United States 

Department of

Agriculture

Forest 

Service

Southwestern

Region

MB-R3-10-15

June 2012

Final Environmental 

Impact Statement for 

Travel Management on 

the Santa Fe National 

Forest

Santa Fe, New Mexico
Cover Photo: Boulders moved to drive on a road.

Note: All photos used in this document were taken by Santa Fe National Forest employees except where 

noted otherwise.

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Printed on recycled paper – June 2012
FEIS for Travel Management on the Santa Fe National Forest i

Final Environmental Impact Statement for 

Travel Management on the Santa Fe National Forest

Santa Fe, New Mexico

Lead Agency: USDA Forest Service

Responsible Official: Maria T. Garcia, Forest Supervisor

Santa Fe National Forest

11 Forest Lane

Santa Fe, NM 87508

For Information Contact: Julie Bain 

Santa Fe National Forest 

11 Forest Lane 

Santa Fe, NM 87508

(505) 438-5443

Abstract: The forest supervisor of the Santa Fe National Forest proposes to make changes to the 

current system of roads, trails, and areas open to motorized use. The result will be fewer roads, 

motorized trails, and specific areas designated for motorized use. Motorized cross-country 

travel—driving off of roads or motorized trails—will be prohibited except in designated 

motorized areas and fixed-distance corridors solely for the purpose of motorized dispersed 

camping or motorized big game retrieval. Part of the proposal amends the “Santa Fe National 

Forest Plan” to comply with the Travel Management Rule, which implements Executive Orders 

11644 and 11989. This document analyzes five action alternatives showing different motorized 

systems. The action alternatives are based on the public’s comments during the scoping and 

notice and comment periods. The forest supervisor’s preferred alternative is 2M, which modifies 

slightly alternative 2 based on public comments during the notice and comment period. 

To Review the Large Maps of the Alternatives: The Santa Fe National Forest’s headquarters 

and seven ranger district offices (Coyote, Cuba, Jemez, Pecos, Las Vegas, Los Alamos, and 

Española) have large maps, 34 by 44 inches, for people to review. Most printing and copy 

businesses can print maps from a CD, the Internet, or a thumb drive.

Appeals: Pursuant to the regulations at 36 CFR 215, people and organizations who commented 

on the draft environmental impact statement during the notice and comment period that ran from 

August 7 to September 30, 2010, have standing to appeal the forest supervisor’s decision. People 

who commented anonymously or outside of the notice and comment period do not have standing 

to appeal. Appeals received, including the names and addresses of those who appeal, will be part 

of the public record. 

How to Submit an Appeal: You must submit your appeal within 45 days after the legal notice of 

decision is published in the Albuquerque Journal. The publication date of the legal notice is the 

exclusive means for calculating the time to file an appeal (§215.15 (a)). Do not rely upon dates or 

timeframe information provided by any other source. The content of your appeal must meet the 

requirements described in § 215.14.
ii FEIS for Travel Management on the Santa Fe National Forest

Appeals may be delivered by facsimile, hand, U.S. mail, express delivery service, or email. 

Acceptable electronic formats are text in the body of an email or an attachment (.pdf, .doc, .txt, 

.rtf, or other formats readable by Microsoft Word).

Send Appeals to: Corbin Newman, Appeal Deciding Officer

Southwestern Region

333 Broadway Blvd., SE

Albuquerque, NM 87102

Fax number: (505) 842-3173

Email address: appeals-southwestern-regional-office@fs.fed.us

Appeals may be hand delivered to the above address during regular business hours from 8:00 am 

to 4:30 pm. 

Implementation: If no appeal is filed within the 45-day time period, implementation of the 

decision may begin on, but not before, the 5th business day following the close of the appealfiling period (§215.15).

When an appeal is filed, implementation may occur on, but not before, the 15th business day 

following the date of appeal disposition (§215.2). In the event of multiple appeals of the decision, 

the implementation date is controlled by the date of the last appeal disposition.
FEIS for Travel Management on the Santa Fe National Forest iii

Summary

To comply with the Travel Management Rule, the Santa Fe National Forest’s forest supervisor

proposes to provide for a system of roads, trails, and areas designated for motorized use by 

making changes to the current motorized travel system. The proposed changes will reduce the 

places where people can drive in the Santa Fe National Forest, which is the area this proposal 

encompasses. The proposed changes do not restrict where people’s nonmotorized activities—such 

as hiking, camping, bicycling, hunting, and others—may take place.

Background

To address concerns about the effects of unmanaged off-highway vehicles, the Forest Service 

published final travel management regulations for motor vehicle use on national forests and 

grasslands on November 9, 2005. The Travel Management Rule “... provides for a system of 

National Forest System roads, National Forest System trails, and areas on National Forest 

System lands that are designated for motor vehicle use. After these roads, trails, and areas are 

designated, motor vehicle use, including the class of vehicle and time of year, not in accordance 

with these designations is prohibited...”

A motor vehicle use map published by the Santa Fe National Forest (forest) will show where 

people are allowed to drive. The motor vehicle use map enforces the system designated for 

motorized use. People will only be allowed to drive on the roads, trails, and areas depicted on the 

motor vehicle use map. If they drive places that aren’t on the map, they will be subject to a fine 

unless they have a permit or other authorization from the Forest Service. Because the forest will 

publish the motor vehicle use map annually, roads, trails, and areas can be added or removed each 

year after the appropriate environmental analysis is done.

Regardless of the designations published on the motor vehicle use map, the forest supervisor will 

continue to have the ability to temporarily close roads, trails, or areas to motorized use based on a 

determination of considerable adverse effects (36 CFR 212.52(b)(2)).

Purpose and Need

The purpose of this project is to comply with the Travel Management Rule by providing a system 

of roads, trails, and areas designated for motor vehicle use by class of vehicle and time of year on 

the Santa Fe National Forest (36 CFR 212.50).

On the Santa Fe National Forest, complying with the Travel Management Rule means there is a 

need for: (1) no cross-country motorized travel except in designated areas; (2) clarification of 

which roads and trails would be open for motorized use; (3) the optional designation of the 

limited use of motor vehicles within a specified distance of certain designated routes and, if 

appropriate, within specified time periods, solely for the purposes of dispersed camping or 

retrieval of a big game animal by an individual who has legally killed that animal; and (4) 

amended forest plan direction regarding motorized vehicle use that is consistent with the rule. 

There is also a need for fewer detrimental effects to natural and cultural resources from 

unmanaged motorized use and the existence of roads and motorized trails. Here are examples—

taken from chapter 3 of this document—of the detrimental effects caused by unmanaged 

motorized use and the presence of roads and motorized trails:
Summary

iv FEIS for Travel Management on the Santa Fe National Forest

• Motorized cross-country travel can create new roads and trails that aren’t properly 

designed. The presence of roads and motorized trails interrupts the natural flow of water, 

channeling it and carrying sediment to streams. Sediment deposited into streams degrades 

water quality and habitat for fish.

• Vehicles transport nonnative invasive plant seeds to and within the forest. Roads and 

motorized trails act as pathways for these seeds. The establishment and spread of 

nonnative invasive plants disrupts native ecological processes, resulting in fewer native 

plants and animals.

• Roads and motorized trails fragment habitat for wildlife. Many small mammals and 

reptiles don’t cross roads, which isolates populations and promotes inbreeding, resulting 

in reduced population viability. Small mammals and reptiles also risk being killed by 

vehicles. Large mammals tend to avoid vehicles, roads, and motorized trails, altering 

where they would normally live and breed.

• Driving off roads and motorized trails can damage cultural resource sites. Wheels crush 

artifacts. Erosion caused by driving can wash away sites. With vehicles, people have 

easier access to cultural resource sites and may intentionally or unintentionally damage 

them.

Public Involvement

From early 2006 to late 2007, Santa Fe National Forest staff held 38 public meetings and 

workshops and attended many field trips. This collaborative period generated more than 1,000 

comment letters from the public. We used the information gathered at meetings and from the 

letters to create the proposed action for managing motorized travel. The forest supervisor

published the proposed action on July 10, 2008.

Publishing the proposed action marked the start of the scoping comment period, during which we 

asked the public for comments on the proposal. We mailed notice of the proposed action to 

10,270 people and held 13 public meetings. In response, we received almost 1,400 letters and 

emails. The content of the letters and emails formed the basis of the alternatives and 

environmental analysis contained in the “Draft Environmental Impact for Travel Management on

the Santa Fe National Forest” (DEIS).

The forest supervisor published the draft environmental impact statement on July 22, 2010, and 

held eight meetings for the public to discuss the alternatives and analysis. The notice and 

comment period ran from August 7 through September 30, 2010. We received over 850 comment 

letters on the draft environmental impact statement.

Forest staff have consulted with tribes and pueblos throughout the process.

Significant Issues

Reading and analyzing the public’s scoping letters resulted in a list of issues. Significant issues 

form the basis of alternatives to the proposed action. They are issues not resolved by the proposed 

action. We identified these five significant issues from the scoping comment letters:

1. Continued public motorized use of routes and areas described in the proposed action will 

adversely affect forest resources. These effects include:
Summary

FEIS for Travel Management on the Santa Fe National Forest v

• Erosion, soil compaction, and degradation of water quality and watershed condition;

• Degradation of fish and wildlife habitat;

• Damage to cultural resource sites;

• Damage to traditional cultural properties;

• Spread of invasive plant species;

• Damage to rare plants; and

• Compromise to the character of wilderness and inventoried roadless areas.

2. The reduction in miles of routes and the prohibition of cross-country travel described in 

the proposed action will adversely affect the quantity of public motorized experiences 

because the proposed action:

• Lacks enough loops and connectors to provide for longer rides;

• Lacks diverse opportunities for all-terrain vehicles, motorcycles, and 4x4s;

• Lacks diverse routes for different skill levels;

• Restricts access to traditional cultural properties;

• Does not provide enough area for motorcycle trials; 

• Closes too many routes, which will concentrate use and take away the semiprimitive 

aspect of riding in the forest; and

• Does not plan for the future growth in motorized sports.

3. Prohibiting motorized cross-country travel will limit the retrieval of big game, perhaps to 

an unacceptable level.

4. Designating motorized dispersed camping corridors will increase cross-country travel and 

the resource damage associated with it and curtail the kind of unrestricted camping that 

the Santa Fe National Forest currently provides.

5. The proposed action, by designating routes uniformly across the forest outside of 

designated wilderness, will cause conflicts between motorized and nonmotorized users 

because they will be recreating in the same vicinity.

Using these significant issues, we created three alternatives to the proposed action and presented 

them in the draft environmental impact statement. The public then commented on the draft. 

Although we received a lot of comments on the DEIS, we did not receive any comments with 

new significant issues. Our complete response to the public’s comments is located in appendix 7.

The regulations at 40 CFR 1503.4 give an agency five different ways to respond to the public’s 

comments on a draft environmental impact statement. One of the ways is to modify an existing 

alternative. After reading the public’s comments on the draft environmental impact statement, we 

modified an existing alternative—the proposed action—to best meet the public’s need for access 

while balancing that against protecting natural resources. This final environmental impact 

statement, then, contains six alternatives: the no action alternative required by the regulations, the 

proposed action, and four alternatives to the proposed action.
Summary

vi FEIS for Travel Management on the Santa Fe National Forest

Alternatives

Alternative 1 is the no action alternative. For this project, the no action is the same as the existing 

condition. It is our best estimate of where people drive now. Where people drive now represents 

no change from current management direction or level of management intensity (NEPA’s Forty 

Most Asked Questions, http://ceq.hss.doe.gov/nepa/regs/40/1-10.HTM#3). For example, if the 

forest didn’t make any changes to the motorized system, people would continue to drive where 

they pleased.

Alternative 2 is the proposed action, which is the forest’s first attempt at meeting the purpose and 

need. The proposed action described in this document differs slightly from the one mailed to the 

public in July 2008 (36 CFR 220.5(e)(1)). It corrects the locations of roads and motorized trails 

based on the public’s comments and our field verification. It also adds the ability to retrieve big 

game with a vehicle in the same fixed-distance corridors proposed for motorized dispersed 

camping.

Alternative 2M is similar to alternative 2, the proposed action, but modified as a result of the 

public’s comments on the draft environmental impact statement and our subsequent analysis. It is 

the forest supervisor’s preferred alternative. It incorporates concerns raised in significant issues 1, 

2, 3, and 4. It would designate fewer miles of roads, motorized trails, and fixed-distance corridors 

than alternative 2. 

Alternative 3 would provide the fewest miles of designated roads and motorized trails. It proposes 

no driving off roads or motorized trails for any reason. This means that to camp, retrieve game, or 

participate in any other forest activity, people would have to park next to the side of the road and 

proceed without their vehicles. It incorporates concerns raised in significant issues 1, 3, and 4.

Alternative 4 would provide more roads, motorized trails, and areas designated for motorized use 

than the proposed action, but still less than the amount people drive on now. It would allow the 

most places for people to drive to retrieve game or set up a campsite. It incorporates concerns 

raised in significant issues 2, 3, and 4.

Alternative 5 would provide about the same amount of roads, motorized trails, and areas 

designated for motorized use as the proposed action, but arranges motorized use geographically. 

This means that alternative 5 attempts to cluster motorized use in certain places on the forest, 

leaving other places with less motorized use. It incorporates concerns raised in significant issue 5.

Alternatives 2 through 5 nearly eliminate motorized cross-country travel. 

Except for alternative 4, alternatives 2 through 5 decrease the mileage of motorized trails from 

what people said they use now. Alternatives 2 through 5 all increase the miles of motorized 

system trail—those trails officially managed by the Forest Service for motorized use.

Figure 1, figure 2, and table 1 compare the resultant motorized system to and change from 

alternative 1 for each alternative.
Summary

FEIS for Travel Management on the Santa Fe National Forest vii

Figure 1. Summary of the miles of roads and motorized trails that would result 

from each alternative, and their overall percent change from alternative 1, the 

existing condition

Figure 2. Comparison of acres available for driving off road, by alternative. 

Percent change is not depicted because some acres can be used in more 

than one way. For instance, the corridors for dispersed camping and for 

retrieving big game are the same in alternative 2.
Summary

viii FEIS for Travel Management on the Santa Fe National Forest

Table 1. Comparison of motorized system resulting from changes to alternative 1, the 

existing condition

Where 

People 

Drive Now

Resultant Motorized System, by Action Alternative

Alternative 1 2 2M 3 4 5

Roads

Miles 5,218 2,290 2,255 1,817 2,554 2,231

Percent change 

from alternative 1 -56% -57% -65% -51% -57%

Motorized 

trails

Miles 408 263 208 53 462 306

Percent change 

from alternative 1 -36% -49% -87% 13% -25%

Total roads 

and 

motorized 

trails

Miles 5,626 2,552 2,463 1,869 3,017 2,573

Percent change 

from alternative 1 -55% -56% -67% -46% -55%

Motorized 

areas

Acres 433,848 40 41 0 49 35

Percent change 

from alternative 1 -100% -100% -100% -100% -100%

Motorized 

access to 

dispersed 

camping

Miles 17,195 16,237 13,856 0 32,890 11,422

Percent change 

from alternative 1 -6% -19% -100% 91% -34%

Motorized 

access for 

big game 

retrieval

Miles 1,258,361 16,237 13,856 0 1,098,330 370,841

Percent change 

from alternative 1 -99% -99% -100% -13% -71%

Conclusions About the Effects of the Alternatives 

The effects of this project can be split into two types: (1) effects to people and how they use the 

forest, called “social effects” here, and (2) effects to natural and cultural resources. Social effects 

include things like opportunities for motorized access and recreation, motorized access to private 

land, noise, conflicts between people, and loss of jobs and revenue associated with motorized use 

of the national forest. Natural and cultural resources include soil, water, habitat for fish and

wildlife, nonnative invasive plants, cultural resource sites, air, wildfires, and visual quality. 

Chapter 3 examines effects to these and other resources in detail. 

For motorized opportunities, choosing any of the action alternatives (2 through 5) significantly 

reduces the places where people can drive in the Santa Fe National Forest from the existing 

condition. The total amount of roads and trails open for motorized use would be reduced by 46 to 

67 percent depending on the alternative selected, and virtually no driving off roads or motorized 

trails would be allowed. People’s ability to drive to a dispersed campsite or to retrieve big game 

would be restricted to corridors designated for such use.

Limiting where people can drive may alter some people’s ability to enjoy the national forest in the 

manner they are accustomed to. Being able to drive on about half as many roads and trails means 

people might not be able to drive to their recreational destination. This applies to motorized and 

nonmotorized uses of the forest. Some people may no longer be able to get to a hiking spot, for 
Summary

FEIS for Travel Management on the Santa Fe National Forest ix

instance. For those with limited time or physical ability, some destinations would be rendered 

inaccessible. Exploring or touring by driving off roads or trails would no longer be allowed. 

Some people’s favorite trails would not be open to motorcycles or ATVs. Some people indicated 

that curtailing motorized use of the national forest unacceptably limits their freedom.

That said, people who value motorized access and recreation are most likely to favor alternative 4 

because it preserves more motorized opportunities than the other action alternatives. Though the 

biggest change is between alternative 1 and the others, drivers and riders would want to forfeit as 

few motorized opportunities as possible. Proponents of nonmotorized use of the national forest 

are most likely to favor alternative 3, which proposes the fewest miles of motorized routes and no 

driving off road for any reason.

Fewer open routes and less motorized cross-country use tend to be more protective of natural and 

cultural resources. As a result, choosing any of the action alternatives (2 through 5) tends to 

maintain or increase the protection of natural and cultural resources from the existing condition. 

Alternative 3 would best protect natural and cultural resources because it would allow the least 

amount of driving and no motorized travel off road. 

Most natural and cultural resources would benefit from any of the action alternatives. But a few 

resources—soil, water, and fish—have exceptions. The motorized dispersed camping proposed in 

alternative 4 would move soil and water quality away from the desired conditions listed in the 

forest plan and the Clean Water Act. Alternatives 4 and 5 propose a motorized trail that runs 

partially up Polvadera Creek, home to one of the Santa Fe National Forest’s core conservation 

populations of Rio Grande cutthroat trout.

Decision to Be Made

Based on public comment, the effects to social, natural, and cultural resources, and the criteria 

listed in the Travel Management Rule at 36 CFR 212.55, the forest supervisor will decide what 

changes to make to the current motorized travel system. The “record of decision” will document 

her decision and the reasons for it.
FEIS for Travel Management on the Santa Fe National Forest xi

Contents

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

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

Background...................................................................................................................................1

Location........................................................................................................................................2

Purpose and Need.........................................................................................................................3

Decision to be Made.....................................................................................................................4

Public Involvement.......................................................................................................................5

Important Notes..........................................................................................................................10

Chapter 2. Alternatives, Including the Proposed Action.........................................................13

Introduction ................................................................................................................................13

Alternatives Considered in Detail...............................................................................................16

Mitigations..................................................................................................................................43

Alternatives Considered but Not Studied in Detail ....................................................................44

Comparison of Alternatives........................................................................................................56

Chapter 3. Affected Environment and Environmental Consequences...................................63

The Basic Components of an Effects Analysis...........................................................................63

Affected Environment and Environmental Consequences.........................................................78

Recreation – Affected Environment...........................................................................................79

Social and Economic Environment ..........................................................................................123

Lands – Affected Environment.................................................................................................140

Soil and Water – Affected Environment ..................................................................................149

Fisheries....................................................................................................................................171

Wildlife.....................................................................................................................................183

Nonnative Invasive Plants – Affected Environment ................................................................204

Nonnative Invasive Plants – Environmental Consequences.....................................................206

Cultural Resources – Affected Environment............................................................................210

Cultural Resources – Environmental Consequences................................................................216

Air Quality – Affected Environment........................................................................................218

Air Quality - Environmental Consequences.............................................................................221

Wildfires - Affected Environment............................................................................................224

Wildfires - Environmental Consequences................................................................................225

Visual Quality - Affected Environment....................................................................................227

Visual Quality - Environmental Consequences........................................................................228

Short-term Uses and Long-term Productivity ..........................................................................230

Unavoidable Adverse Impacts..................................................................................................230

Irreversible and Irretrievable Commitments of Resources.......................................................230

Other Required Disclosures......................................................................................................232

Chapter 4. Consultation and Coordination.............................................................................233

List of Preparers .......................................................................................................................233

Other Contributors....................................................................................................................234

List of Agencies, Organizations and Persons to Whom Copies of the FEIS Were Sent.........234

Glossary ..............................................................................................................................235

References ..............................................................................................................................237

Appendix

1. Proposed Amendments to the Forest Plan..........................................................................251

2. Summary of Proposed Changes and Resultant Motorized System by Alternative..............263
Contents

xii FEIS for Travel Management on the Santa Fe National Forest

3. Analysis of Consistency with the Forest Plan, Laws, 

 and Regulations - Soil and Water.......................................................................................269

4. The Forest’s Current Motorized Travel Policy...................................................................273

5. Roads, Trails, and Fixed-distance Corridors Proposed for Designation 

 that May Not Appear on the First Motor Vehicle Use Map...............................................277

6. Changed Conditions Due to the 2011 Las Conchas Fire.....................................................281

7. Response to Comments on the DEIS..................................................................................285

8. Errata ...................................................................................................................................351

Index ..............................................................................................................................353

List of Tables

Table 1 Comparison of motorized system resulting from 

changes to alternative 1, the existing condition ......................................................................... viii

Table 2 Relationship between alternatives and significant issues ............................................................13

Table 3 Summary of alternatives and their criteria...................................................................................14

Table 4 Alternative 1, no action – where people drive now .....................................................................17

Table 5 Miles of unauthorized routes proposed for designation and reason why in alternative 2 ............24

Table 6 The designated motorized system as a result of the changes proposed in alternative 2...............24

Table 7 Miles of unauthorized routes proposed for designation and reason why in alternative 2M.........28

Table 8 The designated motorized system as a result of the changes proposed in alternative 2M...........28

Table 9 Miles of unauthorized routes proposed for designation and reason why in alternative 3 ............32

Table 10 The designated motorized system as a result of the changes proposed in alternative 3...............32

Table 11 Miles of unauthorized routes proposed for designation and reason why in alternative 4 ............36

Table 12 The designated motorized system as a result of the changes proposed in alternative 4...............36

Table 13 Miles of unauthorized routes proposed for designation and reason why in alternative 5 ............40

Table 14 The designated motorized system as a result of the changes proposed in alternative 5...............40

Table 15 Summary of the proposed changes for each alternative 

and how they compare to where people drive now......................................................................56

Table 16 Summary of the effects described in detail in chapter 3 ..............................................................57

Table 17 Past and present actions from 1987 to 2011 that contributed to the existing condition...............65

Table 18 Present and reasonably foreseeable future actions related to motorized use (2009–2025)*........67

Table 19 Current and predicted motorized use and existence ....................................................................68

Table 20 Percent of visitors who participated in 28 different 

activities in the Santa Fe National Forest during FY 2008a

.........................................................81

Table 21 Miles of trails being used now on the Santa Fe National Forest. Does not include 

any miles of forest system roads, even though roads may connect loops 

(figure 21) or appear to be trails on the ground. ..........................................................................85

Table 22 Change in roads open to motorized use by alternative. Passenger car 

roads carry the most traffic on the forest, and few of them would be closed. .............................89

Table 23 Change in motorized trails by alternative. Alternative 1 shows 

the miles thought to be driven on now.........................................................................................89

Table 24 Percent of routes open seasonally by alternative. You can see that alternatives 2 

through 5 have fewer routes open all year than alternative 1, the existing condition. .................93

Table 25 Percent of routes with no seasonal closures.................................................................................93

Table 26 Comparison of acres available (or used—alternative 1) for 

motorized dispersed camping by alternative..............................................................................103

Table 27 Percent of forest acres having low, medium, or high route densities. 

We anticipate more conflicts in places with high route densities. .............................................107

Table 28 Comparison of motorized use close to wilderness by alternative ..............................................109
Contents

FEIS for Travel Management on the Santa Fe National Forest xiii

Table 29 Comparison of routes in and near the forest’s inventoried roadless areas by alternative ..........114

Table 30 Number of violations for resource damage on the 

Santa Fe National Forest in the past 4 years..............................................................................115

Table 31 Number of map variations by alternative. The more variations, 

the more complicated the map would be to read. ......................................................................117

Table 32 Road maintenance needs on the Santa Fe National 

Forest by alternative in millions of dollars................................................................................119

Table 33 Trail maintenance needs on the Santa Fe National 

Forest by alternative, in thousands of dollars ............................................................................120

Table 34 Areas with motorized recreation opportunities near the Santa Fe National Forest....................126

Table 35 Comparison of maximum amount of job loss and 

income from motorized recreation by alternative ......................................................................128

Table 36 Miles of routes near primitive and semiprimitive nonmotorized 

areas as a proxy for the appropriateness of noise ......................................................................131

Table 37 Percent of the population by race and ethnicity shown at different scales ................................134

Table 38 Percent of the population below the Federal poverty 

level in 2007 shown at the state and county levels....................................................................134

Table 39 Comparison of designated roads crossing habitats where people collect forest products..........138

Table 40 A summary of the benefits and drawbacks to landowners of 

different kinds of access to private land. This list may not be complete. 

Some items were raised by the public during the scoping period..............................................141

Table 41 Measures used as proxies for showing the effects of the proposed changes..............................155

Table 42 Changes in the measures for forest system routes.....................................................................157

Table 43 Changes related to soil and water by adding unauthorized 

routes to the forest transportation system ..................................................................................161

Table 44 Measures for motorized cross-country travel as they relate to soil and water resources...........162

Table 45 Changes in measures for motorized access to dispersed 

camping as they relate to soil and water resources....................................................................164

Table 46 Fish in the Santa Fe National Forest having special management status...................................171

Table 47 Comparison of open route density, by alternative, in watersheds that feed 

critical habitat for the Rio Grande silvery minnow. Watershed area and route 

miles are tabulated for the portion of the watershed within the forest boundary only...............175

Table 48 Comparison of the amount of motorized use near streams by alternative .................................177

Table 49 Comparison of motorized use within 300 feet of streams 

occupied by Rio Grande cutthroat trout.....................................................................................180

Table 50 Comparison of motorized use close to perennial, native fish-bearing streams..........................181

Table 51 Comparison of miles of routes and route density in Mexican 

spotted owl habitat by alternative ..............................................................................................188

Table 52 Comparison of miles of routes and route density in 

Southwestern willow flycatcher habitat by alternative ..............................................................191

Table 53 Comparison of miles of routes in potential amphibian habitat by species and alternative ........193

Table 54 Comparison of miles of routes in potential bird habitat by species and alternative...................194

Table 55 Comparison of miles of routes in potential mammal habitat by species and alternative ...........195

Table 56 Comparison of miles of routes in potential plant habitat by species and alternative .................198

Table 57 The forest’s management indicator species, their habitats and population trends.....................200

Table 58 Comparison of miles of routes and route density in 

Rocky Mountain elk habitat by alternative................................................................................201

Table 59 Comparison of miles of routes and route density in 

Merriam’s turkey habitat by alternative.....................................................................................202

Table 60 Measures for invasive species analysis......................................................................................206

Table 61 Number of cultural resource sites that could be damaged 

through vehicle use under the existing condition, alternative 1.................................................215

Table 62 Number of traditional cultural properties that could be damaged 

through vehicle use under the existing condition, alternative 1.................................................215
Contents

xiv FEIS for Travel Management on the Santa Fe National Forest

Table 63 Maximum concentrations of PM10 monitored near the Santa Fe National Forest .....................220

Table 64 Maximum concentrations of PM2.5 monitored near the Santa Fe National Forest.....................220

Table 65 Summary of number and causes of wildfires in the Santa Fe National Forest, 2000–2010.......225

Table 66 The following amendments to the forest plan will 

occur regardless of which alternative is selected.......................................................................251

Table 67 The following amendments to the forest plan will occur only if the 

alternative specified is selected or that are specific to certain routes or corridors.....................257

Table 68 Summary of roads and trails combined in the resultant system, by alternative .........................263

Table 69 Summary of trails in the resultant system, by alternative ..........................................................264

Table 70 Summary of roads in the resultant system.................................................................................265

Table 71 Summary of areas in the resultant system .................................................................................266

Table 72 Summary of changes to roads and trails from existing policy and conditions...........................267

Table 73 Summary of changes to areas from existing policy and conditions...........................................268

Table 74 Consistency of travel management with forest plan ..................................................................269

Table 75 Current policy for motorized travel on the Santa Fe National Forest (SFNF)...........................273

Table 76 Miles of routes and corridors that may not appear on the first motor vehicle use map .............277

Table 77 Miles and acres of alternative 2M that may not appear on the 

first motor vehicle use map as a result of the Las Conchas Fire................................................283

List of Figures

Figure 1 Summary of the miles of roads and motorized trails that would result from each 

alternative, and their overall percent change from alternative 1, the existing condition............. vii

Figure 2 Comparison of acres available for driving off road, by alternative. Percent change is 

not depicted because some acres can be used in more than one way. For instance, the 

corridors for dispersed camping and for retrieving big game are the same in alternative 2. ...... vii

Figure 3 Location of the Santa Fe National Forest ......................................................................................2

Figure 4 A forest system road winding through a valley on the Española Ranger District..........................3

Figure 5 Alternative 1 (no action)—roads, trails, and areas where people drive now. The 

fixed-distance corridors shown are based on the dispersed camping inventories 

done by the forest in 2008 and 2009 to show what people use now............................................19

Figure 6 Area where a trail existed before the Cerro Grande Fire. 

Motorcyclists requested that we repair and open it again............................................................21

Figure 7 Roads, trails, areas, and fixed-distance corridors proposed – alternative 2 .................................25

Figure 8 Roads, trails, areas, and fixed-distance corridors proposed – alternative 2M..............................29

Figure 9 Roads and trails proposed – alternative 3 ....................................................................................33

Figure 10 Roads, trails, areas, and fixed-distance corridors proposed – alternative 4 .................................37

Figure 11 Roads, trails, areas, and fixed-distance corridors proposed – alternative 5 .................................41

Figure 12 Designating a motorized trail here would be the same 

thing as allowing motorized cross-country travel........................................................................46

Figure 13 Trials riding in the Jemez Mountains ..........................................................................................47

Figure 14 A meadow that has not been driven on........................................................................................48

Figure 15 Example of a fence built to block ATVs from shortcutting roads...............................................50

Figure 16 An example of a place in a designated camping corridor where vehicles 

couldn’t drive because there are too many trees and it is too steep. Other 

parts of the corridor are conducive to driving to get to campsites. ..............................................75

Figure 17 An unauthorized route leading to a camping spot on the Cuba Ranger District..........................83

Figure 18 A typical National Forest System trail in the Jemez Ranger District. 

This one is not in a wilderness area. ............................................................................................84

Figure 19 Example diagram showing how some trails cross nonmotorized areas, 

but for a driver, there would be no way to tell.............................................................................84

Figure 20 An example where a road connects two trails. To get from Point A to B, you 

have to drive on a road. To a rider, it might all look like a single, seamless trail........................85
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FEIS for Travel Management on the Santa Fe National Forest xv

Figure 21 An example of coincident routes. The trail and the road are the 

same, or coincident, between points A and B..............................................................................86

Figure 22 Impassable road due to mud ........................................................................................................87

Figure 23 Miles of roads and trails open for motorized use by alternative ..................................................88

Figure 24 Miles of trail proposed for motorized use by alternative. The resultant 

system would have more motorized National Forest System trails, but 

restrict motorized travel from what is happening now. ...............................................................90

Figure 25 Comparison of how many of the 541 miles of unauthorized 

routes are proposed by alternative ...............................................................................................90

Figure 26 Conceptual illustration of change in acreage open for 

motorized cross-country travel by alternative (not to scale)........................................................91

Figure 27 Percent of routes open per year by alternative. Alternatives 2M and 4 keep 90 

percent of routes open for 9 months or more. By comparison, alternatives 2, 3, 

and 5 keep about 30 percent of routes open for 9 months or more..............................................92

Figure 28 Comparison of acres, and percent change from existing condition, 

where people would be allowed to drive to retrieve elk and mule deer.......................................96

Figure 29 A motorized dispersed campsite, meaning it has no Forest Service facilities. 

This site in the Jemez Ranger District is close to trails popular with ATV riders. ......................99

Figure 30 A popular camping site near Dalton Creek, Pecos/Las Vegas Ranger District ...........................99

Figure 31 An example of a campsite right next to water ...........................................................................100

Figure 32 A buck and pole fence that keeps cars away from the stream, 

but lets people camp close to the stream if they walk................................................................100

Figure 33 An example of an infrequently used campsite on the Coyote Ranger District ..........................101

Figure 34 Comparison of acres available for motorized dispersed 

camping by alternative (acres used in alternative 1)..................................................................103

Figure 35 The photo on the left is what we mean when we say a route has a footprint on the 

ground; the photo on the right does not. Neither photo is in an inventoried roadless area. .......112

Figure 36 Miles of routes in the forest’s inventoried roadless areas by alternative ...................................113

Figure 37 An example of what the Santa Fe National Forest’s motor vehicle use map could 

look like. The symbols and color (black and white) are the same for all national forests. ........116

Figure 38 An example of a short forest system road that leads to private property. 

The truck is on the main road. ..................................................................................................140

Figure 39 An example of a historic road that runs through a riparian area leading to 

private property. It’s unlikely this access will be authorized by permit or 

easement in the future. Another way to the property would need to be found. .........................142

Figure 40 Gated private road. If this road has an easement, it would not show on the motor 

vehicle use map. In that situation, a gate is appropriate because the public is not 

allowed to drive on the road, but could engage in nonmotorized activities on the

public land behind the gate. That would not change under any alternative. ..............................143

Figure 41 The rectangle represents privately owned land. According to the forest plan, 

both these situations should only have one road leading to them. In practice, 

the Santa Fe National Forest has allowed situations like that on the right.................................146

Figure 42 Road leading to private property that is causing damage to the stream and riparian area .........147

Figure 43 Without plant cover to stop it, rain or snowmelt carries soil 

down this eroded hillside directly into the stream .....................................................................150

Figure 44 An example of how roads alter the patterns of runoff in a watershed. Water normally 

flows down a hill in a sheet. Here, the bar ditch adjacent to the road intercepts the water, 

concentrating it in one fast channel, which is downcutting and carrying sediment. From 

an engineering perspective, the bar ditch is doing its job: keeping water off the road. .............151

Figure 45 Route crossing where soil is carried directly into a stream 

because there is a lack of vegetation to help stop it...................................................................151

Figure 46 Photo illustrating the concept of braiding. When the main 

road is muddy, people drive to the left, widening the road........................................................152
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xvi FEIS for Travel Management on the Santa Fe National Forest

Figure 47 Area where repeated camping and parking next to the stream has caused most of 

the riparian plants to die, resulting in bare ground and a muddy stream ...................................153

Figure 48 Example of a National Forest System road on the Coyote Ranger District that 

has partially recovered, though bare ground is still present. Having some 

vegetation, however, is an improvement over having none.......................................................158

Figure 49 A National Forest System road that has been closed to use, but continues to erode. There is 

an erosion channel starting above the horse’s right ear and leading to the top of the photo......159

Figure 50 A system trail that is incised, forming a channel through which water flows. 

As the water flows, it pulls more soil down with it. Even without motorized use, 

this system trail is not likely to revegetate on its own within 15 years......................................159

Figure 51 Example of a route that the Forest Service physically decommissioned ...................................160

Figure 52 Area that used to be a two-track route to a livestock watering tank (the horse in 

the picture is standing at the livestock tank). It probably existed in 1987 

when the forest plan was adopted, but it has since grown over. ................................................163

Figure 53 Example of where motorized dispersed camping has had detrimental effects 

on the riparian area. At this site along the Rio de las Vacas, motorized access 

to the dispersed campsite has compacted the soil and removed all vegetation. 

Motorized use goes all the way down to the streambank, and the riparian 

vegetation has been removed within the vicinity of the site. .....................................................165

Figure 54 This photo illustrates how, in alternative 2M or 3, people would not be able to 

drive their vehicles into their campsite. No bare ground is evident in the campsite, 

and the riparian vegetation in the middle right part of the photo is present...............................166

Figure 55 The Las Conchas Fire burned intensely uphill of this road, removing all 

vegetation and litter. After a storm, the runoff collected debris and impacted this road. ..........168

Figure 56 An example of livestock grazing in riparian areas in the forest.................................................169

Figure 57 Example of a ditch that carries water off the road, so it 

prevents sediment from being carried to streams ......................................................................172

Figure 58 A Rio Grande silvery minnow (Photo Aimee Roberson, 

Courtesy of U.S. Fish and Wildlife Service) .............................................................................174

Figure 59 Example of trail segment running up a streambed.....................................................................179

Figure 60 A Mexican spotted owl (Photo Courtesy of U.S. Fish and Wildlife Service)............................187

Figure 61 A Southwestern willow flycatcher (Photo Jim Rorabaugh, 

Courtesy of U.S. Fish and Wildlife Service) .............................................................................191

Figure 62 Rocky Mountain elk (Photo Courtesy Rocky Mountain Elk Foundation).................................201

Figure 63 Merriam’s turkeys (Photo courtesy of National Wild Turkey Federation)................................202

Figure 64 A long-billed curlew, one of the Southern Rockies/Colorado Plateau Bird Conservation 

Region’s migratory birds (Photo Bob Gress, Courtesy of U.S. Fish and Wildlife Service) ......203

Figure 65 Spotted knapweed (photo from Noxious and Nuisance 

Plant Management Information System, USDA-ARS) .............................................................205

Figure 66 Site density map of cultural resources on the Santa Fe National Forest....................................210

Figure 67 Rubble from a collapsed ancestral pueblo field house, damaged by past road 

construction and use, Jemez district. All archaeological deposits within the 

road have already been displaced or destroyed by past road construction and use....................213

Figure 68 Fire ring in a dispersed camping area constructed from the 

foundation stones of an early 20th century cabin, Pecos/Las Vegas 

district. Foundation is visible in shadows behind the fire ring ..................................................214

Figure 69 Early 20th century Forest Service administrative building near a dispersed camping area, 

painted with graffiti, Española Ranger District .........................................................................214

Figure 70 A view of Cerro Pedernal. Even though camping 

happens in these mountains, you can’t see it from far away......................................................228

Figure 71 The section of Forest Trail 726A in orange falls into one of the categories above; 

however, none of 726A will appear on the motor vehicle use map until the 

issues with the section in orange are resolved. ..........................................................................280

Figure 72 Fire severity map of the Las Conchas Fire which occurred in 2011..........................................282
FEIS for Travel Management on the Santa Fe National Forest 1

Chapter 1. Purpose of and Need for Action

Structure of this Document

The Santa Fe National Forest (forest) has prepared this final environmental impact statement to 

analyze different ways of implementing the Travel Management Rule. This statement describes 

the forest’s proposed alternatives and their environmental consequences. The analysis complies 

with and is conducted under the authority of the National Environmental Policy Act’s 

implementing regulations at 40 CFR 1500 and other relevant Federal laws and regulations. The 

document consists of the following: 

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

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

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

responded. 

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

proposed action and alternatives—including no action—in detail. We developed these 

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

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

you only have time to read one chapter, this one would give you the most complete 

picture of the project and its effects.

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

describes the environmental consequences of each alternative in detail. 

• Chapter 4. Consultation and Coordination: This chapter contains a list of people who 

wrote this document and the people and agencies we sent it to. 

• Glossary

• References

• Appendix: The appendix supports the analyses presented in the environmental impact 

statement and consists of several parts.

• Index: The index provides page numbers for different topics.

The project record is located at the Santa Fe National Forest headquarters, 11 Forest Lane, Santa 

Fe, New Mexico 87508. The project record index is posted on the forest’s Web site at: 

http://www.fs.fed.us/r3/sfe/travelmgt/index.html.

Background

This project will reduce the places where people can drive in the Santa Fe National Forest. 

To address concerns about the effects of unmanaged off-highway vehicles, the Forest Service

published final travel management regulations for motor vehicle use on national forests and 

grasslands on November 9, 2005. The Travel Management Rule “... provides for a system of 

National Forest System roads, National Forest System trails, and areas on National Forest 

System lands that are designated for motor vehicle use. After these roads, trails, and areas are 

designated, motor vehicle use, including the class of vehicle and time of year, not in accordance 

with these designations is prohibited by 36 CFR 261.13.”
Chapter 1. Purpose of and Need for Action

2 FEIS for Travel Management on the Santa Fe National Forest

The Travel Management Rule recognizes the important role vehicles play in people’s enjoyment 

of their national forests: “Motor vehicles are a legitimate and appropriate way for people to enjoy 

their National Forests—in the right places, and with proper management.” (70 FR 26864)

Driving a vehicle is an important part of virtually every activity on the forest. Most visitors drive 

to the forest to sightsee, camp, hike, hunt, fish, ride horses, collect firewood, picnic, sit by the 

water, or for a number of other activities. People come to the forest to ride on roads and trails in 

pickup trucks, ATVs, motorcycles, and other vehicles. Outfitters, grazing permittees, 

telecommunications companies, and loggers use vehicles to support their business on the national 

forest.

People drive on “National Forest system” roads and trails—also called forest roads and trails in 

this statement—which are part of the Santa Fe National Forest’s official transportation network, 

as well as “unauthorized” roads and trails, which are all the others (36 CFR 212.1). 

Location

The area this statement analyzes is the Santa Fe National Forest, located in northern New Mexico 

as shown in figure 3. The forest has over 1.5 million acres of public land within its boundary.

Figure 3. Location of the Santa Fe National Forest
Chapter 1. Purpose of and Need for Action

FEIS for Travel Management on the Santa Fe National Forest 3

Purpose and Need

The purpose of this project is to comply with the Travel Management Rule by providing a system 

of roads, trails, and areas designated for motor vehicle use by class of vehicle and time of year on 

the Santa Fe National Forest (36 CFR 212.50).

On the Santa Fe National Forest, complying with the Travel Management Rule means there is a 

need for: (1) no cross-country motorized travel except in designated areas; (2) clarification of 

which roads and trails would be open for motorized use; (3) the optional designation of the 

limited use of motor vehicles within a specified distance of certain designated routes and, if 

appropriate, within specified time periods, solely for the purposes of dispersed camping or 

retrieval of a big game animal by an individual who has legally killed that animal; and (4) 

amended forest plan direction regarding motorized vehicle use that is consistent with the rule. 

Projects must be consistent with the forest plan, or the forest plan must be amended.

Figure 4. A forest system road winding through a valley on the Española Ranger District

There is also a need for fewer detrimental effects to natural and cultural resources from 

unmanaged motorized use and the existence of roads and motorized trails. Here are examples—

taken from chapter 3 of this document—of the detrimental effects caused by unmanaged 

motorized use and the presence of roads and motorized trails:

• Motorized cross-country travel can create new roads and trails that aren’t properly 

designed. The presence of roads and motorized trails interrupts the natural flow of water, 
Chapter 1. Purpose of and Need for Action

4 FEIS for Travel Management on the Santa Fe National Forest

channeling it and carrying sediment to streams. Sediment deposited into streams degrades 

water quality and habitat for fish.

• Vehicles transport nonnative invasive plant seeds to and within the forest. Roads and 

motorized trails act as pathways for these seeds. The establishment and spread of 

nonnative invasive plants disrupts native ecological processes, resulting in fewer native 

plants and animals.

• Roads and motorized trails fragment habitat for wildlife. Many small mammals and 

reptiles don’t cross roads, which isolates populations and promotes inbreeding, resulting 

in reduced population viability. Small mammals and reptiles also risk being killed by 

vehicles. Large mammals tend to avoid vehicles, roads, and motorized trails, altering 

where they would normally live and breed.

• Driving off roads and motorized trails can damage cultural resource sites. Wheels crush 

artifacts. Erosion caused by driving can wash away sites. With vehicles, people have 

easier access to cultural resource sites and may intentionally or unintentionally damage 

them.

Decision to be Made

The forest supervisor will decide what changes to make to the current motorized travel system

and what forest plan amendments to adopt. Changes to the current motorized travel system may 

include:

• Closing the forest to motorized cross-country travel except in areas designated for 

motorized use;

• Adding or removing National Forest System roads designated for motorized travel;

• Adding unauthorized routes to the designated motorized system;

• Allowing motorized use on system trails built for nonmotorized uses;

• Deciding what kinds of vehicles may travel on designated routes;

• Deciding what time of year vehicles may travel on designated routes; and

• Deciding to designate the limited use of motor vehicles within a specified distance of 

certain routes solely for the purposes of dispersed camping or retrieval of a downed big 

game animal by an individual who has legally taken that animal.

The amendments to the “Santa Fe National Forest Plan” proposed for each alternative are 

described briefly in chapter 2, and in full in appendix 1.

The forest supervisor’s decision applies only to unrestricted public use of roads, trails, and areas 

designated for motorized use. The rule at 36 CFR 212.51(a) (4) and (8) exempts limited 

administrative use by the Forest Service and use specifically authorized under a written 

authorization issued under Federal law or regulations. Moreover, the designation process 

determines the scope of opportunities for motorized recreation (73 FR 74692). A full discussion 

of roads used for administrative purposes is in the project record in the document titled “Roads 

Used for Administrative Purposes,” dated September 10, 2009. 
Chapter 1. Purpose of and Need for Action

FEIS for Travel Management on the Santa Fe National Forest 5

The parts of the existing designated travel system that won’t change don’t need to be authorized 

again in this travel management planning process:

“The responsible official may incorporate previous administrative decisions 

regarding travel management made under other authorities, including 

designations and prohibitions of motor vehicle use, in designating National 

Forest System roads, National Forest System trails, and areas on National Forest 

System lands for motor vehicle use under this subpart (§ 212.50(b)).”

Public Involvement

Since the rule’s publication in 2005, forest personnel have actively sought the public’s input 

during the travel management planning process. Informally, the district rangers and forest 

supervisor met with many groups and attended a number of field trips to observe conditions on 

the ground. We have received nearly 3,300 comments throughout the planning process. The 

formal aspect of public involvement to date consists of four phases: collaboration, scoping, notice 

and comment, and tribal consultation. Each is described next.

Collaboration

Forest personnel engaged in an intensive collaboration process from early 2006 through late 2007 

by hosting 38 public meetings and workshops, attending many field trips, and speaking with 

many individuals personally (various project record documents dated 2006–2007). The meetings 

generated approximately 1,100 letters from the public. We used the letters to develop the “Travel 

Analysis Process Report,” the report that fulfilled the requirements of 36 CFR 212.5(b) (“subpart 

A”) of the Travel Management Rule. The “Travel Analysis Process Report” is located in the 

project record (USDA Forest Service, 2008b). 

Scoping

On July 10, 2008, the forest supervisor let the public know the proposed action for managing 

motorized travel was ready for scoping comments by sending 7,510 letters and 2,760 emails to 

the 10,270 people on the mailing list at that time. An additional 1,140 people on the mailing list 

did not receive a letter because their mailing address was not valid, and they did not provide an 

email address. The mailing list was composed of people who attended public meetings, people 

who asked to be on the list, private landowners, tribes and pueblos, government agencies, media 

contacts, and organizations. We posted the proposed action and maps on the forest’s Web site on 

the same day we mailed the letters, July 10, 2008.

The notice of intent to prepare an environmental impact statement was published in the Federal 

Register on July 17, 2008 (USDA Forest Service 2008g). Its publication marked the beginning of 

the scoping comment period, during which we invited comments on the proposed action. The 

scoping period ended September 2, 2008. During the scoping period, we held 13 public meetings 

to introduce the proposal, answer questions, solicit comments, and listen to the public’s opinions. 

Meetings took place in the vicinity of all five ranger districts and the forest headquarters. 

Approximately 570 people attended. The district rangers and forest supervisor also met 

individually with people who asked.
Chapter 1. Purpose of and Need for Action

6 FEIS for Travel Management on the Santa Fe National Forest

Scoping Comments

We received 1,386 emails and letters commenting on the proposal. Of these, 45 came from 

organizations or agencies and the rest from individual citizens. Several people provided their own 

alternatives for us to consider. In addition, we received six different petitions. Almost everyone 

sent their comments by September 2, 2008, though a few continued to come in as late as 2010. 

These comments have been included in the record. However, because the analysis of effects was 

substantially completed by early 2010, these late comments weren’t reflected in the draft 

environmental impact statement.

The Santa Fe National Forest’s travel management interdisciplinary team, a team of Forest 

Service employees with different professional specialties, read and evaluated every letter. Using 

an established analytical process for sorting and categorizing comments into a database, the team 

identified the individual comments contained within each letter. For example, a single letter might 

contain four different comments on things like wildlife habitat, erosion, access, and noise. The 

team identified 3,749 comments within the scoping comment letters. Many of the comments 

express similar ideas.

The team found two kinds of comments. The first, “general comments,” pertained to the whole 

forest. An example of this is, “Please provide access for hunting.” The general comments 

numbered 2,401. The interdisciplinary team used the general comments to develop the issues 

discussed in this statement. 

The other kind of comment, “site specific,” identifies an exact place on the forest. An example is, 

“I would like to see Forest Road 144 open to vehicles all year.” The site-specific comments 

numbered 1,348. Staff on the five ranger districts considered each site-specific comment to see 

whether the suggestion could be incorporated into an alternative. Most suggestions were placed in

one or more alternatives, but some were not. When district staff recommended the comment not 

be in any alternative, they provided a reason why not. These reasons are found in the site-specific 

database in the project record (USDA Forest Service 2010g). 

Issues

The interdisciplinary team grouped the 2,401 general comments into more than 60 public concern 

statements. Each public concern statement captured a unique theme that one or more members of 

the public raised. A public concern was carried forward as a significant issue if it wasn’t resolved 

by the proposed action, or disagreement about the impacts of the proposed action existed, or the 

concern wasn’t already addressed by law, regulation, or policy (see the section below called 

“Issues Not Considered in Detail” for a complete list of the latter). As a significant issue, it 

formed the basis of one or more of the alternatives.

For a full explanation of how the interdisciplinary team analyzed the comments received during 

scoping and identified the issues to analyze, refer to these documents in the project record: (1) 

Content Analysis Methodology (April 9, 2009); (2) Memo to File Approving Issues and 

Alternatives (March 17, 2010); (3) Comment Tracking Database (contains the general comments) 

(June 2, 2010); and (4) Report on Site Specific Suggestions (contains the site-specific comments) 

(June 2, 2010).
Chapter 1. Purpose of and Need for Action

FEIS for Travel Management on the Santa Fe National Forest 7

Significant Issues

We identified these five significant issues from the comment letters:

1. Continued public motorized use of routes and areas described in the proposed action will 

adversely affect forest resources. These effects include:

• Erosion, soil compaction, and degradation of water quality and watershed condition;

• Degradation of fish and wildlife habitat;

• Damage to cultural resource sites;

• Damage to traditional cultural properties;

• Spread of invasive plant species;

• Damage to rare plants; and

• Compromising the character of wilderness and inventoried roadless areas.

2. The reduction in miles of routes and the prohibition on cross-country travel described in 

the proposed action will adversely affect the quantity of public motorized experiences 

because the proposed action:

• Lacks enough loops and connectors to provide for longer rides;

• Lacks diverse opportunities for all-terrain vehicles, motorcycles, and 4x4s;

• Lacks diverse routes for different skill levels;

• Restricts access to traditional cultural properties;

• Does not provide enough area for motorcycle trials; 

• Closes too many routes, which will concentrate use and take away the semiprimitive 

aspect of riding in the forest; and

• Does not plan for the future growth in motorized sports.

3. Prohibiting motorized cross-country travel will limit the retrieval of big game, perhaps to 

an unacceptable level.

4. Designating motorized dispersed camping corridors will increase cross-country travel and 

the resource damage associated with it and also curtail the kind of unrestricted camping 

that the Santa Fe National Forest currently provides.

5. The proposed action, by designating routes uniformly across the forest outside of 

designated wilderness, will cause conflicts between motorized and nonmotorized users 

because they will be recreating in the same vicinity.

Other Issues

“Other issues” didn’t form the basis of an alternative, but are analyzed in this statement.

• Designating routes close to private property may increase incidents of trespass on private 

land.

• Motorized travel causes fugitive dust and vehicle emissions that are harmful to human 

health and contribute to climate change.

• Designating routes to or motorized dispersed camping close to private property limits 

recreational opportunities or encourages trespass.
Chapter 1. Purpose of and Need for Action

8 FEIS for Travel Management on the Santa Fe National Forest

• The motor vehicle use map alone will be an inadequate enforcement tool.

• Any reasonable designated motorized trail system will require more maintenance than the 

Forest Service can provide by itself. An unmaintained system will continue to adversely 

affect forest resources.

• Closing routes to motorized use could affect visual quality.

• Reducing the miles of roads and trails could decrease the amount of motorized recreation 

on the forest, resulting in negative economic impacts.

• Motorized routes in the Santa Fe National Forest could result in undesirable noise

affecting those who visit the national forest and surrounding areas.

• Motorized routes in the Santa Fe National Forest could affect property values for lands 

adjacent to the forest.

• Reducing the miles of routes for motorized use in the Santa Fe National Forest could 

impact the cultural practices and traditions by limiting opportunity for traditional 

activities on the forest.

• The designation of routes for motorized use in the Santa Fe National Forest could result 

in a disproportionately high and adverse human health or environmental effect on 

minority populations and low-income populations.

• Motorized use of the forest increases the risk of wildfire starts.

• The proposed action restricts motorized access to hunting and fishing opportunities, as 

well as forest product collection.

Issues Not Considered in Detail

We recognize that all concerns raised by the public are important. Some concerns, however, do 

not fit into this environmental analysis for a variety of reasons. The Council on Environmental 

Quality’s NEPA regulations direct interdisciplinary teams to “...identify and eliminate from 

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

environmental review (40 CFR 1506.3)...” For example, a commenter might suggest we follow 

the NEPA process, which we are already required to do by law. 

The comments not analyzed in detail fell into one of the following categories. They were:

• Already part of the proposed action;

• Addressed through implementation of standards, guidelines, or best management 

practices in the forest plan;

• Already decided by law, regulation, or policy;

• Beyond the scope of the project; or

• Not supported by scientific evidence.

The document titled “Final List of Issues and Concerns from Scoping” dated February 9, 2010, in 

the project record lists each concern not considered in detail with an explanation as to how it was 

considered.
Chapter 1. Purpose of and Need for Action

FEIS for Travel Management on the Santa Fe National Forest 9

Notice and Comment Period 

for the Draft Environmental Impact Statement

The forest posted the draft environmental impact statement on its Web site on July 22, 2010. The 

forest supervisor notified 1,211 individuals and organizations via email or letter on July 22 and 

23, 2010, letting people know the draft was available for review. The people notified were those 

who commented during scoping, who asked to be kept on the mailing list, or who specifically 

requested notification of the draft’s availability. The notice and comment period—the official 

time allotted for the public to comment on the draft environmental impact statement to have 

standing to appeal—started with publication of the notice of availability in the Federal Register 

on August 6, 2010. The notice and comment period ran from August 7 through September 30, 

2010. The public had 71 days to review the draft from the time it was posted on the internet 

through the end of the comment period.

In conjunction with the notice and comment period, the forest hosted another eight public 

meetings to present the alternatives and answer questions.

We received 859 letters and emails from the public commenting on the draft. As with the scoping 

period, the forest’s interdisciplinary team used an established method for reading, coding, sorting, 

and analyzing each letter (USDA Forest Service 2012o). 

Response to Comments Made During the Notice and Comment Period

The regulations implementing the National Environmental Policy Act provide this direction to 

agencies responding to comments on draft environmental impact statements:

“An agency preparing a final environmental impact statement shall assess and 

consider comments both individually and collectively, and shall respond by one 

or more of the means listed below, stating its response in the final statement. 

Possible responses are to: 

• Modify alternatives including the proposed action. 

• Develop and evaluate alternatives not previously given serious consideration 

by the agency. 

• Supplement, improve, or modify its analyses. 

• Make factual corrections. 

• Explain why the comments do not warrant further agency response, citing the 

sources, authorities, or reasons which support the agency’s position and, if 

appropriate, indicate those circumstances which would trigger agency 

reappraisal or further response.” (40 CFR 1503.4)

The forest considered comments individually by evaluating each letter and identifying the 

specific comment(s) contained within. Because of the high volume of comments received, the 

forest grouped like comments together into one and answered them (appendix 7).

Tribal Consultation

The five district rangers started talking to tribal government officials about the forest’s travel 

management planning in 2006. The forest supervisor sent the first formal invitation to all the 
Chapter 1. Purpose of and Need for Action

10 FEIS for Travel Management on the Santa Fe National Forest

tribes with whom we maintain ongoing government-to-government relationships to consult on 

this subject on April 10, 2007. We received no formal responses to this invitation.

The second formal invitation to consult on this project was sent on July 10, 2008, at the same

time the proposed action was released. We received one formal response from the Navajo Nation. 

Its response identified specific sites of concern in the forest and requested continued access to 

these sites. The heritage specialist report addresses these concerns, and they will be discussed in 

the clearance report. 

The forest supervisor sent a general invitation to consult on all forest projects—including travel 

management—to all tribes on April 17, 2009. We received no responses related to travel 

management.

Informal discussions among tribal officials, district rangers and other forest employees indicate a 

general feeling among tribal people that they are pleased with the reduction in motorized routes,

and they are satisfied with assurances that they will continue to have access to sites that have 

importance to them.

Important Notes 

The Decision Will Change Where People Can Drive in the Forest

Right now, the Santa Fe National Forest is open to motorized use unless marked closed1. This 

means that people can drive where they like as long as no sign or closure order posts it closed. 

The Travel Management Rule switches that around: the forest is closed to motorized use unless 

specifically designated as open for motor vehicle use. Driving off routes will no longer be 

allowed unless it is in a designated area or fixed-distance corridor. If people drive somewhere that 

is not on the motor vehicle use map, they would be driving illegally and subject to a fine. The 

official reference for what is open will be the motor vehicle use map, which will show the roads, 

motorized trails, areas, and fixed-distance corridors where driving is allowed.

The First Motor Vehicle Use Map

The first motor vehicle use map may not show all the roads, trails, and fixed-distance corridors

designated in the record of decision. Appendix 5 explains why.

Subsequent Motor Vehicle Use Maps

We emphasize that the motor vehicle use map is dynamic, and will be reviewed and published 

annually. If a road, motorized trail, or area is not included in the first map, it could be included or 

removed in subsequent maps as long as the appropriate environmental analysis, surveys, 

monitoring, or documentation are completed. The annual publication of the motor vehicle use 

map means the public can continue to work with forest staff to add or remove roads, motorized

trails, and areas as appropriate.

 

1 The forest plan allows driving off roads on 53 percent of the forest.
Chapter 1. Purpose of and Need for Action

FEIS for Travel Management on the Santa Fe National Forest 11

Errata

The maps of the alternatives were “frozen” in April 2011 so the environmental analysis could be 

performed on a consistent set of maps. Between April 2011 and April 2012, forest staff 

discovered and corrected some errors. The complete list of errata is included as appendix 8 as 

provided for by the regulations at 40 CFR 1503.4(C).

Use of “Closed”

The definition of a “closed road” is provided in the glossary, and we have attempted to adhere to 

it in this statement. Where used, “closed” may also refer to a road that isn’t designated for 

motorized use. Some of these roads or trails may be decommissioned or obliterated at a future 

date. The forest’s INFRA database should contain which roads are closed and which are slated for 

decommissioning after the forest supervisor makes her decision.
FEIS for Travel Management on the Santa Fe National Forest 13

Chapter 2. Alternatives,

Including the Proposed Action

Introduction

The interdisciplinary team used the significant issues listed in chapter 1 to develop the three 

action alternatives analyzed in the draft environmental impact statement. Summarized briefly, the 

five significant issues are: protection of natural and cultural resources, reduction of the amount 

and type of motorized access, motorized access for retrieving big game, motorized access for 

dispersed camping, and conflict between motorized and nonmotorized uses. The alternatives 

approach the purpose and need—to provide for a designated system of roads, motorized trails, 

and areas and to reduce detrimental impacts caused by unmanaged motorized use—differently. 

The alternatives respond to the significant issues as shown in table 2.

Table 2. Relationship between alternatives and significant issues

This Alternative Responds to These Significant Issues

1 – No Action Baseline, required by law

2 – Proposed Action Initial proposal (7/8/08) amended in DEIS as allowed by 36 

CFR 220.5(e)(1)

2M – Modified 

Proposed Action

Protection of natural resources

Provision of motorized opportunities

Motorized access to dispersed camping

Motorized access for retrieving big game

3 and 4 Protection of natural resources

Provision of motorized opportunities

Motorized access to dispersed camping

Motorized access for retrieving big game

5 Motorized access for retrieving big game

Motorized access for dispersed camping

Conflicts between motorized and nonmotorized forest users

The interdisciplinary team built the alternatives around three loose themes. Alternative 3 

emphasizes natural resource protection and high habitat quality by providing a reduced amount of 

motorized access to and in the forest. Alternative 4 increases motorized access while providing 

for resource and habitat protection, but at a lower level than the proposed action. Alternative 5 

geographically groups motorized routes, providing separation between motorized and 

nonmotorized uses. The team developed the fourth action alternative, 2M, as a result of the 

public’s comments on the draft environmental impact statement. Alternative 2M modifies the 

proposed action. Settling on which alternatives to consider in detail was an iterative process that 

occurred over the course of several months. The forest supervisor approved the final list of 

alternatives. To read about the Forest Service’s deliberative process, please refer to the 

interdisciplinary and steering committee meeting notes in the project record. 

In addition to the issues raised during the scoping period, several members of the public sent in 

alternatives for the forest staff to consider. The five action alternatives presented in this final

environmental impact statement incorporate elements of some of these proposals as well as other 

comments made by the public. The interdisciplinary team also used information from other 

agencies to develop and refine the alternatives.
Chapter 2. Alternatives, Including the Proposed Action

14 FEIS for Travel Management on the Santa Fe National Forest

Overview of the Alternatives’ Development

This statement considers six alternatives in detail. The next table summarizes when each was first 

available to the public and the criteria used in its development. A complete description of the 

steps taken and criteria used to develop the alternatives is in the project record (USDA Forest 

Service 2012p).

Table 3. Summary of alternatives and their criteria

Alternative Date First 

Published

Published 

in . . . Main Criteria Used Comments

1 – No Action July 22, 2010 DEIS 

FEIS

No change from current 

management

This alternative shows where 

people drive now.

2 – Proposed 

Action

July 10, 2008 Scoping 

notice

DEIS

FEIS

The July 10, 2008, proposed 

action was taken from the 

“Travel Analysis Process 

Report.”

The proposed action in the 

DEIS was modified as a 

result of public comments 

and field verification (36 

CFR 220(e)(1)).

The document titled 

“Explanation of Differences 

between the July 2008 

Proposed Action and the 

Corrected Proposed Action” 

dated January 27, 2010, in the 

project record provides an 

explanation of the changes. 

2M June 2012 FEIS Public comment This alternative modifies the 

proposed action as a result of 

the public’s comments on the 

DEIS (40 CFR 1503.4).

This is the forest supervisor’s 

preferred alternative.

3 July 22, 2010 DEIS 

FEIS

USDA Forest Service 2009c

4 July 22, 2010 DEIS 

FEIS

USDA Forest Service 2009c

5 July 22, 2010 DEIS 

FEIS

USDA Forest Service 2009c

Miscellaneous Notes on Alternative Development

Some people requested that the alternatives provide loops 25 miles or longer for riding. We 

haven’t listed miles of loops for each alternative because the combination of roads and trails that 

a person might ride on determines the mileage of the loop. All of the alternatives provide loops 

that are 25 miles or longer, depending on how someone strings together their choice of routes. 

Not all the alternatives provide the kind of riding experience that may be desired. Alternative 3, 

for example, contains the fewest miles of single track.

Some people asked the Forest Service to make sure that the designated system has enough variety 

for drivers and riders with different skill levels (beginners through experts) and for different types 

of vehicles, such as motorcycles or 4x4s. The Forest Service does not rate routes in terms of 

difficulty. What one person considers an easy route might be very difficult for another. We 

attempted, however, to provide enough total mileage and variety so that everyone could find what 

they need and like.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 15

Motorized access to dispersed camping is provided in two ways. The first are the designated, 

fixed-distance corridors in which people can drive a limited distance off roads to set up camp. 

The second are routes that end at dispersed campsites. These tend to be short, open spur roads 

that are not specifically designated for dispersed camping. These spurs provide additional 

motorized access to camping than what is tallied in this chapter’s summary tables.

On the paper or electronic copies of the maps of the alternatives, some routes appear to dip into 

the San Pedro Parks and Chama River Canyon Wilderness areas. This, however, is a function of 

how the boundaries of the wilderness areas are electronically mapped in GIS. The Santa Fe 

National Forest does not have the authority to change the mapped, electronic boundaries. On the 

ground, the routes do not go into wilderness areas. The forest surveyor investigated all the routes 

that appear to cross wilderness areas, and found that on the ground, none do (USDA Forest 

Service 2009a). 

No alternative prohibits nonmotorized activities; the change proposed with this project is where 

people can drive to get to places in the forest to do these activities. Designated system roads and 

motorized trails would also be open for walking, hiking, bicycling, horseback riding, or other 

nonmotorized activities.

All the action alternatives provide access to popular destinations, loops, and connectors for longer 

riding time; routes that increase the diversity of opportunities for different vehicle classes (ATVs, 

motorcycles, full-size 4-wheel drive); and routes that provide semiprimitive riding experiences. A 

route was included in one alternative and not in another depending on whether it fit with the 

objective of the alternative.

Maps of the Alternatives

Draft Environmental Impact Statement: The interdisciplinary team completed the maps of the 

alternatives shown in the draft on September 30, 2009. Between then and publishing the draft on 

July 22, 2010, the team continued to find changes, but froze the alternatives on September 30, 

2009, so that specialists could begin their effects analysis with a consistent set of numbers and 

maps. 

Final Environmental Impact Statement: Between publication of the draft and final statements, 

forest staff continued to record mistakes and changes. For example, forest staff used GPS to 

locate more routes and their alignments were refined. The forest’s transportation engineer visited

a number of unauthorized routes to identify road management objectives for them, and some 

don’t exist (USDA Forest Service 2012b). Changes to the maps between September 30, 2009, and 

April 2011 have been incorporated into this FEIS. This means that a change identified by staff or 

the public after April 2011 will not show up on the maps of the alternatives in this final

environmental impact statement. These changes are listed in the errata in appendix 8. These 

changes will be incorporated into the forest supervisor’s final decision where appropriate.

Despite the public’s corrections and the district staffs’ field work, we still lack complete 

information on the location and condition of every route and area due to the volume of routes that 

exist on the forest. We will continue to make changes with the annual review and publication of 

the motor vehicle use map.
Chapter 2. Alternatives, Including the Proposed Action

16 FEIS for Travel Management on the Santa Fe National Forest

Statement of Incomplete or Unavailable Information

This section fulfills the requirements listed in 40 CFR 1502.22.

The forest doesn’t have complete information on the condition and level of use of its forest 

system roads and trails, unauthorized routes, or motorized cross-country use. Collecting that 

information would constitute covering over 7,500 miles of forest system routes, an unknown 

mileage of unauthorized routes, and 1.5 million acres of National Forest System lands. The 

overall cost of obtaining this information would be exorbitant and time consuming, besides the 

fact that it changes every year. For example, the 2011 Las Conchas Fire changed the condition of

routes within its perimeter. 

Having complete information on the condition and motorized use of every mile and acre of the 

Santa Fe National Forest is not relevant to effectively analyzing the reasonably foreseeable 

significant adverse impacts on the human environment. The general effects of the existence and 

use of routes and off-road travel on natural and cultural resources are well documented and 

presented in each section of chapter 3. 

None of the action alternatives are expected to have catastrophic consequences; on the contrary, 

most improve or maintain the condition of natural and cultural resources while continuing to 

provide motorized opportunities to the public.

Alternatives Considered in Detail

Some Important Laws and Policies

that Will Continue to Apply to Any Alternative

Current law and policy applies to all the alternatives analyzed in this statement. A few key items 

merit mention here since they were of particular concern to the public:

• Motorized use on National Forest System roads and trails is subject to New Mexico State 

Law.

• In accordance with 36 CFR 261.12, National Forest System roads and trails, the 

following is prohibited: (c) Damaging and leaving in a damaged condition any such road, 

trail, or segment thereof.

• In accordance with 36 CFR 261.15, use of vehicles off roads (h), it is prohibited to 

operate any vehicle off National Forest System, State, or county roads in a manner which 

damages or unreasonably disturbs the land, wildlife, or vegetative resources.

• The provisions of the Alaska National Interest Lands Conservation Act (ANILCA; P.L. 

96-487) that require the Forest Service to allow access to private inholdings will continue 

to apply.

• As provided for in the Travel Management Rule, none of the alternatives preclude the 

forest from closing roads, trails, or areas to motorized use through emergency closure 

orders if the conditions specified in the regulations are met (36 CFR 212.52(b)(2)).

In essence, people must continue to follow State and Federal rules and regulations in addition to 

the motor vehicle use map.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 17

Alternative 1 – No Action

The no action alternative is no change from current management direction or level of 

management intensity. The “no action” alternative may be thought of in terms of continuing with 

the present course of action until that action is changed (CEQ’s 40 Most Asked Questions, No. 3). 

Therefore, for this project, the no action alternative is the forest’s best estimate of where people 

drive now, which reflects the current management and present course of action.

Alternative 1, the no action alternative, displays existing conditions and provides a baseline for 

comparing the other alternatives. Under the no action alternative, the conflicting direction 

contained in the 1987 “Santa Fe National Forest Plan” (forest plan) and other written direction 

(e.g., closure orders and the forest visitor map) would continue to guide motor vehicle use in the 

national forest. The Travel Management Rule would not be implemented, and no motor vehicle 

use map would be produced. No permanent prohibition on motorized cross-country travel would 

be in place. No changes to the existing transportation system would be made. Without clear 

direction, motorized use of the national forest would continue in more or less the same manner as 

it does presently. 

Table 4 shows where people drive now, which is the present course of action. Because we don’t 

have complete information on all the places being used, we made some assumptions and 

estimates. A detailed explanation of the assumptions for alternative 1 is found in the project 

record in a document called “How Alternative 1 (No Action) is Defined” dated November 16, 

2009.

Table 4. Alternative 1, no action – where people drive now

Row 

No. Type of Route Total 

Miles

Miles Being Driven on 

(percent of total forest system)

1

All system roads and trails on the Santa Fe National 

Forest (does not include unauthorized routes since these 

are not part of the forest’s transportation system)

6,899 --

2 System roads not managed as open for motorized use 1,349 269 (4%)

3 System roads managed as open for motorized use 5,084 4,751 (69%)

4 Unauthorized routes that may be open for motorized 

use* 914 540 (N/A)

5 System trail built for nonmotorized uses outside 

wilderness* 459 41 (less than 1%)

6 Motorized system trails 26 26 (less than 1%)

Total miles of National Forest System routes being 

driven on 5,087 (74%)

Type of Area Acres

(percent of total forest system)

7

Total acres of National Forest System lands on Santa Fe 

National Forest (does not include private or other 

inholdings)

1,553,369 (100%) 

(Percents below do not add up to 

100 because uses overlap.)

8 National Forest System land being used for any kind of 

motorized use 443,848 (29%)

9 Motorized access to dispersed camping 17,195 (1%)

10 Motorized retrieval of downed big game 1,258,361 (81%)

*If the route is in a place where motorized cross-country travel is allowed, then motorized travel on the route is 

allowed.
Chapter 2. Alternatives, Including the Proposed Action

18 FEIS for Travel Management on the Santa Fe National Forest

Approximately 41 miles (row 4) of system trails built for nonmotorized uses are being used by 

motorized groups. Though these trails were built for nonmotorized uses like hiking, the forest 

doesn’t actively discourage motorized use on them.

The forest built 26 miles (row 5) of system trail specifically for motorized use, and motorized 

groups indicated to us that they ride on all of them.

Areas and Fixed-distance Corridors People are Driving on Now

The acres of National Forest System lands within the Santa Fe National Forest’s boundary, 

1,553,369, are shown in row 7. This figure excludes land held privately. It is all the acres of 

public land managed by the Santa Fe National Forest.

The 443,848 acres (row 8) where motorized cross-country travel is estimated to occur is shown in 

figure 5. Staff on the five ranger districts identified places where people drive off roads regularly 

for dispersed camping, collecting forest products, driving for pleasure, ATV use, and 4-wheel 

drive use.

We estimate that people drive and camp close to roads on about 17,195 acres (row 9). During 

2008 and 2009, ranger district personnel conducted field inventories to determine where people 

“car camp.” A complete description of the protocol used and results obtained is located in the 

project record (USDA Forest Service 2008d). For ease of comparison to the other alternatives, we 

placed corridors for alternative 1 around these existing sites. We acknowledge that people are also 

driving cross country in the forest at large to camp; however, we think this is relatively small 

compared to that which occurs along roads. 

The area being used by people retrieving downed game with a vehicle is estimated at 1,258,361

acres (row 10). It is all the acres outside of the four congressionally designated wilderness areas 

on the forest. As explained in the document called “How Alternative 1 (No Action) is Defined,”

neither the Forest Service nor the New Mexico Department of Game and Fish have data on where 

people drive to retrieve game animals. The interdisciplinary team thought it reasonable to assume 

that game could potentially be retrieved from any part of the forest where a vehicle could go, and 

excluded wilderness areas because those tend to have specific access points so people know 

where they are. This figure is in no way meant to imply that hunters are not following the rules. 

In the absence of data, we made this assumption. It is likely that people can’t drive on many of 

these acres due to slope, vegetation, and terrain.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 19

Figure 5. Alternative 1 (no action)—roads, trails, and areas where people drive now. The fixed-distance

corridors shown are based on the dispersed camping inventories done by the forest in 2008 and 2009 to 

show what people use now.
Chapter 2. Alternatives, Including the Proposed Action

20 FEIS for Travel Management on the Santa Fe National Forest

Format Describing the Action Alternatives

Alternatives 2 through 5, the “action” alternatives, all propose changes to the forest’s current

motorized travel system. (Because alternative 1 is the baseline where no changes are proposed, 

the following format doesn’t apply.) To make it easier to compare the alternatives, each is 

described using the same format:

1. The theme or principle behind the alternative.

2. The six kinds of specific, proposed changes to the current motorized travel system, as 

follows:

a. Motorized cross-country travel: All of the action alternatives would prohibit the 

public from using a vehicle off designated National Forest System roads, National 

Forest System motorized trails, and areas on National Forest System lands shown on 

the motor vehicle use map except as allowed by permit or other authorization. This 

changes the forest’s current policy, which allows motorized travel on 53 percent of 

the forest, and satisfies the requirement in the Travel Management Rule (36 CFR 

212.1; 70 FR 68273-4). Four of the action alternatives keep small areas, intended for 

motorcycle trials and dispersed camping, open for motorized cross-country travel.

b. Changes to existing National Forest System routes: Changes to existing system 

routes include closing routes to motorized use, allowing motorized use on routes that 

currently prohibit it, converting roads to trails, or vice versa.

c. Adding routes to the system: All of the action alternatives propose to add 

unauthorized routes to the forest’s transportation system. Unauthorized routes have 

been proposed for these reasons: (1) to provide a diversity of desirable motorized 

recreational experiences in appropriate locations; (2) to provide access to certain 

places in the forest; (3) to provide motorized dispersed camping (usually at the end of 

a short spur road); and (4) to provide access to private land. The document called 

“GEN08_TravelMgt_UnauthorizedRoutesDesignations_20110502.xlsx” in the 

project record contains the unauthorized routes proposed for addition and the reason 

why for each alternative. The calculations upon which each table showing the 

unauthorized routes is based on is found in the document called 

“GEN09_TravelMgt_PurposeOfUnauthRoute_20120112_JB.xlsx” in the project 

record. In a few instances, routes that do not exist on the ground are proposed to 

provide motorized access to private property, to show an easement owned by the 

Forest Service, or to provide motorized recreation (figure 6). In these cases, the 

route’s exact alignment would be determined at a future date, and construction 

allowed only after the appropriate environmental analysis and permitting is done. 

d. Changing motorized access to dispersed camping or big game retrieval: The 

Travel Management Rule at section 212.51(b) provides for the optional designation 

of “the limited use of motor vehicles within a specified distance of certain designated 

routes and, if appropriate, within specified time periods, solely for the purposes of 

dispersed camping or retrieval of a downed big game animal by an individual who 

has legally taken that animal.” The action alternatives propose varying amounts of 

motorized access for these purposes, depending on the emphasis of the alternative.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 21

Figure 6. Area where a trail existed before the Cerro Grande Fire. 

Motorcyclists requested that we repair and open it again. 

e. Changing vehicle class allowed on routes: The action alternatives include changes 

to the types of vehicles, such as passenger cars or motorcycles, allowed on routes. 

(The current motorized travel system does not specify what kinds of vehicles are 

allowed on roads or trails. By default, then, all vehicles are allowed anywhere they 

can physically pass.) In many cases, the types of vehicles allowed correspond with 

existing tread widths. For instance, routes designated as single track generally 

accommodate motorcycles only, whereas routes designated for vehicles 50 inches 

wide or less accept motorcycles and ATVs. The forest does not intend to reconstruct

routes to match the vehicle class. Some routes, though designated for all vehicles, 

may be too rough for a passenger car. Some routes may exist as two tracks on the 

ground, and be designated as single track to provide that kind of riding experience. 

The forest would not, however, close one of the tracks to make a single track.

f. Changing season of use: The action alternatives propose different combinations of 

seasonal closures depending on the focus of the alternative. Seasonal closures are 

composed of restrictions to protect breeding wildlife and to prevent driving on routes 

when they are wet and vulnerable to damage. The current motorized travel system

does not contain uniform seasonal restrictions.

3. Features unique to the alternative.

4. A table showing the motorized system that results from the proposed changes—this 

shows how much of the forest would be open for driving. The calculations from which 

these tables are created are in the spreadsheet 

“GEN05c_TravelMgt_RoutesByMOT_ExistCond_JB_20111221.xlsx”.

5. A map of the designated roads, trails, areas, and fixed-distance corridors.
Chapter 2. Alternatives, Including the Proposed Action

22 FEIS for Travel Management on the Santa Fe National Forest

A brief description of proposed amendments to the forest plan follows alternative 5. Appendix 1 

contains the exact text of the forest plan amendments for each alternative.

The miles, acres, and percent changes shown in this FEIS for alternatives 1, 2, 3, 4, and 5 differ 

from those shown in the DEIS. The reason is the groupings composing each category—such as 

unauthorized routes or routes managed as open to motorized use—have changed. It’s important to 

note that this doesn’t constitute a substantive change in the designations proposed in each 

alternative. The alternatives shown in the DEIS are the same as those in the FEIS (except 

alternative 2M, which is new), outside of alignment changes and other minor corrections (USDA 

Forest Service 2011e).

Appendix 2 contains tables summarizing the proposed changes, how this differs from the current 

motorized travel system, how it differs from where people drive now, and the resultant system for 

each alternative. Appendix 2 contains this summary for letters a through d described above. The 

calculations that support letters e and f are located in these spreadsheets in the project record:

GEN01_TravelMgt_RoutesByMOT_20111220_JBworking.xlsx and 

GEN07_TravelMgt_SeasonalDates_20120124_JB.xlsx. To find out if a route has a new seasonal 

restriction or is proposed to be closed to certain kinds of vehicles, refer to the large maps of the 

alternatives.

All miles, acres, and percentages have been rounded to the nearest whole number. The totals 

shown in the tables and text may differ slightly due to rounding.

Alternative 2

1. Theme: Alternative 2 is the proposed action 

described in the draft environmental impact 

statement published July 22, 2010. 

2. Proposed changes to existing travel policy:

a. Motorized cross-country travel: 

• Motorized travel by the public off 

designated National Forest System 

roads, trails, and areas shown on the 

motor vehicle use map would be 

prohibited except as allowed by permit 

or other authorization. 

b. Changes to existing National Forest 

System routes:

• Allow motorized use by all vehicles on 64 miles of system roads not currently 

managed as open for motorized use.

• Allow motorized use by highway legal vehicles only on 2 miles of system roads 

not currently managed as open.

• Convert 48 miles of closed system roads to motorized system trail; 14 miles for 

motorcycles only and 34 miles for vehicles less than or equal to 50 inches wide.

• Convert 102 miles of open system roads to motorized system trail; 26 miles for 

motorcycles only and 76 miles for vehicles less than or equal to 50 inches wide.

Features Unique to Alternative 2

• Motorized access for dispersed 

camping and big game retrieval are 

in the same corridors.

• Keeps most of the existing use for 

motorized dispersed camping.

• Keeps 11 unique areas (40 acres 

total) open for motorized crosscountry use.

• Has the most (11) different seasonal 

closure dates.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 23

• Convert 259 miles of system roads open to all vehicles to be open to highway 

legal vehicles only.

• Close 2,813 miles of open system roads to all motorized use.

• Allow motorized use for motorcycles only on 8 miles of system trail not built for 

motorized use outside wilderness. 

• Close 7 miles of motorized system trail.

• Change 7 miles of open system road that is coincident with motorized trail to be 

2 miles for motorcycles only, 3 miles for vehicles 50 inches or less, and 2 miles 

open to all vehicles.

c. Adding routes to the system (table 5):

• Add 51 miles of unauthorized routes as roads open to all vehicles.

• Add 3 miles of unauthorized routes as roads open to highway legal vehicles only.

• Add 10 miles of unauthorized routes as motorized trails for vehicles 50 inches 

wide or less.

• Add 78 miles of unauthorized routes as motorized trails open to motorcycles 

only. 

d. Changing motorized access to dispersed camping or big game retrieval:

• Designate approximately 16,237 acres along 423 miles of National Forest System

routes solely for the purpose of motorized access to dispersed camping or to 

retrieve a downed big game animal. In alternative 2, the corridors for dispersed 

camping and motorized big game retrieval are the same. We propose the 

corridors in two widths, either 150 or 300 feet from either side of the route.

e. Changing vehicle class allowed on routes:

• 2,027 miles would be open to all vehicles.

• 263 miles would be open to vehicles legal on paved highways (no ATVs or 

motorcycles that are not street legal).

• 123 miles would be open to vehicles 50 inches or less in width.

• 140 miles would be open to motorcycles only.

f. Changing season of use:

• 720 miles of routes would be open all year.

• 1,832 miles of routes would be open seasonally.

3. Features unique to alternative 2: Alternative 2 proposes motorized access for dispersed 

camping and big game retrieval in the same corridors because the New Mexico 

Department of Game and Fish requested that hunters not be treated differently than other 

drivers. This alternative allows motorized access to dispersed camping where it currently 

happens along roads and trails, except where forest staff identified unacceptable resource 

damage during field surveys. Alternative 2 has 11 different dates for seasonal closures in 

an effort to provide the best balance between resource protection and motorized access. 

The dates are tailored to individual situations, which allows more access than does 

“grouping” dates.

4. Designated motorized system that results from the changes (table 6).
Chapter 2. Alternatives, Including the Proposed Action

24 FEIS for Travel Management on the Santa Fe National Forest

5. The roads, trails, areas, and fixed-distance corridors proposed in alternative 2 are 

shown in figure 7.

Table 5. Miles of unauthorized routes proposed for designation and reason why in 

alternative 2 

Reason for 

Proposed 

Designation

Type of Designation (miles)

Road 

Open to 

All 

Vehicles

Road Open 

to Highway 

Legal 

Vehicles 

Only

Trail Open 

to 

Motorcycles 

Only

Trail Open to 

Vehicles 

Less than 50 

Inches Wide

Unauthorized 

Route, Not 

Designated

Total

Camping 9 1 2 11

Connector 13 1 2 15

General access 14 10 24

Motorized trail 2 78 10 67 158

Private access 13 1 3 17

Not designated 317 317

Total 51 2 78 10 401 541

Table 6. The designated motorized system as a result of the changes proposed in 

alternative 2

Kind of Vehicle Allowed Miles Miles Open 

by Time of Year

Percent Open 

by Time of 

Year

Roads

Open to all vehicles 2,027

All year 532 26%

Seasonal 1,494 74%

Open to vehicles legal on 

paved highways* 263

All year 152 58%

Seasonal 111 42%

Trails

Open to vehicles less than or 

equal to 50 inches wide 123

All year 12 10%

Seasonal 110 90%

Open to motorcycles only 141

All year 24 17%

Seasonal 117 83%

Miles Percent Open All Year

Total roads 2,290 30%

Total trails 263 14%

Total trails, vehicles ≤ 50 inches 

wide 123 10%

Total trails, motorcycles only 140 17%

GRAND TOTAL, Alternative 2 2,552 28%

Acres Miles

Areas 40 NA

Corridors - dispersed camping 16,237 423

Corridors - big game retrieval 16,237 423

* Under New Mexico State law, ATVs are not allowed on paved highways but are allowed on nonsurfaced highways.
FEIS for Travel Management on the Santa Fe National Forest 25

Chapter 2. Alternatives, Including the Proposed Action

Figure 7. Roads, trails, areas, and fixed-distance corridors proposed – alternative 2
Chapter 2. Alternatives, Including the Proposed Action

26 FEIS for Travel Management on the Santa Fe National Forest

Alternative 2M

1. Theme: Alternative 2M is the forest supervisor’s 

preferred alternative. It is similar to alternative 2, 

the proposed action, but modified as a result of the 

public’s comments and our subsequent analysis.

The modifications are primarily adding or 

removing specific routes, not allowing motorized 

travel off roads or trails within 100 feet of water in 

areas and fixed-distance corridors, and has no set 

closure dates for weather.

2. Proposed changes to existing travel policy:

a. Motorized cross-country travel: 

• Motorized travel by the public off 

designated National Forest System roads, 

trails, and areas shown on the motor 

vehicle use map would be prohibited 

except as allowed by permit or other 

authorization.

• Alternative 2M would not allow any 

vehicles within 100 feet of water (FSM 

2526.03). The concept of not driving near 

water was originally presented in the draft 

environmental impact statement in 

alternative 3, which proposes no driving off 

roads for any reason.

b. Changes to existing National Forest System routes:

• Allow motorized use by all vehicles on 65 miles of system roads not currently 

managed as open for motorized use.

• Allow motorized use by highway legal vehicles only on 2 miles of system roads 

not currently managed as open.

• Convert 39 miles of closed system roads to motorized system trail; 13 miles for 

motorcycles only and 26 miles for vehicles less than or equal to 50 inches wide.

• Convert 68 miles of open system roads to motorized system trail; 22 miles for 

motorcycles only and 47 miles for vehicles less than or equal to 50 inches wide.

• Convert 108 miles of system roads open to all vehicles to be open to highway 

legal vehicles only.

• Close 2,878 miles of open system roads to all motorized use.

• Allow motorized use for motorcycles only on 3 miles of system trail not built for 

motorized use outside wilderness. 

• Close 13 miles of motorized system trail.

• Change 4 miles of open system road that is coincident with motorized trail to be 

2 miles for motorcycles only, 1 mile for vehicles 50 inches or less, and 1 mile 

open to all vehicles.

Features Unique 

to Alternative 2M

• Doesn’t allow driving off roads or 

trails within 100 feet of water in 

areas or corridors.

• Motorized access for dispersed 

camping and big game retrieval are 

in the same corridors. All corridors 

are 150 feet from either side of the 

road.

• Seasonal closures: Keeps closure 

dates for protection of wildlife 

habitat. No set closure dates for 

weather; those would be handled 

with individual closure orders on an 

annual basis.

• Keeps 41 acres as motorized crosscountry use areas.

• Motorized use in inventoried 

roadless areas allowed on a caseby-case basis.

• Keeps 81 percent of the motorized 

dispersed camping corridors being 

used now.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 27

c. Adding routes to the system (table 7):

• Add 48 miles of unauthorized routes as roads open to all vehicles.

• Add 7 miles of unauthorized routes as motorized trails for vehicles 50 inches 

wide or less.

• Add 82 miles of unauthorized routes as motorized trails open to motorcycles 

only. 

d. Changing motorized access to dispersed camping or big game retrieval:

• Designate approximately 13,856 acres along 381 miles of National Forest System

routes solely for the purpose of motorized access to dispersed camping or to 

retrieve a downed big game animal. In alternative 2M, the corridors for dispersed 

camping and motorized big game retrieval are the same. All corridors would be 

150 feet from either side of the road.

e. Changing vehicle class allowed on routes:

• 2,144 miles would be open to all vehicles.

• 111 miles would be open to vehicles legal on paved highways (no ATVs or 

motorcycles that are not street legal).

• 80 miles would be open to vehicles 50 inches or less in width.

• 128 miles would be open to motorcycles only.

f. Changing season of use:

• 2,298 miles of routes would have no set closure date, but could be closed 

individually during wet seasons.

• 164 miles of routes would be closed certain times of year to protect wildlife.

3. Features unique to alternative 2M: Alternative 2M proposes motorized access for 

dispersed camping and big game retrieval in the same corridors because the New Mexico 

Department of Game and Fish requested that hunters not be treated differently than other 

drivers. This alternative prevents motorized access in the designated corridors within 100 

feet of water in areas and fixed-distance corridors2

. Alternative 2 keeps the seasonal 

closures for wildlife protection listed in the forest plan. It would have no set closure dates 

for weather. Instead, roads and trails would be closed as needed in wet weather, allowing 

for the most flexibility in access while balancing resource protection. This alternative 

proposes to designate some existing roads or trails in inventoried roadless areas, but 

reduces motorized access from the existing condition in them.

4. Designated motorized system that results from the changes (table 8).

5. The roads, trails, areas, and fixed-distance corridors proposed in alternative 2M are 

shown in figure 8.

 

2 The Forest Service Manual defines a riparian area as being at least 100 feet from the edges of streams, lakes, and 

other bodies of water (FSM Section 2526.03 Riparian Management Policy). Thus, we chose to not allow vehicles 

within 100 feet of water in areas and fixed-distance corridors as a starting point. Future site-specific analyses may 

show that vehicles could be allowed closer, or need to be pulled even farther back depending on the site. This 

provision doesn’t apply to roads and trails because that would fundamentally alter the forest’s transportation 

infrastructure since a great deal of roads, trails, and developed recreational sites are within 100 feet of water now.
Chapter 2. Alternatives, Including the Proposed Action

28 FEIS for Travel Management on the Santa Fe National Forest

Table 7. Miles of unauthorized routes proposed for designation and reason why in 

alternative 2M

Reason for 

Proposed 

Designation

Type of Designation (miles)

Road 

Open to 

All 

Vehicles

Road Open 

to Highway 

Legal 

Vehicles 

Only

Trail Open 

to 

Motorcycles 

Only

Trail Open to 

Vehicles 

Less Than 

50 inches

Wide

Unauthorized 

Route, Not 

Designated

Total

Camping 9 less than 1 1 11

Connector 13 less than 1 2 15

General access 14 10 24

Motorized trail 4 82 7 66 158

Private access 8 less than 1 8 17

Not designated 317 317

Total 48 1 82 7 404 541

Table 8. The designated motorized system as a result of the changes proposed in

alternative 2M

Kind of Vehicle Allowed Miles Miles Open 

by Time of Year**

Percent Open by 

Time of Year**

Roads

Open to all vehicles 2,144

All year 2,017 94%

Seasonal 127 6%

Open to vehicles legal on 

paved highways* 111

All year 110 99%

Seasonal 1 1%

Trails

Open to vehicles less than 

or equal to 50 inches wide 80

All year 68 85%

Seasonal 13 16%

Open to motorcycles only 128

All year 104 81%

Seasonal 24 19%

Miles Percent Open All Year**

Total roads 2,255 94%

Total trails 208 82%

Total trails, vehicles ≤ 50 inches wide 80 84%

Total trails, motorcycles only 128 81%

GRAND TOTAL, Alternative 2M 2,463 93%

Acres Miles

Areas 41 NA

Corridors - dispersed camping 13,856 381

Corridors - big game retrieval 13,856 381

* Under New Mexico State law, ATVs are not allowed on paved highways but are allowed on nonsurfaced highways.

**Roads or trails may be closed due to wet weather on an individual basis, but no set closure dates for weather are 

proposed.
FEIS for Travel Management on the Santa Fe National Forest 29

Chapter 2. Alternatives, Including the Proposed Action

Figure 8. Roads, trails, areas, and fixed-distance corridors proposed – alternative 2M
Chapter 2. Alternatives, Including the Proposed Action

30 FEIS for Travel Management on the Santa Fe National Forest

Alternative 3

1. Theme: Alternative 3 emphasizes natural 

resource protection and habitat quality while 

still providing motorized access to and in the 

forest. It incorporates the concerns raised in 

significant issues 1 (protection of natural and 

cultural resources) and 3 (motorized dispersed 

camping).

2. Proposed changes to existing travel policy:

a. Motorized cross-country travel: 

• Motorized travel by the public off 

designated National Forest System roads, trails, and areas shown on the motor 

vehicle use map would be prohibited except as allowed by permit or other 

authorization. 

b. Changes to existing National Forest System routes:

• Allow motorized use by all vehicles on 39 miles of system roads not currently 

managed as open for motorized use.

• Allow motorized use by highway legal vehicles only on 2 miles of system roads 

not currently managed as open.

• Convert 12 miles of closed system roads to motorized system trail; 1 mile for 

motorcycles only and 11 miles for vehicles less than or equal to 50 inches wide.

• Convert 37 miles of open system roads to motorized system trail; 8 miles for 

motorcycles only and 29 miles for vehicles less than or equal to 50 inches wide.

• Convert 239 miles of system roads open to all vehicles to be open to highway 

legal vehicles only.

• Close 3,309 miles of open system roads to all motorized use.

• Close 22 miles of motorized system trail.

• Change 2 miles of open system road that is coincident with motorized trail to be 

2 miles open to all vehicles.

c. Adding routes to the system (table 9):

• Add 34 miles of unauthorized routes as roads open to all vehicles.

• Add 2 miles of unauthorized routes as roads open to highway legal vehicles only.

• Add 1 mile of unauthorized routes as motorized trails open to motorcycles only.

d. Changing motorized access to dispersed camping or big game retrieval:

• No fixed-distance corridors for motorized access to dispersed camping or big 

game retrieval would be designated. 

Features Unique to Alternative 3

• Has the fewest routes open for 

driving.

• Allows no driving off roads or trails 

for any reason.

• Adds only 1 mile of unauthorized 

trail.

• Has four different seasonal closure 

dates.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 31

e. Changing vehicle class allowed on routes: 

• 1,574 miles would be open to all vehicles.

• 243 miles would be open to vehicles legal on paved highways (no ATVs or 

motorcycles that are not street legal).

• 41 miles would be open to vehicles 50 inches or less in width.

• 12 miles would be open to motorcycles only.

f. Changing season of use:

• 516 miles of routes would be open all year.

• 1,354 miles of routes would be open seasonally.

3. Features unique to alternative 3: Of the alternatives, the changes proposed in 

alternative 3 would result in the fewest places where people could drive. It would not 

allow people to drive off roads or trails anywhere for any reason unless under permit or 

other authorization. This means that to camp, people must park next to the side of the 

road and then tote their gear to a camping spot. They could not drive their car to the 

campsite. Hunting and retrieving game would similarly need to be done by foot, 

horseback, or other nonmotorized method. Alternative 3 would not add any unauthorized 

trails to the system. This means that people wanting to ride on loops would be restricted 

mainly to the road system. This alternative would not designate any unauthorized 

motorized trails in inventoried roadless areas. This alternative contains four different 

seasonal closure dates. One is the forest standard for weather, and the remaining are for 

wildlife protection.

4. Designated motorized system that results from the changes is shown in table 10.

5. The roads, trails, areas, and fixed-distance corridors proposed in alternative 3 are 

shown in figure 9.
Chapter 2. Alternatives, Including the Proposed Action

32 FEIS for Travel Management on the Santa Fe National Forest

Table 9. Miles of unauthorized routes proposed for designation and reason why in 

alternative 3

Reason for 

Proposed 

Designation

Type of Designation (miles)

Road 

Open to 

All 

Vehicles

Road Open 

to Highway 

Legal 

Vehicles 

Only

Trail Open 

to 

Motorcycles 

Only

Trail Open to 

Vehicles 

Less Than 

50 Inches 

Wide

Unauthorized 

Route, Not 

Designated

Total

Camping 6 1 4 11

Connector 7 less than 1 8 15

General access 6 18 24

Motorized trail 2 1 less than 1 154 158

Private access 12 1 4 17

Not designated 317 317

Total 34 2 1 less than 1 504 541

Table 10. The designated motorized system as a result of the changes proposed in 

alternative 3

Kind of Vehicle 

Allowed Miles Miles Open 

by Time of Year

Percent 

Open by 

Time of Year

Roads

Open to all vehicles 1,574

All Year 399 25%

Seasonal 1,175 75%

Open to vehicles legal on 

paved highways* 243

All Year 111 46%

Seasonal 132 54%

Trails

Open to vehicles less than 

or equal to 50 inches wide 41

All Year 2 4%

Seasonal 39 96%

Open to motorcycles only 12

All Year 4 34%

Seasonal 8 66%

Miles Percent Open All Year

Total roads 1,817 28%

Total trails 53 11%

Total trails, vehicles ≤ 50 inches wide 41 4%

Total trails, motorcycles only 12 34%

GRAND TOTAL, Alternative 3 1,869 28%

Acres Miles

Areas 0 NA

Corridors - dispersed camping 0 0

Corridors - big game retrieval 0 0

* Under New Mexico State law, ATVs are not allowed on paved highways but are allowed on nonsurfaced highways.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 33

Figure 9. Roads and trails proposed– alternative 3
Chapter 2. Alternatives, Including the Proposed Action

34 FEIS for Travel Management on the Santa Fe National Forest

Alternative 4

1. Theme: Alternative 4 emphasizes motorized 

access and recreation while protecting natural 

and cultural resources. It addresses concerns 

raised in significant issues 2 (motorized access 

and recreation), 3 (motorized dispersed 

camping), and 4 (motorized big game retrieval).

2. Proposed changes to existing travel policy:

a. Motorized cross-country travel: 

• Motorized travel by the public off 

designated National Forest System 

roads, trails, and areas shown on the 

motor vehicle use map would be 

prohibited except as allowed by permit 

or other authorization. 

b. Changes to existing National Forest 

System routes:

• Allow motorized use by all vehicles on 123 miles of system roads not currently 

managed as open for motorized use.

• Allow motorized use by highway legal vehicles only on 1 mile of system roads 

not currently managed as open.

• Convert 80 miles of closed system roads to motorized system trail; 20 miles for 

motorcycles only and 59 miles for vehicles less than or equal to 50 inches wide.

• Convert 200 miles of open system roads to motorized system trail; 43 miles for 

motorcycles only and 157 miles for vehicles less than or equal to 50 inches wide.

• Convert 114 miles of system roads open to all vehicles to be open to highway 

legal vehicles only.

• Close 2,533 miles of open system roads to all motorized use.

• Allow motorized use for motorcycles only on 36 miles of system trail not built 

for motorized use outside wilderness. 

• Close 7 miles of motorized system trail.

• Change 7 miles of open system road that is coincident with motorized trail to be 

2 miles for motorcycles only, 3 miles for vehicles 50 inches or less, and 2 miles 

open to all vehicles.

c. Adding routes to the system (table 11):

• Add 69 miles of unauthorized routes as roads open to all vehicles.

• Add 2 miles of unauthorized routes as roads open to highway legal vehicles only.

• Add 23 miles of unauthorized routes as motorized trails for vehicles 50 inches 

wide or less.

• Add 112 miles of unauthorized routes as motorized trails open to motorcycles 

only.

Features Unique to Alternative 4

• Has the most routes open for 

driving.

• Keeps 29 unique areas (49 acres 

total) open for motorized crosscountry use.

• Individual closure orders would be 

used for weather.

• Has the most places where people 

could drive to retrieve downed 

game.

• Has the most places where people 

could drive to access dispersed 

camping.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 35

d. Changing motorized access to dispersed camping or big game retrieval:

• Designate approximately 32,890 acres along 461 miles of National Forest System

routes solely for the purpose of motorized access to dispersed camping. The 

corridors would all be 300 feet from either side of the route.

• Designate approximately 1,098,330 acres along 2,847 miles of National Forest 

System routes solely for the purpose of motorized access to retrieve downed big 

game. The corridors would all be 1 mile from either side of all designated routes, 

except where they cross wilderness, the Santa Fe watershed, or private property. 

e. Changing vehicle class allowed on routes: 

• 2,434 miles would be open to all vehicles.

• 120 miles would be open to vehicles legal on paved highways (no ATVs or 

motorcycles that are not street legal).

• 243 miles would be open to vehicles 50 inches or less in width.

• 219 miles would be open to motorcycles only.

f. Changing season of use:

• 2,672 miles of routes would be open all year.

• 345 miles of routes would be open seasonally.

3. Features unique to alternative 4: Of the action alternatives, the changes proposed in 

alternative 4 would result in the most miles of designated routes and the highest number 

of acres designated for motorized use. It would not have uniform seasonal closures for 

weather, which means that people would be able to drive on routes until they “closed 

themselves” with snow or until the ranger districts put closure orders on them. Seasonal 

closures for wildlife would remain in place at the minimums specified in the forest plan. 

Alternative 4 would have two different corridor widths: 300 feet for motorized access to 

dispersed camping, and 1 mile for motorized retrieval of downed big game. This 

alternative would add the most miles of unauthorized routes to the system. 

4. Designated motorized system that results from the changes is shown in table 12.

5. The roads, trails, areas, and fixed-distance corridors proposed in alternative 4 are 

shown in figure 10.
Chapter 2. Alternatives, Including the Proposed Action

36 FEIS for Travel Management on the Santa Fe National Forest

Table 11. Miles of unauthorized routes proposed for designation and reason why in 

alternative 4

Reason for 

Proposed 

Designation

Type of Designation (miles)

Road 

Open to 

All 

Vehicles

Road Open 

to Highway 

Legal 

Vehicles 

Only

Trail Open 

to 

Motorcycles 

Only

Trail Open to 

Vehicles 

Less Than 50 

Inches Wide

Unauthorized 

Route, Not 

Designated

Total

Camping 9 1 1 11

Connector 15 less than 1 less than 1 15

General Access 22 2 24

Motorized Trail 8 112 23 14 158

Private access 15 1 1 17

Not designated 317 317

Total 69 2 112 23 335 541

Table 12. The designated motorized system as a result of the changes proposed in 

alternative 4

Kind of Vehicle Allowed Miles Miles Open 

by Time of Year

Percent Open 

by Time of Year

Roads

Open to all vehicles 2,434

All Year 2,219 91%

Seasonal 215 9%

Open to vehicles legal on 

paved highways* 120

All Year 119 100%

Seasonal 2 0%

Trails

Open to vehicles less than or 

equal to 50 inches wide 243

All Year 206 85%

Seasonal 37 15%

Open to motorcycles only 219

All Year 128 59%

Seasonal 92 41%

Miles Percent Open All Year

Total roads 2,554 92%

Total trails 462 73%

Total trails, vehicles ≤ 50 inches wide 243 85%

Total trails, motorcycles only 219 59%

GRAND TOTAL, Alternative 4 3,017 89%

Acres Miles

Areas 49 NA

Corridors - dispersed camping 32,890 461

Corridors - big game retrieval 1,098,330 2,847

* Under New Mexico State law, ATVs are not allowed on paved highways but are allowed on nonsurfaced highways.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 37

Figure 10. Roads, trails, areas, and fixed-distance corridors proposed –alternative 4
Chapter 2. Alternatives, Including the Proposed Action

38 FEIS for Travel Management on the Santa Fe National Forest

Alternative 5

1. Theme: Alternative 5 geographically groups 

motorized and nonmotorized uses separately as 

much as possible to reduce conflicts between 

visitors. It addresses the concern raised in 

significant issue 5 (conflicts between motorized 

and nonmotorized users).

2. Proposed changes to existing travel policy:

a. Motorized cross-country travel:

• Motorized travel by the public off 

designated National Forest System 

roads, trails, and areas shown on the motor vehicle use map would be prohibited 

except as allowed by permit or other authorization. 

b. Changes to existing system routes:

• Allow motorized use by all vehicles on 73 miles of system roads not currently 

managed as open for motorized use.

• Allow motorized use by highway legal vehicles only on 7 miles of system roads 

not currently managed as open.

• Convert 58 miles of closed system roads to motorized system trail; 14 miles for 

motorcycles only and 44 miles for vehicles less than or equal to 50 inches wide.

• Convert 130 miles of open system roads to motorized system trail; 21 miles for 

motorcycles only and 109 miles for vehicles less than or equal to 50 inches wide.

• Convert 324 miles of system roads open to all vehicles to be open to highway 

legal vehicles only.

• Close 2,860 miles of open system roads to all motorized use.

• Allow motorized use for motorcycles only on 19 miles of system trail not built 

for motorized use outside wilderness. 

• Close 12 miles of motorized system trail.

• Change 4 miles of open system road that is coincident with motorized trail to be 

2 miles for motorcycles only and 2 miles open to all vehicles.

c. Adding routes to the system (table 13):

• Add 52 miles of unauthorized routes as roads open to all vehicles.

• Add 4 miles of unauthorized routes as roads open to highway legal vehicles only.

• Add 14 miles of unauthorized routes as motorized trails for vehicles 50 inches 

wide or less.

• Add 73 miles of unauthorized routes as motorized trails open to motorcycles 

only.

Features Unique to Alternative 5

• Has about the same miles of routes 

open for people to drive on as 

alternative 2, but arranges them 

differently on the landscape.

• Keeps nine unique areas (35 acres 

total) open for motorized crosscountry use.

• Has five different seasonal closure 

dates.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 39

d. Changing motorized access to dispersed camping or big game retrieval:

• Designate approximately 11,422 acres along 294 miles of National Forest System

routes solely for the purpose of motorized access to dispersed camping. The 

corridors would be 150 or 300 feet from either side of the route.

• Designate approximately 370,841 acres along 373 miles of National Forest 

System routes solely for the purpose of motorized access to retrieve downed big 

game. The corridors would all be 1 mile from either side of some routes, except 

where they cross wilderness or private property. 

e. Changing vehicle class allowed on routes: 

• 1,897 miles would be open to all vehicles.

• 334 miles would be open to vehicles legal on paved highways (no ATVs or 

motorcycles that are not street legal).

• 167 miles would be open to vehicles 50 inches or less in width.

• 139 miles would be open to motorcycles only.

f. Changing season of use:

• 695 miles of routes would be open all year.

• 1,842 miles of routes would be open seasonally.

3. Features unique to alternative 5: Alternative 5 clusters motorized routes, with 

motorized recreation in mind, in certain places in the forest. This means that motorized 

recreation could occur away from nonmotorized recreation on a larger scale. This 

alternative contains five different seasonal closure dates. One is the forest standard for 

weather, and the remaining are for wildlife protection.

4. Designated motorized system that results from the changes is shown in table 14.

5. The roads, trails, areas, and fixed-distance corridors proposed in alternative 5 are 

shown in figure 11.
Chapter 2. Alternatives, Including the Proposed Action

40 FEIS for Travel Management on the Santa Fe National Forest

Table 13. Miles of unauthorized routes proposed for designation and reason why in 

alternative 5

Reason for 

Proposed 

Designation

Type of Designation (miles)

Road 

Open to 

All 

Vehicles

Road Open 

to Highway 

Legal 

Vehicles 

Only

Trail Open 

to 

Motorcycles 

Only

Trail Open to 

Vehicles 

Less Than 50 

Inches Wide

Unauthorized 

Route, Not 

Designated

Total

Camping 8 1 2 11

Connector 11 0 4 15

General access 19 5 24

Motorized trail 3 73 14 68 158

Private access 12 2 3 17

Not designated 317 317

Total 52 4 73 14 398 541

Table 14. The designated motorized system as a result of the changes proposed in 

alternative 5

Kind of Vehicle Allowed Miles Miles Open 

by Time of Year

Percent 

Open by 

Time of 

Year

Roads

Open to all vehicles 1,897

All year 580 31%

Seasonal 1,317 69%

Open to vehicles legal on 

paved highways 334

All year 72 22%

Seasonal 263 78%

Trails

Open to vehicles less than or 

equal to 50 inches wide 167

All year 21 12%

Seasonal 147 88%

Open to motorcycles only 139

All year 22 16%

Seasonal 117 84%

Miles Percent Open All Year

Total roads 2,231 29%

Total trails 306 14%

Total trails, vehicles ≤ 50 inches 

wide 167 12%

Total trails, motorcycles only 139 16%

GRAND TOTAL, Alternative 5 2,537 28%

Acres Miles

Areas 35 NA

Corridors - dispersed camping 11,422 294

Corridors - big game retrieval 370,841 371

* Under New Mexico State Law, ATVs are not allowed on paved highways but are allowed on nonsurfaced highways.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 41

Figure 11. Roads, trails, areas, and fixed-distance corridors proposed –alternative 5
Chapter 2. Alternatives, Including the Proposed Action

42 FEIS for Travel Management on the Santa Fe National Forest

Proposed Amendments to the Forest Plan

The exact text of the proposed amendments is located in appendix 1. This section provides an 

overview of the proposed changes common to alternatives 2 through 5:

• Change language in the forest plan to be consistent with the Travel Management Rule. 

For example, change off-road vehicle to off-highway vehicle.

• Motor vehicle use by the public off the designated system of roads, trails, and areas is 

prohibited, except as identified on the motor vehicle use map or where exempted under 

36 CFR 212.51.

• Prohibit motorized cross-country travel in all management areas.

• Remove the lower limit of the open road density standards for all management areas. This 

would make the lower limit zero.

• Allow motorized cross-country travel on some acres in management areas where it had 

previously been prohibited for the purpose of motorized access to dispersed camping and 

to retrieve big game. 

• Allow motorized use of some roads and trails in management areas where it had 

previously been prohibited. The miles of roads and trails affected vary by alternative.

Features Common to All Action Alternatives

The things listed in this section would be a part of any alternative selected.

Removing routes from the motor vehicle use map: If, through monitoring, the Forest Service 

finds that motor vehicle use on a route is directly causing adverse effects on public safety or on 

natural or cultural resources, it may be closed immediately per 36 CFR 212.52(b)(2) until the 

forest supervisor determines that such adverse effects have been mitigated or eliminated. 

A monitoring plan will be written separately from this NEPA document (36 CFR 212.57, 70 FR 

26879).

Tracked vehicles: Tracked vehicles would be permitted in all the alternatives as long as they met 

the size class shown on the motor vehicle use map.

Spur routes for access to motorized dispersed camping: All the action alternatives propose to 

designate numerous short spur routes that end at dispersed campsites. This adds to the motorized 

dispersed camping provided for by fixed-distance corridors.

Motorized trails for vehicles 50 inches or less: All motorized trails designated for vehicles 50 

inches wide or less would also allow motorcycles.

Parking safely next to the side of the road: Parking safely next to the side of any designated

road or trail would be allowed in all the alternatives. Parking would be allowed within 30 feet

from the edge of the road surface. This project does not prohibit any forest activities, only where 

a person could drive to do the activity. Parking next to the road means a person could still have a 

picnic, set up a campsite, ride their bicycle, hike, or do any other activity they do now.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 43

ATV-only trails: None of the action alternatives proposes motorized trails just for ATVs. ATVs 

would be allowed on designated motorized trails for vehicles less than or equal to 50 inches wide 

and roads designated as open to all vehicles. 

Jeep or 4x4 trails: We did not specifically identify jeep trails in any of the alternatives. Jeeps and 

4x4s would be allowed on all designated roads, but not trails. Many of the forest roads, due to 

remoteness and condition, effectively serve as jeep or 4x4 trails without being specially 

designated as such. Technical driving skill varies by individual. 

Big game: Except in alternative 3 where no motorized big game retrieval is proposed, the game 

that licensed hunters may use vehicles to retrieve includes elk and mule deer (New Mexico 

Department of Game and Fish 2009). Only hunters with a valid license and a tagged animal may 

use a vehicle to retrieve game.

Ground disturbance: None of the action alternatives propose any ground-disturbing activities 

such as obliterating roads, constructing new routes, or installing gates or berms. Such activities 

would require separate analysis under the National Environmental Policy Act.

Mitigations

The Council on Environmental Quality’s regulations for implementing NEPA define mitigations

as measures that avoid, minimize, reduce, rectify, or compensate for impacts to the physical 

environment resulting from Federal actions (40 CFR 1508.20). They are things the Forest Service 

will do as part of implementing the decision to lessen any potential damage to natural or cultural 

resources. The mitigation measures listed here apply to all the action alternatives.

Cultural Resources

Where we identify substantial impacts to cultural resource sites from route designation, we will 

apply one of three mitigations:

1. The route, or a portion of the route, will be excluded from the motor vehicle use map.

2. The route, or portion of the route, will be plated (covered and armored). 

3. The route, or a portion of the route, will be rerouted, reconstructed, or will undergo 

another kind of physical mitigation. These activities would all require separate NEPA 

analysis and compliance with the National Historic Preservation Act.

Where we identify substantial impacts to cultural resource sites from fixed-distance corridors for 

motorized dispersed camping or areas, we will apply one of two mitigations:

1. The corridor, or portions of the corridor, will be excluded from the motor vehicle use map 

so that sites are excluded from a corridor. 

2. Other kinds of physical mitigation such as placement of fencing or barriers will be 

constructed to exclude sites from effects associated with designating the corridor.
Chapter 2. Alternatives, Including the Proposed Action

44 FEIS for Travel Management on the Santa Fe National Forest

Where we identify impacts to traditional cultural properties from motorized access, we will apply 

two mitigations:

1. Where motorized access to traditional cultural properties is reduced because of 

designation, we will grant special use or other authorizations to users.

2. Where traditional cultural properties have the potential to be physically impacted by 

routes, fixed-distance corridors, or areas, mitigation will consist of not designating them 

or using other kinds of mitigation to reduce adverse effects. In some cases, consultation 

with traditional communities may result in other mitigation measures that would avoid or 

not adversely affect traditional cultural properties.

Wildlife

Unauthorized roads and trails that go through Jemez Mountain salamander habitat won’t be 

published on the motor vehicle use map until they have been assessed for potential resource 

concerns and appropriate actions are taken to minimize effects to resources. 

Any new motorized routes through Mexican spotted owl habitat will be evaluated for effects and 

have seasonal restrictions placed on them consistent with the forest plan. 

Alternatives Considered but Not Studied in Detail

This section describes the alternatives considered but eliminated from detailed study and the 

reasons why. We present these in no particular order.

Both the Forest Service and the public developed alternatives that have not been carried forward 

in detail. Most suggestions from the interdisciplinary team and the public were not fully 

developed alternatives. Rather, they were conceptual suggestions for one aspect of the proposal, 

such as having corridors on every route. Or, they covered only one part of the forest, such as 

Glorieta Mesa or the Jemez Mountains. No alternative from the public contained a map of 

proposed designated routes for the entire forest.

To make this section easier to read, we bundled similar suggestions into thematic alternatives. 

The project record contains the description of how we bundled the suggestions (USDA Forest 

Service 2010d).

Current Motorized Travel Policy Alternative

This alternative is the forest’s current motorized travel policy, shown in detail in appendix 4. Key 

elements of this alternative are:

• It would allow motorized cross-country travel on 53 percent of the forest.

• It is ambiguous about where motorized use of trails and roads would be allowed. 

• It would not limit motorized access for dispersed camping or big game retrieval.

• It would not have consistent seasonal restrictions.

• It would not specify the kinds of vehicles that may drive on certain routes.

• It would rely on closure orders to restrict motorized use.

• It contains conflicting direction on where motorized vehicles are allowed.
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 45

Reason Not Analyzed In Detail

The interdisciplinary team did not analyze this alternative in detail for several reasons. This 

alternative does not meet the project’s purpose and need because it doesn’t establish a clearly 

designated system of roads, trails, areas, and fixed-distance corridors required by the Travel 

Management Rule. By not restricting motorized cross-country travel, it would not reduce the 

detrimental effects to natural and cultural resources from unmanaged motorized cross-country 

use. 

July 2008 Proposed Action

The July 2008 proposed action resembles alternative 2 shown in this FEIS, but doesn’t propose 

any corridors for motorized big game retrieval and is less accurate in its route alignments than 

alternative 2.

Reason Not Analyzed In Detail

The regulations don’t require us to analyze a proposal that we’ve modified (36 CFR 220.5(e)(1)). 

Since we’ve made changes to the proposed action since July 2008, it is an alternative considered 

and eliminated from detailed study. We’ve documented the incremental changes in the project 

record (USDA Forest Service 2010c).

Alternative 1 with No Motorized Cross-Country Travel

The public brought this alternative forward in its comments on the DEIS. It would continue the 

present course of action by designating all forest system roads and trails for motorized use but 

prohibiting motorized cross-country travel.

Reason Not Analyzed In Detail

Designating all the forest’s roads and trails for motorized use would not meet the criteria for 

designation listed in 36 CFR 212.55. For example, trails are to be designated with the objective of 

minimizing damage to soil, watershed, vegetation, and other forest resources (§212.55(b)(1)). 

Many roads and trails have been identified as causing damage to natural and cultural resources as 

early as the publication of the “Travel Analysis Process Report” (USDA Forest Service 2008b). 

During field verification, we found that many forest system roads and trails don’t exist. To 

designate these would be permitting cross-country travel (figure 12). Finally, designating all the 

forest roads as open to motorized travel wouldn’t meet the open road density standards shown in 

the forest plan.

Highway Legal Vehicles Only

The public brought this alternative forward in its comments on the DEIS. It would only allow 

highway legal vehicles (e.g., no ATVs and only some motorcycles) into the national forest.

Reason Not Analyzed In Detail

The Travel Management Rule never intended to eliminate motorized recreation in the national 

forests; instead, it seeks to designate motorized use where appropriate. The use of ATVs and 

motorcycles is a legitimate use of the national forest when properly managed.
Chapter 2. Alternatives, Including the Proposed Action

46 FEIS for Travel Management on the Santa Fe National Forest

Figure 12. Designating a motorized trail here would be the same thing 

as allowing motorized cross-country travel

Minimum Road System Alternative

This alternative would designate the 3,737 miles of roads identified as being the minimum 

“needed for safe and efficient travel and for administration, utilization, and protection of National 

Forest System lands” (36 CFR 212, Subpart A) in the “Travel Analysis Process Report” (USDA 

Forest Service 2008b).

Reason Not Analyzed In Detail

This alternative would not meet the project’s purpose and need because it does not provide for a 

designated system of roads and trails. It describes the roads needed and contains only a cursory 

mention of trails. It is silent on motorized cross-country travel in areas. It also designates roads 

for administrative purposes, and these are exempt from designation pursuant to the Travel 

Management Rule (§212.51(a)(4)). 

The “Travel Analysis Process Report” meets the requirements of subpart A of the rule whereas the 

designation process meets subpart B. 

Maximum Motorized Access and Recreation Alternative

This alternative is composed of suggestions from the public and the Forest Service. Key elements 

are:

• Designate every existing road in the Santa Fe National Forest’s transportation system, 

and all the unauthorized routes. 

• Focus on designating recreational, motorized loops.

• Designate 300-foot corridors on all designated routes for motorized dispersed camping. 
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 47

• Make the fixed-distance corridors into areas where driving to all activities, such as 

picnicking, day use, or firewood collection, would be allowed.

• Change the “open to vehicles less than 50 inches” designation to “open to vehicles less 

than 60 inches” in light of newer UTVs having a wheelbase of 54 to 60 inches.

• Have routes designated for ATVs only.

Reason Not Analyzed In Detail

This alternative would not fulfill the purpose and need, which is in part to counter detrimental 

effects to natural and cultural resources from roads, trails, and unmanaged motorized crosscountry travel. Not all the forest’s routes receive use and a number of them have reverted to their 

natural state.

As recorded in various meeting notes in the project record, we initially considered two

alternatives that responded to the significant issue of variety and kinds of motorized access. One 

would have featured routes that primarily went out and back (access), and another that would 

have focused on motorized loops (recreation). Since travel management is a tool to provide for 

the needs of all motorized users, not just for motorized recreation, we concluded that it was not 

appropriate to segregate those two types of uses. Instead, alternative 4 combined access and 

recreation by providing more kinds of motorized opportunities of all kinds than the proposed 

action. Alternative 5, by responding to the issue of conflicts between uses, provided a way to have 

more motorized loops in some parts of the forest and less in others without sacrificing motorized 

access.

People are not currently camping along 

every route in the forest (USDA Forest 

Service 2009g). Many of the forest’s routes 

are not suitable for driving off road to 

camp due to slope, terrain, or vegetation. 

For alternative 2, district personnel 

identified where people are currently 

camping, then the alternatives varied from 

that baseline. Alternative 4, for example, 

proposes 300-foot corridors for motorized 

dispersed camping on some routes to 

accommodate potential future use.

After much debate, we concluded that 

converting the fixed-distance corridors into 

areas did not meet the intent of the Travel 

Management Rule, which is to have areas be much smaller than ranger districts. To participate in 

day use activities, parking safely within 30 feet of all designated routes is an option in all the 

action alternatives. People with permits may drive places that are not on the motor vehicle use 

map according to the exemptions listed in the Travel Management Rule (§212.55(a)(8)).

Based on public comments, we believe that keeping motorized trails open only to smaller 

vehicles is desirable. Motorcycle riders in particular commented that they wanted trails that were 

not shared with large vehicles. UTVs with wheelbases larger than 50 inches will continue to be 

allowed on routes designated for all vehicles.

Figure 13. Trials riding in the Jemez Mountains
Chapter 2. Alternatives, Including the Proposed Action

48 FEIS for Travel Management on the Santa Fe National Forest

We looked at designating routes solely for ATVs; however, it did not appear to be needed based 

on the lack of public comment requesting such. Staff on the ranger districts indicated that ATV 

riders appear to be satisfied using forest routes that are shared with full-size vehicles on roads, or 

with motorcycles on trails. 

Minimum Motorized Access and Recreation Alternative

Key features of this alternative are one or more of the following:

• Only designate routes for which the Forest Service can maintain and enforce the correct 

use.

• Do not add any unauthorized routes.

• Do not designate any roads for high-clearance vehicles.

• Do not designate any trails for motorized use.

• Do not designate any routes in inventoried roadless areas.

• Designate individual motorized dispersed campsites instead of fixed-distance corridors.

• Designate only trails that meet current trail maintenance standards. 

• Reduce the miles of routes near wilderness.

Reason Not Analyzed in Detail

We do not intend to eliminate motorized access to and motorized recreational use of the national 

forest since vehicles are an integral part of peoples’ enjoyment of their public lands.

Not adding any unauthorized routes isn’t reasonable and goes against the intent of the Travel 

Management Rule (70 FR 68270, 68277). The public currently uses the unauthorized routes, 

which in many cases provide important recreational opportunities. Some of these routes are well 

laid out and are not causing unacceptable resource damage. Some, like National Forest System

trails, may need minor maintenance only.

The Santa Fe National Forest has numerous high-clearance roads that exist for important reasons 

and that the public has used for decades. To not designate any of these roads would prevent the 

public from using their public lands. All routes 

were subject to environmental and social 

analysis in order to determine if motorized use 

on these routes is appropriate.

The Santa Fe National Forest currently has 

approximately 210 miles of system and known 

unauthorized routes in its inventoried roadless 

areas. Of these, we estimate that people are 

now driving on approximately 168 miles. 

Chapter 3 contains a detailed discussion of 

routes in inventoried roadless areas. All the 

action alternatives propose routes that cross 

inventoried roadless areas to varying degrees, 

depending on the emphasis of the alternative. 

Proposing no routes in inventoried roadless 

Figure 14. A meadow that has not been 

driven on 
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 49

areas was not possible. Some of the routes existed prior to the roadless inventory and are needed 

to get to private land. Some boundaries of the inventoried roadless areas were not correctly 

mapped and contained roads in error. At the time of this writing, designating motorized trails in 

inventoried roadless areas was permitted and was requested by motorized groups as providing a 

unique riding opportunity.

The Travel Management Rule has no provision for the designation of individual campsites, so this 

suggestion is beyond the scope of this project. Instead, where appropriate, the alternatives have 

routes that lead to dispersed campsites. 

Chapter 3 looks at the miles of routes near wilderness by alternative. Only Congress can create 

wilderness areas. We proposed routes near wilderness in accordance with the focus of the 

alternative, not to expand or contract wilderness.

Private Property Alternative

This alternative suggested two different ways to handle access to private property:

• Provide only one access route to contiguous blocks of private land, regardless of the 

number of subdivided parcels contained within. 

• Designate no roads to private property. 

Reason Not Analyzed in Detail

Limiting existing access routes to one per block of private land would not be possible due to the 

history of private land access on the Santa Fe National Forest and the extensive property 

ownership research that would be required (USDA Forest Service 2012i). We proposed 

designating routes to private property on a case-by-case basis where the private ownership is 

clear. In other cases where subdivision and ownership facts are not clear, we defaulted to the 

solution of designating existing access route(s). Where we are certain duplicate access can be 

removed, we proposed it.

Not designating any routes to private property is not possible because it would mean the 

landowners would be unable to legally drive to their property until they had a written 

authorization in place. If a road does not appear on the motor vehicle use map, and the property 

owner does not have an authorization, then motorized travel on the road would be illegal.

Forest staff would not be able to process the anticipated requests for authorizations had we not 

designated roads to private property. The process for obtaining a written authorization is lengthy

and expensive. In the interim, people would not be able to legally drive to their property. As a 

result, we concluded that it would be prudent to designate roads to private property, and then 

work to issue authorizations for those who desire and can afford them over time.

Enforcement Alternative

The idea behind this alternative is to designate roads and trails in a physical configuration that 

would make enforcement easier. This alternative could include pinch points, more motorized 

access (where all use is legal), less motorized access (where any use off a very few routes is 

illegal), fewer seasonal dates, or other elements.
Chapter 2. Alternatives, Including the Proposed Action

50 FEIS for Travel Management on the Santa Fe National Forest

Reason Not Analyzed in Detail

Members of the interdisciplinary team met with the forest’s law enforcement officers to attempt 

to flesh out this alternative. The group concluded that configurations that would make 

enforcement easier would not meet the project’s purpose and need. If all the routes were 

designated, then resource protection would not be achieved to the desired level. If very few routes 

were designated, then needs for access to use and enjoy the national forest would not be met. 

Some places on the forest might lend themselves to “pinch points,” places where routes converge, 

but most do not. The motor vehicle use map will be the primary enforcement tool. We will 

consider other methods of education and enforcement during implementation.

Administrative Alternative

This alternative, a combination of suggestions submitted independently, contains 

recommendations for controlling off-highway vehicle use by administrative means. Its main 

features include:

• Have nonmotorized volunteer community patrols work with the Forest Service to protect 

public lands.

• Require permits for all motorized use of the forest. Permits would be free if using the 

designated system and at a cost if operating off the system.

• Issue travel regulations and policies with each permit.

• Use the permit system to monitor use, and temporarily close off areas to mitigate damage 

to sensitive areas.

• Rotate open and closed places over the years.

• Require permit holders, like ranchers, and the Forest Service itself, to operate on 

horseback or on foot.

• Develop an education plan.

• Develop an enforcement plan 

and increase the budget for 

enforcement.

• Enforce noise limits of 80

decibels or less.

• Require spark arrestors on all 

off-highway vehicles.

• Have sizable fines for off-road 

abuse.

• Post signs on routes.

• Install barriers, like gates or 

berms, to physically block 

roads as part of closing routes 

to motorized use (figure 15).

Reason Not Analyzed in Detail

Things like education, signing, putting in physical barriers, working with volunteer groups, and 

enforcement are outside the scope of this decision, which will result in a designated motorized 

Figure 15. Example of a fence built to block ATVs 

from shortcutting roads
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 51

system. We like some of these suggestions and could use and expand on them during 

implementation of the project. 

The State of New Mexico has jurisdiction over things like decibel limits, fines, licensing, and 

registration.

Constructing physical barriers usually entails disturbing the ground, which requires site-specific 

analysis under the National Environmental Policy Act. Analyzing site-specific impacts from 

ground disturbances is outside the scope of this analysis, which is at a forestwide level. In coming 

years we plan to identify routes that are still causing negative environmental effects and do 

separate NEPA analysis to determine the best way to mitigate those effects. If constructing 

barriers or physical obliteration is necessary, then we would do the analysis for that.

Motorized Big Game Retrieval Alternative

This alternative focused on methods for providing and controlling motorized access to retrieve 

downed big game. Key points include:

• Require licensed hunters to purchase a permit for off-road access to retrieve downed big 

game.

• The permit would be hunt specific, limited to a certain window and only to that hunter. 

Game could only be retrieved using an off-highway vehicle between 12 p.m. and 4 p.m.

• Require hunters to fill out a followup “use report” indicating whether the permit was used 

to retrieve an animal off road. Set penalties for not filling out the use report.

• Set strict consequences for failing to follow the permit system.

Reason Not Analyzed in Detail

We didn’t study this alternative in detail because the Forest Service does not have the regulatory 

authority to set up this kind of permit system.

Glorieta Mesa Alternative

This alternative contains recommendations specific to Glorieta Mesa, mostly its north end. Its key 

points are:

• Eliminate the fixed-distance corridors that provide motorized access to dispersed 

camping. 

• Designate loop roads for vehicles legal on paved highways only so that no ATVs or dirt 

bikes would be allowed.

• Close motorized access on roads where significant negative impact to natural resources, 

adjacent private property, and traditional uses has already occurred.

• Notify and involve permit holders, inholders, and adjacent property holders before 

modifying the transportation plan in any way.

• Do not allow ATVs or dirt bikes to use any places used by local ranchers.
Chapter 2. Alternatives, Including the Proposed Action

52 FEIS for Travel Management on the Santa Fe National Forest

Reason Not Analyzed in Detail

We didn’t consider this a stand-alone alternative because it pertains only to a small part of the 

Santa Fe National Forest. This project’s geographic scope covers the entire national forest. Staff 

on the Pecos/Las Vegas Ranger District, where Glorieta Mesa is located, considered each 

suggestion made and incorporated it into one or more alternatives. If a suggestion wasn’t included 

in an alternative, district staff provided the reason why (USDA Forest Service 2010g and 2010i; 

appendix 7).

Citizen’s Alternative to Include Traditional User-created Trail 

Routes in the Santa Fe National Forest OHV Transportation Rule 

(August 28, 2008) and the Amendment to the Citizen’s Alternative

to Include Historical and New Event Sites for Motorcycle Observed 

Trials in the Santa Fe National Forest Draft EIS (August 28, 2008)

This alternative requests that a large network of single-track trails and trials riding areas, mainly 

in the Jemez Mountains, be adopted. The Blackfeather Trail Preservation Alliance, a subgroup of 

the New Mexico Off-Highway Vehicle Alliance, and the New Mexico Trials Association prepared 

and submitted it. The Blue Ribbon Coalition wrote to support it. Key elements of this alternative 

include:

• Analyze all of the routes and areas submitted by motorized users in the “No Change” 

alternative. (Note: This has been done as part of alternative 1, no action.)

• Loops should be comprised primarily of single track or double track, and have a 

minimum amount of roads as part of mileage.

• Designate this approximate mileage for multiple use (motorcycles, equestrians, hikers, 

and bicyclists): 120 miles of major system roads; 275 miles of user-maintained logging 

roads and system trails; and 115 miles of user-created and maintained trails.

• Designate appropriate areas for motorcycle trials, which include a staging area with 

parking and camping; a loop with termini at the staging area; and sections containing 

obstacles.

• Conduct a cultural resources survey of the routes to establish that they comply with the 

Antiquities Act. The group believes that routes over a certain age are historic and, thus,

should be designated.

• Repair routes through mitigation measures rather than close them to motorized use

altogether.

• Initiate a process for opening routes to motorized use in nonwilderness areas currently 

closed to motorized vehicles.

Reason Not Analyzed in Detail

We did not analyze this alternative as a stand-alone alternative because it does not pertain to the 

whole forest, and this project is being conducted at the forestwide level. We did analyze each 

specific loop and route submitted to see if it could be included in one or more alternatives (USDA 

Forest Service 2010g and 2010i).

We incorporated some of the conceptual suggestions included with this alternative into one or 

more alternatives. Personnel on the Jemez, Coyote, and Española Ranger Districts (where the 

majority of the routes were proposed) worked hard to include loops composed of single and 
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 53

double track with few roads in all the action alternatives, but especially in alternative 4. The 

Jemez Ranger District included the trials areas requested by motorcycle riders in alternatives 2, 

2M, 4, and 5. It is not clear where the specific mileages listed come from, or which routes the 

“user-maintained logging roads” refers to. The forest’s GIS personnel analyzed the routes 

provided by motorized users and determined whether they were existing routes or new routes 

(USDA Forest Service 2008a). 

The rest of the conceptual suggestions are already decided by law, regulation, or policy. All the 

routes on the Santa Fe National Forest will be available for multiple use. This project does not 

restrict nonmotorized use in any way, so hikers, mountain bikers, and equestrians will be able to 

use routes that are designated for motorized use. The National Historic Preservation Act dictates 

the process the Forest Service will comply with to survey and clear cultural resources, not the 

Antiquities Act. The Santa Fe National Forest’s report documenting the requirements of Section 

106 will contain the recommendations to approve cultural resource clearance for designation. 

Where possible, we intend to mitigate routes rather than close them; however, this will not apply 

to all routes. Finally, this designation process is one that could result in “new”—that is, 

unauthorized—routes being opened in nonmotorized areas outside of wilderness. The motor 

vehicle use map will be printed every year, and new routes may be added once the proper 

environmental analysis has taken place.

Science-based Alternative

The main idea behind this alternative is that, when designating a system for motorized use, the 

Forest Service focus on the science, and not put the idea of multiple use above the science. Key 

points include:

• The environmental analysis should dictate the designated route system.

• Include adaptive management triggers.

Reason Not Analyzed in Detail

Considering environmental consequences is already mandated. The forest supervisor will 

consider the environmental consequences and explain how she considered and evaluated them in 

the record of decision. The purpose of the NEPA process is to “...provide full and fair discussion 

of significant environmental impacts and ... inform decision makers and the public of the 

reasonable alternatives which would avoid or minimize adverse impacts or enhance the quality of 

the human environment” (40 CFR 1502.1). 

We considered incorporating adaptive management at several stages of the process (USDA Forest 

Service 2009b and 2009e). We eventually concluded that adaptive management required an 

exhaustive, site-specific analysis that is beyond the scale of this project (USDA Forest Service 

2009e). Periodically revising the motor vehicle use map effectively serves as adaptive 

management.

Landscape-based Alternative

The main ideas behind this alternative, submitted by Wild Earth Guardians and others, were to 

use landscape planning principles in route designation and to expand the concept of the motor 

vehicle use map into a fully developed travel management plan. Its guiding principle was to 

reduce the amount of motorized use from that described in the proposed action. Its key points are:
Chapter 2. Alternatives, Including the Proposed Action

54 FEIS for Travel Management on the Santa Fe National Forest

• Incorporate landscape planning principles into route designation, rather than the road-byroad analysis done in the “Travel Analysis Process Report.”

• Use geographical features to constrain motorized recreation and prevent cross-country 

travel.

• Develop a full travel management plan, including route obliteration, education, and 

enforcement, not just the motor vehicle use map.

• Reduce overall route densities on the Santa Fe National Forest.

• Do not designate any unauthorized routes.

• Minimize user conflicts.

• Use monitoring and adaptive management to determine whether resource thresholds have 

been exceeded and action should be taken.

Reason Not Analyzed in Detail

As submitted, this alternative did not specify a designated system of roads, trails, and areas. It is 

unclear whether any routes are proposed in this alternative. The 174 pages of tabular appendices 

to this letter contain lists of routes “within proximity of, located within, or transverse (sic) areas 

of the forest easily impacted by motorized vehicle use. These sensitive areas ... should be 

candidates for closure, decommissioning, or minimally seasonal closures to motorized use (sic).” 

We propose to close many of the routes in these tables already. The tables disregarded the need to 

connect routes; in other words, it appears that all routes in all sensitive areas were listed as 

candidates for closure, without regard for needs for access to and within the forest.

Though landscape planning principles can be incorporated, in order to create a map each road, 

trail, and area must be analyzed using the criteria listed in the Travel Management Rule (36 CFR 

212.55). The interdisciplinary team appreciated the suggestion on landscape planning and 

incorporated those principles in alternative 3, where larger blocks of land without routes were 

proposed, and alternative 5, which separated motorized and nonmotorized uses. The latter also 

addressed the issue of conflicts between users.

All the action alternatives reduce open road densities in each management area from the present 

situation, and all meet the open road densities in the forest plan (USDA Forest Service 2012r).

Education, enforcement, monitoring, and route obliteration are all beyond the scope of this 

project. We will, however, consider incorporating each during implementation.

Monitoring Alternative

Several people wrote to ask that the Forest Service include monitoring as part of this project. We 

received many creative suggestions, including:

• Create a thorough, science-based monitoring plan with action-oriented management 

responses to address problem areas associated with off-highway vehicle travel. 

• Monitor nonmotorized areas exactly as the motorized trail areas. 

• Baseline should be the existing condition of the areas. 

• Monitoring records need to be made public. 

• Use speed sensors, noise detectors, webcams, and other high-tech devices to monitor. 
Chapter 2. Alternatives, Including the Proposed Action

FEIS for Travel Management on the Santa Fe National Forest 55

• Embed colored gravels into ruts on closed trails and roads so disturbance of them shows 

unacceptable use.

Reason Not Analyzed in Detail

Monitoring is beyond the scope of this project, which is to provide for a designated system of 

roads, trails, and areas for motorized use. The Travel Management Rule, however, requires that 

monitoring be done: 

“For each administrative unit of the National Forest System, the responsible 

official shall monitor the effects of motor vehicle use on designated roads and 

trails and in designated areas under the jurisdiction of that responsible official, 

consistent with the applicable land management plan, as appropriate and 

feasible.” (36 CFR 212.57)

We will create a monitoring plan separately, and will consider these and other suggestions as part 

of it.

Equal Use Alternative

This alternative suggested that motorized route and area designations should be equally dispersed 

across all five ranger districts. 

Reason Not Analyzed in Detail

The Santa Fe National Forest’s terrain and district boundaries do not lend themselves to having 

equal amounts of motorized routes and areas. For example, the Pecos Wilderness, where no 

motorized use is allowed by law, composes almost 25 percent of the Pecos/Las Vegas Ranger 

District, whereas the Dome Wilderness on the Jemez Ranger District is about 2 percent of that 

district. Some ranger districts, like the Jemez, are closer to urban centers like Albuquerque than 

the Coyote Ranger District is. As a result, the Jemez generally has a higher demand for access to 

the forest and for places to ride recreationally. 

Road Density Alternative

Some people asked that the Santa Fe National Forest rework the way it calculates open road 

density, and to change the standards in the forest plan. The suggestions included:

• The forest should adhere to federally mandated road densities.

• Motorized trails should be included in the calculation of road density.

• Road density standards are outdated and not an accurate way to determine route 

designations.

• The forest plan’s open road densities are objectives, not standards.

• All routes, whether open or closed, should be included in the calculation of road density.

Reason Not Analyzed in Detail

We concluded that changing the method for calculating road density or the upper limit of the 

standards listed in the forest plan is beyond the scope of this project, which is to provide for a 

system of roads, trails, and areas designated for motorized use. Changing the upper limit of the 

road density standards or the way they are calculated is better suited for forest plan revision. 
Chapter 2. Alternatives, Including the Proposed Action

56 FEIS for Travel Management on the Santa Fe National Forest

We have proposed to remove the lower bound of road density. These proposed amendments to the 

forest plan clarify that the lower thresholds are not sensible in the context of the guideline’s intent 

of “limiting open road density.” It was never envisioned, for example, that if there were areas 

where road density was less than 1 mile per square mile that we would be required to build more 

road, or in this context, only consider alternatives that have at least 1 mile per square mile. 

Comparison of Alternatives

Table 15. Summary of the proposed changes for each alternative and how they compare to 

where people drive now

Where People Drive 

Now, No Action Type of Change 

Proposed

Action Alternative

Alternative 1 2 2M 3 4 5

Unauthorized 

roads and 

trails, miles

539 Add unauthorized roads 

and trails to National Forest 

System miles

141 138 37 206 143

Percent change from 

where people drive now

-74 -74 -93 -62 -73

Forest system 

roads and 

trails managed 

as closed to 

motorized use, 

miles

269 Allow motorized use on 

roads and trails currently 

closed, miles

114 106 53 204 137

Percent change from 

where people drive now

-58 -61 -80 -24 -49

Forest system 

roads and 

trails managed 

as open to 

motorized use, 

miles

4,751 Close roads and trails that 

currently allow motorized 

use, miles

2,272 2,207 1,776 2,552 2,224

Percent change from 

where people drive now

-52 -54 -63 -46 -53

Areas, acres* 443,848 Close areas that are 

currently open to motorized 

cross-country travel, acres*

821,604 821,603 821,644 821,595 821,609

Percent change from 

where people drive now

-100 -100 -100 -100 -100

Motorized 

dispersed 

camping, 

acres

17,195 Designate corridors for 

motorized access to 

dispersed camping, acres

16,237 13,856 0 32,890 11,422

Percent change from 

where people drive now

-6 -19 -100 91 -34

Motorized big 

game 

retrieval, acres

1,258,361 Designate corridors for 

motorized access to retrieve 

big game, acres

16,237 13,856 0 1,098,330 370,841

Percent change from 

where people drive now

-99 -99 -100 -13 -71

*The forest proposes to close more acres than people are driving on now. In other words, the whole forest will be 

closed to motorized cross-country travel. Taken from GEN01 and GEN05d excel spreadsheets.
FEIS for Travel Management on the Santa Fe National Forest 57

Chapter 2. Alternatives, Including the Proposed Action

Table 16. Summary of the effects described in detail in chapter 3

Resource Type

Alternative

1 2 2M 3 4 5

Motorized 

access and 

recreational 

opportunities

Roads, miles 5,218 2,290 2,255 1,817 2,554 2,231

Trails, miles 408 263 208 53 462 306

Areas, acres 443,848 40 41 0 49 35

Seasonal 

closure dates, 

number of 

different

No uniform dates 

exist

11 8 4 5 5

Big game 

retrieval, 

acres

1,258,361 16,237 – allowed 

only during hunting 

season with a 

license and downed

animal

13,856 – allowed 

only during hunting 

season with a 

license and downed

animal

0 1,098,330 –

allowed only 

during hunting 

season with a 

license and 

downed animal

370,841 – allowed 

only during hunting 

season with a 

license

Dispersed 

camping, 

acres

17,195 along roads, 

but driving off road 

to camp is also 

allowed on 53 

percent of the forest.

16,237 13,856 – no 

vehicles allowed 

within 100 feet of 

water

0 32,890 11,422

Unauthorized 

routes, miles

539 (miles being 

used now)

141 138 37 206 143

Conflicts 

between 

motorized 

and 

nonmotorize

d users of 

the forest

Tends to happen in 

particular places 

rather than 

forestwide.

Expected to reduce 

conflicts by keeping 

motorists on a 

known, published 

system.

Same as alternative 

2.

Same as alternative 

2.

Same as 

alternative 2.

Expected to reduce 

conflicts the most 

because it also 

groups motorized 

activities 

geographically.

Wilderness No motorized use 

allowed inside. 

Negligible 

disturbance from 

adjacent land due to 

infrequent use. Most 

potential to disturb.

Greatly reduces 

potential to cause 

disturbance inside 

wilderness.

Same as alternative 

2.

Least potential to 

cause disturbance 

in wilderness.

Most potential to 

cause disturbance 

in wilderness.

Same as alternative 

2.
Chapter 2. Alternatives, Including the Proposed Action

58 FEIS for Travel Management on the Santa Fe National Forest

Table 16. Summary of the effects described in detail in chapter 3

Resource Type

Alternative

1 2 2M 3 4 5

Inventoried 

roadless 

areas

Most motorized use 

in IRAs (120 miles)

Reduces routes open 

to motorized use in 

IRAs by 61 percent.

Reduces routes open 

to motorized use in 

IRAs by 58 percent.

Reduces routes 

open to motorized 

use by 67 percent 

and fewest miles

of trails in IRAs.

Reduces routes 

open to motorized 

use by 38 percent

and proposes most 

trails in IRAs.

Would need 

department 

approval to 

designate 2 miles 

of road.

Reduces routes 

open to motorized 

use in IRAs by 61

percent.

Ease of 

enforcement

and 

compliance

Visitor map serves as 

guide for motorists; it 

does not match the 

forest plan.

Improves by having 

a single reference; 

however, the 

MVUM would be 

the most 

complicated.

Improves by having 

a single reference, 

the MVUM.

Improves by 

having a single 

reference. The 

MVUM would be 

the least 

complicated.

Improves by 

having a single 

reference, the 

MVUM.

Improves by having 

a single reference, 

the MVUM.

Maintenance Forest cannot 

maintain the entire 

route system on an 

annual basis.

No change, but 

frequency of 

maintenance would 

increase

Same as alternative 

2.

Same as alternative 

2.

Same as 

alternative 2.

Same as alternative 

2.

Safety Route system is safe. No change No change No change No change No change

Social and 

economic

environment

Jobs and 

income from 

motorized 

use in the 

forest

Negligible at the 

scale of the local 

economy.

No change No change No change No change No change

Noise Most noise occurs on 

passenger car routes.

Highest amount of 

places in primitive 

and SPNM areas 

where noise could 

occur.

Reduces places 

where engine noise 

would occur by 

eliminating 

motorized crosscountry travel and 

reducing designated 

routes.

Same as alternative 

2.

Has the least 

amount of places 

where engine noise 

would occur.

Of the action 

alternatives, has 

the most places 

where engine 

noise would 

occur.

Same as alternative 

2.
FEIS for Travel Management on the Santa Fe National Forest 59

Chapter 2. Alternatives, Including the Proposed Action

Table 16. Summary of the effects described in detail in chapter 3

Resource Type

Alternative

1 2 2M 3 4 5

Property 

values

Could increase or 

decrease values 

depending on what 

characteristics people 

seek in a property.

No change No change No change No change No change

Collecting 

forest 

products

Allowed with a 

permit. No permit 

needed now to collect 

piñon nuts.

No change for 

permitted uses. 

Reduces places 

people can drive to 

collect piñon nuts 

and other plants.

May reduce user 

conflicts.

Same as alternative 

2.

No change for 

permitted uses. 

Reduces places 

where people can 

drive the most.

No change for 

permitted uses. 

Reduces places 

where people can 

drive the least.

Same as alternative 

2.

Environmental 

justice

No change in 

motorized related 

employment or 

access to the forest.

No measureable 

change to minority 

or low-income 

populations.

Same as alternative 

2.

Same as alternative 

2.

Same as 

alternative 2.

Same as alternative 

2.

Lands Access to 

private 

property

Provides the most 

access and keeps 

access people are 

accustomed to.

Removes some 

duplicate access. 

People must have an 

authorization or 

their road must be 

on the MVUM.

Same as alternative 

2.

Removes duplicate 

access. People 

must have an 

authorization or 

their road must be 

on the MVUM. 

Eliminates 

motorized access 

to some properties 

in inventoried 

roadless areas 

(IRAs).

Removes 

duplicate access. 

People must have 

an authorization 

or their road must 

be on the MVUM. 

Allows motorized 

use on some trails 

in IRAs for 

access.

Same as alternative 

2.
Chapter 2. Alternatives, Including the Proposed Action

60 FEIS for Travel Management on the Santa Fe National Forest

Table 16. Summary of the effects described in detail in chapter 3

Resource Type

Alternative

1 2 2M 3 4 5

Soil and 

water

Erosion and soil 

compaction from the 

use and existence of 

routes, motorized 

cross-country travel, 

and motorized 

dispersed camping in 

riparian areas likely 

to continue or 

increase.

Most likely to 

sustain current soil 

and water quality 

conditions. The 

effects from routes 

would stay the 

same, motorized 

cross-country use 

would be nearly 

eliminated, and 

there would be little 

change in acres 

available for 

motorized dispersed 

camping.

Most likely to 

sustain current soil 

and water quality 

condition, with the 

potential to improve 

over time. The 

effects from routes 

would stay the 

same, motorized 

cross-country use 

would be nearly 

eliminated, and no 

driving within 100 

feet of water is 

allowed.

Most likely to 

improve soil and 

water quality 

conditions. The 

effects from 

constructed routes 

would stay the 

same, but 

motorized crosscountry use and 

motorized 

dispersed camping 

would be 

eliminated.

Most likely to 

decrease soil and 

water quality 

conditions. The 

effects from 

routes would stay 

the same and 

motorized crosscountry use would 

be nearly 

eliminated. There 

would be over 

twice as many 

acres available for 

motorized 

dispersed 

camping.

Likely sustains

current soil and 

water quality 

condition, with 

potential to improve 

over time. Effects 

from routes would 

stay the same, 

motorized crosscountry use would 

be nearly 

eliminated, and 

there would be 

about a third less 

acres available for 

motorized dispersed 

camping.

Habitat for 

fish

The quality of fish 

habitat varies across 

the forest. It is not 

causing a trend 

toward listing or a 

loss of viability. 

Motorized trail in 

Polvadera Creek is a 

risk to the Rio 

Grande cutthroat 

trout.

Improves the quality 

of fish habitat 

across the forest. 

Protects the core 

population of Rio 

Grande cutthroat 

trout by not 

proposing the 

motorized trail in 

Polvadera Creek.

Second best to 

improve fish habitat 

by not allowing 

vehicles within 100 

feet of water.

Protects core 

population of Rio 

Grande cutthroat 

trout by not 

proposing 

motorized trail in 

Polvadera Creek.

Best for improving 

fish habitat by not 

allowing vehicles 

within 100 feet of 

water. Protects the 

core population of 

Rio Grande 

cutthroat trout by 

not proposing the 

motorized trail in 

Polvadera Creek.

Slightly improves 

the quality of fish 

habitat across the 

forest, but would 

not protect the 

core population of 

Rio Grande 

cutthroat trout in 

Polvadera Creek.

Slightly improves 

the quality of fish 

habitat across the 

forest, but would 

not protect the core 

population of Rio 

Grande cutthroat 

trout in Polvadera 

Creek.

Habitat for 

wildlife

The current route 

system and amount 

of motorized crosscountry travel is the 

most likely to disturb 

wildlife and its 

habitat.

Improves wildlife 

habitat and reduces 

disturbance from 

motorized use.

Improves wildlife 

habitat and reduces 

disturbance from 

motorized use by 

not allowing 

motorized use 

within 100 feet of 

water.

Improves wildlife 

habitat and reduces 

disturbance from 

motorized use the 

most because no 

driving off routes 

is allowed.

Improves wildlife 

habitat and 

reduces 

disturbance from 

motorized use the 

least of the action 

alternatives.

Improves wildlife 

habitat and reduces 

disturbance from 

motorized use.
FEIS for Travel Management on the Santa Fe National Forest 61

Chapter 2. Alternatives, Including the Proposed Action

Table 16. Summary of the effects described in detail in chapter 3

Resource Type

Alternative

1 2 2M 3 4 5

Nonnative 

invasive 

plants

Highest risk of 

establishment and 

spread.

Risk of 

establishment and 

spread considered 

low.

Same as alternative 

2.

Greatest decrease 

in the risk of 

establishment and 

spread because no 

driving off roads is 

allowed.

Risk of 

establishment and 

spread would be 

the highest among 

the action 

alternatives.

Risk of 

establishment and 

spread considered 

low to moderate.

Cultural 

resources

Moderate to high risk 

that cultural resource 

sites and traditional 

cultural properties 

would be damaged.

No adverse effect to 

cultural resource 

sites.

No adverse effect to 

cultural resource 

sites.

No adverse effect 

to cultural resource 

sites.

No adverse effect 

to cultural 

resource sites.

No adverse effect to 

cultural resource 

sites.

Air Quality Emissions of 

particulate matter are 

well below national 

standards.

No change No change No change No change No change

Health Health problems 

from dust from forest 

not known, but 

expected to be 

negligible.

Fewer locations 

where vehicles 

would cause dust.

Same as alternative 

2.

Fewest locations 

where vehicles 

would cause dust.

Of action 

alternatives, most

locations where 

vehicles would 

cause dust.

Same as alternative 

2.

Greenhouse 

Gases

Contribution from 

forest traffic is 

negligible.

No change No change No change No change No change

Visibility Good to excellent. Negligible 

improvement

Same as alternative 

2.

Same as alternative 

2.

Same as 

alternative 2.

Same as alternative 

2.

Wildfire Firefighters 

Response 

Time

Varies depending on 

location of the 

wildfire.

No change -

emergency vehicles 

are exempt.

Same as alternative 

2.

Same as alternative 

2.

Same as 

alternative 2.

Same as alternative 

2.

Number of 

Humancaused Fires

Average of 28 per 

year from 2000 to 

2010.

Slight decrease Same as alternative 

2.

Same as alternative 

2.

Same as 

alternative 2.

Same as alternative 

2.
Chapter 2. Alternatives, Including the Proposed Action

62 FEIS for Travel Management on the Santa Fe National Forest

Table 16. Summary of the effects described in detail in chapter 3

Resource Type

Alternative

1 2 2M 3 4 5

Visual 

Quality

Most locations where 

visual quality is 

degraded due to 

unauthorized routes 

and unmanaged 

motorized dispersed 

camping.

Slight increase in 

visual quality 

because no new 

unauthorized routes 

and less motorized 

dispersed camping.

Same as alternative 

2.

Has the most 

places where 

visual quality 

could improve 

because no driving 

off roads or trails 

allowed.

Has the most 

places of the 

action alternatives 

where visual 

quality could 

decrease.

Same as alternative 

2.
FEIS for Travel Management on the Santa Fe National Forest 63

Chapter 3. Affected Environment

and Environmental Consequences

This chapter is the scientific and analytic basis for comparing the alternatives (40 CFR 1502.16). 

It shows the tradeoffs among the alternatives for the public and the forest supervisor. It does not 

claim to accurately predict the outcomes of the alternatives. Rather, its purpose is to show the 

relative change among the alternatives. This chapter supports table 16 found at the end of chapter 

2. Before describing the predicted effects of the alternatives, we start by explaining the basic 

components of an effects analysis.

The Basic Components of an Effects Analysis

This section explains the basic components of an effects analysis done under the National 

Environmental Policy Act for those who are not familiar with the process.

The Affected Environment

An effects analysis starts by describing the affected environment. As the name implies, this 

section describes those parts of the environment or project area that would change as a result of 

the proposed action. The Council on Environmental Quality describes it this way:

“The environmental impact statement shall succinctly describe the environment 

of the area(s) to be affected or created by the alternatives under 

consideration. The descriptions shall be no longer than is necessary to 

understand the effects of the alternatives.” (40 CFR 1502.15).

Using an example of a person wanting to lose weight, the affected environment would be the 

person’s weight, percent body fat, and current fitness level. It would not include what kind of car 

they drive or where they attended grade school, for instance.

The affected environment describes what is going on now. The existing condition is the baseline 

against which to compare the other alternatives. It is alternative 1, no action.

Effects

An effect is the result of an action. If you throw a rock into a pond, it makes ripples. Throwing the 

rock is the action, and the effect is the ripples. The environmental consequences are all the effects 

considered together.

The Council on Environmental Quality lists different kinds of effects that need to be analyzed 

under the National Environmental Policy Act:

1. Direct effects, which are caused by the action and occur at the same time and place.

2. Indirect effects, which are caused by the action and are later in time or farther removed in 

distance, but are still reasonably foreseeable.

3. Cumulative effects, which are the sum of the incremental impacts from the action 

combined with other actions. These are described in the next section.

To illustrate using the example of the person wanting to lose weight, let’s say they eat less and 

exercise more, two actions. The direct effects of these actions might be that the person feels 
Chapter 3. Affected Environment and Environmental Consequences

64 FEIS for Travel Management on the Santa Fe National Forest

hungry and has sore muscles. The indirect effects, those that happen later in time, would be that 

the person loses weight and gets stronger. In this example, effects are beneficial (improved 

fitness) and detrimental (hungry and sore muscles).

The same holds true for environmental consequences—they can be both beneficial and 

detrimental (40 CFR 1508.8). For the travel management project, closing roads to motorized use 

could improve wildlife habitat (beneficial effect for wildlife species) and reduce the amount of 

motorized recreational opportunities (detrimental impact to riders).

The regulations do not require agencies to separate the direct and indirect effects, so in this 

document we describe them together. Cumulative effects have their own section.

Cumulative Effects

The Council on Environmental Quality defines a cumulative effect like this: 

“‘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 nonFederal) or person undertakes such other actions. Cumulative impacts can result 

from individually minor but collectively significant actions taking place over a 

period of time.” (40 CFR 1508.7).

To be cumulative, effects must overlap in space and time. Continuing with the example of a 

person eating less and exercising more, a cumulative effect—if we suppose that many people 

were eating less and exercising more during the same year—could be a decrease in rates of 

diabetes. 

Cumulative impacts are important because they could cause a tipping point, either beneficial or 

negative. To analyze cumulative effects, we look at the effects from this proposal and add it to the 

effects from past, present, and reasonably foreseeable future actions. The next sections briefly 

summarize how the interdisciplinary team identified and handled the past, present, and reasonably 

foreseeable future actions. The full text of this discussion is in the project record (USDA Forest 

Service 2011f).

Past and Present Actions

The interdisciplinary team considered the effects of past actions from 1987 to the present as part 

of the existing condition. The current conditions in the forest are the sum total of past actions. We 

chose 1987 because that is the year the forest plan was published. The Council on Environmental 

Quality recognizes “agencies can conduct an adequate cumulative effects analysis by focusing on 

the current aggregate effects of past actions without delving into the historical details of 

individual past actions” (Council on Environmental Quality 2005). Innumerable actions over the 

last century and beyond have shaped the Santa Fe National Forest’s current designated road 

system. Attempting to isolate and catalog these individual actions and their effects would be 

nearly impossible. By looking at current conditions, we capture the effects of past human actions 

and natural events, regardless of which event contributed those effects. Listing the past actions, 

however, can show trends. On balance, some past actions increased the amount of motorized use 

in the Santa Fe National Forest and others decreased it. Details about any action listed can be 

found in the document called “Temporal Bound and List of Projects for Cumulative Effects
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 65

Analysis for the Final Draft Environmental Impact Statement” dated December 31, 2011, in the 

project record.

Table 17. Past and present actions from 1987 to 2011 that contributed to the existing 

condition

Action Description

Annual treatment of noxious weeds Removes noxious weeds by pulling, grazing, mowing, treating with 

chemicals, or other methods.

Road construction and maintenance Uses heavy equipment to build or maintain permanent or temporary roads.

Trail construction and maintenance Uses hand tools or light equipment (e.g., ATV) to build or maintain trails.

Unauthorized routes Created by repeated driving in the same place.

Construction and reconstruction of 

recreational facilities (such as 

campgrounds, fishing access, toilet 

installations)

Generally using heavy equipment.

Subdivision and development of 

private inholdings and land adjacent 

to the forest

Mining claims and development of 

mining 

Wildfires, including suppression and 

rehabilitation

This category includes suppression activities such as use of fire retardants 

and building fire line with hand tools or heavy equipment. It also includes 

rehabilitation work such as seeding and felling trees to reduce erosion.

Hazardous fuels treatment and 

prescribed burning

Thinning trees by hand or with equipment. Conducting prescribed fires.

Livestock grazing Annual grazing of cattle pursuant to permit terms.

New Mexico Senate Bill 379 This law increased safety and registration requirements for people under 18; 

restricted OHV use on state game commission and state park lands, except 

where designated; provided for the addition of state OHV park; provided for 

the closure of OHV trails causing irreversible damage; provides for 

development of overall enforcement across the state; and creates a fund for 

education, monitoring, and enforcement.

Jemez National Recreation Act This act established the Jemez National Recreation Area (JNRA) in order to 

conserve, protect, and restore the recreational, ecological, cultural, religious, 

and wildlife resource values of the Jemez Mountains. The JNRA is 

comprised of nearly 57,000 acres within the Jemez Mountains. The Santa Fe 

National Forest has developed numerous recreational facilities, 

campgrounds, day use sites, and fishing access, within the Jemez National 

Recreation Area.

Wild and Scenic Rivers – Pecos, East 

Fork Jemez, and Rio Chama

Designated certain rivers for their “outstandingly remarkable scenic, 

recreational, geologic, fish and wildlife, historic, cultural, or other similar 

values, shall be preserved in free-flowing condition, and that they and their 

immediate environments shall be protected for the benefit and enjoyment of 

present and future generations” (PL 90-542, 1968).

Creation of the Valles Caldera 

National Preserve

The creation of the Valles Caldera National Preserve made lands previously 

in private ownership open to public use. The Valles Caldera National 

Preserve is made up of 89,000 acres within the Jemez Mountain range and 

offers numerous recreational opportunities.
Chapter 3. Affected Environment and Environmental Consequences

66 FEIS for Travel Management on the Santa Fe National Forest

Table 17. Past and present actions from 1987 to 2011 that contributed to the existing 

condition

Action Description

Land transfers from the Santa Fe 

National Forest to other entities: 

San Ildefonso

Santo Domingo

Pecos National Historic Park

Respect the Rio Program The Respect the Rio Program is a multi-faceted restoration and education 

program started in 2001 and designed to balance the need for preservation of 

riparian and flood-prone areas with needs of the public. The Respect the Rio 

Program seeks to do this by accomplishing the following goals:

1. Identifying and addressing water quality issues that have developed 

from recreational use.

2. Educating the public about habitat, habitat needs, and ongoing 

restoration projects.

3. Creating community partnerships. 

4. Creating a program and materials that are easily adaptable to other 

forests and agencies.

Acquisition of lands by the Santa Fe 

National Forest

The Santa Fe National Forest aquires lands through purchase, exchange, or 

transfer. A comprehensive list of acquisitions is not available at this time.

Road decommissioning Removes roads from the landscape, usually using heavy equipment to 

restore the natural slope, and reseed. Has also occurred naturally with 

vegetation growing in unused roads, but in this case the drainage pattern is 

still altered from the original condition. A comprehensive list of past road 

decommissioning is not available at this time.

Technological advances in OHVs 

(e.g. 3-wheelers, 4-wheelers, side-bysides, tracked vehicles)

Technological advances in OHVs have improved performance, allowing 

OHVs to travel further across difficult terrains. Improved performance has 

also resulted in better gas mileage, less emissions, and better exhaust 

systems. 

Forest product collection This category includes products covered by a permit, such as firewood and 

Christmas trees, and other products such as pinon and products used for 

religious ceremonies.

Administrative use This category includes uses authorized by the Santa Fe National Forest by a 

special use permit (excluding forest product collection) and the use of Forest 

Service roads by Forest Service staff to manage the forest. Examples of 

activities authorized by a special use permit are access to communication 

sites, access to utility corridors, and access for outfitters and guides. The 

“Travel Analysis Process Report” estimated that administrative use occurs 

on approximately 1,400 miles of roads.

Activities on land in other 

jurisdictions

The Santa Fe National Forest has very little information on activities 

currently happening on lands within the project boundary that are under 

other jurisdictions. This makes it hard to determine the effects of those 

activities along with the effects of our travel management planning. 

However, the Santa Fe National Forest does not believe that the effects on 

these lands are significant when analyzed at the forest level. 

Existence of private or state OHV 

parks outside of Forest boundary

A number of OHV opportunities are provided by private or state OHV parks 

outside the Santa Fe National Forest boundary such as J-cross Motocross 

near San Ysidro and the Rio Puerco area outside of Rio Rancho. 

Economic recession
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 67

Reasonably Foreseeable Future Actions

Courts have interpreted a “reasonably foreseeable future action” as a human action that has been 

proposed and is in the planning stages (e.g., Weinberger v. Catholic Action of Hawaii, 454 U.S. 

139, 70 E.Ed.2d 289 (1981)). For example, a subdivision would not be reasonably foreseeable 

until the owner submitted plans to the county. To analyze the cumulative effects of reasonably 

foreseeable future actions, each resource specialist looked at the list of projects created by the 

interdisciplinary team in table 18. They identified the ones expected to cause effects on their 

resource at the same time and in the same place as effects from the proposed action or 

alternatives. Some specialists analyzed additional actions that pertained only to their resource.

Table 18. Present and reasonably foreseeable future actions related to motorized use 

(2009–2025)*

Action Description

Preparation of travel management 

plans and motor vehicle use maps by 

other national forests and agencies

All national forests and grasslands in New Mexico, and some Bureau of 

Land Management districts.

Transfer of management of lands in 

Pecos Canyon from New Mexico 

Department of Game and Fish to the 

New Mexico State Parks

SJM 16 authorized New Mexico State Parks to enter into a Joint Powers 

Agreement with the New Mexico Department of Game and Fish in order to 

better manage recreation on 186 acres of land divided between six 

locations along the Pecos River. These locations provide fishing access, 

day use, and overnight camping opportunties along the Pecos River. 

Projects on the SOPA

Geothermal leases in Coyote and Cuba 

Ranger Districts

The Santa Fe National Forest is considering a geothermal leasing proposal. 

The proposal would be to drill exploration wells north and west of the 

Valles Caldera National Preserve. Small roads would be developed to 

access the exploration wells. If the project moves to completion,

production wells and a power line would be installed.

Oil and gas leases in Cuba Ranger 

District

The proposal is to lease additional acreage adjacent to lands currently 

leased for oil and gas. Short roads would be developed to any new wells 

installed and would remain in use until the well is abandoned at which 

point the road would be reclaimed. 

Mineral (pumice) leases in Jemez 

Ranger District

See the next 3 rows for more details. 

El Cajete reopening and expansion The proposal is to expand the El Cajete No. 1 mine by 15 acres and 

proposes to open a second mine to the north. A road would need to be 

constructed to access the second mine. 

South Pit extension The proposal is to expand the South Pit Mine by 48 acres. Access to the 

mine is already available and no new road construction is proposed. 

Duran 2010 The proposal is to open a new 20-acre pumice mine on the Jemez Ranger 

District. An existing road would need to be upgraded to provided sufficient 

access for operation.

* The interdisciplinary team started this list in 2009 and made it final in December 2011

Current and Predicted Use and Existence

Between the draft and final environmental impact statement, the interdisciplinary team realized 

that displaying the difference between the motorized use and the existence of a road, trail, area, or 

fixed-distance corridor is important. The effects between the use and existence of routes and areas 

may differ. Table 19 summarizes these differences. The conditions described in the table apply to 

the direct, indirect, and cumulative effects analysis.
Chapter 3. Affected Environment and Environmental Consequences

68 FEIS for Travel Management on the Santa Fe National Forest

Table 19. Current and predicted motorized use and existence

Changes Common to 

All Action 

Alternatives 

(miles and acres vary 

by alternative)

What Exists Now - Existing Condition Predicted Use or Condition, 15 Years 

After First Motor Vehicle Use Map

Notes

Prohibit driving off 

designated roads, trails, 

and areas and outside of 

designated fixed-distance 

corridors.

It’s estimated that people drive off-road on 

about 29 percent of the forest. This 

motorized use is generally light to moderate, 

but can be heavy in particular places.

No driving off road occurs except in 

designated areas and corridors. 

Administrative use would not change 

(chapter 3, assumption 17).

User-created two track and single track 

routes exist. The exact number is not known 

and the Travel Management Rule doesn’t 

require that knowledge (70 FR 68269). 

Compacted soil, with or without vegetation, 

exists where motorized use occurs.

No new unauthorized routes would be created.

Natural rehabilitation of areas that had light 

motorized use could occur. Areas heavily used 

by motor vehicles would take longer than 15 

years to naturally rehabilitate, and in some 

cases would require active restoration by the 

Forest Service (USDA Forest Service 2012a 

and 2012d).

Determining which routes would 

rehabilitate and which would continue 

to erode is not possible within the 

timeframe of this analysis. Such 

information is not needed to make a 

decision about designating a motorized 

travel system. For the purposes of this 

analysis, we assumed that there would 

be no net change on the forest (chapter 

3, assumption 23).

Allow motorized use on 

some system roads 

currently managed as 

closed to it.

Motorized use occurs on some of the closed 

roads proposed for designation (USDA 

Forest Service 2008b). 

No noticeable change in motorized use 

(chapter 3, assumption 1).

For purposes of complying with law and 

policy, some resources, such as wildlife 

and heritage, treat the action of 

changing a closed road to open as new 

use, even though a footprint exists and 

the roads are being driven on.

Footprints of roads or two tracks exists 

(chapter 3, assumption 22).

No change in roads’ footprint (USDA Forest 

Service 2012a and 2012d).
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 69

Table 19. Current and predicted motorized use and existence

Changes Common to 

All Action 

Alternatives 

(miles and acres vary 

by alternative)

What Exists Now - Existing Condition Predicted Use or Condition, 15 Years 

After First Motor Vehicle Use Map

Notes

Allow motorized use on 

some system trails.

(Motorized use on most 

system trails outside of 

wilderness is allowed 

now, regardless of what 

the trail was designed 

for.)

Motorized use occurs on the system trails 

proposed for designation (USDA Forest 

Service 2008a).

No noticeable change in motorized use 

(chapter 3, assumption 1).

Footprints of trails exists (chapter 3, 

assumption 22).

No change in trails’ footprint (USDA Forest 

Service 2012a and 2012d).

Add some unauthorized 

roads to the system.

Motorized use occurs on the most of the 

unauthorized roads proposed for designation 

(USDA Forest Service 2008a).

No noticeable change in motorized use 

(chapter 3, assumption 1).

Footprints of roads exist. No change in roads’ footprint (USDA Forest 

Service 2012a and 2012d).

Add some unauthorized 

trails to the system.

Motorized use occurs on most unauthorized 

trails proposed for designation (USDA 

Forest Service 2008a).

No noticeable change in motorized use 

(chapter 3, assumption 1).

Footprints of trails exist (chapter 3, 

assumption 22).

No change in trails’ footprint (USDA Forest 

Service 2012a and 2012d).

Prohibit motorized use on 

some system roads 

currently managed as 

open to it.

Light to no motorized use occurs on most of 

the system roads not proposed for 

designation (chapter 3, assumption 1).

No motorized use of closed roads would 

occur. For effects analysis, we assumed no 

measurable change; for example, going from 1 

vehicle per week to none isn’t enough to 

measure a change (chapter 3, assumption 1).

Footprint of road or two track exists 

(chapter 3, assumption 22).

For the purposes of this analysis, we assumed 

that there would be no net change in the 

existence of system roads on the forest 

(chapter 3, assumption 23). Constructed roads 

are not likely to naturally rehabilitate in the 

15-year timeframe considered, and their 

footprints would remain present for much 

longer (USDA Forest Service 2012a).

Physical decommissionning of roads is 

possible in the 15-year timeframe 

analyzed. Decommissioning is likely to 

occur on only a small percentage of 

miles due to funding limitations and the 

need for site-specific NEPA.
Chapter 3. Affected Environment and Environmental Consequences

70 FEIS for Travel Management on the Santa Fe National Forest

Table 19. Current and predicted motorized use and existence

Changes Common to 

All Action 

Alternatives 

(miles and acres vary 

by alternative)

What Exists Now - Existing Condition Predicted Use or Condition, 15 Years 

After First Motor Vehicle Use Map

Notes

Prohibit motorized use on 

some system trails 

currently open to it. 

(Motorized use on most 

system trails outside of 

wilderness is allowed 

now, regardless of what 

the trail was designed 

for.)

Light motorized use occurs on some of the 

system trails not proposed for designation.

No motorized use of closed roads would 

occur. For effects analysis, we assumed no 

measurable change; for example, going from 1 

vehicle per week to none isn’t enough to 

measure a change (chapter 3, assumption 1).

Footprint of trail or two track exists (chapter 

3, assumption 22).

For the purposes of this analysis, we assumed 

that there would be no net change in the 

existence of system trails on the forest 

(chapter 3, assumption 23). Constructed trails 

are not likely to naturally rehabilitate in the 

15-year timeframe considered, and their 

footprints would remain present for much 

longer (USDA Forest Service 2012a).

Use could switch (or continue) from 

hikers, bikers, horses.

Change the vehicle types 

allowed on some roads 

and trails.

Almost no restrictions on vehicle types 

allowed on roads or trails exist now. 

No noticeable change in the amount of 

motorized use (chapter 3, assumption 1).

People would follow the designations 

on the MVUM. Thus, the kinds of 

vehicles found on roads and trails would 

change from the present. For most 

resources, however, we assume that all 

vehicles cause similar effects (chapter 3, 

assumption 6).

Footprints of roads and trails exist (chapter 

3, assumption 22).

No change in the footprint (USDA Forest 

Service 2012a and 2012d). 

Put seasonal closures on 

some roads and trails.

Motorized use of roads and trails occurs all 

year unless there is a closure order or the 

route is impassable as a result of weather.

No motorized use of roads and trails would 

occur during the time there is a seasonal 

closure placed on them.

Seasonal closures of roads and trails is 

to protect certain species of wildlife 

during their breeding season. Ranger 

district staff will continue to issue 

weather related closure orders on a 

route-by-route basis. Administrative use 

of routes, such as to access private 

property, would continue.

Footprints of roads and trails exist (chapter 

3, assumption 22).

No change in the footprint (USDA Forest 

Service 2012a and 2012d).
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 71

Table 19. Current and predicted motorized use and existence

Changes Common to 

All Action 

Alternatives 

(miles and acres vary 

by alternative)

What Exists Now - Existing Condition Predicted Use or Condition, 15 Years 

After First Motor Vehicle Use Map

Notes

Designate corridors for 

motorized dispersed 

camping.

Based on data collected during 2008 and 

2009, motorized access to dispersed 

camping occurs as shown in alternative 1 

(chapter 3, assumption 18). People drive 

right to the water’s edge when they can.

The amount of motorized dispersed camping 

would not change (chapter 3, assumption 19).

Motorized use would not occur within 100 

feet of water.

(USDA Forest Service 2009g) We expect to see some recovery where 

vehicles aren’t allowed within 100 feet of 

water, but conditions won’t be natural in the 

15-year timeframe. Would need intervention 

in some cases to return the area to “natural”

(USDA Forest Service 2012a).

Hardened camping access and sites, 

especially those near water, are more 

likely to recover than engineered roads.

The former are mostly user created, 

whereas the latter have been compacted.

The availability of water helps plants 

grow more quickly (USDA Forest 

Service 2012a).

Designate corridors for 

motorized big game 

retrieval.

Neither the forest nor the NMDGF has 

accurate data on where motorized big game 

retrieval occurs. We estimate 438 average 

annual trips (2 in, 2 out) across about 1.26 

million acres.

The amount of motorized use to retrieve game 

would not change, but would be limited to the 

edge of the designated corridor. Motorized use 

would not occur within 100 feet of water.

User-created two track and single tracks 

exist. The exact number is not known and 

the Travel Management Rule doesn't require

that knowledge (70 FR 68269). Compacted 

soil, with or without vegetation, exists 

where motorized use occurs.

No new unauthorized routes as a result of 

motorized big game retrieval would be created 

(chapter 3, assumption 16). Natural 

rehabilitation of areas that had light motorized 

use could occur. Areas heavily used by motor 

vehicles would take longer than 15 years to 

naturally rehabilitate, and in some cases would 

require active restoration by the Forest Service 

(USDA Forest Service 2012a and 2012d).
Chapter 3. Affected Environment and Environmental Consequences

72 FEIS for Travel Management on the Santa Fe National Forest

Methodology for this Effects Analysis

This final environmental impact statement looks at effects at the forestwide scale. We aggregated 

effects of proposed changes to the forest level rather than describing the site-specific effect for

each road or trail. For instance, the “Fisheries” section describes the overall effects of reducing 

the places people could drive. It does not list every route and predict the effects at that particular 

site. Specialists, however, sometimes used individual sites as examples.

The analysis in this chapter focuses on the effects of the proposed changes to the current 

designated system. It does not analyze the effects of the whole designated system. To use a 

hypothetical example, the effects analysis looks at what happens when 2,000 miles of roads are 

closed to motorized use, not what happens on the miles that remain. The Travel Management 

Rule does not require the Forest Service to revisit parts of the motorized system it wants to keep 

as is (36 CFR 212.50(b)).

Most specialists used GIS to calculate the miles and areas affected, or to model habitats. We 

describe other models specialists used if it is other than GIS. The purpose of the effects analysis is 

to compare alternatives, not to make exact predictions about the future.

To compare “apples to apples,” we assume that motorized use would occur where it is proposed. 

This way, the effects analysis describes the effects resulting from the change between where 

people are driving now (alternative 1) and where people would drive (alternatives 2 through 5).

This analysis contains uncertainty. For example, the exact location of every road and trail 

proposed is not likely precise, but certainly is close. We don’t know exactly where hunters drive 

to retrieve big game. The number of people with health problems caused by dust from the forest 

is not known. The condition of every stream crossing has not been assessed. This kind of precise 

data is not needed to make an informed decision because the effect of reducing motorized use is 

well documented. The trends in effects for each alternative are sufficient for the forest supervisor

to base her decision on. 

Amendments to the “Santa Fe National Forest Plan”

By law, actions we propose must be consistent with our forest plan or the plan must be changed. 

For instance, the forest plan prohibits motorized cross-country travel in Management Area I. If an 

alternative proposes a fixed-distance corridor for motorized access to dispersed camping in 

Management Area I, then the forest plan would need to be amended because the corridor allows 

people to drive off the road to camp. When alternatives are consistent with the forest plan, no 

amendments are needed.

Amendments to the forest plan can have effects because they propose changes in the management 

of the forest. Not allowing motorized use in places that used to allow it is an example of a change 

in management that might cause effects for future projects. These effects, like those from the 

proposed action and alternatives, are disclosed as part of the effects analysis for each resource.

Assumptions and Limitations Common to All Resources

The forest’s specialists made assumptions in situations where they didn’t have all the information 

they needed to include in the effects analysis. These assumptions were applied consistently 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 73

throughout the effects analysis to ensure the outcome was not skewed toward a singular 

conclusion.

These assumptions and limitations apply to all the resources analyzed. Some specialists made 

additional assumptions pertaining to their resource. 

1. For the purposes of this analysis, the amount of current and future motorized travel on 

roads and trails is held constant among alternatives.

• Discussion: The Travel Management Rule and the recreation specialist report 

document an increase in motorized use on national forests nationwide, including the 

Santa Fe National Forest. Indeed the increase in unmanaged motorized use gave rise 

to the rule. Economic conditions, population increase or decrease, and the public’s 

recreational preferences could increase or decrease the overall amount of motorized 

travel on the forest over time. The effect of these factors, however, would be 

impossible to predict or accurately quantify for this analysis. By holding the amount 

of motorized use constant among alternatives, the interdisciplinary team can better 

display the effects of the alternative on their resource.

As discussed in the specialist report for roads (USDA Forest Service 2012d), the 

amount that traffic would change is not known due to limitations in the way traffic is 

measured. 

We propose to close only 5 to 6 percent of the passenger car roads (maintenance 

levels 3 and 4), depending on the alternative. These roads receive most of the traffic, 

and use on these roads is not expected to change. Depending on the alternative, 55 to 

70 percent of roads for high-clearance vehicles (maintenance level 2) would be 

closed to motorized use. It is expected that closing these wouldn’t cause a noticeable 

increase in concentration of traffic on the routes remaining open. For example, on a 

high-clearance vehicle road left open, one car per week could increase to two cars per 

week. This situation illustrates a 100 percent increase in use during the time 

measured, but one that we nonetheless regard as a low concentration of use. 

2. Publishing a system of motorized routes on a map may cause an increase in motorized 

use on the forest, but for the purposes of this analysis we assume a constant amount of 

use.

• Discussion: Some people commented that displaying previously unknown routes on 

a map that’s available nationwide will draw more motorized use to this forest. No 

evidence exists either in the body of scientific research focusing on this subject, nor 

from less formal, site-specific studies of motorized use on public lands (Christensen 

and Watson 2006). Since every national forest in the country is expected to publish a 

motor vehicle use map, the Santa Fe National Forest is not unique in this regard. 

Because so many variables—such as fuel prices, personal preferences, and changes in 

the technology of motorized vehicles—exist, it wasn’t reasonable to assume either an 

increase or decrease in the overall amount of motorized use of the forest. 

3. The capability to enforce and the public’s compliance with the motor vehicle use map 

would increase over the present situation for all action alternatives.
Chapter 3. Affected Environment and Environmental Consequences

74 FEIS for Travel Management on the Santa Fe National Forest

• Discussion: Experience of forest staff shows that after an initial educational period, 

compliance with new rules and regulations increases over time.

4. The condition of roads and trails kept open for motorized use will stay the same, or 

slightly improve, over current conditions and over time. 

• Discussion: Roads and motorized trails will continue to be maintained as the forest’s 

budget allows. Fewer miles of roads would be designated at the higher maintenance 

level, so funding could be used on more miles of road or at more frequent intervals 

(USDA Forest Service 2012d). For motorized trails, the forest anticipates engaging 

the public to develop additional volunteer and partnership opportunities to assist with 

trail maintenance.

5. The types of effects of motorized trails are the same as the effects of roads.

• Discussion: At localized scales, motorized trails and roads have the same types of 

environmental effects, such as erosion, reduced plant cover, and others, and the rates 

of each effect are similar (Stokowski and LaPointe 2000). For example, one square 

foot of motorized trail and one square foot of road, with all other variables being 

equal, will have similar erosion rates. Motorized trails and roads do differ in the 

magnitude of effect at localized scales. Because roads tend to occupy more area than 

motorized trails, the magnitude of their effects tends to be larger (Dissmeyer 2000). 

Due to the unmanaged nature of the forest’s motorized trail system, many motorized 

trail widths are as wide as roads, or have two tracks like roads. Excessive motorized 

trail widths can be caused by poor trail location, gullying, trail sloughing, and 

braiding. Since many motorized trail widths on the forest resemble road widths, for 

the purpose of this analysis, the effects of motorized trails and roads are considered 

the same.

6. All motorized vehicles, such as motorcycles, ATVs, trucks, and cars, cause similar 

impacts to resources. There may be some exceptions for some resources.

• Discussion: All motorized use causes similar types of impacts to forest resources—

trampled vegetation, emissions, erosion, and others (Ouren et al. 2007, Stokowski 

and LaPointe 2000).

7. The approximate 6 acres of areas proposed for motorized dispersed camping will 

continue to be used for dispersed camping.

• Discussion: It is likely the areas would continue to be used for dispersed camping 

since they have been used in this manner for upward of 20 years.

8. In corridors designated for motorized dispersed camping, the use will be motorized 

dispersed camping.

• Discussion: Experience of forest staff shows that after an initial educational period,

compliance with new rules and regulations increases over time.

9. Not every acre of corridors designated for motorized dispersed camping and motorized 

big game retrieval would be driven on.

• Discussion: Slope and vegetation limit motorized access in many places within the 

corridors. We proposed fixed-distance corridors in such a manner as to improve 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 75

peoples’ ability to read the map. For instance, the scale of the map does not facilitate 

designating corridors less than 1⁄2 mile in length. As a result, some designated 

corridors include places where people wouldn’t be able to drive (figure 16).

Figure 16. An example of a place in a designated camping corridor 

where vehicles couldn’t drive because there are too many trees and 

it is too steep. Other parts of the corridor are conducive to driving 

to get to campsites.

10. The estimated number of motorized trips to retrieve a downed big game animal would not 

change among alternatives, except for alternative 3, which would not allow it.

• Discussion: We estimate the average number of big game animals taken to be 438 

per year (USDA Forest Service 2009j). This estimate is likely low. Because the forest 

does not have data on the locations of where big game is retrieved, we assumed that it 

occurs everywhere outside of wilderness, recognizing that not all of these acres are 

conducive to driving due to slope, terrain, or vegetation. 

Regional guidelines state that hunters should make the minimum number of trips to 

retrieve an animal (USDA Forest Service 2008c). Specialists assumed that people 

would make less than four trips (up to two in and two out).

11. With a restriction on public use, the amount of driving on roads used for administrative 

purposes will be less than the existing use.

• Discussion: The forest does not have data on the frequency with which the 

administrative roads are presently used, but it is reasonable to assume that by not 

allowing the public to drive on the roads, use will be less than what occurs now.

12. Temporary roads, trails, and areas built to support emergency operations or temporarily 

authorized in association with contracts, permits, administrative use, or leases are not 

intended for public use. Any proposal to add these temporary roads, trails, and areas to 

the system will require a separate NEPA decision and is not part of this analysis.
Chapter 3. Affected Environment and Environmental Consequences

76 FEIS for Travel Management on the Santa Fe National Forest

13. Any routes not included in the decision are not precluded from being added or removed 

from the forest’s transportation system in future travel management decisions.

14. Routes that would not be kept as part of the system would receive no maintenance. 

Routes closed to all motorized use, but needed for administrative purposes, would only 

receive basic custodial maintenance sufficient to keep damage to adjacent resources to an 

acceptable level. 

15. An increase or decrease in visitation to the forest because of population change is not 

predictable.

• Discussion: Though visits to the forest have increased over the last 20 years; 

however, the future trend cannot be predicted with certainty due to unknown 

variables like fuel costs, population and demographic change, and personal 

preferences.

16. Motorized big game retrieval in designated corridors would not result in the creation of 

new routes.

• Discussion: Retrieving a downed big game animal is not likely to result in repeated 

trips in the same place year after year because animals are not taken in the same 

places every year. 

17. The amount of administrative motorized use of National Forest System roads is not 

expected to change among alternatives.

• Discussion: The access and maintenance needed to administer forest activities is 

expected to remain constant after changes to the designated motorized system are 

made. Permits for firewood collection, which could include motorized cross-country 

travel, would continue until specific collection areas are designated (expected over 

the next 2 to 5 years). Because the administrative and permitted uses are exempt, they 

are not included in the analysis.

18. The fixed-distance corridors created for alternative 1 capture the vast majority of the 

existing motorized dispersed camping on the forest. People do drive and camp outside of 

the corridors shown in alternative 1, but this occurs infrequently enough to be considered 

insignificant at the scale of the forest.

• Discussion: The motorized dispersed camping corridors displayed in alternative 1 

show the results of data collected by forest staff in 2008 and 2009. The protocol 

directed the district staff to identify and inventory the roads, trails, and areas where 

people currently drive to camp (USDA Forest Service 2008d). The data collected 

reflects the majority of those places (USDA Forest Service 2009g). 

19. For the purposes of this analysis, the number of motorized dispersed campers is assumed 

constant among alternatives. 

• Discussion: Some people commented that designating motorized dispersed camping 

on a map that’s available nationwide will draw more motorized use to this forest. We 

are not aware of studies or data documenting a change in the amount of motorized 

use on a forest following publication of its motor vehicle use map. Since every 

national forest in the country is publishing a motor vehicle use map, the Santa Fe 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 77

National Forest is not unique in this regard. Because so many variables—such as fuel 

prices, personal preferences, and changes in the technology of motorized vehicles—

exist, it wasn’t reasonable to assume either an increase or decrease in the overall 

amount of motorized use of the forest.

20. In alternative 3, people will continue to camp in the corridors displayed in alternative 1. 

The difference is that they won’t drive to the sites, but will park next to the side of the 

road and walk their gear to the sites.

• Discussion: While we can’t accurately predict peoples’ future behavior, we support 

this assumption based on experience. For instance, people aren’t allowed to drive to 

the Rio Cebolla because it is blocked by a fence. People park next to the fence, and 

camp next to the river. Some places on the forest, particularly those next to water, are 

so attractive that people will continue to camp there even if they can’t drive to the 

site. We also acknowledge that people may not camp in the less “attractive” sites if 

they aren’t allowed to drive there. The reason we use alternative 1 is because this is

where people camp now (USDA Forest Service 2009g).

21. The current number of motorized dispersed campers will use the acreage designated in 

each alternative for this activity.

• Discussion: Where more acres are designated for motorized dispersed camping than 

the existing condition, people would spread out. Where fewer acres are designated, 

they would be concentrated. Without data on people’s future behavior, this is the 

most reasonable assumption. Experience has shown that this activity tends to result in 

bare, hardened ground and new routes in some locations.

22. Almost all routes proposed for designation have an existing footprint on the ground.

• Discussion: Some exceptions exist. Some routes proposed as open to all vehicles for 

access to private property currently exist as trails. This analysis examines the 

motorized use of proposed routes and their effects. Additional NEPA analysis would 

be required on routes needing physical construction or groundwork.

23. Without motorized use, over time some routes would naturally revegetate and others 

would not. For the purposes of this analysis, we assume no net change at the forest scale. 

• Discussion: Processes and impacts associated with the current road and trail system 

would continue much the same until route surface conditions change or 

decommissioning activities occur. This is because once a trail or road becomes 

established, the soil of the tread is subject to the continuing erosional forces of 

rainfall, running water, wind, freeze and thaw cycles, and gravity, and to some extent 

is maintained in an unvegetated, disturbed, condition (Leung and Marion 1996). 

Natural recovery of roads is often impaired by their highly compacted soils (Elseroad 

et al. 2003).

A route designation decision does have the potential to affect soil and water resources 

indirectly to the extent that it affects the concentration of use on roads and trails, the 

levels of maintenance needed, and the potential for damaged areas to recover. The 

magnitude of the indirect effects will depend on how well routes closed to public 

motorized use recover on their own without restoration treatments and how many 

routes’ current condition worsens from lack of attention and maintenance. Since these 
Chapter 3. Affected Environment and Environmental Consequences

78 FEIS for Travel Management on the Santa Fe National Forest

factors are unknown at this time, for the purposes of this analysis, the condition of the 

designated and nondesignated routes on the landscape will be assumed to stay equal 

to the current condition.

24. For the purpose of this analysis, we assume the unauthorized routes were created by 

“pioneering,” or the repeated driving in the same place. By this we mean that people saw 

an opportunity, such as a cow trail, a skid trail, or an open field, and drove across it 

repeatedly until it became a distinct route.

• Discussion: Most of the unauthorized routes proposed for designation weren’t 

designed and built by the Forest Service. Such construction has different effects than 

those created from people driving over the same place opportunistically. Though 

people report that some of the unauthorized routes proposed for designation were 

constructed, we believe the quantity of these is relatively immaterial when compared 

to the pioneered routes. Some of the unauthorized routes were built by motorized 

users, with or without the permission of the Forest Service. Some of the unauthorized 

routes are decommissioned roads that were never physically put to bed and that we 

now need for access or recreation.

The unauthorized routes vary in width from single track to normal road width. They 

vary also in the amount of ground cover. Some can only be found by following 

cairns, whereas some are plainly visible and completely lack vegetation. 

Affected Environment and Environmental Consequences

Spatial and Temporal Bounds of the Analysis

The spatial bounds, except as noted, for the direct and indirect effects are the National Forest 

System lands within the proclaimed boundary of the Santa Fe National Forest. For cultural 

resources and lands, the bounds include some places adjacent to the forest easily reached by 

National Forest System routes. The social and economic analysis includes seven counties, those 

that make up parts of the Santa Fe National Forest plus Bernalillo County, due to higher 

population base and proximity to the forest. 

The spatial bounds for the cumulative effects analysis are the same, except for the following 

resources. Air quality considers cumulative effects to the western states. Recreational 

opportunities are examined for the 7-county area laid out in the “Social and Economic

Environment” section. The cumulative effects for motorized access to hunting and camping are 

considered statewide.

For all resources, the temporal bound for the direct and indirect effects is from publication of the 

motor vehicle use map, anticipated in 2012, through 2025. The temporal bound for the 

cumulative effects analysis for all resources is from publication of the forest plan in 1987 through 

2025. We chose 2025 because it is the farthest date out we felt it reasonable to identify future 

actions.

Consistency with the Forest Plan and Other Laws

All the alternatives are consistent with standards and guidelines in the “Santa Fe National Forest 

Plan” or the plan has been proposed for amendment. The amendments are shown in appendix 1, 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 79

and the effects of them analyzed in each section. All the alternatives are consistent with

applicable laws, regulation, and policy. Please find details in the individual specialist’s report.

The remainder of this chapter discusses the predicted effects of the alternatives by resource.

Recreation – Affected Environment

Everything in this section summarizes the specialist reports for recreation and roads located in the 

project record.

The public and forest employees had six significant issues1 (1 through 6) and two other issues (7 

and 8) about how the proposed action would affect recreation. Analysis of issue 9 is required by 

the Travel Management Rule.

1. Motorized Opportunity: The reduction in miles of routes and the prohibition on crosscountry travel in the proposed action will adversely affect the quantity of public 

motorized experiences.

2. Motorized Big Game Retrieval: Prohibiting motorized cross-country travel will limit the 

motorized retrieval of big game, perhaps to an unacceptable level. 

3. Motorized Dispersed Camping: Designating motorized dispersed camping corridors will 

increase cross-country travel and the resource damage associated with it, and curtail the 

kind of unrestricted camping that the Santa Fe National Forest currently provides.

4. Conflicts: The proposed action, by designating routes uniformly across the forest outside 

of designated wilderness, will cause conflicts between motorized and nonmotorized users 

because they will be recreating in the same vicinity.

5. Wilderness: Designating motorized routes close to wilderness will detract from the 

wilderness experience because of noise and trespass.

6. Inventoried Roadless Areas: Designating motorized routes through or close to inventoried 

roadless areas will detract from the potential wilderness characteristics of these areas.

7. Enforcement: The motor vehicle use map alone will be an inadequate enforcement tool.

8. Maintenance: Any reasonable designated motorized system will require more 

maintenance than the Forest Service can provide by itself. An unmaintained system will 

continue to adversely affect forest resources.

9. Safety: As required by the Travel Management Rule.

Opportunity (Roads, Trails, Areas,

and Seasonal Closures) – Affected Environment

People who ride motor vehicles in the forest raised this issue about opportunity:

 

1 The reason six significant issues are listed here is that some of the bullets included in significant issue 1 are itemized 

separately for the purpose of clarity.
Chapter 3. Affected Environment and Environmental Consequences

80 FEIS for Travel Management on the Santa Fe National Forest

“The reduction in miles of routes and the prohibition on cross-country travel in 

the proposed action will adversely affect the quantity of public motorized 

experiences.”

The Santa Fe National Forest, at 1.5 million acres, offers something to every kind of outdoor 

enthusiast. “Developed” opportunities—such as official campgrounds, trailheads, and the ski 

area—satisfy people who prefer having facilities. Campgrounds have picnic tables, grills, and tent 

sites. Trailheads have kiosks with maps and information. We aren’t proposing to change any 

access to developed opportunities and won’t discuss them further. All routes to developed sites 

would continue to be open for motorized use. 

“Dispersed” opportunities suit people looking for solitude and self-sufficiency. Hunting, 

collecting firewood, hiking or riding on trails, and camping without amenities are examples of 

dispersed opportunities. We call some activities, like cutting Christmas trees, dispersed because 

they are spread out. This project could curtail some dispersed opportunities by restricting the 

amount of motorized access to and within the Santa Fe National Forest. People use vehicles to get 

to places where they participate in nonmotorized activities, like hiking, camping, or horseback 

riding. 

Visitors to the Santa Fe National Forest are predominantly local. Greater than 60 percent of 

visitors come from Santa Fe, Albuquerque, or towns adjacent to the forest such as Jemez Pueblo, 

White Rock, and Las Vegas. Fewer than 1 percent of visitors are international (Kocis et al. 2010).

Over 65 percent of visitors to the Santa Fe National Forest came to the forest for the purpose of 

recreation (Kocis et al. 2010).

What kind of recreation do people engage in when visiting the forest? The most recent National 

Visitor Use Monitoring data was collected from October 2008 through September 20092

.

Nonmotorized recreation accounted for over 90 percent of people’s activities. The survey showed 

peoples’ four main activities are hiking or walking (67 percent), viewing natural features (32

percent), relaxing (22 percent), and viewing wildlife (22 percent; table 20). People interviewed 

for the survey listed hiking and viewing natural features as their top two primary activities.

The 2009 report showed that 0 percent of those who come to the forest do so for the primary 

purposed of riding off-highway vehicles, though less than 1 percent said they do participate in the 

sport. About 2 percent of people said they come to the forest to drive for pleasure. Just under 13 

percent of people reported engaging in one of the six kinds of motorized recreation listed (table 

20).

The National Visitor Use Monitoring (NVUM) survey does have limitations. Surveys are 

collected at specific recreational sites in the forest; as such, small sites used by few people—such 

as local motorized use—is not captured. Unrecorded recreational visits may represent a 

significant contribution to one type of recreation, so the survey results may be low. Visitors who 

agree to be interviewed are considered to be representative of the entire population of visitors. 

Survey days are randomly distributed, so seasonal recreation activities (like downhill skiing) can 

be overreported. Despite these limitations, it is widely accepted that the National Visitor Use 

Monitoring data is very useful for forest planning and decisionmaking.

 

2 The draft environmental impact statement cited results from the 2004 NVUM study. Because of the manner in which 

the data were collected, the 2004 and 2008 studies can’t be directly compared to evaluate trends.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 81

To show how motorized opportunities and access would change among alternatives, we use the 

miles of roads and trails and the acres of areas open for motorized use as a proxy because these 

represent the places people can drive.

Table 20. Percent of visitors who participated in 28 different activities in the 

Santa Fe National Forest during FY 2008a

Activity

Santa Fe National Forest

FY 2009b

Percent Participating Percent that Consider 

It a Primary Activity

Developed Camping 5.1 2.3

Primitive Camping 1.9 0.4

Backpacking2 1.8 0.9

Resort Use 0.7 0.0

Picnicking 7.7 1.7

Viewing Natural Features 32.4 9.5

Visiting Historic Sites 2.8 0.1

Nature Center Activities 4.2 0.0

Nature Study 10.1 0.4

Relaxing 21.6 4.3

Fishing 9.1 5.3

Hunting 2.3 1.5

OHV Use1 0.4 0.0

Driving for Pleasure1 11.3 1.7

Snowmobiling1 0.0 0.0

Motorized Water Activities1 0.1 0.0

Other Motorized Activity1 0.0 0.0

Hiking/walking2 66.5 50.7

Horseback Riding2 0.6 0.1

Bicycling2 2.6 2.0

Nonmotorized Water2 0.9 0.8

Downhill Skiing2 8.5 8.3

Cross-country Skiing2 9.4 9.1

Other Nonmotorized2 2.2 0.6

Gathering Forest Products 3.2 0.1

Viewing Wildlife 22.2 0.6

Motorized Trail Activity1 0.8 0.0

Some Other Activity 3.3 1.9

No Activity Reported 0.2 0.2

a From the National Visitor Use Monitoring Results, USDA Forest Service, National Summary 

Report, data collected FY 2003 through FY 2009, last updated April 25, 2010. b From the National Visitor Use Monitoring Results, USDA Forest Service, Region 3, Santa Fe 

National Forest, February 2011. 1 Activities that are specifically considered to be motorized recreation. 2 Activities that are specifically considered to be nonmotorized recreation.
Chapter 3. Affected Environment and Environmental Consequences

82 FEIS for Travel Management on the Santa Fe National Forest

Roads

The Forest Service has two types of roads:

1. Roads suitable for passenger cars, and

2. Roads suitable only for high-clearance vehicles.

Roads that are suitable for passenger cars are usually paved or have a gravel surface. On the Santa 

Fe National Forest, most passenger car roads have a gravel surface. Except for the south end of 

Forest Road 376 and part of Forest Road 263, most paved roads are in campgrounds or lead to 

them. Passenger car roads are maintained more frequently because they receive the most use.

High-clearance vehicle roads are usually dirt roads. High-clearance vehicle roads receive little 

maintenance and a pickup truck or a 4-wheel-drive, high-clearance vehicle is required to drive on 

many of these. Many sections of high-clearance vehicle roads are smooth and level and would be 

suitable for passenger cars, but are not maintained for that use. 

Passenger car roads carry the most traffic on the forest. Forest Road 376 on the Jemez Ranger 

District, for example, appears to be the most heavily traveled National Forest System road on the 

forest. Traffic counts at the south end of the road near the tunnels show an annual average daily 

traffic of around 185 vehicles. For comparison, the New Mexico Department of Transportation 

shows that the annual average daily traffic through Jemez Springs is around 2,600 vehicles. 

Farther north on Forest Road 376, the average annual daily traffic drops to around 150 vehicles. 

This is the number of vehicles that go past the counter, regardless of direction. Many of these 

vehicles will be counted twice because people drive in and out, and don’t necessarily drive a 

looped route. 

High-clearance vehicle roads carry fewer cars, sometimes as little as one or none every 2 weeks. 

On the Pecos/Las Vegas Ranger District, Forest Road 79 doesn’t get as much traffic as Forest 

Road 376. Forest Road 79 is a dead end road that serves a trailhead and goes to some private 

property in the Cañada de Los Alamos area. At the south end of the road near the forest boundary, 

the average annual daily traffic is 30 vehicles, but at the trailhead, the count is only 15 vehicles. 

In the Glorieta Mesa area, Forest Road 326’s average annual daily traffic is 23.

The forest also has roads people created by driving repeatedly in the same tracks (figure 17). 

These roads, called unauthorized, are not tallied in the forest’s database and are not part of the 

official transportation system. We don’t have an inventory of all the unauthorized roads in the 

forest. People who like to drive in the forest told us of 540 miles of unauthorized roads and trails 

they use3

.

Traffic on all forest roads is low compared with city roads. We estimate that people are using 

5,218 miles of roads now. 

 

3 In this document, the category called “unauthorized” includes unauthorized, decommissioned, and undetermined 

routes because adding these all add miles to the forest’s transportation system. The draft environmental impact 

statement only listed unauthorized, which is why the numbers differ here.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 83

Figure 17. An unauthorized route leading to a camping spot on the 

Cuba Ranger District

Trails

Of the 947 miles of system trails in the forest, 460 are in designated wilderness where motorized 

use is prohibited by law. Most of these trails were designed for stock or hikers. Some were 

historically used as sheep or cattle driveways. Four hundred sixty miles of system trails built for

nonmotorized use exist outside of wilderness (figure 18). Though these trails were built for 

nonmotorized uses, motorized use hasn’t been prohibited on most of them. The other 27 miles are 

motorized system trails4

. Some segments of the system trails outside wilderness pass through 

areas designated in the forest plan for nonmotorized opportunities, or in areas having special 

closures due to fire, wildlife, or other resource concerns. It is difficult to describe the management 

direction for system trails in simple terms by using just miles, since many have segments that go 

through different forest plan management areas with different objectives.

Some portions of the trails built for nonmotorized use cross places where the forest plan or a 

closure order prohibits motorized use (figure 19). In theory, this means that section would be 

closed to motorized use, so someone couldn’t drive to the end or finish a loop. In practice, 

however, no one has delineated where the trails cross boundaries into nonmotorized areas, so a 

driver would not know that motorized use wasn’t allowed. Thus, we have not calculated the 

mileage of the segments that are technically closed (as in the little piece shown crossing the 

nonmotorized area in figure 19). Instead, they are included with the miles of nonmotorized trail 

outside of wilderness.

 

4 Aspen Loop and Pajarito Trail, totaling 8 miles, are hiking trails, but are incorrectly coded as “open to all vehicles” in 

the forest’s database, which would mean they should be roads. We keep both counted with the motorized trails so that 

mileages match among reports.
Chapter 3. Affected Environment and Environmental Consequences

84 FEIS for Travel Management on the Santa Fe National Forest

Figure 18. A typical National Forest System trail in the Jemez Ranger 

District. This one is not in a wilderness area.

Besides the system trails, unauthorized trails exist on the ground but are not part of the forest’s

transportation system. People driving in the forest create unauthorized routes. For instance, 

motorcyclists might follow a cow trail, and after several rides it becomes a motorcycle trail. Or, 

ATVs could cross a meadow and leave tracks that others follow. Over time, this too could become 

a trail. Some commenters wrote that all unauthorized trails were illegally created and should not 

be designated. If a driver was in a part 

of the forest that allows people to drive 

off roads (53 percent of the forest’s

area), then the trail was not illegally 

created. Some unauthorized routes are 

well located, provide excellent 

opportunities for outdoor recreation by 

motorized and nonmotorized users, 

cause less environmental impact than 

unrestricted cross-country motor 

vehicle use, and would enhance the 

designated system for motorized use. 

Others are poorly located and cause 

unacceptable environmental impact.

The forest plan, written in 1987, didn’t 

contemplate the extent to which 

motorized recreation would become 

part of the forest’s recreational 

Figure 19. Example diagram showing how some 

trails cross nonmotorized areas, but for a driver, 

there would be no way to tell
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 85

landscape. This is evident in that the forest currently has only 27 miles of managed system trail 

and not all are being driven on; most riders are using unauthorized trails instead.

We do not have an inventory of all the unauthorized routes, and the Travel Management Rule 

does not require that we do. We proposed to designate some of the routes that people who like to 

ride in the forest gave us. Of the 1,124 miles of routes provided by motorized user groups, about 

770 are on system roads. In other words, most of the mileage used as motorized “trails” is either 

roads or trails that are already part of the forest’s transportation system.

The chance that what a motorized enthusiast calls a trail is actually a road in the forest’s system is 

three out of four. The motorized trails that people like to drive on are typically closed roads that 

link trails together (figure 20). In this report, we keep the miles of roads and trails separate in 

order to count them only once. This is important since the miles of trail proposed for 

designation will appear smaller than where people said they ride.

We recognize that the opportunity to drive recreationally now is almost unlimited. Few 

restrictions exist on the 460 miles of system trail built for nonmotorized uses outside of 

wilderness, and motorized cross-country travel is allowed on 53 percent of the forest. The 

baseline we use to compare the alternatives is where people drive now, not where they are 

allowed to drive (table 21).

Table 21. Miles of trails being used now on the Santa Fe National Forest. Does not include 

any miles of forest system roads, even though roads may connect loops (figure 21) or 

appear to be trails on the ground.

Used by Vehicles Less Than 

or Equal to 50 Inches

(motorcycles and ATVs)

Used by Motorcycles 

Only Used by ATVs Only

Alternative 1 408 (295 are unauthorized) 17 (3 are unauthorized) 6

Figure 20. An example where a road connects two trails. To get from 

Point A to B, you have to drive on a road. To a rider, it might all look 

like a single, seamless trail.
Chapter 3. Affected Environment and Environmental Consequences

86 FEIS for Travel Management on the Santa Fe National Forest

Figure 21. An example of coincident routes. The trail and the road are 

the same, or coincident, between points A and B. 

Roads may complete parts of trails (figure 20) or be coincident with them (figure 21). If a trail is 

coincident with a road, we counted it as a trail. If we designate a motorized trail that is coincident 

with a road, we would close the road and convert it to a motorized trail. Only vehicles less than or 

equal to 50 inches wide would be allowed on a motorized trail (or motorcycles only in some 

cases).

Areas

Though the “Santa Fe National Forest Plan” allows people to drive off roads on about 53 percent 

(822,000 acres) of the forest, we estimate that people are only doing so on about 29 percent 

(444,000 acres). People drive off roads to explore, scout for game, retrieve downed game, drive 

for pleasure, cut firewood, camp, have motorcycle trials competitions, and get to places where 

they can hike, bike, ride horses, fish, find a geocache, or rock climb and other activities. 

Seasonal Closures

No consistent closures for weather or wildlife exist. Ranger district personnel close some roads 

when they get wet and muddy, typically in winter but also to protect resources like wildlife during 

reproductive seasons and other reasons. Other roads close themselves when they have too much 

snow or otherwise become impassable (figure 22).

Opportunity (Roads, Trails, Areas, and

Seasonal Closures) – Environmental Consequences

Direct and Indirect Effects, Alternative 1

The opportunities for driving on roads, trails, and in areas would not change from the current 

condition as just described. Alternative 1 (no action) provides the most miles and acres for people 

to drive on. Without uniform seasonal closures, people have access to the forest for the longest 

period of time.

The existing condition provides much more opportunity for motorized experiences than the 

current demand, according to the National Visitor Use Monitoring data.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 87

Figure 22. Impassable road due to mud

It is likely that the number of unauthorized routes would grow. Alternative 1 allows travel off 

routes on more than half the forest. Observations by forest staff show the tracks people leave 

when driving off road tend to become established paths over time.

The official motorized trail system would remain small at 27 miles. Use on the other 460 miles of 

trails outside wilderness would be open to vehicles unless posted closed. The Forest Service 

would not manage these trails for a motorized experience with things like signs, loop markers, 

and trail maintenance for ATVs and motorcycles. Local riders would have the advantage of 

knowing where to go, whereas nonlocal tourists may not. 

Cumulative Effects, Alternative 1

Many of the past and present actions listed at the beginning of this chapter contributed to the 

condition of the forest’s transportation system today. The reasonably foreseeable future actions 

are not likely to make large, cumulative changes to the transportation system. 

Direct and Indirect Effects, Alternatives 2 Through 5

Alternatives 2 through 5 reduce the places where people could drive on the Santa Fe National 

Forest (figure 23). Even alternative 4, which leaves the most roads and trails open for motorized 

use of the action alternatives, still reduces open miles by 46 percent. Having fewer miles of roads 

and trails open means that people may not be able to drive to places they can now. All the action 

alternatives prohibit driving off roads except in designated areas and corridors solely for 

motorized access to dispersed camping or big game retrieval. Some people would consider this a 

loss of opportunity to enjoy their national forest, especially those who participate in dispersed 

recreational activities. Others may find a designated, managed system an improvement.
Chapter 3. Affected Environment and Environmental Consequences

88 FEIS for Travel Management on the Santa Fe National Forest

Figure 23. Miles of roads and trails open for motorized use by 

alternative

All the action alternatives would bring the motorized opportunities more in line with the existing 

demand as recorded in the 2009 National Visitor Use Monitoring Survey (Kocis et al. 2010).

All the action alternatives propose designating some unauthorized routes. This means that a 

portion of the roads and trails riders requested would be designated, meeting at least a portion of 

recreational demand.

Roads

People who use out-of-the-way, challenging, high-clearance roads would no longer have as many 

of them to drive on. People will no longer be able to ride or explore on infrequently used roads 

that are not designated. It may be harder for people to go somewhere and be alone, or take longer 

to get there since they would have to proceed without their car at some point. For people who like 

to hike, for instance, not being able to drive to an out-of-the-way trail might mean they wouldn’t 

hike there anymore—hiking to the trail would itself become the hike. Restricting where people 

can drive may affect some hunters who would no longer be able to drive to as many places as 

they used to. Other hunters who prefer to walk may appreciate that fewer places will allow 

motorized use.

Closing more than half the roads to motorized use may not be as drastic as it appears because we 

propose to close roads that people don’t drive on or drive on infrequently. We described earlier 

how passenger car roads get the most use and high-clearance vehicle roads the least. We propose 

to keep most passenger car roads open; the bulk of roads we propose to close are high-clearance 

roads that get little or no use (table 22). Nonetheless, closing the high-clearance roads completely 

removes the potential to use them.

The action alternatives would bring motorized use and dispersed camping in compliance with the 

“Rio Chama Management Plan,” which is part of the forest plan. This means, though, that people 

won’t be able to drive places in the Rio Chama corridor where they do now, and is likely to be 

perceived as a decrease in their ability to enjoy the Rio Chama. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 89

Table 22. Change in roads open to motorized use by alternative. Passenger car 

roads carry the most traffic on the forest, and few of them would be closed.

Alternative

Miles Proposed for Designation

Passenger Car High-clearance Vehicle

1 428 4,691

2 408 1,882

2M 406 1,827

3 405 1,424

4 408 2,140

5 403 1,827

Percent Change from Alternative 1

2 -5 -60

2M -5 -61

3 -5 -70

4 -5 -54

5 -6 -61

Trails

The Santa Fe National Forest manages only 27 miles of motorized system trails, and alternatives 

2 through 5 increase the miles of official motorized system trail to varying degrees. Few 

restrictions on motorized use exist now, so any designated system restricts the amount of 

motorized opportunity from what is allowed under alternative 1, the existing condition (table 23, 

figure 24). Some people will perceive a system of trails designated for motorized use as an 

increase in motorized opportunities by having maintained, signed trails; others will see it as a 

decrease because they won’t be able to drive to places they used to. 

Alternative 4 appears to provide more trails than people drive on now. In reality, many of these 

trails exist and are being used in alternative 1—it’s just that they are National Forest System roads 

now. Alternative 4, by converting these roads to trails, provides more trails uniquely for vehicles 

less than or equal to 50 inches in width. (This is also true for the other alternatives. The only 

difference is that they don’t propose more motorized trails than are currently being used.)

Table 23. Change in motorized trails by alternative. Alternative 1 

shows the miles thought to be driven on now

Type of Route, 

Miles 

Proposed for 

Designation

Alternative

1 2 2M 3 4 5

Vehicles ≤ 50 

inches wide 385 123 80 41 243 167

Motorcycles only 17 140 128 12 219 138

TOTAL 408 263 208 53 462 305
Chapter 3. Affected Environment and Environmental Consequences

90 FEIS for Travel Management on the Santa Fe National Forest

Figure 24. Miles of trail proposed for motorized use by alternative. 

The resultant system would have more motorized National Forest 

System trails, but restrict motorized travel from what is happening 

now.

Alternative 4 also proposes to designate the highest percent of the unauthorized routes motorized 

users provided, the highest of all the alternatives (figure 25). The rest decrease the trail mileage 

from what people are driving and riding on now. Alternative 3 includes almost no unauthorized 

routes. This means that motorcyclists and other drivers who gave us their favorite routes would 

not be able to drive on them, and instead would need to stay on roads. This, in turn, is not likely 

to provide the kind of experience riders seek.

Figure 25. Comparison of how many of the 541 miles of unauthorized 

routes are proposed by alternative
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 91

Alternatives 2, 2M, 4, and 5 propose to allow motorized use on up to 30 miles (depending on the 

alternative—2M at 3 miles and 4 at 30 miles) of system trails built for nonmotorized uses. Since 

people ride on most of these trails now, the change would make them formally open for 

motorized use. If you hike or walk your dog on these trails now, you would continue to encounter 

motorcycles or ATVs unless alternative 3 is chosen. 

Areas

Alternatives 2 through 5 shrink the amount of motorized opportunity by limiting travel off roads 

to the designated system, meaning that driving off roads would no longer be allowed. (We will 

discuss motorized big game retrieval and dispersed camping separately.) Alternatives 2, 2M, 4, 

and 5 propose small areas intended for motorcycle trials and camping, but this is still almost 

nothing compared to alternative 1, the existing condition (figure 26). The areas proposed are 

targeted for certain kinds of use—motorcycle trials and dispersed camping—rather than any kind 

of driving because they’ve been used this way historically, and there is no indication that future 

use would change. The trials areas consist of a series of rocky areas connected by single-track 

trail, without enough room for larger vehicles to travel. The camping areas range in size from 1⁄4 

to about 5 acres, typically too small for motorized cross-country travel. As a result, the 

opportunity for cross-country travel people may be used to in the rest of the forest will be 

removed.

Figure 26. Conceptual illustration of change in acreage open for motorized

cross-country travel by alternative (not to scale)

Not being able to drive a vehicle off road means that people’s dispersed recreational activities 

will change. For instance, hunters will not be able to scout for game off roads on ATVs before 

hunting season, instead having to walk or ride a horse. People will not be able to explore by 

driving cross country; they will have to park and walk or ride a bike or a horse. People who drive

cross country to get to places where they rock climb, ride horses, or bicycle will also have to park 

next to a road and proceed without their cars. A trip that used to take a day may take longer 

because of the time required to get to the desired destination without a vehicle. We expect that 

some people will forego the trip altogether.
Chapter 3. Affected Environment and Environmental Consequences

92 FEIS for Travel Management on the Santa Fe National Forest

The areas proposed for motorcycle trials have been used for it in the past. The dispersed camping 

areas on the Pecos/Las Vegas Ranger District are also used for dispersed camping now every 

weekend during the summer and have been for many years. 

Seasonal Closures

Alternatives 2 through 5 propose seasonal restrictions in various combinations to protect wildlife 

and to prevent driving on routes when they are wet. Having uniform seasonal closures limits

motorized opportunities because closures will exist where they don’t now. All the alternatives, 

however, keep more than 90 percent of the routes open for 7 months or longer (figure 27, table 

24). Snow naturally closes the high country for 5 to 7 months, so people would most notice new 

seasonal closures at lower elevations.

Figure 27. Percent of routes open per year by alternative. 

Alternatives 2M and 4 keep 90 percent of routes open for 9 months 

or more. By comparison, alternatives 2, 3, and 5 keep about 30 

percent of routes open for 9 months or more.

In alternative 1, the existing condition, all routes stay open 9 months of the year or more (with the 

exception of some site-specific forest closure orders which close roads during the winter). 

Alternatives 2M and 4, having 90 percent of routes open 9 months or more, have no uniform 

closures for weather. This means that people would be able to drive on routes until they were 

snowed out or until the ranger districts put closure orders on them when they had snow or were 

muddy. These alternatives provide the most flexibility for keeping routes open, and also the most 

flexibility for closures when needed, for example during the monsoons. The duration routes are 

open in alternatives 2, 3, and 5 is about the same—about 60 percent are open 7 to 9 months, and 

30 percent 2 to 12 months. With uniform seasonal closures proposed for alternatives 2, 3, and 5, 

the forest would not be able to open roads earlier than indicated on the motor vehicle use map. 

Routes also couldn’t be closed during wet periods such as monsoons, resulting in rutting and 

erosion.

Table 24 shows that not all routes would be open all year, as now. It groups roads and trails 

together to show the percent of routes open for different durations. Table 25 breaks out the kind of 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 93

route and shows the percent that do not have seasonal closures. Using alternative 4 as an 

example: 92 percent of the roads would be open all year in this alternative, as would 59 percent of 

the trails for motorcycles only. Alternative 3, conversely, keeps 28 percent of the roads and 34

percent of the motorcycle trails open all year.

Table 24. Percent of routes open seasonally by alternative. You can see that alternatives 2

through 5 have fewer routes open all year than alternative 1, the existing condition.

Months Open 

per Year 

(approximate)

Alternative (percent of routes open)

1 2 2M 3 4 5

3–5 0 2 0 3 4 2

5–7 0 6 2 5 6 5

7–9 0 63 1 63 0 64

9–12 100 29 96 29 90 29

Table 25. Percent of routes with no seasonal closures

Type of Route

Percent of Routes with No Seasonal Closure by Alternative

1 2 2M 3 4 5

Roads 100 30 94 28 92 29

Trails for vehicles ≤ 50 inches wide 100 10 84 4 85 12

Motorcycles only 100 17 81 34 59 16

Grand Total 100 28 93 28 89 28

To interpret the effect of seasonal closures, both tables should be considered together. For 

instance, even though alternatives 2, 3, and 5 only have 28 percent of the routes open all year 

(table 25), more than 90 percent of all the routes are open 7 months or more (table 24).

Having annual, seasonal closures may represent one of the larger changes experienced by the 

public. Seasonal closures limit motorized access compared to the existing condition. Closures 

represent lost motorized recreation opportunity. However, since route conditions will likely be 

improved by providing the forest with a smaller and, thus, more manageable system of routes, it 

also represents an increased recreational benefit of easier access and better conditions for 

motorized recreation. 

Cumulative Effects, Alternatives 2 Through 5

The effect of all the action alternatives would be to reduce the opportunity for motorized access 

and recreation on the forest. The reduction in motorized travel and recreation on the Santa Fe 

National Forest would cumulatively contribute to a similar reduction in access on other public 

lands in the 7-county area. The Carson and Cibola National Forests and the BLM are also going 

through the route designation process, which is expected to also reduce motorized opportunities. 

Though motorized opportunities on public lands would be reduced overall, they would not be 

eliminated. The transition to active management may enhance user experiences by providing a 

higher quality system.
Chapter 3. Affected Environment and Environmental Consequences

94 FEIS for Travel Management on the Santa Fe National Forest

The reduction of motorized access on public lands could be offset by private motorized parks, but 

the extent of the offset cannot be predicted.

Motorized Big Game Retrieval – Affected Environment

The public raised this issue:

“Prohibiting motorized cross-country travel will limit the retrieval of big game, 

perhaps to an unacceptable level.”

Right now, some hunters use trucks and ATVs for at least two reasons directly related to hunting: 

to scout for game before the season and to pick up large game they have killed. (Camping is 

discussed in the next section.) As for scouting with a vehicle, we described in the section on 

“Areas” that driving off roads or trails to scout for game will be prohibited. Vehicles must stay on 

roads or trails designated for motorized use unless retrieving a big game animal or camping in 

designated corridors.

Culturally, hunting is an important activity for the people of northern New Mexico. Early 

inhabitants hunted and lived off the land. Now their descendants, who make up the majority of 

the population in rural areas and small towns in northern New Mexico, continue this traditional 

practice that helps to provide food, is a bonding activity between parents and children, and is a 

way of teaching children about nature and the land around them.

Sport hunting has emerged more recently. Sport hunting can involve large groups, off-highway 

vehicles, and hunting camps. Sport hunting can be very social and many hunters return to the 

forest annually for this activity. The growth of sport hunting has given rise to a community of 

commercial outfitters and guides. The Santa Fe National Forest is known for its trophy animals, 

including elk, mule deer, bear, cougar, and bighorn sheep, which draw hunters from all over the 

world.

Motorized big game retrieval is commonly practiced by big game hunters in northern New 

Mexico. Although it is illegal to hunt from a vehicle, it is currently legal to retrieve downed and 

tagged game in parts of the forest where cross-country travel is permitted. The invention of and 

growth in popularity of off-highway vehicles—ATVs in particular—has led to an increase in off 

road game retrieval. 

The New Mexico Department of Game and Fish identifies mule deer and elk as the two types of 

big game animals people might need a vehicle to get. Bear, though large, do not qualify because 

people tend to take just the skin and don’t eat the meat. Carrying the skin out does not warrant 

using a vehicle (USDA Forest Service 2009f).

We estimate that hunters took an average of 438 elk and mule deer, combined, during the 2008 

and 2009 hunting seasons (USDA Forest Service 2009j). We think most people drive straight in, 

dress and pick up their animal, and drive straight out.

Data on where people kill game animals and then go get them doesn’t exist. We are confident that 

locations change every year. The New Mexico Department of Game and Fish doesn’t ask people 

to report the exact location of their animal or the method they used to get it, just the game 

management unit where they brought it down. We assumed that hunters drive everywhere except 

wilderness areas to get their game. This totals close to 1,267,000 acres—in reality it must be less 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 95

since some places are too steep or the trees are too thick for driving. There are currently winter 

road closures in some parts of the forest to protect roads from damage during wet weather. These 

closures go into effect after most hunting seasons are completed, and typically do not affect 

motorized big game retrieval.

While 438 hunters driving to get game on 1,267,000 acres may not seem like much, it is a lot to 

those 438 hunters. It could mean the difference between putting food on the table or not. Some 

people wrote that without driving, they are physically unable to pick up their animals and 

likewise can’t afford to buy or hire horses. 

Finally, the Hunting Heritage and Wildlife Conservation Executive Order 13443 directs agencies 

to encourage and enhance hunting and wildlife habitat. 

Motorized Big Game Retrieval – Environmental Consequences

Direct and Indirect Effects, Alternative 1

There would be no change in how or where game animals are retrieved. Hunters could continue 

to pick up elk and mule deer, as well as smaller game, using vehicles anywhere on the forest 

where driving is allowed. Whether people think hunting is enhanced by the proposal to reduce the 

places where people can drive depends on their perspective. For those who need vehicles to 

retrieve game, alternative 1 would be best for encouraging hunting. On the other side, people who 

think that vehicles disturb game would consider alternative 1 less than ideal since it allows the 

most motorized use. Alternative 1 is the least effective at conserving and enhancing wildlife 

habitat for most species (refer to the “Wildlife” section later in this document). The large area 

available in the existing condition for motorized big game retrieval combined with the relatively 

small number of annual trips likely results in dispersed use, which not only limits resource 

damage, but may also reduce the displacement of game from a specific area.

Cumulative Effects, Alternative 1

The only anticipated, cumulative decrease in opportunity to retrieve game with a vehicle would 

be through closure orders.

The New Mexico Department of Game and Fish issues hunting licenses based on the population 

of elk and mule deer. Should those populations increase, so might the number of licenses issued. 

But simply having more licensed hunters would not necessarily increase the number of motorized 

trips to get game—hunters need to first be successful and, second, choose to drive to get their 

animal. If all these are true, then more trips in vehicles could be the result.

Direct and Indirect Effects, Alternatives 2 Through 5

Alternatives 2 through 5 limit the public’s ability to retrieve big game with a vehicle. All reduce 

the distance from a road a person could drive to retrieve a game animal compared to alternative 1, 

the existing condition (figure 28). This means that a hunter might have to walk all or part of the 

way to pack an animal out. In alternatives 2, 2M, 4, and 5, a hunter could drive to the edge of the 

corridor. If the animal was farther than that, they would have to stop at the edge of the corridor 

and continue on foot. All the corridors proposed are smaller than the area available and used now. 

Alternative 4 most closely preserves the places where people can drive to get game now. 

Alternative 3 does not allow anyone to drive off roads, so hunters would have to walk to get their 
Chapter 3. Affected Environment and Environmental Consequences

96 FEIS for Travel Management on the Santa Fe National Forest

animals. Alternatives 2 and 2M, which propose corridors 150 or 300 feet from either side of some 

roads, severely limit opportunities from the current condition. Alternative 5 represents a middle 

ground. 

Figure 28. Comparison of acres, and percent change from existing 

condition, where people would be allowed to drive to retrieve elk and mule 

deer

If alternative 2, 2M, or 3 is chosen, we anticipate that some hunters would have no way to get 

their animals due to physical limitations. This would effectively eliminate their ability to hunt and 

perhaps have meat in the freezer. On the other hand, some hunters would perceive not having 

motorized big game retrieval as an improvement; little or no engine noise that would startle game 

would be present more than 300 feet from roads.

Having fixed distance corridors is likely to concentrate use of vehicles within the corridors, 

especially in narrower corridors (alternatives 2 and 2M) or where there are fewer miles of roads 

with corridors (alternative 5). Concentrated use in corridors is likely to cause wildlife to avoid the 

corridors. This could, however, improve hunting away from the roads and reduce conflicts with 

nonmotorized users, especially where the area of the corridors is a small percentage of the forest.

Wildlife avoid recreationists of all sorts, on and off trails and roads (Schultz and Bailey 1978). 

Elk are particularly sensitive to ATVs and will flee from an ATV more than 1,000 meters away 

(Preisler et al. 2006, Naylor et al. 2009). Mule deer are also sensitive and can flee from 

recreationists on trails almost 400 meters away (Taylor and Knight 2003).

Nonmotorized forest users, including those who are hunting, would benefit by having motorized 

game retrieval confined to the corridors because it would reduce the number of encounters with 

motorized users outside these areas. If a motorized vehicle spooks an animal that another hunter 

may be stalking on foot, this creates a lost opportunity and may create a conflict among users. If 

motorized big game retrieval is limited to corridors, nonmotorized hunters can move outside these 

corridors where there would be no driving and subsequent spooking of game. Similarly, if 

motorized big game retrieval is confined to a corridor, nonmotorized users that are not hunters 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 97

can also expect not to encounter motorized users outside that area, thus reducing conflicts from 

the existing condition.

Alternatives 2 and 2M are the only alternatives where camping and game retrieval corridors are 

identical in location (miles along road) and width. Having these two off-road motorized 

designations the same fits the recommendation of New Mexico Department of Game and Fish

that motorized big game retrieval be designated in the same places and ways as other off-road 

uses. This would simplify the motor vehicle use map, allowing visitors to easily interpret and 

comply with it. This is also likely to impact the proximity of game to the corridors as elk and 

other ungulates avoid all types of recreationists (Taylor and Knight 2003, Preisler et al. 2006, 

Naylor et al. 2009).

In alternative 3, hunters would be responsible for transporting game from where it was killed to 

the nearest open route via nonmotorized methods. The absence of any corridors to retrieve 

downed game may affect the ability of hunters to retrieve game. This may also result in more 

unretrieved game across the forest. Additionally, alternative 3 may increase the presence of game, 

and, therefore, hunting by increasing the acreage where motorized vehicles are not allowed.

Game would be less likely spooked by vehicles. On the other hand, the number of hunters might 

decrease because they are not able to use motorized retrieval.

The combination of selected roads and corridor widths in alternative 4 would leave only 

wilderness areas and small pockets of the forest unavailable for motorized big game retrieval. The 

alternative would allow cross-country travel for retrieval of game only, and not for scouting of 

game. Alternative 4 does not follow the New Mexico Department of Game and Fish’s 

recommendation to have parallel designations for all off-road uses. The transition from alternative 

1 to alternative 4 would be negligible. We would expect similar levels of dispersion of motorized 

big game retrieval across the forest and effects of motorized recreation on game as is witnessed 

with the existing condition.

Similar to alternative 4, corridor widths in alternative 5 would be 1 mile on each side of selected 

roads. The alternative proposes the second largest acreage for motorized big game retrieval, but 

one of the smallest in terms of miles of road.

Hunters with physical limitations are likely to prefer alternative 4 or 5 because they provide more 

places to drive and get game. Hunters who dislike hearing vehicles in the back country because 

they disturb game are likely to think that alternative 4 or 5 decreases the quality of hunting. 

Alternatives 2 through 5 would improve wildlife habitat for most species (refer to the “Wildlife” 

section later in this report).

Cumulative Effects, Alternatives 2 Through 5

Selecting any of alternatives 2 through 5 could cumulatively contribute to a statewide reduction in 

opportunities for hunters to drive to retrieve game on public land. The Bureau of Land 

Management and four other national forests in New Mexico (Carson, Cibola, Gila, and Lincoln) 

are all designating a system of roads, trails, and areas for motorized use. Like in the Santa Fe 

National Forest, this is expected to limit where people can drive to retrieve game.

The motorized big game retrieval opportunities proposed in the majority of the alternatives would 

not be affected by actions listed in the reasonably foreseeable future. Because of the wide 

corridors proposed for alternative 4, it could potentially be negatively affected by any project that 
Chapter 3. Affected Environment and Environmental Consequences

98 FEIS for Travel Management on the Santa Fe National Forest

seeks to limit access to, or transfer acreage away from, the forest, for example a mineral lease.

Any negative effect, however, from acreage loss would likely be minimal compared to the large 

amount of acreage proposed in alternative 4.

It is unknown whether the reduction in hunting opportunities on public land would be offset by 

private game reserves.

Motorized Dispersed Camping – Affected Environment

The public and interdisciplinary team both questioned aspects of motorized dispersed camping. 

We expressed the issue like this:

“Designating motorized dispersed camping corridors will increase cross-country 

travel and the resource damage associated with it and curtail the kind of 

unrestricted camping that the Santa Fe National Forest currently provides.”

Motorized dispersed camping is a term used here to refer to the activity often called car camping, 

where people drive to a camping spot, park, and set up their gear close to their vehicles (figure 

29). 

Some people expressed a concern that allowing cars to drive off road any distance, even if just for 

one trip in and one trip out, would damage natural or cultural resources. (Other sections of this 

document address these types of effects.) Conversely, others felt that limiting where people can 

camp would change the basic character of camping on National Forest System lands. They didn’t 

like the idea that they wouldn’t have unlimited opportunity to drive their cars anywhere outside of 

wilderness to set up a campsite.

Where do people car camp now? In the summers of 2008 and 2009, we collected data on where 

people drive to camp (USDA Forest Service 2009g). We found that most camping takes place

now along 438 miles of routes. By mapping corridors around the sites people camp in now, we 

estimate that this covers just over 17,000 acres of the forest (figure 5). Most people tend to set up 

campsites close to roads, often near scenic areas or water (figure 30). During the popular summer 

months and fall hunting seasons in the forest’s busiest stretches, people set up camp anywhere flat 

enough to pitch a tent or set up an RV. It is common to see more than three cars, a couple of RVs, 

several tents, and 20 people in a popular site during the summer months. The Rio Guadalupe 

corridor (Road 376, Jemez district), the Rio Chama (Road 151, Coyote district), and Pecos River 

(Road 63, Pecos/Las Vegas) are examples of heavily used camping areas. The Jemez and Cuba 

Ranger Districts reported having the highest number of sites used frequently, and the Pecos/Las 

Vegas and Española Ranger Districts reported having the highest number of sites not used very 

often.

We tend to see three kinds of car camping: smaller, heavily used sites typically next to water; 

infrequently used sites, usually used by hunters during hunting season; and group campsites about 

1⁄4 to 5 acres found on the Pecos/Las Vegas Ranger District.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 99

Figure 29. A motorized dispersed campsite, meaning it has 

no Forest Service facilities. This site in the Jemez Ranger 

District is close to trails popular with ATV riders. 

Figure 30. A popular camping site near Dalton Creek, 

Pecos/Las Vegas Ranger District

In most areas of the forest, people can drive and park next to streams to camp (figure 31). Water 

attracts people, and we commonly see vehicles right next to streams. Through the Respect the Rio 

Program, we have made a concentrated effort to keep cars out of the riparian areas along the Rio 

Guadalupe and Rio Cebolla (Jemez Ranger District) (figure 32) and along the Pecos River 

(Pecos/Las Vegas Ranger District). Buck and pole fencing, backed up by a closure order, allows 

people to camp close to the water, but blocks vehicles from driving close to streams. 
Chapter 3. Affected Environment and Environmental Consequences

100 FEIS for Travel Management on the Santa Fe National Forest

Figure 31. An example of a campsite right next to water 

Figure 32. A buck and pole fence that keeps cars away from 

the stream, but lets people camp close to the stream if they 

walk 

People who prefer isolation drive off roads and camp in the “back forty,” often where no one else 

has camped before. Hunters tend to do this more than the average weekend visitor (figure 33). 

Ranger district employees estimated that people drive cross country for multiple reasons, 

including camping, on about 444,000 acres. We observed during the field surveys, however, that 

the numbers of people who camp farther than 300 feet from roads is relatively small. In this 

analysis, we treated that use as negligible and focused on the places where people camp next to 

roads. This way each alternative has “corridors” that people can easily compare.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 101

Figure 33. An example of an infrequently used campsite on the 

Coyote Ranger District

The Pecos/Las Vegas Ranger District has three sites, ranging in size from 1/2 to 5 acres that 

people use as group campsites. Together these sites total about 6 acres. On summer weekends,

these sites host multiple RVs and vehicles.

The Rio Chama along Forest Road 151 is popular for motorized dispersed camping because it is a 

wild and scenic river with outstandingly remarkable scenic, recreational, geologic, fish and 

wildlife, cultural, and other similar values. Because of its popularity, this corridor has high 

campsite densities with large numbers of campers and hardened sites. The motorized use and 

motorized dispersed camping isn’t consistent with the “Chama River Canyon Management Plan,”

which is part of the forest plan.

Motorized Dispersed Camping – Environmental Consequences

Direct and Indirect Effects, Alternative 1

There would be no change in the amount of places for motorized dispersed camping under 

alternative 1, the existing condition. As happens now, we expect most people would continue to 

camp in their favorite spots next to roads and water, hunters would search out lightly used places 

during hunting season, and a small number of people would explore and find campsites farther 

than 300 feet from a road.

Cumulative Effects, Alternative 1

Alternative 1 would not change the amount of motorized dispersed camping available, so there 

would be no change in cumulative effects.
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102 FEIS for Travel Management on the Santa Fe National Forest

Direct and Indirect Effects, Alternatives 2 Through 5

Alternatives 2 through 5, to different degrees, would limit the amount of places where people 

could drive and camp compared to the existing condition. Having corridors will be new for many 

recreationists and may affect their sense of having the freedom of choice when camping. Some of 

their favorites sites may no longer allow vehicles due to resource concerns. (Note that the places 

where a person can camp will not change—only where they can drive a car to do so. In all 

alternatives, parking within 30 feet of a road and finding a site on foot is allowed.) The 

alternatives do this in two ways:

• Not being able to drive off roads farther than the edge of a corridor to find a place to 

camp. If you like to drive deep into the woods to camp, you won’t be able to do this 

anymore. Instead, you would park next to the side of the road, or at the edge of the 

corridor, and proceed to find a camping spot without your car.

• Not designating some sites that we think are causing unacceptable resource damage. 

About 1,000 acres where people camp with their cars now haven’t been proposed in any 

of the alternatives for this reason.

All the alternatives (except 3) propose to keep most of the popular car camping places identified 

in the 2008–2009 field inventories.

Figure 34 and table 26 compare where people could drive their cars and camp for each 

alternative. Alternatives 2 and 2M designate most the places where we observe people drive and 

camp now, so they most closely keep the current opportunities. Alternative 2M, however, includes 

a 100-foot setback from all water, so people wouldn’t be able to drive and camp as close to water. 

Forestwide, this totals about 260 acres. Alternative 3 is the most restrictive; people could only 

park next to the side of the road and then move their gear to a campsite on foot—they could not 

drive to their campsite in any circumstance. Alternative 4 provides more acres for car camping by 

doubling the width of many corridors proposed in alternative 2 to 300 feet from either side of 

some designated routes. In this alternative, we’d expect people to spread out and not be as close 

to others. Alternative 5 proposes about one-third fewer corridors for car camping than where 

people camp now.

Reducing the places for motorized dispersed camping could result in more concentrated use in the 

fixed-distance corridors or other designated camping areas, though this varies by alternative, 

depending on how much change from the existing situation is proposed (assumption 21). More 

crowded places may not appeal to people who like to camp away from other people. There could 

be a higher demand for developed campsites if people decide to use them instead of dispersed 

campsites. Some people may feel a loss of freedom by not being able to drive cross country 

anywhere on the national forest to find a place to camp. Some of the remote campsites used by 

locals may no longer be driven to.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 103

Figure 34. Comparison of acres available for motorized dispersed 

camping by alternative (acres used in alternative 1)

Table 26. Comparison of acres available (or used—alternative 1) for motorized dispersed 

camping by alternative

Alternative

1 2 2M 3 4 5

Total acres of camping corridors 17,195 16,237 13,856 0 32,890 11,422

Percent change in acres of 

corridors from alternative 1 -- -6 -19 -100 +91 -34

150-foot corridors, miles 398 394 381 0 0 268

300-foot corridors, miles 39 29 0 0 461 26

Acres of areas for motorized 

dispersed camping -- 5 6 0 5 0

The most popular corridors, as described in the “Affected Environment” section, have been 

proposed in all action alternatives as a result of their popularity, except alternative 3 where there 

are no corridors. According to our assumptions, the forest expects no change in visitation to all 

corridors, even in alternative 3, where people can still park adjacent to the road. Among all the 

alternatives, there would be no change to people’s opportunity to park next to the road and carry 

gear to a campsite using nonmotorized methods.

Alternative 3 is expected to result in the lowest concentrations of motorized dispersed camping 

because the activity is not permitted. Because driving to a dispersed campsite would not be 

allowed, we expect that some people would go elsewhere outside the forest. Others may choose 

to camp in developed campgrounds or move into day use sites not managed for overnight use. 

Finally, because there would still be the option to park a vehicle adjacent to the road and walk to a 

dispersed campsite, this alternative may increase the incidence of roadside parking.

All action alternatives are likely to limit some people’s camping experience. For example, along 

the Rio Chama, some people’s favorite spots may be eliminated from motorized access and some 
Chapter 3. Affected Environment and Environmental Consequences

104 FEIS for Travel Management on the Santa Fe National Forest

of the more remote corridors may not be available via motorized access. This means that a 

favorite place may not be accessible in a day anymore because it is too far to walk to it. 

Alternatives that limit motorized dispersed camping opportunities may encourage people to camp 

in developed campgrounds, move into day use sites not managed for overnight use, or move off 

of the Santa Fe National Forest for dispersed camping.

The action alternatives would bring the Chama River corridor into compliance with the forest 

plan.

Cumulative Effects, Alternatives 2 Through 5

Selecting alternative 2, 2M, 3, or 5 could cumulatively contribute to a statewide reduction in 

places to drive and camp next to your car on public land. Selecting alternative 4 would provide a 

small increase on the Santa Fe, which would somewhat offset other reductions. With the Bureau 

of Land Management, the other four national forests in New Mexico (Carson, Cibola, Gila, and 

Lincoln) also will have a designated system of roads, trails, and areas for motorized use. As in the 

Santa Fe, this will limit where people can drive their cars to camp.

Programs such as Leave No Trace and Respect the Rio already encourage people to not drive or 

camp within 200 feet of water. Alternative 2M would cumulatively add to this concept.

Private landowners offer camping throughout the state. That at least partially offsets any 

reduction on public lands.

Conflicts Between Motorized 

and Nonmotorized Uses – Affected Environment

About 10 percent of the people commenting on the proposed action mentioned having problems 

with vehicles in the woods, or user conflict. To summarize the issue, we wrote this issue 

statement:

“The proposed action, by designating routes uniformly across the forest outside 

of designated wilderness, will cause conflicts between motorized and 

nonmotorized users because they will be recreating in the same vicinity.”

Though conflict between motorized users also can occur—for instance between people on ATVs 

and in full-size trucks driving on the same road—we received few comments about it. Thus, we 

focus on potential conflicts between nonmotorized uses (hiking, horseback riding, bicycling, and 

others) and motorized uses (cars, trucks, ATVs, motorcycles, and others). For example, somebody 

riding a horse may fear that a motorcycle will spook the horse, which could then hurt someone. 

At the same time, the motorcycle rider may also worry about coming around a corner and 

spooking a horse and, therefore, not enjoy their ride as much as they would otherwise.

Conflict between recreational users is a common problem in land management (Calvert et al.

2007). Historically conflict existed primarily between commodity developers—minerals, energy 

resources, timber, and livestock forage—and noncommodity users such as recreationists and 

preservationists (Laitos and Carr 1999). With forest management shifting away from commodity 

extraction and toward recreation, conflict has also shifted. It now tends to be among low impact, 

human powered recreational users and high impact, motorized recreational users (Jubenville 

1978, Laitos and Carr 1999, Andereck et al. 2001, Thapa and Graefe 2003, Calvert et al. 2007).
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 105

Different levels of conflict exist between different types of recreation. The most often reported 

conflicts are between motorized and nonmotorized users, displacement of nonmotorized users, 

and conflicts with private landowners (Dolesh 2004, Government Accountability Office 2009). 

Studies show, in fact, that conflict predominantly exists between motorized and nonmotorized

users (Prey and Kiefaber, Thapa and Graefe 2003, Dolesh 2004, Calvert et al. 2007). In general, 

peoples’ tolerance for other groups was asymmetrical between motorized and nonmotorized; 

nonmotorized users were more likely to feel conflict with motorized users although the reverse 

was not true (Badarraco 1976, Jackson and Wong 1982, Noe et al. 1982, Stokowski and LaPointe 

2000, Andereck et al. 2001, Albritton and Stein 2007).

Conflict exits for many reasons. Both motorized and nonmotorized users often seek similar 

qualities from their experience in nature. For example, both types of recreationists prefer trails 

with scenic overviews and a variety of scenery (Hill and Daniel 2008, Snyder et al. 2008), 

opportunities for solitude (Behan et al. 2000, Kocis et al. 2010, Hallo et al. 2009), places and 

trails with close proximity to water (Albritton and Stein 2007), and places with good or desirable 

trail conditions (Bury and Fillmore 1974). Both groups of users appreciate large areas that allow 

them to travel long distances and over a variety of terrain (Emmel 1992, Snyder et al. 2008). Both 

motorized and nonmotorized users have similar concerns about trail management, including lack 

of ethics by other users, trash, and erosion; however, concerns were ranked differently between 

the two groups (Andereck et al. 2001). Noise from off-highway vehicles is considered one of the 

most widespread and difficult causes of user-conflict on trails (Dolesh 2004).

Despite these similarities, conflict between user groups is sometimes caused by differences in 

desired experiences. Typically, nonmotorized users prefer to have limited exposure to motor 

vehicle noise and presence (Bury and Filmore 1978, Andereck et al. 2001, Snyder et al. 2008). 

Motorized users desire a setting that allows them to perceive freedom and access (Hallo et al. 

2009) and with interconnecting trails that help them achieve long-distance trips (Snyder et al. 

2008). There can be a large variability in values, ethics, and environmental attitudes between 

users. Recreationists labeled as “appreciative,” those participating in activities like hiking, 

camping, picnicking, mountain biking, or photography, were found to have more environmental 

leanings. Motorized recreationists showed more of a desire for environmental dominance (Thapa 

and Graefe 2003).

Conflict also arises from sharing routes or trails with other types of users. Although the majority 

of trail users nationwide are satisfied with their experience and do not report any type of conflict, 

most conflicts occur on multiple or shared-use trails (Dolesh 2004). Conflict is expected to grow 

as the numbers of trail users increase (Dolesh 2004).

In the scoping comments received, we heard that motorcyclists prefer having their own trails. 

ATV riders expressed little objection to sharing trails with single-track riders. A number of 

commenters stated that designating a system of trails would concentrate users and result in 

conflicts. We believe this is unlikely to happen. The number of motorized users in the forest, at 

0.4 percent, is not significant enough to anticipate heavy concentrations on any trail (Kocis et al. 

2010).

A little more than 10 percent of all comments received on the proposed action mentioned having 

conflicts with motorized vehicle use. From this, it appears that although user conflict occurs on 

the Santa Fe National Forest, it is not rampant. The majority of problems seem to be associated 

with specific routes as opposed to overall experiences. Not unlike what the research suggests, 
Chapter 3. Affected Environment and Environmental Consequences

106 FEIS for Travel Management on the Santa Fe National Forest

commenters’ problems involved safety, displacement of nonmotorized users, trail damage caused 

by motorized vehicles, trespass into nonmotorized zones or private property, and disruption of 

quiet. Finally, the perceived conflict does seem to be asymmetrical on this forest. Comments 

received from motorized users sometimes minimized or discounted claims of user conflict.

Even professional researchers find measuring conflicts between users complex since it’s defined a 

number of ways. We chose relative route density—the miles of roads and trails in a given area—

as a measure for conflicts between motorized and nonmotorized users. Nonmotorized users sent 

comments saying they want to go places where noise from vehicles is absent. Most preferred not 

to share routes with motorized users. Intuitively, it seems that higher route densities would spread 

people out, reducing the likelihood that recreationists would encounter one another. Research, 

however, has shown that nonmotorized users prefer to recreate in places separate from motorized 

users, and that motorized users displace nonmotorized users from some shared routes. Therefore, 

we assume areas with high route densities may not reduce user conflict because nonmotorized

users cannot completely avoid drivers. Rather, areas with high route densities increase the overall 

amount of places considered “motorized,” and could limit the opportunities that nonmotorized

recreationists have to themselves.

For this measure, we used these route densities, measured in miles per square mile:

• Low = 0 to 0.4

• Medium = 0.5 to 1.5

• High = 1.6 and greater

Places with high route densities allow for lots of motorized experiences, but provide few areas

where people can go and count on not seeing any vehicles at all. Similarly, places with low route 

densities allow for lots of nonmotorized experiences, but provide few opportunities for motorized 

use. The distribution of places with low, medium, and high route densities also distributes 

recreational experience and, therefore, potentially reduces conflicts between motorized and 

nonmotorized users.

Conflicts Between Motorized and 

Nonmotorized Uses – Environmental Consequences

Direct and Indirect Effects, Alternative 1

We expect that alternative 1 has the greatest potential to cause conflicts between motorized and 

nonmotorized groups. Close to 70 percent of the forest’s acreage has high route densities, 

meaning someone could expect to see or hear a vehicle in the majority of the forest. Though one 

quarter of the forest has low route densities, most of this (75 percent) is in the forest’s wilderness. 

The most likely place to avoid hearing or seeing a vehicle, therefore, would be in a wilderness 

area.

Direct and Indirect Effects, Alternatives 2 Through 5

Regardless of the action alternative chosen, we expect having a system of roads, trails, and areas 

designated for motorized use would reduce conflicts between motorized and nonmotorized

recreationists. Researchers have found that such a system reduces direct conflicts (Filmore and 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 107

Bury 1978, Frost and McCool 1988, Albritton and Stein 2007, Snyder et al. 2008). Drivers stay 

on the system, and everyone else knows where to go to avoid them if they choose.

Alternative 5 is expected to be the most effective at reducing conflict between users. The 

interdisciplinary team developed it by geographically grouping motorized uses away from 

sensitive areas, such as habitat, where possible. 

Alternatives 2 through 5 reduce the acres having high route densities and shift more of them to 

medium route densities. They also increase the acres having low route densities to more places 

outside of wilderness (table 27). Together, this means that people wishing to avoid vehicles would 

have more places to go, and could avoid them without having to go to a wilderness area.

Alternative 4 has the most even balance between high, medium, and low; all represent about onethird of the forest. Alternative 3 would have no areas with high route densities, and is likely to be 

preferred by people seeking nonmotorized experiences. 

Table 27. Percent of forest acres having low, medium, or high route densities. We 

anticipate more conflicts in places with high route densities.

Route Density, 

Miles/square Mile

Alternative

1 2 2M 3 4 5

Low (0 - 0.4)

Total acres 390,924 463,585 449,671 465,193 390,924 463,585

Percent of forest 25 30 29 30 25 30

Percent of low 

density places in 

wilderness

75 63 65 63 75 63

Medium (0.5 - 1.5)

Total acres 80,252 676,018 779,711 1,078,667 463,892 750,557

Percent of forest 5 44 50 69 30 48

High (1.6 +)

Total acres 1,078,087 409,705 319,926 5,448 694,492 335,167

Percent of forest 69 26 21 0 45 22

Cumulative Effects, All Alternatives

We expect that alternative 1, cumulatively, would have the most conflicts when combined with 

the effects of past, present, and reasonably foreseeable future actions described below. We think 

this because it has the most potential for clashes now, as just described. Alternatives 2 through 5

would all cumulatively reduce the amount of conflicts when combined with the actions below.

Subdivision of private property in the forest probably has contributed to conflicts between users 

in the past, and will continue to do so in the future. In many cases, people who move to the forest 

expect a quiet setting and become annoyed by vehicles driving near or through their property. The 

drivers, on the other hand, are used to being able to drive where they want and do not appreciate 

fences suddenly appearing.

The past construction of roads for timber sales and oil and gas developments may also have 

contributed to conflicts by putting in roads where they had not previously existed.

Creation of the Jemez National Recreation Area, three wild and scenic rivers, and educational 

programs such as Respect the Rio likely reduced conflicts by clearly defining what kinds of uses 
Chapter 3. Affected Environment and Environmental Consequences

108 FEIS for Travel Management on the Santa Fe National Forest

could take place within them. Future closure orders and site-specific projects delineating places to 

camp and travel would have the same effect.

Technological advances in off-highway vehicles have probably increased conflicts by allowing 

vehicles to get to places where they hadn’t been before. 

If the population in the Southwest—and its preference for using off-highway vehicles—continues 

to increase, we would expect an increase in conflicts between motorized and nonmotorized users 

in alternative 1. People wishing to avoid vehicles altogether might gradually be pushed to 

wilderness areas exclusively. With a designated system in place, there would be no cumulative 

change since people would know where to go to avoid vehicles.

Wilderness – Affected Environment

People raised this issue about having motorized use near wilderness areas:

“Designating motorized routes close to wilderness will detract from the 

wilderness experience because of noise and trespass.”

Only Congress can designate wilderness areas. The Forest Service can’t create de facto 

wilderness areas by “buffering” them. This section, then, serves to show the potential effects to 

someone in a wilderness area. Adverse effects from motorized use can’t be used to “extend” 

wilderness areas.

Congress passed the Wilderness Act in 1964. The definition of wilderness from the act is:

“A wilderness, in contrast with those areas where man and his own works 

dominate the landscape, is hereby recognized as an area where the earth and its 

community of life are untrammeled by man, where man himself is a visitor who 

does not remain.” 

The Wilderness Act prohibits permanent roads and the use of vehicles and any other forms of 

mechanized transport in wilderness areas. Even rescue missions need special permission from the 

Forest Service to land a helicopter in wilderness, and they usually aren’t allowed to if there is 

another way to send help.

The act describes wilderness using these four qualities:

• Untrammeled, meaning free from modern human control or manipulation.

• Natural, where the natural condition of the land, its plants, wildlife, water, soil, air, and 

the ecological processes are managed, protected, and preserved.

• Undeveloped, retaining its primeval character and influence, and is essentially without 

permanent improvements or human occupation.

• Solitude or primitive and unconfined recreational opportunities.

Engine noise could carry and disturb somebody in a wilderness area, compromising one or more 

of these qualities. We chose 1⁄2 mile as the maximum distance that engine noise could carry, 

though it could be less or more depending on topography, vegetation, and the direction of the 

wind. To measure the possibility of noise reaching wilderness, we tallied all routes and acres 

within 1⁄2 mile of a wilderness boundary for each alternative.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 109

Certainly, seeing a vehicle in wilderness would violate the principles of untrammeled, natural, 

undeveloped, and primitive. One way a person could drive into wilderness is on a road or trail 

that dead ends at the wilderness boundary. So, we measured the number of routes that end at a 

wilderness boundary as a proxy for the potential of illegal trespass. Not all of these, however, are 

conduits to wilderness. Many end in parking lots and are often impassable to vehicles due to 

slope, vegetation, terrain, peer pressure, or a combination of these.

Wilderness – Environmental Consequences

Direct and Indirect Effects, Alternative 1

This alternative has the greatest potential for noise to carry into wilderness and for trespass. The 

number and miles of routes and cross-country travel within 1⁄2 mile of wilderness boundaries and 

any illegal intrusions could affect all four wilderness characteristics. 

Alternative 1 has 597 motorized routes totaling 252 miles within 1⁄2 mile of the Santa Fe National 

Forest’s wilderness areas (table 28). About 19 routes lead to wilderness boundaries. Some of 

these, like Road 151 leading up the Chama River Canyon or Iron Gate Road to the Pecos 

Wilderness, provide access to the wilderness itself. People drive these frequently, especially in the 

summer. Noise from vehicles could carry into the wilderness depending on the specific situation. 

The access routes not shown on the forest visitor map are likely not used as often because people 

don’t know about them, so the frequency of disturbance from these would be less.

Table 28. Comparison of motorized use close to wilderness by alternative

Alternative

1 2 2M 3 4 5

Total miles routes within 1⁄2 mile of 

wilderness boundary 267 127 127 94 138 101

Percent reduction -- -52 -52 -65 -48 -62

Number (count) of routes within 1⁄2 mile 

of wilderness boundary 597 184 167 131 195 131

Percent reduction -- -69 -72 -78 -67 -78

Number of routes ending near wilderness 

boundary* 19 3 3 1 2 1

Percent reduction -- -84 -84 -95 -89 -95

Acres within 1/2 mile of wilderness 

boundary where travel off roads is 

permitted (area or corridor)

9,841 0 0 0 6 0

Percent reduction -- -100 -100 -100 -100 -100

* Some of these are not on the forest visitor map because that map does not show every route in the forest. Some routes 

do not provide access into wilderness due to terrain (e.g., a canyon) or do not lead to a system trail that goes into 

wilderness.

Motorized cross-country travel on 9,841 acres within 1⁄2 mile of wilderness boundaries would 

continue. Visitors in wilderness areas might be able to hear or see vehicles—or drivers could 

trespass into wilderness from these places because they are adjacent—depending on the terrain.
Chapter 3. Affected Environment and Environmental Consequences

110 FEIS for Travel Management on the Santa Fe National Forest

We’ve not received any complaints from people in wilderness about noise from vehicles, so we 

believe the use near wilderness and the ability to hear noise is low now. We have received a few 

complaints of trespass.

Cumulative Effects, Alternative 1

To have a cumulative effect, effects must overlap in space and time. Though alternative 1 has the 

most potential for engine noise or trespass in wilderness, these events are not likely to overlap in 

space or time with other intrusive noises or sights. For example, a person in wilderness would 

have to hear a car and see an airplane passing at the same time for there to be a cumulative effect. 

This is possible, of course, but would be of short duration. Such an event would cause an instant 

of manmade sights and sounds, but would not be permanent. The wilderness would quickly return 

to its untrammeled state. No other present or reasonably foreseeable future projects would add to 

the potential of noise or trespass in wilderness areas.

Direct and Indirect Effects, Alternatives 2 Through 5

Alternatives 2 through 5 reduce the miles, acres, and number of routes within 1⁄2 mile of 

wilderness boundaries, and the acres where driving off roads would be allowed. Thus, all would 

reduce the chance that someone in wilderness would see or hear a vehicle from the wilderness by 

approximately 50 percent or more compared to alternative 1, the existing condition (table 28). 

The action alternatives differ most in the acres next to wilderness where driving off roads would 

be allowed. Use is low now; however, removing cross-country travel and routes near wilderness 

would eliminate the potential for effects in wilderness.

The reduction of places where people could drive would improve all four wilderness 

characteristics. Reductions in illegal intrusions would reduce the influence of humans on the 

wilderness, improving untrammeled and undeveloped characteristics. In addition, fewer 

intrusions would reduce resource damage, improving the natural characteristic. Finally, the 

decrease in number and miles of routes and acreage available for cross-country travel near 

wilderness would reduce the encroachment of sights and sounds across the wilderness boundary, 

improving the opportunity for solitude and primitive recreation.

Cumulative Effects, Alternatives 2 Through 5

Because the alternatives reduce the chance that a person would hear or see a vehicle, the chance 

of having a cumulative effect is likewise less. None of the reasonably foreseeable future actions 

are likely to contribute to effects to wilderness because they are located away from it, or 

mitigations associated with each project would prevent effects.

Inventoried Roadless Areas – Affected Environment

People’s concerns about inventoried roadless areas are the same as those they have about 

wilderness. We wrote the issue this way:

“Designating motorized routes through or close to inventoried roadless areas 

will detract from the potential wilderness characteristics of these areas.”

An inventoried roadless area is a large tract of land whose characteristics resemble wilderness but 

is usually not as pristine. Though we call them “roadless,” many have roads—just not very many 

compared to other areas of the forest (not including wilderness). States and others have legally 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 111

challenged the Forest Service’s rulemaking for, and management of, inventoried roadless areas 

since 2001.

The measures used in this section serve as a proxy of how roads through or near inventoried 

roadless areas would detract from any of the nine characteristics of roadless areas as defined in 

the 2001 Roadless Rule. Specifically, each measure does this as explained below.

• Roads within 1⁄2 mile of inventoried roadless areas represent the potential to detract from 

all nine roadless characteristics.

• Seasonal closures are often implemented to protect wildlife during reproductive seasons 

or soil resources when the ground is soft. Therefore, seasonal restrictions of motorized 

vehicles can help protect some of the characteristics.

• Designating unauthorized or decommissioned roads is considered building new roads and 

in violation of the 2001 Roadless Rule. Trails, including motorized trails, are not included 

in this aspect of the Roadless Rule.

The 2001 Roadless Rule lists nine characteristics often associated with inventoried roadless areas: 

1. High quality or undisturbed soil, water, and air.

2. Sources of public drinking water.

3. Diversity of plant and animal communities.

4. Habitat for threatened, endangered, proposed, candidate, and sensitive species and those 

species dependent on large, undisturbed areas of land.

5. Primitive, semiprimitive nonmotorized, and semiprimitive motorized classes of dispersed 

recreation.

6. Reference landscapes.

7. Natural appearing landscapes with high scenic quality.

8. Traditional cultural properties and sacred sites.

9. Other locally identified unique characteristics (i.e., social, cultural, or historical 

characteristics).

Forest staff chose to use the nine characteristics from the Roadless Rule as the standard for 

analysis when assessing effects to inventoried roadless areas. Since the forest is not regulating 

motorized travel based on the Roadless Rule—just using a portion of it to aid in 

decisionmaking—the nine characteristics are the best choice for assessing impacts from 

motorized travel.

Since the Roadless Rule applies only to roads and not motorized trails, mileages in this section 

are for roads only. Motorized trails may have indirect effects on some Roadless Rule 

characteristics, and these are discussed qualitatively. 

Roads and motorized trails through inventoried roadless areas alter wilderness characteristics. 

Roads and motorized trails aren’t natural—people build them. They serve as conduits for 

vehicles, which are not natural or primitive and disrupt solitude with engine noise. Depending on 

their location and how often people use them, roads and trails can detract from plant, fish, and 
Chapter 3. Affected Environment and Environmental Consequences

112 FEIS for Travel Management on the Santa Fe National Forest

wildlife habitat and damage cultural resource sites. The presence of a road or motorized trail in 

the visual path of an outstanding landscape feature could diminish its beauty.

The Santa Fe National Forest has 55 inventoried roadless areas totaling 241,076 acres. About 293 

miles of routes, including system and unauthorized routes, cross them now. We think that people 

are driving on about 120 miles (41 percent) of these. The roads and trails proposed in the 

alternatives are for access to private land or for recreational purposes.

Inventoried Roadless Areas – Environmental Consequences

Effects Common to All Alternatives

Roads that go through inventoried roadless areas affect roadless characteristics more than those 

within 1⁄2 mile of them. Noise is not likely to travel more than 1⁄2 mile, especially in steep, densely 

forested places. Only 3 percent or less of the total miles of roads in the forest cross inventoried 

roadless areas in any alternative. Only 10 percent or less is within 1⁄2 mile.

Proposing fewer roads than people are driving on now means that they will be barred from using 

some places they like. 

All unauthorized and decommissioned roads proposed for designation already have a footprint on

the ground (figure 35) and are being used. Proposing any of these is not expected to result in a 

change in use (assumption 1). Even if we close roads to motorized use, traces will likely remain 

for a long time, especially those on steep slopes where erosion often prevents plants from 

growing back (refer to the “Soil and Water” section). From this perspective, no difference among 

the alternatives exists.

Figure 35. The photo on the left is what we mean when we say a route has a footprint on 

the ground; the photo on the right does not. Neither photo is in an inventoried roadless 

area.

All alternatives except alternative 1 institute some uniform seasonal closures for weather, 

wildlife, or both. Seasonal closures improve consistency with roadless characteristics by 

protecting wildlife habitat and preventing erosion.

Motorized trails through or in inventoried roadless areas may affect the characteristics that allow 

for dispersed recreation opportunities in solitude and quiet because they can increase noise and 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 113

disrupt feelings of isolation. Although not included in the measures, trails may limit the scenic 

quality of the landscape if they are visible. Finally, they may impact the wildlife species in the 

area by increasing noise, habitat fragmentation, or ingress of invasive species (as discussed for 

routes in general in other sections of this chapter).

Figure 36. Miles of routes in the forest’s inventoried roadless areas 

by alternative

Direct and Indirect Effects – Alternative 1

No change from the current condition would occur. Alternative 1 is the least consistent with 

roadless characteristics because it allows the most motorized use in and near inventoried roadless 

areas. 

The majority of the existing roads through inventoried roadless areas in alternative 1 are on 

existing roads that predate the Roadless Rule, which does not allow for the building of new roads.

The Roadless Rule does allow motorized trails in inventoried roadless areas.

Direct and Indirect Effects – Alternatives 2 Through 5

The effect of the action alternatives is twofold. First, existing routes on the land contrast with the 

characteristics integral to inventoried roadless areas. It is unlikely that removing motorized use 

will result in most routes healing over within 15 years (refer to the “Soil and Water” section of 

this report), but it will allow the potential for routes to begin to revegetate. Second, motorized use 

of routes in inventoried roadless areas causes temporary noise—perhaps 30 seconds or so while 

the vehicle passes—which is not consistent with the principle of solitude. Reducing the places 

where people can drive will reduce the places where people will hear noise from engines.

Alternatives 2 through 5 would all be more consistent with roadless characteristics than 

alternative 1. All shrink the number of routes open for motorized use in and within 1⁄2 mile of 

inventoried roadless areas (table 29). This means the instances where someone could hear or see a 

vehicle in an inventoried roadless area would also diminish. 
Chapter 3. Affected Environment and Environmental Consequences

114 FEIS for Travel Management on the Santa Fe National Forest

By current policy, the adoption of the unauthorized and decommissioned roads would require 

approval from the Secretary of Agriculture in order to adopt them. Alternative 4 is the only 

alternative that proposes unauthorized or decommissioned roads for designation.

Table 29. Comparison of routes in and near the forest’s inventoried roadless areas by 

alternative

Alternative

1 2 2M 3 4 5

Miles of roads inside inventoried 

roadless areas

Roads 120 47 50 40 74 47

Percent change -- -61 -58 -67 -38 -61

Miles of roads within 1⁄2 mile of 

inventoried roadless areas

Total 504 222 208 187 242 195

Percent change -- -56 -59 -63 -52 -61

Miles of unauthorized and 

decommissioned roads in 

inventoried roadless areas

Roads 6 0 0 0 2 0

Percent change -- -100 -100 -100 -63 -100

Cumulative Effects – All Alternatives

Noise from vehicles in inventoried roadless areas could cumulatively combine with other noises 

that are generally considered unacceptable in inventoried roadless areas. Noise from the Gallinas 

Watershed Thinning Project, airplanes, or helicopters could temporarily add to noise from 

vehicles, but this effect would be fleeting. Tracks made by machinery in the Gallinas Watershed 

Project could cumulatively contribute to the appearance of permanent features until the tracks 

heal over or are removed by the Forest Service. 

The preparation of travel management plans and motor vehicle use maps by other national forests 

is likely to cumulatively improve the characteristics of inventoried roadless areas in the 7-county 

area.

Enforcement – Affected Environment

The public questioned the Santa Fe National Forest’s ability to enforce a system of roads, trails, 

and areas designated for motorized use:

“The motor vehicle use map alone will be an inadequate enforcement tool.”

Implicit in this concern is that if people don’t follow the motor vehicle use map, then the effects 

associated with unregulated motorized use—noise, erosion, conflicts between visitors, harassment 

of wildlife—would continue.

Currently, three commissioned law enforcement officers (LEOs) and 20 noncommissioned forest 

protection officers (FPOs) cover the forest. Twelve of the FPOs can write violation notices. These 

officers are responsible for monitoring all 1.6 million acres of the forest.

Data from 2008 and 2009 indicate that 99 percent of violations for damaging natural resources on 

the forest were from off-road vehicles (table 30). Violation notices require either paying a fine or 

a court appearance. Warning notices are written notices of inappropriate, but legal behavior. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 115

Incident reports are written when an FPO observes damage or signs of illegal activity but no one 

is at the site.

Table 30. Number of violations for resource damage on the Santa Fe National Forest in the 

past 4 years

Year CFR Section 

of Offense

Violation 

Notice Warning Incident Total

2006 36CFR2619A1 1 2 62 65

2007 36CFR2619A 6 1 57 64

2008

36CFR2619A 2 0 1 3

36CFR26115H2 5 7 179 191

2009

36CFR2619A 0 0 1 1

36CFR26115H 4 4 64 72

1 36 Code of Federal Regulations Part 261 Chapter 9 (Property) section (a) states the following is prohibited:

“Damaging any natural feature or other property of the United States.” 2 36 Code of Federal Regulations Part 261 Chapter 15 (use of vehicles off roads) Section H states “It is prohibited to 

operate any vehicle off National Forest System, State or County roads in a manner which damages or unreasonably 

disturbs the land, wildlife, or vegetative resources.”

The set of regulations under which LEOs may cite people now are not sufficient to prevent 

resource damage from motor vehicle use. The forest plan was written when off-road vehicles 

were less powerful and less common, and damage from it was not anticipated to be significant.

Two types of violations of the regulations exist now. The first driving in a manner that damages 

natural resources, such as in riparian areas or on steep slopes, in places where cross-country travel 

is allowed (over half the forest). LEOs write violation notices for resource damage only if they 

can tie the damage to an individual or group beyond reasonable doubt. This is a standard that is 

difficult to achieve.

The second type of violation of a regulation is driving in an area that is not open for this activity.

This can include operation of motor vehicles in designated wilderness areas, or on a trail that has 

a closure order in place prohibiting this activity. Currently the forest’s visitor map conveys what 

types of motor vehicle use is allowed. The map is divided into eight sections depicting where 

motor vehicle use is permitted off routes, restricted to roads and trails, seasonally restricted to 

roads and trails either during or outside of the summer, closed to motor vehicles (both areas and 

trails), closed to mechanized vehicles, or closed to all. These restrictions, however, are only 

enforceable where closure orders have been imposed. Most of the forest covered by the 

restrictions shown on the visitor map does not have closure orders.

The effects analysis discussion focuses on the clarity of the motor vehicle use map rather than 

how we implement it. People sent us many good ideas for making this project work on the 

ground: hidden cameras, enforcement “blitzes,” signs, permits, officers on ATVs, high fees for 

violations, self-policing, and others. We will look at these things when we implement this project. 

For this section, we presume that the easier a map is to follow, the more likely people are to 

comply with it.
Chapter 3. Affected Environment and Environmental Consequences

116 FEIS for Travel Management on the Santa Fe National Forest

Enforcement – Environmental Consequences

Direct and Indirect Effects, Alternative 1

No single source would tell people where they are allowed to drive. Inconsistencies between the 

forest’s maps (visitor, ORV, firewood cutting) and the forest plan would continue to exist. The 

forest would remain open to motorized use unless posted closed. Without signed boundaries, 

people might drive into closed areas by mistake.

Direct and Indirect Effects, Alternatives 2 Through 5

Implementing the Travel Management Rule will change the forest’s enforcement context 

completely. Once the decision is made, motorized use will only be allowed where designated, and 

LEOs can issue citations for any motorized use in areas or on routes not designated for that use. 

The New Mexico State Off-Highway Vehicle Statute as amended in 2009 allows State law 

enforcement officers—including New Mexico Department of Game and Fish officers, County 

Sheriff officers, and Department of Public Safety officers—to enforce designations on National 

Forest System land with citations to the State Court system. We are currently working with 

personnel from Game and Fish to coordinate education of law enforcement officers and the 

public, and to plan for coordination of enforcement efforts. 

The motor vehicle use map will clearly designate routes by vehicle class and season. Having a 

single source, the motor vehicle use map, to let people know where they can drive would improve 

compliance and make enforcement easier. The motor vehicle use map follows a national standard, 

so people’s ability to interpret the map would improve because it would be the same for any 

national forest (figure 37). Driving off roads would not be allowed (except for in designated 

corridors for camping and retrieving game), so people would not inadvertently drive into closed 

areas. They would know that any driving off roads is not allowed.

Figure 37. An example of what the Santa Fe National Forest’s motor 

vehicle use map could look like. The symbols and color (black and 

white) are the same for all national forests.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 117

Despite having a single map that follows a national standard, variations in the alternatives make 

some easier to read than others (table 31). As a rule, we think it’s easier to read maps with fewer 

variations—the simpler, the better. Thus, alternatives having several corridor widths for different 

activities would be harder for people to understand. The same goes for seasonal closure dates; 

having more of them would make the map more difficult to understand. Each time a corridor 

changes width or closure date, it must be identified on the motor vehicle use map. To do this, we 

mark each milepost that has a change and put it in a table on the back of the map. This means you 

would have to flip back and forth between the front and back, and also know exactly where you 

were.

Using this metric, the motor vehicle use map for alternatives 2 and 2M would be the hardest for 

people to interpret, whereas alternative 3 would be the easiest. Alternatives 4 and 5 are about the 

same.

Table 31. Number of map variations by alternative. The more variations, the more 

complicated the map would be to read.

Alternative

1 2 2M 3 4 5

Number of different dates for seasonal closures 0 11 8 4 5 5

Number of different corridor widths 0 2 1 0 2 3

Total variations 0 13 9 4 7 8

Cumulative Effects, All Alternatives

Having a national standard for the motor vehicle use map should cumulatively improve people’s 

ability to interpret and understand the Santa Fe National Forest’s map. Because the map will have 

the same symbols for all national forests, people won’t have to learn new symbols for each map. 

A forthcoming implementation plan, which includes education, engineering, and enforcement, 

would cumulatively improve the public’s compliance with the motor vehicle use map. Educating 

people about the proper use of off-highway vehicles in the forest helps them do the right thing in 

the first place. Same with “engineering” controls—signs, gated or bermed roads—or other such 

thing help keep people where they are supposed to be. Last, having fines for breaking the rules is 

a deterrent. All three cumulatively improve the efficacy of the motor vehicle use map.

Maintenance – Affected Environment

As with the topic of enforcement, the public had a lot to say about the Santa Fe National Forest’s 

ability to maintain its route system:

“Any reasonable designated motorized trail system will require more 

maintenance than the Forest Service can provide by itself. An unmaintained 

system will continue to adversely affect forest resources.”

Roads

In 2009, the road maintenance budget for the Santa Fe National Forest was around $1,500,000. 

This budget has been stable over the past 10 years. With it, we maintain between 400 and 550 

miles of road each year. We spend our money where we have the most traffic—on passenger car 
Chapter 3. Affected Environment and Environmental Consequences

118 FEIS for Travel Management on the Santa Fe National Forest

roads. We maintain some high-clearance vehicle roads, too. In 2007, we maintained 88 miles and 

in 2006, we maintained 49 miles. District rangers and the engineering group decide on priorities 

for maintenance of these high-clearance roads based on needs for resource protection, access, and 

condition of the roads. Some receive annual maintenance; others on an as-needed basis.

The Santa Fe National Forest is not funded to maintain all its roads every year. With thousands of 

miles of roads and the funds to maintain only 400 to 550 miles, the maintenance backlog is 

obvious.

Road maintenance costs cannot be simplified into a “cost per mile” unit and applied to all roads 

on the forest. The cost to maintain a mile of road varies by the location and type of road. We can, 

however, determine average needs for certain types of roads. In 2006, the annual maintenance 

needs for passenger car roads on the Santa Fe National Forest was approximately $11,000 per 

mile. This is an average amount that includes the cost of brushing and maintenance of drainage, 

signs, and surface; it is based on a standard method that the Forest Service uses to determine 

maintenance needs. It is by no means perfect, but it is the best information we have. From 

information we gathered in 2005, the annual maintenance needs for high-clearance vehicle roads 

on the forest was approximately $500 per mile. 

Trails

As with roads, the Santa Fe National Forest cannot afford to maintain all of its system trails every 

year, but maintains some every year. We maintain trails the public uses most often, ones that have 

health and safety concerns, erosion or resource damage first or more frequently. We maintain the 

ones that get little use, are remote, or don’t have resource damage less frequently, perhaps every 3 

to 5 years. The forest has typically exceeded its goals due to partnerships and volunteers and has 

maintained between 70 and 220 miles of trails annually in the past several years. For example, in 

2011, volunteers accomplished 171 of the 282 miles of trail maintenance done forestwide. We 

anticipate for this to be the trend over the next several years and are relying heavily on volunteers 

to help maintain the trails.

Trail maintenance costs cannot be simplified into a “cost per mile” unit and applied to all trails on 

the forest. The cost to maintain a mile of trail varies by its location and trail class. We can, 

however, determine average needs for certain types of trails.

To compare the maintenance needs for a motorized trail system, we use two figures. One is the 

average cost to maintain an existing system trail, and the other is to convert an unauthorized trail 

to a system trail. We assume the latter costs more since we might have to build waterbars or other 

basic structures. We’ve assumed the cost to convert a trail is the same as constructing it to Forest 

Service standards. This is likely an overestimate—most of these routes have a footprint or are on 

existing National Forest System roads and don’t require starting from scratch—but this is the 

most reasonable figure we have. 

The Santa Fe National Forest does not have enough miles of motorized trail to provide a 

historical average cost per mile for either maintenance or construction. Costs were derived from 

the Deschutes National Forest for annual maintenance and construction of class 2 trails for

motorcycles and ATVs. Motorcycle maintenance costs are $294 per mile and ATV maintenance 

costs are $423 per mile. Conversion costs were used at $3,000 per mile, which is conservative. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 119

None of these are absolute figures because the actual cost varies with use, slope, terrain, soil type, 

and other factors.

Maintenance – Environmental Consequences

Direct and Indirect Effects, All Alternatives

Roads

The road maintenance needs do not significantly vary among the action alternatives (table 32), 

but all reduce the needed maintenance compared to alternative 1, the existing condition. The 

forest is not likely to receive funds to maintain all the roads annually no matter what alternative is 

chosen, but any of the action alternatives should allow the forest to maintain roads more 

frequently than now. Each alternative has approximately the same number of passenger car miles, 

and these roads are responsible for the vast majority of the costs. The difference between 

$5,200,000 for alternative 3 and $5,500,000 for alternative 4 is around 5 percent of the total 

maintenance needs. This amount could easily be accounted for in the averaging process. 

Having seasonal closures would prevent people from driving on wet roads and making ruts. In 

turn, this would preserve road condition and reduce the need for maintenance. Even though 

alternatives 2M and 4 propose no weather related closures, district personnel are expected to be 

able to implement closure orders in a timely manner. This means that roads would be protected 

when they most need it, while continuing to provide the most flexibility in access.

Table 32. Road maintenance needs on the Santa Fe National Forest by alternative in 

millions of dollars

Alternative

1 2 and 2M 3 4 5

Passenger car roads 4.7 4.5 4.5 4.5 4.4

High-clearance vehicle roads 2.3 0.9 0.7 1 0.9

Total 7 5.4 5.2 5.5 5.3

Trails

On one hand, alternatives 2 through 5 reduce the anticipated trail maintenance needs by at least 

48 percent compared to alternative 1, the existing condition (table 33). (This assumes a consistent 

level and standard of maintenance across all six alternatives.) Alternative 3 proposes the fewest 

miles of unauthorized routes, so would have the least cost of all action alternatives. 

On the other hand, because all the alternatives increase the miles of motorized system trail, all 

increase costs from what is now maintained. That is, people drive on trails but little or no 

maintenance occurs because these trails are not part of the motorized system. Once a trail is part 

of the National Forest System, we maintain it as funds allow.

Having seasonal closures would prevent people from driving on wet trails and making ruts. In 

turn, this would preserve trail condition and reduce the need for maintenance. Even though 

alternatives 2M and 4 propose no weather related closures, district personnel are expected to be 

able to implement closure orders in a timely manner. This means that trails would be protected 

when they most need it, while continuing to provide the most flexibility in access.
Chapter 3. Affected Environment and Environmental Consequences

120 FEIS for Travel Management on the Santa Fe National Forest

Table 33. Trail maintenance needs on the Santa Fe National Forest by alternative, in 

thousands of dollars

Alternative

1 2 2M 3 4 5

Trails for vehicles ≤ 50 

inches wide

Maintain 40.6* 47.3 31.3 17.3 93.1 65.1

Convert 885* 30 21 0 23 15

Trails for motorcycles 

only

Maintain 4.1* 18.5 13.5 3.2 31.8 19.4

Convert 9 234 246 3 336 219

Total, in thousands of dollars 938.7* 329.8 311.8 23.5 483.9 318.5

Percent change from alternative 1 -- -65 -67 -98 -48 -66

*These are theoretical costs computed for comparison purposes only. No new trails would be constructed in the no 

action alternative. These computed costs are what would be required to maintain the existing system of trails at the 

same standard as assumed for the action alternatives. See the recreation specialist’s report for a thorough discussion of 

the assumptions used in this maintenance cost analysis.

Cumulative Effects, All Alternatives

Roads

Given current levels of funding, we won’t be able to maintain every designated road each year in 

any alternative. None of the past, present, and reasonably foreseeable actions would contribute 

enough resources to allow us to do so. Cumulatively with other small projects on the forest, more 

roads would be maintained, but this effect is expected to be negligible when considered over the 

scale of the whole forest.

People with property in the national forest are responsible for maintaining their roads. Some 

counties maintain some roads that cross national forest lands, but this is independent of what the 

Forest Service maintains. In other words, we don’t maintain the same roads as the counties do. 

Transferring land to other entities means the Forest Service would have fewer roads to maintain. 

Conversely, acquiring lands could give us more roads to maintain. “Legacy roads and trails” 

projects, as well as other small road improvement projects on the forest, increase the amount of 

maintenance.

Trails 

For all alternatives, volunteers who maintain trails help stretch our maintenance budget. 

Volunteers enable us to accomplish more maintenance with fewer dollars. Some people wrote to 

say the forest should designate more miles of trails because volunteer assistance would make up 

the difference in maintenance. Even with the added help of volunteers, the trail systems we have 

proposed are the ones we think we are most likely to be able to maintain even with outside help. 

At that, alternative 4—the costliest—is probably out of our reach to adequately maintain even 

with volunteers.

Grants and other sources of funding could be viable options for increasing our ability to maintain 

system trails. Having a designated motorized trail system increases our chances of obtaining 

grants.

While grants and volunteers cumulatively increase the amount of trails we could maintain, it isn’t 

expected to be enough to maintain every trail on the system each year.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 121

Safety – Affected Environment

Public safety involves the type, amount, and speed of traffic on a forest road. Engineering 

employees drive the roads on the Santa Fe National Forest on a regular basis and use that 

information to evaluate public safety. We also use information from accident fatalities. 

In the past 5 years, five fatal accidents have happened in the forest. In three, the drivers were 

either drunk or under the influence of controlled substances. One of the three accidents involved 

an off-highway vehicle and both people on the vehicle died. The Sandoval County Sheriff’s 

Office determined that the fifth fatality was a suicide—the accident wasn’t discovered until 

months after it happened.

On most National Forest System roads, the quality of the roads limits the speed. On a road with 

heavy washboarding, it is impossible to safely go much over 10 or 15 miles per hour. A well 

maintained gravel road allows higher speeds on straight sections, but the curves and hills in the 

road (the geometry) keep speeds lower. On many dirt roads, you must crawl along at less than 5 

miles per hour to keep the wheels out of the erosion channels. The slow speed of traffic usually 

keeps people from having bad accidents.

Volume refers to the number of vehicles on the road. Except for the main roads on the forest, 

traffic volumes are low. Even on the busiest roads, it is possible to drive the entire length of the 

road and not see another vehicle. Having few vehicles on the road also reduces the chance of 

accidents.

Composition is the different types of vehicles in the stream of traffic. Though we have no data on 

composition, we do see different vehicles on forest roads. We see pickup trucks the most, but also 

passenger cars, ATVs, RVs, and motorcycles.

Distribution of traffic generally means directional distribution—how many vehicles go in each 

direction. We have no data on distribution. It is, however, safe to assume that people drive onto 

the forest and then leave. This would tend to indicate that distribution is a 50-50 split; half the 

traffic goes in each direction, even on loops.

The Travel Management Rule requires that we consider compatibility of vehicle class with road 

geometry and road surfacing. Over 90 percent of the road miles on the forest are dirt. The second 

most common surface is gravel, at less than 10 percent. Finally, most campground roads and part 

of Forest Road 376 are paved. The geometry of roads on the forest is fixed. In some cases, we 

designed the roads and considered things like sight distance and ease of driving. In some cases,

the roads came about gradually over many years as people drove on the forest. Sometimes cow 

trails gradually changed from one track to two tracks and became roads.

Safety – Environmental Consequences

Direct and Indirect Effects, All Alternatives 

Alternatives 2 through 5 would be the same as alternative 1, meaning any resultant designated 

system would be considered safe. None of the action alternatives would change the speed that 

vehicles travel, so traffic speeds would remain low, which tends to prevent bad accidents.

We don’t expect the volume, composition, or distribution of traffic to change after designation. 

The passenger car roads that carry the most traffic would continue to carry the most traffic. These 
Chapter 3. Affected Environment and Environmental Consequences

122 FEIS for Travel Management on the Santa Fe National Forest

roads are safe now, and there is no reason they would become unsafe with changes in route 

designations.

The geometry of roads would continue to be appropriate for the types of vehicles that drive in the 

forest. This project proposes no physical construction.

Cumulative Effects, All Alternatives

Past projects shaped the road system we have today, which we consider safe. The action 

alternatives would keep the same level of safety. None of the present or reasonably foreseeable 

actions have effects that would overlap in space and time with the safety of a person driving on an 

individual road. Things the individual could do, like not drink and drive, buckle their seatbelts, 

and keep their vehicles in proper working order, would cumulatively contribute to an individual’s 

safety when driving a National Forest System road.

Effects of Forest Plan Amendments to Recreation

Proposed Amendments in Table 66 of Appendix 1

All the proposed amendments that are administrative in nature are not expected to have effects to 

recreation as a result of this project or future projects. These proposed amendments, for the most 

part, simply update and provide consistent direction for application of the motor vehicle use map.

The proposed amendments that alter off-highway vehicle use within specific management areas 

have no effect because they keep direction for adding motorized use consistent with the intent as 

per the current forest plan and travel management regulations. Management areas where crosscountry travel has been allowed (Management Areas A, B, E, G, P, Q, R, and S) have no plan 

amendment changes that restrict the addition of this type of use through the designation of areas 

or corridors in the future. Management areas where cross-country travel was limited 

(Management Areas C, D, I, J, K, M, and N) have plan amendment changes that continue to limit 

the addition of areas and corridors except when consistent with management emphasis for the 

area. Therefore, none of these amendments are expected to have any effects to recreation in the 

future.

The proposed amendment to the Jemez National Recreation Area (Management Area X) restricts 

the ability of motorized vehicles to pull off roads in JNRA - A areas (as per the travel area map, 

equal to 15,445 acres) to only where motorized dispersed camping or motorized big game 

retrieval corridors are specifically designated. Although this amendment limits these uses to 

places designated on the motor vehicle use map, it does not limit the amount of these corridors 

that can be added in the future and does not represent a big change from current plan direction.

Therefore, this amendment should have no effect on recreation.

Proposed Amendments in Table 67 of Appendix 1

Most of the amendments in this table propose to allow the inclusion of motorized dispersed 

camping corridors and/or motorized big game retrieval corridors in the wild and scenic river areas 

(East Fork Jemez, Rio Chama, and Pecos) and the Jemez National Recreation Area, where these 

uses are currently prohibited. These amendments affect alternatives 4 and 5 only. These 

amendments would have an impact on recreation, specifically causing more potential for conflict 

between motorized and nonmotorized recreation users. These specially designated areas currently 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 123

prohibit or limit motorized dispersed camping or motorized big game retrieval, and people who 

recreate in them have come to expect recreation experiences without this type of off-road travel. 

These amendments allow for the potential expansion of these motorized uses through future 

designations which may negatively impact the potential enjoyment and desire for solitude that 

nonmotorized recreationists such as hikers and fishers expect from these parts of the forest. Laws 

would continue to regulate where within the wild and scenic river areas that corridors could be 

added, but there is still the potential for effects to recreation, especially in scenic and recreation 

designated portions.

The effects of amendments to allow for motorized use on specifically identified routes (in 

Management Areas H and L for varying alternatives) would be identical to the direct, indirect, 

and cumulative effects presented in this report because they relate to a specific road as proposed 

and analyzed for each of the specific alternatives.

Social and Economic Environment

People who commented on the proposed action had several concerns that this document addresses 

in this section:

1. Economics. Reducing routes open to motorized use could decrease the amount of 

motorized recreation in the forest, resulting in negative economic impacts to local 

businesses.

2. Noise. Any motorized use of the forest could cause undesirable noise from engines, 

affecting those who visit the forest and in surrounding areas.

3. Property values. The choice of routes designated could affect the property values of lands 

adjacent or in the forest.

4. Cultural practices and traditions. Reducing routes will limit people’s ability to gather 

forest products like piñon nuts and firewood.

This section, which summarizes the social and economic analysis specialist report, analyzes all 

these issues (USDA Forest Service 2012e). The Forest Service also routinely considers 

environmental justice (how a project could disproportionately affect minority and low income 

populations) in its analysis.

Economics – Affected Environment

Social and Demographic Environment

Modeling Employment and Income from Motorized Use

To describe the potential economic impacts to businesses from the alternatives, we measure the 

number of jobs and income generated by motorized recreation in the Santa Fe National Forest. 

To get the number of jobs and income associated with motorized recreation, we used two models, 

IMPLAN (Impact Analysis for Planning, Professional Version 2.0) and RECA (Recreation 

Economic Contribution Application, called TMECA in the specialist report). These models 

predict how much employment would result from the demand for goods and services. In this case,

the “goods and services” is the opportunity to ride motor vehicles in the Santa Fe National Forest. 

We assumed that more routes designated for motorized use would lead to more motorized use of 
Chapter 3. Affected Environment and Environmental Consequences

124 FEIS for Travel Management on the Santa Fe National Forest

the forest. More motorized use could increase local economic activity by leading more people to 

stay in hotels, creating more jobs to run the hotels, and by people buying meals in local 

restaurants or spending money on gear or equipment.

The models need several pieces of information, including the area of potential economic impact, 

industry sector data (how much economic activity happens in a type of business), and demand 

(the number of people visiting the forest and the activities they participate in). Because we don’t 

have perfect information about all these things, we used the best available data combined with 

assumptions5

. The kinds of information we used to run the models were:.

• Area of potential economic impact. Six of the seven counties within which the Santa Fe 

National Forest is located comprise the area of economic impact. These are Los Alamos, 

Mora, Rio Arriba, San Miguel, Sandoval, and Santa Fe Counties. We excluded Taos 

County because the 7,000-acre portion contained in the forest is the Pecos Wilderness, 

where motorized use is not allowed by law. Whether Bernalillo County was included 

depends on which type of data characterizing “demand” was used, as described in the 

third bullet. Visitor surveys show that a high number of visitors to the Santa Fe National 

Forest come from the Albuquerque area (Kocis et al. 2004, p. 8), which is located 

primarily in Bernalillo County.

• Industry sector data. Data from the Bureau of the Census capture most aspects of 

businesses: shipments, total employment, number of workers, capital expenditures, and 

imports and exports. These numbers are available in the project record.

• Demand. Having data on demand is crucial because the models use it to allocate 

spending to a motorized or nonmotorized category. Of the model’s inputs, data on 

demand is the most uncertain because it is based on survey data. Two different surveys on 

how people use the forest exist: NVUM (National Visitor Use Monitoring) and ABV 

(Attitude, Belief, and Value). The model can only use one dataset at a time. We ran it 

using both sets of data. Running the NVUM and the ABV produces different results 

because of each survey’s intent and how the data were collected. The ABV data show a 

higher numbers of jobs and income than the NVUM. Because of these uncertainties, the 

number of jobs and amount of income are not portrayed as exact predictions; rather, the 

intent is to show a range and compare the alternatives. The percent change is a better 

figure to look at since it normalizes the data, comparing numbers on the same scale.

The NVUM dataset, because of how it was collected, is better suited to the models. One aspect of 

the NVUM dataset is that it focuses on the differences between local and nonlocal spending to 

illustrate how people spend money while participating in different activities. “Local” is defined as 

those people living in a place with a zip code 50 miles or less from the point where the survey 

was taken. As a result, survey participants living in Bernalillo County are not considered local in 

this survey. Thus, Bernalillo County is not included in the area of potential economic impact 

when NVUM data are used as the source of demand.

The ABV survey collected information from people living in Arizona and New Mexico, and did 

not define what “local” meant. Thus, ABV data can be stratified to include Bernalillo County. 

 

5 Some assumptions used in this analysis differ from the interdisciplinary team’s assumptions due to the models’ needs. 

The social and economic analysis specialist report provides the details about the data and the assumptions used.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 125

Including Bernalillo County increases the predicted number of jobs and amount of income, and is 

represented by the high end of the range shown.

The models do not account for the displacement of or potential increase in nonmotorized

recreation that could result from expanding or restricting motorized use on the forest. Thus, this 

analysis takes a “worst case scenario” approach to assessing economic impacts because it focuses 

on the jobs and labor income that would be lost from decreases in motorized use, but not from the 

jobs and labor income that would be gained from increases in nonmotorized use.

Population

Though the population won’t change as a result of the proposal to change motorized use in the 

Santa Fe National Forest, it shows the backdrop in which motorized use occurs.

The analysis area includes almost 1 million people, which is about 60 percent of the population of 

New Mexico. Slightly over 60 percent of the population in the analysis area is located in 

Bernalillo County. Between 1970 and 2006, the population here grew at an average annual rate of

2.1 percent (Headwaters Economics 2009). Sandoval County had the highest growth rate, 5.3 

percent, likely due to the emergence of Rio Rancho as a major population center. The population 

of the seven counties is expected to grow 36 percent over the next 20 years, much as a result of 

retirees attracted by the quality of life (Ulibarrí 2007). 

People aged 35 to 54 years old compose the largest portion of the population. Data show the 

median age of residents is increasing. The largest single age category is 40 to 44 years old at 8.2 

percent. The group aged 50 to 54 years old has grown the fastest, while younger age classes are 

decreasing (Headwaters Economics 2009). Men and women are evenly represented in the area’s 

population. The percent of different ethnicities is becoming more even as the population grows 

(Ulibarrí 2007). 

Employment and Income in General for the Analysis Area

Economic data illustrate four trends in the 7-county area. First, per capita income has steadily 

increased over the past several decades at the same rate or higher than the national average.

Second, service-oriented industries supply most of the economy’s growth. Third, nonlabor 

income—such as social security—contributes the most new income; for instance, it provided over 

a third of all income in 2006. Fourth, government employment is high compared to the rest of the 

State and Nation. The analysis area contains federally managed lands, Indian reservations, and

Los Alamos and Sandia National Laboratories. This last characteristic would likely limit the 

economic impacts of changes in forest management since government jobs are not dependent on 

changes in off-highway vehicle use.

Each county, though following the above four trends, shows differences. For example, the 

difference in average per capita income between Mora and Los Alamos Counties is among the 

highest nationally within a region. Los Alamos County has an exceedingly high rate of 

government employment, whereas Mora County has much higher rate of nonlabor income than 

any other county (Headwaters Economics 2009e, Headwaters Economics 2009b). Most of the 

economic growth came from Sandoval, Bernalillo, and Rio Arriba Counties. All counties show a 

strong trend of growth in the services industry, yet some counties such as San Miguel and Mora 

show equally or almost as much growth in retail industries (Headwaters Economics 2009b, 
Chapter 3. Affected Environment and Environmental Consequences

126 FEIS for Travel Management on the Santa Fe National Forest

Headwaters Economics 2009d). All seven counties have experienced increased unemployment in 

the recent economic downturn (U.S. Bureau of Labor Statistics 2009). 

Employment and Income from Motorized Use

According to the models we used, motorized use contributes between 7.4 and 53 jobs and 

between $187,823 and $1,367,728 of labor income—as opposed to income from pensions or 

retirement accounts—to the local economy. Using 2008 county employment estimates, this 

represents approximately 0.03 percent of all jobs and 0.02 percent of all labor income in the 6-

county analysis area model. In other words, the amount of jobs for motorized recreation on the 

Santa Fe National Forest is less than one-half of one-tenth of 1 percent when compared to the 

entire local economy. 

Motorized Recreational Use in General 

Numerous motorized opportunities exist within the 7-county and surrounding areas. Those we’re 

aware of within a few hours’ drive of the forest are listed in table 34. 

Table 34. Areas with motorized recreation opportunities near the Santa Fe National Forest 

Motorized Vehicle Opportunity Ownership Approximate Time 

from Forest

Mescalero Sands North Dune Off-Highway 

Vehicle Area* BLM – Roswell Field Office 5 hrs

Haystack Mountain OHV Area* BLM – Roswell Field Office 5 hrs

Gordy’s Hill Special Management Area* BLM – Rio Puerco Field Office 2 hrs 20 min

Quebradas Backcountry Byway BLM – Rio Puerco Field Office 2 hrs 20 min

Glade Run Recreation Area* BLM – Farmington Field Office 2 hrs 10 min

Dunes Vehicle Recreation Area* BLM – Farmington Field Office 2 hrs

Gallup OHV-Motocross Park* City of Gallup, NM 2 hrs

Moriarty Motocross* Private – Moriarty, NM 1 hr 30 min

Mountainair Ranger District Forest Service; Cibola NF 1 hr 30 min

NVRP Motocross* Private – Socorro, NM 1 hr 30 min

Sandia Ranger District Forest Service; Cibola NF 1 hr

Mount Taylor Ranger District Forest Service; Cibola NF 1 hr

Various BLM Lands BLM – Rio Puerco Field Office 1 hr

Sandia Motocross Park* Private – Albuquerque, NM 1 hr

Montessa OHV Park* Albuquerque Open Space 45 min

“Rio Puerco Area” Private – Rio Rancho, NM 35 min

San Ysidro Trials Bike Area* BLM – Rio Puerco Field Office 10 min

Carson National Forest Forest Service Adjacent to SFNF boundary

* Specifically intended for OHV use (Source: State of New Mexico 2009)

More information about these and other off-highway vehicle opportunities is available in a report 

titled “Off-Road Vehicle Recreation in New Mexico, Appendix H: ORV Parks and Recreation 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 127

Areas: Supporting Materials”6. In 2011, the New Mexico Game and Fish Department also 

released a brochure entitled “OHVs in New Mexico,” which includes a listing and map of where 

to ride in New Mexico (State of New Mexico 20117

).

From 1982 to 2001, driving motor vehicles off road became one of the fastest growing categories 

of outdoor activity in the country (Cordell et al. 2009). The percentage of people age 16 and older 

who said they participated in off-highway vehicle recreation increased from 17.5 percent in 2000 

to a peak of 23.2 percent in 2003 (Cordell et al. 2008). After 2003, the percent decreased to 19.2 

percent in 2007. Hispanic use of off-highway vehicles grew at the fastest rate, more than 160

percent. The rate of participation by American Indians, at 27 percent, was higher than any other 

racial or ethnic group between 1999 and 2007. Hispanic and Native American represent a high 

percent of northern New Mexico populations.

Motorized Recreational Use in the Santa Fe National Forest

According to the forest’s 2009 National Visitor Use Monitoring (NVUM) report, the two 

“primary use” activities having the highest percent of public participation are hiking and viewing 

natural features. Less than 1 percent of the forest’s visitors come primarily to ride off-highway 

vehicles, though about 0.4 percent said they participate in it. Data from the 2006 ABV survey 

reported a higher percent of off-highway vehicle recreation and driving for pleasure, but still 

found that hiking was one of visitors’ main forest activities. The ABV survey also showed higher 

participation in viewing historic or prehistoric sites or viewing natural features.

The NVUM dataset is more likely to capture those activities that visitors actually participate in 

rather than activities they might choose to participate in. The site-specific collection method used, 

however, has its drawbacks. The NVUM method puts data collection points at main intersections 

or developed recreational facilities. This means that the survey is more likely to collect data from 

visitors that don’t know of lesser used access points. For example, the NVUM is not likely to 

capture local use originating from private lands or lesser known access points. Since visitors from 

outside the local area are more likely to use developed sites, it makes sense that the NVUM data 

shows hiking as a higher use than something like ATV use, which requires knowledge of 

unmarked, unadvertised routes. 

On the other hand, the ABV dataset likely overestimates off-highway vehicle use because it 

disproportionately surveys members of the general population more likely to participate in offhighway vehicle use. It overrepresents high income households, underrepresents low income 

households, overrepresents men, and underrepresents women (Begay 2009).

Using both data sources shows that 0 to 25 percent of the forest’s visitors use off-highway 

vehicles, and that 20 to 67 percent of these folks do so purely for recreational purposes. Data 

from infrared trail counters show motorized use to occur regularly, but at a low level. Vehicle 

counters placed in Cochiti Mesa, for example, show that the most popular trails average 2 riders 

on weekdays and 3 to 7 riders on weekends; the highest count recorded in 1 day was 16 (USDA 

Forest Service 2009bb). When compared to nationally known trails such as the Paiute Trail in 

Utah that averages 164 riders per day, use on the Santa Fe National Forest is comparatively low.

 

6 Available online at http://www.emnrd.state.nm.us/main/sjm40/SJM40report-01-07-09.pdf

7 Available online at http://www.b4uride.com/
Chapter 3. Affected Environment and Environmental Consequences

128 FEIS for Travel Management on the Santa Fe National Forest

The survey data show that people do not consider the Santa Fe National Forest a nationally 

known off-highway vehicle destination. The main riders appear to be local residents familiar with 

the area. The data from the NVUM and ABV surveys demonstrate that most people think of the 

forest as a place to relax and “get away to nature.” There is a lack of off-highway vehicle 

businesses tied to the forest. For example, between 2008 and 2009, a company providing dirt bike 

rentals and tours on the Santa Fe National Forest was unable to survive, because despite all 

efforts to attract business there was no more demand than approximately 15 customers for the 

entire year. The NVUM data show little or no demand for additional opportunities for riding offhighway vehicles, though this could be because most of the forest is open to motorized use now.

Economics – Environmental Consequences

Direct and Indirect Effects, Alternative 1

There would be no change from the existing condition just described.

Direct and Indirect Effects, Alternatives 2 Through 5

Alternatives 2 through 5 would result in an almost imperceptible loss of jobs and income from 

motorized uses considering the scale of the economy in the 6- or 7-county analysis area (table 

35). The maximum predicted job loss from any alternative is far less than one-tenth of a percent, 

and most likely would be less than that. It is likely that the maximums shown are overestimated 

because they are generated from the ABV data.

These numbers are stated as potential maximum decreases, because the jobs and income would be 

lost to the local economy only if all motorized users stop this activity on Santa Fe National Forest 

and all other public lands in the analysis area. More realistically, motorized recreationists would

shift to other private or public areas, which may result in a displacement or loss of jobs and labor 

income. Many people contend that simply the act of designating routes would sharply increase 

their use; however, scientific and informal studies show no evidence of this (Christensen and 

Watson 2006).

Table 35. Comparison of maximum amount of job loss and income from motorized 

recreation by alternative

Existing 

Condition

Alternative 1

Predicted Decrease by Alternative

2 2M 3 4 5

Jobs, number 7 - 53 1 - 13 1 - 13 1 - 27 0 - 5 0 - 13

Maximum percent change 

from alternative 1 -- -0.0065 -0.0065 -0.013 -0.003 -0.0065

Labor income, dollars 

(rounded to nearest hundred) 187,800 - 1,367,700 -- -- -- -- --

Maximum dollar loss from 

alternative 1 -- 341,900 341,900 683,900 136,800 341,900

Service industries and government dominate employment sectors in northern New Mexico. Thus, 

losing such a comparatively small number of jobs to the less developed industry of motorized 

recreation would further diminish the effect. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 129

Reducing the places where people can drive under any of the action alternatives may have these 

positive economic impacts:

• Increased nonmotorized recreation in areas previously used for motorized recreation

• Increase in private businesses catering to nonmotorized recreation

• Increase in motorized use of other public lands to offset losses in the Santa Fe National 

Forest

Though the alternatives are likely to cause a slight loss of jobs and labor income in the economy, 

they could cause a gain of jobs from an increase in nonmotorized recreation. 

Cumulative Effects, All Alternatives

Alternative 1 would not change the management of vehicles in the national forest, so there would 

be no changes in economic effects. Because there would be no changes in economic effects, there 

would be no cumulative effects.

For any of alternatives 2 through 5, the economic change resulting from decreasing the amount of 

routes open to vehicles would be so small as to be overshadowed by larger economic trends. The 

loss of jobs and income for any would be imperceptible at the scale of the local economy, even 

when combined with unemployment due to the recent economic downturn and other public lands 

restricting motorized use.

Since the forest accounts for an estimated 1.3 percent of employment in the adjacent counties 

(Ulibarrí 2007b), this means any action alternative would result in less than a 0.01 percent change 

in employment in the assessment area. This very small potential effect on employment would 

result in a cumulative effect when combined with the national economic downturn since fall 

2007, but still remain less than 0.01 percent. Unemployment has approximately doubled from 

around 3 percent in October 2007 to approximately 6 percent in April 2011. An exception to this 

is Mora County, which went from 5.8 percent in October 2007 to 15.5 percent unemployment in 

April 2011 (U.S. Bureau of Labor Statistics 2011).

Noise – Affected Environment

Noise is defined here as any unwanted sound. A person’s perception—both their ability to hear 

the sound and to consider it a nuisance—plays a large role in what “noise” is. We break down 

noise into four components.

Frequency is how often the sound is heard. For this, we use the traffic count data collected by the 

forest’s transportation engineer. At a given spot, the number of times someone can hear an engine 

depends on how many times a vehicle within earshot goes by. In the Santa Fe National Forest, the 

major routes carry more vehicles than the smaller ones, and both carry far less traffic than roads 

in towns. For example, eight vehicles per hour over an 18-hour period traveled on Forest Road 

376 north of the Gilman Tunnels, the busiest road in the forest. On Forest Trail 113 and 

Crosstown Trail, only three vehicles per day traveled during the week.

Duration is how long the sound can be heard. Sounds from vehicles in the forest usually last 5 to 

30 seconds as a vehicle of any sort tends to be in motion while producing noise.
Chapter 3. Affected Environment and Environmental Consequences

130 FEIS for Travel Management on the Santa Fe National Forest

Magnitude is how loud the sound is, described in decibels. For this we used a model called 

SPreAD (System for the Prediction of Acoustic Detectability), specifically designed to assess 

how noise travels in a wildland setting. Though it can’t provide a clear and definitive statement 

about the noise from a source such as an off-highway vehicle, it can illustrate where sounds from 

motorized use would be greatest and at what levels they could occur. 

The loudness of vehicles varies first with the vehicle. Engine noise ranges from 75 decibels for 

automobiles to 83 decibels for motorcycles. It also varies with distance from the source, 

atmospheric conditions, weather and wind, vegetation, topography, and ambient noise levels. 

Flat, dry, hot, sparsely vegetated landscapes tend to carry sounds the farthest because they present 

the fewest barriers to it. Softer sounds could be heard from farther away in this kind of setting. 

For example, the Caja del Rio would be more likely to carry sounds than Cochiti Mesa (before 

the Las Conchas Fire). Caja del Rio is a sparsely vegetated, hot, and dry mesa top, whereas the 

Cochiti Mesa area is a densely vegetated, higher elevation area with a series of mesas and ridges 

cut by steep canyons. In Cochiti Mesa, sound from an automobile or motorcycle would be much 

more muffled because the vegetation and landscape absorb or deflect the noise. Sound from a 

motorcycle might be heard on the mesa where it is occurring or even may be heard at a lesser 

magnitude on a ridgetop a mile away, but may not be heard in a canyon from 200 yards away. 

Finally, appropriateness refers to sounds that aren’t acceptable in a given setting. For this, we 

measured the miles of routes traversing and close to primitive and semiprimitive nonmotorized

areas defined in the forest plan. These are two classes of areas where the probability of isolation 

from the sights and sounds of people is high, so not having engine noise in these areas is 

desirable.

Noise – Environmental Consequences

Direct and Indirect Effects, Alternative 1

Motorized use would occur on the greatest number of routes and, thus, would affect the greatest 

overall area. Alternative 1 is expected to cause the most noise in areas managed to have little or 

no sounds from people. 

Approximately 48 miles of roads and motorized trails exist in “primitive” and “semiprimitive 

nonmotorized” areas, and an additional 281 miles within 1⁄4 mile of these areas (table 36). The 

total mileage in and near these areas (329) is more than double the mileage of routes in any other 

alternative. Motorized use of these routes probably occurs regularly, but not often. Alternative 1 

would also have noise from motorized cross-country travel that would infringe on primitive and 

semiprimitive nonmotorized areas. For example, approximately 66,250 acres of areas open to 

motorized cross-country travel within 1⁄2 mile of designated wilderness exist in this alternative. 

The frequency and duration of such noise, however, would continue to be low based on estimates 

of motorized use.

Alternative 1 likely causes noise now in Bandelier Wilderness; currently there are approximately 

4 miles of road within a quarter mile of it. These routes are located in the Caja del Rio and Rabbit 

Hill area, which is north of Dome Wilderness, and are used by off-highway vehicles, likely 

resulting in motor vehicle noise that can be heard in Bandelier Wilderness. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 131

Table 36. Miles of routes near primitive and semiprimitive nonmotorized areas as a proxy 

for the appropriateness of noise

Recreational Opportunity 

Spectrum Designation

Alternative, Miles (unauthorized routes in parentheses)

1 2 2M 3 4 5

Miles of routes in primitive 

ROS 9 (0) 4 (0) 4 (0) 1 (0) 1 (0) 1 (0)

Percent change from 

alternative 1 -- -55 -55 -89 -89 -89

Miles of routes in 

semiprimitive nonmotorized

ROS

38 (7) 11 (1) 8 (1) 4 (3) 23 (1) 16 (1)

Percent change from 

alternative 1 -- -71 -79 -89 -39 -58

Miles within 1⁄4 mile of either 282 (22) 134 (8) 126 (7) 94 (2) 150 (10) 116 (8)

Percent change from 

alternative 1 -- -52 -55 -66 -47 -59

Alternative 1 includes 37 miles of motorized routes within 1⁄4 mile of the Valles Caldera National 

Preserve. Portions of these routes on the Jemez, Coyote, and Española districts receive use by offhighway vehicles—such as the motorcycle trails in or adjacent to San Antonio Canyon—likely 

causing engine noise heard in the Valles Caldera National Preserve.

Cumulative Effects, Alternative 1

Since alternative 1 proposes the most routes open for motorized use and keeps the existing 

motorized cross-country travel across much of the forest, activities like hunting, camping, or use 

of chain saws from woodcutting would result in a cumulative impact. Roads and trails facilitate 

access to the forest. Where there is access, there is a greater likelihood for sound-producing 

activities to occur. As a result, since this alternative includes the greatest amount of routes in 

primitive and semiprimitive nonmotorized areas, it would likely result in the greatest cumulative 

noise impact to other forest visitors and those who live in or adjacent to the forest.

Direct and Indirect Effects, All Action Alternatives

All the action alternatives establish a designated system for motorized travel. This means where 

motor vehicles are used will be predictable, so visitors sensitive to or concerned about noise from 

motor vehicles can avoid these areas.

Alternatives 2 through 5 would all diminish the instances where inappropriate noise—as defined 

by the recreation opportunity spectrum—is heard in a primitive area because they all reduce the 

number of roads and trails where people could drive. Table 36 shows that all the action 

alternatives would reduce the miles of routes open for motorized travel in and near primitive and 

semiprimitive nonmotorized areas. This means that the places where driving would be allowed is 

less than the current condition, and we expect the instances of engine noise to be correspondingly 

reduced. The action alternatives nearly eliminate motorized cross-country travel, which 

eliminates it as a source of noise. Compared to the current condition, all the action alternatives 

limit off-road driving to retrieve big game or camp by placing distance limits (corridor width) or 

time limits (seasonal restrictions). This means that the instances of engine noise from any of the 

action alternatives would also diminish. Alternative 3, by not allowing off-road driving for any 
Chapter 3. Affected Environment and Environmental Consequences

132 FEIS for Travel Management on the Santa Fe National Forest

reason and designating the fewest routes for motorized use, is expected to reduce the instances of 

noise the most.

All the action alternatives keep some routes in and near primitive and semiprimitive 

nonmotorized areas, and most propose to add some unauthorized routes. Because motorized use 

occurs on these routes now, there would be no change from the current condition in terms of noise 

generated from driving on them.

We assume that the amount of motorized use is held constant among alternatives because there 

are no data to show otherwise. Some members of the public, however, stated that motorized use 

of remaining routes would increase by concentrating drivers in the same places. Data collected in 

May 2009 on trails in the Cochiti Mesa area show an average of 2.5 off-highway vehicles per day 

with a maximum of 10. Even assuming traffic would concentrate by 20 percent results in an 

average increase of only 0.3 off-highway vehicles per day. This increase in use would be 

overshadowed by eliminating motorized noise from cross-country travel and reducing the number 

of designated routes.

All the alternatives reduce the miles of routes within a quarter mile of Bandelier Wilderness.

Alternatives 2, 2M, 3, and 5 completely eliminate them. This means that noise from current motor 

vehicle use on routes on the Caja del Rio and in the Rabbit Hill area would be minimized and,

thus, would enhance the primitive values of Bandelier Wilderness. Alternative 4 keeps about 4 

miles open, so some noise would continue to be heard. Similarly, all the alternatives decrease the 

miles of routes open to motorized use within 1⁄4 mile of the Valles Caldera National Preserve 

between 22 and 52 percent, thus decreasing the instances of noise from motor vehicle use on the 

edges of the preserve and enhancing the values of solitude for which the preserve is managed.

Alternative 4, because it keeps the most miles open for motorized use, would result in more 

instances of motor vehicle noise than the other action alternatives. It also has the widest fixeddistance corridors for big game retrieval and camping, which means some engine noise in 

primitive and semiprimitive nonmotorized areas may be heard. This noise is expected, however, 

to occur at a very low frequency.

All the action alternatives keep between 94 and 100 percent of the passenger car routes, where the 

majority of the forest’s traffic occurs, so the frequency of noise along the forest’s main routes, 

such as Highway 63 in Pecos Canyon or Forest Road 376, would not change.

The duration of time that vehicles travel (when noise could be heard) is not expected to change 

because no changes in speed limits are proposed. The magnitude of noise would be the same for 

all the alternatives because no change in the kinds of vehicles driving in the forest is expected. 

The other things that govern magnitude, like the weather, topography, and vegetation, are not 

expected to change.

Cumulative Effects, All Action Alternatives

All the action alternatives are expected to reduce the places where noise from vehicles is heard. 

By establishing a predictable motorized system on the motor vehicle use map, all would allow 

forest visitors sensitive to noise to avoid it.

Over the past several decades, motor vehicle use from off-highway vehicles has increased, 

causing more occurrences of noise in popular areas such as the Jemez National Recreation Area, 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 133

Hyde Park area, and Pecos Canyon. The increase in vehicle traffic often has been associated with 

improvements to the recreational facilities. Because little or no change in the number of main 

routes is proposed, there would be no change in noise from them and, therefore, no cumulative 

effect.

At the same time, the forest has cumulatively reduced the places where people can drive by 

establishing closure orders to protect sensitive resources like riparian areas or cultural sites. For 

example, the Jemez Ranger District has enacted 25 closure orders since 1984. Closing even more 

areas and routes to motorized use should cumulatively reduce the places where people hear 

engine noise in the more remote areas of the forest.

Even if motorized use on the remaining routes increased, the noise isn’t expected to cause a 

cumulative impact because all the action alternatives greatly reduce the places where, and the 

times when, people may drive. For noise from any of the alternatives to cause a cumulative effect, 

a person would have to hear the vehicle at the same time as other noises, such as chain saws or 

loud campers. Because the sounds of vehicles are usually less than 30 seconds—the time it takes 

them to pass by—any cumulative effects would also last that amount of time. Any cumulative 

effects would not be permanent. Nonetheless, alternative 4 would likely have the most instances 

where people hear cumulative noise since it has the most places and, therefore, opportunities for 

motorized use to occur.

Environmental Justice – Affected Environment

Environmental justice means that minority or low income groups do not suffer more from the 

government’s projects than other groups8

. In 1994, President Clinton issued Executive Order 

12898 because agencies were repeatedly allowing companies to put harmful things like dumps for 

toxic waste in low income or minority communities. The order requires Federal agencies, 

including the Forest Service, to consider environmental justice when proposing projects.

We used the data from the 2000 census to identify minority populations in the 7-county analysis 

area. The regulation defining a minority population requires that we look at several scales. Table 

37 shows those scales, and also shows the ones that meet the definition of a minority population.

Low income means individuals or households that are below the Federal poverty level. Table 38

shows the percent of the population below the Federal poverty level, and those that meet the 

definition of low income. The data from the last 10 years show that the percent of people in 

poverty decreased. To analyze whether any alternative poses issues with environmental justice, 

we use the projected economic impacts of the alternatives.

 

8 The official definition of environmental justice is that, to the greatest extent practicable and permitted by law, all 

populations are provided the opportunity to comment before decisions are rendered on, are allowed to share in the 

benefits of, are not excluded from, and are not affected in a disproportionately high and adverse manner by 

government programs and activities affecting human health or the environment.
Chapter 3. Affected Environment and Environmental Consequences

134 FEIS for Travel Management on the Santa Fe National Forest

Table 37. Percent of the population by race and ethnicity shown at different scales

Scale or County

Ethnicity Race

Hispanic Not 

Hispanic

Native 

American White All Others

State of New Mexico 42 58 10 67 23

Seven-county Analysis Area 44* 56 6 70 25

Bernalillo County 42 58 4 71 25

Los Alamos County 12 88 1 90 9

Mora County 82* 18 1 59 40

Rio Arriba County 73* 27 14* 57 30

Sandoval County 29 71 16* 65 19

Santa Fe County 49* 51 3 74 23

San Miguel County 78* 22 2 56 42

* Meets the definition of a minority population (Headwaters Economics 2009)

Table 38. Percent of the population below the Federal 

poverty level in 2007 shown at the state and county levels

County Percent

State of New Mexico 18

Bernalillo 15

Los Alamos 3

Mora* 22

Rio Arriba* 21

Sandoval 10

Santa Fe 15

San Miguel* 25

* Meets the definition of low income (Headwaters Economics 2009

Environmental Justice – Environmental Consequences

Direct and Indirect Effects, All Alternatives

Alternative 1 makes no changes to the current designated transportation system, so there would 

be no changes in motorized access to the forest or employment related to motorized use. As a 

result, there would be no effects to minority or low income populations.

Alternatives 2 through 5 would have no measurable effects to low income or other minority 

populations. The restrictions on motorized use apply to all races and ethnicities, so minorities and 

low-income populations would not bear a disproportionate burden. Native Americans and 

Hispanics in the area frequently supplement their household income with the use and sale of 

forest products with piñon nuts in particular. Though being able to drive fewer places may limit 

where people are willing to go to collect piñon, no alternative eliminates this activity. Alternative

3, which is the most restricted in terms of access, would have the largest effect on this activity.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 135

The cost associated with owning and operating a vehicle can be considerable. Low-income 

households are unlikely to own an off-road vehicle just for recreational driving because they do 

not have adequate discretionary income to afford to participate in the sport. In this regard, 

changing motorized access won’t affect people who don’t ride off-highway vehicles 

recreationally now. Low-income households, however, may use Forest Service roads to acquire 

firewood and other subsistence products. Because these activities are governed by permit, there 

would be no change in any of the action alternatives.

Cumulative Effects, All Alternatives

Because there would be no measurable direct or indirect effects from any of the alternatives, there 

would be no cumulative effects.

Property Values – Affected Environment

The value of private property is tied to people’s perceptions. Several studies show that having a 

natural, protected area like a national forest or national park near private property increases its 

value (Kim and Johnson 2002). On the other hand, some may perceive activities conducted by the 

forest or park, such as cutting trees, as undesirable (Kim and Johnson 2002).

People could perceive the reduction of roads, trails, and areas designated for motorized use as 

either negative or positive. Fewer routes to drive on means less access to places in the forest, and 

people might perceive this as negative. They also might see it as an improvement in things like 

scenery or water quality, which would be a positive perception and possibly higher property 

values.

Some people who live in or next to the Santa Fe National Forest wrote that noise and pollution 

from off-highway vehicles would decrease the value of their property. No scientific studies show 

a clear relationship between designating routes for motorized use on public land and property 

values. In urban environments, studies show that building large infrastructure next to homes 

(highways and airports, for example) that introduce new noise may decrease or increase property 

values depending on whether the construction is perceived as a benefit or a nuisance (Bateman et 

al. 2001, pp. 104–112).

We don’t have the capacity to determine how changing where people can drive in the Santa Fe 

National Forest will change property values, or even how the current designated system affects 

property values. The forces that influence property values (like noise, air quality, scenery, water 

quality, wildfire, recreational opportunities, and wildlife abundance) can act in opposing and 

potentially unforeseen ways. Studies identify a correlation between remoteness, scenery, and 

property values but don’t identify a causal relationship (Sengupta and Osgood 2003). Though a 

negative relationship between some characteristics and property prices have been well 

documented, these correlations are from large transportation and infrastructure construction 

projects such as highways and airports that are much greater in magnitude and intensity than any 

potential management changes being considered in this analysis.
Chapter 3. Affected Environment and Environmental Consequences

136 FEIS for Travel Management on the Santa Fe National Forest

Property Values – Environmental Consequences

Direct, Indirect, and Cumulative Effects

As a result of this uncertainty and complexity, we conclude that comparing potential changes in 

property values is too speculative to analyze in detail. It is possible that changes in route 

designation could have an impact on private property values; however, research in this area is far 

from conclusive. Even if economic impacts could be tied to route designation, it is unclear if the 

overall impact would be discernible, positive, or negative. The impacts of route designation on 

each property would likely differ with the preferences of those interested in buying property in 

the area. Because we don’t know how property values would be affected, we cannot definitively 

describe cumulative effects. Having information on the effects to property values isn’t required by 

the Travel Management Rule in order to make a decision.

Cultural Practices and Traditions – Affected Environment

The Santa Fe National Forest provides the people living in its surrounding small, rural 

communities the opportunity to engage in activities, such as hunting and gathering piñon nuts and 

firewood, that provide or supplement a family’s income or food. In a 2000 survey of forest users 

in the Southwest, 31 percent of respondents reported participating in forest product gathering, and 

96 percent said they gathered for personal use rather than for income (Cordell and Tarrant 2002).

The ABV survey recorded that people living in or near a national forest in northern New Mexico 

think the Forest Service needs to respect these uses when planning projects and making decisions.

People depend on the national forest for the following activities:

• Grazing livestock

• Collecting firewood, posts, and other 

small timber products

• Cutting Christmas trees

• Irrigation

• Special uses, like pipelines for 

drinking water

• Hunting 

• Picking piñon nuts

• Collecting nonwoody forest products, 

like edible and decorative plants

Most people use vehicles to participate in these activities. Because all except the last three (those 

on the right side of the page) require permits from the Forest Service, they are exempt under the 

Travel Management Rule (36 CFR 212.51 (a)(8) and 36 CFR 261.13(h)). This means that people 

having a permit would continue to be allowed to engage in these activities regardless of which 

alternative the Forest Service chooses. The permit, however, must specifically authorize use of 

routes and areas not on the motor vehicle use map. Please note that the “Recreation” section of 

this report addresses the issue of hunting. 

The Santa Fe National Forest has not required or issued permits for picking piñon nuts, herbs, 

mushrooms, or other plants. To analyze how these might be affected by changing what is 

designated for motorized use, we measure the miles of roads that go through piñon-juniper 

woodlands (for piñon nuts) and through mixed-conifer, aspen, and cottonwood forests (for herbs, 

plants, and mushrooms). Based on observations, we’ve concluded that people use roads, not 

trails, to get to places to collect forest products, and we’ve only analyzed the roads that cross 

these habitat types.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 137

The extent and magnitude of conflicts between forest visitors engaging in cultural practices and 

others is well documented (Russel and Adams-Russel 2006), but not well quantified (Cordell and 

Tarrant 2002). For this analysis, we assume that any conflict most likely occurs in areas having 

extensive forest product collection and motorized use. 

Cultural and Traditional Practices – Environmental Consequences

Direct and Indirect Effects, Alternative 1

Table 39 shows the miles of routes existing in the habitat types examined. Alternative 1 has the 

highest mileage in both habitat types. In addition, it keeps over half the forest open to motorized 

cross-country travel. Most of the terrain associated with the piñon vegetation type is suited to 

motorized cross-country travel, and is used for off-highway driving. The terrain on which mixed 

conifer, aspen, and cottonwood exists tends to be denser and, thus, less accessible to motorized 

cross-country travel. 

Since alternative 1 would not change the existing condition, there would be no impacts to 

people’s ability to collect piñon nuts, plant materials, herbs, or mushrooms. This alternative, 

however, could increase conflicts between users—even displacing those collecting—over the next 

several years with the expected rise in off-highway vehicle use. Stokowski and LaPointe (2000) 

state, “...noise and intrusion of the modern world into nature often compromises the enjoyment 

of many user groups. The numbers of motorized recreationists, and their intensity of use, also 

results in environmental degradation that reduces the pleasure of nonmotorized visitors, 

potentially resulting in displacement of the nonmotorized users.” For example, elevated use by 

motorcycles in Bland Canyon, Cochiti Mesa, and Peralta Canyon in the Jemez Mountains could 

eventually displace those who collect herbs, mushrooms, or other forest products such as fir 

boughs in the same places.

Cumulative Effects, Alternative 1

Because alternative 1 keeps the existing motorized travel system in place, it would have no direct 

or indirect effect on people’s access for collecting piñon nuts, plant materials, herbs, mushrooms, 

clay or other materials. Because it has no direct or indirect effect on motorized access, there 

would be no cumulative effects. 

Alternative 1 could increase conflicts between forest product gatherers and others, or displace the 

product gatherers altogether. This indirect effect would be most acute in rural, less populated 

communities, such as those in Mora, San Miguel, Rio Arriba, and Sandoval Counties, that depend 

on forest products (Ulibarrí 2007b).

Other activities predicted to cause cumulative increase in user-conflict or displacement of those 

using the forest for collecting materials are rather limited. Restoration, fuels management, and 

vegetation management projects could cumulatively restrict access to treatment areas and change 

the abundance and composition of forest vegetation. These projects, however, generally restrict 

access for one season or less and often increase the abundance and diversity of forest vegetation 

more than 1 year after treatment (Dodson et al. 2007). As a result, Forest Service projects might 

cumulatively restrict access for a season in the treatment areas, but result in cumulatively more 

forest products a year after projects are finished. 
Chapter 3. Affected Environment and Environmental Consequences

138 FEIS for Travel Management on the Santa Fe National Forest

Pumice mining is also likely to cumulatively displace those who use the forest for cultural 

activities. Specifically, the Pueblo of Jemez has concerns about its impacts to cultural uses in the 

Jemez Mountains. Pumice mining would cause a long-term loss in forest products since mines 

strip vegetation. The mines would affect small areas, 2 to 3 acres each, near main forest routes. 

The terrain around the pumice mines also lends itself to motorized cross-country travel, and 

unauthorized routes have proliferated around Forest Roads 10, 271, and 266. Together, pumice 

mines and continued motorized cross-country travel could cause a cumulative displacement of 

those collecting forest products, or an increase in conflicts between visitors.

Direct and Indirect Effects, All Action Alternatives

None of the alternatives restricts the collection of any forest products, only where a person can 

drive a vehicle to get to them. There would be no change in motorized access for people having a 

permit from the Forest Service.

Table 39 shows that all action alternatives reduce the miles of routes in piñon and mixed conifer, 

aspen, and cottonwood types. In addition, all prohibit motorized cross-country motorized travel 

except in designated areas. Alternative 3 designates the fewest high-clearance vehicle roads, 

which are the ones most likely used to collect forest products; alternative 4 designates the most. 

Camping corridors will be limited in size (less than 2 percent of the forest) and off-road 

motorized use to retrieve game would be limited primarily to the fall, which would leave many 

areas where gathering occurs in the spring and summer unaffected. Reducing motorized access is 

likely to keep different uses separate. Studies show that multiple uses in the same places cause 

user conflict in some instances in national forests in northern New Mexico (Russel and AdamsRussel 2006).

Table 39. Comparison of designated roads crossing habitats where people collect forest 

products

Miles of Roads Open to 

Motorized Use Through Forest 

Type

Alternative

1 2 and 2M 3 4 5

Piñon-juniper (piñon nuts) 874 375 273 451 393

Percent change from alternative 1 -- -57 -69 -48 -55

Mixed conifer, aspen, and cottonwood

(herbs, plants, mushrooms) 1,252 440 355 641 490

Percent change from alternative 1 -- -60 -72 -49 -61

Reducing motorized access is likely to decrease some people’s ability to access and engage in 

cultural or traditional uses. Though still accessible by foot or horseback, traveling to collect 

products farther off designated routes would take more effort and is, thus, less likely to occur. 

On the other hand, reducing the places where people can drive could also reduce conflicts 

between forest product gatherers and motorized users. Less motorized access means fewer 

differing activities in the same location, fewer impacts to vegetation, and could help conserve the 

value of locations used to gather forest products. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 139

Cumulative Effects, All Alternatives

The cumulative impacts of decreased motorized access to gather forest products are considered at 

the spatial scale of the northern New Mexico region and temporal scale of the next decade. 

Alternatives 2 through 5 would incrementally reduce the ease with which people can collect 

forest products on public land in the state of New Mexico. The magnitude and extent of these 

traditional practices are not known. 

Since 1987, the Santa Fe National Forest has implemented a number of laws, regulations, and 

orders that restrict motorized access: the establishment of the Jemez National Recreation Area, 

and the East Fork Jemez and Pecos Wild and Scenic Rivers; the development of the lower Jemez 

Corridor and implementation of the Respect the Rio Program, which have limited vehicular 

access in stream buffer zones; land transactions removing parts of the southeast part of the Jemez 

Ranger District from public access and the legislated transfers and exchanges of portions of the 

National Forest System to the San Ildefonso Pueblo and the Pecos National Historical Park; and 

several administrative closures throughout the forest. Adjacent public land, such as the Bureau of 

Land Management and the Cibola and Carson National Forests, are also restricting the use of 

motorized vehicles to designated routes. Overall, these cause a cumulative decrease in motorized 

access. 

Effects of Plan Amendments 

on Social and Economic Environment

None of the amendments in table 65 of appendix 1 have any effects to social and economic values 

analyzed. They have no effects on social and economic values analyzed because they are 

administrative in nature or are modifying the forest plan in accordance with current use on the 

forest.

Proposed amendments that alter motorized use within specific management areas also have no 

effects on any of the social and economic values analyzed because the direction for adding or 

limiting motorized use specified by the amendments is consistent with the intent of allowing 

(Management Areas A, B, E, G, P, Q, R, and S) or limiting (Management Areas C, D, I J, K, M,

and N) motorized travel to corridors in the current plan. The proposed amendments would have 

no additional effects from motorized use in these management areas on jobs, labor income, 

economy, impacts of noise, or traditional and cultural practices because the amendments do not 

allow motorized use where it isn’t currently occurring at some level.

The amendments in table 66 of appendix 1 that allow future designation of motorized dispersed 

camping or motorized big game retrieval corridors in management areas currently closed to crosscountry travel have potential effects. These amendments occur in the wild and scenic river areas 

(East Fork Jemez, Rio Chama, and Pecos) and the Jemez National Recreation Area and apply to 

alternatives 4 and 5 only. The amendments allow for designation of motorized use, specifically 

areas and/or motorized dispersed camping and motorized big game retrieval corridors where it is 

currently prohibited. These amendments could result in a possible decrease in nonmotorized

recreation and increased motorized noise where nonmotorized uses currently predominate, 

potentially resulting in local displacement of some recreational users. The proposed amendments 

would have no additional effects on impacts to traditional and cultural practices.
Chapter 3. Affected Environment and Environmental Consequences

140 FEIS for Travel Management on the Santa Fe National Forest

Lands – Affected Environment

This section focuses on how implementing the Travel Management Rule affects people’s access 

to private land in the Santa Fe National Forest. It summarizes the lands specialist report in the 

project record (USDA Forest Service 2012i).

Legal Background

As described in detail in the lands specialist report, several laws, regulations, and policies govern 

access to private land across National Forest System lands. The Travel Management Rule states 

that the responsible official shall “recognize valid existing rights and the rights of use of National 

Forest System roads and National Forest System trails under § 212.6(b)” (36 CFR 212.55(d)). 

The Forest Service is obligated by law to allow access to private land within the boundary of the 

national forest11 (figure 38). The requirement to do so, however, is not unqualified. The Forest 

Service doesn’t have to construct the road or pay for it. How and where the road is placed is 

based on individual facts and circumstances. The Forest Service does not have to approve access 

that degrades natural resources. For example, if owners have used a route through a riparian area 

to get to their property, the Forest Service can ask that a new route be constructed and used. The 

access to which the landowner is entitled need not be on the most direct, economical, or 

convenient route for the landowner.

Adequate access may not be on a road in 

all cases, and alternative modes of access 

may be considered. The appropriate mode 

or type of access selected should be one 

that is both reasonable for the planned use 

of the private land and, insofar as possible, 

compatible with resource management 

objectives for the National Forest System 

lands. 

Physical access is usually not sufficient for 

the “legal access” requirement imposed by 

mortgage lenders and title companies. 

Most institutions require a road to have an 

easement or be an open forest system road. 

While the law does not obligate the Forest 

Service to provide legal access, it becomes 

a practical necessity for landowners whenever they seek to do anything with their land that 

requires title insurance or a mortgage. The Forest Service authorizes access to private property in 

three ways: a forest system road open to the public, by special use permit, or by easement. Each 

type of authorization has benefits and drawbacks, as summarized in table 40.

 

11 The law that mandates this is ANILCA, the Alaska National Interest Lands Conservation Act of 1980 (P.L. 96-487, 

16 U.S.C. 3210).

Figure 38. An example of a short forest system 

road that leads to private property. The truck is 

on the main road. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 141

Table 40. A summary of the benefits and drawbacks to landowners of different kinds of 

access to private land. This list may not be complete. Some items were raised by the 

public during the scoping period.

Kind of Road Benefits Drawbacks

Open National 

Forest System

road

• It is recognized as legal access by 

mortgage and title companies.

• It is inexpensive; there is no cost to 

the landowner to show the road on 

the motor vehicle use map.

• It is quick—the road appears on the 

motor vehicle use map with the next 

revision, done annually.

• The Forest Service maintains the 

road.

• The road appears on the motor vehicle use map, 

meaning the public is allowed to drive on it 

(cannot be gated).

• The maintenance standard for National Forest 

System roads is resource protection; this often 

falls short of what landowners desire in an access 

road.

Private road 

under special 

use permit

• The road typically does not appear on 

the motor vehicle use map, so the 

public would not be allowed to drive 

on it. The public could, however, use 

the road without a vehicle by hiking 

or biking, for instance.

• It is not recognized as legal access by mortgage 

and title companies; it is essentially considered a 

license that does not convey an interest in real 

property.

• It is expensive to obtain a permit; the landowner 

must pay the Forest Service’s time to analyze, 

prepare, and process the permit. This could be a 

few thousand dollars for a short road, and many 

times that for a long or complicated road. It costs 

almost as much as an easement, but does not carry 

the legal weight of an easement.

• It takes several years for the Forest Service to 

process and issue the special use permit.

• The landowner is responsible for road 

maintenance.

Private road 

having an 

easement

• It is recognized as legal access by 

mortgage and title companies because 

it conveys an interest in real property 

upon transfer. This generally 

enhances property values.

• The road typically does not appear on 

the motor vehicle use map, so the 

public would not be allowed to drive 

on it. The public could, however, use 

the road without a vehicle by hiking 

or biking, for instance.

• Easements reduce future 

disagreements about the location and 

legal status of the road.

• It is expensive to obtain an easement; the 

landowner must pay for the Forest Service’s time 

to analyze, prepare, and process it, and for a 

survey and plat; and in some cases, the formation 

of a road association. This could be quite 

expensive for even a short road, and prohibitive 

for most people for a long or complicated road.

• It takes several years for the Forest Service to 

process and issue the easement.

• The landowner is responsible for road 

maintenance.

• Easements are not exclusive; the Forest Service 

may authorize someone else to use the road, and 

retains the right to use it, too.

The History of Access to Private Land 

in the Santa Fe National Forest

In the past, access to private lands across the Santa Fe National Forest has often been handled in a 

casual manner. Though numerous examples of carefully platted and deeded easements exist, it is 

also not uncommon to find agreements that are generations old, based on nothing more than a 

handshake.
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142 FEIS for Travel Management on the Santa Fe National Forest

The forest has not been closed to overland travel, so many routes were historically created by the 

public over the path of least resistance, often to access private lands. Most patented homesteads 

within the forest lack an easement for access, and instead rely on public and unregulated roads 

over forest lands.

Changing cultural and legal requirements now means we’re faced with two common problems. In 

situations where the Forest Service lacks a public road easement across private lands, landowners 

now tend to gate the road, blocking off all public access, sometimes locking out the public from 

vast acreages. Conversely, private landowners who have made use of a road without easement 

across their neighbor’s property, now find themselves blocked out and in need of a new road. The 

Forest Service then is often perceived as the easiest and first choice solution for new access, with 

the result being many more roads than necessary across public lands.

Figure 39. An example of a historic road that runs through a 

riparian area leading to private property. It’s unlikely this access 

will be authorized by permit or easement in the future. Another way 

to the property would need to be found.

Over time, as we sought ways to manage the network of roads on the forest, we assigned numbers 

to almost all roads for the purpose of identification and classification. One consequence of doing 

this was to give all of these roads status as legal access in the eyes of mortgage lenders and title 

insurance companies. As a result, landowners have relied upon these roads as evidence of legal 

access; properties have been bought, sold, appraised, subdivided, mortgaged, and insured for 

legal access. This backdrop has left us with the following set of circumstances and expectations.

Maintenance Standards. The Forest Service does not have the responsibility to maintain roads 

for subdivision purposes, and lacks the resources to maintain most roads to the standard desired 

by most private landowners. Lacking their own ability to absorb maintenance costs, private 

landowners commonly demand road maintenance be at a higher standard than we can accomplish. 

Some are willing to pay for and perform maintenance duties under a road use permit.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 143

Exclusive Use. Many landowners who perform their own maintenance expect to have exclusive 

access and control over the road. They want their own road, and do not want to share their access 

road with other landowners or the public. They often want to gate and sign the road at some 

distance from the edge of their private land, in order to discourage trespass, vandalism, and theft 

from their homes. Prohibiting public use also eliminates the additional maintenance caused by the 

road-going public.

Physical Location. Many roads originally established by homesteaders or the general public are 

located in places that cause harm to natural resources (figure 40). Often running through riparian 

areas, these roads are not appropriate for access, whether used by the public or private 

landowners. 

Financial Implications. Landowners are finding that in order to continue crossing national forest 

lands, it will cost them significant sums of money to have private access, a privilege they may 

have enjoyed free for generations.

Figure 40. Gated private road. If this road has an easement, it 

would not show on the motor vehicle use map. In that situation, 

a gate is appropriate because the public is not allowed to drive 

on the road, but could engage in nonmotorized activities on the 

public land behind the gate. That would not change under any 

alternative. 

The Santa Fe National Forest’s Approach to 

Providing Access to Private Property Under Travel Management

The Forest Service can satisfy its obligation to allow access to private land in two ways: (1) 

designating a road for motorized use and publishing it on the motor vehicle use map, so it will be 

open to everyone; or (2) authorizing a road under easement or special use authorization to the 

appropriate party and not showing it on the motor vehicle use map. In practice, these two choices 

may conflict with the desires of private landowners, the historic manner in which private lands 
Chapter 3. Affected Environment and Environmental Consequences

144 FEIS for Travel Management on the Santa Fe National Forest

have been accessed, or the need to protect natural resources. Both the rule and the regional 

guidance acknowledge the existence of numerous grey areas where we must evaluate the specific 

situation and apply discretion to our decisions. In the short term, the Santa Fe National Forest 

does not have the capacity to issue authorizations to all landowners who would want or require 

one if the road accessing their property is not designated for motorized use.

When examining requests for legal access to private property, forest staff must consider who, 

what, where, when, why, and how. For example:

• Who is applying? Who owns the land(s) being accessed by the road? Who will be 

maintaining the road?

• What is the motivation for the proposal? What type of access is being requested? What 

type of access do we believe is reasonable? What other uses can be expected over and 

across the road?

• Where is the access being requested? Does it cause unacceptable resource issues? Does 

the proposed location satisfy access for all landowners within a subdivided parcel?

• When does the proponent want the access? Will they need year-round access?

• Why is it necessary to cross NFS lands? Does the proponent have deeded access across 

adjoining private lands? Has the proponent exhausted all legal remedies if they’re 

landlocked by an adjoining private landowner?

• How does the proponent intend to travel across the roadway? How will the person 

applying pay for the proposed improvements?

When considering whether to designate system or unauthorized roads to private land, we tried to 

err on the side of the landowner by including them in alternative 2M, the preferred alternative, 

when they met certain criteria. It’s reasonable to assume that if the forest has historically 

recognized a road as a system road, then a private landowner would assume he’s had legal access 

by way of this system road. So, if a road had one or more of these characteristics, we included it 

in alternative 2M: (1) the appearance of providing access to private lands; (2) whether the road is

currently identified as a system road, regardless of whether it’s open or closed for motorized use; 

or (3) if a road is currently unauthorized, a review was performed to see if there was any 

indication that at one time it had been a formally designated system road. Our research identified 

several “unauthorized” roads that had in fact been system roads in the past. On the other hand, a 

number of unauthorized roads were deliberately not placed in alternative 2M because they 

appeared to have been recently constructed without authorization, and there was no indication 

they had ever been formally part of the forest’s system.

Roads to private property potentially causing damage to other natural resources, such as cultural 

or wildlife, were analyzed individually and included (or not) in the other alternatives, or won’t be 

on the first motor vehicle use map because a mitigation is required.

Motorized Use Near Private Land

There are many private in-holdings within the Santa Fe National Forest. Tension exists between 

private property owners and recreationists using land near private properties. From the 

perspective of the private property owner there is a problem when the public trespasses, 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 145

intentionally or unintentionally, onto private land. From the perspective of the recreationist, they 

have the right to use National Forest System lands immediately adjacent to the private property. 

Most private property is accessed, at least in part, using forest roads. These roads have varying 

degrees of maintenance and rights of access. Often, the less traveled roads used primarily to 

access private land are gated at some distance from the actual private boundary. Some of these 

gates are authorized while many are not. Frequently, these gates are signed “No Trespassing” and 

“Private Property,” leading the general public to infer that the roads themselves and all lands 

beyond the road are private. While this perception is incorrect, it is nevertheless prevalent.

Conversely, other roads that access private lands are heavily traveled and, therefore, receive 

regular public trespass. In some instances, it can be difficult to determine where private property 

boundaries start and public land stops. In others, the public trespass is common regardless of 

boundary marking. These circumstances can prove frustrating to private landowners, who often 

resort to fencing, signs, and confronting trespassers along their boundary.

Lands – Environmental Consequences

Direct and Indirect Effects, Alternative 1

Alternative 1 is the most likely to provide the access needed to private land because it does not 

change where people can drive now. Because we lack the extensive title, subdivision, and 

ownership data for the hundreds of blocks of private land in and adjacent to the forest, we don’t

know who qualifies for ANILCA access rights. As a result, we don’t know how many separate 

access authorizations might ultimately be necessary to address access needs to private lands and, 

therefore, keeping the system “as is” allows people to continue to get to their land in an 

unaffected way.

There would be no changes made to the current system of motorized roads, trails, or areas in 

alternative 1. Therefore, the potential for trespass would remain the same. The current road 

system is extensive and provides many opportunities for recreation near and even on private 

property. Visitors are allowed to use all National Forest System lands, including lands adjacent to 

the private property boundaries. Private property boundaries, however, are frequently not clearly 

marked or are inaccurately portrayed on the ground. This can have the consequence of increasing 

the amount of acreage a private landowner effectively controls, thereby limiting recreation for the 

general public.

Direct and Indirect Effects, Alternatives 2 Through 5

Access

Alternatives 2 through 5 attempt to maintain adequate access across National Forest System lands 

to private property. But each of these alternatives fails to maintain access to certain parcels—

some known, some likely unknown. 

Because motorized use of routes and areas by the general public will be restricted to those shown 

on the motor vehicle use map, the map is likely to be inappropriately used as title evidence 

demonstrating a landowner’s legal access to their private lands across National Forest System 

lands. People have done the same with the forest visitor map, only to find out that the access did 

not exist or was not in the correct location. People should continue to consult with the forest’s 

lands staff on matters of legal access.
Chapter 3. Affected Environment and Environmental Consequences

146 FEIS for Travel Management on the Santa Fe National Forest

Some landowners are likely to discover that roads they thought were private are on the motor 

vehicle use map and open for the public to drive on. The road would remain open to the public 

unless the landowner obtained an easement, which is a costly and time-consuming process. Those 

roads not needed for public motorized use and for which the landowner prefers (and is willing to 

pay for) an easement will eventually be granted an easement. Some landowners will not enjoy the 

same access that once existed because we have removed a duplicate route, or their land does not 

fall under the scope of our legal obligation to provide access (figure 41).

Figure 41. The rectangle represents privately owned land. According to the forest plan, 

both these situations should only have one road leading to them. In practice, the Santa Fe 

National Forest has allowed situations like that on the right.

Publishing the motor vehicle use map is expected to generate a number of issues about access all 

at once. In the past, market forces caused the issues to surface over time. Our capacity to address 

lands issues is limited, so some people would have an unwanted form of access for an unknown 

amount of time into the future.

From an access standpoint, alternatives 2, 2M, 4, and 5 all have similar consequences. Because 

alternative 3 favors resource protection over property rights on certain specific roads, there will 

be greater interference with access to private lands, if this alternative is chosen.

A few parcels of land, such as those around Bearhead Peak on the Jemez Ranger District or the 

one near Nambe adjacent to the Pecos Wilderness, are located in inventoried roadless areas. For 

this reason, alternative 3 does not propose motorized access to these and other parcels in sensitive 

places, like riparian areas. This is likely to create problems and expense for the landowners 

should they wish to sell their property.

Alternative 4, on the other hand, does propose motorized access to some of these parcels. As a 

result, people who are used to hiking to Bearhead Peak could expect to see vehicles, and it would 

cause motorized use in inventoried roadless areas. We expect that many hikers would consider 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 147

this a loss of a hiking trail. Some roads provide historical access to landowners, but are situated in 

a way that causes damage to natural resources (figure 42). Alternative 4 proposes some of these 

for motorized use.

Figure 42. Road leading to private property that is causing 

damage to the stream and riparian area

All of the alternatives take away some discretionary or duplicate roads. By not designating some 

roads that exist now, we may have inadvertently removed legal access to some property (figure 

41). If this is the case, we would correct the motor vehicle use map to provide the needed access.

Use Near Private Land

The number of routes to private property has been reduced in alternatives 2 through 5, which 

would reduce the potential for trespass. Most of these routes, however, will now appear on the 

motor vehicle use map whereas they may not have appeared on any other publication. Publishing 

the location of a route on the motor vehicle use map could cause more people to drive on it and,

thus, trespass. Alternatively, if the route ends on private property many people would not drive up 

it. In the current condition, people might follow a route to private property just to explore.

Designating routes to private land as “open to highway legal vehicles only” would reduce the 

possibility of trespass by ATVs since they would not be allowed on that route. It would also 

eliminate the ability of private property owners to use ATVs as ingress and egress across Forest 

Service land to their property.

Alternative 4 proposes the largest number of routes open to motorized vehicles, which increases 

the opportunity for trespass more than the other action alternatives. In addition, this alternative 

designates motorized access to a few private parcels currently accessed only by hiking trail, for 

example Bearhead Peak on Jemez Ranger District. As a result, these properties would be easier to 
Chapter 3. Affected Environment and Environmental Consequences

148 FEIS for Travel Management on the Santa Fe National Forest

access than in the other action alternatives, increasing the chance of trespass from the existing 

condition. 

Showing designated routes to private land on the motor vehicle use map could increase motorized 

travel on those routes. Intentional and unintentional trespass by recreationists onto private 

property near national forest lands is recognized as a relatively common occurrence. Logically, 

parcels of private property near National Forest System lands that receive heavy recreational use 

are likely to see greater numbers of trespassers, simply by virtue of their close proximity to large 

populations of people. However, remote, unfenced private lands are not immune. Trespass can be 

limited by gating roads that access private property. Since many people perceive that trespass 

beyond any gate is prohibited, public access to Forest Service land beyond the gate becomes 

restricted. The Forest Service does not monitor the rate of trespass onto private property, but it 

knows through discussions between landowners and law enforcement officers that the situation 

occurs.

Cumulative Effects, All Alternatives

Because issues of access to private land occur over specific roads, they are unique. No additional 

actions contribute to access issues that are outside the scope of the original issue, so no 

cumulative effects exist for any of the alternatives.

Effects of Forest Plan Amendments to Lands

Proposed Amendments in Table 66 of Appendix 1

There are two lands related amendments proposed which would affect access to private lands, and 

the administration of new special use authorization applications. In both instances, the proposed 

language refines previous direction by providing more clarity. The amendments also remove 

language tied to definitive limitations on how we provide access, and the timeframe in which 

we’re to respond to applications as a forest. The new language reflects a historical reality in how 

we’ve issued authorizations that if not modified, would leave us perennially unable to meet plan 

direction. The new language also simplifies administration of new special use authorization 

applications by stating that we’ll follow existing policy and regulation, enabling the forest to 

maintain consistent forest plan direction, regardless of future changes to policy and regulation. 

Both proposed changes are advantageous to future management of the realty program.

The proposed amendments that would restrict off-highway vehicle travel in management areas 

that are currently open to it are likely to result in no effect to the lands program because adding 

fixed-distance corridors doesn’t alter access to private land. 

Proposed amendments that authorize designation of additional areas and corridors for motorized

travel in Management Areas C, D, I, J, K, M, and N are also not expected to have effects to future 

management of the lands program because they do not alter private property access.

Proposed Amendments in Table 67 of Appendix 1

These amendments are alternative specific, principally applying to alternatives 4 and 5, and 

propose to allow the inclusion of motorized dispersed camping corridors and motorized big game 

retrieval in the wild and scenic river areas (East Fork Jemez, Rio Chama, and Pecos) and the 

Jemez National Recreation Area, where this use is currently prohibited. With the exception of an 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 149

amendment for Management Area L in alternatives 2, 2M, and 4, these amendments are not 

expected to have effects on future management of the lands program because access to private 

property is protected and regulated by other legislation, such as the Alaska National Interest 

Lands Conservation (ANILCA). The amendment for Management Area L simply recognizes the 

existence of this legislation.

The effects of amendments to allow for motorized use on specifically identified routes (in 

Management Areas H and L for varying alternatives) would be identical to the direct, indirect, 

and cumulative effects presented in this report because they relate to a specific road as proposed 

and analyzed for each of the specific alternatives.

Soil and Water – Affected Environment

This section summarizes the soil and water resources specialist report in the project record 

(USDA Forest Service 2012a). Two of the significant issues raised by the public relate to soil and 

water:

1. “Continued motorized use of routes and areas by the public will cause 

erosion and soil compaction and degrade water quality and watershed 

condition.”

2. “Designating motorized dispersed camping corridors will increase crosscountry travel and the resource damage associated with it.”

An important part of the Forest Service’s mission is to protect soil and water quality. Congress 

established our national forests in part to protect the watersheds that provide much of the 

country’s drinking water. Intact soils sustain the plant growth that provides forage, fiber, wildlife 

habitat, and watershed protection. Healthy, functioning watersheds provide a reliable water 

supply, protect water quality, and prevent or reduce downstream floods.

To compare the effects of the alternatives, we based our measurements on the sixth-field 

watershed level. The sixth-field level allows the analyst to understand the predicted effects at a 

more local level. Watersheds form the basic unit of the hydrologic system. They naturally divide 

the landscape into units, draining rainfall and snowmelt into a common stream, stream network, 

or body of water. Environmental changes commonly accumulate and appear in watersheds. The 

U.S. Geological Survey developed the system for describing watersheds by different scales, 

dividing them into progressively smaller, nested watersheds. The first level is the largest. For 

example, the lower 48 states contain 18 first-field watersheds. The Santa Fe National Forest has 

jurisdiction in all or parts of 123 sixth-field watersheds that contain at least 1 square mile of 

National Forest System lands (USDA Forest Service 2012a). An additional 17 sixth-field 

watersheds were removed from discussion because they had less than 1 square mile of SFNF 

ownership. Due to the scale of this project, it was impractical to describe effects on so few acres.

Background

How Routes Affect Soil and Water

Bare or eroding soil causes a number of problems. Plants and trees can’t take root in moving soil, 

so the soil is not productive. Without plant cover or litter, rainwater and snowmelt has nothing to 
Chapter 3. Affected Environment and Environmental Consequences

150 FEIS for Travel Management on the Santa Fe National Forest

slow it down, increasing the chances of 

flooding and sedimentation (figure 43) 

(MacDonald and Coe 2008). 

When it rains or when snow melts, grass and 

plants catch and filter water so that it seeps into 

the soil. This replenishes groundwater, checks 

flooding, and prevents sedimentation, the 

process where soil is carried by water into 

streams. 

Roads and trails increase sedimentation beyond 

natural conditions (Satterland and Adams 

1992). In forested watersheds, roads and trails 

disrupt a watershed’s natural hydrology by 

presenting ribbons of bare soil that parallel or 

cross streams (Furniss et al. 2000). If they are 

unpaved, rain and snow causes them to erode. 

Paved or unpaved, they concentrate and 

accelerate runoff until it leaves the route (figure 

44). By channeling and accelerating water, 

routes can increase the amount of water 

naturally carried by streams, especially during 

spring snowmelt and thunderstorms (King and 

Tennyson 1984). With more water than usual, 

streams widen or deepen, which decreases bank stability, increases sediment, and increases the 

water’s temperature (MacDonald and Stednick 2003).

In compliance with the Clean Water Act, the New Mexico Environment Department lists streams 

as “impaired” when they exceed certain parameters, such as temperature, sediment, and turbidity. 

Routes and vehicle use contribute to these three impairments, though other forest activities can, 

too.

Not all sediment from routes immediately enters perennial streams. Often ephemeral and 

intermittent channels will capture and temporarily store sediment until a big storm. Then, 

sediment is flushed and routed to perennial streams lower in the watershed (Bilby et al. 1989).

Where and how routes are constructed and maintained makes a difference. Roads or trails 

constructed next to streams usually take away riparian habitat and alter ground water storage, 

which reduces the size and function of these places. Routes on steep or unstable slopes can lead to 

landslides that put a great deal of sediment into streams at once. Even maintaining roads can 

increase erosion in the short term by breaking up the armor that develops over time. Routes built 

on flat ground or having proper drainage features may cause little or no erosion and 

sedimentation.

The point where routes cross streams causes the most sedimentation because no vegetation exists 

to filter it (Swift 1985). Because crossings occur over or through water, they deliver sediment 

directly into streams (figure 45). At low water crossings, wheels going through streams kick up 

Figure 43. Without plant cover to stop it, 

rain or snowmelt carries soil down this 

eroded hillside directly into the stream
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 151

sediment, but this effect tends to be fleeting. The larger effect is from the road approach to the 

low water crossing (Taylor et al. 1999).

Figure 44. An example of how roads alter the patterns of 

runoff in a watershed. Water normally flows down a hill in a 

sheet. Here, the bar ditch adjacent to the road intercepts the 

water, concentrating it in one fast channel, which is 

downcutting and carrying sediment. From an engineering 

perspective, the bar ditch is doing its job: keeping water off 

the road. 

Figure 45. Route crossing where soil is carried directly into 

a stream because there is a lack of vegetation to help stop it
Chapter 3. Affected Environment and Environmental Consequences

152 FEIS for Travel Management on the Santa Fe National Forest

In summary, the existence of fewer roads, trails, and stream crossings in a watershed tends to 

result in better watershed condition.

How Driving Off Routes in Areas and Corridors Affects Soil and Water

Driving off routes across fresh ground causes soil to compact. This lowers the tracks relative to 

the adjacent ground. The lower surface then intercepts and drains water, channeling it and causing 

erosion and pooling in low sections (Meyer 2002). Drivers tend to avoid muck holes by driving 

around them, which widens the route and causes more of the same type of resource damage 

(figure 46). The compacted soil and loss of plant cover caused by driving off roads and trails 

leaves the soil vulnerable to erosion. Erosion, in turn, produces sediment that degrades water 

quality when it enters streams.

Figure 46. Photo illustrating the concept of braiding. When 

the main road is muddy, people drive to the left, widening 

the road. 

Riparian vegetation is critical for keeping streams healthy by filtering sediment and contaminants, 

stabilizing banks, reducing water temperature, moderating floods, supplying food for stream 

organisms, and contributing large woody debris for fish habitat (Obedzinski et al. 2001). 

People like to camp close to water. In the Santa Fe National Forest, they often drive their vehicles 

close to the water’s edge to set up camp (figure 47). The effects on riparian soils from vehicles 

includes compaction, destruction of soil organisms, increased erosion, and the physical alteration 

of riparian and aquatic habitats (Johnson and Carothers 1982). Motorized use degrades riparian 

areas by decreasing the ability of ground cover and canopy vegetation to grow (Johnson and 

Carothers 1982). This loss of riparian vegetation at campsites near water can increase stream 

temperature and sedimentation, both factors that can cause a stream to be listed as impaired. 

Recovery of vegetation on campsites close to water is generally slow due to the continual traffic 

during the growing season.

In summary, less motorized cross-country travel and less motorized use in riparian areas tends to 

result in better watershed condition.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 153

Affected Environment

Aquatic ecosystems, impaired streams, 

and soils are the factors that determine 

the relative health of soil and water 

resources.

Aquatic Ecosystems

Aquatic ecosystems are water-dependent 

systems centered around streams. 

Streams are classified as perennial, 

intermittent, or ephemeral:

Perennial stream – A stream that 

flows continuously or nearly so 

throughout the year.

Intermittent stream – A stream 

that flows, in its natural condition, 

only during certain times of the year 

or in intermittent years. Intermittent streams have areas with permanent surface water and 

aquatic flora and fauna adapted to these relatively harsh environmental conditions.

Ephemeral stream – A stream that flows only after precipitation in the immediate area.

The Santa Fe National Forest has approximately 5,570 miles of drainages. Of these, 

approximately 1,001 miles are perennial streams. The remaining 4,569 miles are composed of 

intermittent and ephemeral channels. Analyzing the effects of motorized use on ephemeral and 

intermittent channels is important because these headwater channels often temporarily retain 

sediment and then route it down to the mainstream perennial channels during high flow events.

Impaired Streams

Section 303(d) of the Clean Water Act (CWA) directs states to list streams with impaired water 

quality and develop strategies to control the nonpoint source pollutants causing their loss of 

beneficial uses. The analysis in this report uses the 2010–2012 State of New Mexico CWA 

§303d/§305(b) Integrated Report as its basis. The State lists approximately 347 miles of impaired 

streams in the forest boundary. As directed by the Clean Water Act, it is the forest’s responsibility 

to not further degrade impaired streams. 

Of the 1,001 miles of perennial streams in the forest, 262 miles (26 percent) are listed as impaired 

for temperature, turbidity, sediment, or a combination of these impairments with others. Because 

temperature, turbidity, and sediment are impairments that could be caused by motorized use, we 

only analyze these 262 miles. In addition to the existence of routes and motorized use, other 

forest activities can also contribute to these three impairments.

Soils

The “Terrestrial Ecosystem Survey of the Santa Fe National Forest” (TES) maps and describes 

the forest’s soils (USDA Forest Service 1993). It assigns “soil condition limitation ratings,” such 

Figure 47. Area where repeated camping and 

parking next to the stream has caused most of 

the riparian plants to die, resulting in bare ground 

and a muddy stream
Chapter 3. Affected Environment and Environmental Consequences

154 FEIS for Travel Management on the Santa Fe National Forest

as erosion hazard, to each soil type. The rating shows land managers the kinds of uses that could 

cause detrimental soil loss from that use.

Methodology and Measures

The changes proposed in each action alternative have the potential to influence the quality of 

aquatic ecosystems, impaired streams, and soils. The changes proposed reduce the places where 

people can drive roads, trails, areas, and fixed-distance corridors. The measures listed in this 

section serve as a proxy to show the magnitude of the effects from the changes. We calculated 

measures using GIS for the 123 sixth-field watersheds that the forest has at least 1 square mile of 

ownership in. The numbers derived for each measure are not considered absolute or conclusive; 

rather, they are viewed as relative and a means for comparing the effects of the alternatives by 

sixth-field watershed. 

Table 41 shows the measures used for each change proposed and the reason why. In the 

discussion that follows, the effects as measured for all 123 sixth-field watersheds are 

summarized. The tables containing the measures by individual watershed are found in the soil and 

water resources final report (USDA Forest Service 2012a).

Soil and Water – Environmental Consequences

Summary of Direct and Indirect Effects by Alternative

Of the five alternatives, alternative 2 is the most likely to sustain current soil and water quality 

conditions. The effects from constructed routes would stay the same, motorized cross-country use 

would be eliminated in all but two watersheds, and there would be little change to the acres 

available for motorized dispersed camping.

Alternative 3 is the most likely of the five alternatives to improve soil and water quality 

conditions. The current effects from constructed routes would stay the same, but motorized crosscountry use and motorized access to dispersed camping would be eliminated. 

Alternative 2M is the most likely to sustain current soil and water quality conditions, with the 

potential to improve over time. The current effects from constructed routes would stay the same, 

motorized cross-country use would be eliminated in all but one watershed, and there would be 

approximately a third fewer acres available near riparian areas for motorized dispersed camping.

Alternative 4 is the most likely of the five alternatives to decrease soil and water quality 

conditions. The current effects from constructed routes would stay the same and motorized crosscountry use would be eliminated in all but three watersheds. However, there would be over twice 

as many acres available for motorized dispersed camping.

Alternative 5 is also likely to sustain current soil and water quality conditions, with the potential 

to improve over time. The current effects from constructed routes would stay the same, motorized 

cross-country use would be eliminated in all but one watershed, and there would be 

approximately a third fewer acres available for motorized dispersed camping.
FEIS for Travel Management on the Santa Fe National Forest 155

Chapter 3. Affected Environment and Environmental Consequences

Table 41. Measures used as proxies for showing the effects of the proposed changes

Proposed Change 

Common to All 

Alternatives

Measures Used Reason

Reduce the miles of roads 

and trails open for driving

Total miles of roads and trails Routes alter the hydrology of watersheds by collecting and channeling runoff from storms.

Miles of routes within 300 feet of 

perennial and intermittent or 

ephemeral streams

Scientific literature suggests roads and trails close to streams are often primary sediment 

contributors (MacDonald and Stednick 2003). Routes constructed near streams pose a risk to 

water quality by increasing the amount of runoff, eroded material, and other pollutants 

transported to the stream. Being close to a stream means that there is less buffering between the 

route and the stream. Studies show that road related sediment can move as far as 300 feet via 

overland flow (Burroughs and King 1989, Belt, O’Laughlin and Merrill 1992).

Miles of routes within 300 feet of 

impaired streams

Same as above. All listed impaired streams are perennial.

Number of places where routes cross 

perennial and intermittent or 

ephemeral streams

Crossings efficiently deliver sediment directly into streams. Swift (1985) states, “The stream 

crossing is the most critical section of the road influencing water quality.” 

Open route density by watershed, 

expressed as miles per square mile

Open route density is the miles of roads and trails within a given area. Open route density signals 

the relative amount of runoff, erosion, modified hydrology, and water quality impacts. High route 

densities, for example, compound the effects of heavy rainfall by rerouting it and increasing the 

amount of sediment and pollutants deposited in streams (Gucinski et al. 2001, Trombulak and 

Frissell 2000, Furniss et al. 2000). Only routes on and land owned by the Santa Fe National 

Forest were used for the calculations. 

Reduce the area open for 

motorized cross-country 

use

Acres of areas Driving off road creates routes and compacts soil, which subsequently alters a watershed’s 

hydrology.

Acres of motorized cross-country use 

on soils having a “wheeled off-road 

vehicle limitation” rating of severe 

(USDA Forest Service 1993)

A rating of severe means that the risk of losing soil productivity from off-road vehicle use is high, 

and that any such use will result in significant site degradation. (USDA Forest Service 1993)

Acres of motorized cross-country use 

within 300 feet of perennial and 

intermittent or ephemeral streams

Scientific literature suggests roads and trails close to streams are often primary sediment 

contributors (MacDonald and Stednick 2003). Sediment is one of the causes of stream 

impairment.

Acres of motorized cross-country use 

within 300 feet of impaired streams

Same as above. All listed impaired streams are perennial.
Chapter 3. Affected Environment and Environmental Consequences

156 FEIS for Travel Management on the Santa Fe National Forest

Table 41. Measures used as proxies for showing the effects of the proposed changes

Proposed Change 

Common to All 

Alternatives

Measures Used Reason

Designate fixed-distance 

corridors for access to 

motorized dispersed 

camping

Acres of motorized dispersed camping 

corridors

Driving off road creates routes and compacts soil, which subsequently alters a watershed’s 

hydrology.

Acres of fixed-distance corridors for 

motorized access to dispersed 

camping on soils having an “erosion 

hazard” rating of moderate or severe 

(USDA Forest Service 1993)

Erosion hazard is the probability of soil loss when vegetation and litter is completely absent. A 

moderate rating means that a site’s productivity will decrease as a result of unchecked soil loss. A 

severe rating means that soil loss is likely to lower site productivity faster than mitigating 

measures can be applied (USDA FS 1993). Without measures to prevent it, topsoil loss will be 

faster than soil-forming processes can replace it.

Acres of fixed-distance corridors for 

motorized access to dispersed 

camping within 300 feet of perennial 

and intermittent or ephemeral streams

Motorized dispersed camping corridors near streams are likely to be a primary sediment 

contributor for the same reason that routes are.

Acres of fixed-distance corridors for 

motorized access to dispersed 

camping within 300 feet of impaired 

streams

Same as above. All listed impaired streams are perennial.

Acres of fixed-distance corridors for 

motorized access to dispersed 

camping within 100 feet of perennial 

streams

This indicator serves as a proxy for the acres of motorized dispersed camping corridors within 

riparian habitat. Forest Service Manual Section 2526.03, Riparian Management Policy, defines 

the riparian area as being at least 100 feet from the edges of streams, lakes, and other bodies of 

water. Riparian vegetation filters sediment and provides shade to streams. Removal of this 

vegetation due to motorized dispersed camping activities reduces the capability of the riparian 

habitat to function and, thus, jeopardizes water quality.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 157

Direct and Indirect Effects Common to All Alternatives

This section describes the effects to aquatic ecosystems, impaired streams, and soils from 

changing the motorized use on routes, areas, and in fixed-distance corridors.

Forest System Routes

Removing traffic from National Forest System roads and trails is not expected to change aquatic 

ecosystems, impaired streams, or soils from the existing condition within the 15 years this project 

analyzes. Table 42 predicts, at the forest level, no change in the existence of the footprints of 

roads and trails during that time. This means that the effects from the footprints of existing 

National Forest System roads and trails are the same for alternatives 2 through 5 as for alternative 

1 for the next 15 years. The only difference is that alternatives 2 through 5, by removing traffic 

from about half the National Forest System routes, allow for the possibility of natural 

revegetation or future route decommissioning. Table 42 shows the changes in the measures 

related to forest system routes.

It is unknown how well routes closed to public motorized use recover on their own without active 

restoration, how many routes’ current condition worsens from lack of maintenance, and what 

level of use occurs on the remaining open routes. Thus, for the purposes of this analysis, the 

condition of the designated and nondesignated routes on the landscape is assumed to stay equal to 

the current condition.

Table 42. Changes in the measures for forest system routes

Measure

Where People 

Drive Now

Action Alternative

1 2 2M 3 4 5

Routes within 300 feet 

of all streams, miles

1,766 819 785 624 951 827

Percent change from 

alternative 1

-54% -56% -65% -46% -53%

Routes within 300 feet 

of a perennial impaired 

stream, miles

64 35 31 32 38 37

Percent change from 

alternative 1

-45% -52% -49% -41% -43%

Number of stream 

crossings

7,254 3,026 2,912 2,215 3,567 3,101

Percent change from 

alternative 1

-58% -60% -69% -51% -57%

Open route density, 

miles per square mile

2 1.0 0.9 0.7 1.1 1.0

Percent change from 

alternative 1

-50% -55% -65% -45% -50%

The presence of roads and trails alters the natural hydrological patterns of a watershed. Even 

without motorized use, the impacts from roads and trails persist until the route is “disconnected” 

from the water source (Leung and Marion 1996). For the effects of roads and trails to entirely 
Chapter 3. Affected Environment and Environmental Consequences

158 FEIS for Travel Management on the Santa Fe National Forest

disappear, the routes would have to be restored to their natural slope (not have a “bench” that

serves to intercept and transport water) and be fully re-vegetated, having little or no bare ground. 

When some vegetation grows on routes, there is a corresponding improvement, but some effects 

to soil, water, and natural hydrological processes will continue until the route is returned 

completely to its original, natural state (figure 48).

Figure 48. Example of a National Forest System road on the 

Coyote Ranger District that has partially recovered, though bare 

ground is still present. Having some vegetation, however, is an 

improvement over having none. 

The footprint of engineered roads—those that the Forest Service intentionally builds or maintains, 

including its main roads and skid trails—last for a long time, and so do their effects to soil and 

water. (We discuss unauthorized routes in the section on “Areas,” below.) The reason for this is 

that route construction and maintenance compacts soil and removes organic material (replacing it 

instead with things like base course or gravel) so that they are drivable. Highly compacted soils 

without organic material are not conducive to plant growth (Elseroad et al. 2003). 

Removing traffic from engineered routes allows for the possibility of reclamation, either by 

natural revegetation or physical decommissioning. Whether plants will colonize an abandoned, 

engineered route depends on each route’s condition, soil type, and location. We expect the time it 

would take for plants to naturally revegetate on an engineered route would be longer than the 15 

years this analysis considers, and could be much longer (figure 49). This is because the tread is 

subject to the continuing erosional forces of rain, running water, wind, freezing and thawing, and 

gravity that keeps plants from establishing (Leung and Marion 1996). The soil compaction can 

persist for years before natural, soil loosening processes can restore the soil’s texture to a point 

where it supports vegetation.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 159

Figure 49. A National Forest System road that has been closed to 

use, but continues to erode. There is an erosion channel starting 

above the horse’s right ear and leading to the top of the photo. 

Routes closed to traffic won’t be maintained (assumption 14), and this means that some roads and 

trails with problems could continue to erode and deposit sediment into streams (figure 50).

Figure 50. A system trail that is incised, forming a channel through 

which water flows. As the water flows, it pulls more soil down with 

it. Even without motorized use, this system trail is not likely to 

revegetate on its own within 15 years. 
Chapter 3. Affected Environment and Environmental Consequences

160 FEIS for Travel Management on the Santa Fe National Forest

As stated in the “Recreation” section, most of the system routes proposed for closure in the action 

alternatives are for high-clearance vehicles, and are used infrequently now. Even with infrequent 

use, most still appear on the landscape, illustrating the principle that it takes a long time for 

engineered routes to naturally recover.

Some routes, in order to completely return to natural, would require the Forest Service to 

decommission them (figure 51). Closing them to motorized use is the first step, and it is likely 

that the forest would decommission some routes within the next 15 years. Sometimes, though, 

even physical decommissioning does not return a route back to a completely natural state.

Figure 51. Example of a route that the Forest Service physically 

decommissioned 

Unauthorized Routes

As is the case with the National Forest System routes, none of the action alternatives (2, 2M, 3, 4, 

or 5) would immediately affect the footprint of the unauthorized routes on the landscape. The 

processes and impacts just described also apply to the unauthorized routes. This means that the 

effects would continue much the same until route surface conditions change or physical 

restoration activities occur. Table 43 displays the measures related to the unauthorized routes 

proposed for addition to the forest transportation system. 

Stream Crossings

Removing traffic from stream crossings on National Forest System roads and trails is not 

expected to change aquatic ecosystems, impaired streams, or soil from the existing condition 

within the 15 years this project analyzes because it is the physical presence of the stream crossing 

that causes the biggest effect to soil and water quality (Taylor et al. 1999). Low water stream 

crossings are not likely to heal themselves because it is difficult for streambanks to rebuild 

themselves at crossings. Because this project would not remove or repair any bridges, culverts, or
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 161

low water crossings, the number would not change between alternatives and, therefore, effects

wouldn’t either. The table shows the changes in stream crossings that would be open to motorized 

use.

Table 43. Changes related to soil and water by adding unauthorized routes to the forest 

transportation system

Measure

Where People 

Drive Now

Action Alternative

1 2 2M 3 4 5

Routes within 300 feet 

of all streams, miles

157 40 37 15 59 46

Percent change from 

alternative 1

-74% -76% -91% -63% -71%

Routes within 300 feet 

of a perennial impaired 

stream, miles

11 3.9 3.5 2.4 4.5 4.2

Percent change from 

alternative 1

-65% -68% -78% -59% -61%

Number of stream 

crossings

694 164 175 60 248 199

Percent change from 

alternative 1

-76% -75% -91% -64% -71%

Direct and Indirect Effects by Alternative

Motorized Big Game Retrieval

Alternative 1

At the forestwide scale, the impacts to aquatic ecosystems, impaired streams, and soil from 

retrieving 438 big game animals with a vehicle on an annual basis are likely to be negligible. 

Taking up to four trips is not likely to compact soil to the point that permanent tracks remain, and 

hunters take animals in different places every year. Without repeated use, permanent tracks are 

not likely to form. Alternative 1, however, without a restriction of driving off roads, is the most 

likely to result in new permanent tracks because people tend to explore by driving on tracks 

others have made.

Alternatives 2, 4, and 5

Effects to aquatic ecosystems, impaired streams, and soils from motorized big game retrieval 

across the forest are expected to result in minimal impact at the sixth-field watershed scale. The 

alternatives could have impacts in specific locations if people drive on sensitive soils, through 

wet meadows or riparian areas, or ford streams to retrieve game. 

Alternative 2M

Effects to aquatic ecosystems, impaired streams, and soils from motorized big game retrieval 

across the forest are expected to result in very minimal impact at the sixth-field watershed scale. 

This alternative prevents motorized access in the designated corridors within 100 feet of water, so 

fording streams or driving in wet meadows or riparian areas would be prohibited. This means that 

even localized impacts would be less than alternatives 1, 2, 4, and 5.
Chapter 3. Affected Environment and Environmental Consequences

162 FEIS for Travel Management on the Santa Fe National Forest

Alternative 3

There is no motorized big game retrieval proposed for alternative 3, which means the impacts 

associated with motorized cross-country travel on aquatic ecosystems, impaired streams, and soils 

would be eliminated.

Areas

Table 44 shows that, for the action alternatives, the motorized cross-country use proposed is 

likely to remove most impacts relative to soil and water resources. This means their condition 

would stay the same or improve.

Table 44. Measures for motorized cross-country travel as they relate to soil and water 

resources

Measure

Where People 

Drive Now

Action Alternative

1 2 2M 3 4 5

Acres of motorized crosscountry use on soils with a 

wheeled off-road vehicle 

limitation rating of “severe”

220,848 13 13 0 14 13

Percent change from alt. 1 -100% -100% -100% -100% -100%

Acres of motorized crosscountry use within 300 feet of 

all streams 

99,014 5.1 5.7 0.0 6.1 5.1

Percent change from alt. 1 -100% -100% -100% -100% -100%

Acres of motorized crosscountry use within 300 feet of 

impaired streams (perennial)

2,563 0 0 0 0 0

Percent change from alt. 1 -100% -100% -100% -100% -100%

Alternative 1

Alternative 1 is the most likely to degrade aquatic ecosystems, impaired streams, and soils

because it would allow people to drive off routes on 53 percent of the forest. Currently, motorized 

cross-country use occurs in 113 of the 123 watersheds analyzed in this report. Approximately 50

percent of this use is on soils rated as “severe” for the category “Wheeled Off-Road Vehicle 

limitation.” This means that these soils have likely been impaired by cross-country use. Ouren 

(2007) states that, “The generally impervious nature of soils compacted by OHV traffic enhances 

gully formation, thus promoting additional flows of sediments and suspended solids into aquatic 

systems, effectively extending the drainage network of a given watershed.” Just over 20 percent

of the current motorized cross-country use takes place within 300 feet of streams. One positive, 

however, is that less that 1 percent of it takes place within 300 feet of streams impaired for 

temperature, turbidity, or sediment. 

Alternative 2, 2M, 3, 4, and 5

All of the alternatives considered in this analysis reduce motorized cross-country use to almost 

nothing. This means that effects to aquatic ecosystems, impaired streams, or soils would stay the 

same or improve, but not get worse.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 163

Alternative 3 eliminates it completely, while the other four alternatives isolate it to a few very 

small motorized use areas. All of the measures related to motorized cross-country use show 

drastic reductions. For instance, the number of acres located on soils having a “Wheeled OffRoad Vehicle limitation” rating of “severe” is reduced to less than 15 acres across all of the 

alternatives. The acres within 300 feet of streams impaired for temperature, turbidity, or sediment 

is reduced to zero for all alternatives.

The effects associated with past use—such as the two tracks that exist on the landscape now—are 

likely to continue for some time into the future. Removing motorized use in areas would allow 

the possibility of natural revegetation, but the subsidence associated with compaction may 

remain. Because the routes created by cross-country use are not engineered, however, they are 

more apt to naturally revegetate in a shorter period than constructed routes (figure 52). Some 

routes may begin revegetating within the 15 years considered in this analysis, but it isn’t likely 

they would completely recover in that time. Again, having some vegetation grow on the routes 

would incrementally reduce the erosion and sediment that degrade soil and water quality.

Figure 52. Area that used to be a two-track route to a livestock watering 

tank (the horse in the picture is standing at the livestock tank). It 

probably existed in 1987 when the forest plan was adopted, but it has 

since grown over. 

Motorized Dispersed Camping

Table 45 shows the measures for motorized access to dispersed camping as they relate to soil and 

water resources.
Chapter 3. Affected Environment and Environmental Consequences

164 FEIS for Travel Management on the Santa Fe National Forest

Alternative 1

The effects to aquatic ecosystems, impaired streams, and soils from motorized dispersed camping 

under alternative 1 is likely to remain the same or become worse over time because it keeps the 

existing opportunities in place and does not limit future expansion into new places unless closure 

orders are issued.

The majority of the watersheds where motorized access to dispersed camping currently occurs 

have much of this use on soils with an erosion hazard rating of “moderate” or “high,” and it 

occurs mainly within 300 feet of streams. This means that where motorized dispersed camping is 

happening now, there is a high probability of soil loss due to the removal of vegetation and litter,

and a high probability that these areas deliver sediment directly to streams (table 45, figure 53). 

The proximity of campsites and bare ground to water means that sediment doesn’t have far to 

travel before entering streams. 

Table 45. Changes in measures for motorized access to dispersed camping as they relate 

to soil and water resources

Measure

Where People 

Drive Now

Action Alternative

1 2 2M 3 4 5

Acres of motorized dispersed 

camping corridors on soils 

with an erosion hazard rating 

of moderate or severe

16,559 15,843 13,609 0 32,144 11,091

Percent change from alt. 1 -4% -18% -100% 94% -33%

Acres of motorized dispersed 

camping corridors within 300 

feet of all streams

6,006 5,350 4,241* 0 10,723 3,711

Percent change from alt. 1 -11% -29% -100% 79% -38%

Acres of motorized dispersed 

camping corridors within 300 

feet of impaired streams

(perennial)

354 262 195* 0 510 256

Percent change from alt. 1 -26% -45% -100% 44% -28%

Acres of motorized dispersed 

camping corridors within 100 

feet of riparian habitat

628 454 0 0 884 378

Percent change from alt. 1 -28% -100% -100% 41% -40%

*These values do not take into account the 100-foot setback from perennial water.

The majority of the watersheds have very few acres within 300 feet of an impaired stream. 

The majority of the watersheds have less than 15 percent of the existing motorized dispersed 

camping acres within 100 feet of riparian habitat. Some watersheds, however, have considerably 

higher acreages of dispersed camping corridors in riparian habitat. This is an important indicator 

because riparian vegetation filters sediment and provides shade to streams. Removal of this 

vegetation due to motorized dispersed camping activities reduces the capability of the riparian 

habitat to function and, thus, jeopardizes water quality.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 165

Figure 53. Example of where motorized dispersed camping 

has had detrimental effects on the riparian area. At this site 

along the Rio de las Vacas, motorized access to the 

dispersed campsite has compacted the soil and removed all 

vegetation. Motorized use goes all the way down to the 

streambank, and the riparian vegetation has been removed 

within the vicinity of the site. 

Effects Common to All Action Alternatives

The intensity of the effects of people’s activities on soil and water resources from camping under 

alternatives 2 through 5 would not change from alternative 1, the existing condition. None of the 

action alternatives prohibit or limit camping itself, only where vehicles are allowed. The effects 

of camping itself (aside from the vehicles), varies only by whether people would continue to 

camp in places that they could no longer drive to. 

Because camping itself is not expected to vary greatly, the rest of the effects analysis focuses on 

where vehicles would be allowed. Overall, experience of forest staff shows that having vehicles 

next to water causes more degradation of soil and water quality than does people’s activities 

while camping. For example, as part of the Respect the Rio Program, we built buck and pole 

fencing that allows people to camp next to water, but prevents them from driving close to the 

stream (figure 54). Without the presence of vehicles—but still having campers—riparian 

vegetation is returning (U.S. Environmental Protection Agency 2010). 

Alternative 2

Alternative 2 results in a 5.5 percent reduction in total acres of motorized dispersed camping 

corridors from the current use. This by itself is not enough to improve water and soil resources 

currently impacted by motorized dispersed camping corridors. There is, however, an 11 percent

reduction in acres available within 300 feet of all streams, a 26 percent reduction in acres 

available within 300 feet of streams impaired for temperature, turbidity, or sediment, and a 27

percent reduction in acres available in riparian habitat. 
Chapter 3. Affected Environment and Environmental Consequences

166 FEIS for Travel Management on the Santa Fe National Forest

Figure 54. This photo illustrates how, in alternative 2M or 3, people 

would not be able to drive their vehicles into their campsite. No 

bare ground is evident in the campsite, and the riparian vegetation 

in the middle right part of the photo is present.

Alternative 2M

Of the alternatives that propose fixed-distance corridors for motorized dispersed camping, 

alternative 2M is the best for soil and water resources. It eliminates vehicles in close proximity to 

streams or on riparian vegetation by not allowing motorized use within 100 feet of perennial 

water in areas or fixed-distance corridors. This would result in a 100 percent improvement in 

motorized dispersed camping corridors within riparian habitat. In practice, there would still be 

some motorized dispersed camping within riparian habitat because people would be able to pull 

off any road within 30 feet to park. It is difficult to know how much use within riparian habitat 

this would result in. Nonetheless, the effects caused by parking would likely be much less than 

currently occurs in riparian habitat. For example, keeping vehicles off the Rio Cebolla resulted in 

a positive change in riparian vegetation (U.S. Environmental Protection Agency 2010). 

Alternative 2M reduces the total acres available to drive and camp by 19 percent, acres on soils 

with an erosion hazard rating of moderate or severe by 18 percent, acres within 300 feet of all 

streams by 29 percent, and acres within 300 feet of impaired streams by 45 percent. 

Alternative 3

Alternative 3, because it proposes no driving off roads or trails for any reason, is the most likely 

to maintain or improve soil and water resources. The effects associated with past use, however, 

are likely to remain. Places currently compacted and devoid of vegetation would continue in that 

condition until, over time, natural processes or active restoration efforts took place. Removing 

motorized dispersed camping corridors in all watersheds would allow the timeframe to start on 

these natural processes. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 167

We expect that alternative 3 would also have fewer camping activities (not just fewer vehicles) 

because it allows no driving off roads, and some people are, therefore, likely to forego a camping 

trip entirely.

Alternative 4

Alternative 4 is the most likely to degrade soil and water resources by what it proposes for 

motorized dispersed camping. It proposes to increase access to motorized dispersed camping 

from what happens now to accommodate future use, or to allow people to spread out. Most of the 

new acreage proposed would be on soils with an erosion hazard rating of moderate or severe. 

Also, many of these new acres are located within 300 feet of streams. A high potential for soil 

loss and proximity to streams means that there is a higher probability that some of these sites 

would deliver sediment to stream systems.

Another concern is that much of the increase is in riparian habitat. As previously stated, this is 

important because riparian vegetation filters sediment and provides shade to streams. Removal or 

degradation of this vegetation due to motorized dispersed camping activities reduces the 

capability of the riparian habitat to function, thus jeopardizing water quality. 

Even though the number of motorized campers is expected to remain the same (assumption 19), it 

is expected that the increase in acreage in the motorized dispersed camping corridors would be 

used due to recreational displacement. Green (1998) states:

“Deterioration of recreational sites has negative impacts on the recreation 

experience. As a site becomes increasingly damaged, recreationalists might be 

displaced. Recreation displacement is defined as a change in recreational 

behavior in response to changes in the recreational environment. Displacement of 

recreation to other less damaged areas might increase the real extent of damage.”

Alternative 5

In alternative 5, many of the watersheds having a reduction of total acres for motorized dispersed 

camping corridors see a corresponding reduction in acres located on soils with an erosion hazard 

rated as moderate or high, and those within 300 feet of streams. This should reduce the amount of 

sediment delivered to streams. The total acreage of motorized dispersed camping corridors in 

riparian habitat would be reduced by 40 percent. These reductions would help improve conditions 

in riparian habitat which, in turn, would help improve water quality over time.

Cumulative Effects, All Alternatives

Summary

Although some programs and activities may have local, negative effects on soil and water 

resources, the cumulative effect of past, present, and reasonably foreseeable programs and 

activities, including the reduction of open, motorized roads and trails and motorized cross-country 

travel through designation under the Travel Management Rule, are generally beneficial. Forest 

staff will continue to target degraded locations for restoration.

Activities considered in this cumulative effects analysis include those directly and indirectly 

modifying soil and water resources.
Chapter 3. Affected Environment and Environmental Consequences

168 FEIS for Travel Management on the Santa Fe National Forest

Past and Present Actions (1987–2011)

Some activities have had little effect on soil and water resources. Examples of activities which, 

when carried out consistently with existing regulations and best management practices, produce 

negligible cumulative effects to soil and water resources include:

• Forest product collection

• Special uses and other administrative use

• Noxious weed management

Other activities, including wildfire, livestock grazing, recreation management, road management, 

and prescribed fire, have the potential to create cumulative effects.

• Wildfire - Wildfires tend to increase sediment delivery for 10 years or more. The size, 

location, and severity of the fire affects the land’s rate of recovery. Severe burns consume 

duff and cause physical damage to the surface layers of soil. Rates of sediment delivery 

from past fires vary from gully cutting, to bedrock and debris flows, to virtually no 

erosion on low severity fires. 

Roads and trails may compound the effects of fire. Roads and trails concentrate upslope 

flow and deliver it to streams. On severely burned landscapes, water from high intensity 

storms concentrates on roads and trails and runs downslope. Soils made bare from a fire 

can erode greatly due to the concentrated water (figure 55).

Figure 55. The Las Conchas Fire burned intensely uphill of this road, 

removing all vegetation and litter. After a storm, the runoff collected 

debris and impacted this road.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 169

Many burned areas from older fires have sufficiently healed to the point they are no 

longer affecting soil and water resources on a watershed scale. The more recent fires 

including Bear Paw, Tecolote, South Fork, Pacheco, and Las Conchas will continue to 

have negative impacts on soil and water resources for a considerable amount of time.

• Livestock Grazing - Cattle grazing has occurred in the forest for hundreds of years. The 

upland effects of livestock grazing are usually restricted to small areas around water 

developments, salt locations, and where cattle trail from one location to the next. The 

soils in these places tend to be compacted and bare, which renders them more susceptible 

to erosion. Grazing along streams and within riparian areas occurs in many of the forest’s 

allotments (figure 56). This may affect water quality by increasing fine sediments 

delivered to streams, reducing shade along streambanks, and altering riparian habitat. 

These effects are not universal, but they are distributed throughout the analysis area. 

Figure 56. An example of livestock grazing in riparian areas in the 

forest

Livestock grazing occurs along many of the impaired stream miles—those impaired for 

temperature, turbidity, or sediment—that are also affected by motorized use. Thus, 

reducing the component caused by motorized use should result in a cumulatively 

beneficial effect.

• Recreation Management - Multiple decisions, such as the Jemez National Recreation 

Act, establishment of three wild and scenic rivers in the forest, reconstruction of 

recreational facilities, and implementation of Respect the Rio, have decreased the impacts 

recreational use can have on soil and water resources. These management actions better 

direct recreational activities away from sensitive areas like riparian habitat. 

• Road Management - Road management in the forest encompasses maintenance, closure, 

and decommissioning. Budgets for road maintenance have declined compared to the past. 

Lack of maintenance leads to rutting, loss of surfacing, erosion, and sedimentation. 
Chapter 3. Affected Environment and Environmental Consequences

170 FEIS for Travel Management on the Santa Fe National Forest

Lack of maintenance affects closed roads as well. Closed roads aren’t maintained, and 

simply closing a road to use doesn’t necessarily eliminate hydrologic impacts. The 

disturbed road surface takes years to stabilize. Closed roads may continue to produce 

sediment until they are fully revegetated, which often takes a long time due to the forest’s 

soils and climate. 

Road decommissioning stabilizes and restores unneeded roads to a natural state. Because 

of imprecise tracking, it is difficult to know how many miles of forest system roads have 

been physically decommissioned in the past. 

• Prescribed Fire - Thousands of acres in the forest have been treated with prescribed fire. 

Prescribed fire sometimes has detrimental impacts to soil when burn severities are too 

high. The majority of prescribed fires, however, are designed to minimize severe burning 

of soils, which minimizes the risk of impacts to water quality. 

Reasonably foreseeable actions include reauthorizing livestock grazing permits, treating 

vegetation mechanically and with prescribed fire, improving and maintaining roads and trails, 

improving riparian and wildlife habitat, mining for oil and gas, pumice, and possibly geothermal. 

All will undergo NEPA analysis, where their effects on soil and water resources will be analyzed. 

If negative effects are expected, best management practices will be established to prevent or 

diminish the effects. 

Effects of Forest Plan Amendments on Soil and Water

Proposed Amendments in Table 66 of Appendix 1

The proposed amendments that are administrative in nature are not expected to have effects to 

soil and water resources as a result of this or future projects. These proposed amendments, for the 

most part, simply update and provide consistent direction for application of the MVUM. 

The proposed amendments that alter off-highway vehicle use within specific management areas 

have no effect because they keep direction for adding that use consistent with the intent as per the 

current plan and the travel management regulations. Management areas where cross-country 

travel has been allowed (Management Areas A, B, E, G, P, Q, R, and S) have no plan amendment 

changes that restrict the addition of this type of use through designation of areas or corridors in 

the future. Management areas where cross-country travel was limited (Management Areas C, D, I, 

J, K, M, and N) have plan amendment changes that continue to limit the addition of areas and 

corridors except when consistent with management emphasis for the area. Therefore, none of 

these amendments are expected to decrease soil productivity, increase erosion, or further 

contribute sediment to streams because the proposed changes continue motorized use that is 

consistent with the travel management regulations and management emphases for the areas.

The proposed amendment to the Jemez National Recreation Area (Management Area X) restricts 

the ability of motorized vehicles to pull off roads in JNRA - A areas (as per the travel area map, 

equal to 15,445 acres) to only where motorized dispersed camping or motorized big game 

retrieval corridors are specifically designated. This amendment will be a benefit to soil and water 

resources as it will likely limit the amount of future motorized use off of roads in parts of the 

JNRA. This limitation would decrease the amount of area that could experience soil compaction 

and erosion caused by off-road motorized vehicle use. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 171

Proposed Amendments in Table 67 of Appendix 1

Most of the amendments in this table propose to allow the inclusion of motorized dispersed 

camping corridors and/or motorized big game retrieval corridors in the wild and scenic river areas 

(East Fork Jemez, Rio Chama, and Pecos) and the Jemez National Recreation Area, where these 

uses are currently prohibited. These amendments apply to alternatives 4 and 5 only. These 

amendments may have an impact on soil and water resources as this type of use can lead to 

further degradation of soil and water resources through erosion and sedimentation into streams 

and rivers. These specially designated areas currently prohibit or limit motorized use associated 

with areas, motorized dispersed camping, and/or motorized big game retrieval, whereas the 

proposed amendments allow for the potential expansion of these motorized uses through future 

designations. This may lead to direct and indirect effects to soil and water resources. Impacts 

from motorized use can include modifications to the soil’s physical, chemical, and biological 

characteristics. Motorized use can also adversely affect water quality and alter riparian health and 

vigor. 

The effects of amendments to allow for motorized use on specifically identified routes (in 

Management Areas H and L for varying alternatives) would be identical to the direct, indirect, 

and cumulative effects presented in this report because they relate to a specific road as proposed 

and analyzed for each of the specific alternatives.

Consistency with the Forest Plan and Legal Requirements

Appendix 3 contains a detailed analysis of each alternative’s consistency with the “Santa Fe 

National Forest Plan” and other laws. In sum, alternative 4 is the least likely to move the soil and 

water resource toward a desired condition, and alternative 3 is the most likely to. Alternatives 2M 

and 5 are expected to maintain or improve current conditions. Alternative 2 would maintain 

current conditions.

Fisheries

Some people raised the issue that continued motorized use of the Santa Fe National Forest would 

impair habitat for fish. This section, which summarizes the fisheries specialist report (USDA 

Forest Service 2012-l), analyzes the effects to threatened, endangered, sensitive, management 

indicator, and native fish species.

Table 46. Fish in the Santa Fe National Forest having special management status

Species Management Status

Rio Grande cutthroat trout Management indicator and Regional Forester’s sensitive species

Rio Grande silvery minnow Endangered species

Rio Grande chub Regional Forester’s sensitive species

Rio Grande sucker Regional Forester’s sensitive species

Effects of Routes and Motorized Use on Fish Habitat

The issue related to routes, the use of vehicles, and fish habitat is sediment. Sediment is soil, 

usually carried by water that gets into streams. When excessive sediment gets into streams, it 

does a number of things that degrade fish habitat. Sediment changes the shape of the stream, 
Chapter 3. Affected Environment and Environmental Consequences

172 FEIS for Travel Management on the Santa Fe National Forest

either widening it so it’s shallow and warm, or causing it to become a fast, straight channel. 

Neither is suitable for fish to live in. Fine sediment covers up pebbles and rocks that fish lay their 

eggs in, reducing their chance of reproductive success. Sediment also hides food sources for fish, 

making it harder for them to survive and compete with other fish, especially nonnative species.

Here’s how motorized use directly and indirectly increases the chance for sediment to reach 

streams:

A route’s footprint. Much research exists showing that roads and trails increase erosion and 

sediment delivery to streams (Gucinski et al. 2001). Driving on unpaved routes disturbs soils 

and increases the potential for erosion and sediment delivery to streams (Furniss et al. 1991).

Roads and trails act like funnels that deliver sediment to streams. When it rains (or during 

snowmelt), water flows across a slope until it reaches a road or trail. Once it’s on the route, 

water follows the route downhill, collecting sediment as it goes. In the forest, many dirt 

routes cross streams. When the sediment filled water reaches the stream, all the water and 

sediment is deposited into the stream.

Routes that are close to streams tend to contribute the most sediment because it doesn’t have 

far to travel. Vegetation acts like a filter and catches sediment. If little or no vegetation is 

present, then the chance of sediment getting into the stream is greater. If routes have 

sufficient drainage, water can be diverted before it reaches streams (figure 57) (Furniss et al. 

1991). This helps keep sediment out of streams.

Figure 57. Example of a ditch that carries water off the road, so it 

prevents sediment from being carried to streams

Roads and trails also pose barriers to migration, increase water temperature by decreasing 

vegetation and slowing the flow of water, and altering the stream’s natural shape and 

movement. Improperly placed culverts at stream crossings can reduce or eliminate fish 

passage (Belford and Gould 1989). One study documented a positive correlation between the 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 173

number of culverts and stream crossings and amount of fine sediment in stream channels, and 

a negative correlation with fish density and numbers of culverts in the Medicine Bow 

National Forest (Eaglin and Hubert 1993).

People’s activities near water. Routes are conduits for people, and people’s activities 

sometimes contribute to poor fish habitat. When people camp near water, they tend to use 

large pieces of wood for things like campfires and makeshift benches. These large pieces 

never make it into the stream as “large woody debris.” Fish use large woody debris for cover. 

They feed on the insects that colonize large woody debris. These large pieces of wood create 

habitat when the water rushes over and around them and scours out new habitats. Camping 

often causes the ground to become bare, exposing soil that is then free to move into the 

adjacent stream. Vegetation on the ground acts like a filter and catches sediment before it hits 

streams. Without vegetation, there is nothing to stop it. Unintentionally, people may pollute 

streams with food, dripping oil from cars, or other things.

Driving off roads. Driving off roads and trails causes the soil under tires to compact. Plants 

have a hard time growing in compacted soil. Without plants, soil is easily mobilized into 

wetlands and streams via runoff. With repeated use, these areas of compaction may become 

channels that transport water and sediment to streams. Sometimes, two tracks become 

unauthorized routes. Poorly placed unauthorized routes often direct sediment to streams.

Routes that cross streams. In general, low water crossings don’t block fish passage. 

Culverts do, however, if they are perched, undersized, or too long. Having more crossings 

increases the potential for having one or more that pose a barrier to fish movement. This 

reduces genetic variation by promoting inbreeding. Stream crossings make isolated 

populations more vulnerable to extirpation by extreme events such as mass wasting or ash 

flow. They have high amounts of fine sediments that cover food sources and habitat. Driving 

through streams disturbs soils and increases the potential for erosion and sediment in streams. 

It directly impacts habitat for fish and their prey by disturbing riffle spawning and feeding 

habitats.

Methods

As just shown, roads, trails, areas, and fixed-distance corridors can degrade fish habitat. 

Depending on the species analyzed, we use one or more of the following measures as a proxy for 

effects to fish habitat: 

• The miles of open, motorized roads and trails within 300 feet of streams occupied by the 

species analyzed.

• The acres of land available for motorized dispersed camping and motorized cross-country 

travel (“areas”) within 300 feet of streams occupied by the species analyzed. 

• The number of stream crossings for open, motorized roads and trails on fish-bearing 

streams.

• Combined open road and motorized trail densities in watersheds (10-digit Hydrologic 

Unit Code) that are source to the Middle Rio Grande designated critical habitat for Rio 

Grande silvery minnow. 

Studies show that roads have the highest potential to contribute sediment over the long term in 

forested watersheds (Megahan and Kidd 1972; Rice, Rothacher and Megahan 1972). Additional 
Chapter 3. Affected Environment and Environmental Consequences

174 FEIS for Travel Management on the Santa Fe National Forest

studies show that road related sediment can move as far as 300 feet via overland flow (Burroughs 

and King 1989, Belt, O’Laughlin and Merrill, 1992). Based on this information, a buffer distance 

of 300 feet was selected for examining road and motorized cross-country trails adjacent to 

streams occupied by fish, as sediment is one of the key threats to habitat quality.

The U.S. Fish and Wildlife Service and National Oceanic and Atmospheric Administration’s 

National Marine Fisheries use route density to measure watershed condition as it relates to fish 

habitat. The agencies jointly recommend that a given watershed should have less than 2.5 mi/mi2 

of roads. While this is not a standard for New Mexico and Arizona, the Forest Service’s 

Southwestern Rgional Office used it to display effects to aquatic species in the “Biological 

Assessment for the Eleven Land and Resource Management Plans of the National Forests and 

National Grasslands in the USDA Forest Service Southwestern Region.” In keeping with this 

analyses and the resulting §7 consultation, we use the route density threshold of 2.5 miles per 

square mile to display the potential effects of each of the travel management alternatives on Rio 

Grande silvery minnow.

Threatened and Endangered Fish Species

The Rio Grande cutthroat trout, a candidate species, is analyzed in the section “Management 

Indicator Species” that follows.

Rio Grande Silvery Minnow – Affected Environment

The Rio Grande silvery minnow (Hybognathus amarus) is listed as an endangered species. 

Historically, it was one of the most widespread and abundant fishes in New Mexico. Today, its 

habitat is about 7 percent of its former range. The silvery minnow appears to live only in a 163-

mile reach of the Rio Grande from around Cochiti Dam downstream to Elephant Butte Reservoir, 

and a 2.8-mile stretch of the Lower Jemez River between the Jemez Canyon Dam and its 

confluence with the Rio Grande (U.S. Fish and Wildlife Service 2007). No silvery minnows have 

been found on the Santa Fe National 

Forest.

In 2002 and 2003, the United States 

Fish and Wildlife Service identified 

critical habitat for the Rio Grande 

silvery minnow between Cochiti Dam 

and Elephant Butte Reservoir (U.S.

Fish and Wildlife Service 2003). The 

Santa Fe National Forest does not 

manage lands designated as critical 

habitat. It does, however, manage 

three watersheds that feed the middle 

Rio Grande where critical habitat and 

the silvery minnow exist. Thus, we

look at how the alternatives might 

protect these watersheds and prevent 

them from contributing adverse effects 

downstream.

Figure 58. A Rio Grande silvery minnow (Photo 

Aimee Roberson, Courtesy of U.S. Fish and Wildlife 

Service)
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 175

To measure the effects of closing parts of the forest to motorized use, we use the density of open 

roads and motorized trails in watersheds that are source to the middle Rio Grande designated 

habitat.

Rio Grande Silvery Minnow – Environmental Consequences

Direct and Indirect Effects Common to All Alternatives

There would be no direct effects to Rio Grande silvery minnow under any alternative because the 

species is extirpated from the forest. Additionally, the Santa Fe National Forest does not manage 

lands within the area designated as critical habitat. For indirect effects, alternatives 2M and 3 

have a determination of no effect because of the restriction of not driving within 100 feet of 

water, or off-road, respectively. Not having vehicles near water nearly eliminates the indirect 

effects of sedimentation during heavy rains. Alternatives 2, 4, and 5 have the determination of 

may affect, not likely to adversely affect because vehicles would still be allowed to drive near 

water in these alternatives.

Indirect Effects, Alternative 1

Alternative 1 would have an effects determination of “may affect, not likely to adversely affect”

for the Rio Grande silvery minnow and its critical habitat. “May affect, not likely to adversely 

affect” is one category that is assigned during consultation with the U.S. Fish and Wildlife 

Service about effects to species classified as threatened or endangered under the Endangered 

Species Act. While there could be adverse effects to the watershed from localized road or trail 

erosion, the route density of two Forest Service watersheds feeding into critical habitat for the Rio 

Grande silvery minnow is well below the agency recommendation, and in the headwaters of

Galisteo Creek, the route density is slightly over agency recommendations (3.0 mi/mi2

; table 47). 

Vehicle use, however, on Forest Service roads and trails here occurs many miles from Rio Grande 

silvery minnow occupied habitat, and is connected only by intermittent flows. Conchas and other 

reservoirs serve as a sink for sediment that could negatively affect silvery minnows. As a result, 

effects should be absent or so small as to be undetectable.

The action alternatives propose to add short segments of unauthorized routes in each watershed. 

Adding these segments will help ensure that they are brought up to standard, if needed, thereby 

minimizing potential impacts.

Table 47. Comparison of open route density, by alternative, in watersheds that feed critical 

habitat for the Rio Grande silvery minnow. Watershed area and route miles are tabulated 

for the portion of the watershed within the forest boundary only.

Watershed

Alternative

1 2 2M 3 4 5

Canada Ancha - Rio Grande 2.2 1.1 1.0 0.7 1.4 0.9

Headwaters Galisteo Creek 3.2 1.2 1.1 0.9 1.5 1.2

Arroyo Tonque - Rio Grande 2.1 0.9 0.8 0.2 1.0 1.1

All action alternatives improve upon the current condition by reducing the miles of roads and 

trails open to vehicular traffic. Some will revegetate naturally and others won’t. Those that do 

will lessen the amount of sediment that reaches streams.
Chapter 3. Affected Environment and Environmental Consequences

176 FEIS for Travel Management on the Santa Fe National Forest

Sensitive Species – Affected Environment

The Rio Grande chub (Gila pandora), Rio Grande sucker (Catostomus plebeius), and Rio Grande 

cutthroat trout (Oncorhynchus clarki virginalis) are on the Regional Forester’s sensitive species 

list. In the National Forest System, a sensitive species is a species for which population viability 

is a concern due to a current or predicted downward trend in population numbers or in habitat 

capability. The Rio Grande cutthroat trout is also a candidate species for the endangered species 

list and a management indicator species.

Because excessive fine sediment degrades the habitats of Rio Grande cutthroat trout, chub, and 

sucker, and because roads and trails are a source of sediment, we use the miles of routes and acres 

of land used by vehicles as a proxy for the effects to these fish species. The streams in which the 

Rio Grande cutthroat trout, chub, and sucker live vary in their quality for fish habitat from poor to 

excellent. The fisheries specialist report describes each species’ life history in detail.

Rio Grande Cutthroat Trout

The habitat and quantitative analysis for Rio Grande cutthroat trout is described in the 

“Management Indicator Species” section. Because it is also a sensitive species, the effects 

determinations for it in this section are inclusive of the Rio Grande cutthroat trout.

Rio Grande Chub

On the Santa Fe National Forest, habitat for Rio Grande chub occurs in several streams of the 

Jemez, Rio Chama, Rio Grande, Cañones, Rio Puerco, and Gallina watersheds. Approximately 

250 miles of 12 streams within or proximate to the forest are currently known to be occupied by 

the species.

Rio Grande Sucker

On the Santa Fe National Forest, habitat for Rio Grande sucker occurs in several streams of the 

Jemez, Rio Chama, Rio Grande, Cañones, Rio Puerco, and Gallina watersheds. Approximately 

299 miles of 18 streams within or proximate to the forest are currently known to be occupied by 

the species.

Sensitive Species – Environmental Consequences

Direct and Indirect Effects, Alternative 1

Alternative 1 is not likely to result in a trend toward Federal listing or a loss of species viability. 

Though it has the most motorized use of the alternatives, the amount of occupied habitat 

potentially impacted by these roads and trails is relatively small, around 10 percent for the chub 

and sucker, and about 24 percent for the trout. 

The effects to sensitive fish from motorized use described would continue at their present rate. 

This means that routes, driving cross-country, and people would contribute to habitat degradation 

in some locations. Other locations would remain inaccessible to people and vehicles and not 

change. The motorized use in alternative 1 is not likely to greatly improve the conditions of 

streams—they would remain the same or get worse.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 177

Direct and Indirect Effects, Alternatives 2 Through 5

Alternatives 2 through 5 are not likely to result in a trend toward Federal listing or a loss of 

species viability—though they may impact individuals—because they improve on the current 

condition. All reduce the places where people could drive near streams, especially the number of 

stream crossings open to motorized use and motorized travel off roads (table 48). Having less 

motorized use near streams reduces the potential for sediment to get to a stream or be stirred up in 

it, which in turn improves habitat by keeping water clear and not changing the stream’s channel.

Table 48. Comparison of the amount of motorized use near streams by alternative

Species Within 300 Feet of Stream 

Occupied by Sensitive Fish

Alternative

1 2 2M 3 4 5

Rio 

Grande 

chub

Miles of routes 31 24 23 22 25 24

Miles of corridors for camping 

(DC) or game retrieval (G)

12 

(DC)

8 

(DC, G)

4

(DC, G) 0 8 (DC) 

23 (G) 8 (DC)

Acres of areas 1,948 0 0 0 0 0

Number of stream crossings 37 20 17 19 28 26

Rio 

Grande 

sucker

Miles of routes 42 28 26 27 29 28

Miles of corridors for camping 

(DC) or game retrieval (G)

13 

(DC)

9 

(DC, G)

4

(DC, G) 0 9 (DC) 

28 (G) 9 (DC)

Acres of areas 2,147 0 0 0 0 0

Number of stream crossings 69 26 23 25 34 32

Reducing the places where people can drive in the forest would allow some routes to revegetate 

naturally over time; others would not (refer to the “Soil and Water” section for a description of 

the time and likelihood of routes and areas regenerating). Routes on steep slopes are likely to 

continue contributing sediment until they are decommissioned. 

Vegetation along streambanks is most likely to recover under alternatives 2M and 3 because they 

do not allow driving off roads or trails near perennial water. This restriction would effectively 

eliminate much of the impact associated with motorized dispersed camping near streams within 

300 feet of occupied Rio Grande chub and Rio Grande sucker habitats. Having less motorized use 

near streams reduces the potential for sedimentation in streams, which in turn improves habitat by 

keeping water clear and not changing the stream channel morphology. For alternatives 2, 4, and 5, 

motorized use near streams (especially for camping) would not be entirely eliminated, neither 

would the detrimental effects to habitat associated with it; though there would be an improvement 

when compared to alternative 1. 

Limiting camping to fixed-distance corridors is likely to cause an increase in new hardened sites 

since people won’t be able to spread out as much as they do now (assumption 21). As described, 

this tends to cause a downward trend in habitat condition.

Management Indicator Species – Affected Environment

The Rio Grande cutthroat trout is a management indicator species, and as such, it represents a 

larger group of fish species presumed to share the same habitat requirements. Rio Grande 

cutthroat trout is also a sensitive species and a candidate to the endangered species list.
Chapter 3. Affected Environment and Environmental Consequences

178 FEIS for Travel Management on the Santa Fe National Forest

The Rio Grande cutthroat trout represents the quality of aquatic habitat on the Santa Fe National 

Forest. We manage 1,072 miles of perennial streams. Of these, Rio Grande cutthroat trout lived in 

approximately 965 miles before 1896, when streams were first stocked with nonnative fish

(Sublette et al. 1990). Data collected in March 2008 by the New Mexico Department of Game 

and Fish and the Santa Fe National Forest identified 44 streams totaling 141 miles as having Rio 

Grande cutthroat trout. Of these, 47 miles are considered secure, meaning they aren’t invaded by 

nonnative fish.

Habitat for the Rio Grande cutthroat trout varies in quality according to a qualitative ranking 

based on a matrix of variables outlined in the USFS Region 3 Stream Inventory protocol (USDA 

Forest Service 2005). At higher elevations, where recreation and grazing is limited by topography 

and restrictions associated with wilderness, stream quality is moderate to excellent. At lower 

elevations used more by people, habitat tends to be poor. Poor habitat conditions are caused by a 

lack of instream large woody debris, sediment filled pools, loss of undercut banks, depletion of 

beaver populations, lack of side channel development, and poor riparian health. Decreased water 

quality can be attributed to soil compaction, road and trail runoff, unstable banks, and delivery of 

pollutants from nonpoint sources. Motorized use close to streams tends to cause sedimentation, 

which degrades fish habitat.

As discussed, roads and trails increase sediment delivery to streams. How sediment affects trout 

varies by the fish’s life stage and the quality and quantity of its habitat. Adults typically prefer 

pools, whereas juveniles use pools, runs, and riffles. When the amount of sediment exceeds the 

habitat’s capacity to absorb it, streams become more wide than deep. This increases the water 

temperature to the trout’s detriment. Incubating eggs require clean spawning gravels; when fine 

sediments increase in spawning gravels, it lessens the fish’s chance for survival (Bjornn and 

Reiser 1991, Hicks et al. 1991).

Management Indicator Species – Environmental Consequences 

Direct and Indirect Effects, Alternative 1

Alternative 1 is not likely to result in a trend toward Federal listing or a loss of species viability. 

Though it has the most motorized use of the alternatives and the most miles of motorized routes 

within 300 feet of occupied Rio Grande cutthroat streams, the number of occupied stream 

systems (and populations) potentially impacted by these roads and trails is relatively small. Many 

of the occupied systems are located within designated wilderness or high elevation systems with 

limited access. Nonetheless, the 41 miles of motorized roads and trails that run within 300 feet of 

occupied Rio Grande cutthroat cross occupied streams 105 times. As shown, this tends to degrade 

fish habitat and ability to survive.

The effects to fish from motorized use described would continue at their present rate. Of 

particular concern are some routes that cross and parallel streams occupied by the Rio Grande 

cutthroat trout, such as one off Forest Road 422 which crosses Polvadera Creek several times and 

has trail segments that run up the streambed itself (figure 59). The 2010 South Fork Fire burned 

much of Polvadera Creek’s headwaters. Excessive erosion and ash flow during the 2010 monsoon 

season eliminated much of the fishery and the trail. However, Rio Grande cutthroat trout 

managed to survive in the upper reach, and the stream is still considered to be “occupied.”

Keeping motorized use here has the potential to degrade habitat.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 179

Polvadera Creek is home to one of 

the forest’s “core conservation” 

populations of Rio Grande 

cutthroat trout, meaning this 

population’s genetic purity is 

greater than 99 percent and is 

deemed the “the highest priority 

for long range conservation 

management” by the New Mexico 

Department of Game and Fish.

Unfortunately, a number of 

stressors, including the trail, have 

combined to create a stream in 

which riffle sediment content, 

pool development, and pool 

quality are not properly 

functioning. In addition, 

heightened stream temperatures 

led to Polvadera Creek being listed as impaired because it is not meeting the designated use set by 

the New Mexico Environment Department as a high quality cold-water fishery.

Direct and Indirect Effects, Alternatives 2 Through 5

Alternatives 2 through 5 are not likely to result in a trend toward Federal listing or a loss of 

species viability because they improve on the current condition, though individual Rio Grande 

cutthroat trout may be negatively impacted. All reduce the places near streams where people 

could drive, especially the number of stream crossings open to motorized use and motorized 

travel off roads (table 49). Having less motorized use near streams reduces the potential for 

sediment to get to a stream or be stirred up in it, which in turn improves habitat by keeping water 

clear and not changing the stream’s channel. This improves fish habitat, which could potentially 

promote the species.

Alternatives 2, 2M, and 3 don’t propose the trail in Polvadera Creek, so these would be better at 

protecting this core population of Rio Grande cutthroat trout. Alternatives 4 and 5 would retain 

the motorized trail through Polvadera Creek, with the restriction that this trail would only be open 

seasonally. Under alternatives 4 and 5, the habitat disturbance caused by wheels in the stream is 

lessened, but still present. The trail through Polvadera Creek contains known low water crossings. 

Though the direct effects of operating motorized vehicles across and in an occupied stream are 

reduced from the existing condition through the seasonal restriction and through the restriction of 

motorcycles only, the impacts would still be evident. Wheels through streams disturb soils and 

increase the potential for erosion and sediment transport and deposition in streams. In addition, 

the motorized use would be allowed during spawning season, so potential impacts include an 

increase in fine sediment spawning gravels, which is linked to a decrease in fry emergence and 

juvenile fish densities. Alternatives 2, 2M, and 3, would have no known low water crossings.

Figure 59. Example of trail segment running up a 

streambed
Chapter 3. Affected Environment and Environmental Consequences

180 FEIS for Travel Management on the Santa Fe National Forest

Table 49. Comparison of motorized use within 300 feet of streams occupied by Rio Grande 

cutthroat trout

Within 300 Feet of Stream 

Occupied by Rio Grande Cutthroat 

Trout (RGCT)

Alternative

1 2 2M 3 4 5

Total miles of routes Roads 24 7 7 6 7 6

Trails 17 0.1 0.1 0 4 2

Miles of unauthorized 

routes only

Roads 2 0.7 0.8 0.5 0.7 0.7

Trails 3 0.1 0.1 0.1 0.5 0.5

Miles of corridors for dispersed camping 

(DC) or game retrieval (G) 0.3 0.3 

(DC, G)

0.3 

(DC, G) 0 0.3 (DC) 

13 (G)

0.2 (DC)

0.3 (G)

Acres of areas 1,280 0 0 0 0

Number of stream crossings (RGCT 

occupied) 105 29 29 28 39 37

All action alternatives improve upon the current condition by reducing the miles of roads and 

trails open to driving and by nearly eliminating motorized cross-country travel. Prohibiting use of 

most unauthorized routes, because they are often not constructed in a manner that minimizes 

sediment delivery to streams or receive routine maintenance, is also expected to reduce sediment 

delivery. As discussed in the “Soil and Water” section of this chapter, the degree to which closed 

routes will recover on their own or worsen over time is unknown, so it is assumed the same as the 

existing condition. 

For alternatives 2, 4, and 5, people could drive through wetlands, riparian areas, and across 

streams inhabited by fish when retrieving big game. This would increase the risk of sedimentation 

of key instream habitats. The potential impact is limited to the number of big game animals 

retrieved, which averages 438 per year, and some probably wouldn’t need to cross streams. 

Because retrieving game is limited to hunting season and to the edge of a corridor, it reduces the 

effects as compared to alternative 1. Alternatives 2M and 3 completely eliminate this possibility 

because people wouldn’t be allowed to drive within 100 feet of water or off road, respectively. 

By not allowing driving within 100 feet of water or at all, alternatives 2M and 3 eliminate the 

largest effect of motorized dispersed camping, which is having vehicles drive and park right next 

to streams. Alternatives 2, 4, and 5 retain the ability to drive close to water in camping corridors, 

so aren’t as effective at protecting habitat. They all, however, are an improvement when 

compared to alternative 1.

Alternatives 2 through 5 propose to add unauthorized trails to the forest transportation system, 

half or less of what is being used now. Their locations were selected to minimize disturbance to 

fish habitat. As part of the system, they will receive regular maintenance, which is expected to 

reduce the amount of sediment delivered to any nearby streams.

Fish-bearing Streams – Affected Environment

A number of other native fish live in the streams in the Santa Fe National Forest. These include 

the red and bluntnose shiners, fathead minnow, longnose dace, river carpsucker, mosquitofish, 

and bluegill. A few, the American eel, bluntnose shiner, speckled chub, and Rio Grande shiner, are 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 181

likely extirpated or are considered a species of “greatest conservation need” by the State of New 

Mexico.

Like the special status fish just described, most of these require clear water and unaltered stream 

channels in order to thrive. The fish-bearing streams in the Santa Fe National Forest vary in their 

quality for fish habitat from poor to excellent. 

Fish-bearing Streams – Environmental Consequences

Direct and Indirect Effects, All Alternatives

Alternative 1 would continue motorized use of the forest at its present rate. This means that 

routes, driving cross country, and people would contribute to habitat degradation in some 

locations. Other locations would remain inaccessible to people and vehicles. Alternative 1 is not 

likely to greatly improve the conditions of streams; they would remain the same or get worse.

Alternatives 2 through 5 would all improve on the current condition because they reduce the 

amount of motorized use near streams, especially the number of stream crossings open for 

motorized use and motorized travel off roads (table 50). It is difficult to predict exactly where and 

to what extent habitat in the forest’s streams would improve. Some places would heal, others 

would remain the same, and because these alternatives don’t entirely eliminate motorized use, 

some places could degrade more (refer to the “Soil and Water” section for a description of the 

likelihood of routes and areas recovering naturally). Alternatives 2M and 3 are the most likely to 

improve habitat because they don’t allow driving within 100 feet or at all, respectively, near 

water.

Table 50. Comparison of motorized use close to perennial, native fish-bearing streams

Within 300 Feet of Perennial, 

Native Fish-bearing Streams

Alternative

1 2 2M 3 4 5

Miles of routes 387 207 194 177 234 214

Miles of corridors for dispersed 

camping (DC) or game retrieval (G) 44 (DC) 36

(DC, G)

23

(DC, G) 0 41 (DC) 

208 (G)

28 (DC)

28 (G)

Acres of areas 17,215 0 0.6 0 0 0

Number of stream crossings (occupied

w/Rio Grande cutthroat trout) 1,044 477 443 354 573 560

On balance, having less motorized use near streams reduces the potential for sediment to get to a 

stream, which in turn improves habitat by keeping water clear and not changing the stream’s 

channel. This improves fish habitat, which could potentially promote the species.

Cumulative Effects to All Fish Species, All Alternatives

The action alternatives are expected to improve fish habitat by reducing the potential for sediment 

to reach streams. The cumulative effect with past, present, and reasonably foreseeable future 

actions vary by the management action, and are described below.
Chapter 3. Affected Environment and Environmental Consequences

182 FEIS for Travel Management on the Santa Fe National Forest

Past and Present Actions (1987 – 2011)

Past actions in the Santa Fe National Forest that are relevant to the discussion of cumulative 

effects on fish and their habitats include: subdivision and development of private inholdings and 

access to them, past road construction and stabilization for access across the forest, development 

of access to oil and gas and mining claims, vegetation management and associated road 

development, grazing, dispersed and developed recreation and associated authorized and 

unauthorized road development, trail creation and maintenance, and past wildfires. The 

cumulative effect of these past programs and activities was to reduce the quality and quantity of 

aquatic habitat for native fish, including Rio Grande cutthroat, chubs and suckers. These effects 

are highly variable and localized. Since the last collection of Rio Grande silvery minnow from the 

Rio Chama was in 1949, and the last collection from the Rio Grande above Cochiti Lake was in 

the late 1970s following construction of Cochiti Dam, it is unlikely that these activities had much 

effect on that species.

During the mid-to-latter part of this period, forest staff implemented several programs and 

activities to improve—or with a side benefit of improving—management of aquatic resources.

These included management plans for wild and scenic rivers, creation of the Jemez National 

Recreation Area, road decommissioning and obliteration, improvements to roads and trails 

impacting watersheds through the “Legacy Roads Program,” and Respect the Rio, an educationbased program promoting river friendly camping in the Jemez watershed. 

Present programs and activities either maintain or improve fish habitat. These activities include 

road reconstruction and road decommissioning (i.e., Forest Roads 612, 87, 488, 10J), stream 

crossing modification (i.e., State Highway 4), modification of range management permits, 

reduced timber harvest, trail improvements and dispersed campsite modification in the Jemez 

watershed through Respect the Rio (ongoing partnership), and the future expansion of this 

program to the Upper Pecos watershed. Watershed and fish population and habitat restoration 

projects, including the Peralta, San Antonio, and Cañones watershed improvement projects, and 

the Polvadera CWA §319 partnership, provide locally significant beneficial effects to native Rio 

Grande cutthroat trout, chubs, suckers, and other native or naturalized fishes.

Reasonably Foreseeable Actions (2011-2025)

Although some programs and activities may have localized, short-term negative effects on fish 

and their habitats, the cumulative effects of reasonably foreseeable programs and activities are 

generally beneficial. Degraded aquatic habitats will be targeted for restoration. Management plans 

and range improvements will be updated in range allotments with degraded riparian and stream 

habitats, and additional road and stream crossings will be modified to improve aquatic organism 

passage and reduce impacts to stream channels and fish habitat.

Effects of Forest Plan Amendments on Fish

Proposed Amendments in Table 66 of Appendix 1

The proposed amendments that are administrative in nature are not expected to have an effect on 

fish resources as a result of this project or future projects. These proposed amendments, for the 

most part, simply update direction in the forest plan and ensure consistency with implementation 

of the motor vehicle use map. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 183

The proposed amendments that address off-highway vehicle use within specific management 

areas where cross-country travel was limited (Management Areas C, D, I, J, K, M, and N) have 

no effect on fish resources because they retain specific direction for adding motorized use 

(motorized dispersed camping and motorized big game retrieval) only when it is consistent with 

the management emphasis as per the current forest plan and travel management regulations.

Future projects that add motorized areas or corridors to these management areas would be 

analyzed through the appropriate level of NEPA, which would include an effects analysis for 

riparian and fish resources.

Management areas where cross-country travel has been allowed (Management Areas A, B, E, G, 

P, Q, R, and S) have no plan amendments that restrict adding this type of use through the 

designation of areas or corridors in the future.

Therefore, none of these amendments are expected to negatively affect fish resources, because the 

proposed changes continue to maintain off-highway vehicle use that is consistent with the travel 

management regulations and management emphases for the areas.

The proposed amendment to the Jemez National Recreation Area (Management Area X) restricts 

motorized travel to designated forest system roads and trails, except to pull off the road for 

motorized dispersed camping or motorized big game retrieval in designated corridors. This 

amendment will benefit fish resources, as it would likely limit future motorized off-road travel in 

parts of the JNRA, which would decrease the number of stream crossings (fords) and riparian 

disturbance.

Proposed Amendments in Table 67 of Appendix 1

These amendments are alternative specific, applying principally to alternatives 4 and 5. They 

propose to amend the forest plan to include motorized dispersed camping corridors and motorized 

big game retrieval in the wild and scenic river corridors (East Fork Jemez, Rio Chama, and 

Pecos) and the Jemez National Recreation Area, where this use is currently prohibited. 

These proposed changes to allow motorized travel in areas where it was previously restricted may 

have an impact on soil and water resources via increased soil erosion and sedimentation into 

streams and rivers. This would, in turn, indirectly impact fish habitat and fish resources. There is 

no restriction on dispersed camping within 100 feet of perennial streams in either alternative 4 or 

5, so it is likely that motorized travel in the dispersed camping corridors would reduce the amount 

and vigor of riparian vegetation and, in turn, negatively impact streambank stability and fish 

habitat. The additional motorized travel may increase direct impacts on fish resources due to 

vehicles traveling off road and fording streams.

The effects of amendments that allow for motorized use on specifically identified routes (in 

Management Areas H and L for varying alternatives) would be identical to the direct, indirect, 

and cumulative effects presented in the fisheries specialist’s report, because they relate to a 

specific road as proposed and analyzed for each of the specific alternatives.

Wildlife

Some people wrote that continued motorized use of the Santa Fe National Forest would damage 

wildlife habitat. We routinely analyze a project’s effects on threatened or endangered species, 

sensitive species, management indicator species, and migratory birds. All are discussed in this 
Chapter 3. Affected Environment and Environmental Consequences

184 FEIS for Travel Management on the Santa Fe National Forest

section, which summarizes the wildlife specialist report, biological assessment, and biological 

evaluation in the project record (USDA Forest Service 2011a, 2012k, and 2012m).

First, we explain how roads, motorized trails, and vehicles affect wildlife in general. Unless 

noted, these apply to all species discussed. Then we describe the projects that cumulatively affect 

all wildlife. Finally, for each species or group of species, we describe its habitat and the 

anticipated effects from each alternative followed by any cumulative effects specific to it.

Important note: All the tables showing the miles of routes in different species’ habitats have a 

row called “Routes not currently open for motorized use.” The kinds of routes compiled in this 

category are ones that people aren’t supposed to be driving on or unauthorized routes (these are 

the bulk of them)12.

How Routes and Vehicles Affect Wildlife

The discussion that follows applies to all wildlife species analyzed in this section. 

Roads, trails, and their adjacent habitats tend to negatively affect terrestrial animals (Baker and 

Knight 2000, van der Zande et al. 1980). Roads and trails remove vegetation, which results in 

habitat loss. They fragment habitats, potentially reducing the genetic variability of a population. 

Edge effects favor some species over others (Mader 1984, Marcot et al. 1994, Reed et al. 1996). 

For example, roads give cowbirds the opportunity to invade forested environments, and 

subsequently decrease populations of neotropical migratory birds through nest parasitism. Roads 

facilitate wood collection, which causes a loss of important habitat components such as snags and 

downed logs. Roads bring people, resulting in increased poaching (Wisdom et al. 2000) and 

harassment. Many animals avoid roads and traffic, which can displace them from their natural 

habitat. For example, one study showed that bears crossed roads with little traffic more often than 

those with a volume of traffic (Brody and Pelton 1989).

As described later in this chapter, roads and trails facilitate the transport and establishment of 

nonnative invasive plants. They are often a weed’s first point of entry into a new landscape and 

serve as a corridor to move farther into the landscape (Greenberg et al. 1997, Lonsdale and Lane 

1994).

Because of vehicles’ slow speed on most forest roads, large mammals aren’t usually killed by 

being hit, but small species often are (Lyon 1983, Cade and Woods 1997, Taylor and Goldingay 

2004). Large animals like elk commonly stay away from roads at least 200 meters (Lyon 1985). 

The more traffic on a road, the more they avoid them (Wisdom et al. 2000). Small, slow moving, 

migratory animals like amphibians and small mammals are highly vulnerable when crossing even 

narrow forest roads. Reptiles seek roads for thermal cooling and heating, and in doing so these 

species are more vulnerable to mortality from motorized vehicles. Roads often restrict the 

movements of small mammals (Mader 1984, Swihart and Slade 1984). Consequently, roads 

function as barriers to population dispersal and movement of some species of small mammals, 

reducing the gene flow among populations (Oxley et al. 1974). 

 

12 The specific categories of routes compiled into this row are: closed system, decommissioned, nonsystem closed, 

system trails built for nonmotorized uses, unauthorized, and undetermined. If any of these are located in a place on 

the forest where motorized cross-country use is allowed, then use of the route would also be allowed.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 185

The magnitude of noise from a vehicle can vary greatly depending on distance from noise source, 

atmospheric conditions, weather and wind conditions, vegetation, topography, and ambient noise 

levels. The noise from vehicles can disturb animals, but this varies widely by species and the 

cause and effect relationship is poorly understood (Brumm 2004, Gaines et al. 2003, Blumstein et 

al. 2003). The impacts from noise take many forms, including changing the habitat used, 

increased stress, diminished ability to fight off illness, reduced reproductive success, and a higher 

risk of predation (Blumstein et al. 2003, Brumm 2004, Delaney et al. 1999, Gaines et al. 2003). 

Some species, like chipmunks, jays, and squirrels, become habituated to noise and people, 

especially where hunting is not allowed or not popular (Singer and Doherty 1985). Motorized use 

on main roads in the Santa Fe National Forest is considered low compared to cities, and 

infrequent on high-clearance vehicle roads.

Because studies have shown that routes and vehicles disturb wildlife, we use the miles of roads 

and motorized trails being used or proposed as a proxy for disturbance. This approach doesn’t 

account for the distance from a road that any given species may be affected. Though the literature 

recognizes effects from motorized routes expand beyond a route’s footprint, it varies widely by 

type of disturbance and species (Wisdom 2004, Blumstein et al. 2003, Brumm 2004, Delaney et 

al. 1999). Many studies examine the effects from roads having 10,000 or more vehicles per day 

(Reijnen and Foppen 1995, Forman and Deblinger 2000). Daily traffic on the forest’s busiest 

roads ranges in the low hundreds of vehicles, and on infrequently used roads is less than ten 

vehicles per day.

Methods

The forest biologist reviewed scientific literature describing species’ habitats and modeled the 

location of habitat on the forest using GIS. In summary, modeling each habitat entailed reviewing 

current available scientific literature about the species addressed; identifying physical and 

biological attributes required by each species for all or part of its life history; modeling the 

identified attributes in GIS; comparing GIS modeling to the available observation data; and 

determining the number of miles of motorized routes intersecting modeled habitat for each 

species by alternative. 

The assessment of each habitat was based on the presence of habitat characteristics as described 

in available scientific literature, previous wildlife surveys, recorded wildlife observations, and 

from such databases as BISON-M and Nature Serve that are recognized as credible sources of 

natural biotic information. Some wildlife surveys were conducted specifically for this project and 

the information is incorporated in this analysis.

The acres of resultant habitat for each species shows where they could potentially be—not where 

they definitively are—providing a means to compare existing conditions with the action 

alternatives in a quantitative manner. Where species are closely correlated to specific vegetation 

types, this method provides a good means to assess the changes by alternative (e.g. meadow (New 

Mexico) jumping mouse, Zapus hudsonius luteus). In other cases, the species may be loosely 

associated or associated to a broad range of habitats, making the analysis for those species less 

extrapolative.

Finally, this analysis builds off previous efforts to identify federally listed or sensitive species’ 

habitats. Mexican spotted owl protected activity centers, Jemez Mountain salamander occupied 

and essential habitat, and northern goshawk post-fledgling areas have already been delineated.
Chapter 3. Affected Environment and Environmental Consequences

186 FEIS for Travel Management on the Santa Fe National Forest

Though these may not identify all available or potential habitats, they still provide a reasonable 

means to quantitatively assess the different effects to the species by alternative.

Direct and Indirect Effects Common to All Species

Direct and Indirect Effects, Alternative 1

Alternative 1 has the most places where motorized use is allowed. A species’ response to routes 

and vehicles varies, but as just described, is usually negative. 

Direct and Indirect Effects, Alternatives 2 Through 5

Alternatives 2 through 5 reduce or eliminate the disturbance caused by vehicles driving off roads 

by limiting the places where people can drive off roads (in corridors only) and the duration they 

are allowed to drive off roads (seasonal closures or during hunting season). Alternative 3, because 

it allows no driving off roads and does not designate any unauthorized trails, is the most 

protective of wildlife habitat. Although alternative 4 allows for longer travel distances for big 

game retrieval, based on our assumptions, the number of trips is not expected to be greater and 

the location of game retrieval trips is not known. For these reasons, it is not possible to analyze 

the differences in effects to any given species, but the differences would appear to be minimal.

Though none of the action alternatives physically decommissions roads, all action alternatives 

reduce the amount of disturbance caused by vehicles and people because all reduce the designated 

motorized system from its current condition. This diminishes the effects listed in the “Affected 

Environment” section.

Because they keep some routes and add others, the action alternatives do not entirely eliminate 

the effects from motorized routes and vehicles. Though they all reduce the total miles of routes

available for driving in the forest, each alternative proposes to add some unauthorized routes, 

which adds new miles to the transportation system (even though there is an overall reduction in 

total miles proposed from now). The unauthorized motorized trails proposed for addition in each 

alternative have seasonal closures to protect wildlife during breeding season; the closures thus 

minimize the effects of adding the trails to the system. Adding unauthorized routes to the system 

is expected to minimize disturbances to wildlife compared to the existing condition because the 

routes have been selected to be outside of sensitive habitats. 

The areas proposed in all the alternatives except 3 minimize effects to wildlife because they aren’t 

located in any sensitive habitats. Limiting motorized cross-country travel to the edge of fixeddistance corridors minimizes effects to wildlife by greatly reducing the number of acres where 

driving can occur, and also limiting it temporally to hunting season or outside of breeding season.

Cumulative Effects Common to All Species, for All Alternatives

Unless noted under the discussion of each species, these cumulative effects apply to all wildlife. 

Cumulative actions that pertain to a specific species are discussed with that species.

Past and future actions that either have benefited or may benefit wildlife include: the designation 

of Mexican spotted owl critical habitat and protected activity centers, closure orders, road 

obliteration or natural closures, Lower Jemez Complex Development Restoration, designation of 

wild and scenic river corridors, implementation of the Respect the Rio Program, annual treatment 

of noxious weeds, and all actions that result in a decrease in motorized use or were habitat 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 187

improvement projects. Some past projects—such as hazardous fuels treatments and prescribed 

fire—may have had short-term, negative effects to wildlife, but with long-term benefits overall. 

Other reductions in cumulative effects to wildlife resources may come from listing species under 

the Endangered Species Act of 1973, as amended, providing additional protections to those 

species.

Past and future actions that either have or may be detrimental to wildlife include: subdivision and 

development of private inholdings, road construction for timber sales, development of mining 

claims, increased demand for forest products, advancement in off-highway vehicle technology, 

increase in the State’s population, road maintenance agreements (assuming these agreements 

result in an increase of road use due to an increase in regular maintenance), and all actions that 

result in an increase in motorized use or road construction, or projects improving the condition of 

roads or trails for public use. Actions such as development of private inholdings, road 

construction, mining, oil and gas leases, geothermal leases, and, to a lesser extent, demand for 

forest products would cumulatively reduce the amount of land available for wildlife and increase 

fragmentation of habitat within the project area. The other actions have the potential to 

cumulative increase disturbance to wildlife through increased traffic on motorized routes.

Threatened and Endangered Species

The federally listed species and their critical habitat (if present) in the Santa Fe National Forest 

are:

• Rio Grande silvery minnow (Hybognathus amarus) (endangered) – addressed in the 

“Fisheries” section of this report

• Mexican spotted owl (Strix occidentalis lucida) (threatened)

• Southwestern willow flycatcher (Empidonax traillii extimus) (endangered)

• Holy Ghost ipomopsis (Ipomopsis sancti-spiritus) (endangered)

Mexican Spotted Owl – Affected 

Environment

The U.S. Fish and Wildlife Service listed 

the Mexican spotted owl as threatened in 

1993. Timber harvest and high intensity 

wildfire caused enough change in the 

Mexican spotted owl’s habitat that its 

population declined.

Mexican spotted owls live in steep, 

forested canyons that have high canopy 

closure, high stand density, a multilayered 

canopy, snags, and downed logs (USDI 

1993). They prefer forests dominated by 

mature Douglas-fir or white fir mixed with 

other species of pine. They nest in caves, 

cliff ledges, or old trees in steep canyons 

(USDI 1993 and NatureServe 2009). Figure 60. A Mexican spotted owl (Photo 

Courtesy of U.S. Fish and Wildlife Service)
Chapter 3. Affected Environment and Environmental Consequences

188 FEIS for Travel Management on the Santa Fe National Forest

Mexican spotted owls nest and breed in protected activity centers (PACs), which forest biologists 

delineate around nesting sites. The Santa Fe National Forest knows of 50 protected activity 

centers on about 33,000 acres.

Four designated critical habitat units for the Mexican spotted owl exist (USDI 2004). Critical 

habitat for the Mexican spotted owl contains at least one primary constituent element, those 

physical and biological features that support roosting, nesting, and foraging. Examples of primary 

constituent elements are forests with trees larger than 12 inches in diameter, water, canyon walls 

with crevices, or a wide range of tree and plant species. The Santa Fe National Forest contains 

four critical habitat units, totaling approximately 242,000 acres, in the Cuba, Jemez, and 

Pecos/Las Vegas Ranger Districts. An estimated 10 to 100 breeding pairs of Mexican spotted 

owls live in the Santa Fe National Forest. People are driving on 708 miles of roads and 97 miles 

of motorized trails in critical habitat. Of these, 126 miles are unauthorized routes or closed.

Habitat in the Santa Fe National Forest for the Mexican spotted owl is declining. Fewer stands 

reach old-growth status because of past fire suppression, which has resulted in smaller, 

overcrowded forests (wildfires thin the forest). Younger forests do not provide the habitat 

required by Mexican spotted owls.

Mexican Spotted Owl – Environmental Consequences

Routes cause a loss of habitat for the Mexican spotted owl by fragmenting intact landscapes into 

smaller pieces. Because they serve as conduits for people, routes also contribute to habitat loss 

through wood collection and because owls tend to avoid people. Alternative 1 represents the most 

disturbances from routes, vehicles, and people because it has the most motorized use.

The reduction of routes and motorized cross-country travel associated with the action alternatives 

is likely to improve habitat and promote the recovery of the species (table 51). Alternatives 2 

through 5 are all an improvement from the current condition, though alternative 3 reduces 

motorized routes the most in Mexican spotted owl habitat. Fewer routes means a more intact 

habitat without edges, less chance of owls being hit by vehicles, and fewer conduits by which 

people can disturb nests. 

Table 51. Comparison of miles of routes and route density in Mexican spotted owl habitat

by alternative

Alternative

1 2 2M 3 4 5

Protected 

activity 

centers

Miles of closed and unauthorized 

routes proposed 24 0.5 0.4* 0 7 3

Total miles, all routes

Percent change from alternative 1

124

--

37

-70

35

-72

26

-79

51

-59

37

-70

Critical 

habitat

Miles of closed and unauthorized 

routes proposed 198 52 49 15 77 45

Total miles, all routes

Percent change from alternative 1

806

--

324

-60

311

-61

225

-72

408

-49

308

-62

*Of these, 0.2 mile is closed seasonally.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 189

All of the action alternatives include seasonal closures on roads and motorized trails—including 

for unauthorized routes—in Mexican spotted owl habitat, minimizing disturbance and harassment 

to owls during the breeding season. Selection of any of the action alternatives may negatively 

impact individual Mexican spotted owls, but is not anticipated to appreciably reduce the 

likelihood of both the survival and recovery in the wild. Additionally, selection of any of the 

action alternatives will not appreciably diminish the value of constituent elements essential to the 

Mexican spotted owl’s conservation.

The forest consulted with the U.S. Fish and Wildlife Service on alternative 2M, the preferred 

alternative (USDA Forest Service 2011a). The U.S. Fish and Wildlife Service concurred with the 

forest’s determination for alternative 2M of “may affect, not likely to adversely affect” the 

Mexican spotted owl and its critical habitat on June 27, 2011. Among the reasons for this 

determination are:

• Motorized cross-country travel wouldn’t be allowed in any protected activity centers. 

Since no areas are proposed in protected activity centers, disturbance and harassment of 

owls is minimized.

• The seasonal restrictions placed on unauthorized motorized trails in protected activity 

centers would minimize disturbance and harassment to owls. Only 0.18 mile of 

unauthorized motorized trail would be designated in Guaje Canyon without seasonal 

restrictions. This trail is located about 0.5 mile from the core area on the mesa along the 

northern boundary of the protected activity center. The canyon topography of the 

protected activity center provides a topographic buffer from the core area. The remaining 

0.20 mile in Guaje Canyon would be designated with a breeding season restriction 

(March 1–August 31).

• No roads would be designated in the seven protected activity centers that currently do not 

have any.

• The five protected activity centers—Joaquin, Lake Fork, Los Utes, Lower Cochiti, and 

Medio Dia—proposing fixed-distance corridors for motorized dispersed camping propose 

them on the mesas and along the perimeter of the protected activity centers, providing 

topographic separation from the core area. Camping is currently taking place in these 

areas and has been for many years. The amount of camping is not expected to change, 

and the area designated in any single protected activity center is insignificant compared 

to the amount of owl habitat available.

• Alternative 2M closes 88 miles, about 71 percent, of motorized routes currently in 

protected activity centers. This results in 20 of the 50 protected activity centers in the 

forest having no roads open to the public.

• The prohibition on driving within 100 feet of water in fixed-distance corridors will 

reduce effects to riparian areas, thereby minimizing disturbance to the owl’s foraging 

habitat.

• In critical habitat, approximately 61 percent—493 miles—of roads now open to 

motorized use would be closed. About 98 miles of unauthorized motorized trails people 

use now would also be closed.

• Within critical habitat, only 3,894 acres of motorized dispersed camping corridors would 

be designated compared to the 5,603 acres being used now, a 30 percent reduction.
Chapter 3. Affected Environment and Environmental Consequences

190 FEIS for Travel Management on the Santa Fe National Forest

Though the potential exists to remove ground cover, accelerate erosion, and increase soil 

compaction in the corridors, thereby affecting the primary constituent elements, this 

effect is negligible compared to the over 200,000 acres of critical habitat on the forest and 

the over 30,000-acre reduction in disturbance from the removal of motorized routes open 

to the public. Designating motorized dispersed camping corridors will improve the 

forest’s ability to manage these areas and, thus, minimize disturbance from motorized 

vehicles to natural resources, providing an overall benefit to the Mexican spotted owl.

The “Travel Management Rule on the Santa Fe National Forest Biological Assessment” contains 

a detailed description of the reasons for the determination. 

Different management actions and natural occurrences have cumulatively increased or decreased 

Mexican spotted owl habitat. Since 1995, timber harvest in the Santa Fe National Forest in 

Mexican spotted owl habitat has decreased. The U.S. Fish and Wildlife Service designated critical 

habitat in 2004. Along with reducing the places where people can drive, less timber harvest and 

designated, protected habitat would provide a cumulative benefit to the Mexican spotted owl and 

its habitat. 

Tribal and state lands next to the forest potentially contain owl habitat. Activities on them can 

include vegetation treatments, grazing, and recreation. Activities on adjacent private land vary but 

include subdivisions, roads, mining, recreation, and grazing. The 2011 Las Conchas Fire 

contained a number of protected activity centers that were burned. These activities increase 

disturbance and reduce the quality and quantity of nesting and foraging habitat.

Southwestern Willow Flycatcher – Affected Environment

Southwestern willow flycatchers prefer habitat near gently flowing streams in wide open valleys. 

They nest in thickets of trees and shrubs and build their nests at ground level up to 13 feet. The 

average size of a flycatcher’s breeding patch is approximately 20 acres, but has been found up to 

175 acres in the upper Gila River. Biologists have named several kinds of habitat for the 

Southwestern willow flycatcher (USDI Fish and Wildlife Service 2005b):

• Currently suitable habitat is at least 2.5 acres and consists of dense riparian shrubs and 

patches of trees, with at least 30 feet of riparian patches.

• Potentially suitable habitat occurs in flood plains where dense riparian vegetation could 

grow, but does not currently exist.

• Unsuitable habitat would not support dense riparian trees and shrubs.

• Critical habitat – The Santa Fe National Forest is in the Rio Grande Recovery Unit, but 

does not contain any critical habitat for the Southwestern willow flycatcher.

The Santa Fe National Forest has potentially suitable habitat (about 3,800 acres) along the Rio 

Grande and Jemez and Pecos Rivers on the Jemez, Española, and Pecos/Las Vegas Ranger 

Districts.

The Southwestern willow flycatcher is not known to occur in the forest, nor does its designated 

critical habitat occur (USDI Fish and Wildlife Service 2005b). None has been sighted in the 

forest.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 191

Southwestern Willow Flycatcher –

Environmental Consequences

Studies have shown that developed 

recreational facilities and off-road vehicles 

threaten the Southwestern willow 

flycatcher’s habitat (USDI Fish and Wildlife 

Service 2005a). Roads in riparian areas 

bisect and, thus, degrade habitat. People 

engaging in recreational activities remove 

riparian vegetation (such as for campfires), 

which reduces the area flycatchers need to 

breed and grow and inhibit their behavior.

The brown-headed cowbird is a widespread 

and significant threat to Southwestern 

willow flycatcher (Sogge 1992). Cowbirds 

engage in brood parasitism by laying their 

eggs in flycatcher nests; the unsuspecting flycatcher then raises a cowbird at the expense of her 

own. Cowbirds thrive in edge habitat along roads and trails. Thus, the number of routes may play 

a major role in promoting cowbird parasitism.

The miles of routes in potential habitat among alternatives ranges from 6.8 to 8 (table 52). The 

difference between alternatives, therefore, is small. Alternative 1, because it is most permissive 

about motorized use off roads, would be least effective at promoting suitable habitat for the 

Southwestern willow flycatcher.

Table 52. Comparison of miles of routes and route density in Southwestern willow 

flycatcher habitat by alternative

Potential Habitat for 

Southwestern Willow 

Flycatcher

Alternative

1 2 2M 3 4 5

Miles of closed and 

unauthorized routes in 

potential habitat

1.2 0.7 0.1 0.7 1.1 1.1

Total miles in potential habitat

Percent change from 

alternative 1

10.1

--

8.9

-12

6.0

-41

9.8

-3

11.2

+11

11.2

+11

Reducing places where people can drive in riparian ecosystems will increase the quality of 

potential habitat for southwestern willow flycatcher. Alternative 3 reduces driving along streams 

the most because no driving off roads is allowed. Alternative 2M wouldn’t allow vehicles within 

100 feet of water’s edge. Though none of the alternatives physically remove any motorized roads 

or trails, reducing where people can drive would minimize the potential for direct mortality, 

displacement, or avoidance from vehicular traffic, and human interaction. Eliminating motorized 

cross-country use will minimize people’s ability to randomly drive through streams and the 

effects associated with it. Over time, the action alternatives are likely to improve potential habitat 

for Southwestern willow flycatcher to varying degrees, with alternatives 3 and 2M being the most 

Figure 61. A Southwestern willow flycatcher 

(Photo Jim Rorabaugh, Courtesy of U.S. Fish 

and Wildlife Service)
Chapter 3. Affected Environment and Environmental Consequences

192 FEIS for Travel Management on the Santa Fe National Forest

favorable. Based on this information, and that no Southwestern willow flycatchers have been 

detected in the forest, the forest biologist determined that selecting alternative 2M—the preferred 

alternative—would have “no effect” on the Southwestern willow flycatcher.

Holy Ghost Ipomopsis – Affected Environment

The Holy Ghost ipomopsis is a rare plant that lives in a 2-mile stretch of canyon in the Sangre de 

Cristo Mountains. It prefers dry, steep, west- and southwest-facing slopes in forests containing 

ponderosa pine, Douglas-fir, Gambel oak, and quaking aspen. The plants have colonized the cut 

and fill slopes along a National Forest System road, indicating a preference for open, disturbed 

areas.

Its small population, road maintenance, recreational activities, and high intensity wildfires pose 

the main threats to the Holy Ghost ipomopsis. The entire population consists of 1,200 to 1,500 

plants. About 80 percent live on the cut and fill slopes and the other 20 percent in naturally dry 

and open habitat higher up on canyon slopes.

Holy Ghost Ipomopsis – Environmental Consequences

This project would have no effect on the Holy Ghost ipomopsis because the road along which it 

lives would remain the same under all the alternatives. Because there are no direct or indirect 

effects, there would be no cumulative effects.

Sensitive Species – Affected 

Environment and Environmental Consequences

A species on the “Regional Forester’s sensitive species list” is one that could become threatened 

or endangered if its habitat is lost. They tend to be less abundant than management indicator 

species. The Santa Fe National Forest has 43 sensitive species. Three of them—Botta’s pocket 

gopher, Rocky Mountain bighorn sheep, and Lilljeborg’s pea-clam—do not live in places affected 

by this project, so we won’t discuss them further.

We divide the sensitive species into amphibians, birds, mammals, and plants when discussing 

their habitats and the potential effects from changing the forests’ designated motorized system. 

Given the number of species, we have simplified the discussion into tables. Unless noted, the 

cumulative effects are the same as those described above for all species. The “Wildlife and Rare 

Plants Biological Evaluation” contains a detailed description of each species’ habitat and life 

history.

Based on the overall reduction of places where people can drive, mitigation measures proposed to 

protect Jemez Mountain salamander, not allowing vehicles within 100 feet of water, and 

elimination of cross-country use, the forest biologist determined that selecting alternative 2M, the 

preferred alternative, may impact individuals but is not likely to result in a trend toward Federal 

listing or loss of species viability of any of the sensitive species discussed in this section.

Amphibians

None of the action alternatives is likely to result in a trend toward Federal listing or a loss of 

species viability because all reduce the places where people can drive compared to the existing 

condition (table 53). Roads, trails, and motorized use tends to negatively affect amphibians as 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 193

described in the section “How Routes and Vehicles Affect Wildlife.” Individuals may be impacted 

since motorized use of the forest is not being entirely eliminated. Reducing the places where 

people can drive in the forest would improve the quality of habitat for amphibians by keeping 

vegetation in place, lessening erosion, diminishing the chance of being run over, and allowing 

better movement and dispersal.

Effects to the Jemez Mountain salamander in particular would be minimized because habitat 

surveys and subsequent mitigations are required prior to unauthorized trails or areas being 

published on the motor vehicle use map.

Roads, trails, and motorized use affect amphibians by removing the vegetation—including 

downed logs when people collect wood—that composes its habitat. Roads and trails fragment 

habitat for these small creatures, which potentially reduces their genetic variability because they 

can’t move freely. Not allowing people to drive near water as proposed in alternatives 3 and 2M 

would be particularly beneficial to amphibians since they live in moist environments. 

Table 53. Comparison of miles of routes in potential amphibian habitat by species and 

alternative

Species

(acres) Habitat Miles of Routes in 

Potential Habitat

Alternative

1 2 2M 3 4 5

Jemez 

Mountain 

salamander

(33,100)

Occupied

Closed and unauthorized 

routes 17 2 2 0 5 1

All routes 37 14 13 8 18 12

Essential

Closed and unauthorized 

routes 47 8 10 0 17 5

All routes 104 45 45 24 52 33

Occupied 

and essential

Total

Percent change

141

--

58

-59

57

-60

32

-77

70

-50

45

-68

Northern 

leopard 

frog

(57,600)

Springs, 

marshes, wet 

meadows

Routes not currently open for 

motorized use 64 22 22 16 34 28

Total

Percent change

356

--

200

-44

188

-47

170

-52

224

-37

205

-42

Birds

None of the action alternatives is likely to result in a trend toward Federal listing or a loss of 

species viability because all reduce the places where people can drive compared to the existing 

condition (table 54). Roads, trails, and motorized use tend to negatively affect birds as described 

in the section “How Routes and Vehicles Affect Wildlife.” Individuals may be impacted since 

motorized use of the forest is not being entirely eliminated. Reducing the places where motorized 

use may occur in the forest would improve the quality of habitat for birds by reducing 

fragmentation, having fewer interactions with humans, and lessening the chance of direct 

mortality. Designating the unauthorized trails would minimize disturbance to sensitive bird 

species because the trails are already being used, they have been chosen to be in locations away 

from sensitive habitats, and are fewer than what is being driven on now. Designating the areas is 

expected to have no impact on sensitive bird species because the areas proposed aren’t located in 

their habitat and are inconsequential in size when compared to the entire forest. 
Chapter 3. Affected Environment and Environmental Consequences

194 FEIS for Travel Management on the Santa Fe National Forest

No bald eagle nests are known on the forest, and wintering habitat is limited. Thus, no change is 

expected by implementing any of the action alternatives. Because of these reasons, the forest 

biologist determined there would be no effect to the bald eagle.

An activity that could cumulatively offset benefits to the peregrine falcon from the action 

alternatives is the collection of eyases (young hawks) for falconry; the New Mexico Department 

of Game and Fish permits the collection of up to two eyases annually.

Table 54. Comparison of miles of routes in potential bird habitat by species and alternative

Species Habitat

Acres of 

Potential 

Habitat*

Miles of Routes 

in Potential 

Habitat

Alternative

1 2 2M 3 4 5

White-tailed 

ptarmigan

Alpine 

ecosystems 

above 

10,500 feet 

elevation

137,300

Closed and 

unauthorized routes 3 0.3 0.5 0.3 0.7 0.7

Total

Percent change

81

--

30

-62

31

-62

25

-69

32

-60

27

-67

Northern 

goshawk

Coniferous 

forests in a 

variety of 

structural 

stages

26,900

Closed and 

unauthorized routes 18 6 5 3 7 5

Total

Percent change

95

--

44

-54

39

-59

33

-65

51

-46

45

-53

American 

peregrine 

falcon

Variety of 

grasslands 

and forests 

with cliffs

236,100

Closed and 

unauthorized routes 144 29 31 8 62 27

Total 518 256 245 200 303 243

Percent change -- -51 -53 -61 -42 -53

Western 

yellowbilled 

cuckoo

Mature 

riparian 

cottonwood 

and willow 

woodlands

2,200

Closed and 

unauthorized routes 3 1 2 1 2 1

Total

Percent change

8

--

4

-50

3

-63

4

-50

4

-50

4

-50

Burrowing 

owl

Grasslands, 

open 

shrublands, 

and 

woodlands

69,800

Closed and 

unauthorized routes 28 2 3 1 14 10

Total

Percent change

476

--

207

-57

206

-57

164

-66

258

-46

235

-51

Boreal owl

Spruce-fir 

forests 

above 

9,500 feet 

elevation

195,200

Closed and 

unauthorized routes 50 23 23 4 35 26

Total

Percent change

189

--

94

-50

94

-50

60

-68

116

-39

96

-49

Gray vireo

Piñonjuniper 

woodlands 

with 

various 

shrubs and 

grasses

199,400

Closed and 

unauthorized routes 61 11 12 6 28 23

Total

Percent change

379

--

173

-54

164

-57

118

-69

202

-47

189

-50

*Rounded to nearest hundred.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 195

Mammals

None of the action alternatives is likely to result in a trend toward Federal listing or a loss of 

species viability because all reduce the places where people can drive compared to the existing 

condition (table 55). Roads, trails, and motorized use tends to negatively affect mammals as 

described in the section “How Routes and Vehicles Affect Wildlife.” Adding unauthorized 

motorized trails will minimize disturbance to individual species by reducing the places people can 

drive compared to the existing condition, and because the routes have been selected in locations 

not expected to significantly impact species or their habitats. Designating the motorized areas is 

expected to have no effect because they aren’t located in sensitive species habitats. Individuals 

may be impacted since motorized use of the forest is not being entirely eliminated. Reducing the 

places where motorized use may occur in the forest would improve the quality of habitat for 

mammals by reducing fragmentation and barriers to movement (this improves genetic variation), 

having fewer interactions with humans, keeping vegetation intact, and lessening the chance of 

direct mortality.

For the New Mexico meadow jumping mouse, grazing by livestock could cumulatively offset 

some of the benefits gained from closing routes to motorized use.

Table 55. Comparison of miles of routes in potential mammal habitat by species and alternative

Species Habitat

Acres of 

Potential 

Habitat*

Miles of Routes 

in Potential 

Habitat

Alternative

1 2 2M 3 4 5

Cinereus 

(masked) 

shrew

Riparian 

areas in 

subalpine 

coniferous

forest

268,500

Closed and 

unauthorized 76 33 31 8 48 29

Total 425 180 172 131 225 183

Percent change -- -58 -60 -69 -47 -57

Dwarf shrew

Talus and 

rocky areas 

in Douglasfir forests

334,500

Closed and 

unauthorized 233 83 73 11 129 72

Total 1,193 491 471 334 612 466

Percent change -- -59 -60 -72 -49 -61

Water shrew 

and Preble’s 

shrew

Near 

perennial 

streams in 

SFNF 

mountain 

ranges

76,900

Closed and 

unauthorized 64 22 22 16 34 29

Total 359 200 189 170 225 206

Percent change -- -44 -47 -53 -37 -43

Spotted bat

Variety, 

including 

riparian, 

woodlands, 

and forests

76,900

Closed and 

unauthorized 64 22 22 16 34 29

Total 359 200 189 170 225 206

Percent change -- -44 -47 -53 -37 -43

Pale 

Townsend’s 

big-eared bat

Areas 

having 

caves

302,600

Closed and 

unauthorized 94 24 22 16 55 39

Total 765 340 337 291 428 366

Percent change -- -56 -56 -62 -44 -52
Chapter 3. Affected Environment and Environmental Consequences

196 FEIS for Travel Management on the Santa Fe National Forest

Table 55. Comparison of miles of routes in potential mammal habitat by species and alternative

Species Habitat

Acres of 

Potential 

Habitat*

Miles of Routes 

in Potential 

Habitat

Alternative

1 2 2M 3 4 5

Pika

Talus slopes 

adjacent to 

meadows

86,400

Closed and 

unauthorized 1 0 0 0 0 0

Total 39 16 16 13 16 13

Percent change -- -60 -60 -66 -60 -66

Goat Peak 

pika

Talus slopes 

adjacent to 

meadows in 

the Jemez 

Mountains

7,400

Closed and 

unauthorized 5 2 18 1 2 2

Total 17 10 9 7 10 10

Percent change -- -41 -49 -60 -41 -41

Snowshoe 

hare

Dense 

spruce-fir 

forest with 

dense 

understory

124,700

Closed and 

unauthorized 3 0 0 0 1 1

Total 44 15 16 14 19 17

Percent change -- -65 -65 -69 -58 -62

Yellowbellied 

marmot

Sloped 

alpine 

tundra, 

subalpine 

and 

montane 

meadows

34,600

Closed and 

unauthorized 3 1 1 1 2 1

Total 42 24 24 22 25 23

Percent change -- -44 -44 -48 -40 -45

Gunnison’s 

prairie dog

Short and 

mid-grass 

prairies

143,100

Closed and 

unauthorized 78 16 16 8 37 27

Total 936 421 414 331 519 466

Percent change -- -55 -56 -65 -45 -50

NM bannertailed 

kangaroo rat

Desert 

grasslands 

with 

scattered 

shrubs

94,900

Closed and 

unauthorized 39 5 5 3 18 13

Total 548 232 231 179 297 277

Percent change -- -58 -58 -67 -46 -49

Southern redbacked vole

Cool, wet 

sites in 

spruce-fir 

forest

497,000

Closed and 

unauthorized 254 94 84 15 142 83

Total 1,288 541 520 367 668 517

Percent change -- -58 -60 -72 -48 -60

Western 

heather vole

Highaltitude 

montane 

forests with 

dense 

grasses

291,700

Closed and 

unauthorized 22 7 3 3 14 5

Total 325 111 107 95 148 113

Percent change -- -66 -67 -71 -55 -65

Long-tailed 

vole

Coniferous 

forest with a 

grassy floor 

and near 

meadows

76,900

Closed and 

unauthorized 64 22 22 16 34 29

Total 359 200 189 170 225 206

Percent change -- -44 -47 -53 -37 -43
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 197

Table 55. Comparison of miles of routes in potential mammal habitat by species and alternative

Species Habitat

Acres of 

Potential 

Habitat*

Miles of Routes 

in Potential 

Habitat

Alternative

1 2 2M 3 4 5

Meadow 

(NM) 

jumping 

mouse

Near 

perennial 

streams in 

places with 

wet soils 

and riparian 

vegetation

28,900

Closed and 

unauthorized 45 16 15 12 25 21

Total 180 102 96 86 116 106

Percent change -- -43 -47 -52 -36 -41

American 

marten

Old-growth 

spruce-fir 

forest

269,100

Closed and 

unauthorized 76 40 35 8 55 39

Total 351 177 169 114 211 175

Percent change -- -50 -52 -67 -40 -50

Ermine 

High 

altitude 

mixed 

conifer 

forest

367,800

Closed and 

unauthorized 159 64 547 18 97 65

Total 874 414 397 302 497 412

Percent change -- -53 -55 -65 -43 -53

Mink

Close to 

permanent 

water 

sources, 

such as 

large rivers

110,400

Closed and 

unauthorized 80 27 27 18 42 35

Total 573 300 286 248 345 311

Percent change -- -48 -50 -57 -40 -46

*Rounded to nearest hundred.

Plants

None of the action alternatives is likely to result in a trend toward Federal listing or a loss of 

species viability because all reduce the places where people can drive compared to the existing 

condition (table 56). Alternative 2M, the preferred alternative, nearly eliminates motorized crosscountry travel, doesn’t allow vehicles within 100 feet of water, and greatly reduces the miles of 

routes open for driving. Adding the unauthorized trails and designating areas will minimize 

impacts to sensitive plants because they aren’t located through any known populations. 

Individuals may be impacted since motorized use of the forest is not being entirely eliminated. 

Though selecting any of the action alternatives would not physically remove any motorized 

routes, reducing the routes on which people can drive and eliminating cross-country use would 

reduce the potential for individual plants to be crushed, soil loss, and subsequent competition 

from nonnative plants. Over time, individual plants could reestablish themselves on routes closed 

to motorized use. 
Chapter 3. Affected Environment and Environmental Consequences

198 FEIS for Travel Management on the Santa Fe National Forest

Table 56. Comparison of miles of routes in potential plant habitat by species and alternative

Species Habitat

Acres of 

Potential 

Habitat*

Miles of Routes 

in Potential 

Habitat

Alternative

1 2 2M 3 4 5

Tufted sand 

verbena

Hills and 

ridges of 

gypsum

9,600

Closed and 

unauthorized 7 4 5 2 5 5

Total 37 24 24 21 26 23

Percent change -- -36 -35 -44 -30 -38

Greene

milkweed

Plains, 

open hills, 

and low 

slopes

32,400

Closed and 

unauthorized 8 1 1 0 3 1

Total 205 77 75 55 100 90

Percent change -- -63 -63 -73 -51 -56

Chaco 

milkvetch

Outcrops of 

sandstone 

in pinyonjuniper 

woodland

107,700

Closed and 

unauthorized 19 8 10 4 15 6

Total 205 102 99 82 120 94

Percent change -- -50 -52 -60 -41 -54

Pecos 

mariposa 

lily

Highaltitude 

meadows 

and aspen 

glades

52,000

Closed and 

unauthorized 11 5 6 1 7 5

Total 46 22 20 11 29 22

Percent change -- -53 -57 -76 -37 -52

Yellow 

lady’s 

slipper

Fir, pine, 

and aspen 

forests, 

usually 

near water

73,500

Closed and 

unauthorized 63 19 19 13 30 24

Total 397 215 205 185 243 218

Percent change -- -46 -48 -53 -39 -45

Robust 

larkspur

Canyon 

bottoms 

and aspen 

groves

103,200

Closed and 

unauthorized 69 26 25 14 37 30

Total 372 197 186 160 225 199

Percent change -- -47 -50 -57 -40 -46

Pecos 

fleabane

Rocky, 

open 

meadows 

in 

subalpine 

coniferous 

forest

5,500

Closed and 

unauthorized 0 0 0 0 0 0

Total 9 5 5 5 5 5

Percent change -- -43 -43 -46 -43 -46

Wood lily

Welldrained 

soils rich in 

humus

62,600

Closed and 

unauthorized 17 4 5 2 7 6

Total 166 65 60 48 80 66

Percent change -- -61 -64 -71 -52 -60

Chama 

blazing star

Upper 

Chama 

River 

valley on 

disturbed 

areas

3,200

Closed and 

unauthorized 3 0 3 0 0 0

Total 8 4 7 4 7 4

Percent change -- -53 -10 -53 -9 -53
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 199

Table 56. Comparison of miles of routes in potential plant habitat by species and alternative

Species Habitat

Acres of 

Potential 

Habitat*

Miles of Routes 

in Potential 

Habitat

Alternative

1 2 2M 3 4 5

Springer’s 

blazing star

Volcanic 

pumice in 

pinyonjuniper 

woodlands

16,000

Closed and 

unauthorized 12 1 1 0 6 2

Total 54 27 25 21 32 27

Percent change -- -51 -54 -61 -41 -49

Arizona 

willow

Sedge 

meadow 

and wet 

drainages 

in 

subalpine 

coniferous 

forest

14,100

Closed and 

unauthorized 0 0 0 0 0 0

Total 3 1 1 1 1 1

Percent change -- -77 -77 -83 -70 -70

*Rounded to nearest hundred.

For the tufted sand verbena, an increasing population could increase the demand for this rare 

plant; collecting plants could cumulatively offset some of the benefits gained by closing routes to 

motorized use. Similarly, Pueblo people used milkweeds and Arizona willow for food and 

medicine, and might continue collecting them today. Nonnative people looking to use natural 

remedies might also put pressure on milkweed and willow populations.

Management Indicator Species – Affected Environment

The Santa Fe National Forest selected its management indicator species to represent certain 

habitats. A management indicator species acts as a signal for changes in habitat. If the population 

of a management indicator species changes, it could be a result of forest management. The 

“Environmental Impact Statement for the Santa Fe National Forest Plan” explains why we chose 

the management indicator species we did and what habitats they represent. The 2012 

“Management Indicator Species Assessment” for the forest is herein incorporated by reference, 

where additional information on management indicator species and their habitats is found.

The forest’s management indicator species are: Rocky Mountain bighorn sheep (Ovis canadensis 

canadensis), Rocky Mountain elk (Cervis elaphus nelsoni), Mexican spotted owl (Strix 

occidentalis lucida), Merriam’s turkey (Meleagris gallopavo), hairy woodpecker (Picoides 

villosus), Rio Grande cutthroat trout (Oncorhynchus clarki virginalis), pinyon jay (Gymnorhinus 

cyanocephalus), and mourning dove (Zenaida macroura). The “Environmental Impact Statement 

for the Santa Fe National Forest Plan” identifies the habitat types and projected effects of 

management actions for each species. It states that changes in road density or amount of 

motorized use will not affect the quantity of habitat for any management indicator species in the 

forest. Habitat quality, however, for Rocky Mountain elk and Merriam’s turkey may be affected 

by roads. None of the habitats of the other management indicator species are expected to be 

influenced by changes in road and trail management according to the EIS for the forest plan; thus, 

the action alternatives have no effect. This section only addresses the effects of the action 

alternatives to Rocky Mountain elk and Merriam’s turkey (table 57).
Chapter 3. Affected Environment and Environmental Consequences

200 FEIS for Travel Management on the Santa Fe National Forest

We analyzed the effects to Rio Grande cutthroat trout in the “Fisheries” section of this report. 

Effects to the Mexican spotted owl—also a management indicator species—are described earlier 

in the “Threatened and Endangered Species” section.

Table 57. The forest’s management indicator species, their habitats and population trends

Management 

Indicator 

Species

Habitat Type

Acres of 

Habitat

Habitat 

Trend

Population 

Trend Comment

Rocky 

Mountain elk

Variety of forested 

and open 

landscapes; shrub 

cover for calving

574,000 Increasing

1,000 to 10,000 

breeding females 

on the forest. 

Ranked as 

common.

NM Department of 

Game and Fish controls 

population with special 

hunts.

Merriam’s 

turkey

Variety of forested 

land, especially 

ponderosa pine with 

a robust understory, 

with small clearings 

and mast-producing 

trees.

603,200 Stable to 

increasing

1,000 to 10,000 

breeding females 

on the forest. 

Ranked as 

common/stable to 

increasing.

NM Department of 

Game and Fish controls 

population by adjusting 

the length of the 

hunting season and 

number of birds 

allowed to be taken.

Management Indicator Species – Environmental Consequences

Direct and Indirect Effects, Alternative 1

Alternative 1, the existing condition, would have the most motorized use. Despite this, 

management indicator species except Mexican spotted owl have sustained or increased their 

population. This is likely due to factors other than roads and motorized trails, which generally 

have a negative effect on habitats as documented above.

Direct and Indirect Effects Common to 

All Management Indicator Species, Alternatives 2 Through 5

Since alternatives 2 through 5 reduce the places on the forest where motorized use is allowed, 

selection of any of the action alternatives is not likely to result in a trend toward Federal listing or 

loss of viability of any management indicator species. Any of the alternatives may, however, 

impact individual animals.

The seasonal closures placed on the unauthorized routes serve to minimize disturbance and 

harassment of the management indicator species during breeding season. The areas proposed in 

all the action alternatives minimize harassment and disturbance because they are not located in 

sensitive habitat. Limiting motorized cross-country travel to the edge of fixed-distance corridors 

minimizes effects to wildlife by greatly reducing the number of acres where driving can occur, 

and also limiting it temporally to hunting season or outside of breeding season.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 201

Rocky Mountain Elk

Alternatives 2 through 5 are 

likely to improve elk habitat and,

therefore, likely to result in an 

increasing population trend over

time. All action alternatives 

would lessen the disturbance to 

elk and their habitat from vehicles 

and people by limiting the miles 

of routes in calving areas and 

crucial winter and summer range 

compared to alternative 1, the 

existing condition (table 58). 

Reducing the miles of routes open 

to motorized use would reduce 

the potential fragmentation of 

suitable habitat, poaching 

opportunities, and displacement or avoidance. The action alternatives also limit driving off roads 

to corridors (alternatives 2, 2M, 4, and 5) or eliminate it altogether (alternative 3). This minimizes

the effects of motorized use, such as harassment and disturbance, on wildlife described in the 

affected environment. Seasonal closures on motorized trails for elk calving and in winter range 

protect the animals from being disturbed by vehicles during these periods of stress. The areas 

proposed aren’t currently used as habitat by elk, and are so small—40 acres or less—as to be 

immaterial. Thus, the areas proposed minimize disturbance to Rocky Mountain elk.

Table 58. Comparison of miles of routes and route density in Rocky Mountain elk habitat 

by alternative

Alternative

1 2 2M 3 4 5

Calving areas 

(170,060 acres)

Total miles, all routes 570 215 209 147 291 217

Percent change 

from alternative 1 -- -62 -63 -74 -49 -62

Crucial winter 

range (12,997 

acres)

Total miles, all routes 36 27 27 19 28 28

Percent change 

from alternative 1 -- -25 -25 -47 -23 -23

Crucial 

summer range 

(574,434 acres)

Total miles, all routes 1,288 508 400 649 486

Percent change 

from alternative 1 -- -100 -61 -69 -50 -62

Merriam’s Turkey

Reducing the miles of motorized routes and limiting the amount of driving off roads is likely to 

improve habitat for and lessen disturbance to Merriam’s turkey and, therefore, likely to result in 

an increasing population trend over time (table 59). The unauthorized trails proposed for addition 

to the system were selected specifically to minimize disturbance and harassment to wildlife. 

Figure 62. Rocky Mountain elk (Photo Courtesy Rocky 

Mountain Elk Foundation)
Chapter 3. Affected Environment and Environmental Consequences

202 FEIS for Travel Management on the Santa Fe National Forest

Table 59. Comparison of miles of routes and route density in Merriam’s turkey habitat by 

alternative

Alternative

1 2 2M 3 4 5

Habitat for 

Merriam’s 

turkey

Total miles, all 

routes 1,809 815 782 546 974 772

Percent change 

from alternative 1 -- -55 -57 -70 -46 -57

Reducing the places where vehicles can go would cumulatively benefit Merriam’s turkey and its 

habitat. The forest has improved turkey habitat by thinning, building wildlife drinkers, burning in 

ponderosa pine, and creating piles of slash for nesting habitat. Most of these projects have been 

less than 100 acres in size. Low intensity wildfires also benefit turkeys by creating openings. The

larger fires, on the other hand, have had a net negative effect because they tend to change the 

habitat entirely to something else. Livestock grazing is having a slight negative effect, but not 

enough to affect turkey habitat.

Figure 63. Merriam’s turkeys (Photo courtesy of 

National Wild Turkey Federation)

Migratory Birds – Affected Environment

A migratory bird spends all or part of its life in the United States. It is a nongame bird. Many 

migratory birds need active conservation measures to prevent habitat loss and reduce their 

likelihood of being listed under the Endangered Species Act. Others, like Canada geese, are 

thriving without active conservation measures. The migratory birds we consider in this report are 

listed in the New Mexico Bird Conservation Plan (NMPIF 2007) and the U.S. Fish and Wildlife 

Service’s Birds of Conservation Concern (USDI 2008). We also looked at important bird areas in 

the Santa Fe National Forest. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 203

The Santa Fe National Forest lies within the Southern 

Rockies/Colorado Plateau Bird Conservation Region

(NABCI 2007). The Southwestern willow flycatcher, 

yellow-billed cuckoo, Mexican spotted owl, and gray 

vireo are ranked high on the list of birds of conservation 

and biodiversity conservation concern in the New 

Mexico Bird Conservation Plan. Analyzing the effects of 

the action alternatives on these bird species reasonably

represents that of all the forest’s migratory birds. Thus, 

effects to these species represent the effects from all 

action alternatives to migratory birds as a whole. Please 

find the effects analysis for these four species in the 

“Threatened and Endangered” and “Sensitive Species”

sections.

The effects to migratory birds from motorized use and 

the existence of routes is consistent with the discussion 

in the section “How Routes and Vehicles Affect Wildlife.”

The forest’s important bird areas are the Chama River Gorge/Golondrina Mesa and the Caja del 

Rio Plateau. The Chama River Gorge/Golondrina important bird area is in the Chama River 

Canyon Wilderness, where no motorized use is allowed so this project will not affect it. The Caja 

del Rio Plateau lies in the southern portion of the Española Ranger District, west of the city of 

Santa Fe. The Bureau of Land Management and Santa Fe National Forest manage the land in this 

important bird area. Most of this area is open to motorized cross-country travel now.

Migratory Birds – Environmental Consequences

All action alternatives are consistent with the 1918 Migratory Bird Treaty Act and the Migratory 

Bird Executive Order 13186. Alternatives 2 through 5 would reduce the places motor vehicles 

could drive on the forest compared to alternative 1. Reducing the places where people can drive 

would improve habitat for migratory birds by reducing displacement or avoidance of otherwise 

suitable habitat. Over time, habitat quality could improve on the unused roads and trails that would 

naturally reclaim themselves with vegetation, reducing fragmentation and edge effects. The 

unauthorized trails proposed for addition would minimize disturbance and harassment to migratory 

birds when compared to alternative 1, because the location of the trails was selected to reduce such 

disturbance. The areas proposed for designation—about 40 acres or less—are immaterial when 

considered at the forestwide scale and, compared to being allowed to drive on over half the forest, 

would minimize harassment and disturbance to migratory birds.

For the reasons just described, the action alternatives would improve habitat for migratory birds 

and reduce take in the Caja del Rio Plateau important bird area. There would be no effect to the 

Chama River Gorge/Golondrina important bird area. It lies in the Chama River Canyon 

Wilderness, where motorized use is prohibited by law. None of the action alternatives changes this. 

Effects of Forest Plan Amendments on Wildlife

Proposed amendments to the “Santa Fe National Forest Plan” that restrict motorized travel in 

management areas that are currently open to it would result in no effect to wildlife resources 

Figure 64. A long-billed curlew, one 

of the Southern Rockies/Colorado 

Plateau Bird Conservation Region’s 

migratory birds (Photo Bob Gress, 

Courtesy of U.S. Fish and Wildlife 

Service)
Chapter 3. Affected Environment and Environmental Consequences

204 FEIS for Travel Management on the Santa Fe National Forest

when future management projects are implemented. These amendments will only permit crosscountry vehicular travel where authorized by the motor vehicle use map or permit and after 

analysis through the appropriate level of NEPA.

Modifications to the “Santa Fe National Forest Plan” that permit the addition of areas and 

corridors (motorized dispersed camping and motorized big game retrieval) for management areas 

currently closed to cross-country vehicular travel (Management areas J, K, M, and N) would also 

have no effect to wildlife resources when future management projects are implemented because 

these modifications specify that these additions must be consistent with the management 

emphasis for the area. Some amendments propose that designating areas or corridors in these 

management areas will be minimal. This is not expected to cause any impacts to wildlife during 

future projects because the intent of keeping these areas free of cross-country vehicles is 

preserved. Also, future projects that add areas or corridors to these management areas would be 

analyzed through the appropriate level of NEPA including affects to wildlife resources. 

Amendments in table 2 of appendix 1 specific to alternatives 4 and 5 propose to allow the 

inclusion of camping and/or motorized big game retrieval corridors in the wild and scenic river 

areas (East Fork, Rio Chama, and Pecos) and the Jemez National Recreation Area, where crosscountry use is currently prohibited. This would likely lead to an increase in cross-country use or 

establishment of new trails that would increase the amount of ground disturbance, increase 

fragmentation of wildlife habitat, and increase disturbance to wildlife species through motorized 

use. This would also likely increase the spread of weed species. This could especially have an 

effect in areas that are occupied by the Jemez Mountain salamander (East Fork Jemez and Jemez 

National Recreation Area) by facilitating removal of surface logs used by salamanders, 

compaction of soil, and turning (disturbing) surface habitat. However, future addition of areas or 

corridors would be analyzed by the appropriate level of NEPA.

All other proposed amendments not discussed specifically above (e.g., removal of lower 

thresholds for road density standards, eliminating the closures and restricted areas on the forest 

visitor map because of the motor vehicle use map, etc.) are administrative and, therefore, not 

expected to have effects on wildlife resources, so there would be no change by designating these 

routes and making them part of the system. 

Nonnative Invasive Plants – Affected Environment

This section summarizes the nonnative invasive plant specialist report, located in the project 

record (USDA Forest Service 2012g).

The Forest Service has identified the spread of invasive species as one of the four major threats to 

the Nation’s forests (http://www.fs.fed.us/projects/four-threats/). An “invasive” is defined as “a 

species that is nonnative (or alien) to the ecosystem” where found and whose “introduction is 

likely to cause economic or environmental harm or harms to human health” (Executive Order 

13112 1999). Though thousands of plants that are productively used for agricultural and 

horticultural purposes without problems have been introduced into the United States, other 

nonnative plants have become invasive. These plants severely threaten biodiversity, habitat 

quality, and ecosystem functions.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 205

Roads and trails provide pathways along which invasive, nonnative plant species can move from 

one area to another, crossing barriers that would normally stop or slow their spread. Most 

nonnative species prefer highly disturbed sites such as areas along rivers and streams, trails, 

trailheads, roadsides, building sites, wildlife bedding 

grounds, overgrazed areas, and campgrounds (Sheley 

and Petroff 1999). Russian and spotted knapweed 

(figure 65), nonnative thistles, hoary cress, and 

yellow starthistle are common examples of invasive 

plants along roads in the Santa Fe National Forest.

The public expressed this concern about nonnative 

invasive plants: 

Continued public motorized use of routes 

and areas described in the proposed action 

will adversely affect forest resources. These 

effects include the spread of invasive plant 

species.

Wind, water, livestock, wildlife, vehicles, pets, and 

human foot traffic all spread invasive plants. On the 

Santa Fe National Forest, however, the vast majority 

of nonnative invasive plants occur along roads and 

trails. The disturbed ground along roads and trails 

and in camping areas provides habitat most conducive to invasive plants. Vehicles tend to carry 

and distribute invasive weeds and their seeds farther and more easily from offsite sources. Thus, 

motor vehicle use of roads and trails would likely lead to an increase in the number and scale of 

weed populations; this effect has been well documented (Hansen and Clevenger 2005, Montana 

Department of Transportation, 2006).

To illustrate the potential spread of invasive plants from motorized use among alternatives, we 

use three measures.

Measure 1: Miles of designated routes and fixed-distance corridors traversing known 

populations of invasive species. Vehicles are more likely to transport seeds where they 

encounter existing populations. This measure shows the relative opportunity of weed spread 

from vehicles crossing existing invasive plant populations.

Measure 2: Miles of routes open to any kind of vehicle use. This shows the difference in 

potential pathways. It includes any route open to any kind of motorized use since all vehicles 

are capable of spreading invasive plants. For example, roads proposed open to highway-legal 

vehicles only—but closed to ATVs—are counted here because cars and trucks can spread 

weeds. Routes closed to motor vehicle use are not counted in this measure because they no 

longer provide pathways from vehicles for invasive species.

Measure 3: Acres of areas open to motorized cross-country travel. This measure includes 

areas and the acres in fixed-distance corridors because the latter allows limited travel off 

roads for the specific purposes of dispersed camping and retrieval of big game. Driving off 

road can spread weeds into areas where they did not previously exist, so this measure 

Figure 65. Spotted knapweed (photo 

from Noxious and Nuisance Plant 

Management Information System, 

USDA-ARS)
Chapter 3. Affected Environment and Environmental Consequences

206 FEIS for Travel Management on the Santa Fe National Forest

illustrates the potential for new populations. New user-created routes increase the risk of 

transport, introduction, and establishment of new populations of invasive species.

Nonnative Invasive Plants – Environmental Consequences

Effects Common to All Alternatives

All alternatives, because they allow people to use the forest, have the potential for new 

populations of invasive species to become established. The number of new weed populations on 

the Santa Fe National Forest tends to be greater at lower elevations and in areas with higher open 

road and trail densities. These sites are warmer, drier, and typically exhibit some level of soil 

disturbance (USDA Forest Service 2005). Table 60 displays the measures for each of the 

alternatives, and the relative change from the existing condition, alternative 1.

Table 60. Measures for invasive species analysis

Measure

Alternative

1 2 2M 3 4 5

Miles of roads and trails traversing an 

existing invasive species population 131 90 89 82 97 89

Percent change from alternative 1 -- -31 -32 -37 -26 -32

Miles of routes open to any kind of 

vehicle use 5,626 2,552 2,463 1,869 3,017 2,537

Percent change from alternative 1 -- -55 -56 -67 -46 -55

Acres where driving off road is allowed 

(area or fixed-distance corridor)*

Percent change from alternative 1

1,266,910

--

16,278

-99

13,897

-99

0

-100

1,065,440

-16

377,175

-70

*The nonnative invasive plant report, pages 5-6, provides an explanation of how the acres in this row are calculated.

The potential increase in invasive plant infestations measured here would be a direct result of 

seeds being transported along roads, trails, and areas having motorized cross-country travel. Once 

established, weed populations may spread other ways, like wind, water, livestock, wildlife, and 

humans (Center for Invasive Plant Management 2003). In the forest, many of the known invasive 

plant populations are associated with existing roads and trails, with new infestations being 

inventoried each year. We recognize risk exists for the introduction and transport of invasive 

plants through nonmotorized means, but locally, motorized use is one of the dominant 

mechanisms for weed dispersal.

The establishment of invasive species is closely associated with ground disturbance. The more 

disturbed a site, the greater the potential for establishment when a seed source is introduced. 

Areas regularly used for dispersed camping, for instance, have a high likelihood of becoming 

infested with invasive species because they tend to have extensive ground disturbance (see photos 

in the “Soil and Water” section). 

All alternatives that allow cross-country motorized vehicle use—including in fixed-distance 

corridors—would result in an increased potential for invasive species transport, introduction, and 

establishment. Fixed-distance corridors to retrieve big game are expected to have less risk of 

weed establishment as compared to dispersed camping because the use is expected to be much 

less and have minimal ground disturbance. Nonetheless, some weed populations are expected to 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 207

expand into new areas wherever motorized cross-country use is permitted. The likelihood 

associated with big game retrieval is expected to be slight because trips are limited to one time in 

and out, occur infrequently across the forest, and are seasonally limited.

All the action alternatives propose designating unauthorized routes. The potential for invasive 

species populations to establish and spread from designating unauthorized routes is the same as 

along any system route. The unauthorized routes proposed for designation, ranging from 7 to 38 

percent of those currently being used, still reduce the places where people can drive compared to 

alternative 1. 

Direct and Indirect Effects, Alternative 1

The likelihood and potential extent of weed spread from motorized vehicles is highest under 

alternative 1, the current condition. Of all the alternatives, it permits the most motorized use on 

the Santa Fe National Forest. The potential for weeds and seeds to be spread by vehicles is greater 

due to the high number of open roads and trails in this alternative. 

Not having any seasonal restriction on motorized cross-country travel may increase the potential 

for invasives to be transported into previously “clean” areas. It is not possible to predict how 

many new weed populations would be established as the result of motorized cross-country travel, 

but they would likely expand into new places. Off-highway vehicle tracks, with repeated use, can 

become established routes, which then provide habitat conducive to invasive species 

establishment. In Glacier National Park, for instance, exotic plant species showed a continuous 

distribution along road and trail corridors in the majority of study transects (Tyser and Worley 

1992). 

Cumulative Effects, Alternative 1

There would be no change in the rate of spread of weeds under alternative 1, the existing 

condition. Even with direct treatment of weeds, the cumulative effect of alternative 1 is that 

invasive plants are likely to increase in extent and number. 

Most of the past, present, and reasonably foreseeable future actions on the Santa Fe National 

Forest tend to increase the risk of new weed infestations. On the other hand, the direct treatment 

of weeds can reduce or control weed populations. Currently, the forest can treat weeds if it does a 

site-specific analysis. It is working on a forestwide environmental impact statement that will 

propose a full suite of treatment methods, including herbicides, at the forestwide scale. Weed 

control efforts by other agencies and individuals may reduce the spread of weeds by having fewer 

weeds entering the forest from adjacent properties.

Direct and Indirect Effects, Alternatives 2 Through 5

All the action alternatives are expected to reduce the risk of new weed populations being 

established, mainly by preventing motorized cross-country travel. It is not possible to precisely 

predict how many new populations of invasive species would be prevented. None of the action 

alternatives would entirely prevent the establishment and spread of invasive species because some 

level of motorized and human use of the forest would continue.

As stated earlier, motorized travel off roads results in an increased potential for invasive species 

transport, introduction, and establishment. Alternatives 2, 2M, 4, and 5 allow motorized travel off 
Chapter 3. Affected Environment and Environmental Consequences

208 FEIS for Travel Management on the Santa Fe National Forest

roads in areas for dispersed camping and retrieval of downed big game and, thus, have a higher 

likelihood of having new weed infestations. Places used for dispersed camping tend to be more 

easily infested with weeds than do access routes used for motorized big game retrieval. Camping 

areas are often highly disturbed, lack vegetation, and used frequently, whereas access routes for 

big game retrieval are not used repeatedly and tend to have minimal ground disturbance. In 

addition, motorized big game retrieval is limited to hunting season, and no seasonal restriction for 

dispersed camping exists unless the route itself is closed seasonally.

The likelihood and potential extent of weed spread from motorized vehicles would be low for 

alternative 2. The number of open roads and trails is reduced compared to alternative 1. Though it 

allows motorized cross-country travel in some areas for dispersed camping and big game 

retrieval, this use is limited in distance (150 or 300 feet from existing routes), intensity (usually 

one time in and out), and timing (big game retrieval is seasonally limited). All these restrictions

reduce the risk of transport and introduction of invasive species compared to the existing 

condition.

Under alternative 2M, the likelihood and potential extent of weed introduction and spread from 

motorized vehicles would be low compared to alternative 1. Its limitations on motorized crosscountry travel in corridors are more restrictive than those proposed in alternative 2. All corridors 

are no more than 150 feet from the edge of the road, and no vehicles are allowed within 100 feet 

of water when in corridors. This restriction is expected to reduce the potential for weed 

introduction, establishment, and spread along waterways. Limiting areas open to motorized crosscountry travel as proposed in this alternative is expected to reduce the potential for invasives to be 

transported into previously “clean” areas more than alternative 1.

Alternative 3 reduces the likelihood and potential extent of weed spread the most as compared to 

alternative 1. Overall, it would have the lowest risk of potential spread of all the action 

alternatives because it reduces the miles of designated routes the most and completely eliminates 

motorized travel off roads and trails for any purpose.

Under alternative 4, the likelihood and potential extent of weed spread from motorized vehicles is 

less than alternative 1, but more than any of the action alternatives. The amount of motorized 

travel off roads is less than alternative 1 because it is limited in space to 300-foot corridors for 

camping and 1-mile corridors for big game retrieval. The latter is also limited in time to hunting 

season, but the spatial area covered is most of the forest. Because motorized use in fixed-distance

corridors is restricted—a fixed distance from certain designated routes and only for those two 

purposes—it reduces the risk of transport and introduction of invasive species as compared to 

alternative 1.

Under alternative 5, the likelihood and potential extent of weed spread from motorized vehicles is 

less than alternative 1, and considered low to moderate overall compared to the other action 

alternatives. The amount of motorized travel off roads is less than alternative 1 because it is 

limited in space to 150- or 300-foot corridors for camping and 1-mile corridors off some main 

routes for big game retrieval. The latter is also limited in time to hunting season. Because the 

motorized use in fixed-distance corridors is restricted—a fixed distance from certain designated 

routes and only for those two purposes—it reduces the risk of transport and introduction of 

invasive species as compared to alternative 1. Because the motorized big game retrieval corridors 

in alternative 5 are limited to main routes, they cover less area than in alternative 4.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 209

Cumulative Effects, All Action Alternatives

The proposal to provide for a designated system of roads, trails, and areas for motorized use could 

offset other activities that tend to increase weed populations. Combined with direct treatment of 

weeds, the cumulative effect of any of the action alternatives is to reduce the likelihood and 

potential extent of the spread of new and existing populations of invasive species. It is unlikely 

weeds would be completely eliminated.

Most of the past, present, and reasonably foreseeable future actions on the Santa Fe National 

Forest tend to increase the risk of new weed infestations. On the other hand, the direct treatment 

of weeds can reduce or control weed populations. The forest’s ability to use a full suite of 

treatment methods is limited until a project specific environmental analysis analyzing the use of 

herbicides is finished and a decision made to authorize the use. Weed control efforts by other 

agencies and individuals may also be reducing the spread of weeds by having fewer weeds 

entering the forest from adjacent properties.

Effects of Forest Plan Amendments to Nonnative Invasive Plants

Proposed Amendments in Table 66 of Appendix 1

The proposed amendments that are administrative in nature are not expected to have effects to 

nonnative invasive species in this project or future projects. These proposed amendments, for the 

most part, simply update and provide consistent direction for the motor vehicle use map instead 

of the forest visitor map. 

The proposed amendments restricting motorized travel in management areas that are currently 

open to it travel are likely to result in beneficial effects to nonnative invasive species when this 

project is, or future projects are, implemented. Restricting the addition of corridors, unless it is 

consistent with and benefits management area direction is expected to reduce the potential for 

introduction, transport, and establishment of invasive plant infestations. These amendments 

would only allow the addition of motorized dispersed camping and big game retrieval areas to the 

motor vehicle use map if the action is consistent with management area direction and following 

an appropriate level of NEPA analysis.

Proposed amendments that authorize designation of additional areas and corridors for motorized

travel in Management Areas I, J, K, M, and N are also not expected to have effects to nonnative 

invasive species because all future actions will need to be consistent with management emphasis 

for the area in which the action is proposed, and are subject to an appropriate level of NEPA 

analysis. The emphasis for these management areas is to preserve specific high value resources 

and, therefore, future motorized designations are expected to be minimal.

Proposed Amendments in Table 67 of Appendix 1

These amendments are alternative specific, principally applying to alternatives 4 and 5, and 

propose to allow the inclusion of motorized dispersed camping corridors and motorized big game 

retrieval in the wild and scenic river areas (East Fork Jemez, Rio Chama, and Pecos) and the 

Jemez National Recreation Area, where this use is currently prohibited. For this project, these 

modifications are expected to increase the risk of transport, introduction, and establishment of 

nonnative invasive species as a result of increased ground disturbance and vehicular traffic.

Infestations of invasive plants can negatively affect the diversity of native plant communities, 
Chapter 3. Affected Environment and Environmental Consequences

210 FEIS for Travel Management on the Santa Fe National Forest

reduce the quality of habitat for wildlife species, contribute to increased soil erosion, and decrease 

the recreational quality of the landscape for outdoor enthusiasts.

The modifications to the forest plan amendments specific to alternatives 4 and 5 leave the door 

open to future additions of areas or corridors to the MVUM and, if done, would be expected to 

have similar effects to invasive plants as described above for alternatives 4 and 5. However, 

future actions and the resultant effects will be subject to disclosure in an appropriate level NEPA 

analysis.

The amendments to alternatives 2 and 2M in Management Areas H and L are not expected to 

result in measurable increased risk of transport, introduction, or establishment of invasive plants 

because they are specific to very limited routes or access to private property. Those effects were 

already analyzed for this project.

Cultural Resources – Affected Environment

This section summarizes the heritage specialist report, located in the project record (USDA Forest 

Service 2012q).

The Santa Fe National Forest has approximately 10,000 cultural resources recorded in the New 

Mexico Cultural Resources Information System database. For the analysis conducted for this 

project, the total number of sites documented in the database is 9,896 located on forest lands, and 

48 sites located on system roads outside of forest lands for a total number of 9,944 sites used in 

the analysis. The sites are widely distributed across the forest with concentrations occurring in 

certain parts of the forest

that were suitable for 

occupation (figure 66).

Between 9000 and 5000 

B.C., Paleo-Indian big

game hunters occupied 

forest lands as indicated 

by the presence of large 

projectile points and 

campsites. Around 5500 

B.C., occupation and use 

of the lands in the Santa 

Fe National Forest 

changed from PaleoIndian to Archaic 

subsistence patterns. This 

change was reflected in a 

reduced reliance on large 

game exclusively, and 

more of a reliance on 

large game combined with

use of wild plant foods 

and small game. Figure 66. Site density map of cultural resources on the Santa 

Fe National Forest
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 211

No clear transition from an Archaic lifestyle to a pueblo life way is evident. Between AD 600 and 

1300, evidence for Ancestral Pueblo use is poorly represented on the forest. By the end of the 

13th century, conditions changed radically in upland situations in the Jemez, along the Rio 

Chama, in the Pecos Valley, and in the Gallina country. During this time, the size of sites grew 

exponentially, but the number of them declined because people abandoned the small, scattered 

sites in favor of the larger communities, some with over 1,000 rooms. The mid-15th century 

represents the pinnacle of Ancestral Pueblo development on forest lands. Similar to earlier times, 

the Jemez Mesas, Pajarito Plateau, and Rio Chama drainage were the areas occupied. These 

communities continued to aggregate, grow, divide, grow again, and develop lands into the historic 

period.

Initial European settlement of areas around the forest occurred in 1598 with an expedition led by 

Don Juan de Oñate of Zacatecas, who colonized New Mexico in 1595. After 1598, the Spanish 

established mission communities and awarded land grants. The Camino Real from Mexico 

provided the lifeline between the seat of Spanish power in Mexico and the far northern frontier in 

northern New Mexico. In 1680, the pueblo populations along the Rio Grande revolted, forcing the 

Spanish to leave the area until 1692. In 1692, Don Diego de Vargas led forces back into northern 

New Mexico to reestablish the Spanish capital at Santa Fe. Pueblo communities reacted 

differently to the reconquest. Some capitulated, and others established refugee communities.

Mexican independence from Spain in 1821 meant Mexico no longer had the resources to manage 

its far northern communities. This eventually led to Spanish rule, and for Native American 

communities, the loss of any special status. Hispanic communities expanded onto tribal land and 

lands that were to become the Santa Fe National Forest. The process of granting lands increased 

and led to growth of Hispanic communities. In addition to the Camino Real, the establishment of 

trade with the United States to the east via the Santa Fe Trail and to the west via the Old Spanish 

Trail led to further commercial expansion into New Mexico.

Conflict between the United States and Mexico over trade arose. The ensuing conflict ended in 

1846 with the signing of the Treaty of Guadalupe Hidalgo, in which the territory of New Mexico 

became part of the United States. As the population grew, so did use of forest lands. In 1862, the 

Homesteading Act granted land to people, in many cases on lands that were formerly considered 

grant lands. Population growth at the beginning of the 20th century resulted in continuing 

expansion onto forest lands. In 1912, New Mexico entered the United States as the 47th state.

The Santa Fe National Forest was created from the Pecos River Forest Reserve (1892) and the 

Jemez Forest Reserve (1905) in 1915. Much of the newly formed forest consisted of land grants, 

which led to conflicts between land grant communities and forest users. Commercialization of 

forest resources, primarily timber, led to expansion of commercial enterprises on the forest.

The Forest Service also contributed to the historic record by constructing administrative sites

such as ranger district offices, lookouts, permitted recreation residences, work stations, recreation 

sites, and contact stations. Much of this built environment disappeared when locations stopped 

being used and before historic preservation laws were passed.

Much of the transportation system on the forest resulted from construction of timber sale roads 

and subsequent use by the public once sales were complete. Many of these roads follow old 

wagon roads, trails, and access ways developed by Native Americans and Hispanics. 
Chapter 3. Affected Environment and Environmental Consequences

212 FEIS for Travel Management on the Santa Fe National Forest

Few national forests have the ethnographic diversity found on the Santa Fe National Forest. 

Ethnographic use is important because forest activities could affect traditional cultural properties 

and traditional cultural practices. Native Americans have used and occupied forest land for 

millennia and, in their eyes, since “time immemorial.” Many of the archaeological sites, 

especially the large Classic Period pueblos, were the homes of modern day pueblo people’s 

ancestors. The modern pueblo communities include the Towa speakers of the Pueblo of Jemez 

living in the village of Walatowa; the Keres speakers of the modern day villages of Zia, Santo 

Domingo, and Cochiti; the Tewa speakers of the six villages in the Española Basin including

Tesuque, Pojoaque, Nambe, San Ildefonso, Santa Clara and Ohkay Owinge (San Juan); and the 

Tiwa speaking pueblos of Picuris and Taos. 

The pueblos have the strongest connection to forest lands by virtue of proximity and ties to the 

abundance of archaeological resources. The pueblo way of life is heavily tied to the landscape 

and incorporates the land into their cosmological understanding of the order of the world. Pueblo 

life is reliant on ties between sacred locations marked by trails and shrines, as well as other 

markers. They mark the landscape with prayer and ceremony and incorporate it into their daily 

lives. Many places on forest lands still retain a sense of importance and function for pueblo 

communities. Access and use of these places is essential for the continuation of pueblo life.

Nonpueblo Native American communities, including the Jicarilla Apache, Navajo, Ute Mountain 

Ute, Southern Ute, and Apache, Kiowa and Comanche Tribes, also have ancestral ties to certain 

sites and areas in the forest. Sites associated with these groups tend to be lower in number 

because they came to the area later and didn’t supplant the existing ancestral pueblo populations.

They may have trails and shrines, but the association with their larger life way does not match 

that of the pueblos.

Hispanic communities adjacent to and surrounded by the forest have strong ties to the land,

primarily as a resource base. Lands that were once land grants still provide firewood and other 

plant resources for those communities. The ancestors of these communities lived by extracting 

timber, game, and subsistence and medicinal resources from forest lands.

In summary, the Santa Fe National Forest “...embraces and, in turn, is surrounded by lands 

within the traditional use areas of many of the Native American and Hispanic communities of 

northern New Mexico.” (Levine 1996:349). 

Three concerns related to cultural resources came up during the scoping period:

1. Motorized use of the forest could damage cultural resource sites.

2. Motorized use of the forest could damage traditional cultural properties.

3. Reducing the miles of designated routes could restrict access to traditional cultural 

properties.

Regulatory Background for Cultural Resource Sites

Section 106 of the National Historic Preservation Act requires Federal agencies to take into 

account the effects of their undertakings on historic properties. Designating certain roads, trails, 

areas, and fixed-distance corridors is considered an undertaking. To help the Forest Service 

determine which kinds of designations are undertakings, the Southwestern Region of the Forest 

Service negotiated a “Standard Consultation Protocol for Travel Management Route Designation” 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 213

with State Historic Preservation 

Officers from Arizona, New 

Mexico, Oklahoma, and Texas. The 

protocol exempts some 

undertakings from review and 

consultation under Section 106. 

Examples of the exemptions 

include designating existing open 

National Forest System routes, 

designating existing fixed-distance 

corridors, allowing parking next to 

a road, and continuing 

authorizations covered by other 

NEPA decisions. The reason is that 

any detrimental effects have 

already occurred (figure 67).

Proposing to allow motorized use 

on roads currently closed to it, 

adding unauthorized routes to the 

system, and designating new fixeddistance corridors or areas does

require consultation under Section 106. 

A separate report documenting the inventory, evaluation, and resolution of effects to cultural 

resources to meet the requirements of Section 106 of the National Historic Preservation Act has 

been prepared and submitted to the New Mexico State Preservation Officer, who concurred with 

the forest’s findings on May 16, 2012. This completes the first phase of survey and clearance; the 

protocol allows subsequent phasing. Only routes and areas meeting the requirements of Section 

106, as articulated in the protocol, will be posted to the map.

Potential Damage to Cultural Resource Sites

The Santa Fe National Forest defines a cultural resource site as “a location of purposeful 

prehistoric or historic human activity [resulting in] a deposit of cultural materials beyond the level 

of one or a few accidentally lost artifacts.” In practical terms, this means a cultural resource site 

can range from an old pueblo building, an old homestead, rusted tin cans, or broken pot shards 

and arrowheads scattered over the ground. Forest personnel have records for 9,944 cultural 

resource sites in and near the forest.

The wheels of vehicles can displace small artifacts located on the ground’s surface. Repeated use 

of a route or area removes its vegetation, which can accelerate the erosion and displace and 

damage artifacts. Vehicles transporting people to and around the forest can indirectly cause 

damage to cultural resource sites. For example, people may inadvertently damage sites while 

camping (figure 68). In other cases, damage appears to be intentional (figure 69).

Figure 67. Rubble from a collapsed ancestral pueblo 

field house, damaged by past road construction and 

use, Jemez district. All archaeological deposits within 

the road have already been displaced or destroyed by 

past road construction and use.
Chapter 3. Affected Environment and Environmental Consequences

214 FEIS for Travel Management on the Santa Fe National Forest

Figure 68. Fire ring in a dispersed camping area constructed from 

the foundation stones of an early 20th century cabin, Pecos/Las 

Vegas district. Foundation is visible in shadows behind the fire 

ring

Figure 69. Early 20th century Forest Service administrative building 

near a dispersed camping area, painted with graffiti, Española 

Ranger District 

Under alternative 1, the places on the Santa Fe National Forest where damage to cultural resource 

sites could occur are unauthorized routes, closed roads being proposed open for motorized use, 

fixed-distance corridors for motorized access to dispersed camping, and areas open to motorized 

cross-country use. Table 61 depicts the number of sites existing at each of these locations. 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 215

Table 61. Number of cultural resource sites that could be damaged through vehicle use 

under the existing condition, alternative 1

Location of Cultural Resource Site Number of Sites 

at Risk 

Percent of All 

Known Sites

Acreage of Sites 

at Risk

Within an unauthorized or closed route 147 1 less than 4

In a fixed-distance corridor for motorized 

dispersed camping 439 4 541

In places currently being used for 

motorized cross-country travel 4,459 45 7,995

Potential Damage to Traditional Cultural Properties

A traditional cultural property “... can be defined generally as one that is eligible for inclusion in 

the National Register because of its association with cultural practices or beliefs of a living 

community that (a) are rooted in that community’s history, and (b) are important in maintaining 

the continuing cultural identity of the community.” Examples of traditional cultural properties are 

trails used by the penitentés for ceremonial purposes, or sacred sites used by tribes and pueblos.

Vehicles may physically damage traditional cultural properties with their wheels or by causing

erosion. An indirect way that vehicles cause damage is by transporting people to traditional 

cultural properties. Sometimes people who do not know about the importance of a traditional 

cultural property damage them or intrude on them. 

The traditional cultural properties identified in this analysis came from those provided to forest 

heritage staff during other projects. No traditional cultural properties were identified during 

scoping conducted for this project, although effects to traditional cultural properties were 

identified as an issue. Twenty-three traditional cultural properties are documented on or near the 

Santa Fe National Forest, and the physical manifestation of each one varies in location, physical 

appearance, and association with traditional use. For instance, at some the presence of “outsiders” 

can disrupt traditional use, while at others the presence of outsiders is irrelevant. Because of this 

variability, and based on their experience in prior consultation with traditional and indigenous 

communities, forest heritage specialists evaluated the documentation for each recorded traditional 

cultural property and judged whether it would be at risk (table 62). This total is not expected to be 

a complete inventory of all traditional cultural properties on the forest, but represents those 

documented up to the date of this analysis.

Table 62. Number of traditional cultural properties that could be damaged through vehicle 

use under the existing condition, alternative 1

Location of Traditional Cultural Property Number at Risk Percent at Risk

Within an unauthorized or closed route, in a fixed-distance corridor for 

motorized dispersed camping, or in a place where motorized crosscountry travel is happening

11 48

Close to any of the above so that unwanted disturbance by outsiders is 

a possibility

13 57
Chapter 3. Affected Environment and Environmental Consequences

216 FEIS for Travel Management on the Santa Fe National Forest

Access to Traditional Cultural Properties

Under the current designated system, people have nearly unlimited motorized access to traditional 

cultural properties.

Cultural Resources – Environmental Consequences

Direct and Indirect Effects, Alternative 1

Potential Damage to Cultural Resource Sites and Traditional Cultural Properties

Motorized use of the Santa Fe National Forest under alternative 1 risks damaging or disturbing 

the sites (or participants at sites) listed in table 61 and table 62 by potentially causing rutting, 

erosion and surface disturbance, or indirectly leading to site deterioration from vandalism.

In table 61, a higher number of sites or acreage is not equivalent to a greater amount of damage. 

Damage depends on the location of the site relative to the motorized use. Unauthorized routes 

may skirt the corner of a site or go through the middle of one. Fixed-distance corridors for 

motorized dispersed camping have a wider footprint (150 or 300 feet from either side of the road)

and are, thus, more likely to contain entire sites within their boundary. Sites within motorized 

dispersed camping corridors are also more likely to be disturbed since the entire site tends to be 

accessible to campers (figure 68). The potential for damage to sites in places being used for 

motorized cross-country travel is not uniform because motorized travel in them is not uniform.

Table 62 shows 11 traditional cultural properties falling completely or partially within places 

where motorized cross-country travel occurs. Unauthorized routes cross three of these, and two 

are located partially within motorized dispersed camping corridors. As with cultural resource 

sites, traditional cultural properties located where motorized cross-country travel occurs are not 

uniformly impacted by vehicles because use in the areas is not uniform. In some cases, overall 

impacts in cross-country areas may be less than that in unauthorized routes or motorized 

dispersed camping corridors.

Access to Traditional Cultural Properties

Two properties may not have sufficient motorized access under the current condition. Otherwise, 

with few restrictions on motorized use, people are able to get to the forest’s known traditional 

cultural properties with vehicles.

Cumulative Effects, Alternative 1

The direct and indirect effect of alternative 1 is that cultural resource sites and traditional cultural 

properties risk being damaged by the use and existence of roads and areas. The past, present, and 

reasonably foreseeable future management actions are not anticipated to cause cumulatively more

adverse effects on cultural resources because the activities proposed will result in determinations 

of “no historic properties affected” or “no adverse effect.” Cultural resources are always avoided 

or mitigated in management activities proposed by the forest. Natural disturbances, however, such 

as the Las Conchas Fire and subsequent flooding, could cumulatively result in irretrievable losses 

of cultural resource sites.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 217

Direct and Indirect Effects, Alternatives 2 Through 5

Potential Damage to Cultural Resource Sites and Traditional Cultural Properties

The potential for damage to cultural resource sites or traditional cultural properties is almost none

under any of the action alternatives because effects to sites would be mitigated, or sites would be 

avoided (see “Mitigations” section in chapter 2). The change from the current condition would be 

a 100 percent reduction in risk of damage to cultural resource sites and traditional cultural 

properties because motorized travel would be restricted to routes and corridors that have heritage 

clearance. Designating unauthorized routes would not damage any cultural resources because 

sites wouldn’t be placed on the motor vehicle use map unless they were reviewed and consulted 

on under Section 106.

Motorized big game retrieval is considered an undertaking that does not have the potential to 

affect cultural resources (amended PA, appendix A, sections IIA, O, P and Q). Santa Fe National 

Forest archaeologists have determined that motorized big game retrieval does not pose a threat to 

either type of site. This activity is similar in its spatial extent and impact to districtwide or 

areawide personal use firewood collection. It has been programmatically determined that there 

are no substantial impacts to cultural resource sites from personal use districtwide or areawide 

firewood collection (USDA Forest Service and State Historic Preservation Offices, 2007,

appendix A, II, P). Because motorized big game retrieval is similar in impact and is much less in 

yearly occurrence than districtwide or areawide firewood permits, it is reasonable to assume that 

there would be no substantial impact to cultural resource sites from motorized big game retrieval. 

Therefore, there would be no differences in potential impacts between alternatives. 

Access to Traditional Cultural Properties

No effect on access to traditional cultural properties exists because the Santa Fe National Forest 

would issue permits to those who require motorized access. This means there would be no change 

from the current condition because people who need to would continue to be able to drive to 

traditional cultural properties. If inadequate access exists now, alternatives 2 through 5 would not 

improve it because no new routes are proposed for construction.

Cumulative Effects, Alternatives 2 Through 5

Because alternatives 2 through 5 are anticipated to have no effect to cultural resources, there 

would be no cumulative effects. 

Effects of Forest Plan Amendments to Cultural Resources

Management Areas I, P, Q and R in the forest plan contain management emphasis specific to 

cultural resources. None of the plan amendments will alter the management emphasis of these 

areas.

Proposed amendments that are administrative in nature (e.g. removal of lower thresholds for road 

density standards, eliminating the closures and restricted areas on the forest visitor map because 

of the motor vehicle use map, etc.) will have no effect on cultural resources.

Proposed amendments in table 65 restricting off-highway vehicle travel in management areas 

currently open to it will not adversely affect cultural resources when future projects are 

implemented (specifically Management Areas P, Q, and R for cultural resources). These 
Chapter 3. Affected Environment and Environmental Consequences

218 FEIS for Travel Management on the Santa Fe National Forest

amendments will only permit cross-country travel where authorized by the motor vehicle use map

or permit, after appropriate NEPA analysis and completion of the Section 106 process. The 

Section 106 process will account for disturbances of known cultural resources including 

archaeological sites and traditional cultural properties (TCPs). Restricting motorized travel may 

have beneficial effects in terms of reducing exposure of cultural resources to motorized travel.

Proposed amendments in table 65 authorizing designation of areas and corridors (specifically 

Management Area I for cultural resources) currently closed to cross-country motorized travel will 

not adversely affect cultural resources because the plan still specifies modifications must be 

consistent with the management direction of the area. The presence of areas and fixed-distance 

corridors are not, by definition, incompatible with the management direction and consultation 

associated with the Section 106 process and completion of appropriate NEPA analysis will result 

in no adverse effects to cultural resources. These amendments also are consistent with current 

management and land use.

Proposed amendments in table 66—specific to alternatives 4 and 5 authorizing the addition of 

motorized dispersed camping and big game retrieval corridors, specifically in the wild and scenic 

rivers and Jemez National Recreation Area—may lead to an increase in cross-country use or 

establishment of new trails which will result in ground disturbance that has the potential to 

adversely affect cultural resources. However, additions of areas or fixed-distance corridors would 

receive an appropriate level of NEPA analysis and completion of the Section 106 process.

Completion of NEPA and Section 106 will result in cultural resources not being adversely 

affected or adverse effects will be mitigated prior to implementation.

Air Quality – Affected Environment

This section on air quality summarizes the report “Air Quality” located in the project record 

(USDA Forest Service 2012c).

The public expressed this concern about air quality:

“Motorized travel causes fugitive dust and vehicle emissions that are harmful to 

human health and contribute to climate change.”

The Forest Service also considered how dust and emissions caused by vehicles could affect 

visibility in Class I areas in and adjacent to the forest.

Vehicles driving on unpaved roads and trails stir up dust as well as produce tailpipe emissions. In 

addition, disturbed soil such as the existing unpaved road network on the forest also produces 

dust as a result of wind erosion. Dust, whether caused by vehicles or wind, contributes particulate 

matter (PM) to the atmosphere. Roads and trails also act as corridors for vehicles’ emissions, 

which contain pollutants like carbon monoxide (CO), nitrogen oxide (NO and NO2, referred to as 

NOx), and volatile organic compounds (VOCs).

Ideally, direct measurements of air quality data in high traffic areas near the forest would be 

available to truly assess air quality conditions on the forest. Alternately, traffic counts, vehicle 

miles traveled, or average vehicle speed on the forest could all be used to characterize dust, 

particulate matter, and tailpipe emissions at a local level. These data, however, aren’t sufficiently 

available to characterize dust or emissions from the forest. Monitoring air quality and directly 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 219

measuring dust and tailpipe emissions on all forest routes is neither practical nor economically 

feasible. 

Lacking direct measurements, traffic counts, and other parameters in the forest, we analyzed air 

quality data from outside the forest. We also reviewed “nonattainment” and “maintenance” areas 

under the Clean Air Act’s National Ambient Air Quality Standards. Regional haze conditions near 

the forest’s Class I areas were evaluated using a model called IMPROVE

(http://views.cira.colostate.edu/web/), and populated with data from San Pedro Parks Wilderness 

and Bandelier National Monument. Finally, to understand traffic patterns, we compared the New 

Mexico Department of Transportation’s traffic count data from 2006 on roads near the forest to 

known traffic loads in the forest.

All vehicles pollute the air with NOx, CO, and VOCs. The Environmental Protection Agency 

found that an unregulated recreational vehicle with a two-stroke engine can cause as much 

pollution as 20 automobiles. On dirt roads and trails, all vehicles raise dust if conditions are right. 

Silty soils cause the most dust. 

The volume of traffic on the Santa Fe National Forest contributes a minor source of dust and 

vehicle emissions when compared to the surrounding urban centers and travel corridors outside 

the forest, which include Santa Fe, Albuquerque, Española, Los Alamos, and Pecos, along with 

State Highway 285 and Interstate 25. Traffic counts on routes in the Santa Fe National Forest 

show that highly used roads have less than 200 vehicles per day. Many forest roads have one 

vehicle or less per day. For comparison, about 2,600 vehicles drive through the village of Jemez 

Springs per day and the average daily traffic on Interstate 25 between Santa Fe and Albuquerque 

for the last 3 years is approximately 18,300 vehicles (New Mexico Department of Transportation 

2009).

Air Quality

Air quality in New Mexico, as measured by criteria pollutants, regional haze, and visibility, is 

good compared to other states. The exceptions are Bernalillo County, Albuquerque, and El Paso. 

Most impacts to air quality in the forest originate elsewhere, from sources like oil and gas 

development and electric power generation in the San Juan basin. These sources contribute to 

ozone and regional haze. The urban transportation networks of Santa Fe, Albuquerque, Española, 

and Los Alamos and Highway 285 and I-25 can impact air quality in the forest. Typically, 

wildfires cause the worst air quality in the region for several months in the summer. Despite these 

sources, monitoring data show that air quality in and near the forest is good. For 2011, the EPA 

classified all counties in and adjacent to the forest as being in attainment of air quality standards 

(U.S. Environmental Protection Agency 2011).

No air quality monitoring stations exist in the forest itself. The city of Santa Fe, however, is often 

cited for its excellent air quality. For instance, the World Health Organization cited it—out of 

1,100 cities in 91 countries—as having some of the lowest concentrations of particulate matter 

(WHO 2011). The amounts of PM10 and PM2.5 are far below national standards and, thus,

representative of very good air quality (table 63 and table 64). 
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220 FEIS for Travel Management on the Santa Fe National Forest

Table 63. Maximum concentrations of PM10 monitored near the Santa 

Fe National Forest

PM10 24 Hour Standard = 150 ug/m3

Year Bernalillo Jemez Pueblo Santa Fe

2008 31 145 25

2009 45 82 33

2010 22 84 36

2011 62 ND ND

Source: EPA 2011a

Table 64. Maximum concentrations of PM2.5 monitored near the Santa Fe National Forest

PM2.5

24 Hour Standard (98th percentile) = 35 ug/m3 Annual Standard = 15 ug/m3

Rio Rancho Jemez Pueblo Santa Fe Rio Rancho Santa Fe

2008 10.1 72.4 7 4.32 3.15

2009 10 32.4 6.7 3.75 2.68

2010 ND 19.2 6 ND 2.93

Source: EPA 2011a

Albuquerque represents an urban setting rather than that typical of the Santa Fe National Forest, 

so it wasn’t included in the tables above.

Health

Emissions and dust compose the two main sources of air pollution from vehicles in the forest. 

Emissions commonly thought to impact human health include nitrogen oxides, carbon monoxide, 

volatile organic compounds, and particulate matter. Dust is composed of particulate matter. The 

finest particulate matter, called PM2.5, if embedded in people’s lungs, can cause premature death 

from heart or lung disease. To cause health problems, people must be exposed regularly to high 

concentrations of these pollutants and dust. Forest personnel have no data on whether these 

pollutants or dust has caused people to have health problems. Monitoring data, however, near the 

forest show low levels of these pollutants—at levels public health officials consider to be good. 

We consider the amount of traffic on the Santa Fe National Forest to be low, so the amount of 

vehicle emissions and dust generated is also low. For example, the kinds of duststorms seen 

blowing across Albuquerque in May are extremely rare in our forested setting. Trees block wind 

that carries dust. 

Greenhouse Gases

All vehicles emit greenhouse gases that contribute to global warming. Information to quantify the 

amount of emissions, such as actual miles driven, from the Santa Fe National Forest does not 

exist.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 221

Visibility

The forest contains two Class I areas, the Pecos Wilderness and San Pedro Parks Wilderness. 

Bandelier National Monument, which is adjacent to the forest, is also a Class 1 Area. San Pedro 

Parks and Bandelier are expected to meet their Class I area visibility goals based on monitoring 

data so far. The two visibility monitors located in San Pedro Parks and Bandelier—because of 

their proximity—are also used to assess visibility in the Pecos Wilderness.

Under the 1999 Regional Haze Rule, the EPA set a goal of restoring visibility to “natural 

conditions” at 156 national parks and wilderness areas by 2064. “Natural conditions” refers to 

what visibility should be without anthropogenic influence. Based on monitoring data from San 

Pedro Parks and Bandelier, visibility is impaired when compared to natural conditions. Electric 

utilities and oil and gas development from the four corners area contribute the most pollutants 

that impair visibility. The fraction of pollution attributed to dust is relatively small and is not 

viewed as a significant issue at these two sites.

New Mexico is required to have a state implementation plan to meet the 2064 visibility goals.

Due to the amount of planning and potential regulations that the State or EPA may have to impose 

on industry, the State is not expected to attain the 2064 goals in the next few years. It must, 

though, show progress toward the 2064 goal. Based on the last decade, visibility has improved at 

Bandelier and San Pedro Parks. If visibility continues to improve at the current rate, the State will 

meet the visibility goals by 2064.

Air Quality - Environmental Consequences

Direct and Indirect Effects, Alternative 1

Air Quality

Traffic in the forest contributes a minor source of fugitive dust and tailpipe emissions within 

airsheds that include the urban transportation network of Santa Fe, Albuquerque, Espanola, Los 

Alamos, and Pecos, as well as Highway 285 and I-25. Given this context, discernible changes to 

air quality as a result of current conditions is negligible.

Health

Alternative 1, which is where people drive now, has the most miles of unpaved roads and trails. 

As noted in the “Affected Environment” section, however, we consider the amount of vehicle 

emissions and dust raised now to be very low. We do not have data on whether anybody has 

health problems from vehicle emissions or dust caused by driving in the forest, though monitored 

data near the forest shows very low levels of these pollutants, at levels public health officials 

consider to be good.

Greenhouse Gases

We predict that the forest’s contribution to greenhouse gases from vehicles is negligible now, and 

would continue to be negligible under alternative 1. The number of vehicles driving in the 

national forest is an extremely small part of the daily traffic in the surrounding area.
Chapter 3. Affected Environment and Environmental Consequences

222 FEIS for Travel Management on the Santa Fe National Forest

Visibility

Visibility in the forest’s Class 1 areas is on track to meet future goals, and vehicular emissions 

and fugitive dust from the forest is not a significant contributor to visibility impairment on the 

forest.

Direct and Indirect Effects, Alternatives 2 Through 5

Air Quality

Alternatives 2 through 5 reduce the miles of unpaved routes that people could drive on.

Alternative 3 reduces it the most; alternative 4 the least. 

Where dust and emissions go varies greatly with weather, topography, and road condition. All the 

alternatives reduce the mileage of unpaved routes, but saying that dust and emissions would also 

decrease may not be accurate. A dry, windy summer coupled with a lot of visitors might cause a 

lot of dust and pollution under any of the alternatives. Conversely, the proposed closures for wet 

weather would have no effect because no dust rises from mud.

We can say that having fewer unpaved routes available for motorized use would reduce the 

locations where dust and emissions from vehicles occur. Not allowing motorized cross-country 

travel would decrease the amount of dust and locations in which it could be generated by 

eliminating the potential for new unauthorized routes. New routes increase the chance of dust by 

removing vegetation and lowering the threshold at which particles become airborne (Goosens and 

Buck, 2008). 

All action alternatives reduce the miles of unpaved soil surfaces in the vicinity of Class 1 areas 

that could be driven on. This should reduce the places where fugitive dust from vehicles arises

and, in turn, result in a benefit to air quality near San Pedro Park Wilderness, Pecos Wilderness, 

and Bandelier National Monument. Similar air quality benefits would be expected near Dome 

Wilderness and Chama River Canyon Wilderness.

Because we assume the amount of motorized use would be the same under the action alternatives 

(assumption 1), no change in total emissions of pollutants from vehicles, or the dust they cause 

would occur on the forest and the vehicular network will remain in place. As such there is no 

significant distinction between alternatives at the forest level.

Health

The effect of any of the action alternatives on people’s health is difficult to predict, though it is 

expected that there are negligible differences between alternatives in terms of air quality impacts 

to human health. The amount of vehicle emissions and dust generated is not expected to change, 

and is very low now. Whether people are affected depends on how often they breathe dust, which 

we cannot predict in this analysis. The fate and transport of dust and tailpipe emissions on any 

day will be highly variable for all alternatives, contingent on weather and actual travel. It can be 

assumed that some level of nuisance exposure to fugitive dust or tailpipe emissions is possible 

under all alternatives. Any direct or indirect dose-response effect to people from forest travel is 

difficult to isolate and identify, but is expected to be negligible.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 223

Greenhouse Gases

Because we assumed that the amount of motorized use of the Santa Fe National Forest would not 

change, the amount of greenhouse gases emitted by vehicles in the forest would also not change. 

We predict that the forest’s contribution to greenhouse gas emissions from vehicles is negligible 

now, and would continue to be negligible under alternatives 2 through 5. The number of vehicles 

driving in the national forest is an extremely small part of the daily traffic in the area.

Greenhouse gas emissions from vehicles used in the forest may be more influenced by Federal 

regulatory restrictions on mobile sources of air pollution as well as market penetration and 

adoption of less polluting, four-stroke engines for recreational vehicles. 

Visibility

Visibility in the forest’s Class 1 areas is on track to meet future goals, and vehicular emissions 

and fugitive dust from the forest is not a significant contributor to visibility impairment on the 

forest. As a result any change would likely not be noticeable since the forest’s overall contribution 

to air pollution is already small. There is no significant distinction between alternatives at the 

forest level with regards to visibility.

Cumulative Effects, All Alternatives

Air Quality

Because no change in air quality is expected as a result of the alternatives, there would be no 

cumulative effects to air quality.

Health

We don’t know how many people have health problems caused by vehicle emissions or dust, so 

we can’t make a prediction about how other actions would cumulatively affect people’s health. 

Many other factors, like diet and lifestyle, play into a person’s health. In addition, most of the air 

pollution in the forest comes from activities that occur off the forest, including dust. Monitoring 

data from sites near the forest shows that all pollution in and near the forest is at very low levels, 

at levels public health officials consider to be good.

Greenhouse Gases

The greenhouse gases emitted under any alternative would be negligible. Keeping or changing the 

Santa Fe National Forest’s current designated route system would make no difference since it 

would not change the amount of motorized use.

Visibility

None of the alternatives would cause a cumulative effect on visibility. Alternative 1 would result 

in no change in visibility, so there would be no cumulative effect. Alternatives 2 through 5 could 

improve the visibility of Class I areas, but to such a small degree as to not be noticeable.
Chapter 3. Affected Environment and Environmental Consequences

224 FEIS for Travel Management on the Santa Fe National Forest

Effects of Forest Plan Amendments to Air Quality

Modifying the forest plan with the amendments in appendix 1 would have no significant effects 

to air quality at the forest level as a result of this project and future projects.

Proposed amendments in table 65 of appendix 1 are administrative in nature, restrict off-highway 

vehicle travel in management areas that are currently open to it, or authorize designation of 

additional areas and corridors for motorized travel in Management Areas C, D I, J, K, M, and N. 

These amendments simply update and provide consistent direction for the motor vehicle use map, 

or only allow the addition of areas, motorized dispersed camping, and big game retrieval areas to 

the motor vehicle use map if the action is consistent with management area direction in the 

current forest plan, so none of the amendments are expected to have effects to air quality at the 

forest level as a result of this project or future projects.

Proposed amendments in table 66 of appendix 1 are alternative specific and either (1) propose, 

principally in alternatives 4 and 5 to allow the inclusion of motorized dispersed camping corridors 

and motorized big game retrieval in the wild and scenic river areas (East Fork, Rio Chama, and 

Pecos) and the Jemez National Recreation Area, where this use is currently prohibited or (2) 

allow for motorized use on specifically identified routes, principally in Management Areas H and 

L. For this project, these modifications may have small impacts to air quality locally, but will 

have no effect to air quality at the forest level as a result of increased ground disturbance and 

vehicular traffic.

Wildfires - Affected Environment

This section summarizes the wildfire report located in the project record (USDA Forest Service 

2012f).

People raised these two concerns about wildfires:

1. Closing routes to motorized use increases the chance of having larger wildfires because it 

would take longer for firefighters to get to them.

2. Motorized use of the forest increases the risk of wildfires caused by peoples’ activities.

Firefighters’ Response Time: The time it takes firefighters 

to get to wildfires varies greatly depending on the fire’s 

location. Firefighters can easily drive to abandoned 

campfires in Forest Service campgrounds, for example, since 

the roads to and in campgrounds are usually in good 

condition. On the other hand, they must hike or fly to fires 

located in a wilderness area. Driving and flying to fires tends 

to be quicker than hiking, but again that depends on how far 

away the fire is from a staging area. The Travel Management 

Rule exempts firefighters from motorized designations when 

responding to wildfires.

Number and Causes of Wildfires: Lightning and people 

caused all of the wildfires on the Santa Fe National Forest 

during the last 10 years (table 65). Lightning accounted for 

From 2000 to 2010:

• Number of human-caused 

wildfires started within 300 feet 

of all existing roads: 525

• Percent that were campfires: 90

• Number of human-caused 

wildfires in alternative 1

camping corridors: 12

• Number of human-caused 

wildfires started in areas where 

motorized cross-country travel 

is allowed: 201

• Percent of human-caused 

wildfires from campfires: 61
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 225

83 percent of all the wildfires, and people the remaining 17 percent. A variety of human activities 

contributed to the wildfires, but campfires caused the most by a wide margin.

At least one study documents that off-highway vehicles can directly cause wildfires when grasses 

and forest litter come in contact with hot exhaust systems, exhaust, and hot manifolds for an 

extended period of time (Baxter 2002). This study, however, does not examine the probability of 

ignition over a wide range of conditions, and forest fuels only catch fire in very specific 

conditions.

Vehicles indirectly aid in starting wildfires by transporting people to and around the forest. 

Campfires compose the main source of all human-caused wildfires in the last 10 years. Arson, 

downed power lines, chain saws, and smoking also contributed. Santa Fe National Forest fire 

personnel have not documented any instances where a vehicle’s exhaust system has directly 

caused a wildfire. We do not collect data on whether vehicles were indirectly associated with the 

cause of a wildfire. For example, we can’t determine the number of wildfires that hunters 

retrieving their downed game caused, because it would have been attributed to smoking or a 

campfire.

Table 65. Summary of number and causes of wildfires in the Santa Fe 

National Forest, 2000–2010

Cause

Total Number of 

Recorded Wildfires, 

2000–2010

Percent of Total 

Wildfires

2000–2010

Lightning 1,409 83

All human caused 284 17

Fires caused by campfires only 173 10

Wildfires - Environmental Consequences

Direct and Indirect Effects, Alternative 1

Firefighters’ Response Time – With no change in the designated route system, firefighters are 

expected to get to fires in the same amount of time as they do now. As just described, this varies 

depending on the location of the fire.

Number and Causes of Wildfires – The wildfires caused by people would remain the same as 

shown in table 65 because motorized use of the forest would not change.

Cumulative Effects, Alternative 1

Because no change in response time or the numbers and causes of wildfires is expected under 

alternative 1, there would be no cumulative effect.

Direct and Indirect Effects, All Action Alternatives

Firefighter’s Response Time – The time it takes for firefighters to arrive at a fire could slightly 

increase, slightly decrease, or remain the same. It could increase slightly if the routes closed to

motorized use become impassable by engines over time due to vegetation or severe erosion from 

lack of maintenance. This, however, could be offset by the other means, like helicopters, that
Chapter 3. Affected Environment and Environmental Consequences

226 FEIS for Travel Management on the Santa Fe National Forest

firefighters have to get to fires. Should the condition of routes closed to motorized use remain the 

same, there would be no change in response time because vehicles responding to emergencies 

like wildfires are exempt from the designations under the Travel Management Rule. With 

improved maintenance on routes open to motorized use, firefighters could conceivably get to 

wildfires more quickly.

Number and Causes of Wildfires – No change in wildfires caused by lightning is expected as a 

result of having a designated system of roads, trails, and areas because lightning is a natural 

event. No change in the number of human-caused fires associated with exempted uses, like 

woodcutting with a permit, would occur unless fewer permits were issued, or the restrictions on 

driving written into permits increase.

For alternatives 2 through 5, it is likely that campfires would continue to be the main source of 

human-caused fires since the amount of camping on the national forest overall is not expected to 

change. This project reduces where people can drive to camp, but doesn’t restrict their ability to 

camp.

For alternatives 2 through 5, with the prohibition on motorized cross-country travel, we expect to 

see a small decrease in the number of human-caused fires away from routes since some people 

will no longer drive off road, and some places that had been accessible with a vehicle will no 

longer be. If people park next to the road and go into the back country on foot, the number of 

human-caused wildfires could remain the same, but there is no way to predict how many people 

will forfeit a visit because they can’t drive, or how many would choose to walk into the back

country. Adding unauthorized routes to the system could slightly increase the risk of humancaused wildfires nearby. Since the unauthorized routes are already being driven on, we think the 

risk is smaller than if the area had been previously inaccessible.

No change from alternative 1 in the number of wildfires caused by campfires in the fixed-distance 

corridors is expected for any of the action alternatives. The proposed corridors in all the action 

alternatives capture most of the existing motorized dispersed camping, which is not expected to 

change even if people need to walk their gear to a campsite.

The number of wildfires caused by hunters retrieving game is not known, but is expected to be 

very small since no fires have been attributed directly to a vehicle, and less than 2 percent to 

smoking and equipment combined. Since the number of trips to retrieve game is not expected to 

vary enough among the alternatives (even alternative 3, where someone might walk in) to be 

material, there would be no change in the number of potential wildfires caused by motorized big 

game retrieval.

Cumulative Effects, All Action Alternatives

The time it takes for firefighters to get to a fire is not expected to change enough to be substantial, 

so there would be no cumulative effects.

We expect a slight reduction in the number of human-caused wildfires from the prohibition on 

motorized cross-country travel. Combined with the forest’s other prevention efforts like thinning 

and prescribed burning and education campaigns such as Smokey Bear, there could be a 

cumulative reduction in human-caused wildfires for all the action alternatives. Because, however, 

lightning causes most of the wildfires, the overall reduction in the number of wildfires on an 

annual basis would probably not be noticeable.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 227

Past, present, and reasonably foreseeable future actions that could cumulatively offset any 

reduction in wildfire starts caused by the action alternatives are: construction, reconstruction, and 

maintenance of roads and developed recreational sites; subdivision and development of private 

property including mining claims; and technological advances in off-highway vehicles. 

Effects of Forest Plan Amendments to Wildfires

The proposed amendments in table 65 of appendix 1 are not expected to have an effect on 

wildfire starts. The administrative amendments simply update and provide consistent direction. 

Future designations of motorized areas or corridors for Management Areas I, J, K, M, and N are 

expected to be minimal because of management emphasis to protect specific high value 

resources. Further, any additional designations will be subject to the appropriate level of NEPA.

The proposed amendments to include motorized dispersed camping and motorized big game 

retrieval corridors in wild and scenic river areas (East Fork Jemez, Rio Chama, and Pecos) and 

the Jemez National Recreation Area, where this use is currently not allowed, apply to alternatives 

4 and 5. The amendments allowing motorized dispersed camping and motorized big game 

retrieval corridors may increase the risk of wildfire starts because they allow for the designation 

of additional motorized corridors in the future. Any increase in motorized dispersed camping and 

motorized big game retrieval would increase the amount of access in these places, which may 

lead to an increased risk of wildfire starts from things like campfires. The amendments allowing 

motorized use along the small number of roads and trails under special use authorization or where 

use is believed to be important to continue to allow are not expected to affect wildfire starts 

because motorized use along those routes is infrequent.

Visual Quality - Affected Environment

The full text of this section is located in the project record in the report called “Visual Quality” 

(USDA Forest Service 2012j).

The Santa Fe National Forest routinely considers a project’s effects on visual quality. The 

interdisciplinary team wrote this concern:

“Closing routes to motorized use could affect visual quality.”

A forest’s visual quality combines its scenic attractiveness with the public’s visual expectations. 

Scenic attractiveness could be a view of the mountains, a stream draped over boulders, a 

waterfall, or a meadow full of wildflowers. The public expects to see natural things like these in a 

forest, rather than ATMs, traffic lights, strip malls, or anything else commonly found in cities.

The number of scenic places in the Santa Fe National Forest attests to the importance of its visual 

quality: two scenic byways, three research natural areas, a national recreation area, four 

wilderness areas, and three wild and scenic rivers. In 2008, the National Visitor Use Monitoring 

Survey showed that two of the top five recreational activities was looking at scenery.

The distance between a person and what they are looking at affects their perception of visual 

quality (figure 70). Someone looking at the Santa Fe National Forest’s mountains from Interstate 

25 would not notice a campsite having bare ground and trash. This sort of unnatural feature is 

more noticeable when you are close to it.
Chapter 3. Affected Environment and Environmental Consequences

228 FEIS for Travel Management on the Santa Fe National Forest

Visual effects, such as erosion from roads and trails, usually happen when the route has not been 

designed for resource protection. Some system and unauthorized routes degrade visual quality by 

not being in the right place and receiving little maintenance, which causes erosion and rutting and 

strips vegetation from the sides. Motorized cross-country travel can create these kinds of routes.

Figure 70. A view of Cerro Pedernal. Even though camping happens in 

these mountains, you can’t see it from far away

Visual Quality - Environmental Consequences

Effects Common to All Alternatives

Routes in poor condition will degrade visual quality until they grow vegetation, or until the Forest 

Service repairs or decommissions them. Some routes, because of their location and construction, 

would not naturally revegetate and could erode more, continuing to degrade visual quality.

All the alternatives provide for closures during wet weather, which helps prevent rutting when 

vehicles drive on muddy roads. The uniform seasonal closures proposed in alternatives 2, 3, and 

5, help limit rutting and erosion on muddy roads during winter, but may miss other times of year 

such as monsoon season. Alternatives 2M and 4 would use closure orders to protect routes, so the 

opening of routes would be tailored to the season and the route, and still prevent erosion on 

muddy routes. Preventing such problems on routes helps keep visual quality intact.

Direct and Indirect Effects, Alternative 1

Alternative 1, where motorized cross-country travel occurs on about 1⁄4 of the forest, is most likely 

to create new routes that aren’t designed by the Forest Service. The effects from erosion and bare 

soil that would result from these routes would tend to degrade visual quality. Depending on their 
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 229

location, some may not meet management objectives for visual quality. Depending on the number

of routes, some portions of the forest might not meet objectives for visual quality over time.

Direct and Indirect Effects, Alternatives 2, 2M, 4, and 5

Limiting motorized cross-country travel to fixed-distance corridors for motorized dispersed 

camping would improve visual quality by preventing the creation of new routes on the rest of the 

forest. Visual quality in these camping corridors, however, could be degraded as a result of bare 

ground, trampled vegetation, and other alterations of the natural conditions. For people looking at 

the corridors from a distance, the loss of vegetation would be less noticeable. Camping corridors, 

because they allow people to drive to a campsite, could encourage the creation of new routes with 

accompanying erosion and bare ground. As described, this could detract from visual quality over 

time, but less than under alternative 1.

The fixed-distance corridors for motorized big game retrieval would not degrade visual quality. 

The number of motorized trips to retrieve downed big game is not likely to result in the creation 

of new routes.

Alternatives 2, 2M, 4, and 5 propose about 40 acres of areas each. About 35 acres of these are for 

motorcycle trials and are located mostly on rock, so rutting and erosion is not likely unless on a 

trail that connects the rocks. The remaining 5 acres are camping areas in the Pecos/Las Vegas 

Ranger District. Visual quality here could appear degraded when seen onsite from erosion and 

rutting. Because the total amount of areas is less than 0.01 percent of the forest, any visual 

degradation to the forest overall would be negligible.

Adding unauthorized roads and trails to the forest transportation system is not expected to affect 

visual quality of the Santa Fe National Forest at the forestwide scale because the routes proposed 

for addition are already in use and the additions proposed are small at the forestwide scale. The 

effects they’ve had to visual quality already exist and would improve once the routes become part 

of the system and receive maintenance. Compared to alternative 1—where all unauthorized routes 

would be open for motorized use—all the action alternatives limit the potential effects to visual 

quality.

Direct and Indirect Effects, Alternative 3

Alternative 3 is the most likely to improve visual quality because no new routes, which contribute 

the most to poor visual quality, would be created. This alternative allows no motorized travel off 

roads at all.

Cumulative Effects, All Alternatives

For alternative 1, because no changes are proposed in the motorized system, the cumulative effect 

on visual quality would remain about the same as now. 

Alternatives 2 through 5 are expected to slightly improve visual quality. Cumulatively, other 

projects managed by the Forest Service, such as oil and gas pipelines, thinning and prescribed 

burning, Respect the Rio, livestock grazing, forest product collection, and those done through the 

American Recovery and Reinvestment Act, mitigate visual impacts and keep or improve visual 

quality. Each has specific mitigations for visual quality, or by its nature improves it (like Respect 
Chapter 3. Affected Environment and Environmental Consequences

230 FEIS for Travel Management on the Santa Fe National Forest

the Rio). Creation of the Valles Caldera National Preserve also improved visual quality by 

reducing the places where people can drive on that large tract of land. 

Effects of Forest Plan Amendments to Visual Quality

The proposed amendments that are administrative in nature are not expected to have effects on 

visual quality because they simply update and provide consistent direction.

Proposed amendments that authorize additional areas and corridors for off-highway vehicle travel 

in Management Areas I, J, K, M, and N are also not expected to have effects on visual quality. 

Future motorized designations in these areas are expected to be minimal because of the 

management emphasis to protect specific high value resources and any additional designation will 

be subject to the appropriate level of NEPA analysis.

The proposed amendments table 66 of appendix 1 are alternative specific, with the majority of 

amendments applying to alternatives 4 and 5. These amendments propose to allow motorized 

dispersed camping and motorized big game retrieval corridors in areas where the use is currently 

prohibited. Amendments for alternatives 2 and 2M allow use along a small amount of roads and 

trails where use is occurring under special use authorization or the use is believed to be important 

enough to continue to allow.

The amendments that propose to include motorized dispersed camping and motorized big game 

retrieval corridors in wild and scenic river areas (East Fork Jemez, Rio Chama, and Pecos) and 

the Jemez National Recreation Area, where this use is currently not allowed, apply to alternatives 

4 and 5. The amendments allowing motorized dispersed camping and motorized big game 

retrieval corridors may reduce visual quality in the immediate area if new corridors are added due 

to increased ground disturbance from vehicle traffic. The amendments that allow motorized use 

along FR 503J and UR674 are not expected to affect visual quality because the footprints already 

exist on the ground.

Short-term Uses and Long-term Productivity

The change in driving on National Forest System roads and trails created by any of the action 

alternatives does not jeopardize the long-term productivity of the Santa Fe National Forest. As 

described throughout chapter 3, implementing any of the action alternatives would improve 

resources such as wildlife habitat, cultural resource sites, and others.

Unavoidable Adverse Impacts

Designating unauthorized routes could spread invasive plants to new locations and cause a loss of 

soil productivity. Alternative 4, which is expected to result in more bare ground from motorized 

dispersed camping, would also result in a loss of soil productivity.

Irreversible and Irretrievable

Commitments of Resources

An irreversible commitment of a resource is one that cannot be regained, such as the extinction of 

a species. An irretrievable commitment is one where the value of the resource is lost for a period 

of time, such as the loss of soil productivity from the existence of a road.
Chapter 3. Affected Environment and Environmental Consequences

FEIS for Travel Management on the Santa Fe National Forest 231

Cultural Resources

Alternative 1 could result in the irreversible loss of cultural resource sites. By definition, cultural 

resource sites and traditional cultural properties are not renewable and damage to them cannot be 

reversed. Alternatives 2 through 5, by employing the proposed mitigations, would have no 

irreversible commitments of resources.

Soil

All the alternatives would result in the irretrievable commitment of some of the forest’s soil 

productivity. This commitment, however, would be negligible when considered at the scale of the 

forest. All alternatives designate unauthorized routes, which commits the soil to use as a route 

rather than for growing plants. All alternatives continue to allow camping, which also tends to 

commit soil to that use. 

Wildlife

No irreversible commitments of wildlife resources will result from any of the action alternatives.

All the action alternatives, however, propose to designate unauthorized roads and trails. This 

would be an irretrievable commitment of resources because once designated, these routes would 

not be available for wildlife use until analysis was undertaken to change the designation and 

decommission the route. Despite this irretrievable commitment, reducing the places where people 

can drive by nearly eliminating areas, keeping cross-country travel within fixed-distance 

corridors, and placing seasonal restrictions is expected to minimize disturbance and harassment of 

species and, thus, benefit wildlife resources.

Visual Quality

Alternative 4, which is expected to result in more bare ground from motorized dispersed camping, 

could irretrievably reduce visual quality in some places. This would also be negligible at the scale 

of the forest.

Nonnative Invasive Plants

As a result of the risk of spread of nonnative invasive plants, alternative 1 would result in 

continued threats to native plant communities, watershed health, and wildlife, and may be 

irreversible. Some weed species can invade relatively undisturbed native vegetation, affect runoff 

patterns or the amount of available soil moisture, degrade habitat for native wildlife, decrease 

economic land values, or change the way people use the land (Asher 1998). Some effects, such as 

loss of wildlife habitat, may be irreversible if the weed populations expand beyond the forest’s 

capacity to manage them.

Because they reduce the risk of transport and spread of nonnative invasive plants, the action 

alternatives are less likely to have irreversible or irretrievable effects. They still, however, depend 

on the forest’s ability to manage weed infestations. Implementation of any action alternative may 

slow the establishment of new infestations of invasive species, but without a coincident invasive 

management program, irreversible or irretrievable effects may result. Once established, weed 

populations can be difficult to control, contain, or eradicate, so the change could be long lasting.
Chapter 3. Affected Environment and Environmental Consequences

232 FEIS for Travel Management on the Santa Fe National Forest

Other Required Disclosures

NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft 

environmental impact statements concurrently with and integrated with other environmental 

review laws and executive orders.” We’ve prepared this statement in accordance with the 

National Historic Preservation Act, which governs ground disturbance in historical places, and the 

Endangered Species Act, which covers projects that have threatened or endangered species in its 

boundaries.
DEIS for Travel Management on the Santa Fe National Forest 233

Chapter 4. Consultation and Coordination

List of Preparers 

Name Position Contribution Education

Years of 

Relevant 

Experience

Amy, William Wildlife Program 

Manager

Wildlife B.S. Natural Resource 

Sciences 

16

Apodaca, Anne Assistant Forest 

Recreation/Wilderness/ 

Trails/River Program 

Manager 

Recreation and 

wilderness

B.S. Wildlife Science -

minor Management 

24

Bain, Julie Travel Management 

Project Leader

Team leader B.A. Environmental 

Science

M.E.S. Planning

18

Basham, Matt Archaeologist Heritage and cultural 

resources

B.A. Anthropology

M.A. Anthropology

8

Bremer, Mike Forest Heritage 

Program Manager

Heritage and cultural 

resources

B.A. Anthropology

M.A. Anthropology

34

Connelly, Erin Deputy Forest 

Supervisor

Project oversight B.S. Forest Management 31

Cook, Chantel Forest Fish Biologist Fisheries and aquatic B.A. Biology

M.S. Fisheries Science

23

Cramer, Jennifer Forest Planner Forest plan 

amendments, 

recreation

B.A. Biology 

Ph.D. Plant Biology 

5

Dechter, Mike Jemez and Cuba 

Districts NEPA 

Coordinator

Social and economic B.S. Ecology

Masters in Resource 

Economics and Policy

10

Frazier, Michael Forest Recreation, 

Lands, Minerals, and 

Engineering Staff 

Officer

Project oversight B.A. Philosophy

B.S. Forestry

40

Garcia, Maria T. Forest Supervisor Responsible official

Gonzales, 

Estevan

Student Trainee Wildfire and visual 

quality research

Working on B.A. in 

environmental science

4

Grinde, Pete Forest Range Program 

Manager 

Invasive plants B.S. Range Management 33

Hall, Joshua State Air and Water 

Quality Liaison

Air quality

Hermandorfer, 

Chad

Hydrologist Soil and water 

research

B.S. Environmental 

Science 

M.S. candidate 

Watershed Management

15

Holliday, Kiernan Civil Engineer Roads B.S. with high honors in 

Civil Engineering

J.D.

32

Kulisheck, 

Jeremy

Assistant Forest 

Archaeologist

Heritage and cultural 

resources

B.A. Anthropology

M.A. Anthropology

PhD Anthropology 

29
Chapter 4. Consultation and Coordination

234 FEIS for Travel Management on the Santa Fe National Forest

Name Position Contribution Education

Years of 

Relevant 

Experience

Luetzelschwab, 

Julie

Forest Resource 

Information 

Coordinator

Geographic 

information systems, 

databases, and 

mapping

B.A. Resource and 

Environmental 

Geography, minor –

Ecology

M.A. Geosciences

18

Nevins, Erica Soil and Watershed 

Program Manager 

Soil and water B.S. Soil Science 12

Norton, Roger Forest Realty Specialist Lands Numerous professional 

courses during 

government and private 

sector service, including 

BLM Lands Academy 

and Appraisal Institute

training.

22

Taliaferro, Diane Forest Recreation/ 

Wilderness/Trails/

River Program 

Manager

Recreation and trails B. S. Education - Soc. 

Science/P.E./Health/ 

Recreation/Coaching

M.S. Forestry -

Ecosystem Management

20

Other Contributors

Charlie Gobar, Forest Wildlife Biologist (retired)

Dolores Maese, Forest Public Affairs Officer (retired)

Daniel Jirón, Regional Forester, Region 2

List of Agencies, Organizations and 

Persons to Whom Copies of the FEIS Were Sent

In the letter accompanying the draft environmental impact statement, we let people know that 

they would receive a copy of this final statement if they commented or if they specifically 

requested it. Approximately 650 people of the 1,211 people on our mailing list commented on the 

draft or asked to receive a copy of the final environmental impact statement. Others sent in form 

letters during the comment period. We sent the final environmental impact statement and maps to 

everyone who commented during the notice and comment period, those who sent a form letter, 

and those who asked to receive a copy of it. 

In addition, copies have been sent (or in some cases made electronically available) to Federal 

agencies, federally recognized tribes, State and local governments, and organizations that have 

requested to be involved in the development of this analysis. These entities include the U.S. 

Environmental Protection Agency; U.S. Army Corps of Engineers; U.S. Department of the 

Interior; Federal Highway Administration; Advisory Council on Historic Preservation; USDA 

National Agricultural Library; State wildlife and fisheries management agencies; county 

commissions; and local community governments. Due to the number of people, agencies, and 

organizations, a complete listing has been omitted from this EIS, but is available upon request or 

on the forest Web site at http://www.fs.fed.us/r3/sfe/travelmgt/index.html. This list includes those 

who requested the final environmental impact statement through May 7, 2012.
DEIS for Travel Management on the Santa Fe National Forest 235

Glossary

All-terrain vehicle (ATV). A type of off-highway vehicle that travels on three or more low 

pressure tires; has handlebar steering; is less than or equal to 50 inches in width; and has a seat 

designed to be straddled by the operator (FSM 2353.05, FSH 2309.18.05, FSM 7705). 

Closed road. A road placed in storage between intermittent uses. The period of storage must 

exceed 1 year. These roads are not shown on motor vehicle use maps. They are closed to all 

vehicular traffic but may be available and suitable for nonmotorized uses. A closed road is not the 

same as an obliterated or decommissioned road. A closed road may be opened again for use at 

some time in the future. (Region 3 Transportation Glossary)

Coincident route. Where a road and trail overlap; that is, they are located in the same path. 

(Santa Fe National Forest)

Fixed distance “corridor.” A specified distance within certain designated routes solely for the 

purposes of dispersed camping or retrieval of a downed big game animal by an individual who 

has legally taken that animal. (Santa Fe National Forest)

Forest road or trail. A road or trail wholly or partly within or adjacent to and serving the 

National Forest System that the Forest Service determines is necessary for the protection, 

administration, and utilization of the National Forest System and the use and development of its 

resources. (Travel Management Rule)

Interdisciplinary team. A team of people having different specialties, such as wildlife or 

recreation, that work together on the design and analysis of a project. (Santa Fe National Forest)

Motorized big game retrieval. Driving off a route to retrieve a legally killed elk or mule deer. 

(Santa Fe National Forest)

Motorized cross-country travel.. Driving off a designated road or trail for any purpose. (Santa 

Fe National Forest)

Motorized dispersed camping. Driving off a road and parking to camp. (Santa Fe National 

Forest)

Motor vehicle.. Any vehicle that is self-propelled, other than: (1) a vehicle operated on rails; and 

(2) any wheelchair or mobility device, including one that is battery powered, that is designed 

solely for use by a mobility-impaired person for locomotion, and that is suitable for use in an 

indoor pedestrian area. (Travel Management Rule)

Off-highway vehicle (OHV). Includes any motor vehicle designed for or capable of crosscountry travel on or immediately over land, water, sand, snow, ice, marsh, swampland, or other 

natural terrain. (Travel Management Rule) This, for example, includes pickup trucks, cars with 

four-wheel drive, and motorcycles. 

Open road or trail. A forest system road or trail designed and managed for motorized use. (Santa 

Fe National Forest)
Glossary

236 FEIS for Travel Management on the Santa Fe National Forest

Open to vehicles legal on paved highways. A road open to vehicles with licenses to drive on 

highways. At the time of this writing in New Mexico, most ATVs and some kinds of motorbikes 

are not allowed to drive on paved highways, but they are allowed on dirt roads. Some highways 

in New Mexico are dirt. This designation would not allow most ATVs and motorbikes to drive on 

the road. (Santa Fe National Forest)

Road decommissioning.: (1) Activities that result in the stabilization and restoration of unneeded 

roads to a more natural state (36 CFR 212.1). (2) Activities that result in restoration of unneeded

roads to a more natural state (FSM 7705, FSM 7734).

Road obliteration. To deconstruct, decommission, deactivate, or dismantle a road; the denial of 

use, elimination of travelway functionality, and removal of the road from the forest development 

road system; return of the road corridor to resource production by natural or designated means 

(“A Guide for Road Closure and Obliteration in the FS,” June 1996, T and D Publication 9677 

1205).

Route. Term used to refer to roads and trails. (Santa Fe National Forest)

Unauthorized road or trail. A road or trail that is not a forest road or trail or a temporary road or 

trail and that is not included in a forest transportation atlas. (Travel Management Rule)
FEIS for Travel Management on the Santa Fe National Forest 237

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246 FEIS for Travel Management on the Santa Fe National Forest

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FEIS for Travel Management on the Santa Fe National Forest 247

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management draft environmental impact statement and approval of mitigations. March 

17, 2010. Unpublished report available from the Santa Fe National Forest. Santa Fe, NM.

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Fe National Forest. Santa Fe, NM.

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report available from the Santa Fe National Forest. Santa Fe, NM.

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Travel Management, Santa Fe National Forest. Federal Register, Vol. 75, No. 151. August 

6, 2010.

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Fe, NM.: GEN01_TravelMgt_RoutesByMOT_20111220_JBworking.xlsx. December 20, 

2011.

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21, 2011.

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analysis. December 31, 2011. Unpublished report available from the Santa Fe National 

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References

248 FEIS for Travel Management on the Santa Fe National Forest

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from the Santa Fe National Forest. Santa Fe, NM.

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Unpublished report available from the Santa Fe National Forest. Santa Fe, NM.

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available from the Santa Fe National Forest. Santa Fe, NM.

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available from the Santa Fe National Forest. Santa Fe, NM.

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available from the Santa Fe National Forest. Santa Fe, NM.

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available from the Santa Fe National Forest. Santa Fe, NM.

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available from the Santa Fe National Forest. Santa Fe, NM.

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Threatened Species, Final Rule. Federal Register 58(49):14248-14271.
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focus in the interior Columbia basin: Broad-scale trends and management implications. 

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FEIS for Travel Management on the Santa Fe National Forest 251

Appendix 1. Proposed 

Amendments to the Forest Plan

Table 66. The following amendments to the forest plan will occur regardless of which alternative is 

selected

Chapter/

Management 

Area

Page

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additions and 

deletions].

Chapter 4 -

Forestwide 

Standards and 

Guidelines

52 ORV closure and restrictions are 

indicated by management area. 

Remaining areas are open to ORV use 

unless resource considerations 

necessitate additional restrictions or 

closures based upon monitoring 

activitie and appropriate 

environmental analysis. These actions 

may vary from a seasonal restriction 

for specific vehicles to yearlong 

closures for all vehicles. User 

enjoyment and safety will be 

considered as well as needs for 

resource protection. 

Criteria for restricted use or closure of 

an area may include:

1. Loss of vegetative cover.

2. Degradation of important 

wildlife habitat or wildlife 

harassment.

3. Identifiable impacts on soils, 

riparian ecosystems, or water 

quality.

4. Disturbance of known Native 

American religious or cultural 

resource sites.

5. Need for separation of different 

recreation uses which may 

adversely affect one another.

6. Disruption of grazing 

management programs or 

harassment of permitted 

livestock.

Motor vehicle use by the public, including 

vehicle class and time of year is defined by 

the MVUM (motor vehicle use map) and 

36 CFR 212.5. Motor vehicle use by the 

public off this designated system of roads, 

trails, and areas, and outside of corridors 

(motorized dispersed camping or 

motorized big game retrieval) is 

prohibited, except as identified on the 

MVUM.

Addition of motorized roads, trails, areas 

and corridors (motorized dispersed 

camping and motorized big game 

retrieval) to the MVUM will take into 

consideration the following criteria:

1. Loss of vegetative cover.

2. Degradation of important wildlife 

habitat or wildlife harassment.

3. Identifiable impacts on soils, riparian 

ecosystems, or water quality.

4. Disturbance of known Native 

American religious or cultural resource 

sites.

5. Need for separation of different 

recreation uses which may adversely 

affect one another.

6. Disruption of grazing management 

programs or harassment of permitted 

livestock.

7. Specific direction, if any, as 

indicated for any management area.

8. Regulations specified in 36 CFR 212 

Subpart B – Designation of Roads, 

Trails, and Areas for Motorized Use
Appendix 1. Proposed Amendments to the Forest Plan

252 FEIS for Travel Management on the Santa Fe National Forest

Table 66. The following amendments to the forest plan will occur regardless of which alternative is 

selected

Chapter/

Management 

Area

Page

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additions and 

deletions].

Chapter 4 -

Forestwide 

Standards and 

Guidelines

52 Categories of ORV area management 

are defined as follows:

CLOSED - to all motorized travel. Use 

of motorized vehicles is not permitted 

on trails or for cross-country travel. 

Some administrative roads may occur 

in some areas, but they are not open for 

public use.

RESTRICTED - area closed to all 

cross-country motorized travel. Road 

and trail use is permitted through an 

area, but no cross-country use is 

allowed. Vehicles are allowed to pull 

off of open roads up to 100 yards (or to 

other administratively designated 

areas) for parking or camping.

RESTRICTED SEASONALLY - Same 

guidelines as RESTRICTED but only 

for specified areas or times of the year. 

Outside of these times, areas are open.

OPEN - to cross-country travel. Some 

slopes over 40 percent may be 

designated as open. Organized ORV 

events may occur by permit only. 

Seasonal closures may be imposed for 

resource protection.

[Delete: Redundant with new forestwide 

direction.]

Chapter 4 -

Forestwide 

Standards and 

Guidelines

86 Allow only one private road permit for 

private land or subdivision access 

unless public safety or natural features 

dictate otherwise.

For access to an inholding, allow only one 

private road authorization for private 

land or subdivision access. The 

authorization shall be the only access 

authorized by the United States for such 

inholdings, regardless of future 

landownership patterns. The forest will 

follow regional or forest level manual and 

handbook direction supplements (if 

existing or applicable) for further 

guidance. As a condition of the 

authorization process, the forest will 

require reciprocal public or 

administrative access across the 

authorized road where appropriate.

[The forest is unable to definitively limit the 

number of roads to private property to one 

because of the history of private land access 

on the forest. The forest is moving toward 

this goal with requests for new access.]
Appendix 1. Proposed Amendments to the Forest Plan

FEIS for Travel Management on the Santa Fe National Forest 253

Table 66. The following amendments to the forest plan will occur regardless of which alternative is 

selected

Chapter/

Management 

Area

Page

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additions and 

deletions].

Chapter 4 –

Forestwide 

Standards and 

Guidelines

86 Respond to applications for new 

permits, amendments, documents, 

leases, and rights-of-way within 30 

days of receipt. Administer all existing 

permits.

Respond to applications for new permits, 

amendments, documents, leases, and 

rights-of-way in the manner consistent 

with Forest Service policy and regulation. 

[This language brings the forest in line with 

current direction and guidance.]

Management 

Area A

99 These lands are generally open to ORV 

travel except for the restrictions and 

closures displayed on the ORV map.

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]

100 Road use will be managed with the 

objective of limiting open road density 

to 1.0 to 2.5 miles per square mile.

Road use will be managed with the objective 

of limiting open road density to 2.5 miles per 

square mile or less.

[The new verbiage clarifies that the lower 

threshold is not sensible in the context of the 

guidelines’ intent of “limiting open road 

density.” It was never envisioned that if there 

were areas where road density was less than 

the lower limit that the forest would be 

required to build more roads. This rationale 

applies to all other amendments that 

eliminate the lower threshold.] 

Management 

Area B

103 These lands are generally open to ORV 

travel except for the restrictions and 

closures displayed on the ORV map.

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]

104 Road use will be managed with the 

objective of limiting open road density

to 0.3 to 1.5 miles per square mile.

Road use will be managed with the objective 

of limiting open road density to 1.5 miles per 

square mile or less.

[Eliminates lower threshold.] 

Management 

Area C

107 These lands are generally open to ORV 

travel except within the boundaries of 

developed recreation sites, and for the 

areas displayed on the ORV map.

Addition of areas and corridors 

(motorized dispersed camping and 

motorized big game retrieval) to the 

MVUM are allowed if consistent with the 

management emphasis for the area, except

within the boundaries of developed 

recreation sites.

111 Road use will be managed with the 

objective of limiting open road density 

to 1.0 to 2.5 miles per square mile.

Road use will be managed with the objective 

of limiting open road density to 2.5 miles per 

square mile or less.

[Eliminates lower threshold.]

Management 

Area D

113 These lands are generally open to ORV 

travel except within the boundaries of 

developed recreation sites, and for the 

areas displayed on the ORV map.

Addition of areas and corridors 

(motorized dispersed camping and 

motorized big game retrieval) to the 

MVUM are allowed if consistent with the 

management emphasis for the area, except

within the boundaries of developed 

recreation sites.

116 Road use will be managed with the 

objective of limiting open road density 

Road use will be managed with the objective 

of limiting open road density to 2.5 miles per 
Appendix 1. Proposed Amendments to the Forest Plan

254 FEIS for Travel Management on the Santa Fe National Forest

Table 66. The following amendments to the forest plan will occur regardless of which alternative is 

selected

Chapter/

Management 

Area

Page

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additions and 

deletions].

to 1.0 to 2.5 miles per square mile. square mile or less.

[Eliminates lower threshold.]

Management 

Area E

118 These lands are generally open to ORV 

travel except for the restrictions and 

closures displayed on the ORV map.

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]

119 Road use will be managed with the 

objective of limiting open road density 

to 1.0 to 2.5 miles per square mile.

Road use will be managed with the objective 

of limiting open road density to 2.5 miles per 

square mile or less.

[Eliminates lower threshold.]

Management 

Area G

121 These lands are generally open to ORV 

travel except for the restrictions and 

closures displayed on the ORV map.

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]

123 Road use will be managed with the 

objective of limiting open road density 

to 0.3 to 1.5 miles per square mile.

Road use will be managed with the objective 

of limiting open road density to 1.5 miles per 

square mile or less.

[Eliminates lower threshold.]

Management 

Area I

136 Motorized travel is allowed only on 

open roads. Cross-country travel is 

prohibited, except under the terms of a 

special use permit.

Addition of areas and corridors 

(motorized dispersed camping and 

motorized big game retrieval) to the 

MVUM will be minimal and only allowed 

if consistent with the management 

emphasis for the area.

[Addition of routes and corridors will require 

archaeological survey and a report.]

137 Roads will not be constructed except 

where necessary for permitted special 

uses, mineral activities, private land 

access, to access adjacent management 

areas where other reasonable access is 

not available, or to support cultural 

resource management.

Roads will generally not be constructed 

except where necessary for permitted special 

uses, mineral activities, private land access, 

to access adjacent management areas where 

other reasonable access is not available, or to 

support cultural resource management. Road 

management will be implemented with the 

objective of closing all unnecessary roads 

where they currently exist.

[Allows for the designation of roads and 

trails that are currently unauthorized routes 

or decommissioned roads.]

Management 

Area J

141 Motorized travel is allowed only on 

open roads. Cross-country travel is 

prohibited, except under the terms of a 

special use permit.

Addition of areas and corridors 

(motorized dispersed camping and 

motorized big game retrieval) to the 

MVUM will be minimal and only allowed 

if consistent with the management 

emphasis for the area.
Appendix 1. Proposed Amendments to the Forest Plan

FEIS for Travel Management on the Santa Fe National Forest 255

Table 66. The following amendments to the forest plan will occur regardless of which alternative is 

selected

Chapter/

Management 

Area

Page

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additions and 

deletions].

Management 

Area K

143 Consistent with this theme, ORV travel 

will be prohibited, and recreation, 

grazing, and firewood activities will 

occur only when compatible with the 

primary emphasis.

Consistent with this theme, recreation, 

grazing, and firewood activities will occur 

only when compatible with the primary 

emphasis.

[Removes redundant language and potential 

confusion with MVUM direction.]

144 Motorized travel is allowed on open 

roads only. No cross-country travel is 

allowed, except under the terms of a 

special use authorization. 

Addition of areas and corridors 

(motorized dispersed camping and 

motorized big game retrieval) to the 

MVUM will be minimal and only allowed 

if consistent with the management 

emphasis for the area.

144 Special off-road vehicle recreation 

events will not be permitted in these 

areas.

Special off-highway vehicle recreation 

events will not be permitted in these areas.

[Corrects language, continues direction on 

not issuing special use permit for offhighway events.]

145 Road use will be managed with the 

objective of limiting open road density 

to 0 to 1.0 mile per square mile. 

Road use will be managed with the objective 

of limiting open road density to 1 mile per 

square mile or less.

[Eliminates lower threshold.]

Management 

Area M

151 Cross-country vehicular travel is 

prohibited within study areas.

Addition of areas and corridors 

(motorized dispersed camping and 

motorized big game retrieval) to the 

MVUM is prohibited and only allowed if 

consistent with the management emphasis 

for the area.

Management 

Area N

153 Motorized use is allowed on open roads 

only. No cross-country travel is 

allowed, except under the terms of a 

special use authorization.

Addition of areas and corridors 

(motorized dispersed camping and 

motorized big game retrieval) to the 

MVUM will be minimal and only allowed 

if consistent with the management 

emphasis for the area.

154 Roads will not be constructed except 

where necessary for special use 

permits, mineral activities, and adjacent 

management areas where other 

reasonable access is not available or to 

support wildlife habitat improvement 

projects.

Roads will generally not be constructed 

except where necessary for special use 

permits, mineral activities, and adjacent 

management areas where other reasonable

access is not available, or to support wildlife 

habitat improvement projects.

[Allows for the designation of roads and 

trails that are currently unauthorized routes 

or decommissioned roads.]

Management 

Area P

158 These lands are generally open to ORV 

travel except for the restrictions and 

closures displayed on the ORV map.

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]

160 Road use will be managed with the 

objective of limiting open road density

Road use will be managed with the objective 

of limiting open road density to 2.5 miles per 
Appendix 1. Proposed Amendments to the Forest Plan

256 FEIS for Travel Management on the Santa Fe National Forest

Table 66. The following amendments to the forest plan will occur regardless of which alternative is 

selected

Chapter/

Management 

Area

Page

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additions and 

deletions].

to 1.0 to 2.5 miles per square mile. square mile or less.

[Eliminates lower threshold.]

Management 

Area Q

163 These lands are generally open to ORV 

travel except for the restrictions and 

closures displayed on the ORV map.

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]

164 Road use will be managed with the 

objective of limiting open road density 

to 1.0 to 2.5 miles per square mile.

Road use will be managed with the objective 

of limiting open road density to 2.5 miles per 

square mile or less.

[Eliminates lower threshold.]

Management 

Area R

166 These lands are generally open to ORV 

travel except for the restrictions and 

closures displayed on the ORV map.

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]

168 Road use will be managed with the 

objective of limiting open road density 

to 0.3 to 1.5 miles per square mile.

Road use will be managed with the objective 

of limiting open road density to 1.5 miles per 

square mile or less.

[Eliminates lower threshold.]

Management 

Area S

171 These lands are generally open to ORV 

travel except for the restrictions and 

closures displayed on the ORV map.

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]

173 Road use will be managed with the 

objective of limiting open road density 

to 0.3 to 1.5 miles per square mile.

Road use will be managed with the objective 

of limiting open road density to 1.5 miles per 

square mile or less.

[Eliminates lower threshold.]

Management 

Area X

Jemez National 

Recreation Area 

Management 

Plan

9 Close approximately 14 miles of 

currently open roads, and maintain 

existing road closures (9 miles), 

allowing administrative or permittee 

use only on these roads and 

decommission approximately 84 miles 

of roads, removing them from the 

designated forest road system (in 

additional to the 5 miles previously 

decommissioned in this area) within 5 

years after approval of this 

management plan.

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]

9 The Transportation Plan should reflect 

a total of approximately 23 miles of 

closed roads (for administrative or 

permittee use only), at least 89 miles of 

decommissioned roads (off forest road 

system inventory), and approximately 

128 miles of open roads (including 

highways).

[Delete: Superseded by new forestwide 

direction limiting motorized travel to that 

displayed on the MVUM.]
Appendix 1. Proposed Amendments to the Forest Plan

FEIS for Travel Management on the Santa Fe National Forest 257

Table 66. The following amendments to the forest plan will occur regardless of which alternative is 

selected

Chapter/

Management 

Area

Page

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additions and 

deletions].

Management 

Area X

Jemez National 

Recreation Area 

Management 

Plan

9 and

12

Prohibit or restrict motorized vehicle 

use in accordance with the Travel Area 

Map where:

Open (16,905 acres) - Allows 

motorized travel on or off of designated 

forest roads and trails.

A (15,455 acres) - Restricts motorized 

travel to designated forest system roads 

and trails, as well as any highways, 

except to pull off the road within 300 

feet of the roadway.

A1 (10,145 acres) - Restricts motorized 

travel to designated forest system roads 

and trails, and vehicles may not drive 

beyond the roadway.

D (5,795 acres) - Prohibits all 

motorized travel. These areas may 

contain a few roads or trails for 

administrative use but are not open to 

public use. These are typically areas 

where natural resources may be 

seriously damaged or threatened by 

continued motorized use, or where a 

nonmotorized recreation opportunity is 

desired.

Plan changes to motor vehicle use as 

identified on the MVUM in accordance 

with the travel area map where: 

Open (16,905 acres) - Allows motorized 

travel on designated forest roads and trails 

and the addition of areas and corridors.

A (15,455 acres) - Restricts motorized travel 

to designated forest system roads and trails, 

as well as any highways, except to pull off 

the road for motorized dispersed camping

or motorized big game retrieval only

within 300 feet of the roadway.

A1 (10,145 acres) - Restricts motorized 

travel to designated forest system roads and 

trails, and vehicles may not drive beyond the 

roadway.

D (5,795 acres) - Prohibits all motorized 

travel. These areas may contain a few roads 

or trails for administrative use but are not 

open to public use. These are typically areas 

where natural resources may be seriously 

damaged or threatened by continued 

motorized use, or where a nonmotorized

recreation opportunity is desired.

Monitoring Plan

Facilities 2 and 

Facilities 3

184 Compare actual and planned amounts 

(of road construction and 

reconstruction)

[Delete: This measure is no longer 

meaningful because road construction and 

reconstruction is being implemented on an 

as-needed basis rather than in support of a 

timber program.]

Table 67. The following amendments to the forest plan will occur only if the alternative specified is 

selected or that are specific to certain routes or corridors

Chapter/

Management 

Area and 

Page No.

Alt.

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additons and 

deletions].

East Fork 

Wild and 

Scenic River 

Management 

Plan

Page 9 

Alt. 4 Prohibit new road construction and 

motorized use, with these exceptions: 

Highway 4, developed recreation sites, 

and roads needed for private land 

access, authorized special uses, mine 

claim access, or administrative actions 

related to protecting WSR values.

Prohibit new road construction and 

motorized use, with these exceptions: 

Highway 4, developed recreation sites, and 

roads needed for private land access, 

authorized special uses, mine claim access,

or administrative actions related to protecting 

WSR values, and for motorized dispersed 

camping or motorized big game retrieval 

as designated on the MVUM.
Appendix 1. Proposed Amendments to the Forest Plan

258 FEIS for Travel Management on the Santa Fe National Forest

Table 67. The following amendments to the forest plan will occur only if the alternative specified is 

selected or that are specific to certain routes or corridors

Chapter/

Management 

Area and 

Page No.

Alt.

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additons and 

deletions].

Rio Chama 

Management 

Plan

Page 13 and

31

Alt. 4 The entire corridor, outside of 

designated dispersed camping areas, 

will be closed to off-road travel 

through vehicle barriers, fencing, and 

regulation.

The entire corridor, outside of designated 

motorized dispersed camping corridors and 

motorized big game retrieval corridors as 

designated on the MVUM, will be closed to 

off-road travel through vehicle barriers, 

fencing, and regulation.

Addition of areas and corridors 

(motorized dispersed camping and 

motorized big game retrieval) to the 

MVUM will be very minimal.

Alt. 4 In all other areas within the corridor, 

vehicular use will not be allowed off of 

designated roads and parking areas. 

Existing roads and vehicle tracks will 

be closed with physical barriers, and 

an off-road vehicle (ORV) closure 

order will be written for the entire 

corridor, prohibiting vehicular use 

outside of designated areas and roads.

In all other areas within the corridor, 

vehicular use will not be allowed off of 

designated roads and parking areas, except 

for motorized big game retreival as 

designated on the MVUM. Existing roads

and vehicle tracks will be closed with 

physical barriers, and an off-road vehicle 

(ORV) closure order will be written for the 

entire corridor, prohibiting vehicular use 

outside of designated areas and roads.

Pecos Wild 

and Scenic 

River 

Management 

Plan

Page 8

Alt. 4 In the Recreational segment, prohibit 

all off-road use of motorized vehicles, 

and recommend that NMG&F 

implement the same prohibition on 

their lands in the corridor.

In the “Recreational” segment, prohibit all 

off-road use of motorized vehicles except for 

motorized big game retreival as 

designated on the MVUM, and recommend 

that NMG&F implement the same 

prohibition on their lands in the corridor.

Management 

Area H

Page 126

Alt .2, 

Alt. 2M

Use of mechanical conveyances. 

Including mountain bicycles, is 

prohibited.

Use of mechanical conveyances, including 

mountain bicycles is prohibited, except for 

FR503J where motorized travel is allowed 

on the road only as per the MVUM.

Management 

Area L

Page 146 and

147

Alt. 2, 

Alt. 

2M, 

Alt. 4

These areas are primarily unroaded and 

are closed to motorized recreation.

These areas are primarily unroaded and are

closed to motorized use.

These areas are closed to motorized 

travel. Existing use on roads under 

special use authorization will continue 

until expiration of the permit or a 

suitable substitute for access is 

obtained.

These areas are closed to motorized travel 

except where necessary for private land 

access or use under special use authorization 

which will continue until expiration of the 

permit or a suitable substitute for access is 

obtained.

Alt. 2, 

3, 4, 

and 5

These areas are closed to motorized 

travel. Existing use on roads under 

special use authorization will continue 

until expiration of the permit or a 

suitable substitute for access is 

obtained.

These areas are closed to motorized travel 

except for on FR 24 NGB and UNAU 84 as 

designated on the MVUM under special use 

authorization will continue until expiration of 

the permit or a suitable substitute for access 

is obtained.

Alt. 2 These areas are closed to motorized 

travel. Existing use on roads under 

special use authorization will continue 

These areas are closed to motorized travel 

except for on Trail UR674 and under 

special use authorization which will continue 
Appendix 1. Proposed Amendments to the Forest Plan

FEIS for Travel Management on the Santa Fe National Forest 259

Table 67. The following amendments to the forest plan will occur only if the alternative specified is 

selected or that are specific to certain routes or corridors

Chapter/

Management 

Area and 

Page No.

Alt.

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additons and 

deletions].

until expiration of the permit or a 

suitable substitute for access is 

obtained.

until expiration of the permit or a suitable 

substitute for access is obtained.

Alt. 4, 

Alt. 5

These areas are closed to motorized 

travel. Existing use on roads under 

special use authorization will continue 

until expiration of the permit or a 

suitable substitute for access is 

obtained.

These areas are closed to motorized travel 

except for motorized big game retrieval as 

designated on the MVUM, on Trail 

UR674, and under special use authorization,

which will continue until expiration of the 

permit or a suitable substitute for access is 

obtained.

Alt 2,

Alt 4,

Alt 5

These area are primarily unroaded and 

are closed to motorized recreation.

These areas are primarily unroaded and are 

closed to motorized use except for use on 

Trails 105, 107 (alt. 4 and 5 only), and 108, 

and FR 427 (alt. 4 and 5 only), as depicted 

on the MVUM.

Management 

Area X

Jemez 

National 

Recreation 

Area 

Management 

Plan

Pages 9 and 12

Alt. 5 Prohibit or restrict motorized vehicle 

use in accordance with the Travel Area 

Map where:...

D (5,795 acres) - Prohibits all 

motorized travel. These areas may 

contain a few roads or trails for 

administrative use but are not open to 

public use. These are typically areas 

where natural resources may be 

seriously damaged or threatened by 

continued motorized use, or where a 

nonmotorized recreation opportunity is 

desired.

Plan changes to motor vehicle use as 

identified on the MVUM in accordance 

with the travel area map where:...

[these changes above are proposed for all 

alternatives, see table 1]

D (5,795 acres) - Prohibits all motorized 

travel except for travel on and motorized 

dispersed camping off of FR652D as 

specified on the MVUM. These areas may 

contain a few roads or trails for 

administrative use but are not open to public 

use. These are typically areas where natural 

resources may be seriously damaged or 

threatened by continued motorized use, or 

where a nonmotorized recreation opportunity 

is desired.

Management 

Area X

Jemez 

National 

Recreation 

Area 

Management 

Plan

Pages 9 and 12

Alt. 4, 

Alt. 5

Prohibit or restrict motorized vehicle

use in accordance with the Travel Area 

Map where:

Open (16,905 acres) - Allows 

motorized travel on or off of 

designated forest roads and trails.

A (15,455 acres) - Restricts motorized 

travel to designated forest system 

roads and trails, as well as any 

Plan changes to motor vehicle use as 

identified on the MVUM in accordance 

with the Travel Area Map where:... 

[changes above are proposed for all 

alternatives, see table 1]

Motorized big game retrieval off roads 

and trails is allowed along select roads as 

specified on the MVUM.

Open (16,905 acres) - Allows motorized 

travel on or off of designated forest roads and 

trails.

A (15,455 acres) - Restricts motorized travel 

to designated forest system roads and trails, 

as well as any highways, except to pull off 

the road within 300 feet of the roadway.
Appendix 1. Proposed Amendments to the Forest Plan

260 FEIS for Travel Management on the Santa Fe National Forest

Table 67. The following amendments to the forest plan will occur only if the alternative specified is 

selected or that are specific to certain routes or corridors

Chapter/

Management 

Area and 

Page No.

Alt.

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additons and 

deletions].

highways, except to pull off the road 

within 300 feet of the roadway.

A1 (10,145 acres) - Restricts 

motorized travel to designated forest 

system roads and trails, and vehicles 

may not drive beyond the roadway.

D (5,795 acres) - Prohibits all 

motorized travel. These areas may 

contain a few roads or trails for 

administrative use but are not open to 

public use. These are typically areas 

where natural resources may be 

seriously damaged or threatened by 

continued motorized use, or where a 

nonmotorized recreation opportunity is 

desired.

A1 (10,145 acres) - Restricts motorized 

travel to designated forest system roads and 

trails, and vehicles may not drive beyond the 

roadway.

D (5,795 acres) - Prohibits all motorized

travel. These areas may contain a few roads 

or trails for administrative use but are not 

open to public use. These are typically areas 

where natural resources may be seriously 

damaged or threatened by continued 

motorized use, or where a nonmotorized

recreation opportunity is desired.

Management 

Area X

Jemez 

National 

Recreation 

Area 

Management 

Plan

Pages 9 and 12

Alt. 2, 

2M, 3, 

4, and 5

D (5,795 acres) - Prohibits all 

motorized travel. These areas may 

contain a few roads or trails for 

administrative use but are not open to 

public use. These are typically areas 

where natural resources may be 

seriously damaged or threatened by 

continued motorized use, or where a 

non-motorized recreation opportunity 

is desired.

D (5,795 acres) - Prohibits all motorized 

travel except for on FR 133, 133A, 133AA, 

133AAA, 133C, FR 384, and FR 4B as 

designated on the MVUM. These areas may 

contain a few roads or trails for 

administrative use but are not open to public 

use aside from the exceptions noted above, 

if any. These are typically areas where 

natural resources may be seriously damaged 

or threatened by continued motorized use, or 

where a nonmotorized recreation opportunity 

is desired.

Management 

Area X

Jemez 

National 

Recreation 

Area 

Management

Plan

Pages 9 and 12

Alt. 2, 

2M, 3,

and 5

D (5,795 acres) - Prohibits all 

motorized travel. These areas may 

contain a few roads or trails for 

administrative use but are not open to 

public use. These are typically areas 

where natural resources may be 

seriously damaged or threatened by 

continued motorized use, or where a 

non-motorized recreation opportunity 

is desired.

D (5,795 acres) - Prohibits all motorized 

travel except for on FR 134 as designated 

on the MVUM. These areas may contain a 

few roads or trails for administrative use but 

are not open to public use aside from the 

exceptions noted above. These are typically 

areas where natural resources may be 

seriously damaged or threatened by 

continued motorized use, or where a 

nonmotorized recreation opportunity is 

desired.

Management 

Area X

Jemez 

National 

Recreation 

Area 

Management

Plan

Alt. 4 D (5,795 acres) - Prohibits all 

motorized travel. These areas may 

contain a few roads or trails for 

administrative use but are not open to 

public use. These are typically areas 

where natural resources may be 

seriously damaged or threatened by 

continued motorized use, or where a 

D (5,795 acres) - Prohibits all motorized 

travel except for travel on and motorized 

dispersed camping off of FR 134 as 

designated on the MVUM. These areas may 

contain a few roads or trails for 

administrative use but are not open to public 

use aside from the exceptions noted above. 

These are typically areas where natural 
Appendix 1. Proposed Amendments to the Forest Plan

FEIS for Travel Management on the Santa Fe National Forest 261

Table 67. The following amendments to the forest plan will occur only if the alternative specified is 

selected or that are specific to certain routes or corridors

Chapter/

Management 

Area and 

Page No.

Alt.

Current Plan Direction

Italics shows proposed deletions. Regular 

text shows text that will not change.

Proposed Plan Amendment Direction

Bold text shows proposed new language. Regular 

text shows text that will not change. [Text in 

brackets explains rationale for additons and 

deletions].

Pages 9 and 12 non-motorized recreation opportunity 

is desired.

resources may be seriously damaged or 

threatened by continued motorized use, or 

where a nonmotorized recreation opportunity 

is desired.
FEIS for Travel Management on the Santa Fe National Forest 263

Table 68. Summary of roads and trails combined in the resultant system, by alternative

Where People are 

Driving (existing 

motorized travel 

policy)

Type of Route 

Proposed for 

Designation, Miles of 

Roads and Trails 

Combined

Where People Would be Allowed to Drive (proposed motorized travel policy)***

Action Alternative

Alternative 1 

(No Action) 2 2M 3 4 5

269 System roads not managed 

as open for motorized use 114 106 53 204 137

4,751 System roads managed as 

open for motorized use 2,272 2,207 1,776 2,552 2,224

539

Unauthorized routes that 

may or may not be open for 

motorized use*

141 138 37 206 143

41 Nonmotorized system trails outside of 

wilderness** 8 3 0 36 19

26 Motorized system trails 19 10 4 19 13

5,626 Resultant Designated Motorized System 2,552 2,463 1,869 3,017 2,537

Percent of alternative 1 designated for 

motorized use 45% 44% 33% 54% 45%

7,832 Percent of current motorized system 

designated for motorized use 33% 31% 24% 39% 32%

All numbers are rounded to the nearest mile or percent. Totals may vary slightly due to rounding.

*If the route is in a place where driving off routes is allowed, then motorized travel on the route is allowed.

**Most system trails outside wilderness are designed for nonmotorized uses, but motorized use on the majority of them is allowed and not actively discouraged.

***We assume people would drive where it is proposed to be allowed.

Appendix 2. Summary of Proposed Changes and Resultant Motorized System by Alternative
264 FEIS for Travel Management on the Santa Fe National Forest

Appendix 2. Summary of Proposed Changes and Resultant Motorized System

Table 69. Summary of trails in the resultant system, by alternative

Where People are 

Driving (existing 

motorized travel 

policy)

Type of Route 

Proposed for 

Designation as 

Motorized Trail

Where People Would be Allowed to Drive (proposed motorized travel policy)***

Action Alternative

Alternative 1 

(no action) 2 2M 3 4 5

51 System roads not managed 

as open for motorized use 48 39 12 80 58

2 System roads managed as 

open for motorized use 102 68 37 200 130

298

Unauthorized routes that 

may or may not be open for 

motorized use*

88 89 1 135 87

16 Nonmotorized system trails 

outside of wilderness** 17 9 2 17 12

41 Motorized system trails 8 3 0 30 19

408

Resultant Designated 

Motorized System, Trails 

Only

263 208 53 462 306

Percent of alternative 1 

designated as motorized 

trail

64% 51% 13% 113% 75%

459

Percent of current NFS 

trails designated as 

motorized trail

57% 45% 11% 101% 67%

26

Percent increase in 

designated National 

Forest System motorized 

trails

911% 699% 102% 1,678% 1,077%

All numbers are rounded to the nearest mile or percent. Totals may vary slightly due to rounding.

*If the route is in a place where driving off routes is allowed, then motorized travel on the route is allowed.

**Most system trails outside wilderness are designed for nonmotorized uses, but motorized use on the majority of them is allowed and not actively discouraged.

***We assume people would drive where it is proposed to be allowed.
FEIS for Travel Management on the Santa Fe National Forest 265

Table 70. Summary of roads in the resultant system

Where People are 

Driving (existing 

motorized travel 

policy)

Type of Route 

Proposed for 

Designation as Road

Where People Would be Allowed to Drive (proposed motorized travel policy)***

Action Alternative

Alternative 1 

(no action) 2 2M 3 4 5

218 System roads not managed 

as open for motorized use 65 67 41 124 80

4,749 System roads managed as 

open for motorized use 2,170 2,138 1,738 2,352 2,094

242

Unauthorized routes that 

may or may not be open for 

motorized use*

53 49 36 71 56

10 Nonmotorized system trails 

outside of wilderness** 2 1 2 2 2

0 Motorized system trails 0 0 0 7 0

5,218

Resultant Designated 

Motorized System, Trails 

Only

2,290 2,255 1,817 2,554 2,231

Percent of alternative 1 

designated as road 44% 43% 35% 49% 43%

6,433 Percent of current NFS 

roads designated as road 36% 35% 28% 40% 35%

All numbers are rounded to the nearest mile or percent. Totals may vary slightly due to rounding.

*If the route is in a place where motorized cross-country use is allowed, then motorized travel on the route is allowed.

**In alternative 4, 7 miles of system trail built for nonmotorized uses would be converted to road to provide motorized access to private land.

***These miles are coincident with roads (alternative 1) or proposed to be converted to roads (alternatives 2–5).
266 FEIS for Travel Management on the Santa Fe National Forest

Appendix 2. Summary of Proposed Changes and Resultant Motorized System

Table 71. Summary of areas in the resultant system

Motorized Cross-country Travel is Allowed 

on 821,644 Acres (53%) of the Forest

Where People are 

Driving (existing 

condition)

Total Acres in Resultant System

Alternative 1 (no action)

2 2M345

Area 

(Open for any kind of motorized use) 443,848 40 41

0 49 35

Percent of alternative 1 designated 0% 0% 0% 0% 0%

Corridor - Solely for Motorized Access to 

Dispersed Camping 17,195 16,340 13,856

0 33,079 11,536

Percent of alternative 1 designated 95% 81% 0% 192% 67%

Corridor - Solely for Retrieving Downed Big 

Game With a Valid License 1,258,361 16,340 13,856

0 1,098,618 370,300

Percent of alternative 1 designated 1% 1% 0% 87% 29%

All numbers are rounded to the nearest mile or percent. Totals may vary slightly due to rounding.

The areas and corridors do not necessarily overlap. Each use is individually designated.
Appendix 2. Summary of Proposed Changes and Resultant Motorized System

FEIS for Travel Management on the Santa Fe National Forest 267

Table 72. Summary of changes to roads and trails from existing policy and conditions

Where People 

are Allowed to 

Drive (current

motorized travel 

policy)

Where People are 

Driving

(Existing Condition)

Where People Would Drive 

(proposed direction)***

Alternative 1 

(No Action) Alternative 2 Alternative 2M (Preferred) Alternative 3 Alternative 4 Alternative 5

Miles of 

Route Type 

being Driven 

on1

Total 

Miles 

(%)

Miles Proposed for 

Designation as:

Change 

from 

Existing 

Direction, 

Miles (%)2

Change 

from Alt.

1, Miles 

(%)3

Miles Proposed for 

Designation as:

Change 

from 

Existing 

Direction, 

Miles (%)

Change 

from Alt.

1, Miles 

(%)

Miles Proposed for 

Designation as:

Change 

from 

Existing 

Direction, 

Miles (%)

Change 

from Alt.

1, Miles 

(%)

Miles Proposed for 

Designation as:

Change 

from 

Existing 

Direction

, Miles 

(%)

Change 

from Alt.

1, Miles 

(%)

Miles Proposed for 

Designation as:

Change 

from 

Existing 

Direction, 

miles (%)

Change 

from Alt.

1, Miles 

(%) Total Miles Road Trail Road Trail Total Road Trail Total Road Trail Total Road Trail Total Road Trail Total

System Roads 

Not Open for 

Motorized Use 218 51 269 

(20%) 65 48 114 +114(+8%)

-155

(-58%) 67 39 106 +106(+8%)

-163

(-61%) 41 12 53 +53(+4%)

-216

(-80%) 124 80 204 +204 (+15%)

-65

(-24%) 80 58 137 +137(+10%)

-132

(-49%)

1,349

System Roads 

Open for 

Motorized Use 4,749 2 4,751

(93%) 2,170 102 2,272 -2,812 (-55%)

-2,479

(-52%) 2,138 68 2,207

-2,877

(-57%)

-2,544

(-55%) 1,738 37 1,776 -3,30865%)

-2,975

(-63%) 2,352 200 2,552 -2,532(-50%)

-2,199

(-39%) 2,094 130 2,224 -2,860(-56%)

-2,527

(-53%)

5,084

Unauthorized 

Routes that May 

or May Not Be 

Open for 

Motorized Use* 

242 298 540 

(59%) 53 88 141 +141(+15%)

-399

(-74%) 49 89 138 +138(+15%)

-402

(-74%) 36 1 37 +37(+ 4%)

-503

(-93%) 71 135 206 +206(+23%)

-334

(-62%) 56 87 143 +143(+16%)

-397

(-74%)

914

Non-Motorized 

System Trails 

Outside 

Wilderness**

0 41 41 

(9%) 0 8 8 +8(+ 20%)

-33

(-80%) 0 3 3 +3(+0.01%)

-38

(-93%) 0 0 0 0 (no change)

-41

(-100%) 7 30 36 +36(+8%)

-5

(-12%) 0 19 19 +19(+ 4%)

-22

(-54%)

459

Motorized System 

Trails 10 16 26 

(100%) 2 17 19 -7

(-27%)

-7

(-27%) 1 9 10 -16(-62%)

-16

(-62%) 2 2 4 -22 (-81%)

-22

(-81%) 2 17 19 -7(-26%)

-7

(-26%) 2 12 13 -13(-48%)

-13

(-48%) 26

Resultant System 5,218 408

72%

2,290 263 -5,280

(-67%)

-3,074

(-55%)

2,255 208 -5,369

(-69%)

-3,163

(-56%)

1,817 53 -5,963

(-76%)

-3,757

(-67%)

2,554 462 -4,815

(-61%)

-2,609

(-46%)

2,231 306 -5,295

(-68%)

-3,809

7,832 5,626 2,552 2,463 1,869 3,017 2,537 (-55%)

All numbers are rounded to the nearest mile or percent. Totals may vary slightly due to rounding.

* If the route is in a place where driving off routes is allowed, then motorized travel on the route is allowed.

** Most system trails outside wilderness are designed for nonmotorized uses, but motorized use on the majority of them is allowed and not actively discouraged.

*** We assume people would drive where it is proposed to be allowed.

1 These columns show how people use the route regardless of its status. For example, 10 miles of closed system roads are being used as motorized trails.

2 The change from the existing travel policy shows how much of that type of route would be opened (+) or closed (-) to motorized use by the public. For example, alternative 2 proposes to open 11 percent of roads that are currently closed to motorized use.

3 The change from existing condition shows how much more (+) or less (-) motorized use would be available to the public as compared to what is being driven on now. For example, alternative 2 proposes to designate 44 percent fewer closed system roads than people are driving on now.
Appendix 2. Summary of Proposed Changes and Resultant Motorized System

268 FEIS for Travel Management on the Santa Fe National Forest

Table 73. Summary of changes to areas from existing policy and conditions

All numbers are rounded to the nearest mile or percent. Totals may vary slightly due to rounding.

* We assume people would drive where it is proposed to be allowed.

** All acres or miles of routes outside wilderness areas. Because we have no data on where big game is retrieved with a vehicle, we assumed it takes place everywhere except wilderness.

a 821,644 acres are open to all forms of motorized cross-country travel. Of this, the ORV map in the forest plan identifies 22,103 acres as corridors for “parking and camping” up to 100 yards.

b This figure is the acres and miles of corridors used for motorized dispersed camping identified in the forest’s 2008–2009 field inventory. Motorized dispersed camping also takes place in the 443,848 acres being used for cross-country travel; however, this is believed to be minimal 

compared to that which occurs along roads (IDT Assumption 19). 

c Proposed direction limits motorized big game retrieval to hunters with a valid license during hunting season.

1 The change from the existing travel policy shows how much of that type of area would be opened (+) or closed (-) to motorized use by the public. For example, alternative 2 proposes to close 100 percent of areas that are currently open to motorized use.

2 The change from existing condition shows how much more (+) or less (-) motorized use would be available to the public as compared to what is being driven on now. For example, alternative 2 reduces the areas people drive on now by 100 percent.

Where People 

are Allowed to 

Drive (current 

motorized 

travel policy)

Where People 

are Driving 

(existing 

condition)

Where People Would Drive 

(proposed direction)***

Alternative 1

(no action) Alternative 2 Alternative 2M Alternative 3 Alternative 4 Alternative 5

Acres (%)

Acres (%) Acres (%) Acres (%) Acres (%) Acres (%)

Total Acres

Proposed 

for

Designation

Change 

from 

Existing 

Direction1

Change 

from 

Alt. 1

2

Proposed 

for 

Designation

Change 

from 

Existing 

Direction1

Change 

from 

Alt. 1

2

Proposed 

for 

Designation

Change 

from 

Existing 

Direction

Change 

from 

Alt. 1

Proposed 

for 

Designation

Change 

from

Existing 

Direction

Change 

from 

Alt. 1

Proposed 

for 

Designation

Change from 

Existing 

Direction

Change 

from 

Alt. 1

Area 821,644 443,848 40 -821,604

(-100%)

-443,808

(-100%) 41 -821,603(-100%)

-443,807

(-100%) 0 -821,644(-100%)

-443,848

(-100%) 49 -821,595(100%)

-443,799

(100%) 35 -821,609(100%)

-443,813

(100%)

Motorized 

dispersed 

campinga 821, 644 17,195b 16,237 -805,317

(-98%)

-958

(-6%) 13,856 -807,788(-98%)

-3,339

(-19%) 0 -821,644(-100%)

-17,195

(-100%) 32,890 -788,754(-96%)

+15,695

(+91%) 11,422 -810,222(-99%)

-5,773

(-34%)

Motorized 

big game 

retrievalc 821, 644 1,258,361** 16,237 -805,317

(-98%)

-1,242,124

(-99%) 13,856 -807,788

(-98%)

-3,339

(-19%) 0 -821,644(-100%)

-1,258,361

(-100%) 1,098,329 +276,685(+34%)

-160,032

(-13%) 370,841 -450,803(-55%)

-887,520

(-71%)

Total Miles

(all system 

roads and 

trails open for 

motorized use)

Total Miles (%) 

Routes 

Currently 

being Driven 

on

Miles (%) Miles (%) Miles (%) Miles (%) Miles (%)

Proposed 

for 

Designation

Change 

from 

Existing 

Direction

Change 

from Alt.

1

Proposed 

for 

Designation

Change 

from 

Existing 

Direction

Change 

from 

Alt. 1

Proposed 

for 

Designation

Change 

from 

Existing 

Direction

Change 

from Alt.

1

Proposed 

for 

Designation

Change 

from 

Existing 

Direction

Change 

from 

Alt. 1

Proposed 

for 

Designation

Change from 

Existing 

Direction

Change 

from 

Alt. 1

Motorized 

dispersed 

camping

5,136 437b 423 -4,713

(-92%)

-14

(-3%) 381 -4,755(-93%)

-56

(-13%) 0 -5,136(-100%)

-437

(-100%) 461 -4,675(-91%)

+24

(+5%) 294 -4,842(94%)

-143

(-33%)

Motorized 

big game 

retrievalc 5,136 5,370** 423 -4,713

(-92%)

-4,947

(-92%) 381 -4,755(-93%)

-4,989

(-93%) 0 -5,136(-100%)

-5,370

(-100%) 2,848 -2,288(-45%)

-2,522

(-47%)

373 -4,763

(-93%)

-4,997

(-93%)
DEIS for Travel Management on the Santa Fe National Forest 269

Appendix 3. Analysis of Consistency 

with the Forest Plan, Laws, and 

Regulations - Soil and Water

Table 74. Consistency of travel management with forest plan

Page Forest Plan Direction Mgt.

Area Travel Management Project Compliance

20 Provide direction and support to 

all resource management 

activities with emphasis on 

maintaining the soil resource, 

water quality, and water quantity.

All Of the five alternatives, alternative 2 is the most likely to 

sustain current soil and water quality conditions. 

Alternative 3 is the most likely of the five alternatives to 

improve soil and water quality conditions.

Alternative 4 is the most likely of the five alternatives to 

decrease soil and water quality conditions.

Of the five alternatives, alternatives 2M and 5 are the 

most likely to sustain current soil and water quality 

condition, with the potential to improve over time.

20 Maintain water quality to meet or 

exceed state water quality 

standards.

All Of the five alternatives, alternative 2 is the most likely to 

sustain current water quality conditions. 

Alternative 3 is the most likely of the five alternatives to 

improve water quality conditions.

Alternative 4 is the most likely of the five alternatives to 

decrease water quality conditions.

Of the five alternatives, alternatives 2M and 5 are the 

most likely to sustain current water quality condition, 

with the potential to improve over time.

20 Identify and protect wetlands and 

flood plains.

All In all alternatives, travel routes that are currently within 

or near wetlands and flood plains would continue to 

impact these resources. 

Of the five alternatives, alternative 2 is the most likely to 

sustain current wetland and flood plain conditions. 

Alternative 3 is the most likely of the five alternatives to 

improve wetland and flood plain conditions.

Alternative 4 is the most likely of the five alternatives to 

decrease wetland and flood plain conditions.

Of the five alternatives, alternatives 2M and 5 are the 

most likely to sustain wetland and flood plain 

conditions, with the potential to improve over time.

20 Achieve satisfactory condition in 

riparian ecosystems. Maintain 

areas that are currently in good 

condition. 

All In all alternatives, travel routes that are currently within 

or near riparian ecosystems would continue to impact 

these resources. 

Of the five alternatives, alternative 2 is the most likely to 

sustain current riparian ecosystem conditions. 

Alternative 3 is the most likely of the five alternatives to 

improve riparian ecosystem conditions.

Alternative 4 is the most likely of the five alternatives to 

decrease riparian ecosystem conditions.

Of the five alternatives, alternatives 2M and 5 are the 

most likely to sustain riparian ecosystem conditions, 
Appendix 3. Consistency with the Forest Plan, Laws, and Regulations - Soil and Water

270 FEIS for Travel Management on the Santa Fe National Forest

Table 74. Consistency of travel management with forest plan

Page Forest Plan Direction Mgt.

Area Travel Management Project Compliance

with the potential to improve over time.

20 Minimize disturbances due to 

resource activities and other uses 

in the riparian zone.

All In all alternatives, travel routes that are currently within 

or near riparian ecosystems would continue to impact 

these resources. 

Of the five alternatives, alternative 2 is the most likely to 

sustain current riparian ecosystem conditions. 

Alternative 3 is the most likely of the five alternatives to 

improve riparian ecosystem conditions.

Alternative 4 is the most likely of the five alternatives to 

decrease riparian ecosystem conditions.

Of the five alternatives, alternatives 2M and 5 are the 

most likely to sustain riparian ecosystem conditions, 

with the potential to improve over time.

79 Manage riparian areas in 

accordance with legal 

requirements regarding flood

plains, wetlands, wild and scenic 

rivers, and cultural and other 

resources. Protect the productivity 

and diversity of ripariandependent resources and 

emphasize the protection of soil, 

water, vegetation, wildlife, and 

fish resources prior to 

implementing projects. Give 

preferential consideration to 

resources dependent on riparian 

areas over other resources when 

conflicts among uses arise. 

Riparian areas should be managed 

toward meeting the following 

guidelines:

Ground cover: Provide average 

ground cover of plants and litter 

at 80 percent of natural levels. 

Shade: Provide shading over 

perennial and intermittent water 

surfaces that is 80 percent of 

natural levels considering unit 

reaches of about 2 miles in length. 

Bank cover: Provide shrub and 

tree cover along bank lengths that 

is 80 percent of natural levels. 

Give emphasis to the protection 

of streambank stability provided 

by woody plant roots, particularly 

on outside bends of stream 

channel meanders.

Streambed sedimentation: 

Composition of sand, silt, and 

clays within streambeds should 

not exceed 20 percent of natural 

All In all alternatives, travel routes that are currently within 

or near riparian ecosystems would continue to impact 

these resources. 

Of the five alternatives, alternative 2 is the most likely to 

sustain current riparian ecosystem conditions. 

Alternative 3 is the most likely of the five alternatives to 

improve riparian ecosystem conditions.

Alternative 4 is the most likely of the five alternatives to 

decrease riparian ecosystem conditions.

Of the five alternatives, alternatives 2M and 5 are the 

most likely to sustain riparian ecosystem conditions, 

with the potential to improve over time.
Appendix 3. Consistency with the Forest Plan, Laws, and Regulations - Soil and Water

FEIS for Travel Management on the Santa Fe National Forest 271

Table 74. Consistency of travel management with forest plan

Page Forest Plan Direction Mgt.

Area Travel Management Project Compliance

levels. 

Plant composition: Provide at 

least 60 percent of the woody 

plant composition in three or 

more riparian species.

Replacement 

page 141

Cooperate in the implementation 

of the comprehensive watershed 

management plan. Maintain or 

improve high water quality 

conditions.

J Of the five alternatives, alternative 2 is the most likely to 

sustain current water quality conditions. 

Alternative 3 is the most likely of the five alternatives to 

improve water quality conditions.

Alternative 4 is the most likely of the five alternatives to 

decrease water quality conditions.

Of the five alternatives, alternatives 2M and 5 are the 

most likely to sustain current water quality condition, 

with the potential to improve over time.

Page 145 Close or obliterate unneeded 

travel ways. Consider areas of 

watershed resource damages and 

develop management strategies to 

improve such areas and reduce 

additional adverse impacts.

K The purpose of this project is to close unneeded travel 

ways. No obliteration would occur with this decision. 

All action alternatives reduce unneeded travel ways.

Legal Consistency

• National Forest Management Act of 1976, which ensures that forest planning and 

management activities provide for the conservation and sustained yield of soil and water 

resources.

• Compliance: Of the five alternatives, alternative 2 is the most likely to sustain 

current soil and water quality conditions. 

Alternative 3 is the most likely of the five alternatives to improve soil and water 

quality conditions.

Alternative 4 is the most likely of the five alternatives to decrease soil and water 

quality conditions.

Of the five alternatives, alternatives 2M and 5 are the most likely to sustain current 

soil and water quality condition, with the potential to improve over time.

• Clean Water Act of 1972, which was created to restore and maintain the chemical, 

physical, and biological integrity of the Nation’s waters (Section 101(a)). Section 303(d) 

directs states to list water quality impaired streams and develop total maximum daily 

loads to control the nonpoint source pollutants causing loss of beneficial uses. Section 

404 regulates the discharge of dredged or fill material into navigable waters (waters of 

the U.S.). 

• Compliance: Of the five alternatives, alternative 2 is the most likely to sustain 

current water quality conditions. 

Alternative 3 is the most likely of the five alternatives to improve water quality 

conditions.
Appendix 3. Consistency with the Forest Plan, Laws, and Regulations - Soil and Water

272 FEIS for Travel Management on the Santa Fe National Forest

Alternative 4 is the most likely of the five alternatives to decrease water quality 

conditions.

Of the five alternatives, alternatives 2M and 5 are the most likely to sustain current 

water quality condition, with the potential to improve over time.

• Executive Order 11990, 1977; (Wetlands Management) requires Federal agencies to 

follow avoidance, mitigation, and preservation procedures with public input before 

proposing new construction in wetlands. To comply with Executive Order 11990, the 

Federal agency would coordinate with the Army Corps of Engineers under Section 404 of 

the CWA and mitigate for impacts to wetland habitats.

• Compliance: In all alternatives, travel routes that are currently within or near 

wetlands would continue to impact these resources. 

Of the five alternatives, alternative 2 is the most likely to sustain current wetland 

conditions. 

Alternative 3 is the most likely of the five alternatives to improve wetland conditions.

Alternative 4 is the most likely of the five alternatives to decrease wetland 

conditions.

Of the five alternatives, alternatives 2M and 5 are the most likely to sustain wetland 

conditions, with the potential to improve over time.

• Executive Order 11998, 1977; (Floodplain Management) requires all Federal agencies to 

take actions to reduce the risk of flood loss, restore and preserve the natural and 

beneficial values in flood plains, and minimize the impacts of floods on human safety, 

health, and welfare. 

• Compliance: In all alternatives, travel routes that are currently within or near flood

plains would continue to impact these resources. 

Of the five alternatives, alternative 2 is the most likely to sustain current flood plain 

conditions. 

Alternative 3 is the most likely of the five alternatives to improve flood plain 

conditions.

Alternative 4 is the most likely of the five alternatives to decrease flood plain 

conditions.

Of the five alternatives, alternatives 2M and 5 are the most likely to sustain flood

plain conditions, with the potential to improve over time.
FEIS for Travel Management on the Santa Fe National Forest 273

Appendix 4. The Forest’s 

Current Motorized Travel Policy

It is helpful to discuss the forest’s current motorized travel policy because this project proposes to 

change it. The forest’s current motorized travel policy is not an alternative considered in detail 

because it doesn’t meet the purpose and need.

The Santa Fe National Forest’s current motorized travel policy is unclear and inconsistent. 

Numerous sources, including the forest visitor map, forest plan, closure orders, and databases, 

contain divergent direction on where motorized use is allowed. For instance, the forest visitor 

map does not allow people to drive off roads in the northern half of Anton Chico, but this unit of 

land is part of Management Area G, where the forest plan allows off-road driving. Or, most of the 

forest’s trails were built for nonmotorized uses according to the INFRA database; however, 

motorized use is not prohibited on most of them. The current travel policy does not have 

consistent, uniform closure dates. Ranger districts close some roads to protect wildlife during the 

breeding season and others when the roads are too wet and soft. Many roads close themselves 

when it snows. The policy now does not specify what kinds of vehicles are allowed in certain 

places. 

A map of where motorized travel is allowed now is in the project record. Table 75 summarizes 

where motorized travel is allowed now. The explanation of how we arrived at this table, including 

the assumptions, is found in the project record in a document called “Process for Developing 

Summary Tables for Chapter 2 and the Appendices” dated December 23, 2011. 

Table 75. Current policy for motorized travel on the Santa Fe National Forest (SFNF)

Type of Route Miles 

(percent of total forest system)

All system roads and trails on SFNF (total does not include the unauthorized 

routes since these are not part of the forest’s transportation system.) 6,918 (100%)

System roads not managed as open for motorized use 1,349 (20%)

System roads managed as open for motorized use 5,084 (74%)

Unauthorized routes that may be open for motorized use* 914 (NA)

System trail built for nonmotorized uses outside wilderness* 459 (6%)

Motorized system trails 26 (less than 1%)

*If the route is in a place where motorized cross-country travel is allowed, then driving on the route is allowed.

Type of Area Acres 

(percent of total forest system)

Total acres of National Forest System lands on SFNF (does not include private 

or other inholdings) 1,553,369 (100%)

National Forest System lands open for any kind of motorized use 821,644 (53%)

Fixed-distance corridor – solely for motorized access to dispersed camping None specified, or inconsistent**

Fixed-distance corridor – solely for motorized retrieval of downed big game None specified

**In management areas where motorized travel off roads is not allowed, the forest plan’s off-road vehicle map allows 

people to drive off roads for up to 100 yards for the purposes of parking and motorized camping. The forest visitor 

map says “off-road use is prohibited [in restricted areas] except to pull off roads and trails up to 300 feet for 

camping.” Either way, this totals approximately 22,000 acres and is included in the 821,644 acres where motorized 

cross-country travel is allowed.
Appendix 4. The Forest’s Current Motorized Travel Policy

274 FEIS for Travel Management on the Santa Fe National Forest

Roads and Trails

All the miles of roads and trails considered part of the current motorized travel system are shown 

in row 1. This mileage totals 7,515. Even though all of them are part of the system, we don’t 

currently manage them all as open for motorized use.

The miles of road managed as closed to motorized use (2,380 miles) are shown in row 2. This

figure is about one-third of all the forest’s roads. In theory, no one should be driving on these 

roads since they are closed. Field surveys, however, show that people drive on some of these. 

People use some of these roads because most are not posted closed or the road has not been 

effectively barricaded at the entrance, no comprehensive list of closed roads is readily available to 

the public, and some of these roads are in places where driving cross country is allowed. Some of 

the miles in the closed category may not even be roads—they could be fence lines or rock 

slides—and forest personnel have not had time to field verify them. Others are listed in the 

database as being managed by another jurisdiction, like a county. Even though these are clearly 

open and regularly used, they are not “owned” by the Santa Fe National Forest so they are 

considered “closed.” Some of the closed roads are mistakes in the data entry.

The forest manages 4,650 miles or 62 percent of the roads as open to motorized use (row 3). Even 

though these are supposed to be open to all vehicles, field visits show that some of these roads are 

used so infrequently that they are no longer passable (USDA Forest Service 2008b and 2012d). 

Many of these roads are not needed. Some duplicate each other by going to the same place, others 

are used only for administrative purposes, and some are simply not used.

The miles of unauthorized routes we know about are shown in row 4 (329 miles). Unauthorized 

routes are not part of the forest’s transportation system (36 CFR 212.1). The Forest Service did 

not design them and does not maintain them. Most of these are located in places where driving off 

a road is allowed, so driving on them is not illegal. People who ride vehicles recreationally 

provided us with locations for most of these routes. More probably exist, but we don’t know how 

many or where they are located. The Travel Management Rule doesn’t require a complete 

inventory of unauthorized routes in order to complete the planning process (70 FR 68269).

There are 459 miles of system trail built for nonmotorized uses located outside of congressionally

designated wilderness areas (row 5). These represent the nonmotorized National Forest System 

trails that could be considered for motorized use. No miles of trail within wilderness areas were 

counted because motorized travel is prohibited. Though the Santa Fe National Forest built these 

trails for nonmotorized uses, like hiking and horseback riding, it allows motorized use on most of 

them. Under current policy, if these trails are located in areas of the forest where driving off road 

is allowed, then motorized use of the trail is also allowed. Some of the trails cross places closed to 

motorized use; however, most of these nonmotorized areas are not signed on the ground. A person 

riding on a trail, therefore, would not know when they had entered a nonmotorized area. A trail 

might weave in and out of a nonmotorized area, making compliance and enforcement difficult.

There are only 27 miles of trail that the Santa Fe National Forest built for motorized uses (row 6). 

Approximately 8 miles are coincident with roads, meaning the trail and the road overlap. Though 

there are few miles of trail built specifically for motorized use, that use has been relatively 

unrestricted in the rest of the forest. People are allowed to drive off roads and trails on over half 

the forest and most system trails now allow motorized use.
Appendix 4. The Forest’s Current Motorized Travel Policy

FEIS for Travel Management on the Santa Fe National Forest 275

Areas and Fixed-distance Corridors

The 1,553,369 acres of National Forest System lands within the Santa Fe National Forest’s 

boundary are shown in row 7. This figure excludes land held privately. It is all the acres of public 

land managed by the Santa Fe National Forest.

The acres where motorized cross-country travel is allowed now—821,644 or 53 percent of the 

National Forest System lands—are shown in row 8. This calculation excluded slopes greater than 

40 percent due to direction in the forest plan. Even though these acres permit motorized crosscountry travel, it may not be possible to drive on all of them due to terrain or thick vegetation. 

Row 9 shows that the Santa Fe National Forest does not currently have well defined limits on 

places where people can drive to go camping in the forest. The forest’s current direction allows 

people to drive and camp where driving off road is allowed, on 821,644 acres. The forest’s policy 

on driving to camp varies between the forest plan and the visitor map. As a result, the 

interdisciplinary team concluded that no special corridors just for motorized access to dispersed 

camping exist.

Under the current motorized travel system, people can drive to retrieve downed game where 

driving off road is allowed, on 821,644 acres (row 10). They can also scout for game by driving 

off roads except during the hunting season. More specifically, under New Mexico State Law, “It 

is illegal to drive a motor-driven vehicle off established roads or two-track roads in a hunting area 

if the vehicle bears a person licensed to hunt. . .for species on which season is open in that area” 

(New Mexico Department of Game and Fish 2009).
FEIS for Travel Management on the Santa Fe National Forest 277

Appendix 5. Roads, Trails, and Fixeddistance Corridors Proposed for 

Designation that May Not Appear 

on the First Motor Vehicle Use Map

Some roads, trails, and fixed-distance corridors proposed for designation in the preferred 

alternative, 2M, may not be shown on the first motor vehicle use map for one or more of the 

reasons shown in table 76. Some may never appear on a motor vehicle use map should surveys 

show adverse impacts or requirements cannot be met. Others may require mitigations prior to 

appearing on the map. None will appear on the motor vehicle use map until all requirements are 

met. Figure 71 summarizes the miles and acres of roads, trails, and fixed-distance corridors that 

may appear on the first, or subsequent, motor vehicle use map until the issues associated with 

them are resolved.

Summing the miles in table 76 results in an incorrect total. Many routes and corridors fall into 

more than one category—for example needing GPS and heritage survey—so mileage appears in

both columns, effectively double counting mileage in many cases.

Table 76. Miles of routes and corridors that may not appear on the first motor vehicle use 

map

Heritage 

Survey and 

Clearance

Reason(s) for not appearing on the Motor Vehicle Use Map*

Jemez 

Mountain 

Salamander 

Survey

Safety/Stability 

Assessment, 

Las Conchas 

Fire

GPS

Road 

Management 

Objective

Connector Other

Roads, miles 11.6 3.4 49.1 2.7 12.6 17.1 19.7

Roads with 

fixed-distance 

corridors, 

miles

0.9 0.3 7.4 0 0 1.4 0

Motorized 

trails, miles

23.5 53.8 47.9 9.9 0 19.7 19.9

Fixed-distance 

corridors only, 

miles

63 12.7 15.6 0 0 10.0 0.6

* Please refer to the source table, “GEN15_OnHoldReasons_20120413.xlsx” (the tab called “On Hold Detailed”), to 

find a list of the specific routes, reasons, and exact mileages.

Once the requirement(s) are met, the road, trail, or fixed-distance corridor will appear on the next 

version of the motor vehicle use map, or it will otherwise be signed as open on the ground in the 

interim. No additional analysis under the National Environmental Policy Act is required to 

publish the list of routes and corridors in this appendix on a motor vehicle use map once the 

requirements are met because all other environmental analysis is contained in this final 

environmental impact statement.

The effects of not having these roads, trails, and fixed-distance corridors on the first, or 

subsequent versions, of the motor vehicle use map is qualitatively within the significance of the 

effects described in alternative 3. Alternative 3 proposes no driving off road for any reason, so the 

effects of not having some fixed-distance corridors are described. Even in the unlikely event that 
Appendix 5. Roads, Trails, and Fixed-distance Corridors Proposed 

for Designation that Won’t Appear on the First Motor Vehicle Use Map

278 FEIS for Travel Management on the Santa Fe National Forest

none of the routes below ever appear on the motor vehicle use map, alternative 3 proposes even 

fewer miles of roads and trails. Thus, the effects are qualitatively described at the forestwide 

scale. Conversely, the effects of having every road, trail, and fixed-distance corridor listed in this 

appendix on the motor vehicle use map are covered with the analysis of the alternatives in chapter 

3 because alternative 4 proposes more roads, trails, areas, and fixed-distance corridors than are 

listed here.

Not meeting one or more of the following is the reason that a road, trail, or fixed-distance 

corridor won’t appear on the motor vehicle use map:

1. Cultural resource survey and clearance. The roads and trails in this category contain 

some unauthorized and closed forest system routes proposed for designation. Not all the 

cultural resource survey and clearance for routes and fixed-distance corridors requiring 

review under Section 106 of the National Historic Preservation Act will be finished at the 

time this decision is made. Under the “Standard Consultation Protocol for Travel 

Management Route Designation” dated September 25, 2007 (appendix I to the “First 

Amended Programmatic Agreement Regarding Historic Property Protection and 

Responsibilities” dated December 24, 2003), until a route or area has had survey,

clearance, and concurrence from SHPO, it won’t appear on the motor vehicle use map. 

Under the agreement, the forest has up to 3 years to complete the clearances. 

To appear on the motor vehicle use map: 

Forest staff need to conduct cultural resource survey and clearance under Section 106 of 

the National Historic Preservation Act. Should the cultural resource survey and 

clearance—as concurred with by the State Historic Preservation Officer—indicate no 

adverse effects to cultural resources would occur, the routes and fixed-distance corridors 

would appear on the next version of the motor vehicle use map.

Should the cultural resource survey and clearance determine that a proposed road(s), 

trail(s), area(s), or fixed-distance corridor(s) causes adverse effects, the route(s) or area(s)

would not be shown on the map at all, or until the adverse effects are mitigated as 

described in chapter 3. 

2. Jemez Mountain salamander survey. The roads and trails in this category contain some 

unauthorized and closed forest system routes proposed for designation. Pursuant to the 

conservation management plan, surveys for Jemez Mountain salamander in occupied, 

potential, and survey habitat must be completed prior to routes and areas being published 

on the motor vehicle use map. 

To appear on the motor vehicle use map: 

Forest staff will conduct surveys for Jemez Mountain salamander pursuant to the 

conservation management plan. The Forest Service will discuss the survey results with 

the Endemic Salamander Team, and strategies for mitigating impacts to the salamander 

would be developed in order to list the route on the motor vehicle use map. If the team 

determines that adverse impacts to the salamander or its habitat can’t be avoided, the 

route won’t appear on the motor vehicle use map.

3. Safety assessment of routes and fixed-distance corridors in the Las Conchas Fire 

perimeter. The roads and trails in this category contain unauthorized and forest system 

routes proposed for designation. Most routes and fixed-distance corridors in the Las 
Appendix 5. Roads, Trails, and Fixed-distance Corridors Proposed 

for Designation that Won’t Appear on the First Motor Vehicle Use Map

FEIS for Travel Management on the Santa Fe National Forest 279

Conchas Fire perimeter are potentially quite dangerous as a result of the fire and 

subsequent flooding—trees falling, roads being washed away, and other events. 

To appear on the motor vehicle use map: 

Forest staff anticipate it being several years before some of the routes are stable enough 

to be safe, maintained, or repaired (USDA Forest Service 2012a). Until forest staff 

assesses the routes and corridors and considers them safe for public use, they won’t 

appear on the motor vehicle use map.

Some routes and corridors, if they continue to pose safety hazards, may never appear on 

the motor vehicle use map. Please refer to appendix 6 for a complete discussion of the 

changed condition caused by the Las Conchas Fire.

4. Road management objectives. The roads in this category contain some unauthorized 

roads. Pursuant to Forest Service Manual 7703.26, a road must have a signed road 

management objective prior to being included in the forest’s transportation system. 

To appear on the motor vehicle use map:

Forest staff must create a road management objective for each road, most commonly 

done with a field visit. If, on visiting the road, engineering problems—such as 

nonexistent or unsafe roads, or roads requiring heavy maintenance—are found, the road 

may not appear on the motor vehicle use map until the road is repaired, or analysis to 

construct it is completed under the National Environmental Policy Act. 

5. GPS. The roads and trails in this category contain unauthorized routes. 

To appear on the motor vehicle use map:

Routes must be GPS’d by the Forest Service prior to appearing on the motor vehicle use 

map to ensure they are in appropriate locations. Once GPS’d, forest staff might find that 

other surveys, such as cultural resource or Jemez Mountain salamander, are required. If 

other survey, clearance, or analysis is required, the route wouldn’t be published on the 

motor vehicle use map until those requirements are met.

6. Other reasons. The routes in this category are unauthorized and open and closed forest 

system. Some system and unauthorized routes won’t appear on the first motor vehicle use 

map for other reasons. For instance, on the Coyote Ranger District, a portion of a road is 

concurrent with the Continental Divide Trail. Until the Continental Divide Trail is 

rerouted off the road, the road won’t appear on the motor vehicle use map.

To appear on the motor vehicle use map:

The routes in this category will be published on the motor vehicle use map after their 

unique situation has been met. This includes, but isn’t limited to being routed outside of 

an inventoried roadless area, constructing a turnaround at the end of the road, being 

routed off the Continental Divide Trail, and other situations.

7. Connectors. In most cases, the routes leading to any of the ones in the above categories 

won’t appear on the motor vehicle use map (figure 71).
Appendix 5. Roads, Trails, and Fixed-distance Corridors Proposed 

for Designation that Won’t Appear on the First Motor Vehicle Use Map

280 FEIS for Travel Management on the Santa Fe National Forest

Figure 71. The section of Forest Trail 726A in 

orange falls into one of the categories above; 

however, none of 726A will appear on the motor 

vehicle use map until the issues with the section in 

orange are resolved.
FEIS for Travel Management on the Santa Fe National Forest 281

Appendix 6. Changed Conditions

Due to the 2011 Las Conchas Fire

Purpose

The purpose of this appendix is to describe the changed conditions in the perimeter of the 2011 

Las Conchas Fire (fire) as they relate to the Santa Fe National Forest’s (forest) travel management 

planning process. 

This final environmental impact statement for travel management analyzes alternatives 1, 2, 2M, 

3, 4, and 5. This supplemental information report describes the changed conditions and the 

resultant changes to alternative 2M, the preferred alternative, as a result of the 2011 Las Conchas 

Fire.

Finding 

No supplementation to the analysis presented in the final environmental impact statement for 

travel management as a result of the 2011 Las Conchas Fire is needed. The reasons are: (1) the 

changed condition affects an insignificant amount—approximately 2 percent—of the forest’s 

acreage; (2) the routes and areas that won’t appear on the first motor vehicle use map and the 

designations and changes to the preferred alternative, 2M, constitute a minor variation of 

alternative 2M as analyzed in the body of this FEIS; (3) the effects of the changes are within the 

significance of the effects of the alternatives already analyzed; and (4) the analysis and 

conclusions presented in the FEIS remain valid.

Background

Changed existing condition. The Las Conchas Fire began on June 26, 2011, as the result of a 

windthrown tree striking and shorting out a power line. It burned approximately 156,000 acres. 

About 79,000 acres were on National Forest System lands, and 46 percent of these burned at high 

severity (a measure of the burn’s effects on ground condition and soil function) (figure, next 

page).

The burned area, especially the portions considered moderate or high severity, are likely to 

remain unstable for several years to come.

Field information and research indicate that the greatest impact to soil and watersheds after a fire 

is the lack of organic ground cover and vegetation. This is true in the fire’s burned area. The areas 

considered burned to high severity on steep slopes resulted in, and will continue to result in, 

increased runoff and sedimentation, which causes flooding downstream. Flooding and debris 

flows, in turn, wash out roads and trails (USDA Forest Service 2012a).

Increased surface runoff also accelerates soil erosion. In the moderate and high soil burn severity 

locations, approximately 25 percent of the land area is on slopes greater than 40 percent. Intense 

summer thunderstorms common to this geographic area have the potential to cause widespread 

surface erosion, resulting in ash and sediment delivery to stream channels and drainages. High 

flows, sedimentation, and debris torrents occurred the first monsoon after the fire and will likely 

continue for many years to come (USDA Forest Service 2012a).
Appendix 6. Changed Conditions Due to the 2011 Las Conchas Fire

282 FEIS for Travel Management on the Santa Fe National Forest

Figure 72. Fire severity map of the Las Conchas Fire which occurred in 2011
Appendix 6. Changed Conditions Due to the 2011 Las Conchas Fire

FEIS for Travel Management on the Santa Fe National Forest 283

Changes to Alternative 2M Proposed 

as a Result of the Las Conchas Fire

Routes not proposed for designation in alternative 2M. The following roads and motorized 

trails wouldn’t be designated at all and wouldn’t appear on the motor vehicle use map for the 

foreseeable future:

• Forest Road 139 from Forest Road 266 (Hondo Canyon) both north to the springs and 

south. Forest Road 139C was also removed since it is accessed by Forest Road 139.

• Forest Road 89 and 268 in Cochiti and Bland Canyons.

• Forest trail 113.

The roads and trail listed were obliterated by the floods that followed the fire. 

Roads, trails, and fixed-distance corridors in alternative 2M that may not appear on the 

first motor vehicle use map. Some roads, motorized trails, and fixed-distance corridors won’t 

appear on the motor vehicle use map until forest staff has assessed them for safety and until they 

have stabilized. This is explained in appendix 5. Table 77 shows the miles and acres of alternative 

2M that would not appear on the motor vehicle use map until they have been assessed and 

considered stable and safe.

All the environmental analysis required by NEPA and the Travel Management Rule has been 

completed for these routes and corridors. To be placed on the motor vehicle use map, these routes 

need to be assessed by forest staff and deemed safe for public use. Some routes may not be safe 

or stable for 3 to 10 years, if ever. Others may be published on the first version of the motor 

vehicle use map.

Table 77. Miles and acres of alternative 2M that may

not appear on the first motor vehicle use map as a 

result of the Las Conchas Fire

Type of Route Miles

Road 49

Motorized trail 48

Fixed-distance corridor 23

Change in vehicle use allowed. As a result of the fire, approximately 2 miles of roads would be 

opened to all vehicles in alternative 2M. During the fire, bulldozers creating fire line smoothed 

out and widened these system roads.

Significance

To evaluate whether supplementing the final environmental impact statement is necessary, the 

question to be answered is whether the changed condition and changes in the preferred alternative 

“show that the remaining action will ‘affect the quality of the human environment’ in a significant 

manner or to a significant extent not already considered...” (Marsh v. Oregon Natural Resources 

Council, 490 U.S. 360, 374 (1989)).
Appendix 6. Changed Conditions Due to the 2011 Las Conchas Fire

284 FEIS for Travel Management on the Santa Fe National Forest

The changed conditions, and resultant changes to preferred alternative 2M, are not significant in 

light of the analysis contained in the final environmental impact statement for two reasons.

1. The analysis contained in the FEIS is at the forestwide scale. The high burn severity 

portions of the fire, which are primarily the ones triggering the changes to the preferred 

alternative, amount to only 2.3 percent of the forest’s total acreage. 

2. Second, the changes in alternative 2M are: (1) minor variations to alternative 2M; and (2) 

within the scope of the effects analyzed in alternatives 2 through 5 presented in the draft 

environmental impact statement for travel management:

Russell Country Sportsmen v. United States Forest Service, 2011 WL 4820942 (9th 

Cir. 2011) (“NEPA does not require the Service to prepare a supplemental draft 

environmental impact statement [] where... the final decision makes only minor 

changes and is qualitatively within the spectrum of the alternatives discussed in the 

draft EIS.”). In Russell Country, the Court adopted the Framework in CEQ’s 40 

questions on supplementation of DEISs (quoted below) to set out the following twopart test: “supplementation is not required when two requirements are satisfied: (1) 

the new alternative is a ‘minor variation of one of the alternatives discussed in the 

draft EIS,” and (2) the new alternative is ‘qualitatively within the spectrum of 

alternatives that were discussed in the draft EIS.’”

The changes proposed in alternative 2M constitute a minor variation of those analyzed in 

the FEIS. The roads and motorized trails that would not be designated as a result of the 

fire compose less than 1 percent of the forest’s proposed motorized transportation system. 

The roads and motorized trails that may not appear on the first motor vehicle use map are 

likely to remain part of the designated system—meaning there would be no change from 

what is analyzed in the FEIS. If, however, they weren’t designated because they remain 

unsafe or unstable, the significance of the change is qualitatively within that analyzed in 

alternative 3. 

Alternative 3 proposes fewer miles of roads and trails than alternative 2M, even 

considering the routes that may not appear on the first motor vehicle use map. Alternative 

3 proposes 53 miles of motorized trail. Even if none of the motorized trails in the fire’s 

perimeter are ever put on the motor vehicle use map, alternative 2M still would provide 

160 miles of motorized trail across the forest1

. Alternative 3 proposes no driving off roads 

or motorized trails for any reason; thus, not showing the fixed distance corridors in the 

fire’s perimeter—meaning no driving off road in the fire perimeter until the corridors are 

assessed as being safe—is a concept already analyzed in the DEIS (pp. 83, 88, 131-133, 

166 as examples).

/s/ Maria T. Garcia

MARIA T. GARCIA

Forest Supervisor

 

1 Total mileage of trails proposed in alternative 2M is 207.8. Subtracting 47.9, the miles of motorized trail in the fire’s 

perimeter, still leaves 159.9 miles of motorized trail in alternative 2M, or more than three times that proposed in 

alternative 3.
FEIS for Travel Management on the Santa Fe National Forest 285

Appendix 7. Response to 

Comments on the DEIS

Adaptive Management

The Forest Service needs to use adaptive management when managing the motorized travel 

system because the annual revision of the motor vehicle use map will not be responsive enough if 

problems arise.

We did consider using the tool of adaptive management (steering committee meeting notes 

dated February 19, 2009). In theory, adaptive management allows the forest to implement 

changes without further analysis or decisionmaking if the action, trigger, and planned 

response are analyzed in the environmental impact statement. After doing more research, we 

decided that adaptive management is not an appropriate tool for travel management (steering 

committee meeting notes June 25, 2009). The interdisciplinary team researched the 

implementation of adaptive management on other forests and found that it did not work as 

planned or stated, was overly complicated and not attainable, or not supported by funding. To 

meet the intent of the directives, adaptive management must describe and analyze sitespecific conditions, triggers, and the effects of management changes. Because the scale of the 

travel management project is the forest level, it would not be practical to list proposed 

management actions and analyze those effects on a route-by-route basis.

Administrative Use

The Forest Service should not close roads because doing so will limit emergency vehicles’ ability 

to get to fires and rescues, keep ranchers from managing their cattle, and prevent the Forest 

Service from effectively managing watersheds.

After we have designated motor vehicle use on roads, trails, and areas, and we have shown 

these designations on the map, it would be illegal to operate a motor vehicle outside the 

designations. There are exceptions listed in the Travel Management Rule (36 CFR 212.51(a) 

(1 through 8)). Emergency vehicles responding to an emergency do not have to comply with 

the designations. Forest Service vehicles have a limited administrative use exemption—this 

applies across the forest outside wilderness areas. Any person who has a permit from the 

Forest Service can operate a motor vehicle wherever the permit allows. The “Travel Analysis 

Process Report” describes that about 1,400 miles of routes could be kept on the forest’s 

transportation system for administrative use only, not for general public use.

Air Quality

The Forest Service should analyze the impacts to air quality as a result of decommissioning roads 

and trails.

The physical decommissioning of roads and trails is not proposed as part of this project, 

which only designates a system of roads, trails, and areas for motorized use. We have 

described the effects to air quality from this project in this final environmental impact 

statement. 
Appendix 7. Response to Comments on the DEIS

286 FEIS for Travel Management on the Santa Fe National Forest

Alternatives

The Forest Service should consider an alternative that has fewer roads than alternative 3 because 

the road density in alternative 3 is in excess of the best management conditions for large and 

small animals and fish.

Without knowing the specific references to scientific literature about the “best management 

conditions” for mammals and fish, we cannot verify this claim. As described in the wildlife 

report, fisheries report, and biological evaluation, the existence of roads and trails and their 

use affect mammals and fish depending on the species. The action alternatives propose to 

reduce the miles of routes open to motorized use between 46 and 67 percent and do not allow 

motorized cross-country travel outside of designated areas and corridors. We did consider an 

alternative with fewer routes than alternative 3, the “Minimum Motorized Access and 

Recreation Alternative” (p. 46) but did not analyze it in detail.

We are unable to determine the extent to which route-specific proposals have been carried 

forward into the “action alternatives” nor have we been able to ascertain the reasoning and 

analysis, if any, behind these conclusions with reference to Blackfeather’s “South Jemez” area 

trails (about 40 trails).

Three documents in the project record describe how forest staff analyzed the comments from 

the public at each step of the process: (1) “NFMA Comments Content Analysis 

Methodology” dated December 11, 2007; (2) “Content Analysis Methodology for NEPA 

Scoping Comments” dated April 9, 2009; and (3) “Methodology for Receiving and Analyzing 

the Public’s Comments on the Draft Environmental Impact Statement for Travel Management 

on the Santa Fe National Forest” dated April 27, 2012.

The list of the public’s requests for specific routes during the scoping period, and our reason 

for including it or not, is in the “Site Specific Suggestions” report dated 6/2/10. This report 

contains some inconsistencies. Some of these inconsistencies are errors, and others reflect 

outdated information. The latter is a result of field visits conducted during the content 

analysis period, resulting in changes to district recommendations and corrections to maps. 

Documentation of the field visits are in the project record. The document titled “Site Specific 

Suggestion Methodology” dated April 6, 2011, found in the project record describes the 

inconsistencies between the travel management alternative maps and the site specific 

suggestion document. 

Santa Fe National Forest staff were available at all public meetings and have been available 

to answer any questions that the public had in regards to the process. A number of motorized 

and nonmotorized users contacted Santa Fe National Forest staff in regards to some of the 

inconsistencies, and the staff assisted them in understanding the inclusion or exclusion of a 

specific request in the alternatives.

For alternative 5, the DEIS needs to analyze the impact of designating geographically restricted 

motorized use to the quality of recreation being lost either in terms of routes, being concentrated 

in smaller areas, or the stigma of being the “reviled and unwanted” group.

All effects were analyzed identically for all alternatives, including alternative 5.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 287

The Forest Service did not analyze the quality of motorized experiences in its effects analysis.

The Santa Fe National Forest does not rate the quality of experiences or skill level of 

available or proposed trails since a challenging trail to one person may be considered easy by 

another. 

The Forest Service should not choose alternative 1 because it would damage natural and cultural 

resources. 

Alternative 1 serves as the baseline against which to compare the other alternatives. The 

forest supervisor will decide which alternative to select based on the environmental analysis 

and the public’s comments. Alternative 1 doesn’t meet the purpose and need of the project.

The Forest Service shouldn’t choose alternative 2 because it: (1) would damage natural and 

cultural resources, (2) would not protect wildlife habitats since the road density is still high, and 

(3) eliminates too many loop opportunities.

Many people had strong opinions about which alternative the forest supervisor should select. 

The forest supervisor will select an alternative based on the analysis presented in the final 

environmental impact statement and the public’s comments.

The Forest Service shouldn’t choose alternative 3 because it: (1) doesn’t provide enough 

motorized opportunities, (2) only allows the young and healthy to access the forest, (3) doesn’t 

meet the agency’s mandate to provide for multiple uses, (4) reduces access for people who 

depend on forest products, (5) doesn’t provide loop opportunities, (6) wouldn’t allow people to 

get to springs they use now, and (7) too greatly restricts motorized dispersed camping and game 

retrieval.

Many people had strong opinions about which alternative the forest supervisor should select. 

The forest supervisor will select an alternative based on the analysis presented in the final 

environmental impact statement and the public’s comments.

The Forest Service shouldn’t choose alternative 4 because it: (1) would damage natural and 

cultural resources, (2) would harass wildlife, (3) has the potential to create illegal ATV loops, (4) 

would create an ATV park in Canada de los Alamos, (5) increases the number of routes relative 

to the existing condition, and (6) would degrade the visual quality of the forest.

Many people had strong opinions about which alternative the forest supervisor should select. 

The forest supervisor will select an alternative based on the analysis presented in the final 

environmental impact statement and the public’s comments.

The Forest Service should not choose alternative 5 because (1) it would damage natural and 

cultural resources and (2) would fragment wildlife habitat with high route densities in some 

place.

Many people had strong opinions about which alternative the forest supervisor should select. 

The forest supervisor will select an alternative based on the analysis presented in the final 

environmental impact statement and the public’s comments.
Appendix 7. Response to Comments on the DEIS

288 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service should choose alternative 1 because (1) it is the only one that preserves 

existing motorized access, (2) the public should have the right to access public land, (3) it offers 

the greatest opportunity for unrestricted access to important religious and cultural sites, (4) the 

lands on the Santa Fe National Forest are stolen land grants and roads existing before the 

enactment of the Federal Land Management Policy Act cannot be closed, and (5) the agency 

doesn’t have legitimate justification to restrict motorized use.

Alternative 1 serves as the baseline against which to compare the other alternatives. It doesn’t 

meet the purpose and need of the project. The forest supervisor will decide which alternative 

to select based on the environmental analysis and the public’s comments.

The Forest Service should change alternative 1 to ban cross-country travel and select it because 

that is all the Travel Management Rule requires.

We included this alternative in this final environmental impact statement on page 45.

The Forest Service should choose alternative 2 because (1) it provides the best balance between 

access and protection, (2) it would prevent user-conflicts, and (3) it provides hunting access.

Many people had strong opinions about which alternative the forest supervisor should select. 

The forest supervisor will select an alternative based on the analysis presented in the final 

environmental impact statement and the public's comments.

The Forest Service should choose alternative 3 because (1) it best protects natural and cultural 

resources, (2) it best protects inventoried roadless areas, (3) it would have the least amount of 

engine noise, (4) it would improve the current state of chaos on the forest, (5) it’s the best way to 

preserve our historic lands and the off-highway vehicle riders have enough land already,( 6) it 

would best address the conservation needs of the Jemez Mountain salamander, (7) it protects 

headwaters and the Santa Fe Watershed, (8) it would increase the health of the forest, (9) it 

would be the easiest to enforce, (10) it doesn’t condone or encourage user-created routes, (11) it 

promotes safety and use of the forest for future generations, (12) it enhances enjoyment of 

nonmotorized users, who compose the biggest use of the forest, (13) it is the most economic with 

the best potential to use future funds for enhanced partnerships and protection, and (14) it 

provides adequate motorized access.

Many people had strong opinions about which alternative the forest supervisor should select. 

The forest supervisor will select an alternative based on the analysis presented in the final 

environmental impact statement and the public’s comments.

The Forest Service should select alternative 4 because (1) it best allows off-highway vehicle 

access to the forest in a responsible way, (2) it allows disabled people the most access, (3) it has 

the fewest restrictions but still eliminates motorized cross-country travel, and (4) it provides the 

most motorized recreational opportunities.

Many people had strong opinions about which alternative the forest supervisor should select. 

The forest supervisor will select an alternative based on the analysis presented in the final 

environmental impact statement and the public’s comments.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 289

The Forest Service should select alternative 5 because it (1) separates motorized and 

nonmotorized uses and (2) provides the best access. 

Many people had strong opinions about which alternative the forest supervisor should select. 

The forest supervisor will select an alternative based on the analysis presented in the final 

environmental impact statement and the public’s comments.

The Forest Service should add more motorcycle trails to alternative 4 because they are 

challenging when riding enduro’s.

One of the alternatives considered but not analyzed in detail is the “Maximum Motorized 

Access and Recreation Alternative” (p. 46).

The Forest Service should adopt an alternative that reflects the reality of lack of law enforcement 

available.

The interdisciplinary team considered an alternative, the “Enforcement Alternative,” but did 

not analyze it in detail (p. 49).

The Forest Service should modify alternative 3 to include dispersed camping corridors as 

identified in alternative 2.

Alternative 3 would not allow anyone to drive off roads or trails for any reason. We designed 

it this way to respond to the significant issue of protecting natural and cultural resources from 

the damage caused by traveling off roads and trails to camp. If we added corridors for 

motorized dispersed camping to alternative 3, it would blur the lines between it and 

alternative 2; this would not meet the intent of 40 CFR 1502.14, which asks agencies to 

“sharply defin[e] the issues and provid[e] a clear basis for choice among options.”

The Forest Service should make alternative 4 more of an option by modifying the motorized big 

game retrieval corridors. The 2-mile wide corridors make it appear that 90% of the forest is open 

to off-highway vehicles.

Alternative 4 is a valid option. The Travel Management Rule states, “the responsible official 

may include in the designation the limited use of motor vehicles within a specified distance of 

certain designated routes, and if appropriate within specified time periods, solely for the 

purposes of ...of retrieval of a downed big game animal by an individual who has legally 

taken that animal” (36 CFR 212.51(b)). Compared to the existing condition—where people 

drive off roads and trails on about 29 percent of the forest whenever they want—alternative 4 

limits driving off roads and trails by restricting it to game retrieval for people who have 

legally taken an animal during hunting season.

Alternative 5 favors nonmotorized users and discriminates against motorized users. Alternative 5 

seeks to create a forced displacement of motorized users. Alternative 5 creates better experiences 

ONLY for nonmotorized users, not for motorized users. Alternative 5 does not separate users or 

uses; rather it gives the nonmotorized group an enhanced experience, providing no separation 

and protection for the motorized users who still have to share all recreation routes.

Our intent was not to marginalize motorized uses by proposing alternative 5; it was to reduce 

conflicts between motorized and nonmotorized uses.
Appendix 7. Response to Comments on the DEIS

290 FEIS for Travel Management on the Santa Fe National Forest

Alternative 5 is not needed because motorized and nonmotorized uses and users are already 

separated with designated wilderness areas.

This is an interesting concept, but we don’t agree. Many people participate in nonmotorized

uses outside of the forest’s wilderness areas, and alternative 5 was designed to minimize 

conflicts outside of wilderness.

The DEIS fails to analyze an alternative that would not allow any motorized routes in inventoried 

roadless areas.

No prohibition on the use of existing roads or trails in inventoried roadless areas exists.

Assumptions

The assumption (#5, DEIS p. 64) that the effects of motorized trails are the same as roads is 

flawed, so the entire effects analysis in the draft environmental impact statement is flawed.

Motorized trails and roads do not have the same effect because they are different widths and 

often have different surface types.

At a local scale, motorized trails and roads have the same types of environmental effects, 

such as erosion and lack of plant cover. The rates of each effect are also similar (Dissmeyer 

2000, Ouren et al. 2007, Stokowski and LaPointe 2000). For example, 1 square foot of 

motorized trail and 1 square foot of road, with all other variables being equal, will have 

similar erosion rates. Motorized trails and roads do differ in the magnitude of their effects at 

local scales. Because roads tend to occupy more area than motorized trails, the magnitudes of 

their effects tend to be larger (Dissmeyer 2000). Due to the unmanaged nature of the forest’s 

motorized trail system, many motorized trail widths are the same as road widths. Since the 

widths of many motorized trails on the forest are the same as road widths, we considered the 

effects of motorized trails and roads as being the same for the purposes of this analysis. 

The assumption (#6, DEIS p. 64) that all motorized vehicles cause similar impacts is flawed; 

thus, the entire effects analysis is flawed. Different sized vehicles—motorcycles, pickup trucks,

ATVs, tracked vehicles, and others—do have different impacts. The Travel Management Rule 

itself recognizes that different vehicles have different impacts.

Studies show that all motorized vehicle use causes similar types of impacts to forest 

resources, such as trampled vegetation, emitting byproducts of combustion, and others 

(Dissmeyer 2000, Meadows and Geehan 2008, Ouren et al. 2007, Stokowski and LaPointe 

2000, Switaslski and Jones 2009). The Travel Management Rule does not distinguish among 

types of off-highway vehicles for the purposes of effects analysis (70 FR 68273).

The assumption (#1, DEIS p. 63) that traffic will not increase on the designated routes is 

incorrect and renders the entire analysis incorrect. It does not make logical sense that closing 

over half the roads and trails to motorized use will not concentrate motorized use on the 

remaining system. 

The roads report discusses the issue of concentration in depth. We have not found any 

evidence that closing routes that are infrequently used results in overcrowding on the 

remaining system.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 291

Concentration of Use

Publishing a motor vehicle use map will increase the amount of off-highway vehicle use because 

now the routes will be shown on a map. More off-highway vehicle use will result in more damage 

to natural and cultural resources.

We have found no evidence that publishing a motor vehicle use map will increase motorized

use on the forest. The Santa Fe National Forest publishes a number of maps that show roads 

on the forest. Other agencies and private companies publish maps that show roads on the 

forest. The motor vehicle use map will merely show people where they can drive, and many 

of the roads and trails are already shown on maps, like our visitor maps. Furthermore, most of 

the use on the forest is from the local area and we have no evidence that the motor vehicle use 

map would attract people from outside the area. 

It is important to remember that the Santa Fe National Forest is currently open to crosscountry travel and travel is allowed on any road or trail on the forest. Even in this current 

mode, people do not use every road and trail even though they can. It may be true that more 

off-highway vehicle use will result in more damage to natural and cultural resources, but it is 

not fair to connect the motor vehicle use map with resource damage. With the designation 

process and the motor vehicle use map we are trying to take control of resource damage and 

do what we can to protect resources. We will never protect forest resources absolutely, but we

believe we are making a significant contribution to resource protection and at the same time 

allowing use that people have come to expect on the forest.

The Forest Service should not reduce the roads and trails where people can drive. If motorized 

use is concentrated onto the few remaining routes, it will increase damage to natural and cultural 

resources and be a less satisfying experience for riders.

The specialist report on roads has an extensive discussion on use concentration and why we 

believe that it will not happen on the forest.

Cultural Resources

The forest needs to consider an alternative that would protect cultural resources and 

simultaneously allow for unrestricted motorized access to Jemez tribal members for religious and 

cultural purposes.

This FEIS describes how unrestricted motorized access has the potential to damage cultural 

resources. Allowing that kind of damage would not meet the requirements of the National 

Historic Preservation Act. Should tribal members—or anyone else—require motorized access 

to a special place, they would need to have a written authorization from the Forest Service to 

travel off the designated system.

The Forest Service should correlate incidents of damage to cultural sites with proximity to roads 

or motorized trails and incorporate this into the effects analysis.

The “Standard Consultation Protocol for Travel Management Route Designation” (July 25, 

2007) exempts existing system roads and trails from effects analysis. This FEIS and the 

heritage specialist report completed for travel management route designation does analyze 

effects to cultural resource sites. 
Appendix 7. Response to Comments on the DEIS

292 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service should collaborate more with the local Indian reservations because that will 

help meet the cultural needs of the people.

The forest initiated consultation with 26 tribes via several letters from the forest supervisor, 

and also conducted focused meetings between district rangers and tribal governments. 

Cumulative Effects

The Forest Service needs to display the incremental effects of motorized use on natural and 

cultural resources against cumulative effects from things like grazing, wildfires, hikers, elk, 

mountain bikers, and equestrians. If it does, the Forest Service will see that motorized use causes 

very little impact compared to the other uses.

This comment refers to how we analyze the cumulative effects of past and present actions.

The Council on Environmental Quality provides agencies guidance on analyzing cumulative 

effects. In a June 2005 memorandum, the chairman states that agencies are not required to list 

or analyze the effects of individual past actions unless such information is necessary to 

describe the cumulative effect of all past actions combined. In this case, we believe that 

describing the current aggregated effects of the past actions—resulting in the current 

condition of the forest’s roads, trails, and areas—is sufficient to make a decision, which is to 

restrict where people can drive.

Furthermore, the purpose and need of this project is to designate a system for motorized use.

It will not regulate nonmotorized uses.

By not identifying and considering the environmental impacts of the entire transportation system, 

activities outside National Forest System lands, and other Forest Service activities and large 

natural disturbances, the Forest Service fails to properly analyze the cumulative impacts for this 

project.

The Council on Environmental Quality recognizes that it is not practical “to analyze how the 

cumulative effects of an action interact with the universe; the analysis of environmental 

effects must focus on the aggregate effects of past, present, and reasonably foreseeable future 

actions that are truly meaningful” (CEQ 2005). Chapter 3 of the FEIS does analyze the 

relevant cumulative effects for each resource.

Decision

Please explain the roles and authority of both the decision maker and the public for deciding on 

alternatives within the EIS.

The forest supervisor is the person with the authority to make the decision. The forest 

supervisor also approves the significant issues and alternatives evaluated. The public’s role is 

to send comments from which forest staff identifies significant issues and alternatives.

The Forest Service needs to survey [for heritage] all the routes in the selected alternative before 

the decision or it is potentially removing opportunities outside of the NEPA process.

The decision will reflect the forest supervisor’s desired transportation system, based on the 

information we have at the time of the decision. All routes identified in the decision will have 

been analyzed in the FEIS. Appendix 5 describes the reasons why some routes and areas may 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 293

not appear on the first motor vehicle use map and the reasons why. These routes have also 

gone through the NEPA process and their effects displayed, so no routes are being “removed 

outside of the NEPA process.”

The forest supervisor should make her decision based on the best available science and data from 

studies on the Santa Fe National Forest showing what is best for the environment, not just 

anecdotal evidence.

The regulations for implementing the National Environmental Policy Act direct agencies to 

“insure the professional integrity, including scientific integrity, of the discussions and 

analyses in environmental impact statements” (40 CFR 1502.24). Each specialist has cited the 

relevant studies and best available science in their specialist reports. At the request of the 

public, we have revised the final environmental impact statement to include more of these 

scientific citations. It is not necessary to conduct scientific studies specifically on the Santa 

Fe National Forest to make this decision. The science cited by the specialists applies to the 

Santa Fe National Forest.

The forest supervisor’s decision should provide for a sustainable motorized road and trail system 

that meets current and future needs.

We agree. Since the motor vehicle use map will be published every year, we will have the 

ability to adjust the transportation system—by either adding or removing routes—to meet 

current and future needs.

Deciding on the travel management plan should be a vote and not just decided by the forest 

supervisor.

That the forest supervisor makes the decision, called a “record of decision,” is decided by law 

and policy. The Forest Service Manual (FSM 1909.15, Ch. 26.2) assigns decisionmaking 

authority to the responsible official, which the Code of Federal Regulations defines as “The 

Agency employee who has the authority to make and implement a decision on a proposed 

action (36 CFR 220.3).”

The forest supervisor, when making her decision, should listen to all interested parties rather 

than just one particular group.

The forest supervisor will select an alternative based on the analysis presented in the final 

environmental impact statement and the public’s comments. No group is favored in the 

decisionmaking process, which is objective.

Education

For the plan to be effective, the Forest Service needs to provide an educational component, 

including for children.

We agree. An implementation plan will be completed after the travel management decision, 

and education of the public will be a component of that plan. Education will include various 

programs including those that are appropriate for children such as Tread Lightly.
Appendix 7. Response to Comments on the DEIS

294 FEIS for Travel Management on the Santa Fe National Forest

Emergency Closures

The Forest Service should close some areas to motorized use immediately because not taking 

action will result in damage that will not be repaired.

Part of the purpose of this project is to reduce the detrimental impacts caused by motorized 

cross-country travel, which this final environmental impact statement analyzes in detail. The 

temporary emergency closure section of the Travel Management Rule states that the 

responsible official shall immediately close roads, trails, and areas to motor vehicle use if 

they determine that motor vehicle use is directly causing or will directly cause considerable 

adverse effects on public safety or soil, vegetation, wildlife, wildlife habitat, or cultural 

resources associated with that road, trail, or area (36 CFR 212.52(b) (2)). When we received 

requests for emergency closure, we fully evaluated them and found that the proposed closure 

was not justified. Nothing in the rule prohibits the responsible official from changing 

designations (70 FR 68268) or from using a temporary emergency closure any time it is 

needed.

Enforcement

For the travel management plan to be effective, the Forest Service needs to enforce it.

Forest Service law enforcement personnel play a critical role in ensuring compliance with 

laws and regulations, protecting public safety, and protecting national forest resources. The 

Forest Service also maintains cooperative relationships with many State and local law 

enforcement agencies that provide mutual support across jurisdictional boundaries. Education 

and cooperative relationships with users support enforcement efforts by promoting voluntary 

compliance. The Travel Management Rule will not increase the agency’s budget or the 

number of law enforcement officers. However, the rule will enhance enforcement by 

substituting a regulatory prohibition for closure orders and providing for a motor vehicle use 

map supplemented by signage.

The Forest Service should reduce the number of roads and trails, especially loops, because it is 

difficult to enforce their proper use. Loops enhance illegal hunting and interfere with law 

enforcement.

All the alternatives reduce the miles of roads and trails open for motorized use compared to 

the existing condition. Loop routes provide important opportunities for access and recreation, 

and it is not feasible to only include out-and-back roads and trails in the forest. We are not 

aware of any studies linking loops to illegal hunting or decreased ability to enforce route 

designations.

A motor vehicle use map alone is not robust enough to provide clear management direction. The 

forest should include route decommissioning, an educational program, monitoring, and increased 

enforcement as part of its proposed action.

Whether the alternative that we choose is effective depends to a large part on the public. We 

believe that the Travel Management Rule is one of the most important steps the Forest 

Service has taken to protect forest resources while still allowing adequate access. We intend 

to use monitoring, education, and enforcement to ensure that the alternative that we select 

works. Monitoring, education, and enforcement, however, are part of an implementation plan 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 295

and we will do that work after the designation process is complete. We cannot obliterate roads 

as part of this project because that would be outside the scope of the proposed action. 

The lack of resources to properly enforce existing motorized use is resulting in increased 

degradation to the national forest.

Fifty-three percent of the Santa Fe National Forest is currently open to motorized use. There 

is very little to enforce based on current management. After a decision has been made and the 

motor vehicle use map is published, motorized use off the designated system will be 

prohibited. This change in management is an improvement over existing conditions because it 

provides the Santa Fe National Forest a system that can be enforced. Santa Fe National Forest 

staff believe a designated motorized system will be easier to enforce than the current 

management direction.

Forest Plan

The forest plan should be amended to reflect cross-country travel restrictions on the forest 

consistent with the Travel Management Rule. 

Appendix 1 contains the proposed forest plan amendments.

The Forest Service should have included motorized trails in its calculation of motorized route 

densities because motorized trails have the same effects on natural and cultural resources as 

roads.

The forest plan specifies how road density is to be calculated, and it requires that we calculate 

the density of open roads. Trails, therefore, aren’t included. The specialist report on the forest 

plan contains a detailed discussion. 

The Forest Service shouldn’t let the road density goals in the forest plan guide the closures in the 

travel management process. Road density calculations should be done separately.

Any decisions need to be consistent with the forest plan, or the forest plan needs to be 

amended (36 CFR 219.10). Road density standards and guidelines are specified for most of 

the management areas in the Santa Fe National Forest Plan, which “...defines the direction 

for managing the Santa Fe National Forest...” (p. 1). The proposed alternatives would bring 

the open road density in line with the forest plan’s standards and guidelines. Appendix 1 

contains the proposed amendments to the forest plan.

The Forest Service should continue the special use permit allowing the Department of Game and 

Fish to restock San Gregorio Reservoir.

Should the forest consider it appropriate for the Department of Game and Fish to continue to 

travel on that road to restock the San Griego Reservoir, an authorization can be issued to 

allow travel for this purpose. The forest plan allows this use now. The road that accesses San 

Griego Reservoir is in the San Pedro Parks Wilderness, where no mechanical conveyances, 

including any motorized travel, are allowed. However, 36 CFR 212.51 provides exemptions 

from the designations including “Motor vehicle use that is specifically authorized under a 
Appendix 7. Response to Comments on the DEIS

296 FEIS for Travel Management on the Santa Fe National Forest

written authorization issued under Federal law or regulations.” The decision of whether any 

special use permits will be issued is outside the scope of this analysis. 

The Forest Service should not build roads, and should close existing roads, in management areas 

J, K, M, and N in order to be consistent with the forest plan.

None of the alternatives propose road construction (p. 43). All the alternatives reduce the 

places where people are allowed to drive in management areas J, K, M, and N. Those 

management areas allow roads now, so the alternatives are consistent with the forest plan.

The Forest Service should reduce road densities so that they are consistent with its forest plan.

All the action alternatives meet the open road densities to the standards set in the forest plan

(USDA Forest Service 2012r). 

The Forest Service must explain and analyze forest plan amendments that change road densities.

The forest plan specialist report and appendix 1 explain why we proposed amendments that 

change road densities. Each resource specialist analyzed the effects of the proposed changes 

and included it in their report, or wrote it directly into this FEIS. Each resource section in 

chapter 3 summarizes the effects of the proposed changes.

General

The Forest Service must show how it addressed the March 30, 2009, petition to close roads and 

trails in the Jemez district in the FEIS.

This request is outside the scope of the project. This petition requested the Forest Service 

close roads and trails to motorized use on an emergency basis as allowed in the Travel 

Management Rule. The petition requested action on specific roads and trails and was not a 

comment on the travel management proposal. The forest supervisor responded to the petition 

with a point-by-point response on June 3, 2009. 

The Forest Service should allow continued use on existing routes while they are being surveyed.

After the forest supervisor has signed the order designating motor vehicle use on roads, trails, 

and areas, and the motor vehicle use map has been published, operation off the designated 

system will not be allowed. Until we have completed the required survey(s) described in 

appendix 5, we cannot designate motor vehicle use on the routes or areas.

People who drive off-highway vehicles should follow the state’s guidelines for noise restrictions, 

such as having mufflers.

State law requires that any off-highway vehicle, with the exception of snowmobiles, must be 

equipped with noise reducing mufflers. 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 297

The Forest Service should have prepared one nationwide environmental document for travel 

management because the current system encourages inconsistencies among forests.

The Forest Service designed the Travel Management Rule as a nationwide decisionmaking 

framework to assist forests with designating a motorized system. The Forest Service 

recognized that an effective travel management decision was best created at a local level by 

officials with firsthand knowledge of the area’s particular circumstances with the involvement 

of Federal, tribal, and local governments, local motorized and nonmotorized groups, and 

other local interested parties. The Forest Service recognizes that it is entirely appropriate for 

different national forests to provide different opportunities for recreation and that no forests 

are exactly alike. The Santa Fe National Forest did work with the Carson National Forest to 

minimize inconsistencies because the two forests share boundaries.

The Forest Service should not use herbicides, which are toxic chemicals, because they further 

degrade the forest.

This comment is outside the scope of the project because it does not propose the use of 

herbicides.

Volunteers from Cañada de Los Alamos would like to help with forest reclamation projects and 

maintaining healthy forests.

We appreciate the hard work all our volunteers do to help us maintain the forest, and we look 

forward to working with this community in the future.

The Forest Service should not close any trails to mountain bikers because they are quiet, do not 

pollute, and pose no fire risk.

This comment is outside the scope of the project because it does not propose to close any 

trails to mountain bikers. This project regulates where motor vehicles may use the forest; 

there would be no change in the rules that apply to mountain bikers as a result of this project.

The Forest Service needs to define what a substantive comment is, especially in the context that 

these comments are given “greater weight.”

The section of the draft environmental impact statement called “What Happens Next” (p. 10) 

stated that the forest’s interdisciplinary team would use “substantive comments” to make 

changes to their analysis or modify alternatives. The section also states that some kinds of 

comments “carry less weight” than substantive comments. We regret any confusion that these 

statements caused. 

We read and consider all the comments we receive, not just the “substantive” ones. Anyone 

who sent in a comment to the correct address during the comment period can be assured that 

we read their comment. “Substantive” simply means that the comment is about the project. 

For example, saying “The moon is made of green cheese” is not a substantive comment about 

the Travel Management Rule. On the other hand, saying “I don’t like alternative 3” is. What 

we meant to express is that comments that pertain to the project help us understand the 

public’s concerns about it more than those that do not.
Appendix 7. Response to Comments on the DEIS

298 FEIS for Travel Management on the Santa Fe National Forest

As it did for travel management, the Forest Service should have a parallel initiative to restore 

and regenerate damage done by logging, trapping, overgrazing, and mining.

This is outside the scope of this project, which is to designate a system of roads, trails, and 

areas outside of motorized use.

The Forest Service should add campgrounds if demand warrants.

Currently the campgrounds on the Santa Fe National Forest are rarely at capacity, so there is 

presently no evidence that constructing additional campgrounds is warranted. In any case, 

this issue is outside the scope of this project, which is to designate roads, trails, and areas 

where motorized use will be allowed.

Hunting

The Forest Service should consider increasing quality big game hunting opportunities outside of 

the Valles Caldera National Preserve and wilderness areas to meet local landowner, stakeholder,

and sportsmen desires.

The Forest Service’s task is to manage habitat; managing big game populations is the New 

Mexico Department of Game and Fish’s responsibility. The effects analysis for wildlife in 

chapter 3 shows that having fewer places where people can drive is likely to improve habitat 

for most species. The effects on hunting is described on pages 95 through 97. 

The Forest Service should restrict the use of off-highway vehicles to preserve quality hunting 

experiences. 

The Travel Management Rule focuses on designating motorized use where it is appropriate.

Our goal was to design a balanced system of roads and trails that would meet the needs of all 

users, including hunters, while protecting resources, including wildlife. The Forest Service 

acknowledges that both motorized use and hunting are valid recreational activities. Pages 95 

through 97 describe the predicted effects on hunting.

All roads should stay open because otherwise hunting will be limited to only the wealthy who can 

hire outfitters and guides or who own horses.

Executive Order 13443 requires Federal land management agencies to facilitate the expansion 

and enhancement of hunting opportunities and the management of game species and their 

habitat. We believe we have balanced these two goals by providing sufficient access for 

hunting, while reducing the proliferation of motorized use that can interfere with wildlife’s

use of the habitat. All alternatives in the FEIS include routes where motorized vehicles will 

be allowed. However, all alternatives prohibit cross-country motorized travel except in 

designated areas. In our alternatives, we ensured that motorized access to places most used by 

recreationists, including hunters, were left open. These places were identified through public 

scoping. While access to areas for hunting will still be available, all alternatives do reduce 

motorized access and, therefore, provide larger areas where hunting and game retrieval will 

be done on foot or horseback. Pages 95 through 97 describe the predicted effects on hunting.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 299

Invasive Plants

The impacts of motorized dispersed camping and motorized big game retrieval on the spread of 

invasive plants, especially in areas affected by past fires, is inadequate as presented in the DEIS.

Because it is not possible to predict how many new weed populations would be established as 

a result of motorized cross-country travel, the analysis focuses on the relative risk of weeds 

being transported, introduced, or established based on the number of open acres by 

alternative. The “Nonnative Invasive Plant” section in chapter 3 of this FEIS displays the 

amount of area where driving off road is allowed by alternative. It is recognized that 

disturbed areas are more susceptible to encroachment by weeds than areas without 

disturbance. The analysis lists some typical sites in the Santa Fe National Forest where weed 

species are known to occur. These include: roadsides, trails, gravel pits, parking areas, 

campsites, helispots, high intensity wildfire areas, riparian areas, and administrative sites 

(emphasis added). 

The Forest Service should limit motor vehicles in the forest to only a few primary roads because 

motor vehicles spread seeds of invasive weeds.

Most of the forest’s main routes will remain open under any of the alternatives (p. 88). The 

majority of the roads not proposed for designation are high-clearance roads that currently 

receive little to no use. Routes that remain open to motorized use are a risk for the potential 

establishment and spread of invasive weeds. The forest supervisor will need to take the risk 

of spread of nonnative invasive plants into account when making her decision.

The draft environmental impact statement fails to properly analyze and describe the impacts of 

the alternatives on the spread of noxious weeds and resulting impacts to aquatic and watershed 

resources. 

One of the public’s concerns raised during scoping was that continued public motorized use 

of routes and areas will promote the spread of noxious weeds. Thus, the analysis in the 

nonnative invasive species report focuses on the number of motorized routes and acres of 

areas and the resultant potential risk for weed introduction, establishment, and spread by 

action alternative. The analysis recognized the effects noxious weeds can have to the 

environment, including severely threatening biodiversity, habitat quality, and ecosystem 

functions. The FEIS identifies that motorized vehicles tend to carry and distribute nonnative 

invasive weeds and their seeds, and that some areas are more prone to having populations 

establish and spread than others. 

IRAs, Wilderness

The Forest Service should prohibit off-highway vehicle use near sensitive areas, such as 

designated wilderness, the Valles Caldera National Preserve, and Bandelier National Monument.

The forest analyzed five action alternatives, each containing different configurations of routes 

proposed for designation. We also looked at the effects of designating routes within a half

mile of wilderness boundaries. Forest Service policy does not allow the establishment of 

buffer zones as informal extensions of wilderness. Many trailheads adjacent to wilderness 

provide parking for nonmotorized access to wilderness. Alternative 5 also features a zoning 

concept that looks at wilderness and inventoried roadless areas to lessen the amount of 
Appendix 7. Response to Comments on the DEIS

300 FEIS for Travel Management on the Santa Fe National Forest

motorized routes near these places that possess the qualities of wilderness character. 

Bandelier National Monument and the Valles Caldera are both neighbors to the Santa Fe 

National Forest and staff from both organizations participated. 

The effects analysis for inventoried roadless areas fails to meet current Federal case law.

As of the date of this writing, Federal case law on inventoried roadless areas hadn’t been 

settled. The forest analyzed the effects of motorized routes that went through or were close to 

inventoried roadless areas (IRAs). In the DEIS, we used the five potential wilderness 

characteristics to analyze the effects of motorized use near IRAs. At that time, we did not use 

the roadless characteristics stated in the Roadless Rule due to the conflicting rulings and court 

cases that existed across the country. For the FEIS, however, we decided that using the 9 

characteristics of IRAs is more appropriate because the IRAs on the Santa Fe National Forest 

are not listed as potential wilderness.

The Forest Service should only allow street-legal vehicles near wilderness boundaries to reduce 

noise and off-highway vehicle trespass into wilderness areas.

We have no evidence there is a correlation between the number of forest routes and trespass 

into wilderness areas. We found that most routes near wilderness provide access to trailheads 

and have parking barriers or terrain and topography that make it difficult to drive into the 

wilderness itself. We also haven’t found evidence that having highway-legal vehicles only 

near wilderness reduces trespass. Nonetheless, all the alternatives reduce the miles of roads, 

trails, and areas near wilderness where people could drive.

For this analysis, we assumed that the effects of all vehicles were the same (assumption 6), so 

there would be no difference in the amount of noise caused by different kinds of vehicles near 

wilderness. The discussion on noise in chapter 3 shows that it is transitory and highly 

dependent on terrain. All the action alternatives reduce the places where people can drive, 

thus reducing the number of places where noise might be heard. There is a legal requirement 

that noise from ATVs and off-road motorcycles be limited to a decibel level that makes them 

comparable to the noise from street-legal vehicles. 

The Forest Service must disclose the effect of designating motorized routes in roadless areas on 

potential wilderness designation.

Forest plan revision is the appropriate time and venue to consider designating potential 

wilderness. The issue of potential wilderness designation is beyond the scope of this project, 

which only sets where people are allowed to drive. Nonetheless, all the action alternatives 

reduce the places where people would be allowed to drive in inventoried roadless areas from 

the current condition. 

The fact that motorized uses can be seen or heard from designated wilderness should not serve as

a designation criteria or even a significant decisionmaking factor. The analysis of use within 1/2 

mile of wilderness should be disregarded.

Wilderness areas do not have buffers, and we can allow any otherwise legal activity right up 

to the boundary of a wilderness area. There may be other reasons, however, to restrict motor 

vehicle use near wilderness areas, and these reasons may not relate to the wilderness area. We 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 301

have analyzed the consequences of motor vehicle use. The forest supervisor will make 

decisions that are appropriate for the location.

The Forest Service should prohibit motorized vehicles in inventoried roadless areas (unless it is 

needed to get to private land) to protect the variety of resources found in those areas.

We have analyzed the effects to inventoried roadless areas in chapter 3 of the FEIS. Though 

the status of the 2001 Roadless Rule is still being determined in court, that rule contained no 

prohibition on motorized use in inventoried roadless areas, just on new road construction, 

which we are not proposing.

The Santa Fe National Forest is imposing wilderness standards outside the actual wilderness.

The half mile elimination of all roads and trails near wilderness areas and IRAs due to sound is 

not in accordance with the Travel Management Rule.

We did not eliminate all the roads and trails within a half mile of wilderness or inventoried 

roadless areas in any of the alternatives; we merely analyzed the effects of engine noise 

within that distance.

I support a campaign that will increase the Pecos Wilderness by approximately 50% from 

258,000 acres to approximately 380,000 acres.

This comment is outside the scope of this analysis, which designates roads, trails, and areas 

for motorized use.

The Forest Service must use the nine roadless area characteristics when describing effects to 

inventoried roadless areas. It didn’t take a hard look at the effects of motorized use in IRAs.

For this final environmental impact statement, we did use the nine characteristics of IRAs to 

analyze the effects to IRAs. 

The Santa Fe National Forest needs to adjust analysis of IRA designations according to court 

decisions made since the writing of the DEIS (i.e., 10th Circuit Court of Appeals ruling on State 

of Wyoming's challenge of 2001 Roadless Rule).

The Forest Service analyzed the effects of the project using the nine characteristics of IRAs.

This analysis is appropriate given recent court cases and decisions regarding IRAs.

Jemez Mountain Salamander

The Forest Service should analyze the Jemez Mountain salamander listing on the USFWS 

candidate species list in the FEIS.

The potential effects of the alternatives on the Jemez Mountain salamander are analyzed in 

the biological evaluation. The Forest Service is not required to analyze the potential listing of 

a species. If the Forest Service believes its proposal may adversely affect a candidate species 

and that its listing is imminent, it is the Agency’s discretion to consult with the USFWS.
Appendix 7. Response to Comments on the DEIS

302 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service must analyze the impacts of motorized use and roads and trails to the Jemez 

Mountain salamander on a site-specific basis.

Appendix 5 of this final environmental impact statement describes how roads, trails, and 

fixed-distance corridors that go through Jemez Mountain salamander habitat will be handled.

The Forest Service needs to improve the cumulative effects analysis for the Jemez Mountain 

salamander and its habitat by taking into account all the other uses of trails (cattle, hikers, 

bicycles) in order to display the real impact from motorized use.

In response to this comment, the wildlife biologist has reviewed and improved the cumulative 

effects analysis for all species.

The Forest Service should not authorize motorized big game retrieval in Jemez Mountain 

salamander essential and occupied habitat because it would cause potential mortality and habitat 

degradation for the Jemez Mountain salamander.

The biological evaluation analyzes the effects to the Jemez Mountain salamander from 

motorized big game retrieval. Appendix 5 of this final environmental impact statement 

describes how roads, trails, and fixed-distance corridors that go through Jemez Mountain 

salamander habitat will be handled. The forest supervisor will base her decision on the 

analysis in the FEIS and the public’s comments.

The Forest Service made pre-decisional determinations to exclude certain roads and trails in 

Jemez Mountain salamander habitat from any alternative in violation of statute and regulation.

We did not make any predecisional determinations in this project. The National 

Environmental Policy Act requires us to propose a range of alternatives that meets the 

purpose and need. In this case, nothing requires us to designate motor vehicle use on every 

road and trail because doing so would not meet the purpose and need, which is in part to 

counter the detrimental effects of the use and existence of roads and trails and of driving off 

them. The forest’s wildlife biologists used their professional opinion to recommend what 

roads and trails should be closed to minimize impacts to wildlife such as the Jemez Mountain 

salamander while considering the public’s need to access and recreate in the Santa Fe 

National Forest.

The Forest Service should reduce route densities to protect the Jemez Mountain salamander’s 

habitat.

All the action alternatives reduce open road densities to the standards set in the forest plan.

The biological evaluation displays the route densities proposed specifically in Jemez 

Mountain salamander habitat; all the action alternatives reduce it from current levels. As 

described in the biological evaluation, closing a road to motorized use does not directly 

reduce the effects of the road. This is because the travel management decision does not 

remove the road’s footprint, which represents the largest impact to the salamander. The travel 

management decision may provide future opportunities for reclamation of closed roads that 

may improve habitat for the salamander, but that is not certain.
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FEIS for Travel Management on the Santa Fe National Forest 303

Motorized big game retrieval should not be authorized within essential or occupied habitat 

because it would encourage the use of chainsaws to remove large downed woody debris (a 

primary habitat component of JMS) to access mule deer and elk carcasses.

The claim that people use chain saws to cut their way to downed game appears to be 

anecdotal. We have not found any scientific evidence to support this claim.

It is our understanding that regardless of the alternative selected, if surveys determine that Jemez 

Mountain salamander occur within or near motorized trails proposed for authorization with 

Essential, Occupied, or Priority Survey habitat, those trails will not be authorized.

Whether a route in or near Jemez Mountain salamander habitat is designated depends on sitespecific conditions and findings. The routes that need to be surveyed are the unauthorized 

routes proposed for addition, or the closed system routes proposed for designation. Please 

refer to appendix 5 for a description of how routes in salamander habitat will be handled.

The analysis of effects to the Jemez Mountain salamander in the draft environmental impact 

statement conflicts with the forest’s other environment assessments for livestock grazing.

The effects of travel management do not conflict with the environmental assessments for 

livestock grazing. This environmental impact statement and the environmental assessments 

for the Alamo, Bear Springs, Bland, Del Norte, and Peralta grazing allotments completed in 

2006 and 2007 all include mitigations that resulted in a determination that none of the action 

alternatives would result in a trend toward Federal listing or a loss of species viability. 

The Forest Service should consider impacts to the Jemez Mountain salamander (JMS) and only 

consider critical motorized routes in JMS habitats.

Most of the trails in Jemez Mountain salamander habitat are user created and are displayed in 

the biological evaluation as unauthorized routes. Throughout the travel management process, 

the ranger districts reviewed the motorized system on the district and determined the 

motorized roads and trails needed that best balanced resource impacts with public access.

The Forest Service needs to justify its proposed trail closures in Jemez Mountain salamander 

habitat when the species’ status is stable or improving.

A recent 12-month finding by the U.S. Fish and Wildlife Service places the listing priority 

number for the salamander at “2” (Federal Register 2010–22455, 50 FR Part 17 pp. 54822–

54845). This ranking suggests a high need to list this species based on recent declines that 

were not known during previous NEPA analyses done on the forest.

The life cycle of the Jemez Mountain Salamander (JMS) places this species underground during 

most of the year. How then can motorcycle traffic affect the JMS?

Vehicle use compacts soils and fills interstitial spaces used by the salamander, degrading its 

habitat. Clearing trails by removing logs takes away the salamander’s aboveground habitat 

and increases the dryness of its aboveground habitat. Salamanders prefer moist environments.

Additionally, many of the trails in Jemez Mountain salamander habitat are unauthorized and 

have not been evaluated for impacts to wildlife resources until this travel management 

process.
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304 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service needs to clarify the difference in compaction caused by cattle and 

motorcycles. The [motorcycle] trails are usually less than about two feet wide so soil compaction 

would not limit surface access for the salamander over a wide area.

Compaction caused by cattle is a cumulative effect and is analyzed as such in chapter 3. 

The Forest Service must acknowledge that the chance of motorcycles encountering and harming 

the Jemez Mountain salamander is minute, given the time and frequency with which trail riding 

occurs.

Effects to the Jemez Mountain salamander are not likely to be from direct mortality from 

collision, but from loss or degradation of habitat as described in one of the questions above. 

The forest should not designate unauthorized routes in Jemez Mountain Salamander habitat.

The action alternatives reduce the miles of unauthorized routes within Jemez Mountain 

salamander habitat. Some unauthorized routes have remained in the alternatives to provide 

for recreational riding. Forest staff believes the elimination of cross-country use and the 

overall reduction of motorized routes within the salamander’s habitat will better protect it and 

provide opportunities to improve habitat quality in the future. Appendix 5 describes how 

unauthorized or closed system routes in Jemez Mountain salamander habitat would be 

evaluated for addition in the future.

Keep Motorized Opportunities

The Santa Fe National Forest needs to have follow-up meetings with motorized recreation groups 

to discuss how to incorporate more trails through mitigation, rerouting, loops, etc., after the 

decision.

Since the motor vehicle use map will be published annually, everyone will have the chance to 

suggest changes to it. Changes can be made as long as the appropriate NEPA analysis is done.

The district rangers have an open door policy and are willing to discuss changes to the map.

The Forest Service should relax the seasonal closures proposed in the alternatives because many 

key connector and recreational trails would not be open very often and not meet the recreational 

demand. The seasonal closures in alternative 4 should be from May 1 (not September 1) through 

January 6.

All the action alternatives propose to have 90 percent or better of the routes open for 7 

months or more, and alternatives 2M and 4 do not include seasonal closures in regards to 

weather and instead allow us to close and open routes when conditions change. The seasonal 

closures protect wildlife and meet the standards in the “Santa Fe National Forest Plan.” The 

seasonal closures have been established through other procedures that are beyond the scope 

of this decision. Some alternatives group dates to make the map easier to read, but the 

tradeoff is that the more protective standard is used, resulting in fewer days open. 
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FEIS for Travel Management on the Santa Fe National Forest 305

The Forest Service should designate a motorized system that motorized users approve of to 

enhance the chances that they will comply. Such a system would include trails having technical 

variety and long loops with plenty of single track.

Alternatives 2–5 incorporated routes motorized users gave us to varying degrees. Some of the 

routes were not included in any alternative because our analysis indicated that they would not 

be protective of natural and cultural resources.

The Forest Service should continue to allow the public to drive on all the existing roads and trails 

because the agency’s stated mission is multiple use—which includes recreation—and the public 

has the right to use the land it pays for.

Though we manage forest for multiple uses, the law does not require that we allow people to 

drive anywhere they want to on the forest. Our responsibility is to allow use of the forest, but 

at the same time protect resources. The Travel Management Rule repeatedly emphasizes this 

concept.

The Forest Service should designate more areas for motorized cross-country travel because the 

rule does not require its complete elimination. In particular, more areas should be designated for 

the sport of motorcycle trials, which is a low-impact, family-oriented sport.

The Travel Management Rule states, “Areas designated for motor vehicle use are not 

intended to be large or numerous” (70 FR 68274). The regulation defines an area as “a 

discrete, specifically delineated space that is smaller, and in most cases much smaller, than a 

Ranger District” (§212.1). Our proposed designations reflect this intent. Trials events could 

still be considered under a permit.

The Forest Service needs to preserve the existing motorized opportunities available (hunting, big 

game retrieval, camping, gathering wood, driving to trailheads, and others) so people can use 

their national forest. Wilderness areas exist for those who seek a nonmotorized experience.

The Forest Service is preserving many existing motorized opportunities, but at the same time, 

we have a responsibility to protect forest resources. We have considered many different 

things to arrive at our alternatives during this process. Regardless of the alternative we 

choose, people will still be allowed to engage in their favorite activities on the forest. Hunting 

will still be allowed and so will big game retrieval. All the activities will still be allowed, they 

will, however, be regulated in compliance with the Travel Management Rule.

The Forest Service should designate a large motorized system to start with because it will be 

easier to remove a route that is a problem than it will be to add a new one.

Keeping a large motorized system would not meet the purpose and need of the project, which 

is to counter the detrimental effects of unregulated motorized use. Keeping a route on now 

because it might be more difficult to add back to the system later is not a valid reason to 

designate motor vehicle use now.

The Forest Service should not close open roads because it is illegal and a misuse of regulations.

It is not illegal or a misuse of regulations for the Forest Service to close roads. Congress 

requires that we close some roads. The Travel Management Rule requires that we designate 
Appendix 7. Response to Comments on the DEIS

306 FEIS for Travel Management on the Santa Fe National Forest

motor vehicle use on forest roads. The flip side of the rule is that we will not designate motor 

vehicle use on some forest roads. Through the public involvement process and during the 

environmental analysis process, we have considered what roads we need and what roads we 

do not need. We have made these considerations along with all the other considerations that 

the Travel Management Rule requires.

Mitigation measures should be included in the analysis because it could allow for keeping some 

routes on by mitigating negative impacts to streams or soils with structures like bridges or with 

reroutes. Other NEPA documents incorporate similar mitigation measures (e.g. Polvadera EA) 

that are factored into the decision.

Including mitigation measures for specific routes is not appropriate and would unnecessarily 

complicate the analysis because of the forestwide scale of this analysis. The mitigations 

suggested by the commenter would include ground disturbance, which is best analyzed at the 

site-specific level. The motor vehicle use map is to be published annually, so motorized users 

will have ample opportunity to work with individual ranger districts on specific mitigations 

and routes they would like to see included.

Motorized loop roads help create public safety in case of mechanical failures.

Mechanical failures are always a problem and a risk, but this environmental impact statement 

does not consider mechanical failures. People who use the forest should be aware of the 

condition of their equipment and be prepared for all sorts of problems.

The motorized closures proposed in the draft environmental impact statement aren’t supported by 

the evidence presented. The draft environmental impact states there is very little motorized use 

now. Moreover, it doesn’t present site specific, scientific evidence that motorized use is the 

source of any damage to natural and cultural resources.

At issue is the fact that both the existence and use of motorized routes are detrimental to 

natural and cultural resources. This is described repeatedly in chapter 3. Site specific, 

scientific evidence for each road and trail isn’t necessary for the forest supervisor to make her 

decision. Chapter 3 and each specialist report contains citations for numerous studies that 

describe the detrimental effects of roads and trails. 

Lands

The Forest Service should not show roads that pre-date the Santa Fe National Forest and are 

only used to provide motorized access to private property on the motor vehicle use map. The 

agency should do this without forcing private owners to obtain an easement, which is costly. In 

these situations, the agency should not use cost recovery to charge the owners for surveys, 

easements, and NEPA because the roads have been on the ground for a long time and the owners 

have maintained them for years. The Forest Service needs to ensure that people who own private 

property or who have special use permits have access to their property without putting an 

unreasonable strain on the owners. 

Unfortunately, no provisions in the travel management, special use authorization, or cost 

recovery regulations exist giving the Forest Service the flexibility and accommodation being 

sought by this commenter. In fact, the opposite is true. The various authorities given to us all 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 307

state in one form or another, “such ingress and egress or use shall conform to rules and 

regulations governing the protection and administration of the lands and the roads or trails to 

be used.” In other words, we are required to regulate access over National Forest System 

lands to private lands in the same way for everyone, whether the road in question is newly 

proposed, or established 130 years ago. Implementation of travel management regulations 

provides only a very narrow range of options for these situations, so we can expect difficult 

problems and decisions ahead as we handle requests on a case-by-case basis.

The Forest Service needs to provide a better explanation of how it provides access to private 

inholdings.

While this final statement necessarily abbreviates discussion of how access is provided to 

inholdings, the Lands Specialist’s Report contains a good explanation of authorities, 

requirements, problems, and solutions. Between the draft and the final statement, in order to 

be responsive to the commenter’s concerns, the lands specialist’s report has been further 

revised to provide additional detail.

The DEIS states that the Forest Service does not have the capacity to determine how changing 

where people can drive will change property values, but it is basic to understand that when 

people live in an area to have a quiet experience with nature, the noise and destruction caused by 

off-highway vehicles would be detrimental to property values.

The commenter misunderstands how market value is derived. The question regarding the 

effect on property values caused by noise is addressed in the social and economic specialist’s 

report.

The Forest Service should not designate roads across private lands because it has no right to do 

so.

We have carefully attempted to not designate roads across private lands for which we have 

not acquired an easement. However, there are a few specific instances where we either have 

in the past, or anticipate in the future, taken legal action to protect and have adjudicated the 

public’s rights of access in order to prevent the closure of certain public roads by private 

landowners. We may also have inadvertently made mistakes, and encourage landowners to 

contact us should that be the case.

The Forest Service should not show roads having a private easement on the motor vehicle use 

maps because it will encourage trespass.

With a few exceptions, we tried to follow this theme. If the Forest Service has granted an 

easement to the owner of a private inholding, we typically have removed this road from the 

motor vehicle use map. However, in certain circumstances, there are locations where an 

easement has been issued, but an overriding need for public access across the road has been 

identified. In these few instances, the road has remained open. This is a right we retained in 

the granting of the easements on behalf of the public.
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308 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service should describe the effects to natural and cultural resources of routes kept 

open only to access private land. It should also describe the maintenance burden placed on the 

taxpayer.

The scale of this project is at the forestwide level, and we have analyzed the effects to natural 

and cultural resources from the proposed changes. There is no need to differentiate roads that 

go to private land from other roads. As described in chapter 3, roads historically accessing 

private inholdings were typically created along the path of least physical resistance due to

terrain and natural features. This often resulted in establishment of roads that caused resource 

damage. When these roads were identified as forest system roads, it became more difficult to 

“put the cork back in the bottle.” A direct benefit of the Travel Management Rule will be the 

regulatory strength, over time, to begin the actual movement of roads that access private 

lands out of riparian areas to locations that are much less damaging. Through the special use 

authorization process, each road will receive site-specific analysis to determine the best 

manner in which to protect natural resources. The maintenance burden associated with these 

roads is minimal because those roads that are to be left open only to access private land are 

rarely, if ever, maintained by the Forest Service.

By proposing roads that lead to private as “open to highway legal vehicles only,” the Forest 

Service is preventing private landowners from driving to their property on ATVs or dirt bikes.

This is illegal.

The commenter has correctly interpreted the “open to highway legal vehicles only” restriction 

as one that would affect private landowners from driving to their property on ATVs or dirt 

bikes. However, calling this decision illegal is an inaccurate statement. There exists 

regulation and significant case law which establishes that the Forest Service is allowed (and 

in fact required) to regulate use of National Forest System lands. The question at the heart of 

this comment is whether the proposed restriction is reasonable. Some landowners requested 

that the roads to their private land not allow ATVs or dirt bikes; others did not. We did our 

best to match the proposed designation to the request. Because of this comment, the 

interdisciplinary team specifically re-evaluated and debated the proposed restriction, and after 

lengthy discussion, the acting forest supervisor decided the restriction was appropriate and 

reasonable and has determined that it should remain as proposed.

The DEIS page 120, figure 39 caption states that in theory there should be only one “route” to 

the private property. The DEIS does not disclose what theory this is, or the methodology used to 

develop this theory, nor what authority the agency would be acting under to close one “route”

and not the other. On DEIS page 121 the agency states that some private properties are located 

in Inventoried Roadless Areas (IRAs) and for that reason the roads to the property are not 

designated. This non-designation is a blatant attempt to destroy the value of the property.

This comment has multiple facets, addressed below:

a. The “Santa Fe National Forest Plan” specifically directs “Allow only one private road 

permit for private land or subdivision access unless public safety or natural features 

dictate otherwise.”

b. The forest plan is backed up with authorities found in the Code of Federal Regulations, 

at 36 CFR 251.114, 36 CFR 251.55, and 36 CFR 251.56.
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FEIS for Travel Management on the Santa Fe National Forest 309

c. On reflection, the lands specialist agrees with the commenter that he did not explain 

the authorities and decisionmaking process with regard to access as clearly as he 

should have and has, therefore, revised and updated the lands specialists report to 

more clearly explain the basis for how access decisions are made.

d. The word “theory” in the diagram caption referenced by the commenter was probably 

not the best choice of words. We’ve edited this diagram’s caption in this final 

statement.

e. The DEIS (page 121) does not accurately reflect how private land access within IRAs 

has been addressed. For those properties which are/were served by an actual Forest 

System Road, that access has been retained, due in part to the very issue identified by 

the commenter. Only properties that are/were NOT served by a Forest System Road 

are depicted without access. In this instance, property rights/values should not be at 

issue, because to the best of our knowledge, the right of access had never been 

perfected, so nothing has been destroyed or taken away by the Travel Management 

Rule planning process. If access to the property is desired in the future, the normal 

process for authorizing that would be followed.

Law, Regulation, Policy

The Forest Service is not following the MUSYA because by not allowing motorized use it is 

essentially not allowing any use at all.

The Multiple Use-Sustained Yield Act does not require that the Forest Service allow 

unrestricted motor vehicle use on the forest. The act requires that we consider many things in 

the day-to-day operation of the forest, and one of the things that we must consider is 

recreation. We have considered all the things that we need to consider for this project.

The Forest Service is not following the 1964 National Forest Roads and Trails Act because it is 

not proposing a motorized system that will handle the certain future growth of motorized sports.

The 1964 act cited does not require the current designation of a system that anticipates some 

indeterminate level of future growth. If such growth occurs, the Travel Management Rule

provides for annual revisions of the motor vehicle use map to accommodate that growth.

The Travel Management Rule is another push to manage and intimidate communities rather than 

land, where there are already laws that manage land effectively.

The Travel Management Rule simply requires the national forests to designate a system of 

roads, trails, and areas open to motorized use. Managing motorized use is one aspect of 

managing land. The effects of motorized use on natural and cultural resources are well 

documented in this final statement and the specialist’s reports. The Santa Fe National Forest 

does not intend to manage or intimidate communities; by designating a motorized 

transportation system, it is providing public access to the national forest while minimizing the 

detrimental effects to natural and cultural resources.
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310 FEIS for Travel Management on the Santa Fe National Forest

Closing roads and designating the kind of vehicles allowed on them violates FLPMA (Federal 

Land Policy and Management Act).

The Travel Management Rule went through the Federal rule-making process and it does not 

conflict with FLPMA.

Limited Mobility

By closing most of the roads and trails on the national forest, the Forest Service is discriminating 

against the disabled, elderly, and others with limited mobility. It would prevent people from 

getting outdoors and staying healthy.

The action alternatives treat everyone the same—everyone is allowed to drive in the places 

published on the motor vehicle use map. The Forest Service isn’t legally required to allow 

those with limited mobility to drive places closed to motorized use because such an 

exemption could fundamentally alter the nature of its travel management program (7 CFR 

§15e.103). Reasonable restrictions on motor vehicle use applied consistently to everyone 

aren’t discriminatory.

Maintenance

The Forest Service needs to properly maintain its roads and trails.

Having fewer motorized routes in the forest means that each route can be maintained on a 

more frequent basis than occurs now. The roads and recreation reports contain a detailed 

discussion of maintenance and its costs.

The Forest Service should only designate a motorized system it can properly maintain. Please use 

the cost-estimating model developed by Dr. Michael Wing to do this. The analysis of the impacts 

of a decaying route system that is larger than the Forest Service can afford is lacking in the 

DEIS.

The Travel Management Rule states that the Forest Service must consider “the need for 

maintenance and administration of roads, trails, and areas that would arise if the uses under 

consideration are designated; and the availability of resources for that maintenance and 

administration.” A discussion of maintenance costs appears in the “Recreation” section of 

chapter 3.

We did evaluate the cost estimating model that Dr. Wing developed, and we disagree with its 

assumptions and find it less useful than the system we used. For example, the final section 

estimates the cost of producing motor vehicle use maps for the forest. The spreadsheet 

assumes 2 maps per visit by an off-highway vehicle. The spreadsheet assigns the entire cost 

of producing the maps to off-highway vehicles. This is unreasonable. All motor vehicle

operators will need to know where they can and cannot drive, regardless of the type of 

vehicle. It is unfair to assign the cost of producing the maps to only one type of vehicle.

The Forest Service has a cost estimating system in iWeb. While it is not perfect, it is 

standardized.
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FEIS for Travel Management on the Santa Fe National Forest 311

The Forest Service should not use the excuse of not having enough funds for maintenance to close 

roads and trails because the motorized groups provide a lot of maintenance. Without the 

motorized users keeping trails open, horseback riders and bikers would no longer be able to use 

them, either.

The Santa Fe National Forest truly appreciates the hard work of all its volunteers. Even with 

all the work provided by volunteer groups, including motorized users, the existing network of 

authorized and unauthorized trails is still greater than what can be maintained to a standard 

that acceptably prevents resource damage. Much of the maintenance work on trails done by 

volunteers to date involves cutting out trees that fall over trails. While this work keeps the 

trails open to use, it does not accomplish the maintenance needed to resolve tread wear and 

erosion associated with the trail. There is a limit to the scale of a road and trail system that

can be maintained acceptably. Please see concern 2 of the recreation specialist report for 

analysis regarding this comment.

The Forest Service should make more effort to publicly identify roads and trails in need of 

maintenance—rather than close them—so that the off-highway vehicle community can volunteer 

to maintain and repair them so they do not cause resource issues.

The Santa Fe National Forest enjoys a close relationship with its volunteers and volunteer 

organizations, and volunteer efforts account for a large amount of trail maintenance 

conducted on the forest. Our strategic management of the volunteer maintenance program has 

improved significantly in the last few years, we have begun to accomplish the kind of 

targeted efforts suggested here, and we intend to continue our efforts to improve our 

management of the program in this direction.

The Forest Service fails to analyze data from volunteer hours and maintenance to Forest routes.

This is important to include in the analysis since the Forest repeatedly cites funding limitations as 

a possible limiting factor in determining the scope of the designated motorized system.

The Travel Management Rule focuses on designating motorized use where it is appropriate.

The rule states that the Forest Service must consider maintenance and administration, and the 

availability of resources to conduct that maintenance and administration. There is a limit to 

the scale of a road and trail system that can be maintained acceptably with any combination 

of Forest Service and volunteer maintenance. Available data documenting volunteer work in 

the past are not sufficient to identify quantity or quality of volunteer maintenance to a level 

that would allow a precise prediction of how much future maintenance could be 

accomplished by volunteers. However, it is our judgment that we cannot maintain the system 

currently being used to an acceptable standard with the predicted combination of Forest 

Service and volunteer maintenance.

The Forest Service should keep the existing roads and trails open for motorized use. Having a 

large system means that use is spread out and is therefore easy to maintain because each route is 

not used very often.

Frequency of use is just one of several variables that affect the amount of maintenance 

required for a route. Because of other variables like steepness and soil erodibility, route 

maintenance may still be required regardless of level of use. Even with little or no use, some 
Appendix 7. Response to Comments on the DEIS

312 FEIS for Travel Management on the Santa Fe National Forest

routes still require periodic maintenance to prevent resource damage. Leaving routes open to 

infrequent use will not necessarily decrease maintenance requirements and cost.

Minimum Road System

None of the alternatives represent the minimum road system.

We considered the minimum road system but did not study it in detail for the reasons 

explained on page 46 of the FEIS.

Monitoring

The Forest Service should have a monitoring plan that incorporates public input. The monitoring 

plan would evaluate change over time. The annual plan should focus on: (1) illegal intrusions 

into closed areas; (2) conflicts between users; (3) adverse impacts of motorized use; and (4) use 

the protocols in the forest plan. The monitoring plan needs to be in place at the time the motor 

vehicle use map is published.

We appreciate these suggestions and will consider incorporating them in our monitoring plan. 

The Travel Management Rule requires that we monitor the effects of motor vehicle use on the 

designated system in accordance with the applicable land management plan, as appropriate 

and feasible (36 CFR 212.57). It does not state that we need to have a monitoring plan at the 

time the motor vehicle use map is published.

Motorized Big Game Retrieval

The Forest Service should not allow motorized big game retrieval because there is no evidence 

presented in the draft environmental impact statement that hunters follow the rules when 

retrieving game with motor vehicles. Experience on other forests shows that hunters do not follow 

the rules when retrieving game with a vehicle.

We have no evidence that hunters don’t follow the rules. If a decision is made to allow 

motorized big game retrieval, and hunters do not follow the rules, this becomes an education 

and enforcement issue and will be dealt with accordingly.

The Forest Service should allow motorized big game retrieval because otherwise it renders 

hunting a sport for the wealthy and fit. Some people have physical limitations and need to drive to 

retrieve game. It is impractical to pack out game in difficult terrain.

Four of the five alternatives analyzed in this final statement permit some level of motorized 

big game retrieval. The State of New Mexico has jurisdiction over the activity of hunting.

Currently, if a hunter is disabled, (s)he is allowed to hunt from a motor vehicle. In all 

alternatives, there will be routes open for motorized vehicles, allowing the opportunity for 

disabled hunters.

The forest should allow motorized big game retrieval where there are camping corridors because 

big game retrieval would be logical in those areas.

Each alternative where motorized dispersed camping corridors were designated, big game

retrieval is also permitted. The only alternative that does not contain designated corridors is 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 313

alternative 3. The preferred alternative, 2M, proposes motorized big game retrieval in the 

same corridors designated for motorized dispersed camping.

The Forest Service shouldn’t allow motorized big game retrieval in certain places like 

inventoried roadless areas, within 1 mile of wilderness areas, and on soils with a rating of severe 

in the forest’s terrestrial ecosystem data. 

Alternative 3, which proposes no driving off roads for any reason, most closely honors this 

request. All the action alternatives, however, reduce the places where motorized use would be 

allowed in the entire forest, including the places listed in this comment. Chapter 3 describes 

the impacts of motorized use in and near inventoried roadless areas, wilderness areas, and on 

erodible soils. Minor under the existing condition, the impacts from motorized big game 

retrieval would be reduced under any of the action alternatives. 

The New Mexico Department of Game and Fish recognizes that any OHV use off motorized 

routes establishes tracks that stimulate additional unintended use and subsequent habitat 

degradation, thereby compromising effective control and protection. Alternatives 4 and 5, which 

have 1 mile corridors for hunters to retrieve big game with a vehicle, are not consistent with their 

recommendations to treat hunters the same as other motorized users, and would likely adversely 

affect Rio Grande cutthroat trout, Jemez Mountain salamanders, and their habitats, as well as 

creating additional motorized use in inventoried roadless areas.

We identified motorized big game retrieval as a significant issue based on comments received 

during the scoping period for travel management on the Santa Fe National Forest (significant 

issue 3). To analyze the effects of motorized big game retrieval, a range of corridor sizes and 

locations was considered in the alternatives and their effects are displayed in chapter 3. The 

forest supervisor will determine the size and location of motorized big game retrieval 

corridors based on the effects analysis and input received during the Santa Fe National 

Forest’s travel management planning, including the comments received from the New 

Mexico Department of Game and Fish.

The Forest Service should not designate corridors for people to retrieve big game with a motor 

vehicle for a number of reasons. Driving to get game is not part of the hunting experience; people 

have been walking game out for hundreds of years and can continue to do so. There are already 

special provisions for people with disabilities. Allowing people to drive off roads to get game will 

cause more damage to natural and cultural resources, and it will be too difficult to enforce.

The Travel Management Rule allows the responsible official to designate motor vehicle use 

for big game retrieval in fixed-distance corridors. We have analyzed the consequences of 

allowing motorized big game retrieval to natural and cultural resources on the forest; the 

current use is both irregular and limited. Regardless of what some people believe to be an 

“authentic” hunting experience, we have considered different big game retrieval alternatives.
Appendix 7. Response to Comments on the DEIS

314 FEIS for Travel Management on the Santa Fe National Forest

Motorized Dispersed Camping

The Forest Service should designate corridors that separate motorized dispersed camping and 

ATV use because there are people who enjoy car camping but not ATVs.

The motorized use allowed in camping corridors is strictly for the purpose of camping, and 

this designation does not afford the opportunity for the kind of unlimited motorized use that 

would be present in an ATV play area, for example. Motorized dispersed camping corridors 

are open to cross-country travel by all motorized vehicles within the designated distance of 

the corridor. 

The draft environmental impact statement fails to disclose the direct, indirect, and cumulative 

effects of closing much of the forest to motorized dispersed camping.

Please see chapter 3 for disclosure and analysis associated with motorized dispersed camping. 

The Forest Service should leave large areas open to motorized dispersed camping. Crowding 

people into smaller areas will create conflict, traffic problems, and deteriorate natural and 

cultural resources. People also need a variety of camping opportunities and the limits proposed 

are not likely to provide that.

In 2008 and 2009, the Santa Fe National Forest conducted motorized dispersed camping 

surveys. The surveys captured the locations of the vast majority of motorized dispersed 

camping occurring on the forest. All alternatives, except alternative 3, retain most of the areas 

identified in the 2008–2009 camping surveys. Please see the section on “Motorized Dispersed 

Camping - Environmental Consequences” in chapter 3 for additional information. The Santa 

Fe National Forest provides a wide variety of dispersed camping opportunities, including 

developed, drive-down route, park-and-walk, and back-country camping opportunities.

The Forest Service should not allow motorized dispersed camping because that allows people to 

drive off roads in the corridor. Driving off roads is shown to damage natural and cultural 

resources. People can camp in developed campgrounds.

Motorized dispersed camping is a form of recreation that many Santa Fe National Forest 

users enjoy. Prior to the Travel Management Rule, this type of camping was relatively 

unmanaged. Active management of motorized dispersed camping on the forest will ensure 

that any resource damage is kept to a minimum. 

No motorized dispersed camping should be allowed in Mexican spotted owl habitat.

Right now, people drive to camp in Mexican spotted owl habitat and have been doing so for 

many years. In some cases, Mexican spotted owls have coexisted with this activity for many 

years. All the action alternatives propose to reduce the places where people can drive in 

Mexican spotted owl habitat, which would improve the condition of its habitat. 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 315

For motorized dispersed camping, the Forest Service should designate corridors at least 300 feet 

wide—but up to 900 would be more appropriate—because people don’t like to camp right next to 

the road where traffic causes dust.

The data we collected in 2008 and 2009 reflects where people are currently driving to camp.

It shows that 71 percent of campsites are within 75 feet of an existing road and another 24

percent are between 76 and 200 feet from a road. We did not propose an alternative with a 

larger corridor because the data did not support it. People will still be able to camp wherever 

they want to; this project only limits where people will be able to drive.

The Forest Service should leave large areas open for dispersed camping because some people 

have to sleep in campers or vehicles due to age or disabilities. The Forest Service should leave 

all (or large) areas open to dispersed camping because families and groups enjoy having privacy 

from others and not being an impact on other groups. With privacy, families can also let their 

children wander around without worrying about traffic or other people.

See the answers above.

Motorized Trails

The statement “only alternative 4 proposes to designate more miles of motorized system trail 

than are being used now” is misleading and inaccurate.

Table 60 of the FEIS shows that indeed, alternative 4 does propose to designate more miles of 

new motorized trail than people said they are currently using. About three-quarters of the 

routes given to us by motorized users are already on forest system roads (FEIS, p. 73).

Blackfeather has inventoried more than 570 miles of trail but only 339 miles are shown in 

alternative 1. How did 231 miles just vanish?

Our records show that, at the publishing of the proposed action, motorized users provided 

about 1,074 miles of routes they like to ride on. Of these, 772 miles are already on forest 

system roads, 11 miles are already on forest system trails, and 291 miles are unauthorized. All 

these routes are displayed in alternative 1, which shows where people drive now.

The mileage of current existing motorcycle trails (27) is an error. The Forest needs to include the 

8 trails shown open to ORVs in a 1977 document. If it does not show them, the Forest needs to 

explain why.

The Travel Management Rule at §212.50(b) allows the responsible official to incorporate 

previous administrative decisions regarding travel management made under other authorities, 

including designations and prohibitions. As a result, we used our current database of record, 

“Infrastructure Trails and Access Travel Management,” as the starting point for what forest 

system trails are motorized. If a trail appeared in the database’s “MVUM_TRAIL_ALLOW”

table, we considered it motorized. The trails listed in the MVUM_TRAIL_ALLOW table are

those trails designed for motorized use and where motorized use was encouraged. As of 

October 2, 2009, six trails (113, 146, 273, 279, 285, 286), totaling 27 miles, were in this 

category.
Appendix 7. Response to Comments on the DEIS

316 FEIS for Travel Management on the Santa Fe National Forest

The commenter references a 1977 document that lists these trails as being motorized: 3, 69,

285, 276, 282, 113, 118, and 426. The trails in the 1977 document total about 22.5 miles.

Trail 426 does not exist in Infra. Trail 276 has been decommissioned. Trails 3 and 69 were 

not submitted by motorized users as ones they drive on. Part of 282 was submitted as a user 

provided route, and we designated that part as a motorcycle trail in the proposed action. Trail 

118 is nearly all in the Dome Wilderness and was not submitted as a user provided route.

Generally, motorized use on trails outside of wilderness is accepted but not necessarily 

encouraged. Motorized use on Trails 3, 69, 282, and 118 may be accepted, but not encouraged 

and, thus, were not in the MVUM_TRAIL_ALLOW table.

The Forest Service needs to show the nonmotorized system trails that are being proposed for 

motorized use.

As described on page 86, most of the forest’s system trails were designed for nonmotorized

use, but not specifically limited to that use. Motorized use hasn’t been discouraged on most of 

the forest’s system trails.

NEPA Document

The Forest Service should include a section in the FEIS describing how the public’s comments 

were analyzed and coded.

This final environmental impact statement contains a section on public involvement and how 

comments were analyzed during the comment period for the proposed action. The project 

record contains the reports describing how the team read, coded, and analyzed the comments 

during each phase of the process.

User conflict is not a legitimate significant issue. The Forest Service identified user conflict as an 

issue during development of the Travel Management Rule. 

During the Santa Fe National Forest’s scoping period, the public brought up user conflict. We 

identified it as an issue because the public felt that it was still unresolved by the proposed 

action. The forest supervisor determined that user conflict was a significant issue and 

requested the development of alternative 5 to address it (see the list of final issues and 

concerns.)

The Forest Service needs to display the environmental effects of the alternatives, not simply list 

tables comparing miles of roads and trails. As examples, it needs to calculate the tons of dust and 

sediment and portray the changed recreation settings between groups. The Forest Service needs 

to improve its basic methodology because it does not connect a route’s existence or use to 

specific habitat or site conditions.

Using the miles of roads and trails as a proxy for the magnitude of effects is a well accepted 

method of environmental analysis.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 317

The FEIS needs to better show the effects of allowing motorized cross-country travel in corridors 

designated for motorized dispersed camping or motorized big game retrieval. Allowing vehicles 

to travel cross-country in a corridor to find a place to camp will result in a network of usercreated routes and damage to natural and cultural resources.

Assumption 16 explains why we believe motorized big game retrieval corridors won’t result 

in new routes. Assumption 21 in chapter 3 acknowledges that designating motorized 

dispersed camping corridors is likely to result in the creation of new routes and hardened sites

by assuming the same amount of use in different-sized corridors. Each specialist incorporated 

this assumption into his or her effects analysis for the final environmental impact statement.

The Forest Service should describe or display the different number of campsites that will be 

closed.

No campsites would be closed. The Travel Management Rule only limits where people could 

drive to get to them. Based on the data collected in 2008 and 2009, we believe that we have 

proposed to keep most motorized dispersed camping, either in a corridor or with a spur route 

to a campsite, in all the action alternatives except alternative 3.

To meet CEQ requirements, the FEIS must cite scientific references and describe its 

methodology. 

We have included more scientific citations in this final statement as requested. We also 

summarize the specialist’s methods.

The FEIS needs to specifically disclose how the forest complied with the Travel Management 

Rule. This should include a description on how the criteria in the rule were applied to each road 

and trail.

The record of decision will describe how the criteria in the Travel Management Rule were 

used in the forest supervisor’s decisionmaking process.

The Forest Service should remove “a need to counter the detrimental effects to natural and 

cultural resources from the existence and use of roads” from the purpose and need statement 

because the bulk of the draft environmental impact statement proves that there are not any 

detrimental effects.

We disagree with this opinion and ask the commenter to refer to table 10 in the FEIS. It 

summarizes the effects to natural and cultural resources from the existence and use of roads 

and trails. Further, the detrimental effects of motorized use on natural and cultural resources 

are well documented in the scientific literature and cited in each specialist report.

The FEIS needs to state that it was written in accordance with NEPA and the CEQ regulations.

Thank you for this suggestion. Please refer to page 1.

The Forest Service should rewrite one or more of its significant issue statements because they are 

not accurate. For example, the issue statement about user conflicts is not logical and is being 

used to advance a “minimal OHV alternative.” Just publishing a motor vehicle use map will 
Appendix 7. Response to Comments on the DEIS

318 FEIS for Travel Management on the Santa Fe National Forest

reduce user conflicts drastically by directing forest visitors to areas having the recreation 

experiences they expect.

As stated in the Council on Environmental Quality’s regulations for implementing the 

National Environmental Policy Act, the purpose of scoping is “for determining the scope of 

the issues to be addressed and for identifying the significant issues related to the proposed 

action” and to “identify and eliminate from detailed study the issues which are not significant

40 CFR 1501.7.)” The courts have given the agency considerable deference in how it 

identifies significant issues. We regret that the commenter disagrees with our interpretation of 

the public’s comments.

The Forest Service should reflect in the effects analysis that motorized users are a very small 

minority of recreationists, but have a large negative impact.

Almost everyone who visits the Santa Fe National Forest drives there, whether for 

sightseeing, camping, hiking, hunting, fishing, or for recreation driving, so it is not correct to 

say that motorized users are a small minority. It is true that the people who go to the forest 

specifically to ride OHVs is less than 1 percent, according to National Visitor Use Monitoring

survey data. We have described the effects of all motorized use in chapter 3 of the FEIS.

Mitigation measures should be included in the analysis and decision, similar to other NEPA 

documents.

Chapter 2 lists the mitigations the specialists incorporated into their analysis.

The Forest Service needs to disclose the objective and analyze the effects of changing the 

designation of roads “open to all vehicles” to “open to highway legal only.”

Assumptions 5 and 6 in chapter 3 respond to this comment.

All the data needs to be in the FEIS rather than adjunct reports.

The regulations allow us to incorporate data by reference to cut down on the bulk of 

documents (40 CFR 1502.21). Incorporated material has been briefly described and cited in 

this statement.

The FEIS would benefit from a detailed “methods” section.

The NEPA regulations require that EISs be “analytic rather than encyclopedic” (40 CFR 

1500.4(b)). Thus, we briefly summarize the methods the specialists used to do their analysis 

and refer the reader to the specialist report for a detailed description.

The Forest Service needs to treat the motorized use in the corridors for dispersed camping and 

big game retrieval the same as areas because people will drive wherever they want to in the 

corridors.

We have acknowledged the anticipated effects of allowing motorized use in corridors in 

assumptions 9 and 21.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 319

The DEIS fails to properly analyze and disclose irreversible and irretrievable impacts under the 

alternatives.

We have refined this analysis in this final environmental impact statement.

The Forest Service failed to provide the public with a way to distinguish between which open and 

closed National Forest System roads, motorized and nonmotorized trails, and user-created routes 

the Forest Service is proposing to add to the transportation system. For example, the Forest 

Service fails to identify the location of trails that were designed for nonmotorized use but were 

classified as motorized in the baseline condition.

We did provide the public with a spreadsheet listing every route by number, its proposed 

designation by alternative, and its existing condition (such as open system, closed system, 

decommissioned, etc.) (http://www.fs.fed.us/r3/sfe/travelmgt/deis/index.html—see 

spreadsheet at very bottom of Web page). Using this spreadsheet, anyone can look up what 

routes are closed now and would be open, or vice-versa.

The Forest Service needs to disclose the travel management administrative decisions that are 

incorporated in the decision but made under other authorities, including designations and 

prohibitions of motor vehicle use, in designating roads, trails, and areas for motor vehicle use (as 

per DEIS page 5 and subpart section 212.50(b)).

The “Travel Analysis Process Report” and this statement both describe the current travel 

policy, which is where the forest intends for people to drive now. (This is not where people 

are driving in all cases, as explained many times in the FEIS.) The current travel policy is 

composed of all the “decisions made under other authorities.”

The Forest Service needs to change the name of routes that are not part of the system. Calling 

them “unauthorized” immediately confers an illegal status to them so that people ignore whether 

there are environmental effects or not.

We are merely following the regulations. As defined in 36 C.F.R. §212.1, an unauthorized 

route or trail is a “road or trail that is not a forest road or trail or a temporary road or trail and 

that is not included in a forest transportation atlas.” User-created routes are within the 

definition. Keeping language consistent promotes clarity.

The DEIS and other analyses show that the Forest Service is biased towards nonmotorized users. 

The Forest Service has no authority to take sides in disputes between forest users. Moreover, 

many statements in the DEIS indicate that preferential consideration of desired recreation 

experiences is being given to nonmotorized users.

We regret the perception of bias. Because this project regulates where people can drive—

motorized use—it may appear biased, but that is the direction contained in the Travel 

Management Rule. This project does not regulate nonmotorized uses.
Appendix 7. Response to Comments on the DEIS

320 FEIS for Travel Management on the Santa Fe National Forest

We are concerned that the first motor vehicle use map will not show all of the roads, trails, and 

areas shown in the record of decision because section 106 National Historic Preservation Act 

surveys cannot be completed by the time the record of decision is published.

According to the programmatic agreement with the State Historic Preservation Office for 

travel management, we cannot designate motor vehicle use on certain routes until we have 

completed the archaeology survey and clearance. The agreement stipulates that we have 3 

years to complete the surveys. We may, though, complete the environmental process without 

having the clearances completed.

The Forest Service needs to explain why natural and cultural resources are elevated above 

societal values that result in closing 45% or more of the routes currently being used. The Forest 

Service has no legal authority to elevate natural and cultural resources above social concerns.

On the contrary, this issue was one of the primary motivations that led to the establishment of 

the “forest reserves,” now known as “national forests.” Unregulated extraction and 

consumption of forest products for the general purpose of settling the West led to significant 

natural resource damage. With preservation of sustainable timberlands, watershed protection, 

and wildlife conservation as primary motivating factors, the Federal government passed laws 

first in 1891 and then again in 1897, with the overriding purpose being to withdraw these 

lands from the general Public Domain, and to protect them for natural resource conservation 

purposes.

No Action Alternative

The Forest Service must not include alternative 1 because it is currently in violation of the Travel 

Management Rule.

Regulations require a no action alternative be analyzed in an environmental impact statement 

(40 CFR 1502.14 (c)). It provides a baseline against which to compare the action alternatives.

The No Action alternative is flawed because it arbitrarily eliminates roads and trails from 

consideration and under-reports actual motorized use of the forest. The Forest must give the real 

No Action alternative serious consideration and full treatment. It should either GPS all the roads 

and trails to verify their location, or use all the system roads and trails in the No Action.

Otherwise, the No Action is an inaccurate baseline as presented. The Forest Service is trying to 

make it look like they are closing fewer routes than they truly are.

A number of commenters believe that, because the no action alternative didn’t display every 

route on the forest, that these were improperly removed from consideration. The purpose of 

the no action alternative is to provide a baseline. The no action alternative may be thought of 

in terms of continuing with the present course of action until that action is changed (CEQ’s 

40 Most Asked Questions, 3). Therefore, for this project, the no action alternative is the 

forest’s best estimate of where people drive now, which reflects the current management and 

present course of action. (This is different than every road on the forest, or even different than 

the forest’s current motorized system, which is described in appendix 4.) Any road, trail, or 

area could have been proposed—and many were—for motorized use at any time throughout 

the planning process.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 321

We used the best available information—including data provided by motorized users, field 

trips, traffic counts, and local knowledge—to document where people are driving right now 

and we believe it is accurate, though not perfect. Having perfect information about where 

people drive isn’t necessary to make this decision because the effects of the use and existence 

of routes on natural and cultural resources is well documented.

The no action alternative is given “full treatment” in this final statement.

The No Action alternative, because it included closed, decommissioned, short-term intermittent, 

nonmotorized, and unauthorized routes as part of the baseline system without the requisite sitespecific NEPA analysis, is inaccurate and not legally defensible. By inaccurately defining the No 

Action alternative, the Forest Service is falsely inflating the actual environmental benefits of the 

action alternatives.

As described in the question above, the no action alternative shows where people are driving 

now in the Santa Fe National Forest. This includes closed, decommissioned, and 

unauthorized routes. This final environmental impact statement describes the effects of 

adding unauthorized routes by alternative, thus performing the NEPA analysis requested by 

this commenter.

Alternative 1 does not demonstrate there is damage to natural and cultural resources, so there is 

no justification for closing roads and trails.

We disagree. Chapter 3 clearly displaces the detrimental effects caused by unmanaged 

motorized use and the use and existence of roads and motorized trails.

The Forest Service included closed roads (ML 1) in alternative 1 despite clear policy that the 

public may not use these roads.

The Council on Environmental Quality describes the ways the no action alternative may be 

defined, and we have followed that guidance. The no action alternative may be thought of in 

terms of continuing with the present course of action until that action is changed (CEQ’s 40 

Most Asked Questions, 3). Therefore, for this project, the no action alternative is the forest’s

best estimate of where people drive now, which reflects the current management and present 

course of action.

People are driving on some of the maintenance level 1 roads. In the absence of closure orders 

or physical barriers, some people do not know what routes are open or closed to motorized 

use. 

Adding an unauthorized route to the motorized system requires site-specific analysis of the route.

We agree and have performed this analysis.
Appendix 7. Response to Comments on the DEIS

322 FEIS for Travel Management on the Santa Fe National Forest

The motorized dispersed camping displayed in alternative 1 vastly under-represents the actual 

amount of it occurring in the Santa Fe National Forest. Alternative 1 shows that the public drives 

to camp on only 17,076 acres, yet more than 821,000 acres are actually open to motorized use 

now.

Forest staff collected data in 2008 and 2009 on where people drive to camp. The data show 

that most people (71 percent) camp within 75 feet of a road; 95 percent camp within 200 feet 

of a road. We recognize that the forest’s travel policy allows people to drive on about 821,000 

acres, but staff on the ranger districts believe that the amount of motorized dispersed camping 

that occurs on these acres is relatively small (assumption 18). 

Alternative 1 in the DEIS is flawed because it does not include the 9 areas submitted by the NM 

Trials Association. These are areas where we have had trials events in the past.

To our knowledge, we did include all the known trials areas in alternative 1. Motorized 

groups gave staff at the Jemez Ranger District three separate trials areas: Bear Canyon (13 

polygons), Lake Fork (9 polygons), and Cochiti (5 polygons). The Bear Canyon polygons 

were “absorbed” into a larger area identified by district staff as being used for motorized 

cross-country travel. Thus, the distinctive edges of the Bear Canyon trials areas are not 

shown, but incorporated into the larger cross-country area.

It is inappropriate for the Forest Service to list routes as open system routes for off-highway 

vehicle use when: (1) prior decisions have closed the roads (ML-1), (2) the Forest Service has 

never analyzed the individual routes’ appropriateness for public motorized use or the 

environmental effects of motorized recreational use of the route, and (3) the Forest Service has 

set up its analysis such that the current condition carries through the action alternatives and the 

agency never completes a site-specific analysis before deciding to designate any of these “current 

condition” routes.

The responsible official may—but isn’t required to—incorporate previous administrative 

decisions into travel management (36 CFR 212.50(b)). Deciding to designate a road currently 

managed as closed is a change that is within the scope of this analysis. 

We have done the analysis required by the Travel Management Rule and NEPA in order to 

make changes to the current motorized policy. 

The no action (alternative 1) describes where motor vehicle use is happening now. The action 

alternatives proposed different configurations of motorized routes and areas that aren’t 

necessarily “carried through” from alternative 1.

Historic travel on unauthorized routes represents more than the 7,515-miles used as a standard 

of reference for the existing condition [in the draft environmental impact statement].

This could be true. The Travel Management Rule, however, doesn’t require the Forest Service 

to have a complete inventory of unauthorized routes before making a decision.

Noise

The effects analysis related to noise is incorrect because (1) it doesn’t compare the noise of 

engines to that of other forest users (hikers, fisherman, others), (2) it doesn’t address the impacts 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 323

of noise on other forest users, such as that they are relegated to the backcountry or wilderness if 

they wish to escape engine noise, and (3) it incorrectly characterizes the decibel levels of OHVs 

and how the sound travels.

To answer each of the 3 claims: 

(1) Since the action alternatives propose to change where people can drive, the analysis 

focuses on how noise from engines would change from its current level. There is no 

requirement or need to compare the noise of engines to other forest users since this project 

would not change those. 

(2) The social and economic report does analyze how engine noise would affect forest users.

It does this by estimating the frequency, duration, and magnitude of engine noise and then 

showing how each alternative would change the level of noise. It describes the levels of noise 

predicted in areas meant to be isolated from the sights and sounds of people. The analysis 

shows that all action alternatives would decrease noise from motor vehicles in areas 

designated for primitive and semiprimitive nonmotorized experiences. 

(3) The social and economic specialist report assessed how noise propagates based on the 

best available science, the SPreAD-GIS model, which considers factors including topography, 

climate, prevailing wind, vegetation, and other factors. 

The effects of noise on wildlife are not adequately addressed.

Scientists have studied the effects of noise on wildlife, but the results vary tremendously. The 

effects vary depending on species, type of noise, and time of year. It is difficult to draw 

conclusions from the existing research. In those places where driving is no longer allowed, 

noise would be reduced, resulting in less disturbance to wildlife.

The Forest Service should prohibit ATV use in proximity to residential structures because the

noise is disrupting the residents’ quality of life.

The forest received some comments asking that ATV use near private land be restricted. 

Other comments specifically requested motorized routes to private lands, such as the requests 

for single-track trails to Thompson Ridge or motorized trails along Cochiti Mesa. Based on 

information in the recreation specialist report and the socio-economic specialist report, 

designation of a system of roads, trails and areas for motorized use is expected to reduce 

conflict among various uses of National Forest System lands—including the conflict of noise 

to nearby private lands.

Over-snow Vehicles

The DEIS fails to consider winter travel planning of Over Snow Vehicles (OSV). It has been 

documented in a number of national forests and public lands that OSVs damage alpine tundra, 

trees and vegetation, trails, and water quality. Unregulated OSV use also harasses wildlife, 

trespasses into designated wilderness areas, and results in user conflict with nonmotorized

recreationists.

The regulations at 36 CFR 212.81 state that use by over-snow vehicles may be allowed, 

restricted, or prohibited. The rule does not require that we address over-snow vehicles as part 
Appendix 7. Response to Comments on the DEIS

324 FEIS for Travel Management on the Santa Fe National Forest

of the designation process; they are exempted under §212.51(a) (3). The Santa Fe National 

Forest did not include over-snow vehicles in its designations because we do not reliably 

receive enough snow outside of wilderness areas to consider over-snow vehicles a problem at 

this time.

The discretionary “exemption” for OSVs in the 2005 Rule is not consistent with the 1972 

Executive Orders and does not remove the requirement that the Forest Service comply with the 

Executive Orders.

The 2005 Travel Management Rule implements Executive Orders 11644 and 11989 (70 FR 

68264). The Executive Orders merely require agencies to promulgate regulations providing 

for restrictions and prohibitions on motor vehicle use. The answer above explains why the 

forest didn’t consider over-snow vehicles in this analysis.

Permits and Fees

The Forest Service should have a permitting and licensing program for off-highway vehicles. The 

fees would cover education in forest conservation and to enhance law enforcement.

Federal law does not allow the Forest Service to establish a permitting and licensing program 

for off-highway vehicles. These matters are generally left to the states. This kind of 

permitting and licensing program is already handled by the State of New Mexico.

Physical Barriers

For the plan to be effective, the Forest Service needs to physically block the closed roads and 

trails and install physical barriers on the single-track and less than 50-inch trails to keep the 

right vehicles in the right place.

Though motorized users will be responsible for following the designations in the motor 

vehicle use map, we agree that in some situations physical barriers could help keep vehicles 

in the right place. This project proposes no such barriers or ground disturbance; rather, that 

will be addressed during implementation on a site-specific basis.

Any gates installed should be ADA accessible.

The only portion of the Americans with Disabilities Act that applies to the Forest Service is 

the section specifying that wheelchairs may be used in wilderness areas. ADA mandates 

nondiscrimination in employment and the provision of services by States, local governments 

and private entities. The Architectural Barriers Act (1968) and Section 504 of the 

Rehabilitation Act (1973) specify similar requirements for Forest Service provided activities 

and services. Those requirements have been codified in “Forest Service Outdoor Recreation 

Accessibility Guidelines” (5/06) and “Forest Service Trail Accessibility Guidelines” (5/06). 

(Please see: http://www.fs.fed.us/recreation/programs/accessibility). Any construction that 

we undertake will comply with those requirements. The Forest Service has plans and 

specifications to construct accessible gates, and if we need to, we will install accessible gates.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 325

Process

The Forest Service cannot include the seasonal closures in the decision because the public did 

not have the information on the seasonal closures for the full 45-day comment period.

The information on seasonal closures was indeed available for the full 45 days. Everything 

related to the draft statement in the project record was available to the public from July 22 –

September 30, 2010, which is 71 days. Additionally, at the request of the public, we posted a 

spreadsheet listing every route number, designation by alternative, and its seasonal date on 

our Web site at the same time the maps of the alternatives were posted 

(http://www.fs.fed.us/r3/sfe/travelmgt/deis/index.html; see spreadsheet at very bottom of Web

page). 

The Forest Service should have done a better job of outreach to residents of rural communities 

and the Tribes, particularly in the Rio Grande Sun, as opposed to the Albuquerque Journal. The 

result will be a decision that does not respond to the needs of people who depend upon forest 

resources for their way of life.

Since 2006, the Santa Fe National Forest has provided public notice about the different stages 

of the travel management planning process so the public could participate. We placed 

newspaper ads during key public involvement periods such as during development of the 

proposed action, the scoping period, and the notice and comment period. In all, we advertised 

and held 59 public meetings. The Santa Fe National Forest used fliers, newspaper 

advertisements, the Santa Fe National Forest Web site, social media, and public mailing lists 

to inform the public of developments. The project record contains information on newspaper 

articles, flier locations, and other forms of public outreach the Santa Fe National Forest used. 

The agency needs to withdraw the DEIS because it did not follow the law when it identified 

significant issues. The Forest Service should be developing alternatives to address significant 

issues, not the other way around.

The agency did follow the law when it identified the significant issues and alternatives. The 

project record document called “20120426_Summary_Alt_Development_Process.docx” 

explains the process we used.

The Forest Service did an inadequate job of tracking and explaining why some roads and trails 

appeared (or not) in the alternatives. What was presented was very confusing and hard to follow.

This made it hard for the public to provide comments in a timely manner and did not follow the 

NEPA process.

In response to this comment, we wrote a separate document explaining the process we used to 

sort through and answer comments on the draft environmental impact statement. It is called 

“20120427_method_for_DEIS_comments.docx” and is located in the project record. We 

regret that people had trouble understanding what happened to individual routes. In some 

cases, the names people used for routes did not match our road or trail numbers.
Appendix 7. Response to Comments on the DEIS

326 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service failed to provide data in a timely manner. Because there are no dates showing 

when the documents associated with the DEIS are posted, the public may not have had the full 45 

days to comment on them which is contrary to the regulations.

Seventy-one days elapsed between the time the draft statement and the specialist’s reports 

were posted on the forest’s Web site and the end of the comment period on September 30, 

2010. The entire project record was available to anyone who requested it during that time, 

either by coming into the office or asking for documents through the Freedom of Information 

Act. In addition, we posted all the references and a list of the project record index online for 

people’s convenience.

The Forest Service needs to consider contents from petitions to close roads (specifically March 

30, 2009, for roads in the Jemez Ranger District and July 1, 2010, by Center for Biological 

Diversity) and document how the contents of these petitions were handled in the Travel 

Management process.

We received these petitions outside of any comment period related to the NEPA process for 

travel management. Thus, we considered them separately. As documented in the project 

record, the forest supervisor evaluated the petitions and decided to deny them due to a lack of 

sufficient evidence.

The Coyote Ranger District did not hold public meetings in one of the communities it represents, 

which further indicates neglect of the needs of the Hispanic community.

Since we started working on this project in 2006, we have held 59 public meetings in 

communities around the forest. The forest supervisor, deputy forest supervisor, and district 

rangers also met with people and organizations individually when requested to do so. We

have received over three thousand letters and petitions over this same time period. We 

selected central locations for public meetings, and chose places that had a facility that could 

hold at least 30 people. 

The Forest Service’s poor communication of local meeting times and dates was deliberate 

because the local community opinion of Travel Management is not favorable.

People’s opinions about the Travel Management Rule and the forest’s proposed alternatives 

vary greatly, from very supportive to totally against. We welcome all opinions and do not 

avoid them. We scheduled public meetings so they were as central as possible. We also 

advertised meetings through newspaper ads, on our Web site, through our mailing list, and by 

posting fliers in local communities.

Purpose and Need

The Forest Service must not build its significant issues around front-loaded assumptions because 

it artificially limits its range of alternatives.

The “front-loaded assumptions” referred to in this comment are the examples of the 

detrimental effects from unmanaged motorized use and the existence and use of roads and 

trails included with the purpose and need. Studies document well the detrimental effects of 

both, and we have included these references in this statement. The courts give agencies 

considerable deference in the formation of a purpose and need. Finally, the NEPA regulations 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 327

require that we analyze a reasonable range of alternatives, not every possible alternative (40

CFR 1508.25).

The purpose of the Travel Management Rule is to determine the minimum road system necessary 

to provide safe and efficient travel, and for administration, utilization, and protection of National 

Forest System lands.

The regulations at 36 CFR 212.5 (“subpart A”) requires that the Forest Service identify its 

minimum road system and unneeded roads. Section 212.51 (“subpart B”) requires that we 

designate roads, trails, and areas for motorized use. No requirement that the minimum road 

system be the designated system exists. The minimum road system does not include 

motorized trails, which is a legitimate use of National Forest System lands in the appropriate 

locations with appropriate management.

The Forest Service’s purpose and need is pre-decisional and does not follow the CEQ 

regulations. The purpose and need should attempt to prove or disprove an assumption (a 

hypothesis) and not be a way to frontload a decision.

The National Environmental Policy Act is about disclosure: the reason for doing a project, the 

project, and the project’s effects. No part of the act requires an agency to prove or disprove 

anything, only to describe the predicted effects. The purpose and need of a project describes 

the reason an agency wants to implement a project. It is not a hypothesis.

The purpose and need should also reference the social benefits of motorized recreation. The 

purpose and need statement is too narrowly written and does not go far enough to address the 

legitimate needs of the motorized recreational user.

Though the needs of the motorized user are not included in the purpose and need, the 

alternatives do incorporate them. For example, the Santa Fe National Forest only has 27 miles 

of motorized system trail, and every action alternative proposes to increase that substantially.

The DEIS is flawed because none of the alternatives meet the stated purpose and need, which is 

to reduce the detrimental impacts caused by the existence and use of roads and trails.

We disagree with this comment. Though not every natural and cultural resource is expected to 

see a significant improvement from limiting motorized use, many will. Table 10 of this final 

statement displays the expected improvements to natural and cultural resources and social 

aspects from the action alternatives.

Range of Alternatives

The Santa Fe needs to write an SEIS because the DEIS fails to present an adequate range of 

alternatives. All the alternatives are clustered around closing half of the roads and are too 

restrictive. The DEIS needs to propose as many alternatives that increase the mileage (and acres 

for motorcycle trials) open to motorized use as those that decrease it.

We did not include action alternatives that would increase the amount of motorized use from 

the current condition because it would not meet the need of reducing the detrimental impacts 

caused by motorized use and the use and existence of roads and trails.
Appendix 7. Response to Comments on the DEIS

328 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service did not adequately address conflicts between users in the development of the 

alternatives.

We designed alternative 5 specifically around the issue of conflicts between users.

The science-based alternative was improperly excluded from detailed analysis.

We have explained our rationale for not analyzing this alternative in detail on page 53. We 

have incorporated the best available science into all analysis.

The landscape-based alternative was improperly excluded from detailed analysis.

We have explained our rationale for not analyzing this alternative in detail on page 53.

The route density calculation was improperly considered as a separate alternative. The Santa Fe 

National Forest should adopt the method used by the Apache-Sitgreaves because it includes 

closed roads and does not include wilderness.

It may be true that calculating route densities isn’t really an alternative. Because we received 

a number of comments on it, we wanted to explain how we handled the route density 

calcuations. We based our method of calculating open road density on the “Santa Fe National 

Forest Plan.” The Apache-Sitgreaves is governed by its own forest plan, which may stipulate 

a different method.

The DEIS fails to present a reasonable range of alternatives because no alternative (1) 

completely eliminates routes inside of IRAs, (2) significantly improves wildlife habitat in 

particular for species awaiting listing as threatened or endangered (Rio Grande cutthroat trout 

and Jemez Mountain salamander), (3) proposes the minimum road system, (4) is fiscally 

responsible, and (5) doesn’t include any user-created routes.

The alternatives must meet the stated purpose and need. None of the things listed in the 

comment is included as a need. The effects of the alternatives on IRAs, wildlife, for adding 

unauthorized routes, and to maintenance costs are analyzed in this statement. The minimum 

road system is analyzed briefly in chapter 2.

Recreation

The Forest Service must show how the selected alternative meets the needs identified in the 

Forest Service’s various visitor use studies.

According to the National Visitor Use Monitoring data for the Santa Fe National Forest, the 

existing condition provides much more motorized recreational opportunity than is necessary 

to meet the current demand (recreation specialist report). The visitor use studies do not 

support keeping a system as large as is currently available on the forest. Selection of any 

action alternative would better meet the needs for motorized recreation as identified in the 

National Visitor Use Monitoring study.

The Forest Service must differentiate between the quantity of recreation (miles) and quality 

(benefits) in its effects analysis in order to evaluate the full social tradeoff between analysis. For 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 329

example, replacing miles of single-track in roadless areas with miles of old roads alters the 

quality.

The Forest Service did not analyze the quality of motorized experiences because the Santa Fe 

National Forest does not rate the quality of experiences or skill level of available or proposed 

trails since a challenging trail to one person may be considered easy by another.

The Forest Service fails to acknowledge that the presence of unauthorized trails is a reflection of 

demand.

The forest currently has 27 miles of motorized system trail. We recognize that a larger 

managed motorized trail system is needed. Each alternative proposes to incorporate some 

unauthorized motorized trails. 

The Forest Service fails to analyze the impacts to nonmotorized users within areas designated for 

off-highway vehicle use.

The conflict between motorized and nonmotorized users was one of five significant issues 

analyzed in this final environmental impact statement.

The DEIS has not included an analysis of effective mesh size, or a Roadless Space metric, RV, 

which are two important ways of determining the effects of roads and loops in isolated areas to 

evaluate the consequences of loops and connectors.

The forest didn’t identify specific routes as loops or connectors. Rather, we analyzed the 

effects of the entire proposed system by alternative.

Restrict Motorized Use

No motorized cross-country travel should be allowed on the Santa Fe National Forest because it 

damages natural and cultural resources.

All the action alternatives essentially eliminate motorized cross-country travel by designating 

50 acres or less of areas out of the forest’s 1.5 million acres.

The Forest Service should close all roads and trails to motorized use to protect natural and 

cultural resources. Loops, especially, cause user conflict and enhance fire danger.

Closing all the roads and trails in the Santa Fe National Forest would not allow people to 

access their public lands, so is not practical or reasonable. We know of no studies that show 

loops cause more user conflict and increase fire danger.

The Forest Service should not open any routes that are currently closed to motorized use, such as 

hiking trails.

The 459 miles of forest system trails located outside of wilderness are not closed to motorized 

use, but may not have been built for motorized use. Table 15 in this statement displays the 

mileage of these trails that would allow motorized use by alternative. Most of the trails 

desired by motorized users are unauthorized routes, not existing system trails.
Appendix 7. Response to Comments on the DEIS

330 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service should not designate any unauthorized routes because they are illegal, poorly 

situated, too expensive to bring up to standard, and haven’t gone through the NEPA process.

Because the forest’s travel policy now allows people to drive on 53 percent of the forest, most 

of the unauthorized trails are not “illegal.” We analyze the effects of adding unauthorized 

routes according to Forest Service policy. It is important to remember that the forest proposes 

to close more routes and area than it is designating, and some unauthorized routes are 

appropriately located.

The Forest Service should severely restrict the number of miles of roads and trails open to offhighway vehicles for these reasons: (1) The agency cannot maintain the system it proposes in 

any of the alternatives; (2) The use of off-highway vehicles will damage natural and cultural 

resources; (3) crime will increase; (4) wildfires will increase; (5) people need a place free from 

the noise of engines;( 6) OHVs are a physical danger to others; and (7) most of the public wants 

to see fewer off-highway vehicles in their national forests.

Alternative 3 restricts where people can drive the most while still allowing for reasonable 

access to their national forest. Its effects are described in chapter 3. We were not provided 

with evidence that crime increases with motorized use, or that most of the public wants to see 

less motorized use in the national forest.

The Forest Service should not designate any trails for motorized use unless they have been 

thoroughly ground checked for geological and engineering concerns, the potential for erosion, 

and maintenance costs. 

To include a road or trail in the forest’s transportation system, two things must happen. First, 

the Forest Service must decide to add the road or trail. By conducting this NEPA process and 

following the considerations in the Travel Management Rule (36 CFR 212.55), we meet the 

criteria for decision. The second step is to add the road or trail to the system by putting it into 

the forest’s database and publishing it on the motor vehicle use map, which then makes it part 

of the official system. The Forest Service Manual 7700 contains guidance for adding roads 

and trails to the forest’s transportation system, and describes the things we must consider.

The Forest Service should only allow off-highway vehicle use in very remote areas where the 

environmental impact would be insignificant. The other option would be to allow it near cities 

because people there are used to noise and emissions.

Any environmental impacts that motor vehicles might cause are not lessened because of the 

remoteness of the part of the forest where they are operating. During the public involvement 

process and the environmental analysis process, we considered the impacts that motor 

vehicles may have on the forest and made our alternatives accordingly.

Off-highway vehicles should only be allowed on the main forest roads and not on any trails.

Alternative 3 comes closest to this proposal. We did not feel it was appropriate to completely 

eliminate motorized use of trails because it is a valid recreational use in the right places and 

when managed appropriately.
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FEIS for Travel Management on the Santa Fe National Forest 331

The Forest Service should not add any motorized trails because the trails it has now are not 

being properly maintained.

The Santa Fe National Forest must balance the need for motorized recreation, ability to 

manage recreational opportunities, and other factors such as effect to resources when 

designating its system of motorized trails. It is taking a logical, methodical approach to 

finding the best balance for designating its motorized trails.

Safety

Motorized loop roads help create public safety in case of mechanical failures. 

It is not clear to us how loop routes increase public safety, and we are not aware of any 

studies that corroborate this statement.

The Forest Service should consider the safety of the proposed routes before designating them.

We have considered the safety of the proposed alternatives in chapter 3.

The Forest Service must adopt a forest-wide route density (outside of wilderness and semiprimitive nonmotorized areas) of 1 mi/sq mi because this is the standard supported by the 

preponderance of credible scientific literature to protect natural and cultural resources.

We were unable to locate scientific literature that supports this claim. Route densities, defined 

as the miles of routes divided by an area, vary greatly depending on how they are calculated.

We followed the standards set forth in the “Santa Fe National Forest Plan” when developing 

the alternatives. All the proposed alternatives meet the standards in the forest plan. The 

effects analysis in the soil and water resources specialist report uses an open road density of 1 

mile per square mile to analyze current road density and describe its effects on watershed 

condition. The reason is that the Forest Service uses an open road density of 1 mile per square 

mile or less as a guideline for “good” watershed condition in its watershed condition 

framework, a standard way to describe the condition of its watersheds.

To comply with law, regulation, and policy, the Forest Service needs to have site-specific data, 

including field visits, on every road and trail it proposes to open or close to motorized use.

The National Environmental Policy Act does not require perfect or complete information to 

make a decision. The regulations at 40 CFR 1502.22(b) tell agencies what to do when the 

overall costs of obtaining the information are exorbitant (as would be the case with sitespecific analysis of the approximately 7,800 miles of known routes in the forest); we have 

done this on page 16. The Travel Management Rule does not require agencies to have a 

complete inventory of routes before completing the designation process (70 FR 68268, 

68269).

The Forest Service should observe what is actually going on and not worry about science 

because the science shown so far is flawed.

The regulations at 40 CFR 1502.25 state that agencies are to ensure the professional integrity, 

including scientific integrity, of the discussions and analyses in environmental impact 

statements.
Appendix 7. Response to Comments on the DEIS

332 FEIS for Travel Management on the Santa Fe National Forest

Seasonal Closures

The Forest Service should not choose the year-round access in alternative 4 because in the winter 

roads are impassable due to snow and with snowmelt, there would be increased erosion and road 

damage.

This final statement contains a range of options for seasonal closures, from year-round access 

to specific closure dates. The forest supervisor will make her decision based on the analysis 

and public comment. 

Signs

For the plan to be effective the Forest Service needs to sign the roads and trails because the large 

scale and format of the motor vehicle use map will not help users reliably know where they are.

We agree. We recognize that signs help people orient themselves. Signing roads and 

motorized trails is an ongoing process, and the effort received significant emphasis during 

2009 and 2010. This emphasis will be continued after publishing the motor vehicle use map.

Once the motor vehicle use map is published, it will be the forest visitor’s responsibility to 

know where they are driving whether or not a sign is present.

Social and Economic

The Forest Service should improve or re-do their social and economic analysis section because 

not enough information is written about social benefits of off-highway vehicle recreation; thus, 

the forest supervisor cannot make a fully informed decision.

We agree that there are social benefits associated with off-highway vehicle use. Because of 

that, every action alternative proposes to increase the amount of managed, motorized system 

trails from its present level. We have not seen, however, any studies that link the mileage of 

off-highway vehicle use available on a national forest with a person’s overall well-being.

Improving overall social well-being is not part of the purpose and need of this project. The 

social and economic analysis discloses the potential social impacts for each alternative, 

including cultural and traditional uses that depend on motorized access. The recreation

specialist report discusses how recreational opportunities are likely to change under each 

alternative.

The Forest Service needs to do the social and economic impacts analysis again and comply with 

statute and regulation because it failed to adequately address social and economic impacts of the 

changes that will affect the public who camp, hunt, and use the forest.

The “Social and Economic” section in chapter 3 examines the potential economic 

repercussions of all alternatives by evaluating (a) changes in the number of visitors for 

multiple activities (including public who camp, hunt, and use the forest), and (b) looking at 

the direct, indirect, and induced effects of these changes to all relevant industry sectors of the 

local economy. The recreation section analyzes how the alternatives will change recreation 

opportunities available to those who camp, hunt, and use the forest.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 333

The agency’s economic analysis on the effects of motorized users displacing nonmotorized users 

is insufficient. Non-motorized users provide the largest economic benefits to local communities. 

The social and economic report discusses the displacement of people engaging in 

nonmotorized activities numerous times. First, the economic modeling explicitly included an 

assumption that nonmotorized activities would decrease for the alternative that proposed the 

most motorized use, alternative 4. Second, page 19 of the social and economic report 

specifically discusses this displacement effect. Third, the cumulative effects for each 

alternative states, “Furthermore, a change in management that would slightly reduce 

motorized use on the Santa Fe National Forest may have positive economic impacts in a 

number of other areas:

• Increased nonmotorized recreation in areas previously used for motorized recreation 

• Increased nonmarket values to surrounding areas from resource benefits (e.g. clean water, 

increased wildlife populations, etc.) resulting from decreased motorized recreation on the 

Santa Fe National Forest. Last, the economic analysis is based on NVUM and ABV data, 

which shows that on the Santa Fe National Forest, nonmotorized use is greater than 

motorized use. These data are reflected in the economic analysis.”

The Forest Service must develop a thorough and accurate description of the value of motorized 

forest access so that the responsible official can weigh the loss of this access.

The social and economic analysis evaluates the value of motorized access by modeling forest 

visitation, access restrictions on traditional and cultural uses, and other things affecting

various industries. These are evaluated for each alternative for the responsible official to 

compare them.

The effects analysis for the economic effects fails to meet current Federal case law.

The economic analysis examines the potential economic impacts of each alternative using the 

best available science and models, such as the IMPLAN economic model. We cannot address 

the claim related to the specific case law since it was not provided.

The Forest Service should include the positive economic benefits of roadless areas to New 

Mexico’s economy.

The focus of this project is on unmanaged motorized recreation, not IRAs. The social and 

economic report touches on the economic benefits of nonmotorized use and of nonmarket 

values, but not specifically on the inventoried roadless areas. The scale of analysis is at the 

forest level, not by specific kinds of management areas.

The economics discussion on page 107 of the DEIS fails to consider that wholesale route closures 

will affect every recreational sector. The ripple effect of these wholesale closures is not even 

considered in the DEIS. 

We have clarified this point in the final environmental impact statement. The economic 

analysis in the social and economic report does consider all economic sectors. It uses the 

IMPLAN model to address how changes in activities such as OHV use, driving for pleasure, 

and participation in nonmotorized activities would affect all economic sectors. IMPLAN 
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334 FEIS for Travel Management on the Santa Fe National Forest

considers not only direct and indirect effects, but also induced effects. This means it does 

consider the ripple effects. The model and its limitations are described in detail in the social 

and economic report.

The agency accounts for people going to the power sports store and buying an ATV, but it 

disregards the truck and trailer needed to haul it, the camping equipment needed to spend 

overnight in the forest, the fishing gear, the hunting gear, the specialized clothing for any of those 

activities, the specialized footwear, and the fuel, to name just a few places our forest visitor will 

spend his money in preparation for his trip to the forest.

The camping equipment, truck and trailer purchases, clothes, and everything else mentioned 

are captured as indirect or induced effects of decreasing or increasing motorized recreation or 

nonmotorized recreation in the IMPLAN model. Thus, these economic impacts were 

accounted for in the economic analysis.

In its economic analysis, the agency only looks at one sector (albeit the sector most burdened). 

The agency does not even consider the diversity of other activities people pursue on the forest, all 

of which are dependent upon motorized access.

We did consider the effects to other activities that depend on motorized use in the social and 

economic report. Its analysis divides recreational use among motorized recreation, 

nonmotorized recreation, and other. The analysis assumes that motorized recreation and 

nonmotorized recreation would be affected by each alternative. The changes to the amount of 

recreation in these categories were used to model economic impacts. Changes to the activities 

in the “other” category are expected to be minimal because no main roads necessary for 

access to campgrounds, trailheads, picnic areas, and other heavily used portions of the forest 

are proposed to be closed.

The economic analysis in the DEIS vastly underestimates the effects to the economy by the 

proposed route closures. Suppose there are 1,000 outdoor recreation businesses in the region 

studied for the DEIS. Multiply that 1,000 by the $4,000,000 that one businessman has already 

told the agency he will lose, and these forest closures actually have a $4,000,000,000.00 (four 

billion dollar) effect on the region wide economy.

The commenter’s analysis is based on invalid assumptions. The main flaw in this reasoning is 

it assumes all OHV sales will immediately stop based on a travel management decision on the 

Santa Fe National Forest. This is highly unlikely considering that over 1,800 miles of routes

will still be available for motorized use even if alternative 3 is selected. In addition, many 

private lands, BLM managed lands, and other national forests will still allow motorized use. 

Second, the statement assumes that all motorized retail businesses are exactly the same as the 

business referred to. This is highly unlikely. Third, the assumption that there are 1,000 

outdoor recreational businesses that include OHV retail in the region is not supported by 

evidence, nor is the “region” defined.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 335

The DEIS has no analysis of the cultural and social value of exploration. Exploration coupled 

with the feeling of adventure and accomplishment has been recognized as a social value of our 

country since its discovery. 

Because no scientific references are included, it is unclear what is meant by the “value of 

social exploration.” Implementing a decision under the Travel Management Rule does not 

rule out the kind of exploration primarily used since our country’s discovery—

nonmotorized—whatsoever. The “Recreation” and “Social and Economic” sections discuss 

the effects of the change in opportunity, or the cultural and social value referred to, from the 

existing condition.

During scoping, the agency received a letter from the owner of a local power sports business. It 

appears that the agency failed to realize the import of this business owner’s concern, which 

encompasses 4 shops, 100 employees, and $20,000,000 in annual sales. 

Unfortunately, it is not feasible to analyze the potential economic impact to each individual 

business that is directly or indirectly related to OHVs. We captured the predicted effects of 

designating a managed transportation system by “industry sector.” As described in the social 

and economic report, many industry sectors, such as OHV manufacturers, may be directly 

impacted under some scenarios. Other industries, like hotels or parts manufacturers, may be 

indirectly impacted. The IMPLAN model used in the economic analysis is designed to 

account for all of these effects.

Nowhere in the DEIS or the Specialists reports, nor in any of the project record items made

available, do we find any information about the benefits to individuals and to society of the 

present amount of motorized access to the forest.

The National Environmental Policy Act requires agencies to analyze the effects of a project.

In this case, we propose to change the current amount of nearly unlimited motorized access to 

a designated motorized system. Each section in chapter 3 specifically addresses the predicted 

effects of this change. For example, in the social and economic report, the maximum number 

of jobs that may be lost is estimated using economic models and recreation activity data. 

Thus, the analysis does clearly show how current benefits would be reduced. 

Part of the purpose of the NEPA is to maintain environmental quality “...to the overall welfare 

and development of man...and...create and maintain conditions under which man and nature can 

exist in productive harmony.” This DEIS has completely overlooked that responsibility by not 

including the effects of this project on very high quality leisure activities, called “serious leisure” 

by researchers in the field.

This final statement does not include an analysis on what some researchers have called 

“serious leisure.” While it may be true that high quality leisure activities are important to 

forest users, it is also well established in scientific literature that one person’s high quality 

leisure experience (e.g., ATV riding) reduces the quality of another’s leisure experience 

(Dolesh 2004). For this reason, the EIS discusses the changes in motorized opportunity and 

conflicts.

Conflicts between forest users is an extremely complex subject. Yet, the only basis of analysis in 

the DEIS for the social impact of use conflict is a simple mileage comparison (p. 91): “We chose 
Appendix 7. Response to Comments on the DEIS

336 FEIS for Travel Management on the Santa Fe National Forest

relative route density—the miles of roads and trails in a given area—as a measure for conflicts 

between motorized and nonmotorized users.” This is not sufficient. The miles of roads and trails 

in a given area is one valid basis for measuring conflict.

It appears to us that the “miles of roads and trails in a given area” is the same as route density, 

which we have used to illustrate the potential for conflicts. We recognize the complexity of 

the subject, and have provided a number of scientific references discussing it. This final 

statement and specialist reports address the issue of conflict qualitatively by illustrating how 

the alternatives may impact traditional uses and by analyzing roadless values, wilderness 

values, and the amount of motorized trail in and near semiprimitive nonmotorized areas.

The DEIS only covers economics, noise, property values, cultural practices and traditions, and 

environmental justice. There has been no analysis or even description of social organizations, 

attitudes/beliefs/values, lifestyles, and land use as they pertain to the social sciences.

The National Environmental Policy Act states that agencies shall use the scoping process to 

“determine the scope (§1508.25) and the significant issues to be analyzed in depth in the 

environmental impact statement (40 CFR 1501.7).” The subjects listed by the commenter are 

those that the forest supervisor decided to include in the scope of the analysis. The social and 

economic report draws heavily from data from attitude/beliefs/values studies conducted on 

the Santa Fe and surrounding national forests and uses available data to look at a large 

number of social groups including ethnic minority groups, poor and underserved 

communities, and groups that depend on national forest lands for cultural and traditional 

practices.

The Forest Service has not met the requirements of its own guidance in FSH 1909.15 Chapter 

1973 (sic) for conducting the social analysis.

We have met the management direction for social analysis. The social and economic analysis 

includes an indepth analysis of social and economic conditions, desired conditions as 

identified in the forest plan, and how management activities may affect these systems. It 

looks at the economic impacts by analyzing how alternatives may affect jobs and labor 

income. The recreation specialist report analyzed motorized opportunities and conflict. The 

social analysis looks at how alternatives may affect cultural uses. 

The decision will hurt communities that are already suffering from economic hardships.

Most economic uses of the Santa Fe National Forest, like collecting and selling forest 

products or grazing cattle, require a permit. The Travel Management Rule exempts “motor 

vehicle use that is specifically authorized under a written authorization issued under Federal 

law or regulation” (36 CFR 212.51(8)) from the designations. This means that as long as 

someone has a permit, they will be able to conduct economic activities using a vehicle as 

stipulated in the permit.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 337

The Travel Management Rule is a way to accomplish the aims of environmental groups and 

includes removing people from their land and taking their water rights and land without just 

compensation.

The Travel Management Rule requires that national forests and grasslands provide for a 

system of roads, trails, and areas designated for motorized use. It does not remove people 

from their land or take their water rights.

Soil, Water, and Riparian

The Forest Service should not allow motorized use in riparian areas because its own analysis 

shows the negative effects from the proposed corridors for motorized dispersed camping and 

from having routes near creeks and drainages. Allowing motor vehicles to drive to the water’s 

edge—or even cross streams—in the corridors for camping and game retrieval does not meet the 

forest’s Best Management Practices.

The action alternatives present a range of options that balance the need for access and 

resource protection. All reduce the places where people could drive in and near riparian areas 

by nearly eliminating motorized cross-country travel. Though allowing motorized use in 

riparian areas may not be desirable—the soil and water resources specialist report describes 

these effects—in some situations, it is unavoidable. Many forest roads have existed for 

decades in riparian areas and it would be impossible to eliminate traffic on these roads. Forest 

Road 376, for example, is one of the most heavily traveled roads on the forest and is in and 

near riparian areas. 

The effects analysis of motorized use on water quality needs to be improved by: (1) using the 

sixth-level watershed scale; (2) identifying and analyzing routes proposed on erosive soils; (3) 

showing the differences in effects from miles of road, miles within 300 feet, and number of stream 

crossings; and (4) considering 16 USC §1604(g)(3)(C).

(1) After reading comments from the public, we too believe that the sixth code watershed 

level is the appropriate scale for this analysis, and rewrote the soil and water resources 

specialist report accordingly; (2) The soil and water resources specialist report describes the 

effects of motorized use on soil types; (3) The soil and water resources specialist report 

contains these measures. Keep in mind that the analysis is based on the change to the existing 

travel policy only; and (4) 16 U.S.C. §1604(g) (3) (c) is part of a statute requiring the Forest 

Service to adopt certain regulations and does not apply to this project.

The Forest Service should not designate motor vehicle use on roads near streams and water 

because it must comply with statutes and regulations including the Clean Water Act and the 

National Environmental Policy Act.

Assumption 1 in chapter 3 states there will be no measurable change in motorized use from 

closing some routes. Therefore, there will be no noticeable change in water quality from 

closing routes. However, we do propose to eliminate almost all motorized cross-country use 

in all the action alternatives; alternatives 2M and 3 would not allow vehicle use within 

riparian areas at all. As described in the soil and water specialist report, not having motorized 

cross-country use could improve water quality. We cannot predict exactly by how much 

because many factors outside the scope of this project contribute to water quality.
Appendix 7. Response to Comments on the DEIS

338 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service needs to ensure that the selected alternative complies with Forest Plan 

direction to “maintain water quality or to meet or exceed state water quality standards” and that 

the FEIS documents which alternatives are consistent with the forest plan.

Appendix 3 describes each alternative’s compliance with the forest plan’s direction for soil 

and water resources.

The Forest Service needs to use an analytical tool such as WEPP to conclude whether the 

elimination of motorized travel alone will have any effect on sedimentation. If it cannot show this, 

then the agency needs to choose alternative 4.

This comment asks for 2 things: that we use a model such as WEPP and that we base our 

decision on the change in sediment predicted. No measurable change in motorized use from 

closing some routes is predicted (assumption 1, chapter 3). In addition, in the 15-year 

timeframe we use in the effects analysis, the footprint of most routes will stay on the 

landscape (table 19). Thus, we do not believe there will be a change in sediment production 

during the timeframe analyzed in this final statement. A model such as WEPP requires there 

be a change in conditions. Since we do not foresee a change in conditions, we do not believe 

WEPP is an appropriate tool to analyze the effects of this project.

As to the second point, the forest supervisor is likely to have many reasons for choosing a 

particular alternative, for example, cost, wildlife, heritage, need for access, or sedimentation.

She can choose any of the action alternatives regardless of whether motorized travel alone 

will have any effect on sedimentation. 

The soil and water effects analysis fails to account for potential obliteration of routes within the 

15-year timeframe of the analysis.

In this project’s context, the obliteration of routes would be a cumulative action. For the 

effects of a cumulative action to be considered in the NEPA process, the action must be 

“reasonably foreseeable” (among other things). The courts have defined reasonably 

foreseeable as “projects that are proposed rather than contemplated” and those that are not 

“speculative” (Weinberger v. Catholic Action of Hawaii, 454 U.S. 139, 70 E.Ed.2d 298 

(1981); Kleppe v. Sierra Club, 427 U.S. 390 (1976)). Because no future road obliteration 

projects have been proposed, no cumulative effects from them exist.

The Forest Service should reduce route densities to reduce sedimentation into streams and 

protect aquatic species. It should also close any road or trail that is degrading water quality, 

such as every route located within a stream channel.

Every action alternative reduces open road densities to a level that meets the standards in the 

“Santa Fe National Forest Plan.” As described in the “Soil and Water” section, the existence 

of most routes closed to motorized use will not change, nor will the amount of sediment 

contributed by them change. Closing every route in a stream channel is not possible because 

of needs for access, such as to private land.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 339

The Forest Service should work with the State of New Mexico Water Quality Control Commission 

to prevent the deterioration of watersheds.

This suggestion is outside the scope of this project, which proposes to designate roads, trails, 

and areas for motorized use. Staff on the Santa Fe National Forest, however, work with the 

New Mexico Environment Department and many other partners on watershed improvement 

projects.

The Forest Service needs to explain how water quality will be improved or which areas will be 

improved in the alternatives. The Forest Service must explain, with specificity, how the project 

will ensure that 303(d)-listed streams will come into compliance with water quality standards for 

sediment and/or water temperature. This includes assessing routes that will remain on the ground 

even after the designation process.

The purpose of this project is to regulate where people can drive on the forest, not to improve 

water quality. The National Environmental Policy Act requires agencies to disclose the effects 

of its proposal. The soil and water resources specialist report does this by analyzing how 

closing routes and areas to motorized use affects water quality, and then compares how many 

miles are within a certain proximity of 303(d) listed streams. It does the analysis at the HUC 

6 level, a scale appropriate for a forestwide project. We do not need to assess the impacts of 

routes that will remain on the ground after the designation process since those have nothing to 

do with this proposal. The soil and water resources specialist report does describe the 

cumulative effect of the routes that remain on the landscape after the designation process.

The Forest Service must demonstrate that it is complying with the NFMA and not causing 

permanent impairment of soils and explain how it has incorporated its BMPs into the designation 

process.

The “Legal Consistency” section of the soil and water resources specialist report outlines how 

the alternatives comply with the National Forest Management Act. Routes that are not 

designated for motor vehicle use have the potential for restoration, either natural or planned 

by the Forest Service or others. Best management practices apply to projects where ground 

disturbance occurs. This project proposes no ground disturbance; it only specifies where 

people are allowed to drive. 

The Forest Service should conduct a more detailed analysis for a selected impaired stream 

outside the Travel Management process.

We understand this commenter to be requesting a detailed study on how impaired streams 

respond to various activities and treatments. We like this idea; however, it is outside the scope 

of the project.

We do not believe the discussion that states, “...alternative 4 does not move the soil and water 

resource toward a desired condition” fairly represents what can be done through good 

management combined with the significant reduction of access over the current condition.

Because alternative 4 proposes to close 45 percent of the forest’s routes and nearly eliminates 

cross-country travel, it may seem counterintuitive to say that it does not move the soil and 

water resource toward a desired condition. The existence of good management practices and 

the reduction of routes and areas do not mean that alternative 4 moves the soil and water 
Appendix 7. Response to Comments on the DEIS

340 FEIS for Travel Management on the Santa Fe National Forest

resource toward a desired condition. The soil and water resources specialist report analyzes 

the actions proposed individually. As grouped in this report, the actions are: (1) close roads 

and trails to motorized use; (2) close stream crossings to motorized use; (3) designate 

corridors for motorized big game retrieval; (4) close areas to motorized use; and (5) designate 

corridors for motorized dispersed camping. In sum, the effects of items 1, 2, and 3 result in no 

change from the existing condition. Item 4 would improve the soil and water resource. Item 

5—for alternative 4—would move the soil and water resource away from desired conditions. 

The analysis incorrectly states, “having less motorized use near streams reduces the potential for 

sediment to get to a stream...” The construction and existence of roads and trails potentially 

affects water quality far more than continued travel along them.

While it is true that the construction of routes can affect water quality, it is well documented 

that the use of the route can also contribute to water quality impairments. The soil and water 

resources specialist report describes the effects of the use, existence, and maintenance of 

routes. It does not address construction because none is proposed in this project.

The DEIS needs to provide site-specific data on the number, type, and effects of stream crossings.

This final statement, using the best available data, lists the number of stream crossings and 

describes the effects that they have on soil and water. The soil and water resources report 

does determine (through a GIS stream/road intersection analysis) the number of stream 

crossings per mile. Site-specific analysis of each stream crossing is not necessary for the 

forest supervisor to make a decision. Analyzing the effects of each alternative at the sixth 

code watershed level is appropriate for the forestwide scale of this project.

The DEIS needs to be revised to disclose the total amount of existing routes within riparian areas 

and 300 feet of all streams in order to reasonably describe existing conditions and cumulative 

effects of the alternatives.

The measures used in the soil and water resources specialist report summarizes the miles of 

routes within 300 feet of all streams and in riparian areas for each sixth code watershed. The 

cumulative effects section shows the same information for all the existing routes.

The DEIS needs to disclose the effects of designating routes on soils with high erosion hazard.

None of the action alternatives would change the effects of routes on soils with a high erosion 

hazard, but does reduce the number of these open for driving. Per the roads specialist report, 

there will be no measurable change in motorized use across the forest from closing some 

routes. In addition, in the 15 years considered in this analysis, the footprint of the route will 

stay on the landscape. As a result, we do not believe there will be a change in sediment 

production during the timeframe analyzed in the FEIS.

The DEIS needs to be revised to reasonably disclose the existing conditions of riparian areas and 

assess how they will be affected by the alternatives.

Alternative 1 describes the existing condition of the forest’s riparian areas. The “Soil and 

Water” section and specialist report describe the effects of each alternative on riparian areas.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 341

The DEIS needs to be revised to assess and disclose existing water quality conditions that would 

be affected by each alternative, their effects on beneficial uses, and relationship to water quality 

standards.

This final statement does describe the existing condition of water quality in the forest’s 

streams, how it would be affected by each alternative, and the relationship to water quality 

standards and beneficial uses.

The DEIS does not provide an adequate discussion of the magnitude of effects to soils in the 

corridors proposed for motorized dispersed camping and motorized big game retrieval.

The discussion in this final statement and the soil and water resources specialist report 

contains the information needed for the forest supervisor to make her decision. Measures 10–

14 in the soil and water resources specialist report display how the proposed corridors for 

motorized dispersed camping will affect soil and water quality under each alternative. The 

soil and water resources report also discloses the effects of the proposed corridors for 

motorized big game retrieval. In sum, the effects from motorized big game retrieval under 

alternative 1 are already small, and will be further limited in space and time under each of the 

action alternatives. Chapter 3 discloses the potential for site-specific effects under alternatives 

2, 4, and 5 if motor vehicles drive through sensitive soils, ford streams, or traverse riparian 

areas. 

The DEIS does not disclose the amount of routes within off-route motorized use corridors that are 

within 300 feet of non-perennial streams under alternatives 2, 4, and 5. 

The soil and water resources specialist report provides the miles of routes and the acres of 

corridors within 300 feet of all streams (perennial, intermittent and ephemeral combined) and 

their effects for each alternative. The Travel Management Rule contains no requirement to 

inventory every route on the forest in order to make a decision. Because we cannot anticipate 

where people will drive in corridors, we assume that all the acres proposed in a corridor for 

motorized dispersed camping would be used (assumption 21) in order to perform a 

comparative analysis of the alternatives. We also acknowledge that terrain, vegetation, and 

topography are likely to limit the acres where people can drive (assumption 9).

The changes in route and corridor use under the alternatives have profound effects on the 

impacts of routes on watershed and aquatic resources. These impacts are not adequately 

described in the DEIS. 

We agree that use of routes can have significant effect to watershed resources. Per the roads 

specialist report, there will be no measurable change in use from closing some routes 

(assumption 1, chapter 3). Therefore, we do not believe there will be a change in sediment 

production during the timeframe analyzed in the final environmental impact statement. 

It is essential that the density and miles of routes open to motorized use under all of the action 

alternatives be disclosed in the forthcoming FEIS at the forest and watershed scale for occupied 

fish habitats and impaired streams.

This final environmental impact statement shows the miles of routes open to motorized use 

for all the action alternatives. The “Soil and Water” section further breaks this down by sixth 
Appendix 7. Response to Comments on the DEIS

342 FEIS for Travel Management on the Santa Fe National Forest

code watershed level. The forest plan specialist report displays the open road density by 

forest plan management area because this is the standard required. It also shows the open 

route density, which includes motorized trails, by management area for purposes of 

comparison.

The DEIS does not adequately address motorized use on wet soils.

All the action alternatives propose to nearly eliminate motorized cross-country travel, so 

travel on wet soils will be greatly reduced regardless of the alternative we choose. In addition, 

the action alternatives propose to close between nearly half or more of the roads on the forest, 

so travel on those roads when wet will be prohibited. Finally, each alternative describes how 

the forest would handle closing routes when they are wet.

It is likely that the Santa Fe National Forest has information that is not disclosed in the DEIS 

regarding damage to specific streams associated with specific motorized routes and off-route 

corridors that would be open for use under the alternatives. The FEIS needs to disclose these and 

describe their impacts.

This final environmental impact statement contains the information needed for the forest 

supervisor to make her decision; that is, we focused on the effects from the proposed changes 

at the forestwide scale. Where site-specific data is pertinent, we describe it, such as the effects 

of motorized use on Polvadera Creek. 

The Forest Service should conduct a more detailed analysis for a selected impaired stream 

outside the TM process.

This suggestion is outside the scope of this project, which decides where people can drive in 

the Santa Fe National Forest.

Travel Analysis Process

The Forest Service should re-write the Travel Analysis Process report to reflect a more accurate 

and unbiased assessment of benefits, risks, problems, and growing demand for managed 

motorized recreational activity on National Forest lands.

The “Travel Analysis Process Report” informed the NEPA process, but does not control it. 

This final environmental impact statement discloses the benefits and problems associated 

with the proposed changes to the alternatives.

Threatened or Endangered Species

Applying seasonal closures to routes in Mexican spotted owl habitat is not enough to address the 

indirect and cumulative effects from motorized use (soil compaction, accelerated erosion, 

denuded vegetation, and loss of plant diversity resulting in reduced prey populations and the 

spread of invasive plants) that results in diminished site productivity.

The overall reduction in places where people would be allowed to drive within Mexican 

spotted owl habitat under alternatives 2–5 is expected to benefit the owl.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 343

The Forest Service should eliminate trails, roads, and camping in Mexican spotted owl protected 

activity centers and any endangered species habitat, including riparian areas, since these 

degrade habitat quality.

The complete elimination of trails, roads, and camping in Mexican spotted owl habitat would 

not provide a reasonable amount of public access and recreation. Some protected activity 

areas are traversed by major roads on the forest, such as FR 376. Nonetheless, all the action 

alternatives propose to reduce the places where people can drive in Mexican spotted owl 

habitat.

The conclusion that any of the action alternatives may negatively affect individual spotted owls, 

but not likely to reduce survival and recovery in the wild is suspect. Do not individuals make up 

the collective plural of owls? Isn’t the Forest Service required to protect the entire owl 

population?

We believe that the commenter is confused by the terminology used to describe the “effects 

call” to the Mexican spotted owl. The Mexican spotted owl is a threatened species under the 

Endangered Species Act (ESA) as well as a management indicator species in the “Santa Fe 

National Forest Plan.” The commenter is correct in that the agency has the responsibility to 

not authorize or carry out activities that would cause a decline in owl populations. The forest

also has to evaluate effects to individuals as directed under the ESA, resulting in the language 

used. Admittedly, this language is confusing (but standard with the U.S. Fish and Wildlife 

Service) and has been clarified in this final statement and the biological evaluation.

Tourism

The Forest Service should restrict motorized use of the national forest because it threatens 

nonmotorized related tourism (hiking, backpacking, horseback riding, fishing, and others).

All the action alternatives propose having fewer roads, trails, and areas available for 

motorized use than exist now. The social and economic report discusses the asymmetrical

relationship between motorized and nonmotorized recreation and uses this as a basis to 

analyze the social and economic impacts for each alternative. The recreation specialist report 

also discusses how motorized recreation can displace or affect nonmotorized recreation 

opportunities.

The Forest Service should keep the existing roads and trails open for motorized use because it 

supports businesses such as motorbike shops, grocery stores, hotels, and others near the Santa Fe 

National Forest.

The potential economic effects of restricting motorized access are analyzed in detail in the 

“Social and Economic” section in chapter 3. Specifically, the analysis includes economic 

modeling to estimate the potential maximum loss of jobs and income from restricting 

motorized use under each alternative.
Appendix 7. Response to Comments on the DEIS

344 FEIS for Travel Management on the Santa Fe National Forest

Traditional Use

The restrictions proposed will prevent people from gathering traditional forest products such as 

wood, berries, herbs, and pinon nuts.

Though permitted activities—such as firewood collection—are exempt from the Travel 

Management Rule, the potential impact of each alternative on cultural and traditional forest 

uses is analyzed in the “Social and Economic” section of chapter 3.

Unauthorized Routes

Calling routes “unauthorized” confers an air of illegitimacy to them. For this reason, the term 

“unauthorized” shouldn’t be used.

The term “unauthorized” comes directly from the Travel Management Rule, and we use it for 

consistency’s sake.

The Forest Service should not designate any unauthorized routes because they damage natural 

and cultural resources, were created illegally, and lead to more illegal use.

Some of unauthorized routes have been created in locations that involve less environmental 

impacts than unrestricted cross-country travel and provide excellent recreational 

opportunities. The Santa Fe National Forest believes that use on some of these routes is 

appropriate and has included them in this final statement. Because motorized cross-country 

use is allowed on over half the forest, many of the unauthorized routes weren’t illegally 

created.

We note that Table 3 of the DEIS, row 1 under-represents the existing mileage based on its 

exclusion of unauthorized routes.

Table 3 did not exclude the unauthorized routes. It displayed the Santa Fe National Forest’s 

current travel policy—where people should and should not be driving. Row 4 displays the 

miles of unauthorized routes we are aware of. The footnote to the table acknowledged that if 

an unauthorized route is located in a place where motorized use is allowed, then use of the 

route is also allowed.

Before user-created routes can be added to the designated system, the Forest Service must ensure 

they are constructed according to engineering standards to ensure these routes comply with best 

management practices and prevent resource degradation. Each user-created route proposed must 

have this documentation in the FEIS.

The Forest Service Manual (FSM) describes two things: (1) what we must analyze when 

deciding to add a road or a trail to the forest transportation system; and (2) what we must do 

when actually adding the road or trail to the system, that is, including it in the Infra database 

and on the motor vehicle use map. The requirements for roads, outlined in FSM 7703.26, are 

different from the requirements for trails (FSM 7703.13). Neither section mandates that we 

ensure the routes are constructed to standards before deciding or adding them to the system.

Like the Travel Management Rule, the manual contains a list of things we must consider 

before deciding or adding a route to the system. By conducting this NEPA process, we meet 

the requirements for deciding to add a route. We will also follow the requirements for adding 

the route. 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 345

User Conflict

User-conflict is not appropriate to address as part of Travel Management. The Forest Service 

does not have the authority to regulate user conflict or make land-planning decision based on 

user conflict and the travel management rule cannot be used for regulating nonmotorized

designations, therefore Alternative 5 is inappropriate.

The Travel Management Rule provides general criteria that the responsible official should 

consider when designating a motorized system, including conflict among uses and provision 

of recreational opportunities (36 CFR §212.55(a)). Executive Order 11644 also requires 

agencies to consider user conflict when designating a motorized system. User conflict was 

determined to be a significant issue during scoping and alternative 5 was designed to address 

the issue. 

The DEIS does not prove that user conflict exists to an extent as to be a “significant issue,”

especially as the analysis describes motorized use as “infrequent” (Social Economic Report), 

especially on high-clearance vehicle routes which are the primary routes proposed for closure.

Instead, the discussion of user conflicts focuses around individual routes and specific areas in the 

Jemez and Pecos/Las Vegas Ranger Districts.

We regret that the commenter disagrees with our interpretation of what issues are significant.

We agree that user conflicts do not appear to be widespread and are focused on specific 

routes, as stated in this final environmental impact statement. The courts give agencies 

considerable deference in deciding what issues are significant.

Wildfire Danger

The Forest Service should limit off-highway vehicle use during periods of moderate to high fire 

danger.

The Forest Service currently restricts and will continue to restrict the use of off-highway 

vehicle use during periods of moderate to high fire danger. Restrictions vary from prohibiting 

smoking outside of vehicles to not allowing anyone to enter the national forest. 

The Forest Service should reduce route densities in order to reduce the risk of fire.

All the action alternatives reduce open route densities across the forest. In regards to wildfire, 

the majority of wildfires on the Santa Fe National Forest are caused by lightning, so road 

densities have little effect on the overall amount of wildfire ignitions on the Santa Fe National 

Forest. 

The Forest Service must analyze the effects of response times to lightning caused wildfires.

Chapter 3 contains this discussion. 
Appendix 7. Response to Comments on the DEIS

346 FEIS for Travel Management on the Santa Fe National Forest

Wildlife

The alternative selected should include large swaths of nonmotorized land to ensure wildlife 

habitat remains intact and the impacts to wildlife (inbreeding, mortality, and edge creation) are 

minimized.

All the action alternatives proposed to reduce the places where people can drive, potentially 

increasing nonmotorized areas and improving habitat for wildlife.

The Forest Service should correct the wildlife analysis in the No Action Alternative (#1), because, 

as currently written, it fails to fully disclose pertinent information which would undermine the 

specialist’s conclusions that Alternatives 2 through 5 would be more beneficial to elk herds.

Under the current conditions associated with Alternative #1, there is already an overpopulation 

of elk, which necessitates special population control measures just to hold elk populations at 

current levels, and prevent herd expansion.

Several researchers (Lyon 1983, Lyon 1985, Wisdom et al. 2000, Johnson et al. 2000, and 

others) have documented the effects to elk from motorized use. The “Wildlife” section in 

chapter 3 displays the change in motorized routes in key elk habitats. Alternatives 2 through 5 

would reduce disturbance in key elk habitats, such as calving areas, and improve habitat 

quality for elk over alternative 1. Additionally, the action alternatives would eliminate 

motorized cross-country use on the forest, further reducing potential for habitat disturbance.

Population targets for game management units are determined by the New Mexico 

Department of Game and Fish and are based on many factors such as habitat capacity and 

conflicts with landowners.

The agency’s Biological Evaluation is not specific enough to determine the effects to wildlife from

trails, which is certainly different from roads.

We are unable to locate scientific studies that describe the difference in effects to wildlife 

from either the use or existence of roads versus trails. For this reason, the assumptions 5 and 

6—that roads and trails have the same effects as do the kinds of vehicles—applies.

The Forest Service fails to analyze the impacts to hearing mechanisms of amphibians by ORVs 

considering there is scientific evidence that this occurs.

Recent studies (Eigenbrod et al. 2009 and Parris et al. 2009) looked at the effects of road 

noise on amphibians. These studies considered high-use highways and urban settings, which 

do not reflect the type of activity on the Santa Fe National Forest.

The Forest Service must describe the habitat and population trend for each species analyzed in 

the No Action alternative.

The wildlife report and biological evaluation describe the population data and trends at the 

forest level, the habitat trend at the forest level, and the predicted effects to management 

indicator species as required. 
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 347

The Forest Service fails to describe the effects to migratory birds in alternative 1.

Effects to migratory birds were described in the wildlife report section titled “Effects of 

Motorized Routes on Migratory Birds.” This section describes the regulatory requirements 

and the method used to address Executive Order 13186 (2001) and the Forest Service Land 

Bird Conservation Strategic Plan. This method included review of the list of bird identified 

by Bird Conservation Region (USDI 2008) region 16 (Southern Rockies/Colorado Plateau 

Bird Conservation Region) and review of important bird areas indentified by the New Mexico 

Partners in Flight (2007). 

The Forest Service should follow the New Mexico Department of Game and Fish’s 

recommendations (in its 2008 scoping letter) for road closures and route densities.

All the comments, including those from the New Mexico Department of Game and Fish, are 

taken into account when forming the alternatives and making the decision.

The Forest Service needs to analyze the effects of motorized use in relation to the “white nose 

syndrome” affecting bats.

There is no current scientific research linking motorized use and white nose syndrome in bats.

Federal agencies in conjunction with New Mexico State agencies have developed strategies 

to reduce the introduction and infestation of the syndrome when discovered within the State.

The Forest Service has no reason to close routes to motorized use because the population trends 

of wildlife are upwards under the current condition.

As described throughout the travel management process and in the Travel Management Rule 

(36 CFR 212.55), the Forest Service must consider a number of things, including minimizing 

effects to wildlife, when designating roads or trails. 

The DEIS does not fully explain the loss of effective habitat from the motorized use of roads and 

trails.

The wildlife report and biological evaluation display the change in motorized use in wildlife 

habitat by species among the alternatives. This varies by species because some species are 

more affected by the physical presence of the road and others are more affected by the use of 

the road.

The DEIS needs to describe the effects of motorized use and route density outside of wilderness 

for elk habitats. Including wilderness in the route density calculations makes it difficult to 

compare the alternatives as to how they meet our recommendations of 1.0 mi/sq mi.

The wildlife report explains the reason for including wilderness in the calculation of route 

density. Namely, elk do not differentiate between wilderness and nonwilderness, and we used 

species’ entire potential habitat when calculating route density. Studies show that road density 

is an important measure to analyze and minimize impacts to some wildlife (van Dyke et 

al.1986, Mech et al. 1988, Rowland 2000, Forman 2000). All the action alternatives reduce 

route densities for most species assessed in the wildlife report and biological evaluation. This 

reduction of road density will be a benefit to those species, such as elk and birds, where 

vehicle use disturbs normal behaviors.
Appendix 7. Response to Comments on the DEIS

348 FEIS for Travel Management on the Santa Fe National Forest

The Forest Service needs to provide scientific evidence showing the effects that routes and 

motorized use have on each species of wildlife.

This final statement, the wildlife report, and the biological Eevaluation (BE) contain several 

research citations documenting the general effects of roads to wildlife species. Speciesspecific research on the effects from roads has not been done on all species addressed in the 

wildlife report and BE; however, the body of research done on the effects of roads to wildlife 

substantiates the overall negative effects roads have on wildlife. We have analyzed the effects 

of the different alternatives to wildlife.

The Santa Fe National Forest should participate in the North Central New Mexico Conservation 

Modeling Effort under New Mexico State University.

We could look into this outside of the travel management planning process. 

Proximity to wildlife is the only rationale for closing a road or trail.

The Travel Management Rule requires the Forest Service to consider many factors other than 

wildlife when designating routes (36 CFR 212.55). Nonetheless, there are many attributes of 

roads that affect wildlife discussed in the reports (wildlife and biological evaluation). They 

are species specific and include such effects as fragmentation (e.g. effects from the physical 

presence of the road) and disturbance (e.g. the use of the road).

The Forest neglected to address the differences in effects between roads and trails. Trails are 

much narrower and do not have the same effects.

For reasons described in assumption 5, forest staff assumed that the effects of roads and trails 

are the same. Studies show the type of effects are similar (i.e., increases bare ground, reduces 

vegetative cover), but the magnitude may be different. The forest does not have sufficient 

information to quantify these differences considering the wide range of road and trail types on 

the forest (e.g., level 2 roads, level 3 roads, high clearance two track roads, ATV trails, 

motorcycle trails, etc.).

The DEIS’s claim that roads are bad for wildlife is too general not supported by scientific 

evidence.

The wildlife specialist report discusses the effects of motorized use and routes on wildlife and 

its habitat in detail, including a number of scientific references that document these effects.

The DEIS should compare the effects of different kinds of trail users on wildlife. For example, the 

effects of a 2,000-pound horse have to be different from a motorcycle. 

The National Environmental Policy Act requires agencies to analyze the effects of a proposal.

In this case, we propose to designate where people can drive in the Santa Fe National Forest.

Thus, analyzing the direct and indirect effects of other kinds of use of trails is outside the 

scope of this analysis. We have, however, included past, present, and reasonably foreseeable 

uses of the national forest in the cumulative effects analysis.
Appendix 7. Response to Comments on the DEIS

FEIS for Travel Management on the Santa Fe National Forest 349

Extrapolating the research on the effects of roads on wildlife to imply effects from trails is not 

scientifically credible. The Santa Fe National Forest needs to find or conduct research 

specifically on the effects to wildlife from trails.

Few studies on the effects of motorized trails to wildlife exist; we, therefore, draw upon the 

larger body of well documented research on the effects of roads to wildlife. The types of 

effects—such as bare ground—caused by roads and trails are the same. The magnitude of the 

effects varies with the width and length. As explained in assumption 5, the width of proposed 

roads and trails varies enough across the forest that we consider them the same in our effects 

analysis. We acknowledge that at individual locations the magnitude of the area disturbed 

may be different depending on the width and use of the route, but it isn’t necessary to 

describe these site-specific effects on every route (indeed this would not be possible) before 

making a decision. 

The analysis of effects to the yellow-billed cuckoo includes the risk of collision even though the 

cuckoo may not exist on the Forest.

It is possible that the cuckoo inhabits the forest, though the possibility is low. Nonetheless, 

we are required to show the predicted effects to all species that could or do live in the forest. 

The risk of collision with a vehicle is one of the potential effects.

Volunteers

The Forest Service should do a better job of cultivating cooperative and volunteer working 

relationships with the off-highway vehicle community.

The Santa Fe National Forest has an ongoing relationship with its volunteers and volunteer 

organizations, including off-highway vehicle groups. During the planning for this project, it 

was not appropriate to accelerate the emphasis on volunteer maintenance by motorized users 

because the specific location of the motorized trail system was not yet decided. After the 

decision on designation is made, we fully intend to move into the next phase of fostering and 

managing volunteer work on our motorized trail system.
FEIS for Travel Management on the Santa Fe National Forest 351

Appendix 8. Errata

This appendix describes the minor changes made to the alternatives between April 2011 and 

publication of this final environmental impact statement.

In April 2011, the six alternatives were “frozen” so that analysis could be done on a consistent set 

of maps, resulting in consistent calculations and figures. The specialists used the figures for their 

analysis, which is summarized in chapter 3 of this statement.

The items listed here are errors discovered or changes made between April 21, 2011, and April 

13, 2012. The changes total approximately 24 miles.

These changes are to be incorporated into the alternative for which they are listed.

At the forestwide scale, there is no change in the effects analyzed for any of the alternatives. 

These changes fall within the range of alternatives already analyzed in this final environmental 

impact statement. These changes constitute approximately 0.01 percent or less of the changes 

proposed in the action alternatives.

Road or Trail 

Number Change Made Miles

102 Alt. 2M Add Road 0.3

103FJ Alt. 2M Remove Road 0.4

10DE Alt. 2M Remove Road 0.2

124D Alt. 2M Remove Corridor 0.4

124H Alt. 2M Remove Corridor 0.2

139 Alt. 2M Remove Road 2.3

139C Alt. 2M Remove Road 0.8

144 Alt. 2M Remove Corridor 0.4

144V Alt. 2M Remove Road and Corridor 0.2

144VA Alt. 2M Add Road and Corridor 0.1

144VAA Alt. 2M Add Road and Corridor 0.2

173AE Alt. 2M Remove Road 0.1

181 Alt. 2M Remove Corridor 1.3

264B Alt. 2M Remove Road 0.4

289 Alt. 2M Remove Corridor 0.5

316 Alt. 2M Remove Corridor 0.1

376I Alt. 2M Remove Road 0.1

418 Alt. 2M Remove Corridor 0.5

418P Alt. 2M Remove Corridor 0.2

442D/Trl 279 Alt. 2M Remove Trail 0.2

442R Alt. 2M Remove Trail 1.1

446CC/Trl 286 Alt. 2M Change from Trail to Road 0.6

446F Alt. 2M Add Road 1.6

520D Alt. 2M Remove Corridor 0.2

539 Alt. 2M Remove Corridor 0.4
Appendix 8. Errata Sheet

352 FEIS for Travel Management on the Santa Fe National Forest

Road or Trail 

Number Change Made Miles

615EM Alt. 2M Remove Corridor 0.6

71F Alt. 2M Remove Road 0.3

71O Alt. 2M Remove Road 0.2

71Q Alt. 2M Remove Road 0.1

76 Alt. 2M Remove Corridor 0.2

8 Alt. 2M Remove Corridor 0.1

8ZH Alt. 2M Remove Trail 0.2

83GFB Alt. 2M Remove Corridor 0.4

Trl 113 Alt. 2M Remove Trail 2.1

Trl 279 Alt. 2M Remove Trail 1.4

UNAU105 Alt. 2M Remove Road 0.2

UNAU116 Alt. 2M Remove Road and Corridor 0.1

UNAU121 Alt. 2M Remove Road 0.3

UNAU124 Alt. 2M Remove Road 0.1

UNAU16 Alt. 2M Remove Road 0.2

UNAU17 Alt. 2M Remove Road 0.1

UNAU19 Alt. 2M Remove Road 1.0

UNAU28 Alt. 2M Remove Road 0.0

UNAU55 Alt. 2M Remove Road 0.3

UNAU60 Alt. 2M Remove Road 0.2

UNAU61 Alt. 2M Remove Road 0.5

UNAU69 Alt. 2M Remove Road 0.1

UNAU84 Alt. 2M Remove Road 2.3

UT605 Update Trail with GPS 0.7

UT691 Update Trail with GPS; Alt. 3 Remove Trail 0.2
FEIS for Travel Management on the Santa Fe National Forest 353

Index

air quality, xi, 218, 219, 221, 222, 223, 224, 

239, 285

effects on health, 61, 219, 220, 221, 222, 

223, 234, 249

greenhouse gases, 220, 221, 223

visibility, 61, 221, 222, 223

Alaska National Interest Lands Conservation 

Act (ANILCA), 16, 140, 145, 149, 245

all terrain vehicles (ATVs), ix, xiv, 2, 15, 21, 

23, 24, 27, 28, 31, 32, 35, 36, 39, 40, 43, 45, 

47, 48, 50, 51, 74, 84, 85, 87, 91, 94, 96, 

104, 115, 118, 121, 147, 205, 236, 244, 290, 

300, 308, 314

ATV trails, 43

alternatives, 20

administrative alternative, 50

alternative 1, 17

alternative 2, 22, 23, 26

alternative 2M, 26, 27

alternative 3, 30, 31

alternative 4, 34, 35

alternative 5, 38, 39

comparison of, xi, 56

equal use alternative, 55

features common to alternatives 2 through 

5, 42

Glorieta Mesa alternative, 51

landscape-based alternative, 53

monitoring alternative, 54

motorized big game retrieval alternative, 51

not studied in detail, xi, 44

road density alternative, 55

science-based alternative, 53

American Recovery and Reinvestment Act, 

229

big game retrieval, i, viii, 20, 23, 24, 27, 28, 

30, 32, 34, 35, 36, 39, 40, 43, 44, 45, 51, 56, 

71, 74, 76, 79, 87, 91, 94, 95, 96, 97, 122, 

132, 139, 148, 161, 162, 170, 171, 183, 186, 

204, 207, 208, 209, 217, 218, 224, 226, 227, 

229, 230, 235, 251, 253, 254, 255, 257, 258, 

259, 268, 289, 299, 302, 303, 305, 312, 313, 

317, 318, 340, 341

birds, xvi, 183, 184, 202, 203, 248, 347

carbon monoxide, 218, 220

Christmas trees, 66, 80, 136

Clean Water Act, ix, 150, 153, 271, 337

closures

closed road (defined), 11

closed to motorized use, 10, 56, 72, 73, 83, 

197, 225, 258, 259, 267, 274, 310, 321, 

329, 338

closure orders, 16, 17, 35, 44, 70, 92, 95, 

108, 115, 119, 133, 164, 186, 228, 273, 

294, 321

seasonal, 79, 86, 92, 332

comments

comments on DEIS, 9

on proposed action, xii, 6, 14, 106, 285, 286

cultural practices and traditions, 136

cultural resources, xi, 43, 210, 216, 217, 231, 

291

access to, 216, 217

potential damage to, 213, 215, 216, 217

cumulative effects, 64, 87, 93, 95, 97, 101, 

104, 107, 110, 114, 117, 120, 122, 129, 131, 

132, 135, 136, 137, 139, 148, 167, 181, 186, 

207, 209, 216, 217, 223, 225, 226, 229, 292

decision, xi, 4, 10

decommissioning, 66, 170, 236

designating routes, 7, 147

dispersed camping, 79, 98, 101, 163, 235, 266, 

314

economics, 8, 123, 124, 125, 128, 129, 133, 

134, 136, 233, 240, 243, 332, 333, 334, 335, 

336, 343

elk, xvi, 201

employment, 59, 123, 124, 125, 126, 128, 129, 

134, 324

employment and income, 123, 125, 126

Endangered Species Act, 175, 187, 202, 232, 

343

enforcement, 49, 79, 114, 116, 289, 294

environmental justice (Executive Order 

12898), 123, 133, 134, 239, 336

erosion, xvi, 6, 65, 74, 92, 105, 112, 114, 118, 

121, 149, 150, 152, 154, 155, 156, 159, 163, 
Index

354 FEIS for Travel Management on the Santa Fe National Forest

164, 166, 167, 168, 169, 170, 171, 172, 173, 

175, 178, 179, 183, 190, 193, 210, 213, 215, 

216, 218, 225, 228, 229, 244, 281, 290, 311, 

330, 332, 340, 342

executive order, i, 95, 133, 203, 204, 239, 272, 

298, 324, 345, 347

fisheries, xi, 72, 171, 174, 187, 200, 233, 237, 

239, 240, 241, 248

effects of routes and motorized use on fish 

habitat, 171

fish-bearing streams, 180, 181

forest plan, i, 4, 17, 72, 78, 86, 171, 199, 203, 

204, 245, 295, 304, 308, 328, 331, 338, 343

amendments, 42, 122, 148, 170, 182, 203, 

209, 217, 224, 227, 230

consistency of alternatives with the forest 

plan, 78

forest products, xiii, 18, 59, 123, 134, 136, 

137, 138, 139, 187, 287, 320, 336, 344

Holy Ghost ipomopsis, 192

issues, 6, 7, 8

significant issues, iv, 7, 13

Jemez Mountain salamander, 44, 185, 192, 

193, 204, 278, 279, 288, 301, 302, 303, 304, 

313, 328

Jemez National Recreation Area, 65, 107, 122, 

132, 139, 148, 170, 171, 182, 183, 204, 209, 

218, 224, 227, 230, 256, 257, 259, 260

Jemez River, 174

knapweed, xvi, 205

Las Conchas Fire, xii, xiv, xvi, 16, 130, 168, 

169, 190, 216, 277, 278, 279, 281, 282, 283

location of project, xi, xiv, 2, 143, 215

maintenance, 58, 79, 117, 119, 142, 310

annual maintenance costs, 118

maintenance levels, 73, 74, 321

road maintenance budget, 117

trail maintenance, xiii, 118, 120

management indicator species, 174, 176, 177, 

178, 199, 200, 248

Mexican spotted owl, 187, 188, 239, 248, 249

minimum road system, 46

mitigation measures, xi, 43, 217

motor vehicle use map (MVUM), xv, 58, 59, 

70, 116, 170, 210, 251, 253, 254, 255, 256, 

257, 258, 259, 260, 315, 316

removing routes, 42

the first map, 10

motorized access

maximum access, 46, 289

minimum access, 48, 286

motorized cross-country travel, 20, 22, 26, 30, 

34, 38

National Environmental Policy Act (NEPA), 

1, 9, 43, 51, 63, 277, 279, 293, 302, 318, 

327, 331, 335, 336, 337, 339, 348

National Historic Preservation Act (NHPA), 

43, 53, 212, 213, 232, 278, 291, 320

New Mexico Department of Game and Fish, 

18, 23, 27, 43, 67, 94, 95, 97, 116, 178, 179, 

194, 242, 246, 275, 298, 313, 346, 347

noise, 58, 105, 109, 112, 114, 123, 129, 130, 

239, 322

northern goshawk, 185

obliteration (roads), 236

opportunities, 79

peregrine falcon, 194

private land, xi, 49, 59, 126, 140, 141, 145, 

147, 148, 149, 212, 233, 234, 238, 240, 241, 

242, 243, 248, 306, 307

access to private property, 143

motorized use near private land, 144

property values, 135, 136

proposed action

original proposed action (July 2008), 14, 45

protected activity centers, 185, 186, 188, 189, 

190, 343

public involvement, iv, xi, 5

purpose and need for action, iii, xi, 1, 3, 326

recreation, xi, 46, 48, 65, 79, 122, 123, 126, 

136, 160, 167, 169, 204, 233, 234, 237, 238, 

239, 243, 244, 248, 286, 289, 310, 324, 328, 

335
Index

FEIS for Travel Management on the Santa Fe National Forest 355

Rio Grande chub, 176

Rio Grande cutthroat trout, 176, 180

Rio Grande silvery minnow, 174, 175, 244

Rio Grande sucker, 176

riparian areas, 152, 156

rivers, 190

road density, 42, 45, 55, 56, 253, 254, 255, 

256, 295, 328, 331, 342

roadless areas, 79, 110, 112, 308

roads, iv, viii, xii, xiv, 4, 24, 25, 28, 29, 32, 

33, 36, 37, 40, 41, 57, 74, 82, 86, 88, 93, 

111, 112, 114, 117, 119, 120, 131, 138, 144, 

150, 168, 172, 180, 182, 184, 191, 192, 193, 

195, 205, 218, 233, 237, 238, 246, 248, 251, 

254, 255, 263, 267, 274, 277, 283, 309

routes, xv, 17, 24, 28, 32, 36, 40, 58, 89, 93, 

107, 151, 212, 236, 246, 263, 264, 265, 267, 

273, 278, 283, 291, 331

adding unauthorized routes, 20

changes to, 20, 22, 26, 30, 34

removing routes, 42

safety, 58, 79, 116, 121, 277, 278, 331

scoping, 5, 6, 8, 14, 286

season of use, 21, 23, 27, 31, 35, 39

sediment, 150, 152, 169, 171, 175, 177, 178, 

180, 183, 240, 244, 270, 281, 338

sensitive species, 176, 192, 203

amphibians, 192

birds, 193, 202, 249, 347

mammals, 195

plants, xi, 149, 173, 192, 197, 204, 206, 

209, 231, 244, 299

social and economic analysis, xi, 78, 123, 139

soil and water, xi, xii, 112, 113, 149, 152, 154, 

170, 177, 180, 181, 206, 234, 269, 338, 340, 

341

compaction, 77, 152, 158, 173

erosion, iv, v, 4, 7, 60, 152, 156, 238, 243

southwestern willow flycatcher, 190, 191

spotted owl

critical habitat, 188

streams

listed as impaired, 150, 152, 153, 154, 155, 

156, 157, 160, 161, 162, 164, 166, 169, 

179, 271, 339, 341, 342

stream crossings, 152, 157, 160, 161, 172, 

173, 177, 179, 180, 181, 182, 183, 244, 

337, 340

temperature, 152, 179

temporary roads, 65, 75

threatened and endangered species, 174, 187, 

200, 203

trails, xii, 24, 28, 32, 36, 40, 57, 83, 86, 89, 93, 

111, 118, 119, 120, 180, 233, 234, 251, 259, 

263, 264, 265, 267, 274, 277, 295, 309, 315, 

316, 348

transportation system, xiii, 17, 20, 46, 76, 82, 

84, 85, 87, 134, 160, 161, 180, 186, 211, 

229, 273, 274, 279, 284, 285, 292, 293, 309, 

319, 330, 335, 344

Travel Management Rule, i, iii, ix, 1, 2, 3, 5, 

10, 16, 17, 20, 42, 45, 46, 47, 48, 49, 54, 55, 

68, 71, 72, 73, 79, 85, 116, 121, 136, 140, 

167, 190, 224, 226, 235, 236, 238, 245, 274, 

283, 285, 288, 289, 290, 294, 295, 296, 297, 

298, 301, 305, 308, 309, 310, 311, 312, 313, 

314, 315, 316, 317, 319, 320, 322, 324, 326, 

327, 330, 331, 335, 336, 337, 341, 344, 345, 

347, 348

travel management, current policy, 44

trespass, 7, 79, 106, 108, 109, 110, 143, 145, 

147, 148, 300, 307

tribes, iv, 5, 10, 215, 234, 292

consultation, 9

unauthorized routes, 17, 20, 24, 28, 32, 36, 40, 

44, 56, 57, 65, 160, 216, 236, 263, 264, 265, 

267, 273, 274, 344

vehicles

50 inches or less, 21, 23, 26, 27, 31, 34, 35, 

38, 39, 42

jeeps and 4x4s, v, 7, 14, 43

motorcycles, v, ix, 2, 7, 14, 15, 21, 22, 23, 

24, 26, 27, 28, 30, 31, 32, 34, 35, 36, 38, 

39, 40, 42, 45, 48, 52, 74, 85, 86, 87, 91, 

93, 104, 118, 120, 121, 130, 137, 179, 

235, 290, 300, 304
Index

356 FEIS for Travel Management on the Santa Fe National Forest

off-highway vehicles (OHV), iii, 1, 50, 80, 

94, 105, 108, 117, 127, 128, 130, 131, 

132, 135, 207, 225, 227, 235, 238, 289, 

290, 296, 298, 307, 310, 324, 330

tracked, 42

types of vehicles allowed, 21, 23, 27, 31, 

35, 39

visual quality, xi, 62, 227, 228, 230, 231

wheelchair, 235

wild and scenic rivers, 65, 107, 139, 169, 182, 

218, 227, 244, 270

wilderness, 15, 55, 57, 79, 108, 109, 124, 130, 

132, 146, 203, 219, 221, 222, 233, 234, 237, 

267, 295, 299, 300, 301, 305, 316

wildfires, xi, 65, 168, 224, 225, 227

number and causes of wildfires, 224, 225, 

226

wildlife, xi, xvi, 44, 81, 95, 96, 97, 174, 175, 

183, 187, 189, 190, 191, 192, 202, 203, 231, 

233, 234, 237, 238, 239, 242, 243, 244, 248, 

249, 303, 343, 346

how routes and vehicles affect wildlife, 184, 

193, 195, 203
324

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0 0.5 1 2 3 4

Miles

Alternative 2 Modified

with Errata Changes

Travel Management FEIS

Santa Fe National Forest Eastside

Legend

Open to All Vehicles, Yearlong

Open to All Vehicles, Seasonal

Open to Highway Legal Vehicles Only, Yearlong

Open to Highway Legal Vehicles Only, Seasonal

Open to Vehicles < or = 50", Yearlong

Open to Vehicles < or = 50", Seasonal

Open to Motorcycles Only, Yearlong

Open to Motorcycles Only, Seasonal

Motorized Camping/Big Game Retrieval Corridor*

Area

Wilderness

Other Ownership

USFS Ownership

ATTENTION

This product is reproduced from geospatial information prepared by the U.S. Department

of Agriculture, Forest Service. GIS data and product accuracy may vary. They may be:

developed from sources of differing accuracy, accurate only at certain scales, based on

modeling or interpretation, incomplete while being created or revised, etc. Using GIS

products for purposes other than those for which they were created, may yield inaccurate or

misleading results. The Forest Service reserves the right to correct, update, modify,

or replace, GIS products without notification. This map is not a legal land line or ownership

document. Public lands are subject to change and may have access restrictions; check

with local offices. Roads and trails shown on non-USFS lands may not have public

easement. Obtain permission before entering private land. For more information, contact:

Santa Fe National Forest (505)438-5300.

Data Projection: UTM Zone 13 NAD83;

T:\FS\NFS\SantaFe\Project\SO\TravelManagement\GIS\FEIS\MXD\

DATE: 5/11/12

* Motor vehicle use off a forest road or trail for purposes of Dispersed

Camping/Game Retrieval shall be at least 100 feet from a stream,

wetland or other body of water.

(150 feet from either side of the edge of the route)
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9CC

103RC

655A

313AA

519B

544D

178F

461G

170AE

453B

424A

308C

173AE

267A

12F

8WA

607A

103AIA

148J

447AA

108B

178B

62EC

103NA

112H

62H

461K

24DA

607FC

10AC

103NB

311LA

453AA

316C

103E

174CB

27W

174CBA

317G

8SE

174C

461EA

10N

135AHE

144XA

315G

157D

308CB

515D

611E

93P

266GA

515P

266NA

96LD

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134E

153BJ

535FC

266G

100R

446G

390Q

267F

418HA

514G

103FE

488KA

151H

282E

317H

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453C

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173AD

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100ALDA

103B1

134A

652L

317JB

329H

112AE

390G

461ZC

607FA

103FJ

531AE

170AEA

315QA

144VE

169FEC

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103DI

446CC/Trl 286

317KGC

461EB

322EB

310AA

268

108D

99

62E

20

314

539

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416

103

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144

31

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544

10

488

289

21F

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144

144

103W

11

103

313

9A

445

137

445

316

103

100

268

20

103

653

10

267

503

70

27

8H

174

31

144

27

268D

322

62B

268

315

20O

10

442

510

31K

134

24

268

22

315

534D

376

20

62

271

100

27

100

112A

315

461

172B

24

266

266

125

289

27

27

534

117

31

152

27

103

31

316B

266

503

533

655

316X

8H

144

31

378

103

91

607

558

109

316

31

70

22

539

24

534D

445

89

266

653

103Q

558S

461

25

611BC

488

463

517M

10

543

70

31

70

28

530

76

76L

103W

100

103

64A

89

89

103

88

461

289

99

446C

8

269

77

289

106

270

105

144

100

174

10

418

264

269

100A

172D

0 0.5 1 2 3 4

Miles

Alternative 2 Modified

with Errata Changes

Travel Management FEIS

Santa Fe National Forest Westside

Legend

Open to All Vehicles, Yearlong

Open to All Vehicles, Seasonal

Open to Highway Legal Vehicles Only, Yearlong

Open to Highway Legal Vehicles Only, Seasonal

Open to Vehicles < or = 50", Yearlong

Open to Vehicles < or = 50", Seasonal

Open to Motorcycles Only, Yearlong

Open to Motorcycles Only, Seasonal

Motorized Camp/Big Game Retrieval Corridor*

Area

Wilderness

Other Ownership

USFS Ownership

ATTENTION

This product is reproduced from geospatial information prepared by the U.S. Department

of Agriculture, Forest Service. GIS data and product accuracy may vary. They may be:

developed from sources of differing accuracy, accurate only at certain scales, based on

modeling or interpretation, incomplete while being created or revised, etc. Using GIS

products for purposes other than those for which they were created, may yield inaccurate or

misleading results. The Forest Service reserves the right to correct, update, modify,

or replace, GIS products without notification. This map is not a legal land line or ownership

document. Public lands are subject to change and may have access restrictions; check

with local offices. Roads and trails shown on non-USFS lands may not have public

easement. Obtain permission before entering private land. For more information, contact:

Santa Fe National Forest (505)438-5300.

Data Projection: UTM Zone 13 NAD83;

T:\FS\NFS\SantaFe\Project\SO\TravelManagement\GIS\FEIS\MXD\

DATE: 5/11/12

* Motor vehicle use off a forest road or trail for purposes o

Camping/Game Retrieval shall be at least 100 feet from a s

wetland or other body of water.

(150 feet from either side of the edge of the route)
324

83

86

85

45

326

375

330

92

79

46

646

263

645

113

156

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325

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45C

86A

200

326A

572

638

306

594C

637

46A

102

594

87

123

50A

46G

203

612

122

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615D

555

291

124

124H

330G

393

632

86T

435

330F

439

124D

79W

324HF

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83F

330E

326C

324LA

124W

123A

121

326EA

47C

52H

391

113E

18JB

569

223

325KD

589

86P

634

92NA

124DE

324U

45TD

436

18A

305

47CB

92PA

124S

66F

92M

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114

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83Y

637A

594A

325K

87J

231

326N

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86AP

120D

594D

200L

415

87GC

326J

634D

594DB

83MB

81

263B

569CB

113B

569C

223A

203B

412

325F

569D

325G

45N

569A

18JC

326WA

324HH

441

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326AD

569DA

120

18S

326CJ

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594AC

326WC

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638G

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326EJ

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306E

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594AA

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330Q

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326EB

47CAA

306XA

326BB

326PD

86V

330FD

646Q

326PQ

113EM

66DB 66D

52F

114D

200M

203JF

87G

156A

439L

439M

200MA

325H

569CBA

569B

324H

555F

436C

306EA

124MH

439C

325KB

645Q

441B

45GD

83C

440BH

615DG

306S

646QB

391ED

440BJ

475C

83MX

101A

306

634C

223

203

569

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200

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324

92

92

200MA

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263B

326

83

439

263

87

83F

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306E

324

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124H

86

223

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263

83

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83

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18

86A

632

572

102

569

326

223

86APB

0 0.5 1 2 3 4

Miles

Designated System under Alt. 2M

to Appear on the First MVUM

Travel Management FEIS

Santa Fe National Forest Eastside

Legend

Open to All Vehicles, Yearlong

Open to All Vehicles, Seasonal

Open to Highway Legal Vehicles Only, Yearlong

Open to Highway Legal Vehicles Only, Seasonal

Open to Vehicles < or = 50", Yearlong

Open to Vehicles < or = 50", Seasonal

Open to Motorcycles Only, Yearlong

Open to Motorcycles Only, Seasonal

Motorized Camping/Big Game Retrieval Corridor*

Area

Wilderness

Other Ownership

USFS Ownership

ATTENTION

This product is reproduced from geospatial information prepared by the U.S. Department

of Agriculture, Forest Service. GIS data and product accuracy may vary. They may be:

developed from sources of differing accuracy, accurate only at certain scales, based on

modeling or interpretation, incomplete while being created or revised, etc. Using GIS

products for purposes other than those for which they were created, may yield inaccurate or

misleading results. The Forest Service reserves the right to correct, update, modify,

or replace, GIS products without notification. This map is not a legal land line or ownership

document. Public lands are subject to change and may have access restrictions; check

with local offices. Roads and trails shown on non-USFS lands may not have public

easement. Obtain permission before entering private land. For more information, contact:

Santa Fe National Forest (505)438-5300.

Data Projection: UTM Zone 13 NAD83;

T:\FS\NFS\SantaFe\Project\SO\TravelManagement\GIS\FEIS\MXD\

DATE: 5/11/12

* Motor vehicle use off a forest road or trail for purposes of Dispersed

Camping/Game Retrieval shall be at least 100 feet from a stream,

wetland or other body of water.

(150 feet from either side of the edge of the route)
5

6

31

77

7

376

20

151

9

268

515

93

534

517

135

57

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24

449

313

269

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70

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89

71

27

144

604

96

76

312

98

11

608

100

505

69

136

311

157

424

473

266

117

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64

474

289

103

418

153

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510

148

88

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468

310

558

60

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280

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465

142

458

270

492

453

19

30

489

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316

656

74

25

267

606

91

317

159

524

24M

170

282

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535

106

488

107

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470

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36

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508

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468CA

174

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169

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115

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512

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25K

239

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445C

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315B

15

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199

125

108

318

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24NB

6T

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322

543

64A

71E

178

152

24E

24K

446

466C

311C

471

26

171B

24JF

418J

135A

503

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264

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461

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24D

103L

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418AA

109

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286

271

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100A

96O

521

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288

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137C

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611B

492F

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394

455

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105

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314

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11G

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110

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329

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316P

98A

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94

181

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93Q

159A

486A

5T

317K

313A

311JA

461KA

514P

133

270BD

604R

422A

170A

491B

491

169FE

135B

448

8SA

315

514

76LC

64R

9M

281

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112A

169FD

605E

390L

24WA

544

134

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652

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24BB

446C

500

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418E

510A

464F

171BB

21E

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539JD

534D

461L

172B

287

322E

315J

471C

530

453A

173A

446F

534F

8ZD

311B

418N

103H

25G

316B

77B1

461AB

329F

76L

153BC

8Q

100AL

316H

520B

24BA

22N

311J

505J

103C

522N

27Y

517E

418P

656M

270B

103W

22M

531DA

103EA

458F

517M

418A

607G

655

503C

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311D

416S

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465E

4AD

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103UC

25GD

157G

467A

534O

7D

312J

148G

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534GH

424B

172D

318B

318H

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28

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544J

169D

103HI

418C

188D

608F

442

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172L

418AB

173

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505E

418JC

505K

458A

424F

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317KB

605D

527

604QB

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171C

91C

30B

37A

418JA

103P

144D1

515L

103F

69B

515N

653E

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558S

100CE

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107K

100AL1

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132

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153BI

418L

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62E

181B

604G

322EA

31K

322A

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108D

449B

418H

20O

100CED

103Q

181L

470B

418M

171CA

418KC

376Q8

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31H

268DD

4A

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188B

608G

99DA

103UB

103AI

458HAA

93JA

465B

62B

316BA

379

268D

611BC

169FH

103EH

98C

148GC

390E

170B

318HD

152M

5U

534NA

318K

390A

112R

473J

24JE

309

311CH

194CAA

169DA

655AB

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135AH

151B

76LB

535AE

504E

103EI

144W

461FA

96L

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31D

653EJ

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77B

62G

103T

424BC

446H

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64G

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93PC

424E

69C

103S

518F

141

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517MA

24MJ

25LC

267ED

174Q

656MFA

95A

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317A

103N

506

148F

313R

22GA

488J

22MB

461IT

27L

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75C

604P

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126S

473LA

534GN

172G

169FF

27T

316ZB

106A

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608JB

31J

488F

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20ID

309G

318E

488JA

468CAC

517L

268C

316X

522J

103V

453AE

148N

9CC

103RC

655A

313AA

519B

544D

178F

461G

170AE

453B

424A

308C

173AE

267A

12F

8WA

607A

103AIA

148J

447AA

108B

178B

62EC

103NA

112H

62H

461K

24DA

607FC

10AC

103NB

311LA

453AA

316C

103E

174CB

27W

174CBA

317G

8SE

174C

461EA

10N

135AHE

144XA

315G

157D

308CB

515D

611E

93P

266GA

515P

266NA

96LD

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134E

153BJ

535FC

266G

100R

446G

390Q

267F

418HA

514G

103FE

488KA

151H

282E

317H

655F

517D

17Q

488FA

453C

458HABA

173AD

64AH

100ALDA

103B1

134A

652L

317JB

329H

112AE

390G

461ZC

607FA

103FJ

531AE

170AEA

315QA

144VE

169FEC

531ICAA

103DI

446CC/Trl 286

317KGC

461EB

322EB

310AA

268

108D

99

62E

20

314

539

22

416

103

520D

144

31

10

532

544

10

488

289

21F

471

446C

144

144

103W

11

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313

9A

445

137

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103

100

268

20

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653

10

267

503

70

27

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174

31

144

27

268D

322

62B

268

315

20O

10

442

510

31K

134

24

268

22

315

534D

376

20

62

271

100

27

100

112A

315

461

172B

24

266

266

125

289

27

27

534

117

31

152

27

103

31

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266

503

533

655

316X

8H

144

31

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103

91

607

558

109

316

31

70

22

539

24

534D

445

89

266

653

103Q

558S

461

25

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488

463

517M

10

543

70

31

70

28

530

76

76L

103W

100

103

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89

89

103

88

461

289

99

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8

269

77

289

106

270

105

144

100

174

10

418

264

269

100A

172D

0 0.5 1 2 3 4

Miles

Alternative 2 Modified

with Errata Changes

Travel Management FEIS

Santa Fe National Forest Westside

Legend

Open to All Vehicles, Yearlong

Open to All Vehicles, Seasonal

Open to Highway Legal Vehicles Only, Yearlong

Open to Highway Legal Vehicles Only, Seasonal

Open to Vehicles < or = 50", Yearlong

Open to Vehicles < or = 50", Seasonal

Open to Motorcycles Only, Yearlong

Open to Motorcycles Only, Seasonal

Motorized Camp/Big Game Retrieval Corridor*

Area

Wilderness

Other Ownership

USFS Ownership

ATTENTION

This product is reproduced from geospatial information prepared by the U.S. Department

of Agriculture, Forest Service. GIS data and product accuracy may vary. They may be:

developed from sources of differing accuracy, accurate only at certain scales, based on

modeling or interpretation, incomplete while being created or revised, etc. Using GIS

products for purposes other than those for which they were created, may yield inaccurate or

misleading results. The Forest Service reserves the right to correct, update, modify,

or replace, GIS products without notification. This map is not a legal land line or ownership

document. Public lands are subject to change and may have access restrictions; check

with local offices. Roads and trails shown on non-USFS lands may not have public

easement. Obtain permission before entering private land. For more information, contact:

Santa Fe National Forest (505)438-5300.

Data Projection: UTM Zone 13 NAD83;

T:\FS\NFS\SantaFe\Project\SO\TravelManagement\GIS\FEIS\MXD\

DATE: 5/11/12

* Motor vehicle use off a forest road or trail for purposes o

Camping/Game Retrieval shall be at least 100 feet from a s

wetland or other body of water.

(150 feet from either side of the edge of the route)