forest Service. However, FACA does allow Forest Service representatives to 

participate in groups to share and exchange information. 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 597

Concern Statement: The Forest Service should conduct an effective conflict resolution and 

conflict reduction process aimed not at managing potential discrepancies but at resolving 

potential discrepancies between the plan and county objectives, plans, and policies. 

(161.122)

Response: The Apache-Sitgreaves NFs has encouraged collaborative input on the development of 

the plan and is committed to working with counties and other parties as the plan is implemented. 

It is important to obtain collaborative input in the design and accomplishment of projects and 

activities.

The development of an effective conflict resolution or conflict reduction is beyond the scope of 

the plan. The decision on the plan is subject to a post-decision administrative review. The county 

or other parties may file an appeal if there are unresolved conflicts between the final plan and 

county objectives, plans, and policies.

Appendix C (“Coordination with Other Public Planning Efforts”) in the EIS crosswalks the 

objectives of the plan with county plans and other state, local, and tribal plans. The appendix 

highlights consistencies, potential discrepancies, and provides recommendations for resolving 

inconsistencies. The appendix concludes by acknowledging that other landowners and land 

policies have the potential to impact the Apache-Sitgreaves NFs and vice-versa. The seven county 

objectives: (1) rangelands resources management, (2) forest products resources management, (3) 

mineral and energy resources management, (4) motorized travel and recreation management, (5) 

forested ecosystems restoration and catastrophic wildfire prevention, (6) watersheds restoration, 

and (7) management areas designation are similar to the topics identified in the need for change 

(chapter 1 of the EIS) and are addressed throughout the plan.

Plan and EIS - General

Concern Statement: Update the plan and EIS to make them easier to read and understand 

by: (1) clarifying terminology and using clear and plain language, (2) adding an index of 

acronyms, (3) reducing the length, (4) correcting inconsistencies, grammar, and 

punctuation, (5) providing hyperlinks to downloadable information, and (6) reformatting to 

streamline presentation. (147.1, 152.15, 152.16, 152.7, 99.22, 99.41, 109.2, 108.44, 108.212, 

99.43, 104.3, 102.49, 108.9, 102.9, 108.10, 108.153, 108.173, 108.180, 108.2, 108.3)

Response: The plan and EIS have been updated to make them easier to read and understand. In 

particular, new definitions have been added to the glossary and some text has been rewritten to 

clarify information, an index of acronyms has been added to both the plan and EIS, and factual 

and grammatical errors have been corrected. The length of the document was not reduced; it has 

actually increased with the addition of this appendix. Additional hyperlinks to downloadable 

information were not added because those links may change over time. The interdisciplinary team 

discussed other options for reformatting the plan (streamlining the presentation); however, no 

preferable options were identified.

Concern Statement: Identify the differences between the printed and electronic (.pdf) 

version of the proposed plan. (108.91)

Response: The printed and electronic (.pdf available on the forests’ Web site) versions of the plan 

are the same. However, when first posted to the Web site in January 2013, the individual 
Appendix A

598 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

segments (e.g., chapter 1, chapter 2, etc.) of the electronic versions had incorrect page numbers. 

Once the issue was identified, the page numbers were corrected and the documents were reposted to the Web site.

Concern Statement: Within the plan, describe how the standards and guidelines addressed 

under forest or range management practices are used in meeting desired conditions or 

objectives (e.g., how livestock grazing standards meet a vegetation type's desired 

conditions). (112.1)

Response: Standards and guidelines provide the sideboards or constraints for designing projects 

and activities; those projects and activities help maintain or move towards desired conditions. 

To reduce redundancy in the plan, every standard and guideline is not necessarily repeated under 

every resource or uses section where those standards and guidelines contribute to desired 

conditions or objectives. Standards and guidelines under one section (i.e., the livestock grazing 

guideline “to minimize potential resource impacts from livestock, salt or nutritional supplements 

should not be placed within a quarter of a mile of any riparian area or water source”) may 

contribute to desired conditions of a resource located in another section of the plan (i.e., riparian 

area, water resources). Each resource or use section of the plan contains a “Related Plan Content”

section that points the reader to other pertinent areas of the plan. 

Concern Statement: Explain how improvements to the land will actually happen on the 

ground when the plan does not provide a specific date for achieving desired conditions. 

(122.6, 122.5, 152.5, 152.3, 132.2, 122.13, 152.2)

Response: Desired conditions set forth the social, economic, and ecological attributes of the 

Apache-Sitgreaves NFs. Specific dates for achievement are not defined, as noted in chapter 1 of 

the plan, because some desired conditions may only be achievable over a long timeframe (in 

some cases, several hundred years). The plan does identify objectives to be completed within the 

planning period. Objectives are concise, time-specific statements of measurable planned results 

that make progress toward or maintain desired conditions. In addition, biennial evaluations of 

monitoring information will identify if improvements to the land actually happen on the ground.

Concern Statement: Concern that standards from the 1987 plan have been removed or 

replaced with unenforceable guidelines. The plan should contain stronger binding standards 

and guidelines. There is a concern that the plan relies too heavily on desired conditions 

(aspirations) and that standards and guidelines are discretionary (meaning the Forest 

Service may disregard them in project design and implementation). (26.52, 26.5, 26.17, 

26.54, 26.136, 26.134, 26.12, 23.8, 5.2, 23.3, 23.2, 26.11, 26.63, 26.9, 26.97, 5.19, 9.1, 9.11, 9.2, 

94.1, 94.14, 23.1, 127.16, 3.1, 127.20, 26.22, 26.36, 10.1, 101.22, 102.14, 11.2, 112.12, 127.14, 

127.26, 127.15, 20.1, 127.11, 127.12, 127.47, 127.8, 14.1, 14.8, 154.1, 156.1, 16.1, 162.10, 

162.11, 162.12, 162.13, 162.37, 26.76, 127.23)

Response: Many of the 1987 plan standards and guidelines not carried forward into the plan 

duplicated law, regulation, or policy; the intent was not to repeat law, regulation, or policy in the 

plan. Where appropriate, 1987 plan standards and guidelines were retained, reworded, or 

reframed in the form of desired conditions, objectives, standards, or guidelines. 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 599

Desired conditions are not just aspirations. To be consistent with the plan, projects and activities 

must be designed to maintain, move towards, or be neutral to desired conditions as described in 

chapter 1 of the plan.

In addition, chapter 1 of the plan explains that standards and guidelines are not discretionary. 

Standards are constraints upon project and activity decisionmaking. A project or activity must be 

consistent with all standards applicable to the type of project or activity and its location in the 

plan area. A project or activity is consistent with a standard in only one way; it is designed in 

exact accord with the standard. Variance from a standard is not allowed except by plan 

amendment. A project or activity must be consistent with all guidelines applicable to the type of 

project or activity and its location in the plan area. A project or activity is consistent with a 

guideline in either of two ways: (1) it is designed exactly in accord with the guideline; or (2) it 

varies from the exact words of the guideline, but it is as effective in meeting the purpose of the 

guideline to contribute to the maintenance or attainment of the relevant desired conditions and 

objectives. Guidelines must be followed, but they may be modified for a specific project if the 

intent of the guideline is followed and the deviation is addressed in a decision document with 

supporting rationale. However, when deviation from a guideline does not meet the original intent, 

a plan amendment is required.

Finally, in response to this concern, the Forest Service has prepared a “Crosswalk between 

Apache-Sitgreaves 1987 Forest Plan (as amended) and the Revised Forest Plan,” which has been 

appended to the Final EIS as appendix I. This appendix, while not an exhaustive account of all 

plan direction, tracks plan elements relevant to issues that drove the plan revision process, and/or 

were highlighted in appendix A (Response to Comments). 

Concern Statement: The Forest Service should analyze how the proposed plan's standards 

and guidelines are different from the 1987 plan's and how those differences may affect 

forest resources (e.g., Mexican spotted owl, northern goshawk, riparian). (26.7, 26.53, 

162.28, 26.77, 26.55, 26.50, 26.108, 162.35, 162.27, 127.9, 127.3, 127.27, 127.21, 127.2, 127.13, 

127.10, 26.183, 26.172, 162.24, 26.92)

Response: There are no requirements in the provisions of the 1982 Planning Rule to analyze the 

effects of differences to specific standards and guidelines. The EIS analyzes the effects of the plan 

decisions collectively, not each individual plan decision. Alternative A represents the 1987 plan 

including its standards and guidelines and is analyzed in the EIS along with alternative B (the 

proposed plan), alternative C, and alternative D. Therefore, the effects of changing the 1987 plan 

(alternative A) to one of the action alternatives (alternatives B, C, D) have been analyzed in the 

EIS. The effects to forest resources from the four alternatives are presented throughout chapter 3 

of the EIS in the “Environmental Consequences” sections. 

Concern Statement: Desired conditions should be achievable and based on science. (139.7, 

152.6, 152.19, 102.8, 138.2)

Response: Desired conditions, like the rest of the plan, were developed to be realistic and 

achievable. Desired conditions are based upon the best available science where applicable. 

Desired conditions also reflect the desires of people, what they want the forests to look like or the 

goods and services they want provided.

Concern Statement: Desired conditions should meet the need of the public. (147.9, 152.18)
Appendix A

600 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Response: Desired conditions paint a picture of what we (the public and Forest Service) desire 

the forests to look like or the goods and services we desire them to provide. The ApacheSitgreaves NFs used a collaborative process to develop the plan’s desired conditions in order to 

reflect the need and desire of the public. The public involvement process, including the 

development of plan decisions, is outlined in chapter 1 of the EIS.

Concern Statement: If observable on-the-ground conditions differ from plan guidelines or 

desired conditions, would this be a violation of the plan? (139.5) 

Response: Chapter 1 of the plan describes the criteria that must be met for a project or activity to 

be consistent with the plan. To be consistent with the plan, projects and activities must be 

designed to maintain, move towards, or be neutral to desired conditions. Projects and activities 

must also be designed in accord with the exact wording or intent of a guideline. 

The outcome of a desired condition or guideline may or may not be achieved immediately with 

project or activity implementation. The plan’s monitoring strategy is designed to evaluate the 

effectiveness of plan decisions. If there is no on-the-ground movement towards or attainment of 

desired conditions, the responsible official may choose to amend or revise the plan.

Concern Statement: Concern that areas may not have the potential to meet desired 

conditions because of site characteristics or changing climate. (138.39, 138.4, 138.41, 138.42)

Response: It is recognized that plan decisions (including desired conditions) may not apply in 

every site specific location due to variability in site characteristics. The proposed plan was 

modified in chapter 1 and the introduction of chapters 2 and 3 to make it clear that,

“plan decisions apply to projects or activities where site conditions provide an inherent 

capability to meet those decisions.” 

The plan describes ecological desired conditions that are resilient to a changing climate.

Concern Statement: Consider removing the guideline, “constructed features should be 

maintained to standard or removed when no longer needed" in the “Wildlife and Rare 

Plants” and “Overall Recreation” sections. Hundreds of features are not maintained to 

standard and will not be maintained any time soon. (99.3)

Response: The guideline has not been removed, but it has been modified to clarify the intent of 

the guidance. It now reads,

“Constructed features should be maintained to support the purpose(s) for which they were built. 

Constructed features should be removed when no longer needed.”

Concern Statement: Convert the guideline, “constructed features should be maintained to 

standard or removed when no longer needed" in the “Special Uses” section to a standard. 

(99.8)

Response: This guideline has been modified to clarify the intent of the guidance (see response 

above). Guidelines are non-discretionary, but they would allow the project or activity design to 

deviate from the exact words of the guideline, as long as it is effective in meeting the purpose of 

the guideline to contribute to the maintenance and attainment of the relevant desired conditions 

and objectives. 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 601

Concern Statement: The DEIS and proposed plan should be revised and a second DEIS 

released for public comment prior to a final. (127.51)

Response: A second DEIS was not released. The Apache-Sitgreaves NFs followed the public 

participation requirements outlined in the National Environmental Policy Act, National Forest 

Management Act, and provisions of the 1982 Planning Rule to develop the proposed plan and 

DEIS and make them available for review during a 90-day public comment period. Public 

comments submitted were analyzed by the Forest Service and adjustments were made to the plan 

and EIS based on this input. The adjustments were not substantial enough to merit publication of 

a second DEIS.

Alternatives

Concern Statement: Some commenters supported or rejected all or portions of alternative A

(1987 plan). (161.85, 104.2, 153.5)

Concern Statement: Some commenters supported or rejected all or portions of alternative B

(proposed plan). (161.90, 162.55, 161.9, 161.77, 161.67, 161.51, 161.33, 159.3, 146.2, 128.7, 

128.1, 109.3)

Concern Statement: Some commenters supported or rejected all or portions of alternative 

C. (161.95, 86.1, 87.1, 42.4, 161.79, 161.87, 160.1, 113.2, 91.2)

Concern Statement: Commenters supported or rejected all or portions of alternative D. 

(162.58, 39.7, 33.9, 33.7, 162.63, 162.160, 162.153, 115.4, 162.127, 162.59, 124.8, 33.2, 140.4, 

33.4, 161.28, 161.80)

Response: All four alternatives are described in chapter 2 and analyzed in chapter 3 of the EIS. 

Rationale for the selection of alternative B and the final plan are described in the record of 

decision document.

Concern Statement: Alternative A cannot be labeled the "no action" alternative because the 

map is inconsistent with the 1987 plan (displays wild and scenic rivers and wilderness, does 

not display all roads). (104.1, 147.4, 147.6)

Response: The map of alternative A (no action alternative) displayed in appendix J (“Maps”) of 

the EIS does represent the 1987 plan’s management areas. The map in the DEIS was created from 

the forests’ GIS data which was developed directly from the 1987 plan’s Forest Management 

Areas Index Map published in August 1987.

The alternative A map displays major roads consistent with other alternative maps in this 

appendix. The map displays the wilderness areas as identified in the 1987 plan. The map does not 

display the eligible and suitable wild and scenic rivers. Eligible and suitable wild and scenic 

rivers occur in all alternatives, although the eligibility of these rivers and the suitability of two 

rivers were determined after the approval of the 1987 plan. More information can be found in the 

“Eligibility Report for the National Wild and Scenic River System” (Forest Service, 2009b) and 

the “Final Environmental Assessment for Blue River and KP Creek Wild and Scenic River 

Suitability Study” (Forest Service, 2010a) in the plan set of documents and on the forests’ Web 

site at http://www.fs.usda.gov/main/asnf/landmanagement/planning.
Appendix A

602 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: The Forest Service should discuss the successes and failures of the 1987 

plan to determine what management actions will succeed in the future. (127.32, 26.127, 

26.126, 147.3, 132.1, 127.31, 127.28, 127.19, 127.18, 162.165, 132.4)

Response: See the “Summary of the Analysis of the Management Situation” section in chapter 1 

of the plan. The Analysis of the Management Situation includes the “Comprehensive Evaluation 

Report” (Forest Service, 2008a) that described how the 1987 plan does not provide adequate 

management guidance for the present and future, and identified where the conditions and trends 

indicate a need for change from the 1987 plan. 

Concern Statement: The Forest Service should not rely on monitoring to drive future 

actions when monitoring does not always occur. (127.30)

Response: The provisions of the 1982 Planning Rule (section 219.7(f)) require that monitoring 

and evaluation be conducted. The monitoring strategy reflects the Apache-Sitgreaves NFs’ intent 

which is based on an assumption of recent and relatively stable budgets. Within that context, the 

forest is committed to integrating monitoring with its management decisions as discussed in 

chapter 5 of the plan. By focusing on effective monitoring and movement toward desired 

conditions, the Apache-Sitgreaves NFs will be able to better assess future actions. If funding is 

significantly decreased, it is expected that both monitoring and implementation would be less 

than what is planned. 

Concern Statement: Alternative C should not be considered because it violates the Roadless 

Area Conservation Rule by removing protections for inventoried roadless areas. (33.15, 

58.1, 55.1, 54.1, 52.1, 51.1, 39.4, 39.2, 39.1, 59.1, 33.16, 67.4, 33.14, 33.10, 31.2, 29.2, 37.1, 

76.2, 39.5, 92.4, 85.1, 84.1, 82.5, 82.1, 65.1, 77.1, 63.1, 75.1, 73.1, 71.1, 68.2, 67.5, 162.152, 

65.4, 78.1, 115.3, 125.15, 125.14, 162.149, 125.12, 31.1, 125.1, 125.17, 124.1, 125.13, 115.2, 

108.15, 107.4, 125.4, 69.11, 91.3, 39.3, 124.7, 126.6, 162.128, 158.1, 125.11, 140.1, 125.18, 

126.4, 126.3, 126.2, 125.19, 125.8, 125.7, 125.5, 125.24, 125.22, 125.20, 126.1, 140.2)

Response: Alternative C is still considered a valid alternative in the EIS. The Forest Service 

included consideration of no IRAs and no IRA management in alternative C in response to public 

comments that requested full multiple use of IRAs. The National Environmental Policy Act

(NEPA) allows for the consideration of alternatives that an agency may not legally implement but 

which address public concerns (40 CFR 1502.14(c)). While alternative C was properly developed 

and analyzed in conformance with NEPA requirements, it was not ultimately selected as the 

revised Apache-Sitgreaves NFs’ plan, in part, due to its being in violation of the 2001 Roadless 

Area Conservation Rule (RACR).

Concern Statement: Explain why the DEIS evaluates an alternative that conflicts directly 

with the National Roadless Conservation Rule but will not consider in detail other 

alternatives because those alternatives would not be consistent with the law (e.g., an 

alternative that would eliminate timber harvesting). (125.9)

Response: Unlike other alternatives that were considered but eliminated from detailed study, the 

responsible official decided to include consideration of no IRAs and no IRA management as an 

alternative (alternative C) in the EIS in response to public comments. 

During the forest plan revision process, there were two conflicting legal decisions concerning the 

status of IRAs. The District of Wyoming ruled that the 2001 Roadless Area Conservation Rule 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 603

(RACR) was invalid and issued a nationwide injunction precluding its application. However in 

2009, the 9th Circuit Court of Appeals affirmed a 2006 Northern District of California ruling that 

reinstated the 2001 RACR in the 9th Circuit (includes Arizona) and New Mexico. The alternatives 

considered in the EIS were initially developed during this time of uncertainty. One aspect of 

alternative C was designed to address public concerns that wanted full multiple use for those 

lands that had been designated as an IRA. 

In October 2011, the 10th Circuit Court of Appeals reversed the District Court of Wyoming’s 2008 

decision and reinstated the 2001 RACR nationwide. Because there was continued public concern 

(both for and against the continued management of IRAs), the responsible official decided to 

continue the analysis of alternative C as originally designed. Under all other alternatives, IRAs 

would continue to be managed in compliance with RACR. The EIS discloses the environmental 

consequences of managing IRAs consistent with RACR, as well as the environmental 

consequences if they were managed differently (see the Inventoried Roadless Areas section in 

chapter 3).

The National Environmental Policy Act (NEPA) does allow the consideration of alternatives that 

may not be legal but address public concerns (40 CFR 1502.14(c)). The responsible official did 

consider other alternatives that may not meet legal mandates but chose not to analyze them in 

detail. The “Alternatives Considered but Eliminated from Detailed Study” section in chapter 2 of 

the EIS provides information about those alternatives and the rationale for not analyzing them in 

detail.

Concern Statement: Explain the specific legal requirements of NFMA and MUSYA that 

state the forest must have domestic livestock use no matter what the current conditions or 

pending impacts to the ecosystem. (132.7)

Response: The “Alternatives Considered but Eliminated from Detailed Study” section in chapter 

1 of the EIS states,

“A no grazing alternative would not meet the legal direction of the National Forest Management 

Act or Multiple Use–Sustained Yield Act which direct that forests will be managed using multiple 

use, sustained yield principles.”

The Multiple Use-Sustained-Yield Act (MUSYA) of 1960 (section 1) states that,

“the national forests are established and shall be administered for outdoor recreation, range, 

timber, watershed, and wildlife and fish purposes.”

The National Forest Management Act (NFMA) (section 6(e)(1)) states that in revising plans,

“provide for multiple use and sustained yield of the products and services obtained therefrom in 

accordance with the Multiple-Use, Sustained-Yield Act of 1960, and in particular, include 

coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and 

wilderness...”

The forests are managed for range (livestock grazing) consistent with NFMA and MUSYA. These 

laws do not require livestock grazing when/where ecological conditions are not appropriate. The 

plan is designed to manage for ecological desired conditions, as well as social and economic 

desired conditions (including uses such as livestock grazing, harvest of forest products, and 

recreation).
Appendix A

604 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Suggest the selected alternative include: (1) provisions of alternative B 

- up to 25,000 acres per year treated of grasslands; (2) provisions of alternative C - to 

increase the number of acres logged annually to accelerate the pace of ecological 

restoration; increase the amount of forest byproducts resources by prioritizing mechanical 

thinning treatments over fire as a thinning tool; and increase the maximum allowable sale 

quantity (ASQ) volume to 268,000 CCF (hundred cubic feet) per year to meet the 

foreseeable requirements of the existing and currently developing industry in the White 

Mountains; (3) provisions of alternative C - retain the suitability of 80 percent of the lands 

of the Apache-Sitgreaves NFs for future consideration of new motorized areas and trails; (4) 

provisions of alternative C - forested ecosystems restoration and catastrophic wildfire 

prevention treatment types, scale, pace and prioritization; (5) provisions of alternative C -

watersheds restoration objectives; (6) provisions of alternatives B and C - designation of 

management areas as follows: Community Forest Intermix: approximately 61,000 acres (3 

percent); High Use Developed Recreation Area: approximately 17,000 acres (1 percent); 

Energy Corridor: approximately 2,500 acres (<1 percent); Wild Horse Territory: 

approximately 19,000 acres (1 percent); Wildlife Quiet Area: approximately 50,000 acres (2 

percent); Research Natural Area: approximately 8,000 acres (<1 percent); Primitive Area: 

approximately 200,000 acres (10 percent); and existing Wilderness: approximately 23,000 (1 

percent); (7) removing the proposed Research Natural Areas from suitable rangelands for 

the specific purpose of quantifying and improving the understanding of the rangelands 

resources ecosystem processes and how they relate to improved management practices; (8) 

guidelines for a rangelands resources adaptive management plan that provides clear 

quantitative, qualitative and effectiveness monitoring requirements, and a more balanced 

approach between the goal of restoration and the goal of economic production, as the need 

for restoration in rangelands may not carry the same clear and present benefits as 

restoration in forestlands; (9) alternatively include a specific plan under conventional 

management to reach full utilization of the available animal unit months and to result in the 

full economic impact of approximately 120 jobs and $1.3 million in labor income annually; 

(10) the necessary analysis, and the resulting authority for the responsible official to 

simultaneously implement a restoration program designed to support the existing and 

currently developing industry in the White Mountains, and the contract(s) expected to 

result from the second analysis of the Four Forest Restoration Initiative, including a 

maximum allowable sale quantity (ASQ) volume of 450,000 CCF annually; (11) guidance 

for the upcoming implementation of the national Travel Management Rule and for 

authorized cross-country travel, in order to simultaneously achieve the required 

preservation and conservation objectives and allow reasonable motorized access, travel and 

recreation for dispersed camping, big game retrieval, firewood collection and dispersed 

shooting as outlined in the above comments and the Navajo County Motorized Travel and 

Recreation Management Objectives; (12) guidelines to integrate the provisions of the Four 

Forest Restoration Initiative stakeholders-approved document Old Growth Protection and 

Large Tree Retention Strategy (OGPLTRS) to allow mechanical treatments to proceed 

without using 16-inch diameter caps, while retaining the social license necessary for an 

expeditious, non-conflictual and non-litigious implementation of landscape scale 

restoration; (13) a comparative analysis of prioritization of the 10 priority watersheds 

designated under alternatives, B, C and D, if they are different and have higher or lower 

priority levels as compared to each other; (14) include a revised analysis differentiating 

more clearly between degrading factors and the effects of degrading factors on watersheds 

physical and biological characteristics and processes that affect the hydrologic and soil 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 605

functions, and between natural processes and management effects; (15) specific information 

on the potential location of the proposed 405,000 acres of Natural Landscape Areas under 

alternative B; (16) specific information on the rationale supporting the proposed 

elimination of the existing 322,000 acres of Inventoried Roadless Areas (IRAs) under 

alternative C, (17) the requirements for a quantitative, qualitative and effectiveness 

monitoring strategy, a very specific monitoring implementation plan, and a specific 

monitoring budget, required resources allocation and funding, to the planning and NEPA 

review process of all management projects, to be submitted to public review and comments 

in the draft environmental impact statements (DEIS), to be included in the records of 

decisions (ROD) and to be included in the final environmental impact statements (FEIS) of 

all management projects, in order to insure that monitoring will actually be implemented 

and funded; (18) the responsible officials to be bound by the findings of multi-party 

monitoring boards and to act upon the findings of a multi-party monitoring boards in a 

manner that appropriately addresses the issues raised by the multi-party monitoring 

boards; (19) a fourth phase that outlines clearly the responsibility and authority of 

responsible officials to implement adaptive and if necessary corrective management action 

during the implementation of large scale long duration specific projects as a response to the 

quantitative, qualitative, and effectiveness monitoring of the project, in addition to the three 

phases of planning (assessment, planning, and monitoring) identified in Title 36, Code of 

Federal Regulations, part 219 (36 CFR part 219) and designed to support a framework for 

adaptive management; (20) guidelines to responsible officials to integrate social and 

economic sustainability and social and economic science into the framework of best 

available scientific information to inform their land management planning process and their 

management decisionmaking process; (21) guidelines to responsible officials to implement 

substantive - even though possibly scientifically imperfect - management actions that move 

the ecosystems significantly toward the desired future conditions, when such actions are 

supported by social consensus, rather than spend years attempting to forcibly impose, and 

possibly trigger litigation of management actions that may be deemed scientifically more 

perfect but that do not benefit from the support of the social consensus; (22) an emphasis on 

executing well less than perfect projects now, over developing scientifically perfect projects 

that are never implemented; (23) an emphasis on allowing the public to participate 

meaningfully in, influence substantially, and when appropriate alter the content of the 

decision of responsible officials while they retain their statutory decisionmaking authority; 

(24) a special forum for local government elected officials such as county supervisors to 

represent the socioeconomic interests of the local residents in the decisionmaking process of 

the Forest Service responsible officials, (25) guidelines to reviewing officers to exercise 

careful judgment in their resolution or rejection of objections, in relation to the true 

material importance of the objections – as opposed to their symbolic or emotional 

importance, and the potential effect of litigation on the implementation of the project. 

(161.19, 161.43, 161.83, 161.82, 161.81, 161.20, 161.150, 161.168, 161.42)

Response: This alternative was considered but eliminated from detail study. See the “Alternatives 

Considered but Eliminated from Detailed Study” section in chapter 2 of the EIS under the 

“Alternative Proposed by Counties” header. Several of the counties’ recommendations (1, 2, 3, 4, 

5, and 6) are analyzed as alternatives B and C in chapter 2 and 3 of the EIS. 

Recommendation 7 is consistent with the plan where research natural areas are considered to be 

not suitable for livestock grazing. The specific purposes or types of research to be conducted have 
Appendix A

606 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

not been decided. The backgrounds in the “Research Natural Areas” and “Recommended 

Research Natural Areas” sections in chapter 3 of the plan identify potential opportunities for 

research. The recommended Lower Campbell Blue and Sandrock RNA specifically mention the 

possibility of using these research natural areas to study rangeland-related topics.

The plan provides a monitoring strategy in chapter 5 that outlines the general framework for 

achieving plan monitoring and informing adaptive management. A specific rangelands resources 

adaptive management plan (recommendation 8) is beyond the scope of the plan and would be 

developed at the project-level. The plan contains a guideline in the “All PNVTs” section that,

“Project plans should include quantitative and/or qualitative objectives for implementation 

monitoring and effectiveness monitoring to assist in moving toward or maintaining desired 

conditions.” 

Desired conditions include ecological, social, and economic aspects.

A plan to reach full utilization of available unit months (recommendation 9) is beyond the scope 

of the plan. Available unit months fluctuate from year-to-year based on site specific resource 

conditions, weather, and livestock operations. Stocking decisions (amount of livestock grazing 

authorized) for specific grazing allotments are beyond the scope of this analysis. Grazing is 

authorized through term grazing permits (i.e., a long term authorization subject to forestwide 

standards and guidelines), allotment management plans, and annual operating instructions. 

Changes to these authorizations would be made through project-level analyses.

The plan does not authorize or mandate any site specific projects or activities; therefore it cannot 

authorize the implementation of restoration projects, including the Four Forest Restoration 

Initiative (4-FRI) (recommendation 10). The plan does set the framework for these restoration 

projects by describing desired conditions for ecological components that are resilient to 

disturbance and setting treatment objectives in forested, woodland, grassland, and riparian 

vegetation.

The plan contains standards and guidelines for limiting motorized travel to designated roads, 

trails, and areas and sets the framework for implementing the Travel Management Rule (36 CFR 

§212). However, the responsible official has decided not to address the issues of motorized big 

game retrieval, dispersed camping, firewood collection, and dispersed shooting in the plan 

(recommendation 11); they will be addressed during the planning process for the implementation 

of the Travel Management Rule.

The plan’s interdisciplinary team considered the “Old Growth Protection Large Tree Retention 

Strategy” (OGPLTRS) (recommendation 12) in its entirety, but recommended that it not be 

analyzed in detail. See the “Alternatives Considered but Eliminated from Detailed Study” section 

in chapter 2 of the EIS. Additionally, see the response to comment #26.118 in the “Vegetation” 

section of this appendix.

The plan does not specify a specific implementation schedule for improving the condition class in 

priority watersheds. Therefore, there is no need for a comparative analysis in the EIS of 

prioritization of the 10 priority watersheds (recommendation 13).

The “Watershed” section in chapter 3 of the EIS was updated based on the recommendation to 

clarify degrading factors on watershed characteristics and processes (recommendation 14). The 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 607

locations of the approximate 405,000 acres of Natural Landscape Management Area can be found 

in appendix F (“Maps”) of the plan (recommendation 15).

The rationale (recommendation 16) for considering alternative management for Inventoried 

Roadless Areas (IRAs) is described in the response for comment # 33.15 in the “Alternatives” 

section of this appendix.

Responses to recommendations 17 to 25 can be found in the response for comment #161.100 in 

the “Monitoring” section of this appendix.

Concern Statement: An alternative should focus on managing forests for biological diversity 

and at-risk species by providing a substantial increase in protection for plant and animal 

species to address scientific uncertainty and controversy regarding climate change impacts. 

Err on the side of ecological caution (a “no-regrets strategy”) by managing the national 

forests as a safe harbor and refuge for fish and wildlife, even at the expense of competing 

multiple use activities. (26.96, 162.45, 3.16, 9.12, 9.10, 5.11, 33.11, 3.5, 162.164, 26.94, 26.93, 

26.132, 26.128, 162.9, 23.11, 26.95)

Response: This alternative was considered but eliminated from detail study. See the “Alternatives 

Considered but Eliminated from Detailed Study” section in chapter 2 of the EIS under the 

“Alternative that Emphasizes Biodiversity” header. The alternative was not considered in detail 

because, by focusing solely on biodiversity (i.e., biological diversity) over other uses, it would 

not meet the legal direction of the National Forest Management Act or Multiple Use–Sustained 

Yield Act which direct that forests will be managed using multiple use, sustained yield principles.

Also, in light of changes predicted by current climate models (e.g., increased wildfires, greater 

vulnerability to invasive species, changes in timing of precipitation), there is a need to reduce 

vulnerability by maintaining and restoring resilient native ecosystems which would be an 

outcome in alternatives B, D, C, and A (in order from greatest resilience to least). Management 

practices that sustain healthy plant and animal communities (e.g., thinning for age class diversity 

and structure, reclaiming and restoring native grasslands) promote resilience and reduce 

opportunities for disturbance and damage.

As identified in chapter 1 of the plan, one of the primary focus areas, or revision topics, for the 

plan is “Maintenance and Improvement of Ecosystem Health.” The plan provides specific 

direction (see the “Overall Ecosystem Health,” “Aquatic Habitat and Species,” “All PNVTs,” and 

“Wildlife and Rare Plants” sections) to provide for biodiversity and protect endangered species, 

other animals, and habitat. The plan provides for the viability of all terrestrial and aquatic species. 

Climate change is addressed throughout the plan; indirectly through desired conditions in the 

form of functional ecosystems and resilient landscapes, and directly in management approaches 

and the monitoring strategy, where appropriate. Appendix A (“Climate Change Trends and 

Apache-Sitgreaves NFs Land Management Planning”) in the plan provides a comprehensive 

discussion of climate change trends and Apache-Sitgreaves land management planning.

Concern Statement: One alternative should maximize long term vegetative health through a 

conservative strategy toward grazing that minimizes the damage of livestock grazing and 

maximizes the retention of water and forage for wildlife. (127.46)

Response: This alternative was considered but eliminated from detail study. See the “Alternatives 

Considered but Eliminated from Detailed Study” section in chapter 2 of the EIS under the 

“Alternative with Different Livestock Grazing Management” header. 
Appendix A

608 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

The plan’s primary desired condition for livestock grazing is to “balance livestock grazing with 

available forage” on suitable grazing lands. Stocking decisions (amount of livestock grazing 

authorized) are authorized through term grazing permits (a long term authorization subject to 

forestwide standards and guidelines), allotment management plans, and annual operating 

instructions. Changes to these authorizations would be made through project-level analyses.

The plan provides direction for healthy and resilient vegetation, riparian, and water resources 

conditions in the short and long term. Therefore, the plan provides the framework for livestock 

stocking decisions that would provide for the health of vegetation and retention of water and 

forage for wildlife because those decisions must be consistent with applicable plan direction.

Concern Statement: A stand-alone alternative should: (1) implement existing standards and 

guidelines, (2) forbid new road construction in protected activity centers (PACs), (3) 

incorporate fuel treatment concepts to minimize risk of stand-replacing fire in PACs 

including large tree retention, management of surface fuels and sub-canopy forest structure, 

and spatial orientation of treatments, and (4) apply fuel treatment modeling in Mexican 

spotted owl habitat conducted by Northern Arizona University Forest Ecosystem 

Restoration Analysis. (26.58, 26.177)

Response: This alternative was considered but eliminated from detail study. See the “Alternatives 

Considered but Eliminated from Detailed Study” section in chapter 2 of the EIS under the 

“Alternative to Compare Viability for the Mexican Spotted Owl” header.

The implementation of 1987 plan standards and guidelines is considered in the analysis of 

alternative A in the EIS. The plan provides direction that projects and activities would be 

managed consistent with the Mexican spotted owl recovery plan, including constraints on road 

construction and fuel treatments. 

Methodologies for fuel treatment modeling would be determined by the responsible official on a 

site specific basis. The Northern Arizona University Forest Ecosystem Restoration Analysis may 

be used if determined applicable.

Concern Statement: There should be an alternative that maximizes timber sales, volumes 

offered for sale, the use of mechanical equipment, prescribed fire, and natural fires to 

accomplish the needed work. The acreage of planned fire, prescribed and natural fire use, 

needs to be expanded dramatically. Accomplishments averaging 100,000+ acres per year are 

achievable. (98.19, 98.21)

Response: This alternative was considered but eliminated from detail study. See the “Alternatives 

Considered but Eliminated from Detailed Study” section in chapter 2 of the EIS under the 

“Alternative with Maximum Treatments (Mechanical and Wildland Fire)” header. 

The action alternatives were developed to be realistic and able to be implemented within 

anticipated future budgets (expected to be similar to current budgets). Alternative C represents the 

maximum mechanical treatments, and alternative D represents the maximum burning treatments 

the forests anticipate being able to accomplish within the planning period. An alternative that 

would maximize both treatment types was not considered to be feasible based on anticipated 

future budgets.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 609

EIS - General

Concern Statement: The TES (terrestrial ecosystem survey) data should be based on 

current soil conditions. There is concern that the TES may not be achievable because it is 

based on soil conditions inventoried in the 1980s. (131.12, 138.35, 30.1, 139.1, 138.10, 

108.189, 108.36, 131.3)

Response: The “Soil” section of the plan in chapter 2 has been updated to describe the TES, 

including how it was developed. In addition, the management approaches section emphasizes the 

forests’ commitment to update the TES to reflect current conditions and concepts. 

The TES process fully integrates climate and climate variability into the sampling and 

interpretations of the description for potential plant community composition (potential natural 

vegetation type or PNVT); therefore conditions at the time of initial inventory in the 1980 did not 

skew the information. A 30-year National Oceanic and Atmospheric Administration record from a 

representative climate station/life zone is used to plot the ecological amplitude of the key species 

along an elevational gradient and employs both direct and indirect analysis to objectively assign 

the appropriate vegetation species within their inherent range; this is reported in the TES plant 

community descriptions. There are papers written (Keane, 2013; Fulé at al., 2013) that state 

historic reference conditions are still a valid baseline to understand the past and evolutionary 

history of current ecosystems presently experiencing some form of climate change. Furthermore, 

the first and only publication (Brusca et.al, 2013) that has documented the effects of climate 

change on species distribution was recently published. TES uses the same modeling techniques 

Whitaker (Whittaker and Niering, 1964) used and therefore allowing legacy climate, soil, and 

vegetation data from TES to be adaptable for any climate change scenario.

Assuming the commenter is asking whether the historic range of variation (HRV) is attainable 

during the life of the plan, the simple answer is no. The “Vegetation” section in chapter 3 of the 

EIS and the “Vegetation Specialist Report” (Forest Service, 2014g) describe in detail for each 

PNVT, based on modeling of plan objectives, where the vegetation condition may be at the end of 

the planning period. Based on modeling, the plan objectives in all cases move vegetation 

condition towards HRV.

Concern Statement: The affected environment should reflect conditions following the 

Wallow Fire. (122.8)

Response: The EIS does reflect conditions following the Wallow Fire. As stated in chapter 3,

“unless noted, the effects of the 2011 Wallow Fire are incorporated into the affected environment 

descriptions.”

For example, soil condition and watershed conditions were estimated based on predicted effects 

of the Wallow Fire. An estimated 28 percent of the soils within the Wallow Fire area moved from 

satisfactory condition to impaired or unsatisfactory as a result of the fire. A new table and maps 

are found in the EIS “Watershed” section reflecting post-Wallow Fire changes to watershed 

condition. Recovery rates for both are highly variable and depend on many factors, including soil 

burn severity, soil type, rainfall patterns, aspect, slope and type of burned area emergency 

treatments to name a few. Other resource areas discussed effects of Wallow throughout the 

document.
Appendix A

610 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: The DEIS should disclose the effects on the human environment, 

including impacts to social and economic values, goods, and services. (108.6, 108.8, 138.5)

Response: The EIS does disclose the effects on the human environment throughout chapter 3. In 

particular see the “Socioeconomic Resources” section for impacts to expenditures, revenues, 

social consequences, recreation, minerals, grazing, and wood products by alternative.

National Environmental Policy Act (NEPA) provides the direction for disclosing the effects on 

the human environment,

“Human environment" shall be interpreted comprehensively to include the natural and physical 

environment and the relationship of people with that environment. (See the definition of "effects" 

(Sec. 1508.8).) This means that economic or social effects are not intended by themselves to 

require preparation of an environmental impact statement. When an environmental impact 

statement is prepared and economic or social and natural or physical environmental effects are 

interrelated, then the environmental impact statement will discuss all of these effects on the 

human environment.” (40 CFR §1508.14)

Concern Statement: Remove language from the DEIS that provides an impression that the 

plan will have no direct effects. (108.79)

Response: See chapter 3 of the EIS. Because the plan does not authorize or mandate any site 

specific projects or activities (including ground-disturbing actions), there can be no direct effects. 

However, there may be implications or longer term environmental consequences of managing the 

forests under the programmatic framework of the land management plan. The plan sets the stage 

for what future management actions are needed to achieve desired outcomes (e.g., desired 

conditions, objectives, special areas) and provides the sideboards (e.g., suitability, standards, 

guidelines) under which future activities may occur in order to manage risks to ecological, social, 

and economic environments. 

To actually implement site specific projects, project and activity-level planning, environmental 

analysis, and decisions must occur. For example, the plan may contain direction to close or 

rehabilitate roads in order to benefit riparian areas; however, a subsequent site specific analysis

(including disclosure of potential effects) and decision must be made for proposals that involve 

road closures or decommissioning.

Concern Statement: Natural water sources, aspen regeneration, and grazing must be 

addressed thoroughly in the EIS. (127.34)

Response: These topics are addressed in chapter 3 of the EIS. Natural water sources (e.g., 

springs, rivers, streams, groundwater) are addressed in the “Water Resources” and “Riparian”

sections. Aspen regeneration is addressed under the “Vegetation” and “Forest Health” sections. 

Livestock grazing is addressed in several sections including “Soil,” “Watershed,” “Water 

Resources,” “Riparian,” “Fisheries,” “Wildlife and Rare Plants,” and “Livestock Grazing.”

Concern Statement: The plan and DEIS should use criteria (indicators) that can be 

measured so the public can understand and relate to what is taking place on the national 

forest. (108.11, 108.196, 108.197)
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 611

Response: Where appropriate, the plan uses science-based criteria that can be measured in the 

description of desired conditions, standards, and guidelines. For example, in the desired 

conditions for the “Forests: Ponderosa Pine” section:

“Coarse woody debris, including logs, ranges from 3 to 10 tons per acre. Logs average 3 per 

acre within the forested area of the landscape.” 

Additional criteria for project or activity design are determined by public involvement, science, 

and professional experience at the project or activity-level.

The EIS uses indicators (quantitative or qualitative measures) to describe differences between 

alternatives. Table 3 displays a comparison of indicators by alternative. These indicators are based 

on the need for change and issues for the four alternatives.

Concern Statement: Explain the implications if the assumptions in the DEIS are wrong. 

(122.11)

Response: If assumptions in the DEIS are incorrect, then the potential environmental 

consequences of alternatives may be incorrect. The results of monitoring and evaluation (see 

chapter 5 of the plan) should identify how well the land management plan is working and whether 

the purpose and direction are appropriate. If new information is acquired and change in plan 

direction is needed, the plan can be amended or revised.

Concern Statement: The Forest Service must address and disclose threats to the forests 

from climate change. (162.4, 26.90, 50.1, 162.8, 26.157)

Response: Appendix A (“Climate Change Trends and Apache-Sitgreaves NFs Land Management 

Planning”) of the plan identifies the potential climate change trends and impacts to management 

of the Apache-Sitgreaves NFs. In addition, the possible environmental consequences associated 

with climate change on applicable resources are discussed in chapter 3 of the EIS (see the 

“Climate Change” header under “Environmental Consequences” sections).

Concern Statement: The Forest Service should disclose the degree to which effects of a 

revised Forest Plan on the environment “are likely to be highly controversial” 40 CFR § 

1508.27(b)(4). (26.171)

Response: The National Environmental Policy Act (NEPA) regulation found at 40 CFR 

§1508.27(b)(4) “the degree to which the effects on the quality of the human environment are 

likely to be highly controversial” is not a requirement but one of the considerations in evaluating 

intensity. Intensity, along with context, is a consideration in defining significantly. If an agency’s 

action may be environmentally significant according to these criteria, the agency must prepare an 

EIS. The EIS addresses those controversial issues raised by the public (see the “Issues that Served 

as the Basis for Alternative Development” section in chapter 1 of the EIS).

Coordination

Concern Statement: Explain how the Forest Service complied with requirements for public 

participation, tribal, and intergovernmental coordination and review (36 CFR 219.4 (b)(2), 

36 CFR 219.6(k), 36 CFR 219.7,40 CFR 1502.16(c), 40 CFR 1506.2). (108.58, 108.51, 161.5, 
Appendix A

612 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

161.6, 161.4, 161.2, 161.121, 161.120, 108.56, 108.53, 108.52, 108.49, 108.20, 108.18, 108.16, 

108.17)

Response: The EIS at chapter 4 (“Consultation and Coordination”) and appendix C 

(“Coordination with Other Public Planning Efforts”) describe how the Forest Service met 

requirements for public participation and tribal and intergovernmental coordination.

Concern Statement: Apache County requests documentation of the Forest Service's 

rejection of the county's cooperating agency request. (108.55)

Response: In a letter dated August 16, 2013, the Forest Service provided Apache County the 

cooperating agency agreement the forests had with the County for the purpose of revising the 

land management plan. The agreement was initiated in August 2004; it expired in 2009 and was 

not renewed. In the 2013 letter, the Forest Supervisor made a determination not to reinitiate 

cooperating agency status with the County. The letter is available in the plan set of documents.

Concern Statement: Navajo, Gila, Graham, and Greenlee Counties and Eastern Arizona 

Counties Organization request cooperating agency status. (161.3)

Response: In separate letters dated August 16, 2013, the Forest Service denied Navajo, Gila, 

Graham, and Greenlee Counties and Eastern Arizona Counties Organizations request for 

cooperating agency status. It was not considered timely for the Apache-Sitgreaves NFs to grant 

cooperating agency status because the forests are in the final stages of the plan revision process. 

These letters are available in the plan set of documents.

Requests for cooperating agency status are normally considered at the beginning of the 

environmental analysis process. To qualify as a cooperating agency, an agency must be able to 

demonstrate jurisdiction by law or ability to contribute special expertise.

Air

Concern Statement: The following rules apply to reducing dust from open areas, dry washes 

or riverbeds, roadways and streets: Arizona Administrative Code R18-2-604 and R18-2-605

Arizona Administrative Code R18-2-804. (4.2)

Response: These references are now included in appendix D (“Relevant Laws, Regulations, and 

Policies”) in the plan.

Concern Statement: Portions of the Apache-Sitgreaves NFs are located in a sulfur dioxide 

(SO2) maintenance plan area. (4.3)

Response: This oversight was remedied by additions to the background portion of the “Air”

section in plan and the “Air” section in chapter 3 of the EIS. These sections have been updated to 

recognize the sulfur dioxide (SO2) maintenance plan area near Morenci.

Concern Statement: The Air background statement "smoke and visibility impairment from 

wildland fire that closely mimics what would occur naturally is generally acceptable." 

should be modified because it implies that "natural" is good and "man caused" is bad. 

Smoke is smoke. (102.53)

Response: This statement was removed from the plan.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 613

Concern Statement: Analyze and describe the potential for further reductions in air 

emissions by lessening or eliminating pile burning of residual fuels in favor of biomass 

energy production. (159.8)

Response: The plan does not prescribe a specific method (e.g., pile burning, biomass utilization) 

for treating slash (residual fuels). The plan does not set limits on pile burning, although, a range 

of mechanical treatments are provided, of which, pile burning is considered an option for treating 

residual fuel. While the plan does not prescribe specific methods (or tools) to be used, those 

specific methods would be identified by the interdisciplinary team during project or activity-level

analysis. The team would identify appropriate methods that are consistent with the programmatic 

guidance in the plan.

Biomass energy production is one way the forest is currently reducing residual fuels. The forests 

also employ air quality models that display differences in emissions based on fuel treatment 

methods at the project-level, with results reported as environmental effects of alternatives. 

Soil

Concern Statement: Explain the basis for existing and historic soil conditions and why 

returning to historic vegetation conditions would reduce the amount of impaired soils. 

(108.109)

Response: Existing soil conditions described in the plan and EIS were derived from the 

Terrestrial Ecosystem Survey (TES) for the Apache-Sitgreaves NFs. The survey provides 

information using mapping unit averages, modal sites, and representative sites to characterize 

existing conditions. Reference (historic) soil conditions were estimated using Southwestern 

Region guidance documents, which are based on best available science as well as climate data 

collected within Arizona and New Mexico.

The plan’s vegetation desired conditions are based on reference conditions. The desired 

conditions provide ground cover (herbaceous vegetation and litter) distributed across the soil 

surface. Once a desired ground cover is reached (as documented within each TES unit) the soils 

can be considered to be in satisfactory condition.

Currently, not all potential natural vegetation types (PNVTs) have large percentages of 

unsatisfactory soil conditions. Within the fire-adapted ecosystems, vegetative treatments 

including fire prescriptions that reduce canopy cover that move towards desired conditions allow 

fire to burn under low or mixed severity maintenance intensities and reduce competition for light 

and water for establishment and retention of grasses and forbs. Impaired or unsatisfactory soil 

conditions caused by the lack of effective ground cover are most prevalent in the Madrean pineoak woodland, Great Basin grassland, and semi-desert grasslands PNVTs. As overstory canopies 

are reduced to desired condition levels, it is expected that grasses and forbs will replace bare soil.

Concern Statement: Plan direction for soils is in conflict with the idea that fire will create 

healthy ecosystems and watersheds by consuming accumulations of coarse woody debris. 

Periodic fires burning across the landscape will limit the growth of vegetation and will make 

the accumulation of litter difficult to achieve. Remove conflicting direction. "Soils are stable 

within their natural capability. Vegetation and litter limit accelerated erosion (e.g., rills, 

gullies, root exposure, topsoil loss) and contribute to soil deposition and development" 
Appendix A

614 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

(proposed plan p. 20), "Soils provide for diverse native plant species. Vegetative ground 

cover is well distributed across the soil surface to promote nutrient cycling and water 

infiltration." (proposed plan p. 20), "Biological soil crusts (e.g., mosses, lichens, algae, 

liverworts) are present and reestablished if potential exists." (proposed plan p. 20), "Coarse 

woody debris retention and/or creation should be used as needed to help retain long term 

soil productivity" (proposed plan p. 21). (108.203, 108.181)

Response: The plan has been developed in an interdisciplinary process to minimize conflicting 

direction. The plan provides desired conditions for coarse woody debris within each PNVT in 

chapter 2. It specifically outlines the acceptable range of coarse woody debris in tons per acre 

within the forested and woodland PNVTs.

Prescribed fires and managed wildfires used to meet desired conditions (see “Wildland Fire 

Management” section of the plan) would be mitigated for the protection of soil and vegetation at 

the project-level. Mitigations, including limiting overall fire intensity, varying ignition sequences 

and patterns, and avoiding lighting heavy fuels are commonly prescribed to protect coarse woody 

debris. Effects to biological soil crusts and desirable plants would be mitigated through timing 

burning when soil and vegetation has sufficient moisture to limit mortality. 

The guideline “Soils are stable within their natural capability” was further clarified by adding the 

footnote,

“Satisfactory soil condition exists when indicators signify that soil function is being sustained 

and soil is functioning properly and normally. The ability of soil to maintain resource values and 

sustain outputs is high.”

Concern Statement: Evaluate the effects of the Wallow Fire on soil conditions and provide a 

new and accurate accounting of soil ratings for the forest. Use the new information to 

analyze environmental consequences and determine watershed management direction. 

(108.202)

Response: Based upon this and other comments, the current soil and watershed conditions in the 

plan and EIS have been updated to reflect post-Wallow Fire conditions as estimated immediately 

after the fire. Recovery rates are highly variable as noted in the revised section. See the “Soil” 

and “Watershed” sections in chapter 3 of the EIS.

Concern Statement: Reference the importance of litter (organic materials on the soil 

surface) in all forest NEPA project documents. Include the following two references: (1) 

FSH 2409.18.2.05 and (2) Managing for Mulch, Molinar, Galt & Holechek; August 2001, 

Rangelands 23(4) page 6 recommendations for minimum residual herbage. Cite these 

references in the plan and EIS. (132.31, 132.40)

Response: Desired litter levels vary widely across the Apache-Sitgreaves NFs depending on soil 

type, microclimate, vegetation type, etc. As a result, litter was addressed directly through desired 

conditions. The Apache-Sitgreaves NFs uses these factors along with the TES to determine 

appropriate litter levels for project planning and decisionmaking. Forest Service Handbook 

2509.18 was removed in lieu of new handbook direction that is in progress. The Southwestern 

Region has issued technical guidance (Forest Service, 2013b) to use until the new direction is in 

place which has been added to “Other Sources of Information” for soils section in Appendix D. 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 615

Although the Molinar et al. paper was not referenced within the soils or vegetation specialist’s 

reports, other references to litter were cited, such as Holechek et al. (1998).

Project-level National Environmental Policy Act (NEPA) analyses are beyond the scope of the 

plan and plan revision process.

Concern Statement: Explain the soil desired condition "vegetative ground cover is well 

distributed across the soil surface to promote nutrient cycling and water infiltration" 

(proposed plan p. 20). Well distributed, in comparison to what? (138.9)

Response: The plan desired condition has been clarified to read, 

“Vegetative ground cover (herbaceous vegetation and litter) is distributed evenly across the soil 

surface to promote nutrient cycling, water infiltration, and maintain natural fire regimes.”

The term “well distributed” comes from Technical Guidance for Soil Quality Monitoring in the 

Southwestern Region, (Forest Service, 2013b). It refers to having ground cover evenly distributed 

across the soil surface, as opposed to no litter or litter only associated with prominent plants. An 

example commonly found in the Great Basin grasslands is in areas where the juniper and/or piñon 

overstory is closed (greater than 40 percent canopy). Litter accumulates under tree canopy, with 

very little between tree canopies. This can lead to accelerated soil loss in these tree interspaces. 

Concern Statement: The effect of organic matter loss on site productivity is not well 

understood; therefore the Forest Service should study this matter of scientific uncertainty 

and disclose its significance relative to the environmental impact of plan revision. (26.107)

Response: Organic matter is discussed in the context of its relationship to soil condition (EIS pp. 

59-61). There are numerous studies that compare organic matter levels to soil productivity. A 

recent study conducted in Arizona showed the difference in herbage productivity under a forest 

canopy compared to openings between canopies tied directly to levels of organic matter (Abella 

et al., 2013). It is commonly known that the majority of organic matter in the soil profile occurs 

in the topsoil or upper most layer or topsoil except in soils with lithologic discontinuities and in 

landforms such as recent alluvial plains. Loss of topsoil at a rate higher than the rate of formation 

is considered loss of soil productivity. This is the basic concept used in the application of the soil 

loss tolerance factor by the Natural Resource Conservation Service found in the National Soil 

Survey Handbook, § 618-66 (USDA NRCS, 2014). Soils with current soil loss rates above 

tolerance are characterized as in unsatisfactory soil condition.

Concern Statement: Verify that prescribed fires would not result in high severity burns as 

described in the effects to soils and vegetation (DEIS p. 77). (112.31)

Response: The potential effects of prescribed fires, including high soil burn severity, are 

addressed within chapter 3 of the EIS (see the “Soil,” “Forest Health,” and “Forest Products” 

sections). Specific effects to soil and vegetation resources would also be analyzed at the projectlevel. See also the response to comment # 98.3 in the “Wildland Fire Management” section of this 

appendix.

Concern Statement: There should be standards for litter, bare soil, and erosion rates. 

(132.42, 132.41)
Appendix A

616 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Response: Desired litter levels, herbaceous cover, and estimated erosion rates vary widely across 

the Apache-Sitgreaves NFs depending on soil type, microclimate, vegetation type, etc. As a result, 

litter and herbaceous cover were addressed directly through desired conditions rather than as a 

standard (see the “Soil,” “All PNVTs,” “Riparian Areas,” “Woodlands: Piñon-Juniper,” and 

“Grasslands” sections of the plan). The Apache-Sitgreaves NFs uses these factors along with the 

terrestrial ecosystem survey (TES) to determine appropriate ground cover levels for project-level

planning and decisionmaking.

Watershed

Concern Statement: Evaluate the effects of the Wallow Fire on watershed conditions and 

provide a new and accurate accounting of watershed classifications for the forest. Use the 

new information to analyze environmental consequences and determine watershed 

management direction. (108.227, 162.57, 108.204, 108.23)

Response: The Forest Service has updated the EIS to account for post-Wallow Fire watershed 

conditions. This can be found in table 12 and figures 7 and 8 in chapter 3 of the EIS under the 

“Watershed” section. There are desired conditions, standards, and guidelines within the 

“Landscape Scale Disturbance Events” section of the plan that provide watershed management 

direction as it relates to the protection of soil and water resources following a large scale 

disturbance such as fire.

Concern Statement: Within the watershed affected environment section, suggest adding 

"and the production of water for downstream consumption" to the end of "Watershed

condition is the state of the physical and biological characteristics and processes within a 

watershed that affect the hydrologic and soil functions that support aquatic ecosystems." 

(DEIS p. 63). (161.84)

Response: The recommended language was not added to the EIS. The definition used for 

watershed condition is from the document “Watershed Condition Framework – A Framework for 

Assessing and Tracking Changes to Watershed Conditions” (Forest Service, 2011b). The 

production of water for downstream consumption is inferred in the definition.

Concern Statement: There is a need to make a distinction between degrading factors and 

the effects of degrading factors in the watershed section of the DEIS (DEIS p. 65). (161.155, 

161.88)

Response: This section of the EIS was corrected and rewritten for clarity based on this comment.

Concern Statement: Sedimentation from natural geological features, such as Gila 

Conglomerate, is a natural process. This should indicate that removal of OHV use on the 

San Francisco River will have minimal to no effect on suspended sediment in the river 

system. (42.1, 42.5)

Response: The effects of motorized vehicle use (e.g., off-highway vehicle or OHV), including 

increases in sedimentation to streams and waterbodies, are discussed in chapter 3 of the EIS in the 

“Soil,” “Watershed,” “Water Resources,” “Riparian,” and “Fisheries” sections. 

The natural sediment load is high in the San Francisco and Blue watersheds as a whole (Inman, 

2000). However, critical habitat and habitat conditions for aquatic species in areas within the Blue 
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Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 617

River watersheds are not always affected by natural input from Gila Conglomerate. Management 

actions and other activities that generate and deliver sediment to streams can locally reduce 

spawning habitat and food production such as sediment produced from poorly located, poorly 

maintained or overly dense system roads and trails and unauthorized routes.

Concern Statement: There is concern that a watershed has to be "natural pristine" and 

"show little to no influence from human actions" to be considered properly functioning 

according to the Watershed Condition Classification Technical Guide. Instead use 

monitoring of ground cover, soil loss, sediment loads entering key drainages and 

downstream water quality as indicators of functioning watersheds. (108.78)

Response: As discussed in the “Overall Ecosystem Health” section of the plan, the “Watershed 

Condition Framework – A Framework for Assessing and Tracking Changes to Watershed 

Conditions” (Forest Service, 2011b) is the national guidance the Apache-Sitgreaves NFs will use 

to determine watershed condition. The watersheds were described in discrete categories as to how 

they compared to healthy watersheds that show little or no influence from human actions.

However, there are 12 indicators and 24 attributes that provide the basis for the watershed 

condition rating. It is possible that a few attributes potentially could be rated as “at risk” or 

“impaired” and the watershed could still mathematically attain an overall rating of good (properly 

functioning).

The Apache-Sitgreaves NFs is bound by State and National water quality standards, such as those 

found in ARS § 18 State Water Quality Standards (see the desired conditions for the “Water 

Resources” section of the plan). The State monitors streams across Arizona on a schedule. If 

monitoring demonstrates an impaired condition, a stream could be placed on the impaired stream 

list (303d) resulting in a total maximum daily load analysis and possible mitigation measures 

required within a watershed. 

The “Monitoring Strategy” in the plan (chapter 5) contains the question “How well are 

management activities contributing to desired conditions or maintaining watersheds in a healthy 

state and meeting Arizona water quality standards?” Site-specific monitoring of other items such 

as ground cover, soil loss, and sediment may be required at the project-level but would be 

inappropriate at the forest level due to cost and variable conditions across the forest.

Implementation and monitoring of best management practices (BMPs) is an effective surrogate 

for instream monitoring (Forest Service, 2013b). The plan directs that project-specific soil and 

water conservation practices and BMPs are developed (see the guidelines for the “Water 

Resources” section); these would be monitored on all ground-disturbing projects.

Concern Statement: The DEIS should present the assessments of watershed degradation 

that was done through the Wallow Fire BAER (Burned Area Emergency Response) 

planning. Coordinate the recovery of degraded watersheds with the production and sale of 

forest products and use timber sale receipts to provide for watershed management 

programs, and employ local workforce when possible. (108.200)

Response: Watershed and soil conditions were updated and included in the EIS “Soil” and 

“Watershed” sections for post-Wallow fire conditions. Information gathered during the Wallow 

Fire BAER effort was used to help determine post-Wallow fire conditions. Following the Wallow 

fire, approximately 28 percent of soils in satisfactory soil condition class were moved to impaired 

and unsatisfactory classes. Watershed condition moved from about 68 percent impaired and 
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618 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

unsatisfactory to 80 percent. Recovery rates are variable based on factors such as amount of high 

soil burn severity, post burn treatment type, inherent soil properties, and others.

The plan provides direction to restore priority watersheds that have degrading factors. The plan 

calls for the use of mechanical, fire and other treatments to help restore conditions. The specific 

method (e.g. stewardship contract, timber sale contract) for accomplishing restoration is not 

directed by the plan. Contract awards (including those to local contractors) are beyond the scope 

of the plan. In addition, the use of timber sale receipts is beyond the scope of the plan. The further 

sale of forest products is not precluded from the Wallow Fire area.

Receipts generated from the sale of forest products are very low, and no funding has been made 

directly available for watershed improvement activities such as stream channel or riparian 

improvement for many years. However, thinning the forest has benefitted watershed conditions 

by improving the fire regime condition class and reducing fuel loads, which reduces risk of high 

intensity fire and provides for more herbaceous understory components through reduction of light 

and moisture competition.

Multiple salvage sales began immediately the fire, which cleared rights-of-way. Some revenue 

was generated, however no direct watershed receipts were provided. There is, however, benefit to 

watersheds from reduced fuel load. Seeding disturbed areas caused by salvage offset soil 

disturbance. A large (15,000 acre) salvage sale was approved and work began last year, however, 

the value of the wood diminished quickly, making it somewhat uneconomical to harvest now and 

little revenue is expected from this activity. Soil and water BMPs along with monitoring have 

occurred on this sale to mitigate disturbance. As stated in the “Management Approaches for 

Landscape Scale Disturbance Events” section of the plan, salvage of dead trees may be 

considered where this contributes to the movement toward desired conditions, including 

satisfactory soil condition.

Concern Statement: Explain the plans for implementation and the impacts of 

implementation related to the objective "During the planning period, improve the condition 

class on at least 10 priority 6th level HUC watersheds by removing or mitigating degrading 

factors" (proposed plan p. 17). (108.244, 161.156, 146.3, 138.8)

Response: The plan does not specify a specific implementation schedule for improving the 

condition class in priority watersheds. However, the forests have already started the process to 

identify priority watersheds. For each priority watershed, a watershed restoration action plan will 

be developed, which contains a comprehensive list of critical projects that address removing or 

mitigating degrading factors. Projects will have site specific National Environmental Policy Act 

(NEPA) completed prior to implementation. When projects are completed and monitored, the 

watershed condition rating should move to or remain in satisfactory condition (Forest Service, 

2011b).

Concern Statement: The number of restored watersheds should be increased in all of the 

action alternatives. The watershed treatment prioritization effort should be given a higher 

priority and larger resources. (161.157, 162.167)

Response: The plan objective of improving 10 priority watersheds within the planning period is a 

minimum level based on the estimated workforce capacity and anticipated funding. Most of the 

watersheds on the forest are at risk, with a few impaired. If additional funding and personnel 

opportunities arise, more watersheds could be added.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 619

Concern Statement: Inform the public of the level of management and the expected 

outcomes are for watershed management in the next 10 to 15 years. (108.241, 108.242)

Response: As stated in the plan objectives for the “Overall Ecosystem Health” section, the 

forests would improve the condition class of at least 10 priority 6th code watersheds during the 

planning period. This entails the development and implementation of watershed restoration action 

plans for each, with critical projects identified to remove or mitigate degrading factors. When 

these projects are completed, watersheds would be considered improved. Examples of projects 

include thinning of closed canopy forests in those vegetation types where open canopies are the 

desired condition to allow for improved ground cover conditions or direct stream channel 

improvement through improved cover and stability conditions.

Water Resources

Concern Statement: Remove the statement "pumping from the Little Colorado and 

Morenci groundwater aquifers associated with the forests is greater than the estimate 

recharge, resulting in reduced water availability and affecting some streamflows" and the 

photo of Eagle Creek (proposed plan p. 22). If this increased demand can be documented, 

such documentation should be referenced. (150.3, 150.4, 151.6)

Response: The reference to Morenci aquifer was removed from this statement. A picture of the 

Blue River was substituted for Eagle Creek in this section. The original statement was estimated 

from the Morenci Basin Water Atlas, and should have stated “potential pumping from...” as the 

potential capacity of the wells was compared to the estimated recharge. The reference to Morenci 

aquifer was removed as there were too few actual groundwater pumping studies published to 

verify the claim that pumping was greater than estimated recharge.

Concern Statement: Clarify the desired condition "Soil erosion above the floodplain 

minimally contributes to the impairment of stream function or water quality.” (108.111)

Response: This desired condition does not exist in the proposed plan. The desired condition did 

appear in the 2009 “Working Draft Land Management Plan,” and based on public and employee 

feedback, it appears in the “Water Resources” section of the proposed plan as,

“Vegetation and soil conditions above the floodplain contribute to downstream water quality, 

quantity, and aquatic habitat.”

Concern Statement: Clarify that 4th, 5th, and 6th level hydrologic unit codes (HUCS) are 

equivalent to 8 (sub basin), 10 (watershed), or 12 (sub watershed) digit HUC codes, 

respectively. Explain the rationale for separating different desired conditions in the 4th, 5th, 

and 6th level HUCs. The plan should identify water-resource objectives to make progress 

toward or maintain desired conditions. (112.3, 112.4)

Response: The description of watershed hierarchy was clarified in the plan and EIS.

Concern Statement: Explain the Water Resources desired condition "Flooding does not 

disrupt normal stream characteristics (e.g., water transport, sediment, woody material) or 

alter stream dimensions (e.g., bankfull width, depth, slope, sinuosity)" (proposed plan p. 

23). Concern that flooding will occur and will 'disrupt' stream hydrology. Recommend 

stating “Stream condition is sufficient to withstand large floods of high magnitude without 
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620 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

flooding causing disruption of normal stream characteristics (e.g., water transport, 

sediment, woody material) or altering stream dimensions (e.g., bankfull width, depth, slope, 

sinuosity).” (108.112, 112.5, 138.37)

Response: The desired condition has been rewritten to clarify the statement within the plan,

“Stream condition is sufficient to withstand floods without disrupting normal stream 

characteristics(e.g., water transport, sediment, woody material) or uncharacteristically altering

stream dimensions (e.g., bankfull width, depth, slope, sinuosity).”

Concern Statement: Explain the maintenance procedures and impacts of implementing the 

Water Resources desired condition "Water resources maintain the capability to respond 

and adjust to disturbances without long term adverse changes" (proposed plan p.22). 

(138.36)

Response: Maintenance and improvement of water resources is dependent on the proper 

functioning of riparian and stream systems. Improving riparian condition to proper functioning 

condition (PFC) is desired and would provide resilience with regard to disturbance. PFC riparian 

areas dissipate stream energy from high flows, filter sediment, capture bedload, aid in floodplain 

development, develop root masses that stabilize stream banks, and improve floodwater retention 

and groundwater recharge. The environmental consequences to water are further described in the 

“Water Resources” section in chapter 3 of the EIS.

Concern Statement: Clarify the Water Resources desired condition "Vegetation and soil 

conditions above the floodplain contribute to downstream water quality, quantity, and 

aquatic habitat" (proposed plan p. 23). Does it mean that desired vegetation and soil 

conditions contribute to desired water quality, quantity, and aquatic habitat? (102.54)

Response: Desired vegetation and soil conditions would provide for desired water resources, 

such as preventing and capturing sediment and moderating water flows during heavy precipitation 

events. The desired condition has been modified to help clarify the meaning,

“Vegetation and soil conditions above the floodplain protect downstream water quality, quantity, 

and aquatic habitat.”

This topic is described in the EIS in the ‘Soils,” “Water Resources,” and “Riparian” sections.

Concern Statement: Modify the Water Resources Desired Condition (proposed plan p. 23) 

to read "Streamflow provide connectivity among fish populations and provide unobstructed 

routs critical for fulfilling needs of aquatic, riparian dependent, and many upland species of 

plants and animals except as needed for native species recovery and management." Recovery 

of native fishes would not be possible in most locations on the Apache-Sitgreaves NFs 

without the use of man-made fish barriers (in the absence of a natural emigration barrier).

(101.38)

Response: The desired condition was not modified because it does not preclude management 

actions to recover native species.

Concern Statement: Modify the Water Resources Desired Condition (proposed plan p.23) to 

read "Water quality meets the needs of all desirable aquatic species, including such as the 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 621

California floater, northern and Chiricahua leopard frog, and invertebrates that support 

fish populations." (101.39)

Response: It is assumed this modification is to make the distinction that some aquatic species are

not desirable such as crayfish. The adjective “desirable” has been added to the desired condition 

for clarity.

Concern Statement: Remove reference and statements based on the idea that no 

management of forest would have the same effect on water yield as management or human 

activity. Concern is that the DEIS states water yield impacts are the same for all alternatives 

(DEIS p. 367). (108.89, 81.12)

Response: The statement, “There would be no effects to water availability and use under all 

alternatives” appeared in the DEIS under the header “Environmental Consequences of Wilderness 

Recommendations.” It was modified for clarity by removing the term “availability”.

Concern Statement: In the Water Resources section of the DEIS, add language regarding 

the use of best management practices (BMPs) to the discussion of mechanical treatment 

effects on water quality (p. 76). (112.60)

Response: BMPs are discussed within this section under the “Mechanical Treatment” header and 

all other ground-disturbing activities under the environmental consequences for water quality.

Concern Statement: Add a guideline to protect streamflow regimes, timing, and floods, as 

recommended in USDA 2000, Water & the Forest Service. FS-660, 

at http://www.fs.fed.us/publications/policy-analysis/water.pdf, pages 10-11. The guideline 

should acknowledge the importance of intact groundcover on hydrologic regime, and 

suggest that grazing allotments be modified when necessary to protect streams. (162.75)

Response: The interdisciplinary team determined that there was no need to add an additional 

guideline. The plan provides protections for streamflow regimes, timing, and floods through 

desired conditions, standards, and guidelines contained within the “Water Resources” section.

Within the “Riparian Areas” section of the plan, the desired conditions have been updated to 

include new verbiage that addresses groundcover and vegetation height specifically. Ground

cover is a key component of soil condition, which is discussed in the “Soil” section of the EIS.

Modification of grazing allotments and specific locations of livestock grazing are determined at 

the project-level on a site specific basis. There is manual, handbook, and policy guidance in place 

to make determinations where and when cattle may graze.

Concern Statement: Add to guidelines: “To protect water quality and aquatic species, and to 

prevent the spread of exotic plant and animal species throughout watersheds, heavy 

equipment and vehicles driven into a water body to accomplish work should be completely 

clean of plant materials and seeds, mud and sediment, and aquatic animals." (162.77)

Response: Refer to the standard and guidelines found in the “Invasive Species” section of the 

plan. Projects are to be designed and monitored to reduce the potential for introduction of new 

species or spread of existing invasive or undesirable nonnative populations.
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622 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Include the following, as well as other relevant USDA information 

about surface water protection, under "Other Sources of Information for Water Sources": 

(1) USDA 2011. “Forests to Faucets” interactive maps and data. 

At http://www.fs.fed.us/ecosystemservices/FS_Efforts/forests2faucets.shtml and (2) USDA 

2000. Water & the Forest Service. FS-660. At http://www.fs.fed.us/publications/policyanalysis/water.pdf (162.74)

Response: These references are excellent for general background information but were not 

referenced within the EIS or plan. The concepts discussed in the publication are incorporated into 

plan components.

Concern Statement: Remove water diverting regimes and reject proposals that will deplete 

or divert the water table or any rivers or streams. (5.16, 8.4)

Response: The plan does not prescribe or prevent water diverting regimes. The plan does contain 

a standard in the “Water Resources” section that,

“Consistent with existing water rights, water diversions or obstructions shall at all times allow 

sufficient water to pass downstream to preserve minimum levels of water flow that maintain 

aquatic life and other purposes of national forest establishment.”

Water rights laws in Arizona dictate ownership and priority for water in the state. There are also 

guidance documents within the Forest Service that can help the forest determine if federal rights 

may have been impacted (Forest Service, 2011a). The forest will determine on a site-by-site basis 

each instance where depletion or diversion is observed or predicted.

Concern Statement: The Forest Service should not own water rights. (129.1, 130.3, 135.1, 

137.2)

Response: The Forest Service can and does own water rights, some are federally reserved, and 

most are obtained following Arizona State Statutes like any other water right owner. Most of the 

Apache-Sitgreaves NFs’ water rights are tied to management of the forest, such as water for 

grazing. Without federally owned water rights, land uses for many management activities, such as 

grazing, could not be allowed. The plan contains an objective to prepare at least one instream 

flow water rights application annually (see the “Water Uses” section).

Concern Statement: Explain how the Forest Service's objective to obtain water rights for 

instream flows (proposed plan p. 22) is not in conflict with honoring the continuing validity 

of private, statutory, and pre-existing rights (proposed plan p. 1). (150.2, 150.1)

Response: Water rights laws in Arizona follow the prior appropriations doctrine or first in time,

first in right. Instream flow rights (ISF) were filed relatively recently and are junior to all existing 

rights with prior appropriation dates. The water rights are also non-consumptive, meaning no 

water is diverted out of the stream channel, as the objective is to retain water in the stream 

channel. Additionally, ISF rights protect current priority users from new claims. ISF does not 

affect transfer of water rights by higher priority water right owners in the future.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 623

Concern Statement: Add an objective to immediately begin the process necessary to apply 

for Arizona instream flows on important perennially flowing streams, and to begin the 

application process for new streams each year. (162.76)

Response: The objective in the “Water Uses” section of the plan adequately covers the comment. 

The objective gives a minimum level of acquiring instream flow water rights; it does not preclude 

more if funding and staffing is available to do more.

Concern Statement: Add a guideline to work with water rights holders and the recipients of 

diverted water to increase water delivery efficiency, thereby maximizing instream water 

flows. Add a standard that withdrawal systems should be checked to ensure maximum 

efficiency in water transport and end point usage. (162.80)

Response: There is a desired condition within the “Water Uses” section of the plan that states,

“Dams, diversion or other water control structures are designed, maintained, and operated to 

conserve water resources.”

An addition has been made in the management approaches of the “Water Uses” section that the 

forests will work with water right holders that are “permitted” through terms of easements or 

special use permits to help conserve water.

Riparian

Concern Statement: Explain whether table 15 in the DEIS is current and represents 

conditions following the 2011 Wallow Fire (DEIS p. 84). (112.34)

Response: The table represents pre-Wallow Fire conditions. New riparian information is not 

generally available for post-Wallow Fire conditions. The Forest Service has not been funded to 

complete all of the needed post-Wallow Fire investigations to date. The discussion in the EIS 

regarding riparian condition and the Wallow Fire has been clarified.

Concern Statement: Explain whether the language in the Riparian Areas background of the 

proposed plan is in conflict: "All of the riparian PNVTs, except for the cottonwood-willow 

riparian forest PNVT, are considered departed from reference conditions" and "The 

wetland/cienega and cottonwood willow fire regimes are moderately departed." (proposed 

plan p. 33) (112.6)

Response: The departure mentioned in the first statement refers to departure from reference 

condition for overstory vegetation; while the second reference refers to departure of the fire 

regime by vegetation type. The plan has been updated to clarify this distinction. The two 

“departures” are measured using different criteria. For further information, see the information 

provided by vegetation type within the “Vegetation Specialist Report” (Forest Service, 2014g) in 

the project record. Both metrics and criteria are explained in detail.

Concern Statement: The background for Riparian Areas (proposed plan p. 33) should 

mention that plant density has increased tremendously since 1996 and salt cedar has begun 

to invade riparian areas. (121.5)

Response: The background section for “Riparian Areas” has not been updated to mention salt 

cedar. The forests have no trend data on salt cedar invasion. However, salt cedar is considered an 
Appendix A

624 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

invasive species, is a concern, and would be addressed through plan guidance contained in the 

“Invasive Species” section. Salt cedar is specifically mentioned in chapter 3 of the EIS in the 

affected environment of the “Invasive Species” section, as becoming common along many 

streams. Salt cedar habitat is within the riparian areas on the forests.

Concern Statement: Explain what the Riparian Areas desired condition "sedimentation and 

soil compaction do not negatively impact riparian areas" means, how and when it's 

measured, and how the cause is detected. (proposed plan p. 34) (108.122, 138.20, 30.5)

Response: This desired condition has been updated for clarity, 

“Soil compaction from forest activities (e.g., vehicle use, recreation, livestock grazing) 

does not negatively impact riparian areas.”

Sedimentation and soil compaction can affect riparian areas by reducing the potential for 

vegetative ground cover or plants for stabilizing stream banks. These conditions are detected and 

measured through site observation using proper functioning condition protocols, or other 

methodologies (e.g., Multiple Indicator Monitoring (BLM, 2011); Monitoring the Vegetation 

Resources in Riparian Areas (Winward, 2000) specified at the project-level.

Concern Statement: Explain the term xeroriparian as used in the plan. (108.120)

Response: This terminology is not found in the proposed plan. The term was used in the June 

2009 Working Draft Land Management Plan but was removed from subsequent versions.

Concern Statement: Remove generalizations in Riparian Areas desired conditions (e.g. 

"stream bottoms that are predominantly composed of sand and gravel have large coarse 

woody debris which provides habitat and food and helps dissipate hydraulic energy"). 

Concern is that desired conditions may not be attainable, given specific stream 

characteristics (e.g., wetland-cienega PNVT may not have the capability to provide coarse 

woody debris) (proposed plan p. 33-34). (108.94, 30.3, 138.22, 112.7, 112.11)

Response: The desired condition indicated in this comment was removed.

Concern Statement: Modify or remove the Riparian Areas desired condition "Willows (e.g., 

Bebb, Geyer, Arizona) are reproducing with all age classes present" because not all sites 

have the potential for willows. (30.4, 138.43, 131.4, 123.16, 123.1, 112.8, 108.121, 105.14, 

102.26)

Response: The desired condition mentioned above was modified for clarity, adding “where the 

potential exists.” It now reads,

“Willows (e.g., Bebb, Geyer, Arizona, Goodding’s) are reproducing with all age classes 

present, where the potential exists.”

Potential would be determined at the project-level based on site specific conditions. In addition, 

the following statement has been added to chapters 1, 2, and 3 of the plan to clarify the 

applicability of plan decisions, 

“Plan decisions apply to projects or activities where site conditions provide an inherent 

capability to meet those plan decisions.”
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 625

Concern Statement: The Riparian Areas desired condition "The spatial extent of wetlands 

is maintained" (proposed plan p. 34), if the predictions of drier and warmer conditions due 

to climate change are correct, this desired condition is not likely to be met. (102.27)

Response: The plan’s appendix A (“Climate Change Trends and Apache-Sitgreaves NFs Land 

Management Planning”) discusses a number of potential strategies to provide for maintenance of 

riparian areas and wetlands, such as improving current riparian conditions, implementing water 

conservation strategies, and restoring uplands to resilient native ecosystems. Monitoring is also 

needed to determine trends in weather and resource conditions. The plan’s monitoring strategy in 

chapter 5 identifies monitoring questions that will help the forest assess whether the desired 

condition is achievable. The monitoring strategy includes questions that address riparian, 

wetlands, and climate change. If the desired condition is determined not to be achievable, the plan 

can be amended to remove or modify the desired condition.

Concern Statement: Modify Riparian Areas Desired Condition (proposed plan p. 34) 

"Willows (e.g. Bebb, Geyer, Arizona) are free of disease, and reproducing with all age 

classes present." Need to acknowledge the significant role that disease has played in the loss 

of willows across the Apache-Sitgreaves NFs. (101.50)

Response: The suggested language was not added to the desired condition. The threats to 

successful willow reproduction include numerous factors (e.g., changes to water regime, physical 

modification, introduction of invasive species, disease). More information about threats to 

willows can be found in the affected environment of the “Vegetation” section in chapter 3 of the 

EIS.

Concern Statement: Add Riparian Areas Desired Condition (p. 34) "Wetlands created with

treated wastewater from municipalities provide additional critical wildlife habitat." (101.51)

Response: This desired condition was not added. There is a similar guideline found in the “Water 

Resources” section stating, 

“Treated wastewater may be used to provide wetland habitats.”

Concern Statement: Modify or remove the Riparian Areas desired condition "Floodplains 

and wet meadows provide sufficient herbaceous cover (55 percent or greater) and height (9 

inches or longer) to trap sediment, mitigate flood energy, and provide wildlife habitat" and 

guideline "Wet meadows and active floodplains with riparian-obligate species should 

provide sufficient herbaceous cover (55 percent or greater) and height (6 to 9 inches or 

longer) to trap sediment, mitigate flood energy, stabilize banks, and provide for wildlife and 

plant seeds" (proposed plan p. 34-35). There are concerns that the specified amounts may 

not be achievable or measurable. (123.17, 30.7, 139.9, 30.6, 138.24, 131.7, 131.5, 123.3, 

112.13, 108.95, 105.5, 105.15, 102.32, 102.28, 102.29, 112.9)

Response: These desired conditions have been modified to reflect research and ranges of plant 

taxonomic descriptions in Arizona and found in many cases within the forests’ boundary.

References to the plant height source material are now included in footnotes within the “Riparian

Areas” section. There is also an established protocol for measurement of plant height used on the 

forests found in national and regional direction such as the “Region 3 Rangeland Analysis and 

Management Training Guide” (Forest Service, 1999) and others as found in “Other Sources of 

Information” for livestock grazing in Appendix D in the plan.
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626 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Define geologic control feature as used in the Riparian Areas desired 

condition "Riparian areas that do not depend on geologic control features for stability have 

large, coarse woody debris that provides key habitat for riparian-dependent species" 

(proposed plan p. 34). (112.10)

Response: Geologic control features in this instance is natural geologic features that resist 

vertical or lateral stream movement, such as bedrock outcrops and boulders. This desired 

condition was modified to clarify geologic control, 

“Large coarse woody debris provides stability to riparian areas and stream bottoms

lacking geologic control (e.g., bedrock) or geomorphic features (e.g., functioning 

floodplains, stream sinuosity, width/depth ratio).”

Concern Statement: Remove floodplains from Riparian Areas desired conditions. A better 

way to describe it would be from green line to green line or something similar that defines 

and restricts the areas to the places where it is possible. (123.2)

Response: References to floodplains have not been removed from the “Riparian Areas” desired 

conditions. Floodplains are necessary to dissipate flood energy and to capture excess sediment in 

the stream system. Vegetation and other components, like coarse woody debris or cobbles, resist 

flow across the floodplain which allows for energy dissipation and sediment deposition. The term 

“stream banks” was added to one of the “Riparian Areas” desired condition statements as this is 

another critical component needing protection from high flows. It reads,

“Vegetation and root masses stabilize stream banks, islands, and shoreline features 

against the cutting action of water.”

Concern Statement: The DEIS discusses the ability of riparian systems to recover and 

improve as being affected by ongoing and new impacts (DEIS p 84, 95). This was not 

discussed under standards or guidelines for management activities in the proposed plan. 

(108.232, 112.350)

Response: Effects of current or new impacts are appropriately discussed in the “Riparian” section 

in chapter 3 of the EIS and are not appropriate for the plan. The plan provides guidance for 

management, including standards and guidelines for project or activity design that would reduce 

or minimize potential impacts to riparian systems.

Concern Statement: Review the Riparian Areas guideline "Ground-disturbing projects 

(including planned ignitions) which may degrade long term riparian conditions should be 

avoided" (proposed plan p. 35) and the DEIS Riparian environmental consequences for 

Forest Restoration Activities (DEIS p. 86) to ensure there is no contradiction. (112.38)

Response: The interdisciplinary team reviewed the guideline and environmental consequences 

and did not identify a contradiction. The environmental consequences listed in the EIS describe 

effects of both low severity beneficial burning, as well as effects of high severity burns which can 

result from wildfire.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 627

Concern Statement: Review the Riparian DEIS environmental consequences for 

Mechanical and Burning (p. 87) to ensure there are no contradictions. (112.39, 112.40)

Response: The interdisciplinary team reviewed the environmental consequences of mechanical 

treatments and burning; no contradictions were identified. The effects sections describe possible 

effects of mechanical and burning treatments if best management practices (BMPs) or soil and 

water conservation practices (SWCPs) are inadequate or not implemented. Mitigation of projects 

using BMPs and SWCPs are effective in preventing long term riparian degradation.

Concern Statement: Elk grazing should be taken into account in the specific guidelines for 

vegetation cover and/or height. (102.31)

Response: The plan provides desired conditions for herbivory to be in balance with available 

forage (see the “All PNVTs,” “Livestock Grazing,” and “Wild Horse Territory” sections). Within 

the “Livestock Grazing” section, the plan does provide the following guideline,

“Forage, browse, and cover needs of wildlife, authorized livestock, and wild horses 

should be managed in balance with available forage so that plants providing for these 

needs remain at or move toward a healthy, persistent state.” 

The effects of all grazers, including elk, would be taken into account to move towards desired 

conditions. The allocation of forage to domestic or wild animals is not determined at the plan 

level. It would be a site specific decision completed at the project-level.

Concern Statement: Account for factors (soil loss and erosion, distance to a water body, 

road-stream crossings) and disclose potentially significant impacts that may result from 

existing road networks. (26.137, 112.41)

Response: The environmental consequences of motorized routes, including roads, are discussed 

in chapter 3 of the EIS in the “Soil,” “Watershed,” and “Riparian” sections. The design and use of 

site specific best management practices (BMPs) and streamside management zones are found in

the guidelines in the “Water Resources” section in chapter 2 of the plan. There are no known 

significant impacts resulting from the existing road network. All new road construction, as well as 

maintenance of existing roads, is subject to BMPs to mitigate impacts to water quality.

Concern Statement: Consider best management practices, streamside management zones, 

and wildlife mitigation during livestock grazing implementation (DEIS p. 86). (112.37)

Response: Guidance for design and use of site specific best management practices (BMPs) and 

streamside management zones are found in the guidelines in the “Water Resources” section in 

chapter 2 of the plan. The “Livestock Grazing” section in chapter 2 of the plan provides standards 

and guidelines to protect wildlife species when implementing livestock grazing activities. BMPs, 

streamside management zones, and wildlife mitigation are also incorporated at the project-level

analysis and implementation for grazing activities.

Concern Statement: Riparian areas present a significant issue for analysis because they are 

severely degraded and the Forest Service is required by NFMA to ensure viability of species 

that depend on aquatic habitats. (26.184)

Response: Chapter 3 of the EIS discloses potential environmental consequences to riparian areas 

in the “Riparian” section. The species viability analysis in the EIS (“Fisheries and Aquatic 
Appendix A

628 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Habitat” and “Wildlife”) addresses the needs of aquatic species. Effects to riparian areas would 

also be evaluated during project and activity-level planning. Project-level analysis evaluates both 

positive and negative effects to riparian areas. Riparian condition is commonly found to be a need 

for change, which leads to treatment, mitigation of effects, monitoring and adaptive management 

to improve conditions.

Concern Statement: Explain how the Riparian Areas objectives: "annually, restore 200 to 

500 acres..." and "Annually, remove an average of 2 miles of unauthorized roads or trails 

..." will help that much across a large national forest (proposed plan p. 34). (122.7, 146.14)

Response: These objectives represent a minimum level due to planning guidance that set our 

planning levels at or near current levels; however, they are considered to be lower limits of 

treatments. A greater number of acres or miles of improvement may be achieved depending upon 

environmental conditions, available funding, and staffing.

Concern Statement: Explain how the riparian objectives would be achieved and what 

impact would be incurred by users. Concern if objectives are not met, restrictions may be 

imposed in areas that could eliminate user opportunities. (123.18, 138.44, 138.38)

Response: Objectives would be met by implementing site specific projects, generally identified 

within priority watersheds. Types of treatments could include fencing, planting riparian 

vegetation, grade control, or removal of invasive or unwanted species. The actual level of 

accomplishment would depend on environmental conditions, budgets, and staffing. The potential 

impacts to users would be disclosed during the National Environmental Policy Act (NEPA) 

process at the project-level. 

Concern Statement: The DEIS discusses "objectives to treat riparian areas," explain where 

the objectives are in the plan. (127.43)

Response: They are found in chapter 2 of the plan within the objectives for the “Riparian Areas”

section.

Concern Statement: The Forest Service should prioritize road removal in riparian areas 

associated with aquatic ecosystems. (26.140)

Response: The plan contains two objectives in the “Riparian Areas” section that are designed to 

minimize (through actions such as decommissioning, removing, relocating) the effect of roads 

that add sediment to streams, damage riparian vegetation erode stream banks, cause gullies, 

and/or compact floodplain soils. In addition, road removal treatments could be part of watershed 

restoration plans (WRAPs) that are developed for priority watersheds. There is a plan objective 

(see the “Overall Ecosystem Health” section) to improve the condition class on at least 10 priority 

watersheds during the planning period over the next 15 years.

Concern Statement: Modify the Riparian Areas Objective (proposed plan p. 34) "Within

the planning period, relocate, repair, improve, or decommission a minimum of 4 miles of 

National Forest Systems roads or trails that add sediment to streams, damage riparian

vegetation, erode stream banks, cause gullies, and/or compact floodplain soils. These 

activities should promote adequate trail access that addresses public recreational access needs 

(e.g. fishing and hiking) and minimizes creation of additional unauthorized trails." (101.52)
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 629

Response: Further additions or stipulations to the objective are not deemed necessary. The plan 

allows for the creation of additional trail opportunities. However, additional trail access would 

have to comply with plan guidelines in the “Nonmotorized Opportunities” and “Motorized 

Opportunities” sections to avoid wetlands, riparian areas, and stream bottoms.

Concern Statement: Explain whether there are cheaper fixes for changing riparian 

conditions for the better (e.g., removing cows, changing the time when they graze). (122.10)

Response: Several cost efficient methods for improving riparian conditions are discussed in the

management approaches for the “Riparian Areas” section of the plan. Other methods could 

include timing of livestock use, level of use, and administratively closing non-National Forest 

System roads and trails within riparian areas. Opportunities such as these would be identified 

during project-level analysis.

Concern Statement: The proposed plan acknowledges the generally degraded condition of 

riparian areas, explain why it proposes no new management direction to restore conditions. 

(26.60, 162.182)

Response: There are desired conditions, objectives, and guidelines within the “Riparian Areas”

section of the plan that provide direction to protect and improve conditions. Specifically, an 

objective to move 200 to 500 acres per year towards desired riparian condition and removal of a 

minimum of 2 miles of unauthorized roads and trails can be found in this section.

Concern Statement: Modify Riparian Management Approaches (proposed plan p. 35) in the 

last paragraph the word "elk" should be replaced with "ungulate.” In addition, the 

preceding paragraph should more strongly emphasize the need for landscape scale 

restoration treatments within the context of riparian area management. (101.53)

Response: “Elk” was replaced with “wildlife.” The sentence now reads,

“The Apache-Sitgreaves NFs work with the Arizona Game and Fish Department 

(AZGFD) to minimize wildlife impacts to riparian vegetation and structure and to 

develop project design criteria to protect important habitat features such as springs, 

bogs, seeps, and fens.”

The following statement was added to management approaches for “Riparian Areas,”

“Landscape scale restoration is expected to improve riparian conditions through the 

expected improved hydrologic function of uplands.” 

Concern Statement: Review the role of the proper functioning condition (PFC) assessment 

as a standard or a guideline under Riparian Areas. Since the PFC assessment method is not 

intended to be used as a monitoring tool, clarify how information on changes in ground 

cover, species composition, bank stability, and water quality will be used. (112.2, 112.28)

Response: Many of the elements used in defining desired conditions are similar to the PFC 

literature (BLM, 1998; BLM, 1999). PFC is currently used by the forests to determine riparian 

condition and was added to the management approaches section. The monitoring strategy in 

chapter 5 of the plan includes a monitoring question,

“Are riparian areas attaining and/or moving toward proper functioning condition?”
Appendix A

630 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

PFC elements that indicate at risk or nonfunctioning conditions would be monitored using 

established and approved methods (e.g., Multiple Indicator Monitoring, (BLM, 2011), Monitoring 

the Vegetation Resources in Riparian Areas, (Winward, 2000)). Specific riparian monitoring 

would also be developed and implemented through project-level monitoring plans.

Concern Statement: Review language in the DEIS "riparian areas can regain their 

equilibrium within a few years" and "the riparian system make take decades to reach PFC" 

(DEIS p. 84) to ensure there is no contradiction. Explain the concept of regaining 

equilibrium, whether it involves the area regaining stability or proper functioning condition. 

(112.36)

Response: The statements were reviewed, and no conflict was noted. Equilibrium in this instance 

refers to proper functioning condition.

Concern Statement: The DEIS states the desired condition for riparian areas and wetlands 

is to be in proper functioning condition. Many of the important attributes and processes 

needed by a riparian area to function properly are generally discussed in the desired 

conditions but not specifically stated in the proposed plan. Review consistency between the 

DEIS and plan in discussing desired conditions of riparian areas and wetlands. (112.32, 

112.33)

Response: The plan and EIS were reviewed for consistency. Many of the desired conditions in 

the plan are based on or are similar to elements found in the proper functioning condition 

definitions.

Chapter 1 of the plan explains that desired conditions and guidelines are not discretionary; 

projects must either maintain resources in desired conditions or move them toward desired 

conditions. Any project documentation should explain how the project is consistent with desired 

conditions and describe any short or negligible long term effects the project may have concerning 

the maintenance or attainment of any desired condition.

Concern Statement: There should be a standard(s) to manage riparian areas for proper 

functioning condition. (112.43, 127.42)

Response: The Forest Service has chosen not to frame riparian condition as a standard, but it has 

described many elements of properly functioning condition (PFC) as desired conditions in the 

plan. (BLM, 1998; BLM, 1999). Chapter 1 of the plan explains that desired conditions and 

guidelines are not discretionary; projects must either maintain resources in desired conditions or 

move them toward desired conditions. Any project documentation should explain how the project 

is consistent with desired conditions and describe any short or negligible long term effects the 

project may have concerning the maintenance or attainment of any desired condition.

Fisheries and Aquatic Habitat

Concern Statement: Update information in the Fisheries section of the DEIS including: (1) 

watershed conditions following the 2011 Wallow Fire for Gila trout in Raspberry Creek, (2) 

persistence of loach minnow, and (3) persistence of spikedace. (112.45, 112.46, 112.47, 

112.65)
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 631

Response: Watershed condition ratings have been updated for conditions resulting from the 

Wallow Fire, which is summarized in the EIS (table 12). The specific updated condition for the 

Raspberry Creek 6th code HUC is located within the “Watershed Specialist Report” (Forest 

Service, 2014i). The suggested edit to the sentence regarding the loach minnow was incorporated

as follows, 

“Recent surveys (last 5 to 20 years) have not documented the presence of this species 

within the East Fork Black River, Eagle Creek, or the San Francisco River populations; 

although the U.S. Fish and Wildlife Service considers the populations to still exist.”

The additional suggested edits regarding loach minnow and spikedace distributions and 

introductions were not incorporated, as they are not within the Apache-Sitgreaves NFs, or 

downstream within the action area of the plan.

Concern Statement: Explain why turbidity (muddy water) is considered "good" for chubs, 

dace, and other native minnows in the Colorado River, but not in the Apache-Sitgreaves 

NFs. The emphasis on managing for more heavily consumptive riparian vegetation and less 

turbidity seems like a prescription for a crisis for native warm water fish. References: (1) 

Stream Fish Responses to Grazing Exclosures, Peter B. Baley and Hiram W. Lee, North 

American Journal of Fisheries Management (2) Pacific Salmon Restoration: Trade-offs 

Between Economic Efficiency and Political Acceptance, Junjie Wu, et al., Contemporary 

Economic Policy, January 2003, (3) Native fishes, exotic mammals, and the conservation of 

desert springs, Astrid Kodrie-Brown and James B. Brown, Front Ecol Environ 2007, and (4) 

"At age 50, dam still generates love, hate," Shawn Mckinnon, The Arizona Republic. (133.2, 

133.3)

Response: This comment is concerned with the approach that improving hydrologic conditions 

and riparian vegetation will actually result in the loss of native fish species and the reduction of 

streamflows and is being used as a reason to remove human disturbances. 

The article (McKinnon, 2007) about Glen Canyon Dam is not considered science and is not 

applicable to the Apache-Sitgreaves NFs plan. Both water temperature and turbidity are issues 

that impact water resources and aquatic habitat and species on the Apache-Sitgreaves NFs and

were considered and discussed within chapter 3 of the EIS in the “Water,” “Watershed,” 

“Riparian,” and “Fisheries” sections.

While the articles (Bayley and Li, 2008; Wu et al., 2003) were not used in the development of the 

plan, this issue has been recognized as relevant to the Apache-Sitgreaves NFs and is considered 

and discussed in the “Fisheries Specialist Report” (Forest Service, 2014a). The speckled dace is 

the most widely distributed (table 16, EIS) and secure fish species occurring on the ApacheSitgreaves NFs, and it is recognized that improvements that benefit cold water fish species (i.e.,

Apache and Gila trout) could result in reductions in distribution for this species, and it is not 

considered to be a threat to the viability of the species.

The article (Kodric-Brown and Brown, 2007) studied one pupfish in Nevada and five fish species 

in Australia. This literature was not considered in the preparation of the plan and is not considered 

applicable to the Apache-Sitgreaves NFs or the management of its native fish species. The 

pupfish is limited to only small isolated springs; while some native fish can use these habitat 

types, they occur throughout lotic systems on the Apache-Sitgreaves NFs using various habitat 

types.
Appendix A

632 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

The article (Blaney, 1954) measures water loss from evapotranspiration, especially associated 

with willows and cottonwoods. While this specific article was not considered in the preparation 

of the plan, the evapotranspiration process is widely recognized and considered in the 

management of watersheds, riparian areas, and aquatic habitat. Where improvements and 

restoration of riparian vegetation is considered necessary or desired, the resulting beneficial 

impacts are many, and overall increases in streamflow can occur from improvements in 

hydrologic conditions and functions.

Concern Statement: Explain how the quality of fish habitat is evaluated for historic 

conditions (e.g., native fish have decreased 50 to 75 percent over the past 10 years) and 

explain the cause of decline. (108.113)

Response: The statement (e.g., native fish have decreased 50 to 75 percent over the past 10 

years) provided by the commenter is not found within the proposed plan nor the DEIS. Declines 

in aquatic habitat conditions, fish populations, and limitations associated with various aquatic 

habitat and fish population surveys are discussed within the “Fisheries,” “Riparian,” and “Water 

Resources,” sections in chapter 3 of the EIS and the “Fisheries Specialist Report” (Forest Service, 

2014a).

Concern Statement: There is a need to recognize that not all nonnative species (sportfish) 

are undesirable and include more discussion on current management practices and recent 

research. (109.12, 109.11)

Response: The social and economic values associated with recreational sportfishing are 

recognized by the Apache-Sitgreaves NFs. The plan has three desired conditions that include 

providing for desirable nonnative plants and animals, and these are located within the “Overall 

Ecosystem Health,” “Aquatic Habitat and Species,” and the “All PNVTs” sections in chapter 2. 

The commenter provides no specifics regarding their reference to current management actions 

and research conducted by the Arizona Game and Fish Department that demonstrated rainbow 

trout are compatible with recovery of native fishes. 

Concern Statement: Within the riparian and aquatic habitat sections of the DEIS, explain 

what the term degraded means. (108.220)

Response: The term degraded means, “A decline in the viability of ecosystem functions and 

processes” (Armantrout, 1998). This clarification has been added to the both the “Riparian” and 

“Fisheries” (aquatic habitat) sections in chapter 3 of the EIS.

Concern Statement: Modify Aquatic Habitat and Species Background (proposed plan p. 

25). There are only 23 nonnative fishes that are currently found on the Apache-Sitgreaves 

NFs, not 25. Need to characterize the lower elevation warm water habitat as "cyprinid and 

catostomid (minnow and sucker families) streams" instead of only cyprinid. Mineral Creek 

should be added to the list of streams that are totally diverted. (101.40)

Response: The plan was edited in response to this comment and now reads as follows,

“The forests are home to 14 native and 24 nonnative fish species. Fish habitats range 

from high elevation cold water streams (trout) to the lower elevation warm water streams 

(minnow and sucker).”
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 633

The number of nonnative fish species noted in the proposed plan was incorrect; the correct 

number is 24 species. The 24 nonnative fish species are listed in the “Fisheries” section in chapter 

3 of the EIS. 

The sentence regarding specific streams being totally diverted was also reworded to the 

following,

“Some streams, during low flow years can be totally diverted, impacting habitat and 

aquatic species.”

Concern Statement: Modify the Aquatic Habitat and Species Desired Condition (proposed 

plan p. 25) "Streamflows, habitat, and water quality support native and desirable nonnative

aquatic and riparian-dependent species and habitat." (101.41)

Response: The desired condition was not modified. The plan has three desired conditions that 

include providing for desirable nonnative plants and/or animals; these are located within the 

“Overall Ecosystem Health,” “Aquatic Habitat and Species,” and the “All PNVTs” sections in 

chapter 2. 

Concern Statement: Modify the Aquatic Habitat and Species Desired Condition (proposed 

plan p.25) "Habitat and ecological conditions are capable of providing for self-sustaining 

populations of native and desirable nonnative, riparian dependent plant and animal 

species." (101.42)

Response: The desired condition was not modified. The plan has three desired conditions that 

include providing for desirable nonnative plants and/or animals; and these are located within the 

“Overall Ecosystem Health,” “Aquatic Habitat and Species,” and the “All PNVTs” sections in 

chapter 2. 

Concern Statement: Modify the Aquatic Habitat and Species Desired Condition (proposed 

plan p. 26) "Desirable nonnative fish species, and native fish species (i.e. Apache trout, Gila 

trout, roundtail chub) provide recreational fishing in waters where those opportunities are 

not in conflict with recovery of native fish species." (101.43)

Response: The desired condition was not modified. The intent of this specific desired condition is 

to provide for opportunities for desirable nonnative fish species; the “Aquatic Habitat and 

Species” section within chapter 2 of the plan has four desired conditions, two objectives, and two 

guidelines that provide for native fish species recovery and improvements to aquatic habitat and 

species. 

Concern Statement: The wording used to describe impacts of nonnative fish on page 132 

and of fish stocking on page 133 of the DEIS is inappropriate and disproportionate to the 

descriptions given to other impacts on native fish species. The statement that the 

Department continues to impact native fish throughout the A-S through stocking and 

management of nonnative fish is misleading and unnecessarily confrontational. The 

Department does not dispute that nonnative fish are a major cause of the current status of 

many native fishes on the A-S. However, the impact is not at the level that it used to be 

decades ago. There are numerous processes in place to minimize additional impacts of 

nonnative fishes, fish stocking. The Department goes through intensive consultation with the 

U.S. Fish and Wildlife Service on all stocking activities to determine impacts on native 
Appendix A

634 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

wildlife and to gain associated clearances for those stocking activities. In most cases, there 

are no impacts or it is minimal, and in those few cases where an impact to native wildlife has 

been identified, the Department actively mitigates those impacts. The Department therefore 

asks that a more pragmatic and balanced discussion of nonnative fish and fish stocking exist 

by replacing current narrative with language similar to that within the Livestock Grazing

impacts section on page 130, which states that livestock grazing activities can have 

numerous impacts..., and that livestock also have the potential to introduce nonnative 

species. (101.91)

Response: No modifications were made to the plan based on this comment. This comment is 

concerned with the EIS’ characterization of the impacts to native fish from past and ongoing fish

stocking programs conducted by the Arizona Game and Fish Department. The intent of the 

discussion within the EIS is to capture the historical, current and ongoing, and future impacts 

associated with all known causes and sources associated with nonnative species, and references 

are also made to impacts associated with private lands and both the San Carlos and White 

Mountain Apache tribal lands. 

Concern Statement: Objectives should include restore a third or more of the forest's aquatic 

habitats during the life of the plan. (162.78)

Response: The objectives associated with the restoration and improvements of aquatic habitats 

are based on levels that are considered within the capacity of the Apache-Sitgreaves NFs. There is 

acknowledgement in the introduction to chapter 3 of the EIS stating that the objectives were 

developed with the assumption that budgets would be similar to the past 5 years and the level of 

accomplishment would depend on environmental conditions, budget, and staffing. Several of the 

“Aquatic Habitat and Species” and “Riparian” plan objectives describes a minimum level to 

accomplish; if conditions allow greater accomplishments could be achieved. 

Concern Statement: Add a guideline to maintain or restore functioning riparian plant 

communities provide water filtration, shade and temperature regulation, shelter from 

predators, and foraging areas to protect aquatic species. (162.79)

Response: The plan contains objectives, desired conditions, standards, and guidelines for 

maintaining, improving, and restoring riparian areas, aquatic habitats, and aquatic species. (For 

specifics see desired conditions, objectives, standards, and guidelines for the “Water Resources” 

and “Aquatic Habitat and Species” sections in chapter 2 of the plan). These plan decisions 

provide for the maintenance and restoration of riparian areas and the specific concerns of buffers 

and water filtration, riparian canopy (i.e., shade) and water temperature, and aquatic habitat that 

provides for cover from predators and foraging needs of species.

Concern Statement: Modify Aquatic Habitat and Species Guideline (proposed plan p. 26) 

“To prevent degradation of native species habitat and the incidental or accidental 

introduction of diseases or nonnative species, when transferring aquatic species should not 

be transferred through management activities from one 6th code watershed to another. 

Measures should be taken to prevent the spread of non-target fish species, invasive species, 

parasites, or diseases."” As written, this does not allow critical management actions to recover 

rare species such as T&E fish and candidate species. (101.44)
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 635

Response: No modifications were made to the plan based on this comment. The intent of this 

guideline is to prevent the spread of nonnative species or diseases that could occur through site 

specific actions implemented under the plan (e.g., water transfers, movement of equipment).

Concern Statement: Modify Aquatic Habitat and Species Guideline (proposed plan p. 26) 

"Projects and activities should avoid damming or impounding free-flowing waters to 

provide streamflows needed for aquatic and riparian-dependent species, except as needed 

for native species recovery and management, or instream structures that improve stream 

functionality and stability or improve aquatic habitat conditions for aquatic species."(101.45)

Response: No modifications were made to the plan based on this comment. The “Aquatic Habitat 

and Species” section within chapter 2 of the plan has four desired conditions, two objectives, and 

two guidelines that provide for native fish species recovery and improvements to aquatic habitat 

and species. 

Concern Statement: Correct the sentence in the Aquatic Habitat and Species background 

(proposed plan p. 25) that says Eagle Creek is "totally diverted for several months.” (121.4)

Response: In response to this comment, the statement was changed to read, 

“Some streams, during low flow years can be totally diverted, impacting habitat and aquatic 

species.”

Concern Statement: Aquatic systems in good condition should be maintained and those 

degraded or at risk should have reparative and/or restorative action taken. There is a need 

for recovery plans. (14.7, 5.18)

Response: The plan identifies and recognizes the need to maintain and restore aquatic habitats. 

Desired conditions, objectives, standards, and guidelines are located within the “Riparian Areas,” 

“Water Resources,” and “Aquatic Habitat and Species” sections within chapter 2 of the plan. 

Through implementation of the plan, watershed, riparian, and aquatic habitat maintenance and 

restoration activities would be identified and implemented through site specific projects and 

actions.

Concern Statement: Analyze and disclose what is known about the existing condition of 

riparian areas, aquatic ecosystems, and associated species on the national forest, with 

special attention to fish and amphibian species at risk of extinction. (162.44, 26.125)

Response: The existing conditions for riparian areas on the Apache-Sitgreaves NFs can be found 

within the “Riparian” section of chapter 3 (affected environment and environmental 

consequences) of the EIS. Four riparian PNVTs are also described in detail within the 

“Vegetation” section of chapter 3 of the EIS. Existing condition information for aquatic habitat 

and associated species (e.g., fish and amphibians) and threatened and endangered species can also 

be found within chapter 3 of the EIS under the “Fisheries” and “Wildlife and Rare Plants” 

sections. Additionally, more specific and detailed information can also be found within the 

“Ecological Sustainability Report” (Forest Service, 2008c), “Vegetation Specialist Report” 

(Forest Service, 2014g), “Riparian Specialist Report” (Forest Service, 2014f), “Fisheries 

Specialist Report” (Forest Service, 2014a), “Water Specialist Report” (Forest Service, 2014h), 

“Watershed Specialist Report” (Forest Service, 2014i), and “Wildlife Specialist Report -

Viability” (Forest Service, 2014l).
Appendix A

636 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: The Forest Service should adopt an ecosystem-scale aquatic 

conservation strategy for management of aquatic habitat and at-risk fisheries similar to the 

one adopted in the Pacific Northwest: (1) Designate “key watersheds” in large drainage 

basins that offer the highest quality aquatic habitat, (2) establish “riparian reserves” to 

maintain and restore aquatic habitat, (3) enacts standards and guidelines for management 

in riparian reserves that require project-level actions to meet objectives related to physical, 

chemical and biological aspects of aquatic ecosystems, (4) require watershed analysis at the 

scale of large drainage basins to account for such factors as road density, vegetation cover 

and ecological processes that contribute to aquatic habitat quality, (5) compel active 

restoration of aquatic ecosystems in compliance with standards and guidelines for riparian 

reserves, and (6) prohibits use of site specific mitigation measures or planned restoration 

activities as a substitute for preventing degradation of existing high-quality aquatic habitat. 

(26.181, 162.183, 26.18, 26.73, 26.130)

Response: The plan recognizes the need to maintain, improve, and restore watersheds, riparian 

areas, and aquatic habitat and their associated species on the Apache-Sitgreaves NFs. The primary 

approaches of the plan to address these issues are through ecosystem restoration of the various 

PNVTs across the landscape, addressing degraded watershed conditions, and improving 

conditions within riparian areas and their associated aquatic habitats and species. Numerous 

objectives, desired conditions, standards, and guidelines have been developed for each of these 

for improving conditions by reducing historical, ongoing, and potential impacts through 

restoration activities and moving towards desired conditions through project implementation. Two 

examples of specific plan decisions (objectives) are: 

(1) “During the planning period improve the condition class on at least 10 priority 6th 

level HUC watersheds by removing or mitigating degrading factors.” 

(2) “Annually, enhance or restore 5 to 15 miles of stream and riparian habitat to restore 

structure, composition, and function of physical habitat for native fisheries and ripariandependent species.”

Concern Statement: Modify Aquatic Habitat and Species Management Approaches 

(proposed plan p. 27) "The Apache- Sitgreaves NFs cooperate with the Arizona Game and 

Fish Department (AZGFD), the state wildlife agency with authority over wildlife management 

in Arizona to protect and reintroduce native aquatic species where appropriate and control 

or eradicate nonnative species where appropriate."” Need to clarify the Department's wildlife 

management authority, and that control or eradiation of nonnative species on the ApacheSitgreaves NFs is not an appropriate management action in all circumstances. (101.46)

Response: The Apache-Sitgreaves NFs and the plan recognize the state’s authority over wildlife 

management in Arizona. The sentence has been reworded to read, 

“The Apache-Sitgreaves NFs assist the Arizona Game and Fish Department (AZGFD)

with efforts to protect and reintroduce native aquatic species where appropriate and 

control or eradicate nonnative species.”
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 637

Vegetation

Concern Statement: Explain "historic" or "reference" vegetation conditions, including 

whether it is possible to achieve those conditions. (105.2, 108.240, 108.231, 102.55, 138.34, 

161.13, 108.93, 102.45, 102.4, 102.21, 102.16, 26.103, 162.2, 138.1)

Response: Reference conditions are defined in the glossary of both the plan and EIS. In short, 

reference conditions describe environmental conditions that infer ecological sustainability. 

Reference condition information is used to define restoration goals, determine the restoration 

potential of sites, and evaluate the success of restoration efforts. Reference conditions and desired 

conditions are not necessarily one and the same. The development of desired conditions was 

informed by reference conditions; however, there is no intention to recreate reference conditions. 

For example reference conditions for forest trees (spatial arrangements, densities, and 

composition) were used to develop desired ranges for management, but there is no intent to 

recreate exact historic patterns. Plan decisions provide the framework for restoration and 

movement towards desired conditions. The “Vegetation” section in chapter 3 of the EIS describes 

the ability of each alternative to move towards desired conditions within 50 years. For those 

potential natural vegetation types (PNVTs) modeled except spruce-fir forest, all alternatives, 

including the plan, would produce some movement toward desired conditions within the planning 

period.

Concern Statement: Disagree with the representation made in the DEIS (p. 138-139) that in 

wet mixed conifer and spruce-fir there is an overrepresentation of vegetation structural 

states that are lacking aspen regeneration due to elk browsing. (101.20)

Response: As noted in the Vegetation Specialist Report, vegetation state and transition models 

were developed for the vegetation analysis to compare current vegetation conditions (states) with 

desired conditions and to compare expected results from implementation of the forest plan 

alternatives. The wet mixed conifer and spruce-fir forest PNVTs each currently have 19 described 

vegetation structural states. Based on Smith’s (2006a and 2006b) literature reviews, stand 

structure for these two PNVTs was historically single storied, dense closed canopy, with a 

plurality of shade-tolerant trees, and with aspen regeneration where conifers were removed by 

fire, disease, etc., within their natural disturbance regimes. However, 11 of today’s 19 structural 

states do not reflect reference or the historic range of variability (HRV) conditions but rather 

reflect conditions on contemporary landscapes found only since Euro-American settlement.

Existing conditions relative to structural states for these two PNVTs were derived from data 

gathered during the Forests' mid-scale vegetation mapping project. From these data, tabular 

summaries of acreages and percentages within each state were generated for each PNVT. Today 

these two PNVTs exhibit structural states that are not part of the their HRV, because they exhibit 

one or more of the following characteristics: open canopies (states I, J, M, P, Q, R, S); multistoried (states J, M, O, Q, S); and/or are dominated by shade-intolerant or mixed shade-tolerant 

tree species (states I, J, L, M, N, O, Q, R, S). In addition, prior to the 2011 Wallow Fire, aspen 

regeneration was limited or lacking due to impacts of elk browsing (states K through S). The 

development of state and transitions models for the Apache-Sitgreaves NFs incorporated impacts 

of elk on aspen regeneration as documented prior to the 2011 Wallow Fire (Shepperd and 

Fairweather, 1994; Fairweather, 2008; U.S. Forest Service, 2009a; Rogers, 2009 and 2011; 

Beschta and Ripple, 2010; Lynch et al., 2010). However, this does not mean that all acres in these 

two PNVTs are lacking aspen as these two PNVTs also currently have eight vegetation structural 
Appendix A

638 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

states representing aspen (plan appendix B). These eight states (states A through H) are 

considered to be consistent with HRV and therefore, represent desired conditions.

Concern Statement: Explain how climate change can be an ecosystem component as stated 

in the background of Overall Ecosystem Health "Prior to 1850s, the Apache-Sitgreaves NFs 

ecosystems were considered to be resilient. ... Fire, disease, and climatic changes were 

natural components of these functioning ecosystems" (proposed plan p. 15). Climate is an 

influence on the system not an integral part of it. (102.33)

Response: The sentence has been corrected to read,

“Fire, disease, and weather variability were natural components of these functioning 

ecosystems.” 

Concern Statement: Clarify Overall Ecosystem Health desired conditions: (1) "Ecological 

components are resilient to disturbances including human activities and climate variability" 

(proposed plan p. 16). What is the meaning of 'resilient to disturbances'? (2) "Natural 

ecological processes...return to their innate role within the ecosystem" (proposed plan p. 16). 

Why and how can historical disturbances return to their natural role? (3) "Natural 

ecological processes allow for a shifting of plant communities, structure, and ages across the 

landscape. ... The mosaic of plant communities and the variety within the communities are 

resilient to disturbances" (proposed plan p. 17). What does this mean? (102.12, 108.107)

Response: These desired conditions have been clarified to read: 

(1) “Ecological components (e.g., soil, vegetation, water) are resilient to disturbances 

including human activities and natural ecological disturbances (e.g., climate variability, 

fire, drought, wind, insects, disease, pathogens).” 

(2) “Natural ecological disturbances return to their characteristic roles within the 

ecosystem. Wildfire, in particular, is restored to a more natural function.”

(3) “Natural ecological cycles (i.e., hydrologic, energy, nutrient) facilitate shifting of 

plant communities, structure, and ages across the landscape. Ecotone shifts are 

influenced at both the landscape and watershed scale by ecological processes. The 

mosaic of plant communities and the variety within the communities are resilient to 

disturbances.”

Also see the response to comment # 108.177 below.

Concern Statement: Clarify the meaning of resiliency. (108.177, 108.216)

Response: Resiliency is defined in the glossary of the plan and EIS. Resiliency is the ability of a 

social or ecological system to absorb disturbances while retaining the same basic structure and 

ways of functioning, the capacity for self-organization, and the capacity to adapt to stress and 

change.

Concern Statement: When the term “functioning” or "properly functioning" is used, does it 

not really mean that the system is desirable from the standpoint of sustaining the values 

people desire? Why not define desired vegetation as that which will provide sustainable 

resource outputs and values for human beings? (102.5)
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 639

Response: Desired conditions represent both ecological and socioeconomic sustainability. The 

vegetation desired conditions are worded in such a way as to describe those characteristics that 

will contribute to resilient ecosystems that sustain desired resource outputs and values. While 

people may have differing opinions about how vegetation might meet their desired outputs and 

values, the plan’s desired conditions are based on a synthesis of the best available science to 

provide those outputs and values, without degrading their sustained provision by the ecosystem.

Outputs and values of vegetation conditions for humans are incorporated throughout the plan, 

especially in the desired conditions and objectives stated in chapter 2 “Community-Forest 

Interactions” section (e.g., “Forest Products,” Special Uses,” “American Indian Rights and 

Interests,” “Livestock Grazing”), and the “Managed Recreation” section (e.g., “Motorized

Opportunities,” ”Nonmotorized Opportunities,” “Scenic Resources”); as well as in chapter 3 

“Management Area Direction,” and chapter 4 “Suitability.” Social and economic implications of 

the plan were analyzed in the EIS. Future projects and activities must be consistent with the plan

and various laws, and agency policy and direction to manage vegetation and natural resources for 

multiple uses, all of which provide resource outputs for human society either directly or 

indirectly.

Concern Statement: Explain potential natural vegetation type (PNVT) and, as a goal, if it 

meets the Forest Service mission or mandates. (152.12, 122.12)

Response: PNVTs are defined in the plan (“All PNVTs” section and glossary). In addition, 

PNVTs are explained in chapter 3 of the EIS under the affected environment in the “Vegetation” 

section and further analyzed under environmental consequences.

PNVTs are coarse-scale groupings of ecosystem types that share similar geography, vegetation, 

and historic ecosystem disturbances, such as fire, drought, and grazing by native species. PNVTs 

are only a means to define ecosystems and are not a “goal” in and of themselves. PNVTs 

represent the vegetation type and characteristics that would occur when natural disturbance 

regimes and biological processes prevail (Vander Lee et al., 2006). PNVT desired conditions 

describe vegetation states that are resilient to disturbances, including uncharacteristic fire, human 

activities, and climate variability. Wood products, forage, clean water, etc. would be byproducts 

from the implementation of plan objectives that would move the forests towards PNVT desired 

conditions.

Plan direction to maintain or move toward PNVT desired conditions are in alignment with the 

Forest Service mission to sustain the health, diversity, and productivity of the Nation’s forests and 

grasslands to meet the needs of present and future generations. They will also help the Forest 

Service meet the intent of Congressional mandates such as the Multiple Use-Sustained Yield Act 

of 1960 and the Healthy Forests Restoration Act of 2003.

Concern Statement: The plan seems heavy on dealing with trees but weak on other plant 

layers. (122.9)

Response: Other plant layers besides trees are addressed by the plan. A description of existing 

understory conditions was added to the plan in the background for the forested, woodland, and 

interior chaparral PNVTs. The plan also provides desired conditions for grasses, forbs, shrubs, 

native plants, and rare or unique plan communities in the “All PNVTs” section. Also, see the 

“Riparian,” “Invasive Species,” and “Grasslands” sections in chapter 2 for more plan direction for 

non-tree vegetation. Additions to plan appendix B (“Vegetation Conditions and Management 
Appendix A

640 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Practices”) were also made, see the bar graphs for each PNVT entitled “Herbaceous Understory 

Vegetation Conditions.”

Concern Statement: Use a "future range of variability" that accounts for foreseeable 

impacts of climate change and management effects in DEIS analysis and plan desired 

conditions. (162.3, 26.100)

Response: Reference conditions (based on the historic range of variation) and climate change 

were considered when determining the desired conditions. Reference conditions are considered a 

“best” estimate of a resilient and functioning ecosystem because they reflect the evolutionary and 

historical ecology of forests. Reference conditions are thereby a powerful template for improving 

the resiliency of fire-adapted forests. By restoring resiliency, current fire-adapted forests will be 

better able to adapt to climate change. Climate change is addressed throughout the plan: indirectly 

through desired conditions in the form of functional ecosystems and resilient landscapes and 

directly in management approaches and the monitoring strategy, where appropriate. Appendix A 

(“Climate Change Trends and Apache-Sitgreaves NFs Land Management Planning”) in the plan 

provides a comprehensive discussion of climate change trends and Apache-Sitgreaves NFs land 

management planning.

Concern Statement: The Forest Service should apply the full body of available science to 

describe possible trajectories of plant community succession after fire under the 

management objectives described for each alternative. (26.106)

Response: The plant communities (PNVTs) assume a range of structure, composition, and 

dynamics characteristic to the ecosystem, including that successional patterns in the natural 

disturbance processes are intact. This is reflected in the Vegetation Dynamics Development Tool 

(VDDT) model, which is a state and transition model that shows probabilistic and not 

deterministic transitions for succession. PNVTs are used primarily as a descriptor of a vegetation 

community, and do not imply management toward a vegetative end-state. The desired conditions 

describe the range of conditions that are desired for each PNVT. The state and transitions inputs 

into the model used for the Apache-Sitgreaves NFs plan analysis were built using peer-reviewed 

literature and the best available science, including the Forest Service Southwestern Region’s 

calibration of the VDDT model using the fire and fuels extension of the Forest Vegetation 

Simulator (FVS) model runs conducted for prescribed fire under low-, moderate-, and high 

severity burning conditions, as well as for different wildfire probabilities (Weisz et al., 2012)

Inputs for probability of occurrence under current management came from rates of treatment and 

known disturbances. The vegetation data on the distribution of states came from the mid-scale 

vegetation mapping assessment data provided by the Southwestern Regional Office following a

nationally consistent process. The indices developed for comparing alternatives relate to specific 

desired conditions.

Concern Statement: There should be a large tree retention alternative. (26.124, 26.121, 

26.123)

Response: Alternative D maximized this concept by including a standard to “Retain all large and 

old trees regardless of size or condition.” Environmental consequences of alternative D were 

analyzed and disclosed in the EIS, with greater detail addressed in specialist reports. Some 

consequences include the following: inability to restore forest interspaces, the need to manage for 

desired uneven-aged forest structure in many PNVTs, need to manage for desired tree species 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 641

composition, need to manage insects and diseases, need to remove hazard trees. The 

interdisciplinary team also considered a stricter version of this concept (see response to comment 

26.118 in the “Vegetation” section of this appendix) but dropped it from further consideration 

because of the following factors: (a) use of fire as a management tool cannot be controlled to 

guarantee protection of every large tree on every acre burned and (b) maintaining every large tree 

within the Community Forest Intermix Management Area is not consistent with the defensible 

desired conditions adjacent to private communities. (also see response to comment below).

Concern Statement: An alternative should maximize retention of existing large trees (>16-

inches diameter) outside of a wildland-urban intermix (“WUI”) zone that includes forest 

lands located one-quarter (1/4) mile distant from established residential and other essential 

community infrastructure. (26.117)

Response: This comment describes alternative D almost exactly, which emphasizes retention of 

all trees >16 inches diameter on all acres treated by cutting, except inside the Community-Forest 

Intermix Management Area where some trees over 16 inches could be cut to meet fire hazard 

reduction needs. Sixteen inches diameter was used as a proxy for both large trees and old trees in 

the vegetation modeling analysis, because tree/forest age is not a factor in the model (Vegetation 

Dynamics Development Tool). Alternative D maximized this concept by including a standard to

“Retain all large and old trees regardless of size or condition.” The environmental consequences 

of alternative D were analyzed and disclosed in the EIS as unsustainable. The Community-Forest 

Intermix Management Area serves the purpose of a wildland-urban interface zone that includes 

forest lands located one-half mile distant from established residential and other essential 

community infrastructure. Reducing this distance to a quarter of a mile would jeopardize the 

effective safety zone in which firefighters can aggressively defend community perimeters.

Concern Statement: There is no scientific basis for extracting large trees to promote fire 

resistance in ponderosa pine and mixed conifer forest. (26.120, 26.167)

Response: Fire resistance is not a stand-alone desired condition in the plan for these potential 

natural vegetation types (PNVTs). Restoration to ecological function, integrity, and resiliency 

against uncharacteristic fire and insect/disease outbreaks as well as other severe disturbances is 

one goal (supported by Reynolds et al., 2013) among many others addressed in the plan’s desired 

conditions for these forested PNVTs. 

The plan neither mandates nor prohibits removal of large trees. The majority of forest restoration 

scientists and land managers agree that an arbitrary “one-size-fits-all” restoration approach is not 

scientifically sound and a site specific approach is needed (Allen et al., 2002; Brown et al., 2004; 

DellaSala et al., 2004; Covington, 2000). The choice to retain all, or remove some, large trees 

from any particular project area would still reside with the project interdisciplinary team’s site 

specific analysis, as needed to move the area toward desired conditions including considerations 

for fire hazard, wildlife habitats, watershed stability, visual quality, and/or other multiple-use 

needs.

Removing some large trees may be needed on certain sites to move acres toward desired 

conditions for several ecological reasons: 

• In order to attain the desired condition to have uneven-aged forest structures, some trees 

larger than 16 inches in diameter at breast height need to be removed. Brown et al. (2004) 

discusses using the “percentile method” as an acceptable forest restoration approach 
Appendix A

642 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

which also happens to be a means of achieving uneven-aged forest structure. Studies 

(Abella et al., 2006; Triepke, et al. 2011) have shown that mandating the conservation of 

all trees greater than 16 inches in diameter creates the inability to develop or maintain 

uneven-aged forest structures. Retention of all trees greater than 16 inches in diameter 

obstructs establishment of ponderosa pine regeneration which would perpetuate evenaged forest structures in the ponderosa pine and dry mixed conifer PNVTs.

• Sites where understory trees are sufficiently large and dense, and/or have sufficiently 

large trees of less-fire-resistant species, that attempts to kill (thin) them with fire alone 

would run a high risk of also killing larger overstory trees near them (Brown et al., 2004; 

Allen et al., 2002; Arno and Fiedler, 2005; Fiedler et al., 2010). 

• Mid-seral stands that are developing old-growth characteristics but are too dense and thus 

may need some variable-density thinning to mimic a clumpy distribution that can enable 

the old growth development trend to continue (Brown et al., 2004). 

• Removal of insect-infested and/or disease-infected large trees within an area may be 

needed to help prevent outbreaks that would ultimately spread these damaging agents and 

destroy more large trees in the long-run. Widespread tree health decline and/or tree 

mortality in large numbers can contribute to abnormal fire behavior outside the natural 

fire regime for the ponderosa pine and dry mixed conifer PNVTs (Jenkins et al., 2014; 

Parker et al., 2006; Hoffman et al., 2007). 

• Agee and Skinner (2005) recommend after large trees have been left in the short-term, 

provision must be made in the longer term for sufficient spatial variation in age classes to 

provide for replacement of the larger trees as they die. This case may exist on portions of 

the Apache-Sitgreaves NFs, especially in wildland-urban interface areas where all or the 

vast majority of large trees were left in fuels reduction treatments. 

• All of the above reasons can be consistent with the localized need to reduce crown bulk 

density in the main canopy, and/or break up a continuous main canopy or continuous 

overstory of large trees in order to reduce crown fire spread potential, provided the 

resulting slash is treated effectively (Arno and Fiedler, 2005; Brown et al., 2004; Allen et 

al., 2002). Restoration of characteristic forest patterns (tree groups with interspaces, 

particularly in frequent fire forests) is key to restoring the low severity frequent fire 

regime on those acres (Abella, 2006; Reynolds et. al, 2013; Fiedler et al., 2010).

Concern Statement: An alternative should be analyzed in detail based on the Old Growth 

Protection and Large Tree Retention Strategy (OGPLTRS) collaboratively developed by the 

Four Forest Restoration Initiative (4FRI) public stakeholders, which could allow the plan to 

proceed with a lower risk of conflict. This should be a stand-alone action alternative based 

on the entire OGPLTRS as it was originally designed, or include it as a plan design feature 

common to all action alternatives. (26.118, 161.154, 161.76, 162.42)

Response: The plan’s interdisciplinary team considered the public stakeholders’ August 8, 2012 

revised final and approved “Old Growth Protection Large Tree Retention Strategy” (OGPLTRS) 

(4FRI Stakeholders’ Group, 2011a and 2011b) in its entirety, but recommended that it not be 

analyzed in detail. See the “Alternatives Considered but Eliminated from Detailed Study” section 

in chapter 2 of the EIS.

Although OGPLTRS does not dictate a universal upper cutting size limit (diameter cap); it does 

universally dictate keeping all pre-European-settlement (old) trees in all cases. The modeling 

tools used by Forest Service Southwestern Region and the Apache-Sitgreaves NFs for 

programmatic plan revision analysis (Forest Vegetation Simulator (FVS) and Vegetation 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 643

Dynamics Development Tool (VDDT) models) are not sensitive to the many fine-detailed facets 

of the stakeholders’ OGPLTRS. However, alternative D was developed to capture relatively the 

same concept for tree retention on mechanically treated lands, and was modeled using tree 

diameter as a proxy for tree age, with the results disclosed in the EIS (see the “Vegetation” 

section in chapter 3) and in the “Forest Products Specialist Report” (Forest Service, 2014c). The 

plan does not need to incorporate the OGPLTRS because it directs project managers to retain 

appropriate amounts of large/old trees and/or old growth. The following are just a few of the plan 

decisions that provide this guidance,

“Old growth is dynamic in nature and occurs in well-distributed patches that spatially 

shift across forest and woodland landscapes over time.” (desired condition in “All 

PNVTs”)

“Old or large trees, multistoried canopies, large coarse woody debris, and snags provide 

the structure, function, and associated vegetation composition as appropriate for each 

forested and woodland PNVT.” (desired condition in “All PNVTs”)

“Where current forests are lacking proportional representation of late seral states and 

species composition on a landscape scale, old growth characteristics should be retained 

or encouraged to the greatest extent possible within the scope of meeting other desired 

conditions (e.g., reduce impacts from insects and disease, reduce the threat of 

uncharacteristic wildfire).” (guideline in “All Forested PNVTs”)

“Treatments should leave single or small groups of medium to large trees that are widely 

spaced with expanses of herbaceous vegetation and coarse woody debris to provide for 

soil productivity, traditional uses (e.g., piñon nut gathering), and wildlife needs such as 

foraging habitat for migratory birds (e.g., black-throated gray warbler, pinyon jay) and 

other birds.” (guideline in “All Woodland PNVTs”)

Also see response to comments 26.124, 26.121, and 26.123.

Concern Statement: Due to past losses, forbid the harvest of all old trees and old growth. 

Preserve and encourage the recovery of old growth. (5.5, 9.5 14.4, 23.5, 99.32)

Response: The plan was developed using the best available science for restoration and 

management of the various forest and woodland PNVTs (see the analysis results and literature 

citations/bibliographies in the plan, EIS, and supporting plan record of documents.) Forest 

Service policy also requires interdisciplinary specialists to use the best available science for their 

analyses at the project-level, to inform the deciding official. 

The plan calls for managing old growth structural stages as a component of desired stand 

structure and arrangement (described in the PNVT desired conditions), as part of the ecosystem 

restoration/recovery effort. For example, in the ponderosa pine and dry mixed conifer forests, it is 

desired to manage for uneven-aged forest stands with a similar proportion of young-mid-old 

structural stages in small groups and patches throughout the stand. Every stand would be 

managed to have or develop these approximate structural stage proportions over time. But for 

infrequent fire forests (spruce-fir, wet mixed conifer), it is desired to manage for a landscape scale

mosaic of early, mid, and late seral stages. In these infrequent fire forests, stand scale old growth

structure is desired, but not for frequent fire forests (Reynolds et al., 2013). 
Appendix A

644 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

To attain the desired condition of uneven-aged forest structures and desired arrangement, some

old trees or old tree groups may need to be harvested. Studies (Abella et al., 2006; Triepke, 2011) 

have shown that a mandate to conserve all trees greater than 16 inches in diameter creates the 

inability to develop or maintain uneven-aged forest structures. A mandate which forbids cutting

trees of a certain age or size in all cases on all sites is not appropriate for a programmatic land 

management plan. While recognizing that maximum harvest age or size may be useful or 

appropriate in isolated or site specific cases to move toward certain vegetation desired conditions, 

the plan neither dictates nor prohibits the use of any maximum harvest age, age class, diameter 

limit, or size class. A project level decision to implement management that would move the 

existing forest/woodland conditions away from the plan’s desired conditions (either by reducing 

too many old trees or old growth, or by retaining too many) would be required to provide 

defensible rationale for a project specific amendment to the plan.

Concern Statement: Preserve and encourage the recovery of old growth. (94.5, 33.3, 3.15)

Response: The plan defines “old growth,” “old growth components,” and “old tree” according to 

the best available science on this topic for southwestern ecosystems. Old trees (see Keen’s tree 

class number 4 in appendix B under “Age Classes Typically Occurring on the Apache-Sitgreaves 

NFs”) are one component of old growth. 

Large trees were removed in past timber sales. But many old growth acres set aside for protection 

from logging under the 1987 plan have subsequently been lost in large stand-replacement 

wildfires, notably the Rodeo-Chediski and Wallow Fires (ERI, 2011).

Many sections of the plan (see those listed in the response to comment # 26.118 in the 

“Vegetation” section of this appendix) provide numerous desired conditions, standards, and 

guidelines as direction for future management of old growth and its components, regardless of 

historical events. Project-level analysis and designs for restoration would need to comply with 

that plan direction. In addition to retaining characteristic amounts of existing large trees combined 

with other old growth components, maximizing vigor and growth of younger trees into older age 

classes is equally essential to promote old growth development across the landscape over time. In 

general, restoring forest health and natural processes to prevent further losses, and focusing on 

uneven-aged management for future development of more late-seral forest stages, should 

encourage recovery of old growth. Also see responses to comment numbers 21.1, 26.124, 26.117, 

26.120, 26.118, 5.5, 26.112, 162.5, 26.189, and 26.111 in the “Vegetation” section of this 

appendix.

Concern Statement: The plan should include standards and guidelines that require 

assessment and designation of old growth habitat at site, watershed, and ecosystem scales, 

and allow management treatments within identified old growth only to enhance old growth 

characteristics, such as primary ecological functions mediated by fire. Standards and 

guidelines should specifically address the problem of fragmentation of old growth habitat 

and apply spatially- explicit analysis demonstrating that functional old growth ecosystems 

will be sustained over time under any chosen management alternative. (26.112, 26.113, 

162.41, 26.115)

Response: The plan’s desired conditions were developed to provide for a flow of old-growth 

conditions and function over time at the fine, mid, and landscape scales, which roughly 

approximate the site, watershed, and ecosystem scales. Ecological functions mediated by fire and 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 645

other historic disturbances include the presence of coarse woody debris, downed logs, snags, 

vertical canopy diversity, as well as distributions of large/old/decadent trees. The desired 

conditions provide for the presence of these characteristics, as well as spatial shifting or transition 

of old growth on the landscape over time, consistent with reference conditions. Where existing 

conditions differ from desired conditions, there is a need for change. Finer, more spatially explicit 

direction is determined at the project-level. 

In southwestern frequent fire forests, old growth is naturally fragmented, and occurs as tree 

groups, clumps, individual trees, and occasional patches in an unevenaged forest landscape 

(Reynolds et al., 2013). The fragmentation concept is not applicable for frequent-fire forests in 

the Southwest; it is applicable to infrequent-fire forest ecosystems where large blocks of evenaged old growth develops and persists over long periods of time (e.g., coastal Douglas-fir or highelevation spruce-fir), based on the ecology of those forests. For the spruce-fir/wet mixed conifer 

forest, the plan has a desired condition at the landscape scale that old growth occurs over larger 

areas as large patches, stands, or forests. 

The plan does specify a desired condition for old growth throughout the landscape that shifts 

location over time as a result of succession and disturbance in ponderosa pine and dry mixed 

conifer. An intensely intermixed variety of age classes (i.e., fragmentation) is natural and 

therefore desired in these frequent fire forest types. Thus, designation of old growth stands or 

larger-scale areas is not consistent with the frequent fire forest desired condition to have old 

growth as a proportional component within every uneven-aged stand.

Also see responses to comments 21.1, 26.124, 26.117, 26.120, 26.118, 5.5, 162.5, 26.189, and 

26.111 in the “General Comments” and “Vegetation” sections of this appendix.

Concern Statement: The EIS should provide a scaled analysis of the current status and 

projected future structure, composition, extent and distribution of old growth and compare 

effects of alternatives. (162.40, 26.110)

Response: Old growth is addressed as a component of vegetation structure within each forested, 

riparian forested, and woodland potential natural vegetation type (PNVT), which includes size 

and age classes and specific habitat features (i.e., old trees, dead trees (snags), downed wood 

(coarse woody debris)) rather than old growth as a unique vegetation type of its own. The scale in 

which old forest structure develops differs by the ecology of each forest type. For frequent fire 

forest types, old forest structure characteristically develops at the fine scale (sub-stand), and 

infrequently at the midscale (stand scale). For infrequent fire forest types, old forest structure 

characteristically develops as mid-scale patches (stand scale), patterned in the footprints of 

previous high-severity fires. 

Analyses on the components of vegetation structure using the Vegetation Dynamics Development 

Tool (VDDT) model did make this comparison by alternative for current and future timeframes in 

the “Vegetation” section of the EIS. Vegetation structural states representing late developmental 

or “climax” forest for each PNVT were modeled. Some old trees and other old growth 

components are also included at the fine scale within the younger structural states modeled in 

VDDT. This analysis was conducted at the forestwide level, which includes aggregations of all 

three scales set forth in the plan. A more detailed analysis of existing old growth is not required. 

During plan implementation and project design the Apache-Sitgreaves NFs conducts analyses 

using a variety of sources of forest succession and vegetation structural data that inform and 
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646 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

consider the existing spatial extent, distribution, and structural qualities of old growth at different 

scales when comparing existing conditions to desired conditions. Also see response to comment

26.112 in the “Vegetation” section of this appendix.

Concern Statement: Preserve old growth forest to mitigate effects of climate change. (162.5, 

26.159)

Response: Forest carbon storage to mitigate climate change is optimized through a number of 

strategies depending on the PNVT. In some PNVTs carbon may be concentrated in late 

succession stands; and in other PNVTs, such as all-aged systems, carbon storage is maximized 

within stands relative to the resistance of the system from losses to fire, insects, and disease. Old 

growth stores carbon in the large trees, snags, logs, coarse woody debris, roots, and organic soil 

reserves. Some stands within spruce-fir and wet mixed conifer will reach old growth status, when 

a number of the large trees are in decline thus, only hold the carbon currently in their tissues or 

begin releasing some carbon through decay. Sequestration of additional large amounts of carbon 

from the atmosphere is performed by healthy, vigorously growing trees which absorb carbon 

dioxide and produce oxygen during consistently high rates of photosynthesis and respiration. It is 

recognized that herbaceous vegetation also serves the same function. 

Thinning trees within and around old growth forest structure can reduce competition for limited 

resources, and thus, enable some level of continued carbon sequestration. Restoring natural 

processes that enabled old growth to develop will help maintain old growth on the landscape. 

Reducing risk of stand-replacement wildfire in frequent fire forest types will also help retain old 

growth and reduce massive carbon emissions should it burn severely. Large trees and old growth 

cannot be “preserved” in perpetuity because they are not static in permanent locations; they must 

be constantly shifting across the landscape with replacements in early- and mid-developmental 

stages concurrently moving toward climax or late-development stages. This ongoing replacement 

process usually takes many decades to centuries for completion before repeating again on the 

same acres. It is important to permit this process to complete the cycle and begin again, at the tree 

group and/or stand scale (see old growth “scale” response to comments 162.40 and 26.110). The 

plan provides extensive direction to maintain adequate proportions of old growth in balance with 

younger, healthier forest and herbaceous vegetation, which can help to mitigate climate change. 

Also see responses to comments 21.1, 26.124, 26.117, 26.120, 26.118, 5.5, 26.189, and 26.111 in 

the “General Comments” and “Vegetation” sections of this appendix. 

Concern Statement: Removal of large, mature or old growth trees may constitute an 

irretrievable commitment of resources. (26.189)

Response: Irretrievable is a term that applies to the loss of production, harvest, or use of natural 

resources (Forest Service Handbook 1909.15). These opportunities for use are those lost for a 

period, but could be regained, such as younger trees growing into older trees. The plan would 

allow the removal of some large, mature, and old trees as needed to restore forest conditions 

toward those similar to natural conditions, which would improve resiliency and the evolutionary 

environment of these forests, providing the best opportunity for trees of all age classes to persist 

and adapt to future climates (Reynolds et al., 2013).

Yet, because the plan does not directly authorize or mandate any site specific project or activity 

(including ground-disturbing actions like tree cutting), the plan cannot cause an irretrievable 

commitment of resources. Future project-level decisions under the plan may result in potential 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 647

irretrievable commitments of resources, which would be disclosed accordingly with each project 

site specific analysis. This distinction is clearly stated in the EIS, and in the “Forest Products 

Specialist Report” (Forest Service, 2014c), “Vegetation Specialist Report” (Forest Service, 

2014g), and “Forest Health Specialist Report” (Forest Service, 2014b).

Concern Statement: Clarify the All PNVT desired conditions and guidelines (e.g., “...reduce 

potential for damage to residual vegetation in order to prevent premature or excessive 

mortality”, “landscape scale restoration projects should be designed to spread out 

treatments...”, “restoration methods...should leave a mosaic of undisturbed areas...”, fire 

“may be used to meet desired resource conditions...”) by removing conflicting program 

direction (fire program direction versus direction for soil, watershed, wildlife, and other 

resource programs). (108.184, 108.183)

Response: The desired conditions and guidelines have been developed in an interdisciplinary 

process to minimize conflicting direction. Desired conditions describe the desired outcomes for a 

particular resource (e.g., watershed, soil, wildlife, individual potential natural vegetation types 

(PNVTs)). A new section entitled “Wildland Fire Management” has been added to the plan to 

better clarify the forests’ management approach for wildland fire.

How and when individual projects are applied within a landscape would be evaluated during the 

project-level NEPA analysis. Treatments (e.g., burning, thinning) are commonly applied in 

mosaic patterns to meet the needs of the vegetative communities and desired conditions.

Additionally, the use of fire can help to achieve a mosaic pattern within the landscape because 

fire rarely carries the same severity and intensity through an entire project area.

Although some plan decisions (e.g., “reduce potential for damage to residual vegetation”) may 

seem to conflict with the forests’ intent to use fire as a tool, they do not because fire has played an 

important ecological role in shaping the vegetation on the Apache-Sitgreaves NFs. The PNVTs 

are adapted to recurring wildfires started by lightning from spring and early summer 

thunderstorms. A primary emphasis area for the plan is to manage for desired fire regimes and 

restore fire to a more natural role as one of the forests’ primary disturbance agents. The use of fire 

is a tool to help maintain or move towards desired conditions similar to a mechanical treatment or 

a fish barrier. When using fire as a tool, managers design their burning activities based on 

constraints described in the standards and guidelines and to maintain or move towards desired 

conditions.

Concern Statement: Since climate change is a major factor that determines stand density 

and species composition, explain the meaning of the All PNVT desired condition, "Stand 

densities and species compositions are such that vegetation conditions are resilient under a 

variety of potential future climates" (proposed plan p. 29). (102.10)

Response: Effects of climate change upon vegetation conditions were addressed in various 

sections of the EIS. To the extent that existing native species have evolved under various climatic 

conditions over geologic time, it is likely that there are some species better suited to survive 

and/or adapt to whatever climate change occurs.

This desired condition means the vegetation conditions (vegetation species and diverse genetic 

phenotypes within each species, critical symbiotic relationships with other species, structural 

arrangement, function, and natural disturbance patterns) are intact, healthy, and functional as 

much as possible to enable forest and woodland vegetation to retain their capability to survive 
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648 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

and/or adapt to potential future climate changes. Structural arrangement, such as stand density, 

needs to be suited to the desired tree species’ needs (shade-tolerant or shade-intolerant, fireadapted or non-fire-adapted, etc.). Desired conditions are described at three scales (fine, mid, and 

landscape). The mid-scale (100 to 1,000 acres) is roughly equivalent to stand size. See definition 

of “stand” in the plan’s glossary.

Concern Statement: Modify All PNVTs Desired Condition (proposed plan p. 29) "Herbivory 

is in balance with available forage (i.e., grazing and browsing by authorized and 

unauthorized livestock, wild horses, feral horses and hogs, and wildlife do not exceed 

available forage production within established use levels)." (101.47)

Response: The desired condition was not modified. The intent of this desired condition is to 

manage allowable use levels for livestock authorized under a permit and wild horses in 

consideration of wildlife needs. A definition for feral horses was added to the glossary to help 

reduce confusion with the term “wild horses.” Feral hogs fall under the definition for 

unauthorized livestock. 

Concern Statement: Add a desired condition to All PNVTs (proposed plan p. 29) "The A-S 

is free of unauthorized, feral, and trespass livestock." There is concern over the negative 

impacts of unauthorized, feral, and trespass livestock on wildlife habitat. (101.48)

Response: Unauthorized livestock (including feral and trespass) are prohibited on National 

Forest System land by regulation (36 CFR 261.7). There is not a need to repeat existing law and 

regulations in the plan. The plan does provide direction to manage plants and animals that do, or 

have the potential to do, ecological or economic harm in the “Invasive Species” section of the 

plan in chapter 2. The Forest Service added a discussion about feral horses within this section. A 

definition for feral horses was added to the glossary of the plan.

Concern Statement: Modify All PNVTs Desired Condition (proposed plan p. 30) 

"Herbaceous vegetation amount and structure (e.g. plant density, height, litter, seed heads) 

provides habitat to support wildlife, including prey species." (101.49)

Response: The desired condition under the “All PNVTs” section of the plan has been modified as 

suggested above for completeness.

Concern Statement: Stress the need and intent to focus mechanical thinning efforts on the 

overabundant small diameter trees within the forested vegetation types. (101.23)

Response: The suggested further emphasis is not needed. Departure indices stated in the plan’s 

“Background” section for each different forested PNVT describe which size classes are in excess 

of desired. Vegetation bar graphs in plan appendix B (“Vegetation Conditions and Management 

Practices”) display the disproportionate excesses of small size class states with respect to desired 

levels across the Apache-Sitgreaves NFs. The commenter’s stressed need may be the case on 

many forested acres, but not necessarily on all. The site specific excesses or deficits of certain 

tree size classes must be determined for each project area by the project interdisciplinary team, 

with respect to moving that area toward desired conditions. The plan’s desired conditions 

emphasis for having uneven-aged forest structure on the majority of forested PNVT acres is key 

direction to ensure that the correct proportions of small to medium to large diameter trees will 

occupy most acres treated mechanically.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 649

Concern Statement: Appropriate tree stocking levels should be maintained on suitable 

timberlands regardless of whether the land is treated by mechanized harvest or by fire. 

Apply to fire the All Forested PNVTs standard "On lands suitable for timber production, 

timber harvest activities shall only be used when there is reasonable assurance of restocking 

within 5 years after final regeneration harvest ..." (proposed plan p. 36). (108.187)

Response: This standard is included in accord with the provisions of the 1982 Planning Rule (§ 

219.27 (b)(2) and (c)(3)) for legal compliance with the National Forest Management Act. It 

generally applies to “final regeneration harvest” cuts which are implemented with the intent of 

creating a new generation of tree seedlings. The intended use of wildland fire as a management 

tool often is not to create a new generation of trees. However, in response to this comment, this 

plan standard has been modified with added text to now read:

“On lands suitable for timber production, timber harvest activities shall only be used 

when there is reasonable assurance of restocking within 5 years after final regeneration 

harvest. This also applies where wildland fire is used to create openings for tree 

regeneration purposes on suitable timberlands. Restocking level is prescribed in a site

specific silviculture prescription for a project treatment unit and is determined to be 

adequate depending on the objectives and desired conditions for the plan area. In some 

instances, such as when lands are harvested or prescribed burned to create openings for 

firebreaks and vistas or to prevent encroaching trees, it is appropriate not to restock.”

For consistency, the thirteenth monitoring question of the plan’s “Monitoring Strategy” (chapter 

5) was revised to now read:

“Are forest and woodland stands adequately restocked within 5 years of final harvest 

treatment or after fire-created regeneration openings?”

Furthermore, Forest Service Manual 2400, Chapter 2470 requires reforestation tracking that 

ensures each area deforested or understocked by natural causes, fire, or harvest is planned for 

either reforestation treatment or natural regeneration, or a mix of both. Lands planned for 

artificial and/or natural recovery are tracked until they are certified as stocked. Chapter 2490 

requires a reforestation needs assessment to be done immediately following fires or other natural 

disasters on both suitable and non-suitable timberlands.

Concern Statement: Clarify the Spruce-Fir desired condition “The wildland-urban 

interface (WUI) is comprised primarily of grass/forb/shrub vegetation. Structures in the 

WUI are surrounded by grassy openings with very few or no trees. These conditions result 

in ground fires.” (proposed plan p. 48). If there are no WUIs in spruce-fir, this desired 

condition should be removed. (99.2)

Response: The Apache-Sitgreaves NFs contain over 3,000 acres of spruce-fir forest potential 

natural vegetation type (PNVT) in WUI areas (including areas within the Apache County and 

Greenlee County Community Wildfire Protection Plans) on the Alpine and Springerville Ranger 

Districts. 

The desired condition stated in this comment reflects the characteristics of the primary species in 

this forest type, which are shade-tolerant and not wind-firm. Thus, thinning them to the degree 

needed for WUI fuels reduction objectives would not be sound silviculture. Likewise, this desired 

condition is needed because leaving spruce-fir stands or large groups in a densely-stocked 
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650 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

condition for the shade and wind-firmness these species require is inconsistent with WUI fire 

hazard reduction objectives directly next to structures.

Concern Statement: Increase the targeted acreage of aspen forests (proposed plan p. 50). 

(162.83)

Response: The plan’s objective is for maintaining no less than 50,000 acres of aspen on the 

Apache-Sitgreaves NFs (which is the general historic level of aspen on the forests); it does not set 

that as the upper limit of aspen occurrence.

Concern Statement: Modify the Aspen guideline, “To preclude concentrated herbivore 

impacts, new surface water development should not be constructed within proximity to 

aspen stands (approximately 1⁄4 mile)” (proposed plan p. 50) by increasing the distance to 

several miles. (162.84)

Response: The guideline has not been modified based on this comment. The interdisciplinary

team considered other distances for this guideline. However, one-quarter mile was chosen for the 

following reasons. Where aspen normally occurs, surface water developments are usually located 

to draw herbivorous livestock and wildlife away from pressuring riparian areas. The plan’s 

objective is to maintain 50,000 acres or more of aspen on the Apache-Sitgreaves NFs. The 

existing aspen acreage comprises numerous small, dispersed aspen clones, many of which are 

within one-half mile of each other, and/or within one-half mile of riparian areas. Setting a 

distance greater than one-quarter mile up to several miles away from one aspen clone becomes a 

self-defeating exercise by forcing that water development to automatically be located too close to 

another aspen clone or riparian area. 

Concern Statement: Add a guideline to restore large predator populations, in particular 

wolves, to restore healthy aspen stands. (162.85)

Response: This comment is outside the scope of the plan. Wildlife populations are managed by 

the state of Arizona (Arizona Game and Fish Department). The plan does include a management 

approach in the “Forests: Aspen” section which says, 

“The forests work with the AZGFD to address concerns about aspen reestablishment in 

both the short and long term.”

Concern Statement: In the background for Forests: Aspen (Proposed Plan, page 49), add 

lack of large predators and ungulate browsing as causal agents behind aspen decline. 

(162.88)

Response: The suggested plan addition has not been made. Ungulate browsing effects are already 

addressed in the plan’s aspen section and in the EIS (“Vegetation” and “Forest Health” sections in 

chapter 3) as contributors to aspen decline. While there may be a potential link demonstrated 

between large predators and ungulate browsing on aspen in Yellowstone National Park (Ripple 

and Beschta, 2011), this has not yet been demonstrated on the Apache-Sitgreaves NFs (Beschta 

and Ripple, 2010). Predators are only one means by which ungulate numbers, locations and/or 

timing impacts on aspen could be controlled (Eisenberg et al., 2013) but management of predators 

and wild ungulates is beyond the scope of the plan and is the responsibility of the Arizona Game 

and Fish Department. Also see the response to comments 101.20 and 101.19.
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Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 651

Concern Statement: What is meant by "overmature" aspen clones in the second guideline 

"Restoration of aspen clones should occur where aspen is overmature or in decline to 

maintain a sustainable presence of this species at the landscape level" (proposed plan p.50)? 

Large, old aspen should not be removed to make way for small aspen, since small aspen are 

harder to protect from browsing and therefore difficult to keep alive. Maintaining mature 

aspen will ensure that there is a live root stock in soils to create new suckers after 

disturbance events. Please clarify this guideline so that it does not suggest the removal of 

“overmature” aspen. (162.87)

Response: Trees which are determined to be “overmature” are those which will soon lose their 

ability to reproduce successfully. The ultimate biological age at which any tree species can lose 

its vigor and ability to reproduce successfully, is just one of several considerations used for proper 

management of that tree species. This age can vary from one aspen stand or clone to another 

based on several factors, such as site quality, tree or clonal health/insect/disease issues, genetic 

phenotype, root carbohydrate reserve levels, time since origin and disturbance, and ability to 

reproduce vegetatively versus sexually. Overmature aspen are generally those which have lost 

their hormonal chemistry and vigor that give them the ability to stimulate new vegetative suckers 

in response to aspen tree mortality. 

Removing overmature aspen trees (either by cutting, girdling, or burning) is a standard practice 

used to stimulate clonal root sucker production (DeByle and Winokur, 1985). The 1987 plan sets 

this age class at 80 to100 years. The revised plan does not define a set age for aspen overmaturity in recognition of the above variables. Instead, it leaves this site specific determination to 

be made by a qualified specialist during project-level analysis, using site and clonal conditions 

with best science available at the time. Maintaining mature aspen is desired. Removal of over 

mature aspen is precisely the intent of this plan guideline to regenerate this species where needed 

for maintaining it on the landscape. Therefore this guideline will not be changed. 

The concern regarding protecting small aspen from ungulate browsing damage is addressed in the 

plan’s “Forests: Aspen” section through the following:

“Areas of aspen occur across the forested landscape and are successfully regenerating 

and being recruited into older and larger size classes. Size classes have a natural 

distribution, with the greatest number of stems in the smaller size classes.” (Desired 

Condition)

“Aspen restoration and retention efforts should include measures to ensure viability of 

the aspen stand.”(Guideline)

“Management activities that kill or stress overstory trees (e.g., clearcutting, fire) may be 

used since they mimic natural disturbances and enhance aspen regeneration. Aspen 

restoration efforts may include providing/improving substitute forage away from aspen, 

removing conifer competition, fencing to exclude ungulates, and range management 

practices (e.g., salt locations;, herding; timing, intensity, frequency, and duration of 

livestock use). (Management Approaches)

In addition, the plan’s “Livestock Grazing” section contains the guideline that reads, in part, 

“Salt or nutritional supplements should also be located to minimize herbivory impacts to 

aspen clones.”
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652 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: There is a need for further research and monitoring to improve 

understanding of the complex relationship among aspen and other factors and to support 

development of management responses. (101.19, 102.38)

Response: The best available science on aspen physiology, silvics, management, and recent 

contributors to aspen decline have been consulted and discussed in the EIS analyses, as well as 

direction provided in the plan for aspen as an ecological indicator. The “Research Needs” section 

of appendix B (“Description of the Analysis Process”) identifies the aspen topic as a need for 

additional research. In recognition of this need for more information and adaptive management, 

the plan recommends the new Corduroy Research Natural Area be established on the Alpine 

Ranger District to provide researchers a controlled aspen area for study under various 

management actions and climate trends. The plan’s “Monitoring Strategy” in chapter 5 also 

includes aspen data collection as a plan ecological indicator.

The responsibility to conduct and publish research is held by the research branch of the Forest 

Service, often in cooperation with accredited universities (Forest Service Manual 1400). The 

executive branch of the agency charged with administering national forest lands may assist 

researchers, but is usually limited to conducting monitoring and issuing permits for formal 

research projects.

Concern Statement: Aspen and willow recovery should be described as a forest health issue 

and not attributed to herbivory alone. (109.23, 109.24)

Response: The added descriptions requested are not needed. Aspen health and recovery with 

respect to numerous factors (in addition to herbivory) are already summarized in the plan (see the 

“Forests: Aspen Background” section in chapter 2). The plan’s desired conditions, guidelines, and 

management approaches sections further provide direction to address other aspen management 

issues not caused by ungulates. The existing condition of aspen (affected environment) is also 

summarized in the EIS “Forest Health” section in chapter 3, wherein multiple factors affecting 

aspen health are discussed. Effects of management direction in alternative B (the plan) upon 

aspen health and function in the ecosystem are fully disclosed in the EIS. Also see the response to 

comment numbers 101.20 and 162.88 in the “Vegetation” section of this appendix.

The plan lists three riparian forested PNVTs in which willows are found. The plan’s background 

for the “Riparian Areas” section in chapter 2 states that water diversions for agriculture, several 

changes in watershed condition due to various factors, and drought are also responsible for

willow community declines, in addition to past grazing impacts.

Concern Statement: Large old piñons should be preserved and not cut during restoration, 

habitat, or structural treatments. This should be reflected in the All Woodland PNVTs 

objectives and guidelines. (162.90, 162.89)

Response: The requested additions are not needed. The “All Woodlands” section, a guideline for 

All Woodland PNVTs which includes large native trees was modified to clarify wildlife needs, 

and now reads: 

“Treatments should leave single or small groups of medium to large native trees that are 

widely spaced with expanses of herbaceous vegetation and coarse woody debris to 

provide for soil productivity, traditional uses (e.g., piñon nut gathering), and wildlife 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 653

needs such as foraging habitat for migratory birds (e.g., black-throated gray warbler, 

pinyon jay) and other birds.”

Because piñon pines typically grow on poorer sites and thus grow very slowly with narrow 

annual growth rings, leaving large diameter trees usually equates with old trees. 

Concern Statement: The need for some closed condition woodlands should be reflected in 

the All Woodland PNVT guidelines. (162.91)

Response: The requested guideline has not been added. The desired conditions for woodlands by 

density class (canopy cover used as a proxy) differ somewhat by each woodland potential natural 

vegetation type (PNVT). Desired closed canopy conditions for woodlands have been defined for 

seedling and sapling sized trees (state E), small sized trees (state F), and medium to very large 

sized trees (state G). Desired percentages of closed canopy woodlands consisting of various tree 

size classes can be found in the “Vegetation Conditions and Management Practices” portion of 

appendix B of the plan for both woodland PNVTs. An existing “All Woodlands” guideline 

partially address this concern; it states, 

“Hiding cover, approach cover (by waters), and travel corridor cover should be provided 

where needed by wildlife.” 

In addition, the plan includes a desired condition for the “Piñon-Juniper-Persistent Woodland” 

which states, 

“Tree canopy cover is closed (greater than 30 percent)...”

However, closed canopy is not a desired condition for the piñon-juniper–savanna woodland fire 

regime (Margolis, 2014), and thus, such an addition to the “All Woodlands” section is not 

appropriate. 

Concern Statement: Clarify the statement in background for Woodlands: Piñon-Juniper, 

“There are too many medium to very large trees with open canopies... and small to medium 

size trees with open or closed canopies.” (proposed plan p. 54) How can it be true that all of 

these conditions are simultaneously overrepresented? (162.92)

Response: The wording has been updated to read:

“When compared to desired conditions, there are too many medium to very large trees 

with open and/or closed canopies. While there are too few seedlings, saplings, and small 

trees with open and/or closed canopies, understory vegetation is lacking in many areas.”

The size classes “medium to very large trees” and “small trees” are distinct size classes. The 

terminology may be slightly confusing; however, these are defined in the appendix B 

(“Vegetation Conditions and Management Practices”) of the plan.

Concern Statement: Clarify whether piñon-juniper woodland refers only to those areas

where piñon-juniper occurred historically. (108.219, 108.233)

Response: The piñon-juniper woodland potential natural vegetation type (PNVT) refers to the 

historic extent of piñon-juniper based on analysis by The Nature Conservancy (Vander-Lee et al., 
Appendix A

654 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

2006) and further refinement of the Apache-Sitgreaves NFs terrestrial ecosystem survey (TES). 

The background of the “Woodlands: Piñon-Juniper” section of the plan explains,

“many areas that appear to be piñon-woodland are actually Great Basin grassland that 

has been encroached by woody species.” 

Concern Statement: Modify Piñon-Juniper Savanna Desired Condition (proposed plan p.

54) " Scattered shrubs and a continuous herbaceous understory, including native grasses,

forbs, and annuals, are present to support a natural fire regime and provide for wildlife 

needs." (101.54)

Response: The desired condition was not modified. Wildlife needs are provided for in other 

desired conditions, objectives, standards, and guidelines throughout the plan.

Concern Statement: Modify Piñon-Juniper - Persistent Woodland Desired Condition 

(proposed plan p. 54) "Grass and forb cover is maximized, based on site capability, to 

protect and enrich soils and provide for wildlife needs." (101.55)

Response: The desired condition was not modified. Wildlife needs are provided for in other 

desired conditions, objectives, standards, and guidelines throughout the plan.

Concern Statement: Adopt desired condition wording from the Kaibab NF draft plan 

“Understory composition is within the natural range of variation and contains diverse 

native herbaceous plant species that provide nutrition for pronghorn and other species. 

Depending on soil type, ground cover typically averages 50% live vegetation and 50% 

nonliving vegetation, with vegetation composition averaging 40 to 60 percent grass, 10 – 30 

percent forbs and 5 to 15 percent shrub.” (132.34)

Response: The suggested desired condition was not added to the plan. The desired levels of 

ground cover are addressed in desired condition in the “All PNVTs” and “Soils” sections relative 

to soil protection, erosion, water infiltration, and the ability to carry frequent fire and provide 

wildlife habitat, 

“Soils provide for diverse native plant species1

. Vegetative ground cover (herbaceous 

vegetation and litter) is distributed evenly across the soil surface to promote nutrient 

cycling, water infiltration, and maintain natural fire regimes” (Soils)

“Vegetative ground cover (herbaceous vegetation and litter) is optimized to protect and 

enrich soils and promote water infiltration.” (All PNVTs)

In addition, a fine scale desired condition in the “Grasslands” section of the plan more 

specifically addresses vegetation cover for grasslands.

“Average herbaceous vegetation heights2 vary by grassland PNVT and yearly weather 

conditions. Ungrazed herbaceous vegetation heights3 range from 7 to 29 inches in Great 

 1 Species composition and cover amounts and the amount of vegetation and litter needed for soil protection are 

described by ecological unit in the “Terrestrial Ecosystem Survey for the Apache-Sitgreaves National Forests” (Laing 

et al., 1987, as amended).

2 Measured on ungrazed plants as an indicator of vigor.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 655

Basin grasslands, 7 to 26 inches in montane/subalpine grasslands, and 10 to 32 inches in 

semi-desert grasslands.” (grasslands)

Other desired conditions that provide for vegetative ground cover are included in the “Soils,” “All 

PNVTs,” and “Riparian Areas” sections.

In addition, a standard was added to the “All PNVTs” section to maintain or move plant 

composition towards a moderate to high plant community similarity as compared to site potential.

Concern Statement: Modify Grasslands Desired Condition (proposed plan p. 56)

“Herbaceous vegetation and litter provides for and maintains the natural fire regime (fire 

regime I)..." (101.56)

Response: The grassland desired condition “Litter provides for and maintains the natural fire 

regime (fire regime I and II)” was modified to read,

“Herbaceous vegetation and litter provide for and maintain the natural fire regime (fire 

regime I and II).”

Concern Statement: Clarify the Grasslands desired condition "Prairie dogs are present and 

support healthy grassland soil development and the diversity of other species associated 

with them such as the western burrowing owl" (proposed plan p. 56). Concern that prairie 

dogs will create areas that do not meet the cover and height guidelines and will have a very 

low similarity index (proposed plan p. 57). (102.41, 131.20, 108.234, 108.155, 123.21, 102.59)

Response: Desired conditions are described at various scales reflecting appropriate ecological 

structure, function, and processes. To reflect that healthy grasslands are not fully occupied by 

prairie dog colonies, the desired condition has been moved from the landscape to the midscale 

level. Desired ungrazed herbaceous vegetation heights have been clarified and as a fine scale

desired condition these are not expected to occur across the landscape. 

Concern Statement: Clarify the Grasslands desired condition, "The extent, abundance, 

cover and composition of grasslands is maintained or reestablished and moving closer to 

reference conditions" (proposed plan p. 56). What does "abundance" of grasslands mean? 

(102.42, 108.156, 138.45)

Response: This desired condition statement was rewritten for clarification. The plan’s use of 

“abundance” is consistent with the traditional definition, which may be found in any standard 

dictionary.

Concern Statement: Clarify the Grassland desired conditions and guidelines by removing 

conflicting program direction with fire. (108.188)

Response: The plan has been developed in an interdisciplinary process to minimize conflicting 

direction. No conflicts between the desired conditions for grasslands and the management 

 3 Plant height source material: Vine 1960; Hermann 1970, 1975; Hitchcock and Chase 1971; McDougall 1973; Correll 

and Correll 1975; Gould 1977; Martin and Hutchins 1980; Benson and Darrow 1981; Hickman 1993; Cronquist et al. 

1997; Ruyle and Young 1997; Welsh et al. 1997; Hurd et al. 1998; Barkworth et al. 2003, 2007; Flora of North 

America 2008; and Springer et al. 2009. See the plan for reference citations.
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656 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

direction for fire have been identified. As noted in the background of the “Grasslands” section in 

chapter 2 of the plan, 

“fire plays a key role in the maintenance of the forests grasslands.”

Prescribed fires and managed wildfires used to meet desired conditions would be mitigated for 

the protection of vegetation at the project-level.

Concern Statement: Explain, modify, or remove the Grasslands desired conditions: “The 

extent, abundance, cover, and composition of grasslands is maintained or reestablished and 

moving closer to reference conditions. Ground cover is 35 percent or greater and 

herbaceous vegetation height ranges from 10 to 31 inches depending on grassland type.”,

“Vegetative cover (herbaceous ground cover and litter) is between 45 and 80 percent in 

Great Basin grasslands, 35 to 70 percent in semi-desert grasslands, and 60 to 100 percent in 

montane/subalpine grasslands. These percentages may vary depending on the amount of 

surface rock as described in each ecological mapping unit.”, “Average ungrazed grass 

height varies by grassland PNVT and yearly weather conditions. Grass heights range from 

11 to 26 inches in Great Basin grasslands, 10 to 25 inches in montane/subalpine grasslands, 

and 13 to 31 inches in semi-desert grasslands”, "During the critical pronghorn fawning 

period (May through June), cool season grasses and forbs provide nutritional forage; while 

shrubs and standing grass growth from the previous year provide adequate hiding cover (10 

to 18 inches) to protect fawns from predation.” (proposed plan p. 56-57). There are concerns 

that the specified amounts may not be achievable. (102.44, 30.8, 139.3, 131.19, 131.13, 123.5, 

108.24, 102.43, 123.4)

Response: Each of these desired conditions was rewritten for clarity and to incorporate new 

information. Specific ground cover ranges for grassland types were removed from this section, as 

the range of groundcover represented across the forest is variable and depends on many factors, 

including soil type, surface rock, and overstory canopy cover. In addition, grass heights were 

updated to represent research and taxonomic descriptions of individual plants. All references used 

in determining the range of plant heights are found within footnotes of the desired conditions.

The desired levels of ground cover are addressed in the desired condition in the “All PNVTs” 

section: 

“Vegetative ground cover (herbaceous vegetation and litter) is optimized to protect and 

enrich soils and promote water infiltration.” 

The amount of groundcover needed to protect soils is estimated in the TES and can be modified 

with detailed site specific investigations.

Concern Statement: The Forest Service should measure both grazed and ungrazed plants to 

determine the actual height distributions of grasslands (proposed plan 56-57). (162.95, 

162.96)

Response: Desired condition statement was rewritten for additional clarification following 

accepted forest protocols. In addition, comparison of grazed and ungrazed plants is employed for 

determining percent utilization of plants to determine whether site specific forage use objectives 

are being met and is commonly done at the project-level. In this case, measurement of ungrazed 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 657

plants is an indicator of a sites’ production potential and to determine relative plant health and 

vigor.

Concern Statement: Herbaceous cover and height desired conditions, standards and 

guidelines significantly exceed those attributes ranges found in NRCS ESI documents, 

which are much more current than FS inventories. (30.2)

Response: These are not Forest Service documents, standards, direction or policy. The plan’s 

desired conditions for herbaceous cover and height are based upon the Apache-Sitgreaves NFs 

terrestrial ecosystem survey (TES) and research relevant to the forests, including taxonomic 

descriptions of individual plants. The plan describes the forests’ management approach to update 

the TES to reflect current conditions and concepts (see the “Soil” section in chapter 2).

Concern Statement: Explain, modify, or remove the Grasslands guideline "Grasslands and 

openings should provide for sufficient vegetative ground cover (45 percent or greater in 

Great Basin grasslands, 35 percent or greater in semi-desert grasslands, and 60 percent or 

greater in montane/subalpine grasslands) to prevent accelerated erosion, dissipate rainfall, 

facilitate the natural fire regime, and provide wildlife and insect habitat" (proposed plan p. 

57). There are concerns that the specified amounts may not be achievable or measurable. 

(108.25, 138.26, 30.9)

Response: This guideline has been deleted. These concepts are covered by desired conditions in 

the “Grasslands” and “All PNVTs” sections. For example, the “All PNVTs” desired condition 

reads, 

“Vegetative ground cover (herbaceous vegetation and litter) is optimized to protect and 

enrich soils and promote water infiltration.” 

The ground cover amounts and grass heights are considered to be achievable and measureable.

Concern Statement: Explain why other vegetation types do not have a standard like the one 

for Grasslands "A moderate to high similarity to vegetation climax conditions for plant 

canopy cover and composition as described in each ecological mapping unit shall be 

achieved and/or maintained" (proposed plan p. 57). (127.24)

Response: The standard has been rewritten for clarity and moved to the “All PNVTs” section to 

make it applicable to not only grasslands but all vegetation types. It reads,

“Within each PNVT, vegetation management activities shall be designed to maintain or 

move plant composition towards a moderate to high plant community similarity as 

compared to site potential.”

Concern Statement: Provide more details in the Grasslands standard "A moderate to high 

similarity to vegetation climax conditions for plant canopy cover and composition as 

described in each ecological mapping unit shall be achieved and/or maintained" (proposed 

plan p. 57). There is a concern that it points to other documents and is not the best method 

to convey the details of the standard. (132.33, 108.239)

Response: The standard has been rewritten for clarity and moved to the “All PNVTs” section. It 

no longer points to a specific methodology or document (see comment above). Forest Service
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658 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

policy (e.g., manuals, handbooks) describes approved methods for measuring whether a project 

contributes to moving plant composition to, or maintaining at, site potential.

Concern Statement: Similar guidelines are presented on page 57 of the proposed plan as 

objectives at different scales and as guidelines for Grasslands. These should be removed. 

(102.46)

Response: The guideline to provide sufficient vegetative ground cover was removed because the 

concept was covered under desired conditions in the “All PNVTs” and “Grasslands” sections. The 

desired conditions read,

“Vegetative ground cover (herbaceous vegetation, litter, and woody riparian species) is 

optimized4 to protect and enrich soils and promote water infiltration. There is a diverse 

mix of cool and warm season grasses and desirable forbs species.” (All PNVTs)

“Average herbaceous vegetation heights5 vary by grassland PNVT and yearly weather 

conditions. Ungrazed herbaceous vegetation heights6 range from 7 to 29 inches in Great 

Basin grasslands, 7 to 26 inches in montane/subalpine grasslands, and 10 to 32 inches in 

semi-desert grasslands.” (grasslands)

Concern Statement: Keep the Grasslands guideline "Mechanical restoration of grasslands 

should emphasize individual tree removal to limit soil disturbance" (proposed plan p. 57). 

Fire may be enough to remove excess woody vegetation, but if mechanical methods are 

used, they should be applied on a tree-by-tree basis and retain fragile soils. (162.97)

Response: The guideline remains in the plan. This guideline does not exclude the use of fire.

Concern Statement: The reintroduction of fire, combined with long term rest from livestock 

grazing, should be implemented to restore grasslands to their full capacity. (162.94)

Response: There are many ways that grasslands can be restored to their full capacity. The plan 

does not limit options and provides an objective to accomplish restoration. The objective is to

treat (mechanically or with fire) up to 25,000 acres annually to decrease or maintain woody 

canopy at less than 10 percent. 

A primary emphasis area for the plan is to manage for desired fire regimes and restore fire to a 

more natural role as one of the forest’ primary disturbance agents. In particular, the “Grasslands” 

section of the plan describes the fire regime and fire return interval desired conditions for the 

three grassland types. There is an emphasis to provide enough grass to reduce topsoil loss and 

allow fire to spread and resume its role in maintaining grasslands.

 4 Based on site capability as defined by the specific ecological unit under consideration in the “Terrestrial Ecosystem 

Survey for the Apache-Sitgreaves National Forests” (Laing et al., 1987, as amended).

5 Measured on ungrazed plants as an indicator of vigor.

6 Plant height source material: Vine 1960; Hermann 1970, 1975; Hitchcock and Chase 1971; McDougall 1973; Correll 

and Correll 1975; Gould 1977; Martin and Hutchins 1980; Benson and Darrow 1981; Hickman 1993; Cronquist et al. 

1997; Ruyle and Young 1997; Welsh et al. 1997; Hurd et al. 1998; Barkworth et al. 2003, 2007; Flora of North 

America 2008; and Springer et al. 2009. See the plan for reference citations.
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Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 659

Stocking decisions (amount of livestock grazing authorized) for specific grazing allotments are 

beyond the scope of this analysis. Grazing is authorized through term grazing permits (a long 

term authorization subject to forestwide standards and guidelines), allotment management plans, 

and annual operating instructions. Changes to these authorizations would be made through 

project-level analyses.

Concern Statement: Concern that plan desired condition to reestablish the historic fire 

frequencies in grasslands, especially desert grassland and Great Basin grassland, may not 

be feasible or practical and will not necessarily reduce the shrub cover to historic levels. 

(102.58)

Response: The “Vegetation” section in chapter 3 of the EIS acknowledges this concern and 

discloses that some portions of these grasslands may not be restorable. 

“Currently, much of this grassland more closely resembles woodland than grassland. 

Overall, approximately 68 percent, or nearly 126,200 acres, of this grassland have been 

encroached by woody species, primarily piñon and juniper. According to Vander Lee et 

al. (2006) approximately 70 percent of these encroached acres may be non-restorable to 

their former grassland state. Historically, these grasslands were dominated by 

herbaceous vegetation.” (Grassland PNVTs – Great Basin)

“Currently, much of this grassland more closely resembles woodland than grassland. 

Overall, approximately 80 percent, or nearly 85,600 acres, of this PNVT has been 

encroached by woody species, primarily juniper and mesquite. According to Vander Lee 

et al. (2006) approximately 36 percent of these encroached acres may be non-restorable

to their former grassland state. Historically, these grasslands were dominated by 

herbaceous vegetation.” (Grassland PNVTs – Semi-Desert)

There are many ways that grasslands can be restored. The plan does not limit options and 

provides objectives to accomplish restoration. Specific treatments would be determined at the 

project level.

Wildland Fire Management

Concern Statement: Correct the list and community-forest intermix management area 

showing the Community Wildlife Protection Plan WUI (wildland-urban interface) areas. 

Areas in Greenlee County are missing. Explain why the CWPP area’s in Apache and Navajo 

counties are surrounded with a designation of “General Forest” and the CWPP area in 

Greenlee County is surrounded by a designation of “natural landscape.” (103.1, 103.2, 

103.6)

Response: No changes were made to the list or management area. The Community Forest 

Intermix Management Area consists of National Forest System (NFS) lands within one-half mile 

of communities-at-risk. The 12 communities-at-risk listed in the EIS are those identified as 

“Urban Wildland Interface Communities within the Vicinity of Federal Lands That Are at High 

Risk from Wildfire” within the Federal Register (66 FR 751-777). The communities are 

referenced under the heading “National Fire Policy and Wildland-Urban Interface” within the 

“Fire” section in chapter 3. None of these communities are located within Greenlee County. 
Appendix A

660 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

The Natural Landscape Management Area reflects, in most cases, the presence of Inventoried 

Roadless Areas (IRAs). A large portion of NFS land in Greenlee County is in IRAs. This is why 

much of the land in Greenlee County falls within the Natural Landscape Management Area, 

where other counties have more land in General Forest Management Area. 

The 2001 Roadless Area Conservation Rule provides protection and management direction for the 

areas identified in a set of inventoried roadless area maps contained in Forest Service Roadless 

Area Conservation, Final Environmental Impact Statement, Volume 2, dated November 2000. 

Management activities within the Natural Landscape Management Area may include restoration 

of ecological conditions or habitat components, soil stabilization, planned and unplanned 

ignitions, hazardous fuels reduction, and invasive species reduction.

Concern Statement: Correct the statement "Fire is the most important natural disturbance 

..." (proposed plan p.17). Concern that this statement is not necessarily correct and should 

include reference to geologic processes and climatic fluctuations. (108.116)

Response: This statement is not found in the proposed plan. However a similar statement did 

appear on page 27 under the “All PNVTs” section,

“Fire is among the most important natural ecological processes that shaped these 

vegetation communities.”

It has been updated to read,

“Fire and climatic variability are among the most important natural ecological 

disturbances that shaped these vegetation communities.”

Concern Statement: The occurrences of large fires need to be included in the analysis and 

their occurrence and impacts planned for. (98.10)

Response: The vegetation analysis (see environmental consequences in “Vegetation” section in 

chapter 3 of the EIS) did include the effects of large fires, such as the Rodeo-Chediski, Thomas, 

3-Forks, and KP.

The occurrence of uncharacteristic (e.g., large) fires was one of the key reasons behind the need 

for change (see the “Purpose and Need for Change” section in chapter 1 of the EIS). 

Uncharacteristic wildfires were considered in the analysis in chapter 3 of the EIS.

A primary emphasis area for the plan is to manage for desired fire regimes and restore fire to a 

more natural role as one of the forest’ primary disturbance agents. The plan also has a section 

titled “Landscape Scale Disturbance Events” to address disturbance events (including large fires) 

generally over 10,000 acres. This section contains desired condition, standards, guidelines, and 

management approaches to guide Forest Service managers following these types of events. Also 

see the response to comment # 26.106 in the “Vegetation” section of this appendix.

Concern Statement: With the appropriate resource specialist, analyze and discuss the 

impacts to vegetation strata (percent mortality, value, volume) of current and potential 

changes of fire regime condition class (FRCC) and high intensity fire. Recommend that the 

impacts of a wildfire be evaluated using a rating such as the ERC (Energy Release 

Component) and evaluate the fire at the 90th or 95th percentile and higher of the ERC 

rating for the respective fuel model(s). Include a loss or benefit analysis based upon recent 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 661

high intensity wildfires throughout the Southwest using comparable vegetative: (1) 

types/classes, pre-wildfire and (2) treatments and extrapolated to the proposed alternatives. 

(98.8, 98.6, 108.229, 98.7, 98.5, 98.9)

Response: The “Vegetation” section contained in chapter 3 of the EIS discusses in detail the 14 

potential natural vegetation types (PNVTs) and the measure of departure index. It further outlines 

how each alternative’s proposed treatments would affect the departure index. The “Fire” section 

within chapter 3 demonstrates how each alternative would affect current and potential fire regime 

condition classes (FRCCs). The information contained within these two sections demonstrates the 

impacts on vegetation strata and how this will affect FRCCs.

The recommendation to use ERCs to compare wildfires and their impacts on the fuel type was 

appreciated. However, after further evaluation, it was determined there was no need for additional 

analyses because the plan and EIS, as written, both provide alternatives that are designed to 

improve the FRCCs. 

Chapter 3 in the EIS discusses the affected environment by resource and compares alternatives. 

The “Forest Products” section discloses wood and tree products availability. Table 146 displays 

treatment acres by alternative. This demonstrates the potential value. If lost to a landscape scale 

disturbance, this would indicate the associated lost value.

An increasing body of research is becoming available locally and regionally which generally 

demonstrates the economic practicality of implementing restoration projects at relatively lower 

financial costs. This is compared to the higher financial costs of wildfire suppression plus the 

ecological and social values of natural resources lost in stand-replacement wildfires such as old 

growth, critical wildlife habitats, watershed stability, carbon storage, air quality, wood volume, 

and recreation/scenic values, among others (Snider et al., 2006; ERI, 2011; Donovan et al. 2008; 

Huang et al., 2013; Lynch, 2001).

Concern Statement: Discuss impact of wildfire on the human environment including, but 

not limited to: (1) smoke, (2) air pollution, (3) socioeconomic effects, (4) assess mechanical v. 

burning treatments on smoke and other negative effects, and (5) cost for post-fire flooding 

and infrastructure damage and loss of revenue from activities shut down by fires. (108.77, 

108.23, 108.213, 108.230)

Response: The “Fire” section in chapter 3 of the EIS analyzes the impacts of smoke and air 

pollution under the header “Air Quality Related to Smoke.” This section also compares the 

impacts from treating with wildland fire and mechanical treatments. Other socioeconomic effects 

related to the use of fire are described under “Wildland-Urban Interface,” “Fire Regime Condition 

Class,” and “Cumulative Environmental Consequences.” Additionally, the “Social 

Consequences” header under the “Socioeconomic Resources” section further discusses the 

impacts from prescribed burns. Post-fire impacts are discussed under the “Environmental 

Consequences” headers in other chapter 3 sections (e.g., “Soil” “Forest Health,” “Wildlife and 

Rare Plants,” “Scenic Resources”).

The plan contains direction for “Landscape Scale Disturbance Events,” including large wildfires. 

This forestwide direction specifically addresses post-fire flooding and infrastructure damage 

following large disturbance events. Restoration of PNVTs to their desired conditions would 

contribute to lowering the risk of negative social and economic costs resulting from severe 
Appendix A

662 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

wildfires. Also see the response to comment # 98.8 in the “Wildland Fire Management” section of 

this appendix.

Concern Statement: Explain when a high intensity wildfire would be considered acceptable. 

(98.3)

Response: The “Fire History and Behavior” header in the “Fire” section in chapter 3 of the EIS 

provides examples of when high fire intensity is necessary to create the fire severity required for 

positive ecological results within each of the potential natural vegetation types. For example, the 

natural fire regime for spruce-fir forest and interior chaparral PNVTs indicate high fire severity, 

indicating that high intensity wildfires may be acceptable in these vegetation types. Also, high 

intensity fire could be appropriate to create patchy tree regeneration openings and/or to remove 

(sanitize) insect or disease infested trees. See also the “Vegetation Management Practices” section 

in the plan’s appendix B (“Vegetation Conditions and Management Practices”). This section 

contains a table that displays how fire may be used as a silvicultural management tool.

Concern Statement: Assess more than the degree of fire regime departure from FRCC (fire

regime condition class) and disclose implications of climate change on wildland fire and 

management. (26.141)

Response: The “Fire” section in chapter 3 of the EIS assesses other topics (e.g., hazards 

associated with wildland-urban interface, air quality related to smoke, cumulative environmental 

consequences) in addition to the degree of fire regime departure from FRCC. The degree of 

departure from natural fire regimes utilizing FRCC is a valuable tool to determine the resiliency 

of an ecosystem. 

Climate change is also addressed in this section. 

Appendix A (“Climate Change Trends and Apache-Sitgreaves NFs Land Management Planning”) 

of the plan also outlines the potential implications of climate change to the Apache-Sitgreaves 

N.F. they are:

• Increase in frequency of extreme weather events

• Increase in wildfire risk

• Increase in outbreaks of insect, diseases and nonnative invasive species

• Increase in demand for decreasing upland water supplies

• Increase in national forest socioeconomic uses and demands

Appendix A also outlines five potential strategies for management: 

• Enhance adaptation by anticipating and planning for disturbances from intense storms

• Reduce vulnerability by restoring resilient native ecosystems

• Increase water conservation and plan for reductions in upland water supplies

• Anticipate increase in forest recreation use

• Monitor climate change influences

Concern Statement: The environmental analysis (forest structure and crown fire hazard) 

should ensure professional and scientific information based on field observations. To 

accurately assess fuel treatment effects on the likelihood of crown fire initiation and spread, 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 663

it is necessary to consider: (1) surface fuel density and arrangement; (2) canopy base height; 

(3) local topography; and (4) weather patterns. (26.143, 26.187)

Response: The four critical factors listed above may lead to crown fire initiation. Tables 59 to 62

in the EIS compare each of the alternatives relative to potential natural vegetation type (PNVT), 

and demonstrate how each PNVT relates to fire regime condition class (FRCC) and its 

progression or lack thereof to a more resilient ecosystem. Each action alternative provides 

different techniques for specifically altering factors surface fuel density and arrangement and 

canopy base height.

The four factors above would be taken into consideration in the development of a site specific 

burn plan. In the event of natural ignitions (i.e., lightning), these factors would be considered 

during a risk management-based decisionmaking process to determine if the ignition would 

provide acceptable restoration results.

Concern Statement: Consider the effect of activity-created fuels on fire hazard. Disclose 

how much slash may remain on the ground after logging in different vegetation types. Look 

at slash fuels and treatment options on fire hazard and ecosystem resilience, particularly on 

steep slopes where prescribed fire may not be used due to operability constraints. Provide 

plan guidance for management of activity-created fuels. (26.145, 26.150, 26.188)

Response: The effects of activity-created fuels are discussed in chapter 3 of the EIS in the “Soil,” 

“Forest Health,” “Fire,” “Invasive Species,” “Recreation,” “Scenic Resources,” “Cultural 

Resources,” and “Forest Products” sections.

The plan provides desired conditions for coarse woody debris within each potential natural 

vegetation type (PNVT) in chapter 2. It specifically outlines the acceptable range of coarse 

woody debris in tons per acre within forested and woodland PNVTs. Additionally, a guideline for 

“All Forested PNVTs” states,

“Where a site-specific analysis indicates the need to reduce fire-kill of desired residual 

trees, fuel continuity and/or loading should be reduced before use of prescribed fire.”

Concern Statement: Disclose benefits and potential liabilities of using prescribed fire at 

broad spatial scales to reduce risk, provide ecosystem services, and regulate greenhouse gas 

emissions. (26.165, 26.169)

Response: The “Fire” section in chapter 3 of the EIS discusses the application of fire on the 

landscape at broad spatial scales. It compares the existing fire regime condition class (FRCC) by 

alternative to determine the percent of the forest that would move toward desired conditions, thus 

reducing the risk of uncharacteristic wildfires. It also outlines how each alternative varies in its 

emphasis of treatments near wildland-urban interface, thus reducing the hazards from 

uncharacteristic wildfires. Other sections in chapter 3 (e.g., “Water Resources,” “Vegetation,” 

“Wildlife and Rare Plants,” “Forest Products,” “Scenic Resources”) describe the effect of fire on 

resources that provide ecosystem services. As discussed in the “Fire” section, limits to smoke 

emissions (including greenhouse gases such as carbon dioxide) from prescribed fires and 

wildfires are imposed by the Arizona Department of Environmental Quality.
Appendix A

664 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Correct statement on p. 208 of the DEIS that says previously burned 

areas stop fires. (108.224)

Response: No change was made in the EIS to the statement,

“Historically, fires could burn until they were extinguished by precipitation, ran out of 

fuel, or reached a previously burned area.”

This statement remains accurate both historically and under current environmental conditions. 

This sentence does not state or infer that fires are completely stopped by previously burned areas.

Concern Statement: There should be discussion of the effects of different ignition types on 

subsequent fire events and watershed management activities. (108.243)

Response: Effects from different ignition types is beyond the scope of plan level analysis. 

Different ignition patterns would vary depending on the specific location, potential natural 

vegetation type (PNVT), and topography of the individual watershed. Specific ignition patterns 

would be discussed within the project burn plan following completion of area-specific 

environmental analysis that defines specific ecosystem objectives and goals. 

In the event of natural ignitions (i.e., lightning), each fire is evaluated through a risk 

management-based decisionmaking process to determine if the ignition would provide acceptable 

restoration results.

Concern Statement: Explain the need to return to natural fire regimes compared to simply 

using fire as a tool to achieve the desired vegetation conditions. (108.224, 108.226, 102.56, 

102.7)

Response: The plan’s desired conditions for individual potential natural vegetation types 

(PNVTs) describes the natural fire regime, including fire frequency and severity that would occur 

in a properly functioning system. Simply using fire as a tool does and can assist in reaching 

desired conditions; however, utilizing fire in a way that mimics natural intensity and frequency 

allows for maintenance of or movement towards the desired conditions.

Concern Statement: The plan should focus on safely restoring natural fire regimes and 

identify where natural fires are a priority. (33.6, 5.7, 9.6, 94.6, 3.17, 23.14)

Response: The plan does focus on safely restoring natural fire regimes. To further emphasize this

point, a new section entitled “Wildland Fire Management” was added to the plan because of 

public comments on the proposed plan and DEIS. The plan does not specifically identify the 

priority areas for unplanned ignitions. However, it does discuss the management approach for 

wildland fire, including areas where fire may be the only viable tool for treating the landscape.

Concern Statement: There is a need to address increasing fire occurrence. (98.11, 14.5)

Response: Historical data from 1997 to 2011, including the number of unplanned ignitions and 

acres burned, is displayed under the “Fire History” header, “Fire” section in chapter 3 of the EIS. 

This data shows that the number of ignitions (occurrence) per year has stayed within a similar 

range; however, the two landscape scale uncharacteristic events (Rodeo-Chediski and Wallow 

Fires) caused the acreage burned to significantly increase. Average fire occurrence, based on the 

historical combined wildfire record for the national forests above the Mogollon Rim in Arizona, 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 665

was used in the EIS vegetation modeling (see “Vegetation” section in chapter 3) for the ApacheSitgreaves NFs.

All alternatives analyzed in the EIS focus on restoration to increase the resiliency of the 

ecosystem and individual PNVTs. Resiliency will not necessarily reduce the number of ignitions; 

it would provide, in the next 15 to 50 years, a more fire-adapted ecosystem that is functioning so 

that detrimental effects are not widespread across the landscape. Tables 61 and 62 in the EIS 

depict trends for each fire regime condition classes.

Concern Statement: The plan should describe predetermined burning conditions to 

establish when fires should be suppressed or managed to meet resource objectives. (108.185, 

108.27)

Response: The “Wildland Fire Management” section of the plan in chapter 2 provides general 

forestwide guidance for the Apache-Sitgreaves NFs’ fire program. Additional management area 

direction for fire can be found in chapter 3 for General Forest, Community-Forest Intermix, 

Natural Landscape, and Wilderness Management Areas. 

The plan does not direct suppression or management of fires based on predetermined burning 

conditions. The Apache-Sitgreaves NFs’ annual fire management plan provides the operational 

parameters whereby fire managers implement the plan decisions of the land management plan. 

The fire management plan describes fire management strategies, tactics, and alternatives for fire 

management units. The specific strategies chosen for the management of wildfires includes 

interdisciplinary input to assess site specific values to be protected. Incident objectives and 

courses of action are developed to enhance or protect those values.

More information about wildfire management approaches can be found in the “Wildland Fire 

Management” section of the plan.

Concern Statement: De-emphasize restoration and prioritize the safety of people and 

property, including fire prevention, suppression activities, and reducing fuels in key 

locations. (108.186, 108.41, 108.42, 108.43, 146.6)

Response: Although “Maintenance and Improvement of Ecosystems” is one of the primary focus 

areas of the plan, the proposed plan was modified based on public comment to include a 

“Wildland Fire Management” section. This section of the plan contains a background, desired 

conditions, guidelines, and management approaches to better describe the management intent of 

the Apache-Sitgreaves NFs. The safety of people and property are described in the first desired 

condition. The specific strategies (e.g., use of wildland fire, suppression) for managing a wildfire 

are discussed under the management approaches. Fire prevention is emphasized in desired 

conditions under the “Conservation Education” section. The plan emphasizes reduction of fuels in 

the Community-Forest Intermix Management Area and areas identified in community-wildfire 

protection plans (CWPPs).

In addition, the “Elements Common to All Alternatives” section of the EIS in chapter 2 has been 

updated to include,

“During response to wildland fire, risks to firefighters and the public shall be mitigated. 

Protection of human life overrides all other priorities.”
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666 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: The analysis should consider different approaches (e.g., fire resistant 

landscape features) for the strategic location of fuel treatments. Prioritize fuel treatments at 

locations where relatively little resource investment may create fire resistant conditions in 

the shortest amount of time. (26.153, 26.155)

Response: The plan provides the desired condition in the “Overall Ecosystem Health” section,

“Natural ecological disturbances return to their characteristic role within the ecosystem. 

Wildfire in particular, is restored to a more natural function.” 

The plan also contains objectives to treat vegetation using both mechanical and fire treatments. 

The priority for restoration treatments (including fuel treatments) is to treat priority watersheds 

and locations identified in community wildlife protection plans, including the Community-Forest 

Intermix Management Area.

Different approaches for the strategic location of fuels treatments would be identified during the 

forests’ annual and out-year program of work development. Costs (based on location, extent of 

treatment) and benefits of implementing treatments would be considered before selecting specific 

locations to treat.

Concern Statement: The DEIS and fire specialist report fail to address critical fire 

suppression management variables. (108.74)

Response: Analysis of specific fire suppression variables is beyond the scope of the plan and plan 

revision process. The risk of suppressing a wildfire or managing the fire to meet resource 

objectives is analyzed and decisions are made during each individual wildfire situation. 

The Apache-Sitgreaves NFs’ annual fire management plan provides the operational parameters 

whereby fire managers implement the plan decisions of the land management plan. The fire 

management plan describes fire management strategies, tactics, and alternatives for fire 

management units. It identifies areas where varying levels of response should take place. There 

are areas on the forests that are identified for immediate and direct suppression responses. The 

specific strategies chosen for the management of wildfires includes interdisciplinary input to 

assess site specific values to be protected. Incident objectives and courses of action are developed 

to enhance or protect those values. More information can be found under the management 

approaches for the “Wildland Fire Management” section of the plan.

Concern Statement: The Forest Service should analyze direction of fire spread and slope 

and demonstrate that proposed fuels treatments will meet the need for change. Fuels 

treatments should be oriented in concert with prevailing spatial patterns of fire spread in 

the project area. (26.152)

Response: This level of analysis is completed during project planning and the specific factors 

listed would be addressed there. 

The plan does contain a guideline in the “All PNVTs” section that says,

“Landscape scale restoration projects should be designed to spread out treatments 

spatially and/or temporally to reduce implementation impacts and allow reestablishment 

of vegetation and soil cover.” 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 667

This would result in fuels treatments that are arranged on the landscape to provide a checkerboard 

pattern to minimize the impact on areas that may be susceptible to high severity fire. 

Concern Statement: Prescribed fire planning should minimize the effects of smoke on 

public health, public nuisance, and visibility in Federal Class I Areas. Prescribed fire 

activities must also comply with the requirements of Title 18, Chapter 2, Article 15 of the 

Arizona Administrative Code entitled "Forest and Range Management Burns." (4.1, 159.7)

Response: The “Fire” section in chapter 3 of the EIS addresses smoke management requirements 

and applicable laws related to smoke management. The Clean Air act of 1970 describes the level 

of protection required for Class I airsheds. 

Air quality management direction is addressed under forestwide direction within the plan. It 

outlines strategies and expectations for management of airsheds on a landscape scale. It also 

reaffirms the Apache-Sitgreaves NFs cooperation and coordination with Arizona Department of 

Environmental Quality. The Title 18 State regulation is also listed in appendix D (“Relevant 

Laws, Regulations, and Policies”). 

Wildlife and Rare Plants

Concern Statement: The Forest Service is obligated to consult with USFWS to ensure the 

plan revision “is not likely to jeopardize the continued existence of any endangered species

or threatened species or result in the destruction or adverse modification of [critical] habitat 

of such species.” (26.166)

Response: The Forest Service compiled a biological assessment (BA) describing the short and 

long term effects to federally listed species and their habitats from the proposed actions and 

direction contained within the plan. This BA is the basis for consultation with the U.S. Fish and 

Wildlife Service regarding federally listed species under § 7(a)(2) of the Endangered Species Act, 

as amended. The information compiled for the BA was used to update the EIS between draft and 

final, including updates on listing status, threats to species and habitat, and effects determination.

The USFWS has prepared a biological opinion (BO) of the plan (USFWS, 2015); a summary of 

the conclusions from the BO are documented in the record of decision.

Concern Statement: Modify Wildlife and Rare Plants Background (proposed plan p. 59). In 

the last paragraph it states that "Other species have been introduced, such as Rocky 

Mountain elk and crayfish." The Department considers elk to be a native Arizona species. 

Accordingly, the Department views it wholly inappropriate to present elk, a desired native 

species that provides significant economic and social benefits to the forest and local 

communities, in the same context as crayfish, which is a clearly undesirable and destructive 

nonnative species. (101.57)

Response: This sentence in the background for “Wildlife and Rare Plants” section of the plan has 

been modified to read,

“Other species, some desirable and some not, have been introduced and have become 

naturalized.”

A definition for ‘naturalized’ has been added to the plan’s glossary.
Appendix A

668 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Modify Wildlife and Rare Plants Background (proposed plan p. 59).

Acknowledge the economic contribution of wildlife (hunting, fishing, wildlife viewing) and 

provide such information within the Background for Wildlife and Rare Plants section. 

(101.58)

Response: Additional language that acknowledges the economic contribution of visitors, 

including those that view wildlife, hunt, and fish was added to the background for “Overall 

Recreation Opportunities” section of the plan. The background now notes that the forests’ 

contribution to the local economy from the recreation and wildlife areas is approximately 69 

percent of the local jobs and 68 percent of the local labor income.

Concern Statement: Modify Wildlife and Rare Plants Background (proposed plan p. 60). 

The reference to ′′Mexican wolf′′ should be changed to ′′Mexican gray wolf.′′ (101.59)

Response: As noted in the “Roles and Contributions of the Apache-Sitgreaves NFs” section in 

chapter 1 of the plan, the ‘Mexican gray wolf’ is thereafter referred to as the ‘Mexican wolf.’ This 

is consistent with this wolf’s recovery plan terminology and with the most recent U.S. Fish and 

Wildlife Service proposal to remove the gray wolf from the list of endangered and threatened 

wildlife but to maintain endangered status for the Mexican wolf by listing it as a subspecies 

(Canis lupus baileyi).

Concern Statement: Correct table 103 (DEIS p. 299), the rating description does not match 

the values in the table. (112.57)

Response: Table 103 ratings in the EIS have been corrected to match the values in the rating 

descriptions; thank you for pointing this out.

Concern Statement: Clarify the discussion on habitat connectivity and linkages including 

Table 108. (DEIS p. 308). (162.168, 162.66, 162.68)

Response: Table 108 under the “Habitat Connectivity and Linkages” header of the “Wildlife and 

Rare Plants” section of the EIS was found to have some calculation errors which have been 

corrected. The table has also been simplified to provide a clearer picture of habitat connectivity 

across the Apache-Sitgreaves NFs as a whole, rather than showing partial information for the 

Sitgreaves and Apache sides of the forests. The correction has also been reflected in the following 

“Alternatives Compared” narrative.

Concern Statement: Explain whether threatened and sensitive wildlife species associated 

with closed-canopy forest will maintain habitat if significant reductions of crown bulk 

density is necessary to meet the need for change. (26.122)

Response: The plan does not use “crown bulk density” terminology; however, fine scale forested

PNVT desired conditions provide for mature trees with interlocking crowns consistent with 

historic reference conditions. In addition, during site specific analyses of projects or activities, the 

needs of species (and their prey, as necessary) for more closed canopies would be addressed by 

the plan standard that requires “habitat conditions contribute to the recovery of federally listed 

species.” Sensitive species would be addressed by the plan guideline that “management and 

activities should not contribute to a trend toward the federal listing of a species.”
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 669

Concern Statement: The plan should meet the NFMA (National Forest Management Act) 

requirement for estimation of effects to proposed MIS (management indicator species). 

Concerns include: (1) it ignored criteria prescribed by NFMA for viability determinations, 

including “changes in vegetation type, timber age classes, community composition, rotation 

age, and year-long suitability of habitat related to mobility of [MIS].” 36 CFR § 219.19(a)(1) 

(1982), (2) relies on “plan decisions” as the sole basis for viability findings, and asserts that 

projects “would incorporate” applicable recovery plans for federally listed species, (3) 

recovery plans for federally listed species are not enforceable in project-level management 

decisions, and (4) the efficacy of proposed management direction in promoting the 

conservation and recovery of Mexican spotted owl is uncertain. The Forest Service is 

required to disclose controversy and uncertainty regarding effects to Mexican spotted owl 

and its critical habitat. (26.46, 26.48)

Response: The Forest Service has conformed to the direction of NFMA by adhering to the 

provisions of the 1982 Planning Rule (219.19) for analyzing effects of MIS. These effects are 

described in the “Wildlife” section in chapter 3 of the EIS under the header “Management 

Indicator Species, Migratory Birds, and Eagle Consequences.”

The process to assess viability is described in the EIS under the “Provision for Species Viability” 

and the “Analysis of Species Viability” headers in the “Wildlife and Rare Plants” section. 

Rotation age is a term associated with even-age timber management of which the plan calls for 

limited treatments; instead the plan emphasizes uneven-aged management with desired conditions 

to develop or maintain uneven-aged forest structure. The vegetation treatments modeled for the 

EIS analysis incorporated the plan’s limited even-aged and the plan’s primarily uneven-aged 

direction/amounts. In addition, this modeling addressed vegetation type and composition and 

vegetation states (e.g., age classes). More information about vegetation modeling can be found in 

the “Vegetation” section in chapter 3 of the EIS.

Wildlife species viability was conducted in accordance with National Forest Management Act

direction (provisions of the 1982 Planning Rule) to assure the plan (and plan decisions) maintain 

viable populations of wildlife relative to well distributed habitat, species occupancy, and 

maintenance or restoration of habitat. The viability process included an assessment of species 

abundance and distribution, habitat abundance and distribution, risk ratings for species, etc. See 

the “Wildlife Specialist Report-Viability” (Forest Service, 2014l).

Failure to follow a species’ recovery plan at the project-level would be inconsistent with the legal 

requirements of the plan and the Endangered Species Act and the direction of the National Forest 

Management Act. Guidelines under the “Aquatic Habitat and Species” and the “Wildlife and Rare 

Plants” sections of the plan require that,

“activities occurring within federally listed species habitat should apply habitat 

management direction and species protection measures from recovery plans.”

The site specific projects or activities address species recovery plans and the National 

Environmental Policy Act (NEPA) and Endangered Species Act analyses for these must disclose 

how the project or activity would impact the Mexican spotted owl. 

Concern Statement: The remote nature and remarkable elevation gradient of roadless areas 

make them potentially critical as wildlife refuges from the impacts of climate change. (27.2, 

56.2, 90.3)
Appendix A

670 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Response: Climate change is likely to affect all areas, whether they are roaded or unroaded. 

Wildlife within unroaded areas have one less impact (i.e., stress/disturbance from motorized use

associated with roads and motorized trails) to contend with. This environmental consequence is 

discussed in the “Wildlife Quiet Areas and Habitat Security” portion of the “Wildlife and Rare 

Plants” section of the EIS.

Concern Statement: Clarify the desired conditions "Livestock conflicts with wildlife rarely 

occur" and "Vegetation conditions support a healthy population of Montezuma Quail in 

suitable habitat." (108.149, 108.154)

Response: Neither of these desired conditions is found in the proposed plan or DEIS.

Concern Statement: Explain why beaver dams are considered a benefit to riparian area 

functionality ("Beavers occupy capable stream reaches and help promote the function and 

stability of riparian areas" p. 33) while the Riparian Areas management approach states 

that "Large human constructed dams may be altered or removed to restore ....wetland 

functionality" (proposed plan p. 35). (102.57)

Response: Unlike human constructed dams, beaver dams are permeable and not permanent. As 

such, they are hydrologically different. However, clarification has been added to the statements 

quoted in the comment.

Concern Statement: Establish standards for ungulate browsing of aspen, willow, and 

cottonwood. These standards should (1) inform stocking on allotments, closures, and 

retirement of allotments and (2) establish ungrazed “reference” areas in a diversity of 

ecological and soil types to use as baseline of an area's potential. Study and monitor areas 

for attainment of standards. (162.113)

Response: Regarding item (1), the plan provides direction relative to livestock grazing and 

riparian area conditions. For example, a plan guideline in the “Riparian Areas” section would 

require that,

“active grazing allotments should be managed to maintain or improve to desired riparian 

conditions.”

Where necessary to move toward desired conditions, this could include determining a level for 

browsing of willows and cottonwoods during a site specific project. The plan also contains a 

guideline in the “Livestock Grazing” section that addresses livestock impacts to aspen and 

riparian areas; it requires that in order,

“to minimize potential resource impacts from livestock, salt or nutritional supplements 

should not be placed within a quarter of a mile of any riparian area or water source. Salt 

or nutritional supplements should also be located to minimize herbivory impacts to aspen 

clones.”

Regarding item (2), the “Recommended Research Natural Area” (RRNAs) section of the plan 

notes that the Corduroy Recommended Research Natural Area is representative of high elevation 

vegetation types including aspen. RRNAs are not suitable for livestock grazing (see chapter 4 of 

the plan); hence, the Corduroy RRNA would provide a baseline or benchmark for aspen potential 

on the Apache-Sitgreaves NFs. Chapter 5 of the plan provides the monitoring strategy for aspen 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 671

and riparian forests as both are identified “ecological indicators” or EIs. For a discussion of EIs, 

see the “Habitat Ecological Indicators (EIs)” header in the “Wildlife and Rare Plants” section of 

the EIS. 

Concern Statement: Clarify the Wildlife guideline "Rare, unique habitats (e.g., talus slopes, 

cliffs, canyon slopes, caves, fens, bogs, sinkholes) should be protected" (proposed plan p. 

61). Define 'rare', 'unique', 'habitat', and 'protection' (from what?). (139.4)

Response: Types of rare and unique habitats are provided by the for example (“e.g.”). There may 

be other types of examples based on site specific examination of habitat by the wildlife or 

fisheries biologists or by the forest ecologist during site-specific project or activity analyses. The 

guideline has been rewritten to describe the need for protection,

“Rare and unique features (e.g., talus slopes, cliffs, canyon slopes, caves, fens, bogs, 

sinkholes) should be protected to retain their distinctive ecological functions and 

maintain viability of associated species.”

Concern Statement: Add a standard to inspect project areas for rare plants before project 

implementation, and modify project plans appropriately to protect rare plants. (162.100, 

162.98)

Response: A standard is not necessary because the plan contains the desired condition that

“localized rare plant and animal communities are intact and functioning” which requires 

knowledge of the presence and condition of rare plants (or their absence) in a project or activity 

area. In addition, the “Wildlife and Rare Plant” section of the plan contains a guideline that 

requires that:

“management activities should not contribute to a trend toward the Federal listing of a 

species.”

This may result in modification of project actions for rare plants but this would be determined on 

a site specific project analysis basis.

Concern Statement: Add a guideline to survey grazing allotments for rare plants and 

modify pastures appropriately. (162.99)

Response: See response above. Modification of a proposed action for livestock grazing could 

include changing pasture use, fencing rare plant sites, etc., but this is determined on a site specific

project basis.

Concern Statement: Add a Guideline to Wildlife and Rare Plants (proposed plan p. 60) 

"Right-of-way fencing where pronghorn antelope may be present should be placed and 

constructed in a manner that considers maximizing fence and road permeability for 

pronghorn antelope while addressing public safety concerns." (101.60)

Response: The guideline has not been added; however the plan, within the management 

approaches for the “Wildlife and Rare Plants” section, has been updated. The discussion about the 

Arizona Wildlife Linkages Working Group and the Arizona Department of Transportation 

regarding passage of wildlife and public safety has been expanded to include the potential for 

increasing the distance that roadway fences are set back from the road’s edge in order to provide 

herds of animals more room to maneuver during crossings.
Appendix A

672 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Modify Wildlife and Rare Plants Guideline (proposed plan p. 61) 

"Prairie dog controls should not be authorized except when consistent with approved State 

of Arizona Gunnison's prairie dog conservation strategies, or as authorized by the Arizona 

Game and Fish Commission." (101.61)

Response: This guideline in the “Wildlife and Rare Plants” section of the plan has been footnoted 

to clarify that:

“controls do not include State authorized hunting.”

Concern Statement: Modify Wildlife and Rare Plants Guideline (proposed plan p. 61) "The 

needs of localized species (e.g. New Mexico meadow jumping mouse, Bebb willow, White 

Mountain paintbrush) should be considered and provided for during project activities to 

ensure their limited or specialized habitats are not lost or degraded.” (101.62)

Response: This suggested guideline edit has been incorporated into the plan.

Concern Statement: Ecological based management should be put in place immediately on 

the current and historical areas used or needed by northern goshawk and antelope. (132.29, 

132.30)

Response: Desired conditions for the ponderosa pine potential natural vegetation type (PNVT) 

reflect historic or reference forest conditions that supported northern goshawk. The plan also 

incorporates provisions of the “Management Recommendations for the Northern Goshawk in the 

Southwestern United States” (Reynolds, 1992), although not its exact language. Desired 

conditions for Great Basin and other grasslands reflect the open grassland with vigorous 

herbaceous plant cover and growth of historic or reference conditions needed to support 

pronghorn antelope. 

A plan decision example for goshawk is the mid-scale desired condition for each of the forested

PNVTs (ponderosa pine, dry mixed conifer, wet mixed conifer, and spruce-fir):

“Northern goshawk nest areas have forest conditions that are multi-aged and dominated 

by large trees with relatively denser canopies than the surrounding forest.”

A plan decision example for pronghorn antelope is the fine scale grasslands desired condition:

“Average ungrazed herbaceous vegetation heights vary by grassland PNVT and yearly 

weather conditions. Ungrazed herbaceous vegetation heights range from 7 to 29 inches 

in Great Basin grasslands, 7 to 26 inches in montane/subalpine grasslands, and 10 to 32 

inches in semi-desert grasslands.”

Concern Statement: The management indicator species information is a very generic 

analysis and discussion which makes the bland summary “antelope populations appear to 

be stable.” (132.36)

Response: The quoted statement is not found in the proposed plan or DEIS. However, the 

“Management Indicator Species (MIS) and Indicator Habitat” portion of the “Wildlife and Rare 

Plants” section of the EIS discusses the status of antelope as a management indicator species. It 

states that,
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 673

“Overall, population trend is considered static with approximately 600 to 700 pronghorn 

on the Apache-Sitgreaves NFs portion of game management units 1, 3A, and 3B in the 

last two years.”

This information was provided by Arizona Game and Fish Department in 2012. The Forest 

Service has met the requirements to analyze MIS by following the provisions of the 1982 

Planning Rule (219.19). These effects are described in the “Wildlife” section in chapter 3 of the 

EIS under the header “Management Indicator Species, Migratory Birds, and Eagle 

Consequences.”

Concern Statement: Seed and plant collections, greenhouse collections, and replanting 

should be considered when there is a chance of increasing rare plant species viability 

through these procedures. (162.101)

Response: Propagation of rare plants is outside of the scope of the plan. Sources for plantings 

would be determined during project or activity-level planning. For example, the Natural 

Resources Conservation Service’s Plant Materials Center in Albuquerque, NM propagates 

uncommon plants like Bebb willow from cuttings on the Apache-Sitgreaves NFs that have, in 

turn, been planted back on the forests. 

Rare or sensitive plants are each considered a “forest planning species” (FPS) for the viability 

analysis required by the National Forest Management Act for both plant and animal species on 

the Apache-Sitgreaves NFs. FPS are identified in the EIS under the section by that name, and 

these include all Regional Forester sensitive plant species. The process for assessing viability of 

plants and animals is found in the “Analysis of Species Viability” portion of the “Wildlife and 

Rare Plants” section of the EIS. 

Concern Statement: Maintain and improve habitat security by protecting whole areas 

rather than individual road or route closures. (1) Enforce wildlife and plants closure areas. 

(2) Regularly monitor closure areas to ensure fences are in place to ensure violations are not 

occurring. (3) Regularly check road signs for closure areas. (162.115)

Response: Habitat security is addressed in the EIS under the header “Habitat Security and 

Connectivity and Wildlife Quiet Areas” in the “Wildlife and Rare Plants” section. As noted in the 

introductory paragraphs for “Wildlife and Rare Plants” section in the EIS, habitat security and 

connectivity and the amount of wildlife quiet areas were concerns raised by the public during 

scoping (see the “Alternative Development” section in chapter 2). The “Wildlife Quiet Areas 

(WQAs) and Habitat Security” environmental consequences discussion in the EIS examines the 

number and acreage of management areas best providing for wildlife habitat security and 

connectivity. Besides WQAs, other management areas providing more secure habitat noted in this 

section include wilderness, recommended wilderness, natural landscape, and primitive area.

One plan guideline in the “Wildlife Quiet Area” management area section requires inspection of 

fences where these coincide with wildlife area boundaries. An additional guideline would require 

signing to identify the areas and educate the public about their purpose. Enforcement of closure 

areas to prevent violations is a law enforcement responsibility and is beyond the scope of the 

plan.

Concern Statement: Modify Wildlife and Rare Plants Management Approaches (proposed 

plan p. 62). Reference is made to the Arizona Wildlife and Fisheries Comprehensive Plan. 
Appendix A

674 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

This is an outdated plan. A more appropriate reference would be the State Wildlife Action 

Plan as well as the Wildlife 20/20 Arizona Game and Fish Department's Strategic Plan.

(101.63)

Response: These two document citation updates have been made in the plan in the “Wildlife and 

Rare Plants” section under “Other Sources of Information for Wildlife and Rare Plants.”

Concern Statement: Modify Wildlife and Rare Plants Management Approaches (proposed 

plan p. 63). Promoting healthy population of predators while, reducing livestock conflicts 

with wildlife is discussed. It should be noted that predator control may also be required to 

reduce conflict and meet management objectives for wildlife prey species such as 

pronghorn, especially where degraded habitat conditions or other factors influence the 

natural predator prey relationship. (101.64)

Response: While the Apache-Sitgreaves NFs coordinates annually with the Arizona Game and 

Fish Department on hunt recommendations, this coordination does not include recommendations 

for predators such as coyotes which can influence pronghorn fawn survival, as noted, especially 

in degraded habitat conditions. Instead the plan contains a fine scale desired condition in the 

“Grasslands” section to provide healthy habitat conditions in pronghorn fawning areas to help 

limit predation on fawns early in life.

Concern Statement: Within the plan, clarify how the desired conditions for ponderosa pine, 

dry-mixed conifer, and wet-mixed conifer provide for Mexican spotted owl nesting/roosting 

habitat. Recommend discussing the desired conditions, standards, and guidelines favorable 

for Mexican spotted owl as identified in the DEIS (p. 269). (112.14)

Response: Examples of plan components and how they help provide for Mexican spotted owl 

nesting/roosting habitat follow.

Plan guidelines under the “Forests: Ponderosa Pine” and “Forests: Dry Mixed Conifer” sections 

state,

“Where Gambel oak or other native hardwood trees and shrubs are desirable to retain 

for diversity, treatments should improve vigor and growth of these species.”

This would help retain and improve MSO pine-oak habitat. As noted in the MSO recovery plan, 

MSO are known to nest in ponderosa pine forests with a well-developed Gambel oak component. 

Large Gambel oaks can provide open cavities that may be used for nesting and the leaves of this 

deciduous species can contribute to cooler understory conditions preferred by MSO for nesting 

and roosting.

Plan desired conditions under “Forests: Dry Mixed Conifer” section states,

“Northern goshawk post-fledging family areas (PFAs) may contain 10 to 20 percent 

higher basal area in mid-aged to old tree groups than northern goshawk foraging areas

and the surrounding forest.”

“Northern goshawk nest areas have forest conditions that are multi-aged and dominated 

by large trees with relatively denser canopies than the surrounding forest.”
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 675

“Northern goshawk nest areas have forest conditions that are multi-aged but are 

dominated by large trees with relatively denser canopies than the surrounding forest.”

The biological assessment (Forest Service, 2014k), located in the plan set of documents and on 

the forests’ Web site at http://www.fs.usda.gov/main/asnf/landmanagement/planning, provides 

extensive discussion of conditions important to Mexican spotted owl and plan effects relative to 

plan decisions. These are summarized in chapter 3 of the EIS under the header “Endangered 

Species Act (ESA) Species Existing Condition and Critical Habitat” in the “Wildlife and Rare 

Plants” section.

Concern Statement: Add guidelines under Ponderosa Pine (proposed plan p. 41) for canopy 

cover and openings that provide habitat conditions consistent with the Mexican spotted owl 

Recovery Plan. (112.18)

Response: Tree density and openings for ponderosa pine are contained in desired conditions for 

this PNVT. While pure ponderosa pine is not Mexican spotted owl (MSO) recovery habitat, 

ponderosa pine with Gambel oak is MSO recovery habitat. Examples of guidelines and desired 

conditions with ponderosa pine that provide habitat conditions identified in the MSO recovery 

plan are noted in the response above.

Concern Statement: Include desired conditions, standards, and guidelines for the Forest 

Service to continue to work with the USFWS toward Mexican spotted owl recovery, 

including opportunities to incorporate conservation measures pursuant to 7(a)(1)of the 

Endangered Species Act. (112.20)

Response: There are numerous desired conditions, standards, and guidelines that address the 

composition, structure, and condition of forested PNVTs used by the Mexican spotted owl. One 

guideline, under the “Aquatic Habitat and Species” and the “Wildlife and Rare Plants” sections of 

the plan, requires that,

“Activities occurring within federally listed species habitat should apply habitat 

management direction and species protection measures from recovery plans.”

The Forest Service is required by law to work with the U.S. Fish and Wildlife Service to 

contribute to species recovery under the Endangered Species Act, (symbol) 7(a)1 which may 

include the development of conservation measures, if necessary.

Concern Statement: The Mexican spotted owl Recovery Plan does not discuss specific 

amounts or densities of snags, coarse woody debris, etc. but rather recommends retaining as 

much of these components as possible without affecting human safety, forest restoration and 

owl habitat so review the desired conditions for these components to match the owl recovery 

plan. (112.17)

Response: Desired conditions for PNVTs providing Mexican spotted owl habitat (ponderosa pine 

with Gambel oak, dry mixed conifer, wet mixed conifer, and spruce-fir) as described in the plan 

include ranges of snags, logs, or amounts of woody debris for each PNVT, although in the 

Community-Forest Intermix Management Area, the latter two PNVTs would be treated to be 

more open overall than elsewhere. In addition, desired conditions for “Wildlife and Rare Plants”

state, “habitat conditions contribute to the recovery of federally listed species,” so the needs of 

Mexican spotted owls are provided for in all cases.
Appendix A

676 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Include more specific guidelines for management and protection of 

Mexican spotted owls and other listed species on the Apache-Sitgreaves NF, under the 

Guidelines for Forest: All Forested PNVTs and Guidelines for Wildlife and Rare Plants

sections, in order to incorporate section 7(a)(l) recovery responsibilities. (112.15)

Response: The plan guideline under the “Wildlife and Rare Plants” section requiring that,

“activities occurring within federally listed species habitat should apply habitat management 

objectives and species protection measures from recovery plans” provides the specific direction 

for species like the Mexican spotted owl that have recovery plans. This helps address Federal 

agency responsibility under the Endangered Species Act § 7(a)(1).

Concern Statement: Correct the third column in table 74 (DEIS p. 247) that refers to 

remaining currently suitable northern goshawk habitat. This should be Mexican spotted 

owl habitat. (112.55)

Response: This error has been corrected in the EIS; thank you for pointing this out.

Concern Statement: Disclose the method used to estimate the availability of Mexican 

spotted owl critical habitat or changes to habitat that resulted from the 2011 Wallow Fire. 

(26.28)

Response: Mexican spotted owl habitat is provided by four forested potential natural vegetation 

types (PNVTs) (ponderosa pine with Gambel oak, dry mixed conifer, wet mixed conifer, and 

spruce-fir) and by three forested riparian PNVTs (cottonwood-willow, montane willow, and 

mixed broadleaf deciduous riparian forest). Note that the spruce-fir PNVT on the ApacheSitgreaves NFs meets the definition for “mixed conifer” found in the 2012 MSO recovery plan. 

The acreages and vegetation states or seral stages within these PNVTs are detailed in the 

“Vegetation Specialist Report” (Forest Service, 2014g) located in the plan set of documents and 

on the forests’ Web site at http://www.fs.usda.gov/main/asnf/landmanagement/planning. This 

report details how vegetation states were determined and includes post-Wallow Fire information.

Changes in habitat for the owl from the Wallow Fire are noted in the “Management Indicator 

Species (MIS) and Indicator Habitat” portion of the “Wildlife and Rare Plants” section of the EIS 

in table 74. This information is based in part on the biological assessment for the Wallow Fire 

Burned Area Emergency Response cited as “Forest Service, 2011d” which describes how habitat 

changes post-Wallow Fire were assessed.

Concern Statement: Consider foreseeable cumulative effects to Mexican spotted owl 

viability and recovery resulting from post-fire management activities authorized in critical 

habitat. (26.31)

Response: Endangered Species Act (ESA) cumulative effects include the effects of future State, 

tribal, or private actions that are reasonably certain to occur. Future Federal actions (e.g., post-fire 

management activities in critical habitat on Federal land) are not considered ESA cumulative 

effects for plan consultation because future Federal actions are required by law to have their own 

separate consultation (50 CFR § 402.14(g)(3) and (4).
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 677

Concern Statement: Include the reintroduction of Mexican wolves to their historic homes. 

(1.1, 162.111)

Response: The reintroduction of Mexican wolves is outside of the scope of the plan. It is 

addressed by the “Reintroduction of the Mexican Wolf within its Historic Range in the 

Southwestern United States Final Environmental Impact Statement” (USFWS, 1996). At this

time, the Apache-Sitgreaves NFs are one of two national forests in the Nation to provide a home 

for the recovery of the Mexican wolf. The plan provides direction to ensure the habitat (including 

secure habitat for the wolf and its prey) is available.

Concern Statement: The plan and implementation should give priority to the viability of the 

Mexican grey wolf population including: (1) minimizing human interference by motorized 

vehicles (including snowmobiles), (2) issuing temporary motorized closures near wolf 

denning and rendezvous sites, (3) minimizing conflicts with domestic livestock, and (4) 

allowing non-use of allotments. (127.4, 146.11, 162.110)

Response: Plan desired conditions under the “Wildlife and Rare Plants” section include,

“Wildlife are free from harassment and disturbance at a scale that impacts vital 

functions...that could affect persistence of the species.”

The plan’s management approaches for the “Wildlife and Rare Plants” section addresses the use 

of closures. The latter two comment items are outside of the scope of the plan. However, the Wolf 

Interagency Field Team works with grazing permittees and ranger district managers to help 

minimize conflicts with domestic livestock on a time-specific and site specific basis, including 

changing pasture rotations to avoid pastures with dens during the denning period. Forest Service 

Manual direction at 2231.7 and Forest Service Handbook direction at 2209.13 address nonuse for 

livestock grazing.

Concern Statement: Implement formal recovery plans and establish clear, binding 

standards to ensure the recovery of the Mexican wolf. (162.109)

Response: A plan guideline under the” Wildlife and Rare Plants” section requires that,

“Activities occurring within federally listed species habitat should apply habitat 

management direction and species protection measures from recovery plans.”

This would help toward Mexican wolf recovery.

Concern Statement: Add standards or guidelines specific to Mexican wolves: (1) require all 

permittees to remove or render inedible or unpalatable all livestock carcasses before wolves 

have the opportunity to scavenge them and (2) require all permittees to practice responsible 

livestock management practices, e.g., range riders, guard dogs. (162.112)

Response: Item 1 was a guideline within the June 2009 Working Draft Land Management Plan; 

however, this was an “Alternatives Considered and Eliminated from Detailed Study” (see the EIS 

section with this title). Specifically, this livestock grazing guideline for treatment of livestock 

carcasses to make them unpalatable was dropped because further review of the scientific 

literature showed this is not a cause of increased wolf predation. For item 2, as noted in a 

response above, the Wolf Interagency Field Team works with grazing permittees and ranger 
Appendix A

678 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

district managers to help minimize conflicts with domestic livestock on a time-specific and sitespecific basis.

Concern Statement: Require wolf-compatible livestock management in wolf use areas and 

enable the Forest Service to decrease livestock grazing in areas of high conflict, or when 

necessary to mitigate conflicts: (1) ensure sufficient prey availability to reduce livestock 

conflicts, (2) include plans for voluntary grazing retirements, and (3) include voluntary 

grazing non-use to protect denning and rendezvous sites, and (4) ensure a proper allocation 

of forage for non-livestock herbivores. (162.169)

Response: Livestock grazing administration involving allotment status or non-use such is outside 

of the scope of the plan as is retirement of grazing allotments. Ranger districts and the Wolf 

Interagency Field Team work with grazing permittees to help minimize conflicts with domestic 

livestock on a time-specific and site specific basis. This has included area closures around wolf 

den sites and sometimes changing pasture rotations to avoid areas where wolves are denning.

In terms of wolf prey, the plan fine scale desired condition for “All PNVTs” provides that,

“Herbaceous vegetation amount and structure (e.g., plant density, height, litter, seed 

heads) provides habitat to support wildlife and prey species.”

This would help support elk prey populations.

The plan contains one desired condition and one guideline under the “Livestock Grazing” section 

that addresses allocation of forage among herbivores. Respectively, these are: 

“Livestock grazing is in balance with available forage (i.e., grazing and browsing by 

authorized livestock, wild horses, and wildlife do not exceed available forage production 

within established use levels).” (desired condition)

“Forage, browse, and cover needs of wildlife, authorized livestock, and wild horses 

should be managed in balance with available forage so that plants providing for these 

needs remain at or move toward a healthy, persistent state.” (guideline)

Concern Statement: Limit or restrict roads and routes in sensitive wolf habitat (e.g., close 

roads around denning sites and pack territories, locate roads in forested areas and bounded 

by natural features, reassess roads and routes after the Wallow Fire). (162.114)

Response: The plan does not identify specific roads or routes for closure. Regarding road 

location and closures, as noted in the plan under the management approaches for the “Motorized 

Opportunities” section, potential changes to the Apache-Sitgreaves NFs transportation system 

will be evaluated and implemented through future project-level decisionmaking, including the 

implementation of the Travel Management Rule (36 CFR §212). The plan does provide direction 

to protect wildlife, including the Mexican wolf. For example, the following plan decisions are in 

the “Wildlife and Rare Plants” section,

“Wildlife are free from harassment and disturbance at a scale that impacts vital functions 

(e.g., breeding, rearing young) that could affect persistence of the species.” (desired 

condition)
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Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 679

“Modifications, mitigations, or other measures should be incorporated to reduce 

negative impacts to plants, animals, and their habitats and to help provide for species 

needs, consistent with project or activity objectives.” (guideline) 

On a yearly basis, areas around wolf denning sites including associated roads are closed 

temporarily as needed via forest special order as part of the Apache-Sitgreaves NFs

responsibilities under the Endangered Species Act § 7(a)(2) and as a participatory member of the 

Interagency Wolf Management Team. It is not practical to permanently close roads within 

territories because individual wolf pack territories, that range from 75,000 to over 800,000 acres, 

are fluid (e.g., wolves don’t stay within defined territories) and because wolf packs themselves 

are changing.

Concern Statement: Wilderness designation is an important means of protecting wolf 

habitat in Arizona and New Mexico. (88.2)

Response: The EIS analysis regarding “Habitat Security and Connectivity,” in the “Wildlife and 

Rare Plants” section, acknowledges that wilderness contributes to more secure wildlife habitat.

Concern Statement: The proposed plan has no standards for management of northern 

goshawk habitat, and omits any requirement to survey for goshawks prior to habitat 

disturbance, monitor populations, or retain structural attributes of ponderosa pine forest 

(e.g., canopy cover) essential to nesting and fledging behaviors of the sensitive species. 

(26.178, 162.26, 26.59)

Response: While there are no plan standards specifically related to northern goshawks, there are 

two guidelines under the “Wildlife and Rare Plants” section that address goshawk needs: 

“A minimum of six nest areas (known and replacement) should be located per northern 

goshawk territory. Northern goshawk nest and replacement nest areas should be located 

around active nests, in drainages, at the base of slopes, and on northerly (northwest to 

northeast) aspects. Nest areas should be 25 to 30 acres each in size.”

“Northern goshawk post-fledging family areas (PFAs) of approximately 420 acres in size 

should be designated around the nest sites.” 

In addition, desired conditions incorporate direction for northern goshawk under all the forested 

potential natural vegetation types (PNVTs) (ponderosa pine, dry mixed conifer, wet mixed 

conifer, and spruce-fir). For example, structural attributes are addressed in several desired

conditions including these in the “Forests: Ponderosa Pine” section,

“Northern goshawk post-fledging family areas (PFAs) may contain 10 to 20 percent 

higher basal area in mid-aged to old tree groups than northern goshawk foraging areas 

and the surrounding forest.”

“Northern goshawk nest areas have forest conditions that are multi-aged and dominated 

by large trees with relatively denser canopies than the surrounding forest.”

“The forest arrangement consists of individual trees, small clumps, and groups of trees 

interspersed within variably-sized openings of grasses, forbs, and shrubs. Vegetation

associations are similar to reference conditions. The size, shape, and number of trees per 
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680 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

group and the number of groups per area vary across the landscape. Tree density may be 

greater in some locations, such as north-facing slopes and canyon bottoms.”

“The tree group mosaic comprises an uneven-aged forest with all age classes, size 

classes, and structural stages present. Occasionally, patches of even-aged forest structure 

are present (less than 50 acres). Disturbances sustain the overall age and structural 

distribution.”

“Trees typically occur in irregularly shaped groups and are variably spaced with some 

tight clumps. Tree crowns in the mid- to old-aged groups are interlocking or nearly 

interlocking providing for species such as Abert’s squirrel.”

Survey for goshawks is conducted in accordance with the “Northern Goshawk Inventory and 

Monitoring Technical Guide” (Forest Service, 2006).

Concern Statement: Remove or greatly restrict herbivore use by domestic livestock and 

work with the AZGFD to manage elk use or decrease populations. Concern how the 

Grasslands fine scale desired conditions can be achieved given the current management of 

domestic livestock and uncontrolled herbivory by elk (proposed plan p. 57). (132.32)

Response: The plan provides desired conditions for herbivory to be in balance with available 

forage (see the “All PNVTs,” “Livestock Grazing,” and “Wild Horse Territory” sections). Within 

the “Livestock Grazing” section, the plan does provide the following guideline,

“Forage, browse, and cover needs of wildlife, authorized livestock, and wild horses 

should be managed in balance with available forage so that plants providing for these 

needs remain at or move toward a healthy, persistent state.” 

The effects of all grazers would be taken into account to move towards grassland and other 

desired conditions. The allocation of forage to domestic or wild animals is not determined at the 

plan level. 

Each year the Apache-Sitgreaves NFs provides the Arizona Game and Fish Department input on 

elk hunt recommendations based on precipitation, plant growth, and vegetation impacts expected 

and from the previous year; however, management of elk populations is outside of the mission of 

the Forest Service. Projects, including analyses of livestock grazing, must demonstrate how 

grassland desired conditions will be met or moved toward in order for the project to be consistent

with the plan (as described in the “Plan Consistency” section).

Concern Statement: Provide specifications for pronghorn antelope fence and other 

crossings (proposed plan p. 48). (132.35, 132.39)

Response: The plan addresses fences within pronghorn antelope habitat and other crossings 

through guidelines for grassland potential natural vegetation types (PNVTs) including:

“New fence construction or reconstruction where pronghorn antelope may be present 

should have a barbless bottom wire which is 18 inches from the ground to facilitate 

movement between pastures and other fenced areas. Pole and other types of fences 

should also provide for pronghorn antelope passage where they are present.” 
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Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 681

“Pronghorn antelope fence and other crossings should be installed along known 

movement corridors to prevent habitat fragmentation.”

In addition, an objective in the “Wildlife and Rare Plants” section would help improve wildlife 

habitat connectivity for pronghorn:

“Annually, improve wildlife connectivity by removing at least five unneeded structures 

(e.g., fence).”

Concern Statement: Describe how many miles of fence are in current and historic antelope 

habitat that need to be modified to prevent habitat fragmentation. (132.38)

Response: Additional information has been added for pronghorn antelope under the 

“Management Indicator Species (MIS) and Indicator Habitat” portion of the “Wildlife and Rare 

Plants” section of the EIS. Specifically, 

“...about 200 miles of unneeded fence line has been removed on the forests during the 

last 10 to 15 years (mostly in grasslands), and roughly 300 miles of fence line has been 

modified or rebuilt to wildlife passage standards. While not all of this affects the over 700 

miles of fence line in pronghorn grassland habitats, it does benefit pronghorn in areas 

where they encounter fences outside of grasslands.”

Concern Statement: Any project that could affect antelope should consider: (1) isolated 

small pronghorn populations become increasingly vulnerable to extirpation as numbers 

decrease. Genetic consequences are commonly considered, but stochastic events like 

predation, disease, and climatic events have a greater likelihood of causing extirpations, and 

(2) "predators taking 100 fawns from a population in a valley were 1,000 fawns are borne 

probably is biologically insignificant, but their taking 100 fawns in the same valley when 

only 150 fawns are born is significant.”. Reference: Pronghorn Ecology and Management, 

Bart O’Gara and Jim Yoakum, University of Colorado Press, 2004. (132.64)

Response: The “Management Indicator Species (MIS) and Indicator Habitat” portion of the 

“Wildlife and Rare Plants” section of the EIS notes that while pronghorn antelope are common 

and persistent on the Apache-Sitgreaves NFs, they occur at densities less than habitat capacity per 

information provided by the Arizona Game and Fish Department. As such, extensive restoration 

treatments of grasslands (up to 25,000 acres annually) and overly dense woodlands (5,000 to 

15,000 acres annually) are provided by plan objectives in order to expand suitable habitat 

conditions and facilitate pronghorn movement. In addition, as noted above, there are a number of 

guidelines that address fences for improved passage of wildlife including pronghorn antelope.

Fawn to doe ratios (fawn:doe) are set by Arizona Game and Fish Department and are outside of 

the Forest Service mission.

Concern Statement: Explain how the plan provides for the needs of antelope (hiding cover 

and food resources) while also providing forage for nonnative species. (132.62)

Response: A plan fine scale desired condition for grasslands addresses antelope needs for certain 

forage and herbaceous plant height during the critical fawning period. This does not mean that a 

project (e.g., livestock grazing on an allotment) must provide these conditions everywhere or all 

the time. Hence, livestock management can be adjusted, as by pasture rotations, to meet the 
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682 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

temporal and spatial requirements for pronghorn antelope fawning while still providing forage for

cattle, elk, and other species.

Concern Statement: There should be a desired condition that has a goal of at least 40 fawns 

per 100 does to expand the existing populations of antelope. (132.63)

Response: Fawn to doe ratios (fawn:doe) are set by Arizona Game and Fish Department and are 

outside of the scope of the plan.

Concern Statement: "In grasslands, maximum achievable cover height should be present in 

pastures with known antelope fawning areas each spring/summer ...” (p. 119) This 

statement effectively removes any known antelope fawning area from all livestock grazing 

without any evidence that properly managed grazing influences antelope fawning success. If 

other than only anecdotal evidence exists, then data should be provided. (108.238)

Response: This quote is not found in the proposed plan or DEIS. However, see the response 

above to comment number 132.62 in the “Wildlife and Rare Plants” section of this appendix.

Concern Statement: Correct the DEIS at page 249: "Semi-desert grasslands which on the 

forests occurs below the Mogollon Rim is isolated by topography and dense woodlands, 

supports limited numbers of pronghorn, and is not currently managed for the species by the 

AZGFD." Although pronghorn numbers may be limited, this area is currently managed for 

pronghorn. (101.92)

Response: This paragraph in the “Management Indicator Species (MIS) and Indicator Habitat” 

portion of “Wildlife and Rare Plants” section of the EIS has been rewritten to reflect the above 

clarification.

Concern Statement: Provide for high quality habitat and the maintenance of wildlife 

connectivity to preserve species viability. (101.1, 162.65, 37.3, 56.1, 132.37)

Response: The plan provides for quality wildlife habitat and connectivity. Wildlife habitat quality 

and connectivity are discussed under “Habitat Connectivity and Linkages” header in the “Wildlife 

and Rare Plants” section of the EIS. As noted, in addition to WQAs, other management areas 

such as wilderness, recommended wilderness, primitive area, and natural landscape also provide 

greater habitat security and connectivity.

Concern Statement: Protect wildlife corridors: (1) limit roads in some areas such as Little 

Creek, Paddy Creek, and along the Mogollon Rim, (2) wildlife linkages should have a road 

density of no more than 0.25 mile/square mile, limited developed sites, no logging (except 

restoration treatments), no vehicle or mountain bike use off of designated roads and trails, 

and no new road construction, and (3) roads and routes that threaten or significantly impair 

wildlife movement through critical corridors (162.116)

Response: The comment implies there are distinct, identified wildlife corridors; the plan does not 

delineate specific wildlife corridors. However, it does provide for wildlife habitat quality and 

connectivity. See the discussion of environmental consequences in the “Wildlife and Rare Plants” 

section of the EIS. As noted in the plan under the management approaches for the “Motorized 

Opportunities” section, potential site specific changes to the Apache-Sitgreaves NFs
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 683

transportation system will be evaluated and implemented through future project-level

decisionmaking, including the implementation of the Travel Management Rule (36 CFR §212).

The Arizona Game and Fish Department, in cooperation with various stakeholders, has completed 

a wildlife connectivity assessment identifying linkages for Coconino County. This process is 

underway for Navajo and Apache Counties (Apache-Sitgreaves NFs biologists have provided 

input), but the final report is not yet complete. The process has not been initiated for Greenlee 

County. The assessment would be used to better understand wildlife needs during project and 

activity-level planning

Concern Statement: We do not need any wildlife corridors. (24.3)

Response: The plan does not identify any “wildlife corridors.” The National Forest Management 

Act directs that plans address the viability of species. This entails providing for a wide range of 

wildlife needs such as forage, water, and cover. Genetic exchange between groups of individuals 

of a species is also important to species viability; hence, habitat connectivity has been addressed 

in the plan. Habitat connectivity is discussed under the “Habitat Connectivity and Linkages” 

header in the “Wildlife and Rare Plants” section of the EIS.

Concern Statement: Implement species recovery plans to ensure recovery of threatened and 

endangered species and establish standards to ensure the recovery of each at-risk plant and 

animal species that may occur on the forest. (14.2, 94.2, 23.10, 3.4)

Response: Plan guidelines under the “Aquatic Habitat and Species” and under the “Wildlife and 

Rare Plants” sections include the requirement that,

“Activities occurring within federally listed species habitat should apply habitat 

management direction and species protection measures from recovery plans.” 

For other species, guidelines in these same plan sections include the requirement that,

“Management and activities should not contribute to a trend toward the Federal listing 

of a species.” 

These guidelines help to contribute to recovery of threatened and endangered species and help 

address the needs of species that may be at-risk such as Regional Forester designated sensitive 

species.

Concern Statement: Provide the greatest possible safe habitat for predators (e.g., Mexican 

wolves, mountain lions). (80.3, 12.1)

Response: Plan alternatives provide varying levels of more secure habitat for wildlife, including 

Mexican wolves and mountain lions. See the EIS tables 1 and 2 for the acreages of those 

management areas providing more secure habitat (no motorized vehicle use) for wildlife.

Alternative D has the most acreage in secure habitat areas such as wilderness, recommended 

wilderness, primitive area, wildlife quiet areas, and natural landscape.
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684 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Provide habitat for Mexican wolves, and eventually grizzlies, jaguars 

and all other native species which formally lived in the region. (80.7)

Response: Introduction of extirpated species is outside of the scope of the plan. Habitat for 

Mexican wolves and their prey is addressed under the “Analysis of Species Viability” and the 

Endangered Species Act (ESA) Species” headers within the “Wildlife and Rare Plants” sections 

of the EIS.

Concern Statement: As is often the case, the issue of status of elk as being a nonnative

species is raised in this document. The existence of the Merriam’s subspecies is not well 

established in credible science. It is indisputable that Cervus elaphus or the American elk 

existed in the area now known as the Apache-Sitgreaves NFs. It is important to understand 

that the taxonomic status of what is purported to be Merriam’s elk is in question. (109.22)

Response: There is limited information regarding what is called Merriam’s elk being extirpated 

from the White Mountains of Arizona and nearby New Mexico in the early 1900s; therefore, there 

is debate about this animal.

Information used in the EIS about the Merriam’s elk was taken primarily from “Elk of North 

American–Ecology and Management” (Thomas and Toweill, 1982) and from historic records of 

Roosevelt elk introductions specifically on the Apache-Sitgreaves NFs. Another source of 

information is Heffelfinger et al. (2002) wherein some genetic samples of early Arizona elk 

remains (e.g., bones, skulls) were compared to genetics of elk in the White Mountains today.

They found that the genetic haplotypes of today’s Arizona elk match those of elk in the 

Yellowstone region, the source of the early 1900 elk introductions into this area. They found 

differences between the genetics of today’s elk and genetics from those limited historic elk 

samples. With limited samples and limited DNA segments, questions will remain.

Concern Statement: Clarify why fragmentation of habitat would be the major issue for 

wildlife as opposed to cover and food (forage). (108.221)

Response: To be fully viable, all life function needs of wildlife have to be met across their habitat 

and over time (Hunter, 1990). Habitat fragmentation may limit the ability to reach or have 

adequate amounts of cover and food (forage) as well as limit genetic exchange and species 

survival fitness over the long term. Habitats on the Apache-Sitgreaves NFs are fragmented by 

urban areas, roads, and power lines; however, habitat connectivity can help address this; the 

“Habitat Connectivity and Linkages” header in the “Wildlife and Rare Plants” section of the EIS 

addresses habitat connectivity.

Concern Statement: Explain the plan's definition of diversity and how it will be measured to 

evaluate progress. Explain the evidence that diversity has changed on the Apache-Sitgreaves 

NFs. (102.24, 108.247, 108.96, 102.3, 102.2, 102.1, 102.50)

Response: The definitions for both ecosystem diversity and biological diversity have been added 

to the plan’s glossary. Ecosystem diversity was further clarified in the plan in the “Maintenance 

and Improvement of Ecosystem Health” section:

“Healthy ecosystems are diverse and self-sustaining, displaying a variety of conditions 

(e.g., composition, structure, function, and processes) between and within them. 

Ecosystem diversity provides for the distribution, diversity, and complexity, and natural 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 685

disturbance regimes of watershed and landscape scale features, affecting including 

natural disturbance regimes of terrestrial, aquatic, and riparian ecosystems. 

Communities, populations, and individual plant and animal species are uniquely adapted 

to and dependent upon ecosystem diversity.” 

The plan itself does not call for measuring “diversity” per se, but the monitoring strategy set forth 

in the plan (chapter 5) includes the requirement to monitor various components of ecosystem and 

biological diversity. During plan analysis, the Vegetation Dynamics Development Tool (VDDT)

was used to determine how PNVT conditions have changed, i.e., how departed they are from 

historic or reference conditions. For more information, see the “Vegetation” section in chapter 3 

of the EIS.

Concern Statement: Explain the scientific basis and purpose for management indicator 

species (MIS). (102.34, 102.6, 102.20)

Response: Management indicator species (MIS) are used based on the assumption that they can 

reflect effects on a broader group of species in terms of assessing species viability and for use in 

developing plan alternatives in accordance with the National Forest Management Act (NFMA).

The Forest Service direction for use of MIS species is reiterated in the “Report on the Selection of 

Management Indicator Species and Ecological Indicators for Apache-Sitgreaves NFs” (Forest 

Service, 2014e) found in the plan set of documents and on the forests’ Web site at

http://www.fs.usda.gov/main/asnf/landmanagement/planning. This report contains that direction, 

in part:

“The 1976 National Forest Management Act (NFMA) regulations direct that "Fish and 

wildlife habitat shall be managed to maintain viable populations of existing native and 

desired nonnative vertebrate species in the planning area." For planning purposes, “a 

viable population shall be regarded as one which has the estimated numbers and 

distribution of reproductive individuals to insure its continued existence is well 

distributed in the planning area.” MIS is a concept adopted by the agency (1982 

Planning Rule provision 219.19) to serve, in part, as a barometer for species viability at 

the forest level. 

The 1982 regulations to implement the NFMA require that MIS be identified as part of 

the forest plan. Indicator species serve multiple functions in forest planning by focusing 

development of management alternatives and providing a means to analyze effects on 

biological diversity... Upon plan implementation, monitoring of MIS population trends in 

relationship to habitat changes serves as a reliable feedback mechanism about the 

consequences of land management.”

Additional information can be found in the “Wildlife Specialist Report-Viability” (Forest Service, 

2014l), including the referenced white paper on managing for population viability (Holthausen, 

2002).

Concern Statement: The plan's identification of management indicator species (MIS) is 

controversial because it (1) fails to capture the range of PNVT that host TES species whose 

viability is of planning concern and (2) significantly changes course from the 1987 plan 

which designates 17 MIS that better represent the range of habitats found on the forests. 

(127.48, 26.43, 127.50, 162.21, 162.18, 26.41, 162.19, 162.20)
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686 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Response: There is no requirement to select a management indicator species (MIS) for every 

potential natural vegetation type (PNVT). Rather MIS were selected for PNVTs where extensive 

restoration objectives are planned: ponderosa pine PNVT (northern goshawk), dry and wet mixed 

conifer PNVTs (Mexican spotted owl), and grassland PNVTs (pronghorn antelope). Threatened, 

endangered, and sensitive (TES) species have their own analyses in the EIS and plan biological 

assessment and biological evaluation.

Application of the 17 MIS identified in the 1987 plan was found to be less than useful because 

some species are habitat generalists (e.g., elk use grasslands, woodlands, forests, riparian areas, 

etc.) so their populations are not closely tied to management in any one habitat or PNVT. In 

addition, population changes of some 1987 plan MIS were too difficult to assess compared to 

influences (e.g., macroinvertebrates in watersheds that have more influencing factors than can be 

measured). 

Also, in lieu of selecting for a whole variety of birds that can be influenced by management and a 

broad range of species associated with water on the Apache-Sitgreaves NFs, two “ecological 

indicators” or EIs were selected. For a discussion of these aspen and riparian ecological 

indicators, see the “Habitat Ecological Indicators (EIs)” header in the “Wildlife and Rare Plants” 

section of the EIS.

Additional information about the MIS and EI selection process is documented in the “Report on 

the Selection of Management Indicator Species and Ecological Indicators for Apache-Sitgreaves 

NFs” (Forest Service, 2014e) found in the plan set of documents and on the forests’ Web site at 

http://www.fs.usda.gov/main/asnf/landmanagement/planning.

Concern Statement: Explain why aspen was not selected as an ecological indicator (EI). 

(127.49)

Response: Aspen was selected as an ecological indicator, as noted above, along with a riparian 

ecological indicator.

Concern Statement: Designate management indicator species (MIS) to evaluate the health 

of aquatic and riparian systems. (162.82, 26.45, 162.23, 162.22, 26.176)

Response: See the response as noted two comments above. It describes the difficulties of 

selecting a management indicator species for riparian areas and how the riparian ecological 

indicator was chosen to evaluate the health of riparian systems.

Concern Statement: Include the wetland/cienega PNVT as a riparian ecological indicator 

(EI). (112.51)

Response: Neither the wetland/cienega riparian area PNVT nor the mixed broadleaf deciduous 

riparian forest PNVT were selected for inclusion in the riparian ecological indicator. The 

cottonwood/willow riparian forest PNVT and the montane willow riparian forest PNVT together 

are selected as the riparian ecological indicator. 

This was not clear and has been corrected in the EIS along with rationale for not including the

wetland/cienega riparian area PNVT and not including the mixed broadleaf deciduous riparian 

forest PNVT. The rationale for not including these two PNVTs is documented in the “Report on 

the Selection of Management Indicator Species and Ecological Indicators” (Forest Service, 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 687

2014e) found in the plan set of documents and on the forests’ Web site at 

http://www.fs.usda.gov/main/asnf/landmanagement/planning.

The rationale for not including them as noted in that document follows: 

• While the wetland/cienega riparian area PNVT was initially considered as part of the 

riparian ecological indicator, it was dropped because riparian areas are critical areas for 

monitoring livestock grazing per many National Environmental Policy Act (NEPA) 

grazing decisions. Hence, there was no need to duplicate monitoring efforts. 

The mixed broadleaf deciduous riparian forest PNVT was not considered effective as part of a 

riparian ecological indicator. This PNVT occurs along larger streams and rivers on the ApacheSitgreaves NFs within large watersheds and is extensively affected by a multitude of impacts. 

This creates difficulties in trying to relate impacts within this PNVT to specific forests 

management and activities in the broad watershed.

Concern Statement: The agency admits failure to monitor threatened Mexican spotted owl 

and sensitive northern goshawk populations. Therefore, any estimate of management effect 

to the viability those MIS is arbitrary and capricious. Monitoring failures cast doubt on 

conclusions in the DEIS that the plan will maintain viable populations of proposed MIS. 

(26.179)

Response: The 1987 plan management indicator species (MIS) have been monitored. See the 

“Assessment of Management Indicator Species” (Forest Service, 2012a) document on file at the 

Apache-Sitgreaves NFs Supervisor’s Office that covers multiple years.

Both the Mexican spotted owl and northern goshawk are selected as management indicators in the 

plan and analyzed in the EIS. The 1982 Planning Rule provision at 219.12(k) requires a 

monitoring protocol or plan as discussed in the “Report on the Selection of Management Indicator

Species and Ecological Indicators” (Forest Service, 2014e) found in the plan set of documents 

and on the forests’ Web site at http://www.fs.usda.gov/main/asnf/landmanagement/planning.

Information gleaned from monitoring is used to detect changes in indicator populations and 

habitat trends. That information serves as a reliable feedback mechanism about the consequences 

of land management and facilitates adaptive management. Forest Service Manual 1922.7 and 

Forest Service Handbook 1909.12 chapter 6 provide direction for conducting monitoring and 

evaluation of indicators. Monitoring of MIS population trends in relationship to habitat changes is 

a required plan decision and is discussed in chapter 5 (“Monitoring Strategy”) of the plan.

Concern Statement: Include fine filter habitat elements to reduce viability risk for Mexican 

spotted owls. Include Mexican spotted owl as an associated forest plan species for riparian 

forests and Madrean pine-oak woodland PNVTs. (DEIS p. 227, 240). (112.49, 112.50, 112.53)

Response: A number of fine filter habitat elements that contribute to Mexican spotted owl 

viability are included in the plan. An example of a fine filter habitat guideline under “Forests: All 

Forested PNVTs” is: 

“Where current forests are lacking proportional representation of late seral states and 

species composition on a landscape scale, old growth characteristics should be retained 

or encouraged to the greatest extent possible within the scope of meeting other desired 
Appendix A

688 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

conditions (e.g., reduce impacts from insects and disease, reduce the threat of 

uncharacteristic wildfire).” 

Another example of a guideline under “Forests: Wet Mixed Conifer” is: 

“In mid-aged and older forests, trees are typically variably spaced with crowns 

interlocking (grouped and clumped trees) or nearly interlocking providing for species 

such as red squirrel. Trees within groups can be of similar or variable species and ages.” 

The Mexican spotted was included for the Madrean pine-oak woodland PNVT (DEIS table 66) 

but it was omitted for riparian forests. This has been corrected in the EIS; thank you for pointing 

this out.

Concern Statement: The plan should offer a different approach to ensure species viability 

that is both more protective of existing habitat and more pro-active in restoration of 

reference ecological condition. (162.17, 26.21, 26.3)

Response: The approach to species viability was conducted in accordance with the National 

Forest Management Act (provisions of the 1982 Planning Rule). The Forest Service Southwestern 

Regional Office also provided guidance for viability procedures (see the “Wildlife Specialist 

Report-Viability” (Forest Service, 2014l) in the plan set of documents and on the forests’ Web site 

at http://www.fs.usda.gov/main/asnf/landmanagement/planning for more detail). PNVT desired 

conditions are based on historic or reference conditions (see the “Vegetation” section in chapter 3 

of the EIS).

Concern Statement: Explain why the proposed plan's management approach to species 

viability is different than the 1987 plan and compare the impacts to the environment. 

(26.15)

Response: Species viability analyses under the 1987 plan (alternative A) and under the proposed 

plan (alternative B) and the other action alternatives (alternatives C and D) were conducted as 

directed by the National Forest Management Act (NFMA). The EIS analyzes and discloses the 

environmental consequences of all alternatives in chapter 3. The Forest Service Southwestern 

Regional Office provided guidance for conducting NFMA plan viability analyses at:

http://www.fs.usda.gov/detail/r3/landmanagement/planning/?cid=stelprdb5177400. Also see the 

“Provision for Species Viability” and “Analysis of Species Viability” headers in the “Wildlife and 

Rare Plants” section in the EIS.

Concern Statement: The species viability analysis does not meet NFMA (National Forest 

Management Act) requirements because it does not use a reliable and accurate habitatproxy. To meet the species viability requirement: (1) avoid grouping TES species with more 

common or less specialized animals in the viability analysis, (2) identify a minimum number 

of individuals comprising viable populations, and (3) demonstrate spatially that adequate 

habitat exists for each species of planning concern. (26.32, 108.235, 26.40, 26.39, 26.34, 

26.27, 26.26, 26.25, 26.23, 26.44, 26.175, 26.24, 162.15, 162.16, 26.13, 26.173, 127.22, 26.20, 

162.14)

Response: In assessing species viability, the Apache-Sitgreaves NFs first looked at the potential 

natural vegetation types (PNVTs) providing habitat for a species (coarse filter step). Next, if the 

desired conditions for that PNVT do not fully meet the needs for a species, a fine filter step was 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 689

taken wherein a plan decision was added (standard or guideline). For more information, see the 

“Wildlife Specialist Report-Viability” (Forest Service, 2014l) in the plan set of documents and on 

the forests’ Web site at http://www.fs.usda.gov/main/asnf/landmanagement/planning. However, 

the coarse filter/fine filter approach does not assume that the PNVTs are a proxy for viability, nor 

is the viability analysis process a habitat proxy. In addition, there is no National Forest 

Management Act (NFMA) requirement to spatially demonstrate adequate habitat for each species 

and the Vegetation Dynamics Development Tool (VDDT) modeling is not spatially explicit.

The viability analysis grouped species by the PNVT(s) or habitat element(s) they rely on for 

habitat. Other wildlife specialist reports assessed these species relative to requirements based on 

their status (e.g., threatened/endangered, sensitive, management indicator species, etc.). For 

example, the threatened/endangered species were also analyzed in accordance with Endangered 

Species Act requirements in the biological assessment.

The analysis of species viability was conducted as directed in accordance with National Forest 

Management Act (36 CFR § 219.19) that defines a viable population as,

“one which has the estimated numbers and distribution of reproductive individuals to 

insure its continued existence is well distributed in the planning areas.”

This species viability analysis is not population viability analysis which is the probability of a 

population persisting for a biologically meaningful timeframe and which often seeks to identify a 

minimum number of individuals for population persistence. 

Concern Statement: The EIS should account for southwestern willow flycatcher designated 

critical habitat as identified in the final USFWS rule (See 78 Fed. Reg. 344-534 (Jan. 3, 

2013) (final rule)). (26.174)

Response: The DEIS was submitted for printing prior to the final designation of critical habitat 

for the Southwestern willow flycatcher; the EIS has been updated to include the latest critical 

habitat status and analysis.

Concern Statement: Please vote yes on A.B. 1213 (Bloom), the Bobcat Protection Act of 

2013, which would ban trapping and commercial sale of bobcats in California. California's 

native wildlife should not be exploited and harmed for personal commercial gain. (17.1)

Response: The comment is beyond the scope of the plan. The Apache-Sitgreaves NFs is located 

in Arizona, not California. In addition, as an agency, the Forest Service does not have voting 

rights.

Invasive Species

Concern Statement: Treat more than the planned Invasive Species objective "Annually, 

control or eradicate invasive species (e.g., tamarisk, bullfrogs) on at least 2 stream miles" 

(proposed plan p. 64). (146.4, 162.102)

Response: The plan objective above describes a minimum level based on the estimated 

workforce capacity and anticipated funding. As described in the “Plan Content” section in chapter 

1 of the plan, 
Appendix A

690 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

“Objectives are strongly influenced by recent trends, past experiences and anticipated 

staffing levels, and short term budgets. Variation in achieving objectives may occur 

during the next 15 years because of changes in environmental conditions, available 

budgets, and other factors.” 

If conditions allow, additional stream mileage could be treated to control or eradicate invasive 

species.

Concern Statement: Eradication of cowbirds is included as an objective in this Invasive 

Species section (proposed plan p. 64). Please note that such actions need to be coordinated 

with the Department and appropriate permitting obtained. (101.65)

Response: The Apache-Sitgreaves NFs would follow existing law, regulation, and policy (which 

is not repeated in the plan) when implementing the objectives to contain, control, or eradicate 

plant or animal invasive species. This includes obtaining all State and Federal permits for wildlife 

work as required.

Concern Statement: Add a guideline for Invasive Species: "Treatments should be 

prioritized to minimize effort and maximize results." (162.104)

Response: There is an existing guideline in the “Invasive Species” section within chapter 2 of the 

plan that addresses treatment efficacy. Prioritization of treatments is critical to treatment efficacy.

The guideline states,

“Treatment of invasive species should be designed to effectively control or eliminate 

them; multiple treatments may be needed.”

Concern Statement: Add a guideline for Invasive Species: "Motorized equipment used in 

projects should be cleaned of all mud and plant propagules before entering a project area, 

and workers should be instructed on how to identify invasive species and avoid spreading 

them (i.e., clean mud and seeds off of shoes and socks, avoid walking though invasive plant 

patches, don't throw plants that have gone to seed into streams or washes)." (162.105)

Response: Although not explicit, this would be covered by the standard for “Invasive Species” in 

chapter 2 of the plan, 

“Projects and authorized activities shall be designed to reduce the potential for 

introduction of new species or spread of existing invasive or undesirable aquatic or 

terrestrial nonnative populations.” 

Additional guidance that would prevent or limit the spread of invasive species has been added to 

the “Other Sources of Information” for invasive species section of Appendix D in the plan. For 

example, appendix A of the “Environmental Assessment for the Apache-Sitgreaves NFs 

Integrated Forestwide Noxious or Invasive Weed Management Program” (Forest Service, 2008b) 

provides guidance to prevent new noxious and invasive weed infestations and the spread of 

existing noxious and invasive weeds.

Concern Statement: Add a guideline to require weed and seed free hay and feed. (162.106)

Response: Although not explicit, this would be covered by the standard for invasive species in 

chapter 2 of the plan, 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 691

“Projects and authorized activities shall be designed to reduce the potential for 

introduction of new species or spread of existing invasive or undesirable aquatic or 

terrestrial nonnative populations.” 

In addition, Forest Service Manual 2900 Invasive Species Management was added to the “Other 

Sources of Information” for invasive species section of Appendix D in the plan. This manual 

describes Forest Service policy on weed-free materials.

Concern Statement: Modify Invasive Species Guideline (proposed plan p. 64) "Projects and 

activities, except as needed for wildlife conservation and management projects (i.e., native 

species recovery and management, and sportfish stocking), should not transfer water between 

drainages or between unconnected water bodies within the same drainage to avoid 

spreading disease and aquatic invasive species. For projects and activities where water 

transfers will occur, measures should be taken to prevent the spread of non-target fish species, 

invasive species, parasites, or diseases.” (101.66)

Response: No modifications were made to the plan based on this comment. The intent of this 

guideline is to prevent the spread of nonnative species or diseases that could occur through site 

specific actions implemented under the plan (e.g., water transfers, movement of equipment) and 

would apply to all projects and activities.

Concern Statement: The objective should be to encourage species which contribute to the 

goals of the plan and to control or eliminate (where feasible) those that don't regardless of 

whether they are native or not. (102.23)

Response: The desired conditions, standards, and guidelines throughout the plan are purposely 

intended to maintain and improve native and desirable nonnative species and prevent the spread 

of noxious or invasive species (through containment, control, or eradication).

Concern Statement: The forests should plan to repeat invasive species eradication 

treatments annually for at least five years. (162.103)

Response: Treatment of invasive species populations would be conducted annually as identified 

in the objectives for invasive species in order to contain, control, or eradicate these populations.

The specific amount or repetition of treatments for a particular piece of ground would be 

identified at the project level. For some species, annual treatments may exceed five years in order 

to successfully eradicate established populations.

Concern Statement: Juniper and salt cedar need to be eliminated. (148.2)

Response: Objectives for “Woodlands: All Woodland PNVTs” within chapter 2 of the plan 

identify the need to treat 5,000 to 15,000 acres annually to promote a highly diverse structure.

The intent is not to eliminate juniper but to provide for a more open canopy with trees being 

widely spaced with a higher amount of understory herbaceous vegetation to provide for soil 

productivity, traditional uses, and wildlife needs.

In regard to salt cedar, there is a need to contain, control, or eradicate this invasive species. The 

plan provides direction for this in the “Invasive Species” section in chapter 2 including,

“Invasive species (both plant and animal) are nonexistent or in low occurrence to avoid 

negative impacts to ecosystems.” (desired condition)
Appendix A

692 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

“Undesirable nonnative species are absent or present only to the extent that they do not 

adversely affect ecosystem composition, structure, or function, including native species 

populations or the natural fire regime.” (desired condition)

“Annually, contain, control, or eradicate invasive species (e.g., musk thistle, Dalmatian 

toadflax, cowbirds) on 500 to 3,500 acres.” (objective)

Concern Statement: Add to Other Sources of Information for Invasive Species (proposed 

plan p.65): Aquatic Nuisance Species Task Force. 2011. State of Arizona Aquatic Invasive 

Species Management Plan. At http://anstaskforce.gov/State%20Plans/AZ/AISMPlan.pdf

(162.107)

Response: This has been added to the plan in appendix D.

Concern Statement: Clarify the term wild horses. Concern that wild horses associated with 

the Heber Wild Horse Territory may be confused with unauthorized horses. (105.19, 123.8, 

99.35, 99.33, 99.20, 99.1, 123.10, 131.17)

Response: The definition for feral horse was added to the plan. See definitions for feral horse, 

unauthorized livestock, and wild horse in the plan’s glossary.

Concern Statement: Complete the herd management plan for the Heber Wild Horse 

Territory with full public review as required by NEPA (National Environmental Policy Act). 

(109.10, 109.9)

Response: The completion of a management plan for the Heber Wild Horse Territory is outside 

the scope of the plan and plan revision process. The Forest Service is currently working toward 

the completion of the Heber Wild Horse Territory Management Plan; the expected date of 

completion is the fall of 2015.

Concern Statement: Recognize the impact of unauthorized horses in the Black River 

drainage, including their destruction of habitat. (109.8)

Response: The Forest Service recognizes the presence of unauthorized livestock, including feral 

horses, across the forests. The background of the “Invasive Species” section of the plan has been 

updated to include information about these feral horses and their impact on ecological conditions. 

Concern Statement: Horses, other than wild horses, should not be included when 

determining the needs and management of livestock and wildlife. Concern with guideline 

“forage, browse and cover needs of wildlife, authorized livestock, and wild horses should be 

managed in balance with available forage" (proposed plan p. 96). (138.33, 123.9, 123.7)

Response: Unauthorized livestock, including feral horses (see definition in EIS glossary), are not 

included as part of this guideline. This guideline only applies to wildlife, authorized livestock, 

and wild horses.

Concern Statement: Explain why there is not an established use level for wild horses except 

for the Heber Wild Horse Territory. (138.15)

Response: Use levels are assigned only to wild horses in the Heber Wild Horse Territory.

Established use levels are not assigned to unauthorized livestock, including feral horses.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 693

Unauthorized livestock are prohibited on National Forest System land by regulation (36 CFR § 

261.7). 

Concern Statement: If no wild horses currently inhabit the wild horse territory, this area 

should be dropped as a management area. (99.10, 99.12)

Response: The wild horse territory remains as one of the 12 management areas identified in 

chapter 3 of the plan. The Heber Wild Horse Territory management plan (in progress) will 

identify the appropriate management level (number of wild horses) for this area. If this number is 

zero, the plan could be amended in the future to remove the territory.

Concern Statement: The Heber Wild Horse Territory should be abolished. (108.167)

Response: The Heber Wild Horse Territory was established by Congress and as such, can only be 

removed by a Congressional Act.

Concern Statement: Modify Wild Horse Territory Desired Condition (proposed plan p. 111) 

"Grazing is in balance with available forage (i.e., grazing and browsing by authorized and 

unauthorized livestock, wild horses, feral horses and hogs, and wildlife do not exceed the 

available forage production within established use levels)." (101.82)

Response: The desired condition has not been modified based on this comment. Feral horses and 

hogs fall under the definition for unauthorized livestock. The intent of this desired condition is to 

address allowable use levels for authorized livestock under a permit, wild horses, and wildlife.

Unauthorized livestock, including feral horses and hogs, are not part of any desired condition.

Recreation

Concern Statement: In Overall Recreation Opportunities affected environment (DEIS p. 

316), there should be a discussion identifying the uses practiced by the local residents and 

the importance of the forests to the local population and economy. (99.23)

Response: The recreation data from the National Visitor Use Monitoring used in the EIS does not 

differentiate between local users and users from more distant population centers. Additional 

language was added to the “Overall Recreation Opportunities” section of the EIS to highlight the 

percentage of visitor use the forests receive from the counties where the forests are located. The 

importance of the forests to the local population and economy is reflected throughout the plan and 

EIS, especially the “Recreation,” “Forest Products,” and “Socioeconomic Resources” sections.

Concern Statement: Modify Overall Recreational Opportunities Background (proposed 

plan p. 68). Add boating to the list of primary recreational activities. Kayaking and 

canoeing are becoming very popular activities on some lakes such as Fool Hollow, Bear 

Canyon, and Woods Canyon, in addition to some motorized boating recreation. (101.68)

Response: Additional language was added to the “Background for Overall Recreation 

Opportunities” section of the plan, 

“A wide variety of other activities, including boating and hunting, also occur on the 

forests.”
Appendix A

694 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

The primary recreation activities (those with the higher primary activity percentages) listed in the 

plan are taken from table 110 in the “Recreation” section of the EIS and are based on the national 

visitor use monitoring results (Kocis et al., 2002).

Concern Statement: Modify Developed Recreation Background (proposed plan p. 72). In 

addition to the Apache-Sitgreaves NFs and State Parks, Fool Hollow Lake Recreation Area 

is operated through a partnership with the Arizona Game and Fish Department and the 

City of Show Low. (101.69)

Response: The Arizona Game and Fish Department and the City of Show Low have been added 

to the sentence about Fool Hollow Lake in the “Background for Developed Recreation” section of 

the plan.

Concern Statement: Dispersed camping should be part of the future of the forest. (153.1, 

149.5)

Response: The plan recognizes the importance of dispersed recreation, including dispersed 

camping, to the forests’ visitors. Desired conditions, objectives, standards, guidelines, and 

management approaches for dispersed recreation are found in the “Dispersed Recreation” section 

of the plan.

Concern Statement: Concern that there may be conflicts between ROS (recreation 

opportunity spectrum) classification and access (motorized and non-motorized) to State 

Trust Land. For example, NFS land adjacent to State Land is classified as Semi-Primitive 

Motorized (SPM), however access and motorized use through State Trust land is allowed 

only on designated routes permitted by the Arizona State Land Department. (34.7, 34.6, 

34.2, 34.4)

Response: The Recreation Opportunity Spectrum (ROS) is a planning tool for defining and 

identifying the types of outdoor recreation opportunities available on forest lands based on the 

social, physical, and managerial settings. ROS is discussed in the affected environment of the

“Managed Recreation” section of the EIS. The plan provides guidance that recreation related 

project-level decisions and implementation activities should be consistent with the ROS. The plan

does not direct or designate routes or areas for motorized travel. Specific access and motorized 

use determinations adjacent to State Trust Land would be done through future project-level

decisionmaking, including the implementation of the Travel Management Rule (36 CFR §212).

Concern Statement: More effort should be placed on encouraging volunteerism. (99.16, 

99.4)

Response: The desired conditions in the “Overall Recreation Opportunities” section of the plan

include volunteers:

“Recreation opportunities provide for a variety of skill levels, needs, and desires in 

partnership with recreation permit holders, private entities, volunteer groups, community 

groups, and State, Federal, and tribal governments.” 

The use of volunteers is also included as a management approach for accomplishing plan desired 

conditions, objectives, standards, and guidelines. Volunteers are specifically mentioned in the 

plan as management approaches for “Motorized Opportunities” and “Nonmotorized 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 695

Opportunities,” in the introductory paragraphs for “Community-Forest Interaction,” and in 

appendix E (“Possible Management Actions”).

Concern Statement: Describe the recreation development planned in each alternative. 

(149.1)

Response: The plan is programmatic in nature and does not identify any new recreation 

developments. Therefore, no specific recreation developments are analyzed in the EIS. Any new

recreation development would be addressed site specifically at the project-level. The plan 

provides a framework for future recreation development and focuses on maintaining existing 

recreation facilities in a safe and sustainable manner for quality visitor opportunities. Any new 

construction would be balanced with current and future maintenance requirements.

Concern Statement: Make the developed campgrounds more spacious with larger parking 

places for trailers, motor homes, and tow vehicles. Provide more space between camping 

sites. (98.25)

Response: The redesign of existing campgrounds and the design of any new campground are 

beyond the scope of the plan. Modifications to recreation sites would be subject to project-level

National Environmental Policy Act (NEPA) analyses, including opportunities for public 

involvement.

Concern Statement: Recreation demand data should be used to inform decisions on 

recreation. The forests should ensure the next National Visitor Use Monitoring (NVUM) 

survey has a sufficient response rate to be meaningful. (162.123, 162.173, 108.28, 162.122)

Response: Data on recreation demand was used in the analysis presented in the “Recreation” 

section of the EIS. Sources included the 2001 National Visitor Use Monitoring (NVUM) survey 

(Kocis et al., 2002), National (Cordell et al., 2004, 2008a, and 2009), and State (Arizona State 

Parks, 2007 and 2009) information. It is recognized that not all forest uses can occur at the same 

time in the same location. The plan provides a spectrum of recreation settings and opportunities 

for a variety of users and activities.

The request concerning the NVUM survey is beyond the scope of the plan and plan revision 

process. Presently, there is no data specific to the Apache-Sitgreaves NFs available to determine 

recreation use trends. When the data collected by the Fiscal Year 2014 NVUM survey is analyzed, 

this information should be available. 

Concern Statement: The plan should meet the people's desires for recreation as they have 

historically enjoyed it. (149.4, 81.1)

Response: The plan strives to balance the developed, dispersed, motorized, and nonmotorized 

recreation opportunities available on the forests. If only “historically enjoyed” recreation were 

allowed, that could limit the recreation opportunities currently available and those that may arise 

in the future.

Concern Statement: Shooting sports, including shooting ranges, should not be considered a 

use on public land. (2.1, 2.2)

Response: Eliminating shooting sports is beyond the scope of the plan and plan revision process. 

Shooting sports, including target ranges, are a legitimate use of National Forest System lands. 
Appendix A

696 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Target ranges are permitted as a recreation special use under Forest Service Handbook 2709.14 -

Recreation Special Uses Handbook, Chapter 70 - Target Ranges and Other Outdoor Recreation 

Improvements. The plan contains a guideline in the “Special Uses” section that would limit the 

location of new target ranges to the General Forest and Community-Forest Intermix Management 

Areas.

Concern Statement: Wildlife-based recreation is important to the economy. There is a need 

to protect wildlife habitat. (18.1, 60.3)

Response: The plan acknowledges the economic contribution of visitors, including those that 

view wildlife, hunt, and fish. Wildlife habitat would be improved and maintained through the 

activities and treatments identified throughout the plan to restore potential natural vegetation 

types and functioning ecosystems. Several management areas identified in the plan would also 

respond to a variety of wildlife needs; these include Wildlife Quiet Area, Natural Landscape, 

Recommended Wilderness, Primitive Area, and Wilderness.

Motorized and Nonmotorized Opportunities

Concern Statement: Consider development of more multi-use single track and OHV trails. 

(44.1, 22.1)

Response: The plan would allow the development of single track and off-highway vehicle (OHV)

trails (see “Motorized Uses Suitability” in chapter 4). Development of any new motorized trail 

would be addressed site specifically and a decision made following a project-level National 

Environmental Policy Act (NEPA) analysis.

Concern Statement: Do not eliminate opportunities to use OHVs (off-highway vehicles) or 

ATVs (all-terrain vehicles) on the forest. (43.2, 42.3, 114.1)

Response: The plan allows a variety of motorized recreation opportunities, including offhighway vehicle (OHV) and all-terrain vehicle (ATV) use. The identification of specific OHV 

and ATV routes would be considered in future project-level decisions, including implementation 

of the Travel Management Rule (36 CFR §212) for the Apache-Sitgreaves NFs. Some 

management areas and other areas may not be suitable for motorized use (see plan chapter 4 

under “Motorized Uses Suitability”).

Concern Statement: Consider the impacts from OHVs (off-highway vehicles) including loss 

of meadows and traditional campsites, exhaust and noise pollution, soil loss causes (loss of 

vegetation, wildlife habitat, overall long term forest productivity, biological diversity, etc.). 

(66.1, 124.5, 124.14)

Response: The environmental consequences of OHVs, motorized recreation, and motorized 

cross-country travel on forest resources are discussed in chapter 3 of the EIS in the “Air,” “Soil,”

“Watershed,” “Water Resources,” “Invasive Species,” “Riparian,” “Recreation,” “Infrastructure,”

“Inventoried Roadless Areas,” “Wilderness Resources,” “Scenic Resources,” “Cultural 

Resources,” “American Indian Rights and Interests,” and “Livestock Grazing” sections.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 697

Concern Statement: Maintain the OHV trail system along the San Francisco River. (113.4, 

160.2)

Response: The plan is programmatic in nature and does not address specific off-highway vehicle 

(OHV) trails. This topic could be addressed in future project-level decisionmaking, such as

implementation of the Travel Management Rule (36 CFR §212) for the Apache-Sitgreaves NFs.

Concern Statement: The Forest Service should more carefully consider the sources it cites to 

support development of more ORV routes. Those that have a bias do not represent the 

interests of the majority of forest users. (162.185)

Response: The commenter refers to the following statement from the “Recreation” section of the 

EIS:

“The use of motorized vehicles for recreation activities has increased dramatically in 

recent years.” 

The source of this information is the State of Arizona (Arizona State Parks, 2007). The 

commenter did not provide references to refute this statement.

Concern Statement: Clarify Motorized Opportunities Background (proposed plan p. 73). 

The final sentence in this paragraph states "These roads and trails are also needed for 

forest management." It is unclear if the Apache-Sitgreaves NFs is also considering 

unauthorized roads (user-created) as being needed for forest management. (101.70)

Response: The paragraph under “Background for Motorized Opportunities” in the plan has been 

reorganized to eliminate the confusion. The statement in the proposed plan was not intended to 

infer that unauthorized roads are needed for management.

Concern Statement: Modify Motorized Opportunities Desired Condition (proposed plan p. 

73) "Open NFS roads and motorized trails are easily identified on the ground (e.g., wellmarked, and marked open unless closed). (101.71)

Response: The plan has been modified in the desired conditions for the “Motorized 

Opportunities” section to read:

“NFS roads, motorized trails, and motorized areas are easily identified on the ground 

(e.g., well marked).” 

The specific requirements for how the routes will be marked (e.g., closed unless designated open) 

would be addressed in a separate site specific implementation plan following the completion of 

the public motorized travel management planning process (implementation of Subpart B of the 

Travel Management Rule (36 CFR §212)).
Appendix A

698 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Modify Motorized Opportunities Management Approaches (proposed 

plan p.76) "The Apache-Sitgreaves NFs coordinate with Federal Highways Administration, 

Arizona Game and Fish Department, and ADOT to facilitate transportation needs, planned 

improvements, and transportation conditions. Apache-Sitgreaves NFs work with ADOT and 

Arizona Game and Fish Department to alleviate concerns with scenic resources; maintenance 

activities; use of herbicides; use of deicing agents; and creation of turnouts, parking lots, 

and wildlife crossings." (101.74)

Response: This management approach describes how the Apache- Sitgreaves NFs provide input 

to the Arizona Department of Transportation (ADOT) and Federal Highways Administration 

when those agencies propose any reconstruction and/or heavy maintenance of their roads 

(easements) that cross National Forest System (NFS) land. The Arizona Game and Fish 

Department was not included because they do not own any roads that cross NFS land. 

Concern Statement: Use decommissioned roads as hiking trails. (109.27)

Response: The plan would allow the consideration of this concept. However, conversion of a 

decommissioned road to a hiking trail would be determined site specifically following projectlevel National Environmental Policy Act (NEPA) analysis.

Concern Statement: Address maintenance and management of cross-country ski facilities. 

Add an objective to accomplish this. (99.14, 99.15, 99.17)

Response: The “Dispersed Recreation” and “Nonmotorized Opportunities” sections of the plan 

provide management direction for winter recreation. The plan is programmatic in nature and 

management of specific recreation facilities would be addressed through site-specific recreation 

plans and day-to-day management at the project-level.

Concern Statement: Correct the Motorized Routes affected environment statement "An 

inventory has not been completed, but it is estimated that there are hundreds of miles of 

unauthorized routes" (DEIS p. 332). CMLUA (Citizens for Multiple Land Use and Access) 

spent over 2 years cataloging many of these routes for the Forest Service. (147.10)

Response: The Forest Service acknowledges and appreciates the contribution made by the 

Citizens for Multiple Land Use and Access (CMLUA). The group identified many unauthorized 

motorized routes on the Apache NF portion of the forests in response to the travel management 

planning efforts. The forests are required to validate this information prior to adding it to our 

geographic information system (GIS) database, and this will be an on-going process as resources 

are made available. In addition to the inventory provided by CMLUA, it is still estimated there 

are hundreds of miles of unauthorized routes on the Sitgreaves NF portion of the forests. 

Concern Statement: Remaining roads should be decommissioned or significantly reduced to 

limit incursion by motorized travel into sensitive areas. (5.13)

Response: Objectives for closing, relocating, and decommissioning of existing system roads and 

unauthorized motorized routes to protect sensitive areas are contained in the “Riparian Areas” 

section of the plan. The plan also contains standards and guidelines in the “Motorized 

Opportunities” section to minimize incursion or effects of motorized trails into sensitive areas. 

The plan provides a framework to guide future changes to the transportation system. Actual 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 699

decommissioning or closure of roads would only be authorized following project-level National 

Environmental Policy Act (NEPA) analyses, including opportunity for public involvement.

Concern Statement: Prohibit new road and motorized trail development. There are too 

many roads. (5.20, 9.13, 41.1, 94.4, 94.3, 8.2, 64.2, 47.1, 23.12, 158.2, 107.2, 80.4, 73.2, 74.1)

Response: An alternative to prohibit new road or motorized trail construction was considered; 

however; it was considered not feasible. For example, new road construction may be required

when access to a particular resource or private inholding is needed. New motorized trails may be 

needed to provide a variety of opportunities, including destinations and loops. See the 

“Alternatives Considered but Eliminated from Detailed Study” section in chapter 2 of the EIS for 

more information. 

All of the action alternatives, including the plan, were designed to address the impacts of roads 

and motorized trails on forest resources. Plan direction identifies areas suitable for new road and 

motorized trail development, minimizes new road construction, and provides objectives to 

decommission existing roads and unauthorized motorized routes and relocate existing roads. Any 

new road or motorized trail construction would only be authorized following project-level

National Environmental Policy Act (NEPA) analyses and would be accomplished using best 

management practices (BMPs) to minimize resource impacts while providing for access needs to 

the forests. 

Concern Statement: Do not close roads. (95.1, 130.2, 136.1, 6.4)

Response: The plan provides a framework to guide future changes to the transportation system.

Potential changes to the forests’ transportation system, including road closures, would be 

evaluated in future project-level decisionmaking, including the implementation of the Travel 

Management Rule (36 CFR §212). Those decisions would be consistent with the National 

Environmental Policy Act (NEPA), including analysis and opportunity for public involvement.

Concern Statement: Prioritize maintenance and access for level 3-5 roads (suitable for 

passenger cars) and close level 2 roads (high clearance vehicles) when financial limits 

restrict the amount of maintenance that can be performed. (162.124)

Response: Prioritization of road maintenance planning is outside the scope of the plan and plan 

revision process. Maintenance planning is a requirement of Forest Service Manual 7732.11 that

requires the forest to,

“Develop annual road maintenance plans based on road management objectives and 

expected traffic for all National Forest System Roads.”

“Clearly display the allocation of available funds in highest priority order in road 

maintenance plans in case of funding short falls.”

Concern Statement: No new level 2 roads should be considered and large portions of the 

forest should not be considered suitable for additional road development unless level 3-5 

roads are required. (162.125)

Response: The plan provides a framework to guide future changes to the transportation system.

Potential changes to the forests’ transportation system, including new roads, would be evaluated 
Appendix A

700 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

in future project-level decisionmaking, including the implementation of the Travel Management 

Rule (36 CFR §212). 

The plan describes the suitability of areas for new roads in the “Motorized Uses Suitability” 

section in chapter 4 of the plan. Although certain areas may be determined suitable for the 

development of new roads, there may be specific locations where plan standards and guidelines

would restrict the development of new roads.

Proposals for new road development and the associated environmental effects would be 

considered through project-level planning. Any new road construction design would be consistent 

with plan standards and guidelines, best management practice (BMPs), and Forest Service

Handbook 7709.56 Road Preconstruction Handbook.

The assigned road maintenance level (e.g., level 2) is a function of the road management 

objective (RMO). Direction on RMOs can be found in Forest Service Manual 7714 and Forest 

Service Handbook 7709.59, Chapter 10. The RMOs should complement the resource 

management objectives contained in the documentation for the project. The resource prescriptions 

and RMOs are key items used to determine road design criteria, elements, and standards. 

Concern Statement: Add a standard for road density of 2.0 mile/square mile or less. (162.39, 

94.13, 26.138, 3.3)

Response: An alternative was considered but not analyzed in detail that included a road density 

standard (see the “Alternatives Considered but Eliminated from Detailed Study” section in 

chapter 2 of the EIS). The plan provides for the protection and management of healthy and 

sustainable soils, watersheds, and wildlife connectivity which are the primary resource concerns 

associated with National Forest System roads and motorized trails.

Potential changes to the forests’ transportation system would be evaluated in separate analysis 

through future project-level decisionmaking such as the implementation of the Travel 

Management Rule (36 CFR§212). Site specific travel management planning will use the 

framework set by the plan (e.g., desired conditions, standards, guidelines) and will consider

potential resource impacts, access needs, public input, and alternative views rather than using an 

arbitrary road density target. If undesirable resource conditions resulted from open roads, they 

could be addressed through site specific evaluation and analysis.

Concern Statement: The plan should enact standards prohibiting commercial timber 

harvest and road construction in recently burned forests more than one-quarter (1/4) mile 

from existing system roads. (94.7, 23.13, 3.9, 5.9, 9.14)

Response: The plan provides direction for management following fires in the “Landscape Scale 

Disturbance Events” section of the plan in chapter 2. It includes desired conditions and guidelines 

to protect and facilitate recovery of soil and vegetation components and improve ecosystem 

health. 

Wildfires burn with different intensities and require different activities for restoration to achieve 

desired conditions. Where extensive tree mortality results from fires and economic value exists, 

salvage of dead trees may be considered where this contributes to the movement toward desired 

conditions. Deferral of ecological restoration or salvage projects and activities may also be 

considered where these are not necessary for recovery. Site specific projects that include timber 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 701

harvest or road construction would only be authorized following project-level National 

Environmental Policy Act (NEPA) analyses, including opportunity for public involvement.

Concern Statement: Explain why historically open roads have been closed. (6.2)

Response: Past decisions are outside the scope of the plan. Road closures would have been 

evaluated in a project-level National Environmental Policy Act (NEPA) analysis and decision. 

The rationale would be specific to that project decision.

Concern Statement: Motorized cross-country travel should be allowed. (153.4, 40.1, 100.3, 

100.4, 100.2)

Response: An alternative (alternative A) that would allow motorized cross-country travel was 

considered in the EIS.

Concern Statement: Motorized cross-country travel should not be allowed. (8.3, 124.10, 

101.9)

Response: The plan contains a standard that would prohibit motorized cross-country travel unless 

specifically authorized or exempted. The plan is programmatic in nature; therefore, subsequent 

site specific National Environmental Policy Act (NEPA) analyses would be needed before the 

prohibition of motorized cross-country travel could be implemented.

This change to current management would be evaluated in the future project-level

implementation of the Travel Management Rule (36 CFR §212). Once the implementation of the 

Travel Management Rule is complete and the transportation system is designated, motor vehicle 

use off the designated system would be prohibited. 

This travel management planning process will use the framework set by the plan (e.g., desired 

conditions, standards, guidelines.) and would consider potential resource impacts, access needs, 

public input and alternative views in accordance with Forest Service regulations (CFR 36 §212 

(Travel Management) and 36 CFR §251 (Land Uses, Part 261 (Prohibitions)).

Concern Statement: Allow motorized cross-country travel for big game retrieval; allow 

motorized cross-country travel for big game retrieval on at least 95 percent of the hunting 

areas in each district. (161.59, 161.58, 161.57, 101.7, 109.18, 153.2, 101.88)

Response: The plan would prohibit motorized cross-country travel unless specifically authorized 

or exempted. The responsible official has decided not to address the issue of motorized big game 

retrieval in the plan; it will be addressed during the planning process for the implementation of 

the Travel Management Rule (36 CFR §212). 

Concern Statement: Clarify Motorized Opportunities Standards (proposed plan p. 74) 

"Motorized vehicle travel shall be managed to occur only on the designated system of NFS 

roads and motorized trails and designated motorized areas." It should be made clear that 

there will be authorized exemptions, including motorized big game retrieval. (101.72)

Response: The standard has not been modified. The plan does list the Travel Management Rule 

(36 CFR §212) exemptions for motorized travel off of National Forest System (NFS) roads, NFS 

motorized trails, or designated motorized areas (see the “Motorized Uses Suitability” section in 

chapter 4). The responsible official has decided not to address the issue of motorized big game 
Appendix A

702 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

retrieval in the plan; it will be addressed during the planning process for the implementation of 

the Travel Management Rule. Agency regulations at 36 CFR §212.51(b) specifically address 

motor vehicle use for big game retrieval.

Concern Statement: Clarify Motorized Opportunities Standard (proposed plan p. 74) 

"Unless specifically authorized, motorized cross-country travel shall be managed to occur 

only in designated motorized areas." It should be made clear that motorized big game 

retrieval is included in the activities that are specifically authorized. (101.73)

Response: See the response above.

Concern Statement: Do not restrict dispersed camping to a 300 foot corridor off either side 

of a designated road or trail. (161.60, 161.61, 161.62, 98.26)

Response: The plan does not restrict dispersed camping adjacent to roads or trails.

Potential changes to the forests’ transportation system, including motorized access to known 

dispersed camping sites, would be evaluated during the implementation of the Travel 

Management Rule. The travel management planning process will use the framework set by the 

plan (e.g., desired conditions, standards, guidelines.) and would consider potential resource 

impacts, access needs, public input and alternative views in accordance with Forest Service 

regulations (CFR 36 §212 (Travel Management) and 36 CFR §251 (Land Uses), part 261 

(Prohibitions)).

36 CFR §212.51(b) specifically addresses motor vehicle use for dispersed camping.

Concern Statement: Allow motorized cross-country travel for firewood gathering in areas 

specifically designated for motorized firewood gathering, or that the authorized motorized 

collection of firewood consist of the minimum number of trips each way, as defined based on 

the transport capacity of the vehicle and the trailer, from the downed tree to the closest 

legally open road or trail in the authorized firewood collection area, by the most direct route 

compatible with safety and the preservation of other values such as riparian areas, 

archeological sites, etc. (161.63)

Concern Statement: Allow motorized cross-country travel for dispersed shooting. (161.65)

Response: This response addresses the above two concern statements. The plan would prohibit 

motorized cross-country travel unless specifically authorized or exempted. Motor vehicle use that 

is specifically authorized under a written authorization issued under Federal law or regulations

would be allowed. Written authorizations would be issued on a site-specific basis.

The plan is programmatic in nature; therefore, subsequent site-specific National Environmental 

Policy Act (NEPA) analyses would be needed before the prohibition of motorized cross-country 

travel could be implemented.

This change to current management would be evaluated in the future project-level

implementation of the Travel Management Rule (36 CFR §212). This travel management 

planning process will use the framework set by the plan (e.g., desired conditions, standards, 

guidelines.) and would consider potential resource impacts, access needs, public input and 

alternative views. Once the implementation of the Travel Management Rule is complete and the 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 703

transportation system is designated, motor vehicle use off the designated system would be 

prohibited. 

Concern Statement: Address OSV (over -snow vehicle) travel in the plan. Do not exclude 

snowmobiles from the motorized cross-country travel ban. Apply Executive Order 11644, as 

amended by Executive Order 11989, minimization criteria to route and area designations. 

(99.24, 162.172, 162.120, 162.121)

Response: The plan would prohibit motorized cross-country travel unless specifically authorized 

or exempted. One of the exemptions provided by the Travel Management Rule (36 CFR §212) is 

for over-snow vehicles.

Use by over-snow vehicles is regulated by 36 CFR § 212 Subpart C and defers to the responsible 

official to propose restrictions or prohibitions on use by over-snow vehicles under this subpart. 

Potential restrictions and prohibitions for over-snow vehicles will be addressed in the future 

project-level implementation of the Travel Management Rule. This travel management planning 

process will use the framework set by the plan (e.g., desired conditions, standards, guidelines) 

and would consider potential resource impacts, access needs, public input, and alternative views. 

Executive Order 1164, as amended by Executive Order 11989 requires agencies to develop 

procedures (i.e., Travel Management Rule) to manage off-road vehicles, including over-snow 

vehicles. As of March 29, 2013 there was a court case pending to remove the Travel Management 

Rule over-snow vehicle exemption from subpart B of 36 CFR §212 and require the designation of 

specific routes, trails and areas to include over-snow vehicles and remove Subpart C deferring it 

to the responsible official consistent with the executive order.

Concern Statement: Do not include travel management rule-related direction in the plan. 

(108.48, 147.11)

Response: The plan is required to be in compliance with all applicable Executive Orders.

Implementation of the Travel Management Rule (36 CFR §212) is required by Executive Order 

11644. The designation of specific routes, trails, and areas for motorized vehicle travel on the 

Apache-Sitgreaves NFs will be addressed in the separate public motorized travel management 

planning process. The process will use the framework provided by the plan and be consistent with 

the plan decisions.

Concern Statement: Include guidance for the implementation of the travel management 

rule. (161.71, 161.70, 161.56)

Response: The plan provides the framework (e.g., desired conditions, standards, guidelines) for 

implementing the Travel Management Rule (36 CFR §212). In particular, the “Motorized 

Opportunities” section in chapter 2 contains standards that would limit motorized vehicle travel to 

a designated system of NFS roads and motorized trails, and designated motorized areas. In 

addition, the “Motorized Uses Suitability” in chapter 4 describes the suitability of areas for 

motorized uses. Once the final decision on the plan has been made, the implementation of the 

Travel Management Rule will be conducted under a separate National Environmental Policy Act 

(NEPA) analysis.
Appendix A

704 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Implement a ban on cross-country travel with the implementation of 

the land management plan instead of waiting on the implementation of the Travel 

Management Plan. (162.171)

Response: The plan contains a standard that would prohibit motorized cross-country travel unless 

specifically authorized or exempted. The plan is programmatic in nature; therefore, subsequent 

site-specific National Environmental Policy Act (NEPA) analyses would be needed before the 

prohibition of motorized cross-country travel could be implemented.

This change to current management would be evaluated in the future project-level

implementation of the Travel Management Rule (36 CFR §212). Once the implementation of the 

Travel Management Rule is complete and the transportation system is designated, motor vehicle 

use off the designated system would be prohibited. 

This travel management planning process will use the framework set by the plan (e.g., desired 

conditions, standards, guidelines) and would consider potential resource impacts, access needs, 

public input and alternative views in accordance with Forest Service regulations.

Concern Statement: Explain why the forest doesn't have guidelines that restrict the use of 

OHVs (off-highway vehicles) on NFS land. (124.11)

Response: The plan provides direction for motorized vehicles; it does not differentiate 

management specifically for off-highway vehicles (OHVs).

36 CFR §212 defines an “off-highway vehicle” as, 

“any motorized vehicle designed for or capable of cross-country travel on or immediately 

over land, water, sand, snow, ice, marsh, swampland or other natural terrain...”

It would be difficult to restrict and enforce the use of OHVs differently than other motorized 

vehicles. OHVs are considered motorized vehicle and fall under the standards and guidelines for 

using roads and motorized trails in chapter 2 and chapter 3 of the plan. The plan contains a 

standard that would prohibit motorized cross-country travel for all motorized vehicles unless 

specifically authorized. In addition, the “Motorized Uses Suitability” section in chapter 4 

(“Suitability”) describes those vehicles and uses (e.g., aircraft, emergency vehicles, use 

specifically authorized by permit) that are exempted from the motorized cross-country travel 

prohibition per the Travel Management Rule (36 CFR §212).

Concern Statement: Explain where the enforcement is to address people driving motor 

vehicles that cause damage. (6.3)

Response: The enforcement of laws and regulations is outside the scope of the plan. Enforcement 

is not a plan decision but is a requirement of the Agency; agency regulations at 36 CFR §261.9 

prohibit damage of any natural feature or other property of the United States.

Eligible and Suitable Wild and Scenic Rivers

Concern Statement: The designation of Sardine Creek as "wild" is not consistent with its 

location near the Morenci copper mining complex, the historical homestead use, or with 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 705

potential future uses associated with mining operations as afforded by the statutory rights 

of unpatented mining claimants. (151.7)

Response: Sardine Creek is not a designated wild and scenic river—only Congress can designate 

a river as “wild and scenic.” Sardine Creek was first evaluated for wild and scenic river eligibility 

in 1993 as part of the “Resource Information Report, Potential Wild-Scenic-Recreational River 

Designation, National Forests in Arizona” (Forest Service, 1993). Because of changed conditions 

(e.g., Endangered Species Act (ESA) and sensitive species), Sardine Creek was re-evaluated in

2009 for wild and scenic river eligibility per direction in Forest Service Handbook 1909.12, 

Chapter 80. It was found to be eligible and was given a potential classification of “wild.” The 

classification criteria for wild, scenic, and recreational river areas can be found in Section 82.3 -

Exhibit 01 of the above document. Potential classification is based on the condition of the river 

and the adjacent lands at the time of the study (the Morenci mine complex is not adjacent to 

Sardine Creek), “the presence of a few inconspicuous structures, particularly those of historic or 

cultural value, is acceptable” in wild river areas, and there were no mining claims or operations 

on adjacent lands at the time of the eligibility re-evaluation.

The plan provides guidance for eligible wild and scenic rivers consistent with the interim 

management direction provided in Forest Service Handbook 1909.12, Chapter 80, Section 82.5. 

The river segment class (wild, scenic, or recreational) determines the types of actions or activities 

that may occur

Concern Statement: There are concerns regarding river classification around man-made 

fish barriers as identified in the 2009 Eligibility Report for the National Wild and Scenic 

River System Apache-Sitgreaves National Forests. The eligibility of these segments and the 

associated management that is required to maintain and possibly modify barriers may be in 

conflict. For the 2009 analysis, two segments of two streams, Fish Creek and East Fork 

Lower Colorado River (LCR) were requested to be excluded and classified as not eligible 

for WSR designation given the same conditions involving existing man-made fish barriers, 

but were not. The East Fork LCR, included an excluded segment for two gabion fish 

barriers, but did not include an exclusion for another fish barrier upstream at Colter Dam. 

(101.15, 101.18, 101.17, 101.16)

Response: The 2009 “Eligibility Report for the National Wild and Scenic River System, ApacheSitgreaves National Forests” (Forest Service, 2009b) is the result of extensive coordination with 

all ranger districts on the Apache-Sitgreaves NFs. Information in this report was either verified by 

or supplied by district personnel. 

“The determination of eligibility is an assessment that does not require a decision or 

approval document, although the results of this inventory need to be documented as part 

of the ... plan set of documents. “ (Forest Service Handbook 1909.12, Chapter 80 - Wild 

and Scenic River Evaluation, Section 82.1)

Specifically, the forests requested that the segment of Fish Creek with the fish barrier be 

classified as “recreational,” with the remainder of the river classified as “scenic.” Maintenance or 

modification of the fish barrier on the recreational segment of Fish Creek would be governed by 

the following guideline: 

“Construction of structures ... to protect and enhance wildlife and fish habitat should full 

protect identified river values. Any portion of a wildlife or fisheries restoration project 
Appendix A

706 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

that has the potential to affect the river’s free-flowing character shall be evaluated as a 

water resources project.” (Forest Service Handbook 1909.12, Chapter 80 - Wild and 

Scenic River Evaluation, Section 82.51 (8.c.)).

Additional internal coordination concerning the East Fork of the Little Colorado River and Colter 

Dam resulted in no changes to eligibility or classification. As a scenic river segment, the 

following Forest Service Handbook guideline would govern maintenance or modification of a 

fish barrier: 

“Construction of structures ... to protect and enhance wildlife and fish habitat should 

harmonize with the area’s largely undeveloped character and fully protect identified river 

values. Any portion of a wildlife or fisheries restoration project that has the potential to 

affect the river’s free-flowing character shall be evaluated as a water resources project.” 

(Forest Service Handbook 1909.12, Chapter 80 - Wild and Scenic River Evaluation, Sec. 

82.51 (8.b.))

Research into Colter Dam yielded the following information: (1) Colter Dam does not impound 

water, (2) the dam itself is in an “unsafe, non-emergency condition requiring rehabilitation or 

removal,” and (3) the State of Arizona will not allow the owner, Lyman Water Co., to store water 

there.

The concern statement also makes reference to requests to exclude river segments with fish 

barriers. Research into the plan record did not identify any correspondence with the Arizona 

Game and Fish Department specific to fish barriers.

When suitability studies are done for eligible rivers, there will be opportunities for the public to 

comment.

Concern Statement: Wildlife-related recreational (hunting, fishing, watchable wildlife) 

opportunities should continue to be allowed in eligible and suitable wild and scenic rivers. 

(101.14)

Response: The plan provides guidance for eligible and suitable wild and scenic rivers consistent 

with the interim management direction in Forest Service Handbook 1909.12, Chapter 80, Section

82.5. The river segment class (wild, scenic, or recreational) determines the type of actions or 

activities that may occur. In general, hunting, fishing, and watchable wildlife activities would be 

allowed in eligible and suitable wild and scenic river corridors, provided plan direction, including

suitability, and the Forest Service Handbook are followed. For example, motorized travel may not 

be appropriate in wild river areas/corridors. This is reflected in the plan “Motorized Uses 

Suitability” discussion and tables in chapter 4.

Concern Statement: Eligible and suitable scenic river segments should be managed for very 

high scenic integrity, not just moderate to high. (162.161)

Response: The plan describes the desired scenic integrity levels for wild, scenic, and recreational 

river segments in the desired conditions for the “Eligible and Suitable Wild and Scenic Rivers” 

section of the plan in chapter 2. 

Moderate to high scenic integrity objectives (SIO) are appropriate for scenic river segments. By 

definition (plan) scenic river segments are free of impoundments, with shorelines or watersheds 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 707

still largely primitive, and shorelines largely undeveloped but accessible in places by roads. Small 

communities, dispersed dwellings, or farm buildings; grazing, hay production, or row crops; or 

evidence of past or ongoing timber harvest are also acceptable (Forest Service Handbook

1909.12, Chapter 80, Section 82.3 - Exhibit 01). The presence of roads, buildings, agriculture, 

and timber harvest would not be compatible with a very high SIO, which “generally provides for 

ecological change only.” Management of eligible and suitable scenic rivers for very high scenic 

integrity would unnecessarily restrict current and future facilities and activities.

Concern Statement: AZGFD requests the Apache-Sitgreaves NFs coordinate closely 

regarding any development of management direction for eligible and suitable wild and 

scenic rivers to ensure full consideration is given to the potential impacts on the ability of 

AZGFD to manage fish and wildlife resources. (101.13)

Response: The plan provides guidance for eligible and suitable wild and scenic rivers in the 

“Eligible and Suitable Wild and Scenic Rivers” section in chapter 2. This guidance is consistent 

with the interim management direction in Forest Service Handbook 1909.12, Chapter 80, Section

82.5. Management guidelines for specific resources and activities are found in Section 82.51. The 

Apache-Sitgreaves NFs will work with the Arizona Game and Fish Department to manage fish 

and wildlife resources, while following the above Forest Service Handbook direction and 

guidelines and plan decisions in managing eligible and suitable wild and scenic rivers.

Concern Statement: No wild and scenic rivers or any other restricted or enlarged restricted 

areas. (154.2, 156.2)

Response: As part of the plan revision process, national forests are required to complete a 

comprehensive evaluation of the potential for rivers to be eligible for inclusion in the National 

Wild and Scenic Rivers System (Forest Service Handbook 1909.12, Chapter 80 - Wild and Scenic 

River Evaluation, Section 81.2). This evaluation is documented in the “Eligibility Report for the 

National Wild and Scenic River System, Apache-Sitgreaves National Forests” (Forest Service, 

2009b).

Consideration of wilderness suitability is also inherent in land management planning. All lands on 

forest were inventoried to determine if any satisfied the definition of wilderness found in the 

Wilderness Act of 1964. Those that met the definition of wilderness were evaluated further. These 

are documented in the “Potential Wilderness Evaluations” (Forest Service, 2012b) in the plan set 

of documents and on the forests’ Web site at 

http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606. The plan 

contains preliminary administrative recommendations for wilderness. These recommendations 

would receive further review, including applicable site specific National Environmental Policy 

Act (NEPA) analysis.

Congress has reserved the authority to make final decisions on wilderness designation and the 

inclusion of rivers into the National Wild and Scenic Rivers System.

Concern Statement: More miles of eligible wild and scenic rivers should be studied for 

suitability. (162.162)

Response: Wild and scenic river suitability determinations are beyond the scope of the plan and 

plan revision process. During the plan revision effort, the forests are not required to make 

suitability determinations for eligible wild and scenic rivers. This policy is set forth in Forest 
Appendix A

708 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Service Handbook 1909.12, Chapter 80 and is specifically disclosed in the “Scope of Analysis” 

section in chapter 1 of the EIS. Suitability studies would, most likely, occur on a case-by-case 

basis as opportunities arise or projects on eligible rivers are proposed. The need to conduct 

suitability studies in the future is acknowledged in appendix E (“Possible Management Actions”)

of the plan.

Concern Statement: The forests must determine eligibility of rivers and cease carrying the 

“potentially” eligible designation. The plan should indicate a timeframe for analysis and 

designation of wild and scenic rivers. (99.26, 99.37, 99.5)

Response: In 2005, the Ninth Circuit Court of Appeals concluded that the Forest Service’s 1993 

Resource Evaluation Report constituted eligibility for the rivers contained in that report. 

Therefore, at the time plan revision was initiated, there were 22 eligible wild and scenic rivers on 

the forests. An eligibility re-evaluation, conducted for plan revision, yielded 25 eligible rivers. A 

suitability study for the Blue River and KP Creek was conducted in response to a proposal to 

install fish barriers on these rivers. Additional suitability studies for eligible rivers on the ApacheSitgreaves NFs are deferred to a later time consistent with direction in Forest Service Handbook

1909.12, Chapter 80. This is specifically disclosed in the “Scope of Analysis” section in chapter 1 

of the EIS.

The plan is programmatic in nature and does not identify compulsory language (i.e., timeframes) 

as its implementation is subject to fluctuating budgets and changing capacity. Only Congress can 

designate a wild and scenic river.

Concern Statement: To protect the health of all eligible wild and scenic river segments, 

roads should be kept as far from the waterways as possible, and maintained to reduce 

sediment inputs. Proper crossings should be built and maintained where required. (162.163)

Response: The health and integrity of eligible wild and scenic rivers is provided for by the plan 

decisions in the “Eligible and Suitable Wild and Scenic Rivers” section in chapter 2 of the plan. 

Most eligible wild and scenic river segments are in steep canyons where few roads currently 

exist, with no new roads planned. Road maintenance is subject to the standard in the “Motorized 

Opportunities” section of the plan: 

“Road maintenance and construction activities shall be designed to reduce sediment 

(e.g., water bars, sediment traps, grade dips) while first providing for user safety.”

It is also subject to the “Apache-Sitgreaves National Forests Best Management Practices for Road 

Maintenance” (listed in “Other Sources of Information” for motorized opportunities in Appendix 

D of the plan). The forests also implement streamside management zones which provide guidance 

on number of roads, orientation with the stream, and number of crossings within them (see the 

guideline in “Water Resources” section and the discussion in management approaches for the

“Water Resources” section). Road maintenance, best management practices, and streamside 

management zones are implemented at the project-level.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 709

Concern Statement: Concern that the Campbell Blue wild and scenic river designation 

conflicts with the wildland-urban interface treatments to protect the health and safety of 

people. (104.8)

Response: The “Eligible and Suitable Wild and Scenic Rivers” section of the plan in chapter 2 

provides direction for managing these rivers. Campbell Blue Creek has been managed as an 

eligible wild and scenic river since 2005. The recreational river classification of Campbell Blue 

Creek from Castle Creek to Dry Blue Creek, excluding the private lands, allows for a 

“range of vegetation management and timber harvest practices..., provided these 

practices are designed to protect, restore, or enhance the river environment, including the 

long-term scenic character” (Forest Service Handbook 1909.12, Chapter 80, Section

82.51, 9.b.). 

Only Congress can designate a wild and scenic river. The plan provides direction to maintain the 

outstandingly remarkable values of these eligible and suitable rivers until Congress takes action.

Concern Statement: Concern that wild and scenic river designations conflict with multiple 

use management, including other land owner's ability to manage the land. (104.7)

Response: The “Eligible and Suitable Wild and Scenic Rivers” section in chapter 2 of the plan 

provides direction for managing these rivers. Eligible and suitable river corridors on the ApacheSitgreaves NFs do not include private lands. The Forest Service has no jurisdiction over private 

lands. National Forest System lands are managed for multiple uses under the Multiple UseSustained Yield Act of 1964. A variety of uses and activities are allowed in eligible and suitable 

rivers corridors as described in Forest Service Handbook 1909.12, Chapter 80, Section 82.5. Only 

Congress can designate a wild and scenic river. The plan provides direction to maintain the 

outstandingly remarkable values of these eligible and suitable rivers until Congress takes action.

Inventoried Roadless Areas

Concern Statement: Correct the statement "When the roadless lands were reconsidered in 

the 2000 Roadless Area Conservation FEIS, there was no additional inventory or 

adjustment of boundaries to reflect these activities" (DEIS p. 349). There was an 

opportunity in 2000 for the forests to alter boundaries of the inventoried roadless area 

(IRA) boundaries, but based on public and internal reviews the forest did not do so. 

(162.174)

Response: The “Inventoried Roadless Areas” section in chapter 3 of the EIS has been updated by 

removing the phrase “additional inventory or.”

Concern Statement: Recognize that once roads are allowed into roadless areas, the 

ecological values and other attributes of roadless and wilderness areas are degraded to a 

point of affecting the whole system. (124.2, 124.13, 68.1)

Response: The effects of roads and other activities on inventoried roadless areas and roadless 

character are described in the “Inventoried Roadless Areas” section in chapter 3 of the EIS.
Appendix A

710 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Protect inventoried roadless areas IRAs). (81.20, 67.2, 28.2, 28.1)

Response: The plan protects inventoried roadless areas (IRAs) through implementation of the 

2001 Roadless Area Conservation Rule (RACR) and management guidance under Natural 

Landscape Management Area (most of the IRAs are located within this management area).

Protection of IRAs is considered in the EIS. IRAs are protected in alternative A through 

implementation of the 2001 RACR. In alternative B they are protected through implementation of 

the RACR and by management as Natural Landscape Management Area. In alternative D, almost 

all of these lands are included in the Recommended Wilderness Management Area. Alternative C

considers multiple-use management for the IRA lands.

Concern Statement: RARE II lands were released to multiple use management per the 1984 

Wilderness Act. Therefore, these released lands (inventoried roadless areas) should be 

managed under multiple use and other land management regulations. (32.15, 32.3, 32.6, 

32.7, 32.14)

Response: The Arizona Wilderness Act of 1984 did release the RARE II lands in Arizona to 

multiple use management. However, the 2001 Roadless Area Conservation Rule provides 

protection and management direction for the areas identified in a set of inventoried roadless area 

maps contained in Forest Service Roadless Area Conservation, Final Environmental Impact 

Statement, Volume 2, dated November 2000. These inventoried roadless areas (IRAs) are, in most 

cases, the RARE II lands. 

Management guidance for inventoried roadless areas is found in chapter 2 of the plan under 

Managed Recreation and chapter 3 of the plan under Natural Landscape Management Area. This 

management area consists of generally undeveloped areas that are natural appearing and provide 

primitive and semi-primitive recreation opportunities. This management area includes most of the 

inventoried roadless areas identified in the Roadless Area Conservation Rule. All IRAs would be 

managed to protect and conserve their roadless character.

Concern Statement: The plan should adjust inventoried roadless area (IRA) boundaries to 

remove those portions which no longer have roadless characteristics. The plan should 

indicate a timeframe for accomplishment of analysis and designation. (99.28, 99.27)

Response: The first part of this concern statement is beyond the scope of the plan and plan 

process. Inventoried roadless area (IRA) boundaries were set in place by the 2001 Roadless Area 

Conservation Rule (RACR). Changing IRA boundaries would require Federal rulemaking in 

accordance with the Administrative Procedures Act. 

All Apache-Sitgreaves NFs lands, including the IRAs, were considered in the potential wilderness 

inventory. The IRA lands that met the inventory criteria were included (analyzed) in the potential 

wilderness evaluation process. Any IRA lands that are recommended for wilderness in the plan 

(Recommended Wilderness Management Area) would be managed to protect wilderness and 

roadless character until a congressional decision is made. Any IRA lands not recommended for 

wilderness would be managed to protect roadless character. There is no provision in the 2001 

RACR to release IRAs to multiple-use management.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 711

Wilderness Resources

Concern Statement: Underrepresented ecosystems should not be used as a criterion in the 

wilderness evaluation process. (32.12, 108.85, 81.9)

Response: The Forest Service considered underrepresented ecosystems as a criterion in the 

wilderness evaluation process consistent with agency policy. Forest Service policy/planning 

direction is found in the Forest Service Manual 1920 and Forest Service Handbook 1909.12. 

Forest Service Handbook 1909.12, Chapter 70 (January 2007) is the policy direction that guides 

wilderness evaluations. Section 72.3 specifically directs the evaluation process to:

“Deal with ‘need’ on a regional basis and evaluate such factors as geographic 

distribution of areas and representations of landforms and ecosystems.” 

Six specific factors, one of which is to consider “ecosystems underrepresented in wilderness,” are 

listed in Section 72.31.

The methodology and results of the wilderness evaluation process are documented in the 

“Potential Wilderness Evaluation” reports (Forest Service, 2012b) available in the plan set of 

documents and on the forests’ Web site at 

http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606. 

Concern Statement: The Forest Service should use the former chapter 7, instead of 

FSH1909.12 chapter 70 to guide the wilderness evaluation process including considering 

areas that contain closed system roads. (162.130, 162.131, 162.132)

Response: Consistent with agency policy, the Forest Service used Forest Service Handbook 

1909.12, Chapter 70 to guide the wilderness evaluation process and did not consider areas that 

contained forest roads or other authorized roads. Forest Service policy/planning direction is found 

in the Forest Service Manual 1920 and Forest Service Handbook 1909.12. As such, Forest 

Service Handbook 1909.12, Chapter 70 (January 2007) is the policy direction that guides 

wilderness evaluations. The Chapter 7 referenced in the comment was replaced by Chapter 70. 

Chapter 7 no longer exists as policy direction, and thus, is not eligible to be applied. 

Further, the October 23, 2009, Washington Office correspondence provides guidance as to which 

“the planning directives to use to carry out the 1982 Planning Regulation[s].” Chapter 70 -

Wilderness Evaluation of Forest Service Handbook 1909.12 is listed as applicable to plan 

revisions under the 1982 Planning Regulations. This correspondence can be found in the plan set 

of documents.

The current Chapter 70 requirements at Section 71.1 - Inventory Criteria, explicitly state that 

areas considered for the inventory,

“do not contain forest roads (36 CFR § 212.1) or other permanently authorized roads...”

The methodology and results of the wilderness evaluation process are documented in the 

“Potential Wilderness Evaluation” reports (Forest Service, 2012b) available in the plan set of 

documents and on the forests’ Web site at 

http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606.
Appendix A

712 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Consider the need for preserving this last-of-its-kind intact system of 

wildland rather than only analyze their value as stand-alone potential wilderness units. 

There is concern that the ecological “need” for preserving the wilderness characteristic of 

quiet, resilient and unfragmented habitat is high for all potential wilderness units. (162.141, 

162.139, 39.15, 107.3, 162.157, 23.9, 140.3, 94.11, 80.5)

Response: There is no Forest Service guidance to consider wildland systems or unfragmented 

habitat during the wilderness evaluation process. Forest Service policy/planning direction is 

found in the Forest Service Manual 1920 and Forest Service Handbook 1909.12. Forest Service 

Handbook 1909.12, Chapter 70 (January 2007) is the policy direction that guides wilderness 

evaluations.

The current Chapter 70 requirements at Section 71.1 - Inventory Criteria, explicitly state that 

areas considered for the inventory,

“do not contain forest roads (36 CFR § 212.1) or other permanently authorized roads...”

For this reason, only stand-alone potential wilderness and areas adjacent to existing wilderness 

and the primitive area were evaluated. Wilderness character, as defined in the Wilderness Act of 

1964, does not include “quiet, resilient and unfragmented habitat.”

Alternative strategies for managing “wildlands” were considered in the EIS. “Wildlands” on the 

Apache-Sitgreaves NFs (wilderness, primitive area, inventoried roadless areas, recommended 

wilderness) are managed under alternatives A, B, and D through plan direction, a variety of laws, 

regulations, policies, and the 2001 Roadless Area Conservation Rule (RACR) to protect their 

wilderness and roadless character. Under alternative C, wilderness, primitive area, and 

recommended wilderness are managed through plan direction and a variety of laws, regulations, 

and policies. The plan also provides for quality wildlife habitat and connectivity. Wildlife habitat 

quality and connectivity are discussed under the “Habitat Connectivity and Linkages” heading in 

the “Wildlife and Rare Plants” section of the EIS.

Concern Statement: Explain the criteria used in "factor one" and "factor three" of the 

wilderness need evaluation. There is concern that arbitrary distances from illogical 

community centers lead to the conclusion that the need for additional wilderness is low. 

(162.133)

Response: Factor 1 considers the location and size of other wilderness areas near a potential 

wilderness and their distance from a potential wilderness. It also considers the location of a 

potential wilderness with regard to population centers because public demand for wilderness may 

increase with proximity to growing population centers. Factor 3 examines the extent to which 

non-wilderness lands on the forests or other Federal lands are likely to provide opportunities for 

unconfined outdoor recreation experiences. Non-wilderness lands include inventoried roadless 

areas, wilderness study areas, proposed wilderness, and recreation opportunity spectrum semiprimitive nonmotorized and primitive lands.

The “Regional Demand for Wilderness, Southwestern Region” (Forest Service, 2009c) and the 

“R3 Wilderness Need Assessment Instructions” (Forest Service, 2007) were used to determine the 

population centers and distances from those population centers to be used in factors 1 and 3 of the 

need assessment.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 713

The population centers used in the factor 1 and 3 need assessments were Flagstaff, Phoenix, and 

Tucson, Arizona. These population centers align with the counties of origin for the majority of the 

forests’ visitors. Silver City, New Mexico, was considered as a population center only for the 

three potential wilderness areas that will be considered during the Gila NF potential wilderness 

evaluation and land management plan revision processes and the one where a portion of the 

potential wilderness is located on the Gila NF.

The need assessments for all potential wilderness on the Apache-Sitgreaves NFs were updated 

prior to issuance of the proposed plan and DEIS to include rating criteria and individual ratings 

for the six need factors. An overall need rating was determined and presented for each potential 

wilderness. This information is found in each “Potential Wilderness Evaluation” (Forest Service, 

2012b) and is summarized in the “Capability, Availability, and Need Ratings Documentation” 

(Forest Service, 2012a) that can be found under “Potential Wilderness Evaluation” on the 

Apache-Sitgreaves NFs Web site: 

http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606

Concern Statement: Reconsider the underrepresentation of wilderness in the northeast 

quadrant of Arizona in the evaluation of Need Assessment Factor 2. (162.135, 162.136)

Response: The underrepresentation of wilderness in the northeast quadrant of Arizona was 

considered in the rating criteria developed for factor 2. The need assessments for all potential 

wilderness were updated prior to issuance of the proposed plan and DEIS to include rating criteria 

and individual ratings for the six need factors. This information is found in each “Potential 

Wilderness Evaluation” (Forest Service, 2012b) that can be found under “Potential Wilderness 

Evaluation” on the Apache-Sitgreaves NFs Web site: 

http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606

Concern Statement: Remove any recommendation for designation of wilderness solely 

based on a desire to provide recreation opportunities. (108.83)

Response: No wilderness recommendation is based solely on an area’s recreation opportunities. 

Rationale for the alternative B, C, and D wilderness recommendations is included in the 

environmental consequences for the “Recommended Wilderness” section in the EIS.

Opportunities for a primitive and unconfined type of recreation is one characteristic that was 

considered in the potential wilderness capability evaluation. Other capability characteristics (the 

basic characteristics that make the area appropriate and valuable for wilderness designation)

evaluated were naturalness, undeveloped, opportunities for solitude, special values, and 

manageability. Potential wilderness were also evaluated for availability (examines the potential 

impact of designating an area as wilderness to both the current and future land uses and activities)

and need (considered at the regional level and considers other opportunities for unconfined 

outdoor recreation or preservation of certain ecosystem characteristics). Each “Potential 

Wilderness Evaluation” (Forest Service, 2012b) can be found under “Potential Wilderness 

Evaluation” on the Apache-Sitgreaves NFs Web site: 

http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606
Appendix A

714 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Reconsider "factor four" of the wilderness need evaluation. (162.137, 

162.138)

Response: The Forest Service considered factor 4 during the wilderness need evaluation. Factor 4 

specifically addresses,

“The need to provide a refuge for those species that have demonstrated an inability to 

survive in less than primitive surroundings, or the need for a protected area for other 

unique scientific values or phenomena” (Forest Service Handbook 1909.12, Chapter 70, 

§ 72.31). 

The need assessments for all potential wilderness areas were updated prior to issuance of the 

proposed plan and DEIS to include rating criteria and individual ratings for the six need factors. 

An overall need rating was determined and presented for each potential wilderness. This 

information is found in the “Potential Wilderness Evaluations” (Forest Service, 2012b) and is 

summarized in the “Capability, Availability, and Need Ratings Documentation” (Forest Service, 

2012a) that can be found under “Potential Wilderness Evaluation” on the Apache-Sitgreaves NFs 

Web site: http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606

Factor 4 specific changes included the following: (1) removal of references to “Species of 

Concern” and” Species of Interest,” (2) inclusion of information on Forest Planning Species, and 

(3) inclusion of information on species and habitats from the “Wildlife Specialist Report -

Viability” (Forest Service, 2014l) and “Fisheries Specialist Report” (Forest Service, 2014a).

Evaluation of factor 4 was coordinated with forest plan revision wildlife and fisheries biologists. 

No species were identified that require primitive surroundings. However, many species and their 

habitats were identified as benefitting from primitive surroundings. These species and habitats are 

shown in the “Factor 4 Table” in the “Wilderness Need Evaluation Tables” document (Forest 

Service, 2012e) that can be found at the following Web site:

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5406404.pdf

Concern Statement: The Forest Service should reconsider evaluating areas within the 

Wallow fire that were burned with moderate to high intensity as potential “wilderness.” 

(81.8)

Response: The Forest Service considered if there was a need to update the potential wilderness 

evaluations to account for the effects of the 2011 Wallow Fire. It was determined that the 

potential wilderness evaluations were still valid based on the assumption that fire does not change 

wilderness character. For more information, see the “Wallow Fire Changed Condition 

Assessment” (Forest Service, 2012d) at the following Web site: 

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5406194.pdf

Concern Statement: The current condition, including the impacts of the 2011 Wallow Fire, 

of wilderness should be described in the plan. (81.14, 108.246, 81.22, 108.245)

Response: The current conditions for wilderness are described in the affected environment of the 

“Wilderness Resources” section in the EIS. The wilderness character of these lands was not 

affected by the Wallow Fire.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 715

Concern Statement: Wilderness Background (proposed plan p. 120) Add to the first 

paragraph regarding Mt. Baldy wilderness. "The East Fork Little Colorado River and West 

Fork Little Colorado River originate on Mt. Baldy and flow throughout the year through 

this wilderness, providing habitat for the threatened Apache trout." This language mirrors 

language provided for the Bear Wallow Wilderness and Bear Wallow Creek. (101.85)

Response: Language addressing the comment has been added to the “Background for 

Wilderness” section in chapter 3 of the plan.

Concern Statement: Consider the effects of wilderness or other restrictive land use on the 

human and natural environment. Remove assumptions and conclusions that human activity 

creates negative impacts on wildlife (DEIS p. 366). (108.82, 108.88, 81.19, 81.2, 81.11)

Response: The EIS analyzes the effects of wilderness recommendations and management in the

environmental consequences for the “Wilderness Resources” section in chapter 3. Additional 

analysis can be found in the “Wilderness Resources and Inventoried Roadless Areas Specialist 

Report” (Forest Service, 2014j) and the “Potential Wilderness Evaluations” (Forest Service, 

2012b).

The statement in question from page 366 of the DEIS has been modified to read,

“Recommended wilderness would provide greater protection for wildlife and wildlife 

habitats because of reduced disturbance from motorized vehicle use.” 

General effects to wildlife and wildlife habitats can be found in the “Fisheries” and “Wildlife and 

Rare Plants” sections in chapter 3 of the EIS. The “Wildlife Specialist Report - Viability” (Forest 

Service, 2014l), “Fisheries Specialist Report” (Forest Service, 2014a), and the Biological 

Assessment (Forest Service, 2014k), located in the plan set of documents and on the forests’ Web 

site at http://www.fs.usda.gov/main/asnf/landmanagement/planning, also document 

environmental consequences, based on current literature and science, to wildlife and wildlife 

habitats.

Concern Statement: Acknowledge that wilderness designation will affect the use of fire a 

vegetation treatment tool (DEIS p. 367). (81.13, 108.90)

Response: The plan, consistent with Forest Service policy, allows the use of prescribed fire as a 

vegetation treatment tool in wilderness. The DEIS acknowledges the general environmental 

consequences of recommending an area for wilderness on the use of fire as a vegetation treatment 

tool on page 368 under the “Fire, Insects and Disease, Non-Federal Lands” heading and in the 

“Wilderness Resources and Inventoried Roadless Areas Specialist Report” (Forest Service,

2014j). Additional effects and more detail can be found in the “Potential Wilderness Evaluations” 

(Forest Service, 2012b). These documents can be found in the plan set of documents and on the 

forests’ Web site at http://www.fs.usda.gov/main/asnf/landmanagement/planning. The plan 

revision process does not designate wilderness; only Congress has that authority.

Concern Statement: Acknowledge that wilderness designation will affect active 

management practices such as mechanical thinning. (81.4, 109.7)

Response: Active management (e.g., prescribed fire, livestock grazing, trail management) 

compatible with wilderness resource management objectives is allowed in wilderness. However, 
Appendix A

716 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

motorized vehicles and equipment and mechanical transport cannot be used. The EIS 

acknowledges the general environmental consequences of recommending an area for wilderness 

on the use of mechanical thinning under “Environmental Consequences of Wilderness 

Recommendation” portion of the “Wilderness Resources” section in chapter 3. Additional 

information can be found in the “Wilderness Resources and Inventoried Roadless Areas Specialist 

Report” (Forest Service 2014j) and “Potential Wilderness Evaluations” (Forest Service, 2012b)

for the Apache-Sitgreaves NFs. These documents can be found in the plan set of documents and 

on the forests’ Web site at http://www.fs.usda.gov/main/asnf/landmanagement/planning. The 

forest planning process does not designate wilderness; only Congress has that authority.

Concern Statement: Use data regarding what percentage of the public does or does not 

want more wilderness to inform recommendations for wilderness designation. Delete the 

statement that indicates the public desires more wilderness (DEIS p. 364). (81.10, 134.2, 

108.86)

Response: The comment refers to the statement, 

“Alternative B would address public desire for more wilderness by recommending 7,074

acres...” 

Many commenters throughout the planning process requested the consideration of additional 

wilderness on the Apache-Sitgreaves NFs. In a national study Cordell et al. (2008b) found that a 

majority of U.S. residents age 16 and older felt there was not enough land designated as 

wilderness. Based on comments received on the Apache-Sitgreaves NFs proposed plan and DEIS 

and Forest Service review, the statement concerning public desire for more wilderness is retained.

Concern Statement: The wilderness party size standard is too restrictive: "Party size of 12 

persons and/or 12 head of stock for hiking and riding groups in Mount Baldy Wilderness

shall not be exceeded. A party size of 6 persons for overnight camping shall not be 

exceeded" (proposed plan p.121). Concern that it may impact families and scout troops. 

(123.13)

Response: The group size limits for Mount Baldy Wilderness, as described above, have been in 

effect since at least 1978; the group size limits were printed on the back side of the 1978 Mount 

Baldy Wilderness Map and Guide. These limits have been enforceable through forest orders since 

at least 1978. The plan continues these long standing group size limits. Group size limits are set 

to protect wilderness characteristics and to maintain opportunities for solitude.

Concern Statement: The party size standards for wilderness and primitive area should not 

apply to wildlife and fisheries management activities (e.g. stream renovation and fish 

restocking activities). (101.86, 101.87)

Response: All requests from agencies for fish and wildlife management activities by groups 

exceeding the group size limit would be considered administratively on a case-by-case basis. As 

discussed in the management approaches for the “Wilderness” section and referenced in the 

“Other Sources of Information” for wilderness section of the plan in Appendix D, these proposals 

would be considered through a minimum requirements analysis using the “Minimum 

Requirements Decision Guide” (USDA and USDOI, 2012). Group size limits are set to protect 

wilderness characteristics and to maintain opportunities for solitude.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 717

Concern Statement: Correct conflicting Wilderness guidelines about fire (proposed plan p. 

121). (108.190)

Response: The wilderness guidelines regarding fire and fire management in the proposed plan 

were reviewed and determined to not be in conflict with wilderness desired conditions. However, 

the fourth guideline has been rewritten for clarity as follows: 

“Prescribed fire should be considered to reduce the risks and consequences of 

uncharacteristic wildfire within wilderness or escaping from wilderness by reducing 

unnatural fuel accumulations, if necessary to meet wilderness fire management 

objectives. Naturally occurring wildfires should be allowed to perform, as much as 

possible, their natural ecological role within wilderness.” 

This guideline can be found in chapter 3 of the plan in the “Wilderness” section.

Concern Statement: Provide provisions for AZGFD management in wilderness. Specific 

actions which may be necessary, and may necessitate the use of motorized equipment, 

include periodic fish surveys and nonnative fish removal utilizing nets or battery and gas 

powered electrofishing equipment, construction or maintenance of fish barriers, chemical 

stream renovations, fish stocking, low-level aerial wildlife surveys, research, and law 

enforcement flights, wildlife capture, construction of temporary release pens, construction 

and maintenance of wildlife waters, providing salt and mineral supplements, depredation, 

and wildlife mortality investigations. (101.10, 101.8)

Response: The plan provides guidance to manage wilderness consistent with law and policy. 

Wilderness is managed according to the Wilderness Act of 1964 and Forest Service Manual 2300 

Chapter 2320 - Wilderness Management. Section 4(c) of the Wilderness Act specifically prohibits 

the use of motorized equipment in designated wilderness “except as necessary to meet minimum 

requirements for the administration of the area for the purpose of this Act.” Forest Service 

Manual 2320.3 specifically applies to the management of wildlife and fish. Forest Service 

Manual 2326 provides direction on the use of motorized equipment in wilderness. 

Specific proposed actions would be considered on a case-by-case basis with use of the “Minimum 

Requirements Decision Guide” (MRDG) (USDA and USDOI, 2012). The MRDG is designed for 

use when making a determination that one of the ‘prohibited uses’ (listed in Section 4(c) of the 

Act) is the minimum necessary requirement. The MRDG is discussed in the management 

approaches for the “Wilderness section and referenced in the “Other Sources of Information” for 

wilderness section of the plan in Appendix D.

Concern Statement: Additionally, the Department must maintain motorized access to and 

around the Chevelon Lake dam to adequately monitor and maintain this structure. 

Inadequate maintenance of this dam can create a safety issue to those using the lake and 

those downstream of the lake, and presents liabilities that the Department is not willing to 

assume. (101.29)

Response: Chevelon Lake Dam and its access road are not included in Chevelon Lake Potential 

Wilderness. These features were “cherry-stemmed” out when the area was inventoried for 

wilderness potential because of the forest road and the dam. See Forest Service Handbook 

1909.12, Chapter 70, Section 71.1, #3. Under the plan, Chevelon Lake, Chevelon Lake Dam, and 

the access road would be managed under the General Forest Management Area direction.
Appendix A

718 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Trespass into wilderness and unclear boundaries should be dealt with 

within current management capabilities. (32.10)

Response: The plan is programmatic in nature. Within the desired conditions for the 

“Wilderness” section in chapter 3 it provides direction that,

“Wilderness boundaries are posted and visible to visitors.” 

The actual task of posting boundaries and addressing trespass issues would be addressed at the 

project level.

Concern Statement: Remove wilderness designation for areas where the designation was 

solely based upon the desire to provide recreation opportunities. (81.5)

Response: Removal of wilderness designation is beyond the scope of the plan decision to be 

made. Only Congress can designate (or remove a designation) a wilderness.

No wilderness designation is based solely on an area’s recreation opportunities. An area 

considered for or designated as wilderness must:

“(1) generally appears to have been affected primarily by the forces of nature, with the 

imprint of man’s work substantially unnoticeable; (2) has outstanding opportunities for 

solitude or a primitive and unconfined type of recreation; (3) has at least five thousand 

acres of land or is of sufficient size as to make practicable its preservation and use in an 

unimpaired condition; and (4) may also contain ecological, geological, or other features 

of scientific, educational, scenic, or historical value.” (Wilderness Act of 1964, Section 2 

(c)).

Concern Statement: The Forest Service should withdraw its recommendation to designate 

the Blue Range Primitive Area as wilderness and move forward managing the lands for the 

various resource values they contain. (81.18)

Response: This is beyond the scope of the decision to be made. Because a presidential 

recommendation to Congress has been made, the plan does not contain a preliminary 

administrative recommendation for the Primitive Area Management Area. It is up to Congress to 

make a decision about the Blue Range Primitive Area and presidential recommended additions.

In 1971, the Forest Service submitted a recommendation to the President of the United States for 

the Blue Range Wilderness in New Mexico and Arizona. The President forwarded the 

recommendation to Congress, who eventually acted on a portion of the recommendation. In 1980,

Congress designated, and the President signed into law, the Blue Range Wilderness in New 

Mexico. The Arizona portion of the 1971 presidential recommendation (166,591 acres) included 

20,031 acres outside and along the west primitive area boundary. The Forest Service and 

presidential recommendation for the Blue Range Wilderness in Arizona has not been acted upon.

Until Congress acts on the 1971 wilderness recommendation, the plan provides direction to 

manage the Blue Range Primitive Area and the presidential recommended additions as a primitive 

area (see the “Primitive Area” section of the plan in chapter 3).
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 719

Concern Statement: Revise recommended wilderness guidelines to manage these areas as 

multiple use lands. (108.206)

Response: The Forest Service is authorized to manage recommended wilderness through law and 

policy. The Arizona Wilderness Act of 1984 states, 

“...areas recommended for wilderness designation [in revised land management plans] 

shall be managed for the purpose of protecting their suitability for wilderness 

designation...” (Section 103 (b)(4)). 

Forest Service Manual (FSM) gives a Forest Supervisor the responsibility to

“Develop management direction for recommended wilderness. . .” (FSM 1923.04c) 

The FSM gives the Regional Forester the responsibility for

“Approving management direction for recommended wilderness. . .” (FSM 1923.04b).

Recommended wilderness in the plan would be managed to retain their wilderness characteristics 

(see the first guideline in the “Recommended Wilderness” section in chapter 3 of the plan) until 

further review and possible modification by the Chief of the Forest Service, Secretary of 

Agriculture, and the President of the United States. Congress takes action to formally designate 

them. However, recommended wilderness is not subject to the same management restrictions as 

formally designated wilderness. Unlike the Wilderness and Primitive Area Management Area plan 

direction, no group size limits are identified for the Recommended Wilderness Management Area. 

Also, FSM 2300, Chapter 2320 - Wilderness Management and the Congressional Grazing 

Guidelines are not applicable to recommended wilderness. The project or activity-level decision 

maker may exercise discretion in determining that proposed site specific actions within a given 

recommended wilderness are consistent with retaining the area’s wilderness characteristics.

Concern Statement: Modify the Recommended Wilderness guideline "Motorized 

equipment (i.e., chain saws) may be used for trail maintenance" (proposed plan p. 124) by 

(1) change 'motorized equipment' to 'gasoline powered equipment' and (2) add ‘and fence 

repair’. (121.1, 99.11)

Response: This comment is no longer applicable. This guideline has been removed, because 

there are no National Forest System trails in the Recommended Wilderness Management Area. As 

mentioned in the management approaches for the “Recommended Wilderness” section (chapter 3 

of the plan), the “Minimum Requirements Decision Guide” (USDA and USDI, 2012) would be

used to evaluate actions proposed within recommended wilderness.

Concern Statement: There is a need for more protections for wilderness-type areas (i.e., 

designated wilderness, primitive area, roadless areas, recommended wilderness, potential 

wilderness). (29.1, 146.8, 70.1, 5.15, 14.3, 106.3, 124.9, 107.1, 48.1, 88.1, 107.5)

Response: The plan provides for protection of designated wilderness and the primitive area 

consistent with the Wilderness Act of 1964, Forest Service Manual 2300, Chapter 2320 -

Wilderness Management, and 36 CFR §293.17(a) through implementation of Wilderness 

Management Area and Primitive Area Management Area direction. Recommended wilderness is 

protected through plan direction for the Recommended Wilderness Management Area consistent 

with the Arizona Wilderness Act of 1984 and Forest Service Manual 1923.
Appendix A

720 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

The plan provides for protection of Inventoried Roadless Areas (IRAs) and most potential 

wilderness areas through Natural Landscape Management Area direction and the implementation 

of the 2001 Roadless Area Conservation Rule (RACR).

Protection of “wilderness-type areas” is considered in all EIS alternatives. Protection of 

designated wilderness and the primitive area does not change by alternative and would be as 

described above. IRAs and most potential wilderness lands are protected in alternative A through 

implementation of the RACR. In alternative B they are protected by management under Natural 

Landscape Management Area direction and implementation of the RACR. In alternative D, 

almost all IRAs and potential wilderness areas are included in the Recommended Wilderness 

Management Area and would also be subject to the RACR. Varying amounts of recommended 

wilderness would be protected in the action alternatives through Recommended Wilderness 

Management Area direction.

Concern Statement: Review areas of recommended wilderness, including additions to 

Escudilla Wilderness that do not meet the requirements for wilderness designation (DEIS p. 

364 paragraph 3). (108.87)

Response: All areas identified in the EIS as potential wilderness were evaluated through the 

Forest Service policy/planning direction found in the Forest Service Manual 1920 and Forest 

Service Handbook 1909.12. Forest Service Handbook 1909.12, Chapter 70 (January 2007) 

contains the policy direction that guides wilderness evaluations. “Potential Wilderness 

Evaluations” (Forest Service, 2012b) for each area can be found on the Apache-Sitgreaves NFs

Web site: http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606.

The responsible official reviewed and included in the action alternatives those areas that would be 

recommended for wilderness. The EIS discloses that lands in the Escudilla Mountain area would 

need additional actions to reduce signs of past activities before any wilderness designation.

Concern Statement: Explain why table 4 (proposed plan p. 124) displays 261 acres for Bear 

Wallow Wilderness Additions and the DEIS shows 260 acres (p. 364). (121.2)

Response: The 1-acre difference is the result of rounding. A footnote has been added to the EIS 

to explain the acreage difference.

Concern Statement: Wilderness areas and recommended wilderness restrict access for 

senior citizens and persons with disabilities. (134.3, 22.4, 98.22, 123.20)

Response: The plan provides for a variety of recreation opportunities: motorized, nonmotorized, 

developed, dispersed, and everything in between. However, not every recreation opportunity can 

be found everywhere on the forests. For example, while much of the forests is available for 

motorized recreation, there are fewer opportunities for primitive or semi-primitive, non-motorized 

activities.

The plan provides guidance to manage wilderness consistent with the Wilderness Act of 1964.

The Forest Service does not exclude anyone from wilderness; restrictions are based on the 

method of transportation and types of assistive devices permitted, not on the abilities of visitors. 

Motorized wheelchairs are permitted in wilderness, as long as they are designed for mobility 

purposes, are used by a person with such an impairment and are suitable for indoor use (i.e., 

electric, not internal combustion). Other appropriate modes of travel in wilderness include horses, 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 721

mules, pack stock, and nonmotorized watercraft, where appropriate. The Forest Service is not 

obligated to modify trails and natural areas to accommodate mobility devices or persons with 

limited mobility.

Concern Statement: Explain how the Forest Service has the authority to provide 

management area guidance for recommended wilderness. Concern is that only Congress 

can create wilderness areas. (32.13, 32.4, 32.8, 97.1)

Response: The Forest Service has authority to provide management area guidance for 

recommended wilderness through law and policy. The Arizona Wilderness Act of 1984 states,

“...areas recommended for wilderness designation [in revised land management plans] 

shall be managed for the purpose of protecting their suitability for wilderness 

designation...” (Section 103 (b)(4)). 

Forest Service Manual (FSM) gives a Forest Supervisor the responsibility to “Develop 

management direction for recommended wilderness. . .” (FSM 1923.04c) and the Regional 

Forester the responsibility for “Approving management direction for recommended 

wilderness...” (FSM 1923.04b). Forest Service policy/planning direction is found in the Forest 

Service Manual 1920 and Forest Service Handbook 1909.12. Forest Service Handbook 1909.12, 

Chapter 70 (January 2007) contains the policy direction that guides wilderness evaluations and 

the process of recommending areas for wilderness. 

A recommendation for wilderness within the plan is,

“a preliminary administrative recommendation that would receive further review and 

possible modification by the Chief of the Forest Service, Secretary of Agriculture, and the 

President of the United States. The Congress has reserved the authority to make final 

decisions on wilderness designation.” (Forest Service Handbook 1909.12, Chapter 70, 

Section 73.11). 

This language is included in both the EIS and plan.

The areas recommended for wilderness in the Apache-Sitgreaves NFs plan would not be managed 

as wilderness; they would be managed to:

“protect their wilderness characteristics pending legislation and designation and to 

provide for existing uses where compatible” (chapter 3 of the EIS, environmental 

consequences for the “Wilderness Resources” section). 

The direction provided in the Recommended Wilderness Management Area section in chapter 3 

of the plan would accomplish this requirement of the Arizona Wilderness Act of 1984 and the 

responsibilities found in Forest Service Manual 1923.04. 

The plan just makes wilderness recommendations; only Congress can designate a wilderness. The 

plan provides guidance to maintain the wilderness characteristics of these areas until Congress 

takes action.
Appendix A

722 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: For areas that received a medium, medium/high, or high capability 

rating in the wilderness evaluation, the Forest Service should manage them in a way to 

preserve their wilderness values. (162.148, 162.188)

Response: Section 217.17 of the 1982 Planning Rule requires that unroaded areas within the 

National Forest System be evaluated and considered for recommendation for wilderness 

designation during plan revision. The Apache-Sitgreaves NFs used the wilderness evaluation 

process outlined in Forest Service Handbook 1909.12, Chapter 70. Identification as a potential 

wilderness does not confer any special status to an area nor does it require any additional 

management restrictions; it simply identifies which areas were capable and available for 

wilderness recommendation and could help meet regional wilderness needs (Potential Wilderness 

Evaluations (Forest Service, 2012b).

The Arizona Wilderness Act of 1984 states,

“...areas not recommended for wilderness designation [in revised land management 

plans] need not be managed for the purpose of protecting their suitability for wilderness 

designation prior to or during revision of such plan...” (Section 103 (b)(4)). 

The logical extension of this is that areas not recommended for wilderness in a plan, do not need 

to be managed to protect their wilderness suitability.

Conversely, the Arizona Wilderness Act of 1984 also states,

“...areas recommended for wilderness designation [in revised land management plans] 

shall be managed for the purpose of protecting their suitability for wilderness 

designation...” (Section 103 (b)(4)).

Only areas recommended for wilderness designation by the Regional Forester will be managed to 

maintain their wilderness characteristics (see the “Recommended Wilderness Management Area” 

section in chapter 3 of the plan). Preliminary administrative recommendations for wilderness are 

included in the record of decision for the plan.

Potential wilderness not recommended for wilderness designation would be managed under plan 

forestwide direction and the appropriate management area direction. Potential wilderness within 

the Primitive Area Management Area (29 percent) would be managed according to that 

management area direction consistent with 36 CFR §293.17(a). Another 58 percent would be 

managed under the Natural Landscape Management Area. Any inventoried roadless area, 

regardless of its management area location, would be managed to protect its roadless character.

Concern Statement: The DEIS states that "opportunity" for additional wilderness/primitive 

areas exists; however no justification is provided as to the purpose of designating more. 

(108.222)

Response: The rationale for recommending additional areas for wilderness is discussed under the 

“Recommended Wilderness” header in the “Wilderness Resources” section in chapter 3 of the 

EIS.

Section 217.17 of the 1982 Planning Rule requires that unroaded areas within the National Forest 

System be evaluated and considered for recommendation for wilderness designation during plan 

revision. The Apache-Sitgreaves NFs used the wilderness evaluation process outlined in Forest 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 723

Service Handbook 1909.12, Chapter 70; the areas assessed were identified as potential 

wilderness. Identification as a potential wilderness does not confer any special status to an area

nor require any additional management restrictions; it simply identifies which areas were assessed 

in the “Potential Wilderness Evaluations” (Forest Service, 2012b). The plan only makes 

recommendations; only Congress can designate a wilderness.

Concern Statement: Include ample wilderness recommendations to protect large contiguous 

habitats and protect opportunities for quiet recreation. (23.9, 140.3, 94.11, 80.5)

Response: The plan protects large contiguous habitats and opportunities for quiet recreation 

primarily through management area direction. The Wilderness, Primitive Area, and 

Recommended Wilderness Management Areas all have desired conditions that these areas 

provide primitive and/or semi-primitive nonmotorized recreation opportunities and that recognize 

the importance of these areas to wildlife. Several Natural Landscape Management Area desired 

conditions also emphasize the area’s contributions to quiet recreation opportunities and wildlife 

habitat and connectivity.

Concern Statement: Complete a conservation vision for Escudilla Mountain that allows for 

planned vegetation management and motorized access to Terry Flat loop while protecting 

solitude and quiet wilderness of Escudilla Wilderness: (1) Protect as recommended 

wilderness the maximum additions to Escudilla Wilderness as submitted by the White 

Mountain Conservation League and the Arizona Wilderness Coalition, (2) Increase the 

proposed wilderness addition in Alternative B to wrap around the south side of Terry Flat 

along Alpine wildland-urban interface boundary (WUI) to Crackerjack Lake and the 

boundary of the Nutrioso WUI, (3) maintain the Hulsey Bench Wildlife Quiet Area and 

extend it into Paddy Creek drainage to eventually share its boundary with the wilderness 

proposal at Crackerjack Lake. (39.14, 39.20, 39.12, 39.11, 162.155, 146.7, 162.178, 162.175, 

162.156, 162.187)

Response: The plan includes a preliminary administrative recommendation for 6,813 acres of 

wilderness adjacent to the north and east sides of Escudilla Wilderness and southeast of the 

wilderness between Forest Service roads 275 and 8056 on Terry Flat. The plan does not include 

item 2 above or the extension of Hulsey Bench Wildlife Quiet Area (WQA) south of Forest 

Service road 8056. These lands would be part of the General Forest Management Area. The 

Hulsey Bench WQA was not extended to the south (item 3), because FS road 8056 would bisect 

the WQA and the area would not meet WQA desired conditions.

The Recommended Wilderness Management Area in alternative D of the EIS includes all 

potential wilderness around Escudilla Wilderness. However, there are no changes to the Hulsey 

Bench Wildlife Quiet Area (WQA) in any alternative because of the reason stated above. More 

detailed information about each potential wilderness can be found under “Potential Wilderness 

Evaluations” (Forest Service, 2012b) on the Apache-Sitgreaves NFs Web site: 

http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606.

Concern Statement: The contiguous roadless lands surrounding the Blue Range Primitive 

Area to the north, west, and south (including the Pipestem, Lower San Francisco, Mitchel 

Peak, and Sunset Inventoried Roadless Areas) should be recommended for wilderness 

designation and must be managed to preserve wilderness values per Parker v. U.S. (162.143, 

162.186)
Appendix A

724 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Response: The Apache-Sitgreaves NFs reviewed the report concerning the applicability of Parker 

v. U.S. to the Blue Range Primitive Area contiguous lands in 2010 and responded to seven 

individuals and two organizations. The Forest Service disagrees with the opinion presented in the 

report that lands contiguous to the Blue Range Primitive Area must be managed to preserve 

wilderness values. The response letter is available in the plan set of documents. 

The plan would manage these lands primarily within the Natural Landscape Management Area; 

guidance is found in chapter 3. This management area consists of generally undeveloped areas 

that are natural appearing and provide primitive and semi-primitive recreation opportunities. This 

management area includes most of the inventoried roadless areas (IRA) identified in the 2001 

Roadless Area Conservation Rule; the IRAs would be managed to protect and conserve their 

roadless character.

Lower San Francisco and Pipestem IRAs are contiguous to the Blue Range Primitive Area. 

Sunset and Mitchell Peak IRAs are considered to not be contiguous to the Blue Range Primitive 

Area. Forest Service road 212 separates Sunset IRA from Lower San Francisco and Mitchel Peak 

IRAs. Forest Service road 475 separates Mitchell Peak IRA from Pipestem IRA.

Concern Statement: Leonard Canyon, West Chevelon Canyon, Chevelon Canyon North, 

Chevelon Canyon, Wildcat Canyon South, Black Canyon, and Chevelon Lake should be 

recommended for wilderness designation. (162.158, 39.16)

Response: These areas are not recommended for wilderness in the plan. However, the effects of 

recommending these areas were considered in the EIS. The areas are included in the alternative D 

Recommended Wilderness Management Area. Portions of these areas are included in eligible 

wild and scenic river corridors in all alternatives.

Concern Statement: Chevelon Lake should not be recommended for wilderness designation. 

(101.4)

Response: Chevelon Lake is not recommended for wilderness in the plan. The area is considered 

for wilderness recommendation in alternative D in the EIS; while alternatives A, B, and C 

consider the effects of not recommending the area for wilderness.

Concern Statement: There is no need for additional wilderness. (24.1, 24.4, 98.23, 148.1, 

109.6, 22.2)

Response: This is considered under alternative A in the EIS, where no lands are recommended 

for wilderness.

Concern Statement: Remove wilderness designations and wilderness recommendations for 

areas within the Wallow Fire that burned with moderate and high intensity. Concern is 

these areas should be managed to stop further degradation and be re-vegetated. (108.81)

Response: Wilderness is designated by Congress. It is beyond the scope of the plan revision 

process and Forest Service authority to remove wilderness designations.

The Wallow Fire may have affected Bear Wallow Wilderness, Escudilla Wilderness, portions of 

the Blue Range Primitive Area, and recommended wilderness adjacent to Bear Wallow and 

Escudilla but it did not affect the wilderness character of these areas. They still possess 

naturalness, opportunities for solitude or a primitive and unconfined type of recreation, and 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 725

special values. Plan direction for these areas is found in chapter 3 in the “Wilderness,” “Primitive 

Area,” and “Recommended Wilderness” sections. The “Potential Wilderness Evaluations” (Forest 

Service, 2012b) were reviewed following the Wallow Fire. It was determined that the evaluations 

were still valid based on the assumption that fire does not change wilderness character. 

The priorities for rehabilitation post-Wallow were areas with the potential flooding and/or erosion 

effects to human life and property. No rehabilitation treatments occurred in designated wilderness 

or the primitive area. Only a small portion of the recommended wilderness north of Escudilla 

Wilderness was seeded to reduce erosion and establish vegetation. The remaining recommended 

wilderness was not seeded or mulched because the danger to human life and property was not 

present. Seeding and/or mulching of recommended wilderness is not permanent and would not 

negatively affect wilderness character (naturalness) in the long term. Natural revegetation is 

occurring in many areas.

Research Natural Areas

Concern Statement: Clarify the affected environment for the proposed research natural 

areas (RNAs): (1) amount burned in 2011 Wallow Fire and (2) whether lands were impacted 

by high intensity fire, erosion, or flooding. (108.210, 81.23)

Response: The interdisciplinary team evaluated the forests’ one existing research natural area 

(RNA) and seven proposed RNAs for potential inclusion into the plan. This is documented in 

“Research Natural Areas (RNAs) of the Apache-Sitgreaves NFs and the Revision of the Forest 

Plan” (Forest Service, 2012c). This document describes the amount these areas were burned by 

the Wallow Fire and the severity of the burn. This document provides the basis for those areas 

recommended as research natural areas in the plan and analyzed in the EIS.

Concern Statement: Modify Background for Recommended Research Natural Areas 

(proposed plan p. 118). The recommended Sandrock Research Natural Area is described as 

having been excluded from domestic grazing for 25 years. Though the intent was to exclude 

livestock grazing for the period described, livestock were present on Sandrock throughout 

the entire period. (101.83)

Response: The forests acknowledge unauthorized and feral cattle have been reported on the 

allotment. The plan provides a guideline stating that if necessary, recommended research natural 

areas (RNAs) should be fenced to manage unique features (see the “Research Natural Areas” 

section in chapter 3).

Concern Statement: Modify Recommended Research Natural Area Desired Condition 

(proposed plan p. 118) "The Three Forks Closure Area (30 acres) of the recommended 

Three Forks RNA is free from human trampling and other disturbances to protect very 

sensitive and unique species, such as the Three Forks springsnail, California floater, New 

Mexico meadow jumping mouse, and Chiricahua leopard frog, and loach minnow." Loach 

minnow have never been documented within the actual closure area. Loach minnow have 

been documented within the mainstem of the East Fork Black River, which runs parallel to 

but not within or through the closure area. Designated Critical Habitat for loach minnow 

also exists on the East Fork Black River but not within the closure area. (101.84)
Appendix A

726 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Response: No change was made to the desired condition for “Recommended Research Natural 

Areas” as loach minnow are present in the lower reach of Coyote Creek, which falls within the 

Three Forks Closure Area.

Concern Statement: Remove research natural area (RNA) designations. Concern is that it 

leads to de facto wilderness management. (108.209, 81.17)

Response: The interdisciplinary team evaluated the forests’ one existing research natural area 

(RNA) and seven proposed RNAs for potential inclusion in the plan (see the “Research Natural 

Areas” section in chapter 3 of the EIS). The evaluation considered the need for the existing or 

additional RNAs. The primary criterion for determining need was the lack of ecological 

representation in the RNA system regionwide. 

Research Natural Areas are units of land where natural conditions are maintained to allow natural 

physical and biological processes to continue without human intervention. These areas are 

essential for comparison to managed areas and to provide baseline conditions; they are especially 

important with regards to climate change. However, some deliberate manipulation can be utilized

to maintain the unique feature that the RNA was established to protect, such as the aspen in the 

Corduroy Recommended RNA near Hannagan Meadows. 

The plan retains the existing Phelps Cabin RNA and adds the Phelps Botanical Area to the RNA. 

The plan includes six recommended RNAs: Thomas Creek, Corduroy, Three Forks, Lower 

Campbell Blue, Sandrock, and the recommended Phelps Cabin RNA addition (Phelps Cabin 

Botanical Area). Following approval of the plan, further evaluation and a National Environmental 

Policy Act (NEPA) environmental assessment would be completed for each recommended RNA. 

If approved by the regional forester, with concurrence of the station director, the plan would then 

be amended to recognize these areas as designated RNAs. As stated in the management 

approaches for the “Recommended Research Natural Areas” section, if the RNA is not designated 

within 5 years, it may be re-evaluated to verify its need for RNA designation.

Concern Statement: Concern that in U.S. v. NM, the Supreme Court defined the law as to 

the limitations of Forest Service's use of water resources and forbid the agency’s use of 

waters for the purposes of such as research natural areas. (104.9)

Response: In 1978, in United States of America v. New Mexico, the Court found that the reserved 

water rights on national forests apply only to the preservation of timber resources and water 

flows. All other claimed needs were to be considered secondary purposes and the Federal 

government would have to obtain rights like any other appropriator under State law. Federal 

reserved water rights may only include quantities of water necessary to meet the primary purpose 

for which the reservation was established ("primary purpose" requirement) and only in the 

minimum amounts necessary to meet those purposes ("minimal needs" requirement). The forests 

have followed statutes set forth by the State for purposes such as for wildlife use and for instream 

flow uses, which may occur in proposed research natural areas. The plan addresses management 

of water in the “Water Resources” and “Water Uses” section of the plan in chapter 2.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 727

Scenic Resources

Concern Statement: Explain the link between ecological function and scenic values.

(108.236)

Response: The phrase “and ecological function” has been removed from the third desired 

condition in the “Scenic Resources” section of the plan to clarify the desired condition.

Lands and Special Uses

Concern Statement: Address road trespass, in particular, where private inholdings have 

alternative legal access across non-Federal lands. (99.30)

Response: The plan contains a desired condition and an objective to resolve trespass cases; these 

are listed in the “Lands section of the plan in chapter 2. The Apache-Sitgreaves NFs would 

address road trespass at the project-level on a case-by-case basis as resources and funding is 

available.

Concern Statement: Clarify whether the number of recreation residences is correct in table 

133 (DEIS p. 393). (99.29)

Response: Table 133 in the “Lands and Special Uses” section in chapter 3 of EIS has been 

updated. There are 25 recreation residences on the Apache-Sitgreaves NFs.

Concern Statement: Modify the Special Uses guideline "Large group and recreation event 

special uses should not be authorized within wilderness, recommended wilderness, primitive 

area, wildlife quiet areas, eligible "wild" river corridors, Phelps Cabin Botanical Area, 

Phelps Cabin Research Natural Area, or recommended research natural areas to protect the 

unique character of these areas" (proposed plan p. 101) to exclude or limit riparian and 

wetlands areas as sites authorized for large group and recreational special use events, where 

practicable. (112.27)

Response: The guideline has been modified to include riparian and wetland areas. This would 

exclude or limit large group and recreational special use events within riparian and wetlands to 

protect the unique character of these areas.

Concern Statement: Modify the Special Uses guideline to read "Commercial outfitters and 

guides should not be authorized to use developed campgrounds and developed trailheads so 

those sites remain available for noncommercial forest visitors" (proposed plan p. 101). 

(99.7)

Response: The guideline was not modified, it reads

“Commercial outfitters and guides should not be authorized to use developed 

campgrounds so those sites remain available for noncommercial forest visitors.” 

The interdisciplinary team discussed the proposed change and concluded parking at trailheads 

could be allowed by outfitters and guides to reduce parking along roads that could interfere with 

safe travel. Restrictions at trailheads could be imposed during the outfitter-guide permitting 

process or through site specific analysis.
Appendix A

728 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Recognize that small communities (e.g., Eagar, Alpine) depend on 

water sources (e.g., wells, springs) located on the Apache-Sitgreaves NFs. (99.21)

Response: The following sentence was added to the “Water Resources” section of the EIS, under 

the “Water Yield” header, 

“Although there are no designated municipal watersheds within the forests, many local 

communities and individuals depend on water generated from the forests through springs, 

streams, and groundwater pumping for domestic, irrigation, and some 

industrial/agricultural uses.”

Added a phrase on small communities in the Management Approaches for Water Uses section of 

the plan, 

“Management emphasis is to provide adequate water supplies to support the mission of 

the Agency in addition to helping maintain continuous water supplies to downstream 

users on and off the forests including small communities located adjacent to the ApacheSitgreaves NFs.”

Concern Statement: Select a plan that will protect the greatest amount of biodiversity and 

allow you to purchase more land of such type and quality. (8.6)

Response: The plan provides protections for biodiversity (i.e., biological diversity); it sets forth 

desired conditions, objectives, standards, and guidelines to maintain species diversity and species 

viability across the planning area. The management approaches for the “Lands” section in chapter 

2 describes criteria for lands desirable for acquisition. These criteria include those directly related 

to biodiversity: vital wildlife habitat and riparian areas.

Concern Statement: Forbid the exchange or sale of any land to any public or private entity. 

(8.7)

Response: Exchange, sale, or purchase of land is beyond the scope of the plan and the plan 

process. Land adjustments (e.g., exchanges, purchases) benefit the Forest Service and the public 

through consolidating the National Forest System land base, reducing administrative problems 

and costs, enhancing public access and use, and supporting resource management objectives. The 

Forest Service would follow law (e.g., General Exchange Act of 1922, Townsite Act, Small Tracts 

Act) when considering or conducting land adjustments.

Concern Statement: Explain how non-permitted signs located on the forests are managed. 

(99.31)

Response: Specific direction for the management of signs is not addressed in the plan; 

programmatic direction for special uses can be found in the “Special Uses” section in chapter 2 of 

the plan.

Signs on the Apache-Sitgreaves NFs that are not permitted are either placed under a special use 

permit or removed from the forests. Permitting is accomplished on a site specific case-by-case 

basis in conformance with Forest Service Handbook 2709.11 - Special Uses Handbook. 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 729

Cultural Resources

Concern Statement: Recognize that historic places include not only Indian ruins, but also 

ranger stations, fire lookouts, administrative sites, historic stock driveways (Sheep 

Driveway and Grapevine Canyon), old cabins (Greenwood cabin), and corrals. (105.17, 

131.14)

Response: The plan does recognize historic places including lookouts, ranger stations, and 

administrative sites in the “Cultural Resources” section. The properties presently listed on the 

National Register of Historic Places (NRHP) are described in the background. The plan also 

contains the following objective: 

“During the planning period, nominate at least five eligible cultural resources for 

inclusion in the NRHP.” 

Concern Statement: Correct table 137 (DEIS p. 402) to include Yavapai under protohistoric 

and prehistoric occupation. (7.1)

Response: Table 137 in the EIS, “historic-age activities and possible site types” has been updated 

to recognize the Yavapai and Apache peoples. Thank you for pointing this out.

Concern Statement: Consider using a database like AZGFD HabiMap as an efficient 

method to research all culture clearances on the Apache-Sitgreaves NFs. (121.3)

Response: The plan does not identify specific methods for researching cultural clearances. 

During plan implementation, the Apache-Sitgreaves NFs archaeologists use a variety of methods 

(as allowed by agency policy) to determine whether to grant cultural resources clearance for a 

project or activity. The Arizona Game and Fish Department HabiMap is used, in addition to other 

inventories and tools, to assist the archaeologists in their analyses.

American Indian Rights and Interests

Concern Statement: ''Members of affiliated Tribes have access to gather traditional forest 

resources" (p 54). "Traditional forest resources" is not defined. (108.148)

Response: The desired condition listed above does not appear in the proposed plan. It appeared in 

the June 2009 Working Draft Land Management Plan (see EIS, chapter 2, “Alternatives 

Considered but Eliminated from Detailed Study” section). Based on public feedback, the desired 

condition was clarified and appears in the “American Indian Rights and Interests” section of the 

plan as:

“Members of affiliated tribes have access to gather forest resources and products for 

traditional cultural purposes7 (e.g., medicinal plants, boughs, basket materials, pollen, 

plants and minerals for pigments).”

 7 Sacred sites as defined in E.O. 13007, traditional cultural properties as defined in National Register Bulletin 38, 

traditional cultural purposes as defined in the 2008 Farm Bill Section 8102, Subtitle B.
Appendix A

730 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: The provision of consulting tribes during planning and project design 

to incorporate tribal perspectives and knowledge into decisions should be extended to other 

people, including those that have ancestral links to places and artifacts. (108.205)

Response: No additional direction requiring consultation with members of the public was added 

to the plan. Law and policy (e.g., National Environmental Policy Act, National Forest 

Management Act, Forest Service Manual 1500) already require the Forest Service to include 

public participation during planning and project design and decisions. 

American Indian tribes are sovereign nations. As a result, the Forest Service has a Federal Trust 

Duty to American Indians. Several laws require the Forests Service to consult with tribes. 

Executive Order 13175 specifically requires consultation with Tribes when proposed policies or 

management actions may affect their interests.

Extensive public involvement and collaboration, in addition to tribal consultation, has occurred in 

the development of the plan. See the EIS “Public Involvement” section (chapter 1) and appendix 

F (“Collaboration and Public Involvement”). 

Forest Products

Concern Statement: The Forest Service must consider and disclose the contribution of 

foreseeable management activities to climate change including: groundwater extraction, 

surface water diversions and withdrawals, use of existing roads and trails, construction of 

new roads and trails livestock grazing, fire and fuel management, timber harvest, minerals 

development, and spread of invasive species. (26.158, 26.160, 46.1, 64.3, 162.6)

Response: Global and national climate change is beyond the scope of the plan. The largest extent 

considered in the cumulative environmental consequences analyses in chapter 3 of the EIS was 

set at the White Mountains-San Francisco Peaks- Mogollon Rim Ecoregion scale. Climate change 

effects were analyzed at this ecoregion scale in the “Vegetation,” “Forest Products,” and “Forest 

Health” sections of the EIS. The effects of climate change to forest resources was also analyzed in 

the “Air,” “Soil,” “Watershed,” “Water Resources,” “Riparian,” “Wildlife and Rare Plants,” 

“Invasive Species,” and “Livestock Grazing” sections of the EIS.

Additional text has been added to the EIS “Forest Products” section that discloses the potential 

environmental effects with respect to carbon storage and sequestration. In summary, the science 

indicates that many complex variables and tradeoffs must be considered. Scientific literature on 

the role of forests and forest management in carbon storage versus carbon emissions indicates that 

many complex variables and tradeoffs must be considered. In general, according to Ryan et al.,

2010; Huang et al., 2013; North and Hurteau, 2011; Hurteau et al., 2010; North et al., 2009;

Hurteau and North, 2009; Finkral and Evans, 2008; and Dore et al., 2010, treatments that prevent 

deforestation, reforest severely burned forests, retain the majority of large trees, retain soil 

organic reserves, increase health and growth rates of existing forests and herbaceous vegetation, 

and convert trees into durable wood products retain and improve carbon storage. Use of biomass 

energy can reduce fossil fuel carbon emissions. Exhaust from harvesting and industrial operations

and from wildland fire treatments would cause immediate carbon emissions. However, these 

activities can reduce greater pulses of carbon emitted from large stand-replacement wildfires in 

addition to preventing large scale losses of forests as important carbon sinks. Well-designed 

restoration thinning and maintenance of tree groups and/or stands to sustainable levels of all tree 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 731

sizes present should be an important treatment consideration for the site capability, species 

silvics, and fire regime involved (Fiedler et al., 2010; Dore et al., 2010; Reynolds et al., 2013; 

Triepke et al., 2011; Hurteau et al.. 2010; Covington, 2000).

Concern Statement: Concern that the maximum allowable sale quantity (ASQ) volumes 

identified by alternative in the EIS may prove a limiting factor for the continued long term 

growth of the existing industry, even without considering the Four Forest Restoration

Initiative (4FRI) contract. It is unrealistic to expect long term sustained contributions from 

non-suitable lands to the availability of steady volumes of industrial forest products. 

Increase the ASQ volume to 450,000 CCF annually, in order implement a restoration 

program designed to support the existing and currently developing industry in the White 

Mountains and to simultaneously support the contract(s) expected to result from the second 

analysis of the4FRI. To ensure that this higher volume is harvested, follow these strategies 

for the lifetime of the plan: (1) subordinate the focus on restoring grasslands and other nonsuitable timberlands; (2) reduce extensive use of moderate and/or high severity fire as a first 

entry thinning treatment on suitable timberlands and treat with mechanical harvest instead.

(161.37, 161.39, 161.40, 161.41)

Response: The Allowable Sale Quantity (ASQ) from suitable timberlands (wood volume) is 

analyzed and the environmental consequences disclosed in the “Forest Products” section of the 

EIS. Forest ecosystem restoration is one of the primary goals of the plan, to ensure that all forest 

products and services are sustainable long term. Therefore, wood volume generated from 

restoration cuts is considered a by-product of restoration treatments. 

For the wood volumes to be produced as projected in the plan (see the objectives in the “Forest 

Products”), restoration of over-stocked forested acres is necessary before additional 

uncharacteristic wildfire and/or insect outbreak events impact the forests. Designating national 

forest acres as suitable timberlands does not exclude them from legally mandated multiple use 

requirements and resource protections. In accordance with the1982 Planning Rule provisions, in 

compliance with the National Forest Management Act and other legislation, the plan in its totality 

requires that timber harvesting levels must be compatible with providing wildlife habitat, 

watershed stability, and numerous natural resource protections. 

Note that approximately 29 percent of the forested PNVT acres were removed from immediate 

timber production by the Rodeo-Chediski, Wallow, and other large wildfires since the year 2000; 

the higher wood volumes this commenter desires to see produced annually would not readily be 

available within the planning period (approximately 15 years). 

Alternative C explored the maximum wood harvest volumes possible in the context of existing 

conditions, multiple use mandates, predicted budgets and workforce capacity. It was not selected 

due to ecological analysis results, and because alternative B (the plan) was found to provide 

adequate wood harvest volumes to support industrial demands during the planning period. To 

increase post-Wallow Fire wood volumes offered annually above those already analyzed would 

require either: cutting more acres per year; cutting more commercial-sized trees per each acre 

treated annually; targeting only large diameter trees in all annual cuts; increasing the number of 

suitable timberland acres; or some combination thereof. Increases in cutting levels beyond those 

analyzed in detail would have the potential to threaten the viability of some wildlife and/or fish 

species. An alternative to have large increases in timber harvest was considered in chapter 1 of the 

EIS (see the “Alternatives Considered but Eliminated from Detailed Study” section).
Appendix A

732 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

The analysis of cumulative environmental consequences in the “Forest Products” section in 

chapter 3 of the EIS shows that the plan would meet a large portion of the increasing market 

demand when combined with the other three national forests participating in the Four-Forest 

Restoration Initiative (4FRI). If the 4FRI treatments are limited to mostly ponderosa pine and dry 

mixed conifer acres, with less emphasis on treating the other PNVT acres, this could prevent 

larger increases in possible industrial volume offerings. One possible offset might be additional 

salvage volume made available after current or future insect/disease outbreaks, wildfire, and/or 

use of wildland fire, which is not included in the ASQ volume calculations. 

The plan’s focus to restore grasslands and riparian forest acres is preferred to improve overall 

ecosystem health and fire-resiliency in PNVTs which should normally function as natural barriers 

to rapid crown fire spread. Conifer encroachment can be removed at relatively lower costs, and 

once restored, grasslands should provide improved herbaceous ground cover with better forage 

production and watershed stability contributing to other aspects of the local economy.

Expeditious restoration of the landscape cannot be achieved entirely by mechanized tree removal, 

which is a much slower method than using fire. The plan strikes a reasonable balance between 

these two methods. (Also see response to comment 161.22 in the “Vegetation” section of this 

appendix)

New industrial uses for small diameter (non-commercial sized) trees (Livingston 2008, 2006, 

2004), uses for previously non-industrial tree species, and improvements with in-forest wood 

removal as well as new milling efficiencies (waste reductions) are further expected to help 

support developing markets to better utilize more of the same volume offered per acre (Drury and 

Boehning, 2013). The Forest Service would continue to monitor market demand and if resource 

conditions allow, the plan could be amended to increase the ASQ if needed.

Concern Statement: Concern that the Forest Service guaranteed 5,000 acres/year to the 

White Mountain Stewardship project resulting in approximately 12% of the forest actually 

treated. Thus the Fire Specialist Report statement which says that “since 2001, there has 

been a management emphasis to treat areas identified in the CWPPs and WUIs” should be 

removed or corrected. (108.228)

Response: Upon further review, the statement was determined to be correct and has not been 

removed or corrected.

This first sentence of the above comment is made with respect to recent vegetation treatments

implemented under the current 1987 plan (alternative A). The quote the commenter refers to is 

taken from the “Fire” section in chapter 3 of the EIS. In full, it states, 

“Alternative A (1987 plan) does not address the hazards associated with the WUI. 

However, since 2001, there has been a management emphasis to treat areas identified in 

the CWPPs and WUI.” 

Treatments completed in the wildland-urban interface (WUI) and within the community wildfire 

protection plans (CWPP) areas in the past 12 years have been focused on fuels and fire hazard 

reduction, rather than complete forest or woodland restoration. Acres treated by the White 

Mountain Stewardship (WMS) contracts do not reflect total acres which received fuels reduction 

treatments, as numerous additional acres were treated independently from the WMS mechanized 

treatments during the same timeframe, by using other methods instead of, or in addition to, 

mechanized thinning. 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 733

Concern Statement: Modify the Forest Products standard "Permits which authorize the 

collection of forest products shall include permit provisions to ensure the needs of wildlife, 

which depend upon those forest products, will continue to be met (e.g., cone and mushroom 

collection and the overwinter forage needs of squirrels)" (proposed plan p. 94) to include 

conditions on forest product harvest permits that ensure the needs of aquatic and riparian 

resources, watershed protection, and listed species habitat needs. (112.21)

Response: The standard was not modified based upon this comment.

The phrase “...provisions to ensure the needs of wildlife...” in this standard is all-inclusive and 

partially addresses this comment. Moreover, this standard has been edited to now read,

“Authorizations to cut, collect, or use forest products for any personal, commercial, or 

scientific purpose (i.e., permits, contracts, agreements) shall include permit provisions to 

ensure the needs of wildlife, which depend upon those forest products, will continue to be 

met (e.g., fungi and cone and mushroom collection with respect to and the overwinter 

forage needs of squirrels).”

This change was made to strengthen the standard’s applicability to all administrative forms of 

permitted forest products removal.

The “Forest Products” section in chapter 2 of the plan contains a desired condition and a 

guideline that are also all-inclusive in meeting the intent of this Concern Statement: 

“The collection of live plants, mushrooms, and other forest products does not impact 

species persistence onsite.” (Desired Condition)

“Permits issued for forest products should include stipulations to protect resources.”

(Guideline)

To further address this comment, text was added to the management approaches for the “Forest 

Products” section: 

“Plan direction and interdisciplinary input are used to develop additional projectspecific and/or resource specific conditions to be included in all forest product permits 

and contracts issued.”

The plan’s “Special Uses” section contains a standard and a guideline that are also all-inclusive 

and tie in with a sentence in the management approaches: 

“Special use authorizations for the collection of live species with limited distribution 

(e.g., some invertebrates, plants) shall include permit provisions to ensure the species 

persist onsite.” (Standard)

“As applicable, issuance of special use authorizations should incorporate measures to 

reduce potential impacts to wildlife and avoid rare and unique habitats (e.g., bogs, 

fens).” (Guideline)

“Forest users should have information regarding when there is a need to obtain a permit, 

particularly for collection of forest products.”(Management Approach)
Appendix A

734 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Finally, there are related plan decisions in the “Water Resources,” “Aquatic Habitat and Species,” 

“All PNVTs,” “Riparian Areas,” “All Forested PNVTs,” and the “General Forest Management 

Area,” sections that would apply.

Concern Statement: Bring back logging so the forest can be groomed. (153.3)

Response: Tree thinning and/or cutting is identified for nearly all potential natural vegetation 

types (PNVTs) as one means to attain desired conditions identified in the plan. Table 146 in 

chapter 3 of the EIS shows a succinct comparison of cutting levels by alternative. The “Lands 

Suitable for Timber Production” section of the plan lists management areas in which commercial 

timber production prescriptions and activities are suitable, as well those areas in which tree 

cutting is suitable to meet non-commercial restoration and maintenance goals, using either 

mechanized and/or hand cutting as appropriate. Timber harvest on suitable timberlands would be 

done at sustainable levels as identified in the long term sustained yield capacity determination 

which is documented in appendix B (“Description of the Analysis Process”) of the EIS. 

Concern Statement: Forest products management actions should be dictated primarily by 

the expeditious implementation of landscape scale restoration primarily through 

mechanical treatments that produce products to sustain the existing forest industry and to 

allow natural resources-based rural economic development through new infrastructure of 

small diameter tree utilization at industrial scale. To ensure that this can be done most 

expeditiously, follow these strategies for the lifetime of the plan: (1) subordinate the focus on 

scientific silviculture priorities and traditional forestry methods of uneven-aged 

management and sustained yield of harvest volumes on a regulated non declining evenflow basis for the long term; (2) sustain the social license required for the re-introduction

of appropriate scale industry logging activities at the landscape scale in a non-conflictual

and non-litigious manner. (161.22, 161.31, 161.34, 161.73, 98.16, 61.1)

Response: Just as industry has physical limits to the capacity of raw material it can handle or 

treatment rates it can produce, the Apache-Sitgreaves NFs have a limit to budget and workforce 

capacities for analyzing, preparing, and implementing annual restoration projects. The plan offers 

a reasonable treatment rate for mechanized operations on this national forest, especially when 

viewed in combination with the acreages to be offered to industry for treatment on the other three 

national forests in northern Arizona under the Four Forest Restoration Initiative (4FRI) contract.

Removal of strictly small-diameter trees does not necessarily constitute ecosystem restoration. It 

is neither practical nor possible to expect that the entire ecosystem can be restored within 10 years 

after the 100+ years it took to become departed from desired conditions. Avoidance of all conflict 

is a worthwhile ideal, but providing social license to avoid conflict is outside the scope of the 

plan.

The plan states that federal laws and Forest Service policy must also be followed in all projects. 

The Forest Service uses the best available science, in an interdisciplinary National Environmental

Policy Act (NEPA) process, for all project analyses to inform the deciding official. However the 

official is not required to choose the alternative or to implement the project design which is most 

consistent with the current science, especially if new pertinent sound science comes to light. The 

plan incorporates the best available science into its components. All projects and activities must 

be consistent with the plan as described in chapter 1 under the “Plan Consistency” section.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 735

Appendix B in the plan’s “Vegetation Management Practices” section cites chapters in FSM 2470 

and FSM 5100 which require sound forestry science to be applied through silvicultural systems 

and methods, by a certified Silviculturist working in cooperation with a qualified Fuels Specialist 

if needed (Rasure and Harbor 2011, Bartuska and Croft 2001). Traditional forestry and 

silviculture practices are adaptable to new restoration concepts and techniques (Arno and Fiedler 

2005), and can be applied in consistency with FSM 2020 for management toward ecological 

restoration and resilience.

Uneven-aged management is perhaps the least-litigious management system because it retains 

trees of all sizes across the treatment area for sustainable forest conditions. There have been 

numerous timber sale lawsuits and court injunctions across the Forest Service Southwestern 

Region for cutting too many large trees under even-aged management methods in the 1980s and 

90s. Tribal foresters in the southwest have preferred uneven-aged management for decades with 

very little conflict. Uneven-aged management is the most clearly-defined system to achieve the 

plan’s many desired conditions for restoring forest structure and function. It should provide a high 

degree of success now that more markets are available to take the excessive numbers of small 

diameter trees per acre, which is vital for complete restoration. Sustained yield of harvest 

volumes on a regulated non declining, even-flow basis for the long term is required by the 

provisions of the 1982 Planning Rule, and by FSM 2400 directives, for legal compliance.

Concern Statement: Do not eliminate ability to cut firewood used to heat homes. (24.5)

Response: The plan contains an objective in the “Forest Products” section in chapter 2 to 

annually provide up to 94,000 hundred cubic feet (CCF) of firewood for personal and commercial 

use. On a side note, the cord volume estimate was found to be in error in the proposed plan; it has 

been corrected to the true equivalent of 119,380 cords. The plan’s “Monitoring Strategy” in 

chapter 5 includes a monitoring question to track whether forest products provided to 

communities are consistent with the plan’s projections.

Concern Statement: Concern with recent policy of accomplishing forest restoration work by 

paying contractors to do all the work, while the national deficit increases and budgets 

diminish. The Forest needs to provide timber sales with sufficient product, quality and value 

so operators can do forest restoration work while making a profit and in so doing provide 

stumpage income to the Government. Eliminating certain size classes of timber from 

consideration needs to be modified in order to establish multiproduct sales that will 

accomplish restoration. Permit cutting (including sanitation cuts) of any size material or 

trees necessary to manage for desired stand conditions (e.g., stand densities, fuel loading, 

species composition, etc.). (98.15, 98.17)

Response: The plan would generally allow projects to remove live or dead trees of any size, 

species, or condition as needed to move the project area toward the plan’s desired conditions as 

long as the project is consistent with the other plan decisions and site specific considerations 

during National Environmental Policy Act (NEPA) analyses.

Modeling analysis for alternative B (the plan) described in the EIS and resulting harvest volumes 

do include removing varying numbers of trees of all sizes and species on most (but not all) 

cutting treatment acres. During project-level analysis, the interdisciplinary team would be tasked 

with disclosing the need to remove particular trees of certain sizes, species, or conditions on 

certain sites, in balance with retaining enough of the same tree sizes/species needed to be 
Appendix A

736 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

consistent with the plan and other legal requirements for wildlife habitat, watershed stability, 

visual quality, and so forth.

The plan neither directs nor restricts the Apache-Sitgreaves NFs from using any particular type of 

contract or timber sale as the means of project-specific implementation. Managers of each site 

specific project would have the flexibility to choose the most efficient, cost-effective contract 

design to accomplish restoration quickly and in-step with market demands/conditions at the time.

Multiproduct sales are just one of many methods or tools that could be used to treat toward 

desired conditions while also offering wood products as stumpage for sale. 

Livestock Grazing

Concern Statement: Disclose scientific controversy related to the statement "Livestock 

grazing and associated activities contribute to healthy, diverse plant communities, 

satisfactory soils, and wildlife habitat" (proposed plan p. 95). Concern is there is no science 

that says livestock grazing 'contributes' to satisfactory soils and virtually every current 

study acknowledges that livestock degrade diverse plant communities and wildlife habitat. 

(127.44, 132.9, 132.27)

Response: We have edited the desired condition to state:

“Livestock grazing and associated activities occur such that healthy, diverse plant 

communities, satisfactory condition soils, and wildlife habitat are maintained or 

improved.”

Concern Statement: Explain the statement "Also, it would not allow the attainment of the 

desired condition for livestock grazing to contribute to the social, economic, and cultural 

diversity and stability of rural communities" (DEIS p. 15). Concern how these 

intrinsic/romantic statements of benefit off-set the negative impacts of nonnative herbivores. 

(132.8)

Response: Page 15 of the DEIS describes an alternative with no livestock grazing; however, it 

was not considered in detail (see the “Alternatives Considered but Eliminated from Detailed 

Study” section in chapter 2). An alternative with no livestock grazing would not meet legal 

direction of the National Forest Management Act or Multiple Use–Sustained Yield Act which 

direct that forests will be managed using multiple use, sustained yield principles. In addition, as 

mentioned in the concern statement, an alternative with no livestock grazing would not contribute 

to the plan desired condition,

“Livestock grazing contributes to the social, economic, and cultural diversity and 

stability of rural communities.”

The plan manages herbivory with a focus on balancing available forage, as described in the 

“Livestock Grazing” section desired condition,

“Livestock grazing is in balance with available forage (i.e., grazing and browsing by 

authorized livestock, wild horses, and wildlife do not exceed available forage production 

within established use levels).”
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 737

The management approach for livestock grazing as described in chapter 2 of the plan is to 

improve or maintain the health of rangelands. The plan contains desired conditions, standards, 

and guidelines to manage livestock grazing. The plan is designed to manage for ecological 

desired conditions, as well as social and economic desired conditions (including uses such as 

livestock grazing, harvest of forest products, and recreation).

Achievement of desired conditions would occur through completion of site specific National 

Environmental Policy Act (NEPA) environmental analysis, assessments, and decisions and 

updating allotment management plans for individual grazing allotments that take into account the 

desired conditions. The “Socioeconomic Resources” section in chapter 3 of the EIS analyses 

social and economic environmental consequences and takes into account the livestock grazing 

program area.

Concern Statement: Modify Livestock Grazing Desired Conditions (proposed plan p. 95) 

"Livestock grazing is in balance with available forage (i.e., grazing and browsing by 

authorized and unauthorized livestock, wild horses, feral horses and hogs, and wildlife do 

not exceed available forage production within established use levels)" (101.75)

Response: The desired condition was not modified. The intent of this desired condition is to 

manage allowable use levels for livestock authorized under a permit, wild horses, and wildlife. A 

definition for feral horses was added to the glossary of the plan. Feral hogs fall under the 

definition for unauthorized livestock. Unauthorized livestock and feral horses will be addressed 

through the National Environmental Policy Act (NEPA) process for the completion of the Heber 

Wild Horse Territory Management Plan.

Concern Statement: Modify Livestock Grazing Desired Conditions (proposed plan p. 95). 

Add "Livestock Grazing does not negatively affect wildlife habitat and populations." There 

is a similar desired condition under Managed Recreation on page 69. (101.76)

Response: No additions to livestock grazing desired conditions were made based on this 

comment. There is already a desired condition under the “Livestock Grazing” section in chapter 2 

that states, 

“Livestock grazing and associated activities contribute to healthy, diverse plant 

communities, satisfactory condition soils, and wildlife habitat.” 

In addition, there are numerous desired conditions, standards, and guidelines in chapter 2 that will 

guide future project design to protect wildlife habitat and species. For example, the “Overall 

Ecosystem Health” section contains the desired condition, 

“Ecological conditions for habitat quality, distribution, and abundance contribute to selfsustaining populations of native and desirable nonnative plants and animals that are 

healthy, well distributed, connected, and genetically diverse. Conditions provide for the 

life history, distribution, and natural population fluctuations of the species within the 

capability of the landscape.” 
Appendix A

738 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Explain how forest restoration that opens canopies will be expected to 

produce additional forage to a degree that would decrease livestock use in riparian areas 

(DEIS p. 89). (112.42)

Response: This is described under the “Woody Species Reduction” header in the “Livestock 

Grazing” section in chapter 3 of the EIS. It states, 

“By removing trees in woodlands and grasslands, the resulting open canopy would 

promote understory herbaceous plant growth. The understory vegetation would benefit 

from reduced competition with trees and would increase in vigor, expand its basal and 

canopy cover, and deposit seeds that could sprout into new plants and result in improved 

forage conditions and ground cover.”

The increase in forage would improve livestock distribution in pastures reducing impacts on use 

on other areas.

“Riparian area and wetland protection strategies should be integrated with upland 

management strategies. The health of the riparian and wetland ecosystems, receiving 

waterbody quality, and stream base flow levels are often dependent on the use, 

management and condition of adjacent uplands. Proper management of uplands can 

reduce grazing pressure on riparian areas and also increase forage productivity due to 

increased water table height and stream base flow. Increased forage productivity and 

overall upland health can result in increased economic benefits to the landowner or 

grazing management entity” (EPA, 2003).

There are numerous research articles, some in Arizona, that have identified relationships between 

forest canopy or basal area and forage production for forest and woodland ecosystems (e.g.,

Jameson, 1967; Thill et al., 1983). Current conditions as described in the EIS indicate that 

ponderosa pine, piñon-juniper, Madrean pine-oak, and dry mixed conifer potential natural 

vegetation types (PNVTs) have closed canopies; desired conditions are for more open canopies.

The potential acreage available for restoration treatment is large. Great Basin and semi-desert 

grasslands have also been found to have canopy cover well in excess of desired conditions. As 

these acreages are treated mechanically or by prescribed fire, forage production would increase.

There has been forage monitoring within the Rodeo-Chediski Fire burned area, which shows 

large increases in forage as compared to pre-fire conditions. Monitoring forage in mechanically 

treated areas have also shown increases in available forage.

Concern Statement: Obtain soil, riparian, and vegetation information, particularly with 

respect to livestock grazing, to substantiate claims that areas will improve with 

implementation of the plan. (127.37)

Response: The plan contains guidance to improve or maintain the health of rangelands. The 

affected environment of and potential environmental consequences to soil, riparian areas, and 

vegetation are discussed in those respective sections in chapter 3 of the EIS. The EIS describes 

potential indirect effects of grazing based on the management guidance brought forward in the 

plan. There are other plan documents that describe in detail potential causes of current conditions, 

such as the “Comprehensive Evaluation Report” (Forest Service, 2008a).and the “Ecological 

Sustainability Report” (Forest Service, 2008c).
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 739

The plan provides guidance in the form of desired conditions, standards, and guidelines to 

protect, maintain, and improve soil, riparian areas, and vegetation conditions; it is at the projectlevel where site specific existing conditions are compared to desired conditions along with social 

and economic issues. Direct effects of grazing are tied to project-level allotment management, 

where site specific mitigation is developed and implemented and monitoring plans to trigger 

adaptive management are developed.

The monitoring strategy and questions presented in chapter 5 of the plan would help determine 

the effects of resource management activities and movement toward desired conditions and 

objectives identified in the plan.

Concern Statement: Consider the anticipated continuation of livestock grazing and its 

contribution to climate change. Disclose effects from herbivory by nonnative species in both 

wet as well as drought periods. (132.21, 132.23, 26.162, 26.85)

Response: The potential environmental consequences of climate change are discussed in 

appendix A (“Climate Change Trends and Apache-Sitgreaves NFs Land Management Planning”) 

of the plan and in the “Livestock Grazing” section in chapter 3 of the EIS. Livestock grazing 

should have no measurable effect on air quality, but it could contribute to the risk of invasive 

plant infestation and spread which is addressed in the standards and guidelines under the invasive 

species section in chapter 2 of the plan.

Concern Statement: Address the impacts of livestock grazing including: soil productivity, 

water quantity and quality, soil stability, forest fires, and invasive or nonnative species. 

(127.40, 132.17, 132.22)

Response: Potential impacts of livestock grazing are described in the EIS within the “Soils,”

“Water Resources,” “Riparian Areas,” “Fisheries,” “Wildlife and Rare Plants,” and “Invasive 

Species” in chapter 3. Since the plan does not include project and activity decisions, it is not 

appropriate to identify direct impacts. Analysis of site specific impacts would be completed later

during the National Environmental Policy Act (NEPA) process, after specific proposals are made 

and there is additional opportunity for public involvement. 

The plan addresses potential impacts of livestock grazing. For example, the standards and 

guidelines in chapter 2 have been developed to minimize long and short term impacts to soil and 

water resources, and reduce the potential for introduction or spread of invasive or nonnative

species. The “Landscape Scale Disturbance Events” section of the plan provides direction to 

protect existing resources and facilitate recovery of soil and vegetation following large fires. In 

addition as mentioned in the management approaches for the “Livestock Grazing” section:

“Forest managers work with permittees to adjust timing, intensity, and frequency of 

livestock grazing to respond to changing resource conditions. Livestock and associated 

developments are managed to minimize impacts to forest resources, including cultural 

resources, native plant and animal species, wetlands, and riparian areas.”
Appendix A

740 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Take a hard look at the effects of foreseeable range improvements to 

the environment. Propose standards and guidelines to limit their impact, quantify the 

financial cost to taxpayers that may result, and specify any source of appropriated funds 

that the Forest Service intends to use to pay for them. (26.87)

Response: The effects of range developments upon the environment and measures to reduce the 

potential effects are addressed individually at the project-level environmental analysis. The costs 

of those developments and sources of funding would also be determined at the project-level. 

There are often multiple opportunities to fund range structural developments through other 

Federal programs or wildlife groups such as the Arizona Elk Society, Rocky Mountain Elk 

Foundation, Mule Deer Foundation, etc., the quantification of financial costs to taxpayers and 

specification of funding sources to pay for them is beyond the scope of the plan and plan revision 

process.

The plan contains direction to minimize the impacts of range developments, including the 

following desired condition and standards and guidelines: 

“Range developments for livestock minimize impacts to wildlife and blend with the 

natural environment,” (Desired Condition)

“New or reconstructed fencing shall allow for wildlife passage, except where specifically 

intended to exclude wildlife (e.g., elk fencing).” (Standard)

“New livestock watering facilities shall be designed to allow wildlife access and 

escape.”(Standard)

“During maintenance of existing watering facilities, escape ramps that are ineffective or 

missing should be replaced.”(Guideline)

“New livestock troughs, tanks, and holding facilities should be located out of riparian 

areas to reduce concentration of livestock in these areas. Existing facilities in riparian 

areas should be modified, relocated, or removed where their presence is determined to 

inhibit movement toward desired riparian or aquatic conditions.”(Guideline)

“New range developments should be located to minimize impacts to scenic resources and 

reduce the potential for vandalism and livestock-vehicle conflicts. Range developments 

should be designed in consideration of public safety, especially in areas of concentrated 

recreation use.” (Guideline)

“Constructed features should be maintained to support the purpose(s) for which they 

were built. Constructed features should be removed when no longer needed.” (Guideline)

These plan decisions are located in the “Livestock Grazing” section of the plan in chapter 2.

Concern Statement: Explain how the Forest Service can improve soil conditions while still 

permitting herbivory by nonnative species both livestock and elk grazing. (132.51, 132.61)

Response: Potential impacts of herbivory by nonnative species (i.e., livestock grazing, elk 

grazing) to ecosystems and native wildlife species were considered during development of the 

plan. These impacts are disclosed in the “Soils” section in chapter 3 of the EIS. This section 

concludes that site specific best management practices (BMPs) and soil and water conservation 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 741

practices (SWCPs) would provide protection from the effects of grazing and are prescribed in 

project-level analysis.

The plan provides guidance to maintain or move soil conditions to a satisfactory condition (see 

the “Soils” section of the plan in chapter 2) and direction to maintain adequate ground cover (see 

the “All PNVTs” section). The plan includes standard guidelines to specifically manage livestock 

grazing activities across the forests (see the “Livestock Grazing” section). This guidance allows 

management flexibility to adapt to changing conditions, including vegetation responses to 

herbivory, drought and wildfire. The plan also includes additional guidelines that protect riparian 

areas and vegetation from livestock damage.

Concern Statement: Integrate the scientific research and implement the science-based 

recommendations developed by rangelands resources management peer-reviewed expert 

scientists such as Allan Savory of the Savory Institute; Steve Rich of the Rangeland 

Restoration Academy; Eric Schwennesen of Resource Management International; Dr. 

Lamar Smith, Associate Professor Emeritus at the University of Arizona; Dr. Jerry 

Holechek, Professor at New Mexico State University; and Dr. J. Wayne Burkhardt, 

Professor Emeritus at University of Nevada, Reno. Also include information from the 

National Riparian Team. (40.3, 139.10, 131.21, 161.11)

Response: The National Riparian Services Team and Dr. Holechek are cited in the EIS. Scientific 

information from numerous authors, universities, research facilities, and State and Federal 

publications has been considered in the development of the plan (e.g., Arizona Game and Fish

Department, National Resource Conservation Service, University of Arizona, Society of Range 

Management). Literature citations for both the plan and EIS are listed in the “References” chapter 

of each document. Science-based recommendations have been implemented throughout the plan.

The commenters did not list specific literature to be considered.

Concern Statement: The statement that available rangeland may vary by alternative must 

be clarified as to its meaning and how it varies from one alternative to another. (108.223)

Response: The plan and the EIS do not use the term “available rangeland.” The amount of land 

suitable for livestock grazing is described for each alternative in the “Livestock Grazing” section 

in chapter 3 of the EIS. This amount would vary slightly between the action alternatives 

(alternatives B, C, and D) based on the number of recommended and designated research natural 

areas (RNAs). Livestock grazing is considered not suitable in these areas. The following is a list 

of the acres and percent of National Forest System land suitable for livestock grazing by 

alternative:

• Alternative A – 1,931,951 acres suitable for livestock grazing or approximately 96 

percent of NFS lands on the Apache-Sitgreaves NFs.

• Alternative B – 1,901,512 acres suitable for livestock grazing or approximately 94 

percent of NFS lands on the Apache-Sitgreaves NFs.

• Alternative C – 1,901512 acres suitable for livestock grazing or approximately 94 percent 

of NFS lands on the Apache-Sitgreaves NFs.

• Alternative D – 1,903,116 acres suitable for livestock grazing or approximately 94 

percent of NFS lands on the Apache-Sitgreaves NFs.

The livestock grazing suitability analysis is described in more detail in appendix B (“Description 

of the Analysis Process”) of the EIS.
Appendix A

742 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Support for establishing forage reserves as opportunities arise 

(proposed plan p. 96). (101.26)

Concern Statement: The establishment of forage reserves is not necessary (proposed plan p. 

96). (131.15, 102.18, 105.9)

Concern Statement: Explain how forage reserves would be managed (e.g., how the reserves 

will be selected, who will have access to them, who will do the maintenance on the fences 

and waters) (proposed plan p. 96). (102.60, 138.47, 108.26, 112.22, 30.10)

Response: Forage reserves were considered in each of the action alternatives (alternatives B, C, 

and D) in the DEIS. Alternative A considered no forage reserves. Based on concerns regarding 

maintenance of rangeland improvements, associated economics, and impacts to wildlife the plan

objective to establish forage reserves on each ranger district has been removed. However, the plan 

would not preclude establishing forage reserves as opportunities arise.

Concern Statement: Include livestock grazing standards that identify how desired 

conditions for grasslands and other PNVTs would be met. (112.23)

Response: The proposed plan contained a standard in the “Grasslands” section in chapter 2 that 

related to vegetation similarity as compared to TES potential. After reviewing comments 

received, this standard was determined to apply to all vegetation and was rewritten and moved to 

the standards for the “All PNVTs” section. This standard states that,

“Across the planning unit, within each PNVT, vegetation management activities shall be 

designed to maintain or move plant composition towards a moderate to high plant 

community similarity8 as compared to site potential.” 

This standard would apply to livestock grazing and other management activities that may affect 

plant composition. The concern is addressed through this standard; no additional standards have 

been added to the plan based on this comment.

Concern Statement: There is a need for livestock grazing standards to address the degraded 

condition of riparian areas. (26.62)

Response: The plan contains desired conditions, objectives, and guidelines specifically designed 

to address the degraded condition of riparian areas and improve their condition (see the “Riparian

Areas” section in chapter 2 of the plan). In particular this section contains six guidelines to 

prevent resource damage or degradation and promote maintenance or improvement of riparian 

conditions that apply to all projects and activities. In addition, the “Livestock Grazing” section 

provides additional guidelines to protect forest resources, including three that specially address 

protection of riparian areas. The concern is addressed through plan guidelines and projects and 

activities must be consistent with guidelines; no additional standards have been added to the plan 

based on this comment. 

 8 Moderate similarity to the desired plant community begins at 34 percent; high similarity to the desired plant 

community begins at 67 percent. Similarity is described in FSH 2090.11 (1.47a - Ecological Status). Current 

methodology for estimating similarity is found in the Region 3 Rangeland Analysis and Management Training Guide, 

July 1999 (revised November 2013).
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 743

Concern Statement: Modify Livestock Grazing Standard (proposed plan p. 96) "New or 

reconstructed fencing shall allow for wildlife passage, except where specifically intended to 

exclude wildlife (e.g. elk). Construction of new fences parallel to existing .fences shall not be 

allowed unless there is concurrent removal of the existing unneeded fence."” (101.77)

Response: No changes have been made to this standard. This comment is partially addressed by 

the guideline in the “Livestock Grazing” section in chapter 2 of the plan, 

“Constructed features should be maintained to support the purpose(s) for which they 

were built. Constructed features should be removed when no longer needed.” 

An additional guideline within this section, addresses range developments and impacts to scenic 

resources and public safety. It is further addressed under the management approaches for the

“Livestock Grazing” section where it states,

“Livestock and associated developments are managed to minimize impacts to forest 

resources, including cultural resources, native plant and animal species, wetlands, and 

riparian areas.” 

Concern Statement: Delete or modify the Livestock Grazing guideline "To prevent resource 

damage, trailing of livestock should not occur along riparian areas" (proposed plan p. 96). 

Concern that it is not attainable because there are times when it is necessary to move 

livestock through these areas. (121.9, 123.11, 105.20, 102.48, 131.16)

Response: This guideline was modified and occurs as follows, 

“To prevent resource damage, (e.g., stream banks) and disturbance to federally listed and 

sensitive wildlife species, trailing of livestock should not occur along riparian areas. 

Where no alternative route is available, approval may be granted where effective 

mitigation measures are implemented (e.g., timing of trailing, number of livestock trailed 

at one time).”

Concern Statement: Mention other methods to separate domestic sheep from wild sheep to 

preclude the introduction of lethal diseases such as purchase and retirement of existing 

sheep allotments or conversion of these allotments to other types of use such as cattle 

operations. (109.21)

Response: As noted under management approaches for the “Wildlife and Rare Plants” section in 

chapter 2 of the plan, efforts to help prevent disease transmission among domestic and wild sheep 

are determined at the site specific project analysis level. Although changes in class of livestock or 

removal of livestock are outside of the scope of the plan, some additional methods have been 

added to this section as examples.

Concern Statement: Adopt the recommendation that 9- to 14-mile wide buffer zones be 

established between bighorn sheep habitat and domestic sheep grazing (Western 

Association of Fish and Wildlife Agencies 2010). (112.24)

Response: As noted in the cited document, buffers may or may not be effective or practical. As 

noted in the response above, the site specific project or activity analyses would determine the best 

methods to help prevent disease transmission between domestic and wild sheep under each 

situation. Therefore a designated buffer zone has not been added to the plan.
Appendix A

744 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Concern Statement: Modify Livestock Grazing Guideline (proposed plan p. 96) "Efforts 

(e.g. temporary fencing, increased herding, herding dogs) should be made to prevent 

transfer of disease from domestic sheep and goats to bighorn sheep wherever bighorn sheep 

occur. Permit conversions to domestic sheep or goats should not be allowed in areas 

adjacent to or inhabited by bighorn sheep or areas identified by the Arizona Game and Fish 

Department for bighorn sheep reintroductions.” (101.79)

Response: The phrase “adjacent to or” has been added to this guideline. However, how close 

“adjacent to” might be would be determined on a site specific basis when permit conversions are 

considered. The Arizona Game and Fish Department would be consulted on any such permit 

conversions as a normal course of action so the last phrase is not necessary.

Concern Statement: Remove Livestock Grazing guideline “To minimize potential resource 

impacts from livestock, salt or nutritional supplements should not be placed within a 

quarter of a mile of any riparian area or water source ...” (proposed plan 96). Salt is used as 

a method to move cattle and treat areas; it is addressed in the annual operating instructions 

(AOI). (112.26, 121.8)

Response: The guideline has not been removed nor has it been modified to allow placement of 

salt or supplement blocks near water resources. As described in chapter 1 of the plan, guidelines 

must be followed but they may be modified if the intent of the guideline is followed. A plan 

amendment would not be required as long as the project contributes to the maintenance or 

attainment of the relevant desired conditions and objectives. Therefore, if the project or activity 

can be designed to minimize resource impacts from the salt or supplements and meet the relevant 

desired conditions and objectives, placement of salt or supplement blocks near water could occur.

Concern Statement: Modify Livestock Grazing guidelines "During maintenance of existing 

watering facilities, escape ramps that are ineffective or missing should be replaced" and 

"New livestock troughs, tanks, and holding facilities should be located out of riparian areas 

to prevent concentration of livestock in these areas. Existing facilities in riparian areas 

should be modified, relocated, or removed where their presence is determined to inhibit 

movement toward desired riparian or aquatic conditions" (proposed plan p. 96) to add "to 

occur as partnering process to improve wildlife habitat" and to be flexible because cultural 

and wildlife clearance prevent timely occurrence. (123.6, 148.3, 121.10, 121.6)

Response: These guidelines have not been modified based on this comment. The specific 

methods and timing to conduct clearances and maintain, modify, relocate, or remove 

developments would be determined at the project-level. The Apache-Sitgreaves NFs has existing 

cooperators and partnerships available to help with construction and/or maintenance of structural 

range improvements. 

Concern Statement: Modify the Livestock Grazing guideline "Grazing use on seasonal 

allotments should be timed to the appropriate plant growth stage and soil moisture" 

(proposed plan p. 96) by adding "and riparian areas" after seasonal allotments to allow for 

future riparian grazing if necessary. (121.7)

Response: This guideline has not been modified based on this comment. This recommendation is 

addressed by the updated guideline in the “Livestock Grazing” section in chapter 2 of the plan,
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 745

“Forage, browse, and cover needs of wildlife, authorized livestock, and wild horses 

should be managed in balance with available forage so that plants providing for these 

needs remain at or move toward a healthy, persistent state.” 

The guideline would apply in all vegetation types, including riparian areas. 

Concern Statement: Modify the Livestock Grazing guideline "New range developments 

should be located to minimize impacts ..." (proposed plan p. 97) to include "where possible 

and practical.” (123.12)

Response: This guideline has not been modified based on this comment. The specific methods 

for placement of range developments (e.g., design, location, mitigation measures) would be 

determined at the project-level. 

Concern Statement: Modify Livestock Grazing Guideline (proposed plan p. 96) "New 

livestock watering facilities shall be designed to allow wildlife access and escape. Existing 

livestock watering facilities shall be modified as opportunities arise to allow for wildlife access 

and escape." (101.78)

Response: This guideline has not been modified based on this comment. There is a guideline 

under the “Livestock Grazing” section in chapter 2 of the plan that addresses this concern. The 

guideline states, 

“During maintenance of existing watering facilities, escape ramps that are ineffective or 

missing should be replaced.” 

Concern Statement: In the plan, reference the document "Guide to Rangeland Monitoring

and Assessment" produced by Arizona Grazing Lands Conservation Association. (105.21, 

105.16, 121.11, 131.8, 123.22)

Response: The “Arizona Grazing Lands Association Guide to Rangeland Monitoring and 

Assessment” (Arizona Grazing Lands Conservation Association, 2012), was added to the “Other 

Sources of Information” for livestock grazing section in Appendix D of the plan.

Concern Statement: Eliminate or minimize livestock grazing. (125.10, 94.8, 9.8, 3.2, 23.7, 

21.3, 132.47, 12.2, 80.2, 14.6)

Response: The Apache-Sitgreaves NFs considered a no grazing alternative but did not analyze in 

detail because it would not meet the legal direction of the National Forest Management Act or 

Multiple Use–Sustained Yield Act which direct that forests will be managed using multiple use, 

sustained yield principles (see the “Alternatives Considered but Eliminated from Detailed Study” 

section in chapter 1 of the EIS).

The plan does not specify the actual amount of livestock grazing (stocking) that could occur on 

the forests. The management focus described in chapter 2 of the EIS under “Elements Common to 

All Alternatives,” including the plan, is to “balance livestock grazing with available forage” on 

suitable grazing lands. The amount of land suitable for livestock grazing varies slightly between 

all alternatives. The livestock grazing program has multiple mechanisms to evaluate, review, and 

adapt management as needed to effectively protect resources and respond to changing conditions. 

Stocking decisions (amount of livestock grazing authorized) for specific grazing allotments are 

beyond the scope of the plan. Grazing is authorized through term grazing permits (a long term
Appendix A

746 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

authorization subject to forestwide standards and guidelines), allotment management plans, and 

annual operating instructions. Grazing can be reduced or adjusted in response to any site specific

resources conditions within any grazing allotment. Changes to these authorizations would be 

made through project-level analyses. 

Concern Statement: There is a need for more livestock grazing. (148.5)

Response: The plan does not specify the actual amount of livestock grazing (stocking) that could 

occur on the forests. The management focus described in chapter 2 of the EIS under “Elements 

Common to All Alternatives,” including the plan, is to “balance livestock grazing with available 

forage” on suitable grazing lands. The amount of land suitable for livestock grazing varies 

slightly between all alternatives. The livestock grazing program has multiple mechanisms to 

evaluate, review, and adapt management as needed to effectively protect resources and respond to 

changing conditions. Stocking decisions (amount of livestock grazing authorized) for specific 

grazing allotments are beyond the scope of this analysis. Grazing is authorized through term 

grazing permits (a long term authorization subject to forestwide standards and guidelines), 

allotment management plans, and annual operating instructions. Changes to these authorizations 

would be made through project-level analyses. 

Concern Statement: Explain how the desired condition that grazing is "balanced with 

available forage" will make a difference in the new plan since the 1987 plan had similar 

direction. (122.2)

Response: The plan identifies a “Monitoring Strategy” in chapter 5. The results of this forest 

level monitoring would be evaluated biennially and would describe the progress made towards 

the plan’s desired conditions, including the one stated above.

In addition, livestock grazing allotments on the Apache-Sitgreaves NFs use an adaptive 

management approach to match livestock numbers with forage production. The management 

focus described in chapter 2 of the EIS under elements common to all alternatives is to “balance 

livestock grazing with available forage” on suitable grazing lands. The criteria for the suitability 

of livestock grazing are the same in all action alternatives. The amount of land suitable for 

livestock grazing varies slightly between the action alternatives based on the number of 

recommended research natural areas (RNAs). Stocking decisions (amount of livestock grazing 

authorized) for specific grazing allotments are beyond the scope of this analysis. Grazing is 

authorized through term grazing permits (a long term authorization subject to forestwide 

standards and guidelines), allotment management plans, and annual operating instructions. 

Changes to these authorizations would be made through project-level analyses.

Concern Statement: Explain where in the plan basic grazing considerations are addressed 

(ensuring cattle are not in the same pasture year after year). (122.4)

Response: Considerations for ensuring livestock are not authorized in the same pasture at the 

same time year after year are addressed by the standard in the “All PNVTs” section and 

guidelines in the “Livestock Grazing” section in chapter 2 of the plan.

As mentioned in the management approaches for the “Livestock Grazing” section of the plan in 

chapter 2,
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 747

“Forest managers work with permittees to adjust timing, intensity, and frequency of 

livestock grazing to respond to changing resource conditions.”

Concern Statement: Alternatives should address the effects of grazing: (1) the loss of cold 

season grasses, (2) riparian systems, (3) water developments, (4) capability/suitability, (5) 

the amount of unsatisfactory or impaired lands, and (6) how monitoring has been 

implemented and what it has shown. (127.39, 122.1, 127.38)

Response: The plan contains components to address cool season grasses and other vegetation, 

riparian systems, natural and constructed waters, suitability of livestock grazing, and soils and 

watershed. The EIS analyzes the capability and suitability of livestock grazing (see Chapter 5). It 

also describes current rangeland conditions in the “Vegetation” section in chapter 3.

Under the action alternatives, there are objectives, guidelines, and standards for the maintenance 

of or movement toward desired conditions identified throughout the plan. Under all alternatives, 

grazing can be adjusted through site specific project analysis utilizing an adaptive management 

approach in response to any site specific resource conditions within any grazing allotment. 

Most range-related monitoring is site specific and conducted at the project-level; however, the 

“Monitoring Strategy” presented in chapter 5 in the plan does help to ensure effectiveness of 

grazing management.

Concern Statement: Authorize the voluntary, permanent retirement of grazing allotments 

by permittees for conservation purposes, including endangered species recovery. (132.46)

Response: Allowing permittees to permanently retire their allotments is outside the scope of the 

plan.

Concern Statement: Rangelands resources management needs to be modified to include: (1) 

maximum management flexibility in terms of seasonal use, any use at all, numbers of 

livestock, etc., (2) real time three tier rangelands resources management quantitative 

monitoring, (3) dynamic real time adaptive management allowing the permittees to make 

required management adjustments on their own initiative in response to short term 

variables. (161.12, 161.16)

Response: Stocking decisions (amount of livestock grazing authorized) for specific grazing 

allotments are beyond the scope of the plan. Grazing is authorized through term grazing permits 

(a long term authorization subject to forestwide standards and guidelines), allotment management 

plans, and annual operating instructions. Livestock grazing is managed through an adaptive 

management approach and adjustments in the timing, intensity, duration, and frequency are made 

continuously in relation to short and long term monitoring information. Grazing can be adjusted 

in response to any site specific resources conditions within any grazing allotment.

Concern Statement: The plan should encourage greater opportunity for adaptive 

management suited to the needs of improved resource conditions: i.e. flexibility of timing, 

intensity and duration of grazing periods, use of livestock as a tool for improving previously 

ungrazed and or debilitated areas managed with electric fences to limit the disconnect of 

landscape areas. (138.46)
Appendix A

748 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Response: Chapter 5 (“Monitoring Strategy”) in the plan describes adaptive management and its 

value in allowing the use of alternative solutions to meet desired conditions. Livestock grazing is 

managed through an adaptive management approach and adjustments in the timing, intensity, 

duration, and frequency are made continuously in relation to short and long term monitoring 

information. Under the plan, grazing can be reduced or adjusted in response to any site specific

resources conditions within any grazing allotment.

Minerals and Energy

Concern Statement: The DEIS should add some mention of phosphate mining activity on 

non-forest lands in Navajo County that are adjacent to the Apache-Sitgreaves NFs. (99.39)

Response: The cumulative environmental consequences analysis for mineral resources (see 

“Minerals and Energy” section in chapter 3 of the EIS) is limited to those lands adjacent to the 

Apache-Sitgreaves NFs. The Forest Service is not aware of phosphate mining activity 

immediately adjacent to the forests. There is proposed potash mining that could occur 

approximately 40 to 50 miles from the forests, southeast of Holbrook.

Concern Statement: The guidelines for Minerals and Geology (proposed plan p.98-99) 

should provide guidance related to locatable minerals and recognize the statutory rights of 

those who maintain unpatented mining claims and sites. (151.5)

Response: Regulations governing locatable minerals are found in 36 CFR § 228, Part A. The plan 

does not repeat existing law, policy, or regulation. Locatable minerals are discussed in the 

“Minerals and Energy” section in chapter 3 of the EIS. The Apache-Sitgreaves NFs would work 

with claimants to ensure their actions are consistent with overall plan guidance.

Concern Statement: Recommend deleting the second Minerals and Geology guideline 

because they say the same thing: (1) " Key cultural sites, research natural areas, and 

administrative and recreation sites with an investment in facilities should be withdrawn 

from mineral entry to protect resources and existing infrastructure. Research natural 

areas" or (2) "Administrative sites, high use developed recreation areas, and other areas 

with substantial investment in infrastructure should be withdrawn from mineral entry" 

(proposed plan p.98-99). (99.18)

Response: The last guideline has been removed because it repeats the first guideline (see the 

“Minerals and Geology” section in chapter 2 of the plan).

Concern Statement: The plan should provide guidance for karst and cave management. 

Reference the karst and cave implementation plan. (35.2, 35.3, 35.4, 35.5, 35.1)

Response: The plan is programmatic and provides broad guidance for cave and karst 

management. For example, there are several desired conditions in the “Minerals and Geology” 

section in chapter 2 of the plan specific to caves. A guideline in the “Wildlife and Rare Plants” 

would provide protection for caves and karsts, 

“Rare and unique features (e.g., talus slopes, cliffs, canyon slopes, caves, fens, bogs, 

sinkholes) should be protected to retain their distinctive ecological functions and 

maintain viability of associated species.”
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 749

As mentioned in the management approaches for the “Minerals and Geology” section, cave and 

karst management plans would be developed as needed. The site specific details of cave and karst 

management would be addressed in these separate plans. This site specific plan would be beyond 

the scope of decision to be made in forest planning. 

Forest Service Manual 2300, Chapter 2350, Section 2356 - Cave Management and the 

Memorandum of Understanding between the National Speleological Society and the USDA, 

Forest Service Cave and Karst Management have been added as “Other Sources of Information”

for minerals and geology in Appendix D of the plan. These references would be used as cave and 

karst management plans are developed.

Concern Statement: Karst and cave geologic areas should be identified as a management 

area and have specific management direction. (35.6)

Response: A geological area is a special area that the Forest Service can designate. During initial 

plan revision scoping, including the identification of the “need for change,” the need for 

geological areas was not identified. Because of time and financial constraints an extensive 

inventory for potential special areas, including geologic areas, was not completed (Forest Service, 

2009e). The forests relied on information gathered from previous revision efforts, public scoping, 

and internal sources for the need for change evaluation.

Because geological areas were not identified, no specific management area was created. 

Forestwide desired conditions, standards, and guidelines, including the plan decisions in the 

“Minerals and Geology” section of the plan, would guide management of these lands.

Concern Statement: Correct the Minerals Report, proposed plan, and DEIS to reflect the 

fact that a world class copper deposit is located in the immediate vicinity of the southern 

portion of the forest, that the potential for locatable minerals is extremely high in this area, 

and that the potential for locatable minerals on Apache-Sitgreaves NFs lands may be much 

greater at depth than surface geology would otherwise suggest. (151.1)

Response: The “Background for Minerals and Geology” in chapter 2 of the plan and the 

“Minerals” section in chapter 3 of the EIS have been updated to recognize the copper deposit 

located near the Apache-Sitgreaves NFs’ southern boundary. 

Concern Statement: Update the Minerals Report to properly reflect all unpatented mining 

claims and sites maintained on Apache-Sitgreaves NFs lands as of at least December 6, 2012. 

(151.4, 151.2, 151.3)

Response: The EIS and the “Minerals and Energy Specialist Report” (Forest Service, 2014d)

have been updated to reflect the number of unpatented mining claims and mill sites as of July 

2013.

Socioeconomic Resources

Concern Statement: Provide an economic analysis for recreation, grazing, and wildlife on 

par with what was produced for other functions. (132.28)

Response: The 1982 Planning Rule provisions provide direction for conducting plan revision 

efforts and outline the requirements for economic analysis to include:
Appendix A

750 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Direct and indirect benefits and costs, analyzed in sufficient detail to estimate --

i. the expected real-dollar costs ...

ii. the expected real-dollar value ...

iii. the economic effects of alternatives ...

and

iv. the monetary opportunity costs (changes in present net value) ... 

[from § 219.12(g)(3)]. 

The results of the economic analysis are summarized in the “Socioeconomic Resources” section 

in chapter 3 of the EIS. The economic impact analysis for all program areas, including recreation, 

grazing and wildlife, including methodology and economic models, can be found in the 

“Socioeconomic Resource Report” available on the Apache-Sitgreaves NFs Web site at:

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5411486.pdf

Concern Statement: Provide a detailed accounting of the economic impact of grazing 

including the cost to administer the livestock program. (132.10, 132.26, 132.24)

Response: The “Socioeconomic Resources” section in chapter 3 of the EIS provides a financial 

efficiency analysis for all alternatives, including the plan (alternative B). This analysis takes into 

account the livestock grazing program area. It compares the forest expenditures and revenues 

throughout the life of the plan.

Concern Statement: Provide an assessment of returns to the treasury and costs to the public 

of livestock grazing. Concern is that the Forest Service charges grazing permit holders a 

low fee (subsidy) and returns less than 10 percent of its expenditure for grazing 

management to the U.S. Treasury. (127.33, 26.88)

Response: An assessment of returns to the treasury and costs to the public of livestock grazing is 

beyond the scope of the plan and plan revision process. Grazing fees on public lands are 

determined using a formula established by Congress in the Public Rangelands Improvement Act 

of 1978 and has continued under a presidential Executive Order issued in 1986. 

Concern Statement: The economic analysis needs to include a calculation of the economic 

costs of the constraints imposed on the permittees by the current rangelands resources 

management agency processes that limits the ability of the permittees to manage optimally 

the land and the livestock due to the rigidity of the administrative processes. (161.17)

Response: The effects of administrative processes are beyond the scope of the plan and plan 

revision process. Therefore, they have not been analyzed in the EIS. 

Concern Statement: Concern that the current level of economic contribution of livestock 

grazing, approximately 66 jobs and $713,000 in labor income annually, is only 

approximately half of the approximately 120 jobs and $1.3 million in labor income annually 

that can be supported by the full utilization of the available animal unit months (AUMs) 

(DEIS p. 491). (161.148)

Response: The current economic contribution is based on authorized animal unit months for 

2010 (see the “Socioeconomic Resources” section in chapter 3 of the EIS.) Authorized animal 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 751

unit months fluctuate from year-to-year based on site specific resource conditions, weather, and 

livestock operations. Stocking decisions (amount of livestock grazing authorized) for specific 

grazing allotments are beyond the scope of this analysis. Grazing is authorized through term 

grazing permits (a long term authorization subject to forestwide standards and guidelines), 

allotment management plans, and annual operating instructions. Changes to these authorizations 

would be made through project-level analyses.

Concern Statement: The forest should eliminate livestock grazing and fund counties an 

annual payment of $43,900 to save the tax payers $1,296,000 per year. (132.50)

Response: Elimination of livestock grazing was considered but not analyzed in detail because it 

would not meet the legal direction of the National Forest Management Act or Multiple Use–

Sustained Yield Act which direct that forests will be managed using multiple use, sustained yield 

principles (see the “Alternatives Considered but Eliminated from Detailed Study section in 

chapter 1 of the EIS).

Payments to counties are beyond the scope of the plan and plan revision process. There are no 

legal mechanisms that would allow the forests to directly transfer appropriated Federal monies to 

county governments.

Concern Statement: Consider the economic impact of additional roadless area designations 

and/or roads closure and/or limitation of suitability for future consideration of new 

motorized areas and trails and/or indiscriminate cross-country motorized travel restrictions 

that would further decrease recreation opportunities. (161.152)

Response: The “Socioeconomic Resources” section in chapter 3 of the EIS discloses the 

economic and social consequences of all four alternatives, including the plan. The alternatives 

contain varying amounts of land suitable for future consideration of new motorized areas and 

trails; the environmental consequences are discussed in the “Recreation” section of the EIS. The 

effects of recommended wilderness and inventoried roadless areas are discussed in the 

“Wilderness Resources” and “Inventoried Roadless Areas” sections of the EIS. The plan does not 

designate additional roadless areas; these areas were identified in the Forest Service Roadless 

Area Conservation, Final Environmental Impact Statement, Volume 2, dated November 2000.

More detailed economic analysis would be considered during project-level analysis, including

implementation of the Travel Management Rule (36 CFR §212). 

Concern Statement: Explain why there is no value for hunting and fishing. (132.25)

Response: Specific recreation activities are not analyzed separately. The economic contributions 

from hunting, fishing, and other recreation activities are included under recreation in the 

socioeconomic analysis portion of the “Socioeconomic Resources” section in chapter 3 of the 

EIS.

Additional language that acknowledges the economic contribution of visitors, including those that 

view wildlife, hunt, and fish was added to the background for “Overall Recreation Opportunities”

section of the plan. The background now notes that the forests’ contribution to the local economy 

from the recreation and wildlife areas is approximately 69 percent of the local jobs and 68 percent 

of the local labor income.
Appendix A

752 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Landscape Scale Disturbance Events

Concern Statement: Identify criteria (e.g., size of burn, slope) to be met before using 

nonnative seeds to manage soil erosion post-wildfire. (109.16)

Response: Nonnative persistent plant seeds would not be used. The plan provides direction to 

ensure the persistence of native species including the guideline in the “Soil” section in chapter 2 

of the plan, 

“Locally collected seed should be used where available and cost effective. Seeds should 

be tested to ensure they are free from noxious weeds and invasive nonnative plants at a 

State certified seed testing laboratory before acceptance and mixing.”

The specific methods to address soil post-wildfire would be determined at the project-level. In 

general, annual cereal grains are added to many seed mixes to provide quick and effective ground 

cover. These species grow quickly, and generally do not last more than one or two growing 

seasons, while producing large amounts of mulch to protect the soil, retard overland flow, and 

improve native plant survival. Use of cereal grain in the mix is dependent whether the risk to 

downstream or on-site values of life, property or land productivity outweighs the cost or risk of 

the treatment itself. Great care is taken to ensure nonnative/invasive seed is not included in the 

mix and that treatments are monitored afterwards for unwanted weed and treated if needed.

Concern Statement: Burned but standing forest and single burned snags should be 

managed for natural recovery and not looked to for commercial gain. (5.8, 9.7)

Response: Plan guidelines for large-scale disturbance events primarily focus on restoring the land 

to meet desired conditions in the plan (see the “Landscape Scale Disturbance Events” section in 

chapter 2 of the plan). The desired conditions are integrated and are intended to reflect healthy 

ecological systems as well as social and economic considerations as described in chapter 1 of the 

plan. The desired conditions for forest and woodland communities would not change after largescale disturbances, including severe fire. The plan decisions in the “Landscape Scale Disturbance 

Events” section were developed to protect existing resources and facilitate recovery of soil and 

vegetation components, and assist in attaining desired conditions in areas affected by large-scale 

disturbance, should a site specific proposal be made following the disturbance.

As described in the management approaches for the “Landscape Scale Disturbance Events” 

section, hazard trees may be removed and where there is extensive tree mortality and economic 

value exists, salvage of dead trees may be considered where this contributes to the movement 

toward desired conditions. Deferral of ecological restoration or salvage projects and activities

may also be considered where these are not necessary for recovery.

Concern Statement: Salvage logging should not be equated with ecological restoration or 

forest management objectives other than economically-motivated multiple uses. (26.105)

Response: Salvage logging is not equated with ecological restoration; however, salvage is a tool 

for achieving certain restoration objectives and desired conditions (see the “Vegetation,” “Soil,”

“Watershed,” “Forest Health” and “Forest Products” sections in chapter 3 of the EIS). In some 

cases where excessive pre-fire forest density existed, removal of excessive biomass may be 

necessary to initiate the restoration processes towards desired ecosystem structure and functions. 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 753

Removal of excess biomass may be necessary to facilitate reforestation and survival of natural 

forest regeneration, at levels that are compatible with re-establishment of frequent surface fires. 

Concern Statement: There is a need to remove or reduce livestock grazing post-fire. (122.3, 

127.41, 127.5)

Response: There is a guideline within the “Livestock Grazing” section in chapter 2 of the plan 

that addresses modifying grazing in areas after large disturbances, 

“As areas are mechanically treated or burned, or after large disturbances, timing of 

livestock grazing should be modified as needed, in order to move toward desired 

conditions and to accomplish the objectives for the treatment or disturbed area.”

Concern Statement: Add a drought policy to the plan. Recommend using the Drought 

Monitor from the National Climate Data Center. (132.58)

Response: The plan provides reference to Forest Service Southwestern Region drought policy 

(Forest Service Handbook 2209.13) in the “Other Sources of Information” for livestock grazing

in Appendix D of the plan. The management approaches in the “Livestock Grazing” section of the 

plan has been update to include the following language,

“Because drought is inevitable in the Southwest, livestock grazing management on the 

ASNFs incorporates, as necessary, 1) evaluation of drought conditions, 2) drought 

management relative to vegetation impacts, 3) stocking during and after drought, and 4) 

early and effective communications with all affected parties.”

Concern Statement: Modify Landscape Scale Disturbance Events Guideline (proposed plan 

p.66) "Erosion control mitigation features should be implemented to protect significant 

resource values and infrastructure such as stream channels, roads, structures, threatened 

and endangered species, and cultural resources. The use of nonnative grass seed for aerial 

seeding should be discouraged." Concern with the use of "non- persistent" nonnative grass 

seed to mitigate wildfire impacts and possible unintended consequences such as 

concentrating elk within seeded locations, discouraging normal daily and seasonal 

movement patterns, outcompeting native forbs and grasses, and impacting aspen 

regeneration. (101.67)

Response: The plan provides direction to ensure the persistence of native species including the 

guideline in the “Soil” section in chapter 2 of the plan, 

“Locally collected seed should be used where available and cost effective. Seeds should 

be tested to ensure they are free from noxious weeds and invasive nonnative plants at a 

State certified seed testing laboratory before acceptance and mixing.”

The specific methods to address soil post-wildfire would be determined at the project-level. 

Seeding with non-persistent annual or native perennial plants is a tool the forests would continue 

to utilize to protect watershed values at risk. The decision to seed is determined at the forest level 

by the forest supervisor and is based on recommendations from the burned area emergency 

response (BAER) assessment team. 

The Forest Service considers the concentration of elk within seeded areas a positive outcome. 

Observations made post-fire have shown that riparian areas and meadows (which contain 
Appendix A

754 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

sprouting vegetation and additional moisture) revegetate sooner than other areas, and 

consequently, draw wildlife to them. The result is over utilization and retarded recovery. 

Therefore, it is beneficial to draw wildlife to other areas because these riparian areas are the last 

line of defense for filtering ash and sediment after a wildfire. Cattle are generally removed or 

restricted from these areas after a fire, so effects of grazers are from wildlife. 

Research has shown mixed results on effectiveness of seeding, some areas were successful, and 

some were not as far as providing enough groundcover to reduce soil erosion. Preliminary results 

on a research study within the Wallow Fire show no statistical difference between native species 

recovery of seeded and unseeded plots (Robichaud et al., 2014) with small but not statistically 

different increases in ground cover. Seeding under mulch was vastly different in effective ground 

cover compared to untreated and is reflected in many applications across the west (Robichaud et 

al., 2010).

Conservation Education

Concern Statement: Delete the statement in Conservation Education background "There is 

a clear lack of public understanding regarding forest issues, laws, consequences of forest 

user behavior, and forest management actions" (proposed plan p. 85). (152.11)

Response: The statement was modified to read,

“There is a need for the public to understand forest issues, laws, consequences of forest 

user behavior, and forest management actions.”

Concern Statement: Modify the last sentence in the Conservation Education management 

approach (proposed plan p. 86) to read: "The forests place an emphasis on providing 

interpretive programs, especially through its visitor centers (Big Lake and Mogollon Rim) 

and front line desk at Ranger Districts and Supervisor's Office and development of 

education tools (e.g., invasive species prevention)." (99.6)

Response: This proposed plan sentence was not modified, 

“The forests place an emphasis on providing interpretive programs, especially through its 

visitor centers (Big Lake and Mogollon Rim) and development of education tools (e.g., 

invasive species prevention).”

Although the forests’ front line desk personnel provide information and other services to the 

public, they generally do not provide interpretive programs at the front desk.

Overall Ecosystem Health

Concern Statement: Clarify the Overall Ecosystem Health desired condition "Habitat 

quality, distribution, and abundance exist to support the recovery of federally listed species

and the continued existence of all native and desirable nonnative species" (proposed plan 

p.17). Explain the justification for this and discuss instances when such habitat never 

occurred on the site or is incapable of being produced now. (108.108)

Response: The implementing regulations (1982 Planning Rule Section 219.19) of the National 

Forest Management Act require that,
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 755

“Fish and wildlife habitat shall be managed to maintain viable populations of existing 

native and desired nonnative vertebrate species in the planning area.” 

This desired condition contributes to meeting that requirement as well as requirements of the 

Endangered Species Act to support the recovery of federally listed species.

As noted in chapter 1 of the plan, plan decisions apply to projects or activities where site 

conditions provide an inherent capability to meet those plan decisions.

Concern Statement: Clarify terms used in the Overall Ecosystem Health section of the plan, 

including ecotone, high geomorphic, hydrologic, biotic integrity, ecological maintenance, 

and natural potential condition. (108.174, 108.29, 102.52, 108.214, 108.237)

Response: These terms have now been defined and are found in the plan’s glossary.

Concern Statement: Concern that the Overall Ecosystem Health background statement 

"...ecosystems were considered to be resilient" (proposed plan p.15) implies that ranchers, 

settlers and farmers were the inherent cause of deviation from desired conditions. (138.6)

Response: There are many documented causes for deviation from desired conditions. The 

premise of the plan is to acknowledge current conditions and work towards desired conditions.

Concern Statement: Correct the Overall Ecosystem Health desired condition "Natural 

ecological processes allow for a shifting of plant communities ...plant communities and the 

variety within the communities are resilient to disturbances" (proposed plan p. 17). 

Statement is contradictory, shifting means changing and resilient means going back to the 

same. (138.7)

Response: The desired condition statement has been rewritten to provide clarity. The desired 

condition statement now reads

“Natural ecological cycles (i.e., hydrologic, energy, nutrient) facilitate shifting of plant 

communities, structure, and ages across the landscape. Ecotone shifts are influenced at 

both the landscape and watershed scale by ecological processes. The mosaic of plant 

communities and the variety within the communities are resilient to disturbances.” 

Shifting in this instance refers to moving from one vegetation state to another vegetation state.

With both natural and man caused disturbance, the state (which in this case is determined by 

overstory vegetation size class, dominant species, and canopy cover class) can change. The ability 

of the site to move from one state to another in a natural progression or pathway can be 

considered its resiliency. As an example, a fire removes the overstory vegetation (trees) in an area 

with large trees, closed canopy forest. As a result, the state has changed to an open, grass/forb 

state. As tree seedlings establish, the state changes to an open canopy, seedling/sapling state. As 

trees grow, it then changes to an open or closed mid-sized tree state, and finally to an open or 

closed large tree state. There are many pathways on how the vegetation state changes. Some, such 

as high burn severity fire, may lead to a non-natural state, such as found on areas within the 

Rodeo-Chediski and Wallow Fires, where bare soil dominates the burned areas for years. Grazing 

by cattle and wildlife, invasive plant infestations, and commercial tree harvest can affect the 

progression as well.
Appendix A

756 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Management Areas

Concern Statement: Prescribed burning or natural fires need to be repeated not more than 

every 10 years. Critical locations could be treated more frequently. (98.12)

Response: Wildfires cannot be predicted or put onto a regular maintenance cycle further defining 

which of these could be used to achieve desired results. However, the plan describes desired 

conditions based on natural fire regimes, including natural return intervals for fires, by potential 

natural vegetation type (PNVT). The exact or desired maintenance cycle for a particular piece of 

ground would be recommended in project-level planning and during the development of project 

burn plans for prescribed fires.

Concern Statement: Increase the treatment areas around the Community-Forest Intermix

Management Area from half-mile to one- or two-miles. (98.14)

Response: The size of the Community-Forest Intermix Management Area has not been increased. 

The interdisciplinary team considered this option but determined the desired conditions and future 

treatments adjacent to the Community-Forest Intermix Management Area would provide for a 

resilient landscape and further protection from uncharacteristic wildfires for communities 

themselves. The plan’s landscape scale treatment approach is to create a mosaic pattern to reduce 

fire intensity and long range spotting potential which would also further reduce hazards to 

communities. The actual Community-Forest Intermix Management Area is designed to provide 

firefighters an area where they can aggressively defend communities based on expected lower fire 

behavior.

Concern Statement: Modify Community-Forest Intermix Desired Condition (proposed plan 

p. 106) "Native grasses, forbs, shrubs, and litter (i.e., fine fuels) are abundant enough to 

maintain and support natural fire regimes, protect soils, provide for wildlife needs, and 

support water infiltration." (101.80)

Response: This desired condition has not been modified in the plan. The interdisciplinary team 

reviewed the comment and felt there was no need to add the additional qualifier (provide for 

wildlife needs). The plan provides for species viability and includes other specific plan decisions 

that provide for wildlife needs, including the following found in the “Wildlife and Rare Plants” 

section:

“Modifications, mitigations, or other measures should be incorporated to reduce 

negative impacts to plants, animals, and their habitats and to help provide for species 

needs, consistent with project or activity objectives.”

“Cool and/or dense vegetation should be provided for species needing these habitat 

components (e.g., Goodding’s onion, black bear, White Mountains chipmunk, western 

yellow-billed cuckoo).”

Concern Statement: The plan should allow for utilities to have motorized access to the 

energy corridors as well as within the energy corridor. (128.3, 101.81, 101.89)

Response: This guideline to manage energy corridors for nonmotorized travel has been modified 

to allow motorized equipment for operations and maintenance, 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 757

“Energy corridors should be managed as nonmotorized areas to avoid conflicts with 

corridor operations and maintenance needs, although operations and maintenance 

activities may use motorized equipment.” 

This is located in the “Energy Corridor” section in chapter 3 of the plan.

Concern Statement: Include National Energy Regulatory Commission compliance 

requirements for vegetation clearing within and adjacent to energy corridors and the 2010 

Memorandum of Understanding providing for the coordination among federal agency 

reviews of electric transmission facilities in the plan. (128.5, 128.6)

Response: The following statement has been added to the management approaches for the

“Energy Corridor” section of the plan in chapter 3:

“Energy utility companies also comply with maintenance standards enforced by the 

North American Electric Reliability Corporation.” 

The 2010 Memorandum of Understanding has been added to the “Other Sources of Information” 

for energy corridor section of Appendix D in the plan.

Concern Statement: The Carr Lake and Palomino areas, in addition to the eight existing 

wildlife quiet areas (WQAs), should be designated as wildlife quiet areas. (101.3, 101.5)

Response: Carr Lake and Palomino Wildlife Quiet Areas (WQAs) were proposed and analyzed 

under alternative D in the EIS, but they were not included in the other alternatives in order to 

provide a range of WQAs across alternatives.

Concern Statement: The commenter supports the designation of Cottonwood and Bear 

Springs areas as wildlife quiet areas. (101.6)

Response: The plan provides guidance for Bear Springs and Cottonwood Seep, in addition to 

eight other areas, in the “Wildlife Quiet Areas” section of the plan in chapter 3. 

The Cottonwood Seep and Bear Springs Wildlife Quiet Areas were both proposed and analyzed 

under alternatives B and D, but they were not included under alternatives A and C of the EIS.

Concern Statement: The plan (e.g., need for Wildlife Quiet Area Management Area) should 

be based on actual data concerning wildlife populations on the forest and wildlife 

interaction with motorized vehicles. (108.207, 81.15)

Response: The Wildlife Quiet Area Management Area was established not on actual wildlife 

population numbers but on the need for some habitat areas across the landscape that are free of 

motorized vehicle impacts (disturbance/stress). The “Wildlife Quiet Areas (WQAs) and Habitat 

Linkages Report” (Forest Service, 2014m) located in the plan set of documents and on the forests’ 

Web site at http://www.fs.usda.gov/main/asnf/landmanagement/planning details the need for and 

history of the establishment of WQAs and subsequent changes and results of implementation.

Since established, the need for and effectiveness of WQAs have been evaluated a number of 

times. Some findings based on research from the Arizona Game and Fish Department (AZGFD)

and observations by Apache-Sitgreaves NFs and AZGFD biologists and wildlife managers 

include: (1) more acres of available and suitable habitat being used, (2) improved wildlife 
Appendix A

758 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

population recruitment (more effective habitat), (3) improved nature viewing and greater chance 

of observing and photographing wildlife, and (4) increased quality of the non-motorized hunt 

experience and, likely, hunter success (based on ongoing hunter input). Forest and State biologists

believe these benefits are likely the function of: (1) wildlife knowledge of, and site fidelity to, 

long term security (core habitat) areas, (2) improved (more natural) predator prey functions 

(reduced human related disturbance to both predator and prey), and (3) secure areas helping to 

provide habitat linkages across open, heavily human-utilized and managed areas.

Concern Statement: There is a concern that the existing Sitgreaves' wildlife quiet areas 

(DEIS p. 305-306) are “few and greatly spaced." (162.159)

Response: Currently, on the Sitgreaves NF distances between wildlife quiet areas (WQAs) are up 

to 50 miles. For this reason two additional WQAs were proposed and analyzed for the Sitgreaves 

NF under alternatives B and D in the EIS. These are the Bear Springs and Cottonwood Seep 

WQAs (see EIS Table 106).

The plan provides guidance for Bear Springs and Cottonwood Seep, in addition to eight other 

areas, in the “Wildlife Quiet Areas” section of the plan in chapter 3. 

Concern Statement: Remove Natural Landscape Management Area. Concern is that it leads 

to de facto wilderness management. (108.208, 81.6, 81.7, 81.16)

Response: The Apache-Sitgreaves NFs manage National Forest System lands under the multiple 

use concept. However, management of some areas is constrained by laws and regulations. The 

Forest Service must follow laws and regulations. As stated in the “Background for Natural 

Landscape” section of the plan, 

“This management area includes most of the Inventoried Roadless Areas (IRAs) that were 

identified in the 2001 Roadless Area Conservation Rule.” 

The Forest Service is required to manage IRAs to protect and conserve their roadless character. 

The Natural Landscape Management Area is not managed as wilderness or for wilderness 

character.

Concern Statement: Provide information on the potential location of the proposed 

405,000 acres of Natural Landscape Management Area. (161.94)

Response: The Natural Landscape Management Area is shown on the management areas maps 

found in appendix F (“Maps”) of the plan.

Suitability 

Concern Statement: Allow grazing in areas that may not be under allotment or in special 

use areas that are otherwise suitable for grazing. (98.24)

Response: Areas not under an Apache-Sitgreaves NFs’ allotment that are identified as suitable 

for livestock grazing include portions of the Apache NF along the boundary with the Gila NF and 

an area near Clifton. The area along the Gila NF comprises the majority of acreage and these 

areas are grazed by livestock but they are administered by the Gila NF since the larger portion of 

the allotment is on the Gila NF. The area near Clifton weaves back and forth across the forest 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 759

boundary and these lands are not under an existing grazing allotment due to the topographical 

limitations.

A plan suitability determination as “suitable” indicates that grazing is compatible with the desired 

conditions for the relevant portion of the plan area. It is guidance for project and activity 

decisionmaking, and is not a commitment or a final decision. It does not mean that grazing will or 

will not occur in a particular area. The final decision to authorize livestock grazing and the 

determination for how lands are managed (including those that have been identified as not 

capable of producing forage), is made at the project or allotment level. The decision to authorize 

grazing and under what conditions is made following environmental analysis (National 

Environmental Policy Act) where site specific conditions can be assessed and addressed through 

project design.

Concern Statement: Support removing proposed and designated research natural areas 

from suitable rangelands. However, these rangelands should be managed for the specific 

purpose of quantifying and improving the understanding of the rangelands resources 

ecosystem processes and how they relate to improved management practices. (161.18, 161.7, 

161.8)

Response: In determining the future need for research natural areas (RNAs), the interdisciplinary 

team followed the regional plan revision guidance “Research Natural Area Process for Forest 

Plan Revision Under the 1982 Planning Rule Provisions” (Forest Service, 2009d). RNAs are

protected and maintained in a natural condition for the purpose of conducting non-manipulative 

research and for fostering education. As such, they were identified as areas not suitable for 

livestock grazing in the suitability analysis presented in the “Livestock Grazing Suitability” 

section in chapter 4 of the plan and described in appendix B (“Description of the Analysis 

Process”) of the EIS.

The specific purposes or types of research to be conducted have not been decided. The 

backgrounds in the “Research Natural Areas” and “Recommended Research Natural Areas” 

sections in chapter 3 of the plan identify potential opportunities for research. The recommended 

Lower Campbell Blue and Sandrock RNA specifically mention the possibility of using these 

areas to study rangeland-related topics.

Concern Statement: Explain how the Forest Service met the requirements to identify 

capable and suitable lands for livestock grazing. Concern that the Forest Service needs to 

calculate suitability and capability as required by regulations at 219.20. (127.25, 26.83, 

132.13, 132.12, 26.84, 127.35, 127.1, 127.36)

Response: The Forest Service completed capability and suitability estimates as required by the 

provisions of the 1982 Planning Rule (Section 219.20). This is described in appendix B 

(“Description of the Analysis Process”) of the EIS under the “Livestock Grazing Suitability 

Analysis” section. It notes, 

“Capability to produce forage for grazing animals was originally determined in the 

1980s during the development of the 1987 plan and was based on individual allotment 

data. Landscape scale conditions that determine capability have not changed since the 

first evaluation. The Analysis of the Management Situation (1983) and the Environmental 

Impact Statement (1987) document the analysis of grazing capability and suitability for 

the 1987 plan.” 
Appendix A

760 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Suitable rangeland was determined based on whether an area was appropriate for the activity of 

livestock grazing in consideration of relevant social, economic, and ecological factors. 

Recommended research natural areas, research natural areas, and current National Forest System 

land not in a grazing allotment were considered to be not suitable for livestock grazing.

The identification of lands suitable for livestock grazing within the plan is not a decision to 

authorize livestock grazing. The final decision to authorize livestock grazing would be made at a 

project (individual grazing allotment) level. On a site-specific basis, grazing allotments are 

guided by an adaptive management strategy whereby results from long and short term monitoring 

are used to determine yearly stocking rates, pasture rotations, and whether other adjustments are 

needed in order to meet management objectives and desired conditions for rangelands.

Concern Statement: In the livestock grazing suitability analysis, consider: (1) food and 

hiding cover for wildlife, (2) distance from water, (3) amount of litter, (4) amount of bare 

soil, (5) erosion rates, (6) current plant composition, abundance and distribution as 

compared to historical and/or potential, (7) fire, (8) moisture cycles, and (9) slope. (132.43, 

132.18, 132.60, 132.20, 132.14, 132.44, 132.59)

Response: The suitability determination for livestock grazing has not been changed based on this 

comment. The factors listed above are generally considered in the capability for livestock grazing 

determination. Capability is the potential of an area of land to produce resources and supply 

goods and services. Capability depends upon current conditions and site conditions such as 

climate variability, slope, landform, soils, and geology. Capability was determined in the 1980s 

during the first round of forest planning by compiling data from the most recent individual 

allotment analyses. Landscape scale conditions have not changed significantly since that

evaluation; the capability determination was not updated during this revision process. The factors 

listed above could be considered at the project-level for individual allotment analysis.

Concern Statement: Include the following in the plan and implement immediately once the 

plan is approved: (1) new criteria for lands capable of supporting livestock using a specific 

distance to water (Holechek) as well as “other” criteria as noted by Cook, (2) a requirement 

that there is a quantitative and qualitative analysis prior to the issuance of any annual 

operating instruction (AOI), that there is adequate open water available for the term of 

livestock grazing and ample supply to support the current populations of native wildlife in 

the area adjacent to that open water. (132.19)

Response: The identification of lands suitable for livestock grazing within the plan is not a 

decision to authorize livestock grazing. The final decision to authorize livestock grazing would be 

made at a project (individual grazing allotment) level. The considerations in the comment could 

be considered at that time. On a site-specific basis, grazing allotments are guided by an adaptive 

management strategy whereby results from long- and short-term monitoring are used to determine 

yearly stocking rates, pasture rotations, and whether other adjustments are needed in order to 

meet management objectives and desired conditions for rangelands.

Concern Statement: There should be a change in suitability for grazing in and around 

aspen stands: livestock grazing should be moved away from aspen stands. (162.86, 162.93)

Response: The suitability determination for livestock grazing has not been changed based on this 

comment. The plan identifies a guideline under the “Forests: Aspen” section in chapter 2 to 

preclude concentrated herbivore impacts within proximity to aspen stands and another guideline 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 761

within the “Livestock Grazing” section to minimize herbivory to aspen clones. In addition, where 

there are site-specific concerns related to livestock grazing, they may be addressed in the annual 

operating instructions and throughout the season. The “Monitoring Strategy” in chapter 5 of the 

plan includes questions that will also help identify any potentially negative impacts from 

livestock in aspen stands.

Concern Statement: There should be a change in grazing suitability of piñon-juniper 

woodlands so that the understory can rebound.

Response: The suitability determination for livestock grazing has not been changed based on this 

comment. The plan identifies a desired condition under the “All PNVTs” section in chapter 2 that 

would address understory for all PNVTs, including piñon-juniper woodland, 

“Vegetative ground cover (herbaceous vegetation and litter) is optimized to protect and 

enrich soils and promote water infiltration.” 

The identification of lands suitable for livestock grazing within the plan is not a decision to 

authorize livestock grazing. The final decision to authorize livestock grazing would be made at a 

project (individual grazing allotment) level. On a site-specific basis, grazing allotments are 

guided by an adaptive management strategy whereby results from long and short term monitoring 

are used to determine yearly stocking rates, pasture rotations, and whether other adjustments are 

needed in order to meet management objectives and desired conditions for rangelands.

Concern Statement: Explain the statement that landscape scale conditions that determine 

capability have not changed significantly since the first evaluation (DEIS p. 451). Concern 

that the 1987 plan permitted use of 219,510 AUMS, in 2008 authorized use was 200,259 

AUMs, and the 2000 analysis estimated the grazing capacity to be 78,984 AUMs. Concern 

that rangelands in the planning area ever will unlikely return to “historical norms” that 

supported forage production capacity over the past century. (26.186, 26.81)

Response: Capability is defined in the glossary of the 1987 plan as,

“The potential of an area of land to produce resources, supply goods and services, and 

allow resource uses under an assumed set of management practices and at a given level 

of management intensity. Capability depends upon site conditions such as climate 

variability, slope, landform, soils, and geology, as well as the application of management 

practices, such as silviculture or protection from fire, insects, and disease.”

Capability was determined in the 1980s during the first round of forest planning by compiling 

data from the most recent individual allotment analyses. Slope, landform, soils, and geology have 

not changed significantly since the 1980s.

Climate has been variable since the first round of forest planning was completed in the 1980s.

Adaptive management strategies to address potential change in climatic conditions are described 

in appendix A of the plan. 

The 1987 plan’s EIS (Forest Service, 1987), table 48, shows the existing livestock grazing 

capacity at 204,348 animal unit months (AUMs). At that time, allowable use levels were closer to 

50 percent of forage production as identified in the Supplemental Monitoring Report (July 2000).

Allowable use levels applied in the grazing capacity analysis for the Supplemental Monitoring 
Appendix A

762 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Report are more conservative (23 percent) allocating more forage production to ecosystem 

maintenance including watershed protection of soils and streams as well as wildlife needs. This 

is, in part, based on more recent project-level assessments completed during the mid-1990s. In 

addition, this conservative allowable use level is primarily directed at improving areas that are in 

poor or very poor range condition. Applying this conservative value across the forests, the 

grazing capacity estimate of 78,984 AUMs identified in the Supplemental Monitoring Report is 

substantially lower than the capacity identified in the first round of forest planning.

As stated in the report, site specific data accounts for 55 percent of AUM capacity and geographic 

information system (GIS) projects account for 45 percent of the capacity estimates. In other 

words, where site specific data was lacking, GIS was used to develop a projection of forestwide 

range capability. Applying the allotment percentages of acreages for full, potential, and no 

capability acres identified in the report, allotments on one Ranger District have a significantly 

higher (67 percent) amount of no capability acres (279,397 acres). Forestwide capability and 

capacity estimates are considerably more conservative in part due to the lack of site specific data.

As stated in the report,

“this data should not be used for making site specific decisions or inferences for lands 

without additional information.” 

The 1987 plan’s “Analysis of the Management Situation” (Forest Service, 1983) and the 

“Environmental Impact Statement” (Forest Service, 1987) document the analysis of grazing 

capability and suitability for the 1987 plan. Suitable rangeland was determined based on whether 

an area was appropriate for the activity of livestock grazing in consideration of relevant social, 

economic, and ecological factors. Recommended research natural areas, research natural areas, 

and current NFS land not in a grazing allotment were considered to not be suitable for livestock 

grazing.

The identification of lands suitable for livestock grazing within the plan is not a decision to 

authorize livestock grazing. The final decision to authorize livestock grazing would be made at a 

project (individual grazing allotment) level. On a site-specific basis, grazing allotments are 

guided by an adaptive management strategy whereby results from long- and short-term 

monitoring are used to determine yearly stocking rates, pasture rotations, and whether other 

adjustments are needed in order to meet management objectives and desired conditions for

rangelands.

Concern Statement: Disclose the foreseeable climate effects to range suitability and 

capability, and disclose past instances when excessive livestock grazing has exceeded 

capability. (26.86, 162.53)

Response: The potential environmental consequences of climate change are discussed in 

appendix A (“Climate Change Trends and Apache-Sitgreaves NFs Land Management Planning”)

of the plan and in the “Livestock Grazing” section in chapter 3 of the EIS. The plan states, 

“Changes in climate may affect the vigor and productivity of forage plants and, thus, the 

overall conditions of both wildlife habitat and ecological conditions which may affect 

grazing capability. It is possible that higher temperatures and decreased precipitation 

described for the next century will also decrease forage production and shorten the 

growing and grazing season, causing a reduction in livestock numbers; while flash floods 

and increased risk of animal disease can adversely affect the livestock industry (Joyce et 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 763

al., 2001) dependent upon the Apache-Sitgreaves NFs’ forage resources. Coupled with 

poor forage conditions, there may be a general scarcity of water for livestock, which may 

affect grazing capability.” 

The determination of instances where excessive livestock grazing has exceeded capability is 

outside the scope of this analysis. Actual balancing livestock use with available forage occurs at 

the project-level individual allotment environmental analysis. 

Concern Statement: Provide the science to support the livestock grazing capability and 

suitability criteria slope and production, pounds per acre. (132.55, 132.15, 132.52)

Response: As shown in appendix B (“Description of the Analysis Process”) of the EIS under the 

“Livestock Grazing Suitability Analysis” section, 

“Capability to produce forage for grazing animals was originally determined in the 

1980s during the development of the 1987 plan and was based on individual allotment 

data. Landscape scale conditions that determine capability have not changed since the 

first evaluation. The Analysis of the Management Situation (1983) and the Environmental 

Impact Statement (1987) document the analysis of grazing capability and suitability for 

the 1987 plan.” 

Suitable rangeland was determined based on whether an area was appropriate for the activity of 

livestock grazing in consideration of relevant social, economic, and ecological factors. 

Recommended research natural areas, research natural areas, and current National Forest System

land not in a grazing allotment were considered to be not suitable for livestock grazing.

The identification of lands suitable for livestock grazing within the plan is not a decision to 

authorize livestock grazing. The final decision to authorize livestock grazing would be made at a 

project (individual grazing allotment) level. On a site-specific basis, grazing allotments are 

guided by an adaptive management strategy whereby results from long- and short-term 

monitoring are used to determine yearly stocking rates, pasture rotations, and whether other 

adjustments are needed in order to meet management objectives and desired conditions for 

rangelands.

Concern Statement: The following should be considered suitable for livestock grazing: (1) 

current NFS land not in a grazing allotment, (2) Black River Conservation Area. (proposed 

plan p.128). (105.13, 131.18)

Response: Provisions of the 1982 Planning Rule require that the capability and suitability for 

producing forage for grazing animals on NFS lands be determined. Capability is the potential of 

an area of land to produce resources, and supply goods and services. Capability depends upon 

current conditions and site conditions such as climate, slope, landform, soils, and geology, as well 

as the application of management practices. 

The capability of the lands on the Apache-Sitgreaves NFs to produce forage for grazing animals 

was determined in the 1980s during the first round of forest planning. Landscape scale conditions 

that determine capability have not changed significantly since the first evaluation.
Appendix A

764 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Suitability is the appropriateness of applying certain resource management practices to a 

particular area of land, in consideration of relevant social, economic, and ecological factors. A 

unit of land may be suitable for a variety of individual or combined management practices.

There are 77,000 acres outside of grazing allotments. Active and vacant allotments are generally 

suitable. Closed allotments and NFS areas that are not in allotments are generally not suitable 

(Forest Service, 2008d). The Black River Conservation Area has been removed from the 

suitability table because it is not in a grazing allotment. 

Concern Statement: Karst and cave geologic areas may be suitable for livestock grazing, 

energy transportation, communications infrastructure, recreation, timber production, and 

motorized uses in accordance with the guidelines and restrictions set forth in the Karst and 

Cave Management plan. (35.7, 35.8, 35.9, 35.10, 35.11)

Response: There are currently no karst and cave geological areas on the Apache-Sitgreaves NFs. 

The plan does not provide suitability determinations for areas on or near karst and cave features. 

The plan does provide guidance to protect cave and karst features including desired conditions in 

the “Minerals and Geology” section and a guideline in the “Wildlife and Rare Plants” that states,

“Rare and unique features (e.g., talus slopes, cliffs, canyon slopes, caves, fens, bogs, 

sinkholes) should be protected to retain their distinctive ecological functions and 

maintain viability of associated species.” 

As mentioned in the management approaches in the “Minerals and Geology” section of the plan, 

“Cave and karst management plans are developed as needed.”

The site-specific details of cave and karst management would be addressed in these separate 

plans. Specific methods to protect caves and karsts would be determined in project or activitylevel analysis.

Concern Statement: Review the prior classification of lands unsuitable for timber 

production; it is not sufficient under the National Forest Management Act to carry forward 

lands that previously were deemed unsuitable without further analysis. (162.48, 26.78)

Response: The only lands previously classified as unsuitable for timber production under the 

1987 plan that were carried forward again in this analysis were those areas specified by the 1982 

Planning Rule provisions as areas legally/administratively withdrawn from timber production 

such as wilderness (Section 219.14(a)(4)).

The 1987 plan neither classifies forest lands as potential natural vegetation types (PNVTs) nor has 

the same management areas as were used for the action alternatives in the EIS. Thus, for fair 

comparison, all forested PNVT lands and soils criteria (Section 219.14(a)(1)) were re-evaluated 

further in this analysis for all four alternatives (including alternative A) according to the 1982 

Planning Rule (Sections 219.14(a)(c), along with consideration of section 219.27). See EIS 

appendix B (“Description of the Analysis Process”) and “Forest Products Specialist Report”

appendix A2 (Forest Service, 2014c) for further descriptions of the steps used in this re-analysis 

process.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 765

Concern Statement: Consider the following as criteria for designating lands as unsuitable 

for timber production: (1) high or severe erosion hazard soils, (2) steep slopes over 30 

percent, (3) lands within one site-potential tree height of perennial or intermittent streams 

or wetlands, (4) areas larger than 1,000 acres without roads, (5) critical habitat of 

threatened or endangered species, or candidate species proposed for listing, (6) designated 

conservation areas for sensitive or management indicator species, including proposed 

“wildlife quiet areas,” and (7) occupied locations of endemic species with ranges limited to 

the national forests. (162.49, 26.78)

Response: The determination of timber suitability process is described in chapter 4 of the plan in 

the “Lands Suitable for Timber Production” section and in appendix B (“Description of the 

Analysis Process”) of the EIS. The EIS and “Forest Products Specialist Report” (Forest Service 

2014c), including appendix A2 and appendix F, demonstrate in detail how the Apache-Sitgreaves 

NFs terrestrial ecosystem survey (TES) soils units were used to eliminate lands from timber

production suitability status in the plan (alternative B). Lands eliminated possess many 

characteristics, including the following: unstable soils and/or steep slopes (high erosion hazard), 

irreversible damage likely from mechanical equipment, riparian, and water.

Lands located inside certain management areas (wilderness, recommended wilderness, research 

natural areas, recommended research areas, natural landscapes, high use developed recreation 

areas), eligible and suitable wild and scenic river corridors, TES riparian soils, and water acreages 

(containing the majority of perennial or intermittent streams and wetlands) have been excluded 

from timberland suitability status. These lands are either administratively withdrawn or are lands 

where management area prescriptions preclude timber production, or are lands where 

management objectives limit timber harvest. Additionally, lands which are steep but loggable, 

unroaded (any size), and/or are too isolated or too small to log were dropped as not being 

economically cost-efficient for timber harvest.

Additionally, all Mexican spotted owl protected activity centers (critical habitat for a threatened 

species) were categorized as lands where management objectives limit timber harvest and 

therefore, eliminated from timberland suitability status. Some other threatened and endangered 

species habitat acres, like fisheries, are included in the same lands previously eliminated for other 

reasons, and thus, were not listed again in order to avoid double- or triple-counting the same acres 

in the suitability classification process. Including any forthcoming critical habitats for candidate 

species proposed for listing, as well as occupied locations of endemic species with ranges limited 

to the national forests, would be too speculative and premature at the time of this analysis for an 

accurate accounting of acres involved. 

The identification of an area as suitable for a particular use or uses is guidance for project and 

activity decisionmaking; it is not a commitment or a final decision and does not mean that a 

particular use will or will not occur in the area. When projects are proposed under plan 

implementation, the appropriateness of timber harvest or mechanical treatments would be 

evaluated and the project interdisciplinary team would address site-specific resource concerns 

such as the presence of perennial and intermittent streams or wetlands; trees on stream-banks or 

wetland edges; roadless areas; lands directly impacted by high severity fire effects; wildlife quiet 

areas; and habitat for species that are threatened, endangered, proposed, rare, endemic, 

management indicator, or otherwise of concern. Such project-level determinations would also be 

included for consideration in the next 10-year timber suitability re-evaluation that is required by 

law.
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766 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

A project with the purpose of timber production may only occur in an area identified as suitable 

for timber production (16 USC 1604(k)). The documentation for the project would confirm the 

project area meets the suitability requirements.

Also see responses to comment numbers 162.48, 26.185, 26.184, and 26.111 in the “Suitability of 

Areas,” “Riparian,” and “Vegetation” sections of this appendix.

Concern Statement: Consider lands impacted by high severity fire effects to vegetation or 

soil as criteria for designating lands as unsuitable for timber production. Consider long 

term losses of soil productivity resulting from synergistic impacts of fire and mechanical 

disturbance (i.e., “salvage logging”), particularly where spread of exotic invasive species is a 

risk, in the timber suitability determination. Add a caveat to the suitability designation 

stating that forests affected by severe fire will be managed for natural recovery rather than 

for economic production. (26.185, 162.50, 26.79)

Response: The timber suitability determination (classification) process is consistent with the 

provisions of the 1982 Planning Rule and Southwestern Region planning advice (Forest Service, 

2009f). Risk of exotic invasive species spread is a surface condition that can be reversed on a sitespecific basis, and thus, has no merit in the classification process for timberland land suitability 

status. Further, Section 219.27(c)(1) of the 1982 Planning Rule clarifies that post-fire salvage 

logging and tree planting may also be used on non-suitable timberlands, when determined to be 

appropriate to achieve multiple-use objectives of the plan. The 1982 Planning Rule does not 

provide for making caveats to the land suitability designation involving site specific management 

actions, which are to be determined at the project-level on a case-by-case analysis. 

The management approaches for the “Landscape Scale Disturbance Events” section describes 

possible options following fire, 

“Where extensive tree mortality results from landscape scale disturbance and economic 

value exists, salvage of dead trees may be considered where this contributes to the 

movement toward desired conditions. Deferral of ecological restoration or salvage 

projects and activities may also be considered where these are not necessary for 

recovery.”

According to the Apache-Sitgreaves NFs terrestrial ecosystem survey, soils most sensitive to 

mechanical disturbance impacts have already been classified as non-suitable timberlands in this 

analysis. See EIS appendix B “Timber Suitability Analysis” section, “Forest Products Specialist 

Report” and report appendix A2 and appendix F (Forest Service, 2014c) in the plan set of 

documents and on the forests’ Web site at 

http://www.fs.usda.gov/main/asnf/landmanagement/planning. Project-level designs to minimize 

mechanical disturbance and/or noxious weeds during management activities are directed in the 

plan, chapter 2 through desired conditions in the “Overall Ecosystem Health” and “Soil” sections; 

guidelines in the “Soil,” “Invasive Species,” “Landscape Scale Disturbance Events” sections; and 

standards in the “Special Uses” section. The management approaches for the “Forests: All 

Forested PNVTs” section in the plan further describes protection measures, including those that 

would follow high severity fire.

Any long term losses of soil productivity resulting from fire or other disturbances and 

management activities would be considered in the next 10-year timber suitability re-evaluation, 

after monitoring is conducted under the plan to determine if site productivity has been lost or 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 767

degraded. See the plan’s “Monitoring Strategy” in chapter 5, (first and twelfth monitoring 

questions), as well as objectives and management approaches in the “Soil” section. Also see 

response to comment 26.111.

Concern Statement: Recommend deferral of all old growth forest that meet standards and 

guidelines set forth in the 1987 plan from designation as suitable for timber harvest. (26.111)

Response: Timber suitability classification was conducted in compliance with the provisions of 

the 1982 Planning Rule and Southwestern Region planning direction (Forest Service, 2009f) is 

based on land availability, capability, operability, management area objectives and requirements, 

and economic feasibility of the land. See EIS appendix B “Timber Suitability Analysis” section 

and the “Forest Products Specialist Report” (Forest Service, 2014c) including appendices 

(appendix A2 and appendix F - item 3 under “Timber Production Suitability Analysis” header). 

Also see plan chapter 3 for management area direction and chapter 4 for land suitability by 

management area.

Timberland suitability classification is made irrespective of current tree age classes and/or forest 

structure, or presence of exotic/invasive plant species, presently standing on any particular acres 

of land. For example, bare ground currently un-forested can qualify as suitable timberland in the 

required classification process. Standards and guidelines for old growth set forth in the current 

1987 plan, as amended in 1996, would only apply to alternative A, but they would still not serve 

as criteria for determination of land suitability for timber production nor do they reflect today’s 

best available science on old growth, especially in frequent-fire PNVTs (Reynolds et al., 2013).

Forested acres meeting the plan’s definition of old growth that occur on lands classified as 

suitable or non-suitable timberlands could be either treated, or deferred from treatment, under 

each site specific analysis and decision made at the project-level to best meet multiple resource 

objectives consistent with plan direction.

Those project-level decisions would be directed at multiple scales and would be consistent with 

the plan including the following sections: “Overall Ecosystem Health,” “All PNVTs,” “Riparian 

Areas,” “Forests: All Forested PNVTs,” “Forests: Ponderosa Pine,” “Forests: Dry Mixed 

Conifer,” “Forests: Wet Mixed Conifer,” “Forests: Spruce-Fir,” “Forests: Aspen,” “ Woodlands: 

All Woodland PNVTs,” “Woodlands: Madrean Pine-Oak,” “Woodlands: Piñon-Juniper,” and 

“Wildlife and Rare Plants.” 

The plan provides direction to manage for well-distributed occurrences of old growth. The 

following are three examples from the plan’s desired conditions from the “All PNVTs” section: 

“Diverse vegetation structure, species composition, densities, and seral states provide 

quality habitat for native and desirable nonnative plant and animal species throughout 

their life cycle and at multiple spatial scales. Landscapes provide for the full range of 

ecosystem diversity at multiple scales, including habitats for those species associated 

with late seral states and old growth forests.” 

“Old growth is dynamic in nature and occurs in well-distributed patches that spatially 

shift across forest and woodland landscapes over time.”

“Old or large trees, multistoried canopies, large coarse woody debris, and snags provide 

the structure, function, and associated vegetation composition as appropriate for each 

forested and woodland PNVT.”
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768 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

An example of a guideline from the “Forests: All Forested PNVTs” section includes: 

“Where current forests are lacking proportional representation of late seral states and 

species composition on a landscape scale, old growth characteristics should be retained 

or encouraged to the greatest extent possible within the scope of meeting other desired 

conditions (e.g., reduce impacts from insects and disease, reduce the threat of 

uncharacteristic wildfire).”

Concern Statement: Recommend identifying chainsaws as gasoline powered or nonmechanized instead of motorized in table 7 footnotes (proposed plan p.130). (99.13)

Response: This comment is no longer applicable. Footnote 3 has been removed from table 8 

because there are no National Forest System trails in the Recommended Wilderness Management 

Area.

Concern Statement: Timber suitability designations must apply cost-benefit analysis and 

“stratify” lands by allowable intensity of timber management. (162.184)

Response: In accordance with the 1982 Planning Rule provisions (Section 219.14) tentatively 

suitable lands were stratified by various timber management harvesting and access systems into 

four strata. Then a financial (present net value and benefit-cost ratio) analysis was conducted by 

stratum following the procedure outlined by Connelly (2009). The list of proposed and possible 

harvest actions, including mechanical thinning, and probable management prescriptions are listed 

in appendix B (“Vegetation Conditions and Management Practices”) and in appendix E of the 

plan. See EIS appendix B (“Description of the Analysis Process”) and “Forest Products Specialist 

Report” appendices A2, A3, and A3Roads (Forest Service, 2014c). The stratification maps and 

tables used for this step of the timberland suitability analysis are filed in the plan set of 

documents.

Monitoring

Concern Statement: Explain how the monitoring strategy will address attainment of objectives 

and compliance with guidelines. (102.47, 26.104)

Response: An additional monitoring question (“Are plan objectives being achieved?”) was added 

to the plan’s monitoring strategy. This, along with the existing question “Are the standards and 

guidelines prescribed being incorporated in National Environmental Policy Act (NEPA)

documents and implemented in projects and activities?” will focus the forests monitoring and 

evaluation efforts to address attainment of objectives and compliance with guidelines.

Concern Statement: Explain how the monitoring strategy addresses diversity. Forest 

Service regulations call for environmental monitoring to insure that natural diversity is 

maintained. (102.51)

Response: The Forest Service planning regulations (provisions of the 1982 Planning Rule) do not 

contain a requirement for monitoring to ensure that natural diversity is maintained. However, the 

plan’s monitoring strategy (chapter 5) does have several monitoring questions that can provide 

information about the biological and ecosystem diversity of the Apache-Sitgreaves NFs. For 

example:
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 769

“Are habitat for threatened, endangered, sensitive, and other species for the forests being 

maintained or enhanced...?” 

“Are PNVTs and habitat needs being provided for and contributing to desired 

conditions?” 

“How are management activities affecting late successional forest structure in relation to 

desired conditions?”

Concern Statement: Establish a science-based monitoring plan that results in an adaptive 

management strategy. (138.4)

Response: The monitoring strategy is identified in chapter 5 of the plan. This strategy outlines 

the general framework for achieving plan monitoring. Plan monitoring is one piece of the 

adaptive management strategy which includes measurable objectives, monitoring, learning and 

making changes, and recognizing the uncertainties of outcomes. A monitoring implementation 

plan, based on the monitoring strategy, is currently under development. This guide will provide 

the specific science-based protocols for specific monitoring items. The monitoring 

implementation plan is not part of the plan; it will be contained in a document outside of the plan 

and updated based on new information gathered from the adaptive management process. 

Concern Statement: Identify what will be monitored and on what schedule. (109.14, 26.170)

Response: The monitoring strategy in chapter 5 of the plan identifies monitoring questions, 

possible monitoring methods, and frequency of measurement. More detailed information about 

the specific monitoring items will be identified in the monitoring implementation plan (currently 

under development). The monitoring implementation plan is not part of the plan; it will be 

contained in a document outside of the plan and updated based on new information gathered from 

the adaptive management process. Results of monitoring will be presented in evaluation reports 

biennially.

Concern Statement: Monitor the impact of ever expanding wild horse populations and the 

response of aspen to stand-converting fires. (109.15)

Response: The impacts specifically related to the wild horse population have not been identified 

as a plan level monitoring item. Monitoring of wild horse impacts would be identified in the 

Heber Wild Horse Territory Management Plan (currently under development).

Aspen is identified as an ecological indicator in the plan and EIS. The plan’s monitoring strategy 

(chapter 5) contains a question focused on understanding the effect of management upon habitat 

trends of ecological indicators across the forests. The monitoring strategy identifies a possible 

method to conduct aspen monitoring in both burned and unburned areas.

Concern Statement: Disclose the source of monitoring results. Concern that the Forest 

Service often does not reveal that it uses permittees to conduct its monitoring, and trusts 

their answers even though they have zero incentive to self-report their failings. (127.29)

Response: The specific detail of the plan’s monitoring strategy (chapter 5), including monitoring 

protocol and data sources, will be identified in the monitoring implementation plan (currently 

under development). The monitoring implementation plan is not part of the plan; it will be 
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770 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

contained in a document outside of the plan and updated based on new information gathered from 

the adaptive management process.

Concern Statement: Include in very specific terms the requirements for a quantitative, 

qualitative and effectiveness monitoring strategy, a very specific monitoring implementation 

plan, and a specific monitoring budget, required resources allocation and funding, to the 

planning and NEPA review process of all management projects, to be submitted to public 

review and comments in the Draft Environmental Impact Statements (DEIS), to be included 

in the Records of Decisions (ROD) and to be included in the Final Environmental Impact 

Statements (FEIS) of all management projects, in order to insure that monitoring will 

actually be implemented and funded. (1) Include in very specific terms the requirements for 

the responsible officials to be bound by the findings of multi-party monitoring boards and 

to act upon the findings of a multi- party monitoring boards in a manner that appropriately 

addresses the issues raised by the multi-party monitoring boards. (2) Include in very 

specific terms a fourth phase that outlines clearly the responsibility and authority of 

responsible officials to implement adaptive and if necessary corrective management action 

during the implementation of large scale long duration specific projects as a response to the 

quantitative, qualitative, and effectiveness monitoring of the project, in addition to the three 

phases of planning (assessment, planning, and monitoring) identified in Title 36, Code of 

Federal Regulations, part 219 (36 CFR part 219) and designed to support a framework for 

adaptive management. (3) Include clear and unambiguous guidelines to responsible officials 

to integrate social and economic sustainability and social and economic science into the 

framework of best available scientific information to inform their land management 

planning process and their management decisionmaking process. (4) Include clear and 

unambiguous guidelines to responsible officials to implement substantive - even though 

possibly scientifically imperfect - management actions that move the ecosystems 

significantly toward the desired future conditions, when such actions are supported by 

social consensus, rather than spend years attempting to forcibly impose, and possibly 

trigger litigation of management actions that may be deemed scientifically more perfect but 

that do not benefit from the support of the social consensus. (5) Include an emphasis on 

executing well less than perfect projects now, over developing scientifically perfect projects 

that are never implemented. (6) Include an emphasis on allowing the public to participate 

meaningfully in, influence substantially, and when appropriate alter the content of the 

decision of responsible officials while they retain their statutory decisionmaking authority. 

(7) Include a special forum for local government elected officials such as County 

Supervisors to represent the socio economic interests of the local residents in the 

decisionmaking process of the Forest Service responsible officials. (8) Include clear and 

unambiguous guidelines to reviewing officers to exercise careful judgment in their 

resolution or rejection of objections, in relation to the true material importance of the 

objections – as opposed to their symbolic or emotional importance, and the potential effect 

of litigation on the implementation of the project. (161.100, 161.98, 161.97, 161.172, 161.110, 

161.111, 161.109, 161.106, 161.105, 161.101, 161.113)

Response: The plan (chapter 5) provides a monitoring strategy, including monitoring questions 

that can be answered both quantitatively and qualitatively, to evaluate the effectiveness of the 

plan. The specific details of the monitoring strategy, including monitoring protocol, data sources, 

necessary resources, and costs of monitoring, will be identified in the monitoring implementation 

plan (currently under development). The monitoring implementation plan is not part of the plan; 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 771

it will be contained in a document outside of the plan and updated based on new information 

gathered from the adaptive management process. Actual budgets for monitoring would vary by 

year based on Congressional allocation.

Responses to itemized comments:

(1) Appendix D of the plan (“Relevant Laws, Regulations, and Policies”) includes direction that 

guides responsible officials in public participation (e.g., National Environmental Policy Act, 

National Forest Management Act, Forest Service Manual 1500). While the Forest Service is 

committed to public participation and encourages collaboration, the responsible official is 

accountable for all formal land management decisions affecting National Forest System lands and 

may not relinquish that responsibility. Responsible officials have the authority to use input from 

multi-party monitoring boards to inform their decision.

(2) Plan decisions would apply to complex, large scale, long term projects conducted on the 

Apache-Sitgreaves NFs. This includes monitoring and evaluating the results of the monitoring 

strategy. Using adaptive management, the responsible official could make corrective actions as 

the need arises. With exception to development of the plan monitoring program, the 2012 

Planning Rule (36 CFR § 219) requirements referenced are beyond the scope of this planning 

process. This planning process uses the provisions of the 1982 Planning Rule, as allowed per the 

transition language of the 2012 Planning Rule (36 CFR § 219.17(b)(3)).

(3) The plan is designed to contribute to ecological, social, and economic sustainability. The 

responsible official’s decisions on projects and activities must be consistent with the plan and 

applicable law, regulations, and policy. Responsible officials have the discretion to determine the 

best available science to inform their decisions.

(4) This plan provides guidance and information for responsible officials to conduct project and 

activity decisionmaking on the Apache-Sitgreaves NFs. Those projects and activities would be 

designed to meet desired conditions. In addition, the plan identifies objectives. The objectives 

represent just some of the expected outcomes or actions required to accomplish movement toward 

desired conditions.

(5) Responsible officials have the discretion to determine the scope, design, and use of best 

available science in their project and activity decisionmaking within the constraints that it is 

consistent with the land management plan, applicable law, regulations, and policy.

(6) Appendix D of the plan (“Relevant Laws, Regulations, and Policies”) includes direction that 

guides responsible officials in public participation (e.g., National Environmental Policy Act, 

National Forest Management Act, Forest Service Manual 1500). While the Forest Service is 

committed to public participation and encourages collaboration, the responsible official is 

accountable for all formal land management decisions affecting National Forest System lands and 

may not relinquish that responsibility.

(7) Appendix D of the plan (“Relevant Laws, Regulations, and Policies”) includes direction that 

guides responsible officials in intergovernmental relations and public participation (e.g., National 

Environmental Policy Act, National Forest Management Act, Forest Service Manual 1500). 

Responsible officials have the authority to use input from local elected officials to inform their 

decision.
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772 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

(8) The objection process is outside the scope of the plan and plan revision process. The decision 

on the plan is subject to a post-decision administrative review. The review will use an appeal 

process following the “Optional Appeal Procedures Available during the Planning Rule Transition 

Period” (the former 36 CFR § 217 appeal procedures that were in effect prior to November 9, 

2000) will be used.

Concern Statement: The three phases of planning (assessment, planning, and monitoring) 

should be augmented with a fourth phase that outlines clearly the responsibility and 

authority of responsible officials to implement adaptive and if necessary corrective action 

during the implementation of large scale long duration specific projects as a response to 

quantitative, qualitative, and effectiveness monitoring of the project. NEPA analysis of 

complex, large scale, long term projects should specifically be designed from inception to 

formalize the inclusion of a four phase adaptive management framework. (161.102, 161.175, 

161.103, 161.99)

Response: The plan decisions would apply to complex, large scale, long term projects conducted 

on the Apache-Sitgreaves NFs. This includes monitoring and evaluating the results of the 

monitoring strategy. Using adaptive management, the responsible official could make corrective 

actions as the need arises.

Concern Statement: Explain how the Forest Service complied with the monitoring 

requirements of the 2012 Planning Rule. (161.96, 161.171, 161.173, 161.174, 161.176)

Response: The revised plan, including the “Monitoring Strategy” in chapter 5, was developed 

following the provisions of the 1982 Planning Rule. The Apache-Sitgreaves NFs plan is not 

required to comply with the 2012 Planning Rule monitoring requirements until May 2016. The 

2012 Planning Rule states that 

“Where a plan’s monitoring program has been developed under the provisions of a prior 

planning regulation and the unit has not initiated plan revision [under the 2012 Rule], 

the responsible official shall modify the plan monitoring program within 4 years of the 

effective date of [the 2012 Rule], or as soon as practicable...” (36 CFR § 219.12(c)) 

Since the 2012 Planning Rule became effective on May 9, 2012, the forests have until May 9, 

2016, to transition 1982 Planning Rule plan monitoring programs to the 2012 Planning Rule 

monitoring requirements.

The monitoring strategy has been developed with the 2012 monitoring requirements in mind, and 

the Forest Service anticipates few changes will be needed to bring it into full compliance. 

Concern Statement: Disclose uncertainty and controversy associated with monitoring and 

adaptive management. (26.80)

Response: Chapter 5 of the plan does acknowledge the uncertainties related to monitoring 

implementation:

“Forest managers may need to prioritize what would be monitored in any given year and 

would schedule monitoring and evaluation through the annual budget process. Actual 

budget levels, funding emphasis, and emergence of new issues may affect 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 773

accomplishment. Partnerships may be developed to accomplish monitoring and 

evaluation.” 

A monitoring implementation plan, with the specific details of the monitoring strategy (chapter 5 

of the plan) is currently under development. The monitoring implementation plan is not part of 

the plan; it will be contained in a document outside of the plan and updated based on new 

information gathered from the adaptive management process. As the details of monitoring 

protocols are identified, uncertainties and controversies would be disclosed.

Concern Statement: The complete monitoring plan, including study design and analysis 

protocols, should be made available for public review and comment before a decision is 

made to revise the forest plan. Explain the: (1) criteria for selection of measurable 

indicators of change; (2) sampling design power analysis and expected observational error 

rates; (3) sampling procedures including monitoring cycle; (4) confidence levels to be 

applied in data analysis and reporting; (5) timeframe for evaluation of results; (6) triggers 

for management adaptation using new information; and (7) funding sources. (26.37)

Response: A monitoring implementation plan, with the specific details of the monitoring strategy 

(chapter 5 of the plan) is currently under development. The monitoring implementation plan is 

not part of the plan; it will be contained in a document outside of the plan and updated based on 

new information gathered from the adaptive management process. The draft monitoring 

implementation plan is available upon request, and the Forest Service welcomes review and 

input. The specific measurable indicators of change, sampling design and procedures, confidence 

levels, triggers for management adaptation, and potential funding sources would be considered 

for inclusion in the monitoring implementation plan. Monitoring results would be discussed in a 

biennial evaluation report. 

Appendix D – Relevant Laws, Regulations, Policies, and 

Agreements

Concern Statement: Add additional laws, regulation, and agency directives into the DEIS 

and plan appendix: (1) National Forest Management Act, (2) Forest and Rangeland 

Renewable Resources Planning Act, (3) Multiple Use-Sustained Yield Act of 1960, U.S 

Forest Service 219 Planning Rule: Coordination with Other Public Planning Efforts, (4) 

Forest Service Manual (FSM) 1921.63(a), (5) FSM 1950.2, (6) FSM 1970, (7) Integrated 

Resource Management Process-the Road to Ecosystem Management (USFS Region 3, 4 

edition, appendix A), (8) National Environmental Policy Act, (9) Joint Planning (40 CFR 

§1506.2 (b)); Cooperating Agencies (40 CFR§1501.6); (10) President's Council on 

Environmental Quality Directive to Federal Agencies regarding Cooperating Agency, Feb. 

2002, (11) 40 CFR §1501.7; 40 CFR §1503.1, (12) Regulatory Flexibility Act, (13) Proper 

Consideration of Small Entities in Agency Rulemaking - Presidential Executive Order 

13272, (14) Intergovernmental Cooperation Act, (15) Intergovernmental Review of Federal 

Programs- Presidential Executive Order 12372, (16) Facilitation of Cooperative 

Conservation- Presidential Executive Order 13352, (17) Environmental Justice- Presidential 

Executive Order 12898 §302(d), (18) Outdoor Recreation Act, (19) National Trails System 

Act, (20) Presidential Executive Order 13195: Trails for America in the 21st Century, (21) 

Arizona Coordination Act, (22) Apache County Board of Supervisors Resolution in Feb. 

2010 notified Apache-Sitgreaves National Forest: The need to coordinate the Agency Forest 
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774 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Plan process, and (23) Catron County Ordinance 002-93: Catron County Environmental 

Planning & Review Process; and, Catron County Resolution 002-2010: County Board of 

Supervisors Asserting Legal Standing and Formally Invoking Coordination with All 

Federal and State Agencies Maintaining Jurisdiction Over Lands And/Or Resources 

Located Within The County of Catron, New Mexico. (108.50)

Response: Items 1, 2, 3, 4, 5, 8, 9, 11, 14, 15, 17, and 19 were referenced in appendix D 

(“Relevant Laws, Regulations, and Policies”) in the proposed plan. Items 6, 16, and 20 were 

added to the plan’s appendix D. 

The remaining items were not added to the plan or EIS. Item 7 is obsolete. Item 10 is a memo and 

therefore not listed in the plan or EIS. Items 12 and 13 apply to agency rulemaking and are 

beyond the scope of a land management plan. The Act identified in item 18 does not exist (16 

U.S.C. 4601 refers to the Department of Interior’s Take Pride in America Program). Items 21 to 

23 apply to local and state levels and do not apply to National Forest System lands.

Concern Statement: Modify Appendix D (proposed plan p. 255). Add to the list of 

agreements: Memorandum of Understanding between the Apache-Sitgreaves National 

Forests, Arizona Game and Fish Commission, U.S. Fish and Wildlife Service, Arizona Trout 

Unlimited, Federation of Fly Fishers, and Wildlife Conservation Council for the restoration 

of native trout on the Apache National Forest. (101.90)

Response: This agreement was not added to the plan. The Memorandum of Understanding 

expired in 2005 and has not been renewed. 

Glossary

Concern Statement: Provide or clarify definitions for the following: native species, 

functioning ecosystem, herbivory, livestock grazing, scenic integrity, sustainable, resilience, 

and restoration. (108.217, 108.215, 26.99, 26.98, 108.178, 108.176, 108.175, 102.11, 108.218, 

102.18)

Response: These terms are defined in the glossary of the plan and EIS.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 775

Commenter Codes

The following table displays a list of commenter codes with the associated commenter name and 

organization. Each unique letter was assigned a commenter code. There are seven form letters 

(letters that have the same content submitted by multiple commenters) listed in the table.

Table 178. List of commenter codes and associated commenter name and organization

Commenter 

Code Commenter Organization

1 Marc Beauchamp

2 Anonymous1

3 Thalia Vaillancourt-Lininger

4 Diane Arnst, Manager

Air Quality Legal Support Section

Arizona Department of Environmental 

Quality

5 Jon Spar

6 Gary Horner

7 Linda Ogo, Culture Research Director Yavapai Prescott Indian Tribe

8 Stefan Kodet

9 Form Letter 1

10 Kathy Kron

11 Judith Castiano

12 Danielle Berd

13 Rob Mrowka

14 Pamela Blunt

15 Francis Schilling

16 Mary Ray

17 Form Letter 2

18 Linda Miller

20 Kristine Richter

21 Lori Paul

22 Aniceto Ribeiro

23 Form Letter 3

24 Barbara And Fred Klug

26 Jay Lininger, Wildland Ecologist Center for Biological Diversity

27 Joel Frey

28 Roy Munroe

29 Dorothy Reed-Inman

30 George Ruyle University of Arizona

31 Pauline Reetz
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776 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Commenter 

Code Commenter Organization

32 Dave Williams

33 Virginia Dotson

34 Victoria Carella, Project Manager Arizona State Land Department

35 Rich Bohman, Conservation Chair Central Arizona Grotto

37 Cynthia Wicker

39 Form Letter 5

40 Pascal Berlioux, Executive Director Eastern Arizona Counties Organization

41 John Soos

42 Michael Fletcher

43 Elaine Phelps

44 Kenneth Bigler

46 Roger Martin

47 R Jordan

48 Luna Woden

49 Robert Hilgenberg

50 Claire Chang

51 Lisa Lynott-Carroll

52 Francesca Reitano

53 Jason Kamalie

54 Joya Feltzin

55 Jim Miller

56 Judith Kanfer

58 Patricia Amazalorso

59 Cathy Gumtow-Farrior

60 Christopher Amerding

61 Andrea Bowen

63 Susan Ostlie

64 Lawrence Rosin

65 Mark Harris

66 Margaret Paddock

67 James Field

68 Drew Roenneburg

69 Sandra Peterson

70 Adella Albiani

71 Anold Lane
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Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 777

Commenter 

Code Commenter Organization

72 Judee Reel

73 Tina Stanton

74 Cary Jones

75 Maryann Mabbott

76 Petra Gampper

77 Sandra Pena

78 Jerry Chilson

80 Michael Ghiglieri

81 Bryce Hamblin, Mayor

Submitted by: Shawn Nau Town of Eagar

82 Fran Field

83 Fran Salisbury

84 Mason Frichette

85 Annie McCombs

86 Thomas Cole

87 Barbara Fitzpatrick

88 Bob Brister

89 Amby Duncan-Carr

90 Kathryn Webers

91 John Andes

92 Joanne Capozzelli

93 John Thompson

94 Ann Yarmal

95 Sam And Julia Luce

97 Dave Stucky

98 George Leech

99 Joe Sitarzewski

100 Ralph Harris

101 Chris Bagnoli, Pinetop Regional Supervisor

Submitted by: Dave Dorum Arizona Game And Fish Department

102 Lamar Smith Casabel Range Consultants at request of the 

Ranching Heritage Alliance

103 Mary Macnab

104 Thomas Macnab

105 Daric Knight

106 Alan Timmermann

107 Lori Adkison
Appendix A

778 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Commenter 

Code Commenter Organization

108 Barry Weller, District III Supervisor

Submitted by: Doyel Shamley Apache County

109 Form Letter 7 Arizona Elk Society and Arizona Desert 

Bighorn Sheep Society, Inc.

112

Patricia Sanderson Port, Regional Environmental 

Officer

Submitted by: Vanessa Burge

United States Fish and Wildlife Service

113 Michael Fletcher

114 Anonymous

115 Laurie Herring

116 Robert Corbell

117 Robert Corbell

118 Robert Corbell

119 Robert Corbell

121 Darcy Ely Four Drag Ranch

122 Van L. Norris

123 Norman Brown

124 Richard Inman

125

Edward B. Zuloski, Staff Attorney

for The Wilderness Society and Arizona 

Wilderness Coalition

Earth Justice

The Wilderness Society

Arizona Wilderness Coalition

126 Form Letter 4

127 Erik Ryberg, Attorney for Western Watersheds 

Project Western Watersheds Project

128

Ray Hedrick, Manager

Biological and Cultural Resource Services

Submitted by: Lesly Swanson

Salt River Project

129 Scott and Amanda McLaws

130 Scott and Amanda McLaws

131 Roxanne Knight Cinco Noches Ranch

132 Rick Erman, Member The Friends of Anderson Mesa

133 Mary Macnab

134 John Tate

135 John Tate

136 Melody Tate

137 Kelly Port

138 Wink Crigler X Diamond Ranch

139 Eric Schwennesen Greenlee Cattle Grower’s Association

140 Sheryl Eaton

146 Susan Flader

147 John Bennett Citizens for Multiple Land Use and Access
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 779

Commenter 

Code Commenter Organization

148 Daisy Mae Cannon

149 Stan Ciminski

150 Vicente Ramirez

151 Fennemore Craig, P.C. 

Marc A. Marra

Freeport-McMoRan Copper & Gold Inc., 

and its subsidiary, Freeport-McMoRan 

Morenci Inc.

152 John Macivor

153 Jim Finch Jr.

154 Glenda Finch

155 Gary Finch

156 Jim Finch Sr.

157 James D. Finch Jr.

158 Douglas Reppa

159 Kathleen Martyn Goforth, Manager

Environmental Review Office Environmental Protection Agency

160 Michael Fletcher

161 Form Letter 6 Gila County, Graham County, Greenlee 

County, and Navajo County

162

Alicyn Gitlin, Sierra Club – Grand Canyon 

Chapter

Submitted by: Sandy Bahr

Sierra Club, White Mountain Conservation 

League, Arizona Wilderness Coalition, 

Center for Biological Diversity, Great Old 

Broads for Wilderness, Grand Canyon Wolf 

Recovery Project, Grand Canyon Wildlands 

Council, Public Employees for 

Environmental Responsibility, Defenders of 

Wildlife, and Sky Island Alliance
Appendix A

780 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

References

Abella, S.R.; C. Denton; R. Steinke; and D. Brewer. (2013). Soil development in vegetation 

patches of Pinus ponderosa forests: Interface with restoration thinning and carbon 

storage. Forest Ecology and Management, 310: 632-642.

Abella, S.R.; P.Z. Fulé; and W. W. Covington. (2006). Diameter caps for thinning Southwestern 

ponderosa pine forests: Viewpoints, effects, and tradeoffs. Journal of Forestry, 104: 407-

414.

Agee, J.K.; and C.N. Skinner. (2005). Basic principles of forest fuel reduction treatments. Forest 

Ecology and Management, 211: 83-96.

Allen, C.D.; M.A. Savage; D.A. Falk; K.F. Suckling; T.W. Swetnam; T. Schulke; P.B. Stacey; P.;

Morgan; M. Hoffman; and J.T. Klingle. (2002). Ecological restoration of southwestern 

ponderosa pine ecosystems: A broad perspective. Ecological Applications, 12(5):1418-

1433.

Armantrout, N. B., compiler. (1998). Glossary of aquatic habitat inventory terminology. American 

Fisheries Society, Bethesda, MD.

Arizona Grazing Lands Conservation Association. (2012). The Guide to Rangeland Monitoring 

and Assessment. 161 pp.

Arizona State Parks. (2007). 2008 Statewide comprehensive outdoor recreation plan (SCORP). 

Prepared by the Statewide Planning Unit, Resources Management Section, Arizona State 

Parks. Phoenix, AZ. 254 pp.

Arizona State Parks. (2009). Arizona trails 2010: A statewide motorized and nonmotorized 

recreational trails plan. Prepared under the authority of the Arizona State Parks Board, 

Arizona State Parks. Phoenix, AZ. 318 pp.

Arno, S.F.; and C.E. Fiedler, (2005). Mimicking Nature’s Fire: Restoring Fire-Prone Forests in 

the West. Island Press. Washington D.C. 242 pp.

Bartuska, A.M.; and H. Croft. (2001). Silviculture prescriptions and burn plans. USDA Forest 

Service Washington Office policy letter from Directors of Forest/Rangelands and 

Fire/Aviation Management to Regional Foresters, file code 2470/5100. March 19, 2001. 

Washington D.C. 

Bayley, P.B.; and. H.W. Li. (2008) Stream Fish Responses to Grazing Exclosures. North 

American Journal of Fisheries Management, 28:11, 135-147.

Beschta, R.L.; and W.J. Ripple. (2010). Mexican wolves, elk, and aspen in Arizona: Is there a 

trophic cascade? Forest Ecology and Management, 260: 915-922. 

Blaney, H.F. (1954). Consumptive Use of Ground Water by Phreatophytes and Hydrophytes. 

(Paper presented at the Tenth General Assembly of the International Union of Geodesy 

and Geophysics, Rome, Italy, September 1954). Western Soil and Water Management 

Research Branch, Soil and Water Conservation Research Division, Agricultural Research 

Service, United States Department of Agriculture. Los Angeles, CA.

Brown, R.T.; J.K. Agee; and J.F. Franklin. (2004). Forest restoration and fire: principles in the 

context of place. Conservation Biology, 18(4): 903-912.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 781

Brusca, R; J. Wiens; W. Meyer; J. Eble; K. Franklin; J. Overpeck; and W. Moore. (2013). 

Dramatic response to climate change in the Southwest: Robert Whittaker’s 1963 Arizona 

Mountain plant transect revisited. Ecology and Evolution, 3:720. 

Connelly, W.J. (2009). Section 219.14b Timber Suitability Spreadsheet and Instructions. Timber 

harvesting economic analysis procedure developed by the Planning Specialist of the U.S.

Forest Service National Ecosystem Management Coordination Office. USDA Forest 

Service. Washington D.C.

Cordell, H.K.; C.J. Betz; B.J. Butler; and J.C. Bergstrom. (2008). Trends in forest-based 

recreation: reports for the 2010 Montreal process indicators for the U.S. A Recreation 

Research Report in the Internet Research Information (IRIS) Series. September 2008. 

8 pp. Available at: http://warnell.forestry.uga.edu/nrrt/nsre/IRISRec/IRISRec8rpt.pdf

Cordell, H.K; C.J. Betz; J.M. Fly; S. Mou; and G.T. Green. (2008a). How do Americans View 

Wilderness, A Wilderness Research Report in the IRIS Series. Available at: 

http://www.srs.fs.usda.gov/trends/pdf-iris/IRISWild1rptfs.pdf

Cordell, H.K.; C.J. Betz; G.T. Green; S. Mou; V.R. Leeworthy; P.C. Wiley; J.J. Barry; and D. 

Hellerstein. (2004). Outdoor Recreation for 21st Century America: A Report to the Nation, 

the National Survey on Recreation and the Environment. Venture Publishing, Inc. State 

College, PA. 293 pp.

Cordell, H.K.; G.T. Green; and C.J. Betz. (2009). Long-term national trends in outdoor recreation 

activity participation—1980 to now. A Recreation Research Report in the Internet 

Research Information (IRIS) Series. May 2009. 5 pp. Available at: 

http://warnell.forestry.uga.edu/nrrt/nsre/IRISRec/IRISRec12rpt.pdf

Covington, W.W. (2000). Helping western forests heal: the prognosis is poor for United States

forest ecosystems. Nature, 408: 135-136.

DeByle, N.V.; and R.P. Winokur, editors. (1985). Aspen: Ecology and Management in the 

Western United States. USDA Forest Service, General Technical Report RM-119.

DellaSala, D.A.; J.E. Williams; C.D. Williams; and J.F. Franklin. (2004). Beyond smoke and 

mirrors: a synthesis of fire policy and science. Conservation Biology, 18(4):976-986.

Donovan, G.H.; and T.C. Brown. (2008). Estimating the avoided fuel-treatment costs of wildfire. 

Western Journal of Applied Forestry, 23(4). Society of American Foresters. 

Dore, S.; T.E. Kolb; M. Montes-Helu; S.E. Eckert; B.W. Sullivan; B.A. Hungate; J.P. Kaye; S.C. 

Hart; G.W. Koch; and A. Finkral. (2010). Carbon and water fluxes from ponderosa pine 

forests disturbed by wildfire and thinning. Ecological Applications, 20(3): 663-683.

Drury, J.A.; and M. Boehning. (2013). Professional written correspondence (email) dated August 

13, 2013 between the Apache-Sitgreaves National Forests’ natural resources staff officer 

and plan revision team member, regarding May 18, 2013 Navajo County comment letter, 

pages 18-21. Springerville, AZ.

Ecological Restoration Institute (ERI). (2011). Ecological Restoration Institute Fact Sheet: 

Lessons learned from the Wallow fire. September 2011. Northern Arizona University.

Flagstaff, AZ.
Appendix A

782 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Eisenberg, C.; S. T. Seager; and D.E. Hibbs. (2013). Wolf, elk, and aspen food web relationships: 

Context and complexity. Forest Ecology and Management, 299:70-80.

Fairweather, M.L. (2008). Insect and Disease Activity in Hall Ranch WUI, Springerville RD. File 

Code 3420, Project Report by Forest Pathologist. USDA Forest Service Southwestern 

Region, Forest Health, AZ Zone Office. Flagstaff, AZ. 

Fiedler, C.E.; K.L. Metlen; and E.K. Dodson. (2010). Restoration treatment effects on stand 

structure, tree growth, and fire hazard in a ponderosa pine/Douglas-fir forest in Montana. 

Forest Science 56(1):18-31.

Finkral, A.J.; and A.M. Evans. (2008). The effects of a thinning treatment on carbon stocks in a 

northern Arizona ponderosa pine forest. Forest Ecology and Management, 255: 2743-

2750.

Four Forest Restoration Initiative Stakeholders’ Group (4FRI Stakeholders’ Group). (2011a). Old 

Growth Protection and Large Tree Retention Strategy. September 13, 2011 (revised 

August 2012). Flagstaff, AZ. Available at: http://www.4fri.org/documents.html

Four Forest Restoration Initiative Stakeholders’ Group (4 FRI Stakeholders’ Group). (2011b). 

4FRI Stakeholders’ Group letter to the four forests forest supervisors regarding their large 

tree retention strategy. October 20, 2011. Vosick, D. and E. Smith, Co-Chairs. Flagstaff, 

AZ.

Fulé, P.Z.; T. Swetnam; P. Brown; D. Falk; D. Peterson; C. Allen; G. Aplet; M. Battaglia; D. 

Binkley; C. Farris; R. Keane; E. Margolis; H. Grissino-Mayer; C. Miller; C. Sieg; C. 

Skinner; S. Stephens; and A. Taylor. (2013). Unsupported inferences of high severity fire 

in historical dry forests of the western United States: response to Williams and Baker. 

Global Ecology and Biogeography, 12136. 

Heffelfinger, J.; J.R. Purdue; and K.E. Nicolls. (2002). Is Merriam’s elk really extinct? Wildlife 

Views, 5: 6-10. 

Hoffman, C.; R. Mathiasen; and C.H. Sieg. (2007). Dwarf mistletoe effects on fuel loadings in 

ponderosa pine forests in northern Arizona. Canadian Journal of Forest Research, 37: 

662-670.

Holechek, J.L.; R.D. Pieper; and C.H. Herbel. (1998). Range management: principles and 

practices. 3rd ed. Prentice-Hall, Inc. Upper Saddle River, NJ. 542 pp.

Holthausen, R.S. (2002). White paper on managing for population viability. Draft; July 2002. 

Prepared for the USDA Forest Service Southwestern Region, Albuquerque, NM. 37 pp.

Huang, C.H.; A. Finkral; C. Sorensen; and T. Kolb. (2013). Toward full economic valuation of 

forest fuels-reduction treatments. Journal of Environmental Management, 130 (2013): 

221-231.

Hunter, M.L. Jr. (1990). Wildlife, Forests, and Forestry. Prentice Hall Career & Technology. 

370 pp.

Hurteau, M.; and M. North. (2009). Fuel treatment effects on tree-based forest carbon storage and 

emissions under modeled wildfire scenarios. Frontiers in Ecology and the Environment,

7(8): 409-414.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 783

Hurteau, M.D.; M.T. Stoddard; and P.Z. Fulé. (2010). Fact Sheet: Carbon costs of mitigating high 

severity wildfires. Ecological Restoration Institute (ERI), Northern Arizona University. 

Flagstaff, AZ.

Inman, D. (2000). Blue River Terrain Analysis. unpublished report. 

Jameson, D.A. (1967). The relationship of tree overstory and herbaceous understory vegetation. 

Journal of Range Management, 20(4): 247-249.

Jenkins, M.J.; J.B. Runyon; C.J. Fettig; W.G. Page; and B.J. Bentz.(2014). Interactions among the 

mountain pine beetle, fires, and fuels. Forest Science, 60(3):489-501.

Keane, R. (2013). Disturbance Regimes and the Historical Range of Variation in Terrestrial 

Ecosystems. In S.A. Levin, ed. Encyclopedia of Biodiversity, 2: 568-581. Academic 

Press. Waltham, MA.

Kocis, S.M.; D.B.K. English; S.J. Zarnoch; R. Arnold; and L.Warren (2002). National visitor use 

monitoring results: Apache-Sitgreaves National Forests. National Visitor Use Monitoring

Project, Final Publication, August 2002. Report prepared for USDA Forest Service, 

Southwestern Region. Albuquerque, NM. 22 pp.

Kodric-Brown, A.; and J.H. Brown. (2007). Native fishes, exotic mammals, and the conservation 

of desert springs. Frontiers in Ecology and the Environment, 5(10): 549-553.

Laing, L.; N. Ambos; T. Subirge; C. McDonald; C. Nelson; and W. Robbie. (1987). Terrestrial 

Ecosystem Survey for the Apache-Sitgreaves National Forests. Prepared for USDA 

Forest Service, Southwestern Region. Albuquerque, NM. 453 pp.

Livingston, J. (2004). Small-Diameter Success Stories. USDA Forest Service Forest Lab. 

Madison, WI.

Livingston, J. (2006). Small-Diameter Success Stories II. USDA Forest Service Forest Lab. 

General Technical Report. FPL-GTR-168. Madison, WI.

Livingston, J. (2008). Small-Diameter Success Stories III. USDA Forest Service Forest Lab. 

General Technical Report. FPL-GTR-175. Madison, WI.

Lynch, A.M.; J.A. Anhold; J.D. McMillin; S.M. Dudley; R.A. Fitzgibbon; and M.L. Fairweather. 

(2010). Forest insect and disease activity on the Apache-Sitgreaves NF, and Fort Apache 

Indian Reservation, 1918-2009: Report for the Apache-Sitgreaves NF/Regional Analysis 

Team. February 2010. USDA Forest Service Rocky Mountain Research Station, Tucson, 

Arizona, and USDA Forest Service Southwestern Region Forest Health, Arizona Zone 

Office, Flagstaff, AZ. 40 pp.

Lynch, D.L. (2001). Financial results of ponderosa pine forest restoration in southwestern 

Colorado. In: Vance, R.K.E.; B. Carleton; W.W. Covington; and J.A. Blake (Eds.), 

Ponderosa pine ecosystems restoration and conservation: steps toward stewardship. April 

25-27, 2000, Flagstaff, AZ Proceedings, RMRS-P-22. Ogden, UT: USDA Forest Service, 

Rocky Mountain Research Station. 188 pp.

Margolis, E.Q. (2014). Fire regime shift linked to increased forest density in a piñon-juniper 

savanna landscape. International Journal of Wildland Fire. 23(2): 234-245.

McKinnon, S. (2007). At age 50, dam still generates love, hate. May 28, 2007. Arizona Republic.
Appendix A

784 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

North, M.; M. Hurteau; and J. Innes. (2009). Fire suppression and fuels treatment effects on 

mixed-conifer carbon stocks and emissions. Ecological Applications, 19(6): 1385-1396. 

North, M.P.; and M.D. Hurteau. (2011). High severity wildfire effects on carbon stock and 

emissions in fuels treated and untreated forest. Forest Ecology and Management, 261(6): 

1115-1120.

Parker, T.J.; K.M. Clancy; and R.L. Mathiasen. (2006). Interactions among fire, insects, and 

pathogens in coniferous forests of the Interior Western United States and Canada. 

Agricultural and Forest Entomology, 8: 167-189.

Rasure, N.B; and T.C. Harbor. (2011). Integration of silvicultural prescriptions and prescribed fire 

burn plans. USDA Forest Service Washington Office policy letter from Directors of 

Forest and Fire/Aviation Management to Regional Foresters, file code 2470/5150. 

Washington, D.C.

Reynolds, R.T.; R.T. Graham; M.H. Reiser; and others. (1992). Management recommendations 

for the northern goshawk in the southwestern United States. General Technical Report 

RM-217. USDA Forest Service, Rocky Mountain Forest and Range Experiment Station.

Fort Collins, CO. 90 pp.

Reynolds, R.T.; A.J. Sanchez Meador; J.A. Youtz; T. Nicolet; M.S. Matonis; P.L. Jackson; D. G. 

DeLorenzo; and A.D. Graves. (2013). Restoring the composition and structure in 

southwestern frequent-fire forests: a science-based framework for improving ecosystem 

resiliency. General Technical Report RMRS-GTR-310. USDA Forest Service, Rocky 

Mountain Research Station. Fort Collins, CO. 76 pp.

Ripple, W.J.; and R.L. Beschta. (2011). Trophic cascades in Yellowstone: The first 15 years after 

wolf reintroduction. Biological Conservation, 145(1): 205-213.

Robichaud, P.R.; L.E. Ashmun; and B.D. Sims. (2010). Post-Fire Treatment Effectiveness for 

Hillslope Stabilization. General Technical Report RMRS-GTR-240. USDA Forest 

Service, Rocky Mountain Forest and Range Experiment Station. Fort Collins, CO. 62 pp.

Robichaud, P.R.; J. Wagenbrenner; and S. Larson. (2014). Wallow Fire Emergency Response 

Seeding Monitoring Project, 2013 Progress Report. unpublished report.

Rogers, P.C. (2009). August 25, 2009 letter to Apache-Sitgreaves Forest Supervisor, regarding: 

aspen decline condition in Northern Arizona; by Director of Western Aspen Alliance and 

professor at Utah State University Wildland Resources Department, Logan UT.

Rogers, P.C. (2011). Letter, dated October 24, 2011, to USFS Southwestern Regional Forester 

summarizing post-Wallow Fire aspen conditions and regeneration monitoring field visit 

(under USFS Region 3 Forest Health Cooperative Agreement No. 11-PA-11031600-080), 

by Director of Western Aspen Alliance and professor at UT State University Wildland 

Resources Department, Logan UT. [online] URL: http://www.western-aspen-alliance.org/

Ryan, M.G.; M.E. Harmon; R.A. Birdsey; C.P. Giardina; L.S. Heath; R.A. Houghton; R.B. 

Jackson; D.C. McKinley; J.F. Morrison; B.C. Murray; D.E. Pataki; and K.E. Skog. 

(2010). A synthesis of the science on forests and carbon for U.S. forests. Issues in 

Ecology, Report Number 13, Spring 2010. Washington, D.C.

Shepperd, W.D.; and M.L. Fairweather.(1994). Impact of large ungulates in restoration of aspen 

communities in a southwestern ponderosa pine ecosystem. Pp. 344-347. In: Covington, 
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 785

W.W.; and L.F. DeBano (tech. coords.), Sustainable ecological systems: implementing an 

ecological approach to land management. 1993 July 12-15; Flagstaff, Arizona. General 

Technical Report RMRS-GTR-247, USDA Forest Service, Rocky Mountain Research 

Station. Fort Collins, CO. 363 pp.

Snider, G.; P.J. Daugherty; and D. Wood. (2006). The irrationality of continued fire suppression: 

an avoided cost analysis of fire hazard reduction treatments versus no treatment. Journal 

of Forestry, 104(8): 431-437.

Thill, R.E.; P.F. Folliott; and D.R. Patton. (1983). Deer and elk forage production in Arizona 

mixed conifer forests. Research Paper RMRS-RP-248. USDA Forest Service, Rocky 

Mountain Research Station. Fort Collins, CO. 13 pp.

Thomas, J.W.; and D.E. Toweill (eds.). (1982). Elk of North America: Ecology and Management. 

Stockpole Books, Harrisburg, PA. 698 pp.

Triepke, F.J.; B. J. Higgins; R. N. Weisz; J. A. Youtz; and T. Nicolet. (2011). Diameter caps and 

forest restoration - Evaluation of a 16-inch cut limit on achieving desired conditions. 

Forestry Report FR-R3-16-3. USDA Forest Service, Southwestern Region, Regional 

Office. Albuquerque, NM. 31 pp.

U.S. Department of Agriculture (USDA), Forest Service, and U.S. Department of the Interior 

(USDOI), Bureau of Land Management, Fish and Wildlife Service, and National Park 

Service. (2012). Minimum Requirements Decision Guide. Available at: 

http://www.wilderness.net/MRA

U.S. Department of Interior, Bureau of Land Management (BLM). (1998). Riparian area 

management: a user guide to assessing proper functioning condition and the supporting 

science for lotic areas. D. Prichard; J. Anderson; C. Correll; J.Fogg; K.Gebhardt; R. 

Krapf; S. Leonard; B. Mitchell; and J. Staats (working group). Technical Reference 1737-

15, USDI Bureau of Land Management, Service Center. Denver, CO. BLM/RS/ST98/001+1737. 134 pp.

U.S. Department of Interior, Bureau of Land Management (BLM). (1999). Riparian area 

management: a user guide to assessing proper functioning condition and the supporting 

science for lentic areas. (revised 2003). D. Prichard; F. Berg; W. Hagenbuck; R. Krapf; R. 

Leinard; S. Leonard; M. Manning; C. Noble; and J. Staats (working group). Technical 

Reference 1737-16, USDI Bureau of Land Management, Service Center, Denver, CO. 

BLM/RS/ST-99/001+1737+REV03. 118 pp.

U.S. Department of Interior, Bureau of Land Management (BLM). (2011). Multiple Indicator 

Management of stream channels and streamside vegetation. T. Burton; S. Smith; and E.

Cowley (working group). Technical Reference 1737-23, USDI Bureau of Land 

Management, Service Center, Denver, CO. BLM/OC/ST-10/003+1737. 155 pp.

U.S. Department of Interior, Fish and Wildlife Service (USFWS). (1995). Recovery Plan for the 

Mexican Spotted Owl: Volume I. USDI Fish and Wildlife Service, Southwest Region. 

Albuquerque, NM.

U.S. Department of Interior, Fish and Wildlife Service (USFWS). (1996). Reintroduction of the 

Mexican Wolf within its Historic Range in the Southwestern United States Final 
Appendix A

786 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

Environmental Impact Statement. USDI Fish and Wildlife Service, Southwest Region. 

Albuquerque, NM.

U.S. Department of Interior, Fish and Wildlife Service (USFWS). (2012). Final Recovery Plan for 

the Mexican Spotted Owl (Strix occidentalis lucida), First Revision. USDI Fish and 

Wildlife Service, Southwest Region. Albuquerque, NM. 413 pp.

U.S. Environmental Protection Agency (EPA) (2003). National Management Measures for the 

Control of Nonpoint Pollution from Agriculture. USEPA, Office of Water. Washington 

D.C.

U.S. Forest Service. (1983). Analysis of the Management Situation Apache-Sitgreaves National 

Forests. USDA Forest Service, Southwestern Region. Albuquerque, NM.

U.S. Forest Service. (1987). Environmental Impact Statement for the Apache-Sitgreaves National 

Forests Plan. USDA Forest Service, Southwestern Region. Albuquerque, NM. 392 pp.

U.S. Forest Service. (1993). Resource Information Report: Potential Wild/Scenic/Recreational 

River Designation, National Forests of Arizona. USDA Forest Service, Southwestern 

Region. Albuquerque, NM.

U.S. Forest Service. (1999). Region 3 Rangeland Analysis and Management Training Guide. 

USDA Forest Service, Southwestern Region. Albuquerque, NM. 224 pp.

U.S. Forest Service. (2005). Memorandum of Understanding Among Apache-Sitgreaves National 

Forests, Arizona Elk Society, and Livestock Permittees. FS Agreement No. 05-MU11030121-012. USDA Forest Service, Apache-Sitgreaves National Forests. Springerville, 

AZ.

U.S. Forest Service. (2006). Northern Goshawk Inventory and Monitoring Technical Guide. 

General Technical Report W0-71. 

U.S. Forest Service. (2007). R3 Wilderness Need Assessment Instructions. USDA Forest Service, 

Southwestern Region. Albuquerque, NM. 6 pp.

U.S. Forest Service. (2008a). Comprehensive Evaluation Report: Apache-Sitgreaves National 

Forests. USDA Forest Service, Southwestern Region. Springerville, AZ. 40 pp.

U.S. Forest Service. (2008b). Decision Notice and Finding of No Significant Impact: 

Environmental Assessment for the A-SNFs Integrated Forest-Wide Noxious or Invasive 

Weed Management Program. USDA Forest Service, Apache-Sitgreaves National Forests. 

Springerville, AZ. 194 pp.

U.S. Forest Service. (2008c). Ecological Sustainability Report. Apache-Sitgreaves National 

Forests. USDA Forest Service, Southwestern Region. Springerville, AZ. 139 pp.

U.S. Forest Service. (2008d). Identification of Lands Generally Suitable for Livestock Grazing. 

Plan Revisions, Version 2.0 – September 2008. USDA Forest Service, Southwestern 

Region.

U.S. Forest Service. (2009a). Chitty fire salvage sale silviculture specialist report. Analysis report 

prepared for the Alpine Ranger District by the Apache-Sitgreaves National Forests zoned 

silviculturist, M. Boehning, dated February 24, 2009. 49 pp.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 787

U.S. Forest Service. (2009b). Eligibility Report for the National Wild and Scenic River System. 

USDA Forest Service, Apache-Sitgreaves National Forests. Springerville, AZ.

U.S. Forest Service (2009c). Regional Demand for Wilderness, Southwestern Region. USDA 

Forest Service, Southwestern Region. Albuquerque, NM. 12 pp.

U.S. Forest Service. (2009d). Research Natural Area Process for Forest Plan Revision Under the 

1982 Planning Rule Provisions. Southwestern Region RNA Work Group. USDA Forest 

Service, Southwestern Regional Office. Albuquerque, NM. 19 pp.

U.S. Forest Service. (2009e). Special Areas and Forest Plan Revision Region 3 Work Group 

Product. USDA Forest Service, Southwestern Regional Office. Albuquerque, NM. 33 pp.

U.S. Forest Service. (2009f). Regional direction for compliance with the 1982 Planning Rule 

Provisions, Sections 219.14(a)(c). version 3.0. October 2009. USDA Forest Service, 

Southwest Regional Office. Albuquerque, NM.

U.S. Forest Service. (2010a). Final Environmental Assessment for Blue River and KP Creek Wild 

and Scenic Suitability. USDA Forest Service, Apache-Sitgreaves National Forests. 

Springerville, AZ.

U.S. Forest Service. (2010b). Apache-Sitgreaves National Forests CER Supplement to meet AMS 

Requirements. USDA Forest Service, Apache-Sitgreaves National Forests. Springerville, 

AZ. 10 pp.

U.S. Forest Service. (2011a). Technical Guide to Managing Water Resources. USDA Forest 

Service, Minerals and Geology Management/Watershed, Fish, Wildlife, Air & Rare 

Plants/Engineering. FS-881. Washington D.C. 281 pp.

U.S. Forest Service. (2011b). Watershed Condition Framework-A Framework for Assessing and 

Tracking Changes to Watershed Condition FS-977. Washington D.C. 32 pp.

U.S. Forest Service. (2012a). Capability, Availability and Need Ratings Documentation. USDA 

Forest Service, Apache-Sitgreaves National Forests. Springerville, AZ. Available at:

http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606

U.S. Forest Service. (2012b). Final Potential Wilderness Evaluation Reports. USDA Forest 

Service, Apache-Sitgreaves National Forests. Springerville, AZ. Available at:

http://www.fs.usda.gov/detail/asnf/landmanagement/planning/?cid=stelprdb5405606

U.S. Forest Service. (2012c). Research Natural Areas (RNAs) of the Apache-Sitgreaves NFs and 

the Revision of the Forest Plan. USDA Forest Service, Apache-Sitgreaves National 

Forests. Springerville, AZ. 41 pp.

U.S. Forest Service. (2012d). Wallow Fire Changed Condition Assessment. USDA Forest Service, 

Apache-Sitgreaves National Forests. Springerville, AZ. 

U.S. Forest Service. (2012e). Wilderness Need Evaluation Tables. USDA Forest Service, ApacheSitgreaves National Forests. Springerville, AZ. Available at:

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5406404.pdf

U.S. Forest Service. (2013a). Desired Conditions for Use in Forest Planning in the Southwestern 

Region: Development and Science Basis. unpublished white paper. (updated August 

2013). USDA Forest Service, Southwestern Region. Albuquerque, NM.
Appendix A

788 Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan

U.S. Forest Service. (2013b). Technical Guidance for Soil Quality Monitoring in the 

Southwestern Region. USDA Forest Service, Southwestern Region. Albuquerque, NM. 

U.S. Forest Service. (2013c). Memorandum of understanding between the State of Arizona 

Department of Environmental Quality and the USDA Forest Service: AZ water quality 

protection agreement. No. 13-MU-11031500-12. USDA Forest Service, Southwestern 

Region. Albuquerque, NM.

U.S. Forest Service. (2014a). Fisheries Specialist Report Forest Plan Revision FEIS. USDA 

Forest Service, Apache-Sitgreaves National Forests, Southwestern Region. Springerville, 

AZ.

U.S. Forest Service. (2014b). Forest Health Specialist Report Forest Plan Revision FEIS. USDA 

Forest Service, Apache-Sitgreaves National Forests, Southwestern Region. Springerville, 

AZ.

U.S. Forest Service. (2014c). Forest Products Specialist Report Forest Plan Revision FEIS. 

USDA Forest Service, Apache-Sitgreaves National Forests, Southwestern Region. 

Springerville, AZ.

U.S. Forest Service. (2014d). Minerals and Energy Specialist Report Forest Plan Revision FEIS. 

USDA Forest Service, Apache-Sitgreaves National Forests, Southwestern Region. 

Springerville, AZ.

U.S. Forest Service. (2014e). Report on the Selection of Management Indicator Species and 

Ecological Indicators USDA Forest Service, Apache-Sitgreaves National Forests, 

Southwestern Region. Springerville, AZ.

U.S. Forest Service. (2014f). Riparian Specialist Report Forest Plan Revision FEIS. USDA Forest 

Service, Apache-Sitgreaves National Forests, Southwestern Region. Springerville, AZ.

U.S. Forest Service. (2014g). Vegetation Specialist Report Forest Plan Revision FEIS. USDA 

Forest Service, Apache-Sitgreaves National Forests, Southwestern Region. Springerville, 

AZ. 441 pp.

U.S. Forest Service. (2014h). Water Specialist Report Forest Plan Revision FEIS. USDA Forest 

Service, Apache-Sitgreaves National Forests, Southwestern Region. Springerville, AZ.

U.S. Forest Service. (2014i). Watershed Specialist Report Forest Plan Revision FEIS. USDA 

Forest Service, Apache-Sitgreaves National Forests, Southwestern Region. Springerville, 

AZ.

U.S. Forest Service. (2014j). Wilderness Resources and Inventoried Roadless Areas Specialist 

Report Forest Plan Revision FEIS. USDA Forest Service, Apache-Sitgreaves National 

Forests, Southwestern Region. Springerville, AZ.

U.S. Forest Service. (2014k). Wildlife Specialist Report - Biological Assessment [i.e., the ESA 

species]. USDA Forest Service, Apache-Sitgreaves National Forests, Southwestern 

Region. Springerville, AZ.

U.S. Forest Service. (2014l). Wildlife Specialist Report - Viability. USDA Forest Service,

Apache-Sitgreaves National Forests, Southwestern Region. Springerville, AZ.
Appendix A

Programmatic FEIS for the Apache-Sitgreaves NFs Land Management Plan 789

U.S. Forest Service. (2014m). Wildlife Quiet Areas (WQAs) and Habitat Linkages Report. USDA 

Forest Service, Apache-Sitgreaves National Forests, Southwestern Region. Springerville, 

AZ.

U.S. Natural Resource Conservation Service (NRCS). (2014). National Soil Survey Handbook: 

430-VI-NSSH. USDA Natural Resource Conservation Service. Washington D.C.

Vander Lee, B.; R. Smith; and J. Bate. (2006). Methods, Chapter 2, pp. 2-1 - 2-29. In: B. Vander 

Lee; and R. Smith (eds.), Ecological and biological diversity of National Forests in 

Region 3. Southwest Forest Assessment Project. The Nature Conservancy. Tucson, AZ.

148 pp.

Wadleigh, L. (2011). White Paper H: Fire Modeling Rationale. (One of 16 papers in the regional 

white paper series titled “The R3 FVS Process for Evaluating the Effects of Vegetation

Management Activities in the Forest Plan Revision Process”). Interoffice publication.

USDA Forest Service, Southwestern Region, Regional Office. Albuquerque, NM. 

Weisz, R. (2011). White Paper C: Background of State and Transition Models in the R3 Forest 

Plan Revision Process(One of 16 papers in the regional white paper series titled “The R3 

FVS Process for Evaluating the Effects of Vegetation Management Activities in the 

Forest Plan Revision Process”). Interoffice publication. USDA Forest Service, 

Southwestern Region, Regional Office. Albuquerque, NM. 

Weisz, R.; and D. Vandendriesche (2014). White Paper A: Introduction: The R3 FVS Process for 

Evaluating the Effects of Vegetation Management Activities in the Forest Plan Revision 

Process. Interoffice publication. USDA Forest Service, Southwestern Region, Regional 

Office. Albuquerque, NM. 

Weisz, R.; D. Vandendriesche; and M. Moeur. (February 2012). White Paper O - Overview of 

How We Created VDDT Models with FVS - Calibrating Natural and Anthropogenic 

Events in State and Transition Models with FVS: A case study for ponderosa pine forest 

ecosystems. (One of 16 papers in the regional white paper series titled “The R3 FVS 

Process for Evaluating the Effects of Vegetation Management Activities in the Forest 

Plan Revision Process”). USDA Forest Service, Southwestern Region, Regional Office.

Albuquerque, NM. Interoffice publication.

Whittaker, R.; and W. Niering. (1964). Vegetation of the Santa Catalina Mountains, Arizona. 

Ecological classification and distribution of species. Journal of Arizona Academy of 

Science, 3(1): 9-34. 

Winward, A.H. (2000). Monitoring the vegetation resources in riparian areas. General Technical 

Report RMRS-GTR-46. USDA Forest Service, Rocky Mountain Research Station, 

Ogden, UT. 49 pp

Wu, J.; K. Skelton-Groth; W.G. Boggess; and R.M. Adams. (2003). Pacific Salmon Restoration: 

Trade-Offs Between Economic Efficiency and Political Acceptance. Contemporary 

Economic Policy, 21(1): 78-89.