United States Department of Agriculture

 Forest Southwest MB-R3-04-22 July 2014

 Service Region

Draft Environmental Impact 

Statement for the Flagstaff 

Watershed Protection Project

Coconino National Forest

Coconino County, Arizona

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and 

activities on the basis of race, color, national origin, age, disability, and where applicable, sex, 

marital status, familial status, parental status, religion, sexual orientation, genetic information, 

political beliefs, reprisal, or because all or part of an individual’s income is derived from any 

public assistance program. (Not all prohibited bases apply to all programs.) Persons with 

disabilities who require alternative means of communication of program information (Braille, 

large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and 

TTY). To file a complaint of discrimination, write to USDA, Director of Civil Rights, 1400 

Independence Avenue SW, Washington, DC 20250-9410, or call (800) 795-3272 (voice) or (202) 

720-6382 (TTY). USDA is an equal opportunity provider and employer.

Printed on recycled paper – July 2014

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project i

Environmental Impact Statement for the 

Flagstaff Watershed Protection Project

Coconino National Forest

Coconino County, Arizona

Lead Agency: USDA Forest Service

Cooperating Agencies: City of Flagstaff

Arizona Game and Fish Department

Responsible Official: M. Earl Stewart, Forest Supervisor

1824 S. Thompson St, Flagstaff, AZ 86001

For Information Contact: Erin Phelps, Project Manager

5075 N. Hwy 89, Flagstaff, AZ 86004

928-527-8240

Abstract: This environmental impact statement discusses the effects associated with four 

alternatives, including the No Action Alternative, the Proposed Action with Cable Logging, the 

Proposed Action without Cable Logging, and the Minimal Treatment Alternative. No alternative 

is preferred, and the final decision could contain a melding of two or more alternatives. All three 

action alternatives would require two Forest Plan amendments, one to allow treatments within 

Mexican spotted owl habitat to be more in line with the revised Mexican Spotted Owl Recovery 

Plan (USFWS 2012) and one to allow mechanical treatment on slopes above 40 percent (see 

Chapter 2 and Appendix A).

In order to have standing to object to the draft decision, reviewers must provide the Forest 

Service with their comments during the review period of the draft environmental impact 

statement or other designated comment period (e.g. scoping). This will enable the Forest Service 

to analyze and respond to the comments at one time and to use information acquired in the 

preparation of the final environmental impact statement, thus avoiding undue delay in the 

decision making process. Reviewers have an obligation to structure their participation in the 

National Environmental Policy Act process so that it is meaningful and alerts the agency to the 

reviewers’ position and contentions. Environmental objections that could have been raised at the 

draft stage may be waived if not raised until after completion of the final environmental impact 

statement. In addition, 36 CFR 218.8(c) states “issues raised in objections must be based on 

previously submitted specific written comments regarding the proposed project or activity and 

attributed to the objector...”. Comments on the draft environmental impact statement should be 

specific and should address the adequacy of the statement and the merits of the alternatives 

discussed (40 CFR 1503.3).

Send Comments to: Erin Phelps

5075 N. Hwy 89, Flagstaff, AZ 86004
ii Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

Summary

During the November 2012 elections, residents of Flagstaff, AZ approved a $10 million bond to 

support forest restoration work within key watersheds on the Coconino National Forest and State 

of Arizona lands. Identified on the ballot as the “Forest Health and Water Supply Protection 

Project,” the planning effort on the National Forest segment is now known as the “Flagstaff 

Watershed Protection Project (FWPP).” This is one of only a handful of examples in the country 

where forest restoration work on the National Forests is being funded by a municipality, and the 

only known instance where such an effort is funded from municipal bonds. 

There have been notable successes with forest thinning efforts, both within and adjacent to the 

City in the past decade, where emerging wildfires entered treated areas and were able to be 

effectively and safely suppressed with minimal damage. However the experience of the Schultz 

Fire in 2010 demonstrated the potential for severe downstream impacts even when residential 

areas are spared from the fire itself. Following the Schultz Fire, severe and repeated flooding 

occurred in unincorporated neighborhoods just outside Flagstaff city limits, causing tens of 

millions of dollars of damage to infrastructure and private property. 

Predictions of post-fire flooding suggest that a wildfire in the Dry Lake Hills could cause 

widespread flooding in such areas as downtown Flagstaff and that post-fire erosion could impact 

the City of Flagstaff’s ability to utilize Upper Lake Mary as a domestic water supply. 

The FWPP analysis area includes approximately 10,544 acres (roughly 7,569 acres in the Dry 

Lake Hills portion and 2,975 on Mormon Mountain) and includes portions of the Coconino 

National Forest that have either not been analyzed or not been treated previously due to 

prohibitive costs associated with very steep terrain, low value material, and other challenging 

issues such as potential impacts to wildlife and visual concerns. 

The primary purpose of FWPP is to reduce the risk of high severity wildfire and subsequent 

flooding in two key watersheds near Flagstaff, Arizona: the Dry Lake Hills portion of the Rio de 

Flag Watershed (DLH) and the Mormon Mountain portion of the Walnut Creek-Upper Lake 

Mary Watershed (MM) (see Chapter 1 for more information). More specifically, there is a need 

to reduce the potential for crown fires, high intensity surface fires, and to reduce the likelihood of 

human-caused ignitions. Subsequently, FWPP is a fire risk reduction project with components of 

restoration; Chapter 2 contains more information on the differences and similarities between the 

two. 

The Forest Service published a proposed action in April 2013 to engage the public and solicit 

feedback. During the scoping process, the public raised concerns about certain aspects of the 

proposed action, including the use of cable logging, potential impacts to the threatened Mexican 

spotted owl and its habitat, and the removal of large and old trees (see Public Involvement section 

in Chapter 1 for more details). 

These concerns led the agency to refine the proposed action and develop two additional 

alternatives including one that would avoid the use of cable logging, and another that would treat 

the “minimal” amount necessary to still meet the purpose and need. 

The DEIS analyzes a variety of harvesting and fuel reduction methods to meet that purpose, 

including the use of traditional ground-based equipment, hand thinning, and also methods 

atypical for the region, including cable and helicopter logging, in order to treat steep, inaccessible 

terrain. Alternatives 2 and 3 are similar in that the treatment objectives and acreages are roughly 

the same; the differences between the two alternatives lie in the implementation methods. 

Alternative 2 would utilize cable logging to remove timber, while Alternative 3 would instead use 
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project iii

a combination of specialized steep-slope machinery and helicopters. Alternative 4 would treat 

less acreage and use a “minimal treatment” approach, where the steepest slopes would largely 

remain untreated and efforts would be focused on the lower and upper portions of the hills, where 

traditional ground-based equipment could be utilized, along with hand felling in the rougher 

terrain. Chapter 2 contains more information about the alternatives and their associated design 

features. 

Major conclusions include: 

Alternatives 2 and 3 would have the greatest reduction in active crown fire potential: from 

approximately 57 percent of the project area under the No Action Alternative to 7 percent under 

Alternatives 2 and 3, compared to approximately 28 percent under Alternative 4. Alternatives 2 

and 3 would also result in the greatest reduction in post-fire predicted peak discharge associated 

with a 100-year storm event (1 percent recurrence interval): 60 percent reduction for Alternatives 

2 and 3 versus 30 percent reduction for Alternative 4 as compared to the No Action Alternative. 

All three action alternatives include a Forest Plan amendment to allow mechanized equipment for 

thinning on slopes greater than 40 percent (see Forest Plan Amendments in Chapter 2 and 

Appendix A for more information).

Due to the cable logging corridors and the safety requirements of both cable logging and 

helicopter logging, Alternatives 2 and 3 would remove the greatest number of snags, resulting in 

greater impacts to Mexican spotted owl (MSO) critical habitat. All three action alternatives would 

include a Forest Plan amendment related to treatments in MSO habitat which include thinning 

and prescribed burning in the Schultz Creek nest core, prescribed burning only in the other nest 

cores, mechanized thinning up to 18 inches dbh in PACs, and a project-specific monitoring 

proposal. Per the amendment, treatments with MSO protected activity centers (PACs) would also 

be allowed for up to two breeding seasons, which would result in impacts to MSO. Project 

activities are not anticipated to change trends for any Management Indicator Species (MIS), or 

Forest Service Sensitive Species. The Wildlife section of Chapter 3 contains more detailed 

analysis of the impacts on wildlife.

At a project level, there is little difference between action alternatives in the number of trees 

greater than 18 inches dbh post-treatment, with trees greater than 24 inches dbh likely to be 

removed only under Alternative 2 for cable logging corridors. On Mormon Mountain, there is no 

difference shown in modeling as the wet mixed conifer band that is deferred in Alternative 4 

would still receive only light treatment in the other two action alternatives (creating regeneration 

pockets within aspen stands, piling and burning of dead and down material). In the Dry Lake 

Hills, there is a slight difference in the ponderosa pine treatments, where an average of four trees 

per acre greater than 18 inches dbh would be cut in Alternatives 2 and 3, and an average of three 

trees per acres greater than 18 inches dbh would be cut under Alternative 4. Trees greater than 24 

inches dbh would not be targeted for removal under any alternative, and in fact, the only place 

that the modeling shows them being removed is in the cable corridors under Alternative 2. The 

Forest Structure and Health section contains numerous tables and discussion on post-treatment 

conditions for all the alternatives, and also models those conditions out 20 and 40 years after 

treatment. The Wildlife section of Chapter 3 contains more information about removal of larger 

trees and snags within MSO habitats under the action alternatives. Chapter 2 contains a 

Comparison of Alternatives table that summarizes some of the key differences between the 

alternatives. 

Based upon the effects of the alternatives, the responsible official will decide the best method for 

treating within the project area, which could involve a blending of alternatives. This “blending” 

could mean that a portion of two or more alternatives are chosen to essentially create a new 

alternative, as long as that decision includes actions that are identified and the potential effects are 
iv Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

disclosed through the analysis of at least one of the alternatives. The range of alternatives 

included in the DEIS seeks to cover every feasible treatment option so that the responsible 

official can compare effects of each before deciding. This way, the decision could include 

components of each alternative; for example, cable logging in certain portions of the project area, 

helicopter logging in more sensitive habit, and no treatment in others.
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project v

Content

Environmental Impact Statement for the Flagstaff Watershed Protection Project...............................i

Summary......................................................................................................................................................ii

Commonly Used Acronyms.....................................................................................................................xiv

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

Document Structure................................................................................................................................1

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

Location..................................................................................................................................................4

Purpose and Need for Action..................................................................................................................4

Proposed Action ...................................................................................................................................38

Design Criteria Integral to the Proposed Action by Resource..............................................................39

Decision Framework ............................................................................................................................40

Public Involvement...............................................................................................................................41

Issues....................................................................................................................................................42

Chapter 2. Alternatives.............................................................................................................................47

Introduction ..........................................................................................................................................47

Alternatives Considered in Detail ........................................................................................................57

Comparison of Alternatives................................................................................................................122

Chapter 3. Affected Environment and Environmental Consequences...............................................129

Fire & Fuels........................................................................................................................................129

Air Quality..........................................................................................................................................185

Forest Structure and Health................................................................................................................191

Soil & Water Resources......................................................................................................................262

Wildlife...............................................................................................................................................291

Scenery ...............................................................................................................................................384

Economics..........................................................................................................................................425

Invasive Plant Species........................................................................................................................433

Sensitive Plants...................................................................................................................................447

Recreation...........................................................................................................................................455

Heritage ..............................................................................................................................................474

Chapter 4. Consultation and Coordination ..........................................................................................483

Preparers and Contributors.................................................................................................................483

Chapter 5. References.............................................................................................................................485

Glossary ...................................................................................................................................................506

Appendix A – Forest Plan Amendments................................................................................................519

Appendix B – Monitoring Protocols......................................................................................................527

Appendix C – Law, Regulation & Policy Compliance .........................................................................533

Fire, Fuels and Air Quality .................................................................................................................533

Forest Structure and Health................................................................................................................535

Soil & Water Resources......................................................................................................................539

Wildlife...............................................................................................................................................542

Scenery ...............................................................................................................................................543

Invasive Plant Species........................................................................................................................553
vi Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

Recreation...........................................................................................................................................554

Heritage ..............................................................................................................................................557

Index.........................................................................................................................................................561

List of Tables

Table 1: Wildfire Ignition Occurrence over the Past 20 years within FWPP............................ 6

Table 2: Fire Hazard Ratings for Acreages Surveyed within FWPP......................................... 7

Table 3: Crown Fire Potential (97th percentile) for the Project Area (with percent of project 

area) ................................................................................................................................ 10

Table 4: Crown Fire Potential (Schultz Fire Conditions) for the Project Area (with percent of 

project area) .....................................................................................................................11

Table 5: Analysis Area Cover Type Acres............................................................................... 12

Table 6: Acres and percent of existing old growth by cover type and site potential located 

within FWPP. .................................................................................................................. 17

Table 7: Existing Ponderosa Pine Beetle Hazard Rating (Percent of stands in each Project 

Area) ............................................................................................................................... 19

Table 8: EC - Dwarf Mistletoe Infection Level of ponderosa pine and mixed conifer within 

FWPP.............................................................................................................................. 20

Table 9: Desired Vegetative Structural Stage (VSS) distribution for the northern goshawk, 

according to the Forest Plan, for DLH (ponderosa pine)................................................ 29

Table 10: Forest Plan Management and Geographic Areas, Acres within Project Area ......... 40

Table 11: Alternative 2 Proposed Treatment Descriptions, Objectives and Acres.................. 61

Table 12: Alternative 2 Harvesting Methods for DLH............................................................ 65

Table 13: Alternative 2 Harvesting Methods for MM............................................................. 66

Table 14: Roads within the FWPP area, their current status and proposed status postimplementation for all action alternatives....................................................................... 73

Table 15: Mitigation Measures Specific to Alternatives 2 and/or 3........................................ 79

Table 16: Alternative 3 Proposed Treatment Descriptions, Objectives and Acres.................. 83

Table 17: Alternative 3 Harvesting Methods for DLH............................................................ 87

Table 18: Alternative 3 Harvesting Methods for MM............................................................. 88

Table 19: Alternative 4 Proposed Treatment Descriptions, Objectives and Acres.................. 94

Table 20: Alternative 4 Harvesting Methods for DLH............................................................ 97

Table 21: Alternative 4 Harvesting Methods for MM............................................................. 98

Table 22: Ranges of reference conditions for ponderosa pine forests in the Southwestern 

United States from studies detailed in RMRS-GTR-310 (2013). ................................. 100

Table 23: Proposed Treatments and their focus (restoration versus fire risk reduction)....... 103

Table 24: Mitigation Measures Common to all Action Alternatives..................................... 105

Table 25: Comparison of Proposed Actions between Alternatives....................................... 122

Table 26: Comparison of transportation systems proposed for each alternative, Dry Lake Hills

...................................................................................................................................... 124

Table 27: Comparison of transportation systems proposed for each alternative, Mormon 

Mountain....................................................................................................................... 125

Table 28: Comparison of Effects between Alternatives........................................................ 126

Table 29: Historic Fire Regime Groups and Descriptions.................................................... 133

Table 30: Condition Class definitions used for FRCC.......................................................... 134

Table 31: DLH Summary Fire Regime and Condition Class Acres...................................... 135

Table 32: MM Summary Fire Regime and Condition Class Acres....................................... 136

Table 33: Existing Conditions for DLH project area (2013)................................................. 137

Table 34: Existing Conditions for MM project area (2013).................................................. 137

Table 35: Arrival time in acres/hour under the Existing Condition (No Action Alternative) 139
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project vii

Table 36: DLH average projected conditions in treatment areas under the No Action 

Alternative .................................................................................................................... 144

Table 37: MM average no action alternative projected conditions in treatments areas under 

the No Action Alternative ............................................................................................. 144

Table 38: Crown Fire potential Alternatives 2 and 3 ............................................................ 152

Table 39: Prescribed Fire Implementation Effects Dry Lake Hills ALternative 2................ 155

Table 40: Prescribed Fire Implementation Effects Mormon Mountain Alternative 2........... 156

Table 41: Dry Lake Hills average for Alternative 2 projected post-treatment conditions. ... 158

Table 42: Mormon Mountain average for Alternative 2 projected post-treatment conditions.

...................................................................................................................................... 160

Table 43: Dry Lake Hills Fire Hazard post treatment Alts 2 & 3 ......................................... 162

Table 44 Mormon Mountain Fire hazard post treatment Alts 2 & 3..................................... 162

Table 45: Comparison Arrival time in acres/hour Alternative 2 & 3 .................................... 163

Table 46: Prescribed Fire Implementation Effects Dry Lake Hills Alternative 3 ................. 165

Table 47: Prescribed Fire Implementation Effects Mormon Mountain Alternative 3........... 166

Table 48: Dry Lake Hills average projected treatment conditions for Alternative 3. ........... 167

Table 49: Mormon Mountain average projected treatment conditions for Alternative 3...... 169

Table 50: Prescribed Fire Implementation Effects Dry Lake Hills Alternative 4. ................ 172

Table 51 Prescribed Fire Implementation Effects Mormon Mountain Alternative 4............ 173

Table 52: Existing Crown fire potential and modeled Alt. 4................................................. 176

Table 53: Dry Lake Hills average projected treatment conditions for Alternative 4 ............ 180

Table 54: Mormon Mountain average projected treatment conditions for Alternative 4...... 182

Table 55: Comparison Arrival time in acres/hour Alternative 4 ........................................... 184

Table 56: Description of Vegetation Structural Stages (VSS)............................................... 194

Table 57: Relationships of Forest Density to Forest Stand Development and Tree 

Characteristics............................................................................................................... 196

Table 58: Stocking Guides to Meet Tree Group Canopy Cover Requirements within Goshawk 

Habitat Areas Outside of PFAs (LOPFA) ..................................................................... 197

Table 59: Stocking Guides to Meet Tree Group Canopy Cover Requirements within Goshawk 

PFAs.............................................................................................................................. 198

Table 60: MSO Habitat Stratification within the Analysis Area (Acres within each project 

site) under the 2012 MSO Recovery Plan..................................................................... 199

Table 61: Northern Goshawk Habitat Stratification within the Analysis Area (Acres by project 

site) ............................................................................................................................... 199

Table 62: Existing Spotted Owl Habitat Forest Structure and Habitat Components ............ 201

Table 63: Existing Goshawk Nest/PFA Habitat Forest Structure and Habitat Components. 203

Table 64: Existing Goshawk LOPFA Habitat Forest Structure and Habitat Components.... 203

Table 65: Existing Forest Structure – Goshawk LOPFA Stands Percent of Area by Vegetative 

Structural Stages. .......................................................................................................... 204

Table 66: Existing Forest Structure – Goshawk PFA/Nest Stands Percent of Area by 

Vegetative Structural Stages. ........................................................................................ 204

Table 67: Dry Lake Hills - Small scale analysis of current conditions using data analyzed at 

the plot level and broken out into nest, PFA, and LOPFA areas. Average values 

calculated at the point level using individual stand exam plot data.............................. 215

Table 68: Dry Lake Hills - Mid-scale analysis of current stand condition using data analyzed 

at the stand level and broken out into nest, PFA and LOPFA areas. Average values 

calculated by stand broken out by LOPFA, PFA, Nest areas, MSO PAC treatments and 

MSO PAC Nest Burn Only treatments. ........................................................................ 215
viii Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

Table 69: Dry Lake Hills - Large scale analysis of current conditions across all goshawk areas 

treated within the DLH Area. Stand values averaged across all ponderosa pine stands 

within the northern goshawk habitat............................................................................. 216

Table 70: Dry Lake Hills - Stand values of post vegetation treatment conditions (2013). ... 216

Table 71: Dry Lake Hills - Average stand values of the no action and action alternatives 

projected 20 years out (2033). ...................................................................................... 217

Table 72: Dry Lake Hills - Average stand values of the no action and action alternatives 

projected 40 years out (2053). ...................................................................................... 218

Table 73: Mormon Mountain - Stand values of current conditions and post treatment 

conditions for Ponderosa Pine Fuels Reduction treatments.......................................... 223

Table 74: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 20 years out for ponderosa pine stands. ........................................................ 224

Table 75: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 40 years out for ponderosa pine stands. ........................................................ 225

Table 76: Dry Lake Hills - Stand values of current conditions and post treatment conditions 

for Dry Mixed Conifer.................................................................................................. 230

Table 77: Dry Lake Hills - Average stand values of no action and proposed alternatives 

projected 20 years for Dry Mixed Conifer.................................................................... 231

Table 78: Dry Lake Hills - Average stand values of no action and proposed alternatives 

projected 40 years for Dry Mixed Conifer.................................................................... 232

Table 79: Mormon Mountain - Stand values of current conditions and post treatment 

conditions for Dry Mixed Conifer................................................................................. 234

Table 80: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 20 years for Dry Mixed Conifer.................................................................... 234

Table 81: Mormon Mountain - Average stand values of No Action and proposed alternatives 

projected 40 years for Dry Mixed Conifer.................................................................... 234

Table 82: Mormon Mountain - Stand values of current conditions and post treatment 

conditions for Wet Mixed Conifer. ............................................................................... 236

Table 83: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 20 years for Wet Mixed Conifer.................................................................... 237

Table 84: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 40 years for Wet Mixed Conifer.................................................................... 237

Table 85: The number and percent of trees per acre over 18 inches dbh cut within MSO PACs 

of the DLH.................................................................................................................... 238

Table 86: The number and percent of trees per acre over 24 inches dbh cut within MSO 

Recovery Habitat in the Dry Lake Hills ....................................................................... 240

Table 87: The number and percent of trees per acre over 18 inches dbh cut within MSO PACs 

on MM .......................................................................................................................... 241

Table 88: Basal area and trees per acre for the Aspen Treatment areas under Alternatives 2, 3 

and 4. These numbers do not include anticipated aspen regeneration (DLH) .............. 243

Table 89: Acres and percent of currently allocated acres being managed for old growth by 

cover type and site potential, and the proposed acres for future old growth management 

located within FWPP..................................................................................................... 244

Table 90: Current conditions and post treatment Dwarf Mistletoe Infection Level of 

ponderosa pine and mixed conifer as a percentage of stands with stand exams within 

FWPP............................................................................................................................ 247

Table 91: Current and Post Treatment Ponderosa Pine and Mixed Conifer Beetle Hazard 

Ratings (Percent of stands in each Project Area).......................................................... 248
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project ix

Table 92: FWPP Cumulative Effects Project List of past, present, and reasonably foreseeable 

actions in the Dry Lake Hills project area and surrounding areas ................................ 249

Table 93: FWPP Cumulative Effects Project List for past, present, and reasonably foreseeable 

actions in the Mormon Mountain project area and surrounding area ........................... 250

Table 94: Dry Lake Hills - Current and Post Treatment Stand Values.................................. 256

Table 95: Dry Lake Hills - Projected 20 Years ..................................................................... 257

Table 96: Dry Lake Hills - Projected 40 Years ..................................................................... 257

Table 97: Mormon Mountain - Current and Post Treatment within MSO Habitat ............... 258

Table 98: Mormon Mountain - Projected 20 Years within MSO Habitat ............................. 259

Table 99: Projected 40 Years within MSO Habitat - MM..................................................... 260

Table 100: Soil Burn Severity Categories as a percentage of simulated wildfire, DLH....... 268

Table 101: Soil Burn Severity Categories as a percentage of simulated wildfire, MM........ 268

Table 102: Summary of total sediment delivered to stream networks in the DLH area during 

the first year following simulated wildfire.................................................................... 268

Table 103: Summary of total sediment delivered to stream networks in the MM area during 

the first year following simulated wildfire.................................................................... 269

Table 104: Predicted Peak Discharges for Schultz Creek at Mt. Elden Lookout Road ........ 274

Table 105: Predicted rates of erosion (from Elliot and Robichaud, 2005)............................ 275

Table 106: List of TES wildlife species that are present or have habitat in the FWPP action 

area................................................................................................................................ 292

Table 107: Summary of acreages of MSO PACs and core areas in the project area............. 293

Table 108: Active crown fire potential in MSO habitats in Dry Lake Hills.......................... 294

Table 109: Active crown fire potential in MSO habitats for Mormon Mountain project area

...................................................................................................................................... 295

Table 110: Acreages of MSO Recovery Habitat within the Project Area ............................. 295

Table 111: Critical Habitat within the FWPP Project Area ................................................... 297

Table 112: Alternative 2 acres of thinning and/or burning proposed in MSO habitat .......... 301

Table 113: Alt. 2 Loss of MSO Key Habitat Components within Areas Cable Logged 

including Cable Corridors............................................................................................. 303

Table 114: Alternatives 2 and 3 Post Treatment Crown Fire Potential ................................. 304

Table 115: Alternatives 2 and 3 Post Treatment Crown Fire Potential ................................. 304

Table 116: Alternative 2 - Miles/Acres of Cable Corridors, Temp and Relocated Roads in 

Protected and Recovery Habitat.................................................................................... 306

Table 117: Alternative 3 - Miles of Temp and Relocated Roads in Protected (by PAC) and 

Recovery Habitats......................................................................................................... 312

Table 118: Alternative 4 - Acres of Treatments in MSO Habitat .......................................... 315

Table 119: Alternative 4 Post Treatment Crown Fire Potential in MSO Habitats, DLH ...... 316

Table 120: Alternative 4 Post Treatment Crown Fire Potential in MSO habitats, MM ........ 317

Table 121: Alt 4 - Number/Acres of Temp and Relocated Roads in Protected (by PAC) and 

Recovery Habitat .......................................................................................................... 317

Table 122: NOGO PFA and Nest Stand Acres in the Project................................................ 324

Table 123: Alt. 2 - Cable Corridors (Acres) and Temporary Roads (Miles) in NOGO Habitat

...................................................................................................................................... 328

Table 124: Alt. 3 - Miles of Temporary Roads in NOGO Habitat ........................................ 330

Table 125: Alt. 4 - Miles of Temporary and Relocated Roads in NOGO Habitat................. 331

Table 126: Snags/acre > 18" diameter breast height (dbh) and > 12" DBH immediately after 

treatment by alternative ................................................................................................ 345

Table 127: MAs within the FWPP with the Associated MIS................................................ 353
x Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

Table 128: MIS and Forestwide Population Trend, Important Habitat Components, and 

Forestwide Component Trends..................................................................................... 354

Table 129: MIS Habitat Treated by Alternative (Acres/% of Forest-wide habitat)............... 355

Table 130: Effects to MIS indicator habitat quantity by alternative (Acres/% of Forest-wide 

habitat).......................................................................................................................... 355

Table 131: Effects to MIS habitat quality by alternative (Acres/% of Forest-wide habitat). 356

Table 132: Acres of Migratory Bird Habitat within the FWPP Area .................................... 376

Table 133: Scenic integrity-visual quality and perception crosswalk (Forest Service 2000) 385

Table 134: Summary of scenery stability evaluation with condition and risk ratings. ......... 390

Table 135: Comparison of existing conditions and desired scenic character........................ 393

Table 136: Estimated scenic recovery times by treatment type, Alternative 2 ..................... 409

Table 137: Estimated recovery time by treatment type for the Dry Lake Hills and Mormon 

Mountain areas, Alternative 3....................................................................................... 418

Table 138: Estimate of recovery time following implementation, Alternative 4. ................. 421

Table 139: Logging cost summary, Alternative 2 ................................................................. 429

Table 140: Logging cost summary, Alternative 3 ................................................................. 431

Table 141: Logging cost summary, Alternative 4 ................................................................. 432

Table 142: Comparison of costs per alternative.................................................................... 432

Table 143: Noxious or invasive weed species detected in or adjacent to DLH and MM ..... 434

Table 144. Locations and sites containing Rusby milkvetch in the Dry Lake Hills portion of 

the project area, with proposed treatments for each action alternative......................... 448

Table 145: USFS trails located within the FWPP analysis area............................................ 458

Table 146: USFS trailheads located within the analysis area ............................................... 459

Table 147: Special-use events that occur within the FWPP analysis area ............................ 460

Table 148: USFS trails with segments located within proposed cable logging locations..... 472

Table 149: USFS trails with segments located within 500 feet of cable logging locations 

(CLL)............................................................................................................................ 472

Table 150: Amendment 1: Current and Proposed MSO Forest Plan Language.................... 520

Table 151: Amendment 2: Current and Proposed Steep Slope Forest Plan Language.......... 524

Table 152: Soil & Water Resource Compliance with Forest Plan and Other Relevant Laws, 

Regulations, Policies and Plans.................................................................................... 539

Table 153: Summary of the existing Forest Plan management direction for scenery (Forest 

Service 1987)................................................................................................................ 545

Table 154: Summary of the existing Forest Plan management direction for Recreation and 

Wilderness (Forest Service, 1987)................................................................................ 554

List of Figures

Figure 1: General Vicinity Map ................................................................................................ 3

Figure 2: View of dense vegetation and steep slopes taken from within the DLH portion of the 

project area. The San Francisco Peaks are visible in the background. ............................. 5

Figure 3: Looking down on the City of Flagstaff from the communication site on Mount 

Elden, within the DLH portion of the project area. .......................................................... 6

Figure 4: Natural Fire Regime Groups (from the Interagency Fire Regime Condition Class 

Guidebook, Sept. 2010) .................................................................................................... 8

Figure 5: Historic picture of Mount Elden from 1895 (photo courtesy of the NAU Archives) 9

Figure 6: Reference photo of Mount Elden taken on June 5, 2013........................................... 9

Figure 7: Stratification of forested and non-forested lands within FWPP.............................. 13

Figure 8: Erosion Hazard Ratings within the DLH Analysis Area ......................................... 31

Figure 9: Erosion Hazard Ratings within the Mormon Mountain Analysis Area ................... 32
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project xi

Figure 10: Streamcourses and Drainage Areas within the DLH Portion of the Analysis Area

........................................................................................................................................ 34

Figure 11: Streamcourses and Drainage Areas within the MM Area...................................... 36

Figure 12: Wheeled feller-buncher used on slopes up to 25 percent ...................................... 48

Figure 13: Tracked, boomed feller-buncher for steep slopes.................................................. 49

Figure 14: Grapple Skidder..................................................................................................... 49

Figure 15: Log processer ........................................................................................................ 50

Figure 16: Log Loader ............................................................................................................ 50

Figure 17: Harvester ............................................................................................................... 51

Figure 18: Forwarder on 65% slope........................................................................................ 52

Figure 19: Drawing of a skyline logging system, tops of the logs or trees usually drag on the 

ground............................................................................................................................. 53

Figure 20: Skyline Yarder ....................................................................................................... 53

Figure 21: Excaliner yarding logs........................................................................................... 54

Figure 22: Helicopter Yarding................................................................................................. 55

Figure 23: Hand piles along Elden Lookout Road.................................................................. 56

Figure 24: Spider piling slash on steep ground....................................................................... 57

Figure 25: Alternative 2 Proposed Treatments, DLH ............................................................. 59

Figure 26: Alternative 2 Proposed Treatments, MM............................................................... 60

Figure 27: Proposed Transportation System for Alternative 2, DLH...................................... 76

Figure 28: Proposed Transportation System for Alternative 2, MM....................................... 77

Figure 29: Alternative 3 Proposed Treatments, DLH ............................................................. 81

Figure 30: Alternative 3 Proposed Treatments, MM............................................................... 82

Figure 31: Proposed Transportation System for Alternative 3, DLH...................................... 90

Figure 32: Proposed Transportation System for Alternative 3, MM....................................... 91

Figure 33: Alternative 4 Proposed Treatments, DLH ............................................................. 93

Figure 34: Alternative 4 Proposed Treatments, MM............................................................... 94

Figure 35: Proposed Transportation System for Alternative 4, DLH.................................... 101

Figure 36: Proposed Transportation System for Alternative 4, MM..................................... 102

Figure 37: Crown Fire Potential under 2010 Schultz Wildfire and 97th Percentile Weather 

Conditions for DLH and MM ....................................................................................... 138

Figure 38: Estimated Fire Arrival Time for Alternative 1 DLH, modeled under Schultz Fire 

weather conditions........................................................................................................ 142

Figure 39: Estimated Fire Arrival Time for Alternative 1, MM, modeled under Schultz Fire 

Weather Conditions....................................................................................................... 143

Figure 40: Existing Conditions (No Action Alternative) fire behavior modeled under 2010 

Schultz Wildfire weather conditions – Dry Lake Hills................................................. 145

Figure 41: Existing Conditions (No Action Alternative) Fire behavior modeled under 2010 

Schultz Wildfire weather conditions – Mormon Mountain .......................................... 146

Figure 42: Estimated Fire Progression for Alternatives 2 and 3, DLH................................. 149

Figure 43: Estimated Fire Progression for Alternatives 2 and 3, MM.................................. 150

Figure 44 Modeled crown fire potential Alternatives 2 and 3 .............................................. 151

Figure 45: Alternatives 2 and 3 fire behavior post-treatment, modeled under 2010 Schultz 

Wildfire weather conditions – DLH.............................................................................. 153

Figure 46: Alternatives 2 and 3 fire behavior post-treatment, modeled under 2010 Schultz 

Wildfire weather conditions – MM............................................................................... 154

Figure 47: Estimated Fire Progression for Alternative 4, DLH ............................................ 174

Figure 48: Estimated Fire Progression for Alternative 4, MM ............................................. 175

Figure 49: Modeled Crown Fire potential for Alternative 4 ................................................. 176
xii Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

Figure 50: Alternative 4 fire behavior modeled under 2010 Schultz Wildfire weather 

conditions – Dry Lake Hills.......................................................................................... 177

Figure 51: Alternative 4 fire behavior modeled under 2010 Schultz Wildfire weather 

conditions –Mormon Mountain .................................................................................... 178

Figure 52: Predicted reduction in potential wildfire emission of PM 2.5 per alternative Dry 

Lake Hills...................................................................................................................... 186

Figure 53: Predicted reductions in potential wildfire emission of PM 2.5 per alternative 

Mormon Mountain........................................................................................................ 187

Figure 54: General Smoke Emissions for a particulate matter 10 and 2.5 for prescribed fire 

and wildfire on the Coconino NF ................................................................................. 190

Figure 55: Conifer encroaching an aspen stand in the DLH (2013) ..................................... 209

Figure 56: Existing old growth and designated developing old growth located within the Dry 

Lake Hills area.............................................................................................................. 245

Figure 57: Existing old growth and designated developing old growth located within the 

Mormon Mountain area ................................................................................................ 246

Figure 58: Changes in stand density in southwestern ponderosa pine, non-reserved forest 

lands, NM and AZ (USDA Forest Service 2004). ........................................................ 253

Figure 59: Soil Burn Severity for DLH under Existing Conditions, Calibrated to the Schultz 

Burn Severity Assessment from the Burned Area Emergency Response (BAER) 

Assessment ................................................................................................................... 264

Figure 60: Soil Burn Severity Map for DLH, No Action Alternative with Simulated Wildfire

...................................................................................................................................... 270

Figure 61: Soil Burn Severity Map for MM, No Action Alternative with Simulated Wildfire

...................................................................................................................................... 271

Figure 62: Soil Burn Severity Map for DLH with Simulated Wildfire, Alternatives 2 & 3 . 279

Figure 63: Soil Burn Severity Map for DLH with Simulated Wildfire, Alternative 4.......... 280

Figure 64: Soil burn severity modeled after Alternative 2 & 3 treatments, compared to the 

Schultz Fire burn severity............................................................................................. 281

Figure 65: Soil burn severity modeled after Alternative 4 treatments, compared to the Schultz 

Fire burn severity.......................................................................................................... 282

Figure 66: Soil Burn Severity Map for Alternatives 2 & 3, MM.......................................... 283

Figure 67: Soil Burn Severity Map for Alternative 4, MM................................................... 284

Figure 68: Picture of a Mexican spotted owl, courtesy of the Texas Fish and Game website 

(accessed February 19, 2014) ....................................................................................... 293

Figure 69: Dry Lake Hills MSO Habitats............................................................................. 298

Figure 70: Mormon Mountain MSO Habitats....................................................................... 299

Figure 71: Dry Lake Hills NOGO PFAs............................................................................... 325

Figure 72: Mormon Mountain NOGO PFAs ........................................................................ 326

Figure 73: Rocky outcrops on Mt Elden. (photo courtesy of Mountain Project, taken by JJ 

Schlick)......................................................................................................................... 387

Figure 74: Almost contiguous coniferous forest common in the project areas, as shown in Dry 

Lake Hills...................................................................................................................... 389

Figure 75: Scenic Integrity Objectives for Dry Lake Hills................................................... 395

Figure 76: Scenic Integrity Objectives for Mormon Mountain. ........................................... 395

Figure 77: Example of high intensity wildfire on Mt Elden, and effects on vegetation 

following Schultz Fire .................................................................................................. 398

Figure 78: Tree and boundary marking pre-project actions would be noticeable from roads, 

trails and recreation sites near or within the project. .................................................... 402

Figure 79: Slash chipper in operation (Photo courtesy of R & S Biomass Equipment) ....... 403
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project xiii

Figure 80: Hand piled slash. ................................................................................................. 403

Figure 81: Machine piles are larger than hand piles and create more ground disturbance. .. 404

Figure 82: Active temporary road (Coconino NF)................................................................ 407

Figure 83: A temporary road five years following rehabilitation (Coconino NF). ............... 407

Figure 84: Cable corridor in foreground view, Lolo National Forest ................................... 412

Figure 85: Cable corridors in middleground view, Clearwater National Forest ................... 413

Figure 86: Before cable harvesting begins, Bitterroot National Forest ................................ 413

Figure 87: One year after cable harvesting in winter, Bitterroot National Forest................. 414

Figure 88: Summer two years after cable harvesting, Bitterroot National Forest................. 414

Figure 89: Known locations of noxious and invasive weed species in and adjacent to the DLH 

area................................................................................................................................ 435

Figure 90: Known locations of noxious and invasive weed species in and adjacent to MM 

area................................................................................................................................ 437

Figure 91: Sunset Trail – Hiker enjoying the views and scenery.......................................... 456

Figure 92: Hunting Unit 11 M, AZGFD ............................................................................... 457

Figure 93: Map of Hunting Unit 6A, AZGFD ...................................................................... 457

Figure 94: Little Bear Trail, Post-Schultz Fire, October 2010.............................................. 462

Figure 95: Widow-maker tree with detached limb (above); dead standing tree with little 

holding wood (right); pictures from Waterline Trail damaged by Schultz Fire. ........... 463

Figure 96: Debris flow onto Little Elden Trail, Post-Schultz Fire........................................ 463

Figure 97: Alternative 2 Proposed Treatments with Trails and Roads Displayed................. 471
xiv Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

Commonly Used Acronyms

AZGFD – Arizona Game and Fish 

Department

BA – Basal area

BMP – Best management practice

CNF – Coconino National Forest

CTL – Cut to length

CWPP – Community wildfire protection 

plan

Dbh – Diameter at breast height

HUC – Hydrologic unit code

ERI – Ecological Restoration Institute

FR – Forest road

FSVeg – Field sampled vegetation

4FRI – Four Forests Restoration Initiative

FRCC – Fire regime condition class

FWPP – Flagstaff Watershed Protection 

Project

IDT – Interdisciplinary Team

LOPFA – Landscapes outside of northern 

goshawk post-fledgling family areas and 

Mexican spotted owl protected activity 

centers

MA – Management area

MSO – Mexican spotted owl

MSN – Most similar neighbor

NEPA – National Environmental Policy Act

NF – National Forest

PAC – Protected activity center (Mexican 

spotted owl)

PFA – Post-fledgling family area (northern 

goshawk)

SDI – Stand density index

TCP – Traditional cultural property

TES – Terrestrial ecosystem survey

TPA – Trees per acre

ULM – Upper Lake Mary sub-watershed

USFWS – U.S. Fish and Wildlife Service

VSS – Vegetative structural stages

WUI – Wildland-urban interface
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 1

Chapter 1. Purpose of and Need for Action

Document Structure

The Forest Service has prepared this Environmental Impact Statement in compliance with the National 

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

Environmental Impact Statement discloses the direct, indirect, and cumulative environmental impacts that 

would result from the proposed action and alternatives. The document is organized into four chapters: 

Chapter 1. Purpose and Need for Action: The chapter includes information on the history of the 

project proposal, the purpose of and need for the project, and the agency’s proposal for achieving 

that purpose and need. This section also details how the Forest Service informed the public of the 

proposal and how the public responded. 

Chapter 2. Alternatives, including the Proposed Action: This chapter provides a more detailed 

description of the agency’s proposed action as well as alternative methods for achieving the stated 

purpose. These alternatives were developed based on significant issues raised by the public and 

other agencies. This discussion also includes mitigation measures. Finally, this section provides a 

summary table of the environmental consequences associated with each alternative. 

Chapter 3. Affected Environment and Environmental Consequences: This chapter describes the 

environmental effects of implementing the proposed action and other alternatives. This analysis is 

organized by resource area. 

Chapter 4. Consultation and Coordination: This chapter provides a list of preparers and agencies 

consulted during the development of the environmental impact statement. 

Chapter 5: References: List of references used in the analyses, organized by resource area.

Appendices: The appendices (A-C) provide more detailed information to support the analyses 

presented in the environmental impact statement such as the record index, public comments and 

responses, etc.

Index: The index provides page numbers by document topic.

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

the project planning record located at the Flagstaff District Office on the Coconino National Forest.

Background

The City of Flagstaff has seen first-hand the devastating impacts of fire and post-fire flooding following

the 2010 Schultz Fire on the east side of the San Francisco Peaks. The cost of fire suppression was 

approximately $10 million; however, the actual cost of the fire is many times greater than that figure. 

Many of those additional costs have been associated with severe, repeated flooding following the fire, 

with flows originating on the National Forest and traveling into semi-rural residential areas just outside 

the city limits. Almost four years after the actual wildfire, the Forest Service and Coconino County 

continue to work on mitigating the threat of flooding in those areas. 

The Forest Service and the City of Flagstaff (also referred to throughout this document as “the City”) are 

working together to reduce similar threats on National Forest System lands in the Dry Lake Hills area 

(Rio de Flag 6

th HUC Watershed) north of Flagstaff (DLH) and on Mormon Mountain (Walnut CreekUpper Lake Mary 6

th HUC Watershed) south of town (MM), which is in a critical municipal watershed
Chapter 1 – Purpose and Need

2 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

(Figure 1). Projections show that there could be severe flooding in parts of Flagstaff if a fire producing 

impacts to vegetation and soils similar to that which occurred form the Schultz fire were to occur on the 

slopes of the DLH, and that post-fire erosion following a similar fire in the Mormon Mountain area could 

impact the City’s ability to utilize the Lake Mary Reservoir as a potable water supply, as this reservoir 

provides roughly 50 percent of the City’s drinking water. During the November 2012 elections, residents 

of Flagstaff passed a $10 million bond with approximately 74 percent approval to support forest 

treatments within these two watersheds on the Coconino National Forest and also on State of Arizona 

lands. Identified on the ballot as the “Forest Health and Water Supply Protection Project,” the planning 

effort on the National Forest segment is now known as the “Flagstaff Watershed Protection Project 

(FWPP).” Similar treatments may occur on approximately 3,000 acres of State of Arizona lands or on 

private lands, including an approximately 140-acre parcel in the middle of the Dry Lake Hills owned by 

the Navajo Nation, as part of the overarching project funded through the City bond; however these 

activities are not included in this FWPP EIS planning effort as it pertains strictly to those actions 

proposed on the National Forest. The implementation of watershed protection treatments on the National 

Forest System lands does not depend on the implementation of treatments on adjacent lands under other 

ownership. Treatments on adjacent lands will be included in the cumulative effects analysis portion of 

the FWPP EIS. 

Project Milestones

On January 28, 2013, the City of Flagstaff was designated as a cooperating agency through the signing of 

a Memorandum of Understanding (MOU), which outlines the responsibilities of both the Forest Service 

and the City. This status allows a City representative to be a part of the Interdisciplinary Team (IDT) and 

also contribute technical expertise and information for the environmental assessment process. 

In February, 2013 Forest leadership decided to change the level of analysis from an Environmental 

Assessment to an Environmental Impact Statement due to concerns identified by the IDT about potential 

impacts to the Mexican spotted owl and other forest resources. In March 2013, the USDA issued the final 

rule for project-level pre-decisional administration review process known as 36 CFR Part 218; FWPP is a 

project implementing the 1987 Coconino National Forest Plan, is not authorized under the healthy Forest 

Restoration Act, and falls under this 36 CFR Part 218 regulation and therefore is subject to the new 

predecisional objection procedures.
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 3

Figure 1: General Vicinity Map

Figure 1 shows the project area locations relative to the watersheds in which they are located. The yellow 

and orange areas depict the areas being analyzed in this DEIS for treatment. Chapter 2 contains 

information about which areas would actually be treated under each alternative. 

The FWPP project area is of high scenic, cultural, wildlife, and recreational value. Public use of the 

project area is very heavy, with many heavily-used trails (for both motorized and non-motorized use), 
Chapter 1 – Purpose and Need

4 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

camping areas, and rock climbing areas. The area also has religious significance to several Native 

American tribes in the region.

Overlap between the Four Forests Restoration Initiative (4FRI) DEIS analysis area and the FWPP area is

present; those areas that were analyzed by the 4FRI DEIS were included in this planning effort to address 

additional treatment options (such as treatments on steep slopes) and will not be carried forward into the 

4FRI FEIS or Record of Decision. The Mount Elden/Dry Lake Hills (MEDL) Recreation Planning Project 

is also underway, and overlaps a majority of the project area within the Dry Lake Hills. While the 

purposes for the two projects differ, consistency between the proposed actions will be maintained as each 

moves through the analysis process to ensure there are no conflicts between proposals.

Currently about 1,872 acres within the general project boundary are already covered under previous 

NEPA decisions: Jack Smith/Schultz (2009) and Eastside (2007) Fuels Reduction and Forest Health 

Restoration Projects. The treatable areas covered under those decisions are either currently being 

implemented or will be implemented in the near future while the FWPP EIS planning process occurs on 

the rest of the project area. For example, the Orion Task Order (from the Jack Smith/Schultz Decision, 

2009) is within the project boundary in the DLH area and is anticipated to be treated through the 4FRI 

contractor in 2014. Some areas within the Jack Smith/Schultz project area were either determined to be 

untreatable by ground-based equipment or were designated as No Treatment during that planning effort 

due to steep slopes and accessibility issues; those areas are being reanalyzed in the FWPP EIS. 

Location

The analysis area contains two distinct areas: the DLH portion, which is north of Flagstaff, AZ, and the 

MM portion, which is south of Flagstaff (Figure 1). The DLH area is roughly bound by the City of 

Flagstaff to the south, Kachina Peaks Wilderness to the north, the watershed boundary to the east, and a 

closed forest road (FR 06275) to the west. The MM portion is located west of Forest Highway 3 (Lake 

Mary Road) and northwest of Mormon Lake and Mormon Lake Village, on the upper slopes of Mormon 

Mountain, and is generally bound by FR 132D to the north and FR 648 to the south. 

Purpose and Need for Action

The primary purpose of the Flagstaff Watershed Protection Project (FWPP) is to reduce the risk of high 

severity wildfire and subsequent flooding in two key watersheds around Flagstaff, Arizona: in the Dry 

Lake Hills portion of the Rio de Flag Watershed, and the Mormon Mountain portion of the Walnut CreekUpper Lake Mary Watershed (see Figure 1). 

There is a need to reduce the risk of fire and post-fire flooding that would likely damage the drinking 

water infrastructure south of town and which could also cause extensive damage to residential and 

commercial areas should a high-intensity wildfire occur in mountainous areas that make-up the Upper 

Lake Mary and Rio de Flag watersheds.

More specifically, there is a need to reduce the potential for crown fire and high intensity surface fire, to 

reduce the likelihood of human-caused ignitions, and to increase the ability of fire suppression crews to 

control a wildfire occurring within the project area. In order to accomplish this, there is a need to amend 

the Forest Plan to allow mechanical treatment on slopes greater than 40 percent and a need to amend the 

Forest Plan to better align treatments within the FWPP Mexican spotted owl habitats with the 2012 

Recovery Plan. 

The following sections on fire risk, forest structure and health, and soil and water resources further detail 

the existing conditions, desired conditions, and the need for change. 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 5

Fire Risk

Several variables affect fire behavior on a site and over a landscape. Besides weather and terrain factors 

such as slope steepness, aspect, and landform type (chute, canyon, chimney, saddle, etc.), the variables 

that play the largest role in influencing fire behavior within a forest include dead and live fuel loadings, 

fuel moistures, crown bulk density (the volume of fuel available in tree crowns), crown base height (the 

height at which tree branches can be ignited by ground fire), and canopy closure (percentage of ground 

area vertically shaded by overhead foliage) (Agee and Skinner 2005). 

These variables, depending on their structure and arrangement, can create many different fire behavior 

outcomes for a landscape. Intense fire behavior will most likely occur during hot, dry, and windy weather 

conditions under forest conditions of high fuel loadings, including a large number of trees per acre, large 

crown bulk densities, low crown base heights, and closed canopy conditions. 

Existing Conditions

Existing conditions within the project area include dense stands with numerous dog-hair thickets on steep 

slopes with high fire risk (Figure 2), with a substantial wildland urban interface (Figure 3). Cover types

in the project area include ponderosa pine, aspen, dry mixed conifer, wet mixed conifer, oak woodland, 

and grassland. 

Figure 2: View of dense vegetation and steep slopes taken from within the DLH portion of the 

project area. The San Francisco Peaks are visible in the background. 
Chapter 1 – Purpose and Need

6 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

Figure 3: Looking down on the City of Flagstaff from the communication site on Mount Elden, 

within the DLH portion of the project area. 

Table 1 displays the wildfire occurrence over the last twenty years. Other than the Radio Fire (1977), 

which burned approximately 383 acres on Mt. Elden, the project areas have not experienced high severity 

fire or large fires in recorded history; therefore the 20 year time period was used as the best source of 

information relating to the project area. 

Table 1: Wildfire Ignition Occurrence over the Past 20 years within FWPP

Past Wildfire Occurrence Human Caused (total acres) Lightning Caused (total 

acres)

Dry Lake Hills*22 Fires (26.3 Acres) 40 Fires (83.2 Acres)

Mormon Mountain 4 Fires (0.5 Acres) 15 Fires (2.3 Acres)

*Wildfire Occurrence Analysis does not include the human caused Radio Fire (1977) that burned approximately 383 acres within the Dry Lake 

Hills Project Boundary as it occurred before the 20 year time period identified for this exercise.

Based on stand surveys completed in 2012 and 2013 on 6,621 acres within the project area, at least 71 

percent of the surveyed area currently has a fire hazard rating of extreme (Table 2). Fire hazard ratings 

measure how intensely a fire would burn under hot, dry, and windy conditions during April through July, 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 7

and include dead and down fuel loading (tons per acre), number of tree stems per acre, tree diameter, 

percent canopy closure, height to bottom of live crown (crown base height), tree height, slope and aspect

in the calculations. As stand exams were completed on approximately 63 percent of the FWPP area, the 

numbers in Table 2 are a conservative estimate based on the areas that received stand exams. Because of 

the lack of fire within both project areas and knowledge of adjacent stand conditions, it is likely that the 

remaining unsurveyed acres would also be in the high to extreme rating.

Table 2: Fire Hazard Ratings for Acreages Surveyed within FWPP

Fire Hazard Rating Dry Lake 

Hills1

Mormon 

Mountain2

Total Acres 

for FWPP

Percent of Total 

Area Surveyed

Extreme 2,582 acres 2,089 acres 4,671 acres 71%

Very High 72 acres 197 acres 269 acres 4%

High 613 acres 273 acres 886 acres 13%

Moderate 470 acres 174 acres 644 acres 10%

Low 100 acres 51 acres 151 acres 2%

There is also a high departure from historic vegetation conditions and fire return intervals within most of 

the project area (Figure 5 and Figure 6). In general, fire regimes3in the analysis area have shifted from 

historically more frequent, lower-intensity surface fires (Fire Regime I and III, Condition Class I) to less 

frequent, higher-intensity crown fires (Condition Class4III). See also Figure 4. This departure has created 

conditions where, if a wildfire were to occur, there would likely be more severe effects to ecosystem 

components (trees, soil, wildlife) than would have occurred under the natural fire regime. 

 

1 Based on the 3,837 acres survey in the DLH (roughly 51% of the Dry Lake Hills area)

2 Based on the 2,784 acres surveyed on Mormon Mountain (roughly 93% of the Mormon Mt. area)

3 A fire regime classifies the role of fire over the landscape in the absence of modern human mechanical intervention. There are 

five natural fire regimes that are characterized based on average numbers of years between fires combined with fire severity of 

the dominant overstory vegetation. Fire Regime I (FRI) indicates a landscape with frequent fires (0-35 years) with surface to 

mixed burn severity. Fire Regime III (FRIII) indicates a landscape with fires every 35 to 200 years, with low to mixed burn 

severity.

4 Condition Class refers to the level of departure from the historic fire regime. CC1 means the departure is slight, while CC3 

means there is a great departure. See also Table 30.
Chapter 1 – Purpose and Need

8 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

Figure 4: Natural Fire Regime Groups (from the Interagency Fire Regime Condition Class 

Guidebook, Sept. 2010)

A minority of the project area includes vegetation that likely naturally burned at moderate or high 

intensities during historic conditions. While these vegetation types are limited in the project area, these 

too would be treated to limit the potential for crown fire and subsequent flooding in and downstream of 

the project area; however frequent low-severity fire would not be introduced into wet mixed conifer forest 

types. Frequent surface fire would either fail to carry due to lack of long-needle conifer litter and 

bunchgrasses, or the surface fire would result in unacceptably high cambial and root scorch and very high 

forest mortality. Surface fires are not characteristic or appropriate for these forest types.
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 9

Figure 5: Historic picture of Mount Elden from 1895 (photo courtesy of the NAU Archives)

Figure 6: Reference photo of Mount Elden taken on June 5, 2013
Chapter 1 – Purpose and Need

10 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 

Crown fire potential was also analyzed for both project areas using data generated from modeling 

performed using FlamMap 3.0. Three types of fires result from the modeling: surface fire, passive 

crown fire, and active crown fire. Surface fire describes fire that burns through the surface fuels of the 

forest floor. This type of fire has the least active of fire behaviors and is the most beneficial of the three 

types of fires in maintaining the historical, ecological role of low intensity, high frequency fire in the 

southwestern ponderosa pine ecosystem. Passive crown fire, or torching, occurs when flame lengths are 

long enough to reach the lower edge of the canopy and can result in individual or small group tree 

torching but does not proliferate through the forest canopy through continuous crown fire spread. Active 

crown fire occurs when flames reach the forest canopy and spread through it with intensity and 

continuity.

The fuel moisture and weather characteristics used to model the effects and behavior of a potential 

wildfire for existing and desired conditions are 97th percentile conditions from the Flagstaff RAWS 

station and observed conditions on the Schultz fire on June 20th, 2010. The conditions used were as 

follows: 

97th Percentile Conditions

1-hour fuel moisture: 2%

10-hour fuel moisture: 2%

100- hour fuel moisture: 4%

1000- hour fuel moisture: 7%

20-foot wind speed: 25 mph

Air temperature: 850F

Schultz Fire Conditions

1-hour fuel moisture: 3%

10-hour fuel moisture: 3%

100- hour fuel moisture: 6%

1000- hour fuel moisture: 11%

20-foot wind speed: 23 mph

Air temperature: 740F

The 97th percentile and the Schultz Fire weather conditions were used in modeling to give an 

overall worst case scenario in terms of crown fire potential, and also a comparable local 

reference. The 97th percentile conditions represent the top three percent (3%) worst fire weather 

days from 2002-2011, and the Schultz Fire was one of the biggest high intensity/stand replacing 

fires that has occurred recently within fifteen miles of Flagstaff, Arizona. 

Table 3: Crown Fire Potential (97th percentile) for the Project Area (with percent of project 

area)5

CROWN FIRE 

POTENTIAL 

DRY LAKE HILLS MORMON 

MOUNTAIN

TOTALS

Surface Fire 1,426 acres (19%) 286 acres (10%) 1,712 acres (16%)

Passive Crown Fire 557 acres (7%) 481 acres (16%) 1,038 acres (10%)

Active Crown Fire 5,480 acres (73%) 2,201 acres (74%) 7,681 acres (74%)

TOTALS 7,463 modeled acres 2,968 modeled acres 10,431 modeled

acres

 

5 Acreages and percentages may differ slightly between tables due to rounding. Approximately 18 acres were also 

classified as “no data” for use in this model; modeled acreages only cover forested vegetation and do not include the 

aproximately 93 non-forested acres within the project area. 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 11

Table 4: Crown Fire Potential (Schultz Fire Conditions) for the Project Area (with percent of 

project area)

CROWN FIRE 

POTENTIAL 

DRY LAKE HILLS MORMON 

MOUNTAIN

TOTALS

Surface Fire 2,881 acres (39%) 176 acres (6%) 3,057 acres (29%)

Passive Crown Fire 749 acres (10%) 725 acres (24%) 1,474 acres (14%)

Active Crown Fire 3,832 acres (51%) 2,068 acres (70%) 5,900 acres (57%)

TOTALS 7,462 modeled acres 2,969 modeled acres 10,431 modeled

acres

Desired Conditions

The desired condition for the project area is to be able to support low intensity, frequent surface 

fires according to the historical fire regime for the vegetation type. For the majority of the project 

area, the desired condition is to decrease the magnitude of departure from historic conditions, and 

return the majority of the analysis area in FRI and FRIII to Condition Class 1.

Desired future conditions include fewer ladder fuels and dead vegetation on the forest floor (dead 

and down fuel) and the heavy fuel live fuel loading (stems per acre), a more open forest structure 

according to historical vegetative conditions and fire regimes. Desired conditions also include 

reducing potential fire intensity so that more of the project area would experience surface fire 

with low soil burn severity instead of active or passive crown fire with high soil burn severity. 

Need for Change

The purpose of FWPP is to reduce the risk of high severity wildfire and subsequent high severity 

flooding in two key watersheds around the City of Flagstaff. To address the need for fuel 

reduction as directed in the Forest Plan, there is a need to meet the following objectives of fuel 

treatments:

1) There is a need to reduce the probability of crown fire initiation. This is achieved by 

accomplishing the following across the project areas.

a. Reducing the crown bulk density (the mass per volume of available canopy fuels).

b. Increasing the canopy base height (the height at which tree branches can be ignited by 

ground fire).

c. Reducing the potential flame length (e.g. the intensity of the fire).

2) There is a need for wildfires to remain on the ground surface. This is achieved by reducing the 

percent of canopy closure, in addition to those methods described above to reduce crown fire 

initiation.

3) There is a need to reduce the potential for spot fires. This can also be achieved by reducing the 

crown bulk density and amount of surface fuel, by increasing the effective crown base height, and 

by reducing the expected flame length.
Chapter 1 – Purpose and Need

12 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

4) There is a need for the proposed treatments to maintain these objectives for approximately 20 

years by implementing periodic prescribed burning without executing additional thinning 

treatments. 

Forest Structure and Forest Health

Existing Conditions

The Existing Conditions section will go through the cover types present within the project area 

first, followed by a discussion of Mexican spotted owl (MSO) habitat and northern goshawk 

habitat conditions (in terms of forest density and structure), old growth, then forest health. 

Cover Types 

Cover types are divided into three broad categories that describe vegetative state – non-vegetated, 

non-forest or forest. The following is a description of the cover types that occur within the 

analysis area. Table 5 below lists the acres within the analysis area by cover type. Figure 7

displays the breakdown of acres of MSO and northern goshawk habitat and their cover types in 

both the DLH and MM portions. 

Table 5: Analysis Area Cover Type Acres

Cover Type DLH MM Total

Non-Vegetated

Barren (Right of Ways) 33 0 33

Non-Forest Communities

Grassland 60 0 60

Forest Communities

Ponderosa Pine* 4336 1924 6260

Dry Mixed Conifer 3118 838 3956

Wet Mixed Conifer 0 213 213

Aspen 22 0 22

Total Forested Acres: 7,476 2,975 10,451

Total Analysis Area Acres: 7,569 2,975 10,544

*Includes areas of Pine-Oak
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 13

Figure 7: Stratification of forested and non-forested lands within FWPP

Dry Lake 

Hills

7,569 acres

Forested 

Lands

7,475 acres

NonForested 

Lands

94 acres Northern 

Goshawk

Habitat

3,489 acres

Mexican Spotted 

Owl (MSO) 

Habitat

3,987 acres

Mormon 

Mountain

2,974 acres

Forested 

Lands

2,963 

acres

Non-Forested 

Lands

12 acres

Mexican Spotted 

Owl (MSO) 

Habitat

2,963 acres

Northern 

Goshawk

Habitat

0 acres

Ponderosa 

Pine & PineOak

847 acres

Mixed Conifer 

3,118 acres

Ponderosa 

Pine 

3,489 acres

Ponderosa 

Pine & PineOak

1,924 acres

Mixed Conifer

826 acres

Wet Mixed 

Conifer 

213 acres

Aspen 

22 acres
Chapter 1 – Purpose and Need

14 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Ponderosa Pine

The ponderosa pine forest vegetation community within the project occurs at elevations ranging 

from 7,000 to 9,200 feet. It is dominated by ponderosa pine and commonly includes other species 

such as oak, juniper. Species such as aspen, Douglas-fir, white fir, southwestern white pine 

(limber pine) and pinyon may also be present, but occur infrequently as small groups or 

individual trees. This forest vegetation community typically occurs with an understory of grasses 

and forbs, although it sometimes includes shrubs.

Historically, ponderosa pine forests of northern Arizona were characterized by frequent, lowintensity surface fires occurring every 2 to 12 years. The historic fire regime maintained an open 

canopy structure and a variable, patchy tree distribution across much of the forest by thinning 

smaller trees (Moir et al. 1997, Covington et al. 1997, Heinlein et al. 2005). 

Ponderosa pine commonly grows in pure stands and currently is found in even-aged6and unevenaged7

structural conditions across the area. The open park-like stands characteristic of the 

reference conditions for ponderosa pine forests promoted greater faunal diversity and fire 

resilience than the dense, closed-canopy stands of today. Ponderosa pine forests within the project 

are generally denser and more continuous than in reference conditions, and accumulations of 

forest litter and woody debris are much higher than would have occurred under the historic 

disturbance regime. 

Gambel Oak within Ponderosa Pine Forest

Gambel oak is frequently the only deciduous tree in otherwise pure southwestern ponderosa pine 

forests, adding diversity to these forests. A portion of the stands have a large enough component 

of Gambel oak to be considered pine-oak habitat for MSO (as described in the Forest Plan and 

MSO Recovery Plan). Similar to pure ponderosa pine forests, pine-Gambel oak forests have 

become altered since Euro-American settlement in the late 1800s, resulting in an overall increase 

in small- and medium sized Gambel oak stems and a more simplified forest structure (Abella 

2008). 

Understory Vegetation within Ponderosa Pine Forest

Herbaceous vegetation (grass and forbs) are a major understory associate within the ponderosa 

pine plant associations throughout the analysis area. Research at the Fort Valley Experimental 

Forest, located very near the project area, has shown that substantial declines in herbaceous 

vegetation diversity and growth have occurred over the past century due to increased tree density, 

increased canopy covers, and increased forest floor depth (Covington et al 1997). This trend 

indicates a shift away from a more diverse balance across a broad variety of understory plants to 

productivity dominated by pine trees. 

Woodland species with in the Ponderosa Pine Forest

On slopes with southern aspects, scattered groups and individuals of woodland species may be 

found within the ponderosa pine forests. Species include pinyon pine, alligator juniper, one-seed 

juniper, rocky mountain juniper, and Utah juniper. These species have increased in density and 

spread over a wider area since the advent of Euro-American settlement and the suppression 

wildfires. Management strategies for woodland species within this project would include 

 

6

Even-aged – pertaining to a stand composed of a single age class in which the tree ages are within + 20 percent 

variability based upon the mature stand age (SAF 1998).

7 Uneven-aged – pertaining to a stand with trees of three or more distinct age classes (SAF 1998).
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 15

conservation of all existing large or old individuals, maintaining a variety of growth forms,

managing for a range of densities and population locations. 

Dry and Wet Mixed Conifer

The mixed conifer vegetation communities within the project area occur from 7,200 to 9,200 feet 

elevation, and occur as two separate types, referred to in this report as “dry” and “wet.” Due to 

the frequent disturbance regime, historic dry mixed conifer forests were dominated by fire 

resistant, shade-intolerant conifer species such as ponderosa pine, southwestern white pine, and 

Douglas-fir. Historically shade-tolerant species were absent or present as a minor stand 

component on the drier sites such as ridge tops and southwest-facing slopes, with more abundant 

but still subdominant representation on cooler, wetter, north-facing slopes (Heinlen et al. 2005. 

Currently, dry mixed conifer forests within the project area are dominated by ponderosa pine, 

Douglas-fir, southwestern white pine, and white fir. Aspen is an early seral species and occurs 

frequently throughout the mixed conifer areas. Southwestern white pine does not occur in the 

Mormon Mountain portion of the project. Wet mixed conifer only occurs on the MM portion of 

the project are (a, and also includes white-fir, Douglas-fir, aspen, and maple. Dry mixed conifer 

types tend to be on lower north facing slopes or higher elevation south facing slopes and are more 

open than the wet types. The wet mixed conifer types typically occur at higher elevations and on 

north facing slopes. 

In dry and wet mixed conifer forests, habitat types are usually intermingled in relatively small 

areas, such as opposing aspects of the same hillside. The area of wet mixed conifer identified on 

Mormon Mountain is a contiguous 213 acre area. 

Historically the dry type experienced relatively frequent low to moderate intensity fire (every 2 to 

21 years) (Heinlen et al. 2005, Swetnam 1996), similar to ponderosa pine forests, and were 

typically uneven aged, growing in a patchy structure. In the wet types, fires were less frequent 

but generally of a higher intensity and severity, resulting in larger patches of homogeneous tree 

ages and higher patch density overall (Smith 2006, Margolis et. al. 2011). Wet mixed conifer 

vegetation types are found where historically fires occurred infrequently.

Dry mixed conifer forests within the project are generally denser and more continuous than in 

reference conditions, and accumulations of forest litter and woody debris are much higher than 

would have occurred under the historic disturbance regime. Lack of fire disturbance has led to 

increased tree density and fuel loads that increase the risk of uncharacteristically intense wildfire 

and drought-related mortality. When fires occur under current conditions, they tend to kill a lot of 

trees, including the large and old trees. These trees take longer to replace, moving the forest 

further from desired conditions, and increasing the time it would take to return to desired 

conditions. There is a high risk of insect and/or disease outbreak, which is also a function of 

increased tree density (see Forest Health Section).

Wet mixed conifer forest within the project, may or may not be highly departed from reference 

conditions. The wet mixed conifer forest in this project does not contain any Engelmann spruce 

or sub-alpine fire. Wet mixed conifer forests that contain those two species are considered to be 

high severity stand replacing fire regimes. The wet mixed conifer in this project contains White 

Fir, Douglas-fir, scattered Aspen patches and occasional ponderosa pine which indicates that the 

fire regime may be that of a more mixed severity than stand replacing.
Chapter 1 – Purpose and Need

16 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Aspen

An accelerated decline of aspen occurred across the project area following a frost event in June 

1999, a long-term drought that included an extremely dry and warm period from 2001 through 

2002, and bouts of defoliation by the western tent caterpillar in 2004, 2005, and 2007. Surveys 

across the Coconino National Forest have shown that aspen on low-elevation xeric sites (<7500 

ft) sustained 95 percent mortality since 2000. Mid-elevation sites (7500–8500 ft) lost 61 percent

of aspen stems during the same time period; mortality is expected to continue in these sites 

because some remaining trees have 70 to 90 percent crown dieback. 

Within the project area, quaking aspen is limited to small patches within a larger forest matrix 

dominated by ponderosa pine or mixed conifer vegetation (see Figure 55 in Chapter 3). These 

patches consist of a few overstory trees with a sapling understory component. There is one 22 

acre stand of pure aspen in the DLH which was created by post fire regeneration after the 1977 

Radio fire.

Aspen reproduces asexually through root suckers that are a clone of the original parent tree. Fire, 

insect, disease, wind and human disturbances regenerate this shade-intolerant species by opening 

up the canopy and removing conifers from the understory. Without disturbance, conifers 

gradually overtop aspen, closing the canopy and eventually killing mature trees and reducing 

regeneration. Aspen is highly susceptible to browsing and disease or death due to bark injuries. 

Aspen patches are regenerating successfully where livestock and wildlife are excluded by 

fencing. Several aspen patches within the project area show signs of decline marked by mortality 

and dieback of crowns, similar to what has been observed across Arizona over the past several 

years (Fairweather et al. 2008). 

Grasslands

Grasslands within the project area typically occur between 7,000 and 9,000 feet in elevation and 

are categorized as the productive Montane/Subalpine and the more arid Colorado Plateau/Great 

Basin. Approximately 60 acres within the analysis area are classified as grassland cover type 

based on stand data. A wide variety of species of grasses, forbs, shrubs and/or trees characterize 

their vegetation which varies according to soil type, soil moisture, and temperature. 

Historically, these grasslands had less than 10 percent tree cover. The grassland cover type has 

experienced some degree of conifer (ponderosa pine and mixed conifer) encroachment over the 

last 100 years as a result of fire exclusion and grazing use. Many of the pre-settlement trees that 

grew along the edges of these grasslands were removed historically. These edges as well as much 

of the interior of the grasslands have become stocked by sapling and young to mid-aged trees. 

These trees are growing rapidly due to the open growing conditions and a lack of competition. 

Old Growth

The old growth specifications for ponderosa pine, mixed conifer and aspen cover types can be 

found in the Forest Plan on pages 70-72. Table 6 shows the acres of existing old growth broken 

out by cover type and overall percent of each cover type that meets the current standard of 

existing old growth.
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 17

Table 6: Acres and percent of existing old growth by cover type and site potential located 

within FWPP. 

Project Area Cover Type Acres 

of 

Cover 

Type

Acres of 

Currently 

Allocated 

% Old 

Growth

Acres 

needed 

for 20%

Dry Lake Hills Interior Ponderosa 

Pine – High 4336 1183 27% 0

Mixed Species 

Group – High 

(Mixed Conifer)

3118 1450 47% 0

Aspen 22 0 0% 4

Mormon 

Mountain

Interior Ponderosa 

Pine – High 1924 53 3% 332

Mixed Species 

Group – High 

(Mixed Conifer)

1051 561 53% 0

According to the Forest Plan, old-growth forest should also be analyzed at multiple scales – one 

scale above and one scale below the ecosystem management areas. The three scales used to 

analyze old-growth for this project include:

Small scale – Individual stands were evaluated for existing old growth conditions and or 

suitability for managing towards old growth conditions. 

Mid-scale - the ecosystem management area level. EMA was chosen due to Forest Plan 

direction.

Large scale - across the Coconino National Forest.

This analysis only looks at the forest types that occur and would be managed in this project. They 

include ponderosa pine, mixed conifer, and aspen. More information about the old growth 

analysis scales and existing conditions can be found in the Silviculture Specialist Report, located 

in the project record. 

Forest Health

For the purposes of this analysis, forest health is defined by the vigor and condition of the forest 

stands and the presence of insects and disease that affect the sustainability of the forest. A 

working definition of a healthy forest is a forest where:

Native insect and disease activity is within the historic range of variability, and nonnative insects/diseases are absent or incidental; 

Stand densities are at levels that facilitate overall forest development, tree vigor, and 

resilience to characteristic disturbances;

Forest structure represents all age classes necessary for a sustainable balance of 

regeneration, growth, mortality and decomposition;

Overall these conditions are resilient to natural biotic and abiotic disturbances (e.g., fire, 

insects, diseases, and wind).
Chapter 1 – Purpose and Need

18 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Southwestern ecosystems have evolved under a long and complex history of climate variability 

and change. Taking into consideration the number of mega-droughts and other climate-related 

variation through time, southwestern systems have some built-in resilience. Risks of increased 

wildfire, insects and disease outbreaks, and invasive species represent ongoing, broad-scale 

management challenges. These issues are not new. However, climate change has the potential to 

increase and exacerbate the impacts of these ecosystem risks.

Based on current projections, the primary regional-level effects of climate change most likely to 

occur in the Southwest that would have an effect on forest vegetation include warmer 

temperatures, decreasing precipitation, and increased extreme weather events. These changes 

could result in immediate vegetation disturbance due to wind or flooding, increased wildfire risks, 

increased outbreaks of insects, diseases, and spread of invasive species, increased drought related 

mortality and changes in plant species composition. It is predicted by climate models that the 

average forest drought stress by the 2050s will exceed that of the most severe droughts in the past 

1000 years (Williams et al. 2012). 

Aspen Mortality

According to the 2008 Fairweather et al. report, aspen on the Coconino National Forest have been 

in decline over the past decade. Several insects and pathogens were associated with aspen 

mortality but appeared to be acting as secondary agents on stressed trees. Aspen regeneration 

occurred to some degree on all the sites studied following the death of mature trees, although 

aspen sprouts were nearly nonexistent by the summer of 2007. This loss of spouts was attributed 

to browsing by elk and deer as none of the sites studied were grazed currently by domestic cattle. 

Widespread mortality of mature aspen trees, chronic browsing by ungulates, and advanced 

conifer reproduction is expected to result in rapid vegetation change of many ecologically unique 

and important sites (Fairweather et. al. 2008). The annual Forest Health Protection aerial survey 

conducted in 2010 (USDA FS 2011) indicated a continuation of the mortality trend within the 

project area.

Bark Beetles

An outbreak of bark beetles, starting in 2002 to 2003, resulted in widespread mortality across 

Arizona, including mortality in the project area. The outbreak was primarily the result of several 

native bark beetle species responding to the weakened condition of moisture-stressed, overcrowded forests. Trees on stress-prone sites were most affected. A decrease in affected acres 

began to occur in 2007 (USDA FS 2008). 

The annual aerial surveys on the Coconino National Forest in the summer of 2012 detected 

mortality associated with bark beetles on approximately 520 acres of ponderosa pine and mixed 

conifer within the project area. This mortality is most likely associated with the ips beetle and 

western pine beetle. The previous year’s survey (2011) showed only six acres of mortality within 

the project area. 

Research in the West clearly shows that when trees are stressed from overstocking they are more 

susceptible to bark beetle attack (DeMars and Roettgering 1982, Schmid and Mata 1992, Schmid 

et al. 1994, Chojnacky et al. 2000, Negrón et al. 2000,). During the recent landscape-level bark 

beetle outbreak in Arizona, elevation and tree density were significant variables for estimating the 

probability of occurrence of mortality in ponderosa pine stands on several forests (Negrón et al. 

2009). Dwarf mistletoe infection also appears to influence attack patterns of bark beetles on 

ponderosa pine during drought events (Kenaley et al. 2006, 2008).
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 19

A general bark beetle hazard model for southwestern ponderosa pine based exclusively on the tree 

density relationships developed in the Dendroctonus hazard model by Munson and Anhold 1995 

(as documented in Chojnacky et al. 2000) and the draft Ips hazard model developed by McMillin 

et al. (2011) indicates that stands of ponderosa pine within the project area with a relative density 

below 30 percent of SDImax have a low hazard rating and stands between 30 and 40 percent of 

SDImax have a moderate hazard rating. Using these relative density thresholds, approximately 11 

percent of the DLH analysis area has a low bark beetle hazard rating, while 13 percent of the area 

has a moderate rating and the remaining 76 percent has a high hazard of beetle attack (Table 7).

For the MM area, approximately 3 percent is rated at low hazard and the remaining 97 percent is 

rated as high hazard for bark beetle mortality.

Table 7: Existing Ponderosa Pine Beetle Hazard Rating (Percent of stands in each Project 

Area)

Cover Type Hazard 

Rating

Dry Lake 

Hills

Mormon 

Mountain

Pine Low 11% 3%

Pine Moderate 13% 0%

Pine High 76% 97%

Mixed Conifer Low 0% 27%

Mixed Conifer Moderate 5% 0%

Mixed Conifer High 95% 73%

Dwarf Mistletoe

Dwarf mistletoes are the most widespread and damaging forest pathogens (disease-causing 

organisms) in the Southwest. Damage from dwarf mistletoes includes growth reduction,

deformity—especially the characteristic witches’ brooms, and decreased longevity. Infected areas 

often have much higher mortality rates than uninfected areas. Infection is often a major factor in 

mortality attributed to other damaging agents. For example, severely infected trees are often 

attacked by bark beetles (USDA Forest Service 2011).

Southwestern dwarf mistletoe infection in ponderosa pine is common throughout the ponderosa 

pine analysis area. On both the stand and landscape level, the distribution of dwarf mistletoes is 

usually patchy, with more or less discrete infection centers surrounded by areas without the 

disease. Infection centers expand very slowly, so overall incidence changes little from year to 

year (USDA Forest Service 2011). 

Table 8 displays ponderosa pine dwarf mistletoe infection in terms of area by infection level for 

both ponderosa pine and mixed conifer. Within the mixed conifer, ponderosa pine and Doulas-fir 

are the two predominate tree species infected with mistletoe. The area with the highest level of 

infection is within the ponderosa pine in the DLH. Approximately 37 percent of the area is either

not infected or has a low infection level. Thirty four percent of the area is moderately or heavily 

infected. The remaining 29 percent is severely infected. 
Chapter 1 – Purpose and Need

20 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 8: EC - Dwarf Mistletoe Infection Level of ponderosa pine and mixed conifer within

FWPP

Cover 

Type

Infection Level Dry Lake Hills Mormon Mountain

Pine None/Low Percent of Area 37% 69%

Pine Moderate/High Percent of Area 34% 31%

Pine Severe Percent of Area 29% 0%

Mixed 

Conifer

None/Low Percent of Area

80% 91%

Mixed 

Conifer

Moderate/High Percent of Area

20% 9%

Mixed 

Conifer

Severe Percent of Area

0% 0%

Desired Conditions

Supporting Science

The project desired conditions have been developed based upon the project Purpose and Need and 

Forest Plan direction for forest vegetation management. Current best available science was used 

for analysis of conditions necessary to meet the project Purpose and Need. Science relative to 

historic reference conditions has informed this process.

The Desired Conditions for ponderosa pine forests incorporated information on the ecology of the 

overstory and understory vegetation comprising this type as well as information on its historic or 

natural range of variability in the composition, structure and pattern of vegetation. 

Restoring southwestern ponderosa pine forests revolves around reintroducing a regime of 

frequent, low-intensity fires like those that historically maintained forest structure and function 

(Friederici 2004). Restoration treatments that include prescribed burning, often preceded by 

thinning to reduce fuel loads, have the potential to improve the ecological health of these forests. 

In order to wisely set the goals that underlie these treatments, it is useful for us to know as much 

as possible about past forest conditions, especially the “reference conditions” that existed before 

forest structure and function were altered by Euro-American settlers. Such conditions were not 

unchanging, but they sustained themselves across what has been called a “natural range of 

variability” (Friederici 2004).

The natural range of variability (NRV) specific to the Flagstaff Watershed Protection Project area 

comes from early written records, general land office surveys, Forest Service records, oral 

histories, and photographs as well as old forest remnants, physical remains of old trees and 

dendrochronology. For example, Cooper (1960) researched the cultural evidence to document the 

historic condition of southwestern pine forests. Many early travelers, surveyors and government 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 21

officials left records of their impressions of pine forest country specific to the project area. The 

19th century descriptions of ponderosa pine forest conditions by the likes of Lt. Edward Beale, 

Lt. Ives, C. Hart Merriam, J.B. Lieberg, S.J. Holsinger could be summarized as follows: “The 

forest was decidedly open and park like; reproduction was not abundant, and in many areas was 

markedly deficient; grass was abundant but not universal” (Cooper 1960). Other documentation 

that has informed our current understanding of the NRV includes plot data by early scientists 

(Woolsey 1911, Pearson 1950), tree ring, dendrochronological, and restoration studies (Covington 

and Moore 1994, Swetnam and Baisan 1996, Covington et al. 1997), natural area and old growth 

studies (White 1985), and wildland fuel management strategies (Pearson 1950, and Fule et al. 

1997). The following is a NRV description based on these and many other references.

Natural Range of Variability

All southwestern forests and woodlands are periodically affected by natural disturbances such as 

fire, insects, disease, wind, and herbivory (Mast et al. 1998 and 1999, Brown et al. 2001, Ehle and 

Baker 2003). These disturbances have variable effects on forest vegetation depending on the type, 

frequency, intensity, and spatial scale of disturbances. The type, frequency, and intensity of 

disturbances varied historically among forest and woodland types. A forest or woodland's 

characteristic composition, structure, and landscape pattern, the result of vegetation 

establishment, growth, and succession, combined with the periodic resetting of these by 

characteristic natural disturbances, constitutes a forest or woodland's natural range of variability. 

The temporal and spatial variability in vegetation establishment, growth, and mortality, and the 

consequences of natural disturbances in a forest or woodland define the natural range of 

variability. Much of the range of variability stems from fine- to landscape scale heterogeneity in 

aspect, slope, elevation, and soils that can lead to topographically different growing conditions 

and disturbance regimes (Fule et al. 2003). The ability of a forest ecosystem to absorb and 

recover from disturbances without drastic alteration of its inherent function is central to the 

concept of natural range of variability. In the southwestern United States, fire is a primary 

disturbance agent and fire regimes are central to understanding natural range of variability as it 

relates to the composition, structure, and pattern in various forest types (Fule et al. 2003).

Species Composition

In this type, ponderosa pine is the dominant seral and climax tree species, but depending on locale 

may mix with gamble oak, several juniper and pinyon species, quaking aspen, Douglas-fir, limber 

pine, white fir, or white pine (USDA 1997). Composition of the grass/forb/shrub understory is 

typically diverse in ponderosa pine forests, especially when canopy openings are present (Moir 

1966, Naumburg and Dewald 1999, Laughlin et al. 2006, Abella et al. 2011). Presence of shrubs 

is variable depending on habitat type and locale (USDA 1997). While grasses and herbs occur in 

most ponderosa pine types (USDA 1997), the composition, abundance (cover), and productivity 

is variable depending on soil, aspect, elevation, latitude, moisture, and the presence or absence of 

tree cover (Moir 1966, Naumburg and Dewald 1999, Laughlin et al. 2006, Abella et al. 2011).

Tree Density and Distribution

Historical tree densities on reconstructed plots throughout the Southwest varied depending on 

factors such as elevation, aspect, slope, soils, moisture, and a site's unique history. An example of 

this was a reconstruction study involving 53 2.5-acre plots representing nine different ponderosa 

pine ecosystem types near Flagstaff, Arizona. Historical tree densities on these sites varied 19-

fold, and averaged between 2 -40 trees per acre (Abella and Denton 2009). Moore's et al. (2004) 

reconstruction study on their 15 2.5 acre Woolsey plots estimated a mean density of 40 trees per 

acre based on live tree and cut-stump BA (Moore et al. 2004). On the same Woolsey plots, 
Chapter 1 – Purpose and Need

22 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Sanchez Meador et al. (2010) found that the number of tree groups ranged from 4-11 per acre and 

ranged in size from 0.004 ac to 0.06 acre. Other reports of historical tree densities include 22 trees 

per acre near Walnut Canyon (Menzel and Covington 1990), 23 trees per acre at Bar-M-Canyon 

(Covington and Moore 1994), 24 trees per acre on the Gus Pearson Natural Area (GPNA) on the 

Fort Valley Experimental Forest (Mast et al. 1999), and 24 trees per acre at Camp Navajo (Fule 

etal. 1997). A 1938 forest inventory on the long Valley Experimental Forest (central Arizona) 

showed that 75 trees per acre were present prior to the cessation of frequent fire (between 1880 

and 1900). Woolsey (1911) reported an average of 18 trees per acre (> 4 inches dbh) in northern 

Arizona in the early 20th century. Typical historical tree groups ranged from 0.1 to 0.75 acres in 

size and comprised 2 to 40+ trees per group (White 1985, Fule et al. 2003, Covington et al. 1997). 

Restoration studies on the Fort Valley Experimental Forest near Flagstaff, Arizona, showed an 

average of 23 trees per acre that were grouped into distinct 0.05- to 0.7-acre groups consisting of 

2-40 trees (Covington et al. 1997).

Structural characteristics widely reported for historical Southwest ponderosa pine are relatively 

open forests with trees typically aggregated in small groups within a grass/forb/shrub matrix 

(Cooper 1960, White 1985, Pearson 1950, Covington et a1.1997, Abella and Denton 2009). 

Recent work in northern Arizona has shown that tree densities across nine different ponderosa 

pine ecosystems depended to a large extent on soil type and climatic variables such as minimum 

spring and fall temperatures, and May precipitation (Abella and Denton 2009). This work also 

showed that the degree to which trees were aggregated into groups was largely explained by 

ecosystem soil type. Twenty-eight to 74 percent of all trees were in groups; the remaining trees 

were scattered individuals (Abella and Denton 2009). These structural conditions were 

maintained by frequent low-intensity surface fires that more often killed small rather than large 

trees (Weaver 1951, Fiedler et al. 1996, Cooper 1960). Other small-scale disturbances such as 

insects, disease and others also shaped this characteristic forest structure. Low intensity fires 

occurred every 2 to 12 years and maintained an open canopy structure (Covington et al. 1997, 

Moir et al. 1997). The grass/forb/shrub understory and fine fuels (needles, cones, limbs) from 

large trees fueled these frequent fires started by lightning and, to an uncertain extent by Native 

Americans (Kaye and Swetnam 1999, Allen et al. 2002). Regular fire thinned or eliminated 

thickets of small trees, resulting in open, park-like forests (Cooper 1960, Covington et al. 1997, 

Allen et al. 2002). 

While the ponderosa pine forest of northern Arizona have been widely studied and researched, the 

mixed conifer forest within northern Arizona have not been as widely studied or researched. 

However there are a growing number of studies within the mixed conifer forest across the 

southwest Colorado Plateau that provide historic reference conditions. The studies show a much 

wider variation in historic mixed conifer forest conditions compared to ponderosa pine. The two 

most relevant studies to this project were conducted on the San Francisco Peaks (Heinlein et. al. 

2005 and Cocke et. al. 2005). The Heinlein study looked at two studies on the San Francisco 

Peaks between 7800 and 8800 feet. The study shows that the historical mixed conifer stands 

were dominated by ponderosa pine and tree densities averaged 21 trees per acre. The Cocke 

study also took place on the San Francisco Peaks between 8000 and 11700 feet; the mixed conifer 

portion of the study found historical conditions of 65 trees per acre. 

Forest Openings and the Grass/Forb/Shrub Vegetation Matrix

Woolsey (1911) described late 19th century southwestern ponderosa pine forests as follows: "The 

typical western yellow (ponderosa) pine forest of the Southwest is a pure park-like stand(s) made 

up of scattered groups of from 2 to 20 trees, usually connected by scattering individual. Openings 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 23

are frequent and vary in size. Because of the open character of the stand and the fire-resisting 

bark, often 3 inches thick, the actual loss in yellow (ponderosa) pine by fire is less than with 

other, more gregarious species." 

Others also described historical ponderosa pine forests as having low tree density, open, savannalike stands consisting of groups of pine trees interspersed with grassy or shrubby openings (White 

1985). The actual degree of "openness" has received little measurement; instead, most 

reconstruction/restoration studies focused on tree densities and tree aggregation. Although White 

(1985) did not define how close trees had to be to constitute a "group" (he used the absence of 

1919 regeneration beneath large tree crowns to define groups), he reported 22 percent of his plot 

on the GPNA was under tree groups. Thus, 78 percent of the 18 acre area would likely have been 

open before the 1919 regeneration pulse (White 1985). White (1985) reported that 12 percent of 

the historical trees on his plot were not in groups of three trees; if he had included single trees and 

groups of 2 trees, the percent open would have been less than 78 percent. Covington et al. (1997), 

also working on the GPNA, reported that while canopy cover was high within groups of trees, 

only 19 percent of the surface area of their study plot was under pine canopy; the balance (81 

percent) represented grassy openings (Covington et al. 1997). Where crown cover was not 

reported, Gill’s et al. (2000) mean crown radius for mature ponderosa pine (19.7 feet) can be used 

to estimate area under crowns. Of the 53 study plots in Abella and Denton (2009), those with only 

two trees had less than 2 percent under tree crown (98 percent open). At the opposite extreme, a 

plot with 40-trees had an estimated 28 percent under crowns (72 percent open). Using the same 

approach on the Long Valley Experiment Forest, for the 75 trees present before the cessation of 

fire (about 1900) resulted in about 52 percent of the per acre area under tree crowns (48 percent 

open). Sanchez Meador (Sanchez Meador et al. 2011 found a similar range between 10 and 30 

percent on reconstructed Woolsey plots located throughout Arizona and New Mexico.

Sustainability and Resilience 

Knowledge of the historical forest composition and structure on a site can provide estimates of 

forest composition, structure and pattern that was resilient to disturbance agents (insects, fire) and 

sustainable through at least several generations of trees (Allen et al. 2002, Abella et al. 2011). It 

may not be necessary, or even desirable in some cases, to have desired conditions that are within 

the natural range of variability at every site in southwestern forests and woodlands. However, 

historical conditions are more synchronous with the natural disturbance regime to which the 

forest and woodland ecosystems are adapted. Social, political and economic factors are much 

different today than a century ago and there are valid considerations for leaving areas of higher or 

lower tree-density or differing composition to meet resource management needs. But restoration 

on some portion of the landscape to conditions reminiscent of pre-European settlement times 

would most likely provide for greater biodiversity, and greater ecosystem productivity, stability, 

sustainability, and services.

General

A variety of forest conditions (composition, structure and pattern) would exist across the 

landscape, comparable to historic conditions. Forested landscapes would be diverse with groups 

and patches of variable tree densities, including groups with dense, closed canopies (interlocking 

crowns) and small areas of scattered individual trees; well shaded soil beneath tree groups; dead, 

deformed and diseased trees; large logs and woody debris; and old, large oaks, junipers and 

aspen. Canopy openings within the forest would be common and support a diverse species

composition and productive grass/forb/shrub community. Forest habitats would contain a forest 
Chapter 1 – Purpose and Need

24 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

overstory dominated by ponderosa pine, mixed where appropriate with pinyon and juniper 

species, oaks, aspen, Douglas fir, limber pine or white fir. Large old alligator junipers would 

continue to exist where they currently occur. 

Overall, the project area would be comprised of forest conditions that are resilient to disturbance 

(insects, disease, fire, climate change) and sustainable through at least several generations of 

trees. Forest habitats would generally be vigorous, with endemic levels of native insect and 

disease occurrences. Dwarf mistletoe would be an element of the forest landscape. There would 

be a varied level of mistletoe across the landscape, comparable to historic conditions. Forest 

structure and density would impede spread and reduces impacts associated with infection.

Desired stand dwarf mistletoe infection levels would not exceed 20 percent infection of the host 

species (trees per acre basis), or 25 percent of the area infected for any given tree species

(Conklin and Fairweather 2010). Dwarf mistletoe infections would be irregularly distributed 

among tree groups, such that effects are limited to the forest group and patch scale.

The ponderosa pine and dry mixed conifer forest would contain uneven-aged stands composed of 

a distribution of age classes that comprise a sustainable balance of structural stages. Old trees and 

old forest structure would be sustained over time across the landscape. In dry mixed conifer areas 

outside of MSO PACs and nest roost recovery habitats, basal areas would average less than 80 

ft2/acre. In wet mixed conifer areas, forests would be uneven-aged, with diverse species 

composition is maintained by large and small scale disturbances, and early seral species would be

well represented.

Fully stocked, healthy forest conditions would facilitate capacity to store carbon and minimize 

tree losses to wildfires, insects, and diseases. Forests within the project area would provide a 

sustainable supply of diverse uses and values while contributing to the stabilization of carbon 

released into the atmosphere.

Ponderosa Pine

Ponderosa Pine Goshawk Habitat Restoration within LOPFA Areas*

Desired future conditions include increased diversity in age and size classes, uneven-aged stand 

structure, and improved successional dynamics. Distribution of vegetative structural stages (VSS) 

is: 10 percent grass/forb/shrub (VSS 1), 10 percent seedling-sapling (VSS 2), 20 percent young 

forest (VSS 3), 20 percent mid-aged forest (VSS 4), 20 percent mature forest (VSS 5), and 20

percent old forest (VSS 6).

Desired future conditions for the LOPFA areas include groups of 2 to 40 trees ranging in size 

from 0.1 acre to .7 acre, with openings between groups. Canopy cover within VSS 4-5-6 groups 

would vary from 40 percent to 70 percent. At the group level, basal areas would average 50 ft2 

per acre or greater in VSS 4, 5 and 6 groups. Stand density indices would be below 35 percent of 

SDImax over the majority of the area. 

All yellow pines would be retained. All snags greater than 12 inches diameter would be retained, 

3 downed logs greater than 12 inches diameter and at least 8 ft long, and 5-7 tons of woody debris 

greater than 3 inches in diameter would be retained per acre. Regeneration openings from 0.1 to 

4 acres would be created across 20 percent of each stand. Regeneration openings up to 4 acres 

with a maximum width of 200 feet may be created; however openings should rarely be greater 

than two acres and the average opening size is approximately one acre. Regeneration openings 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 25

would comprise up to 20 percent of each stand. Three to five trees per acres would remain in 

openings greater than one acre. 

Ponderosa Pine Restoration within Northern Goshawk Post Fledging Areas (PFA) 

Desired future conditions include increased diversity in age and size classes, uneven-aged stand 

structure, and improved successional dynamics. Distribution of vegetative structural stages (VSS) 

is: 10 percent grass/forb/shrub (VSS 1), 10 percent seedling-sapling (VSS 2), 20 percent young 

forest (VSS 3), 20 percent mid-aged forest (VSS 4), 20 percent mature forest (VSS 5), and 20

percent old forest (VSS 6). Tree groups in VSS 4 would average 1/3 60 percent and 2/3 50

percent canopy cover. 

Desired future conditions for PFAs include groups of 2 to 40 trees ranging in size from 0.1 acre to 

.7 acre, with openings between groups. Canopy cover within VSS 4-5-6 groups would vary from 

40 percent to 70 percent. At the group level, basal areas would average 70 ft2 per acre or greater 

in VSS 4, 5 and 6 groups. Stand density indices would be below 35 percent of SDI max over the 

majority of the area. 

All yellow pines would be retained except where necessary for harvesting operations (e.g. in 

cable logging corridors). All snags greater than 12 inches diameter would be retained, 3 downed 

logs greater than 12 inches diameter and at least 8 ft long, and 5-7 tons of woody debris greater 

than 3 inches in diameter would be retained per acre. Regeneration openings up to 2 acres with a 

maximum width of 200 feet may be created; however openings should rarely be greater than two 

acres and the average opening size is approximately one acre. Regeneration openings to establish 

new or release existing VSS 1 and 2 would comprise up to 20 percent of each stand. Three to 

five trees per acres would be retained in openings greater than one acre. 

Ponderosa Pine Restoration within Northern Goshawk Post Fledging Nest Areas

Desired future conditions include mature to old age trees with high canopy cover. Canopy cover 

averages approximately 60 percent across VSS 4, 5 and 6 tree groups. All snags greater than 12 

inches diameter would be retained, 3 downed logs greater than 12 inches diameter and at least 8 ft 

long, and 5-7 tons of woody debris greater than 3 inches in diameter would be retained per acre. 

No openings would be created and treatments would emphasize retention of large trees. Retain 

and promote large trees. Within the northern goshawk nest area, desired future conditions include 

non-uniform tree spacing and increased tree growth to progress VSS 4 to VSS 5 and 6. 

Canopy cover was assessed at the stand level to meet the Forest plan standards and guidelines; 

Forest Plan standards for canopy cover apply to VSS 4, 5, and 6 within ponderosa pine. Canopy 

cover is averaged across the stand. Standards vary within and outside of northern goshawk PFAs 

and within goshawk nesting areas. 

Ponderosa Pine within MSO Protected Activity Centers (PACs)

Desired future conditions for stands of ponderosa pine inside MSO PACs is to achieve old growth 

structural attributes as specified in the revised MSO Recovery Plan (USDI FWS 2012) and to 

reduce the risk of high intensity wildfire from burning up the PAC by reducing the fuels hazard. 

The desired conditions listed in the recovery plan call for a diversity of patch sizes with a 

minimum patch size of 2.5 acres, horizontal and vertical heterogeneity within patches, maintain 

or increase species diversity, create openings up to 2.5 acres in size, maintain canopy cover of 40

percent, and maintain 50 percent of basal area in trees greater than 16 inches dbh. Treatments 
Chapter 1 – Purpose and Need

26 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

would retain all trees greater than 18 inches dbh, woody debris larger than 12 inches in diameter,

retain all snags, and all hard wood trees. 

Forest Structure 

Desired future conditions within the ponderosa pine cover types include: a more “open” forest 

structure that is sustainable, uneven-aged, and within the historic range of natural variability. 

Trees would be arranged primarily in “groups” of varying shape, size, and number of trees, with a 

mosaic pattern of individual and clustered trees interspersed among openings. The project area 

would exhibit an increase in age class diversity, decreased canopy cover, improved successional 

dynamics, increased and unsuppressed regeneration, increased old-growth forest, and increased 

vertical and horizontal heterogeneity (within stands and across the project area) compared to 

existing conditions.

Mixed Conifer

Dry Mixed Conifer Restoration 

Desired future conditions within the conifer cover types include: a more “open” forest structure 

that is sustainable, uneven-aged, and within the historic range of natural variability. Trees would 

be arranged primarily in “groups” of varying shape, size, and number of trees, with a mosaic 

pattern of individual and clustered trees interspersed among openings. The project area would 

maintain age class diversity, decrease canopy cover, improve successional dynamics, increase 

unsuppressed regeneration, increase old-growth forest, and maintain or increase vertical and 

horizontal heterogeneity. 

Regeneration openings up to 2 acres with a maximum width of 200 feet may be created; however 

openings are rarely greater than two acres and the average opening size is approximately one 

acre. Three to five trees per acres would be retained in openings greater than one acre. 

All yellow pines and mixed conifer trees with fire scars would be retained. All snags greater than 

18 inches diameter would be retained, 5 down logs greater than 12 inches diameter and at least 8 

ft long, and 10-15 tons of woody debris greater than 3 inches in diameter would be retained per 

acre. 

Dry Mixed Conifer within MSO Protected Activity Centers

Desired future conditions for stands of mixed conifer inside MSO PACs is to achieve old growth 

structural attributes as specified in the revised MSO Recovery Plan and to reduce the risk of high 

intensity wildfire from burning up the PAC by reducing the fuels hazard. The desired conditions 

listed in the recovery plan call for a diversity of patch sizes with a minimum patch size of 2.5 

acres, horizontal and vertical heterogeneity within patches, maintain or increase species diversity, 

create openings up to 2.5 acres in size, maintain canopy cover of 60 percent, and maintain 50

percent of basal area in trees greater than 16 inches DBH. Treatments would retain trees greater 

than 18 inches dbh, yellow pines, mixed conifer trees with fire scars, snags greater than 18 inches, 

down logs greater than 12 inches mid-point diameter, and large hardwoods.

Exceptions would be made in the cable yarding treatment units for the cutting of large trees, and 

oaks to create cable corridors and falling of snags for safety purposes, and within the helicopter 

harvest units for the falling of snags for safety purposes. 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 27

Wet Mixed Conifer within MSO Protected Activity Centers

Desired future conditions for wet mixed conifer is to maintain a sustainable uneven-age structure 

perpetuated by small scale natural disturbance events. Effects from a wildfire would be moderate 

with mixed severity burns. The percentage of area in early seral stages is well represented. 

Small openings allow for the establishment of early seral species, such as aspen, pine, and 

Douglas-fir across the forest type. Large hardwoods, oak and maple, are maintained and are 

successfully regenerating.

Dry Mixed Conifer MSO Recovery Habitat

Within MSO recovery habitat, desired conditions include treatments that mimic natural 

disturbance patterns by incorporating natural variation, such as irregular tree spacing and various 

patch sizes. Stand structure should be uneven-aged. Treatments would emphasize the retention of

trees greater than 24 inches dbh, yellow pines, mixed conifer trees with fire scars, snags greater 

than 18 inches, down logs greater than 12 inches mid-point diameter, and large hardwoods.

Dry Mixed Conifer MSO Nest Roost Recovery Habitat

Within MSO recovery habitat, desired conditions include a minimum average basal area of 120 

ft2 per acre. Trees from 12-18 inches dbh would comprise thirty percent of stand basal area and 

an additional 30 percent of basal area would come from trees greater than 18 inches dbh. The 

desired conditions for nest roost recovery also call for a diversity of patch sizes with a minimum 

patch size of 2.5 acres, horizontal and vertical heterogeneity within patches, maintain or increase 

species diversity, create openings up to 2.5 acres in size, maintain canopy cover of 60 percent. 

Desired conditions include treatments that mimic natural disturbance patterns by incorporating 

natural variation, such as irregular tree spacing and various patch sizes. Stand structure should be 

uneven-aged. Treatments would not remove trees greater than 18 inches dbh, yellow pines, 

mixed conifer trees with fire scars, snags greater than 18 inches, down logs greater than 12 inches 

mid-point diameter, and large hardwoods.

Aspen

Desired future conditions within the aspen cover type include: retention of aspen across in 

existing stands, increased regeneration, protection of regeneration from ungulate browsing, 

decreased conifer density and competition within aspen clones, and improved health, vigor, 

longevity, and sustainability of aspen clones. 

Grasslands

The desired condition for mountain grasslands is to be relatively free of conifer encroachment, 

and to maintain a healthy and vigorous herbaceous production that allows for periodic and regular 

fire return intervals, which would also prevent conifer encroachment.

Old Growth

Desired conditions for old growth are to allocate a minimum of 20 percent of the forested 

landscape for managing toward old-growth conditions. Desired conditions for all stands of 

ponderosa pine and mixed conifer which fall inside designated MSO PACs, and in northern 

goshawk nest areas is to achieve old growth structural attributes as specified in the Forest Plan.
Chapter 1 – Purpose and Need

28 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Forest Health 

Desired future conditions across the project area include improved tree health and vigor, 

improved forest health, and a sustainable forest structure that is more resilient to high-severity 

wildfire, insects and diseases. 

Dwarf mistletoe is an element of the forest landscape. There is a varied level of mistletoe across 

the landscape, comparable with historic conditions such that it does not impede achieving and 

sustaining desired uneven-aged forest conditions. Desired stand dwarf mistletoe infection levels

do not exceed 20 percent infection of the host species (trees per acre basis), or 25 percent of the 

area infected for any given tree species (Conklin and Fairweather 2010). Dwarf mistletoe 

infections are irregularly distributed among tree groups, such that effects are limited to the forest 

group and patch scale.

Desired future conditions for understory vegetation include increased diversity, productivity, and 

abundance of understory species. 

Need for Change

Ponderosa Pine

In general across northern goshawk habitat, there is a need to decrease canopy cover and create a 

more variable and patchy tree distribution. There is a need to decrease the percent of the project 

area in “closed” canopy conditions within VSS 3, 4, 5, and 6 groups. There is also a need to 

create a more variable, patchy tree distribution across the project area. There is a need to decrease 

stand densities in the majority of the ponderosa pine and mixed conifer forest within the project 

area. There is a need to reduce tree densities across northern goshawk nest areas and create nonuniform tree spacing.

Dry Mixed Conifer

There is a need to reduce overall stand density in the majority of mixed conifer stands. There is a 

need to reduce the threat of high intensity wildfire in mixed conifer stands within the MSO PACs. 

There is a need to reduce fire hazard to “low” or “moderate” and to create conditions conducive 

to the reintroduction of low-intensity prescribed fire. There is a need to create a leave tree 

arrangement that would result in decreased inter-tree competition, increased tree health and vigor, 

reduced fire hazard, and increased size class diversity

There is a need to reduce canopy cover on the 76 percent of mixed conifer areas where canopy 

cover exceeds 60 percent. There is a need to reduce SDI in mixed conifer areas where SDI is 

greater than 35 percent of max SDI. Three is a need to reintroduce periodic low intensity fires. 

Wet Mixed Conifer

There is a need to minimize the amount of high burn severity that would occur if the wet mixed 

conifer areas were to burn in a wildfire. There is a need to reduce the current fuel loading. There 

is a need to increase the percentage of early seral species the wet mixed conifer by creating 

openings across 10 percent of the area. There is a need to protect aspen and maple regeneration 

from ungulate browsing by jackstrawing or fencing.
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 29

Aspen

There is a need for increased regeneration, protection of regeneration from ungulate browsing, 

decreased conifer density and competition within aspen clones, and improved health, vigor, 

longevity, and sustainability of aspen clones. There is a need to remove conifer encroachment 

across 22 acres of identified aspen stands and within pockets of aspen that occur within

ponderosa pine and mixed conifer stands. There is a need to protect aspen regeneration from 

ungulate browse by either jackstrawing or fencing.

Grasslands

There is a need to restore identified mountain grasslands. There is a need to remove 

encroachment to the known historic extent and to restore frequent fire return interval. 

Vegetative Structural Stage (VSS)

The desired VSS distribution for the northern goshawk according to the Forest Plan, in 

comparison with existing conditions and the resultant gap, is displayed in Table 9. VSS 

guidelines apply only to pine stands located outside of MSO habitat. In order to obtain desired 

future conditions, there is a need to decrease the proportion of the ponderosa pine in young and 

mid-aged forest by approximately 43 percent. VSS 1 and 2 are severely lacking across the 

project area or occur in small amounts. Thus, there is a need to create up to 20 percent openings 

across the forested ponderosa pine stands within the project area to increase and promote existing

natural regeneration, thereby increasing VSS1 and VSS2. Additionally, there is a need to 

increase the proportion of the project area in mature to old forest by approximately 22 percent. 

Currently approximately 100 percent of goshawk nest areas within the ponderosa pine are VSS 4. 

There is a need to manage nest stands to help move the nests stands to the desired VSS 5 and 6 

classes. 

Table 9: Desired Vegetative Structural Stage (VSS) distribution for the northern goshawk, 

according to the Forest Plan, for DLH (ponderosa pine)

VSS DISTRIBUTION VSS 1 VSS 2 VSS 3 VSS 4 VSS 5 VSS 6

DESIRED FUTURE 

CONDITIONS 10% 10% 20% 20% 20% 20%

EXISTING 

CONDITIONS: 0 0 39 44 7 11

NEED FOR CHANGE +10% +10% -19% -24% +13% +9%

Old Growth

There is a need to increase the amount of area allocated to be managed toward old-growth desired 

conditions in the ponderosa pine cover type forest in the MM area by a minimum of 332 acres. 

There is a need to designate and manage to develop old growth all stands within MSO PACs and 

goshawk nest stands that do not currently meet existing old growth conditions. Those stands 

would need to be managed to achieve old growth conditions over the long term. 

Forest Health 

There is a need to decrease stand densities below critical thresholds for increased risk of bark 

beetle attack and mortality. There is a need to reduce fire hazard to “low” or “moderate” and to 
Chapter 1 – Purpose and Need

30 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

create conditions conducive to the reintroduction of low-intensity prescribed fire. There is a need 

to create a tree arrangement that would result in reduced fire hazard, decreased inter-tree 

competition, increased tree health and vigor, and increased size class diversity.

Soil and Water Resources

The description of existing conditions of soil resources, including limitations associated with their 

management and land use activities, relies largely on information published in the Coconino 

National Forest (CNF), Terrestrial Ecosystem Survey (TES) (Miller, et. al. 1995). The Soils & 

Hydrology Specialist Report includes more information about existing conditions, including 

background on TES and watershed condition framework.

Existing Conditions

Soil Condition

A soil condition category is assigned to each TES map component either through Universal Soil 

Loss Equation (USLE) predictions regarding long-term annual soil loss or using the soil quality 

(condition) assessment and rating protocol developed for Region 3 of the Forest Service (USDA 

Forest Service, File 2550). Soil condition ratings are based on interpretations of the three 

primary soil functions: soil hydrologic function, soil stability and nutrient cycling. In general, 

hydrologic function of the soil is assessed based on indications of reduced infiltration through 

compaction and modification of surface soil structure. 

Soil condition classes used are Satisfactory, Impaired, and Unsatisfactory. The entire DLH 

portion of the project area is within the Satisfactory soil condition class. Roughly 98 percent of 

MM is also in the Satisfactory soil condition class; the remaining acres are listed as Impaired, due 

to those areas having less vegetative ground cover than identified in the TES reference conditions 

for possible reasons ranging from conifer encroachment to grazing by domestic and wild 

ungulates. The satisfactory condition of soils in the analysis area is generally attributed to high 

amounts of vegetative ground cover, including vegetation basal area and litter, which serves to 

protect the soil from raindrop impact and dissipate the energy of overland flow. Despite this 

overall rating, nutrient cycling within ponderosa pine and mixed conifer vegetation types has 

been observed to be less than satisfactory as a result of low understory species diversity. This 

low diversity of understory species is typically the result of a dense overstory canopy cover that 

limits growth of herbaceous plants.

Soil burn severity has been identified as a key indicator of the susceptibility of a burned area to 

accelerated erosion and flooding and, consequently, soil burn severity categories are used to 

determine appropriate soil and hydrologic parameters needed for post-fire runoff and erosion 

modeling (see the Soil and Water Resources Methodology section for more information about the 

modeling). More analysis of soil burn severity is included in the Soil and Water Resources section 

(within the No Action Alternative analysis) of Chapter 3. 

Erosion Hazard Rating

TES defines erosion hazard as the probability of soil loss resulting from the complete removal of 

vegetation and litter. It is determined though a comparison of the potential soil loss rate for a map 

unit component as calculated using USLE to the estimated tolerance soil loss rate for a map unit 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 31

component. A slight rating indicates that all vegetative ground cover could be removed from the 

site and the resulting soil loss will not exceed "tolerance" soil loss rates. A moderate rate 

indicates that predicted rates of soil loss will result in a reduction of site productivity if left 

unchecked. Conditions in moderate erosion hazard sites are such that reasonable and 

economically feasible mitigation measures can be applied to reduce or eliminate soil loss. A 

severe rating indicates that predicted rates of soil loss have a high probability of reducing site 

productivity before mitigating measures can be applied. Erosion hazard ratings for soils within 

the DLH and MM analysis areas are shown in Figure 8 and Figure 9.

The majority of soils in map units associated with the DLH analysis area have low soil erodability 

factors; however, many of these same soils are assigned moderate to severe erosion hazard 

ratings. This can generally be explained by the steep slopes in the DLH area. Slope has a strong 

influence on erosion as reflected in USLE since runoff velocity is a function of slope gradient. 

The majority of soils associated with TES map units in the MM analysis area have moderate soil 

erodability factors. Map units with severe erosion hazard ratings are often found on steep slopes. 

Figure 8: Erosion Hazard Ratings within the DLH Analysis Area
Chapter 1 – Purpose and Need

32 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 9: Erosion Hazard Ratings within the Mormon Mountain Analysis Area

Hydrology: Watersheds and Streamcourses 

The DLH analysis area occurs mostly within the Upper and Lower Rio De Flag subwatersheds 

with the analysis area’s northeastern boundary roughly coincident with the western boundary of 

the Doney Park sub-watershed. All three of these sub-watersheds are in the larger Rio De Flag 

watershed, which drains to the Little Colorado River to the east. The analysis area is drained by 

two drainage areas tributary to the Rio De Flag; Schultz Creek and Spruce Avenue Wash as 

shown in Figure 10. The analysis area contains one feature mapped as a wetland by the National 

Wetlands Inventory (NWI), which is located in the DLH-portion of the project area and 

commonly known as “Dry Lake.” 

There are three mapped springs in the analysis area including Orion Spring and an unnamed 

spring in the DLH-portion of the project area, and Weimer Spring in in the MM-portion of the 

project area. 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 33

There are two main drainages in the DLH-portion of the project area; Schultz Creek and Spruce 

Avenue Wash. These drainages are both tributary to the Rio De Flag. Flow data for these 

drainages is limited to measurements of peak discharge as estimated using crest-stage gages 

installed and monitored as part of a USGS study of the flood hydrology in and around the City of 

Flagstaff (Hill, et.al., 1988). In six of eleven years of gage data, no discharge was recorded for 

the Schultz Creek drainage. In the eleven year period of record spanning from 1970 to 1980, the

highest peak discharge of 48 cubic feet/second (CFS) was recorded in April 1973. The no or low 

annual peak discharge estimates for Schultz Creek are likely attributable to the mostly 

undeveloped nature of the Schultz Creek drainage basin combined with its high amount of 

vegetative ground cover, high infiltration rates of the associated forest soils, underlying geology, 

and its position relative to subsurface water-bearing zones. Schultz Creek is considered an 

ephemeral stream. There may, however, be portions of the roughly six mile long drainage with 

more persistent surface water as has been observed in the vicinity of the Schultz Creek and Sunset 

trail intersection where willows (Salix sp.) are present and surface water has been observed 

persisting into June, which is usually the driest month of the year. 

As part of the same USGS study referenced above, annual peak discharge estimates for Spruce 

Avenue Wash (referred to as the Switzer Canyon Tributary by the USGS) were made from creststage gage measurements spanning a 12 year period of record beginning in 1968 and ending in 

1980. Annual peak discharge estimates for this drainage ranged from a low of 15 CFS in 

December of 1971 to a high of 262 CFS in August of 1968. The USGS study concluded that 

most of the runoff in this drainage originated from the urbanized portion of the drainage basin. 

Although the amount of runoff generated in the undeveloped portion of the drainage basin 

occurring on Forest Service-managed lands was not determined, observations made where the 

Spruce Avenue Wash crosses Cedar Street indicated that runoff did not reach the urban part of the 

watershed and the highest peak discharge was estimated to be five CFS, presumably based on an 

observation of flow debris. The limited discharge from the un-urbanized portion of the Spruce 

Avenue Watershed is probably attributable to the same factors limiting flow in Schultz Creek and 

this drainage is also classified as ephemeral. 

See the Soil/Hydrology Specialist Report for more information about ephemeral and intermittent 

surface water within the project area.
Chapter 1 – Purpose and Need

34 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 10: Streamcourses and Drainage Areas within the DLH Portion of the 

Analysis Area
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 35

The MM analysis area is almost entirely within the Walnut Creek-Upper Lake Mary (ULM) subwatershed as shown in Figure 11. The flow of surface water to Upper Lake Mary, an important 

watershed for the drinking water of Flagstaff, is derived from the Walnut Creek – ULM subwatershed. This sub-watershed is part of the Walnut Creek watershed which drains to the San 

Francisco wash, located east of Flagstaff, and eventually, to the Little Colorado River. Three 

drainage areas with outlets at Upper Lake Mary, informally referred to Newman basin, Middle 

basin, and East basin, drain the MM analysis area as shown in Figure 11.

There are two main streamcourses with headwaters in the MM-portion of the project area that 

enter Lake Mary as shown in Figure 11: Newman Canyon and an unnamed streamcourse. 

Roughly 44 percent of the project area (1300 acres) drains through Newman Canyon. Except for 

roughly 22 acres (less than one percent) of the project area that drains through Railroad Wash 

entering roughly the upper portion of Upper Lake Mary, surface flow from the remainder of the 

project area is directed through an unnamed drainage entering the upper end of Upper Lake Mary. 

No flow data exists for these drainages, but the size and elevation of the contributing watersheds 

suggest that these drainages may be intermittent flowing for extended periods during the spring 

from snow melt. 
Chapter 1 – Purpose and Need

36 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 11: Streamcourses and Drainage Areas within the MM Area

As discussed in the Fire and Fuels section, approximately 88 percent (4,783 acres) of the DLH 

portion of the analysis area is in fire regime I, condition class 3 with most of the remaining area in 

fire regime III, condition class 3 (1,487 acres). Within the MM portion of the analysis area, 

approximately 89 percent (2,646 acres) is within fire regime I, condition class 3. This high 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 37

departure from natural (reference) conditions highlights the vulnerability of the catchments 

draining the analysis area to a fire that would likely greatly alter the catchment hydrologic 

response, rate of erosion, and sediment transport (Neary, et.al., 2005).

Water Quality

There is limited water quality data available for streamcourses within or immediately downstream 

of the analysis area primarily because they are not perennial surface waters. Arizona Department 

of Environmental Quality’s (ADEQ) most recent assessment of surface water quality included 

two streamcourses with their headwaters at roughly the northern boundary of the MM-portion of 

the analysis area: Newman Canyon and Railroad Wash (ADEQ, 2012). Both streamcourses were 

rated as “inconclusive” though no exceedances of state water quality standards were reported 

during the respective sampling periods. Both streamcourses were sampled near their inlets to 

Upper Lake Mary. ADEQ also assessed and rated as “inconclusive” a 3.7 mile reach of the Rio 

De Flag extending from the discharge outfall for the City of Flagstaff’s Wildcat Hill wastewater 

treatment facility to San Francisco Wash. No exceedances of state water quality standards were 

reported during the sampling period. This reach is downstream of locations where Schultz Creek 

and Spruce Avenue Wash/Switzer Canyon enter the Rio De Flag.

In 2002, five lakes in what is referred to as the “Lake Mary Region” (LMR), including Upper 

Lake Mary, were listed as impaired for mercury in fish tissue. A TMDL study of the LMR lakes 

was completed in 2010 (ADEQ, 2012). Potential sources of mercury identified in the report 

included direct atmospheric deposition to the lakes, and input of sediment containing mercury 

from atmospheric deposition or existing naturally in soil parent material. In Upper Lake Mary, 

81 percent of the average annual loading of mercury for a 10 year period was estimated to be 

from sediment input to the lake, whereas 19 percent was attributed to direct atmospheric 

deposition. It was further determined that most of the annual sediment loading was from 

transport by snowmelt though average mercury concentrations in runoff during August and 

November were more than twice average mercury concentrations in runoff during January 

through April, suggesting that rainfall has a bigger contribution than suggested by previous 

determinations. 

Desired Conditions

The following desired conditions for soils and water resources are based on applicable state and 

Federal laws, Forest Service direction, and the professional judgment of the interdisciplinary team 

resource specialist. 

Critical soil functions and processes including the infiltration and storage of water, the 

cycling and storage of nutrients, and the maintenance of diverse populations of native soil 

microflora are enhanced or preserved. Management activities do not produce substantial 

and permanent impairment of land productivity. 

Water quality meets state standards for designated uses. Sediment inputs to stream 

courses do not contribute to impairment of stream courses or other water bodies.

Susceptibility of soils and water resources to the potential negative consequences from an 

uncharacteristic wildfire are minimized. 
Chapter 1 – Purpose and Need

38 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Need for Change

The need for change for the soils and water resource area are closely tied to those described in the 

Fire Risk Section above. In order to meet the desired conditions defined above, there is a need to 

reduce the risk of high severity wildfire in the project area to reduce the potential effects from fire 

on the forest soils and water resources.

Proposed Action Development & Refinement

The proposed action displayed here is the updated version of the proposed action published in 

April 2013, and represents many of the comments received during the scoping period and 

subsequent IDT meetings. 

Proposed Action

In response to the purpose and need, the Coconino National Forest proposes to conduct thinning 

and burning activities within the approximately 10,544 acre project area using a variety of 

harvesting methods, analyzed in three action alternatives: Alternative2: Proposed Action with 

Cable Logging, Alternative 3: Proposed Action without Cable Logging, and Alternative 4: 

Minimal Treatment. Two Forest Plan amendments are proposed for all three of the action 

alternatives: Amendment 1 relates to treatments in Mexican spotted owl habitats, and Alternative 

2 would authorize mechanized equipment use on slopes above 40 percent.

Chapter 2 displays proposed activities by alternative for comparison; more detailed information

about each alternative, including design features/mitigation measures, can be found in Chapter 2. 

In general, the proposed action would: 

Cut up to approximately 5,329 acres of mixed conifer stands, up to 3,240 acres of 

ponderosa pine stands, up to 22 acres of aspen stand, and 60 acres of grasslands. Trees 

cut would be piled, burned, lopped and scattered or removed.

Cut trees up to 18 inches dbh on 3,141 acres within 10 MSO PACs, potentially during 

one but no more than two breeding seasons (see the Forest Plan Amendments section of 

Chapter 2).

Cut trees up to 5 inches dbh within 80 percent of the Schultz Creek nest core (20 percent 

would be deferred). Conduct prescribed burning within all MSO nest cores. All activities 

within MSO nest cores would occur outside of the breeding season (see the Forest Plan 

Amendments section of Chapter 2).

Conduct prescribed burning on up to 8,973 acres. Burning methods would include 

jackpot, pile burning and broadcast. Maintenance burns would occur every five to ten 

years in the ponderosa pine to maintain openings between trees, maintain tree groups and 

clumps, and move towards and/or maintain Fire Regime Condition Class (FRCC) I. 

Maintenance burning may not occur within the mixed conifer during the life of the 

project due to its historically higher fire return interval. 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 39

Utilize (and reconstruct as needed) up to 21 miles of existing closed roads and new 

temporary roads. Use of the roads would be temporary. Once treatment has occurred, 

roads would be returned to a closed status and/or decomissioned.

Decommission up to 4.38 miles of select closed roads. Decommission methods would 

include installing signs, gates, rock barriers, ripping, or re-contouring of slopes to 

preclude future motorized use. Roads that have established vegetation may need minimal

treatment while others may need to be entirely ripped, seeded and roadbeds re-contoured. 

Implement a permanent Campfire Closure Order in the Dry Lake Hills portion of the 

project area. 

Design Criteria Integral to the Proposed Action by 

Resource 

Forest Plan requirements by resource which are required of all activities in the proposed 

action are located in Appendix C. 

Sampling surveys for heritage resources has already been completed within the project

area and accepted by the State Historic Preservation Office. Additional surveys for any 

new disturbance areas, including temporary road locations, would be conducted prior to 

implementation. 

The project-specific MSO monitoring plan would be finalized through consultation with 

the Fish and Wildlife Service prior to implementation. 

Treatments would be designed to manage for old age trees in order to have and sustain as 

much old forest structure as possible across the landscape. 

Relationship to the Forest Plan

This EIS is a project-level analysis; its scope is confined to addressing key issues and possible 

environmental consequences of the project. 

The Coconino Land and Resource Management Plan (hereafter referred to as the “Forest Plan”) 

sets forth in detail the direction for managing the land and resources of the forest. The desired 

conditions for the project are based on Forest Plan objectives, goals, standards and guidelines. As 

appropriate, the desired conditions also reflect the language from the draft forest plan currently

underway. The analysis also tiers to the forest’s Final Environmental Impact Statements (USDA 

Forest Service 1987) as encouraged by 40 CFR 1502.20. All three action alternatives would 

include two site-specific, non-significant amendments to the 1987 Forest Plan related to MSO 

treatments and use of mechanical equipment on slopes greater than 40 percent. See Chapter 2 and 

Appendix A for more information. 
Chapter 1 – Purpose and Need

40 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Management Direction 

The project area includes 11 Management Areas (MA) as described in the Coconino NF forest 

plan (pp. 46 to 206-113). An additional 40 acres is classified as private lands which were formerly 

private but are now Forest Service land. In the Dry Lake Hills part of the project the Schultz 

management area (MA-36) overlays most of the project area. In the Mormon Mountain part of 

the project the Lake Mary Watershed Management Area (MA-35) also overlays most of this part 

of the project area. 

Table 10 summarizes applicable forest plan direction by Management Area (MA) for those 

management and geographic areas where restoration actions are proposed. Chapter 4 of the Forest 

Plan (pp. 21 to 206-118) has detailed descriptions of forest-wide resource direction specific to the 

management/geographic areas. How the alternatives are consistent with the Forest Plan is 

discussed in Chapter 2, Alternatives, and in Appendix C.

Table 10: Forest Plan Management and Geographic Areas, Acres within Project Area

Forest Plan 

Management 

Area/ Geographic 

Area 

Management Area/Geographic 

Area Description

Acres of Management 

Area/Geographic Area 

in Project Area

MA -3 Ponderosa pine and mixed conifer 

on less than 40 percent slopes 

5,509 acres

MA -4 Ponderosa pine and mixed conifer 

on greater than 40 percent slopes 

3,734 acres

MA -5 Aspen (MA-08) 91 acres

MA -6 Unproductive Timber Land 672 acres

MA-8 Pinon-Juniper Woodlands, greater 

than 40 percent slope

15 acres

MA-9 Mountain Grasslands 46 acres

MA-10 Grasslands and sparse PinyonJuniper Above the Rim140 acres

MA-18 Elden Environmental Study Area 286 acres

Electronic Sites 28 acres

Decision Framework

Given the purpose and need of the project, the Coconino Forest Supervisor will review the 

proposed action, other alternatives and the environmental consequences in order to decide 

whether or not, and in what manner, lands within the Flagstaff Watershed Protection project area 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 41

would be treated to reduce wildfire and flooding hazards. The decision will be based on a 

consideration of the environmental effects of implementing the proposed action or alternatives. 

Based upon the effects of the alternatives and public comment, the Forest Supervisor will decide 

the best method for treating within the project area, which could involve a blending of 

alternatives. This “blending” could mean that a portion of two or more alternatives are chosen to 

essentially create a new alternative, as long as that decision includes actions that are identified 

and the potential effects are disclosed through the analysis of at least one of the alternatives. The 

range of alternatives included in the DEIS seeks to cover every feasible treatment option so that 

the responsible official can compare effects of each before deciding.

Items in this decision will include: 

number of acres treated mechanically

number of acres treated by hand thinning

number of acres treated with prescribed fire

treatments within the MSO recovery habitat

treatments within MSO PACs and protected habitat

treatments within northern goshawk habitat

construction and rehabilitation of new temporary roads

decommissioning of closed roads after implementation

type of implementation method to be used

issuance of a permanent campfire restriction order in the Dry Lake Hills

project-specific Forest Plan amendments

design features to protect forest resources of soil, water, scenery values, wildlife and 

habitat, and rare plants

monitoring proposal for treatments in MSO habitat

Public Involvement

FWPP has been listed on the Coconino National Forest Schedule of Proposed Actions (SOPA) 

since January, 2013. Throughout the project’s proposal development and the scoping period, the 

FWPP interdisciplinary team (IDT) met with interested parties, agencies and Tribes, including the 

Arizona Department of Game and Fish, the United States Fish and Wildlife Service, the 

Ecological Restoration Institute of Northern Arizona University, and environmental groups to 

discuss the proposed action. 

The formal 30-day public scoping period began with the publication of the Notice of Intent (NOI) 

to prepare an Environmental Impact Statement in the Federal Register on April 11, 2013, and 

ended May 13, 2013. The NOI referenced the public open house for May 1, 2013 hosted by the 

Forest, and that the Greater Flagstaff Forests Partnership (GFFP) would be hosting meetings on 

behalf of the City of Flagstaff, with information about the external project website

(www.flagstaffwatershedprotection.org). 

Scoping letters, including a link to the proposed action on the Forest website, were sent as hard 

copies to 606 individuals, including permittees, property owners, and state and local agencies. 

Thirteen personalized letters to tribal contacts were mailed simultaneously, and included hard 
Chapter 1 – Purpose and Need

42 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

copies of maps and the proposed action. An additional 157 cover letters with links to more 

detailed project information were sent to email contacts. A press release was issued from the 

Coconino National Forest April 10, 2013, and a public open house on the proposed action was 

held on May 1 to provide more information on potential activities, funding sources, and 

collaboration with the city. Notices regarding the meetings were posted on the Coconino website 

and the Flagstaff Watershed Protection Project external website. 

Approximately 19 people attended the public meeting. Throughout April 2013, the City of 

Flagstaff hosted three outreach meetings targeted at specific interest groups with Forest Service 

involvement, including one for recreation user groups, interest groups, and adjacent land owners 

in the Mount Elden area (respectively). An additional public meeting geared toward the primarilyseasonal residents of Mormon Lake was hosted by the Forest Service on August 24, 2013. Twenty 

residents attended the meeting, held at the Mormon Lake Fire Station, and primarily voiced 

concerns about dust abatement and ensuring Best Management Practices are followed during 

implementation.

Using the comments from the general public, other agencies, environmental groups and Tribes 

(see Issues section), the interdisciplinary team developed a list of issues to address. 

Tribal Consultation

On February 14, 2013 the Forest sent a separate consultation letters providing information and 

seeking involvement and comments to 13 Tribes and Tribal Chapters including the Pueblo of 

Acoma, the Hualapai Tribe, the White Mountain Apache Tribe, the Fort McDowell Yavapai 

Nation, the Navajo Nation, the Yavapai-Apache Nation, the Hopi Tribe, the Tonto apache Tribe, 

the Pueblo of Zuni, the Yavapai Prescott Indian Tribe, the San Carlos Apache Tribe, the San Juan 

Southern Paiute Tribe, and the Havasupai Tribe, who all have historic ties and an interest in the 

Coconino National Forest. Two written responses were received and The San Carlos Apache 

Tribe responded with a thank you and deferral to the Yavapai-Apache Nation, and the Hopi Tribe

asked for additional information on what the expected outcome of the proposals would be and 

invited project representatives to their next administrative meeting. IDT representatives met with 

the Hopi Tribe on March 21, 2013 and on February 12, 2014 in Kykotsmovi, AZ; the Navajo 

Nation on May 7, 2013 in Window Rock, AZ; the Cameron Chapter of the Navajo Nation on July 

14, 2013 to discuss the project. Representatives are also scheduled to meet with the San Carlos 

Apache Tribe March 5, 2014 in Globe, AZ. A tribal consultation report can also be found in the 

FWPP project record.

Issues

During the scoping process for FWPP, the public and the IDT identified several issues. The Forest 

Service separated the issues into two groups: relevant and non-relevant issues. Relevant issues 

were defined as those directly or indirectly caused by implementing the proposed action. Nonrelevant issues were identified as those: 1) outside the scope of the proposed action; 2) already 

decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the 

decision to be made; or 4) conjectural and not supported by scientific or factual evidence. The

Council on Environmental Quality (CEQ) NEPA regulations explain this delineation in Sec. 

1501.7, “...identify and eliminate from detailed study the issues which are not significant

[relevant] or which have been covered by prior environmental review (Sec. 1506.3)...” A list of 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 43

non-relevant issues and reasons regarding their categorization as non-relevant may be found in 

the project record.

Twenty-five submissions from the public were received, containing a total of 144 comments (see 

the Scoping Summary document in the project record). One comment brought forth from the 

Center for Biological Diversity requested the development of an action alternative that would 

retain the Large Tree Retention Strategy (LTRS) developed by the Four Forests Restoration 

Initiative (4FRI) in its entirety, and also brought forth the concept of strategic placement of 

treatments, which is discussed in Chapter 2 for all the action alternatives. Another comment from 

Wildearth Guardians requested an alternative that did not include any temporary road 

construction and used hand thinning only. Some of the comments resulted in the refinement of the 

proposed action, including development and/or modification of design features and clarification 

of statements. Two additional action alternatives would also developed and retained for further 

analysis. 

As for relevant issues, the Forest Service identified the following issues during scoping:

1. Restoration versus Fire Risk Reduction Issue: A common public concern voiced during 

scoping was the importance and sustainability of restoring ecosystems versus a purely 

fire-risk reduction approach to treatment because there is concern that a fire-risk 

reduction approach would result in unnecessarily departing from historical conditions that 

could be more sustainable long-term. This issue is addressed by providing clarification in 

the Silviculturist report of which treatments are restoration-focused and which are 

designed for fire risk reduction, and why the focus may not be a strict return to historical 

conditions in every part of the project area. Chapter 2 contains a section titled 

“Restoration Versus Fire Risk Reduction” which discusses the proposed treatment types 

and whether their focus is restoration or fire-risk reduction (see Table 23). The 

Silviculture section in Chapter 3 contains more detailed information, summarized from 

the Silviculture Specialist Report, located in the project record. 

2. Mixed Conifer Issue: Several comments included concerns about different aspects of 

treatments in mixed conifer including what was perceived to be a proposal to change the 

Fire Regime of mixed conifer areas, the potential for vegetation conversion, and the 

differences between wet and dry mixed conifer vegetation types and treatments. The 

Silviculturist and Fire/Fuels sections include discussions of the existing and desired 

conditions for the primary vegetation types in the project area, including but not limited 

to species composition, canopy cover, tree group size, basal area, trees per acre, and Fire 

Regime Condition Class, and a discussion of how each alternative affects those 

conditions. The Silviculture section also contains an explanation of desired tree group 

size and basis for those ranges, as well as an explanation of wet and dry mixed conifer 

characteristics and locations. The Fire and Fuels section analyzes the effects of the 

proposed treatments on Fire Regime Condition Class of mixed conifer vegetation.

Several comments also voiced concerns over treatments proposed in mixed conifer 

vegetation types due to its relative rarity and importance to wildlife. The Silviculture 

section includes discussion and clarification of where dry and wet mixed conifer occurs 

and the ecological need to treat in those areas. The Silviculture section also discusses

how treatments in those areas would differ from each other and from treatments proposed 

for ponderosa pine. The Wildlife section includes discussion of anticipated effects of 
Chapter 1 – Purpose and Need

44 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

mixed conifer treatments on wildlife, particularly those species dependent on the mixed 

conifer vegetation type. 

3. Conservation of Large (18” dbh+) Trees Issue: some comments indicated that the Forest 

Service should adopt project-level restrictions to minimize the cutting of trees greater 

than 18 inches dbh. This issue is addressed in Alternatives 3 and 4 through a greater 

focus on the protection of large-diameter trees; in Alternative 3 by the absence of cable 

logging, and in Alternative 4 though a minimal treatment approach. The Silviculture 

section details the estimated number of large (18” dbh +) trees that would be retained 

post-treatment under each alternative. Additionally, design features to protect fire-scarred 

mixed conifer species, large oaks and alligator juniper were be added to the action 

alternatives. 

4. Monitoring Issue: Several comments included concerns over the lack of monitoring for 

anything other than the Mexican spotted owl and thus the potential to not know the 

effects of treatments on other wildlife and habitats. While the Mexican spotted owl 

includes an additional species-specific monitoring program, monitoring of treatment 

implementation, treatment effectiveness, and of wildlife habitat will occur. Specialists 

identified any required and/or supplemental monitoring that would occur in their resource 

areas as a part of this project, such as implementation and effectiveness monitoring. 

These monitoring requirements, as well as monitoring efforts proposed by outside 

organizations within the project area, detailed in Chapter 2 and Appendix B. 

5. Snag Retention and Creation Issue: There is some concern over the loss of snags due to 

cable logging and also the effectiveness and viability of snags created through girdling 

and topping healthy trees compared to snags created through natural processes. This issue 

is addressed in Alternatives 3, which would not include cable logging harvesting methods 

and Alternative 4, which would treat a reduced area and thus restrict potential impacts on 

existing snags. Concerns about the viability of snag development are discussed in the 

Wildlife section of Chapter 3.

6. Prescribed Burning/Maintenance Issue: Public comments showed concern over proposed

exclusion of prescribed burning in areas with mixed conifer on steep slopes due to the 

effectiveness and importance of prescribed fire. Concerns over whether maintenance 

burning would be included and what the intervals would be for the different fire regimes 

also arose during the scoping period. This has been addressed by revising the action 

alternatives to include prescribed burning over more of the project area, but with a 

different method proposed for wet mixed conifer. Maintenance burning was also included 

in the action alternatives with different return intervals proposed for ponderosa pine and 

mixed conifer. Chapter 2 and the Fire/Fuels section of Chapter 3describes how the 

proposed prescribed burning would be implemented for different vegetation types within 

the project area. The Fire/Fuels section also includes a discussion of the different Fire 

Regime Condition Classes (FRCCs) throughout the project area, and the goals and 

impacts of prescribed burning/maintenance burning within them. 

7. Significance of Forest Plan Amendments Issue: The public voiced a concern about the 

significance of the proposed Forest Plan amendments included in one more of the 

alternatives due to the impact of these amendments on wildlife species including the 

northern goshawk and the Mexican spotted owl. This issue is addressed through the 
Chapter 1 – Purpose and Need

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 45

analyses of each Forest Plan amendment in each resource area and by the removal of the 

proposed amendment for canopy cover/interspaces; the latter was determined not to be 

necessary to meet the purpose and need of the project. Specialists included discussions of 

the effects of these amendments in their effects analyses, and the DEIS includes details 

on what would be amended in the Forest Plan and why. 

8. Visual Effects Issue: The IDT identified a concern about potential impacts to scenic 

resources as a result of implementation due to the highly-valued view sheds contained 

within the project area. This concern is addressed through the development of Alternative 

4, which includes a minimal treatment scenario. The Scenery Management section 

discusses effects to these resources and provides examples of what post-treatment 

conditions may look like under the different alternatives. 

In addition to the issues identified above, a number of issues identified from public scoping were

addressed through Design Features incorporated into one or more of the alternatives. The 

following topics were addressed through modification and/or creation of a design feature 

associated with the proposed action to address issues common to all action alternatives:

1. Residual slash treatment

2. Retention of old growth trees

3. Single-track trail protection

4. Fuelwood gathering area identification

5. Biomass utilization 

6. No machine piling within 300 feet of residences

7. No hand piling within 50 feet of residences

8. Hunting access coordination with AZGFD

9. Dust abatement measures on Forest Roads during hauling activities
Chapter 2 - Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 46
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 47

Chapter 2. Alternatives

Introduction

This chapter describes and compares the alternatives considered for the Flagstaff Watershed 

Protection Project. It includes a description and map of each alternative considered. This section 

also presents the alternatives in comparative form, sharply defining the differences between each 

alternative and providing a clear basis for choice among options by the decision maker and the 

public. Some of the information used to compare the alternatives is based upon the design of the 

alternative (i.e., helicopter logging versus the use of skid trails) and some of the information is 

based upon the environmental, social and economic effects of implementing each alternative (i.e., 

the amount of erosion caused by helicopter logging versus skidding). 

Action Alternatives: Strategic Placement of Treatments

The concept of strategically placing treatments across a landscape to modify fire growth and 

behavior at the landscape level has been proposed as a potential strategy for addressing 

implementation problems including limited funding, inadequate road access, variable land 

ownership and restrictions on prescribed fire and timber harvest (Finney 2001). Many studies 

have shown that strategic placement of treatments, especially intensive treatments, can reduce the 

risk of the spread of high-severity wildfire at the landscape level (Finney 2001, Suffling et al. 

2008, Kim 2006, Ager et al. 2010)

The action alternatives focus treatment intensities on areas within the landscape that are highly 

vulnerable to high-severity wildfire. The project area includes areas on steep slopes with dense 

vegetation that have been identified as parts of the landscape most susceptible to post-fire impacts 

(because they are the most likely to result in downstream flooding), which means that the project 

itself is an attempt to strategically place treatments on the landscape by targeting those areas most 

likely to experience high-severity fire and those areas most susceptible to post-fire impacts. 

In Alternatives 2 and 3, treatments are proposed for the majority of the project area, with more 

aggressive thinning treatments strategically proposed in areas at higher-risk of severe wildfire, 

including areas where topography aligns with the dominant winds. Areas within the project that 

present low fire hazard risk or contain uniquely limited habitats are proposed for less aggressive 

or no treatment. Alternative 4, in contrast, would include treatments only in those areas identified 

as highest risk of severe wildfire effects to soil resources as identified through fire and watershed 

modeling. The purpose for Alternative 4 is to provide an alternative that includes only the 

minimum amount of treatment necessary to meet the purpose and need; thus the proposed 

treatments would be more focused and less continuous across the project area. 

Harvest Systems/Methods Descriptions

The following descriptions of harvesting systems, machinery and methods are described here to 

provide background and context to the proposed treatments and the associated effects analyses in 

Chapter 3. All of the systems/methods are analyzed for use, but the actual equipment used would

depend on the final decision and also the contractor procured during implementation. The pictures 

are examples and are not necessarily representative of what would be used within the FWPP 

project area. 
Chapter 2. Alternatives 

48 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Conventional Ground Based: Conventional ground based harvest systems typically consist of 

several machines that all perform specialized functions. First a feller-buncher cuts the trees with 

a saw or shear head and then places them into bunches for subsequent removal. Wheeled fellersbunchers, (Figure 12) are the dominant felling machines used in northern Arizona and operate 

well, up to approximately a 25 percent slope. Beyond 25 percent it is often necessary to use a 

tracked boomed feller-buncher (Figure 13) that has leveling capability and is capable of operating 

on steep slopes. These leveling feller-bunchers can work on up to 55 percent slopes but very 

rocky ground can limit their operation. 

A rubber tired grapple skidder, (Figure 14) then drags whole trees that have been bunched by the 

feller-buncher, to a roadside landing area. At the landing, a processor, (Figure 15) removes limbs 

from trees and cuts them into log length. Finally, a loader (Figure 16) places logs onto a truck for 

transportation to a mill. Logging slash, (limbs and tops) generated at the landing can be burned 

on site or chipped and removed as biomass. Conventional ground based harvesting is generally 

limited to slopes of 40 percent or less due to capability limitations. 

Figure 12: Wheeled feller-buncher used on slopes up to 25 percent
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 49

Figure 13: Tracked, boomed feller-buncher for steep slopes

Figure 14: Grapple Skidder
Chapter 2. Alternatives 

50 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 15: Log processer

Figure 16: Log Loader
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 51

Cut to length: The cut to length, (CTL) harvest system consists of a harvester, (Figure 17) that 

cuts trees with a bar saw and then, without releasing them from its cutting head, delimbs and 

processes them into logs. Limbs and tops are placed in front of the machine and are crushed down 

as the harvester moves ahead. A forwarder, (Figure 18) then follows in the harvester’s trail and 

loads the cut logs into log bunks on the machine. These logs are carried above the ground service 

to a roadside landing. Repeated trips by the forwarder on the trail crush the slash into the ground. 

If it is desirable to remove more of the slash, it is possible to only process the tree to the extent 

needed to get it on the forwarder. In some instances it may be possible to not process the tree at 

all and take it to the landing in tree length form. The stem then must be processed into logs at the 

landing. 

In the past CTL has been limited to slopes of approximately 40 percent; however recent 

developments in technology now allow some models of harvesters and forwarders to operate on 

slopes of up to 65 percent slope for downhill forwarding and 45 percent uphill. Rocks that 

protrude from the ground over about 12 inches limit operability; however rocks that are 

embedded in the ground without a vertical side above ground do not impede operation greatly.

Figure 17: Harvester
Chapter 2. Alternatives 

52 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 18: Forwarder on 65% slope

Cable Logging (Skyline Yarding): Skyline yarding uses a system of cables, (Figure 20) to drag 

logs or whole trees from the cutting unit to a roadside landing. It is used on sites that are too 

steep for ground based operations. 

A skyline yarder, (Figure 19) remains stationary on a road and supplies the power to operate the 

cables which pull in the harvested stems. The yarder also contains the drums on which the cables 

are stored. A tower on the yarder provides partial lift for the logs so that they better clear 

obstacles (e.g. topographical features, other vegetation, etc.). 

A skyline is strung from the yarder and anchored to a tailhold at the bottom of the cutting unit. 

Roughly parallel “corridors” for the skyline needs to be placed every 100 to 140 feet. These

corridors are approximately 12-feet wide and must have all trees removed from them to facilitate 

yarding. Logs are laterally yarded to this corridor and are then hauled up the skyline to the 

landing. 

Trees can be mechanically cut if the ground conditions allow for feller-bunchers or harvesters to 

operate on it, otherwise felling is done by hand with chainsaws. Yarding is nearly always done 

uphill against gravity as this allows for the logs to remain under control of the yarder. Downhill 

yarding is very difficult in partial cuttings such as thinnings and requires a yarder with additional 

capability. Downhill yarding results in significantly greater stand damage and safety issues. 

Skyline yarding is not limited by slope. If whole trees are yarded to the landing, a processor can 

manufacture the stem into logs just as in conventional ground based operations. A loader also 

loads the logs onto trucks for tranport.
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 53

Figure 19: Drawing of a skyline logging system, tops of the logs or trees usually drag on the 

ground

Figure 20: Skyline Yarder
Chapter 2. Alternatives 

54 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

A variation of skyline yarding involves a machine referred to as an Excaliner (Figure 21). 

Excaliners are excavators that have been converted for use as a skyline yarder. They are capable 

of operating off of constructed roads and yard timber up to the top of steep areas that a 

conventional yarder, which must remain on the road, would not be capable of accessing. Yarded 

timber is then skidded to a roadside landing with a rubber-tired skidder.

Figure 21: Excaliner yarding logs

Helicopter Yarding: Helicopter logging or yarding is a very simple logging method. Trees are 

felled either by hand or mechanically and then lifted free of the ground with a helicopter equipped 

with a 150-200-foot long line, (Figure 22) and flown to a roadside landing. Either logs or whole 

trees may be removed. However, flying whole trees with limbs and tops attached can 

significantly raise logging cost, as limbs and tops have little to no commercial value and are 

expensive to fly. Helicopter yarding is an extremely expensive method due to the high cost of 

operating a helicopter. If whole trees are flown, the tree is processed at the landing area with a 

processor.
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 55

Figure 22: Helicopter Yarding

Methods of Treating Fuels on Site without Extraction: Fuels can also be treated on site 

without being removed. Treating fuels on site could be carried out in areas where removing the 

material is not practical or desirable or in areas where the material being cut has little or no 

commercial value. Treating these fuels on site may be the most cost-effective method to achieve 

fuel reduction goals.

The most commonly employed method is to cut trees by hand, buck them to approximately 6-foot

lengths and place this material into small piles, (Figure 23). Piles are then burned when weather 

and fuel moisture condition limit the fire’s potential to spread beyond the pile. This method is 

simple, but it is also fairly expensive and labor intensive to implement.
Chapter 2. Alternatives 

56 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 23: Hand piles along Elden Lookout Road

On site piling can also be done mechanically with a feller-buncher or a harvester. A harvester is 

capable of cutting trees into any length desired and can create piles very similar to a hand 

constructed pile. Feller-bunchers however, are not designed to cut trees into logs and as a result 

can only place whole trees into long windrows for burning.

On very steep or rocky sites a steep slope excavator, commonly known as a “spider” may be used 

to treat fuels, (Figure 24). Spiders are designed to work in extremely difficult topography. While 

they are most often used as an excavator for piling or digging, they can be equipped with a 

harvester head and can cut, buck and pile standing trees. Their legs operate independently and 

they push themselves uphill with their boom. They can maneuver around and over fair sized 

boulders that would limit operations of other machines such as harvesters and feller-bunchers. 

They are a very specialized machine that is uncommon, especially in northern Arizona.
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 57

Figure 24: Spider piling slash on steep ground

Alternatives Considered in Detail

The Forest Service analyzed four alternatives in detail: the No Action (required by law as a 

baseline), the proposed action, and two alternatives to the proposed action in response to issues 

raised by the public. 

Alternative 1: No Action Alternative

Under this alternative, no new areas treated in the FWPP area. Implementation of previous NEPA 

decisions, including Jack Smith Schultz and the Eastside Fuels Reduction and Forest Health 

Restoration projects could continue. For this Environmental Impact Statement, specialists 

analyzed the impacts of a modeled wildfire occurring under existing conditions (see the Fire & 

Fuels section of Chapter 3 for more information about the modeled wildfire). 

Alternative 2: Proposed Action with Cable Logging Emphasis on Steep 

Slopes

Alternative 2 includes the updated proposed action (below) with an emphasis on the use of cable 

logging wherever plausible, as detailed in the Implementation Methods section. 

Alternative 2 Treatment Summary

The FWPP project area includes approximately 10,544 acres; roughly 1,605 of those acres are 

either non-treatable due to rock faces and/or boulder fields, or are not slated to be analyzed in this 
Chapter 2. Alternatives 

58 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

project (see Figure 25). Treatments would include mechanical and hand thinning as well as 

prescribed fire on the remaining acres (approximately 8,938 acres). 

Mechanical tree thinning would occur within Mexican spotted owl protected activity centers 

(MSO PACs) with a desired condition of trees greater than 16 inches dbh contributing more than 

50 percent of the stand basal area and maintaining a minimum of 40 percent canopy cover in 

pine-oak and 60 percent in mixed conifer per the MSO Recovery Plan (2012, pp. 276-277), 

followed by prescribed burning. Hand thinning up to 5 inches dbh in approximately 80 percent of

the Schultz Creek Nest Core and prescribed burning in all nest cores would occur. In addition, 

hand thinning up to 9 inches dbh in the DLH, mechanical thinning up to 24 inches dbh on MM,

and prescribed burning at both areas would also occur within MSO nest/roost habitat in 

coordination with the US Fish and Wildlife Service (FWS) to reduce the risk of high severity 

wildfire (See Table 11 for more information). No cable logging would occur within MSO nest 

cores and no temporary roads would be located within MSO nest cores. Some treatments 

proposed within occupied PACs may need to occur during the breeding season (March 1-August 

31) and would be coordinated with FWS. Treatments in nest cores would not occur during the 

breeding season.

Prescribed fire would include initial pile burning to remove slash accumulated through 

harvesting, followed by broadcast burning. In areas where fuel loading allows, broadcast burning 

may occur prior to thinning. Maintenance burning may occur every five to seven years following 

implementation in order to maintain lower fuel loading levels and to restore a frequent, lowseverity fire regime. Mixed conifer on steep slopes may only receive one broadcast burn through 

the life of the project due to the difficulty of implementation in these fuel types and terrain, and 

also because the historic Fire Return Interval in some vegetation types is historically longer than 

the life of this project. Prescribed burning techniques in wet mixed conifer would target 

accumulated dead and down material rather than using broadcast burning ignition patterns. Other 

slash removal options as described in the Implementation Methods section could also be used in 

lieu of burning, including biomass removal.
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 59

Figure 25: Alternative 2 Proposed Treatments, DLH
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 60

Figure 26: Alternative 2 Proposed Treatments, MM
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 61

Table 11: Alternative 2 Proposed Treatment Descriptions, Objectives and Acres8

Treatment Type Treatment Description/Objective Acres

Ponderosa Pine Fuels 

Reduction

(Northern goshawk LOPFA 

areas)

These treatments areas are outside of MSO 

PACs and northern goshawk PFAs and nest 

cores. Mechanical treatment designed to 

develop uneven-aged structure and a mosaic 

of openings and tree groups of varying sizes. 

Openings would occupy approximately 20

percent of the treatment area. Tree groups 

would vary in shape, size, density, and 

number: generally from 0.05 – 0.7 acres in 

size with residual group basal areas of 20-80 

ft2 per acre and 2-40 trees per group. 

1865 – Dry Lake 

Hills (DLH)

766 – Mormon 

Mountain (MM)

Ponderosa Pine Fuels 

Reduction – Hand Thinning

(Northern goshawk LOPFA 

areas)

This treatment includes steep areas that have

low tree density and/or are dominated by 

smaller diameter trees where the purpose and 

need can be met through hand felling 

treatments. Where practical and feasible, 

treatments would be designed to develop 

uneven-aged structure and a mosaic of tree 

groups of varying sizes similar to the 

treatment described above.

150 - DLH

Mixed Conifer Fuels 

Reduction

(MSO Recovery areas)

These treatments areas include dry mixed 

conifer areas outside of MSO PACs, 

replacement nest/roost habitat, and northern 

goshawk PFAs and nest cores, but include 

MSO restricted habitat. Mechanical 

treatment designed to develop uneven-aged 

structure and a mosaic of openings and tree 

groups of varying sizes. Trees above 24” dbh 

would not be cut except if necessary for 

cable corridor locations.9 Openings would 

occupy about 10-20 percent of the treatment 

area. Tree groups would vary in shape, size, 

density, and number: generally less than one 

acres in size with residual group basal areas 

of 30-90 ft2 per acre and 2-50 trees per 

group.

1140 - DLH

Mixed Conifer Fuels 

Reduction – Hand Thinning

(MSO Recovery areas)

This treatment includes areas where fuels 

reduction objectives can be met through hand 

thinning of trees < 9” dbh; where mechanical 

treatment could cause high levels of resource 

damage; or where mechanical treatments 

would be cost-prohibitive. 

132 - DLH

 

8

Table 20 describes the harvesting method for each treatment type

9 Cable corridors require the removal of trees within the corridor itself as well as hazard trees within the cable logging 

unit to ensure safe operations. 
Chapter 2. Alternatives

62 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Treatment Type Treatment Description/Objective Acres

MSO PAC Fuels Reduction -

Wet Mixed Conifer 

This treatment would create small openings

by hand within and around aspen patches to 

promote regeneration. Dead and down 

material would be piled for burning to reduce 

the heavy fuel loading and allow for lowerintensity prescribed burning. Trees over 18” 

dbh would not be cut. 

180 - MM

MSO PAC Fuels Reduction Mechanical treatment to create a diversity of 

tree patch sizes with minimum patch size of 

2.5 acres. Provide for 10 percent openings 

across treatment areas from 0.1 – 2.5 acres in 

size. Maintain a minimum of 40 percent 

canopy cover in pine/pine-oak and 60 

percent in mixed conifer. Post-treatment, 

trees greater than 16” dbh would contribute 

at least 50 percent of the stand basal area per 

MSO Recovery Plan guidelines (2012, pp. 

276-277). Trees above 18” dbh would not be 

cut except if necessary for cable corridor 

locations.

1167 – DLH

1592 - MM

MSO PAC Fuels Reduction –

Hand Thinning

This treatment includes steep areas which 

have low density and dominated by smaller 

trees or are in areas not conducive to cable 

yarding operations. Where feasible, 

treatments would have similar objectives to 

those described in the MSO PAC Fuels 

Reduction treatment above, with the 

limitation that cutting would be limited to 

trees up to 9” dbh due to the constraints of 

hand thinning operations. Otherwise 

treatments would be thin from below up to 

9” dbh to reduce density and fuel ladders.

202 – DLH 

MSO Nest Fuels Reduction -

Hand Thinning

Hand thinning up to 5” dbh would occur 

within 80% of the Schultz Creek nest core in 

coordination with the US Fish and Wildlife 

Service. Approximately 20% of the nest core 

would be deferred from treatment in order to 

maintain denser patches for habitat. Residual 

basal area would be a minimum of 110 ft2, 

and treatment would maintain a minimum of 

60% canopy cover in mixed conifer. This 

nest core would also receive the prescribed 

burning treatment described below

122 – DLH

MSO Nest Fuels Reduction -

Burn Only

In all nest cores other than the Schultz Creek 

nest core, treatment would consist of burning 

only. Dead and down material in MSO nest 

cores would be piled by hand and burned.

261 – DLH

402 – MM
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 63

Treatment Type Treatment Description/Objective Acres

MSO Nest/Roost RecoveryHand ThinningHand thinning up to 9” dbh would occur on 

72 acres in DLH under this treatment, and 

dead trees less than 12” dbh and down 

material would be cut and piled by hand for 

prescribed burning. 

72 - DLH

MSO Nest/Roost RecoveryBurn OnlyThirty-seven acres of Nest/Roost Recovery 

habitat would be prescribed burned only (no 

hand thinning). Snag retention guidelines 

identified in the Forest Plan would still be 

followed (see Design Features – Snags).

Treatments would be designed to move the 

stands towards minimum desired conditions: 

Residual basal area of 110 ft2 in ponderosa 

pine, and 120 ft2 in mixed conifer; canopy 

cover of 40 percent in pine/pine-oak and 60 

percent in mixed conifer; 12 trees per acre 

greater than 18” diameter; trees from 12-18” 

dbh would comprise over 30 percent of 

stands BA, and trees greater than 18 inches 

would comprise an additional 30% of BA.

37 - DLH

MSO Nest/Roost Recovery –

Mechanical Thinning

Mechanical treatment would remove 

ponderosa pine in a variety of size classes up 

to 24” dbh. Target basal area would be 95 

ft2, and no oak would be cut. 

22 - MM

Northern Goshawk Post 

Fledging Areas (PFA) Fuels 

Reduction

Uneven-age mechanical treatment designed 

to develop uneven-aged structure and a 

mosaic of tree groups of varying sizes. 

Openings would occupy 20 percent of the 

treatment area. Tree groups would vary in 

shape, size, density, and number: generally 

from 0.05 – 0.7 acres in size with residual 

group basal areas of up to 30-90 ft2 per acre 

and 2-40 trees per group.

359 - DLH

Northern Goshawk Nest Fuels 

Reduction

Mechanical treatment designed to develop 

northern goshawk nest stand conditions 

consisting of a contiguous over-story of large 

trees. Forest Plan guidelines for canopy 

cover would be met: canopy cover would 

vary from 50 to 70 percent. 

100 - DLH

Aspen Treatment A variety of different treatments would be 

used to promote and protect aspen health and 

regeneration, including the removal of post 

settlement conifers within 100 feet of aspen 

clones, prescribed fire, ripping, planting, 

fencing and/or cutting of aspen to stimulate 

root suckering.

22 – DLH

Grassland Restoration Mechanical treatment to remove encroaching 

post-settlement conifers and restore the pre60 – DLH
Chapter 2. Alternatives

64 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Treatment Type Treatment Description/Objective Acres

settlement tree density and patterns.

Burn Only Burn only treatment would remove excessive 

fuel loading in areas which were previously 

burned by the 1977 Radio Fire.

270 - DLH

Electronic Site – Structure 

Protection

These sites are occupied by 

telecommunication facilities, and would be 

treated to provide a sufficient defensible 

space around these structures from a 

wildland fire. Individual trees that are 

determined to contribute to wildfire risk or 

pose a hazard to the electronic sites would be 

removed. The remainder of the sites would 

receive a thin from below to approximately 

20 – 40 ft2 basal area with the purpose of 

raising the crown base height and leaving the 

largest and most fire resistant trees.

6 – DLH

12 - MM

No Treatment (No New 

Analysis)

These acres include non-treatable areas, 

including rock faces and boulder fields, and 

the Orion Timber Sale (approximately 837

acres). Though the Timber Sale is within the 

project boundary, the treatments for that area 

were analyzed and authorized under the Jack 

Smith Schultz Fuels Reduction and Forest 

Health Restoration Project Decision 

Notice/Finding of No Significant Impact 

(2008). No additional treatments within the 

Timber Sale area are proposed under FWPP. 

1605 - DLH
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 65

Harvesting Methods

Under Alternative 2, cable logging would be used to treat approximately 1,185 acres in the DLH

and 106 acres on MM, based on slope steepness and terrain10. This would also include areas that 

are yarded with an off-road cable yarder known as an excaliner (see Table 12). On DLH, an 

estimated 191 acres would fall within the approximately 12-foot wide cable corridors themselves; 

MM would have approximately 14 acres, some of which falls within the wet mixed conifer fuel 

type. Though treatments proposed for wet mixed conifer would not require the use of cable 

logging systems, treatments in the dry mixed conifer lower on the slope would. Thus, in order for 

the dry mixed conifer areas to be treated, cable logging corridors would have to cross some 

portions of wet mixed conifer due to its location on the slope. Landings would be located at the 

top of the cable corridors, typically on or adjacent to roads. Cable logging was chosen as the 

treatment method based on its ability to remove material on steep, rocky slopes cost-effectively. 

If a market for biomass11 exists during the time of implementation, biomass removal methods 

may be utilized in place of pile burning in areas identified for potential ground based harvesting, 

particularly in areas adjacent to residential property.

Table 12: Alternative 2 Harvesting Methods for DLH

Treatment 

Type

Excali

ne/

Hand 

Cut

Excaline

/

Machine 

Cut

Grou

ndbased

Hand 

Cut/P

iled

Bur

n 

Only

Skylin

e/

Hand 

Cut

Skyline/

Machin

e Cut

Mach

ine 

Cut/P

iled

TOT

AL

Ponderosa 

Pine Fuels 

Reduction

82 170 1613 1,86

5

Ponderosa 

Pine Fuels 

Reduction 

– Hand 

Thinning

150 150

Mixed 

Conifer 

Fuels 

Reduction

64 15 626 225 210 1,14

0

Mixed 

Conifer 

Fuels 

Reduction 

– Hand 

Thinning

132 132

MSO PAC 

Fuels 

26 177 793 46 110 15 1,16

7

 

10 Refers to areas where the majority of the stand is being treated through cable logging methods, includes exaclining 

and skylining

11 Biomass is defined as material from trees and woody plants, including limbs, tops, needles, leaves and other woody 

parts that are the by-products of vegetation management activities.
Chapter 2. Alternatives

66 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Treatment 

Type

Excali

ne/

Hand 

Cut

Excaline

/

Machine 

Cut

Grou

ndbased

Hand 

Cut/P

iled

Bur

n 

Only

Skylin

e/

Hand 

Cut

Skyline/

Machin

e Cut

Mach

ine 

Cut/P

iled

TOT

AL

Reduction

MSO PAC 

Fuels 

Reduction 

– Hand 

Thinning

202 202

MSO Nest 

Fuels 

Reduction

122 261 383

MSO 

Nest/Roost 

Recovery

72 37 109

Goshawk 

PFA Fuels 

Reduction

60 299 359

Goshawk 

Nest Fuels 

Reduction

100 100

Aspen 

Treatment

22 22

Grassland 

Restoration

60 60

Burn Only 270 270

Electronic 

SiteStructure 

Protection

6 6

No 

Treatment/

No New 

Analysis

- - - - - - - - 1605

TOTAL 172 422 3,497 699 568 271 320 15 7569

Table 13: Alternative 2 Harvesting Methods for MM

Treatment Type Excaline/

Machine 

Cut

Groun

dbased

Hand 

Cut/Pile

d

Burn 

Only

Skyline/

Machine 

Cut

TOTA

L

Ponderosa Pine Fuels 

Reduction

767 767

MSO PAC Fuels Reduction 33 1519 40 1,592

MSO PAC Fuels Reduction 

–

Wet Mixed Conifer

147 33 180
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 67

Treatment Type Excaline/

Machine 

Cut

Groun

dbased

Hand 

Cut/Pile

d

Burn 

Only

Skyline/

Machine 

Cut

TOTA

L

MSO Nest Fuels Reduction 402 402

MSO Nest/Roost Recovery 22 22

Electronic Site-Structure 

Protection

12 12

TOTAL 33 2,321 147 402 73 2,975

Campfire Closure Order

The proposed action would also include establishing a permanent campfire restriction order in the 

DLH portion of the project area to limit the potential for human-caused wildfire. The current 

temporary campfire restriction order (Number 04-13-09-F) has been in effect since June, 2011 

(reissued June 2013 for two years), and prohibits building, maintaining, attending, or using a fire, 

campfire12, or stove fire13 (36 CFR § 261.52(a)). The Proposed Action would extend this order 

permanently in the project area. 

Forest Plan Amendments

The Coconino National Forest is currently operating under the 1987 Coconino Land Management 

Plan, as amended; however the Forest is in the process of revising the Forest Plan, with the 

Record of Decision (ROD) for the revised plan anticipated for release in mid-2015. Depending on 

the timing of the release of the final Forest Plan document, the final FWPP analysis will be 

consistent with the revised Forest Plan. The following three project-specific, non-significant 

Forest Plan amendments would only be required if a decision for this project is signed prior to 

implementation of the revised Forest Plan. In other words, no Forest Plan amendments would be

anticipated if FWPP is implemented under the revised Forest Plan. If the amendments are 

necessary, this project would be amending the Forest Plan under the 2012 Planning Rule (36 CFR 

219.13). 

A site (project) specific plan amendment is a one-time variance in Forest Plan direction for the 

project; Forest Plan direction reverts back to its original language/direction upon completion of 

the specified project. The language proposed does not apply to any other forest project.

All three of the action alternatives would require two of the proposed Forest Plan amendments,

Amendment 1 and Amendment 2, summarized below. In the Proposed Action sent out for 

scoping in April 2013, three Forest Plan amendments were proposed, the two summarized below 

as well as one for canopy cover and interspaces. After further analysis of the existing and desired 

conditions along with review of scoping concerns, the IDT decided that the amendment was not 

necessary to meet the objectives of fuels reduction and fire risk abatement.

More information about canopy cover measurements and openings can be found in the 

Silviculture section of Chapter 3 and in the Silviculture Specialist Report, located in the project 

record. Appendix A contains more detailed information on the amendments. 

 

12 Campfire: means a fire, not within any building, mobile home or living accommodation mounted on a motor vehicle, 

which is used for cooking, personal warmth, lighting, ceremonial, or aesthetic purposes. Fire includes campfire.

13 Stove fire: means a campfire built inside an enclosed stove or grill, or a portable brazier, including wood and 

charcoal fires.
Chapter 2. Alternatives

68 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Amendment 1: A revised MSO Recovery Plan, issued by the U.S. Fish and Wildlife Service 

(FWS) was finalized in December of 2012 (USDI 2012). The current Forest Plan is consistent 

with the previous MSO Recovery Plan (USDI 1995). For this project, a Forest Plan amendment 

would utilize some of the more updated management direction in the revised recovery plan where

it is different than what is currently included in the Forest Plan. The proposed Forest Plan 

amendment would modify Forest Plan language to allow mechanical treatments in MSO PACs up 

to 18 inches dbh, hand thinning treatments up to 5 inches dbh in the Schultz Creek nest core, and 

prescribed burning within all MSO nest/cores. The amendment would also allow removal of trees 

24 inches dbh and greater in MSO protected and recovery habitats for cable logging corridors in 

order to facilitate treatments under Alternative 2, and would allow temporary road construction to 

occur within MSO PACs under all three action alternatives. Additionally, Alternatives 2 and 3 

would remove all snags in cable and helicopter logging areas for safety reasons, the effects of 

which are analyzed in Chapter 3. The monitoring requirement specified under the Forest Plan 

would be amended to include the monitoring plan developed by the Forest Service, U.S. Fish and 

Wildlife Service, and the Rocky Mountain Research Station referenced in the following section 

titled, “Monitoring.” This amendment would also remove timing restrictions within MSO PACs 

for the duration of the FWPP project. Treatments within PACs would be accomplished as quickly 

as possible to reduce the duration of impacts, and would be coordinated with FWS. Timing 

restrictions would still apply for treatments within MSO nest cores. The purpose of this 

amendment would be to facilitate treatment in high-priority locations such as Mexican spotted 

owl occupied habitat to prevent high-severity wildfire. This is based on language in the Mexican 

Spotted Owl Recovery Plan (2012), which states, “[wildfires] result in the most significant 

alteration of owl habitat and hence, have the greatest potential for loss of habitat.”

Amendment 2: The current Forest Plan restricts the use of mechanical equipment to slopes less 

than 40 percent. Amendment 2 would remove the restrictive language related to 40 percent slopes 

and also the language identifying slopes above 40 percent as inoperable in order to allow 

mechanical harvesting on slopes greater than 40 percent within the project area. 

It would be necessary to allow for use of specialized mechanical equipment to cut and remove 

trees on steep slopes to reduce the risk of high-severity wildfire in this project area due to the 

preponderance of areas with greater than 40 percent slope in the project area. Furthermore, since 

the Forest Plan was written and amended, mechanized ground-based equipment has progressed to 

be able to operate on steep slopes more effectively with less damage to the soils. While this 

specialized equipment is not commonplace in this region due to the high cost of its use, the 

approval of the City bond makes the use of such equipment a possibility for this project. In order 

to be able to utilize such equipment to treat slopes above 40 percent in the project area and meet 

the purpose and need, this Forest Plan amendment is needed.

Monitoring

Mexican Spotted Owl

The Mexican Spotted Owl Recovery Plan, First Revision (USFWS 2012) provides guidance for 

these treatments and emphasizes the need for monitoring and feedback loops to allow 

management to be adaptive. Well-designed monitoring would provide valuable information on 

the effects of these activities on the owls and their habitat. For FWPP this is of particular interest 

because fuels reduction treatments within mixed conifer vegetation types has not previously 

occurred on the Flagstaff Ranger District; additionally, hand thinning treatments and prescribed 

burning within MSO nest cores have also not occurred on the District, nor frequently across the 

southwest. Therefore, the Forest Service worked with the FWS and the Ecological Restoration 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 69

Institute (ERI) of Northern Arizona University to develop a monitoring plan for this project that 

would assist in determining the effects of thinning and burning on MSO and their habitat

(Appendix B). The monitoring plan includes the details for sample selection, treatment specifics, 

measurement protocols including timing, and planned analyses. The monitoring plan will be 

reviewed as part of the consultation process for treatments planned to occur within PACs.

The proposed monitoring plan would pair treated and untreated (reference) PACs within DLH

and MM portions of the project and compare occupancy rates, reproduction rates, and habitat 

changes. Reference PACs would match the environmental conditions in PACs where treatments 

are proposed, as closely as possible.

Habitat Monitoring

The Ecological Restoration Institute (ERI) of Northern Arizona University is working with the 

Forest Service and FWS to coordinate monitoring efforts within the MSO reference PACs 

identified in the MSO monitoring plan to meet multiple objectives, including but not limited to 

treatment effects on habitat components, such as tree species composition and structure. 

Red Squirrel

Red squirrels play an important role in forest ecology and restoration as they are excellent 

indicators of changes as a result of forest treatments. Red squirrels require a forest structure that 

provides large areas of closed canopy and large trees that produce an abundant cone crop. The 

Forest Service and AZGFD have developed a red squirrel monitoring outline in order to establish 

long-term trends in populations and habitat use and the effects of forest thinning treatments on 

red squirrels.

Soil/Watershed Responses

Implementation and effectiveness monitoring of best management practices (BMPs) listed in the 

Design Features would occur in accordance with the National Core BMP Monitoring Protocols 

(in preparation, FS-900b). Monitoring would determine whether the BMPs are being 

implemented as planned and whether they are effective. 

Fire, Fuels and Air Quality

In the last two years, Flagstaff Ranger District fuels personnel have started to monitor the effects 

of prescribed burning in different project areas. Specific protocols have been developed from a 

combination of the Firemon and FSVeg protocols and following the DRAFT Region 3 Vegetation 

Monitoring/Sampling Protocols (updated December 2008). The forest characteristics that are 

measured pre and post fire/prescribed burn in the managed fire and prescribed fire protocols are 

described in detail in Appendix B and include overstory trees, pole sized tree or saplings, 

seedlings, snags, fuel loading, and CBI (composite burn index which assessed burn severity) 

which is solely performed postfire and under special severe wildfire or prescribed fire situations. 

CBI methodology and protocols would only be implemented when the District Fuels Specialist 

deemed necessary.

Required Transportation System

The Forest Plan directs the forest to:

“Provide and manage a serviceable road transportation system that meets needs for public access, 

land management, resource protection, and user safety. Provisions are made for the construction 
Chapter 2. Alternatives

70 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

and reconstruction, maintenance, seasonal and special closures of Forest roads; and obliteration of 

unnecessary roads,” (1987, as amended). 

To achieve the objectives of the FWPP, a transportation system would be needed in order to 

access the area with log trucks, chip vans and other equipment needed to perform the required 

fuel reduction and timber removal work. Access is also needed for work such as non-commercial 

tree thinning and prescribed burning. 

The three action alternatives have different transportation system requirements for two reasons. 

First, the same acres are not treated under all alternatives. This changes the access needs and the 

transportation system required. Secondly, different alternatives employ different harvest systems 

that have their own unique transportation requirements. 

Transportation systems used under all action alternatives would utilize a combination of existing 

Forest Service system roads, Forest Service system roads that are relocated to reduce erosion, one 

decommissioned road that would be converted to a system road, new temporary roads and 

temporary roads that would be placed on existing road prisms. Roads that are no longer needed 

for management of the National Forest would also be decommissioned under this EIS. 

This section details the transportation system that would be needed to carry out the project under 

each of the alternatives and any changes that are proposed to the current travel management road 

status. 

Road Systems Common to All Action Alternatives

Road Relocations

Under all alternatives, three roads within the project area are being proposed for partial 

relocation. These roads are FR 9466x at Mormon Mountain, FR 6353 and FR 789 in the DLH

area. 

FR 9466x- This is road is currently limited to Forest Service administrative use only. The 

majority of this road has an acceptable grade. However approximately 0.19 miles are a steep 

grade, (up to 14 percent) on shelf rock that is barely passable to a 4-wheeled drive pick-up. It is 

not suitable as a haul route for log trucks. This unusable segment would be decommissioned and 

replaced by a road segment of approximately 0.53 miles that would have a grade of 

approximately 8 percent. This would reduce erosion from the road’s surface and facilitate use by 

log trucks and chip vans. FR 9466x’s travel management status would remain, “Limited Forest 

Service administrative use only.” This road would not be open to the public for motorized use 

under any alternative.

FR 6353- This is road is currently limited to Forest Service administrative use only. Much of this 

road is usable for log hauling in its currently location. However approximately 1.12 miles have 

segments where grades are up to 16 percent and the road is oriented straight up and down the 

slope. In many of these areas the road has been eroded nearly 1.5 feet deep. These road 

segments are an ongoing erosion problem and would be very difficult to drain the water from due 

to the orientation straight up and down the slope and the fact that they are now deeply incised into 

the ground. These segments would be decommissioned and replaced with roads that have an 8

percent grade or less and be constructed so that they have a side that the water can be diverted off 

the road to prevent water running the length of the road causing erosion. FR 6353’s travel 

management status would remain, “Limited Forest Service administrative use only.” This road 

would not be open to the public for motorized use under any alternative.
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 71

FR 789- FR 789 begins at a junction with the FR 420, (the Schultz Pass road). The old road 

location crosses Schultz creek at this point and is currently closed with a gate. It then climbs to 

the mesa on top of the Dry Lake Hills and passes through a parcel of land owned by the Navajo 

Nation. The road passes close to the seasonal lake on the top of Dry Lake Hills and terminates on 

the western edge of mesa at the steep slopes that overlook the Cheshire neighborhood. While the 

road location is evident throughout its route, in some places it has been reduced to little more than 

a trail; this occurs mainly to where it passes through flat grasslands. 

FR 789 provides the only access to the top of the Dry Lake Hills; however this road is currently 

decommissioned. Under the current proposal there are a number of temporary spur roads that 

would branch off from it in all alternatives. FR789 would also provide access for fire protection 

for the entire area between the Schultz Pass road and the Elden Lookout road. This road is also 

needed to provide access for thinning, fuel reduction work and prescribed burning after timber 

harvesting. For these reasons FR789 would be restored to the Coconino Forest road system with 

a travel management status of “Limited Forest Service administrative use only.” 

Road 789 would be relocated or rerouted in two areas. It would be rerouted to an existing road 

prism that is now used as a trail at segment “E” on the transportation map for all alternatives. 

Road 789 would no longer begin at the junction with the 420 road, it would tie into the 6353 road 

and have its beginning at that point. FR 789 would also be relocated at segment “HH” on the 

transportation map. This would allow the road to avoid an unusably steep segment. 

As mentioned earlier FR 789 passes through a parcel of land owned by the Navajo Nation. If it is 

not possible to utilize this portion of FR789, the road would be rerouted to use segments FF and P 

which are currently planned as temporary roads. If FR 789 is rerouted onto these segments they 

would become part of FR789.

This road would not be open to the public for motorized use under any alternative.

Haul Routes: Use of Public Roads by Forest Service Contractors

Forest Service contractors have the right to legally use public roads within and outside of the 

project area, subject to regulation by the public entity charged with jurisdiction of that roadway. 

In order to move timber from the project area to processing facilities, it would be necessary for 

heavy trucks to use public roads through a portion of the city of Flagstaff. The Forest Service 

may only restrict haul routes or timing of routes used by contractors on the National Forest in 

order to provide for public safety. The Forest Service cannot dictate the routes the contractor uses 

once they leave the forest. The routes here are only potential options that could be used.

Dry Lake Hills

This project would utilize several primary haul routes for log trucks and chip vans. For the Dry 

Lake Hills portion of the project these roads would be FR 557, the Elden Lookout road, FR 420 

the Schultz Pass road, FR 556 the Elden Springs road and FR 522 and FR 516 the Snowbowl 

road. All of the timber removed from Mt Elden and the timber from the flats to the west of Mt 

Elden would use the Mt Elden Lookout road to its junction with the Schultz Pass road and then 

enter State Highway 180. Under Alternatives 2 and 3, approximately 3,800 truckloads would use 

this route. Under Alternative 4 approximately 2,600 truckloads would use this route.

Nearly all of the area between Mt Elden Lookout road and Schultz Pass road as well as a portion 

of the project north of the Schultz pass road either be hauled down the Schultz Pass road to 

Highway 180 or on FR 556, the Elden Spring road to US Highway 89. Under Alternatives 2 and 3 
Chapter 2. Alternatives

72 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

approximately 5,200 truckloads would use these routes. Under Alternative 4 approximately 4,200 

truckloads would use these routes.

The very northern portion of the project would be hauled on FR 522 to the Snowbowl road and 

then onto State Highway 180. Under alternatives 2 and 3 approximately 200 truckloads would use 

this route. Under Alternative 4 no loads would be hauled on this route.

Trucks that haul onto State Highway 180 would most likely use N. Switzer Canyon Road to reach

east Route 66. These loads would use Ponderosa Parkway and E. Butler Ave to enter Interstate 

40 at the east Butler Ave interchange, exit 198. Trucks hauling to US Highway 89 would likely 

use East Route 66 to Country Club Drive and enter Interstate 40 at the Country Club interchange, 

exit 201. However, as mentioned previously, these are potential route options; the Forest Service 

cannot dictate where the contractor(s) go once they leave the National Forest. 

Mormon Mountain

Timber hauled from Mormon Mtn. could be either hauled to Interstate 17 at Munds Park via FSR 

240 or onto the Lake Mary road via county road 90. Both of these routes would utilize FR 132, 

132A, 648 and 240 as well as County road 90. Under alternative 2 approximately 4,800 

truckloads would haul on these routes. Under Alternatives 3 and 4 approximately 4,700 

truckloads would use these routes.

Temporary Roads

Existing roads would be used to the extent possible for hauling harvested trees. Forest Roads (FR) 

420, 556 and 557 would be used as the main haul routes for DLH; FR 132, 132A, and 648 would 

be used as the main haul routes for MM. Maintenance on these roads would be necessary prior to 

implementation, including reconditioning and resurfacing of FR 420, 556 and 132. In addition, 

there may be a need to transport harvested trees through the City of Flagstaff to access the 

Interstate system (I-40 and I-17). 

However, it is likely that not all treatment areas would be accessible by existing roads. The exact 

number temp roads required varies by alternative (see the discussion of alternatives below). 

Temp roads are designed to serve as short term access to a specific area for timber removal and 

follow up treatments such as prescribed burning. Where possible, temporary roads would be 

located on existing road prisms (e.g. where historic road beds are still identifiable); however new 

temporary roads in previously undisturbed areas are also anticipated (see Table 28). The locations 

of temporary roads are estimated based on treatment areas. The precise location of temporary 

roads cannot be determined until a contract for treatment is secured and the type of equipment to 

be used is determined; however no temporary roads would be located within MSO nest cores. All 

temporary roads, landings, and skid trails used would be pre-approved by the Forest Service 

Timber Sale Administrator in accordance with resource protection measures. In addition, three 

roads within the project area are being proposed for partial relocation. These roads are FR 9466x 

on MM (approximately 0.53 miles relocated), and FR 6353 and FR 789 in the DLH area

(approximately 1.57 miles relocated total). 

Following completion of work in the area they serve, these temp roads would be rehabilitated and 

made impassable to vehicles. Rehabilitation work could consist of several actions including but 

not limited to: re-contouring, scarifying the road surface, grass seeding, constructing earthen 

berms to prevent erosion and discourage traffic and placing slash on the road surface. 

It is likely that road prisms of temporary roads would still be at least partially visible after 

rehabilitation work is completed. The term “rehabilitation” is used in this document to describe 

this type of post project work done on these roads rather than the term “decommission” in order 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 73

to avoid potential confusion. Decommissioning as used in this document refers to removing a 

Forest Service system road from its current status and placing it into a decommissioned status 

where it is no longer considered part of the forest’s road system. 

The majority of the temp roads proposed in this project are “new temps.” This means that a 

temporary road is planned in an area where no road prism currently exists. Other temp roads are 

being placed on an existing road prism. These existing prisms are either user created roads or are 

roads that have been decommissioned from the Coconino Forest’s road system in the past. In 

either case, they are not Forest Service system roads and if they are to be used, they are 

considered temp roads. In the detailed roads tables for each alternative these roads are designated 

as “Haul Road- temp on existing road prism.” Following completion of work in the area they 

serve, they would be rehabilitated in the same manner as new temp roads.

Changes in Road Travel Management Status

Forest Service roads are classified into several categories for travel management purposes:

Open to all vehicles- The road is open to all types of vehicles

Open to highway legal vehicles- The road is open only to highway legal vehicles

Closed- The road is closed to all vehicles and can only be opened for use by completing a NEPA 

document

Limited to Forest Service Administrative Use- The road is closed to all vehicles except for Forest 

Service vehicles on official business and those of Forest Service cooperators, contractors 

and permittees.

Decommissioned- The road has been decommissioned and is no longer considered a Forest 

Service system road. It is not open for use. If it is to be used, it must be as a new 

temporary road or be restored to a system road under a NEPA document.

This EIS proposes some changes in travel management status and also proposes to decommission 

several roads that are no longer needed for management purposes. It does not make any changes 

to roads that are open to the public. The current level of public access would not change. These 

proposed changes are listed in the detailed road listing for each alternative and are summarized in

Table 14. They are the same under all action alternatives.

Road Decommissioning and Closures

The project area contains approximately 26.5 miles of roads closed to motorized travel through 

the Travel Management Rule (TMR) decision (September 2011). Under all action alternatives, 

approximately 4.19 miles in the DLH and 0.19 miles in MM of these roads would be 

decommissioned upon project completion. Preventing unauthorized motor vehicle use on these 

routes would limit the potential for human-ignited wildfires in the project area, restore forest 

vegetation, and reduce the potential for increased erosion subsequent to a fire. The term 

“rehabilitation” is used in this document to describe this type of post project work done on these 

roads rather than the term “decommission” in order to avoid potential confusion. 

Table 14: Roads within the FWPP area, their current status and proposed status postimplementation for all action alternatives

Road Number Mileage Current Status Post Project Status

789 1.829 Decommissioned/Converted FS Admin use only
Chapter 2. Alternatives

74 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Road Number Mileage Current Status Post Project Status

6274 0.411 FS Admin use only Decommissioned/Converted

6275 (only a portion) 0.109 FS Admin use only Decommissioned/Converted

6353 (Only a portion) 1.12 FS Admin use only Decommissioned/Converted

6356 0.496 FS Admin use only Decommissioned/Converted

6361 0.172 FS Admin use only Decommissioned/Converted

9122 J 0.217 FS Admin use only Decommissioned/Converted

9129 Y 0.445 Closed Unless Open with NEPA Decommissioned/Converted

9166 K 0.827 Closed Unless Open with NEPA Decommissioned/Converted

9166 M 0.134 Closed Unless Open with NEPA Decommissioned/Converted

9173 D 0.265 Closed Unless Open with NEPA Decommissioned/Converted

9466 X (Only a 

portion)

0.19 FS Admin use only Decommissioned/Converted

Appropriate action would be taken on roads that are decommissioned under this EIS as well as 

previously decommissioned roads within the project area which require additional rehabilitation 

work to reduce erosion and discourage vehicle use. These actions could include but not be 

limited to: re-contouring, scarifying the road surface, grass seeding, constructing earthen berms 

and placing slash on the road surface.

Road Maintenance

Road maintenance on roads that receive substantial used by the public are often maintained by the 

Forest Service on a regular basis as funding allows. When there is a substantial increase in use of 

a road by a Forest Service contractor for uses such as log hauling, the associated contractor is 

usually required to perform maintenance both during and after their use of the road commensurate 

with their use. This maintenance is often blading and reshaping of the road surface. Road 

maintenance on roads that are closed to the public would be performed by the logging contractor. 

On this project maintenance could also include applying dust abatement on approximate 0.70 

miles of FR 556 and 0.25 miles on FR 420. Both of these segments are adjacent to residences 

where road dust has the potential to be a concern.

Alternative 2: Proposed Action with Cable Logging Proposed Transportation System

Under Alternative 2, the following actions would occur regarding road use on the DLH and MM 

areas, respectively. 

Dry Lake Hills

System haul roads within the project area 18.07 miles

System haul roads outside the project area 14.33 miles
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 75

New temporary haul roads constructed 14.64 miles

Temporary roads on existing road prisms 2.75 miles

Temporary roads rehabilitated 17.39 miles

Relocated system road used for hauling 1.57 miles

System roads decommissioned 4.19 miles

Mormon Mountain

System haul roads within the project area 16.46 miles

System haul roads outside the project area 18.13 miles

New temporary haul roads constructed 1.07 miles

Temporary roads on existing road prisms 2.52 miles

Temporary road rehabilitated 3.59 miles

Relocated system road used for hauling 0.53 miles

System roads decommissioned 0.19 miles
Chapter 2. Alternatives

76 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 27: Proposed Transportation System for Alternative 2, DLH
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 77

Figure 28: Proposed Transportation System for Alternative 2, MM

Mitigation Measures Specific to Alternatives 2 and/or 3
Chapter 2. Alternatives

78 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 15 contains only those migration measures specific to Alternatives 2 and/or 3. The general 

mitigation measures listed in Table 24 would also apply to these alternatives.
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 79

Table 15: Mitigation Measures Specific to Alternatives 2 and/or 3

Specialist Area Related 

Resource Mitigation Measure

Soils/Watershed Timber 

Operations

Skid trails and cable yarding corridors would be 

restored after use by a combination of any or all 

of the following practices in order to prevent the 

concentration of runoff in skid trails and to 

protect exposed soil: reshaping the surface to 

promote dispersed drainage (i.e., create convex 

vs. concave cross-section), installation of 

drainage features such as water bars to shed 

water, and spreading slash across skid trails and 

cable yarding corridors to protect areas where 

mineral soil is exposed. Where skid trails and or 

cable yarding corridors intersect existing roads or 

trails, native materials such as logs, slash, and/or 

boulders would be placed along skid trail or cable 

corridor to line-of-sight or first 300’, whichever is 

greater. 

Mexican Spotted 

Owl

No cable or helicopter logging would occur 

within MSO nest/cores.

Northern Goshawk

Helicopter paths would be reviewed to exclude 

flights over occupied nest locations during the 

northern goshawk breeding season.

Wildlife

Red Squirrels

Retain all trees within a 26-foot radius from 

cache (1/20th acre). Within cable and 

helicopter units, snags may be felled within 

the 26-foot radius for safety reasons. Caches 

would still be protected and live trees would 

be retained except where cable corridors 

overlap with that buffer. Additional caches 

would be protected outside of cable logging 

units to compensate.

Leave snag patch placement would be 

coordinated with existing red squirrel caches.

Other Wildlife

An implementation guide would be 

developed in coordination with FWS to 

minimize the impacts of helicopter operations 

(i.e. helilanding locations, flight patterns) on 

nesting birds (MSO, peregrines, eagles, 

northern goshawks, etc.). 

Snags

In areas where large snags are cut for safety 

purposes, fallen trees would be left on site as 

needed for wildlife habitat while still 

lowering overall fuel loadings to meet desired 

conditions.

Biologists would identify patches of snags up 

to 10 acres in size in advance of treatment 

unit layout in cable and helicopter logging 
Chapter 2. Alternatives

80 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Specialist Area Related 

Resource Mitigation Measure

areas. This would allow for the protection of 

patches of snags at the ecosystem 

management area level that could serve as a 

reserve area for areas/acres where we are 

unable to maintain snags during operations. 

Patch locations would be identified with 

consideration for red squirrel caches (see Red 

Squirrel Design Features above).

Where helicopter logging is used, consider 

using patch cuts in order to break up fuels. 

This would allow for the maintenance of 

snags outside the patches, but would allow 

for greater removal of trees (live and dead) 

and operational safety within the patches. 

Use logging systems when feasible in 

sensitive habitats that can meet project 

objectives and maintain important structural 

components (e.g., snags, etc.). 

Alternative 3: Proposed Action without Cable Logging

Alternative 3 would be similar to Alternative 2 in that the described treatments would be the same

(see Table 16); however this alternative would address visual concerns and distribution of snags 

and large trees due to the absence of proposed cable corridors. Under Alternative 3, treatments 

would utilize ground-based harvesting across the majority of the project area, with helicopter 

logging for critical areas that are too steep, rocky, or inaccessible to be treated by steep slope 

ground-based equipment (see Table 17 and Figure 29 and Figure 30). No cable logging would 

occur under this alternative, which would reduce the need to remove some large trees and snags 

on steep slopes and also the need to create corridors. The enclosed cabs of steep-slope machinery 

precludes the need to remove hazard trees, and though areas proposed for treatment by helicopter 

would still need to have hazard trees removed, the distribution of snags and large trees could be 

factored into treatment placement more easily. 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 81

Figure 29: Alternative 3 Proposed Treatments, DLH
Chapter 2. Alternatives

82 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 30: Alternative 3 Proposed Treatments, MM
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 83

Table 16: Alternative 3 Proposed Treatment Descriptions, Objectives and Acres

Treatment Type Treatment Description/Objective Acres

Ponderosa Pine Fuels 

Reduction

(Northern Goshawk LOPFA 

Areas)

These treatments areas are outside of MSO 

PACs and northern goshawk PFAs and nest 

cores. Mechanical treatment designed to 

develop uneven-aged structure and a mosaic 

of openings and tree groups of varying sizes. 

Openings would occupy approximately 20

percent of the treatment area. Tree groups 

would vary in shape, size, density, and 

number: generally from 0.05 – 0.7 acres in 

size with residual group basal areas of 20-80 

ft2 per acre and 2-40 trees per group. 

1865 – Dry Lake 

Hills (DLH)

766 – Mormon 

Mountain (MM)

Ponderosa Pine Fuels 

Reduction – Hand Thinning

(Northern Goshawk LOPFA 

Areas)

This treatment includes steep areas that have

low tree density and/or are dominated by 

smaller diameter trees where the purpose and 

need can be met through hand felling 

treatments. Where practical and feasible, 

treatments would be designed to develop 

uneven-aged structure and a mosaic of tree 

groups of varying sizes similar to the 

treatment described above.

150 - DLH

Mixed Conifer Fuels 

Reduction

(MSO Recovery Areas)

These treatments areas include dry mixed 

conifer areas outside of MSO PACs, 

replacement nest/roost habitat, and northern 

goshawk PFAs and nest cores, but include 

MSO restricted habitat. Mechanical 

treatment designed to develop uneven-aged 

structure and a mosaic of openings and tree 

groups of varying sizes. Trees above 24” dbh 

would not be cut. Openings would occupy 

about 10-20 percent of the treatment area. 

Tree groups would vary in shape, size, 

density, and number: generally less than one 

acres in size with residual group basal areas 

of 30-90 ft2 per acre and 2-50 trees per 

group

1158 - DLH

Mixed Conifer Fuels 

Reduction – Hand Thinning

(MSO Recovery Areas)

This treatment includes areas where fuels 

reduction objectives can be met through hand 

thinning of trees < 9” dbh; where mechanical 

treatment could cause high levels of resource 

damage; or where mechanical treatments 

would be cost-prohibitive.

85 - DLH
Chapter 2. Alternatives

84 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Treatment Type Treatment Description/Objective Acres

Ponderosa Pine Fuels 

Reduction

(Northern Goshawk LOPFA 

Areas)

These treatments areas are outside of MSO 

PACs and northern goshawk PFAs and nest 

cores. Mechanical treatment designed to 

develop uneven-aged structure and a mosaic 

of openings and tree groups of varying sizes. 

Openings would occupy approximately 20

percent of the treatment area. Tree groups 

would vary in shape, size, density, and 

number: generally from 0.05 – 0.7 acres in 

size with residual group basal areas of 20-80 

ft2 per acre and 2-40 trees per group. 

1865 – Dry Lake 

Hills (DLH)

766 – Mormon 

Mountain (MM)

MSO PAC Fuels Reduction -

Wet Mixed Conifer 

Mechanical treatment within the wet mixed 

conifer vegetation type would create small 

openings within aspen stands to promote 

regeneration. Dead and down material would 

be piled for burning to reduce the heavy fuel 

loading and allow for lower-intensity 

prescribed burning. 

180 - MM

MSO PAC Fuels Reduction Mechanical treatment to create a diversity of 

patch sizes with minimum patch size of 2.5 

acres. Provide for 10 percent openings across 

treatment areas from 0.1 – 2.5 acres in size. 

Maintain a minimum of 40 percent canopy 

cover in pine/pine-oak and 60 percent in 

mixed conifer. Post-treatment, trees greater 

than 16” dbh would contribute at least 50 

percent of the stand basal area per MSO 

Recovery Plan guidelines (2012). Trees 

above 18” dbh would not be cut except if 

necessary for cable corridor locations.

1195 – DLH

1592 - MM

MSO PAC Fuels Reduction –

Hand Thinning

This treatment includes steep areas which 

have low density and dominated by smaller 

trees or are in areas not conducive to cable 

yarding operations. Treatments where 

feasible would treat stand similar to the MSO 

PAC treatment described from above. 

Otherwise treatments would be thin from 

below to reduce density and fuel ladders.

202 – DLH 

MSO Nest Fuels Reduction -

Hand Thinning

Hand thinning up to 5” dbh would occur 

within 80 % of the Schultz Creek nest core in 

coordination with the US Fish and Wildlife 

Service (122 acres, DLH). Approximately 

20% of the nest core would be deferred from 

treatment in order to maintain denser patches 

122 – DLH
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 85

Treatment Type Treatment Description/Objective Acres

Ponderosa Pine Fuels 

Reduction

(Northern Goshawk LOPFA 

Areas)

These treatments areas are outside of MSO 

PACs and northern goshawk PFAs and nest 

cores. Mechanical treatment designed to 

develop uneven-aged structure and a mosaic 

of openings and tree groups of varying sizes. 

Openings would occupy approximately 20

percent of the treatment area. Tree groups 

would vary in shape, size, density, and 

number: generally from 0.05 – 0.7 acres in 

size with residual group basal areas of 20-80 

ft2 per acre and 2-40 trees per group. 

1865 – Dry Lake 

Hills (DLH)

766 – Mormon 

Mountain (MM)

for habitat. Residual basal area would be a 

minimum of 110 ft2, and treatment would 

maintain a minimum of 60% canopy cover in 

mixed conifer. This nest core would also 

receive the prescribed burning treatment 

described below

MSO Nest Fuels Reduction -

Burn Only

In all nest cores other than the Schultz Creek 

nest core, treatment would consist of burning 

only. Dead and down material in MSO nest 

cores would be piled by hand and burned.

261 – DLH

402 – MM

MSO Nest/Roost RecoveryHand ThinningHand thinning up to 9” dbh would occur on 

72 acres in DLH under this treatment, and 

dead trees less than 12” dbh and down 

material would be cut and piled by hand for 

prescribed burning. 

72 - DLH

MSO Nest/Roost RecoveryBurn OnlyThirty-seven acres of Nest/Roost Recovery 

habitat would be prescribed burned only (no 

hand thinning). Snag retention guidelines 

identified in the Forest Plan would still be 

followed (see Design Features – Snags).

Treatments would be designed to move the 

stands towards minimum desired conditions: 

Residual basal area of 110 ft2 in ponderosa 

pine, and 120 ft2 in mixed conifer; canopy 

cover of 40 percent in pine/pine-oak and 60 

percent in mixed conifer; 12 trees per acre 

greater than 18” diameter; trees from 12-18” 

dbh would comprise over 30 percent of 

stands BA, and trees greater than 18 inches 

would comprise an additional 30% of BA.

37 - DLH

MSO Nest/Roost Recovery –

Mechanical Thinning

Mechanical treatment would remove 

ponderosa pine in a variety of size classes up 

to 24” dbh. Target basal area would be 95 

ft2, and no oak would be cut. 

22 - MM
Chapter 2. Alternatives

86 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Treatment Type Treatment Description/Objective Acres

Ponderosa Pine Fuels 

Reduction

(Northern Goshawk LOPFA 

Areas)

These treatments areas are outside of MSO 

PACs and northern goshawk PFAs and nest 

cores. Mechanical treatment designed to 

develop uneven-aged structure and a mosaic 

of openings and tree groups of varying sizes. 

Openings would occupy approximately 20

percent of the treatment area. Tree groups 

would vary in shape, size, density, and 

number: generally from 0.05 – 0.7 acres in 

size with residual group basal areas of 20-80 

ft2 per acre and 2-40 trees per group. 

1865 – Dry Lake 

Hills (DLH)

766 – Mormon 

Mountain (MM)

Northern Goshawk Post 

Fledging Areas (PFA) Fuels 

Reduction

Uneven-age mechanical treatment designed 

to develop uneven-aged structure and a 

mosaic of tree groups of varying sizes. 

Openings would occupy 20 percent of the 

treatment area. Tree groups would vary in 

shape, size, density, and number: generally

from 0.05 – 0.7 acres in size with residual 

group basal areas of up to 30-90 ft2 per acre 

and 2-40 trees per group

359 - DLH

Northern Goshawk Nest Fuels 

Reduction

Mechanical treatment designed to develop 

northern goshawk nest stand conditions 

consisting of a contiguous over-story of large 

trees. Forest Plan guidelines for canopy 

cover would be met: canopy cover would 

vary from 50 to 70 percent.

100 - DLH

Aspen Treatment A variety of different treatments would be 

used to promote and protect aspen health and 

regeneration, including the removal of post 

settlement conifers within 100 feet of aspen 

clones, prescribed fire, ripping, planting, 

fencing and/or cutting of aspen to stimulate 

root suckering.

22 – DLH

Grassland Restoration Mechanical treatment to remove encroaching 

post-settlement conifers and restore the presettlement tree density and patterns.

60 – DLH

Burn Only Burn only treatment would remove excessive 

fuel loading in areas which were previously 

burned by the Radio Fire.

270 - DLH

Electronic Site – Structure 

Protection

These sites are occupied by 

telecommunication facilities, and would be 

treated to provide a sufficient defensible 

space around these structures from a 

6 – DLH

12 - MM
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 87

Treatment Type Treatment Description/Objective Acres

Ponderosa Pine Fuels 

Reduction

(Northern Goshawk LOPFA 

Areas)

These treatments areas are outside of MSO 

PACs and northern goshawk PFAs and nest 

cores. Mechanical treatment designed to 

develop uneven-aged structure and a mosaic 

of openings and tree groups of varying sizes. 

Openings would occupy approximately 20

percent of the treatment area. Tree groups 

would vary in shape, size, density, and 

number: generally from 0.05 – 0.7 acres in 

size with residual group basal areas of 20-80 

ft2 per acre and 2-40 trees per group. 

1865 – Dry Lake 

Hills (DLH)

766 – Mormon 

Mountain (MM)

wildland fire. Individual trees that are 

determined to contribute to wildfire risk or 

pose a hazard to the electronic sites would be 

removed. The remainder of the sites would 

receive a thin from below to approximately 

20 – 40 ft2 basal area with the purpose of 

raising the crown base height and leaving the 

largest and most fire resistant trees.

No Treatment (No New 

Analysis)

These acres include non-treatable areas, 

including rock faces and boulder fields, and 

the Orion Timber Sale (approximately 837

acres). Though the Timber Sale is within the 

project boundary, the treatments for that area 

were analyzed and authorized under the Jack 

Smith Schultz Fuels Reduction and Forest 

Health Restoration Project Decision 

Notice/Finding of No Significant Impact 

(2008). No additional treatments within the 

Timber Sale area are proposed under FWPP. 

1605 - DLH

Table 17: Alternative 3 Harvesting Methods for DLH

Treatment Type GroundbasedHand 

Cut/Piled

Helicopter Burn 

Only

Steep Slope 

Equipment

TOTAL

Ponderosa Pine 

Fuels Reduction

1613 242 10 1865

Ponderosa Pine 

Fuels Reduction –

Hand Thinning

150 150

Mixed Conifer 

Fuels Reduction

626 425 107 1158

Mixed Conifer 

Fuels Reduction –

Hand Thinning

85 85
Chapter 2. Alternatives

88 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Treatment Type GroundbasedHand 

Cut/Piled

Helicopter Burn 

Only

Steep Slope 

Equipment

TOTAL

MSO PAC Fuels 

Reduction

793 267 135 1195

MSO PAC Fuels 

Reduction – Hand 

Thinning

202 202

MSO Nest Fuels 

Reduction

122 261 383

MSO Nest/Roost 

Recovery

72 37 109

Goshawk PFA 

Fuels Reduction

299 39 21 359

Goshawk Nest 

Fuels Reduction

100 100

Aspen Treatment 22 22

Grassland 

Restoration

60 60

Burn Only 270 270

Electronic SiteStructure 

Protection

6 6

No Treatment/No 

New Analysis

- - - - - 1605

TOTAL 3497 652 973 568 273 7569

Table 18: Alternative 3 Harvesting Methods for MM

Treatment Type GroundbasedHand 

Cut/Piled

Burn 

Only

Steep Slope 

Machinery

TOTAL

Ponderosa Pine Fuels Reduction 766 767

MSO PAC Fuels Reduction 1519 73 1592

MSO PAC Fuels Reduction –

Wet Mixed Conifer

180 180

MSO Nest Fuels Reduction 402 402

MSO Nest/Roost Recovery 22 22

Electronic Site-Structure 

Protection

12 12

TOTAL 2321 180 402 73 2,975

Required Transportation System

Alternative 3: Proposed Action without Cable Logging Proposed Transportation System

Under Alternative 3 the following actions would occur regarding road use, on the Dry Lake Hills 

and Mormon Mountain areas, respectively. 

Dry Lake Hills
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 89

System haul roads within the project area 18.07miles

System haul roads outside the project area 14.33 miles

New temporary haul roads constructed 9.91 miles

Temporary roads on existing road prisms 2.75 miles

Temporary road rehabilitated 12.66 miles

Relocated system road used as haul road 1.57 miles

System road decommissioned 4.19 miles

Mormon Mountain

System haul roads within the project area 16.46 miles

System haul roads outside the project area 18.13 miles

New temporary haul roads constructed 0.0 miles

Temporary roads on existing road prisms 2.52 miles

Temporary road rehabilitated 2.52 miles

Relocated system road used for hauling 0.53 miles

System roads decommissioned 0.19 miles
Chapter 2. Alternatives

90 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 31: Proposed Transportation System for Alternative 3, DLH
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 91

Figure 32: Proposed Transportation System for Alternative 3, MM

Alternative 4: Minimal Treatment Approach

This alternative would be similar to Alternatives 2 and 3; however the purpose of Alternative 4 is 

to implement the minimum amount of treatment necessary to meet the purpose and need. 

Treatments are proposed for those areas with dense fuel loading where topography aligns with 

dominant winds and the probability of severe effects to soil resources from a wildfire is greater,

based on FLAM MAP 5.0 modeling of both fire behavior and fire spread under Schultz fire 

weather conditions. Specifically, factors considered include: fire risk rating, potential damage to 

soils (from high severity fire and also harvesting methods), MSO habitat, and the type of 

harvesting methods necessary to affect change. 

Under Alternative 4, approximately 3,459 acres along the base of Dry Lake Hills and Mount 

Elden and the upper, flatter tops would receive basically the same treatments proposed in 

Alternatives 2 and 3, though under this alternative more areas are proposed for hand thinning and 
Chapter 2. Alternatives

92 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

prescribed burning instead of cable or helicopter logging in order to reduce the potential impacts 

from temporary road network associated with those harvesting methods (roughly 46 percent of 

the DLH project area). Additionally, treatments are focused on the area south and east of FR420 

(Figure 33); the portion of the project area between FR420 and the Kachina Peaks Wilderness 

would still be treated but under the constraints of the analysis and decision for the Jack Smith 

Schultz Fuels Reduction and Forest Health Restoration Project. Thus, no new analysis would be 

performed for those areas under this alternative. 

The Spruce Avenue Wash was identified as a high priority area due to the fuel loading, 

topography, size and also its location relative to the City of Flagstaff and MSO PACs. The 

portion of the Mount Elden MSO PAC within the Spruce Avenue Wash would also be treated 

under the same parameters described in Alternatives 2 and 3. The Schultz Creek MSO PAC and 

nest core were identified in conjunction with the FWS as high priority areas, and would also 

receive the same treatment described for Alternatives 2 and 3.

For MM, treatments would occur on 2,343 acres (Figure 34). The same methodology used for 

treatment placements in the DLH area was applied to MM to determine where to focus 

treatments. Under Alternative 4, the wet mixed conifer belt and MSO nest cores would not be 

treated, (roughly 21 percent of the MM area); however treatments would occur below and above 

that belt. 

Areas not included in this alternative would be designated as No Treatment. All treated acres 

would include prescribed burning in the manner described under Alternative 2: initially pile 

burning to remove slash accumulated through harvesting, followed by broadcast burning. 

Maintenance burning may occur every five to seven years following implementation in order to 

maintain lower fuel loading levels and to restore a frequent, low-severity fire regime. Mixed 

conifer on steep slopes may only receive one broadcast burn through the life of the project due to 

the difficulty of implementation in these fuel types and terrain, and also because the historic Fire 

Return Interval in some vegetation types is historically longer than the life of this project. Other 

slash removal options as described in the Implementation Methods section could also be used in 

lieu of burning, including biomass removal.
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 93

Figure 33: Alternative 4 Proposed Treatments, DLH
Chapter 2. Alternatives

94 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 34: Alternative 4 Proposed Treatments, MM

Table 19: Alternative 4 Proposed Treatment Descriptions, Objectives and Acres

Treatment Type Treatment Description/Objective Acres

Ponderosa Pine Fuels 

Reduction

(Northern Goshawk LOPFA 

Areas)

These treatments areas are outside of MSO 

PACs and northern goshawk PFAs and nest 

cores. Mechanical treatment designed to 

develop uneven-aged structure and a mosaic 

of openings and tree groups of varying sizes. 

Openings would occupy approximately 20

percent of the treatment area. Tree groups 

would vary in shape, size, density, and 

1400– Dry Lake 

Hills (DLH)

766– Mormon 

Mountain (MM)
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 95

Treatment Type Treatment Description/Objective Acres

number: generally from 0.05 – 0.7 acres in 

size with residual group basal areas of 20-80 

ft2 per acre and 2-40 trees per group. 

Ponderosa Pine Fuels 

Reduction – Hand Thinning

(Northern Goshawk LOPFA 

Areas)

This treatment includes steep areas that have

low tree density and/or are dominated by 

smaller diameter trees where the purpose and 

need can be met through hand felling 

treatments. Where practical and feasible, 

treatments would be designed to develop 

uneven-aged structure and a mosaic of tree 

groups of varying sizes similar to the 

treatment described above.

86- DLH

Mixed Conifer Fuels 

Reduction

(MSO Recovery Areas)

These treatments areas include dry mixed 

conifer areas outside of MSO PACs, 

replacement nest/roost habitat, and northern 

goshawk PFAs and nest cores, but include 

MSO restricted habitat. Mechanical 

treatment designed to develop uneven-aged 

structure and a mosaic of openings and tree 

groups of varying sizes. Trees above 24” dbh 

would not be cut. Openings would occupy 

about 10-20 percent of the treatment area. 

Tree groups would vary in shape, size, 

density, and number: generally less than one 

acres in size with residual group basal areas 

of 30-90 ft2 per acre and 2-50 trees per 

group

542- DLH

MSO PAC Fuels Reduction Mechanical treatment to create a diversity of 

patch sizes with minimum patch size of 2.5 

acres. Provide for 10 percent openings across 

treatment areas from 0.1 – 2.5 acres in size. 

Maintain a minimum of 40 percent canopy 

cover in pine/pine-oak and 60 percent in 

mixed conifer. Post-treatment, trees greater 

than 16” dbh would contribute at least 50 

percent of the stand basal area per MSO 

Recovery Plan guidelines (2012). Trees 

above 18” dbh would not be cut except if 

necessary for cable corridor locations.

568– DLH

1509- MM14

MSO PAC Fuels Reduction –

Hand Thinning

This treatment includes steep areas which 

have low density and dominated by smaller 

trees. Treatments where feasible would treat 

stand similar to the MSO PAC treatment 

described from above. Otherwise treatments 

would be thin from below to reduce density 

228– DLH 

 

14 Thirty-three acres within MSO PACs on MM are included in the Burn Only treatment description, and would not 

receive mechanical thinning. Those acres are shown in the Burn Only treatment acres, and are not counted toward the 

total displayed for MSO PAC Fuels Reduction here. 
Chapter 2. Alternatives

96 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Treatment Type Treatment Description/Objective Acres

and fuel ladders.

MSO Nest Fuels Reduction Hand thinning up to 5” dbh and prescribed 

burning would occur within 80% the Schultz

Creek nest core in coordination with the US 

Fish and Wildlife Service (122 acres, DLH). 

Dead and down material in the Schultz Creek

nest core would also be piled by hand and 

burned.

122– DLH

MSO Nest/Roost Recovery Mechanical treatment would remove 

ponderosa pine in a variety of size classes up 

to 24” dbh. Target basal area would be 95 

ft2, and no oak would be cut. Snag retention 

guidelines identified in the Forest Plan would 

still be followed (see Design Features –

Snags). Treatments would be designed to 

move the stands towards minimum desired 

conditions: Residual basal area of 110 ft2 in 

ponderosa pine, and 120 ft2 in mixed 

conifer; canopy cover of 40 percent in 

pine/pine-oak and 60 percent in mixed 

conifer; 12 trees per acre greater than 18” 

diameter; trees from 12-18” dbh would 

comprise over 30 percent of stands BA, and 

trees greater than 18 inches would comprise 

an additional 30% of BA.

22 - MM

Northern Goshawk Post 

Fledging Areas (PFA) Fuels 

Reduction

Uneven-age mechanical treatment designed 

to develop uneven-aged structure and a 

mosaic of tree groups of varying sizes. 

Openings would occupy 20 percent of the 

treatment area. Tree groups would vary in 

shape, size, density, and number: generally 

from 0.05 – 0.7 acres in size with residual 

group basal areas of up to 30-90 ft2 per acre 

and 2-40 trees per group

286- DLH

Northern Goshawk Nest Fuels 

Reduction

Mechanical treatment designed to develop 

northern goshawk nest stand conditions 

consisting of a contiguous over-story of large 

trees. Forest Plan guidelines for canopy 

cover would be met: canopy cover would 

vary from 50 to 70 percent.

100- DLH

Aspen Treatment A variety of different treatments would be 

used to promote and protect aspen health and 

regeneration, including the removal of post 

settlement conifers within 100 feet of aspen 

clones, prescribed fire, ripping, planting, 

fencing and/or cutting of aspen to stimulate 

root suckering.

2– DLH

Grassland Restoration Mechanical treatment to remove encroaching 

post-settlement conifers and restore the pre53– DLH
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 97

Treatment Type Treatment Description/Objective Acres

settlement tree density and patterns.

Burn Only Burn only treatment in the Dry Lake Hills 

would remove excessive fuel loading in areas 

which were previously burned by the Radio 

Fire. Thirty-three acres within MSO PACs 

on Mormon Mountain would be burn only, 

and would not receive mechanical treatment.

67- DLH

33 - MM

Electronic Site – Structure 

Protection

These sites are occupied by 

telecommunication facilities, and would be 

treated to provide a sufficient defensible 

space around these structures from a 

wildland fire. Individual trees that are 

determined to contribute to wildfire risk or 

pose a hazard to the electronic sites would be 

removed. The remainder of the sites would 

receive a thin from below to approximately 

20 – 40 ft2 basal area with the purpose of 

raising the crown base height and leaving the 

largest and most fire resistant trees.

6– DLH

12- MM

No Treatment (No New 

Analysis)

These acres include rock faces, boulder 

fields, some steep slopes requiring 

specialized equipment, and all acres north of 

FR420 (including the Orion Timber Sale), as 

those acres have already been analyzed for 

treatment under the Jack Smith Schultz Fuels 

Reduction and Forest Health Restoration 

Project Decision Notice/Finding of No 

Significant Impact (2008). 

4110- DLH

631 - MM

Table 20: Alternative 4 Harvesting Methods for DLH

Treatment Type GroundbasedHand 

Cut/Piled

Burn 

Only

TOTAL

Ponderosa Pine 

Fuels Reduction

1400 1400

Ponderosa Pine 

Fuels Reduction –

Hand Thinning

86 86

Mixed Conifer 

Fuels Reduction

542 542

MSO PAC Fuels 

Reduction

568 568

MSO PAC Fuels 

Reduction – Hand

Thinning

228 228

MSO Nest Fuels 

Reduction

122 122

Goshawk PFA 286 286
Chapter 2. Alternatives

98 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Treatment Type GroundbasedHand 

Cut/Piled

Burn 

Only

TOTAL

Fuels Reduction

Goshawk Nest 

Fuels Reduction

100 100

Aspen Treatment 2 2

Grassland 

Restoration

53 53

Burn Only 67 67

Electronic SiteStructure 

Protection

6 6

No Treatment - - - 4110

TOTAL 2,953 438 67 7569

Table 21: Alternative 4 Harvesting Methods for MM

Treatment Type Ground-based Burn Only TOTAL

Ponderosa Pine Fuels Reduction 766 766

MSO PAC Fuels Reduction 1509 1509

MSO PAC Fuels Reduction –

Burn Only

33 33

MSO Nest/Roost Recovery 22 22

Electronic Site-Structure Protection 12 12

No Treatment - - 631

TOTAL 2311 33 2,975

Large Tree Retention Strategy

Alternative 4 incorporates the goal of retaining large young trees and old trees within the project 

area brought forth as the Large Tree Retention Strategy (LTRS) by the Center for Biological 

Diversity during the scoping period. However the decision-making authority of the Forest Service 

would not be delegated. The incorporation of the LTRS goals is accomplished in Alternative 4 

primarily by excluding the use of cable logging and specialized steep slope equipment within the 

project area. Those two harvesting methods would require the removal of either a) all trees within 

a 12-foot swath, as in the case of the cable corridors, or b) more large trees on steep slopes for 

maneuverability and/or safety. 

The original LTRS provided by the Center for Biological Diversity was not included in its 

entirety in this alternative as all the action alternatives incorporate the large majority of the 

ecological principles and concepts in the strategy already, including retention of old trees (see 

Mitigation Measures in Chapter 2). The original LTRS provided during the scoping period is 

included in the project record. Large post-settlement trees would be retained throughout the 

project area except: 

1. As necessary to meet community protection and public safety goals (e.g. in WUI areas 

adjacent to communities)
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 99

2. When best available science identifies sites where ecological restoration and biodiversity 

objectives cannot otherwise be met; specifically in the case of FWPP, within stand 

openings and in heavily-stocked stand with high basal area generated by a preponderance 

of large, young trees. 

Per the two points above, the modified LTRS discussed here would only potentially apply to a 

small portion of the project area – approximately 766 acres of ponderosa pine in the MM 

portion—as the DLH portion would fall under the first point noted above. The original LTRS was 

developed specifically for ponderosa pine and so does not apply to mixed conifer areas. 

Assuming the MM portion does not fit within Number 1 above because of its distance from the 

City of Flagstaff, the rest of the LTRS will only pertain to the ponderosa pine Gambel oak forests 

outside of MSO PACs on MM. 

Most of the “exception” categories listed in the LTRS are not relevant for the MM portion of 

FWPP discussed above, including: 

Seeps and Springs

Riparian

Wet Meadows

Encroached Grasslands

Aspen Forest and Woodland

Ponderosa Pine/Gambel Oak forest (outside MSO Recovery Habitat)

As not every acre of the relevant MM portion was surveyed (see Methodology section of Forest 

Structure and Health in Chapter 3), it is possible that the area might primarily contain smalldiameter (less than 16 inches dbh) trees, which would not fit within an exception category under 

the original LTRS. As stated in the Forest Structure and Health methodology section:

The modeling assumptions attempt to meet the spirit of the Large Tree Retention 

Strategy (LTRS) within the limitations of a non-spatially explicit model. On the 

ground cutting prescriptions for Alternatives 2 and 3 would follow components 

of the LTRS that have been incorporated into the design features of this EIS. 

Alternative 4 would include more specific limitations on large tree removal per 

the modified LTRS and related Design Features discussed in this DEIS (p. 191)

Because of this, as long as the purpose and need of fire risk reduction would still be met, 

Alternative 4 would incorporate the following additional Design Features for the Northern 

Goshawk habitat within LOPFA on MM:

To meet the desired condition of increasing the more fire-resilient VSS 5 and 6 age class,

tree retention within groups would focus on existing large trees (generally, trees within 

the dominate and codominant crown position). 

Tree groups, on average, would range in size from 0.1 to 1 acre with northerly aspects, 

sites with a preponderance of large trees and highly productive microsites having larger 

average group sizes (0.25 to 1 acre). Overall, average group size would vary within this 

range depending on fuel loading, site quality and topography, existing stand structure, 

and pre-settlement tree evidence.

Stands with a preponderance of large trees would be managed for greater residual canopy 

cover and density of large young trees while still meeting the purpose and need of 

reduced wildfire risk. Residual stand structure would be managed at the upper end of 
Chapter 2. Alternatives

100 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

natural range of variability for ponderosa pine in the stands that meet these conditions

(e.g. to retain the highest number of trees within the historic range of variability; see 

Table 22). This would be accomplished by focusing treatments towards the higher end of 

the natural range of variability, managing for larger group sizes (see below), and/or 

retaining additional large trees.

Regeneration openings (group selection) account for 10 to 20 percent of tree groups. The 

percentage would vary within this range depending on current VSS distribution. They 

would average 0.25 to 2 acres with an average of approximately 1 acre and would be no 

wider than 200 feet. Where stand structure dictates, establish regeneration openings by 

removing groups of trees of VSS3 and smaller diameter VSS4.

Table 22: Ranges of reference conditions for ponderosa pine forests in the Southwestern 

United States from studies detailed in RMRS-GTR-310 (2013).

Forest attribute Ponderosa pine

Trees / acre 11.7-124

Basal area (ft2 / acre) 22.1-89.3

Spatial patterns Grouped or random

Number of trees / group 2-72

Size of groups (acres) 0.003-0.72

Number of groups / acre 6-7

Forest Plan Amendments

Alternative 4 would contain Forest Plan Amendments 1 and 2 (described under Alternative 2 and 

in Appendix A) because these Forest Plan amendments would be necessary to meet the purpose 

and need of the project to effectively reduce the risk of high-severity wildfire within the project 

and analysis area. 

Required Transportation System

Alternative 4: Minimal Treatment Proposed Transportation System

Under Alternative 4 the following actions would occur regarding road use on the Dry Lake Hills 

and Mormon Mountain Areas, respectively. Alternative 4 differs from Alternatives 2 and 3 in that 

there would be no hauling on FR 522 and FR 516 (Snowbowl road), and also includes fewer temp 

roads than the other two action alternatives (12.71 miles versus 20.98 miles and 15.17 miles for 

Alternatives 2 and 3, respectively). 

Dry Lake Hills

System haul roads within the project area 13.04 miles

System haul roads outside the project area 7.37 miles

New temporary haul roads constructed 9.20 miles

Temporary roads on existing road prisms 0.99 miles

Temporary road rehabilitated 10.19 miles

Relocated system road used as haul road 1.57 miles

System road decommissioned 4.19 miles

Mormon Mountain

System haul roads within the project area 16.46 miles
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 101

System haul roads outside the project area 18.13 miles

New temporary haul roads constructed 0 miles

Temporary roads on existing road prisms 2.52 miles

Temporary road rehabilitated 2.52 miles

Relocated system road used for hauling 0.53 miles

System roads decommissioned 0.19 miles

Figure 35: Proposed Transportation System for Alternative 4, DLH
Chapter 2. Alternatives

102 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 36: Proposed Transportation System for Alternative 4, MM
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 103

Restoration versus Fire Risk Reduction

Table 23 shows the proposed treatments and whether they fit under the umbrella of restoration, or 

if they’re more aimed toward fire-risk reduction. In some cases, the fire-risk reduction treatments 

would result in denser forest conditions than a restoration approach; this is tied to fire regimes, 

wildlife habitat limitations, and also the influence of the wildand-urban interface and the project’s 

purpose and need. 

The fire regime for dry mixed conifer is very similar to that of ponderosa pine, the fire regimes of 

wet mixed conifer involves less frequent, higher-severity fires than what is desirable for 

protection of soil resources and the adjacent urban interface. Thus, for those areas, the proposed 

treatment approach is more geared toward fire-risk reduction than true restoration. 

A large portion of the project area falls within MSO habitat; management of those areas is guided 

by the Recovery Plan, and as such, the desired conditions may generally be denser (i.e. higher 

canopy cover, higher basal area) than what may have been present in mixed conifer historically. 

Therefore the proposed treatments would achieve the purpose and need of reducing the risk of 

high-severity wildfire even though they might not meet full restoration conditions.

The mixed conifer treatments proposed under the action alternatives for FWPP could very well be 

similar to historical conditions in each of those locations; however due to the reasons cited above, 

restoration is only cited as such in the treatments below when that approach also met the purpose 

and need for the project. 

Table 23: Proposed Treatments and their focus (restoration versus fire risk reduction)

Treatment: Focus: Effect of focus:

Aspen Treatment Restoration Restoring aspen stands achieves fire 

risk reduction and desired condition.

Burn Only

Fire Risk Reduction Prescribed burning would reduce fire 

risk and moves towards desired 

condition but would not necessarily 

achieve restoration objectives. 

Electronic Site - Structure 

Protection

Fire Risk Reduction These are highly developed and 

managed sites and restoration to 

historical tree densities and patterns is 

not desirable or practical. Treatments in 

this area would likely remove more 

understory, small diameter trees and 

reflect conditions that likely do not 

historically occur.

Northern Goshawk Nest Fuels 

Reduction

Restoration Treatment would be designed to create 

habitat for northern goshawk nests, 

Tree density would be similar but

denser than historic conditions, and tree 

size distribution and spatial 

arrangement would not follow historic 

patterns.

Northern Goshawk Post 

Fledging Areas (PFA) Fuels 

Reduction

Restoration Treatment would move stands towards 

sustainable uneven-aged conditions and 

spatial arrangements, which would be 

within the natural range of variability 
Chapter 2. Alternatives

104 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Treatment: Focus: Effect of focus:

for this forest type. Treatment would 

also meet fire risk reduction objectives 

and desired condition.

Grassland Restoration

Restoration Restoration of historic grassland extent 

would also meet fuels reduction 

objectives and desired conditions.

Mixed Conifer Fuels 

Reduction

Restoration Treatment would move stands towards 

sustainable uneven-aged conditions and 

spatial arrangements which would be 

similar to and within the natural range 

of variability for this forest type. 

Treatment would also meet fire risk 

reduction objectives.

Mixed Conifer Fuels 

Reduction - Hand Thin

Fire Risk Reduction Treatment would reduce fire risk and 

would move stands towards but not 

meet desired conditions. Tree densities 

would be higher than historic levels 

and spatial patterns would not mimic 

historic patterns. 

MSO Nest Fuels Reduction -

Burn Only

Fire Risk Reduction Prescribed burning would reduce fire 

risk and thus move toward desired 

conditions, but would not necessarily 

achieve restoration objectives. 

MSO Nest Fuels Reduction -

Hand Thin

Fire Risk Reduction Treatment would reduce fire risk. Tree 

densities would be higher than historic 

levels and spatial patterns would not 

mimic historic patterns.

MSO Nest Roost Recovery –

Burn Only

Fire Risk Reduction Prescribed burning would reduce fire 

risk but would not necessarily achieve 

restoration objectives. 

MSO Nest Roost Recovery 

Fire Risk Reduction Treatment would reduce fire risk. Tree 

densities would be higher than historic 

levels and spatial patterns would not 

mimic historic patterns.

MSO PAC Fuels Reduction

Fire Risk Reduction Treatment would move stands towards 

uneven-aged conditions and spatial 

arrangements. Conditions would be 

much denser than historical conditions. 

Treatment would reduce fire risk.

MSO PAC Fuels Reduction -

Hand Thin

Fire Risk Reduction Treatment would reduce fire risk and 

would move stands towards but not 

meet desired conditions. Tree densities 

would be higher than historic levels 

and spatial patterns would not mimic 

historic patterns.

MSO PAC Fuels Reduction –

Wet Mixed Conifer

Fire Risk Reduction Treatments would regenerate patches 

of aspen which would reduce fire risk 

and achieve limited restoration 

objectives. 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 105

Treatment: Focus: Effect of focus:

Ponderosa Pine Fuels 

Reduction

Restoration Treatment would move stands towards 

sustainable uneven-aged conditions and 

spatial arrangements, which would be 

similar to and within the natural range 

of variability for this forest type.

Treatment would meet fire risk 

reduction objectives and desired 

conditions.

Ponderosa Pine Fuels 

Reduction - Hand Thin

Fire Risk Reduction Treatment would reduce fire risk and 

would move stands towards but not 

meet desired conditions. Tree densities 

would be higher than historic levels 

and spatial patterns would not mimic 

historic patterns.

Mitigation Common to All Alternatives

The Forest Service also developed the following mitigation measures to be used as part of all of 

the action alternatives. 

Table 24: Mitigation Measures Common to all Action Alternatives

Specialist Area Related 

Resource Mitigation Measure

Silviculture

Old Trees

Emphasize retaining old, pre-settlement trees 

where possible, particularly within MSO 

recovery nest/roost habitat. Old trees, as defined 

by Thomson (1940) for ponderosa pine, and 

mixed conifer species with fire scars would not 

be targeted for cutting. However, exceptions 

may be necessary. An example of this would be 

removing an old tree to address human health 

and safety concerns and OSHA regulations 

where treatments are occurring if these trees are 

considered to be dangerous. Another instance 

would be to cut an old tree in order to 

accommodate the turning radius of a logging 

truck, rather than relocating an entire road, or if 

they are located within a cable yarding corridor 

or temporary road location.

Large Trees

Post-settlement ponderosa pine trees > 16 inches 

dbh would be prioritized for protection, but may 

be removed to restore forest health and to 

emulate natural vegetation patterns based on 

current stand conditions, pre-settlement 

evidences, desired future conditions, or other 

restoration objectives. Instances where this 

would occur include: in conifer-encroached 

aspen stands, encroached grasslands, in heavily 
Chapter 2. Alternatives

106 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Specialist Area Related 

Resource Mitigation Measure

stocked stands of large, young trees when the 

presence of such trees would prevent the reestablishment of sufficient stand openings, when 

necessary to develop or maintain uneven-aged 

forest conditions (where desired), and if they are 

located within a cable yarding corridor or 

temporary road location. 

Mixed Conifer

Treatments within both dry and wet mixed 

conifer vegetation types would be site-specific 

in nature and vary according to the diversity of 

tree species compositions and locations. 

Juniper & 

Gambel Oak

Gambel oak would only be cut as necessary 

to facilitate logging operations (skid trail 

and landings). 

Large mature juniper (“alligator juniper”) 

and pinyon species would not be cut as part 

of treatments. Young and mid-aged juniper 

and pinyon may be cut to reduce fire risk to 

surrounding larger trees.

Placement of roads, skid trails and landings 

would avoid cutting or damaging large 

alligator junipers. 

Forest Health

Log decks would not be left at the landings or in 

the treatment areas for such a period that would 

contribute to an increase in bark beetle 

populations; typically no longer than 4 weeks if 

bark beetles are present. Logs and log decks 

could be left for longer than 4 weeks if no bark 

beetle activity is detected. Entomologists from 

the Forest Health Group would be consulted as 

needed.

Operations

Operational 

Safety

Danger trees that are present within two treelengths of areas where contractors are not 

enclosed within a Falling Object Protective 

Structure (FOPS) cab may be removed or felled. 

These areas include cutting units that require 

manual falling, cable or helicopter logging units 

and landings. A danger tree is any tree that 

presents a hazard to employees due to 

conditions such as deterioration or damage to 

the root system, trunk, stem or limbs 

Coordination

Use of haul routes designated either within or 

adjacent to utility corridors would be 

coordinated with El Paso Natural Gas Company. 

Fire/Fuels Slash Mats

In areas where slash mats are used to protect 

soils during harvesting activities, District 

fire/fuels personnel would determine if material 

should be piled and burned post-implementation 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 107

Specialist Area Related 

Resource Mitigation Measure

where slash exceeds 4 inches in depth.

Fuelwood 

Gathering 

Areas of project-generated slash suitable for 

fuelwood gathering (outside of MSO PACs, 

recovery habitat and northern goshawk PFAs) 

would be identified for public use. Those areas 

would be identified on the Forest website and 

on the map accompanying each fuelwood 

gathering permit. 

Slash Treatment

Limit machine piling of slash within 300 

feet of private property boundaries.

Limit hand piling within 50 feet of private 

property boundaries. 

If a market for biomass exists during the 

time of implementation, biomass removal 

methods may be utilized in place of pile 

burning in areas identified for potential 

ground based harvesting, particularly in 

areas adjacent to residential property. 

Heritage Site Protection

All fire intolerant sites would be marked for 

avoidance from prescribed burning and all 

National Register of Historic Places (NRHP) 

eligible or unevaluated sites would be protected 

from ground disturbing activities.

Wildlife Mexican Spotted 

Owl

MSO surveys would be coordinated with the 

Fish and Wildlife Service the year of 

implementation or one year prior to 

determine occupancy of owls.Surveys 

include the project area plus 1⁄2 mile beyond 

the peremeter of the project boundary. 

The FWPP project boundary lies within the 

project boundary for 4FRI as well as other 

forest thinning and burning projects. 

Flagstaff Ranger District staff would ensure 

that all proposed treatments are coordinated 

to ensure that there are not multiple entries 

into sensitive habitats (such as MSO PACs) 

that are split between different project 

boundaries. In doing so, habitat and noise 

disturbance to these areas would be 

minimized.

The Forest Service would monitor effects to 

MSO from the proposed action and report 

their findings to the FWS. Implementation 

monitoring would include information such 

as when or if the project was implemented, 

whether the project was implemented as 

analyzed in the site specific BO (including 

conservation measures, and best 
Chapter 2. Alternatives

108 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Specialist Area Related 

Resource Mitigation Measure

management practices), breeding season(s) 

over which the project occurred, relevant 

MSO survey information, and any other 

pertinent information about the project’s 

effects on the species. Treatment activities 

within PACs would be assessed through 

implementation of the monitoring plan 

designed with FWS.

Treatments would be designed so that 

thinning activities within each PAC would 

be completed in one to two breeding 

seasons. Treatments within MSO PACs may 

occur during the breeding season for no 

more than two years; if implementation is 

not completed at the end of two years, 

timing restrictions would apply (March 1 –

August 31). The Thicket northern goshawk 

PFA on Mormon Mountain would be treated 

in conjunction with the PACs it overlaps 

with the same parameters. 

Activities would not occur within MSO 

occupied nest cores during the breeding 

season (March 1 – August 31). 

Initial entry burning and pile burning would 

primarily occur in PACs during the 

fall/winter to minimize impacts from smoke 

on MSO. Maintenance burning within PACs 

but outside of nest cores could occur during 

the breeding season.

Prescribed fire would be allowed to enter 

cores only if it is expected to burn with low 

fire severity and intensity. Firelines, checklines, backfiring, and similar fire 

management tactics would be used to reduce 

fire effects and to maintain key habitat 

elements (e.g. hardwoods, large downed 

logs, snags, and large trees).

In MSO recovery habitat, manage for large 

oaks by removing conifers up to 18 inches 

dbh that do not meet the “old tree” 

definition within 30 feet of oak 10 inches 

drc or larger

Coordinate burning spatially and temporally 

to limit smoke impacts to nesting owls 

(March 1 to August 31).

Northern Goshawk

Thinning treatments within PFAs may occur 

during the northern goshawk breeding 

season for no more than two years; if 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 109

Specialist Area Related 

Resource Mitigation Measure

implementation is not completed at the end 

of two years, timing restrictions would 

apply (March 1 – September 30). The 

Thicket northern goshawk PFA on Mormon 

Mountain would be treated in conjunction 

with the PACs it overlaps with the same 

parameters as those PACs.

Prescribed burn plans in northern goshawk 

PFAs would be designed and implemented 

to minimize smoke impacts to nesting birds 

and minimize loss of nest trees.

Wildlife Other Wildlife

No thinning activities would occur within 

one-quarter mile of the Devil’s Head 

peregrine eyrie if occupied during the 

breeding season (March 1 – August 15).

If any of the three bald eagle nests near 

Mormon Mountain are occupied during the 

eagle breeding season (March 1- August 1), 

prescribed burning would only be permitted 

in the Mormon Mountain project area when 

ventilation is favorable and in coordination 

with the wildlife biologist and FWS. 

Typically nesting status can be confirmed 

by May.

Burn plans within 1/2 mile of golden eagle 

nest and peregrine falcon eyries would be 

coordinated with the district wildlife 

biologist to insure nesting falcons and 

golden eagles would not be adversely 

impacted from smoke.

Hiding cover would be maintained near 

dependable waters by not targeting 

drainages for openings, and through 

implementation of watershed BMPs.

Tanks within 1⁄4 mile of known northern 

leopard frog sites would be surveyed prior 

to implementation. If northern leopard frogs 

are detected, a buffer for no treatments (no 

thinning, no direct ignition) would be 

identified to protect occupied tanks.

A 200-ft protection zone (100 feet either 

side of streamcourse) would be established 

around designated stream courses for 

northern leopard frogs. There would be no 

thinning and no direct ignition of prescribed 

burning within the protection zones. 

Designated skid trail crossings through the 
Chapter 2. Alternatives

110 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Specialist Area Related 

Resource Mitigation Measure

buffer zones are allowed.

Primary red squirrel caches would generally 

be protected at a density of one cache per 

two acres where current cache numbers 

allow. 

Snags

Use logging systems when feasible in 

sensitive habitats that can meet project 

objectives and maintain important structural 

components (e.g., snags, etc.). 

Protect snags and logs wherever possible 

through site prep, implementation planning, 

and ignition techniques to retain within the 

project area an average of approximately ≥ 

2 snags per acre >18 inches dbh and ≥30 ft 

in height and ≥3 logs with > 12 inches midpoint diameter and ≥ 8 ft in length in 

ponderosa pine and ≥ 3 snags per acre >18 

inches dbh and ≥30 ft in height and ≥5 logs 

with >12 inches mid-point diameter and ≥ 8 

ft in length in mixed conifer and spruce-fir

Within the project area, retain an average of 

approximately ≥ 2 trees per acre ≥18 inches 

dbh with dead tops, cavities, and lightning 

strikes wherever possible to provide for 

replacement snags and cavity 

nesting/foraging habitat

Emphasize retention of snags exhibiting 

loose bark to provide habitat for roosting 

bats.

Create snags in key areas (i.e. PACs, 

recovery nest roost habitat) where 

monitoring determines a deficit. Trees 

would be chosen on a case-by-case basis in 

order to ensure successful recruitment as 

snags. 

Botany Noxious/Invasive 

Weeds

Best Management Practices as outlined in 

Appendix B of the “Final Environmental Impact 

Statement for Integrated Treatment of Noxious 

or Invasive Weeds” (USDA Forest Service 

2005) would be followed to incorporate weed 

prevention and control into the project. The 

following features would be incorporated into 

project implementation and monitoring:

Prevent the spread of potential and existing 

noxious or invasive weeds by vehicles used 

in management activities by incorporating 

weed prevention and control into project 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 111

Specialist Area Related 

Resource Mitigation Measure

layout, design, and implementation.

Prior to ground-disturbing activities, survey 

for and prioritize and implement treatments 

of noxious or invasive weeds in project 

operating areas including landings , 

permanent and temporary roads and roads to 

be closed or decommissioned.

Avoid existing noxious or invasive weeds 

during soil disturbing activities.

Clean all vehicles, machinery and tools of 

seeds, soil, vegetative matter, and other 

debris that could contain or hold seeds prior 

to entering the project area, when moving 

from one area to another, and when leaving 

the project. 

Fully incorporate the equipment cleaning 

provisions of the timber sale and/or 

stewardships contracts into the 

implementation contract(s) to prevent the 

introduction or spread of noxious or 

invasive weeds. 

When in areas where known noxious weeds 

exist, designate turnaround sites for log 

trucks and other large equipment that are 

weed free. 

Manage prescribed fires to promote native 

species, aid in control of existing weed 

infestations and prevent spread of existing 

weeds through coordination with the District 

Weeds Coordinator. 

Place slash piles on previously used 

locations such as old piling sites, old log 

deck sites, or other disturbed sites to avoid 

severe disturbance to additional locations 

where possible.

Monitor slash pile sites after burning and if 

found, control noxious or invasive weeds.

Avoid acquiring water for dust abatement 

from weed-infested areas.

Minimize period from end of project 

activities to site preparation, revegetation, 

and contract closure.

Sensitive Plants

Determine potential occurrences and habitat 

of Region 3 sensitive plants in potential 

activity areas when planning for 

implementation. Identify potential species 

and survey the area to be treated before 
Chapter 2. Alternatives

112 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Specialist Area Related 

Resource Mitigation Measure

implementation.

Mitigate loss of individuals and groups of 

Rusby milkvetch during management 

activities by avoiding known locations.

Construct slash piles at least 10-20 feet 

away from known populations of Rusby 

milkvetch.

Prohibit mechanical slash pile construction 

within known populations of Rusky 

milkvetch.

Prohibit temporary road construction or 

reconstruction within known populations of 

Rusby milkvetch. 

Prohibit construction, reconstruction or log 

landings in identified populations of Rusby 

milkvetch

Leave tree groups may include Rusby 

milkvetch plant groups where practical, 

using areas not occupied by the plants as 

openings. 

Manage prescribed burns at low to moderate 

intensity to promote native species and to 

hinder weed species germination.

Monitor the effects of treatment on Region 3 

sensitive plants after treatments are 

completed in areas with known populations. 

Soil/Watershed General

In order to avoid negative impacts to soils 

and water resources, best management 

practices (BMPs) would be implemented for 

prescribed fire and mechanical vegetation 

treatment measures. These resource 

protection measures are derived mainly from 

the Soil and Watershed Conservation 

Practices Handbook (USDA, 1990) and the 

National Best Management Practices for 

Water Quality Management on National 

Forest System Lands, Volume 1: National 

Core BMP Technical Guide (USDA, 2012). 

Resource protection measures are 

implemented to protect soils and minimize 

nonpoint source pollution as outlined in the 

intergovernmental agreement between the 

Arizona Department of Environmental 

Quality and the Southwest Region (Region 

3) of the Forest Service (ADEQ, 2008). 

BMPs would be incorporated in prescribed 

fire burn plans and timber harvesting or 

stewardship contracts. 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 113

Specialist Area Related 

Resource Mitigation Measure

Prescribed Fire

Incorporate prescription elements into the 

prescribed fire plan including such factors as 

weather, slope, aspect, soils, fuel type and 

amount, and fuel moisture in order to 

minimize high soil burn severity. 

Consider the spatial distribution and 

contiguous size of the planned burn area in a 

watershed during prescription development 

to reduce the effects of peak flow change on 

channels. 

Timber Harvesting

At a minimum, all perennial water bodies, 

wetlands, and areas with riparian ecosystems 

would be designated as Aquatic Management 

Zones (AMZs), also called filter strips in the 

1987 Coconino National Forest Plan. Those 

stream channels that support seasonal flow in 

response to snowmelt and/or seasonal 

fluctuations in the water table would also be 

evaluated for potential designation as AMZs. 

AMZ widths would be adjusted based on the 

steepness of upgradient hillslopes with the 

following general guidelines: 

AMZ width is the distance measured 

perpendicularly from the outer edges of 

the streamcourse (i.e., channel bank) or 

wetland. For stream courses or wetlands 

with upgradient hillslopes of 35 percent 

or less, the AMZ width would be 50’. 

For those with upgradient hillslopes 

greater than 35 percent, AMZ width 

would be 100’. As an example, the total 

width of an AMZ for a streamcourse 

with an upgradient hillslope exceeding 

35 percent would be 200’ plus the width 

of the streamcourse. 

Equipment/vehicle staging areas, and fuel used 

for ignition devices would be located outside of 

AMZs. Ignition of fuels would not be initiated 

within AMZs. Hand piling and burning of slash 

within AMZs would be avoided to the extent 

practicable. 

Containment lines would be sited and 

constructed in a manner that minimizes erosion 

and prevents runoff from directly entering water 

bodies by consideration of placement relative to 

the water body(ies) and lay-of-the-land and 

through construction and maintenance of 
Chapter 2. Alternatives

114 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Specialist Area Related 

Resource Mitigation Measure

suitable drainage features such as water bars. 

To the extent possible, wetlands and riparian 

areas would be avoided. Where applicable, 

natural fire breaks such as outcrops would be 

used in lieu of ground-disturbing containment 

lines. In general, spacing of water bars would 

be such that water bars are located at eye level 

when viewed starting at the bottom of a slope 

and traversing upward. 

Staging areas would be kept as small as possible 

while allowing for safe and efficient operation. 

Prior to conducting harvesting activities, all 

AMZs, staging areas (including areas where 

vehicles are serviced, equipment/chemicals are 

stored, and/or fuel is dispensed), primary skid 

trails, cable yarding corridors, temporary roads, 

and landings would be designated on a map and 

visibly marked by means of flagging or other 

suitable measures for approval by the timber 

sale administrator. Temporary fuel storage 

tanks would be permitted and installed in 

accordance with the Office of the State Fire 

Marshall requirements.

To the extent possible, skid trail design would 

not include long, straight downhill segments 

which would concentrate runoff. If it is not 

operational feasible to avoid a long straight 

downhill segment, skid trail rehabilitation 

measures would be applied as soon as skidding 

is completed on that trail. Cable yarding 

corridors would be located to efficiently yard 

materials with the least soil damage. Skidding 

or cable yarding up or down drainage courses 

would not be permissible unless, in the case of 

cable yarding, logs are fully suspended.

Insofar as safety permits, trees would be felled 

to angle in the direction of skidding.

Drainage of roads would be controlled by a 

variety of methods including but not limited to 

insloping of the road bed toward an interior 

drainage ditch with periodic cross drains, 

outsloping of the road bed, crowning of the road 

bed, and construction of rolling dips and water 

lead-off ditches. Drainage from landings and 

skid trails would be controlled to prevent 

concentration of runoff. 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 115

Specialist Area Related 

Resource Mitigation Measure

Equipment would not be operated when ground 

conditions are such that excessive damage 

would result as visually monitored through such 

indicators as soil rutting. 

Machine piling of logging slash would be done 

in such a manner as to minimize the 

construction of new clearings for slash piles 

through use of natural openings, temporary 

roads, and landings. 

Skid trails and cable yarding corridors would be 

restored after use by a combination of any or all 

of the following practices in order to prevent the 

concentration of runoff in skid trails and to 

protect exposed soil: reshaping the surface to 

promote dispersed drainage (i.e., create convex 

vs. concave cross-section), installation of 

drainage features such as water bars to shed 

water, and spreading slash across skid trails and 

cable yarding corridors to protect areas where 

mineral soil is exposed. Where skid trails and or 

cable yarding corridors intersect existing roads 

or trails, native materials such as logs, slash, 

and/or boulders would be placed along skid trail 

or cable corridor to line-of-sight or first 300’, 

whichever is greater. 

Temporary roads and landings would be 

restored after use by a combination of any or all 

of the following practices in order restore 

original topography, protect soils, and prevent 

concentrated runoff: roll berms created during 

temporary road and/or landing construction 

back across the disturbed surface to restore 

original surface topography to the extent 

practicable, install drainage features such as 

water bars where needed to prevent runoff from 

concentrating, and spread slash on areas with 

exposed mineral soil. Where temporary roads 

intersect existing roads or trails, native materials 

such as logs, slash, and/or boulders would be 

placed along temporary road to line-of-sight or 

first 300’, whichever is greater. 

Where visual observation indicates that the 

above methods of erosion protection are 

inadequate, a certified weed-free mix of native 

or naturalized grasses would be broadcast 

evenly over the inadequately protected surface 

at the rate of 5 pounds per acre after surface 
Chapter 2. Alternatives

116 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Specialist Area Related 

Resource Mitigation Measure

scarification.

Recreation

Public Awareness

Inform forest visitors about activities within 

the project area and make them aware of 

potential impacts when visiting this part of 

the forest. Provide information about 

implementation activities on the Forest 

website. 

Issue news release(s) as appropriate when 

forest restoration activities are scheduled to 

occur and how it may affect forest 

visitation.

If it is necessary to close forest roads during 

harvesting operations, notices and signs 

would be posted at key locations adjacent to 

and within the project area to inform the 

public of these closures, in conjunction with 

issuing news releases as stated above. This 

may include major FS roads accessing the 

area, kiosks at trailheads, bulletin boards, 

electronic sign boards, etc.

Utilize dust abatement methods during haul 

of logs on unpaved roads near private land 

residences during the season when dust is 

likely and funding is available

Forest Service Trails

Harvesting activities would avoid forest 

system trails, if possible. If it is determined 

necessary that a trail must be used as a 

temporary road or skid trail, then the trail 

would be restored to USFS standards posttreatment. 

It is acceptable to make perpendicular trail 

crossings. Trail crossing locations would be 

designated and flagged with input from the 

District Trails Coordinator or assigned 

personnel. Trail crossings would be restored 

to pre-project condition after use.

Forest restoration treatments within close 

proximity (i.e. 100’-200’) of forest system 

trails would consider “feathering” the 

treatment so the visual impacts are more 

transitional than abrupt and as to not 

significantly change the character or 

experience of the trail.

Trails originally designated for “single 

track” use (motorized and non motorized)

would be avoided for use as skid trails or 

temporary roads. 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 117

Specialist Area Related 

Resource Mitigation Measure

Special-Use Events

Coordinated efforts would be made with 

sponsors of recreational special-use events (i.e. 

running or mountain biking races) to minimize 

the impacts on such events within the project 

area during implementation. Alternative 

locations would be identified to meet the needs 

of the special-use event if forest management 

activities conflict with preferred locations and 

cannot be resolved through timing.

High-Use 

Weekends and 

Holidays

Efforts would be taken to limit forest treatment 

activities within the project area during high-use 

weekends and holidays (i.e. Memorial Day, 4th

of July, Labor Day, etc.); especially in locations 

where recreation based activities (i.e. trails, 

trailheads, etc.) occur.

Hunting Access

Temporary closures of forest roads and/or 

portions of the project area during 

implementation would be coordinated with 

AZGFD during hunting seasons to reduce 

impacts on hunter and angler access.

Mt. Elden 

Environmental Study 

Area

Measures would be taken to safeguard the trails 

and interpretive signs/markers within the Mt. 

Elden Environmental Study Area from forest 

restoration activities.

Wilderness

Improve the wilderness boundary marking 

where forest restoration operations are planned 

within close proximity (i.e. 1⁄4 mi.) of a 

wilderness area.

Forest restoration treatments within close 

proximity (i.e. 1⁄4 - 1⁄2 mile) to a wilderness area 

would consider “feathering” the treatment so the 

visual impacts are more transitional than abrupt.

Edges of Individual 

Units

Thinning forest vegetation geometric shapes 

(such as linear corridors from cable yarding) 

would be avoided when it does not interfere 

with implementation feasibility or safety, and 

high contrast would be avoided between 

treatment locations. Use the following 

techniques:

Shape and/or feather the edges of treatment 

areas to avoid abrupt changes between 

treated and untreated areas.

Where the treatment unit is adjacent to 

denser forest (treated or untreated), the 

percent of thinning within the transition 

zone (150-250 feet) would be progressively 

reduced toward the denser edges of the unit.
Chapter 2. Alternatives

118 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Specialist Area Related 

Resource Mitigation Measure

Similarly, where the treatment unit 

interfaces with an opening (including 

savannah and grassland treatments, and 

natural openings) the transition zone would 

progressively increase toward the open 

edges of the unit.

Soften edges by thinning adjacent to the 

existing unit boundaries. Treat up to the 

edges; do not leave a screen of trees. Favor 

groups of trees complying with the 

prescribed treatment that visually connect 

with the unit’s edge to avoid an abrupt and 

noticeable change.

Treatment boundaries should extend up and 

over ridgelines to avoid the “Mohawk” look. 

Avoid widely spaced individual trees that 

are silhouetted along the skylines.

Scenery

Unit Marking

Avoid using trails as boundaries especially 

for different prescribed treatments.

Avoid abrupt changes between treatment 

units. Use the techniques suggested for 

edges of treatment units (above). 

Road, Skid Trail 

& Landing 

Construction

Utilize dust abatement methods during haul 

of logs during the season when dust is likely 

and funding is available. Priorities would 

include residential areas, private land and 

adjacent to recreation sites. Coordinate with 

Coconino County on the application and 

timing of application of dust abatement on 

road segments that have County 

Maintenance responsibilities.

Utilize existing skid roads and landings to 

the extent possible.

Log landings, temporary roads, and skid 

trails should be minimized within sensitive 

viewsheds such as those next to developed 

recreation sites, private homes or 

communities, paved and passenger car level 

roads and trails.

To hasten recovery and help eliminate 

unauthorized motorized and non-motorized 

use of skid trails and temporary roads, use 

physical measures such as re-contouring, 

pulling slash and rocks across the line, 

placing cull logs perpendicular to the route, 

and disguising entrances.

If areas where piles were burned are not 

naturally restored, it may be necessary to 
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 119

Specialist Area Related 

Resource Mitigation Measure

scratch in seed and soil from unburned areas 

in order to assure vegetative cover

Cull Logs, 

Stump Heights & 

Slash Treatments

Cull logs would not be abandoned on 

landings.

Use cull logs for closing temporary roads 

and decommissioning roads, and for closed, 

undesignated roads if appropriate.

Cull logs may also be suitable to use as 

down woody material, but must be scattered 

away from the landings.

Stump heights should be cut as low as 

possible.

Unless used for erosion control or 

maintenance of soil productivity, slash on 

log landings must be treated or removed.

In the seen area immediate foreground of 

sensitive places (within 300 feet of the 

centerline of paved or passenger car level 

roads or trails, or 300 feet from the 

boundary of a recreation site or private 

land/communities):

o Where whole tree logging occurs, 

machine piling may occur to the 

middle/back of log landings. 

Prioritize slash burning in these 

locations within one year or as soon 

as possible after treatment.

Root wads and other debris in sensitive 

foreground areas would be removed, buried, 

burned, or chipped. If materials are buried, 

locate in previously disturbed areas where 

possible, such as areas for road obliteration. 

Beyond sensitive immediate foreground 

areas, it is acceptable to scatter these or use 

them to help decommission temporary roads 

or skid trails.

Place project-generated slash outside of 

permitted utility line and pipeline rights-ofway; do not interfere with utility corridor 

management.

Fire Control 

Lines

Wherever possible, construct fire lines to 

reduce the contrast so that they are not 

noticeable in the middle and background 

views. 

Generally restore control lines to a near 

undisturbed condition in the foregrounds 

(within 300 feet) of roads, trails, and 

developed recreation sites with high scenic 
Chapter 2. Alternatives

120 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Specialist Area Related 

Resource Mitigation Measure

integrity objectives.

To hasten recovery and help eliminate 

unauthorized motorized and non-motorized 

use of control lines, use measures such as 

re-contouring, pulling slash and rocks across 

the line, and disguising entrances to nonsystem roads and trails.

Range

Infrastructure Protect range infrastructure from prescribed 

fire (e.g. by lining fence stays).

Upon completion of implementation, cattle 

guards would be cleaned to preimplementation condition.

Implementation Coordinate implementation activities with 

range specialists when implementation 

would impact an active grazing allotment.

Vehicles passing through grazing pastures 

would close gates upon entering and exiting 

the area to ensure livestock remain in the 

correct pasture.

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all 

reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that 

were not developed in detail (40 CFR 1502.14). Public comments received in response to the 

Proposed Action provided suggestions for alternative methods for achieving the purpose and 

need. These alternatives were outside the scope of reducing the risk of high-severity wildfire. 

Therefore the two alternatives discussed below were considered, but dismissed from detailed 

consideration for reasons summarized below.

Alternatives Considered but Dismissed from Further Analysis

The following two alternatives identified through scoping comments were discussed by the IDT 

and determined to not meet the purpose and need for the project. 

Alternative 5: No Temporary Road Use or Forest Plan Amendments & Hand 

Thinning Only

This alternative would involve hand thinning only with no amendments to the Forest Plan, and 

would utilize existing, open roads only. No new temporary roads would be constructed and no 

existing, closed roads would be utilized. Under this alternative achieving the desired conditions of 

reduced high-severity wildfire and achieving a sustainable forest structure would not be possible

due to: the preponderance of trees greater than 9 inches dbh, (the standard limit for hand thinning 

treatments), the safety concerns of hand felling larger trees on steep rocky slopes, the inability to 

remove cut material which would leave an overabundance of fuels on the ground, and the 

subsequent need for extensive hand piling and burning on steep slopes.
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 121

Alternative 6: Kachina Peaks Wilderness 

This alternative would include expanding the DLH portion of the project area to include treating 

in the Kachina Peaks Wilderness. While portion of the wilderness could potentially benefit from 

treatments that reduce the risk of uncharacteristically large, high-severity wildfire, the 

inaccessibility, high fuel loadings, and rough terrain of the area would require road development 

and treatment of an extent that would clearly be in conflict with the objectives of a designated 

Wilderness area. Namely, that of maintaining wilderness in such a manner that “ecosystems are 

unaffected by human manipulation and influences so that plants and animals develop and respond 

to natural forces” (FSM 2320.2(2)). 
Chapter 2. Alternatives

122 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Comparison of Alternatives

This section provides a summary of the differences between the alternatives and their effects. The tables below contain information that is focused 

on activities and effects where different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives. 

Table 25: Comparison of Proposed Actions between Alternatives

Actions Alternative 1 –

No Treatment

Alternative 2 – Proposed 

Action with Cable Logging

Alternative 3 – Proposed Action 

without Cable Logging

Alternative 4 – Minimal 

Treatment

Total Treatment Acres Jack Smith 

Schultz/Eastside15

8,937 acres

5,963 acres DLH

2,975 acres MM

8,937 acres

5,963 acres DLH

2,975 acres MM

5,802 acres 

3,459 acres DLH

2,343 acres MM

Percentage of Total Project 

Area to be Treated

0% 85%

79% DLH

100% MM

85%

79% DLH

100% MM

55%

46% DLH 

79% MM

Acres to be Hand Thinned 0 acres 846 acres

699 acres DLH

147 acres MM

832 acres

652 acres DLH

180 acres MM

438 acres

438 acres DLH

0 acres MM

Acres to be Mechanically 

Thinned

0 acres 7,124 acres

4,697 acres DLH16

2,427 acres MM

7,137 acres

4,743 acres DLH

2,394 acres MM

5,264 acres

2,953 acres DLH

2,311 acres MM

Acres to be Helicopter 

Logged

0 acres 0 acres 973 acres

973 acres DLH

0 acres MM

0 acres

Acres to be Cable Logged 0 acres 1,242 acres

1,169 acres DLH

73 acres MM

0 acres 0 acres

 

15 Past projects with acreages within the FWPP boundary that could be implemented

16 Includes cable logging areas that could be cut by hand
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 123

Actions Alternative 1 –

No Treatment

Alternative 2 – Proposed 

Action with Cable Logging

Alternative 3 – Proposed Action 

without Cable Logging

Alternative 4 – Minimal 

Treatment

Acres to be Prescribed 

Burned

0 acres 8,937 acres

5,963 acres DLH

2,975 acres MM

8,937 acres

5,963 acres DLH

2,975 acres MM

5,802 acres 

3,459 acres DLH

2,343 acres MM

Campfire Closure Order No Yes Yes Yes

Forest Plan Amendments No Yes

1. Related to MSO 

2. Mechanical Treatment on 

slopes >40%

Yes

1. Related to MSO 

2. Mechanical Treatment on slopes 

>40%

Yes

1. Related to MSO 

2. Mechanical Treatment 

on slopes >40%

Harvest Methods for 

treatments on slopes > 40%

N/A Combination of hand 

thinning, mechanized 

equipment, and cable logging

Combination of hand thinning, 

mechanized equipment, and 

helicopter logging

No treatment except for 

select areas of hand 

thinning

Acres Treated in MSO 

Protected Habitat

0 acres 3,926 acres (99%) 3,954 acres (100%) 2,427 acres (61%)

Acres Treated in MSO 

Recovery Habitat

0 acres 2,584 acres (86%) 2,584 (86%) 927 acres (31%)

Treatments in MSO Nest 

Cores

No Yes, hand thinning 122 acres 

and prescribed burning all 

(785 acres total)

Yes, hand thinning 122 acres and 

prescribed burning all (785 acres 

total)

Yes, hand thinning and 

prescribed burning of 122 

acres total.

Acres Treated by Cable 

Logging within MSO 

PACs17

0 465 acres* 0 acres 0 acres

Cable Corridor Acres within 

MSO PACs

0 74 acres 0 acres 0 acres

Acres Treated by Helicopter 

Logging within MSO 

PACs18

0 0 acres 267 acres* 0 acres

 

17 Indicates acres where all snags would have to be removed for safety purposes.

18 Indicates acres where all snags would have to be removed for safety purposes
Chapter 2. Alternatives

124 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Actions Alternative 1 –

No Treatment

Alternative 2 – Proposed 

Action with Cable Logging

Alternative 3 – Proposed Action 

without Cable Logging

Alternative 4 – Minimal 

Treatment

Total Temp Roads Mileage 0 miles 20.98 miles

17.39 DLH

3.59 MM

15.17 miles

12.65 DLH

2.52 MM

12.71 miles

10.19 DLH

2.52 MM

Temp Road Mileage within 

MSO PACs

0 miles 4.7 miles 3.1 miles 3.1 miles

System Road 

Decommissioning

0 miles 4.38 Miles 4.38 Miles 4.38 Miles

Table 26 and Table 27 show a comparative summary the transportation system for all action alternatives

Table 26: Comparison of transportation systems proposed for each alternative, Dry Lake Hills

Alternative 1 Alternative 2 Alternative 3 Alternative 4

System haul roads 

within the project 

area 

18.07 miles 18.07 miles 18.07miles 13.04 miles

System haul roads 

outside the project 

area

14.33 miles 14.33 miles 14.33 miles 7.37 miles

New temporary 

haul roads 

constructed

0.0 miles 14.64 miles 9.91 miles 9.20 miles

Temporary roads 

on existing road 

prisms

0.0 miles 2.75 miles 2.75 miles 0.99 miles

Temporary road 

rehabilitated

0.0 miles 17.39 miles 12.66 miles 10.19 miles

Relocated system 

road used as haul 

road

0.0 miles 1.57 miles 1.57 miles 1.57 miles

System road 0.0 miles 4.19 miles 4.19 miles 4.19 miles
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 125

Alternative 1 Alternative 2 Alternative 3 Alternative 4

decommissioned

Table 27: Comparison of transportation systems proposed for each alternative, Mormon Mountain

Alternative 1 Alternative 2 Alternative 3 Alternative 4

System haul roads 

within the project 

area 

16.46 miles 16.46 miles 16.46 miles 16.46 miles

System haul roads 

outside the project 

area

18.13 miles 18.13 miles 18.13 miles 18.13 miles

New temporary 

haul roads 

constructed

0.0 miles 1.07 miles 0 miles 0 miles

Temporary roads 

on existing road 

prisms

0.0 miles 2.52 miles 2.52 miles 2.52 miles

Temporary road 

rehabilitated

0.0 miles 3.59 miles 2.52 miles 2.52 miles

Relocated system 

road used as haul 

road

0.0 miles 0.53 miles 0.53 miles 0.53 miles

System road 

decommissioned

0.0 miles 0.19 miles 0.19 miles 0.19 miles
Chapter 2. Alternatives

126 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 28: Comparison of Effects between Alternatives 

Actions Alternative 1 –

No Treatment

Alternative 2 – Proposed 

Action with Cable Logging

Alternative 3 – Proposed Action 

without Cable Logging

Alternative 4 – Minimal 

Treatment

Percentage of Project Area 

predicted to have active 

crown fire post-treatment

57% Total

51% DLH

70% MM

7% Total

9% DLH

2% MM

7% Total

9% DLH

2% MM

28% Total

32% DLH

19% MM

Percentage of MSO PAC 

acreage predicted to have 

active crown fire posttreatment

65% of PACs

65% DLH

66% MM

9% of PACs

17% DLH

1% MM

9% of PACs

17% DLH

1% MM

31% of PACs

37% DLH

25% MM

Percentage of project area 

predicted to have high soil 

burn severity in simulated 

wildfire post-treatment

39% DLH

62% MM

8% DLH

1% MM

8% DLH

1% MM

30% DLH

17% MM

Anticipated discharge (cfs) 

within DLH after a

simulated wildfire, during 

Schultz Rain Event19

2,014 cfs 804 cfs 804 cfs 1,409 cfs

Total sediment delivery 

(tons) after simulated 

wildfire20

14,912 tons DLH

2,445 tons MM

8,277 tons DLH

1,432 tons MM

8,277 tons DLH

1,432 MM

12,977 tons DLH

1,551 MM

Total number of trees >18” 

dbh within cable logging 

corridors to be removed in 

MSO PACs

0 132 Total

108 DLH

24 MM

0 0

 

19 Schultz rain event equates to the rain event on July 20, 2010, which produced approximately 1.78 inches in 45 minutes over the area impacted by the Schultz fire.

20 In first year after simulated wildfire
Chapter 2. Alternatives

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 127

Actions Alternative 1 –

No Treatment

Alternative 2 – Proposed 

Action with Cable Logging

Alternative 3 – Proposed Action 

without Cable Logging

Alternative 4 – Minimal 

Treatment

Number of Trees >24” dbh 

within cable logging 

corridors to be removed in 

MSO Recovery Habitat

0 206 Total

206 DLH

0 MM

0 0

Acres of treatment where all 

snags have to be removed 

for safety within MSO 

PACs

0 391 acres 267 acres 0 acres

Temp Road Mileage within 

MSO PACs

0 miles 4.7 miles 3.1 miles 3.1 miles

Road Decommissioning 0 miles 4.38 Miles 4.38 Miles 4.38 Miles

Overall effects to MSO No Impact May have impacts to breeding 

owls as treatments could 

occur within PACs during the 

breeding season for up to two 

years; cable corridors would 

affect quality of critical 

habitat in the short-term 

through the removal of snags 

and large trees. Long-term 

benefits would include 

reduction in risk of highseverity wildfire. 

May have impacts to breeding owls 

as treatments could occur within 

PACs during the breeding season 

for up to two years; areas treated by 

helicopter would affect quality of 

critical habitat in the short-term 

through the removal of snags. 

Long-term benefits would include 

reduction in risk of high-severity 

wildfire. 

May have impacts to 

breeding owls as 

treatments could occur 

within PACs during the 

breeding season for up to 

two years. The project 

activities may affect, but 

are not likely to adversely 

affect MSO critical 

habitat due to the lack of 

having to remove large 

numbers of snags for 

safety requirements. 

Total Implementation 

Cost 

(Net Timber Value minus 

Cost of Implementation)

$102,000

(cost of 

archaeological 

surveys completed)

$7,319,774 $8,508918 $4,079,279
Chapter 3. Affected Environment and Environmental Consequences

128 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 129

Chapter 3. Affected Environment and 

Environmental Consequences

This chapter summarizes the physical, biological, social, and economic environments of the 

project area and the effects of implementing each alternative on that environment. This also 

includes an analysis of the proposed Forest Plan amendments, which is included near the end of 

each resource section. It also presents the scientific and analytical basis for the comparison of 

alternatives presented in the alternatives chapter. Summaries for each resource area are provided 

and all specialist reports are incorporated by reference. Full specialist reports can be found in the 

project record, located at the Flagstaff Ranger District Office. 

Fire & Fuels

This section discusses the effects and concerns of four alternatives on the fire hazard and fuels 

conditions within the project area. Specifically, this section addresses effects relating to fire 

hazard, vegetative condition, and fuel loading conditions of stands within the project area under 

the No Action Alternative as well as the action alternatives, and the projected condition of the 

project area in the next 20 years under each treatment option. 

Several variables affect fire behavior on a site and over a landscape. Besides weather and terrain,

(e.g. slope steepness, aspect, and landform types such as chutes, canyons, chimneys, saddles, 

etc.), the variables that play the largest role in influencing fire behavior within a forest include 

dead and live fuel loadings, fuel moistures, crown bulk density (the volume of fuel available in 

tree crowns), crown base height (the height at which tree branches can be ignited by ground fire), 

and canopy closure (percentage of ground area vertically shaded by overhead foliage) (Agee and 

Skinner 2005).

These variables, depending on their structure and arrangement, can create many different fire 

behavior outcomes for a landscape. Intense fire behavior will most likely occur during hot, dry, 

and windy weather conditions under forest conditions of high fuel loadings, including a large

number of trees per acre, high crown bulk densities, low crown base heights, and large 

percentages of canopy closures. 

Fire hazard ratings are used to quantify the intensity with which a fire can burn over a landscape 

during hot, dry and windy conditions. These weather conditions typically occur from April 

through July on the Mogollon Rim (where FWPP is located), until a monsoonal weather pattern 

sets up. Fire hazard ratings assigned to an area reflect the collective effects of fuel loadings, 

crown bulk density, crown base height and canopy closure on fire behavior if a wildfire were to

occur in the same area under 97th percentile weather conditions. This analysis uses both 97th

percentile weather and 2010 Shultz Fire weather conditions to give both a worst case scenario and 

a scenario that has already occurred in the watershed around Flagstaff. For the analysis, the 97th

percentile weather conditions will only be used to show existing condition; whereas, 2010 Schultz 

Fire weather conditions will be used for both existing conditions and alternative comparison (see 

Methodology section for more information). 

Fire Hazard Ratings range from extreme to low, with extreme indicating that the area rated as such 

is in the highest danger of a worst case wildfire scenario. That is, the area rated as extreme will 

most likely experience high intensity fire if a wildfire were to start during hot, dry, and windy 
Chapter 3. Affected Environment and Environmental Consequences

130 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

conditions. This type of fire would most likely be stand replacing and would create and/or result 

in fire effects outside the historical range of variability for ponderosa pine and mixed conifer 

ecosystems in the project area.

This section also uses Fire Regime Condition Class (FRCC) as a metric in determining the 

existing ecosystem health of a landscape as it relates to historic condition. This metric in its 

original form reflects the current vegetative structure, composition, and amount in relation to the 

departure of that structure, composition, and quantity from the natural range of variability for that 

area. 

Methodology & Assumptions Used in Analysis

A fire regime generally classifies the role of fire over the landscape in the absence of modern 

human mechanical intervention. There are five natural fire regimes, which are characterized 

based on average numbers of years between fires combined with fire severity of the dominant 

overstory vegetation. One can examine fire regimes at a finer scale in which each regime can be 

described at three different condition classes (I, II, III), also known as fire regime condition 

classes (FRCCs). Condition classes were created to characterize the importance of fire frequency 

in ecosystems. FRCC quantifies the amount that current vegetation has departed from the 

simulated historical vegetation reference conditions due to an absence of fire and an increase in 

fire return intervals (Havelina et al. 2010). 

The deviation from the historic fire regime is measured according to the number of fire return 

intervals missed and the disturbance regime altered so as to alter current structure and 

composition of the system outside the normal range of variation (LANDFIRE 1.1.0). FRCC 

includes measures of the departure from historic fire severity and frequency for a given 

landscape. The level of departure is attributable primarily to an increase in fire suppression and 

fire exclusion over the last 125 years and/or an increase in fire return intervals within the area

(e.g. fires occur less frequently), thereby altering the ecological function of fire within that area. 

The lack of low intensity, high frequency fires in the forests of northern Arizona have led to forest 

conditions of higher fuel loadings and a larger number of small and medium-sized trees per acre 

compared to the conditions that occurred historically. 

FRCC is a difficult metric to develop accurately using tools currently available. For this analysis,

fire regimes and FRCCs within the project were assessed using LANDFIRE (LANDFIRE 2013). 

LANDFIRE uses vegetation condition class (VCC) as a surrogate to FRCC, but lack values in fire 

regime departure (Hann and Bunnell 2001). The fire regimes for the project area include I, III, IV, 

and V and the condition classes range from level 1 to level 3. In general, if fire is absent for

more than 100 years, most likely the fire will result in some stand replacement with the rest 

resulting in surface fire activity. Fire regime I indicates that historical fires reoccur in less than a 

35 year period, with fires resulting in a low percentage of overstory trees in the stand being 

replaced. Fires in a stand of fire regime III would generally reoccur every 35 to 200 years with 

mixed/low severity. Fire Regime IV indicates 35 to 100 year frequency, high replacement 

severity. Fire regime V indicates greater than 100 year frequency and severity.

The fuel moisture and weather characteristics used to model the effects and behavior of a 

potential wildfire for existing and desired conditions are conditions under 97th percentile and 

conditions observed on the Schultz fire on June 20th, 2010. The conditions used were as follows: 
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 131

97th Percentile Conditions

1-hour fuel moisture: 2%

10-hour fuel moisture: 2%

100- hour fuel moisture: 4%

1000- hour fuel moisture: 7%

20-foot wind speed: 35 mph

Air temperature: 850F

These weather conditions were used in modeling to give an overall worst case scenario in terms 

of crown fire potential. The 97th percentile conditions represent the top 3 percent worst fire 

weather days from 2002-2013. 

Schultz Fire Conditions

1-hour fuel moisture: 3%

10-hour fuel moisture: 3%

100- hour fuel moisture: 6%

1000- hour fuel moisture: 11%

20-foot wind speed: 23 mph

Air temperature: 740F

These weather conditions were used in modeling because the Schultz Fire was one of the biggest 

high intensity/stand replacing fires that has occurred most recently within fifteen miles of 

Flagstaff, Arizona and the fire resulted in a considerable amount of immediate damage and 

devastation to ecological resources and values at risk within the fire and to surrounding areas. 

Weather conditions used in FVS/FFE for prescribed fire under all action alternatives are as 

followed. Weather conditions used are common for prescribed fire activity on the Flagstaff RD. 

However variables such as wind speed, air temperature, and moisture contents are on the upper 

end of prescriptions. Typically prescribed fire would be implemented under more moderate 

conditions; this report analyzes higher end limits of prescribed fire conditions in order to be as 

conservative as possible to address concerns about potential impacts of prescribed fire.

1-hour fuel moisture: 8%

10-hour fuel moisture:8%

100- hour fuel moisture: 10%

1000- hour fuel moisture: 15%

20-foot wind speed: 10 mph

Air temperature: 800F

Live fuel moisture: 110%

Duff moisture content 50%

The objective of the modeling performed in this analysis is to:

1. Clarify potential effects of a wildfire burning under conditions similar to the Schultz fire

and 97th percentile weather conditions.

2. Identify areas where fire behavior may be problematic from the perspectives of both fire 

effects and control issues.

3. Analyze and evaluate the effects of the different alternatives.

The following metrics will be used to evaluate fire behavior and effects, and are grouped into 

three main sections for the analysis: ground fuels and vegetation; fire suppression, and wildfire 
Chapter 3. Affected Environment and Environmental Consequences

132 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

hazard. For more details on model inputs, methodology and assumptions, refer to the Fire & Fuels 

Specialist Report located in the project record.

1) Fire Behavior (active/passive crown fire, surface fire, heat/unit/area, and fireline intensity)

2) Arrival time: There is no way to know with any certainty where a wildfire would start, so 

three separate ignition point sources were used. Areas used in modeling were identified by 

the District Fuels Specialist based on values at risk, such as urban interface concerns, 

watershed values and recreational activities that occur in the project areas. Modeling 

parameters included Schultz fire weather conditions. Ignition source locations used in the 

DLH area for modeling were:

a) The intersection of Forest road (FR) 420 and 557 (the Y)

b) The intersection of FR 557 and Lower Oldham Trail.

c) At the National Forest boundary north of Paradise Street. 

The modeling ignition location on MM was placed on along FR 648 (Mormon Mountain Tower 

Road). The three areas in the DLH and the one location on MM are identified on the Arrival time 

maps for each alternative below.

3) Emissions: Particulate matter of 2.5 microns or less (PM 2.5) is addressed in the Clean Air Act 

and has a NAAQS annual mean of 15μg/m3, and a 24 hour average of 35μg/m3. Although 

modeling total potential outputs, it is important to note that it is not the total amount of emissions 

from a fire that affect human health, but rather how concentrated pollutants in ambient air are for 

a period of time. PM 2.5 emission amount under a wildfire scenario are estimated using FVS per 

alternative

4) Fire Hazard Ratings: Fire hazard ratings were calculated for existing and desired conditions for 

50 percent of the DLH and 93 percent in the MM project areas, commensurate with the area in 

which field data was collected in each portion of the total project area. Less data was collected in 

the DLH due to steep slopes and lack of access. The field data collected to calculate existing fire 

hazard ratings in the project area include dead and down fuel loading (tons per acre), number of 

tree stems per acre, tree diameter, percent canopy closure, height to bottom of live crown (crown 

base height), and tree height. Slope and aspect also affect fire hazard ratings and therefore were 

acquired for stands in the project area using 10 Meter Digital Elevation Models.

5) Crown fire potential (pre and post treatment): assessed using FlamMap 5.0 modeling, including 

LANDFIRE data GIS. The data layer is a representation of the type of fire that would be burning 

at any given location in the project area within two scenarios: 1) Weather conditions at the 97th

percentile to represent the “worst case” scenario, prevailing winds being out of the southwest, and 

sustained winds at 35mph, and 2) Schultz Fire 2010 weather conditions to represent an existing 

scenario, prevailing winds being out of the southwest at 23mph. Actual number of acres analyzed 

may differ from the proposed action acreage due to modeling outputs and pixel calculations. 

a) Three types of fires result from the modeling: Surface fire describes fire that burns 

through the surface fuels of the forest floor. This type of fire has the least active of fire 

behaviors and is the most beneficial of the three types of fires in maintaining the 

historical, ecological role of low intensity, high frequency fire in the southwestern 

ponderosa pine ecosystem. Passive crown fire, or torching, occurs when flame lengths 

are long enough to reach the lower edge of the canopy and can result in individual or 

small group tree torching but does not proliferate through the forest canopy through 

continuous crown fire spread. Active crown fire occurs when flames reach the forest 

canopy and spreads through it with intensity and continuity.
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 133

Flame Length, Stand Conditions (trees per acre, crown base height, crown bulk density, and 

down woody debris), and Predicted PM 2.5 smoke emission under a wildfire scenario were 

calculated using the Fire and Fuels Extension within the Rocky Mountain variant of the 

Forest Vegetation Simulator (FVS) for silviculture stand data for both existing and post 

treatment conditions. FVS was used to model proposed treatments and determine the effects 

of these treatments (thinning treatments only) on the fuel characteristics of and potential fire 

behavior under severe fire conditions within proposed treatment areas within the project 

areas. Dead and down woody material data was collected in the field by both a contractor 

crew and the Flagstaff Ranger District fuels/silviculture crew, and modeled based on 

treatments identified in each alternative. Stand exam data including dead and down woody 

debris data was collected using FSVeg protocols in approximately fifty percent of the DLH 

area and ninety three percent in the MMM area. No surveying and stand exam data collection 

occurred in the remaining fifty percent of the DLH and seven percent in the MM project area. 

Severe fire conditions modeled in FVS utilizing 97th percentile weather conditions, and fire 

conditions modeled under 2010 Schultz Fire weather conditions. Exact weather parameters 

are listed under the Existing Conditions portion of this report. Flame Lengths were modeled 

for both a post treatments wildfire scenario (surface + crown fuels) and flame lengths during 

prescribed fire (surface fuels). Canopy cover was calculated differently than the base FVS 

model. To better account for local conditions that affect canopy cover, a formula derived from 

research completed in the area was used: 

 (-57.44+25.5047*LN(BA)). 

This formula incorporates basal area (BA) calculated from FVS as a basis in the linear 

function for this formula. This formula also mirrors the formula used for the timber specialist

report.

6) Fire regimes and condition classes: Table 29 and Table 30 describe the different fire regimes 

and condition classes.

Table 29: Historic Fire Regime Groups and Descriptions 

Fire 

Regime

Frequency Severity Severity Description Vegetation types that would be 

affected by treatments proposed 

under the FWPP

I 0 – 35 years Low/ mixed Mostly low severity replaces less 

than 25% of dominant overstory 

vegetation. May include mixedseverity fires that replace up to 

75% 

In pure ponderosa pine, pine/oak, and 

savanna ponderosa pine is the 

dominant species, so the severity of a 

burn is related to the fire effects on the 

pine. 

II 0 – 35 years Replacement High severity replaces greater 

than 75 % of dominant overstory 

(grasslands). 

Grasslands and some dry mixed 

conifer vegetation types fall into this 

category. The herbaceous layer 

(grasses and forbs) are the dominant 

species. Greater than 75 percent of 

these are generally topkilled by a fire, 

so it is considered high severity. 

III 35 - 100 

years

Mixed/

low

Generally mixed-severity; may 

also include low severity fires. 

Some dry mixed conifer falls into this 

category. 

IV 35 - 100 

years

Replacement High severity. Wet Mixed Conifer and Aspen often 

falls into this category. 
Chapter 3. Affected Environment and Environmental Consequences

134 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Fire 

Regime

Frequency Severity Severity Description Vegetation types that would be 

affected by treatments proposed 

under the FWPP

V 100+ years Replacement

/any severity

Any severity may be included, 

but mostly replacement severity; 

may include any severity with 

this frequency 

Much of the Piñon/Juniper (PJ) falls 

into this category, though there are 

different types of PJ systems and the 

fire return intervals vary. 

Table 30: Condition Class definitions used for FRCC.

Departure from historic Fire Regime

Condition 

Class 1

Fire regimes are within historical ranges. Risk of losing key ecosystem components is low. 

Vegetation attributes are intact and functioning within historical ranges. 

Condition 

Class 2

Fire regimes moderately altered from historical range. Risk of losing key ecosystem components 

is moderate. Fire frequencies have departed from historical ranges by one or more return 

intervals. This has resulted in moderate changes to one or more of the following: fire size, 

intensity, severity, and/or landscape patterns. Vegetation attributes have been moderately altered 

from their historical range. 

Condition 

Class 3

Fire regimes significantly altered from historical ranges. Risk of losing key ecosystem 

components is high. Fire frequencies have departed from historical frequencies by multiple return 

intervals resulting in dramatic alterations to: fire size, intensity, severity, and landscape patterns, 

and/or vegetation attributes. 

Affected Environment

The following vegetation types occur in the DLH area include ponderosa pine, dry mixed conifer,

aspen and grasslands; vegetation types in the MM project area include ponderosa pine, dry mixed 

conifer and wet mixed conifer. Fire behavior fuel model descriptions are outlined and described 

in Scott and Burgan (2005). The number and acres of fuel models located within the project area 

differ from the number and acres of fuel models for existing conditions due to available stand 

exam data; in other words, we only used stands for which we had data. 

DLH

Ponderosa pine- 4,059 acres

Mixed conifer- 3,118 acres

Pine /Oak woodland- 277 acres

Aspen- 22 acres

Grassland- 60 acres

Right of way – 33 acres

Mormon Mountain

Ponderosa pine- 1,924 acres

Mixed conifer- 838 acres

Wet mixed conifer – 213 acres

The fire hazard ratings and the corresponding acreages for the percentage of land surveyed in the 

DLH and MM project areas as analyzed are as follows:
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 135

Based on the 3,837 acres (50%) surveyed the fire hazard ratings and the corresponding 

acreages for the Dry Lake Hills project area are as follows:

Extreme- 2,582 acres

Very High- 72 acres

High- 613 acres

Moderate-470 acres

Low- 100 acres

Based on the 2,784 acres (93%) surveyed the fire hazard ratings and the corresponding 

acreages for the Mormon Mountain project area are as follows:

Extreme- 2,089 acres

Very High- 197 acres

High- 273 acres

Moderate-174 acres

Low- 51 acres

The numbers above are a conservative estimate based on the areas that received stand exams. 

Because of the lack of fire within both project areas and knowledge of adjacent stand conditions, 

it is likely that the remaining unsurveyed acres would also be in the high to extreme rating. 

Extreme fire hazard ratings in the project areas were contributed to high fuel loading, low crown 

base heights, a large number of trees per acre, and/or large percentages for canopy closure. 

All five fire regimes and all three VCCs are represented in the project area. Table 31 displays the 

acres for each Fire Regime and condition class (VCC) found in the DLH area. Table 32 displays 

the acres for each Fire Regime and condition class found in the MM area.

Table 31: DLH Summary Fire Regime and Condition Class Acres

Fire Regime I: Frequent Fires (0-35 years), surface to mixed burn 

severity

Condition Class 1-

low vegetation 

departure

Condition Class 

Level 2- moderate 

vegetation departure

Condition Class Level 3-

high vegetation departure

6 ac. <1%% 644 ac. 12% 4,783 ac. 88%

Fire Regime III: 35 to 200 year frequency, low to mixed burn 

severity

Condition Class 

Level 1

Condition Class 

Level 2

Condition Class Level 3

<1 ac. 0% 325 ac. 18% 1487 ac. 82%

Fire Regime IV: 35 to 200 year frequency, high replacement 

severity

Condition Class 

Level 1

Condition Class 

Level 2

Condition Class Level 3

<1 ac. 0% 81 ac. 40% 123 ac 60%

Fire Regime V: > 200 year frequency, any severity
Chapter 3. Affected Environment and Environmental Consequences

136 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Fire Regime I: Frequent Fires (0-35 years), surface to mixed burn 

severity

Barren Condition Class 

Level 2

Condition Class Level 3

<1 ac.2% 28 ac. 72% 10 ac. 26%

The data from DLH shows that 4,783 acres or 88 percent of the project is in Fire Regime I, 

Condition Class Level 3 and 1,487 acres in Fire Regime III Condition Class Level 3. The high 

vegetation departure is due to the fire return interval in the area being greater than the historical 

fire return interval. 

Table 32: MM Summary Fire Regime and Condition Class Acres

Fire Regime I: Frequent Fires (0-35 years), surface to mixed burn 

severity

Condition Class 1-

low vegetation 

departure

Condition Class 

Level 2- moderate 

vegetation departure

Condition Class Level 3-

high vegetation departure

<1 ac. 0% 58 ac. 2% 2,646 ac. 89%

Fire Regime III: 35 to 100 year frequency, low to mixed burn 

severity

Condition Class 

Level 1

Condition Class 

Level 2

Condition Class Level 3

0 ac. 0% 117 ac. 4% 144 ac. 5%

The differences between the current conditions and reference conditions has created existing 

conditions in both project areas favoring wildfire activity, if started, that would result in more 

severe effects to ecosystem components than should occur under the natural fire regime for a 

majority of the project area. The introduction of thinning and prescribed fire would improve the 

VCC rating for those areas that deviate from the historical fire regime. 

The deviation between the current and historical intervals has created existing conditions in both 

project areas favoring wildfire activity, if started, that would result in more severe effects to 

ecosystem components than should occur for the natural fire regime. 

Table 33 and Table 34 describe the existing conditions based off stand data and modeling outputs 

for canopy base height, dead and down (tons/acre), canopy bulk density, percent canopy closure, 

stems per acre, flame lengths (wildfire scenario, includes surface and canopy fuels) and potential 

emissions from smoke (wildfire conditions). The existing conditions modeling outputs may 

differ from the Silviculture Report due to differences in averaging outcomes (trees per acre and 

canopy cover).
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 137

Table 33: Existing Conditions for DLH project area (2013)

Existing Conditions (2013)

Canopy Base Height (ft.)Dead and Downed Fuel (tons/acre) [avg]Canopy Bulk Density (kg/M3

)

Canopy Closure (%)Stems (Trees) per Acre Potential Wildfire Scenario Flame Length (ft.) (surface+canopy fuels)Potential Smoke Emission (PM2.5) (lbs./tons consumed)

Goshawk Nest Stands 3.0 6.2 0.07

71

594 75.1 0.10

MSO Nest Stands 6.5 29.1 0.19

64

1951 98.2 0.21

MSO Nest Roost Recovery Stands 2.6 58 0.25 70 2583 132.9 0.38

MSO PAC Stands 10.8 21 0.11 68 650 82.8 0.17

Ponderosa Pine (Goshawk Foraging and PFA outside 

MSO)

14.6 7.4 0.07 66 260 56.7 0.12

Schultz MSO Nest Stands 6.5 29 0.19 67 1952 98.2 0.21

Table 34: Existing Conditions for MM project area (2013)

Existing Conditions (2013)

Canopy Base Height (ft)Dead and Downed Fuel (tons/acre) [avg]Canopy Bulk Density (kg/M3

)

Canopy Closure (%)Stems (Trees) per Acre Potential Wildfire Scenario Flame Length (ft.) (surface+canopy)fuels)Potential Smoke Emission (PM2.5) (lbs./tons consumed)

*Mixed Conifer 10 40 0.20 64 1164 59 0.41

Ponderosa Pine 9 13 0.09 69 1281 52 0.20

*Includes wet and dry mixed conifer to include MSO Pac and Nest Cores

Measurements of existing height to live crown, dead and down fuel (tons per acre), percent 

canopy closure, fuel type, and stems per acre were collected during stand exams, and fire regime 

condition classes and fuel modes were calculated using LANDFIRE and FVS. Flame lengths 

produced under existing conditions were determined using the FFE (Fire and Fuels) Extension in 

FVS, modeled under 97th percentile conditions. As mentioned, the fuel moisture and weather 
Chapter 3. Affected Environment and Environmental Consequences

138 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

characteristics used to model the effects and behavior of a potential wildfire for existing and 

desired conditions are conditions under 97th percentile and conditions observed on the Schultz fire 

on June 20th, 2010 (see the Methodology section for more information). 

According to the modeling outcome, flame lengths under existing conditions for the majority of 

both project areas would exceed 4 feet. Flame lengths greater than 4 feet usually require these 

fires to be initially attacked using mechanical equipment such as dozers or aerial resources such 

as helicopters and air tankers. Modification of existing conditions that would lower potential 

flame lengths to approximately 4 feet if a wildfire occurred would make it more feasible for 

initial attack forces to control such a wildfire starting under 97th percentile and Schultz fire 

weather conditions. 

Modeling also showed that other forest characteristics contribute to creating severe fire effects 

and behavior in the project areas if a wildfire was to start under dry, hot, and windy weather 

conditions. Canopy closures greater than 50 percent and low crown base heights (less than about

twenty feet) contribute to considerable tree torching, spotting as much as a mile ahead of an 

intense surface fire and in some cases, crown fire spread. These fire behavior conditions would 

inevitably create a fire situation in which fire spread would be difficult to attack and control with 

ground forces within one operational shift (typically 12 hours).

Modeling crown fire potential in the DLH area under both 97th percentile and Schultz fire 

conditions are shown in Figure 37. Under 97th percentile conditions, 73 percent of the area would 

experience active crown fire, 8 percent passive crown fire and 19 percent surface fire. Under 

Schultz conditions, modeling shows 51 percent of the area would experience active crown fire, 10 

percent passive crown fire and 39 percent surface fire behavior. 

Modeling crown fire potential within the MM area under the same parameters is as follows: 97th

percentile equates to 74 percent active crown fire, 16 percent passive and 10 percent surface. 

Schultz conditions would be 70 percent active crown fire, 24 percent passive crown fire and 6 

percent surface fire. Figure 37, Figure 40 and Figure 41 show the existing condition crown fire 

potential in the DLH and MM areas, modeled under Schultz Wildfire weather conditions. 

Figure 37: Crown Fire Potential under 2010 Schultz Wildfire and 97th Percentile Weather 

Conditions for DLH and MM

97th Percentile Weather Conditions 2010 Schultz Fire Weather Conditions

Dry Lake Hills Project Area

Acres 1,426 557 5,480 2,881 749 3,832

0%

19%

8%

73%

51%

10%

39%
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 139

97th Percentile Weather Conditions 2010 Schultz Fire Weather Conditions

Mormon Mountain Project Area

Acres 286 481 2,201 176 725 2,068

Table 35 displays the estimated arrival time of the modeled fires in hours. For example, if a fire 

were to start at the Intersection of FR 420 and FR 557 (the Y). Under modeled conditions the fire 

would burn approximately 51acres in the first hour and 2,803acres within the first 5 hours. 

Arrival time and ignition locations are identified in the Methodology section and in the fire 

spread maps discussed in each alternative analysis below. 

Table 35: Arrival time in acres/hour under the Existing Condition (No Action Alternative)

Arrival Time

Intersection of 

FR 420 and 557

Intersection of FR 

557 and Oldham 

Trail Paradise

FR 648 

(Mormon 

Mountain)

1st Hour 51 acres 469 acres 259 acres 197 acres

2nd Hour 318 acres 1411 acres 1217 acres 607 acres

3rd Hour 960 acres 2414 acres 2012 acres 1003 acres

4th Hour 1604 acres 3482 acres 2773 acres 1614 acres

5th Hour 2803 acres 4156 acres 3438 acres 2508 acres

Environmental Effects

Effects Common to All Action Alternatives

There are many components that influence fire behavior. In order to address how to change the 

influence of these components on fire behavior within a stand and/or over a landscape, an 

explanation of how thinning and burning activities can affect these different components and 

thereby fire behavior has been provided here.

10%

16%

74% 70%

6%

24%

Surface Fire Passive Crown Fire Active Crown Fire 
Chapter 3. Affected Environment and Environmental Consequences

140 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Dead and down fuel loading directly effects flame length and duration. A large amount of dead 

and down fuel on the ground produces longer flame lengths for a longer period of time during 

hot, dry conditions as compared to a low amount of dead and down surface fuel loading. Longer 

flame lengths and burning durations also increase the risk or potential for fire to transition into the 

crown or forest canopy, especially if crown base heights within the stand are low. 

Periodic prescribed burning can reduce expected flame lengths by burning surface fuels initially 

and then maintaining a low dead and down fuel loading in subsequent burns. For prescribed fire 

to be effective and safe within the project area, the continuity of fuels would need to be reduced 

in advance of burning. Therefore, thinning stands before burning helps create a safer 

environment in which to implement prescribed fire. Decreasing canopy closure and crown bulk 

density can increase the canopy base height if many small trees exist in the understory and the 

majority of those small understory trees are cut. 

The height to the bottom of live crown (crown base height) directly affects how easily a fire 

torches trees, producing firebrands, and how easily a fire transitions into a crown fire. The 

number of tree stems per acre also affects how easily a fire is able to transition into a crown fire 

by not providing the fire with burnable material, but also allowing heat to accumulate more easily 

under the canopy. Thinning from below increases height to bottom of live crown, decreases the 

number of stems per acre, opens up the canopy, and allows heat created by burning surface fuels 

to be dispersed more readily. All of these actions reduce the ease with which a fire can “torch” 

trees and/or transition to a crown fire and produce firebrands that create/ignite spot fires. 

Lastly, by both thinning and burning, stands can reach conditions that are closer to the natural 

historic fire regime of vegetation characteristics, fuel composition, fire frequency, severity, and 

pattern. This can be achieved by thinning and prescribed burning at appropriate burn intervals. 

The combination of thinning and then prescribed burning in intervals should help stands that 

currently have FRCC/VCCs of three and fire hazard ratings of extreme to high to reach 

FRCC/VCCs of one or two and fire hazard ratings of moderate to low over time.

Alternative 1: No Action

Direct & Indirect Effects

Ground Fuels and Vegetation 

No fuel reduction and no change in vegetative structure of the forest within the FWPP area would 

occur under the No Action Alternative, with the exception of the areas that could be implemented 

under the Jack Smith Schultz and Eastside project decisions. This alternative would not reduce 

the existing fire hazard within the project area. Not implementing fuel treatments including 

thinning and prescribed burning would encourage a greater departure from historic fire severity 

and frequency. These conditions would persist because fuel loading would continue to 

accumulate on the forest floor without the reduction of these fuels by low intensity, high 

frequency fires mimicked by periodic prescribed burning consisting of three to seven year burn 

intervals. Also without thinning, the number of trees per acre would continue to rise both in the 

forest and in areas that were historically grasslands/meadows, thus increasing the continuity of 

fuels and the area that would be impacted by high-severity wildfire. 

Without periodic prescribed burning, crown base heights would also continue to remain low. As 

more trees grow within the project area, low crown base heights result in more crown ladder fuels 

and with them, in addition to greater crown bulk densities, an increased potential/risk for passive 
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 141

and active crown fires to occur within the forested stands of the project area during hot, dry 

weather conditions. 

High intensity, stand replacing fire would initially reduce the dead and down fuel within the 

project area, but it would do so at the cost of negatively altering existing ecosystem condition and 

diversity (vegetation, wildlife, soils, watershed, etc) and damaging heritage resource sites. The 

existing conditions would not be improved, and the majority of the project area would remain in 

at risk for active conditional crown fire (Figure 37, Figure 40 and Figure 41). Also, as time goes 

by, more dead and down woody fuel would increase, potentially increasing fire hazard over time 

as dead trees and other dead fuels produced in the stand replacing fire fall to the forest floor 

(Greenlee and Greenlee 2002).

Fire Suppression Efforts 

Under this alternative a wildfire would likely produce flame lengths in excess of four feet (Table 

33 and Table 34) over the majority of the project area. Initial attack of these fires would usually 

require using mechanical equipment such as dozers or aerial resources such as helicopters and air 

tankers. If a wildfire occurred under this alternative, it would be difficult for initial attack forces 

to control in the first operational period. Wildfires in the wildland/urban interface place 

particularly high demands on emergency response personnel, and such a fire would threaten 

multiple structures and multiple groups of people in a very short span of time. Firefighting 

resources are deployed when human life is immediately at risk or there is a clear emergency, thus 

leaving fewer personnel to actually bring the fire under control. This generally results in larger 

wildfires and greater resource damage to the National Forest and surrounding areas.

Wildfire Hazard Potential 

Another effect of the No Action Alternative would be the increased potential for a wildfire to 

become established and burn with sufficient intensity to exceed the capability of emergency 

response personnel (see fire arrival times in Figure 38 and Figure 39). 
Chapter 3. Affected Environment and Environmental Consequences

142 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 38: Estimated Fire Arrival Time for Alternative 1 DLH, modeled under 

Schultz Fire weather conditions
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 143

Figure 39: Estimated Fire Arrival Time for Alternative 1, MM, modeled under Schultz Fire 

Weather Conditions

Most of the area surrounding the project area provide several popular recreational opportunities 

for the forest visitor, such as camping, hiking, scenic viewing, hunting, and riding ATV and/or 

UTVs and is highly visited throughout the year although more so during the summer and fall 

months. Recreationists tend to build campfires during their stay in the forest; some fires are 

started in established campfire rings and others in temporary campfire rings. Many times these 

fires are left unattended or do not get properly extinguished and escape from the ring. Prevailing 

winds during the year are mostly out of the southwest. If a campfire escapes in or near the project 

area during hot, dry, windy weather conditions, this escaped fire could pose a threat to the FWPP 

project areas. The No Action Alternative would not include a permanent campfire closure order 

for the DLH portion, and also would not decommission any closed Forest Roads; thereby 

campfires and illegal public access could still occur, and the threat of human-caused fires would 

remain. 

Finally, Alternative 1 leaves much of the area in extreme and very high fire danger as well as 

Condition Class III (a severe departure from the natural historical regime of vegetation 

characteristics, fuel composition, fire frequency, severity and pattern). As time passes, even more 

area would transition to a Condition Class III and further result in destructive wildfires more 

severe than the area’s historic fire regime.

Table 36 and Table 37 represent the existing conditions and anticipated conditions in twenty years 

under the No Action Alternative. 
Chapter 3. Affected Environment and Environmental Consequences

144 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 36: DLH average projected conditions in treatment areas under the No 

Action Alternative 

Alt. 1 Projected Conditions 

Dry Lake Hills

(No Action)

Canopy Base Height (ft)Dead and Downed Fuel (tons/acre) [avg]Canopy Bulk Density (kg/M3

)

Canopy Closure (%)Stems (Trees) per Acre Potential Wildfire Flame Length (ft)Potential Wildfire Smoke Emission (PM2.5) (lbs/tons consumed)

No Treatment 2017

No Treatment 2033

Goshawk Habitat (2017) 3 7 0.07 71 583 14 0.14

Goshawk Habitat (2033) 4 10 0.08 74 534 20 0.17

MSO PAC Habitat (2017) 12 19 0.10 69 610 39 0.20

MSO PAC Habitat (2033) 13 21 0.12 71 543 37 0.23

MSO Nest Core (2017) 8 22 0.11 57 546 33 0.20

MSO Nest Core (2033) 9 28 0.15 67 516 49 0.22

MSO Nest Roost Habitat 

(2017)

3 58 0.24 70 2947 86 0.40

MSO Nest Roost Habitat 

(2033)

3 58 0.25 73 2386 93 0.46

Ponderosa Pine (2017) 16 8 0.7 67 254 10 0.11

Ponderosa Pine (2033) 18 10 0.7 69 231 10 0.12

Table 37: MM average no action alternative projected conditions in treatments 

areas under the No Action Alternative

Alt. 1 Projected Conditions

Mormon Mountain

(No Action)

Canopy Base Height (ft)

Dead and Downed Fuel 

(tons/acre) [avg]

Canopy Bulk Density 

(kg/M3

)

Canopy Closure (%)

Stems (Trees) per Acre

Potential Wildfire Flame 

Length (ft)

Potential Wildfire Smoke 

Emission (PM2.5) (lbs/tons 

consumed)

No Treatment 2017

No Treatment 2033

*Mixed Conifer (2017) 9 40 0.2 64 1153 62 0.43

*Mixed Conifer (2033) 10 45 0.19 71 975 69 0.49

Ponderosa Pine (2017) 8 14 0.9 61 1198 55 0.16

Ponderosa Pine (2033) 11 17 0.11 69 919 57 0.18

*Includes wet and dry mixed conifer, to include MSO PAC’s and Nest Cores
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 145

Under the No Action Alternative, a wildfire would produce flame lengths exceeding 4 feet over 

most of the project area, making it difficult and unsafe for initial attack crews to control a wildfire 

occurring under modeled conditions. The average surface flame lengths under Schultz Fire 

weather conditions commonly range from 10 to 93 ft. (including canopy fuels) over all treatment 

areas. When looking at existing conditions of stands according to fuel model distinction, many 

areas have flame lengths that could potentially reach more than 50+ feet (including canopy fuels). 

These averages seem to be consistent considering many individual stands within treatment areas 

consist of as much as 10 to 60 tons per acre of down and dead woody debris. Furthermore, 

canopy closure exceeds 60 percent in many stands and canopy bulk density is well above 

0.02(kg/M3) in most stands.

Figure 40: Existing Conditions (No Action Alternative) fire behavior modeled under 2010 

Schultz Wildfire weather conditions – Dry Lake Hills
Chapter 3. Affected Environment and Environmental Consequences

146 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 41: Existing Conditions (No Action Alternative) Fire behavior modeled under 2010 Schultz Wildfire weather conditions – Mormon 

Mountain
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 147

Cumulative Effects

The cumulative effects boundary for this project is the Flagstaff Ranger District, as this 

encompasses most of the forested land subject to the prevailing winds driving a wildfire into the 

community of Flagstaff and the surrounding areas. The project areas (DLH and MM) are within 

the Flagstaff Community Wildfire Protection Plan area (CWPP) the treatments proposed are in 

line with the goals and objectives set forth by the CWPP.

The time period analyzed for the cumulative fire effects of this project includes a twenty year 

period from 2013 to 2033. Prior to that time the only activities in the area that affected the fire 

hazard were aggressive fire suppression and the continuing growth of forest vegetation.

Implementation of the No Action Alternative, along with past, present, and reasonably 

foreseeable actions, may have cumulative effects relative to fire and fuel conditions within the 

project area. 

When combined with the effects of climate change, a cumulative effect of the No Action 

Alternative would be an increase in the number of acres of national forest on the District that are 

vulnerable to severe fire effects. The vegetation type across the Coconino National Forest

requires periodic fire to remain balanced. Fuel conditions have reached a point where fire effects 

are more severe than desired and more severe than would naturally occur. The fire hazard and fuel 

profile increases with time as the vegetation grows and dies. 

Unavoidable Adverse Effects, Irreversible and Irretrievable Commitment of 

Resources

As described above, with no treatment, there would be a higher risk of large, high severity fires 

than occurred historically, or than are sustainable within the project area. In recent years, fires on 

the Mogollon Rim that have taken human lives, destroyed homes/property/infrastructure, and 

produced high severity effects across large areas not adapted to high severity fire include 

Rodeo/Chediski 2002 (469,000 acres), Wallow 2011 (538,000 acres), and Whitewater-Baldy 

Complex 2012 (approximately 3000,000 acres). Such fires permanently change tens of thousands 

of acres of forests when they burn with high severity in areas which are not adapted to high 

severity fire. There is broad consensus that such fires would burn in this area if there is no action 

taken, though the specific extent and location of the negative effects would not be known until an 

incident occurs. First order effects would include (but are not limited to) high levels of tree 

mortality across the burned area (assuming ~30 percent high severity). Second order fire effects 

would include (but are not limited to) destroyed infrastructure. Some of these effects would last 

just a few days or weeks (infrastructure would be rebuilt), some would take years to recover, 

some changes would be permanent (Savage and Mast 2005). 

Direct and Indirect Effects Common to Alternatives 2 & 3

Alternative 2 and 3 have similar desired outcomes with slight differences in harvesting methods. 

Effects to ground fuels and vegetation, fire suppression efforts, and wildfire hazard potential (not 

including canopy fire potential and anticipated prescribed fire effects) are the same between the 

two alternatives, and are discussed here. Those differences in effects are discussed separately 

under each alternative.
Chapter 3. Affected Environment and Environmental Consequences

148 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Ground Fuels and Vegetation

Direct effects of Alternatives 2 and 3 would be consistent with other similar fuels treatment 

projects on the Flagstaff Ranger District: prescribed fire would reduce surface fuels, raise crown 

base heights, reduce stems per acre and improve stand conditions. Initial entry and maintenance 

prescribed fire may also result in an increase in tree mortality and reduce the amount of available 

logs and snags. However, with the anticipated mortality associated with prescribed burning 

(Table 39 and Table 40), snags and logs would be created to offset the direct effect. 

Fire Suppression Efforts

Fuel reduction treatments within the wildland urban interface should reduce expected fire 

behavior to a level at which a small number of personnel can quickly and effectively control a 

wildfire. The objectives of the treatments are to reduce the possibility that wildfires can get 

established at sizes beyond the capacity of initial attack forces and reduce the intensity with 

which wildfires can burn. These reductions further reduce the probability that the demand on 

emergency response personnel would be exceeded and reduce the threat to life and private 

property. Wildfires can be controlled with fewer acres burned resulting in less damage to the 

National Forest and adjacent lands. Also, wildfires burn less severely resulting in less resource 

damage to each acre burned. 

Wildfire Hazard Potential

Alternatives 2 and 3 would result in short-term increases (one to two years) in wildfire hazard 

potential while treatments are occurring due to dead trees and slash being produced on site. While 

the proposed thinning reduces crown fire ladders, canopy closure, and crown loading, the 

majority of the slash produced would be piled on site, temporarily increasing the dead and down 

fuel loading until the piles are burned within prescription. Slash treatments under the alternatives

would possibly include whole tree harvesting, which consists of all woody debris being removed

from the forest and therefore reducing the need for pile burning. If available, biomass utilization 

would also remove slash and debris from the forest, thus negating the need for pile burning and 

resulting in an immediate reduction in wildfire hazard potential. However, under all slashremoval options, broadcast burning would still occur prior to or within 1 to 3 years after 

implementation of thinning, along with maintenance burning every 5-7 years in the ponderosa 

pine vegetation type. This would maintain post treatment fuels conditions within those areas. 

Within the mixed conifer vegetation type, maintenance burning may not occur during the life of 

the project due to its historical fire return interval. Because of this, wildfire flame lengths and 

down woody debris would increase over the 20 year period for Alternatives 2 and 3 (Table 42 and

Table 48. 

By treating the FWPP area, the risk of a crown fire starting in the project areas and spreading as a 

crown fire through adjacent areas would be reduced. This treatment would further reduce the risk 

of crown fire spreading to nearby urban interface areas at risk and improve this fire adapted 

ecosystem. Additionally, fire spread is anticipated to be slower when modeled under Schultz Fire 

weather conditions (Figure 42 and Figure 43).
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 149

Figure 42: Estimated Fire Progression for Alternatives 2 and 3, DLH
Chapter 3. Affected Environment and Environmental Consequences

150 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 43: Estimated Fire Progression for Alternatives 2 and 3, MM
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 151

Alternatives 2 and 3 would include a permanent campfire closure order for the DLH portion, and 

also would decommission approximately 4 miles of Forest Roads. This would result in a decrease 

in campfires and unauthorized motorized public access, thereby reducing the threat of humancaused fires within the DLH (Dickson et al. 2006).

Alternatives 2 and 3 address the purpose and need more so than Alternatives 1 (No Action) and 4

by reducing the crown bulk density (thinning), reducing the canopy closure (thinning), increasing 

the effective crown base height in most sites (thinning and prescribed burning over time), and 

reducing the number of potential firebrands and shortening the distance at which spot fires would 

be expected to occur (thinning and prescribed burning). Furthermore, Alternatives 2 and 3 meet 

the project goals and objectives because the fire hazard would be drastically reduced in the 

project area from extreme, very high, and high, to mostly high, moderate, and low, and overall 

goals for community protection and resource protection would be met compared to the results of 

the No Action Alternative.

Crown Fire Potential

Crown fire potential for DLH modeled under Schultz conditions shows active crown fire on 658

acres, passive crown fire on 93acres and 6,686 acres of surface fire (Figure 44 and Figure 45).

Crown fire potential for MM modeled under Schultz conditions shows active crown fire on 63

acres, passive crown fire on 329 and 2,577 acres of surface fire (Figure 44 and Figure 46). Due to 

consistency in treatments between Alternatives 2 and 3, the two alternatives were modeled using 

the same post-treatment condition data set. Under Alternative 3, there may be a slight increase in 

passive/active crown fire related to an increase in residual dead and downed fuel; however, this 

increase is negligible in the scope of modeling.

Figure 44 Modeled crown fire potential Alternatives 2 and 3

2010 Schultz Fire Weather Conditions

Dry Lake Hills Project Area

Acres 6,686 93 658

90%

1% 9%
Chapter 3. Affected Environment and Environmental Consequences

152 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

2010 Schultz Fire Weather Conditions

Mormon Mountain Project Area

Acres 2,577 329 63

Table 38: Crown Fire potential Alternatives 2 and 3

Dry Lake Hills Existing 

Crown Fire 

Potential (97th 

%)

Existing 

Crown Fire 

Potential 

Schultz

Alternative 2 & 3

Schultz conditions

Active 5,480 acres 3,832 acres 658 acres

Passive 557 acres 749 acres 93 acres

Surface 1,426 acres 2,881acres 6,686 acres

Mormon 

Mountain

Existing 

Crown Fire 

Potential (97th 

%)

Existing 

Crown Fire 

Potential 

Schultz

Alternative 2, 

Schultz conditions

Active 2,201 acres 2,068 acres 63acres

Passive 481 acres 725 acres 329 acres

Surface 286 acres 176 acres 2,577 acres

*Differences between 97th percentile conditions and Schultz are negligible, 

therefore only post treatment conditions under Schultz are listed. 

Crown fire potential as modeled for Alternatives 2 and 3 for the DLH unit under Schultz 

Surface Fire Passive Crown Fire Active Crown Fire 

87%

11%

2%
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 153

conditions shows a reduction of crown fire potential from 3,832 to 658 acres of active crown fire, 

749 to 93 acres passive crown fire and 2,881 to 6,686 acres of surface fire behavior. 

Crown fire potential as modeled for Alternatives 2 and 3 for the MM unit under Schultz 

conditions shows a reduction of crown fire potential from 2,608 to 63 acres of active, 725 to 329 

acres of passive crown fire and 176 to 2,577 acres of surface fire behavior

Figure 45: Alternatives 2 and 3 fire behavior post-treatment, modeled under 2010 Schultz 

Wildfire weather conditions – DLH
Chapter 3. Affected Environment and Environmental Consequences

154 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 46: Alternatives 2 and 3 fire behavior post-treatment, modeled under 2010 Schultz Wildfire weather conditions – MM
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 155

Alternative 2: Proposed Action with Cable Logging 

The DLH area includes approximately 7,569 acres; 836 acres are currently being treated under 

the Jack Smith Schultz project and roughly 769 acres are either non-treatable due to rock faces 

and/or boulder fields. Under Alternative 2, treatments in the DLH would include mechanical and 

hand thinning as well as prescribed fire on the remaining acres (approximately 5,963 acres), with 

the use of cable logging to remove cut material from steep, inaccessible slopes on approximately 

1,185 acres.

The MM area includes approximately 2,974 acres. Treatments would include mechanical and 

hand thinning as well as prescribed fire with approximately 106 acres of cable logging proposed.

Alternative 2 also proposes prescribed burning in the wet mixed conifer in the MM area. Burning 

techniques in the wet mixed conifer would target accumulated dead and down material rather than 

usual broadcast burning ignition patterns.

Direct and Indirect Effects

As discussed under Direct and Indirect Effects Common to Alternatives 2 and 3, the majority of 

effects between these two action alternatives would be the same. Therefore, only the differences 

are discussed here and under Alternative 3. 

Prescribed fire would include initial pile burning to remove slash accumulated through 

harvesting, followed by broadcast burning. Within the ponderosa pine vegetation type, 

maintenance burning may occur every five to seven years following implementation in order to 

maintain lower fuel loading levels and to restore a frequent, low-severity fire regime. Mixed 

conifer stands may only receive one broadcast burn through the life of the project due to the 

historic Fire Return Interval. Effects of target burring accumulated dead and down fuels in wet 

mixed conifer would result in a decrease of available fuel loading that would otherwise be left 

and could potentially increase the likelihood of crown fire initiation. Other slash removal options 

as described in the Implementation Methods section could also be used in lieu of burning, 

including biomass removal.

Table 39 and Table 40 represent prescribed fire implementation effects by treatment types. 

Table 39: Prescribed Fire Implementation Effects Dry Lake Hills ALternative 2

Alt.2 Prescribed Fire Implementation 

Effects by Treatment Flame 

Length 

(ft.)

Scorch 

Height 

(ft.)

Smoke 

Emission 

(PM2.5) 

Mortality 

(BA 

Killed)

Post Burn 

DWD 12+ 

(tons/acre)

Electronic Site – Structure Protection **Not Modeled

Grassland Restoration **Not Modeled

Ponderosa Pine Fuels Reduction - Hand Thin **Not Modeled

Aspen Treatment - Hand Thin **Not Modeled

Mixed Conifer - Hand Thin 3.8 22.8 0.14 10.4 7.8
Chapter 3. Affected Environment and Environmental Consequences

156 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Alt.2 Prescribed Fire Implementation 

Effects by Treatment Flame 

Length 

(ft.)

Scorch 

Height 

(ft.)

Smoke 

Emission 

(PM2.5) 

Mortality 

(BA 

Killed)

Post Burn 

DWD 12+ 

(tons/acre)

MSO PAC - Hand Thin 3.7 22.1 0.1 4 14.9

Burn Only 4.9 30.6 0.08 19.4 2.7

Nest Core Burn Only 4.2 25.9 0.04 7.4 0.4*

Goshawk PFA MC Fuels Reduction GB 4 24.1 0.07 4.5 2.9

MSO PAC Fuels Reduction GB 2.6 12.5 0.09 4.4 7.8

MSO PAC Fuels Reduction Cable 2.6 12.6 0.1 3.8 8.8

Goshawk PFA PP Fuels Reduction GB 3.3 16.3 0.06 3.1 0.3*

Goshawk PFA Fuels Reduction Cable 3.2 15.9 0.09 4.6 1.1

Goshawk Nest Fuels Reduction 2.6 11.1 0.07 3.6 1.1

Schultz Nest - Hand Thin 3.6 21.1 0.1 15.8 15.8

Mixed Conifer Fuels Reduction GB 4.1 24.5 0.12 4.8 8

Mixed Conifer Fuels Reduction Cable 3.9 23.1 0.07 1.3 2.7

Ponderosa Pine Fuels Reduction GB 3.1 13.9 0.08 5 0.6*

Ponderosa Pine Fuels Reduction Cable 3.6 18.8 0.08 3.8 1.3

* Pretreatment values were less than 1 ton/acre for downed woody debris larger than 12", ** Stands not modeled due limited 

stand level data. 

Table 40: Prescribed Fire Implementation Effects Mormon Mountain Alternative 2.

Alt.2 Prescribed Fire Implementation 

Effects by Treatment

Flame 

Length 

(ft)

Scorch 

Height 

(ft)

Smoke 

Emission 

(PM2.5) 

(tons

Mortality 

(BA 

Killed)

Post Burn 

DWD 12+ 

(tons/acre)

Electronic Site - Structure Protection **Not Modeled

MSO Nest Mixed Conifer-Burn Only 1.8 7 0.18 9.1 7.1

MSO Nest Ponderosa Pine -Burn Only 2.2 10.2 0.09 11.6 0.3*

MSO Nest / Roost Recovery 3.7 21.5 0.11 11.7 1.0*

MSO PAC MC Fuels Reduction (Cable) 2.4 10.2 0.2 8.2 11.4

MSO PAC MC Fuels Reduction (Ground Based) 2.1 8 0.16 7.6 7.8

MSO PAC PP Fuels Reduction (Cable) 2.9 13.9 0.9 4.9 0.8*

MSO PAC PP Fuels Reduction (Ground Based) 2.9 14.2 0.1 3.8 0.8*

MSO PAC Fuels Reduction - Wet MC 4.5 24.8 0.24 33.9 14
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 157

Alt.2 Prescribed Fire Implementation 

Effects by Treatment

Flame 

Length 

(ft)

Scorch 

Height 

(ft)

Smoke 

Emission 

(PM2.5) 

(tons

Mortality 

(BA 

Killed)

Post Burn 

DWD 12+ 

(tons/acre)

Ponderosa Pine Fuels Reduction Pine/Oak 2.3 8.9 0.1 6.9 0.3*

* Pretreatment values were less than 1 ton/acre for downed woody debris larger than 12", ** not modeled due to no stand data.

Table 41 and Table 42 represent post mechanical treatments and modeled wildfire conditions if a 

fire were to start and burn through the project areas under Schultz fire conditions. 
Chapter 3. Affected Environment and Environmental Consequences

158 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 41: Dry Lake Hills average for Alternative 2 projected post-treatment conditions.

Alt. 2 Projected Conditions

Dry Lake Hills

Acreage

Canopy Base Height (ft.)

Dead and Downed Fuel 

(tons/acre) [avg]

Canopy Bulk Density 

(kg/M3

)

Canopy Closure (%)

Stems (Trees) per Acre

Post-treatment Wildfire 

Flame Length (ft.)

(surface+crown fuels) 

Potential Post-Treatment 

Wildfire Smoke Emission 

(PM2.5) (lbs/tons 

consumed)

Post-Treatment 2017

Post-Treatment 2033

Electronic Site – Structure Protection 6 **Not Modeled

Grassland Restoration 60 **Not Modeled

Ponderosa Pine Fuels Reduction - Hand Thin 150 **Not Modeled

Aspen Treatment - Hand Thin 22 **Not Modeled

Mixed Conifer - Hand Thin (2017) 132 23 15 0.05 50 112 7 0.17

Mixed Conifer - Hand Thin (2033) 23 19 0.06 55 107 7 0.17

MSO PAC - Hand Thin (2017) 202 22 20 0.04 55 82 6 0.12

MSO PAC - Hand Thin (2033) 23 23 0.04 56 75 6 0.13

Burn Only (2017) 270 19 10 0.5 53 140 15 0.13

Burn Only (2033) 24 17 0.55 57 129 16 0.14

Nest Core Burn Only (2017) 261 23 4 0.05 52 114 8 0.08

Nest Core Burn Only (2033) 28 10 0.05 53 102 8 0.10

MSO PAC Fuels Reduction GB (2017)

1167

23 13 0.04 54 307 7 0.11

MSO PAC Fuels Reduction GB (2033) 13 17 0.05 58 297 14 0.13

MSO PAC Fuels Reduction Cable (2017) 21 21 0.04 54 281 9 0.08

MSO PAC Fuels Reduction Cable (2033) 5 18 0.04 58 271 17 0.10

Goshawk PFA MC Fuels Reduction GB (2017)

100

24 7 0.04 50 200 7 0.09

Goshawk PFA MC Fuels Reduction GB (2033) 2 11 0.04 55 192 21 0.11

Goshawk PFA PP Fuels Reduction GB (2017) 29 4 0.02 49 106 4 0.05
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 159

Goshawk PFA PP Fuels Reduction GB (2033) 25 7 0.02 52 99 4 0.07

Goshawk PFA Fuels Reduction Cable (2017) 31 6 0.02 49 78 6 0.06

Goshawk PFA Fuels Reduction Cable (2033) 32 7 0.02 53 69 6 0.07

Goshawk Nest Fuels Reduction (2017) 100 23 5 0.03 54 177 5 0.05

Goshawk Nest Fuels Reduction (2033) 4 7 0.03 57 169 9 0.09

Schultz Nest - Hand Thin (2017) 122 11 22 0.07 52 210 10 0.17

Schultz Nest - Hand Thin (2033) 11 27 0.08 60 199 18 0.18

MSO Nest Roost Recovery – Hand Thin (2017) 72 21 14 0.06 54 97 7 0.17

MSO Nest Roost Recovery – Hand Thin (2033) 22 18 0.07 57 92 20 0.17

Mixed Conifer Fuels Reduction GB (2017)

1140

29 13 0.04 49 240 7 0.12

Mixed Conifer Fuels Reduction GB (2033) 9 16 0.04 53 232 15 0.14

Mixed Conifer Fuels Reduction Cable (2017) 21 21 0.04 49 308 9 0.13

Mixed Conifer Fuels Reduction Cable (2033) 5 18 0.05 53 297 19 0.14

Ponderosa Pine Fuels Reduction GB (2017)

1865

24 5 0.02 38 148 6 0.07

Ponderosa Pine Fuels Reduction GB (2033) 28 7 0.03 44 141 6 0.07

Ponderosa Pine Fuels Reduction Cable (2017) 27 6 0.02 40 93 7 0.07

Ponderosa Pine Fuels Reduction Cable (2033) 24 7 0.02 44 86 7 0.07

No Treatment 1605 - - - - - - -

** Not modeled due to limited stand data
Chapter 3. Affected Environment and Environmental Consequences

160 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 42: Mormon Mountain average for Alternative 2 projected post-treatment conditions.

Alt. 2 Projected Conditions

Mormon Mountain

Acreage

Canopy Base Height (ft.)

Dead and Downed Fuel 

(tons/acre) [avg]

Canopy Bulk Density 

(kg/M3

)

Canopy Closure (%)

Stems (Trees) per Acre

Potential Flame Length 

(ft.) Desired (4-8 ft.)

Potential Smoke Emission 

(PM2.5) (lbs/tons 

consumed)

Post-Treatment 2017

Post-Treatment 2033

Electronic Site - Structure Protection 12 **Not Modeled

MSO Nest Mixed Conifer-Burn Only

402

11 8 0.04 48 243 16 0.24

MSO Nest Mixed Conifer-Burn Only 12 24 0.05 53 227 19 0.27

MSO Nest Ponderosa Pine -Burn Only 11 8 0.04 48 243 16 0.16

MSO Nest Ponderosa Pine-Burn Only 12 24 0.05 53 227 19 0.18

MSO Nest / Roost Recovery (2017)

22 30 8.8 0.03 55 241 6 0.10

MSO Nest / Roost Recovery (2033) 30 15 0.04 61 235 6 0.14

MSO PAC MC Fuels Reduction Cable (2017)

1592

20 22 0.09 58 504 22 0.25

MSO PAC MC Fuels Reduction Cable (2033) 17 25 0.08 62 483 36 0.26

MSO PAC MC Fuels Reduction Ground Based (2017) 14 15 0.07 45 438 18 0.20

MSO PAC MC Fuels Reduction Ground Based (2033) 12 21 0.08 51 421 30 0.22

MSO PAC PP Fuels Reduction Cable (2017) 27 7 0.025 35 182 9 0.08
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 161

MSO PAC PP Fuels Reduction Cable (2033) 25 12 0.03 41 175 9 0.09

MSO PAC PP Fuels Reduction Ground Based(2017) 32 7 0.02 43 196 8 0.09

MSO PAC PP Fuels Reduction Ground Based (2033) 31 12 0.02 48 189 7 0.11

MSO PAC Fuels Reduction - Wet MC (2017)

180 9 28 0.10 60 382 33 0.38

MSO PAC Fuels Reduction - Wet MC (2033) 9 37 0.11 60 368 46 0.39

Ponderosa Pine Fuels Reduction Pine/Oak (2017)

766 30 7 0.01 42 240 5 0.08

Ponderosa Pine Fuels Reduction Pine/Oak (2033) 28 10 0.02 49 230 5 0.09

** Not modeled due to limited stand data
Chapter 3: Affected Environment and Environmental Consequences

162 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Thinning and introducing prescribed fire in the project area would lower the risk of 

uncontrollable wildfire that would produce undesirable and perhaps detrimental effects to the 

ecosystem, especially in areas where fire hazard ratings are extreme to high and fire regime and 

condition classes are outside the natural range of variability. 

Fire hazard ratings were calculated for existing and desired conditions for 50 percent (3,835 

acres) of the DLH and 93 percent (2,784 acres) in the MM areas, commensurate with the area in 

which field data was collected in each portion of the total project area.

The DLH fire hazard ratings after modeling implementation of Alternatives 2 and 3 are illustrated 

in Table 43.

Table 43: Dry Lake Hills Fire Hazard post treatment Alts 2 & 3

Existing Fire 

Hazard

Acres Percent Post 

Treatment 

Fire Hazard

Acres Percent

Extreme 2,582 67% Extreme 91 2%

Very High 72 4% Very High 268 8%

High 613 15% High 510 13%

Moderate 470 12% Moderate 1,930 50%

Low 100 2% Low 1,036 27%

MM fire hazard ratings after modeling implementation of Alternatives 2 and 3 are illustrated in 

Table 44.

Table 44 Mormon Mountain Fire hazard post treatment Alts 2 & 3

Existing Fire 

Hazard

Acres Percent Post 

Treatment 

Fire Hazard

Acres Percent

Extreme 2089 75% Extreme 526 18%

Very High 197 8% Very High 10 1%

High 273 10% High 273 9%

Moderate 173 6% Moderate 736 26%

Low 51 1% Low 1,284 46%

Modeling fire hazard after treatments within the project areas shows decreases in fire hazard, as 

Table 43 and Table 44 illustrate. However extreme and very high ratings are still present in both 

scenarios. This is because the stands are mixed conifer cover types and modeling did not show a 

drastic decrease in surface fuel loading. These stands have dead and down fuel loading of over 

45 tons per acre and are on slopes greater than 30 percent. 

Alternative 2 proposes to thin and prescribe burn 570 acres in the DLH area that are currently 

rated as moderate or low fire hazard. Within the MM area there are also 173 acres that are 

currently rated as moderate and 51 acres rated as low. Although these acres already have an 

acceptable fire hazard rating, proposed treatments would further improve stand composition, 

conditions, and structure that can lead to extreme fire behavior. Without the proposed thinning 

and burning, both current and future stand conditions would most likely promote extreme fire 
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 163

behavior within the urban interface if a fire occurred within and surrounding areas of the project 

area. 

The following table is a comparison of the arrival times for post treatment conditions. 

Table 45: Comparison Arrival time in acres/hour Alternative 2 & 3

Arrival 

Time

Intersection of FR 

420 and 557 (the Y)

Intersection of 557rd 

and Oldham Trail

Paradise Mormon Mountain 

648 Rd

Existing 

Conditions

PostTreatment 

Conditions

Existing 

Conditions

PostTreatment 

Conditions

Existing 

Conditions

PostTreatment 

Conditions

Existing 

Conditions

PostTreatment 

Conditions

1

st HR 51 1 469 23 259 91 197 1

2

nd HR 318 12 1411 45 1217 324 607 4

3

rd HR 960 25 2414 244 2012 584 1103 8

4

th HR 1604 70 3482 484 2773 971 1614 22

5

th HR 2803 192 4156 704 3438 1398 2508 81

Arrival time and ignition locations are identified in the maps displayed under the alternative 

analyses below.

The fire regime for the majority of the project would remain the same (fire regime 1) an open 

forest maintained by frequent low severity fires. The remaining portions of the project area are

fire regime II characterized by a fire frequency between 0 and 35 years, but with a high severity 

(more than 75 percent of the dominant overstory replaced) and fire regime III a mosaic of open 

forest to mid-seral maintained by mixed severity fires recurring generally 35 to 100 years. Over 

the course of the 20 years analyzed, the vegetation condition classes would be greatly improved, 

where vegetation composition, structure, and fuels are similar to those of the natural regime and 

do not predispose the system to risk of loss of key ecosystem components. A wildfire occurring 

under post-treatment conditions would be characteristic of the historic fire regime behavior, 

severity, and patterns. 

Cumulative Effects 

The area analyzed for the cumulative fire effects of this project is the Flagstaff Ranger District, as 

this encompasses most of the forested land subject to the prevailing winds driving a wildfire into 

the community of Flagstaff and the surrounding areas. The project areas (DLH and MM) are 

within the Flagstaff Community Wildfire Protection Plan area (CWPP) the treatments proposed 

are in line with the goals and objectives set forth by the CWPP.

The time period analyzed for the cumulative fire effects of this project includes a twenty year 

period from 2013 to 2033. Prior to that time the only activities in the area that affected the fire 

hazard were aggressive fire suppression and the continuing growth of forest vegetation. 

The effects of FWPP would cumulatively combine with other previously-analyzed forest health 

and fuel reduction projects that lie in the path of the prevailing winds around Flagstaff and its 

suburbs (Wing Mtn., Hart Prairie, Eastside, Ft. Valley Restoration, A-1 Multi-Product, Mars Hill, 

Ritter, Sinks, Mormon Lake Basin, Woody Ridge, Kachina Village, Lake Mary Fuel Reduction, 

Mountainaire, Elk Park, Jack Smith Schultz, Eastside, Marshall and Skunk Fuel Reduction) to 

reduce the risk of high severity fire impacting the City of Flagstaff. The treatments within these 
Chapter 3: Affected Environment and Environmental Consequences

164 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

projects do not eliminate the chance of a crown fire, but greatly reduce the chance of a crown fire 

initiating within their bounds and spreading to adjacent lands. 

The Flagstaff District is currently conducting analysis for the Turkey Butte - Barney Pasture 

Forest Health and Fuels Reduction Project, located approximately thirty miles south of the 

Flagstaff area. However, this project would not have a cumulative effect on the fire behavior or 

fire hazard of the FWPP area due to the distance between the two project areas. 

By treating the Flagstaff Watershed Protection area, the risk of a crown fire starting in the project 

areas and spreading as a crown fire through adjacent areas would be reduced. This treatment 

would further reduce the risk of crown fire spreading to nearby urban interface areas at risk and 

improve this fire adapted ecosystem.

The Four Forests Restoration Initiative (4FRI) is currently being assessed through the NEPA 

process. The preferred alternative includes 434,001 acres of mechanical vegetation treatments and 

593,211 acres of prescribed burning, and encompasses a large portion of the Flagstaff Ranger 

District, including most of the acres adjacent to MM, and many areas adjacent to DLH. The 

implementation of the 4FRI acres covered in the FEIS is expected to begin in late 2014 or 2015. 

The 4FRI will have significant impact on hazardous fuel loading and fire hazard on the Flagstaff 

District. The cumulative effects, when combined with FWPP, should greatly reduce the likelihood 

of high-intensity crown fire from entering the project area from the surrounding landscape over 

the next ten years. Both the DLH and the MM areas overlap with 4FRI treatments, and 

implementation should occur simultaneously, thus in the short-term (one to two years in treatment 

areas) these overlapping or adjacent treatments could result in an increase in activity fuels, which 

could increase the likelihood of passive crown fires occurring.

The effects of past treatments and wildfires within the area considered for cumulative effects 

could affect if and how wildfires burn into the treatment area. Vegetation/fuels in treated/burned 

areas are more likely to produce surface fires, which are easier to manage and are likely to 

produce effects that are beneficial to the ecosystems. Since existing conditions and proposed 

treatments vary widely across the projects discussed, and even within individual projects, it is 

difficult to summarize the fire effects. It is accurate to state that the combination of treatments 

would have the effect of cumulatively reducing the potential for active crown fires over the next 

20 years and thus reduce fire-induced tree mortality across all size classes.

The effects of climate change would also have an effect on the risk of high severity wildfire. 

Several studies have concluded that the expected changes in climate will likely result in more 

burned area from wildfires than in the past (Litschert et al. 2012, Marlon et al. 2009), and that 

there will be more wildfires of much greater severity, especially in the spring and early summer 

(Westerling et al. 2006). According to Millar et al., resilient forests are “those that not only 

accommodate gradual changes related to climate but tend to return toward a prior condition after 

disturbance either naturally or with management assistance (2007). Prescribed burning has been 

identified as an important management strategy for maintaining desired habitats in a changing 

climate with more natural disturbances (USDA FS 2010, Williams 2013). The cumulative effects 

of FWPP and other similar fuels reduction/forest health restoration projects on the Flagstaff 

Ranger District would be to increase the resiliency of the forest to the effects of climate change.

It is also accurate to state that wildfires occurring in these treated areas would be easier to control 

and burn less severely with less acreage burned than if the areas were left untreated. These 

projects combine to form a defensible space for Flagstaff and its surrounding communities.
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 165

Unavoidable Adverse Effects, Irreversible and Irretrievable Commitment of 

Resources

There would not be any irreversible or irretrievable commitments of resources from the reduction 

of wildfire risk and fuels reduction treatments.

Alternative 3: Proposed Action without Cable Logging

Direct and Indirect Effects 

In general, effects to fuel and fire resources under Alternative 3 would be the same as those 

described in Alternative 2, with minor differences in acreages due to harvesting methods (see 

Direct and Indirect Effects Common to Alternatives 2 and 3). These minor differences affect 

predicted prescribed fire outcomes evident as slight increases in flame length, mortality, scorch 

height and downed woody debris, primarily in the mixed conifer vegetation type on steep slopes.

Slight differences in prescribed fire effects (flame length, scorch height, mortality and downed 

woody debris) are also evident between Alternative 2 and 3. Alternative 3 could leave more 

material on the ground compared to Alternative 2 because of harvesting methods and the lack of 

cable corridors.

Table 46: Prescribed Fire Implementation Effects Dry Lake Hills Alternative 3

Alt.3 Prescribed Fire Implementation 

Effects by Treatment

Flame 

Length 

(ft)

Scorch 

Height 

(ft)

Smoke 

Emission 

(PM2.5) 

(tons

Mortality 

(BA 

Killed)

Post Burn 

DWD 12+ 

(tons/acre)

Electronic Site – Structure Protection **Not Modeled

Grassland Restoration **Not Modeled

Ponderosa Pine Fuels Reduction - Hand Thin **Not Modeled

Aspen Treatment - Hand Thin **Not Modeled

Mixed Conifer - Hand Thin 3.8 22.8 0.14 10.4 7.8

MSO PAC - Hand Thin 3.7 22.1 0.1 4 14.9

Burn Only 4.9 30.6 0.08 19.4 2.7

Nest Core Burn Only 4.2 25.9 0.04 7.4 0.4*

Goshawk PFA MC Fuels Reduction (Ground 

Based) 4 24.1 0.07 4.5 2.9

MSO PAC Fuels Reduction GB 2.6 12.5 0.09 4.4 7.8

MSO PAC Fuels Reduction (Helicopter) 2.6 12.5 0.1 3.2 10.8

MSO PAC Fuels Reduction (Steep Slope 

Equipment) 2.6 12.6 0.09 3.7 6.8

Goshawk PFA PP Fuels Reduction (Ground 

Based) 3.3 16.3 0.06 3.1 0.3*

Goshawk PFA PP Fuels Reduction Heli 3.2 15.8 0.08 4.7 1.1

Goshawk Nest Fuels Reduction 70BA 2.6 11.1 0.07 3.6 1.1
Chapter 3: Affected Environment and Environmental Consequences

166 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Alt.3 Prescribed Fire Implementation 

Effects by Treatment

Flame 

Length 

(ft)

Scorch 

Height 

(ft)

Smoke 

Emission 

(PM2.5) 

(tons

Mortality 

(BA 

Killed)

Post Burn 

DWD 12+ 

(tons/acre)

Schultz Nest - Hand Thin 3.6 21.1 0.1 15.8 15.8

Mixed Conifer Fuels Reduction (Ground 

Based) 4.1 24.5 0.12 4.8 8

Mixed Conifer Fuels Reduction (Helicopter) 4.2 25.6 0.12 4.6 8.8

Mixed Conifer Fuels Reduction (Steep Slope 

Equipment) 4.3 26.1 0.11 4.7 5.8

Ponderosa Pine Fuels Reduction (Ground 

Based) 3.1 13.9 0.08 5 0.6*

Ponderosa Pine Fuels Reduction (Helicopter) 3.6 18.3 0.08 3.8 1.3

* Pretreatment values were less than 1 ton/acre for downed woody debris larger than 12", ** Not modeled due to limited 

stand data

Table 47: Prescribed Fire Implementation Effects Mormon Mountain Alternative 3

Alt.3 Prescribed Fire Implementation 

Effects by Treatment

Flame 

Length 

(ft)

Scorch 

Height 

(ft)

Smoke 

Emission 

(PM2.5)

(tons

Mortality 

(BA 

Killed)

Post Burn 

DWD 12+ 

(tons/acre)

Electronic Site - Structure Protection **Not Modeled

MSO Nest Mixed Conifer-Burn Only 1.8 7 0.18 9.1 7.1

MSO Nest Ponderosa Pine -Burn Only 2.2 10.2 0.09 11.6 0.3*

MSO Nest / Roost Recovery 3.7 21.5 0.11 11.7 1.0*

MSO PAC MC Fuels Reduction (Ground 

Based) 2.1 8 0.16 7.6 7.8

MSO PAC PP Fuels Reduction (Ground 

Based) 2.9 14.2 0.1 3.8 0.8*

MSO PAC Fuels Reduction - Wet MC 4.5 24.8 0.24 33.9 14

Ponderosa Pine Fuels Reduction Pine/Oak 2.3 8.9 0.1 6.9 0.3*

* Pretreatment values were less than 1 ton/acre for downed woody debris larger than 12", ** Not modeled due to limited stand 

data

Table 48 and Table 49 represent post mechanical treatments and modeled wildfire conditions if a 

fire were to start and burn through the project areas under Schultz fire conditions. 
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 167

Table 48: Dry Lake Hills average projected treatment conditions for Alternative 3.

Alt. 3 Projected Conditions

Dry Lake Hills

(Desired Conditions)

Acreage

Canopy Base Height (ft.)

Dead and Downed Fuel 

(tons/acre) [avg]

Canopy Bulk Density 

(kg/M3

)

Canopy Closure (%)

Stems (Trees) per Acre

Potential Flame Length 

(ft.) Desired (4-8 ft.)

Potential Smoke Emission 

(PM2.5) (lbs/tons 

consumed)

Post-Treatment 2017

Post-Treatment 2033

Electronic Site – Structure Protection 6 **Not Modeled

Grassland Restoration 60 **Not Modeled

Ponderosa Pine Fuels Reduction - Hand Thin 150 **Not Modeled

Aspen Treatment - Hand Thin (2017) 22 **Not Modeled

Mixed Conifer - Hand Thin (2017) 85 23 15 0.05 50 112 7 0.17

Mixed Conifer - Hand Thin (2033) 23 19 0.06 55 107 7 0.17

MSO PAC - Hand Thin (2017) 202 22 20 0.04 55 82 6 0.12

MSO PAC - Hand Thin (2033) 23 23 0.04 56 75 6 0.14

Burn Only (2017) 270 19 10 0.5 53 140 15 0.13

Burn Only (2033) 24 17 0.55 57 129 16 0.15

Nest Core Burn Only (2017) 261 23 4 0.05 52 114 8 0.08

Nest Core Burn Only (2033) 28 10 0.05 53 102 8 0.10

MSO PAC Fuels Reduction (Ground Based) (2017)

1195

23 13 0.04 54 307 7 0.11

MSO PAC Fuels Reduction (Ground Based) (2033) 13 17 0.05 58 297 14 0.13

MSO PAC Fuels Reduction Heli (2017) 19 16 0.04 55 269 5 0.12

MSO PAC Fuels Reduction Heli (2033) 5 17 0.04 58 260 12 0.14

MSO PAC Fuels Reduction (Steep Slope) (2017) 25 13 0.04 56 185 5 0.10

MSO PAC Fuels Reduction (Steep Slope)(2033) 12 17 0.04 60 375 10 0.13

Goshawk PFA PP Fuels Reduction (Ground Based)

(2017) 359 29 4 0.02 49 106 4 0.05
Chapter 3: Affected Environment and Environmental Consequences

168 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Goshawk PFA PP Fuels Reduction (Ground Based)

(2033)

25 7 0.02 52 99 4 0.07

Goshawk PFA PP Fuels Reduction Heli (2017) 30 6 0.02 45 79 6 0.07

Goshawk PFA PP Fuels Reduction Heli (2033) 31 7 0.02 50 70 6 0.07

Goshawk PFA MC Fuels Reduction GB (2017) 24 7 0.04 50 200 7 0.14

Goshawk PFA MC Fuels Reduction GB (2033) 2 11 0.04 55 192 21 0.11

Goshawk Nest Fuels Reduction 70BA (2017) 100 23 5 0.03 50 177 5 0.05

Goshawk Nest Fuels Reduction 70BA (2033) 4 7 0.03 55 169 9 0.09

Schultz Nest - Hand Thin (2017) 122 11 22 0.07 52 210 10 0.17

Schultz Nest - Hand Thin (2033) 11 27 0.08 60 199 18 0.18

MSO Nest Roost Recovery – Hand Thin (2017) 72 21 14 0.06 54 97 7 0.17

MSO Nest Roost Recovery – Hand Thin (2033) 22 18 0.07 57 92 20 0.17

Mixed Conifer Fuels Reduction (Ground Based) (2017)

1158

29 13 0.4 49 240 7 0.12

Mixed Conifer Fuels Reduction (Ground Based) (2033) 9 16 0.04 53 232 15 0.14

Mixed Conifer Fuels Reduction Heli (2017) 21 21 0.04 41 308 9 0.13

Mixed Conifer Fuels Reduction Heli (2033) 5 18 0.05 45 297 19 0.13

Mixed Conifer Fuels Reduction (Steep Slope)(2017) 33 11 0.02 45 375 8 0.17

Mixed Conifer Fuels Reduction (Steep Slope)(2033) 1 14 0.03 50 365 16 0.13

Ponderosa Pine Fuels Reduction (Ground Based) (2017)

1865

24 5 0.02 38 148 6 0.07

Ponderosa Pine Fuels Reduction (Ground Based) (2033) 28 7 0.03 44 141 6 0.07

Ponderosa Pine Fuels Reduction Heli (2017) 26 6 0.02 40 86 7 0.06

Ponderosa Pine Fuels Reduction Heli (2033) 26 7 0.02 43 79 7 0.07

No Treatment 1605

** Not modeled due to limited stand data
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 169

Table 49: Mormon Mountain average projected treatment conditions for Alternative 3.

Alt. 3 Projected Conditions

Mormon Mountain

(Desired Conditions)

AcreageCanopy Base Height (ft.)Dead and Downed Fuel (tons/acre) [avg]Canopy Bulk Density (kg/M3

)

Canopy Closure (%)Stems (Trees) per Acre Potential Flame Length (ft.) Desired (4-8 ft.)Potential Smoke Emission (PM2.5) (lbs/tons consumed)

Post-Treatment 2017

Post-Treatment 2033

Electronic Site - Structure Protection 12 **Post Treatment Conditions Not Modeled

MSO Nest Mixed Conifer-Burn Only

402

11 8 0.04 48 243 16 0.24

MSO Nest Mixed Conifer-Burn Only 12 24 0.05 53 227 19 0.27

MSO Nest Ponderosa Pine -Burn Only 11 8 0.04 48 243 16 0.16

MSO Nest Ponderosa Pine-Burn Only 12 24 0.05 53 227 19 0.18

MSO Nest / Roost Recovery (2017)

22 30 8.8 0.03 55 241 6 0.10

MSO Nest / Roost Recovery (2033) 30 15 0.04 61 235 6 0.14

MSO PAC MC Fuels Reduction (Ground Based) (2017)

1592 14 15 0.07 58 438 18 0.20

MSO PAC MC Fuels Reduction (Ground Based) (2033) 12 21 0.08 62 421 30 0.22
Chapter 3: Affected Environment and Environmental Consequences

170 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

MSO PAC PP Fuels Reduction Ground Based(2017) 32 7 0.02 35 196 8 0.09

MSO PAC PP Fuels Reduction Ground Based (2033) 31 12 0.02 41 189 7 0.11

MSO PAC Fuels Reduction - Wet MC (2017)

180 9 28 0.10 60 382 33 0.38

MSO PAC Fuels Reduction - Wet MC (2033) 9 37 0.11 60 368 46 0.39

Ponderosa Pine Fuels Reduction Pine/Oak (2017)

766 30 7 0.01 42 240 5 0.08

Ponderosa Pine Fuels Reduction Pine/Oak (2033) 28 10 0.02 49 230 5 0.09

** Not modeled due to limited stand data
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 171

Cumulative Effects 

Cumulative effects from Alternative 3 are the same as those discussed under Alternative 2.

Unavoidable Adverse Effects, Irreversible and Irretrievable Commitment of 

Resources

Unavoidable Adverse Effects, Irreversible and Irretrievable Commitment of Resources would be 

identical to those discussed for Alternative 2.

Alternative 4 – Minimal Treatment Approach

The purpose of Alternative 4 is to implement the minimum amount of treatment necessary to 

meet the purpose and need. Therefore the effects would occur to a lesser degree (e.g. on fewer 

acres and with less intensity). Alternative 4 would treat 2,504 fewer acres in the DLH and 632 

fewer acres on MM than under Alternatives 2 and 3.

Treatments are proposed for those areas with dense fuel loading where topography aligns with 

dominant winds and the probability of severe effects to soil resources from a wildfire is greater,

based on FLAM MAP 5.0 modeling of both fire behavior and fire spread under Schultz fire 

weather conditions. Specifically, factors considered include: fire risk rating, potential damage to 

soils (from high severity fire and also harvesting methods), MSO habitat, and the type of 

harvesting methods necessary to affect change. 

Under Alternative 4, 3,459 acres along the base of Dry Lake Hills and Mount Elden and the 

upper, flatter tops would receive basically the same treatments proposed in Alternatives 2 and 3, 

though under this alternative more areas are proposed for hand thinning and prescribed burning 

instead of cable or helicopter logging in order to reduce the potential impacts from temporary 

road network associated with those harvesting methods. Additionally, treatments are focused on 

the area south and east of FR420; the portion of the project area between FR420 and the Kachina 

Peaks Wilderness would still be treated but under the constraints of the analysis and decision for 

the Jack Smith Schultz Fuels Reduction and Forest Health Restoration Project. Thus, no new 

analysis would be performed for those areas under this alternative. 

The Spruce Avenue Wash was identified as a high priority area due to the fuel loading, 

topography, size and also its location relative to the City of Flagstaff and MSO PACs. The 

portion of the Elden MSO PAC within the Spruce Avenue Wash would also be treated under the 

same parameters described in Alternatives 2 and 3.The Schultz MSO PAC and nest core were 

identified in conjunction with the FWS as high priority areas, and would also receive the same 

treatment described for Alternatives 2 and 3.

For Mormon Mountain, treatments would occur on 2,343 acres. The same methodology used for 

treatment placements in the Dry Lake Hills area was applied to Mormon Mountain to determine 

where to focus treatments. Under Alternative 4, the wet mixed conifer belt and MSO nest cores 

would not be treated; however treatments would occur below and above that belt. 

Areas not included in this alternative would be designated as No Treatment. All treated acres 

would include prescribed burning in the manner described under Alternative 2 and 3: initially pile 

burning to remove slash accumulated through harvesting, followed by broadcast burning. 

Maintenance burning may occur every five to seven years following implementation in order to 
Chapter 3: Affected Environment and Environmental Consequences

172 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

maintain lower fuel loading levels and to restore a frequent, low-severity fire regime. Mixed 

conifer may only receive one broadcast burn through the life of the project due to the historic Fire 

Return Interval in some vegetation types is historically longer than the life of this project. Other 

slash removal options as described in the Implementation Methods section could also be used in 

lieu of burning, including biomass removal.

Direct and Indirect Effects

Ground Fuels and Vegetation

Direct effects of Alternative 4 would be consistent with other similar fuels treatment projects on 

the Flagstaff Ranger District: prescribed fire would reduce surface fuels, raise crown base 

heights, reduce stems per acre and improve stand conditions. Prescribed fire may also result in an 

increase in mortality and reduce the amount of available logs and snags (Table 50 and Table 51), 

consistent with the other two action alternatives, but on fewer acres.

Table 50: Prescribed Fire Implementation Effects Dry Lake Hills Alternative 4.

Alt.4 Prescribed Fire Implementation 

Effects by Treatment

Flame 

Length 

(ft)

Scorch 

Height 

(ft)

Smoke 

Emission 

(PM2.5) 

(tons

Mortality 

(BA 

Killed)

Post Burn 

DWD 12+ 

(tons/acre)

Aspen Treatment - Hand Thin **Not Modeled

Electronic Site Structure Protection **Not Modeled

Goshawk Nest Fuels Reduction 2.6 11.1 0.07 3.6 1.1

Goshawk PFA MC Fuels Reduction (Ground 

Based) 4 24.1 0.07 4.5 2.9

Goshawk PFA PP Fuels Reduction (Ground 

Based) 3.2 15 0.07 3.4 0.4*

MSO Nest Fuels Reduction - Hand Thin 3.2 15.8 0.07 3.4 0.4*

MSO PAC MC Fuels Reduction (Ground 

Based) 2.6 12.6 0.1 3.3 10.5

MSO PAC PP Fuels Reduction (Ground 

Based) 2.7 13.3 0.6 3.9 0.4*

MSO PAC Fuels Reduction - Hand Thin 3.7 22.1 0.1 4 14.9

Mixed Conifer Fuels Reduction (Ground 

Based) 4.1 24.5 0.12 4.8 8

Ponderosa Pine Fuels Reduction (Ground 

Based) 3.1 14 0.08 5.6 0.2*

* Pretreatment values were less than 1 ton/acre for downed woody debris larger than 12", ** Not modeled due to limited 

stand data
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 173

Table 51 Prescribed Fire Implementation Effects Mormon Mountain Alternative 4.

Alt.4 Prescribed Fire Implementation 

Effects by Treatment

Flame 

Length 

(ft)

Scorch 

Height 

(ft)

Smoke 

Emission 

(PM2.5) 

(tons

Mortality 

(BA 

Killed)

Post Burn 

DWD 12+ 

(tons/acre)

Electronic Site - Structure Protection **Not Modeled

MSO Nest Mixed Conifer-Burn Only 1.8 7 0.18 9.1 7.1

MSO Nest Ponderosa Pine -Burn Only 2.2 10.2 0.09 11.6 0.3*

MSO Nest / Roost Recovery 3.7 21.5 0.11 11.7 1.0*

MSO PAC MC Fuels Reduction (Ground 

Based) 2.1 8 0.16 7.6 7.8

MSO PAC PP Fuels Reduction (Ground 

Based) 2.9 14.2 0.1 3.8 0.8*

MSO PAC Fuels Reduction - Wet MC 4.5 24.8 0.24 33.9 14

Ponderosa Pine Fuels Reduction Pine/Oak 2.3 8.9 0.1 6.9 0.3*

* Pretreatment values were less than 1 ton/acre for downed woody debris larger than 12", ** Not modeled due to limited stand data

Fire Suppression Efforts

Under Alternative 4, approximately 3,136 acres would not be treated in the project area, resulting 

in a lesser probability of containing a wildfire during an operational period if a fire were to start 

in the untreated areas. Fire suppression would likely have to focus containment efforts on the base 

of the slopes and ridge tops to be most effective.
Chapter 3: Affected Environment and Environmental Consequences

174 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 47: Estimated Fire Progression for Alternative 4, DLH
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 175

Figure 48: Estimated Fire Progression for Alternative 4, MM

Wildfire Hazard Potential

The direct and indirect effects would be similar in nature to Alternatives 2 and 3, with the 

exception that treatments are on a smaller scale and the project area at large could still have areas 

that are susceptible to high severity fires. Treatments in Alternative 4 would mitigate some 

potential for large scale fires; however since the entire area would not be treated, the project areas 

could be adversely affected by fires starting in neighboring stands and spreading through the 

Alternative 4 project boundary. Additionally a direct effect of a wildfire occurring outside of the 

Alternative 4 treatment areas could have adverse impacts to neighborhoods and communities that 

lie in the immediate areas surrounding the two project areas.

Alternative 4 would also include the permanent campfire closure order for the DLH portion and 

approximately 4 miles of decommissioned Forest Roads, which would result in a decrease in 

campfires and unauthorized motorized public access, thereby reducing the threat of humancaused fires within the DLH.

Alternative 4 would address the purpose and need by reducing the crown bulk density (thinning), 

reducing the canopy closure (thinning), increasing the effective crown base height in most sites 

(thinning and prescribed burning over time), and reducing the number of potential firebrands and 

shortening the distance at which spot fires would be expected to occur (thinning and prescribed 

burning), but to a lesser degree than Alternatives 2 and 3. Crown fire potential would be reduced 

under this alternative, but only on those acres treated. The 3,136 acres left untreated would retain 

the same crown fire potential as under the No Action Alternative. 

Crown fire potential for DLH modeled under Schultz conditions shows active crown fire on 2,326

acres, passive crown fire on 336 and 4,757 acres of surface fire (Figure 49, Table 52). Crown fire 

potential for MM modeled under Schultz conditions shows active crown fire on 558 acres, 

passive crown fire on 240 and 2,167 acres of surface fire.
Chapter 3: Affected Environment and Environmental Consequences

176 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 49: Modeled Crown Fire potential for Alternative 4

2010 Schultz Fire Weather Conditions

Dry Lake Hills Project 

Area

Acres 4,757 336 2,326 Mormon Mountain Project Area

Acres 2,167 240 558

Table 52: Existing Crown fire potential and modeled Alt. 4

Dry Lake Hills Existing 

Crown Fire 

Potential (97th 

%)

Existing 

Crown Fire 

Potential 

Schultz

Alternative 4, 

Schultz conditions

Active 5,480 acres 3,832 acres 2,326 acres

Passive 557 acres 749 acres 336 acres

Surface 1,426 acres 2,881acres 4,757 acres

Mormon 

Mountain

Existing 

Crown Fire 

Potential (97th 

%)

Existing 

Crown Fire 

Potential 

Schultz

Alternative 4, 

Schultz conditions

Active 2,201 acres 2,068 acres 558 acres

Surface Fire Passive Crown Fire Active Crown Fire 

64% 4%

32%

73%

8%

19%
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 177

Dry Lake Hills Existing 

Crown Fire 

Potential (97th 

%)

Existing 

Crown Fire 

Potential 

Schultz

Alternative 4, 

Schultz conditions

Passive 481 acres 725 acres 240 acres

Surface 286 acres 176 acres 2,167 acres

*Differences between 97th percentile conditions and Schultz are negligible, 

therefore only post treatment conditions under Schultz are listed. 

Figure 50: Alternative 4 fire behavior modeled under 2010 Schultz Wildfire weather 

conditions – Dry Lake Hills
Chapter 3: Affected Environment and Environmental Consequences

178 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 51: Alternative 4 fire behavior modeled under 2010 Schultz Wildfire weather conditions –Mormon Mountain
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 179

Implementation of Alternative 4 DLH modeled under Schultz conditions shows a reduction of 

crown fire potential from 3,832 to 2,326 acres of active crown fire, 749 to 336 acres of passive 

crown fire and 2,881to 4,757acres of surface fire behavior. 

Within the MM area modeled under Schultz conditions shows a reduction of crown fire potential 

from 2,068 to 558 acres of active, 725 to 240 acres passive crown fire and 176 to 2,167 acres of 

surface fire behavior. 

Table 53 and Table 54 represent post mechanical treatments and modeled wildfire conditions if a 

fire were to start and burn through the project areas under Schultz fire conditions.
Chapter 3: Affected Environment and Environmental Consequences

180 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 53: Dry Lake Hills average projected treatment conditions for Alternative 4

Alt. 4 Projected Conditions

Dry Lake Hills

(Desired Conditions)

Acreage

Canopy Base Height (ft.)

Dead and Downed Fuel 

(tons/acre) [avg]

Canopy Bulk Density 

(kg/M3

)

Canopy Closure (%)

Stems (Trees) per Acre

Potential Flame Length 

(ft.) Desired (4-8 ft.)

Potential Smoke Emission 

(PM2.5) (lbs/tons 

consumed)

Post-Treatment 2017

Post-Treatment 2033

Aspen Treatment - Hand Thin (2017) 2 **Not Modeled

Electronic Site Structure Protection 6 **Not Modeled

Goshawk Nest Fuels Reduction (2017) 100 23 5 0.03 54 177 5 0.05

Goshawk Nest Fuels Reduction (2033) 4 7 0.03 57 169 9 0.09

Burn Only (2017) 67 19 10 0.5 53 140 15 0.13

Burn Only (2033) 24 17 0.55 57 129 16 0.15

Goshawk PFA MC Fuels Reduction (Ground 

Based)(2017)

286

24 7 0.04 50 200 7 0.14

Goshawk PFA MC Fuels Reduction (Ground 

Based)(2033)

2 11 0.04 55 192 21 0.11

Goshawk PFA PP Fuels Reduction (Ground 

Based)(2017) 27 5 0.03 49 93 4 0.06

Goshawk PFA PP Fuels Reduction (Ground 

Based)(2033) 21 8 0.03 52 87 4 0.08

MSO Nest Fuels Reduction - Hand Thin (2017) 122 11 22 0.07 54 210 10 0.17

MSO Nest Fuels Reduction - Hand Thin (2033) 11 27 0.08 57 199 18 0.18

MSO PAC MC Fuels Reduction (Ground Based)(2017)

568

19 16 0.04 50 434 5 0.12

MSO PAC MC Fuels Reduction (Ground Based)(2033) 4 19 0.04 55 422 15 0.15

MSO PAC PP Fuels Reduction (Ground Based)(2017) 23 5 0.04 49 153 5 0.05

MSO PAC PP Fuels Reduction (Ground Based)(2033) 18 9 0.04 52 144 8 0.09
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 181

MSO PAC Fuels Reduction - Hand Thin (2017) 228 22 20 0.04 54 82 6 0.12

MSO PAC Fuels Reduction - Hand Thin (2033) 23 23 0.04 60 75 6 0.14

Mixed Conifer Fuels Reduction (Ground Based)(2017) 542 29 13 0.4 49 240 7 0.12

Mixed Conifer Fuels Reduction (Ground Based)(2033) 9 16 0.04 53 232 15 0.14

Ponderosa Pine Fuels Reduction (Ground Based)(2017) 1400

28 5 0.02 38 111 6 0.07

Ponderosa Pine Fuels Reduction (Ground Based)(2033) 29 7 0.03 44 104 6 0.07

No Treatment 4110

** Not modeled due to limited stand data
Chapter 3: Affected Environment and Environmental Consequences

182 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 54: Mormon Mountain average projected treatment conditions for Alternative 4.

Alt. 4 Projected Conditions

Mormon Mountain

(Desired Conditions)

AcreageCanopy Base Height (ft.)Dead and Downed Fuel (tons/acre) [avg]Canopy Bulk Density (kg/M3

)

Canopy Closure (%)Stems (Trees) per Acre Potential Flame Length (ft.) Desired (4-8 ft.)Potential Smoke Emission (PM2.5) (lbs/tons consumed)

Post-Treatment 2017

Post-Treatment 2033

Electronic Site - Structure Protection 12 **Not Modeled

MSO Nest Mixed Conifer-Burn Only

33

11 8 0.04 48 243 16 0.24

MSO Nest Mixed Conifer-Burn Only 12 24 0.05 53 227 19 0.27

MSO Nest Ponderosa Pine -Burn Only 11 8 0.04 48 243 16 0.16

MSO Nest Ponderosa Pine-Burn Only 12 24 0.05 53 227 19 0.18

MSO Nest / Roost Recovery (2017)

22 30 8.8 0.03 55 241 6 0.10

MSO Nest / Roost Recovery (2033) 30 15 0.04 61 235 6 0.14

MSO PAC MC Fuels Reduction Ground Based (2017)

1509

14 15 0.07 45 438 18 0.20

MSO PAC MC Fuels Reduction Ground Based (2033) 12 21 0.08 51 421 30 0.22

MSO PAC PP Fuels Reduction Ground Based(2017) 32 7 0.02 43 196 8 0.09

MSO PAC PP Fuels Reduction Ground Based (2033) 31 12 0.02 48 189 7 0.11
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 183

MSO PAC Fuels Reduction - Wet MC (2017) 14 15 0.07 60 437 18 0.38

MSO PAC Fuels Reduction - Wet MC (2033) 12 21 0.08 60 421 30 0.39

Ponderosa Pine Fuels Reduction Pine/Oak (2017)

766 30 7 0.01 42 240 5 0.08

Ponderosa Pine Fuels Reduction Pine/Oak (2033) 28 10 0.02 49 230 5 0.09

No Treatment 631

** Not modeled due to limited stand data
Chapter 3: Affected Environment and Environmental Consequences

184 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

The following table is a comparison of the arrival times for post treatment conditions. 

Table 55: Comparison Arrival time in acres/hour Alternative 4

Arrival 

Time

Intersection of FR 

420 and 557 (the Y)

Intersection of 557rd 

and Oldham Trail

Paradise Mormon Mountain 

648 Rd

Existing 

Conditions

PostTreatment 

Conditions

Existing 

Conditions

PostTreatment 

Conditions

Existing 

Conditions

PostTreatment 

Conditions

Existing 

Conditions

PostTreatment 

Conditions

1

st HR 51 1 469 14 259 26 197 6

2

nd HR 318 3 1,411 20 1,217 148 607 185

3

rd HR 960 9 2,414 32 2,012 395 1,103 343

4

th HR 1,604 64 3,482 170 2,773 882 1,614 504

5

th HR 2,803 206 4,156 424 3,438 1,296 2,508 734

Arrival time acreages for DLH under Alternative 4 are smaller than Alternative 2 and 3 modeling due to 

the fact that Alternative 4 would not alter fuel model composition as extensively as Alternatives 2 and 3. 

Alternatives 2 and 3 have a higher component of Grass/Shrub fuel models that contribute to faster fire 

spread; whereas, the fire type is less severe than Alternative 4.

Cumulative Effects

Cumulative effects for Alternative 4 would be the same as Alternatives 2 and 3, except to a lesser degree.

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

Amendment 1: 

Effects of Forest Plan Amendment 1 would be the same impacts on fire, fuel and air resources as the 

direct and indirect effects discussed for the action alternatives. If the amendment did not occur: 1) 

Mechanical treatments would be limited to a maximum of 9 inches dbh in the PACs thereby restricting the 

treatment to a fuels reduction objective and reducing the ability to improve MSO habitat in terms of 

reducing overall stand densities to desired levels, creating groups, openings, increasing or maintaining age 

class and species diversity, and liberation of overtopped oak.; 2) Without the use of prescribed fire in 

MSO core areas, the opportunity to improve MSO habitat in terms of reducing litter/duff cover and 

stimulating regeneration and growth of native herbaceous vegetation would be eliminated; 3) Treatments 

within MSO habitat would continue to meet the intent of the 1995 MSO recovery plan 4) Mechanical 

treatments within the nest roost recovery habitat would follow the denser 150 ft2 basal area guidance 

thereby reducing the ability to improve MSO nesting/roosting habitat in terms of sustainability, as 

indicated by high potential for density related mortality and high bark beetle hazard rating as well as 

reducing the ability to improve age class and species diversity and the liberation of overtopped oak; 5) 

Implementation of vegetation treatments within the PACs would take 2 to 3 additional years.; 6) 

Following existing Forest Plan language concerning MSO population and habitat monitoring or MSO 

habitat design will not have an effect on the treatments themselves or their outcomes.

Amendment 2: 

Effects of Forest Plan Amendment 2 would be the same impacts on fire, fuel and air resources as the 

direct and indirect effects discussed for the action alternatives. If the amendment did not occur: It would 

not be technically feasible to treat areas on steep slopes to meet the desired conditions; Manual treatment 

(hand thinning and piling) would only be able to treat trees up to 9 inches in diameter due to safety 

concerns; Not treating to the desired condition would not allow for the safe use of prescribed fire on steep 
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 185

slopes in many areas of the project; In areas where prescribed fire could be done in terms of firefighter 

safety, the fire would not have the desired effect, and would cause high levels of mortality across the 

burned areas which would not achieve the desired fuels reduction and post fire flooding reductions

Unavoidable Adverse Effects, Irreversible and Irretrievable Commitment of Resources

Unavoidable Adverse Effects, Irreversible and Irretrievable Commitment of Resources would be identical 

to those discussed under Alternative 2, but to a lesser degree as fewer acres would be treated under 

Alternative 4. 

Air Quality

Air impacts are felt and measured by the concentration of emissions at a given location, be it a town, a 

house, or an air quality monitor. There are no reliable methods of predicting concentrations at specific 

locations years in advance of a prescribed fire. This analysis does not attempt or pretend to predict the 

actual total emissions that would be produced under each alternative. Rather it aims to present a rationale 

for which alternatives are likely to produce “less” or “more” emissions. It assumes that, over time, there 

is some degree of correlation between total emission production, and total air quality impacts. Impacts are 

measured and evaluated based on the concentration of emissions at a specific location, not the total 

amount of emissions. Though meteorological conditions vary immensely by time of day, time of year, 

and from one weather system to the next, over the course of years the averaging effect over time of these 

varying conditions supports a correlation between total emissions and total impacts (Kleindienst 2012). 

The DLH portion of the project is in the Little Colorado River Airshed, and the MM portion is within the 

Verde River Airshed. Smoke emitted from a wildfire or a prescribed fire will settle in to drainages 

adjacent to the units. Diurnal patterns of air movement cause smoke from the DLH area can settle within 

the greater Flagstaff area, with most of it draining towards the Rio De Flag. Smoke emitted from MM 

would settle in the Village of Mormon Lake and can drain west towards Munds Park and Munds Canyon, 

eventually draining to Oak Creek Canyon.

Flagstaff is located to the south of the DLH unit with the housing and neighborhoods immediately 

adjacent to the project boundary. The Kachina Peaks Wilderness is located north of DLH, and will be 

treated as a Class I area as indicated in the Forest Plan. 

The Arizona Department of Environmental Quality (ADEQ) models emissions/pollutants from all 

prescribed burning within the state. Any prescribed burn planned by the Forest Service must be approved 

by ADEQ on a daily basis. ADEQ will not allow more acres burned per day, per air shed, than is 

acceptable with current air quality forecasts. 

When the Forest Service conducts prescribed burning, the burn boss is responsible for monitoring smoke 

plume trajectories to assure impacts are within predicted values. The burn boss makes changes as needed 

when unpredicted weather threatens stronger impacts. 

Methodology

Affected Environment

There are several highly used FS roads within the project boundaries. Recreationists use these roads in 

conjunction with Highway 180 and Lake Mary Rd to access many areas on which to recreate within the 

project areas. Most visitors who take advantage of the recreation opportunities that exist within the 

project areas do so mostly during the spring, summer, and fall months. Some of these activities include 
Chapter 3: Affected Environment and Environmental Consequences

186 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

0

0.02

0.04

0.06

0.08

0.1

0.12

0.14

0.16

Potential Wildfire Emission (PM 2.5 tons/hr)

2013 2014 2016 2017 2023 2033 2043 2053

Years After Treatment

Dry Lake Hills Ponderosa Pine

Alt1

Alt2

Alt3

Alt4

hiking, recreational vehicle camping as well as tent camping, hunting, wildlife viewing, scenic driving, 

and ATV/UTV use. People also cross country ski, snowmobile, and sled in the selected areas during the 

winter months (see also the Recreation Specialist Report). 

The prevailing winds for the FWPP area are out of the southwest. However, as fronts pass, winds can 

arrive from any direction for a period ranging from a few hours to three days. Atmospheric inversions can 

prevent smoke from dispersing. Within the project area, inversions mostly occur between October and 

December. Stagnant atmospheric conditions result from low mixing heights and light transport winds. 

These conditions, when they occur, may last from twelve hours to several days (Arizona Department of 

Environmental Quality, Fort Collins Weather Database).

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Alternative 1 would produce no direct effects since no prescribed burning would occur. However, 

analyzing the emissions from a high severity wildfire occurring within the project area that has not been 

treated using the Forest Vegetation Simulator (FVS ) and Fire and Fuels Extension (FFE), the amount of 

fuel consumed and the smoke generated by a high intensity wildfire would be greater than that under 

Alternatives 2, 3, or 4. 

Under extreme weather conditions, a wildfire would mostly likely burn more acres than would generally 

be burned with a prescribed burn in a day because of the difficulty of suppressing a wildfire in an 

untreated area. The resulting smoke from such a wildfire would spread wider and farther than with 

prescribed fire. Nighttime smoke would reach farther and impact the nearby communities more severely. 

Smoke would exceed air quality standards in both density and duration.

Figure 52: Predicted reduction in potential wildfire emission of PM 2.5 per alternative Dry 

Lake Hills
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 187

Cumulative Effects

The cumulative effects boundary for this analysis is defined as the area contained within the Little 

Colorado River airshed, the Kachina Peaks Wilderness and the Verde River airshed.

Forest health and fuel reduction projects that have occurred in close proximity to the FWPP area have 

most likely helped with reducing the potential effects of wildfire on the above named airsheds. These fuel 

reduction projects include Wing Mtn. Hart Prairie, Ft. Valley, A-1, Lake Mary Fuel Reduction, Skunk 

Fuel Reduction, East Side, and Woody Ridge. However, by not treating FWPP itself, the project area and 

surrounding untreated forested areas would most likely experience damaging fire effects and produce 

great quantity of smoke emissions if a wildfire entered into the untreated area under extreme weather 

conditions. 

According to the Flagstaff Zone Dispatch, the Coconino National Forest averages about four hundred 

wildfires a year. Roughly half of these are human-caused, with the balance caused by lightning. On 

average there are eighty-five days a year in which multiple wildfires start. The vast majority of these fires 

are controlled at one-tenth of an acre. Large destructive fires increase the average annual wildfire acres up 

to four thousand acres a year. Smoke from a wildfire occurring under modeled conditions would exceed 

air quality standards. As more area is left untreated on the forest, smoke from a wildfire occurring under 

0

0.05

0.1

0.15

0.2

0.25

2013 2014 2016 2017 2023 2033 2043 2053

Potential Wildfire Emission (PM 2.5 tons/hr)

Years After Treatment

Mormon Mountain Ponderosa Pine

Alt1

Alt2

Alt3

Alt4

Figure 53: Predicted reductions in potential wildfire emission of PM 2.5 per 

alternative Mormon Mountain
Chapter 3: Affected Environment and Environmental Consequences

188 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

the No Action Alternative could accumulate with emissions from other wildfires and further exceed air 

quality standards.

Alternatives 2, 3 & 4

Effects associated with the action alternatives are anticipated to be the same, though to slightly varying 

degrees according to the differences in acreages proposed for treatment. The effects are discussed 

together, with differences noted. 

Direct & Indirect Effects

Alternatives 2, 3, and 4 seek to reduce the fire hazard while retaining as many nutrients on site as 

possible. For the Dry lake Hills (Alternatives 2 and 3), prescribed burning is proposed for approximately 

5,963 acres of piled slash, and surface fuels on the forest floor using broadcast burning techniques. 

Alternatives 2, 3, and 4 propose prescribed fire and pile burning on 2,975 acres in the Mormon Mountain 

unit. Alternative 4 proposes prescribed fire and pile burning on 3,459 acres for Dry Lake Hills. A direct 

effect of all of the action alternatives is that smoke from prescribed burning will have short-term impacts 

on local air quality. These effects come from three sources: 1) pile burning of slash generated from 

thinning; 2) initial entry broadcast burning of the forest floor and; 3) maintenance broadcast burning.

A direct effect of all the alternatives is that smoke from prescribed burning would have short-term 

impacts on local air quality. These effects come from three sources: 1) pile burning of slash generated 

from thinning trees, 2) initial entry broadcast burning of the forest floor, and 3) maintenance broadcast 

burning of the forest floor. Emissions generated by these actions have been modeled using FVS for the 

project and are found in the proposed treatments per alternative tables (Table 39 and Table 40 for 

Alternative 2; Table 46 and Table 47 for Alternative 3; and Table 50 and Table 51 for Alternative 4).

Prescribed Fire Effects

Slight differences in prescribed fire effects (flame length, scorch height, mortality and downed woody 

debris) are evident between Alternatives 2 and 3. This is because Alternative 3 would leave slightly more 

material on the ground post-implementation compared to Alternative 2 due to the differences in 

harvesting methods. 

Pile Burning

Pile-burning is relatively efficient combustion producing fewer emissions than both wildfires (pretreatment) and initial entry prescribed burning. An ‘initial entry’ fire is a fire that burns though an area 

that has not had fire for at least a couple of decades. A result of decades of fuel buildup is a greater 

volume of emissions per area. Subsequent fires, wildfires or prescribed fires, have less fuel to burn and 

produce less emissions per area. A direct effect of action alternatives (2, 3, and 4) is that some smoke 

from pile burning may still subside into the neighborhoods in and around the project area after most of the 

piles have burned down to 10 percent or less of their original size. Pile burning near subdivisions may 

cause short-term smoke impacts, usually lasting at the most a day. 

Broadcast Burning

The initial prescribed burning of the forest floor produces more emissions than pile burning, but far less 

than most wildfires burning in the same (pre-treatment) fuel bed (compare Table 36 and Table 37 to Table 

39 and Table 40, for example). The initial broadcast burning of each block in the project area would 

generate smoke for as long as seventy-two hours after ignition. The emissions from implementing would 

generally meet National and State Ambient Air Quality Standards because burning would only occur 

under weather conditions that are favorable for burning and on a certain number of acres of land that 

would reduce smoke impacts to surrounding areas. 
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 189

Once initial entry burning has occurred, successive maintenance burns would be implemented every five 

to seven years in the ponderosa pine to mimic the historic fire regime. These maintenance burns would 

generate less smoke volume, be shorter in duration, and have less smoke after sunset compared to that 

created by an initial prescribed burn and far less than that created by a wildfire. 

The high level of recreation activity that occurs in the summer months in and around the DLH area is not 

likely to be impacted by smoke because very little to no prescribed burning would be conducted during 

the summer. Recreationists visiting the project area and surrounding areas in the fall and spring could be 

impacted by smoke from prescribed burning. The smoke impact could last for as long as seventy-two 

hours during initial entry broadcast burning, but usually only six hours during maintenance burning.

Smoke plume trajectories indicate that the communities within and adjacent to the project area and 

Highway 180 and Lake Mary RD may be impacted by smoke when burning. Short-term air quality 

degradation and reduced visibility may be experienced. After sunset, cooling atmospheric conditions 

would carry smoke down drainages. These down-canyon flows typically reach the communities around 

the project area in the early morning hours.

The early morning flows may carry smoke down slope and reduce visibility in surrounding low lying 

areas when blocks adjacent to these areas are being burned. These portions would be posted with 

appropriate signs warning residents living adjacent to the project area, forest visitors, and motorists of 

reduced visibility. Ignition of each day’s block would be completed in the afternoon, thus limiting the 

smoke generated after atmospheric cooling begins. Smoke impacts would be much worse should a 

wildfire occur under modeled weather conditions without the implementation of the proposed action. 

These impacts are shown below.
Chapter 3: Affected Environment and Environmental Consequences

190 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 54: General Smoke Emissions for a particulate matter21 10 and 2.5 for prescribed 

fire and wildfire on the Coconino NF

The reduction in the fuel load and the increased openness of the canopy would allow future broadcast 

burning under a wider range of weather conditions than the existing conditions. The ability of fire

managers to limit undesirable smoke impacts is increased by having a wider range of weather parameters 

within which to burn. Areas that have been thinned mechanically would allow a wider range of weather 

conditions than unthinned forested areas, and would have a lower risk of smoke impacts because the 

canopies have been opened up, allowing for better ventilation and smoke dispersal. Forested areas thinned 

by hand would allow the next widest range of areas determined to need thinning. Areas receiving burn 

only treatments may or may not have an open canopy depending on their existing condition. Burning in 

stands that are not thinned and have high canopy closures will most likely produce the heaviest smoke 

impacts. Potentially heavy smoke impacts would be avoided by burning on days with favorable 

ventilation as regulated by the Arizona Department of Environmental Quality (ADEQ).

Cumulative Effects

The cumulative effects for air quality for the project, the area contained within the Little Colorado River 

airshed, Kachina Peaks Wilderness and the Verde River airshed were considered as those are the primary 

areas that would be affected by prescribed burning within the FWPP area.

Smoke emitted from a wildfire occurring after treatment under alternative two would be unlikely to 

exceed air quality standards by itself. However, it could combine with the emissions of other wildfires 

that may be burning simultaneously in the same airshed. The accumulation of smoke from multiple 

wildfires inside and outside the project area might exceed air quality standards, which would serve as a 

cumulative effect for this project. 

The other fuel reduction projects that are currently being implemented adjacent to the FWPP area also 

include burning activities, which may affect the Little Colorado River and Verde River airsheds (Hart 

 

21 Particulate matter consists of inhalable coarse particles (>2.5 and <10 micrometers) and fine particles (=<2.5 micrometers in diameter) 

(http://www.epa.gov/pm/)
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 191

Prairie, Ft. Valley, A-1, Lake Mary Fuel Reduction, East Side, Woody Ridge, Mormon Lake Basin, Mint, 

Rocky, Munds Park, Mountainaire, Marshall, Elk Park and Kachina). However, the purpose of ADEQ 

regulation of daily burning in multiple areas within an airshed is to limit smoke impacts to that and any 

adjacent airsheds.

Since ADEQ limits the total number of acres burned per day per airshed through the amount of burn 

approvals issued on a daily basis, daily emissions from prescribed burning do not accumulate to exceed 

air quality standards. The number of days per year in which prescribed burning occurs is likely to increase 

as projects are implemented, but exceeding air quality standards would not be an effect due to ADEQ 

daily approval burning limits. Furthermore, these projects combine to reduce future smoke impacts. 

Smoke from pile burning may combine with smoke from wood-burning stoves and automobile smoke on 

some days when inversions are strongest during the winter. 

In sites with more closed canopies, forest floor fuel accumulates more quickly. In sites where canopies are 

denser, prescribed burning can only be executed under a narrower window of weather conditions. Thus, 

denser canopies result in fewer opportunities to prescribe burn. In turn, fuel accumulates on the forest 

floor when not burned frequently; thereby resulting in greater smoke impacts than when burning 

conditions can be met and prescribed burning of the fuel bed takes place.

Unavoidable Adverse Effects, Irreversible and Irretrievable Commitment of Resources

There would be impacts to air quality associated with the implementation of the proposed prescribed fire 

treatments; however National Ambient Air Quality Standards (NAAQS) would not be exceeded. Before 

any prescribed fires can be implemented, a prescribed burn plan must be written and signed by the 

authorizing line officer. For prescribed fire, burn plans include burn techniques, prescriptions, Emission 

Reduction Techniques, etc. that would be expected to maintain emissions levels at acceptable levels. 

Approval to burn on a given day must be approved by the Arizona Department of Environmental Quality 

(ADEQ) before a burn can be initiated. None of the proposed actions under this alternative are expected 

to exceed NAAQs, though nuisance smoke may increase to the degree that the public would tolerate as 

discussed in the Air Quality section of in this report.

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

The effects of the proposed Forest Plan amendments would be the same as those discussed under Fire and 

Fuels. 

Forest Structure and Health

Methodology

Issues and Indicators

Issues serve to highlight effects or unintended consequences that may occur from the proposed action, 

giving opportunities during the analysis to reduce adverse effects and compare trade-offs for the decisionmaker and public to understand. Key issues pertaining to forest structure and health (also referred to as 

Silviculture) identified during scoping and the indicators used to evaluate the issue are:
Chapter 3: Affected Environment and Environmental Consequences

192 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Quantitative pre-treatment and post-treatment three-level analysis for Mexican spotted owl, 

goshawk, old growth, and vegetation structural stage (VSS) for goshawk habitat at the landscape 

scale (ponderosa pine vegetation type) to gauge movement towards restoration desired conditions

Pre-treatment and post-treatment distribution of habitat structure within goshawk habitat 

evaluated at three scales: project level, stand, and group (or point level, equivalent to a stand 

exam plot).

Overall habitat structure (VSS class) and forest density metrics (basal area, stand density index 

and trees per acre) averaged to a per-acre basis with averages including openings, canopy gaps, 

and all forest structural stages. 

Density stocking guides that would be used to meet the VSS class canopy cover requirements 

within goshawk post-fledgling family areas (PFAs) and landscapes outside of post-fledgling 

family areas (LOPFA). 

Data Collection

The base unit for characterizing vegetation conditions is the stand. All forested lands within the Coconino 

National Forests have been delineated into stands based on similar characteristics such as vegetation type, 

slope, aspect, tree density, species composition and management history. Stands vary in size depending 

upon their uniformity, usually from 10 acres up to several hundred acres.

Comprehensive tree data has been collected on a subset of the stands within the project area over the last 

30 years. Within each sampled stand, tree characteristics were measured at sample points, using both 

variable basal area factor plot and fixed plot designs. Specific tree data collected include species, class, 

diameter, height, age, growth, damage and disease. Other data sometimes collected, depending on design,

include surface fuels and understory plant species. This stand data is currently stored in the Field Sampled 

Vegetation (FSVeg) database. A thorough review of the stand data was done for the project area to ensure 

validity. Data that did not match on the ground conditions or minimum sampling intensity was culled. 

Tree data used within for the DLH portion of the vegetation analysis came from stand exam data 

(discussed above) and by averaging stand data from adjacent stands to populate vegetative data to stands 

for which stand exam data was not available. Within the MM portion, vegetation analysis came from 

stand exam data (discussed above) and the Most Similar Neighbor (MSN) Analysis computer program 

within the INFORMS model. The MSN analysis data used for this project (within the MM area) is from 

the same analysis that was conducted and generated by the 4FRI analysis. Refer to the 4FRI Silviculture 

specialist report for further explanation of the model and their analysis methods (McCusker 2012).

All of the stand data collected in 2013 or earlier was then compiled into a database and modeled in the 

Forest Vegetation Simulator (FVS) tree growth model and updated to the year 2013. This process allowed 

us to characterize the current stand conditions and determine the need for change and appropriate 

treatments based on the project purpose and need. The FVS was then used to simulate cutting and 

prescribed burning treatments and growth following treatment for each alternative up to the year 2053.

Modeling

The FVS is a model used for predicting forest stand dynamics throughout the United States and is the 

standard model used by various government agencies including the USDA Forest Service, USDI Bureau 

of Land Management, and USDI Bureau of Indian Affairs (Dixon 2002). The FVS is an individual tree, 

distance independent growth and yield model with linkable modules called extensions, which simulate 

various insect and pathogen impacts, fire effects, fuel loading, snag dynamics, and development of 
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 193

understory tree vegetation. FVS can simulate a wide variety of forest types, stand structures, and pure or 

mixed species stands (Keyser and Dixon 2008). Forest managers have used FVS extensively to 

summarize current stand conditions, predict future stand conditions under various management 

alternatives, and update inventory statistics.

For simulation purposes, each data set was grouped by current forest type and treatment type. Simulations 

were developed for each treatment based on desired conditions. A multitude of vegetation and fuels 

attributes were computed for each growth cycle, including tree density (trees per acre, basal area and 

stand density index) by species or species groups and VSS size class, dwarf mistletoe infection, cubic feet 

of biomass removed, canopy base height and bulk density, live and dead surface fuel loading, live and 

dead standing wood, coarse woody debris and snags. These attributes were then averaged for all the data 

sets represented in the simulation. The averaged computed attributes from FVS were also used to 

calculate other attributes such as dominate VSS size class, canopy density and even-aged or uneven-aged 

structure. All of these attributes were then compiled into an “effects” database by alternative and used to 

analyze and display the direct and indirect effects to the vegetation resource. For Alternative 4, areas that 

are not proposed for treatment were not averaged into modeling.

The following is a list of general modeling assumptions. The Silviculture Specialist Report contains more 

information about the modeling assumptions specific to each treatment type in the proposed action.

All tree data was grown to the common year of 2013 and is considered to represent the existing 

condition. 

All tree cutting and removal was modeled in the year 2013.

For those stands which would be burned, prescribed burns were modeled in the year 2016.

After treatment, the tree data was grown to the common year of 2033 and 2053 and is considered 

to represent the post treatment condition.

The tree data does not indicate tree age. Simulations use diameter as a surrogate for age based on 

the vegetative structural stage definitions. We acknowledge that there are trees on the landscape 

where age class does not fit in the size class; however these are generally thought to be a small

minority of trees. For example there may be young trees that are larger than 11.9 inches dbh; midaged trees that are larger than 17.9 inches dbh; or mature trees that are less than 18 inches dbh.

The modeling assumptions attempt to meet the spirit of the 4FRI stakeholders Large Tree 

Retention Strategy (LTRS) within the limitations of a non-spatially explicit model. On the ground 

cutting prescriptions for Alternatives 2 and 3 would follow components of the LTRS that have 

been incorporated into the design features of this EIS, including those related to old tree retention. 

Alternative 4 would include more specific limitations on large tree removal per the LTRS, as that 

alternative adopted a modified version of that strategy. 

All cutting simulations assume 15 percent of the cut stems are left on site and 10 percent of the 

branchwood from the cut and removed stems is left on site. All other biomass resulting from the 

cutting is assumed to be removed, either through prescribed burning or biomass utilization.

Default parameters within the model were used to predict tree mortality and dwarf mistletoe 

infection intensification.

Snags and coarse wood amounts are based on the inventory or default parameters within the 

model if they were not inventoried. Snag fall rates and changes in surface fuels are based on 

default parameters.
Chapter 3: Affected Environment and Environmental Consequences

194 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

In cutting simulations where cable yarding is proposed, approximately 10% of all species and size 

classes are cut to simulate the effect caused by the creation of cable corridors. All snags in cable 

yarding simulations are assumed to be cut and left on the ground due to operational safety 

requirements.

In helicopter harvesting simulations, the analysis assumes that all snags in those units would be 

cut and left on the ground due to operational safety requirements.

When calculating and averaging data, untreated areas were not averaged in with treatment areas.

Modeling Limitations

Stand exam data is an average characterization of tree and other measurements within the stand 

boundaries. It is limited by sampling intensity and the variability within the sampled area.

FVS is not spatially explicit and cannot model tree groups and openings within stands. The modeling 

results are an average approximation of the desired forest structure.

Results from the FVS model depend upon sample data, validity of the model itself and assumptions made 

by the modeler. 

Output from the FVS model used in this analysis is a characterization of the existing condition and 

relative change over time of management actions or no action. Absolute conditions are neither intended 

nor implied. 

Vegetative Structural Stage (VSS) 

Vegetation structural stage (VSS) is a method of describing the development stages of a stand of living 

trees and is a generalized description of forest age and tree size from seedling to old forests. It is an 

integrative approach, combining vegetation and forest growth, to describe southwestern forests. Six 

vegetation structural stages (VSS) have been defined primarily on tree diameters and are based on the

time it takes seedlings to become established and subsequent growth rates (Table 56). Life expectancy of 

trees determines how long the oldest VSS can be maintained (Reynolds et al. 1992). The VSS 

classification is based on the tree size class with the highest square foot of basal area, which includes all 

tree species.

The VSS classification was further defined to include a measure of tree canopy density and age class

heterogeneity along with the dominant diameter distribution. Age class is a measure of the variety of age 

classes present in relation to the dominant age class and is an indication of canopy layers. A single storied 

stand resembles an even-aged condition while multiple storied stands are considered uneven-aged. Table 

56 describes the VSS coding as defined by the Compendium of NFS Regional Vegetation Classification 

Algorithms (Vandendriesche 2010).

Table 56: Description of Vegetation Structural Stages (VSS)

VSS

(DBH Size Class) Structural Stage

1 (0-.9”) Grass/Forb/Shrub

2 (1.0-4.9”) Seedling/Sapling
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 195

VSS

(DBH Size Class) Structural Stage

3 (5.0-11.9”) Young Forest

4 12.0-17.9”) Mid-age Forest

5 (18-23.9”) Mature Forest

6 (24”+) Old Forest

The following three-scales of VSS were used for the analysis of goshawk habitat areas outside of MSO 

habitat. 

Small Scale: For the small-scale VSS analysis, stand exam data from all the stands with in the treatment 

area were analyzed using point (plot) level data. Points were evaluated and given a point-level VSS 

designation. The Forest Vegetation Simulator was used to calculate the average basal area per acre within 

each VSS class for each of these points. The point-level VSS designation represents the VSS class that 

contained the highest basal area. These point-level VSS designations, once evaluated and analyzed, were 

then used to conduct the small-scale analysis. The point level data was broken out into LOPFA, PFA, and 

nest groups. This analysis is displayed in Table 67.

Mid-Scale: For the mid-scale VSS analysis, stand exam data from all the stands within the treatment 

areas were evaluated and given a stand-level VSS designation. The Forest Vegetation Simulator was used 

to calculate the average basal area per acre within each VSS class for each of these stands. The standlevel VSS designation represents the VSS class that contained the highest basal area. The list of VSS 

designations for each stand is too extensive to place in this document, but can be found in the project 

record. These stand-level VSS designations, once evaluated and analyzed, were then used to conduct the 

mid-scale analysis. The data was grouped by stands into LOPFA, PFA, and nest areas. This analysis is 

displayed in Table 68.

Landscape Scale: For the large-scale VSS analysis, all the stand level data for the entire goshawk habitat 

within the project area was averaged to come up with one average value. Table 69 displays the large-scale 

analysis data. 

Stand Density 

Measures of stand density used in this analysis are basal area, trees per acre and stand density index 

(SDI). Basal area (BA) is the cross-sectional area of all trees, measured in square feet per acre and trees 

per acre (TPA) is simply a count of the total number of trees on an acre. These simple measures of 

stocking do not give an indication of tree sizes and therefore can be biased when used to determine how 

site resources are being used. 

SDI is a relative measure of stand density based on the number of trees per acre and the mean diameter 

(Reineke 1933). SDI expresses the actual density in a stand relative to the theoretical maximum density 

possible for trees of that diameter and species. By taking both tree size (DBH) and numbers (TPA) into 

account, SDI is a good indicator of how site resources are being used. 

Long (1985) divided SDI percentages into four zones that consider the percent of a stand occupied by 

trees. Table 57 displays the amount of tree competition and growth based on stand density percentages 
Chapter 3: Affected Environment and Environmental Consequences

196 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

(percent of maximum stand density index). Based upon established forest density/vigor relationships, 

density-related mortality from competition begins to occur once the forest reaches 45-50 percent of 

maximum stand density (zone 3), and mortality is likely at density levels of 60 percent or more of 

maximum stand density (zone 4). 

Table 57: Relationships of Forest Density to Forest Stand Development and Tree Characteristics

% 

Maximum 

SDI*

Zone Forest Stand Development and Tree Characteristics

0 – 24% 

Low Density 1

Less than full site occupancy, maximum understory forage production.

No competition between trees, little crown differentiation.

Maximum individual tree diameter and volume growth.

Minimum whole stand volume growth.

25 – 34% 

Moderate 

Density

2

Less than full site occupancy, intermediate forage production.

Onset of competition among trees, onset of crown differentiation.

Intermediate individual tree diameter and volume growth.

Intermediate whole stand volume growth.

35 – 55% 

High 

Density

3

Full site occupancy, minimum forage production.

Active competition among trees, active crown differentiation.

Declining individual tree diameter and volume growth.

Maximum whole stand volume growth.

Upper range of zone marks the threshold for the onset of densityrelated mortality.

56+% 

Extremely 

High 

Density

4

Full site occupancy, minimum forage production.

Severe competition among trees, active competition-induced mortality.

Minimum individual tree diameter and volume growth, stagnation.

Declining whole stand volume growth due to mortality

Canopy Cover

Canopy cover is defined as “the percentage of a fixed area covered by the crowns of plants delimited by a 

vertical projection of the outermost perimeter of the spread of foliage” (Reynolds et al. 1992). Canopy 

cover is often viewed as a meaningful expression of stand conditions relating to habitat suitability as well 

as tree overstory/herbaceous understory relationships; however because it is spatial in nature, non-spatial 

analysis may or may not be useful. In the southwest, canopy cover estimates figure in management 

recommendations for both the Mexican spotted owl (USDI Fish and Wildlife Service 2012) and the 

northern goshawk (Reynolds et al. 1992). For this project, there are specific Forest Plan canopy cover 

guidelines for goshawk habitat and old growth that apply to mid-aged and old forest structural stages 

(VSS 4, 5 and 6) and not to grass/forb/shrub and young forest structural stages (VSS 1, 2 and 3).

Canopy cover is time consuming to measure and difficult to standardize to obtain consistent results with 

different observers. Even the definition of the term is dependent on the method of measurement. Percent 

canopy cover for all the analysis within this document was determined using the average basal area (BA) 

as calculated by FVS. For small scale analyses BA was calculated by FVS at the point level. For midscale and large-scale analysis, BA was calculated by averaging the BA of all the points within that stand. 

A study by Shepperd et al. (2002) used vertical crown projection to develop an algorithmic relationship to 
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 197

estimate canopy cover based on the average stand basal area. Average percent canopy cover for each 

stand was calculated using the following formula developed by this study: 

Canopy cover = -57.44 + 25.5047 * LN(BA)

Initial FVS runs for mixed conifer stands calculated canopy cover values that were lower compared to 

observed canopy cover and may not reflect the true canopy cover in the stands themselves. Since canopy 

cover assessment includes not just the number and size of tree crowns, but also the spatial arrangements 

of the trees on the land, non-spatial models such as FVS and equations may not accurately reflect true 

conditions on the ground. To assess the canopy cover of mixed conifer, the crown width of ponderosa

pine, Douglas-fir, white fir and limber pine were measured from trees within the project area in all size 

classes for each species. The crown widths were not significantly different between species. Based on 

this assessment, it was decided to use the above formula to calculate canopy cover from the average stand 

basal area.

While specifying the desired percentage distribution of VSS forest and canopy cover requirements, the 

Forest Plan is ambiguous on which scale measurements should be taken. The Forest Plan states that 

canopy cover guidelines should be applied to VSS 4-6 forest groups (Forest Plan p. 65-9), but does not 

specifically say at which level canopy cover should be measured to show compliance with this guideline. 

As a result, it is our professional judgment that canopy cover should be calculated at the group level to 

show that canopy cover requirements are meeting or moving toward canopy cover guidelines for VSS 4, 

5, 6 forest groups. The Forest Plan also says that ‘canopy cover is measured with vertical crown 

projection on average across the landscape (Forest Plan 65-9),’ thus this NEPA document also discloses 

canopy cover measurements at larger scales for areas that also include forest groups in VSS 1, 2, 3.

Multiple VSS groups can be found within a single uneven-aged stand; therefore, a stand-level approach is 

not useful as it averages multiple VSS group structures and thereby classifies the stand as a single VSS 

class, which doesn’t reflect the stand’s uneven-aged characteristics. All openings are either considered in 

canopy cover calculations for VSS 4-6 or considered to be a part of VSS 1. Table 58 lists the stocking 

guides that would be used to meet canopy cover requirements in tree groups within goshawk LOPFA 

habitat. 

Table 59 lists the stocking guides that would be used to meet canopy cover requirements in tree groups 

within goshawk PFA habitat.

Table 58: Stocking Guides to Meet Tree Group Canopy Cover Requirements within Goshawk 

Habitat Areas Outside of PFAs (LOPFA)

Typical Number of Trees Per Group 

Stocking for Different Group Sizes1

Typical Intra-Group 

(within-group) Densities1

(All Group Acreage Sizes)

VSS DBH Range 1/10 

acre 

group

1/4 

acre 

group

1/2 

acre 

group

3/4 

acre 

group

1 

acre 

group

Relative 

Spacing 

Range 

(feet)

Basal Area2

(ft2/acre)

1 & 2 0 - 4.9” 19 48 96 144 193 12 – 18 N/A

3 5 - 11.9” 11 28 55 83 110 N/A 43

4* 12 - 17.9” 4 9 19 28 37 N/A 45

5* 18 - 23.9” 3 6 13 19 25 N/A 60

6* 24”+ 3 6 12 18 24 N/A 95
Chapter 3: Affected Environment and Environmental Consequences

198 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

1

These are typical values for the desired condition; variation can occur and is desired. However, ranges should center on these 

values. See chart below.

2Rounded to nearest 10 square feet/acre.

* Densities are equivalent to 40% canopy cover.

Table 59: Stocking Guides to Meet Tree Group Canopy Cover Requirements within Goshawk PFAs

Typical Number of Trees Per Group 

Stocking for Different Group Sizes1

Typical Intra-Group

(within-group) Densities1

(All Group Acreage Sizes)

VSS DBH Range 1/10 

acre 

group

1/4 

acre 

group

1/2 

acre 

group

3/4 

acre 

group

1 

acre 

group

Relative 

Spacing 

Range 

(feet)

Basal Area2

(ft2/acre)

1 & 2 0 - 4.9” 19 48 97 145 193 12 – 18 N/A

3 5 - 11.9” 16 39 78 117 156 N/A 60

4* 12 - 17.9” 7 18 37 55 73 N/A 90

5** 18 - 23.9” 4 11 22 33 44 N/A 105

6** 24”+ 3 8 15 23 30 N/A 120

1

These are typical values for the desired condition; variation can occur and is desired. However, ranges should center on these 

values. See chart below.

2Rounded to nearest 10 square feet/acre.

* Densities are equivalent to 55% canopy cover

** Densities are equivalent to 50% canopy cover
Chapter 3. Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 199

Affected Environment

This section will talk about the existing conditions specific to MSO and northern goshawk habitat. See the 

Forest Structure and Forest Health Existing Conditions section of Chapter 1 for more discussion of the 

current conditions for other silvicultural resources within the project area, including aspen, old growth, 

forest health etc.

Mexican Spotted Owl and Northern Goshawk Habitat

All ponderosa pine forested habitat within the analysis area was stratified to meet analysis requirements in 

the Forest Plan and the revised recovery plan for Mexican spotted owl (MSO). Stratification of acres by 

habitat and forest type is displayed in Table 60 (MSO) and Table 61 (goshawk). While both the DLH and 

MM areas have designated goshawk PFAs and nests, only DLH has goshawk habitat outside of MSO 

habitat. 

Table 60: MSO Habitat Stratification within the Analysis Area (Acres within each project site) 

under the 2012 MSO Recovery Plan.

MSO Habitat DLH MM Total

Protected Activity Center

Protected Activity Center (Outside of Nest/Roost 

Core) 1398 1772

3170

Nest/Roost Core 383 402 785

Total MSO PAC: 1781 2174 3955

Recovery Habitat

Pine Oak 277 767 1044

Mixed Conifer 1800 0 1800

Nest/Roost 109 22 131

Total MSO Recovery Habitat: 2186 789 2975

Total MSO Habitat 3967 2963 6930

Table 61: Northern Goshawk Habitat Stratification within the Analysis Area (Acres by project site)

Northern Goshawk Habitat DLH

Nest Habitat 45

Post-fledgling Family Area (PFA) 178

Landscapes Outside Post-fledgling Family Areas 

(LOPFA) 1739
Chapter 3: Affected Environment and Environmental Consequences

200 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Northern Goshawk Habitat DLH

Total Goshawk Habitat 1962

Mexican Spotted Owl Habitat – Forest Density and Structure 

The Protected Activity Centers (PACs) provide the best possible nesting/roosting owl habitat available 

with the nest or activity center located near the center. The recovery habitats are managed to ensure a 

sustained level of both foraging and nest/roost habitat distributed across the landscape. Table 62 displays 

the total basal area, percent of basal area by size class, tree per acre greater than 18 inches dbh and 

Gambel oak basal area as a percent of total basal for all MSO habitats. These structural attributes and 

habitat components are indicators of nest/roost characteristics as outlined in the revised MSO Recovery 

Plan (USDI FWS 2012).

MSO Nest Fuels Reduction & MSO Nest/Roost Recovery: Residual basal area would be a minimum 110 

ft2 in the Nest Cores and 95 ft2 in Nest/Roost Recovery stands. Treatments would maintain a minimum of 

60 percent canopy cover in mixed conifer. Post-treatment, a minimum of 12 trees greater than 18 inches

dbh per acre would be present; trees greater than 12-18 inches dbh would comprise over 30 percent of 

stands, per the MSO Recovery Plan guidelines (2012).
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 201

Table 62: Existing Spotted Owl Habitat Forest Structure and Habitat Components

Habitat Proje

ct Site

Cover 

Type

Basal 

Area

Avg. Percent of 

Basal Area by Size 

Class Avg. 

TPA 

18”+

Avg. 

Gambel Oak 

BA Percent 

of Total BA

Tons 

CWD 

Snags 

>18”

12.0 –

17.9” >18.0”

Recovery 

Habitat –

Nest/Roost

DLH Mixed 

Conifer 145 47% 10% 3.3 0% 37.6 3

MM Pine/Oak 173 17% 60% 39 14% 17.5 1.3

Recovery 

HabitatForaging NonBreeding

DLH

Mixed 

Conifer 142 33% 28% 15 1% 23.3 3.7

Pine/Oak 136 41% 30% 15.6 24% 13.4 .2

MM Pine/Oak 161 41% 26% 16 12% 11.8 .5

MSO PAC 

Habitat DLH

Mixed 

Conifer 135 31% 28% 14 0.7% 26.9 4.0

Pine 130 23% 63% 22 0 9.9 5.5

MM

Mixed 

Conifer 153 23 39% 22 16% 27 9.2

Pine/Oak 161 38% 20% 12.4 16% 14 .9

MSO PAC 

Habitat – Nest DLH Mixed 

Conifer 132 26% 36% 19 3% 25 3.3
Chapter 3: Affected Environment and Environmental Consequences

202 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Habitat Proje

ct Site

Cover 

Type

Basal 

Area

Avg. Percent of 

Basal Area by Size 

Class Avg. 

TPA 

18”+

Avg. 

Gambel Oak 

BA Percent 

of Total BA

Tons 

CWD 

Snags 

>18”

12.0 –

17.9” >18.0”

Core Pine 55 48% 36% 8 0 3.7 1.7

MM

Mixed 

Conifer 140 23% 36% 20 18% 24 9.4

Pine/Oak 146 45 17% 10 12% 11.2 0.5
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 203

Northern Goshawk Habitat – Forest Density and Structure 

The post-fledgling family areas (PFA) consist of nest sites and adjacent habitat most likely to be used by 

fledglings during their early development as well as unoccupied suitable habitat within a 2 to 2.5 mile

range of PFAs. Mixed conifer and pine/oak vegetation types would be managed for MSO protected or 

recovery habitat; which encompasses all of MM and a large portion of the DLH area. The remaining 

ponderosa pine forest outside of MSO PACs, MSO recovery habitat areas, and goshawk PFAs is 

considered goshawk foraging habitat and will be referred to as Landscapes Outside of Goshawk Postfledgling Family Areas (LOPFA) for the remainder of this report.

The existing distribution of forest structure, habitat components and structural stages within northern 

goshawk habitat was evaluated at three scales: Project extent, stand level, and plot level (see also the 

Methodology section of the Forest Structure and Forest Health in Chapter 3). 

Table 63 and Table 64 display the existing forest structure and habitat components for goshawk forest 

habitat at the stand level in the DLH; though goshawk habitat is present on MM, it’s overlapped by MSO 

habitats and thus not shown on the tables below. These structural attributes and habitat components are 

indicators of goshawk habitat (PFA and LOPFA) characteristics as outlined in the Forest Plan.

Table 63: Existing Goshawk Nest/PFA Habitat Forest Structure and Habitat Components

Project Site Basal Area Canopy 

Cover

TPA SDI % of 

Max.

Snags 

>18"

DLH 137 70% 308 51% 1.2

Table 64: Existing Goshawk LOPFA Habitat Forest Structure and Habitat Components

Project Site Basal Area Canopy 

Cover

TPA SDI % of 

Max.

Snags 

>18"

DLH 132 69% 314 54% 1.2

All goshawk habitat was assessed to determine the variety of tree size/age classes present in relation to 

the dominant size/age class (Table 65 and Table 66). Those stands with one or two classes present have 

even-aged structure, and those stands with three or more classes present have uneven-aged structure. 

Forest Plan direction for goshawk habitat outside of nest stands is to manage for uneven-aged stand 

conditions made up of smaller (plot level) even-aged tree “groups” of live trees. Based upon this 

direction, the existing even-aged forest structure at the stand scale is not desired for goshawk forest 

habitat outside of nest stands.

Table 65 and Table 66 demonstrate the distribution of the dominate vegetation structural stages for all 

stands within each of goshawk habitats and age class strata. This is an indication of structural stage 

diversity throughout the goshawk habitat. Since the stand level structural stage is based on the tree size 

class with the highest square foot of basal area, it is a true description of age class diversity in even-aged

stands; however in uneven-aged stands it does not give a complete portrayal. This is due to the fact that 

within uneven-aged stands, there are three or more age classes present and the dominant VSS class only 

tells us which one has the highest basal area. 
Chapter 3: Affected Environment and Environmental Consequences

204 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

The 1987 Coconino National Forest Plan direction for goshawk habitat outside of nest stands is the 

following distribution of vegetation structural stages: 10 percent each grass/forb/shrub (VSS 1) and 

seedling-sapling (VSS 2), and 20 percent each young forest (VSS 3), mid-aged forest (VSS 4), mature 

forest (VSS 5) and old forest (VSS 6).

The even-aged stands are dominated by the young and mid-aged forest structural stages (over 85 percent 

within the LOPFA and 80 percent in the PFA) with very little representation of the other structural stages.

The existing uneven-aged forest structure does not comprise a balance of VSS classes. The young and 

mid-aged forest structural stages are surplus, and the grass/forb/shrub, seedling-sapling, mature and old 

forest stages are deficit relative to Forest Plan direction.

Table 65: Existing Forest Structure – Goshawk LOPFA Stands Percent of Area by Vegetative 

Structural Stages.

Project 

Site

1 –

Grass/Forb/

Shrub

(0.0 - 0.9”)

2 –

Seedling/ 

Sapling

(1.0 - 4.9”)

3 –

Young 

Forest

(5.0 - 11.9”)

4 –

Mid-age 

Forest

(12.0 - 17.9”)

5 –

Mature 

Forest

(18.0 - 23.9”)

6 –

Old Forest 

(24.0” +)

DLH 0% 0% 32% 53% 8% 7%

Table 66: Existing Forest Structure – Goshawk PFA/Nest Stands Percent of Area by Vegetative 

Structural Stages.

Project 

Site

1 –

Grass/Forb/

Shrub

(0.0 - 0.9”)

2 –

Seedling/ 

Sapling

(1.0 - 4.9”)

3 –

Young 

Forest

(5.0 - 11.9”)

4 –

Mid-age 

Forest

(12.0 - 17.9”)

5 –

Mature 

Forest

(18.0 - 23.9”)

6 –

Old Forest 

(24.0” +)

DLH 0% 0% 41% 40% 0% 19%

Environmental Effects

This section describes the proposed treatments and the effects of those treatments on the vegetation 

resource by characterizing the post treatment condition over time for each alternative. This section also 

evaluates each alternative in terms of moving toward the desired vegetation conditions. As the desired 

conditions and treatment area are the same under Alternative 2 and 3, their effects to Silviculture 

resources are similar and so are discussed together. The differences due to harvesting methods are 

included in that discussion. When treatments are the same under all action alternatives, Alternative 4 is 

also grouped into the discussion under a subheading of “Effects Common to All Action Alternatives.” 

Because of the geographic distance between the two project areas (Dry Lake Hills and Mormon 

Mountain) and the distinct habitat conditions of each area, this section analyzes each area independently.

Environmental effects of each alternative on the ponderosa pine and mixed conifer cover types found 

within the project area are discussed first, followed by grasslands, aspen, old growth and forest health. 

The ponderosa pine and mixed conifer vegetation types are further divided by MSO habitat and northern 

goshawk habitat, followed by an analysis of all MSO habitat in each portion of the project to provide a 

look at overall effects from a biological perspective. This is because management of the vegetation types 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 205

differs, and management is guided by the desired conditions for first MSO, and second northern goshawk, 

where goshawk habitat does not overlap with MSO.

This section also contains a general discussion of cumulative effects for all action alternatives and the No 

Action Alternative.

Alternative 1: No Action

Direct & Indirect Effects

Ponderosa Pine – Dry Lake Hills

Under the No Action Alternative, forest areas would remain in an even-aged condition; stands would 

continue to be dominated by VSS 3 and 4 size classes. Mature and old forest conditions would continue 

development at a slow pace and would be at risk of increased rates of mortality (Ritchie et al. 2008, Davis 

et al. 2007). 

Over 40 years, canopy cover would increase, basal areas would increase, and trees per acres would 

decrease. Closed crown canopies result in decreased sunlight to the forest floor, decreased understory 

productivity and diversity, increased inter-tree competition, decreased tree health, growth and vigor, 

increased insect and disease-related mortality especially in older age classes, decreased understory 

productivity and diversity, and decreased horizontal heterogeneity. Number of medium and large sized 

snags would increase overtime due to competition-induced mortality.

Table 71 and Table 72 show the modeling results of the action alternatives and the No Action Alternative 

grown out 20 and 40 years from the time of treatment. Under the No Action, the LOPFA and PFA stands 

would still have an even-aged stand structure. The nest stand would still be a VSS4. In this alternative,

stand conditions would continue to have high density, which contributes to competition induced mortality 

occurring and increases the bark beetle hazard. It also reduces the likelihood of development of mid-aged 

trees to large trees with old growth characteristics. Stands would be dominated by VSS 4, 5 and 6 size 

classes and would still be an even-age stand. 

While it is not displayed in the tables below, the stand exam data shows that there is a severe dwarf 

mistletoe infection in the MSO PAC Fuels Reduction treatment areas. This has caused the No Action

density numbers to decline as opposed to going up as expected. The severe level of dwarf mistletoe 

infection would decreases the ability of the stand to maintain high levels of canopy cover and would 

reduce the rate of tree growth, thus limiting the ability of the stand to maintain large trees and high 

canopy cover. 

Ponderosa Pine – Mormon Mountain

The current stand conditions are shown in Table 73. Stand conditions under the No Action Alternative for 

20 and 40 years from now are shown in Table 74 and Table 75. Current conditions show that all the 

ponderosa pine stands have high BA, ranging from 146 to 173 ft2, which means canopy cover is high. All 

treatment areas have very high numbers of trees per acre, ranging from 600 to 1210 TPA. All these 

factors contribute to the percent max SDI being well into the extreme range of density, which means that 

these stands are likely to experience higher levels of tree mortality and high levels of insect infestation 

and disease.
Chapter 3: Affected Environment and Environmental Consequences

206 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Under the No Action Alternative, forested areas would remain in an even-aged condition; stands would 

continue to be dominated by trees in the 5 to 18 inch dbh size classes. Mature and old forest conditions 

would continue development at a slow pace and be at risk of increased rates of mortality (Ritchie et al. 

2008, Davis et al. 2007). 

Over 40 years, canopy cover would increase, basal areas would increase, and trees per acres would 

decrease. Closed crown canopies result in decreased sunlight to the forest floor, decreased understory 

productivity and diversity, increased inter-tree competition, decreased tree health, growth and vigor, 

increased insect and disease-related mortality especially in older age classes, and decreased horizontal 

heterogeneity. Gambel oaks would continue to be shaded out and decline as a result of competition induce 

mortality from ponderosa pine. The number of medium and large sized snags would increase overtime 

due to competition-induced mortality.

Mixed Conifer – Dry Lake Hills

The current stand conditions are shown in Table 68. Stand conditions under the No Action Alternative for 

20 and 40 years are shown in Table 71and Table 72. Current conditions show that the majority of mixed 

conifer stands have high BA, ranging from 122 to 157 ft2, which means that canopy cover is also high. All 

treatment areas also have very high numbers of TPA, ranging from 476 to 2986. These factors contribute 

to most of the mixed conifer areas being in the extreme range of density of percent max SDI. The 

majority of the mixed conifer stands are uneven-aged with trees in all size classes.

Under the No Action Alternative, ponderosa pine and aspen would not be able to regenerate in the current 

closed canopy conditions and would continue to slowly die out of the stands. In the absence of 

disturbance or fires, white firs and Douglas-firs would continue to increase and eventually dominate the 

overstory. In the absence of fire, shade tolerant species such as white fir and (to a lesser extent) Douglasfir would continue to regenerate in very high numbers of many hundreds to thousands of trees per acre. 

The increased density contributes to fire hazard and increases the likelihood of epidemic levels of insect 

infestation and/or disease mortality. Also, because these species are shade tolerant, their lower limbs are 

slow to die off and remain on the tree much longer than shade intolerant species which would create an 

increased ladder fuel hazard. Mature and old forest conditions would continue development at a slow pace 

and be at risk of increased rates of mortality (Ritchie et al. 2008, Davis et al. 2007). 

Over 40 years, canopy cover would increase, BA would increase, and TPA would decrease. Closed crown 

canopies result in decreased sunlight to the forest floor, decreased understory productivity and diversity, 

increased inter-tree competition, decreased tree health, growth and vigor, increased insect and diseaserelated mortality especially in older age classes, and decreased horizontal heterogeneity. Regeneration 

would comprise mostly of white fir and Douglas-fir. Early seral species aspen and ponderosa pines would 

continue to be shaded out by more shade tolerant white fir and Douglas-fir. The number of medium and 

large-sized snags would increase overtime due to competition-induced mortality.

Mixed Conifer – Mormon Mountain

The current stand conditions are shown in Table 73. Stand conditions under the No Action Alternative for 

20 and 40 years from now are shown in Table 74 and Table 75. Current conditions show that the majority 

of mixed conifer stands have high BA ranging from 140 to 153 ft2, which means that canopy cover is also 

high. All treatment areas have very high numbers of TPA, ranging from 868 to 888. All these factors 

contribute to most of the mixed conifer areas being in the upper end of the high or lower end of extreme 

range of density of percent max SDI. The majority of the mixed conifer stands are uneven-aged with 

trees in all size classes.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 207

Under the No Action Alternative, ponderosa pine, Gambel oak and aspen would not be able to regenerate 

in the current closed canopy conditions and would slowly die out of the stands. In the absence of 

disturbance or fires, white fir and Douglas-fir would continue to increase and eventually dominate the 

overstory. In the absence of fire, shade tolerant species such as white fir and (to a lesser extent) Douglasfir would continue to regenerate in very high numbers of many hundreds to thousands of trees per acre. 

The increased density contributes to fire hazard and increases the likelihood of epidemic levels of insect 

infestation and/or disease mortality. Also, because these species are shade tolerant, their lower limbs are 

slow to die off and remain on the tree much longer than shade intolerant species which would create an 

increased ladder fuel hazard. Mature and old forest conditions would continue development at a slow pace 

and be at risk of increased rates of mortality (Ritchie et al. 2008, Davis et al. 2007). 

Over 40 years, canopy cover would increase, BA would increase, and TPA would decrease. Closed crown 

canopies would result in decreased sunlight to the forest floor, decreased understory productivity and 

diversity, increased inter-tree competition, decreased tree health, growth and vigor, increased insect and 

disease-related mortality (especially in older age classes), and decreased horizontal heterogeneity. 

Regeneration would be comprised mostly of white fir and Douglas-fir. Early seral species aspen, 

ponderosa pine and Gambel oak would continue to be shaded out by more shade tolerant white firs and 

Douglas-firs. The number of medium and large-sized snags would increase overtime due to competitioninduced mortality.

Mexican Spotted Owl Habitat – Dry Lake Hills

This section contains an analysis of the entire MSO habitat in the DLH area, including ponderosa pine as 

well as dry mixed conifer. All of the different treatments that occur within the four different MSO habitat 

stratas (MSO PACs, nest cores, recovery habitat, and nest roost recovery habitat) were combined to show 

the overall effects the treatments would have to MSO habitat. 

Table 94, Table 95 and Table 96 display the value of the stands with in the MSO PACS and recovery 

habitat outside of the MSO PACs along with post treatment data and stand conditions for all alternatives 

projected out 20 and 40 years. 

Under the No Action Alternative, forest conditions within the protected and restricted stands would 

remain much as they are now. Currently in the pine-oak, large oaks are being over-topped by pine and 

shaded out and as a result have small crown ratios and have limited acorn production. In the dry mixed 

conifer, aspen are being shaded out by the more shade tolerant conifers. In 40 years, canopy cover would 

increase, basal areas would increase, and trees per acres would decrease. Closed crown canopies would 

result in decreased sunlight to the forest floor, decreased understory productivity and diversity, increased 

inter-tree competition, decreased tree health, growth and vigor, increased insect and disease-related 

mortality especially in older age classes, decreased understory productivity and diversity, and decreased 

horizontal heterogeneity. Oaks and aspen would continue to decline with little opportunity to regenerate, 

reducing the stand biodiversity and spatial heterogeneity. 

Mexican Spotted Owl Habitat – Mormon Mountain

This section analyzes the entire MSO habitat in the MM area, and includes ponderosa pine as well as dry 

and wet mixed conifer. All of the different treatments that occur within the four different MSO habitat 

stratas (MSO PACs, nest cores, recovery habitat, and nest roost recovery habitat) were combined to show 

the overall effects the treatments would have to MSO habitat. 

Table 73 through Table 75 display the values of the stands within the MSO PACS and recovery habitat,

along with post-treatment data and stand conditions for all alternatives projected out 20 and 40 years. 
Chapter 3: Affected Environment and Environmental Consequences

208 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Under the No Action Alternative, forest conditions within the protected and restricted stands would 

remain much as they are now. Currently in the pine-oak, large oaks are being over-topped by pine and 

shaded out, and as a result have small crown ratios and limited mast production. In the dry mixed conifer 

and wet mixed conifer, the more shade-tolerant conifers are also shading out the aspen.

In 40 years, canopy cover would increase, BA would increase, and TPA would decrease. Closed crown 

canopies would result in decreased sunlight to the forest floor, decreased understory productivity and 

diversity, increased inter-tree competition, decreased tree health, growth and vigor, increased insect and 

disease-related mortality especially in older age classes, and decreased horizontal heterogeneity. Oaks and 

aspen would continue to decline with little opportunity to regenerate. 

In the area proposed for MSO Nest Roost Recovery Habitat Mechanical thinning, under the No Action 

alternative, in 20 years basal area would be 182 ft2 and the average number of trees greater than 18 inches 

dbh would be 43 TPA. The percent BA from 12 to 18 inches dbh would be 21 percent for the No Action, 

while the percent BA in trees greater than 18 inches dbh would be 68 percent. After 40 years, BA would 

be 190ft2and the average number of trees greater than 18 inches dbh per acres would be 40. The percent 

BA from 12 to 18 inches dbh would be 21 percent, while the percent BA in trees greater than 18 inches 

dbh would be 68 percent.

In the area proposed for MSO Nest Roost Recovery Hand thinning, in 20 years BA would be 173ft2and 

the approximate number of trees greater than 18 inches dbh per acre would be 8 for the No Action 

Alternative. The percent BA from 12 to 18 inches dbh would be 29 percent while the percent BA in trees 

greater than 18 inches dbh would be 12 percent. After 40 years, BA would be 200 ft2and the average 

number of trees greater than 18” dbh per acre would be 19. In 40 years, BA would be 200ft2 and the 

average number of trees greater than 18 inches dbh per acre would be 19 for the No Action Alternative.

Grasslands

The No Action Alternative would indirectly affect grasslands within the project area. Over a minimum 

period of 40 years, grasslands would continue to experience pine and mixed conifer encroachment. As 

conifer density increases over time, grasslands would experience decreased productivity and diversity and 

loss of functionality in terms of hydrology, biodiversity, horizontal heterogeneity, and wildlife habitat 

diversity. 

Aspen

Under the No Action Alternative, forest conditions within these stands would continue to decline and 

would not be able to successfully regenerate. Table 88 displays existing conditions within the aspen cover 

type in the DLH area. Over 40 years (assuming no other dramatic aspen die-off occurs), basal areas of 

both aspen and conifer species would increase, and TPA would decrease. The basal area increase of the 

conifer trees would be greater than aspen and would result in a greater rate of decline for aspen trees per 

acre (Figure 55). Increased canopies of conifer species would compete with and shade out the shadeintolerant aspen crowns. Closed crown canopies would result in decreased sunlight to the forest floor, 

decreased understory productivity and diversity, increased inter-tree competition, decreased tree health, 

growth and vigor, increased insect and disease-related mortality especially in older age classes, and 

decreased horizontal heterogeneity (Zegler et al. 2012, Calder et al. 2011). 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 209

Figure 55: Conifer encroaching an aspen stand in the DLH (2013)

Old Growth

Under the No Action Alternative, stands would continue to develop at a slower pace and may eventually 

meet the criteria for old growth under the current Forest Plan unless destroyed via wildfire, insects or 

disease. Current and increasing stand densities would continue to decrease the vigor and health of the 

stands. Due to high density and ladder fuel, fire hazard would increase over time. Without treatment the 

rate of mortality of existing yellow pines would increase both as a result of insects and disease as well as 

a result of combined inter-tree competition and drought (Ritchie et al. 2008, Das et al. 2011). In the event 

of a high severity wildfire, which is more likely under the current conditions than the treated conditions, 

the old ponderosa pines are more prone to dying than younger ponderosa pines (Kolb 2007).

Forest Health

Under the No Action Alternative, there would be no direct effect on dwarf mistletoe infection because no 

trees would be harvested. There would be no change in the level of dwarf mistletoe infection from 

existing levels. However, the No Action Alternative would indirectly affect the level of dwarf mistletoe 

infection over the long term. Under the No Action Alternative, dwarf mistletoe infection would continue 

to spread to more trees throughout and adjacent to infected stands, expanding at a rate of 1-2 feet per year. 

Increased dwarf mistletoe infection would result in reduced tree growth, reduced tree vigor, branch 

deformations, and shortened life span of the infected host (Conklin 2000). Reduced tree vigor and altered 

pitch flow associated with dwarf mistletoe infection would result in compromise of a tree’s defense 
Chapter 3: Affected Environment and Environmental Consequences

210 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

mechanisms to combat bark beetle attack, thus increasing the risk of successful bark beetle attack and 

mortality. Reduced tree growth and shortened life span would result in stagnation of VSS classes. 

Additionally, the accumulation of resin and branch deformations associated with dwarf mistletoe 

infection would result in increased fire hazard (Conklin, 2010, Hoffman et al. 2007). 

Under the No Action Alternative, increasing stand densities would result in increased inter-tree 

competition and decreased tree vigor. Natural defense mechanisms against insect attack, such as the 

production of pitch, would be limited, resulting in increased susceptibility to successful bark beetle attack 

and mortality. As stand densities continue to increase over time, trees become stressed, thus increasing 

the probability of successful bark beetle attack within the project area and further increasing the risk of 

bark beetle attack to all surrounding trees (McMillin 2008).

Cumulative Effects

Past Activities

According to the Coconino National Forest’s historic initial entry timber atlas, the areas within the project 

north of Schultz Pass Road (FR420) were designated as part of a watershed protection area for the City of 

Flagstaff in the early 1900s. That designation along with limited access and steep slopes in the Dry Lake 

Hills and Mount Elden means that limited if any logging has occurred in the areas of mixed conifer forest. 

In the MM area there was a logging railroad spur to the top of the mountain. Logging of the pine and 

mixed conifer occurred on the less steep portions of the mountain. On the steeper slopes of the mountain 

(above approximately 35 percent slope) it does not appear that logging occurred in the mixed conifer or 

ponderosa pine. 

Around the turn of the century and in the early 1900s, high-grade timber harvesting was conducted within 

the project area mainly along the foot slopes and more easily accessible. Portions of the project area were 

logged again during the 1940s, ‘70s and ‘80s. Additionally, pre-commercial thinning took place in the 

‘60s and ‘70s.

From the late 1990s to the mid-2000s, there was a severe region-wide drought, with the year 2002 being 

one of extreme heat and dryness. Monitoring showed an increase of tree mortality in ponderosa pine and 

mixed conifer forests. The results showed that the proportion of trees dying was greatest in large trees, 

particularly in mixed conifer. The level of mortality was greatest in the aspen and white fir species. In 

mixed-conifer forests, mortality in the largest size class (greater than 28 inches dbh) exceeded 22 percent

from 2002 to 2007. (Gainey & Vojta 2011)

Fire has been excluded and/or suppressed from the project area for over 110 years. From the 1970s to 

present, wildfires have occurred on approximately 500 acres within the DLH area and on only three acres 

in the MM area in the last 20 years. Reforestation efforts in the early 1980s occurred after the Radio Fire 

(1977) on top of Mt. Elden but largely failed and as a result, the area is still in a grass/forb development 

stage.

Cumulative Effects – Alternative 1: No Action: 

The cumulative effects of No Action are show in Table 71 through Table 84Table 72. The tables show a 

trend of reduced spatial heterogeneity, mortality of larger trees (especially aspen) and loss of highelevation grasslands that would perpetuate. Canopy cover would remain high and or increase, thus 

further reducing understory biodiversity and production. Inter and intra species competition for limited 

space, water, and sunlight would continue and increase. Aspen would continue to decline from 

competition and shade induced mortality. Increasing density would make existing pine trees more 

susceptible to bark beetle attacks with mortality occurring at a higher rate. Mixed conifer stands would 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 211

continue to retain high density and the more shade tolerant species which are less fire resilient will 

continue to encroach upon and shade out the fire adapted and less shade tolerant ponderosa pine within 

those stands. Existing high fire hazards would continue and increase the risk of an unnatural stand 

replacing fire to occur. Conifer encroachment would continue in the meadows and grasslands. Increasing 

density and canopy cover would also decrease understory species diversity of grass, forbs, and shrubs.

Climate change would continue to interact with the effects of fire suppression and increased tree densities 

to cumulatively increase the likelihood and severity of wildfires (Westerling et al. 2006). Those areas not 

affected by wildfire are likely to be more susceptible to bark beetle infestation resulting from the 

cumulative impact of a century of fire suppression and changing climatic conditions. Large tree 

recruitment would become more limiting over time as climate change imposes chronic drought and more 

widespread tree mortality (Diggins et al. 2010, Seager et al. 2010, Van Mantgem et al. 2009, Williams et 

al. 2012)

Currently, there are two ongoing projects located adjacent and or inside the project area. The purpose of 

the Eastside and Jack Smith Schultz projects is to reduce hazardous fuel accumulation, while improving 

forest health and promoting the development of VSS distributions recommended by management 

recommendations for the northern goshawk. One other project adjacent to the DLH project area has 

recently been completed. The Fort Valley project was a large scale restoration treatment to reduce 

hazardous fuel accumulation, while improving forest health. One other project currently underway is the

4-FRI. 4-FRI is a very large landscape project that would treat the majority of the operable ponderosa 

pine forest across the entire district over the course of approximately 20 years. The treatments proposed 

for the 4-FRI project will likely be somewhat similar but more open compared to the proposed FWPP 

treatments and aforementioned projects. Cumulatively, these projects would have an effect of increasing 

forest health and resiliency at the watershed-level.

The recently-signed decision on the Coconino Travel Management Rule (September 2011) closes a 

number of roads within the DLH and MM project areas. We can expect the restricted travel will reduce 

the amount of snags and down wood removed for fuelwood harvest. (Wisdom, 2008). This would 

partially counteract the effects of the proposed action that include a reduction in downed woody material 

over the next decade as the thinning and prescribed fire treatments would be implemented. 

Alternative 2 and 3 

Direct & Indirect Effects

Effects common to all proposed actions

All of the treatments described below would have a prescribed broadcast burn applied after vegetation 

treatments are completed. Burning of dead and down fuels would release nutrients and create small 

patches of mineral soil, which would facilitate future regeneration. According to the fire and fuels effects 

results in the FVS modeling, after vegetation treatment, prescribed burns would cause approximately 3

percent reduction in stand density of max SDI. The mortality caused by prescribed fire is random and 

unpredictable in terms of identifying which trees would be killed by the burn. However overall mortality 

is greatly reduced compared to a prescribed burn applied to the No Action Alternative. 

Treatments that would be the same under all three action alternatives and thus where effects would be the 

same are noted. Otherwise, effects discussed in this section pertain to only Alternatives 2 and 3. 
Chapter 3: Affected Environment and Environmental Consequences

212 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Ponderosa Pine – Dry Lake Hills (Northern Goshawk)

This section includes ponderosa pine in northern goshawk habitat and in MSO areas. All three levels of 

analysis show that the goshawk habitat area is dominated by VSS 3 and 4 structural stages. VSS 1, 2, and 

5 are lacking. At the point level LOPFA and PFA appear to have adequate representation of VSS 6, 

however at the stand level, LOPFA areas are lacking in VSS 6 while PFAs are over represented in VSS 6. 

Then at the large scale, it show that VSS 1, 2, 5, and 6 are lacking across the ponderosa pine vegetation. 

There is a need to create openings to introduce new VSS 1 and 2 areas. There is also a need to thin the 

VSS 3 and 4 stands to promote the growth of larger trees and to reduce large tree mortality (Ritchie et al. 

2008).

The treatments proposed under Alternatives 2 and 3 would create openings to begin the process of 

creating an uneven-aged stand structure with vertical diversity (except in the nest stands) by reducing the 

amount of VSS 3 and 4 and increasing the amount of VSS 1 and 2. The remaining areas outside of the 

regeneration openings would be thinned into groups creating horizontal diversity. Thinning would also 

have the effect of promoting the growth of large trees, reducing the potential large tree mortality caused 

by inter-tree competition, and increasing the development of VSS 5 and 6 size classes in the near future 

(Ritchie et al. 2008, Davis et al. 2007). The proposed initial entry burn would happen approximately two 

years after vegetation treatment. The post treatment conditions listed in Table 70are immediately after 

vegetation treatment and before the initial prescribed burn.

Current habitat variables such as basal area, canopy cover, and trees per acre, SDI, and snags are similar 

between LOPFA and PFA treatment areas, with the nest areas having a slightly higher BA, CC, and SDI, 

but fewer TPA and large snags. Canopy cover is measured across the stand and includes openings within 

the stand, CC values range from 69 to 72 percent. Basal area ranges from 132 to 146 ft2 and TPA (trees 

per acre) range from 256 to 391 trees. The percent of max SDI is at the high end of High density and low 

end of Extreme density. 

Table 67 includes post-treatment conditions at the stand level for the LOPFA, PFA, and nest areas, and 

shows some changes in VSS classes from Alternatives 2 and 3. For example, within the LOPFA areas, the 

percent of VSS 5 increases from 8 percent before treatment to 22 percent after treatment, while the 

percent of VSS 3 decreases from 32 percent to 1 percent. This is the result of thinning stands that are 

dominated by VSS 3 or VSS 4 sized trees (5-18 inches dbh), but which also have a fair amount of VSS5 

size trees (18 – 24 inches dbh). In these stands, many VSS 3 and 4 trees are being removed while almost 

no VSS 5 trees are removed. As a result, the percent of basal area from VSS 3 trees no longer dominates

the stand, and the basal area from VSS 5 trees is greater than the basal area of other VSS classes. Again 

in Table 67 under the PFA, there is an increase in VSS 5 and 6 and decrease in VSS 3 and 4. Reasons for 

these changes are that these stands are dominated by a mix of VSS3 and VSS4 (5 – 18 inch dbh) trees. 

Typically the VSS 5 and 6 trees are dominate and co-dominate trees while the VSS 3 and 4 trees are codominate, intermediate, and suppressed trees. 

In order to move toward the desired conditions for increasing the amount of VSS 5 trees and openings, it 

is necessary to remove those in greatest abundance, which includes VSS 3 and 4 trees. As a result, a large 

number of stands in the PFA would shift from VSS 3 and 4 to VSS 5 and 6. That is not to say all VSS 3

sized trees would be cut; rather, a group comprised of dominate VSS 3 trees would still be a VSS 3 group 

after thinning. However at the stand level the VSS class would still be classified as a VSS 5 or 6. Over 

time, after this treatment, the openings to create VSS 1 groups would become VSS 2 and then VSS 3 tree 

groups, and in future treatments, new openings would be created in those areas with an overabundance of 

VSS5 and 6 tree groups. 

Converting the even-age stands to uneven-aged stands within this project area would take several 

treatments, the implementation of which would span over many decades. Post-treatment values of SDI 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 213

for LOPFA is low density, while the PFA and nest stands would have an SDI value at the low end of 

moderate density. 

One of the main treatment differences between Alternatives 2 and 3 is the harvest methods. In Alternative 

2 there would be 252 acres of cable thinning (out of 1865 total acres) in LOPFA and 60 acres (out of 178

total acres) in PFA, and in Alternative 3 there would be helicopter harvesting in 242 acres (out of 1865 

acres) of LOPFA and 39 acres (out of 178 acres) of PFA. Both of these harvest methods require the 

falling of all snags for operational safety. Effects of snag removal are discussed in the Wildlife section of 

this chapter.

In Alternative 3 there would be 21 acres of steep slopes in the Goshawk PFA and 10 acres in Ponderosa 

Pine Fuels Reduction treated using specialized steep slope harvesting machines. While the steep slope 

harvesting machines are similar to ground based equipment, they are not as maneuverable on steep slopes 

as they are on flatter ground. The limited maneuverability may require the removal of snags, oaks, or trees 

over 18 inches dbh only when necessary for the machine to operate safely. However the removal of these 

forest components is anticipated to be negligible and would not impact the ability of those areas to meet 

desired conditions. Unlike cable or helicopter harvest methods, ground-based thinning operations do not 

require the falling of snags for safety reasons due to the enclosed cabs of the machines protecting the 

operators. When the cable treatments and helicopter treatments are averaged in with all the ground based 

treatment, there is only a very slight reduction in overall snag density across all those treatment acres (e.g. 

at the project level).

Table 67 through Table 69 include the DLH treatment three-scale analysis for goshawk habitat and also 

the ponderosa pine fuels reduction MSO habitat fuels reduction treatments. Table 70 through Table 72

show the habitat values for current conditions, post treatment conditions, and values projected out 20 

years and 40 years. Values for VSS 1 & 2 have been combined into a single column.

In 20 years, areas treated under Alternatives 2 and 3 would have greater increase in the percent of VSS 1, 

5, and 6 tree groups versus the No Action, thus moving conditions toward desired conditions for 

vegetation structural stages. Openings created in the LOPFA and PFA treatments stands would have 

regenerated moving those stands towards the desired condition of uneven aged stand structure. The more 

open stand structure would increase overall tree growth among the remaining trees by reducing inter-tree 

competition and increasing the availability of moisture, nutrients, and sunlight. The treated stand in the 

goshawk nest treatments would have moved towards desired VSS by moving VSS 3 and 4 trees into a 

VSS5 classification more rapidly. The SDI values for the treated stands would still be in the Low to 

Moderate density ranges, whereas in the no action the density would be in the Extreme range. The 

average canopy cover for the nest stand would be lowered to 53 percent which is lower than the 

recommended 60 percent for goshawk nest stands. This is because the entire stand is not entirely made 

up of VSS 5 and 6 tree groups. There are tree groups of VSS 1, 3, and 4 which would be managed at a 

lower canopy cover to allow for those tree groups to more quickly grow into the desired VSS 5 and 6 size 

class. After 20 years there is no discernable difference in the number of snags between Alternatives 2 

and 3.

In 40 years the majority of the LOPFA and PFA stand would be in the VSS 5 and 6 classifications. The 

openings created during treatment implementation would now be fully occupied by regeneration and 

moving into the VSS 3 classification. After 40 years the Goshawk nest stands would be comprised of 

mostly VSS 5 and 6 tree groups and canopy cover would be at 61 percent.

Approximately 150 acres of hand thinning would occur in ponderosa pine in goshawk habitat. Data for 

this treatment is not displayed in the tables below as there was no stand exam data available from the 

proposed treatment areas to input into the modeling effort. Field visits to these areas determined that 

desired conditions could be met or nearly met by using hand thinning methods. Compared to the other 
Chapter 3: Affected Environment and Environmental Consequences

214 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

pine treatment areas, the hand thinning treatment areas are either less dense and or have smaller average

size trees. Most of the hand thinning areas are located on steep rocky south facing slopes with poorer site 

conditions. These stands with poor site conditions are often the first to be attacked by bark beetles in time 

of drought (North, 2012). The dominate VSS class is VSS 3, BA range from 60-120 ft2. Treatments 

would only thin trees up to 9 inches dbh. Where practical and feasible leave trees would be arranged in 

groups and clumps, small openings would be created for regeneration. Tree per acre would be reduced up 

to 75 percent, and basal area would be reduced up to 35 percent. The thinning would have the effect of 

reducing the bark beetle hazard through reduced competition stress (Hayes et al. 2009). 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 215

Table 67: Dry Lake Hills - Small scale analysis of current conditions using data analyzed at the plot level and broken out into nest, PFA, 

and LOPFA areas. Average values calculated at the point level using individual stand exam plot data.

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

LOPFA Areas 2015 115 66 261 43 4.4 2 12 10% 27% 29% 14% 20%

PFA Areas 178 137 70 321 50 3.9 1.5 12 8% 44% 19% 11% 18%

Nest Areas 45 139 71 259 55 3.2 .2 12 0% 25% 50% 13% 13%

Table 68: Dry Lake Hills - Mid-scale analysis of current stand condition using data analyzed at the stand level and broken out into nest, 

PFA and LOPFA areas. Average values calculated by stand broken out by LOPFA, PFA, Nest areas, MSO PAC treatments and MSO PAC 

Nest Burn Only treatments. 

Acres BA

(ft2) 

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

LOPFA Areas

Alt 1, 2, & 3 2015 132 69 314 54% 2.1 1.2 14 0% 32% 53% 8% 7%

Alt 4 1486 134 70 391 57 1.9 1 11 0% 35% 55% 10% 0%

 PFA Areas

Alt 1, 2, & 3 178 138 70 307 54% 4.2 1.4 18 0% 51% 25% 0% 24%

Alt 4 105 137 70 355 54 5.4 1.8 21 0% 22% 39% 0% 39%

 Goshawk Nest

Alts 1, 2, 3, & 4 45 146 72 256 59% 4 .3 14 0% 0% 100% 0% 0%

MSO PAC 

treatments

Alts 1, 2 & 3 379 130 69 92 43 10.1 5.5 22
Chapter 3: Affected Environment and Environmental Consequences

216 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Acres BA

(ft2) 

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

Alt 4 230 130 69 285 51 3.4 2.4 13

MSO PAC Nest –

Burn Only

Alts 1, 2, 3, & 4 97 55 47 73 18 2.7 1.7 8

Table 69: Dry Lake Hills - Large scale analysis of current conditions across all goshawk areas treated within the DLH Area. Stand 

values averaged across all ponderosa pine stands within the northern goshawk habitat. 

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

All Goshawk 

Treated Acres 2238 133 69 312 54 2.3 1.2 14 0% 34% 51% 6% 9%

Table 70: Dry Lake Hills - Stand values of post vegetation treatment conditions (2013). 

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

LOPFA Areas

Alt 2 1865 48 43 138 19% 1.7 1.0 8 20% 1% 30% 22% 27%

Alt 3 1865 47 43 134 19% 1.7 1.1 8 20% 1% 30% 22% 27%

Alt 4 1486 43 41 177 19% 1.8 1 7 20% 2% 41% 27% 10%

 PFA Areas

Alt 2 178 73 54 99 26% 2.8 1.0 11 20% 0% 25% 11% 44%

Alt 3 178 69 52 98 25% 3.3 1.1 11 20% 0% 20% 11% 49%

Alt 4 105 74 54 106 26% 5.2 1.8 14 20% 0% 0% 18% 62%

 Nest Areas

Alts 2, 3, & 4 45 71 53 71 26% 3.9 .3 11 0% 0% 100% 0% 0%
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 217

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

MSO PAC 

treatments

Alts 2 379 106 64 46 32% 8.9 5.0 23

Alts 3 379 108 64 46 32% 10.1 5.5 24

Alt 4 230 78 56 71 26% 3.5 2.4 13

MSO PAC Nest –

Burn Only*

Alts 2 & 3 97 43 40 35 13% 10.5 2.2 8

*Burn only treatments are modeled in 2016

Table 71: Dry Lake Hills - Average stand values of the no action and action alternatives projected 20 years out (2033). 

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

LOPFA Areas

Alt 1 2015 153 73 283 59% 4.2 1.4 23 0% 2% 67% 24% 7%

Alt 2 1865 54 46 105 21% 2.2 1.2 10 20% 0% 3% 43% 33%

Alt 3 1865 53 46 104 21% 2.3 1.2 10 20% 0% 3% 43% 34%

Alt 4 1486 46 43 128 19% 2.2 1 9 20% 0% 4% 58% 18%

 PFA Areas

Alt 1 178 152 73 271 55% 8.7 2.2 21 0% 9% 42% 49% 0%

Alt 2 178 67 52 97 25% 1.8 1.0 13 20% 0% 25% 0% 55%

Alt 3 178 66 52 96 24% 1.8 1.0 13 20% 0% 18% 7% 55%

Alt 4 105 81 57 87 27% 4.5 2.1 16 20% 0% 0% 0% 80%

 Nest Areas

Alt 1 45 164 74 210 62% 7.9 1 23 0% 0% 100% 0% 0%

Alts 2, 3, & 4 45 82 58 115 32% 4.4 1.2 24 0% 0% 0% 100% 0%
Chapter 3: Affected Environment and Environmental Consequences

218 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

MSO PAC 

treatments

Alt 1 379 118 66 71 38% 11.1 5.5 21

Alts 2 379 97 61 80 32% 8.3 5.4 23

Alt 3 379 98 61 80 33% 8.7 5.7 23

Alt 4 230 81 57 156 30% 6.3 2.6 14

MSO PAC Nest 

–Burn Only

Alts 1 & 4 97 59 49 57 18% 4.6 2.4 13

Alts 2 & 3 97 43 41 28 12% 7.6 2.6 10

Table 72: Dry Lake Hills - Average stand values of the no action and action alternatives projected 40 years out (2053).

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18” 

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

LOPFA Areas

Alt 1 2015 165 75 253 60% 4.2 2 29 0% 0% 50% 38% 12%

Alt 2 1865 77 55 103 27% 2.1 1.1 15 0% 20% 1% 38% 40%

Alt 3 1865 76 55 102 27% 2.2 1.1 15 0% 20% 1% 38% 40%

Alt 4 1486 60 49 119 23% 1.5 .7 12 0% 20% 2% 51% 27%

 PFA Areas

Alt 1 178 160 74 234 54% 11.8 3 23 0% 0% 51% 0% 49%

Alt 2 178 87 58 70 29% 5.3 1.9 18 0% 20% 4% 21% 55%

Alt 3 178 84 57 69 27% 5.3 2.4 18 0% 20% 0% 17% 63%

Alt 4 105 91 60 76 29% 4.6 2.2 19 0% 20% 0% 0% 80%

 Nest Areas

Alt 1 45 167 75 160 59% 12 2.8 35 0% 0% 0% 100% 0%

Alts 2, 3, & 4 45 96 61 103 35% 4.5 2.6 26 0% 0% 0% 100% 0%
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 219

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18” 

VSS 

1/2 %

VSS 3 

%

VSS 4 

%

VSS 5 

%

VSS 6 

%

MSO PAC 

treatments

Alt 1 379 105 63 54 32% 10.6 5.9 22

Alts 2 379 91 59 68 29% 7.1 5.4 22

Alts 3 379 92 60 68 30% 7.3 5.5 22

Alt 4 230 92 60 145 33% 4.9 2.3 22

MSO PAC Nest 

–Burn Only

Alts 1 97 60 49 43 17% 6.1 2.8 15

Alts 2 & 3 97 42 40 21 11% 5.5 2.8 12
Chapter 3: Affected Environment and Environmental Consequences

220 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Ponderosa Pine – Dry Lake Hills (MSO)

The effect of treatment on MSO PAC Fuels Reduction areas reduces the BA from 130 to 106 ft2

for Alternative 2 and to 108 ft2 for Alternative 3. Under both Alternatives, canopy cover is 

reduced from 69 to 64, trees per acre are reduced from 92 to 46, and percent max SDI is reduced 

from 43 percent (high density) to 32 percent (moderate density). One of the differences between 

the alternatives is harvest methods. In Alternative 2 there would be 44 acres (out of 379) treated 

by cable yarding, which would require the cutting of all snags and removal of all trees (including 

those over 18 inches dbh) within the cable corridors. In Alternative 3, there would be 16 acres of 

helicopter logging within MSO PACs, which would require the removal of all snags for 

operational safety. After treatment there would be slightly less large snags per acre under 

Alternative 2 compared to Alternative 3: 5 snags per acre versus 5.5. Due to the treatment area 

having a relatively high number of trees greater than 18 inches dbh that would not be cut, the 

post-treatment stand conditions would continue to be relatively dense. The percent max SDI 

would continue to be in the extreme range. Competition induced mortality would continue to 

occur, the bark beetle hazard would be high and competition induced stress may cause the trees in 

this treatment area to be less resistant to insects and diseases.

In 20 years, BA, canopy cover, SDI, are all lower than the No Action Alternative. The number of 

large snags is about the same as current conditions, and there are slightly more large trees in 

Alternatives 2 and 3 than in the No Action due to increased growth rates from educed 

competition, which would also cause those large trees to be more resistant to mortality from 

competition, drought, insects and disease. 

In 40 years, BA, canopy cover, and SDI are all still slightly lower than the No Action Alternative; 

however the number of snags and large trees are about the same. The treatment has the effect of 

reducing long-term mistletoe infection rating, thus improving the health and resiliency of the 

stands several decades after treatment.

Approximately 94 acres of hand thinning would occur within PACs. Data for this treatment is not 

displayed as there was no stand exam data available from the proposed treatment areas. Field 

visits to these areas determined that desired conditions could be met or nearly met by using hand 

thinning methods. Compared to the other pine treatment areas, the hand thinning treatment areas 

are either less dense and or have smaller average size trees. Most of the hand thinning areas are 

located on steep rocky south facing slopes with poorer site conditions. These stands with poor 

site conditions are often the first to be attacked by bark beetles in time of drought. The dominate 

VSS class is VSS 3, BA range from 60-120 ft2. Treatments would only thin trees up to 9 inches 

dbh. Where practical and feasible leave trees would be arranged in groups and clumps, small 

openings would be created for regeneration. Tree per acre would be reduced up to 75 percent, 

and basal area would be reduced up to 35 percent or approximately 50 ft2 BA (40 percent canopy 

cover). The thinning would have the effect of reducing the bark beetle hazard through reduced 

competition stress (Hayes et al. 2009). 

Prescribed burns would be conducted in all MSO nest cores with low intensity with the purpose 

of reducing dead and down fuel loading, creating some mortality of smaller trees in the denser 

patches and raising canopy base heights. Prescribed burning would create a short term spike of 

smaller sized snags. Small opening may be created where the prescribed burn created pockets of 

mortality. The small openings would allow for trees to regenerate and would have the effect of 

helping to maintaining uneven-age stand characteristics. Any small openings created would also 

have the effect of increasing understory production and diversity.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 221

Ponderosa Pine – Mormon Mountain (MSO)

As shown in Table 73, under all action alternatives, BA in ponderosa pine would be reduced from 

161 to 60 ft2, canopy cover would fall from 74 percent to 49 percent, TPA would be reduced to 

534 from 730, and percent max SDI would fall from 74 percent to 31 percent in the Ponderosa 

Pine Fuels Reduction treatment area. This overall reduction in density along with creating 10

percent openings across each stand would have the effect of opening up the forest floor to 

sunlight and increasing understory diversity. The open stand conditions would allow for 

prescribed fire to be reintroduced in a safe and controlled manner. Competition between trees for 

space, water, and sunlight would be greatly reduced, increasing individual tree health and growth. 

Levels of dwarf mistletoe rating would be reduced through selective cutting of infected trees. 

The creation of regeneration openings would allow for groups of regeneration throughout the 

stand and create desired vertical diversity. The treatments would also leave trees in groups and 

clumps which would also create horizontal diversity. Small to medium size ponderosa pines 

would be removed from around large oaks and have the effect of reducing competition to the 

oaks. Oak crowns would increase in size and volume and mast (acorn) production would

increase.

The effects twenty years after treatment are shown in Table 74. Basal Area and canopy cover 

increase slightly from immediately post-treatment conditions; however TPA and percent max SDI 

have decreased due to the effects of the prescribed fire reducing the number of small Gambel oak 

stems. The number of snags increases but is less than the No Action Alternative due to the 

reduced competition between trees from the thinning and prescribed burn treatments, which 

increase tree health and thus results in less trees dying and becoming snags.

Table 75 shows stand conditions 40 years after treatment. Basal Area and canopy cover, TPA, 

and percent max SDI have all accrued a healthy increase but still continue to be significantly 

lower than the No Action Alternative. The regeneration openings that were created now contain 

young trees that are starting at add to the canopy cover. The increased percent max SDI would 

almost be in the high density range, where the stands would start to see marked declines in 

understory production, competition among trees and reduced tree growth and vigor. Despite the 

increased stand density, this treatment area would still be benefitting from the thinning and 

prescribed burning treatment after 40 years.

The effects of the MSO PAC Fuels Reduction Treatment would be very similar between the 

different action alternatives. Alternative 2 would have 22 acres of treatment implemented using 

cable harvesting. Within those 22 acres, all snags would be felled and left in place due to 

operation safety requirements for cable yarding. Cable yarding also requires the construction of 

corridors for the cables to yard out the logs to be removed. Alternative 3 would implement on 

those same 22 acres using specialized steep slope harvesters. While the steep slope harvesting 

machines are similar to ground based equipment, they are not as maneuverable on steep slopes as 

they are on flatter ground. The limited maneuverability may require the removal of snags, oaks, 

or trees over 18 inches dbh only when necessary for the machine to operate safely. However the 

removal of these forest components is anticipated to be negligible and would not impact the 

ability of those areas to meet desired conditions. Alternative 4 would not treat those 22 acres. 

Under all the action alternatives, the remaining acres would be treated using conventional ground 

based harvesting methods. Treatment intensity would remain the same across all alternatives. 

The overall difference between the three alternatives in this treatment area would be very small

because the 22 acres that would be treated differently is a fraction of the total acres.

As shown in Table 73, in MSO PAC treatments, BA would be reduced from 161 to 63 ft2, canopy 

cover would fall from 74 percent to 50 percent, TPA would be reduced to 515 from 1210, and 
Chapter 3: Affected Environment and Environmental Consequences

222 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

percent max SDI would fall from 72 percent to 28 percent. This overall reduction in density 

along with creating 10 percent openings across each stand would have the effect of opening up 

the forest floor to sunlight and increasing understory diversity. The open stand conditions would 

allow for prescribed fire to be reintroduced in a safe and controlled manner. Levels of dwarf 

mistletoe rating would be reduced through selective cutting of infected trees. The creation of 

regeneration openings would allow for groups of regeneration throughout the stand and create 

desired vertical diversity. The treatments would also leave trees in groups and clumps, which 

would also create horizontal diversity. Small to medium size ponderosa pines would be removed 

from around large oaks and have the effect of reducing competition to the oaks. Oak crowns 

would increase in size and volume and mast (acorn) production would increase.

The effects 20 years after treatment are shown in Table 77. Basal Area and canopy cover 

increase slightly, however TPA and percent max SDI have decreased due to the effects of the 

prescribed fire reducing the number of small Gambel oak stems. 

Table 78 shows stand conditions 40 years after treatment. Basal Area and canopy cover, TPA, 

and percent max SDI have all accrued a healthy increase but still continue to be significantly 

lower than the No Action Alternative. The regeneration openings created during implementation 

would now contain young trees that are starting to add to the canopy cover. The increased 

percent max SDI is still solidly in the moderate density range. Despite the increased stand 

density, this treatment area would benefit from the thinning and prescribed burning treatment 

after 40 years.

There are 52 acres of identified ponderosa pine forest with in the MSO nest cores. The prescribed 

burn treatment would have the effect of reducing basal area from 146 to 122 ft2, canopy cover 

would be lowered from 72 percent to 67 percent. Trees per acre would drop from 600 to 325. 

The percent max SDI is reduced from the extreme density of 61 percent to the high density of 48

percent. The number of medium (greater than 12 inches dbh) and large (greater than 18 inches 

dbh) snags more than doubles after treatment. Prescribed fire would have the effect of killing 

approximately 275 trees (according to modeling). However prescribed fire would not reduce 

basal area by a correspondingly large percent because the treatment would likely kill mostly small 

oak trees. Most of the trees greater than 18 inches dbh are anticipated to survive prescribed 

burning.

After 20 years the BA, canopy cover, and percent max SDI would all have increased since the 

prescribed burn, but would still be appreciably lower than the No Action Alternative. However 

the treatment area would start to once again experience tree competition and possible 

competition-induced mortality. 

After 40 years, the BA, canopy cover, and percent max SDI would all have increased, yet would 

still be lower than under the No Action Alternative. The number of trees greater than 18 inches

dbh would also have greatly increased; however the anticipated increase in density means the 

treatment area would continue to experience tree competition and competition-induced mortality.

MSO Nest Roost Recovery Habitat – Effects Common to all Action Alternatives

The MSO Nest Roost Recovery treatment area was identified as nest roost recovery habitat as 

part of an earlier analysis related to the 4FRI. This stand would be treated to meet the minimum 

habitat requirements for MSO nest roost recovery habitat under the 2012 revised MSO Recovery 

Plan. Under all three action alternatives, BA would be reduced from 173 to 120 ft2, canopy cover 

would be reduced from 76 to 67 percent, trees per acre would be reduced from 949 to 906, and 

percent max SDI would be reduced from 87 to 64 percent. The percent of BA from 12 to 18 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 223

inches dbh would increase from 17 percent to 19 percent, while the percentage of BA in trees 

greater than 18 inches dbh would drop from 61 percent to 49 percent. Stand density would still be 

very high, and competition-induced mortality would still occur after treatment. Stand exam data 

also shows this stand contains a high number of large trees (39 TPA over 18 inches dbh). This 

treatment would reduce the number of trees over 18 inches dbh to approximately 19 TPA 

immediately after treatments. 

In twenty years, BA and canopy cover would be slightly higher; however due to prescribed 

burning, TPA would drop to 448 TPA, and percent max SDI would also drop to 60 percent. 

There would not be as many snags per acre compared to the No Action Alternative. For 

Alternatives 2, 3, and 4, BA would be 131ft2and there would be approximately 22 trees greater 

than 18 inches dbh per acre. The percent BA from 12 to 18 inches dbh would be 30 percent for 

all three action alternatives versus 21 percent for the No Action Alternative. The percent BA in 

trees greater than 18 inches dbh would be 57 percent for all three action alternatives versus 68 

percent under the No Action Alternative. Twenty years after treatment this stand would meet all 

minimum desired conditions for MSO Nest Roost Recovery Habitat of at least 30 percent BA in 

the 12-18 inch dbh size class and 30 percent BA in trees greater than 18 inches dbh, along with 

120 BA and 12 trees per acre greater than 18 inches dbh.

After 40 years, BA, canopy cover, percent max SDI, and tree over 18 inches dbh would have 

increased while TPA and average snags per acre would have decreased. For the action 

alternatives, BA would be 154 and the average number of trees greater than 18” dbh per acre 

would be 24. The percent BA from 12 to 18 inches dbh would be 30 percent for all three action 

alternatives versus 21 percent for the No Action Alternative, while the percent BA in trees greater 

than 18 inches dbh would be 56 percent for all three action alternatives versus 68 percent for the 

No Action. Forty years after treatment this stand would meet all minimum desired conditions for 

MSO Nest Roost Recovery Habitat of at least 30 percent BA in the 12-18 inches dbh size class 

and 30 percent BA in trees greater than 18 inches dbh, along with 120 BA and 12 trees greater 

than 18 inches dbh. After 40 years the decrease in snags would be the result of no new snags 

being created by disturbance agents such as fire or dwarf mistletoe. This stand does not have any 

recorded dwarf mistletoe.

Table 73: Mormon Mountain - Stand values of current conditions and post treatment 

conditions for Ponderosa Pine Fuels Reduction treatments

Acres BA 

(ft2)

CC 

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Ponderosa Pine

Alt 1 776 161 74 730 74% 4.3 0.5 16

Alts 2, 3, & 

4

776 60 49 534 31% 4.1 0.5 9

MSO PAC treatments

Alt 1 1083 161 74 1210 72% 4.9 0.9 12

Alt 2 1083 63 50 515 28% 4.6 0.9 13

Alt 3 1083 63 50 515 28% 4.7 0.9 13

Alt 4 1061 63 50 517 28% 4.7 0.9 13

MSO PAC Nest –Burn Only*
Chapter 3: Affected Environment and Environmental Consequences

224 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Acres BA 

(ft2)

CC 

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Alts 1 & 4 52 146 72 600 61% 4.4 .5 10

Alts 2 & 3 52 122 67 325 48% 12.4 1.2 11

MSO Nest

Roost Recovery

Alt 1 22 173 76 949 87% 5 1.3 39 17% 61%

Alts 2, 3, & 

4

22 120 67 906 64% 4.8 1.3 19 19% 49%

*Burn only treatment modeled in 2016

Table 74: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 20 years out for ponderosa pine stands. 

Acres BA 

(ft2)

CC 

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Ponderosa Pine

Alt 1 776 177 77 598 76% 6.9 1.1 23

Alts 

2, 3, 

& 4

776 65 51 222 28% 2.1 .8 11

MSO PAC treatments

Alt 1 1083 180 77 901 73% 7.9 1.2 18

Alt 2 1083 69 53 207 27% 2.5 1.4 15

Alt 3 1083 69 53 206 27% 2.5 1.4 15

Alt 4 1061 70 53 209 27% 2.5 1.4 15

MSO PAC Nest –Burn Only

Alts 

1 & 4 52 165 75 500 62% 7.1 1.1 15

Alts 

2 & 3 52 137 70 295 50% 7.6 1.3 15

MSO Nest 

Roost Recovery

Alt 1 22 182 77 742 86% 7.6 2.7 43 21% 68%

Alts 

2, 3, 

& 4

22 131 69 448 60% 3.8 1.2 22

30% 57%
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 225

Table 75: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 40 years out for ponderosa pine stands. 

Acres BA

(ft2)

CC

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Ponderosa Pine

Alt 1 776 184 78 506 75% 9.8 2.1 30

Alts 2, 3, 

& 4 776 85 58 208 34% 2.3 1.1 14

MSO PAC treatments

Alt 1 1083 197 79 714 73% 9.5 2 26

Alt 2 1083 86 58 194 31% 2.2 1.6 19

Alt 3 1083 86 58 194 31% 2.2 1.6 19

Alt 4 1061 87 58 195 31% 2.3 1.6 19

MSO PAC Nest –Burn Only

Alts 1 & 

4

52 182 77 440 63% 8 1.6 26

Alts 2 & 

3

52 150 72 258 51% 7.8 1.8 27

MSO Nest

Roost Recovery

Alt 1 22 190 78 608 86% 7.5 3 40 21% 68%

Alts 2, 3, 

& 4 22 154 73 410 67% 2.5 .7 24 30% 56%

Mixed Conifer – Dry Lake Hills

Common to Alternatives 2, 3 and 4

Though the Northern Goshawk Nest Fuels Reduction treatment description is slightly different 

from what is proposed for the rest of mixed conifer MSO recovery habitat, the desired conditions 

would still be in line with guidelines for MSO recovery habitat. All other northern goshawk nests 

are located within MSO PACs, which is why they are not discussed separately. This nest site is 

outside of PACs so we can treat it separately within the revised MSO Recovery Plan guidelines

for recovery habitat. This treatment area would be an intermediate thin from below: basal areas 

would be reduced from 157 to 71. Canopy cover would decrease from 74 to 53 percent and TPA 

would be reduced from 931 to 204. No trees over 18 inches dbh would be cut, of which there is 

an average of 20 TPA. This treatment would also move the stand from an extreme density rating 

to a moderate density rating. Competition between trees for space, water, and sunlight would be 

greatly reduced, increasing individual tree health and growth. This treatment would not create 

any regeneration openings. There would be a response from the understory from opening up the 

overstory canopy, but without creating regeneration openings the increased understory 

productivity would be short lived as the overstory crowns grow and close in. 

After 20 years, BA, canopy cover, and percent max SDI would increase, but still be substantially

lower than the No Action Alternative. Also, the number of large trees would not be as great 

compared to the No Action Alternative. This is not because large trees would be cut; rather it is 
Chapter 3: Affected Environment and Environmental Consequences

226 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

because there would be fewer middle size trees available in the more open treated conditions to 

grow into large trees than there would be in the dense conditions of the No Action Alternative.

After 40 years, BA, canopy cover, and percent max SDI would increase, but still be significantly 

lower than the No Action Alternative. The stand density would now be in the high range and the 

trees would start competing for resources amongst each other. After 40 years, the stand conditions 

would still be much more open than current conditions, showing that the positive effects of 

thinning and burning would last at least 40 years. The number of large trees would still not be as 

great compared to the No Action Alternative.

There are two identified PFAs in the DLH. Only the Schultz Pass PFA contains mixed conifer 

outside of MSO PACs. The action alternatives would mechanically treat mixed conifer within 

the Schultz Pass PFA following the Forest Plan standards and guidelines for managing northern 

goshawk PFAs outside of nest centers. The treatment would also follow the recommendations for 

treatment of MSO recovery habitat. Treatment within the Schultz PFA areas would reduce the 

BA from 135 to 76 ft2 for Alternatives 2, 3 and 4; canopy cover would be reduced from 70 to 55 

percent, and TPA would decrease from 850 to 115. Even though the average stand canopy cover 

would be 55 percent, the Forest Plan standards of maintaining 60 percent canopy cover within 

VSS 4-6 would still be maintained; the average is lower than 60 percent when areas of VSS 1-3 

are factored in. Percent max SDI would decrease from 57 percent (extreme density) to 24 percent 

(low density). The trees per acre of trees larger than 18 inches dbh would decrease from 21 to 15.

Openings would be created in up to 20 percent of the treatment area. The overall reduction in 

density along with creating 20 percent openings across each stand would have the effect of 

opening up the forest floor to sunlight and increasing understory diversity. The creation of 20 

percent openings would allow for early seral species such as aspen and pine to regenerate and 

would have the effect of helping to maintaining uneven-age stand characteristics. The open stand 

conditions would allow for prescribed fire to be reintroduced in a safe and controlled manner. 

Selective cutting of trees infected with dwarf mistletoe would help to reduce overall infection 

levels in the stand and improve overall stand health.

In 20 years, BA, canopy cover, TPA, percent max SDI, and trees greater than 18 inches dbh

would all have increased post-treatment (Table 77). The number of trees would have increased 

due to regeneration in the openings. The number of large snags would have decreased slightly to 

2.2 snags per acre and would only be slightly less than the 2.6 snags per acre in the No Action 

Alternative. The number of trees greater than 18 inches dbh would have gone up slightly but 

would be approximately half that of the No Action Alternative. The number of 18 inch dbh trees 

would be less due to the removal of some of the medium size trees from which are no longer 

available to grow into future large trees. 

In order for the action alternatives to have the same number of large trees as the No Action 

Alternative would require thinning from below in order to leave all the large and medium size 

trees. This would also require the removal of most of the smaller trees and prevent the creation of 

regeneration openings thus not meeting the desired condition of creating an uneven-age 

heterogeneous stand structure. It would also remove all of the lower age class tress that would 

eventually grow into large, mature trees in the coming decades.

In 40 years, BA, canopy cover, and SDI would all still be significantly lower than the No Action 

Alternative (Table 78). The number of snags and large trees would be less than the No Action 

Alternative. Trees over 18 inches dbh would be less than the No Action Alternative: 19 TPA 

compared to 27 TPA due to the same issue discussed in the previous paragraph. However, it is 

important to note that under Alternatives 2 and 3, the large trees would have much less likelihood 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 227

of mortality because they would be much more resilient to inter-tree competition, drought, insects 

and disease. Overall stand density is still greatly lower than current conditions, showing that 

thinning and burning treatments would have the positive effect of lower stand density for at least 

40 years. 

Specific to Alternatives 2 & 3

Treatment within Mixed Conifer Fuels Reduction areas would reduce the BA from 141 to 62 ft2 

for both Alternative 2 and 3; canopy cover would be reduced from 71 to 50 percent, and TPA 

would decrease from 1130 to 213 for Alternative 2 and 198 for Alternative 3. Percent max SDI 

would decrease from 57 percent (extreme density) to 22 and 21 percent (low density) under 

Alternatives 2 and 3, respectively. The creation of 10 percent openings would allow for early 

seral species such as aspen and pine to regenerate and would have the effect of helping to 

maintaining uneven-age stand characteristics.

The main difference between Alternatives 2 and 3 is the harvest methods used. Alternative 2 

would treat 514 acres (out of 1140) by cable yarding, which would require the cutting of all snags

both within and immediately adjacent to cable corridors, as well as the removal of all trees 

(including those over 18 inches dbh) within the cable corridors. Despite the creation of the cable 

corridors, the average number trees over 18 inches dbh post-treatment within this treatment area 

would be about the same in this alternative compared to Alternative 3. Alternative 3 would 

include 425 acres of helicopter logging, which would require the removal of all snags in those 

units for operational safety. 

After treatment there would be fewer large snags per acre under each alternative: 2.1 snags for 

Alternative 2 and 2.4 snags for Alternative 3 compared to snags per acre in the No Action 

Alternative. Openings would be created in up to 10 percent of the treatment area. The overall 

reduction in density along with creating 10 percent openings across each stand would have the 

effect of opening up the forest floor to sunlight and increasing understory diversity. The more 

open stand conditions would allow for prescribed fire to be reintroduced in a safe and controlled 

manner. Selective cutting of trees infected with dwarf mistletoe would help to reduce overall 

infection levels in the stand and improve overall stand health.

In 20 years, BA, canopy cover, SDI, would all still be about the same as post-treatment due to 

mortality associated with prescribed fire. The number of trees would have increased due to 

regeneration in the openings. The number of large snags would be about the same and is only 

slightly less than the No Action Alternative. The number of trees greater than 18 inches dbh

would have gone up slightly but would still be less than the No Action Alternative. The number 

of 18 inch dbh trees would be less due to the removal of some of the medium size trees from 

which are no longer available to grow into future large trees. In order for the action alternatives 

to have the same number of large trees as the no action alternative would require thinning from 

below in order to leave all the large and medium size trees. This would also require the removal 

of most of the smaller trees and prevent the creation of regeneration openings thus not meeting 

the desired condition of creating an uneven-age heterogeneous stand structure.

In 40 years, BA, canopy cover, and SDI would all still be significantly lower than the No Action 

Alternative. The number of snags would be about the same as the No Action Alternative. Trees 

over 18 inches dbh would be less than the No Action Alternative: 17 TPA compared to 23 TPA 

due to the same issue discussed in the previous paragraph. Overall stand density is still greatly 

lower than current conditions, showing that thinning and burning treatments would have the 

positive effect of lower stand density for at least 40 years. 
Chapter 3: Affected Environment and Environmental Consequences

228 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Field visits to the area proposed for Mixed Conifer Fuels Reduction hand-thinning treatment 

determined that treatment by cable yarding would not be desirable or practical due to the high 

cost and potential resource damage from building temporary roads through very rocky, 

inaccessible ground in order to access those areas. Alternative 2 would hand thin 132 acres; under 

Alternative 3, only 85 acres would be hand thinned in this treatment area. The reduction in the 

number hand thinning acres in Alternative 3 is due to more acres that could have material 

removed by helicopter without the anticipated resource damage associated with cable corridors. 

Most of the hand thinning areas would be located on steep rocky slopes with poorer site 

conditions. 

Basal area would be reduced from 140 to 102 ft2, canopy cover would be reduced from 71 to 63 

percent, TPA would be reduced from 1248 to 275, the percent max SDI would be reduced from 

59 to 35 percent. 

After 20 years, basal area and canopy cover would be lower as the result of the mortality 

associated with prescribed burning. TPA would also be lower due to tree mortality from 

prescribed burning. With fewer trees, the percent max SDI would now be in the moderate density 

range.

After 40 years, basal area and canopy cover would have increased. The density rating would still 

be in the moderate range. Even after 40 years, this treatment area would still meet fuels reduction 

targets. 

Low intensity prescribed burning would be conducted within 163 acres of MSO nest cores within 

the DLH with the purpose of reducing dead and down fuel loading, creating some mortality of 

smaller trees in the denser patches, and raising canopy base heights. Prescribed burning would 

create a short term spike of smaller sized snags. Small opening may be created where the 

prescribed burning created pockets of mortality. The small openings would allow for early seral 

species such as aspen and pine to regenerate and would have the effect of helping to maintaining 

uneven-age stand characteristics. Any small openings created would also have the effect of 

increasing understory production and diversity.

A district-wide assessment of available MSO nest roost recovery habitat identified a need to 

designate 72 acres of nest roost habitat within the mixed conifer habitat within DLH. The area 

designated was assessed for treatment needs; based on this assessment, a hand thinning treatment 

was determined to meet the objectives of reducing fire hazard while meeting the intent of the 

revised MSO Recovery Plan guidelines. As outlined in the description of effects below, the 

proposed treatment would lower the BA from 148 to 99 ft2. This would lower the BA below the 

recommended threshold of 120 ft2 ; however this stand has a very high number of trees per acre 

(2,986), of which approximately 2,600 are less than 9 inches dbh. Thinning this stand to 120 ft2 of 

BA would require leaving an additional 74 trees per acre between 5 and 9 inches dbh. If that were 

to occur, after 40 years, there would be 16 trees per acre greater than 18 inches dbh compared to 

17 trees per acre greater than 18 inches dbh under Alternatives 2 and 3. The model shows that 

thinning to 99 ft2instead of 120 ft2 would also have greater fuels reduction benefits over 40 years, 

such as greater average crown base height, less crown bulk density, and greater crowning and 

torching indexes. 

BA in the 72 acres proposed for MSO Nest Roost Recovery hand-thinning would be reduced 

from 148 to 99 ft2, canopy cover would be reduced from 72 to 62 percent, TPA would be reduced 

from 2986 to 421, and the percent max SDI would be reduced from 71 to 34 percent. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 229

After 20 years, BA and canopy cover would be somewhat lower due to mortality caused by 

prescribed burning. TPA would also be lower due to tree mortality from prescribed burning. 

With fewer trees, the percent max SDI would also be lower. Increased sunlight to the forest floor 

would increase understory production and diversity. For Alternatives 2 and 3, BA would be 78ft2

and the average number of trees greater than 18 inches dbh per acre would be 11. The percent 

BA from 12 to 18 inches dbh would be 56 percent for the two action alternatives versus 29 

percent for the No Action Alternative, while the percent BA in trees greater than 18 inches dbh 

would be 30 percent for all three action alternatives versus 12 percent for the No Action 

Alternative. Twenty years after treatment this stand would not meet minimum desired conditions 

for MSO Nest Roost Recovery Habitat of 120 BA and 12 trees greater than 18 inches dbh.

After 40 years, basal area and canopy cover would have increased back to conditions similar to 

post vegetation treatment. For Alternatives 2 and 3, basal area would be 93ft2and the average 

number of trees greater than 18 inches dbh per acre would be 17. The percent BA from 12 to 18

inches dbh would be 30 percent for the two action alternatives versus 20 percent for the No 

Action Alternative, while the percent BA in trees greater than 18 inches dbh would be 62 percent

for the two action alternatives versus 22 percent for the No Action Alternative. Forty years after 

treatment this stand would meet minimum desired conditions for MSO Nest Roost Recovery 

Habitat of at least 30 percent BA in the 12-18 inch dbh size class and 30 percent BA in trees 

greater than 18 inches dbh, along with 12 TPA greater than 18 inches dbh, but would not have the 

minimum 120 BA. Under the No Action Alternative, the minimum habitat requirements would be 

met for BA and large trees but not for percentage of BA in the 12-18 inch dbh or 18 inch+ dbh 

size classes. The minimum habitat requirements would not quite be met in 40 years with this 

treatment, whereas they might be met in the No Action Alternative if no significant wildfire were 

to occur. However, under Alternatives 2 and 3, the stand would be much more fire resilient, tree 

health would be greater and more resilient to major drought events, and trees would have greater 

resistance to bark beetle attacks. 

MSO PAC Fuels Reduction Treatment under Alternatives 2 and 3 would reduce the BA from 137 

to 81 ft2 for Alternative 2 and 82 ft2 for Alternative 3. Canopy cover would be reduced from 70 

to 57 percent, and TPA would be reduced from 1143 to 306 for Alternative 2 and 256 for 

Alternative 3. Percent max SDI would be reduced from 56 percent (extreme density) to 29

percent (moderate density). The creation of 10 percent openings would allow for early seral 

species such as aspen and pine to regenerate and would have the effect of helping to maintaining 

uneven-age stand characteristics.

The primary difference between the two alternatives is harvest method utilized for material 

extraction. In Alternative 2 there would be 316 acres (out of 788 acres) treated by cable yarding,

which would require the cutting of all snags within and adjacent to the cable corridor, and 

removal of all trees (including those over 18 inches dbh) within the cable corridors. In Alternative 

3 there would be 251 acres (out of 816 acres) of helicopter logging, which would require the 

removal of all snags in those units for operational safety. After treatment there would be slightly 

fewer large snags per acre in Alternatives 2 and 3 than under the No Action Alternative: 2.3 and 

2.7 respectively, compared to 4.0 No Action Alternative. Openings would be created in up to 10 

percent of the treatment area. The overall reduction in density along with creating 10 percent

openings across each stand would have the effect of opening up the forest floor to sunlight and 

increasing understory diversity. The open stand conditions would allow for prescribed fire to be 

reintroduced in a safe and controlled manner. Selective cutting of trees infected with dwarf 

mistletoe would help to reduce overall infection levels in the stand and improve overall stand 

health and promote development of VSS 3 and 4 trees to VSS 5 and 6 trees.
Chapter 3: Affected Environment and Environmental Consequences

230 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

In 20 years, BA, canopy cover, SDI, would have increased slightly. The number of large snags 

and trees greater than 18 inches dbh would be slightly less than the No Action Alternative. 

In 40 years, BA, canopy cover, and SDI would all be greatly lower than the No Action

Alternative. The number of snags and large trees would still be slightly lower compared to the 

No Action Alternative. The number of 18 inch dbh trees would be less due to the removal of 

some of the medium size trees from which are no longer available to grow into future large trees. 

In order for the action alternatives to have the same number of large trees as the no action 

alternative would require thinning from below in order to leave all the large and medium size 

trees. This would also require the removal of most of the smaller trees and prevent the creation of 

regeneration openings thus not meeting the desired condition of creating an uneven-age 

heterogeneous stand structure. Thinning from below would also create an age class “gap” so that 

in several decades there would be few or no trees available to replace the large mature trees that 

die off. Because the treatments would reduce recruitment of future large trees in the coming 

decades and stand conditions would be more open, there would be slightly fewer large trees 

available to become snags and the large trees available would have less competitive stress, thus 

would be healthier and would be less likely to die and become snags.

Table 76: Dry Lake Hills - Stand values of current conditions and post treatment conditions 

for Dry Mixed Conifer 

Acres BA

(ft2)

CC

(%) TPA

% 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Goshawk Nest Fuels Red.

Alt 1 54 157 74 931 72 7.4 3.3 20

Alts 2, 3, & 4 54 71 53 204 28 7.2 3.2 20

Goshawk PFA Fuels Red.

Alt 1 181 135 70 850 57 6.6 2.7 21

Alts 2, 3, & 4 181 76 55 115 24 6.4 2.6 15

Mixed Conifer Fuels Red.

Alts 1 1124 141 71 1130 57 9.6 4.0 13

Alt 2 1124 62 50 213 22 5.0 2.1 12

Alt 3 1158 62 50 198 21 5.8 2.4 12

Alt 4 542 63 50 217 22 8.9 3.8 12

Mixed Conifer Fuels Red. Hand Thin

Alts 1 132 140 71 1248 59% 11 4.3 12

Alt 2 132 102 63 275 35% 10.4 4.1 12

Alt 3 85 102 63 275 35% 10.4 4.1 12

MSO Nest Fuels Red. Hand Thin

Alts 1 122 122 67 1952 54 6.2 4.3 13

Alts 2, 3 & 4 122 111 65 540 41 5.9 4.1 13

MSO Nest Fuels Reduction Burn Only*

Alts 1 & 4 163 139 70 476 50 5.9 2.6 24

Alts 2 & 3 163 108 64 174 34 16.3 6.5 21

MSO Nest Roost Recovery Hand Thin

Alts 1 & 4 72 148 72 2986 71 16.23 2.4 7 25% 11%

Alts 2 & 3 72 99 62 421 34 15.4 2.3 7 38% 16%
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 231

Acres BA

(ft2)

CC

(%) TPA

% 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

MSO PAC Fuels Reduction

Alt 1 788 137 70 1143 56 9.2 4.0 14

Alt 2 788 81 57 306 29 5.1 2.3 14

Alt 3 816 82 57 256 29 5.8 2.7 14

Alt 4 337 81 57 201 27 6.9 3.8 16

MSO PAC Fuels Reduction Hand Thin

Alt 1 108 120 67 1067 53 7 4.1 13

Alts 2 & 3 108 93 60 126 29 6.8 4 13

Alt 4 121 93 60 126 29 6.8 4 13

*Burn only treatments were modeled to occur 2016

Table 77: Dry Lake Hills - Average stand values of no action and proposed alternatives 

projected 20 years for Dry Mixed Conifer 

Acres BA

(ft2)

CC

(%) TPA

% 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Goshawk Nest Fuels Red.

Alt 1 54 185 78 853 78 6.3 2.1 33

Alts 2, 3, & 4 54 83 57 223 32 4.2 2.6 24

Goshawk PFA Fuels Red.

Alt 1 181 159 74 767 62 7.9 2.6 26

Alts 2, 3, & 4 181 83 57 202 29 4.4 2.2 17

Mixed Conifer Fuels Red.

Alts 1 1124 169 75 1016 64 5.0 2.3 18

Alt 2 1124 62 50 340 24 3.4 1.9 14

Alt 3 1158 62 50 342 24 3.5 2.0 15

Alt 4 542 64 50 344 24 4.3 2.7 15

Mixed Conifer Fuels Red. Hand Thin

Alts 1 132 171 76 1116 66% 4.8 2.4 16

Alt 2 132 92 60 131 27 6.3 2.9 17

Alt 3 85 92 60 131 27 6.3 2.9 17

MSO Nest Fuels Red. Hand Thin

Alts 1 122 184 78 1477 71 4.1 2 16

Alts 2, 3 & 4 122 111 65 199 35 4.5 2.4 15

MSO Nest Fuels Reduction Burn Only

Alts 1 & 4 163 159 74 438 54 6.1 2.4 27

Alts 2 & 3 163 118 66 201 36 9.7 4 22

MSO Nest Roost Recovery Hand Thin

Alts 1 & 4 72 173 76 2386 75 5.6 1.5 8 29% 12%

Alts 2 & 3 72 78 56 172 23 6 1.5 11 56% 30%

MSO PAC Fuels Reduction

Alt 1 788 166 75 1022 63 5.4 2.4 19

Alt 2 788 87 58 398 33 3.7 2.0 17
Chapter 3: Affected Environment and Environmental Consequences

232 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Acres BA

(ft2)

CC

(%) TPA

% 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Alt 3 816 86 58 379 33 3.9 2.2 17

Alt 4 337 88 59 324 31 4.2 2.7 17

MSO PAC Fuels Reduction Hand Thin

Alt 1 108 140 71 976 57 5.9 2.8 15

Alts 2 & 3 108 85 58 75 25 6.6 3.2 14

Alt 4 121 85 58 75 25 6.6 3.2 14

Table 78: Dry Lake Hills - Average stand values of no action and proposed alternatives 

projected 40 years for Dry Mixed Conifer 

Acres BA

(FT2)

CC

(%) TPA

% 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

Goshawk Nest Fuels Red.

Alt 1 54 211 81 765 80 7.5 2 37

Alts 2, 3, & 4 54 106 63 211 37 2.9 1.7 24

Goshawk PFA Fuels Red.

Alt 1 181 185 78 669 66 8.4 2.8 27

Alts 2, 3, & 4 181 101 62 191 33 3.6 2 19

Mixed Conifer Fuels Red.

Alts 1 1124 193 79 885 68 5.1 1.8 23

Alt 2 1124 77 56 320 27 2.0 1.5 17

Alt 3 1158 77 55 322 27 2.0 1.5 17

Alt 4 542 79 56 323 27 2.4 1.9 17

Mixed Conifer Fuels Red. Hand Thin

Alts 1 132 199 80 965 70% 3.8 1.6 23

Alt 2 132 106 64 123 29% 3.7 2 22

Alt 3 85 106 64 123 29% 3.7 2 22

MSO Nest Fuels Red. Hand Thin

Alts 1 122 225 83 939 77 6 1.5 19

Alts 2, 3 & 4 122 142 71 183 41 3.3 1.3 20

MSO Nest Fuels Reduction Burn Only

Alts 1 & 4 163 178 77 395 57 6 2.7 32

Alts 2 & 3 163 131 69 145 38 6.1 3.3 28

MSO Nest Roost Recovery Hand Thin

Alts 1 & 4 72 200 80 1904 79 5.1 1.2 19 20% 22%

Alts 2 & 3 72 93 60 165 26 1.6 .8 17 30% 62%

MSO PAC Fuels Reduction

Alt 1 788 194 79 885 68 5.1 1.9 24

Alt 2 788 109 64 372 38 2.3 1.6 19

Alt 3 816 108 64 355 38 2.5 1.7 20

Alt 4 337 111 65 302 37 2.9 2.1 20

MSO PAC Fuels Reduction Hand Thin

Alt 1 108 165 75 890 62 6.4 2.5 17
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 233

Acres BA

(FT2)

CC

(%) TPA

% 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

Alts 2 & 3 108 91 60 66 25 6.1 2.6 17

Alt 4 121 91 60 66 25 6.1 2.6 17

Mixed Conifer – Mormon Mountain

Dry Mixed Conifer

Under Alternatives 2 and 3, low intensity prescribed burning would be conducted within 

approximately 317 acres of MSO nest cores with the purpose of reducing dead and down fuel 

loading, creating some mortality of smaller trees in the denser patches, and raising canopy base 

heights within MSO nest cores on Mormon Mountain. Prescribed burning would create a short 

term spike of smaller sized snags. Small openings may be created where the prescribed burning 

created pockets of mortality. The small openings would allow for early seral species such as 

aspen, pine and oak to regenerate and would have the effect of helping to maintaining uneven-age 

stand characteristics. Any small openings created would also have the effect of increasing 

understory production and diversity. Prescribed burning would have the effect of reducing BA 

from 140 to 116 ft2. TPA would be reduced from 868 to 364, and percent max SDI would be 

reduced from 54 to 39 percent. 

In 20 years BA is projected to be 138 ft2 and canopy cover would be 70 percent, which is similar 

to existing conditions.

Forty years after treatment, BA would be 164 ft2, canopy cover would be 75 percent and percent 

max SDI would be 49 percent. While BA and canopy cover would exceed today’s current 

condition, the percent max SDI would still be less. Thus 40 years after treatment, the stand would 

include more large trees as a percentage of all trees, thereby being more in line with desired 

conditions compared to the No Action Alternative. 

MSO PAC Fuels Reduction treatments would apply to approximately 509 acres of mixed conifer 

stands located within the six MSO PACs within the Mormon Mountain area. Up to 509 acres 

would be mechanically treated. Treatments would maintain a minimum of 40 percent canopy 

cover; openings would be created from 0.1 to 2.5 acres in size in up to 10 percent of the treatment 

acres. The openings would allow for early seral species such as aspen, pine and oak to regenerate 

and would have the effect of helping to maintaining uneven-age stand characteristics. Treatments 

would be designed to maintain or create horizontal and vertical patch heterogeneity. Tree species 

diversity would be maintained with an emphasis on protecting large oaks and aspen by thinning 

out conifers which overtop the oaks and aspen. Trees over 18 inches dbh would not be cut, 

except for on 52 acres of proposed cable yarding in Alternative 2 where it would be necessary to 

cut approximately 2 trees per acre larger than 18 inches dbh for the purpose of creating the cable 

yarding corridors. No snags would be cut under this treatment except for safety purposes in the 

52 acres of cable yarding in Alternative 2.

Table 79 displays the post treatment stand values for the proposed treatments. The proposed 

treatments would reduce the BA from 153 to 86 ft2 for Alternative 2, 87 ft2 for Alternative 3, and 

88 ft2 for Alternative 4. Canopy cover is reduced from 73 to 59, and trees per acre are reduced 

from 888 to 274 for alternative 2 and 275 for alternative 3. Percent Max SDI is reduced from 56
Chapter 3: Affected Environment and Environmental Consequences

234 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

percent (extreme density) to 29 percent (moderate density). One of the differences between the 

alternatives is harvest methods. In Alternative 2 there would be 52 acres (out of 509) treated by 

cable yarding which would require the cutting of all snags and removal of approximately 2 trees 

per acre over 18 inches dbh within the cable corridors. After treatment there would be slightly 

fewer large snags per acre in Alternative 2 compared to Alternative 3; 7.8 versus 8.8 Openings

would be created in up to 10 percent of the treatment area. The overall reduction in density along 

with creating 10 percent openings across each stand would have the effect of opening up the 

forest floor to sunlight and increasing understory diversity. The open stand conditions would 

allow for prescribed fire to be reintroduced in a safe and controlled manner. Selective cutting of 

trees infected with dwarf mistletoe would help to reduce overall infection levels in the stand and 

improve overall stand health. Table 80 displays the stand values for the proposed treatments 

projected out 20 years. In 20 years, BA, Canopy Cover, SDI, would have increased slightly. The 

number of large snags and trees greater than 18 inches dbh would be slightly greater than the No 

Action Alternative. 

Table 81 displays the stand values for the proposed treatments projected out 40 years. In 40 years, 

BA, Canopy Cover, and SDI would all continue to be greatly lower than the no action alternative. 

The number of snags and large trees would still be slightly lower compared to the no action. 

Table 79: Mormon Mountain - Stand values of current conditions and post treatment 

conditions for Dry Mixed Conifer.

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

MSO Nest Fuels Reduction - Burn Only

Alt 1 317 140 71 868 54 24.5 9.4 20

Alts 2 & 3* 317 116 66 364 39 21.8 8.3 18

MSO PAC treatments

Alt 1 509 153 73 888 56 22.8 9.2 22

Alt 2 509 86 58 274 29 18.6 7.8 22

Alt 3 509 87 59 275 29 20.8 8.8 22

Alt 4 448 88 59 290 30 20.7 8.7 23

*Burn only treatment modeled in 2016

Table 80: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 20 years for Dry Mixed Conifer. 

Acres BA (ft2) CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

MSO Nest Fuels Reduction - Burn Only

Alt 1 317 174 76 805 61 3.9 2.4 24

Alts 2 & 3 317 138 70 351 44 4.4 2.6 22

MSO PAC treatments

Alt 1 509 188 78 826 64 4.8 2.9 26

Alt 2 509 90 60 263 29 3.4 3.0 21

Alt 3 509 90 60 263 30 3.7 3.2 21

Alt 4 448 91 60 268 30 3.6 3.2 22

Table 81: Mormon Mountain - Average stand values of No Action and proposed 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 235

alternatives projected 40 years for Dry Mixed Conifer. 

Acres BA (ft2) CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

MSO Nest Fuels Reduction - Burn Only

Alt 1 317 206 80 708 63 4 1.9 28

Alts 2 & 3 317 164 75 326 49 3.8 2 27

MSO PAC treatments

Alt 1 509 219 82 747 69 5.1 2.3 29

Alt 2 509 109 65 252 34 2.3 2.0 21

Alt 3 509 110 65 252 35 2.4 2.2 22

Alt 4 448 110 65 257 35 2.3 2.1 22

Wet Mixed Conifer

Under Alternatives 2 and 3, treatments are proposed within the identified wet mix conifer cover 

type within the MSO nest cores on MM. No wet mixed conifer exists within the DLH. The wet 

mixed conifer cover type is a mixed-severity fire regime. This area may or may not be out of the 

historic range of variability. These treatments are being conducted so that if and when this forest 

does burn, it burns as a mixed severity fire and not a severe one (e.g. complete crown fire) with 

undesirable effects.

Low intensity prescribed burning would be conducted with the main purpose of reducing dead 

and down fuel loading. The purpose of the treatment would not be to put fire on every acre of 

ground, but rather to reduce the amount of large woody debris that have resulted from a large 

amount of recent mortality from drought (see Existing Conditions in Chapter 2). In areas outside 

of MSO nest cores where small groups of mature aspen occur from 0.25 to 2 acres in size, aspen 

snags and conifers would be felled by hand and jackstrawed in attempts to regenerate aspen in up 

to 10 percent of the stand. Aspen is an early seral species for wet mixed conifer and serves the 

purpose of breaking up the overstory fuel continuity. Dead and down material would be piled for 

burning to reduce the heavy fuel loading and allow for lower-intensity prescribed burning. Trees 

over 18 inches dbh would not be cut. 

In Alternative 2, approximately 35 acres of wet mixed conifer would have cable corridors running 

through them for the purpose of accessing the dry mixed conifer stand on the slopes below. The 

areas between the cable corridors within the wet mixed conifer would not be thinned; however all 

trees and snags would be cut out of the corridors themselves. Within these 35 acres approximately 

4 acres would be within the corridors.

Table 82 displays the post treatment stand values for the proposed treatments. The proposed 

treatments within wet mixed conifer would reduce the BA from 155 to 129 ft2 for Alternative 2 

and 131 ft2 for Alternative 3. Canopy cover would be reduced from 73 to 69 percent, and TPA 

would be reduced from 1164 to 704 for Alternative 2 and 715 for Alternative 3. Percent max SDI 

would also be reduced from 47 percent (high density) to 39 percent and 40 percent (high density)

for Alternatives 2 and 3, respectively. 

One other difference between the alternatives would be the difference in residual snags due to the 

cable corridors on 33 acres in Alternative 2, which would result in approximately 11.0 snags per 

acre versus 11.2 snags per acre in Alternative 3. Regeneration openings would be created in up to 

10 percent of the treatment area. The overall reduction in density along with the increase in
Chapter 3: Affected Environment and Environmental Consequences

236 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

openings across each stand would have the effect of opening up the forest floor to sunlight and 

increasing understory diversity. The more open stand conditions would allow for aspen to 

regenerate and provide both horizontal and vertical diversity throughout the stand.

Table 83 displays the stand values for the proposed treatments projected out 20 years. In 20 years, 

BA and canopy cover would increase, but the percent max SDI would stay the same. The 

number of large snags would have gone down but would still be a relatively high at four snags per 

acre. 

Table 84 displays the stand values for the proposed treatments projected out 40 years. In 40 years, 

BA, canopy cover, and SDI would all increase and be more in line with desired conditions, but 

would still be lower than the No Action Alternative modeled out to 40 years. After 40 years BA, 

canopy cover, and percent max SDI would exceed or equal the current stand condition. The 

effectiveness of the treatment on stand density would last between 20 and 40 years. The creation 

of openings on up to 10 percent of the stand would have the effect of helping to maintain the 

uneven age conditions of the stand and promote the re-growth of declining aspen stands.

In areas proposed for burn only within MSO nest cores, small openings may be created where 

prescribed burning would create pockets of mortality. The small openings would allow for early 

seral species such as aspen, and pine to regenerate and would have the effect of helping to 

maintaining uneven-age stand characteristics. Any small openings created would also have the 

effect of increasing understory production and diversity.

The burn only treatment would have the effect of reducing BA from 155 to 132 ft2. TPA would 

be reduced from 1164 to 475, and percent max SDI would be reduced from 47 to 37 percent. 

In 20 years BA would be 160 ft2 and canopy cover would be 74 percent, which would exceed the 

current (2013) conditions. However percent max SDI would be 42 percent, which is less than 

current (2013) conditions. Thus the treatments would modify stand conditions to make large trees 

a greater percentage of all trees in the stand and thereby improve tree resilience and move the 

area on a trajectory more in line with desired conditions. 

Forty years after treatment, BA, canopy cover and percent max SDI would be 195, 79 percent, 

and 49 percent, respectively. All three of those variables would exceed the current conditions 

which mean the effects of the treatments would only last about 20 years before stand conditions 

return to or exceed current conditions. 

Table 82: Mormon Mountain - Stand values of current conditions and post treatment 

conditions for Wet Mixed Conifer. 

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

MSO Nest – Burn Only*

Alt 1 & 4 33 155 73 1164 47 25.8 12.1 13

Alts 2, & 3 33 132 69 475 37 24.1 10.6 12

MSO PAC treatments

Alt 1 & 4 180 155 73 1164 47 25.8 12.1 13

Alt 2 180 129 69 704 39 21.0 11.0 12

Alt 3 180 131 69 715 40 21.4 11.2 12

*Burn only treatment modeled in 2016
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 237

Table 83: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 20 years for Wet Mixed Conifer. 

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

MSO Nest – Burn Only

Alt 1 & 4 33 188 78 974 54 7.3 4.1 21

Alts 2, & 3 33 160 74 446 42 5.7 4.1 20

MSO PAC treatments

Alts 1 & 4 180 188 78 974 54 7.3 4.1 21

Alt 2 180 139 71 414 39 4.9 3.9 19

Alt 3 180 141 71 409 39 5 4 19

Table 84: Mormon Mountain - Average stand values of no action and proposed alternatives 

projected 40 years for Wet Mixed Conifer. 

Acres BA

(ft2)

CC (%) TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

MSO Nest – Burn Only

Alt 1 & 4 33 218 82 769 59 6.8 3 25

Alts 2, & 3 33 195 79 403 49 4.8 2.9 23

MSO PAC treatments

Alts 1 & 4 180 218 82 769 59 6.8 3 25

Alt 2 180 173 76 381 45 4.0 2.8 22

Alt 3 180 175 76 378 45 4.1 2.9 22

Mexican Spotted Owl Habitat– Dry Lake Hills

This section analyzes the entire MSO habitat in the DLH area, including ponderosa and dry 

mixed conifer. All of the different treatments that occur within the four different MSO habitat 

stratas (MSO PACs, nest cores, recovery habitat, and nest roost recovery habitat) were combined 

to show the overall effects the treatments would have to MSO habitat. 

The average current condition has a BA of 133 ft2, canopy cover of 69 percent, 824 TPA, and % 

max SDI is 52 percent. After treatment, those numbers would be reduced to: 89 ft2 of BA, 59 

percent canopy cover, 184 TPA, and 20 percent max SDI. The treatments would be designed to 

create a mosaic of patches and openings as recommended by the revised MSO recovery plan. 

Competition between trees for space, water, and sunlight would be greatly reduced, increasing 

individual tree health and growth. Small openings would be created across at least 10 percent of 

the area. The small openings would allow for early seral species such as aspen, pine, and oak to 

regenerate and would have the effect of helping to maintaining uneven-age stand characteristics. 

Any small openings created would also have the effect of increasing understory production and 

diversity.

Alternatives 2 and 3 are very similar; however because of the different harvesting methods, 

Alternative 2 would have slightly fewer large snags than Alternative 3 or 4. Alternative 2 has 360 

acres of treatment that would be conducted utilizing cable yarding systems. Within those 360 

acres, all snags would be felled and left in place due to operation safety requirements for cable 

yarding. Cable yarding also requires the construction of corridors for the cables to yard out the 

logs to be removed. These corridors would require approximately 10 percent of all tree species 
Chapter 3: Affected Environment and Environmental Consequences

238 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

and sizes to be removed across the stand. This includes oak, maples, and trees over 18 inches 

dbh. 

Table 85 below details the number of trees over 18 inches dbh that would be removed within

MSO PACs. Also proposed in Alternative 2 is to treat 15 acres by cutting all the trees and leaving 

them in piles within the stand. The reason for this proposal is due to the high cost of building a 

temp road to access this area and the undesired resource impact the construction of the temp road 

would cause. 

In Alternative 3 those 134 acres would be harvested using specialized steep slope harvesting 

machines which do not require the cutting of snags, oaks, or trees over 18 inches dbh. While the 

steep slope harvesting machines are similar to ground based equipment they are not as 

maneuverable on steep slopes as they are on flatter ground. The limited maneuverability may 

require the removal of snags, oaks, or trees over 18 inches dbh only when necessary for the 

machine to operate safely. However the removal of these forest components is anticipated to be 

negligible and would not impact the ability of those areas to meet desired conditions. Also in 

Alternative 3, 267 acres would be treated by helicopter logging. Within those 267 acres, all snags 

would be felled and left in place due to operation safety requirements for helicopter logging. 

After 20 years BA, and canopy cover would be about the same, and % max SDI and large trees 

over 18 inches dbh would have increased slightly, while trees per acre will have decreased to 267. 

Then after 40 years, BA, canopy cover, and percent max SDI would have increased to 102 ft2 of 

BA, 62 percent canopy cover, and 26 percent max SDI, all of which would still be significantly 

lower than the No Action Alternative. There would also be an average of 20 TPA over 18 inches 

dbh which is a key threshold for meeting the old growth criteria for the Forest Plan. The benefits 

of the thinning and burning treatments would last longer than 40 years.

Table 85: The number and percent of trees per acre over 18 inches dbh cut within 

MSO PACs of the DLH.

Acres of 

Cable

TPA > 18” 

dbh cut

Total TPA 

>18” dbh

% of >18” 

trees cut

Mixed Conifer 314 1.6 15.0 10.6

Ponderosa Pine 44 3.8 37.3 10.2

Average 1.9 17.7 10.5

There would be two different treatments in the DLH’s nest cores. One nest core would receive a 

hand thinning treatment up to 5 inches dbh, with approximately 20 percent of that nest being 

deferred from thinning to retain vertical canopy diversity. The other two PAC nest cores would 

be treated with a prescribed burn only. After treatment, the average nest core conditions would 

be reduced from 112 to 92 ft2 of BA; 63 percent to 58 percent canopy cover; 845 to 256 TPA; 52 

percent to 41 percent max SDI; and 16 to 15 TPA greater than 18 inches dbh. Competition 

between trees for space, water, and sunlight would be reduced, increasing individual tree health 

and growth. Small opening may be created where the prescribed burn created pockets of 

mortality. The small openings would allow for early seral species such as aspen, pine, and oak to 

regenerate and would have the effect of helping to maintaining uneven-age stand characteristics. 

Any small openings created would also have the effect of increasing understory production and 

diversity. In the Schultz nest core that would be hand thinned, the open stand conditions would 

allow for prescribed fire to be reintroduced in a safe and controlled manner. Selective cutting of 

trees infected with dwarf mistletoe would help to reduce overall infection levels in the stand and 

improve overall stand health.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 239

After 20 years BA would be 97 ft2 and canopy cover 59 percent which would still be below 

current conditions. The percent max SDI would be 27 percent compared to the 46 percent current 

condition. Then after 40 years, the BA and Canopy Cover would be similar to current conditions, 

but TPA would be much lower at 126, and % max SDI would also be significantly lower at 29 

percent. The benefits of the treatments would last at least 40 years related to relative density and 

improving individual tree growth and resiliency to fire, insects and disease. 

The recovery habitat treatment include treatments for mixed conifer and ponderosa pine and 

treatment methods include ground based logging, cable yarding, helicopter, steep slope harvester, 

and hand thinning. The treatments would be designed to create a mosaic of patches and openings 

as recommended by the revised MSO recovery plan. Competition between trees for space, water, 

and sunlight would be greatly reduced, increasing individual tree health and growth. Small 

openings would be created across at least 10 percent of the area, with the exception of 20 percent 

openings in 181 acres of PFA treatment and 263 acres in the Pine-oak. The small openings would 

allow for early seral species such as aspen, pine, and oak to regenerate and would have the effect 

of helping to maintaining uneven-age stand characteristics. Any small openings created would 

also have the effect of increasing understory production and diversity. The open stand conditions 

would allow for prescribed fire to be reintroduced in a safe and controlled manner. Selective 

cutting of trees infected with dwarf mistletoe would help to reduce overall infection levels in the 

stand and improve overall stand health.

The effect of treatment in the recovery habitat areas reduces the BA from 140 to 65 ft2 for 

Alternative 2, and 64 ft2 of BA for Alternative 3, canopy cover is reduced from 71 to 50, and trees 

per acre are reduced from 1039 to 255 for Alternative 2 and 244 for Alternative 3, and percent

max SDI is reduced from 54 percent (high density) to 22 percent (low density). 

One of the differences between Alternatives 2 and 3 is harvest methods. In Alternative 2 there 

would be 514 acres (out of 1754) treated by cable yarding which would require the cutting of all 

snags and removal of trees over 24 inches dbh within the cable corridors. Table 86 summarizes 

the estimated number of trees over 24 inches dbh that would be removed, and Table 87 below 

details the number of trees over 18 inches dbh that would be removed. In Alternative 3 there 

would be 425 acres of helicopter logging, which would require the removal of all snags for 

operational safety. Also in Alternative 3 there would be 107 acres of steep slope harvesting. 

While the steep slope harvesting machines are similar to ground based equipment, they are not as 

maneuverable on steep slopes as they are on flatter ground. The limited maneuverability may 

require the removal of snags, oaks, or trees over 24 inches dbh only when necessary for the 

machine to operate safely. However the removal of these forest components is anticipated to be 

negligible and would not impact the ability of those areas to meet desired conditions. After 

treatment there would be 2 large snags per acre compared to 3 snags per acre in the No Action 

Alternative. The open stand conditions would allow for prescribed fire to be reintroduced in a 

safe and controlled manner. Selective cutting of trees infected with dwarf mistletoe would help 

to reduce overall infection levels in the stand and improve overall stand health by increasing the 

resiliency and resistance of trees to fire, insects and disease.

In 20 years, BA and canopy cover would all still be about the same. Trees per acres and percent

max SDI would be increased slightly, also the number of trees over 18 inches dbh would have 

increased from 12 to 14. The number of trees would have increased due to regeneration in the 

openings. The number of large snags is about the same and is only slightly less than the no action 

The number of trees greater than 18 inches dbh would have gone up slightly but would still be 

less than the No Action Alternative.
Chapter 3: Affected Environment and Environmental Consequences

240 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

In 40 years, BA, Canopy Cover, and SDI are all still significantly lower than the No Action

Alternative. The number of snags and large trees are about the same compared to the No Action

Alternative. Trees over 18 inches dbh would be less than the No Action Alternative: 17 TPA 

compared to 26 TPA. Overall stand density is still greatly lower than current conditions showing 

that thinning and burning treatments would have the positive effect of lower stand density for at 

least 40 years.

The effects of the Nest Roost Recovery Habitat treatment are the same as described for MSO 

Nest Roost Recovery Hand Thin.

Table 86: The number and percent of trees per acre over 24 inches dbh cut within 

MSO Recovery Habitat in the Dry Lake Hills

Recovery 

Habitat

TPA > 24” 

dbh cut

Total TPA 

>24” dbh

% of >24” 

trees cut

MC 514 0.4 4.3 9.3

Mexican Spotted Owl Habitat– Mormon Mountain

This section includes an analysis of the entire MSO habitat in the MM area, including ponderosa 

pine as well as dry and wet mixed conifer. All of the different treatments that occur within the 

four different MSO habitat stratas (MSO PACs, nest cores, recovery habitat, and nest roost 

recovery habitat) were combined to show the overall effects the treatments would have to MSO 

habitat. 

Table 73 through Table 75 displays the value of the stands within the MSO PACS and recovery 

habitat, along with post-treatment data and stand conditions for all alternatives projected out 20 

and 40 years. 

Table 73 shows the stand attributes of all the combined treatments in all of the MSO PACs for 

MM. The average current condition has a BA of 158 ft2, canopy cover of 74 percent, 1113 TPA, 

and percent max SDI is 65 percent. After treatment, those numbers would be reduced to: 76 ft2 of 

BA, 54 percent canopy cover, 465 TPA, and 29 percent max SDI. The treatments would be 

designed to create a mosaic of patches and openings as recommended by the revised MSO 

Recovery Plan. Competition between trees for space, water, and sunlight would be greatly

reduced, increasing individual tree health and growth. Small openings would be created across 

up to 10 percent of the area. The small openings would allow for early seral species such as 

aspen, pine, and oak to regenerate and would have the effect of helping to maintaining unevenage stand characteristics. Any small openings created would also have the effect of increasing 

understory production and diversity.

Alternatives 2 and 3 are very similar; however Alternative 2 would include 74 acres of treatment 

that would be conducted through cable yarding systems. Within those 74 acres, all snags would 

be felled and left in place due to operation safety requirements for cable yarding. Cable yarding 

also requires the construction of corridors for the cables to yard out the logs to be removed. An 

additional 33 acres of wet mixed conifer stands would have cable corridors constructed through 

them to reach treatment areas below. These corridors would require approximately 10 percent of 

all tree species and sizes to be removed across the stand. This includes oak, maples, and trees 

over 18 inches dbh. Table 87 below details the number of trees over 18 inches dbh that would be 

removed. Even though the cable corridors have the effect of cutting 10 percent of all the trees it 

does not have the effect of creating 10 percent regeneration openings. Cable corridors are 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 241

approximately 12 ft. in width and occur approximately every 100 feet. The length of the 

corridors depends on the length of the steep slope or the limitation of the equipment. A long 

linear cable corridor does not constitute an opening. Where the cable corridor runs through an 

area identified as an opening, that area of the corridor would be counted as part of the opening. 

Where the corridor runs through the middle of a group, it would not be considered an opening. It 

is common to have spacing greater than 12 feet in-between trees within a group. The residual 

basal area, canopy cover, and density would still be approximately the same compared to 

treatments not using cable harvesting methods.

In Alternative 3 those 72 acres would be harvested using specialized steep slope harvesting 

machines which do not require the cutting of snags, oaks, or trees over 18 inches dbh. While the 

steep slope harvesting machines are similar to ground based equipment, they are not as 

maneuverable on steep slopes as they are on flatter ground. The limited maneuverability may 

require the removal of snags, oaks, or trees over 18 inches dbh only when necessary for the 

machine to operate safely. However the removal of these forest components is anticipated to be 

negligible and would not impact the ability of those areas to meet desired conditions. 

Because of the different harvesting methods, Alternative 2 would have slightly fewer large snags 

than Alternative 3: 3.9 versus 4.2. After 20 years BA, canopy cover, and percent max SDI would 

increase slightly, while trees per acre would decrease to 244. Then after 40 years, BA, canopy 

cover, and percent max SDI would increase to 102 ft2, 62 percent canopy cover, and 34 percent 

max SDI, all of which would still be lower than under the No Action Alternative. There would 

also be an average of 20 TPA over 18 inches dbh, which is a key threshold for meeting the old 

growth criteria for the Forest Plan. The benefits of the thinning and burning treatments would last 

beyond 40 years.

Table 87: The number and percent of trees per acre over 18 inches dbh cut within 

MSO PACs on MM

Acres of 

Cable

TPA > 18” 

dbh cut

Total TPA 

>18” dbh

% of >18” 

trees cut

Mixed Conifer 52 1.7 15.7 10.8

Wet Mixed Conifer 33 2 13.3 15

Ponderosa Pine 22 .3 7.4 4.1

Average 1.5 13.3 11.3

The only treatment that would occur in the MSO nest cores on Mormon Mountain would be a 

prescribed burn. After treatment, stand conditions would be reduced from 142 to 118 ft2 of BA, 

from 71 to 66 percent for canopy cover, from 858 to 368 TPA, from 54 to 40 percent max SDI. 

TPA greater than 18 inches dbh would decrease slightly from 18 to 17. Competition between 

trees for space, water, and sunlight would be reduced, thus increasing individual tree health and 

growth. Small openings may be created where the prescribed burning creates pockets of 

mortality. The small openings would allow for early seral species such as aspen, pine, and oak to 

regenerate and would have the effect of helping to maintaining uneven-age stand characteristics. 

Any small openings created would also have the effect of increasing understory production and 

diversity.

After 20 years BA would be 140 ft2 and canopy cover would be 70 percent, which is similar to 

current conditions. The percent max SDI would be 45 percent compared to the 54 percent in the 

current condition. 
Chapter 3: Affected Environment and Environmental Consequences

242 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

After 40 years, the overall density would be quite high, but still lower that the No Action 

Alternative after 40 years. The BA and canopy cover would be higher than current conditions 

whereas the TPA and percent max SDI would be lower. There would still be some benefits to the 

treatment after 40 years related to relative density and improving individual tree growth; however 

overall stand density and fire hazard would be greater than current conditions.

The effects of Recovery Habitat and Nest Roost Recovery Habitat treatments are the same as 

described for Ponderosa Pine Fuels Reduction. 

Grasslands

Common to All Action Alternatives

The action alternatives would reduce the number of trees within areas that were historically 

grassland vegetation types. Under each alternative, mountain grasslands would be restored to 

presettlement densities. Removal of the forest trees would stop or reduce encroachment upon the 

grasslands. Broadcast burning would release nutrients bound up by dead fuel and help with the 

grassland recovery process (Grady and Hart 2006). Removal of pine encroachment would 

increase sunlight to meadow floor and increase forb and grass production and understory 

diversity (Grady and Hart 2006). Indirect effects of reduced densities in these areas include 

restoration of their functionality in terms of wildlife habitat, watershed production, fire hazard, 

and scenic values. Presettlement densities are an important reference condition for restoration 

because they are the densities that evolved in these areas over centuries with fire, drought, frost, 

wildlife, insects, and disease.

Aspen 

Common to All Action Alternatives

The treatment would have the effect of removing all post-settlement conifer species from within

22 acres of the aspen stand in DLH under Alternatives 2 and 3, and 2 acres of the aspen stand in 

Alternative 4. The MM portion of the project does not contain any pure aspen stands. The 

treatment and effects to aspen within mixed conifer stands are addressed in the mixed conifer 

effects analysis portions of this document. Immediately after treatment, total TPA would also 

decrease; however the number of aspen per acre would remain the same (see Table 88). This 

represents the removal of conifer encroachment from aspen clones. Compared to the No Action 

Alternative, when treated there would be the same basal area after 20 and 40 years; however the 

number of TPA would be significantly less and would be comprised solely of aspens. 

Aspen clones would experience increased health, growth, and vigor due to the removal of conifer 

encroachment. With increased health and vigor, aspen would be more resilient and less 

susceptible to disease, with increased longevity. Alternatives 2, 3 and 4 (to a more limited extent)

would result in increased biodiversity and improved wildlife habitat across the landscape. The 

aspen clone may continue to expand over time but this expansion may be limited due to browse 

pressure from deer; elk browsing in this area is apparently limited by slope. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 243

Table 88: Basal area and trees per acre for the Aspen Treatment areas under 

Alternatives 2, 3 and 4. These numbers do not include anticipated aspen 

regeneration (DLH)

TIME FRAME

BASAL 

AREA ALL 

SPECIES

BASAL 

AREA 

ASPEN

TREES PER 

ACRE ALL 

SPECIES

TREES PER 

ACRE 

ASPEN

EXISTING 

CONDITIONS 51 50 1687 739

POSTTREATMENT 50 50 738 739

No Action 

+20 YEARS 107 98 1493 652

Post Treatment

+20 YEARS 106 106 712 712

No Action 

+40 YEARS 170 145 1190 519

Post Treatment

+40 YEARS 170 170 626 626

Old Growth

Common to All Action Alternatives

These alternatives would designate 2,366 acres to be managed toward old growth conditions in 

the DLH and 2,196 acres in MM. See Table 89 for a breakdown of existing and designated acres 

by cover type. All of the acres in both project areas of existing or designated old growth would 

receive treatments under Alternatives 2 and 3. In Alternative 4, approximately 1,367 acres in 

DLH would be treated and 1,565 acres in MM would be treated. Treatments for each alternative 

would be designed to retain old trees and promote the growth of existing trees to become large 

old trees. The northern goshawk and revised MSO recovery plan both have guidelines to manage 

for uneven-age stand conditions. Most goshawk and MSO treatments across the project would 

retain groups of old trees even in stands not designated to be managed for old growth. As these 

stands continue to be managed for uneven-age conditions into the future, groups of old growth 

trees would be created across most stands and would be able to persist in a sustainable manner. 

For stands that currently meet existing old growth requirements, treatments would be designed to 

retain all old growth characteristics, improve the health of old trees, and reduce the fire hazard for 

those stands. No yellow pines of any size would be cut under the action alternatives except for as 

needed for the creation of cable corridors for cable yarding operations in Alternative 2, and for 

extenuating circumstances as outlined in the design features. Treatments would decrease the 

mortality rate of existing yellow pines and old mixed conifer trees in treated areas. After thinning, 

old ponderosa pines experience increased diameter growth, water uptake and resistance to bark 

beetles. Thinning in and around old ponderosa pines also reduces the likely hood of mortality 

following prescribed burning or a wildfire (Kolb 2007).
Chapter 3: Affected Environment and Environmental Consequences

244 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 89: Acres and percent of currently allocated acres being managed for old 

growth by cover type and site potential, and the proposed acres for future old 

growth management located within FWPP. 

Project Area

Cover Type

Acres of 

Cover 

Type

Acres of 

Currently 

Allocated 

Proposed 

Acres for 

Old Growth 

Management

Total % of 

Existing 

and 

Designated

Dry Lake 

Hills

Interior Ponderosa 

Pine – High 4336 1183 972 22%

Mixed Species 

Group – High 

(Mixed Conifer)

3118 1450 1372 44%

Aspen 22 0 22 100%

Mormon 

Mountain

Interior Ponderosa 

Pine – High 1924 53 1157 60%

Mixed Species 

Group – High 

(Mixed Conifer)

1051 561 1039 99%
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 245

Figure 56: Existing old growth and designated developing old growth located within the 

Dry Lake Hills area
Chapter 3: Affected Environment and Environmental Consequences

246 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 57: Existing old growth and designated developing old growth located within the 

Mormon Mountain area

Forest Health

Common to all Action Alternatives

Dwarf mistletoe is recognized as an endemic species and plays a natural role is the ecology of the 

forest. The following management recommendations set forth in the publication Dwarf 

Mistletoes and their Management in the Southwest (Conklin 2010) would be followed when 

treating stands infected with dwarf mistletoe. In lightly infected stands, where less than 25

percent of the area is infected, mistletoe would generally not be taken into consideration. Those 

lightly infected stands would be thinned similar to uninfected stands. In moderate to severe

infected stands or groups careful consideration would be made on how to treat stands and would 

follow the recommendations of the afore mentioned publication. It is expected that dwarf 

mistletoe infection levels would be reduced slightly from current infection levels and would be 

relatively stable after thinning and burning treatments are completed.

The table below (Table 90) displays the current and post-treatment dwarf mistletoe infection 

levels for stands that have stand exams. The general trend shows that infections levels drop after 

vegetation treatments and then gradually start going back up again overtime. For the most part, 

the infection levels are similar or slightly increased 40 years after treatment. This analysis is 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 247

based on summing up the percentage of stands with stand exam data across the entire cover type. 

The numbers below represent percentage of stands, not percentage of area. It would appear that in 

the DLH, 29 percent of the ponderosa pine is severely infected; however a disproportionate 

number of stands with high levels of mistletoe infection were inventoried for stand exams while 

some stands that have very little to no mistletoe were not inventoried. The actual number of acres 

in pine with severe infection is much less. The point of the table below is to show how the 

proposed management affects infection levels over time.

The data generally shows that treatment in most areas of the project would result in a decrease in 

infection levels, sometimes for several decades. The greatest effect of the treatments, however, 

would be to allow for low and moderate intensity fire to occur in the project area. Studies have 

shownt hat prescribed burning can be a viable tool to manage mistletoe effectively (Conklin and 

Geils 2008). The models below all factor in prescribed burning in 2015. 

Table 90: Current conditions and post treatment Dwarf Mistletoe Infection Level of 

ponderosa pine and mixed conifer as a percentage of stands with stand exams within 

FWPP

Current 

Conditions

2013 2033 2053

Cover 

Type

Infection 

Level

DLH MM DLH MM DLH MM DLH MM

Pine None/Low 37 69 57 88 27 63 21 58

Pine Moderate/

High 34 31 26 12 52 27 46 42

Pine Severe 29 0 16 0 22 0 32 0

Mixed 

Conifer

None/Low 80 91 87 91 80 82 44 82

Mixed 

Conifer

Moderate/

High 20 9 14 0 19 18 51 9

Mixed 

Conifer

Severe 0 0 0 9 2 0 5 9

Current stand densities within the project area provide excellent habitat for increases in bark 

beetle and other insect populations. Insects are attracted to trees under stress from competition 

and a lack of resources, such as water, nutrients, and sunlight. The action alternatives would have 

an indirect effect on susceptibility to insect attack and mortality. Decreasing stand densities 

would reduce competition between trees, resulting in increased tree vigor and resilience. 

Individual trees would be better able to defend themselves against bark beetle attack (McMillin 

2008, Negron 2009). After implementation of the treatments, the risk of insect attack and 

mortality for residual trees would be greatly reduced across the project area (Wallin et al. 2008). 

Table 91 below shows the current and post treatment bark beetle hazard ratings for both DLH and 

MM. The treatments have a beneficial effect on the hazard ratings. Current conditions show the 
Chapter 3: Affected Environment and Environmental Consequences

248 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

majority of stands have a high bark beetle hazard rating. After treatment, the majority of stands 

have a low hazard rating. Even after 40 years, bark beetle hazard ratings would remain 

significantly reduced. 

Table 91: Current and Post Treatment Ponderosa Pine and Mixed Conifer Beetle Hazard 

Ratings (Percent of stands in each Project Area)

2013 –

Current 

Conditions

2013 - Post 

treatment

2033 – Post 

Treatment

2053 – Post 

Treatment

Cover 

Type

Hazard 

Rating

DLH MM DLH MM DLH MM DLH MM

Pine Low 11% 3% 92% 13% 81% 75% 76% 41%

Pine Moderate 13% 0% 5% 38% 14% 22% 22% 40%

Pine High 76% 97% 3% 50% 5% 3% 3% 22%

Mixed 

Conifer Low 0% 27% 69% 55% 51% 36% 32% 36%

Mixed 

Conifer

Moderate 5% 0% 17% 0% 32% 27% 41% 9%

Mixed 

Conifer

High 95% 73% 14% 45% 17% 36% 27% 55%

Cumulative Effects for Alternatives 2, 3 and 4

The spatial boundary for this cumulative effects analysis includes the surrounding watersheds and 

landscape in the Flagstaff Ranger District; the forest conditions in these areas affect the forest 

conditions in the project area and are considered in conjunction with the FWPP project area for 

Forest Plan guidelines related to goshawk and old growth. Reasonably foreseeable activities to 

occur in the next 10 years are considered for cumulative effects in this analysis even though direct 

and indirect effects are modeled out to 40 years as after 10 years, the cumulative actions and their 

effects are too speculative to accurately analyze.

Table 92 and Table 93 list the various vegetation management, fuels treatments and other 

activities that have recently occurred, ongoing, or are likely to happen soon. The DLH area lies in 

between and overlaps two other fuels reduction projects the Eastside fuels reduction project to the 

south, and the Jack Smith / Schultz fuels reduction project to the north. The Fort Valley Fuels 

Reduction project lies to the west. The DLH area is largest area adjacent to the community of 

Flagstaff that has not received fuels reduction treatment. This proposed action would complete a 

wide swath of fuels reduction treatment that was started around Flagstaff approximately 20 years 

ago. 

The MM treatment area lies on the north slopes of Mormon Mountain and drains into Lake Mary. 

While there are no on-going projects immediately adjacent to the project boundary, there are two 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 249

nearby active projects. The Mormon Lake basin project to the south is a fuels reduction and 

forest health project to help protect Mormon Lake Village. To the north is the Elk Park Fuels 

Reduction and Forest Restoration project which is also located in the Lake Mary watershed. The 

4FRI analysis area includes lands adjacent to the MM area, and is included in the table below.

Table 92: FWPP Cumulative Effects Project List of past, present, and reasonably 

foreseeable actions in the Dry Lake Hills project area and surrounding areas

PAST PRESENT 

(ONGOING)

REASONABLYFORESEEABLE

Forest 

Thinning & 

Burning 

Projects

Fort Valley Experimental Forest 

(thinning & burning)

Wing Mountain Fuels Reduction and Forest Health 

Restoration Project. 4FRI task orders will be issued to 

treat the Wing Mountain Project beginning in 2015.

Eastside Fuels Reduction Project: approx. 16 acres of thinning around Elden 

communication towers done around 2008; 85 acres hand thinning along Elden 

Lookout Rd (past and ongoing); part of the Weatherford task order outside 

FWPP project area (along with Jack Smith Schultz). Hand thinning occurring 

within the FWPP project boundary currently and on-going.

Jack Smith Schultz Fuels Reduction Project (and ongoing)

Orion task order (867 acres)for 4FRI to be issued in 2014.

Weatherford 4FRI task order (1017 acres) issued in 2013

Hand thinning occurring within the FWPP project boundary currently and ongoing.

Elden Small Project 

(thinning and 

burning on 200 

acres) 2002

4FRI – Would treat areas in 

the Fort Valley area and 

adjacent urban interface 

areas. The preferred 

alternative includes a total of 

434,001 acres of mechanical 

thinning and 593,211 acres of 

prescribed burning to be 

implemented over the next 20 

years.

Treatments on the Navajo 

Nation parcel (approx. 140 

acres) as well as adjacent 

State and private land

Wildfires Schultz Fire (2010)

15,075 acres. 

BAER work 

included mulching, 

seeding and 

salvage, and hazard 

tree mitigation.

Radio Fire (1977)
Chapter 3: Affected Environment and Environmental Consequences

250 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

PAST PRESENT 

(ONGOING)

REASONABLYFORESEEABLE

4,594 acres

Restoration 

Work

4FRI Spring Enhancements

Reforestation of 

1000 acres of the 

Schultz fire. 

Includes planting 

and jackstrawing.

Reforestation of 

severely burned areas.

Schultz Sediment Reduction – channel 

restoration work performed between FR 420 

and the forest boundary on the National 

Forest by Coconino County to reduce erosion 

into the neighborhoods.

Recreation Arizona Trail 

construction

Special Use Events

Fort Valley Motorized 

Trails

Multi-use throughout 

DLH (hiking, 

mountain biking, 

camping) and trail 

maintenance

Expanded Mt. Elden and Dry 

Lake Hills Trail System

Hunter Access to 

Aspen Depredation

Grazing Peaks Allotment 

(pastures not grazed 

in over 10 years; 

deferred from 

grazing now)

Lands 

Projects

Elden/Devils Head comm 

sites – potential tower 

additions

Travel Management Rule

Table 93: FWPP Cumulative Effects Project List for past, present, and reasonably 

foreseeable actions in the Mormon Mountain project area and surrounding area

PAST PRESENT 

(ONGOING)

REASONABLYFORESEEABLE

Forest 

Thinning & 

Burning 

Projects

Mormon Lake Basin 

Fuels Reduction 

Project. MLB #1 

Stewardship 

Contract (1597 

acres )Completed in 

MLB #2 Stewardship 

Contract thinning in 

progress (568 acres).
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 251

PAST PRESENT 

(ONGOING)

REASONABLYFORESEEABLE

2013

4FRI – Would treat much of 

the area around Mormon 

Mountain and the Lake Mary 

Watershed with mechanical 

vegetation treatment and 

prescribed burning.

Elk Park Project: Elk Park and Clark 4FRI task orders 

issued in 2013 will treat approximately 4,600 acres in 

the Lake Mary Watershed

Thinning around 

communication 

towers (11 acres) 

2007-2008

Wildfires Small, low acreage 

(see Existing 

Conditions –

Fire/Fuels)

Restoration 

Work

4FRI Spring Enhancements

Recreation Dispersed 

recreation

Hunting

Fuelwood 

gathering

Grazing Tinny Springs Allotment: Five hundred 

cow/calf pairs are permitted to graze on 

the Tinny Springs allotment from June 

1 through October 31 using a deferred 

rotation grazing system. 

Pickett Lake/Padre Canyon Allotment: 

Nine hundred 13 adult cattle are 

permitted to graze on the allotment 

from June 1 through September 30 

using a deferred, rest rotation grazing 

system.

Lands 

Projects

Mormon Mt APS 

Line – final rehab 

needed but mostly 

complete

APS Youngs to Mormon Lake new 

69kv line

Mormon Mt Comm Site

FH3 Tree 

Clearing

Travel Management Rule
Chapter 3: Affected Environment and Environmental Consequences

252 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Cumulative Effects – Past Actions

Over the past century, several events, including fire exclusion, livestock grazing, and high-grade 

timber harvesting, occurred in ponderosa pine over the majority of the project area and in 

adjacent stands. These events resulted in disruption of the historic fire regime that consisted of 

frequent, low-intensity surface fires. In 1919, climatic events favored dense ponderosa pine 

regeneration. At this time, understory production was greatly decreased by grazing and offered 

little competition with pine regeneration. As fire suppression and sawlog harvesting continued 

through the 20th century, regeneration from 1919 continued to grow in density. In the mid- to late 

1900s, treatments in and adjacent to the project area removed a large proportion of the mature and 

old trees, contributing to a more even-aged forest structure. At the same time pre-commercial 

thinning treatments occurred that reduced the density of younger forest, mainly through even 

spacing of residual trees. 

Although these treatments did provide some short-term improvement to forest health, vigor, and 

growth by reducing stand densities and increasing the growing space of individual trees, they also 

caused further departure from the variable, patchy tree distribution that typified the historic 

ponderosa pine forest structure. Blending treatments were used to produce a single age class 

deemed “more manageable” in terms of regulated timber harvesting. Past events have resulted in 

increased stand densities, decreased age and size class diversity, altered stand structure, changes 

in successional dynamics, altered insect and disease dynamics, decreased understory productivity 

and diversity, decreased tree vigor, increased fuel accumulation and continuity, increased crown 

fire potential, increased fire size and intensity, and a more even-aged forest structure (Long 

2003). 

Figure 58 depicts changes in trees per acre by size class on non-reserved forest lands in New 

Mexico and Arizona. The graph below (Figure 58) depicts changes that are typical of southwest 

ponderosa pine. The density of trees has increased significantly over time, especially in diameter 

classes less than 13 inches. With this tremendous increase in smaller size classes, size class 

diversity has decreased, resulting in a more even-aged forest structure. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 253

Figure 58: Changes in stand density in southwestern ponderosa pine, non-reserved forest 

lands, NM and AZ (USDA Forest Service 2004).

Cumulative Effects – Alternatives 2, 3, and 4 

Alternative 2 would contribute an additional 8,937 acres toward improving forest health or fuels 

reduction and vegetation diversity/composition, sustaining old forest structure over time, and 

moving forest structure toward the desired conditions.

Alternative 3 would contribute an additional 8,937 acres toward improving forest health or fuels 

reduction and vegetation diversity/composition, sustaining old forest structure over time, and 

moving forest structure toward the desired conditions.

Alternative 4 would contribute an additional 5,802 acres toward improving forest health or fuels 

reduction and vegetation diversity/composition, sustaining old forest structure over time, and 

moving forest structure toward the desired conditions.

The recently-signed decision on the Coconino Travel Management Rule (September 2011) 

designated a road system of reduced mileage across the forest, which included closing a number 

of roads within the project area to the public. This reduced road system available to the public 

would have a cumulative effect with road decommissioning from this project to reduce the 

amount of snags and down woody removed for fuelwood harvest (Wisdom 2008) away from 

designated roads. This cumulative impact would partially counteract the effects of the proposed 

action that include a reduction in downed woody material over the next decade as the thinning 

and prescribed fire treatments would be implemented. 

With the advent of global climate change, more frequent and higher intensity wildfires are 

expected (Marlon et al. 2009). Future droughts and temperature increase would also likely result 

in greater tree mortality from more frequent and higher intensity outbreaks of bark beetles (Van 

0

10

20

30

40

50

60

70

80

90

100

1.0-

2.9

3.0-

4.9

5.0-

6.9

7.0-

8.9

9.0-

10.9

11.0-

12.9

13.0-

14.9

15.0-

16.9

17.0-

18.9

19.0-

20.9

21.0-

22.9

23.0-

24.9

25.0-

26.9

27.0-

28.9

29.0+

Trees per Acre 

Diameter Class (inches) 

1999 

1966 

1910 
Chapter 3: Affected Environment and Environmental Consequences

254 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Mantgem et al. 2009, Williams et al. 2010). This project would make the forest more resilient and 

thus counteract the effects of climate change. 

The proposed treatments in this EIS, in combination with ongoing projects adjacent to the project 

area, would result in a landscape which is more open, variable, and groupy for a minimum of 20 

years into the future. The creation of openings and a more open canopy would result in increased 

natural regeneration across the landscape and a more uneven-aged forest structure, which would 

move conditions toward the desired condition of a well distributed age class with large, resilient 

trees in an uneven-aged structure across the landscape. A mosaic of varying forest structures, 

patterns, densities, and size classes results in increased horizontal and vertical heterogeneity, 

increased biological diversity, improved forest health, and a more sustainable forest structure at 

the landscape-level. A more sustainable forest structure is more resilient and capable of 

maintaining its health in the face of climate change and other disturbances such as insects, 

disease, and severe wildfires, which are expected to intensify under projected changes to the 

climate. The proposed alternatives and ongoing treatments would result in a decreased risk of 

insect attack and mortality at both the project and landscape levels. 

Slash created from thinning activities would have the potential to increase brood habitat for Ips

beetles and the potential for higher intensity ground fires from slash burning. The result of slash 

would be short-tern, until the site is treated with prescribed fire. Increased regeneration of 

ponderosa pine is expected to occur, but dog-hair thickets may be controlled through the planned 

maintenance burning (every 5 to 7 years in ponderosa pine). 

These treatments would also result in faster development of a landscape-level VSS distribution 

recommended for the northern goshawk by retaining large trees, creating openings for 

regeneration, and increasing tree growth and vigor. Thus the cumulative effects of similar 

treatments within the landscape would be to move toward desired vegetation structure and age 

class diversity at the landscape scale over the next several decades. The treatments within the 

MSO PACs from projects such as Wing Mountain Fuels Reduction and Forest Health Restoration 

Project, 4FRI, Eastside Fuels Reduction Project and others would increase the resiliency of those 

stands to withstand wildfires and insect and disease attacks, which would support these areas in 

meeting desired conditions in the coming decades. The creation of small regeneration openings

and restoration of historic grasslands and aspen stands across the landscape would also result in 

increased understory abundance, increased diversity at the landscape scale, and increases in 

insects, such as butterflies, that serve as prey bases for a suite of wildlife species. Increased grass 

and forb production would help spread and carry natural periodic surface fires. Lastly, by 

focusing on the removal of smaller diameter trees, this and other projects would retain and 

produce larger diameter trees for both ecological and social/aesthetic values. 

Alternative 4: Minimal Treatment

Where applicable, effects from Alternative 4 were included in the above discussion for 

Alternatives 2 and 3 (under each section titled “Effects Common to all Action Alternatives”). In 

general, only those differences between Alternative 4 and the other action alternatives are 

included here. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 255

Direct & Indirect Effects

Ponderosa Pine – Dry Lake Hills (Northern Goshawk)

Under Alternative 4, fewer acres would be treated in the Ponderosa Pine Fuels Reduction and 

Goshawk PFA Fuels Reduction. There would be no treatment on steep slopes which would 

require cable yarding, helicopter, or specialized steep slope equipment. The treatment intensity in 

treated areas would remain the same as the other alternatives. The current conditions and posttreatment conditions are mostly similar in the LOPFA and PFA treatments between Alternative 4 

and Alternatives 2 and 3. Alternative 4 post-treatment BA in LOPFA would be slightly lower 

and have higher number of TPA than Alternatives 2 and 3. Alternative 4 would only have 10

percent in VSS 6 compared to 27 percent for Alternative 2 and 3. This is because many of the 

areas that would become VSS 6 in Alternatives 2 and 3 would not be treated under Alternative 4. 

Many of the areas that would be treated under Alternative 4 do not have the large tree component 

necessary to create VSS 6. In the PFA, Alternative 4 would have a higher number of residual 

snags and large trees immediately post-treatment compared to Alternatives 2 and 3 due to the 

subset of acres currently contain a higher average number of snags and large trees. The PFAs 

would have no VSS 4, and a greater amount of VSS 5 and 6 compared to Alternatives 2 and 3. 

Goshawk nest treatments are the same in all the action alternatives. 

Ponderosa Pine – Dry Lake Hills (MSO)

The 230 acres treated in this alternative is a smaller sub-set of the 379 acres in Alternatives 2 and 

3. This alternative does not utilize any steep slope harvesting methods. The post-treatment BA 

and canopy cover on these acres would be lower to Alternatives 2 and 3 and this subset would 

also have a higher number of TPA and fewer large trees and snags. The post-treatment numbers 

show these acres would have a lower BA, canopy cover, and percent max SDI than the No Action 

Alternative. In 20 years after treatment, the models still show these acres would have a lower 

BA, canopy cover, and percent of max SDI compared to Alternatives 2 and 3. However, 40 years 

after treatment BA, canopy cover, percent max SDI and number of large trees would be very 

similar to Alternatives 2 and 3. This is due to the more open conditions allowing for medium size 

trees to grow into larger trees at a faster rate than the denser Alternative 2 and 3 conditions; in 

other words, current stand conditions in Alternative 4 treatment areas have fewer large trees to 

begin with, thus less overall density. Also the areas that would be treated under this alternative 

would have a lower overall dwarf mistletoe infection level than current conditions. 

Ponderosa Pine – Mormon Mountain

The effects of Alternative 4 on the area proposed for Ponderosa Pine Fuels Reduction treatment 

on Mormon Mountain would be similar as those discussed for Alternatives 2 and 3, as the 

proposed treatment for pure ponderosa pine stands is the same under all three action alternatives.

Mixed Conifer – Dry Lake Hills

The effects of the Mixed Conifer Fuels Reduction Treatment would be very similar to the effects 

described for Alternatives 2 and 3. As shown in Table 70, the two main differences would be that 

only 542 acres would be treated as opposed to 1140 acres or 1158 acres under Alternative 2 and 

3, respectively, and there would be no steep slope harvesting methods used to treat stands in 

Alternative 4. 

The 337 acres of MSO PAC Fuels Reduction treated in this alternative is a smaller sub-set of the 

816 acres that would be treated in the other two action alternatives. This alternative does not 
Chapter 3: Affected Environment and Environmental Consequences

256 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

utilize any steep slope harvesting methods. As shown in Table 70, the BA and canopy cover 

post-treatment on these acres would be similar to Alternatives 2 and 3, this subset would have a 

higher number of snags. In both 20 and 40 years, this subset would continue to have very similar 

conditions. The effects would be the same as described for Alternatives 2 and 3, but on fewer 

acres.

Mixed Conifer – Mormon Mountain

Effects from Alternative 4 on MSO nest cores and wet mixed conifer would be the same as those 

described for the No Action Alternative, as no treatment would occur within MSO nest cores on 

Mormon Mountain under Alternative 4. 

Effects to MSO PACs would be the same as described for Alternatives 2 and 3 except to a lesser 

degree as fewer acres would be treated (448 acres).

Mexican Spotted Owl Habitat– Dry Lake Hills

The effects to MSO PACs in Alternative 4 would be very similar to the effects described in 

Alternatives 2 and 3. However Alternative 4 would focus on treating the Schultz and Elden PACs. 

No treatment would be done in the Orion or Weatherford PACs. Treatments would only be 

conducted with conventional ground based logging equipment or done with hand thinning. There 

would be no treatments on steeps slopes in this alternative. Table 94 shows some of the minor 

differences in stand attributes are that BA and canopy cover are a little lower after treatment, and 

the average number of large snags is higher compared to Alternatives 2 and 3. After 20 and 40 

years the stand attributes are virtually identical, as are the overall treatment effects.

The effects to recovery habitat in Alternative 4 are very similar to the effects described in 

Alternatives 2 and 3. However the areas included in Alternative 4 would be treated with 

conventional ground based logging equipment. There would be no treatments on steeps slopes in 

this alternative. Some of the minor differences in stand attributes are that BA is a little lower after 

treatment, and the average number of large snags is higher compared to Alternatives 2 and 3. 

After 20 and 40 years the stand attributes are virtually identical, as are the overall treatment 

effects.

Table 94 through Table 96: Within the DLH portion of FWPP: Stand values for MSO PAC, 

recovery and nest roost recovery habitat. Values displayed are for current conditions, conditions 

after treatment, and stand values for treated and not treated areas projected out 20 years and 40 

years.

Table 94: Dry Lake Hills - Current and Post Treatment Stand Values

Acres BA

(ft2)

CC

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

Current Condition (No Action)

MSO PAC 1275 133 69 824 52% 9 4 16

MSO PAC - Nest 382 112 63 845 43% 5 3 16

Nest Roost 

Recovery 72 148 72 2986 71% 16.23 2.4 7

Recovery 1754 140 71 1039 54 7.9 3.3 14

After treatment
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 257

Acres BA

(ft2)

CC

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

MSO PAC Alt 2 1275 89 59 213 20% 6 3 17

MSO PAC Alt 3 1303 90 59 184 21% 7 4 17

MSO PAC Alt 4 688 82 57 144 18% 6 3 14

MSO PAC - Nest 

Alts 2 & 3 382 92 58 256 28% 12 5 15

MSO PAC - Nest 

Alt 4 122 111 65 540 41% 6 4 13

Nest Roost 

Recovery – Alts 2 

& 3

72 99 62 421 34% 15.4 2.3 7

Recovery – Alt 2 1754 65 51 255 22 4.9 2.1 12

Recovery – Alt 3 1741 64 50 244 22 5.3 2.2 12

Recovery – Alt 4 1040 63 50 279 24 6.2 2.6 12

Table 95: Dry Lake Hills - Projected 20 Years

Acres BA

(ft2)

CC

(%)

TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

Current Condition (No Action)

MSO PAC 1275 150 72 735 44% 7 3 19

MSO PAC - Nest 382 142 69 673 46% 5 2 20

Nest Roost 

Recovery 72 173 76 2386 75% 5.6 1.5 8

Recovery 1754 167 75 939 61 4.7 2.0 22

After treatment

MSO PAC Alt 2 1275 90 59 276 23% 5 3 19

MSO PAC Alt 3 1303 89 59 267 23% 6 3 18

MSO PAC Alt 4 688 85 58 224 20% 5 3 15

MSO PAC - Nest 

Alts 2 & 3 382 97 59 156 27% 8 3 17

MSO PAC - Nest 

Alt 4 122 111 65 199 35% 5 2 15

Nest Roost 

Recovery – Alts 2 

& 3

72 78 56 172 23% 6 1.5 11

Recovery – Alt 2 1754 66 51 298 25 3.3 1.8 14

Recovery – Alt 3 1741 65 51 305 25 3.3 1.8 15

Recovery – Alt 4 1040 65 50 298 26 3.3 2.0 14

Table 96: Dry Lake Hills - Projected 40 Years

Acres BA

(ft2)

CC

(%)

TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

Current Condition (No Action)

MSO PAC 1275 165 74 638 47 7 3 23

MSO PAC - Nest 382 163 72 479 49% 6 2 24
Chapter 3: Affected Environment and Environmental Consequences

258 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Acres BA

(ft2)

CC

(%)

TPA % Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

Nest Roost 

Recovery 72 201 80 1904 79% 5.1 1.2 19

Recovery 1754 192 79 826 65 4.8 1.7 26

After treatment

MSO PAC Alt 2 1275 102 62 256 26 4 3 20

MSO PAC Alt 3 1303 102 63 248 26 4 3 20

MSO PAC Alt 4 688 101 62 208 23 4 2 20

MSO PAC - Nest 

Alts 2 & 3 382 112 62 126 29% 5 3 21

MSO PAC - Nest 

Alt 4 122 142 71 183 41% 3 1 20

Nest Roost 

Recovery – Alts 2 

& 3

72 93 60 165 26% 1.6 .8 17

Recovery – Alt 2 1754 82 57 282 27 2.1 1.4 17

Recovery – Alt 3 1741 81 56 288 28 2.0 1.4 17

Recovery – Alt 4 1040 83 57 282 30 2.1 1.5 16

Mexican Spotted Owl Habitat– Mormon Mountain

This alternative would treat a smaller subset of Alternatives 2 and 3, the main difference being 

that no treatments would be conducted on steep slopes. The average density, number of TPA, and 

snags per acre would be less in Alternative 4 as the areas that are not being treated are not 

averaged into the numbers; those untreated areas are of high density and contain high numbers of 

TPA and snags per acre. Also the ratio of pine to mixed conifer is higher in this alternative. Since 

pine would be treated at a higher intensity, the average numbers for this sub-set of acres are lower 

than the other alternatives. The effects on MSO recovery habitat and nest roost recovery habitat 

are the same as described for Alternative 2 and 3.

Table 97 through

Table 99 show stand values for MSO PAC, recovery and nest roost recovery habitat. Values 

displayed are for current conditions, conditions after treatment, and stand values for treated and 

not treated areas projected out 20 years and 40 years. 

Table 97: Mormon Mountain - Current and Post Treatment within MSO Habitat

Acres BA

(ft2)

CC

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Current Condition (No Action)

PAC – Alt 1 1772 158 74 1113 65 12.2 4.4 15

PAC Nest Burn 

Only

Alts 1 & 4

402 142 71 858 54 22.0 8.5 18

Recovery - Alt 1 776 161 74 730 74 4.3 .5 16

Nest Roost 22 173 76 949 87 5 1.3 39 17% 61%
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 259

Acres BA

(ft2)

CC

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Recovery

After treatment

PAC – Alt 2 1772 76 54 465 29 10.3 3.9 15

PAC – Alt 3 1772 77 55 466 30 11.0 4.2 15

PAC – Alt 4 1509 70 53 450 29 9.5 3.2 16

PAC Nest Burn 

Only

Alts 2 & 3*

402 118 66 368 40 20.8 7.6 17

Recovery - Alts 

2,3,4 776 60 49 534 31 4.1 .5 9

Nest Roost 

Recovery

Alts 2, 3, 4

22 120 67 906 64 4.8 1.3 19

19% 49%

Table 98: Mormon Mountain - Projected 20 Years within MSO Habitat 

Acres BA

(ft2)

CC

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Current Condition (No Action)

PAC 1772 183 77 887 68 6.9 2.0 21

PAC Nest Burn 

Only

Alts 1 & 4

402 174 76 779 61 4.6 2.4 23

Recovery - Alt 1 776 177 77 598 76 6.9 1.1 23

Nest Roost 

Recovery 22 182 77 742 86 7.6 2.7 43 21% 68%

After treatment

PAC – Alt 2 1772 82 57 244 29 2.2 2.1 17

PAC – Alt 3 1772 82 57 243 29 2.3 2.2 17

PAC – Alt 4 1509 76 55 227 28 2.0 1.9 17

PAC Nest Burn 

Only

Alts 2 & 3

402 140 70 352 45 4.9 2.6 21

Recovery - Alts 

2,3,4 776 65 51 222 28 2.1 .8 11

Nest Roost 

Recovery

Alts 2, 3, 4

22 131 69 448 60 3.8 1.2 22

30% 57%
Chapter 3: Affected Environment and Environmental Consequences

260 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 99: Projected 40 Years within MSO Habitat - MM

Acres BA

(ft2)

CC

(%)

TPA % 

Max 

SDI

Snag 

12+

Snag 

18+

Trees 

>18”

% 

BA 

12-

18”

% 

BA 

18”+

Current Condition (No Action)

PAC – Alt 1 1772 205 80 729 70 8.0 2.2 27

PAC Nest Burn 

Only

Alts 1 & 4

402 204 80 678 63 4.7 2.0 27

Recovery - Alt 1 776 184 78 506 75 9.8 2.1 30

Nest Roost 

Recovery 22 190 78 608 86 7.5 3 40

After treatment

PAC – Alt 2 1772 101 62 230 33 2.4 1.8 20

PAC – Alt 3 1772 102 62 229 34 2.5 1.9 20

PAC – Alt 4 1509 94 60 213 32 2.3 1.7 20

PAC Nest Burn 

Only

Alts 2 & 3

402 165 75 324 49 4.4 2.0 27

Recovery - Alts 

2,3,4 776 85 58 208 34 2.3 1.1 14

Nest Roost 

Recovery

Alts 2, 3, 4

22 154 73 410 67 2.5 .7 24

Grasslands, Aspen, Old Growth and Forest Health

The effects of Alternative 4 on grasslands, aspen, old growth and forest health are discussed in 

those respective sections of Alternative 2 and 3. However, since Alternative 4 would treat 

approximately 20 fewer acres of aspen stands, the analysis discussed under Alternatives 2 and 3 

would only pertain to the two acres proposed for treatment under Alternative 4. The following is 

the analysis of the untreated acres of aspen stands.

Under the Alternative 4, forest conditions within the 20 acres of untreated aspen stands would 

remain much as they are now. Only two acres of treatment within the pure aspen stands is 

proposed under Alternative 4. Over 40 years (assuming no other dramatic aspen die-off occurs), 

basal areas of both aspen and conifer species would increase in the untreated acres, and TPA 

would decrease. The basal area increase of the conifer trees would be greater than aspen and 

would result in a greater rate of decline for aspen trees per acre. Increased canopies of conifer 

species would compete with and shade out the shade-intolerant aspen crowns. Closed crown 

canopies would result in decreased sunlight to the forest floor, decreased understory productivity 

and diversity, increased inter-tree competition, decreased tree health, growth and vigor, increased 

insect and disease-related mortality especially in older age classes, and decreased horizontal 

heterogeneity (Zegler et al. 2012, Calder et al. 2011). 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 261

Irreversible and Irretrievable Commitments of Resources

Each action alternative is designed to reduce the risk of high intensity wildfire and modify forest 

structure to perpetuate key forest elements such as large, old, trees and snags. Thus, there would 

be no irretrievable, irreversible effects to vegetation within the project area. The temporary loss of 

resources would only occur in places where roads would be constructed in forested areas to 

implement the proposed treatments. Production of timber would be temporarily lost within the 

road prism due to use of the road and the compaction that would occur. Temporary roads and log 

landings would be rehabilitated once treatments are complete. The loss of timber production 

would last during the time the temporary road are being used and for a few years after the road 

has been rehabilitated for the time that it takes for the compacted soil to naturally loosen up. 

The effect of the temporary loss of timber productivity would have a minor impact in the short 

term and a minimal impact to the functionality of the forest over the long term. The impact is 

spread out over a large area and would not measurably decrease overall timber or understory 

production except for when the harvesting is occurring. 

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

The following is a description of how the forest plan amendments under this EIS would modify 

the forest plan standards and guidelines and what the effects to the vegetation resource would be 

if the amendment did not occur.

Amendment 1

o If the amendment did not occur: 1) Mechanical treatments would be limited to a 

maximum of 9” dbh in the PACs thereby restricting the treatment to an 

ineffective fuels reduction objective and reducing the ability to improve MSO 

habitat in terms of reducing overall stand densities to desired levels, creating 

groups, openings, increasing or maintaining age class and species diversity, and 

liberation of overtopped oak.; 2) Without the use of prescribed fire in MSO core 

areas, the opportunity to improve MSO habitat in terms of reducing litter/duff 

cover and stimulating regeneration and growth of native herbaceous vegetation 

would be eliminated; 3) Treatments within MSO habitat would continue to meet 

the intent of the 1995 MSO recovery plan 4) Mechanical treatments within the 

nest roost recovery habitat would follow the denser 150 ft2 basal area guidance 

thereby reducing the ability to improve MSO nesting/roosting habitat in terms of 

sustainability, as indicated by high potential for density related mortality and high 

bark beetle hazard rating as well as reducing the ability to improve age class and 

species diversity and the liberation of overtopped oak; 5) Implementation of 

vegetation treatments within the PACs would take 2 to 3 additional years.; 6) 

Following existing Forest Plan language concerning MSO population and habitat 

monitoring or MSO habitat design would not have an effect on the treatments 

themselves or their outcomes.

The result of the Forest Plan amendment is to facilitate mechanical thinning and 

prescribed fire in Mexican spotted owl habitat at a level necessary to meet the 

desired conditions and 2012 Mexican Spotted Owl Recovery Plan guidelines for 

forest structure and composition. This Forest Plan amendment will result in 

moving conditions toward a forest structure more in-line with the revised MSO 

recovery plan. The amendment would also have the effect of allowing thinning 

treatments which would enable managers to apply prescribed fire to the forest in 
Chapter 3: Affected Environment and Environmental Consequences

262 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

a safe and effective manner. Furthermore the effect of this amendment would be 

to facilitate treatments to re-establish small openings that would result in greater 

understory biodiversity, improve the diversity of age classes, and reduced intertree competition and resilience to wildfire, drought, insects, and disease.

Amendment 2

o If the amendment did not occur: It would not be technically feasible to treat 

areas on steep slopes to meet the desired conditions; Manual treatment (hand 

thinning and piling) would only be able to treat trees up to 9” in diameter due to 

safety concerns; Not treating to the desired condition would not allow for the safe 

use of prescribed fire on steep slopes in many areas of the project; In areas where 

prescribed fire could be done in terms of firefighter safety, the fire would not 

have the desired effect, and would cause high levels of mortality across the 

burned areas which would not achieve the desired fuels reduction and post fire 

flooding reductions.

The result of the forest plan amendment is to allow for use of specialized 

mechanical equipment to cut and remove trees on steep slopes to reduce the risk 

of high-severity wildfire in this project area due to the preponderance of areas 

with greater than 40 percent slope in the project area. This amendment is needed. 

in order to be able to utilize such equipment to treat slopes above 40 percent in 

the project area in order to create the desired conditions and meet the purpose and 

need of this project.

Soil & Water Resources

Methodology

Soil Burn Severity

Soil burn severity has been identified as a key indicator of the susceptibility of a burned area to 

accelerated erosion and flooding and, consequently, soil burn severity categories are used to 

determine appropriate soil and hydrologic parameters needed for post-fire runoff and erosion 

modeling. For this project, soil burn severity maps were generated for the No Action Alternative 

as well as Alternatives 2 and 4 for the DLH and MM areas using an output from simulated fire 

behavior modeling runs conducted for the various alternatives. The simulated fire behavior 

modeling conducted for this project is described in the Fire and Fuels Section of Chapter 3 and 

the related Specialist Report. Figure 59 shows the estimated soil burn severity with existing 

conditions within the DLH under simulated wildfire when calibrated to the 2010 Schultz Fire 

burn severity assessment performed by the Schultz Burned Area Emergency Response (BAER) 

team. This calibration was based on the similar fuel type and weather conditions for the two areas 

(FWPP and the Schultz Fire burn area). A separate soil burn severity map was not generated for 

Alternative 3 since the proposed total treated area and type of treatments are similar enough to 

Alternative 2 that post-treatment fuel conditions and simulated wildfire behavior would be not be 

substantially different. The specific fire behavior model output used as a metric for soil burn 

severity was heat/unit area (HUA) expressed in units of kilojoules/m2 (kJ/m2). Using rules 

developed by the project fire ecologist, HUA values were further adjusted to account for 

conditional crown fire, which is a crown fire that moves through the crown of trees but is not 

linked to a surface fire. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 263

HUA values corresponding to high, moderate, low, and very low/unburned soil burn severity 

categories were determined by adjusting the minimum HUA value for each soil burn severity 

category to achieve the same percentage of soil burn severities for a wildfire occurring in the 

untreated condition (No Action Alternative) as was mapped for the 2010 Schultz fire. Based on 

this, minimum HUA values for soil burn severity categories of high, moderate, low, and very 

low/unburned were determined to be 60,313 kJ/m2, 8,655 kJ/m2, and 4,594 kJ/m2, respectively. 

These minimum values were then used to create soil burn severity maps for Alternatives 2 and 4 

using HUA outputs from the same simulated fire conditions as were used for the No Action 

Alternative. This process resulted in a higher percentage of the MM area being classified as “high 

soil burn severity” under the No Action Alternative than for the DLH area. Though the Schultz 

fire with its known soil burn severity distribution, proximity to the DHL area, and similar fuel 

load conditions served to calibrate HUA values to soil burn severity categories for the DLH area 

under the No Action Alternative, a similar situation did not exist for the MM area. It is not 

certain that HUA values used to categorize soil burn severity for the DLH area are applicable to 

the MM area; a higher percentage of high soil burn severity would be expected from a wildfire 

burning through the MM area given the fuel load and fuel type conditions in this area. Therefore, 

the estimated soil burn severity used for comparison purposes in this analysis may actually be 

conservative. 
Chapter 3: Affected Environment and Environmental Consequences

264 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 59: Soil Burn Severity for DLH under Existing Conditions, Calibrated to the Schultz 

Burn Severity Assessment from the Burned Area Emergency Response (BAER) 

Assessment
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 265

Hydrologic Modeling

Hydrologic modeling of Schultz Creek was conducted using WildCat5, a hydrologic model for 

predicting total runoff and peak discharge for single rain events based on the curve number (CN) 

method developed by the former U.S. Soil Conservation Service (now USDA Natural Resources 

Conservation Service). The CN method requires the classification of soils into different 

hydrologic soil groups (i.e., A, B, C, and D) based on their minimum infiltration rate as well as 

selection of representative CNs. Soils were placed into different hydrologic soil groups (HSGs) 

based on soils information contained in the TES survey for the Coconino National Forest. CNs 

are coefficients representing the effects of land use/cover, soil type, and surface cover condition 

on the runoff response and generally range from a low of 25 for forested lands with soils 

completely covered by living or dead biomass to a high of 98 for impervious areas such as 

parking lots. Representative CNs for the various hydrologic soil groups (HSGs) under current 

conditions were initially selected from published literature (Haan, et.al., 1994) but were 

subsequently adjusted to generate a peak discharge similar to that identified by FEMA for the 1 

percent recurrence interval event (100-year flood) for Schultz Creek (FEMA, 2010). Post-fire 

CNs based on soil burn severity and HSG were derived from values used for post-Schultz fire 

flood estimation without adjusting for slope. Fire model outputs were not available for roughly 

430 acres within the Schultz Creek watershed as can be seen as uncolored areas on the soil burn 

severity maps. In these areas, CNs were selected to represent unburned forest conditions. 

Modeling runs were conducted for the 100-year precipitation event as well as a precipitation 

event that occurred over the area impacted by the Schultz fire on July 20, 201022. This type of 

high-intensity, short-duration rain event is much more likely than the statistically rare 100-year 

event that has only a 1 percent chance of occurring in any given year. Modeling runs for the 

various action alternatives in the absence of wildfire were not conducted because there is no 

meaningful method for estimating curve numbers under the spatially varied disturbance that is 

typical of fuel treatments. Thinning treatments may locally alter surface cover and soil 

infiltration rates but these areas of disturbance are likely to be surrounded by undisturbed areas 

which act as buffers for absorbing runoff. 

Hillslope Erosion Predictions

Post-simulated wildfire hillslope erosion predictions for untreated and treated forest conditions 

were made using the web-based Erosion Risk Management Tool (ERMiT) without consideration 

of potential Burned Area Emergency Response (BAER) treatments that would potentially be 

implemented following a wildfire of the size simulated. BAER treatments were not considered as 

there is no way to predict the type or quantity of treatments that would potentially be 

implemented. This on-line tool (http://forest.moscowfsl.wsu.edu/cgi-bin/fswepp/ermit/ermit.pl) 

was developed by the U.S. Forest Service based on Water Erosion Prediction Project (WEPP) 

technology specifically for predicting erosion rates on hillslopes following a wildfire (Robichaud, 

et. al ., 2007). This tool specifically predicts post-fire sediment delivery rates to streamcourses 

from rill and interrill erosion processes occurring on hillslopes that drain to these streamcourses. 

Hillslopes and streamcourses were delineated with ArcGIS 10.1 using a 10-meter digital 

elevation model. This delineation resulted in 835 separate hillslopes in the DLH area and 274 

separate hillslopes in the Mormon Mountain area. ERMiT input parameters of soil texture and 

soil burn severity classification were derived from TES and the soil burn severity maps, 

respectively. ERMiT climate input data for the DLH area was derived from a weather station 

located at the Fort Valley Experimental Forest headquarters on State Highway 180 whereas 

 

22 Schultz rain event equates to the approximately 1.78 inches of rain in 45 minutes that occurred on July 20, 2010 over 

the Schultz Fire burn area.
Chapter 3: Affected Environment and Environmental Consequences

266 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

climate data for the Mormon Moutain area was derived from a weather station at the Flagstaff 

airport. Hillslopes with surfaces mapped as rock outcrop were considered to be non-erodible 

whereas sediment delivery from very low/unburned hillslopes was assumed to be zero based on 

reported erosion rates for undisturbed forest conditions (Elliot and Robichaud, 2005).

Rather than absolute values reflecting average erosion rates for a specified period, ERMiT 

sediment delivery predictions are presented in probabilistic terms. For example, a sediment 

delivery rate based on a probability of 50 percent means that this sediment delivery rate has a 50

percent chance of being equaled or exceeded in a given year. This approach to prediction is in 

part, a function of the probabilities associated with various sized rainfall and associated runoff

events based on a statistical analysis of historic weather records.

Timber Harvest Limitation Ratings

TES identifies timber harvest limitations as the limits to be considered when evaluating the 

suitability of timber harvesting by equipment use with regard to maintenance of soil productivity 

(Miller, et.al., 1995). Limits relate to year-round or seasonal use of equipment as the result of 

climate, soil characteristics, and landform. A slight rating indicates that mechanized harvesting 

can be performed year round with a low risk of soil productivity impairment. A moderate or 

severe rating directs the land manager to areas that require some measure of mitigation in order to 

avoid impairment of soil productivity. Timing of thinning operations can often be used to 

mitigate soil moisture problems. For example, thinning can be performed during frozen ground 

or dry conditions to minimize risk of soil compaction and rutting. Additionally, slope limitations 

can be established for different thinning treatments.

Affected Environment

See the Soil and Water Resources Existing Conditions section of Chapter 1 for a discussion of the 

current conditions for soil and hydrological resources within the project area.

Environmental Effects

For the purposes of the analysis of direct/indirect and cumulative effects, short-term effects are 

those lasting five years or less whereas those effects lasting longer than this are considered to be 

long-term effects. The time period for short-term effects is based on information from the Beaver 

Creek experimental watershed in northern Arizona indicating that suspended sediment 

concentrations in a catchment that was clear cut stabilized approximately five years following 

treatment (Hansen, 1965). This finding is consistent with field observations by resource 

specialists indicating that within approximately five years of thinning treatments, vegetative cover 

is restored to pre-disturbance levels (Steinke, personal communication 2013). 

Direct/indirect and cumulative effects to soils, springs, wetlands, and riparian areas are analyzed 

within the proposed project boundary since any impact to these resources by proposed treatments 

would most likely occur at or in their immediate vicinity. For example, soils are most likely to be 

impacted by those activities that occur directly on them as opposed to activities that are distant 

from the soil resource. In the case of water quality, direct/indirect and cumulative effects are 

analyzed at the catchment scale. Catchments are drainage areas nested within larger subwatersheds and are an appropriate analysis scale for this project as impacts to water quality from 

proposed vegetation treatments and past, present, and reasonably foreseeable future actions are 

most likely to be detectable at this scale rather than at the larger sub-watershed scale, in which 

catchments are nested. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 267

Alternative 1: No Action

Soils

Direct & Indirect Effects

Under the No Action Alternative, there would be no vegetation treatments to modify stand 

structure in order to reduce the risk of wildfire and/or its intensity should a wildfire occur within 

the analysis area. The majority of the DLH and MM portions of the analysis area are classified 

as having a group I natural fire regime, which is generally characterized by low-severity fires 

replacing less than 25 percent of the dominant overstory vegetation but can include mixedseverity fires that replace up to 75 percent of the overstory. 

In turn, the condition class for the majority of these areas, which reflects the extent to which 

current vegetation (in terms of composition and structure) departs from simulated historic 

vegetation reference conditions due to an absence of fire and an increase in fire return intervals 

for a particular natural fire regime, is condition class 3, reflecting a high departure from reference 

conditions. This high departure from natural (reference) conditions highlights the vulnerability of 

the catchments draining the analysis area to a fire that would likely greatly alter the catchment 

hydrologic response, rate of erosion, and sediment transport. 

This alternative would not authorize ground disturbance from mechanical vegetation and 

prescribed fire treatment activities. As a result, there would be no risk to soil productivity from 

disturbance associated with these activities. Soil resources, however, would continue to be at risk 

from a wildfire as noted below. 

Fire suppression and historic grazing combined with subsequent favorable weather conditions for 

pine recruitment have been identified as causative factors in the high densities of trees in 

southwestern ponderosa pine forests under post-European settlement conditions (Covington, 

et.al., 1997). The high canopy cover in these forests has reduced understory shrub and 

herbaceous species leading, in some cases, to monoculture stands of stunted ponderosa pines. 

Under the No Action Alternative, the current forest structure would remain unaltered. The 

density of forest overstory cover would remain higher than historic evidence suggests it was and 

herbaceous and shrub species would continue to be suppressed. The risk of stand-replacing fires 

would remain elevated. These “no action” conditions have important consequences to soil 

resources. 

The likelihood of a stand-replacing fire under the current (no action) forest structure poses a 

serious risk to soil condition. Since there would be no vegetation treatments authorized under 

the No Action Alternative, forest soils in untreated areas would potentially be vulnerable to the 

effects of an uncharacteristic stand-replacing wildfire given the departure of existing forest 

conditions from reference conditions. Figure 60 and Figure 61 show the anticipated soil burn 

severity that could occur with simulated wildfire. Such a fire occurred on the Coconino National 

Forest in June 2010 during the Schultz Fire. The Schultz Fire burned approximately 15,000 acres 

with roughly 39 percent of the area classified as high burn severity and 27 percent as moderate 

burn severity (Higginson, 2010). These types of fires can result in large losses of soil nutrients 

through volatilization, mineralization, and subsequent accelerated erosion (Neary, et.al., 1999). 

Soil burn severity maps for the various alternatives are presented in Figure 60 through
Chapter 3: Affected Environment and Environmental Consequences

268 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 67. Soil burn severity categories for the various alternatives are summarized in Table 100. 

Table 100: Soil Burn Severity Categories as a percentage of simulated wildfire, DLH

Soil Burn Severity (% of total simulated 

fire area)

Alternative Very 

low/unburned

low moderate high

No Action 9 27 25 39

Alternative 

2 & 3

37 41 14 8

Alternative 

4

21 31 18 30

Table 101: Soil Burn Severity Categories as a percentage of simulated wildfire, MM

Soil Burn Severity (% of total simulated 

fire)

Alternative

Very 

low/unburned low moderate high

No Action 1 15 22 62

Alternative 

2 32 36 31 1

Alternative 

4 37 31 16 17

Table 102 and Table 103 summarize the total predicted sediment delivery to streamcourses from 

hillslope erosion processes within the DLH and MM areas for the first year following simulated 

wildfire based on a 50 percent probability that these values would be equaled or exceeded during 

this first year. The column displaying the percent of sediment delivery change is a comparison of 

the decrease in total sediment delivery between the No Action Alternative and the three action 

alternatives. Because of the random nature of the rain events that drive erosion, the values 

presented in these tables should not be viewed as absolutes but rather, should be viewed as 

relative values allowing a comparison between the alternatives.

Table 102: Summary of total sediment delivered to stream networks in the DLH area during 

the first year following simulated wildfire

Alternative

Total Sediment 

Delivery (tons)

% Sediment 

Delivery 

Change

No Action 14,912 0

Alternative 2 & 3 8,277 -44

Alternative 4 12,977 -13
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 269

Table 103: Summary of total sediment delivered to stream networks in the MM area during 

the first year following simulated wildfire

Alternative

Total Sediment 

Delivery (tons)

% Sediment 

Delivery 

Change

No Action 2,445 0

Alternative 2 & 3 1,432 -41

Alternative 4 1,551 -37
Chapter 3: Affected Environment and Environmental Consequences

270 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 60: Soil Burn Severity Map for DLH, No Action Alternative with Simulated 

Wildfire

In addition, adverse impacts to soil hydrologic functioning (i.e., reduced infiltration through 

consumption of soil organic matter, loss of soil structure, and formation of soil hydrophobicity) 

can occur (Neary, et.al., 1999). 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 271

Figure 61: Soil Burn Severity Map for MM, No Action Alternative with Simulated Wildfire

Cumulative Effects

Other past, present, and reasonably foreseeable future actions that are likely to cause ground 

disturbance and therefore contribute to cumulative impacts to soil and water resources generally 

include timber harvesting, recreation activities, and grazing. Though not a mode of ground 

disturbance, climate change may also be considered a cumulative effect with potential impacts to 

soil and water resources. Specifically, the effects to soil and water resources associated with the 

following projects/activities were considered in the cumulative effects analysis:

Mountain Elden/Dry Lake Hills (MEDL) Recreation Planning Project

Eastside Fuels Reduction Project

Four Forest Restoration Initiative

Jack Smith Schultz Fuels Reduction Project

General dispersed recreation activities

Grazing

Climate Change

In addition of those direct/indirect effects to soils from the No Action Alternative, particularly, the 

continuation of forest conditions conducive to an uncharacteristic wildfire, the following 

cumulative effects to soils from past, present, and reasonably foreseeable future projects would 

potentially occur. 
Chapter 3: Affected Environment and Environmental Consequences

272 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

The MEDL Recreation Planning Project currently proposes roughly 30 miles of new or re-located 

trails; consolidation, re-location, or expansion of existing trailheads; construction of a hang glider 

launch pad; and establishment of new trailheads with associated parking areas either within or 

immediately adjacent to the analysis area. This project would address increasing demand for 

recreational opportunities in the Flagstaff area by providing a sustainable trail system to 

accommodate multiple user groups including hikers, mountain bikers, horseback riders, climbers, 

and hang gliders. Even though there would be additional impacts to soils associated with new 

trail construction, new or expanded trailhead parking areas, and a hang glider launch pad, the 

project would likely have an overall positive impact on soils since it would re-route those trails 

that cannot be adequately drained because of their position on the landscape, it would include the 

decommissioning of non-system trails and roads, and it would consolidate several trailheads. 

Those portions of non-system trails that meet Forest Service trail construction standards would be 

incorporated into the system of new trails thereby further reducing new disturbance to soils. 

The Eastside Fuels Reduction Project (2009) is an ongoing effort to reduce hazardous fuels 

around the base of Mt Elden involving approximately 226 acres of hand thinning, 151 acres of 

ground-based mechanical thinning on slopes less than 40 percent, and 56 acres of burn only 

(prescribed fire) treatment within the DLH area. The Jack Smith Schultz Fuels Reduction Project 

(2008), located within the DLH area, is a hazardous fuels reduction project in the DLH area that 

includes burn only treatments, mechanized ground-based harvesting on slopes less than 40 

percent, and hand-thinning treatments. Potentially beginning in 2014, a 837 acre portion of the 

DLH area would be treated as part of the future Orion Timber Sale included within the Jack 

Smith Schultz Fuels Reduction Project. This area would be treated by ground-based harvesting on 

slopes less than 40 percent with the effects to soils as described in the section on effects common 

to all action alternatives. Mechanized, ground-based tinning and prescribed fire treatments would 

cause disturbances to soils with erosion rates likely exceeding rates under undisturbed forest 

conditions for the short term; however, similar mitigation measures as proposed for action 

alternatives would be implemented minimizing the amount of disturbance to soils. It is important 

to note that some amount of disturbance to soils can be beneficial as it promotes the spread of 

herbaceous cover that can improve nutrient cycling and soil stability. The reduction in 

hazardous fuels would also reduce the likelihood of an uncharacteristic wildfire with its 

consequent impacts to forest soils. 

There are no past, present, or reasonably foreseeable future vegetation treatments within the MM 

area, but recreation activities, including but not limited to hiking, mountain biking, and hunting 

have occurred and would continue to occur within this portion of the analysis area. These 

activities affect soils because they typically require a network of roads and trails resulting in the 

reduction or elimination of vegetative cover and compaction of soils, both of which can lead to 

accelerated erosion. 

Roads open to the public in the MM area are typically only seasonally accessible because of snow 

accumulation. Roughly one-third of a mile of the Arizona Trail crosses the northeastern corner of 

the project area. Except in localized segments, these roads are not likely to be experiencing 

accelerated erosion because of low or no traffic and limited maintenance both of which are 

factors that affect road erosion rates (Grace and Clinton, 2007). Under low or no traffic 

conditions, road surfaces may become armored, reducing erosion rates by 70 to 80 percent (Elliot, 

et.al. 2009). 

The Peaks Allotment overlaps the DLH-portion of the project area and includes portions of two 

grazing pastures; Freidlein Prairie and Schultz. Neither pasture has been grazed in over ten years 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 273

and are deferred from livestock use indefinitely per the August 19, 2010 Decision Notice/FONSI 

for the Peaks Allotment. 

Two grazing allotments, Tinny Springs and Picket Lake/Padre Canyon overlap the MM-portion 

of the project area. These allotments are grazed from June 1 through October 31, in the case of 

Tinny Springs, and June 1 through September 30, in the case of Picket Lake/Padre Canyon. 

Grazing can affect soils through removal of vegetation and compaction of soils, however; these 

effects are often temporary with recovery of vegetation following precipitation and recovery of 

soil compaction through natural soil disturbance mechanisms such as heaving of soils freeze/thaw 

cycles and burrowing of animals. The transient disturbance to soils from cattle grazing is not 

expected to result in negative impacts to soil productivity even when combined with other 

disturbances to soils as discussed in this section. 

The extent to which climate change impacts soil productivity would be largely governed by the 

impact of climate change on vegetation structure and composition. Vegetative cover fluctuates 

naturally in response to inter-annual and longer climate variability. Climate change in the North 

American southwest is predicted to lead to decreased winter precipitation throughout the current 

century (Seager and Vecchi, 2010). This decline in winter precipitation could lead to a decrease 

in herbaceous cover dependent on winter precipitation. Although winter precipitation is 

important for annuals and cool season grasses as well as replenishment of soil moisture, 

herbaceous productivity in the southwest is primarily controlled by summer precipitation 

delivered by the North American monsoon (NAM) (McCollum, et.al., 2011). The effect of 

climate change on the NAM, which accounts for roughly half the precipitation in the region, is 

uncertain, however; recent research suggests a delay in the onset of the NAM with no change in 

total precipitation 

(http://www.ldeo.columbia.edu/res/div/ocp/glodech/research10futureANM.html). A delay in 

NAM would increase the length of the fire season potentially leading to more severe and 

widespread forest fires. It is this potential effect of climate change that would pose the greatest 

threat to soil productivity likely overwhelming any other cumulative effects to soils within the 

project area. Under the No Action Alternative, risks to soils from climate change-induced 

increases to fire severity and size would not be reduced. 

Water Resources

Direct & Indirect Effects

Under the No Action Alternative, water resources would not be affected by the proposed 

treatments included in the action alternatives as no actions would be authorized. However water 

resources would potentially be affected by the failure to reduce current fuel load conditions that 

are conducive to an uncharacteristic stand-replacing wildfire. In particular, the potential for a 

wildfire similar to the Schulz Fire that occurred in 2010 would still exist. This wildfire resulted 

in an increase in the amount of rainfall converted to runoff producing widespread flooding, 

incision of existing drainages, erosion of hillslopes, and mobilization of sediment. Post-fire peak 

discharges were estimated to be one to two orders of magnitude larger than those produced by

similar pre-fire rainfall events (Neary, et.al. 2012). If a similar fire were to occur in the DLHportion of the analysis area, flooding would likely occur in heavily populated portions of the City 

of Flagstaff along the Rio De Flag and Spruce Avenue Wash/Switzer Canyon drainages. In 

particular, the Rio De Flag has been the subject of a feasibility study to improve flood protection 

along this drainage as the “economic, social, environmental, and regional impacts and damages 

from a large flood event would be severe and devastating to the community” (ACOE, 2000). 

The predicted Schultz Creek peak discharge under the No Action Alternative with simulated 
Chapter 3: Affected Environment and Environmental Consequences

274 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

wildfire was roughly 4.3 times the predicted 100-year peak discharge under current conditions 

(i.e., no fuel treatments or wildfire) (Table 104).

Table 104: Predicted Peak Discharges for Schultz Creek at Mt. Elden Lookout Road

Alternative

100-year Peak 

Discharge23 (cfs)

Schultz Rain 

Event Peak 

Discharge24 (cfs)

No Action, Current 

Conditions (no 

wildfire) 474 222

No Action, Simulated 

Wildfire 2045 2014

Alternative 2 & 3 

Simulated Wildfire 1184 804

Alternative 4, 

Simulated Wildfire 1607 1409

An uncharacteristic stand-replacing wildfire in the MM-portion of the analysis area would 

potentially impact water quality in Upper Lake Mary, the principal source of surface water for the 

City of Flagstaff. A comparison of the amount of sediment that could be delivered to 

streamcourses from hillslope erosion within a one year period following ground-based 

mechanized thinning treatments, thinning treatments combined with prescribed fire, and wildfire 

was simulated by Elliot and Robichaud (2001) using Disturbed WEPP, an Internet-based 

computer program designed to predict runoff and rill/interrill erosion from undisturbed forests, 

forest fires (prescribed and wild), forests disturbed by timber harvesting, and rangelands under 

various cover conditions. Sediment yield was predicted to be 0.033 tons/hectare for first year 

following thinning treatments alone, 0.11 tons/hectare for thinning combined with prescribed fire, 

and 8.93 tons/hectare for wildfire. These simulation results highlight the increase in erosion

following wildfire versus that from vegetation treatment. When compared to natural rates of 

erosion in forest environments, which have been reported to be less than 0.11 tons/hectare (Elliot, 

et.al., 1999), it can be seen that thinning or thinning combined with prescribed fire is not likely to 

increase the amount of sediment reaching streamcourses, but that wildfire may do so by several 

orders of magnitude. 

Cumulative Effects

The cumulative effects of vegetation treatment activities associated with the Jack Smith Schultz 

and Eastside Fuels Reduction projects as well as the MEDL Recreation Planning project may lead 

to short-term increases in the delivery of sediment to streamcourses within the catchments of the 

DLH area, however, these increases are likely to be small and not detectable at catchment outlets 

given the ephemeral nature of flow in these streamcourses, the spatial and temporal aspects of 

 

23 100-year storm equates to 4.98 inches of rain in a single, 24-hour day. The following rainfall distribution pattern used 

to simulate monsoonal patterns: 60% of the rainfall occurs within about 30% of the 24-hour day

24 Schultz rain event equates to the approximately 1.78 inches of rain in 45 minutes that occurred July 20, 2010 over the 

Schultz Fire burn area. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 275

disturbance, and the length of time, measured in years to decades, it takes for sediment to be 

routed through a forest streamcourse (see Table 105; Elliot and Robichaud, 2005). Typical 

erosion and sediment delivery rates for forest disturbances are presented below. Also, recovery 

from even extreme disturbance events in forests, even wildfire, is typically rapid with rates of 

erosion reported to drop by up to two orders of magnitude in the second year following a wildfire 

and returning to natural (undisturbed) rates in the fourth year following a wildfire (Robichaud and 

Brown, 1999). Because disturbance activities would be distributed in both space and time rather 

than simultaneously and concentrated, the cumulative effects to water quality are predicted to be 

insignificant. 

Table 105: Predicted rates of erosion (from Elliot and Robichaud, 2005)

Activity

Erosion 

Disturbance

Rate

Time between 

disturbances

Average 

annual 

sediment 

delivery

Mg/ha years Mg/ha

Wildfire 6.0 40 0.15

Prescribed fire 0.02 20 0.001

Thinning or logging 0.10 20 0.005

Road segments 0.125 1 0.125

(assuming 2.5% of watershed)

Within the catchments draining the MM area, cumulative effects to water quality could occur by 

implementation of mechanical treatments under the Four Forests Restoration Initiative (4FRI) 

combined with those from the road system within the catchments. It is not predicted that grazing 

within the catchments would negatively impact water quality. Since roads within the catchments 

are only seasonally accessible with low traffic conditions and low maintenance activities, two 

conditions that strongly influence rates of erosion on forested roads (Grace and Clinton, 2005), 

combined with streamcourses that flow only intermittently mainly following spring snowmelt, the 

existing road system is not likely to be contributing significantly to water quality degradation in 

Lake Mary. Vegetation treatment activities within the catchments associated with 4FRI would 

likely occur over a period of years, resulting in temporally varied disturbance to forest soils with 

minimal sediment delivery to streamcourses within any given year. The temporary disturbance to 

forest soils with short-term increases in erosion rates and delivery of sediment to streamcourses 

contrasts with the potential impacts to the water quality of Upper Lake Mary from an 

uncharacteristic wildfire that would dramatically increase rates of erosion and the delivery of 

sediment and ash to this water body.

Effects Common to All Action Alternatives

Soils

Direct and Indirect Effects

The three action alternatives all include burn only treatments, hand thinning treatments, and 

mechanized thinning treatments on slopes less than 40 percent. In addition, prescribed burning 

would be performed after the various thinning treatments. This section provides an overview of 

the potential effects to soils and water resources from these treatments. 
Chapter 3: Affected Environment and Environmental Consequences

276 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Hand Thinning

A minor amount of hand thinning using chainsaws and hand piling of downed material with no 

yarding of felled timber would be implemented in the various action alternatives. Hand thinning 

would result in minimal impacts to soils since no construction of temporary roads would be 

needed, and heavy machines would not be used for felling and transporting of harvested timber. 

Soil disturbance from hand thinning operations is generally considered negligible (Robichaud, 

et.al. 2005; Berg and Azuma, 2010). No long-term loss of soil productivity nor accelerated 

erosion would be expected to occur from hand thinning and hand piling operations. 

Ground-based Mechanized Thinning

The majority of the analysis area (roughly 55 percent for Alternatives 2 and 3 and 50 percent for 

Alternative 4) would be treated by mechanized, ground-based harvesting methods on slopes less 

than 40 percent. Ground-based harvesting involves the use of either wheeled or tracked 

machinery in contact with the ground surface to both cut trees and remove them from the harvest 

area to landings in a process called “skidding.” Ground-based harvesting systems include whole 

tree harvesting systems in which trees are felled and the entire tree is skidded from the harvest 

area to landings, where the trees are further processed by delimbing and bucking (i.e., cutting the 

trees to specific lengths) and cut-to-length systems in which trees are felled and processed at the

stump with transport of processed logs to landings. In whole tree harvesting, trees are generally 

felled and bunched using a tracked or rubber-tired feller-buncher and tree bunches are skidded 

(i.e., dragged with crowns in contact with the ground) along designated skid trails to landings. 

Skidding is generally accomplished using tracked or rubber-tired skidders. In cut-to-length 

systems, trees are generally felled using a harvester equipped with a head that allows both cutting 

and processing of trees. Logs are then transported to landings using a forwarder that carries the 

logs fully suspended from the ground in a trailer-type fashion. Occasionally, harvesting and 

forwarding is accomplished with a single piece of equipment referred to as a “harwarder.” 

However this type of equipment is rare. There are various types of harvesters including trackhoes 

fitted with processing heads as well as multi-wheeled machines that are capable of operating on 

slopes exceeding 40 percent (“Forest Operations Equipment,” retrieved May 22, 2014). 

Ground-based mechanized thinning causes disturbance to soils including compaction, 

displacement of surface soil, rutting, and exposure of bare mineral soil attributable mainly to the 

network of temporary roads, skid trails, and landings needed to accomplish thinning. These 

effects have the potential to alter soil productivity, as well as surface runoff and erosion rates, 

which are normally very low under undisturbed forest conditions (MacDonald and Stednick, 

2003). In turn, changes in surface runoff and erosion may have an effect on water quality 

primarily through increased sediment delivery to stream courses. Despite the use of mechanized 

equipment for this purpose, the actual felling of trees causes only minor disturbance to soils 

(MacDonald and Stednick, 2003) and will not be discussed further. 

Compaction

Compaction is the process by which soil particles are rearranged resulting in a decrease in 

void space and a corresponding increase in bulk density (Miller, 2004). Soils are 

compacted by repeated passes of mechanical equipment over the forest floor along the 

designated road and skid trail system and landings established to facilitate harvesting, 

processing, and transport of logs. The degree of compaction is a function of soil 

characteristics, soil moisture content, number of machine passes over the soil, and 

pressure exerted by the machinery. Soils with water content just under field capacity 

(i.e., the water remaining in soil after gravity drainage) are most susceptible to 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 277

compaction whereas soils with higher water content are susceptible to displacement 

generally observed as rutting of the soil (Miller, 2004). Soil compaction may impact soil 

productivity by decreasing soil macroporosity, leading to reduced water infiltration and 

gas exchange important for soil biological activity and oxygen uptake by roots (Han, 

et.al. 2009). Soil compaction may also impact soil productivity by increasing the 

resistance of soil to root penetration thereby limiting root growth (Lacey and Ryan, 

2000). Reduced infiltration rates attributable to soil compaction may lead to increased 

runoff and accelerated soil erosion with potential impacts to water quality and soil 

productivity. 

Soil Displacement

Displacement of soil typically occurs when soil moisture is above field capacity and the 

presence of water-filled voids in the soil prevents further compaction by heavy equipment 

but causes soil to be displaced forming ruts. The displacement of soil can expose less 

productive soil horizons and/or those with a different chemistry potentially altering site 

productivity. In addition, the formation of ruts can concentrate runoff increasing its 

velocity and capacity to detach and transport soil particles. Ruts may also disrupt natural 

runoff patterns from hillslopes. 

Soil Exposure

The exposure of bare mineral soil increases the susceptibility of soil to detachment from 

raindrop impact and sheetflow potentially contributing to accelerated erosion on 

hillslopes. 

Temporary Road Construction

The exposure of bare mineral soil is most pronounced on temporary roads and the road system 

needed to conduct logging operations has been identified as far overshadowing that from other 

aspects of treatment operations (Rice, et.al. 1972; Megahan and Kidd, 1972). Temporary roads 

are those that are constructed during timber harvesting to facilitate access to timber stands and 

that are rehabilitated after harvesting by restoring the roadbed to its pre-disturbance condition to 

the extent possible. Some of the proposed temporary roads would be constructed on existing road 

prisms that were previous Forest Service system roads. Alternatives 2 and 3 are identical in terms 

of area treated by thinning but in Alternative 3, helicopter and forwarder yarding replace cable 

yarding. Because of the difference in yarding methods between the two alternatives, the proposed 

temporary road distance differs by approximately 5.81 miles total (4.7 fewer miles in the DLH 

and 1.07 fewer miles on MM in Alternative 3). Alternative 4 includes less treated acres than 

Alternatives 2 and 3 and therefore, less distance of temporary roads. 

Soil Burn Severity

The following figures and tables show the estimated soil burn severity for the action alternatives, 

with the red color as high burn severity, yellow as moderate burn severity, light green as low burn 

severity, and dark green as very low/unburned. Figure 64 and Figure 65 show the soil burn 

severity modeled after the treatments proposed in Alternatives 2, 3 and 4 compared to the Schultz 

Fire burn severity. 

Table 102 and Table 103 summarize the total sediment estimated to be delivered to stream 

networks in the DLH and MM areas during the first year following a simulated wildfire. 

Alternatives 2 and 3 result in the lowest sediment delivery in both areas, approximately 44 

percent less than the No Action Alternative in DLH and 41 percent less in MM. Alternative 4 
Chapter 3: Affected Environment and Environmental Consequences

278 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

would result in approximately 13 percent less sediment delivery than the No Action Alternative in 

DLH and 37 percent less in MM. These results suggest that thinning treatments proposed under 

Alternatives 2 and 3 would provide the greatest benefits in terms of mitigating the potential threat 

from erosion associated with a wildfire. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 279

Figure 62: Soil Burn Severity Map for DLH with Simulated Wildfire, Alternatives 2 & 3
Chapter 3: Affected Environment and Environmental Consequences

280 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 63: Soil Burn Severity Map for DLH with Simulated Wildfire, Alternative 4
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 281

Figure 64: Soil burn severity modeled after Alternative 2 & 3 treatments, compared to the 

Schultz Fire burn severity
Chapter 3: Affected Environment and Environmental Consequences

282 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 65: Soil burn severity modeled after Alternative 4 treatments, compared to the 

Schultz Fire burn severity
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 283

Figure 66: Soil Burn Severity Map for Alternatives 2 & 3, MM
Chapter 3: Affected Environment and Environmental Consequences

284 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 67: Soil Burn Severity Map for Alternative 4, MM

Broadcast Burning

Fuel treatments using prescribed fire are proposed under the action alternatives either as “burn 

only” treatments (i.e. no other method of treatment) or following treatment in areas where it is 

necessary to reduce the fuel load through either hand or mechanical thinning prior to the 

introduction of fire. In both cases, the effects are anticipated to be similar since prescribed fire 

would not likely be introduced for several years following mechanical treatment, when enough 

fine fuel has accumulated to carry a fire. 

The conditions under which prescribed burning would be conducted are generally characterized 

by high relative humidity, low air temperatures, low fuel loadings, and high fuel moisture. These 

conditions typically produce low burn severity in which surface litter is only partially consumed. 

In addition, the timing of controlled burns is such that burns are conducted during fall or spring, 

when lower ambient temperatures minimize surface litter consumption. Prescribed fires, 

however, do produce spatial variations in burn severity ranging from high to unburned depending 

on surface fuel loads. This spatial variability leads to varying runoff and erosion rates 

(Robichaud, et.al., 2010). 

In areas of low to moderate soil burn severitity, only a portion of the surface organic matter is 

consumed leaving adequate soil cover over much of the burned area. In general, prescribed fire 

does not cause excessive erosion or sediment transport since soil cover is retained in a 

discontinuous pattern across the landscape. Because of this, long-term adverse impact to soils are 

not expected from prescribed fire activities. This conclusion is supported by controlled burning 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 285

experiments conducted on the Fort Apache Reservation located in the White Mountains of 

northeastern Arizona, which indicated minimal soil erosion following controlled burning 

(Weaver, 1952; Cooper, 1961). Cooper (1961) evaluated post-burn erosion on a 35 percent 

hillslope in the White Mountains and concluded that accelerated erosion attributable to controlled 

burning could not be considered severe and that the soil appeared to be stabilized within a year of 

treatment. It was also noted that eroded material was only moved a short distance down slope. 

Conversely, prescribed burning would be expected to have a long-term benefit to soil resources 

by reducing the build-up of fuels, and restoring soil nutrient cyling through reduction of 

overtstory and encouragement of herbaceous cover.

Pile Burning

Burning of slash piles has been shown to negatively affect soil biotic and chemical properties due 

to intense soil heating (Korb et al, 2004 and Seymour and Tecle, 2004). It can result in soil 

sterilization, increased erosion risk and an increased risk of invasive and noxious weeds that 

displace native vegetation. Pile burning sites would constitute a very small portion of the project 

area (i.e., less than 5 percent). Monitoring of these sites for the presence of invasive or noxious 

weeds following pile burning, and treatment of any infestations found would mitigate most 

adverse effects to soils caused by pile burning of slash (see the Invasive Plant Species Specialist 

Report for more information).

Best Management Practices

A number of best management practices (BMPs) would be employed to protect soil resources 

during vegetation treatments. BMPs that would be implemented for all action alternatives are 

identified in the design features section. These BMPs protect soil and water resources by: 

1) Minimizing the amount of disturbance to soils through measures such as designation 

of skid trails and curtailment of mechanical vegetation treatment activities during wet weather 

conditions

2) Preventing concentrated flow through use of drainage measures (i.e., water bars, 

rolling dips) on such features as temporary roads, skid trails, and firelines

3) Protecting stream courses and wetlands through such means as limiting the types of 

activities that can occur in or adjacent to them and establishing buffers or filter strips around 

those water bodies designated as Aquatic Management Zones (AMZs) in which disturbance is 

minimized. 

With implementation of applicable BMPs, most adverse effects to soils and water reources would 

be minimized or mitigated. Additionally, natural disturbance of soils caused by seasonal wetting 

and drying, freezing and thawing, and soil organism activity would naturally ameliorate some 

adverse effects to soils caused by the action alternatives. Although disturbance of soils during 

thinning operations would be minimized through the use of BMPs, total avoidance would be 

neither feasible nor desirable since some amount of disturbance may be beneficial or necessary 

for seed bed preparation and for the establishment of herbaceous plants that may be inhibited by 

thick accumulations of forest litter. 

Cumulative Effects

The actions described in the No Action Alternative section are the same actions that would 

contribute to cumulative effects for the action alternatives. Because the various soil disturbing 

activities would be distributed through time and space within the analysis area, they would not 

likely have an overall long term negative effect on soils. Rather, the combined effects of the past, 

present, and reasonably foreseeable vegetation treatments along with the treatments proposed 

under the various action alternatives would have long-term benefits to soils by reducing the risk 
Chapter 3: Affected Environment and Environmental Consequences

286 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

to soils from an uncharacteristic wildfire, and by improving nutrient cycling through the creation 

of conditions favorable for return of herbaceous cover in areas where increased pine density has 

reduced this cover to near zero. 

In addition, the proposed decommissioning of 4.19 miles of roads in the DLH under the action 

alternatives combined with decommissioning of roads and trails under the future MEDL 

Recreation Planning project would have long-term benefits to soils by creating conditions 

favorable for the recovery of vegetation in these areas. 

Water Resources

Direct & Indirect Effects

Water Yield

The United States Geological Survey (USGS) defines water yield as “the runoff from the 

drainage basin, including ground-water outflow that appears in the stream plus ground-water 

outflow that bypasses the gaging station and leaves the basin underground” (from: 

http://water.usgs.gov/wsc/glossary.html). In ungaged drainage basins, such as those that occur in 

the project area, annual surface runoff is frequently estimated using a water balance approach 

whereby surface runoff is the difference between precipitation and evapotranspiration (i.e., the 

combined losses of water from a system via evaporation and transpiration) plus any changes in 

soil moisture and groundwater storage (MacDonald and Stednick, 2003). Since forest thinning 

generally results in a reduction in evapotranspiration, it could, theoretically, produce a change in 

surface runoff. MacDonald and Stednick (2003), however, note that the large variation in the 

hydrologic effects of forest management activities suggest that one can find studies either 

supporting or refuting this hydrologic response to thinning. This variable response reflects the 

complex interactions of climate; topography; pre- and post-treatment forest structure, 

composition, and density; geology; aspect and other variables on the rainfall/runoff response. 

Perhaps the best summary of the runoff response to thinning in forested environments is provided 

by Robichaud, et.al. (2010) in which it was concluded that “no measurable increase in runoff can 

be expected from thinning operations that remove less than 15 percent of the forest cover or in 

areas with less than 18 inches (450 mm) of annual precipitation. Since evapotranspiration rapidly 

recovers with vegetative regrowth in partially thinned areas, any increase in runoff due to 

thinning operations is likely to persist for no more than 5 to 10 years.” 

Studies conducted in the Beaver Creek Experimental Watershed located south of the analysis area 

along the Mogollon Rim at a slightly lower elevation provide local evidence for increased runoff 

from forest thinning. Clearcut thinning of a ponderosa pine-dominated catchment within the 

experimental watershed resulted in an approximately 30 percent increase in annual water yield for 

a period of seven years, after which water yield became statistically insignificant (Lopes, et.al. 

2001). Strip thinning of a second ponderosa pine-dominated watershed with an overall basal area 

reduction of 57 percent resulted in only a 20 percent increase in water yield, lasting for only four 

years following treatment. 

Under Alternatives 2 and 3 in the DLH-portion of the project area, thinning treatments are 

proposed in roughly 5,960 acres within the portions of Schultz Creek and Spruce Avenue 

drainages above Mt Elden Road and above the Forest Service boundary at Spruce Avenue Wash, 

respectively. These two drainage areas combined encompass roughly 6,890 acres. Thinning 

treatments would result in an approximately 45 percent reduction in basal area within the treated 

portions of the watersheds or a roughly 39 percent overall reduction in basal area within the 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 287

combined drainages. This reduction in forest density may be sufficient to increase the quantity 

of precipitation that is converted to runoff in these drainage areas depending largely on postthinning precipitation. Based on streamflow responses to thinning in ponderosa pine drainages 

within the Beaver Creek watershed, the increase in water yield is likely to be ephemeral, lasting 

perhaps four to seven years after thinning. 

The predicted peak discharge for Alternatives 2 and 3 with simulated wildfire was roughly 2.5 

times the predicted 100-year peak discharge under current conditions, whereas the predicted peak 

discharge for Alternative 4 with simulated wildfire was roughly 3.4 times the predicted 100-year 

peak discharge under current conditions (Table 105). These results suggest that thinning 

treatments proposed under alternative 2 provide the greatest benefits in terms of mitigating the 

potential threat from flooding associated with a wildfire. Although hydrologic modeling was not 

conducted for Spruce Avenue Wash, which drains the eastern portion of the project area, the 

conclusions would likely be similar based on the difference in soil burn severities under the 

various alternatives. The results shown in Table 102 suggest that thinning treatments proposed 

under Alternative 2 and 3 provide the greatest benefits in terms of mitigating the potential threat 

from erosion associated with a wildfire. 

Thinning treatments on approximately 3,392 acres are proposed in Alternative 4 with an 

estimated overall reduction in basal area of 22 percent within the combined drainages. This 

reduction in basal area may produce a slight ephemeral increase in water yield. Treated areas 

within the MM-portion of the project area are mostly within two drainage basins with outlets at 

Upper Lake Mary: an unnamed drainage basin encompassing roughly 4,330 acres, and Newman 

Canyon drainage basin, encompassing roughly 14,234 acres. The limited area of treatment within 

Newman Canyon Basin (approximately 1,300 acres) suggests that thinning treatments would not 

likely influence water yield at the Newman Canyon drainage basin scale. Since thinning would 

encompass a larger portion of the unnamed basin (approximately 39 percent) with an estimated 

overall basin-wide reduction in basal area of 18 percent, there may be a slight ephemeral increase 

in water yield at the drainage basin scale. 

Water Quality

Whereas the direct and indirect effects of the action alternatives on soil resources are largely 

concerned with on-site impacts to soils that reduce productivity, the direct and indirect effects to 

water quality are largely concerned with the movement of sediment from hillslopes to stream 

courses. 

The potential effects of the various action alternatives on water quality are related to the extent to 

which disturbance from the various treatment methods effect hillslope erosion and whether 

mobilized sediment would reach streamcourses. Hillslope erosion depends on such factors as 

amount of soil exposed, changes to infiltration rates, slope steepness, type and depth of soil, and 

the nature of precipitation (i.e., type and intensity) (MacDonald and Stednick, 2003). The 

movement of sediment from actively eroding hillslope areas to streamcourses is dependent on 

these same factors plus the spatial aspects of disturbance (i.e., whether disturbed areas are 

surrounded by relatively undisturbed areas, and the proximity of disturbance to streamcourses), 

and the types of post-treatment mitigation methods or BMPs that are applied. 

Using Disturbed WEPP, Elliot and Robichaud (2001) compared rates of sediment yield (i.e., the 

amount of sediment reaching a channel from hillslope erosion) under average weather conditions 

for the first year following simulated ground-based mechanical thinning/yarding, prescribed fire, 

and wildfire conditions in a relatively dry forested ecosystem in the inter-mountain west with 

precipitation mostly in the form of snow (Elliot and Robichaud, 2001). Disturbed WEPP is an 
Chapter 3: Affected Environment and Environmental Consequences

288 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Internet-based computer program designed to predict runoff and rill/interrill erosion from 

undisturbed forests, forest fires (prescribed and wild), forests disturbed by timber harvesting, and 

rangelands under various cover conditions, and is based on Water Erosion Prediction Project 

(WEPP) model. 

The greatest amount of erosion typically occurs in the first year following disturbance, and after 

several years, erosion declines to near zero. Thinning was assumed to reduce ground cover by 15 

percent over a harvest unit, although this analysis did not include the road system used to 

accomplish thinning. This level of disturbance is, perhaps, conservatively high as evidence for 

total ground disturbance (i.e., disturbance as evidenced by compacted soil, rutted soil, and 

exposed soil) from landings, temporary roads, skid trails, and slash management was measured to 

be approximately 16 percent in a harvest unit thinned by ground-based mechanical harvesting on 

the Kaibab National Forest (MacDonald, 2013). The rate of sediment yield in the first year 

following simulated thinning and wildfire was predicted to be 0.03 Mg/hectare and 8.1 

Mg/hectare, respectively. Predicted rates of sediment yield for simulated thinning followed by 

prescribed fire were approximately 0.1 Mg/hectare during the first year after disturbance. 

These simulation results highlight the increase in erosion following wildfire versus that from 

vegetation treatment. When compared to natural rates of erosion in forest environments, which 

have been reported to be less than 0.1 Mg/hectare (Elliot, et.al., 1999), it can be seen that thinning 

or thinning combined with prescribed fire is not likely to substantially increase the amount of 

sediment reaching streamcoures, but that wildfire may do so by several orders of magnitude. 

The BMPs that would be used to mitigate the effects of treatments are designed to: 

Minimize the amount of disturbance (e.g., requirement to designate skid trails and stream 

crossings, use of prescribed fire only when conditions are such that impacts to soils are 

minimized, etc.) 

Disconnect disturbed areas such as temporary roads, landings, and skid trails from 

streamcourses (e.g., designate aquatic management zones around streamcourses in which 

the amount of disturbance is minimized)

Protect exposed soil through re-seeding and/or spread of slash 

Prevent the concentration of runoff on linear areas of disturbance (i.e., temporary roads, 

skid trails, and fire lines) through the use of such drainage features as rolling dips, water 

bars, and lead-out ditches. 

Other methods that would be used to minimize disturbance include the use of up to 2.5 miles of 

existing road prisms as temporary roads, the rehabilitation of temporary roads after treatment by 

returning them to their pre-disturbance condition to the extent possible, and the decommissioning 

of up to 4.2 miles of existing roads currently designated as open to administrative use only. 

Because of the use of BMPs and these other methods of reducing disturbance, the amount of 

mobilized sediment reaching streamcourses would be minimized but not necessarily eliminated 

because of the nature of precipitation events in northern Arizona. In particular, the convective 

storms that occur during the summer months in northern Arizona may produce locally intense 

rainfall that drastically increases erosion in the absence of disturbance. Though rates of erosion 

in undisturbed forested areas of the western interior of North America are typically low, erosion 

rates may increase by several orders of magnitude as a function of the nature of precipitation 

(MacDonald and Stednick, 2003). This observation highlights the importance of the stochastic 

(or random) nature of erosion.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 289

Cumulative Effects

Cumulative effects to water resources are the effects of activities described in the No Action 

Alternative cumulative effects section combined with direct/indirect effects to water resources 

from proposed vegetation treatments. Cumulative effects to springs, wetlands, and riparian areas 

from the action alternatives and effects from past, present, and reasonably foreseeable activities 

are not anticipated to impact these features because of 1) the use of BMPs, 2) the absence of 

riparian areas within the analysis area, and 3) because of the spatial separation between activities 

and springs and wetlands. 

The effects of past, present, and reasonably foreseeable thinning activities associated with Jack 

Smith Schultz, Eastside, and 4FRII projects could potentially combine with thinning activities 

proposed under the action alternatives to increase water yield beyond that which would 

potentially occur from just the proposed thinning treatments. However, thinning treatments 

would all have to reduce forest cover by at least 15 percent, and the timing of treatments would 

have to be such that they occurred within the same catchments during the same 4 to 7 year period

(Robichaud, et.al.2010). 

Cumulative effects to water quality are not anticipated to be significant because of the dispersed 

nature, both in time and space, of ground-disturbing activities. Though there are likely to be 

short-term disturbances to forest soils with subsequent increases in sediment delivery to 

streamcourses, not all the cumulative increase in sediment delivery would occur during the same 

year and within the same streamcourse. The use of BMPs and proposed decommissioning of 

roads common to all past, present, proposed, and reasonably foreseeable future projects would 

limit disturbance to soils and the potential increase in sediment delivery to streamcourses. The 

combined effects of past, present, proposed, and reasonably foreseeable future vegetation 

treatment projects would be to reduce the risk of uncharacteristic wildfires in the affected 

environment catchments, thereby reducing potential threats to water quality in water bodies such 

as Upper Lake Mary. 

Alternative 2: Proposed Action with Cable Logging

The effects to soils and water resources from prescribed fire, hand thinning with no removal, and 

ground-based mechanized thinning on slopes less than 40 percent as well as the cumulative 

effects of these activities were previously described in the section titled “Effects Common to all 

Action Alternatives” and so are not included in the discussion below.

Direct & Indirect Effects

The types of disturbance to soils from cable yarding are the same as those for ground-based 

mechanized harvesting but the magnitude of disturbance in terms of the area with visible soil 

disturbance, such as exposed soil and rutting, would be less than ground-based 

harvesting/skidding (Reeves, et.al. 2011). 

In a study comparing the extent of soil disturbance associated with ground-based skidding, cable 

yarding, and helicopter yarding, Reeves, et.al. (2011) found that ground-based skidding produced 

the most soil disturbance (roughly 8.2 percent of harvested area excluding roads) with cable 

yarding next (roughly 3.8 percent of harvested area excluding roads) followed by helicopter 

yarding (roughly 0.2 percent of harvested area excluding roads). 
Chapter 3: Affected Environment and Environmental Consequences

290 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Alternative 3: Proposed Action without Cable Logging

The effects to soils and water resources from prescribed fire, hand thinning with no removal, and 

ground-based mechanized thinning on slopes less than 40 percent as well as the cumulative 

effects of these activities were previously described in the section titled “Effects Common to all 

Action Alternatives” and so are not included in the discussion below.

Direct & Indirect Effects

The treatments proposed in Alternative 3 are identical to those proposed in Alternative 2 except 

that helicopter yarding would replace cable yarding on approximately 973 acres and groundbased mechanized harvesting and skidding with specialized steep-slope equipment would occur 

on approximately 273 acres with slopes greater than 40 percent. Because helicopter yarding 

involves the transport of fully suspended logs to landings, there is no need for skid trails and 

cable corridors and less need for temporary roads. This means that the extent of soil disturbance 

under this alternative compared to alternative 2 would be less and potential impacts to water 

resources would be less. 

The proposed thinning by mechanized harvesting and skidding on slopes greater than 40 percent 

would likely be done either with multi-wheeled harvesters or track mounted levelling fellerbunchers designed for operation on steep slopes. Skidding would be done by use of selfpropelled forwarders requiring a separate entry for skidding or with harwarders (harvester and 

forwarder combined). In a study of the effects of harvesting on intermediate (10 to 25 percent) 

and steep slopes (26 to 43 percent), the overall amount of disturbance as a percentage of the 

harvested area was similar between slope classes, but the magnitude of disturbance expressed as 

amount of bare mineral soil exposed was greater in the steeper slope class (Cram, et.al., 2007). It 

was noted that disturbance was light to moderate, indicating less than nine percent exposure of 

bare mineral soil, when the harwarder traveled downslope but the amount of disturbance 

increased with uphill travel with areas of heavy disturbance (i.e., greater than 70 percent exposure 

of bare mineral soil) producing higher rates of runoff and erosion as determined through rainfall 

simulation experiments. There was no difference between rates of erosion in areas with no 

disturbance versus areas with light to moderate disturbance. This finding is consistent with 

research suggesting that erosion rates can be held to acceptably low rates when exposure of bare 

soil is less than 30 percent (MacDonald and Stednick, 2003). Disturbance associated with felling, 

delimbing, and bucking of logs was noted to be negligible. 

Implementation of this alternative would require an amendment to the Forest Plan since groundbased thinning treatments on slopes exceeding a 40 percent gradient is currently prohibited. 

Through use of BMPs, it is anticipated that disturbance would be light to moderate on these 

slopes (i.e., no more than nine percent exposure of bare mineral soil), similar to the level of 

disturbance from ground-based thinning on slopes less than 40 percent. If more than nine percent 

exposure of bare mineral soil was noted on timber access routes, slash mats would be used to 

protect soils. Slash mats would be generated by delimbing felled trees such that the slash would 

be placed in the path of the harvester(s). 

Alternative 4: Minimal Treatment

The effects to soils and water resources from prescribed fire, hand thinning with no removal, and 

ground-based mechanized thinning on slopes less than 40 percent as well as the cumulative 

effects of these activities were previously described in the section titled “Effects Common to all 

Action Alternatives” and so are not included in the discussion below.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 291

Direct & Indirect Effects

There would be fewer disturbances to soils and, subsequently, less delivery of sediment to 

streamcourses from implementation of this alternative; however, it would not likely provide the 

same level of protection against the potential impacts to soils and water resources from an 

uncharacteristic wildfire since it would involve treating a smaller area. 

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

Implementation of a proposed amendment to the Forest Plan to allow mechanical treatments in 

MSO PACs beyond 9 inches dbh, treatments in MSO restricted habitat above 24 inches dbh, and 

treatments and prescribed burning within MSO nest/cores would result in improved vegetative 

ground cover over the long term by providing conditions conducive to the establishment of a 

more vigorous understory of grasses, forbs and shrubs. This increased vegetative ground cover 

would improve nutrient cycling and soil stability while reducing the risks to soils, water quality, 

and watershed function from the effects of a high severity fire. Proposed population and habitat 

monitoring would not pose a risk to soil, watershed function, and water quality.

Implementation of a proposed amendment to allow mechanical harvesting on slopes greater than 

40 percent within the project area would facilitate thinning within the project area ultimately 

resulting in improved soil functioning and reducing the threat posed by a high severity fire to 

water quality, soil productivity and watershed function. Since the Forest Plan was written and 

amended, mechanized ground-based equipment has progressed to be able to operate on steep 

slopes without adverse impacts to soil resources. 

Irreversible and Irretrievable Commitments of Resources

There would be no irreversible or irretrievable commitments of soil or water resources as a result 

of the proposed treatments or activities within the project area. 

Wildlife

The following section summarizes existing conditions and effects from all alternatives to 

threatened, endangered, and Forest Service sensitive species (TES), management indicator 

species, migratory bird priority species that may occur or may have habitat within the FWPP. 

This section also discusses effects to wildlife cover and key habitat components such as snags

and downed logs. Effects are summarized from the Wildlife Specialist Report, located in the 

project record. 

Methodology

The Forest Service is legally required to comply with a number of federal regulatory 

requirements associated with various sections of the Endangered Species Act of 1973, as 

amended (ESA); the Bald and Golden Eagle Protection Act of 1940, as amended; Forest Service

Manuals (FSM) 2620, 2630, 2670, and 2672; Migratory Bird Treaty Act of 1918 (as amended);

Executive Order 13186 (migratory birds), National Environmental Policy Act, 1969; National 

Forest Management Act, 1976 (as amended); and the Coconino Forest Plan, as amended. The 

Wildlife Specialist Report contains more detailed information on the acts, manuals and Forest 

Plan guidance referenced above. 

Specific methodology used for the analysis of impacts to wildlife are included in the species’ 

discussions.
Chapter 3: Affected Environment and Environmental Consequences

292 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Threatened, Endangered and Forest Service Sensitive (TES) Species

The following TES species were analyzed because they are present or have habitat in the 

FWPP Action Area (Table 106). The Action Area is the project area and 0.5 mile buffer 

around the project.

Table 106: List of TES wildlife species that are present or have habitat in the FWPP action 

area

Common Name Scientific Name Status

Birds

Mexican spotted owl Strix occidentalis lucida Threatened

Bald eagle Haliaeetus leucocephalus FS Sensitive

Northern goshawk Accipiter gentilis FS Sensitive

American peregrine falcon Falco peregrinus anatum FS Sensitive

Mammals

Navajo Mogollon vole Microtus mogollonensis navajo FS Sensitive

Allen’s lappet-browed bat Idionycteris phyllotis FS Sensitive

Pale Townsend’s big-eared bat Corynorhinus townsendii pallescens FS Sensitive

Spotted bat Euderma maculatum FS Sensitive

Amphibians

Northern leopard frog Rana pipiens FS Sensitive

Mexican Spotted Owl (Strix occidentalis lucida)

Analysis Methods

The following evaluation criteria were used to compare environmental consequences for

alternatives:

Change in Crown Fire Potential within MSO habitats

Protected and Recovery Habitat Quality – Measures are primary constituent 

elements as identified for critical habitat which include; a range of tree species, 

canopy closure/cover, tree sizes suggestive of uneven-aged management and large 

dead trees (snags) with a diameter of 12 inches or greater.

Prey Habitat – Measures are primary constituent elements as identified for critical 

habitat which include; volumes of fallen trees and other woody debris, plant species 

richness, including hardwoods, residual plant cover to maintain fruits, seeds, and 

regeneration to provide needs of MSO prey species.

Noise disturbance associated with project implementation.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 293

Figure 68: Picture of a Mexican spotted owl, courtesy of the Texas Fish and Game website 

(accessed February 19, 2014)

Affected Environment

On the Coconino National Forest, the MSO occupies mixed conifer and ponderosa pine/Gambel 

oak vegetation types, usually characterized by high canopy closure, high stem density, multilayered canopies within the stand, numerous snags, and downed woody material. 

MSO are nocturnal predators that feed primarily on small mammals. They are “perch and 

pounce” predators that locate prey from an elevated perch by sight or sound, then pounce on the 

prey and capture it with their talons. They consume a variety of prey throughout their range, but 

commonly eat small and medium-sized rodents such as woodrats, peromyscid mice, and 

microtine voles. They also eat bats, birds, reptiles, and arthropods. 

The project area contains both MSO protected and recovery habitats. All of the suitable MSO 

habitat on the FWPP project has been surveyed. Surveys were done to USFWS protocols as 

described in the MSO Recovery Plan (USFWS 2012). Existing acres of MSO habitat are 

summarized in Table 107 and Table 110.

Protected Habitat (PACs)

There are ten Protected Activity Center (PACs) totaling 3,955 acres within the project area. Of 

that area, approximately 20 percent are nest/roost cores. PAC acres are summarized in Table 107

and displayed in Figure 69 (DLH) and Figure 70 (MM).

Table 107: Summary of acreages of MSO PACs and core areas in the project area

Habitat Type Description PAC*

(acres)

Nest/Roost 

Core 

Mormon Mountain De Toro’s 661 104 and 82

Lockwood 149 0
Chapter 3: Affected Environment and Environmental Consequences

294 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Habitat Type Description PAC*

(acres)

Nest/Roost 

Core 

___________________________

Dry Lake Hills 

Moore Well 21 7

Mormon Mountain 148 0

Mormon Mountain North 610 109

Weimer Springs 582 101

Schultz Creek 659 122

Mount Elden 630 102

Orion Spring 328 150

Weatherford 2 163 8

Total 3955 785

*PAC acres include nest/roost core

Additional PACs, not already listed above, that are within the Action Area defined in this report 

include: Archie’s, Red Raspberry, Dairy Spring and Aspen Spring.

One of the primary concerns for MSO is the potential loss of habitat from uncharacteristic 

wildfire (USDI 2012). Crown fire potential was analyzed for both project areas using data 

generated from modeling performed using FlamMap 5.0. Three types of fires result from the 

modeling. Surface fire describes fire that burns through the surface fuels of the forest floor. This 

type of fire has the least active of fire behaviors and is the most beneficial of the three types of 

fires in maintaining the historical, ecological role of low intensity, high frequency fire in the 

southwestern ponderosa pine ecosystem. Passive crown fire, or torching, occurs when flame 

lengths are long enough to reach the lower edge of the canopy and can result in individual or 

small group tree torching but does not proliferate through the forest canopy through continuous 

crown fire spread. Active crown fire occurs when flames reach the forest canopy and spreads 

through it with intensity and continuity (Fire & Fuels Specialist Report). Table 108 and Table 109

summarize the Crown Fire Potential by fire type for MSO habitats with the project as modeled 

under Schultz Fire Weather Conditions (see Fire & Fuels section in this chapter for more 

information). 

Table 108: Active crown fire potential in MSO habitats in Dry Lake Hills

Dry Lake Hills (Schultz Wildfire Weather Conditions)

MSO PAC

Name Surface % Passive % Active %Total

Recovery

Mixed Conifer 622 35% 187 11% 962 54% 1771

Recovery -

Nest/Roost 55 51% 23 21% 30 28% 109

Recovery 

Pine Oak 107 39% 31 11% 135 49% 274

Protected PAC Mt Elden 114 18% 62 10% 454 72% 630

Protected PAC Orion Spring 150 46% 26 8% 150 46% 326

Protected PAC Schultz Creek 118 18% 97 15% 443 67% 658

Protected PAC Weatherford2 34 21% 20 13% 107 66% 162
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 295

Table 109: Active crown fire potential in MSO habitats for Mormon Mountain project area

Mormon Mountain (Schultz Wildfire Weather Conditions)

MSO PAC Name Surface % Passive %

Active %Total

Recovery

Pine Oak 132 17% 14 2% 618 81% 764

Recovery

Nest/Roost 1 5% 0 0% 21 95% 22

Protected PAC Weimer Springs 196 34% 19 3% 367 63% 582

Protected PAC

Mormon 

Mountain

North 147 24% 57 9% 406 67% 610

Protected PAC

Mormon 

Mountain 52 35% 2 1% 94 64% 148

Protected PAC

Moore Well

Rock Dike 7 31% 2 7% 13 61% 21

Protected PAC Lockwood 51 34% 1 1% 97 65% 149

Protected PAC De Toros 133 20% 83 13% 445 67% 660

Approximately 65 percent of the protected habitat in the DLH area and 66 percent in the MM

area was rated as having an Active Crown Fire, indicating that wildfire activity would result in 

more severe effects to ecosystem components than should occur for the natural fire regime. 

Protected habitat is characterized by percent of basal area by size class and trees per acre greater 

than 18 inches diameter as well as the amount of course woody debris and snags greater than 18 

inches dbh. As summarized in the Forest Structure and Health section, all of the protected habitat 

exceeds basal area minimums in large size classes with adequate number of large trees. On 

average, stands have less than half of their stand densities in young trees less than12 inches dbh. 

On average, approximately one-half to three-quarters of their stand densities are in the 12-18 inch 

dbh and greater than 18-inch dbh size classes. Course woody debris exceeds desired conditions in 

all protected habitat and snags greater than 18 inches dbh meet desired conditions in all areas 

except the pine/oak in the MM area.

Recovery Habitat

As shown in Table 110 and depicted in 
Chapter 3: Affected Environment and Environmental Consequences

296 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 69 (DLH) and 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 297

Figure 70 (MM), recovery habitat consists of 1,909 acres of mixed conifer and 1,066 acres of 

pine/oak. The project area does not contain any riparian habitats (Soil and Water Resource 

Specialist Report).

Table 110: Acreages of MSO Recovery Habitat within the Project Area

Habitat Type Description

Acres of 

Recovery 

Habitat

Acres of 

Recovery 

Nest/Roost 

Total 

Recovery 

Habitat

Mixed Conifer Recovery 

Habitat Outside of PACs

Dry Lake Hills 1800 109 1909

Mormon Mountain 0 0 0

Total 1800 109 1909

Pine-Oak Recovery Habitat 

Outside of PACs

Dry Lake Hills 277 0 277

Mormon Mountain 767 22 789

Total 1044 22 1066

Riparian Recovery Habitat 

Outside of PACs

Dry Lake Hills 0 0 0

Mormon Mountain 0 0 0

Total 2844 131 2975

Table 108 and Table 109 list the portion of recovery habitat with each fire type rating.

Approximately 54 percent of the mixed conifer and 49 percent of the ponderosa pine recovery 

habitat in the DLH project area and 81 percent of the ponderosa pine recovery habitat in the MM 

project area was rated as having an Active Crown Fire, indicating that wildfire activity would 

result in more severe effects to ecosystem components than should occur under the natural fire 

regime. 

Recovery habitat is characterized by basal area and percent of basal area of trees 12-18 inches 

dbh and trees per acre greater than 18 inches diameter as well as the amount of course woody 

debris and snags greater than 18 inches dbh. As discussed in the Silviculture section, all of the 

recovery habitat exceeds basal area minimums in large size classes with adequate number of large 

trees. On average, stands have less than half of their stand densities in young trees < 12 inches 

dbh. On average, approximately one-half to three-quarters of their stand densities are in the 12-18

inch size class. On average, course woody debris exceeds desired conditions in all recovery 

habitats and snags greater than 18 inches dbh meet desired conditions in all areas except the 

pine/oak in both project areas.

Forested areas in recovery habitats currently do not provide a sustainable level of owl nest/roost 

habitat distributed across the landscape. These conditions do not provide for replacement owl 

nest/roost habitat because current conditions inhibit recruitment of old-growth trees, thereby not 

favoring the creation of large snags in stands and accumulation of large down logs and woody 

debris on the forest floor over time. The dense overstory is preventing development of a 

structurally and biologically diverse assemblage of tree and understory species. Lack of stand 

diversity prohibits conditions that support a wide variety of prey species for MSO. 

Recovery Nest/Roost Habitat

The 2012 MSO Recovery Plan calls for 25 percent of mixed conifer recovery habitat to consist of 

nest/roost habitat, having a minimum basal area of 120 ft2 with at least 12 trees per acre greater 

than 18 inches dbh, and 10 percent of pine oak restricted habitat having a minimum basal area of 

110 ft2 with at least 12 trees per acre25 greater than 18 inches dbh. For the ponderosa pine, 

 

25 The 1987 Forest Plan identifies pine oak nest/roost habitat having a minimum basal area of 150 ft2 with 

at least 20 trees per acre greater than 24 inches dbh. 
Chapter 3: Affected Environment and Environmental Consequences

298 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

nest/roost stands were identified in previous decisions or as part of the Four Forest Restoration 

Initiative (4FRI). For the mixed conifer, nest/roost stands have been identified through previous 

decisions and as part of a District-wide Assessment (USFS 2013). Approximately 131 acres of 

recovery nest/roost habitat occur within the project. Active Crown Fire Potential within recovery 

nest/roost habitat is 95 percent in DLH and 28 percent in MM (Table 108 and Table 109). 

Designated Critical Habitat

Critical habitat is designated by the FWS to provide for the survival and recovery of listed 

species. For MSO, critical habitat includes areas within mapped boundaries of protected and 

recovery habitat and includes one or more of the primary constituent elements as listed in the

Federal Register (USDI 2004). Critical habitat is in Upper Gila Mountains (UGM) Recovery Unit 

14Critical habitat includes protected and recovery habitats within the USFWS-designated Critical 

habitat boundary. 

Approximately 6,930 acres of critical habitat are within the project area and consists of 3,955

acres of protected habitat, 2,975 acres of recovery habitat and the remainder is other forest and 

woodland. Refer to the discussion under Protected Activity Centers for a description of conditions 

within protected habitat and refer to the discussion under Recovery and Recovery Nest/Roost 

Habitat for a description of conditions within recovery habitat. Table 111 summarizes critical 

habitat by habitat and project area. 

Table 111: Critical Habitat within the FWPP Project Area

Habitat Type Dry Lake Hills Mormon Mountain Project 

Protected 1781 2174 3955

Recovery (Pine Oak) 277 789 1066

Recovery (Mixed 

Conifer)

1909 0 1909

Total 3967 2963 6930
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 299

Figure 69: Dry Lake Hills MSO Habitats
Chapter 3: Affected Environment and Environmental Consequences

300 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 70: Mormon Mountain MSO Habitats

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for MSO would remain in their current condition, notwithstanding natural 

processes such as insect outbreaks, lightning strikes etc. Under the No Action Alternative, there 

would be no direct effect on MSO; however there would be indirect effects. Dense forest
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 301

conditions would exist and the crown fire potential would continue to place MSO habitat at risk

with respect to stand-replacing fire. If a crown fire were to occur in MSO habitat, components 

for nesting, roosting and foraging would be reduced or eliminated, resulting in an indirect

adverse effect. In addition, tree densities would continue to be high, slowing their growth into 

larger diameter classes and thereby limiting habitat for prey. Lastly, recent studies have shown a 

pervasive increase in tree mortality rates in old forests, which is interpreted as symptomatic of 

forests that are stressed and vulnerable to abrupt dieback (Ganey and Vojta 2011, Van Mantgem 

et al. 2009). Most recently this has been a result of bark beetle outbreaks and the combined 

effects of pests, disease, and drought that have resulted in nearly complete mortality of large 

trees in some cases (Van Mantgem et al. 2009). Without some type of management 

intervention, it is expected that forests will experience increasing stress, which would likely 

presage substantial changes in forest structure, composition, and function that would greatly 

impact MSO habitat needs (Notaro et al. 2012, Van Mantgem et al. 2009, Ganey and Vojta 

2011).

If a ground fire occurred, it is likely that ladder fuels would carry fire into the dense canopies

and turn into a passive or active crown fire. The No Action Alternative would not move to 

develop or maintain MSO habitat components.

Cumulative Effects

The cumulative effects boundary for MSO is the action area, defined as the project area and a 

one-half mile buffer around the project. Activity effects over one-half mile from the project 

boundary diminish to very low levels and would not impact owls within the project (i.e noise 

disturbance, smoke accumulations) and therefore would not combine with effects from this 

project. The time period analyzed for cumulative wildlife effects include a 20 year time period 

(2013 to 2033). The No Action Alternative would maintain or result in an increase in the current 

fire risk to MSO habitat and adjacent forest lands. The main effects to owls from this project are 

related to the adverse effect of noise disturbance from implementation and short term habitat 

effects and the long term beneficial effect of improved habitat conditions. All project 

implementation including maintenance burning is expected to be completed by 2033 and the 

desired forest structure in MSO habitat would develop within this period. 

Under Alternative 1 there would be no affect from disturbance during implementation; however 

Alternative 1 would not prevent, delay, or ameliorate predicted effects of climate change, but 

would likely result in a continued trajectory toward increased stressors on the MSO. The dense 

forest conditions resulting from the no action alternative are at a high risk to density related and 

bark beetle mortality and have limited resilience to survive and recover from potential large scale 

impacts. Under warmer weather conditions and more frequent and severe droughts predicted for 

the Coconino National Forest (TACCIMO 2014), the potential impacts of these risks to the 

ecosystem would be increased. Individual tree growth would be limited to the point of stagnation. 

As tree density increases, many areas would experience higher mortality (Notaro et al. 2012, Van 

Mantgem et al. 2009, Ganey and Vojta 2011). Species, including the MSO, requiring closed 

canopy forest conditions or old or large tree, snag, and log structure would be negatively 

impacted in the long-term. This would combine with the loss of habitat from the adjacent Schultz 

Fire, the subsequent waterline project, and the Mormon Mountain powerline replacement project 

to further reduce MSO habitat quality.

The ability to retain sustainable and resilient ecosystems would be further compromised by 

vulnerability to high-severity fires. The overt threat of high-severity fire could limit options for 
Chapter 3: Affected Environment and Environmental Consequences

302 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

treating uncharacteristic fuel loads through the use of unplanned ignitions, compounding the fire 

risk through time.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Treatments were designed to move toward desired conditions as identified in the 2012 Mexican 

Spotted Owl Recovery Plan (MSO Recovery Plan) (USFWS 2012). Table 112 below lists the

acres of treatments in MSO habitat.

Treatments follow the MSO Recovery Plan (USFWS 2012) in protected and recovery habitats 

with two exceptions: 1) trees greater than 24 inches dbh would be cut for cable corridors and 2) 

work would need to be completed in PACs during the breeding season to reduce the duration of 

disturbance from implementation. 

Proposed Treatments in MSO Habitat

Table 112 lists the proposed treatments in MSO protected and restricted habitat under Alternative 

2.

Table 112: Alternative 2 acres of thinning and/or burning proposed in MSO habitat

Treatment Protected Habitat Recovery Habitat

Mixed Conifer Fuels Reduction 0 1140

Mixed Conifer Fuels Reduction Burn Only 0 138

Mixed Conifer Fuels Reduction Hand Thinning 0 132

Ponderosa Pine Fuels Reduction Hand Thinning 0 14

Ponderosa Pine Fuels Reduction 0 1029 

MSO PAC Fuels Reduction (wet mixed conifer) 180 0

MSO PAC Fuels Reduction 2759 0

MSO PAC Fuels Reduction- Hand Thinning 202 0

MSO Nest Fuels Reduction-Burn Only 663 0

MSO Nest Fuels Reduction- Hand Thinning 122 0

MSO Recovery Nest/Roost Hand Thin 0 94

MSO Recovery Nest/Roost Burn Only 0 37

Totals 3926 2584

Protected Habitat

Approximately 3,926 acres of protected habitat (PACs) (99 percent of protected habitat within 

the project) is proposed for thinning and/or burning treatments intended to abate fire risk. Of 

that, approximately 122 acres are within the Schultz nest core, where trees would be thinned up 

to 5 inches dbh and dead and down material would be piled by hand and burned. Approximately 

20 percent of the Schultz nest core would be deferred from treatment to maintain pockets of 

denser trees intended to provide more structural diversity for prey. Additionally, 663 acres are 

nest cores that would be a burn only treatment. No temporary roads would be constructed 

within nest cores; however there would be approximately 4.7 miles of temporary roads 

constructed within protected habitat and another 0.9 miles of road relocation (Table 116). 

Recovery Habitat including Nest/Roost

Under Alternative 2, 2,315 acres (78 percent of the MSO recovery habitat, within the project) 

would be treated with mixed conifer or ponderosa pine fuels reduction treatments. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 303

Approximately 131 acres of recovery habitat (4 percent of MSO recovery habitat, within the

project area), including 94 acres of recovery nest/roost, would be hand thinned uneven-aged 

management with broadcast burning. An additional 138 acres of recovery and 37 acres of 

recovery nest/roost would be a burn only treatment. 

Previous analysis has identified 131 acres as recovery nest/roost. These 131 acres of recovery 

habitat would be treated to develop into nest/roost habitat. No temporary roads would be 

constructed in recovery nest/roost habitat however; there would be approximately 7.0 miles of 

temporary road construction within recovery habitat and another 0.9 miles of road relocation in 

order to accomplish thinning treatments (Table 116). Temporary roads would be rehabilitated 

after harvesting has been completed.

Designated Critical Habitat

Under Alternative 2, 3,926 acres of protected habitat and 2,584 acres of recovery habitat 

would be treated within Critical Habitat as listed above.

Effects of Thinning and Prescribed Burning 

Under Alternative 2, all treatments in MSO habitats would be designed to move toward the 

desired conditions as identified in the MSO Recovery Plan and described in the Wildlife 

Specialist Report (Appendix A, Table 1). Modeling shows that the treatments would move 

toward development of desired conditions both immediately after treatment and continuing 

over the next 20 to 40 years (Silviculturist Specialist Report). Treatments would be designed to 

maintain large snags, large logs and develop trees into the larger size classes. Snags would not 

be targeted for removal except where necessary for cable corridor locations and safety 

requirements in areas where trees would be felled by hand and removed by cable. Trees greater 

than 18 inches dbh would not be cut in protected habitat and trees greater than 24 inches dbh 

would not be cut in recovery habitat except where necessary for cable corridor locations (see 

next paragraph). Under Alternative 2, a Forest Plan amendment would allow for the removal of 

these trees in MSO habitat for cable corridors needed to facilitate skyline (a.k.a. cable) logging 

of steep slopes. 

Skyline logging uses a system of cables to drag logs of whole trees from the cutting unit to a 

roadside landing. It is used on sites that are too steep for ground based operations. Roughly 

parallel “corridors” for the skyline needs to be placed every 100 to 140 feet. These corridors are 

approximately 12 feet wide and must have all trees removed from them to facilitate yarding. 

Much of this area contains large (greater than 24 inches dbh) pre-settlement trees and snags. 

Roughly 74 acres of protected habitat (approximately 2 percent of all protected habitat in the 

project area) and 91 acres of recovery habitat (approximately 3 percent of all recovery habitat in 

the project area) would be denuded by cable corridors (i.e. located within the corridors 

themselves). The Recovery Plan guidelines are to retain large trees (greater than 18 inches dbh) 

in protected habitat and retain trees greater than 24 inches dbh in recovery habitat. This 

alternative would remove roughly 132 trees greater than 18 inches dbh in 2 percent of the MSO 

protected habitat within the project area (24 MM and 108 DLH) and 74 trees greater than 24 

inches dbh in approximately 3 percent of the recovery habitat within the project area. No cable 

corridors are proposed in MSO recovery habitat on MM; however cable corridors are proposed 

within MSO PACs on MM.

In addition, cable logging requires that all hazard trees be removed from the entire area that 

would be cable logged to provide for safety of personnel on the ground outside of protected 

(closed cab) machinery. A design feature requires biologists to identify patches of snags up to 10 

acres in size to allow for retention of some snags in these areas. Not taking into account these 
Chapter 3: Affected Environment and Environmental Consequences

304 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

patches, there would be approximately 391 acres in protected habitat (9 percent of all protected 

habitat within the project area) and 423 acres of recovery habitat (14 percent of all recovery 

habitat within the project area) where all snags could be removed to provide for safety. This loss 

of snags would reduce these key habitat components in protected and recovery habitats. This 

would likely move away from desired conditions for snags within the ponderosa pine in MM 

protected habitat and for ponderosa pine in both MM and DLH recovery habitat; however mixed 

conifer in both DLH and MM would continue to meet desired conditions. 

This alternative would lead to a loss of more MSO key habitat components with a loss of more 

snags and trees greater than 18 inches dbh than any other action alternative. Table 113

summarizes the approximated loss of key habitat components within MSO habitats within areas 

cable logged, including cable corridors. Although there would be a loss of trees greater than 18 

inches dbh in cable corridors within protected habitat and greater than 24 inches dbh in recovery 

habitat, when averaged across the cable treatment areas there would still be ample large trees to 

meet the desired conditions within MSO protected and recovery habitat after treatment habitat. 

Snags would move further away from desired conditions in ponderosa pine within the areas 

treated by cable logging. Design features such as retaining snag patches, and retaining large trees 

with dead tops, cavities and lightning strikes wherever possible would provide for replacement 

snags. Snags would be created if monitoring determines a deficit in these key areas and suitable 

replacement snags are not available.

Table 113: Alt. 2 Loss of MSO Key Habitat Components within Areas Cable Logged 

including Cable Corridors

Project 

Area

Recovery Habitat 

No. Trees >24” DBH

Removed

Protected Habitat

No. Trees >18” DBH

Removed

Recovery Habitat

No. Snags 

Removed

Protected Habitat

No. Snags 

Removed

MM 0 24 12”-18” - 0 12”-18” -306

>18” - 0 >18” - 34

DLH 206 108 12”-18” -1163 12”-18” -927

>18” -857 >18” -707

Thinning and/or prescribed burning activities in MSO habitat may indirectly affect MSO by

changing the owl’s habitat structure including snags, downed logs, woody debris, multi-storied 

canopies, and dense canopy cover. There is a potential for owls to relocate because of 

disturbance during treatment activities. The proposed thinning and burning may change the 

structure of MSO prey species’ habitat, affecting the abundance and composition of prey

species. Although treatments, especially prescribed burning, may have varying effects to prey

species in the short-term (generally one year, depending on climate and moisture) by impacting

individuals of prey species due to disturbance of prey species’ habitat, the proposed treatments 

may increase the diversity of vegetative conditions, which in turn would provide for a diverse

prey base. Empirical models of factors that influence availability of Mexican spotted owls five 

common prey species indicate that microhabitat manipulation can influence abundance of the

Mexican vole, followed by the long-tailed vole, Mexican woodrat, deer mouse and lastly the 

brush mouse (Ward 2001). Ward (2001) found that the total available biomass (kg) of mice and 

voles provided the strongest correlation with reproductive output. Model results indicated that 

abundance (g/ha) of the two vole species could be influenced by manipulating grass-forb height, 

whereas abundance of Mexican woodrats, the preferred prey, might be influenced by promoting

shrub diversity and increasing large log cover.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 305

Table 114 and 115 below summarize the post-treatment Crown Fire Potential for DLH and MM. 

Crown Fire Potential after implementation of Alternative 2 would greatly reduce the potential for 

active crown fire in each of the four PACs in the DLH and all of the recovery habitat in this area 

and at the same time shift the majority of the habitat to crown fire potential of surface fire. The 

largest benefit in PACs would occur in the Schultz PAC where thinning is proposed within the 

nest core. For the MM project area crown fire potential after implementation of Alternative 2 

would greatly reduce crown fire potential in each of the six PACs and all recovery habitat also 

shifting a majority of the acres to a surface fire rating. 

Overall, this shift in fire type from active to surface will result in the majority of MSO habitat in

the project area to be in a condition where low intensity, frequent fire would occur maintaining 

the historical, ecological role of fire. 

Under Alternative 2, the percentage of protected and recovery habitat with active crown fire 

potential is reduced mitigating the risk of large wildfires. The following tables reflect the

change in crown fire potential within protected and recovery habitats.

Table 114: Alternatives 2 and 3 Post Treatment Crown Fire Potential

Dry Lake Hills (Schultz Wildfire Weather Conditions) ALT2 & 3

MSO PAC Name Surface %

Passiv

e

%

Active %Total

Recovery - Mixed 

Conifer n/a 1539 86% 39 2% 194 11% 1793

Recovery -

Nesting/Roosting n/a 109

100

% 0 0% 0 0% 109

Recovery - Pine 

Oak n/a 275 99% 3 1% 0 0% 278

Protected - PAC Mt Elden 450 72% 4 1% 174 28% 628

Protected - PAC Orion Spring 311 95% 4 1% 12 4% 327

Protected - PAC Schultz Creek 578 88% 1 0% 102 15% 660

Protected - PAC Weatherford2 130 81% 8 5% 23 14% 161

Table 115: Alternatives 2 and 3 Post Treatment Crown Fire Potential

Mormon Mountain (Schultz Wildfire Weather Conditions) ALT2 & 3

MSO PAC Name Surface %

Passiv

e

% Active %

Total

Recovery n/a 623 82% 136 18% 1 0% 761

Recovery 

Nest/Roost n/a 22 99% 0 1% 0 0% 22

Protected - PAC Weimer Springs 559 96% 14 2% 7 1% 580
Chapter 3: Affected Environment and Environmental Consequences

306 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Mormon Mountain (Schultz Wildfire Weather Conditions) ALT2 & 3

Protected - PAC

Mormon 

Mountain 

North 512 84% 93 15% 5 1% 610

Protected - PAC

Mormon 

Mountain 137 93% 10 7% 0 0% 147

Protected - PAC

Moore 

Well/Rock Dike 16 77% 5 23% 0 0% 21

Protected - PAC Lockwood 150

100

% 0 0% 0 0% 150

Protected - PAC De Toros 573 87% 69 11% 14 2% 657

By treating recovery habitat with a mixed conifer or ponderosa pine fuels reduction treatment and

prescribed fire, wildfire-induced mortality of key habitat components in recovery habitat would

be reduced for the next several decades. In thinned areas, there would be a short-term (1 to 2 

years) increase in fire hazard in areas where slash needs to be cured before burning. However 

treatments would decrease fire hazard for several decades after thinning and burning treatments 

are complete.

Throughout the project, during broadcast burning activities, torching may occur within treatment 

areas. This torching is expected to create small openings of less than an acre in size; however a

change in the stand structure from this type of event would not be detectable on a stand basis.

Torching would mimic gap processes that occur under natural conditions (e.g. historic wildfire, 

windfall, and historic insect and disease outbreaks). Broadcast burning would decrease coarse

woody debris in all protected and recovery habitat treatments; however, levels would range from 

4 to 21 tons/acre and would exceed Forest Plan requirements. Woody debris and snags are habitat 

for small mammals. Indirect effects of reducing woody debris due to broadcast burning would

decrease prey base abundance on a short-term basis for approximately one year (Jenness 2000).

This decrease in small mammal prey base could be compounded during drought years when the 

prey base is lower due to a lack of food for these animals. However, herbaceous vegetation 

typically responds favorably to broadcast burning, and an increase in forage for small mammals is 

expected, outside of drought conditions. This in turn would have a corresponding increase in the

small mammal prey base (Jenness 2000). Design features to protect snags and logs would reduce

the number of snags and logs burned through a combination of burning techniques and lining (see 

Design Features). Recruitment snags would be identified from live trees that exhibit defects ideal 

for wildlife. For example, trees with spiked tops, lightning strikes, mistletoe brooms, or fading

crowns.

Smoke from broadcast and pile-burning may temporarily disturb MSOs. Burning would be 

managed to minimize the accumulation of smoke in PACs during the breeding season (see Design 

Features). Short-term impacts from smoke would be reduced by coordination and timing and type

of burning with wind direction, topography, time of year, and distance to PACs. Initial entry

burning would not occur in nest cores during the breeding season and burning would be

restricted during the breeding season in areas that may create smoke impacts to occupied PACs. 

Prevailing southwest winds and the topography of the area typically act to lift smoke, carrying it 

away from ignitions sites. PACs in DLH and MM are on raised topographic features and are not 

expected to have smoke settle in them long enough to cause discernable effects to MSOs because 

of air movement in these landscape-scaled features. With this information in mind, along with the 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 307

concept that the species presumably adapted and evolved with smoke from wildland fire, smokerelated effects from maintenance burning would not be substantial. 

Under Alternative 2, there would be indirect effects from the modification of vegetation. Burning, 

thinning and the associated ground disturbance could adversely affect the prey base on a shortterm basis by impacting individuals of prey species due to disturbance of prey species’ habitat and

harm from fire. However, over the long- term, an increased diversity of vegetative structural

stages and improved understory vegetation with improved plant species richness and would 

increase prey species, resulting in indirect beneficial impacts.

Effects of Ground Disturbance 

Ground disturbance can cause indirect effects from the loss of vegetation through compaction and 

rutting and exposure of bare mineral soil. Landings, cable corridors, road construction and 

decommissioning, and other harvest activities could adversely affect the prey base on a short-term

basis by impacting individuals of prey species due to disturbance of prey species’ habitat. The 

following excerpt by the Kaibab National Forest’s Soil Scientist estimates the percent of 

disturbance by harvesting type in Arizona ponderosa pine forest on slopes less than 40 percent:

“Mechanical thinning of the ponderosa pine forests of Arizona has been occurring since the 1980s 

mainly through whole tree harvesting on slopes less than 40%. Typical equipment used for such 

harvesting includes rubber-tired feller bunchers and rubber-tired skidders with tracked dozers 

used for piling of slash. The amount of disturbance as a percentage of a typical harvest unit (i.e., 

area included in a timber sale) impacted by compaction, rutting, and/or exposure of bare mineral 

soil from this type of harvesting has been estimated to be roughly 8% associated with fellerbuncher and skidding operations, 3% associated with machine piling of slash, 3% associated with 

landings, and 3% associated with temporary roads (MacDonald, 2013).” This alternative’s use of 

cable logging would mostly avoid ground disturbance from heavy machinery on steep slopes, and 

thus would generally prevent compaction, rutting, and/or exposer of bare mineral soil on slopes 

greater than 40 percent in the project area. 

Of the 5,203 acres of ground based harvest method in MSO habitat, approximately 2,777 acres 

are protected habitat and 2,426 are recovery habitat. Roughly 728 acres (14 percent) could be 

impacted by compaction, rutting, and/or exposure of bare mineral soil. All harvest methods would 

require temporary roads (Table 116), which would result in additional acres that would be 

impacted by compaction and exposure of bare mineral soil. Temporary roads, including those 

along an existing road prism, road relocations and cable corridors needed for implementation have 

been identified and are summarized in Table 116. 

Table 116: Alternative 2 - Miles/Acres of Cable Corridors, Temp and Relocated Roads in 

Protected and Recovery Habitat

Acres treated by the 

Skyline/

Excaline Harvest 

Method* 

Acres of Cable 

Corridors

Skyline/

Excaline

Miles of Temp Roads/Road 

Relocation 

DeToros PAC 39 5 .6/.1

Lockwood PAC 12 2 .2/0

Moore Well- Rock Dike 

PAC

0 0 0/0

Mormon Mountain PAC 0 2 .9/.4

Mormon Mountain North

PAC

56 7 .8/.4
Chapter 3: Affected Environment and Environmental Consequences

308 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Acres treated by the 

Skyline/

Excaline Harvest 

Method* 

Acres of Cable 

Corridors

Skyline/

Excaline

Miles of Temp Roads/Road 

Relocation 

Weimer Springs PAC 0 0 0/0

Schultz Creek PAC 115 18 1.2/0

Mount Elden PAC 180 31 .9/0

Orion Spring PAC 49 7 .1/0

Weatherford2 PAC 14 2 0/0

Total Miles/Acres in 

PAC 

465 acres 74 acres 4.7/.9 miles

Recovery Habitat DLH- 514

MM - 0

DLH-91

MM-0

DLH-6.1 /.9

MM – .9/0

Recovery Nest/Roost DLH – 0

MM - 0

DLH-0

MM-0

DLH- 0/0

MM – 0/0

Total Miles/Acres in 

Recovery

514 acres 91 acres 7/.9 miles

TOTAL 979 acres 165 acres 11.7/1.8 miles

*Acres treated by Skyline/Excaline harvest method include cable corridors

No temporary roads would be constructed in MSO nest cores, reducing the potential for adverse 

effects to nesting owls. Temporary roads, landings and skid trails would be needed in PACs and 

recovery habitats in order to accomplish thinning treatments; however all would be rehabilitated 

after harvesting. This alternative would have 4.7 miles of temporary roads in protected habitat 

and 7.0 miles in recovery habitat. The construction of temporary roads would remove important 

habitat components such as large trees, snags, and downed wood on approximately 8 acres 

(assuming a 14-foot wide road) in protect habitat and 15.3 acres in recovery habitat. Road 

relocations would be needed in order to accomplish thinning treatments with 0.9 mile in protected 

habitat and 0.9 mile in recovery habitat (affecting approximately 1.6 acres each).

Ground disturbance associated with landings, road decommissioning, temporary roads, cable 

corridors and ground based harvest activities would be short term and temporary in nature, and 

although roads, landings and corridors might displace prey they would not limit their numbers in 

MSO habitats. All ground disturbances would be rehabilitated after implementation. This 

alternative has the most temporary roads and road relocations in protected and recovery habitats 

of all the action alternatives. 

Effects of Disturbance Associated with Project Implementation

Noise disturbance could be caused by project implementation activities including thinning and 

burning, road construction and maintenance, hauling of logs, and road rehabilitation in and 

adjacent to MSO habitat. In general, human activities have been documented to cause disturbance 

to raptors and in many instances can cause nest abandonment or changes in home range 

(Anderson et. al. 1990). Delaney and Grubb (2004) determined that spotted owls appear to be 

capable of hearing sounds from road maintenance equipment to distances of at least 400 meters 

(0.25 miles). No mechanical treatments would occur within nest cores. The potential for noise 

disturbance from hand thinning treatments to directly affect nesting owls would be reduced as no 

thinning would occur within the Schultz nest core during the breeding season if the nest is
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 309

active. Treatments within individual PACs would be limited to no more than two breeding 

seasons (e.g. one entry), reducing the duration of potential disturbance to nesting owls.

Chainsaw operation caused most owls to flush from their perches when chainsaws were operated 

<60 meters (197 ft) from roosting Mexican spotted owls. Owl response decreased with increasing 

distance to noise source for chainsaw operation (Grubb 1999). Thinning and logging activities

within the PAC but away from nesting locations are not expected to impact nesting success. 

Activities would occur during daylight hours when owls are typically roosting within the core 

area and would be protected from noise both by topographic and vegetative features. Owls are 

nocturnal and would forage within the PAC during nighttime hours when logging activities would 

not be occurring. Since disturbance from thinning activities is expected to be minimal during 

times when owls are active, the impacts from this activity are expected to be minimal. Noise 

associated with hauling could disturb nesting owls and may occur over for two to three years in 

MM and five to eight years in DLH. Activities associated with prescribed burning and thinning

treatments conducted outside of the breeding season normally do not result in negative effects to 

the MSO. The MSO habitat within the project area has been surveyed according to approved 

protocols. Effects from proposed treatments to adult and young owls outside of PACs are

unlikely.

Haul routes may cause noise disturbance to nesting owls and vehicles could potentially hit owls, 

causing injury or death. Most logging traffic would occur during day time hours when owls are 

not as mobile; however there could be occasions when trucks are operating at times when owls 

would be foraging in the area. Main haul routes have been identified and include Forest Roads 

(FR) 420, 556, and 557 for DLH and FR 132, 132A and 648 for MM. FR 420, 132, 132A and 648 

pass within a quarter-mile of MSO nest or roost locations, increasing the potential for vehiclerelated disturbance to nesting owls and collisions. Hauling of lumber within the DLH may occur 

within one-quarter mile of the Schultz Creek nest or roost locations during the breeding season. 

Hauling of logs from MM may occur within one-quarter mile of Weimer Spring, DeToros, 

Archies, Mormon Mountain and Moore-Well Rock Dike nest and roost locations during the 

breeding season. For Schultz, Archies, Mormon Mountain and Moore Well-Rock Dike, the haul 

routes skirt the quarter-mile buffer of known nests and roosts. But for Weimer Springs and 

DeToros, the 132A haul route cuts through the buffers, increasing the potential for disturbance. 

There would be an estimated 4,800 truckloads that could haul on these routes. This disturbance 

would occur consistently (i.e. greater than twice per hour) for an extended period of time (more 

than one hour) and could influence reproductive success if owls are nesting. 

Alternative 2 would mechanically treat 4,697 acres in the DLH and 2,427 acres on MM, which 

roughly correlates to a maximum of 9,000 and 4,800 truckloads respectively of logs that would 

potentially be hauled adjacent to these nest cores. Based on a normal operating season of April 15 

– November 30 (150-210 days) assuming mechanical treatments accomplish eight acres per day, 

skyline and excaline yarding accomplish two acres per day, it could potentially take from 5.4 to 

7.5 years (breeding seasons) to complete implementation in the DLH and 1.6 to 2.3 years 

(breeding seasons) to complete implementation on MM. This is a conservative estimate; 

implementation could take less time to complete depending on weather, the contract procured, 

etc.

The MSO monitoring plan is designed to evaluate the effects of prescribed fire and hazardous 

fuels reduction treatments on spotted owl habitats, and to retain or move towards MSO desired 

conditions. This monitoring plan would provide valuable information on the effects of these 

activities on MSO and their habitat.
Chapter 3: Affected Environment and Environmental Consequences

310 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

The Campfire Closure Order would establish a permanent campfire restriction order in the DLH 

portion of the project area. This would result in a reduction of campfires in and adjacent to MSO 

habitat limiting the potential for human-caused wildfire to impact these important habitats. This 

would also reduce wood harvesting associated with campfires reducing the removal of snags and 

logs, key habitat components for MSO and their prey.

Cumulative Effects

The cumulative effects boundary for MSO is the action area, defined as the project area and a 

one-half mile buffer around the project. Activity effects over one-half mile from the project 

boundary diminish to very low levels and would not impact owls within the project (i.e noise 

disturbance, smoke accumulations) and therefore would not combine with effects from FWPP. 

The time period analyzed for cumulative wildlife effects include a 20 year time period (2013 to 

2033). The main effects to owls from this project are related to the adverse effect of noise 

disturbance from implementation and the beneficial effect of improved habitat conditions. All 

project implementation including maintenance burning is expected to be completed by 2033 and 

the desired forest structure in MSO habitat would develop within this period. Reviews of all

projects (past, present and reasonably foreseeable) that have the potential to impact owls during

implementation were analyzed (see Wildlife Specialist Report, Appendix D). 

Review with the Forest Service Fuels Specialist concluded that smoke from broadcast and pile

burning southwest of the project would have similar short-term (3-5 days) and low intensity (drift 

smoke) effects of smoke to individual MSO. Burning inside PACs occurs outside the breeding

season for most projects. Burning outside of PACs during the breeding season is conducted in a

manner that minimizes smoke impacts to MSO. However, it is anticipated that burning activities 

on portions of this project could occur simultaneously with burning activities on other fuels 

reduction projects. While there are numerous burning operations planned in areas adjacent to the 

project area, ADEQ standards limit the total amount of burning allowed in the airshed at a given 

time. Thus, smoke impacts to PACs are limited and expected to be the same as those analyzed in 

the direct and indirect effects section for this project.

Vegetation treatments proposed for the Four Forest Restoration Initiative (4FRI) will occur 

within the action area. Several PACs within the action area are proposed for burning. PACs 

within the action area proposed for vegetation treatment also include Red Raspberry and 

Archies. Restoration of springs are proposed within the Weimer Spring and Red Raspberry 

PACs. Recovery nest roost habitat was identified in ponderosa pine as part of the 4FRI 

analysis and nest roost recovery stands are located within FWPP. The FWPP incorporated 

these nest roost habitat delineations. Any impacts to MSO would be mitigated by 

coordinating with 4FRI to limit entries into PACs (see Design Features). Other ongoing 

implementation of fuels reduction projects such as Jack Smith Schultz, Eastside and Mormon 

Lake Basin are designed to minimize impacts to owls and mitigation of disturbance from 

implementation has been incorporated into the project design for all of these projects. 

Decreases would occur in coarse woody debris, logs, and snags in the ponderosa pine for all of 

the above fuels reduction projects and would combine with FWPP to move away from desired 

conditions in the ponderosa pine. Burn prescriptions and ignition techniques should limit overall 

losses of logs and snags. Burned snags would fall and provide logs and trees killed by fire would

become snags. The longevity of fire-killed snags is less than that of snags formed from other 

processes. However, maintenance burning should provide pulses of snags and logs through time. 

Less course woody debris is expected to be present as a result of prescribed burning. Thinning 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 311

and burning should increase tree growth rates and self-pruning of the lower tree branches through 

time should gradually replenish course woody debris. Improving growing conditions should 

decrease density-related mortality of larger and older trees. Improving recruitment into the larger 

size classes would improve MSO habitat and the ability to provide large snags that remain on the 

landscape longer than smaller diameter or fire-created snags.

Cumulative effects from other proposed projects such as Mount Elden Dry Lake Hills Trails 

Planning, which overlaps with this project, would combine with effects from ground disturbance 

and noise disturbance to MSO and their habitat in the action area. The development of trails 

within protected and recovery habitat reduces the quality of that habitat however, design features 

would be implemented to mitigate impacts. MEDL also proposes to reduce disturbance from one 

trail by relocating it outside of the Mt. Elden nest core. Implementation of trails, trailheads, etc. 

would be coordinated around FWPP implementation. Continued use of user-created trails in the 

DLH area may disturb roosting or nesting owls. New roads or trails would not be designated for 

public motorized or recreational use as part of the FWPP project, and all temporary roads would

be obliterated after implementation.

There are additive effects of reduction of understory vegetation by livestock grazing in the 

Mormon Mountain project area. Livestock grazing would combine with short-term loss of 

understory vegetation from prescribed fire and logging operations. The Mormon Mountain 

project area is managed on deferred rotational and deferred rest rotation grazing systems 

designed to allow forage a chance to recover from livestock grazing, reducing the potential for 

cumulative impacts. Prescribed burning would be coordinated with grazing schedules to 

minimize impacts to vegetation. 

By managing for resistant and resilient ecosystems, promoting landscape connectivity, and 

implementing concepts of adaptive management, land and resource management can respond to 

new information and changing conditions related to climate change that have the potential to 

increase ecosystem risks. Risks associated with dense forest conditions would be reduced and 

forest resiliency large scale disturbance under drier and warmer conditions would be improved by 

implementing the treatments proposed under all action alternatives. Individual tree growth would 

improve, resulting in larger average tree sizes. Species requiring habitat elements associated with 

closed canopy forest conditions or old or large tree, snag, and log structure would be more 

sustainable as forest resiliency improved. 

Determination of Effect

Crown Fire Potential would be reduced in MSO habitats reducing the potential loss of 

habitat to wildfire.

Trees would be thinned up to 5 inches dbh and dead and down material would be piled by 

hand and burned on approximately 122 acres within the Schultz nest core Approximately 

20 percent of the nest core would be deferred from treatment to maintain pockets of 

denser trees intended to provide more structural diversity for prey.

There would be no cable corridors or temporary roads constructed in nest cores or 

recovery nest/roost habitat.

There would be the complete loss of trees (including snags and large trees) on 74 acres in 

protected and 91 acres in recovery habitat due to cable corridors. This correlates to 

roughly 232 live trees and 741 snags >18” dbh that would be cut. Large logs would be 

increased on these acres. 

With the exception of snag retention patches, there would be an additional loss of snags 
Chapter 3: Affected Environment and Environmental Consequences

312 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

on 391 acres in protected habitat and 423 acres in recovery habitat in areas cable logged. 

Large logs would be increased on these acres. 

Ground disturbance would impact 728 acres along with the construction of 11.7 miles of 

temporary roads and 1.8 miles road relocations in MSO habitat may have short term 

impacts to plant cover. 

There would be 3,926 acres of vegetation treatments in protected and 2,584 acres in 

recovery habitat that may have short term impacts but would have long term beneficial 

effects of improving habitat resilience and improving structure and function.

There would be no thinning or burning or road construction/obliteration activities within 

nest cores during the breeding season. With the exception of hauling no PAC would be 

impacted by project activities for more than two years. 

Thinning activities would occur during the breeding season within some PACs being 

impacted for up to two years. Implementation would be designed to limit the number of 

breeding seasons that any one PAC would have thinning activities occurring during the 

breeding season. Monitoring would be used to inform treatment schedules. 

Hauling would occur within a quarter-mile of Schultz, Archies, Weimer Springs, 

DeToros, Mormon Mountain, and Moore Well-Rock Dike nest cores. There would be an 

estimated 4,800 truckloads that would haul on these routes. 

Burning activities would be coordinated with the district biologist and would be designed 

to limit smoke during the breeding season. Pile burning would be completed in the winter 

and initial entry prescribed burning would be completed in the fall/winter within PACs. 

The MSO monitoring plan is designed to evaluate the effects of prescribed fire and 

hazardous fuels reduction treatments on spotted owl habitats, and to retain or move 

towards MSO desired conditions. This monitoring plan would provide valuable 

information on the effects of these activities on MSO and their habitat. 

Based on the above analysis it is my determination that the project’s activities may adversely

affect the Mexican spotted owl and its critical habitat.

Alternative 3: Proposed Action without Cable Logging

Refer to Table 112 for acres of thinning and burning proposed in MSO habitats. The acres of 

treatment are the same as Alternative 2, but with different harvest methods on steep slopes. 

Alternative 3 would use a combination of helicopter logging and specialized steep slope 

equipment to extract the timber rather than cable logging. 

Direct & Indirect Effects

Effects from Thinning and Prescribed Burning 

Under Alternative 3, treatments would utilize ground-based harvesting across the majority of the 

project area, with helicopter logging for critical areas that are too steep, rocky or inaccessible to 

be treated with steep-slope machinery. No cable logging would occur under this alternative, 

which would reduce the need to remove the large trees and logs on steep slopes and also the need 

to create corridors. Effects to MSO habitat are similar as those discussed under Alternative 2 as 

the treatments and desired conditions would be the same; however no trees greater than 18 inches 

dbh would be cut in PACs, and no trees greater than 24 inches dbh would be cut in recovery 

habitat due to the absence of cable logging corridors. Helicopter logging allows for more 

flexibility for snag patch locations and the distribution of snags and large trees would be more 

consistently random due to the absence of proposed cable corridors. The Forest Plan amendment 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 313

required for this alternative would not require an amendment to the Forest Plan to remove trees 

greater than 24 inches dbh in MSO recovery habitat. 

Helicopter logging requires that all hazard trees are removed from the entire area that is 

helicopter logged to provide for safety of personnel on the ground outside of protected (closedcab) machinery. Where helicopter logging would occur, patch cuts may be used in order to break 

up fuels to allow for the maintenance of snags outside of patches while also allowing for greater 

removal of trees (live and dead) and operational safety within the patches. Biologists would 

identify patches of snags up to 10 acres in size in advance of treatment layout. Not taking into 

account these patches, there would be approximately 267 acres in protected habitat and 425 acres 

of recovery habitat where all snags could be removed to provide for safety. This loss of snags 

would reduce these key habitat components in protected and recovery habitats. No helicopter 

logging would occur in the MM area; those areas proposed for cable logging under Alternative 2 

would be treated by steep slope equipment under Alternative 3. Under Alternative 3, there would 

be fewer large trees and snags cut within PACs and wet mixed conifer in the MM area than 

Alternative 2. Overall, this alternative would result in less impact to MSO key habitat 

components including snags, logs and large trees.

Post Treatment Crown Fire Potential is the same as Alternative 2. Table 108 and Table 109

summarize the post-treatment Crown Fire Potential for DLH and MM. Crown Fire Potential after 

implementation of Alternative 3 would greatly reduce the potential for active crown fire in each 

of the four PACs in the DLH and all of the recovery habitat in this area and at the same time 

shifting the majority of the habitat to crown fire potential of surface fire. The largest benefit in 

PACs would occur in the Schultz PAC where thinning is proposed within the nest core. For the 

Mormon Mountain project area crown fire potential after implementation of Alternative 3 would 

greatly reduce crown fire potential in each of the six PACs and all of the recovery habitat, also 

shifting a majority of the acres to a surface fire rating. 

Overall, this shift in fire type from active crown fire to surface fire would result in the majority of 

MSO habitat in a condition where low intensity, frequent fire would occur maintaining the 

historical, ecological role of fire. 

Effects of Ground Disturbance

Project activities that may cause ground disturbance include; logging and skidding operations, 

temporary and relocated roads, helicopter and log landings. Effects to MSO habitat are similar as 

Alternative 2; however some landings would be replaced by helilandings and no cable logging 

would occur under this alternative, which would reduce the need to create corridors. Table 117

summarizes the miles of temporary roads and road relocations in MSO habitats. 

Table 117: Alternative 3 - Miles of Temp and Relocated Roads in Protected (by PAC) and 

Recovery Habitats

PAC Miles of Temp Roads/Relocations

DeToros PAC .4/.1

Lockwood PAC .2/0

Moore Well PAC 0/0

Mormon Mountain PAC .5/0

Mormon Mountain North PAC .5/.4

Weimer Springs PAC 0/0

Schultz Creek PAC 1.2/0
Chapter 3: Affected Environment and Environmental Consequences

314 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

PAC Miles of Temp Roads/Relocations

Mount Elden PAC .2/0

Orion Spring PAC .1/0

Weatherford2 PAC 0/0

Total Miles in PACs 3.1/.5

Recovery Habitat DLH – 3.5/.9

MM - .9/0

Recovery Nest/Roost DLH – 0

MM - 0

Total Miles in Recovery 4.4/0.9

TOTAL 7.5/1.4 miles

No temporary roads would be constructed in MSO nest cores, reducing the potential for adverse 

effects to nesting owls. Temporary roads, landings and skid trails would be needed in PACs and 

recovery habitats in order to accomplish thinning treatments; however all would be rehabilitated 

after harvesting. This alternative would have 3.1 miles of temporary roads in protected habitat 

and 4.4 miles in recovery habitat. The construction of temporary roads would remove important 

habitat components such as large trees, snags, and downed wood on approximately 5.3 acres 

(assuming a 14-foot wide road) in protected habitat, and 7.5 acres in recovery habitat. Road 

reconstruction would be needed in order to accomplish thinning treatments with 0.5 mile in 

protected habitat and 0.9 mile in recovery habitat, affecting approximately 0.9 and 1.6 acres, 

respectively.

Although ground disturbance associated with landings and ground based harvest activities would 

be less than Alternative 2 due to the lack of corridors, it would be more than Alternative 4 

because more acres within MSO habitats would be treated.

Effects from Noise Disturbance from Project Implementation

Disturbance would be similar to Alternative 2; however there would be additional disturbance 

from helicopter operations. Prior to implementation, an implementation guide would be 

developed to insure helicopter landings and flight patterns are located in areas away from nesting 

owls. 

The use of helicopter logging would require landings where trees are processed at the landing 

area with a processor. Delaney (1999) indicates 105-m (344 ft) buffer zone for helicopter 

overflights would minimize impacts of helicopter overflights on MSO. PACs in the MM area 

would not be impacted as no helicopter logging would occur in that project area; however, all 

PACs in the DLH area could be impacted. Implementation of all proposed helicopter logging 

treatments within MSO habitats (protected and recovery) in the DLH would likely exceed 140 

days in duration. However, a design feature to limit thinning and logging in each PAC to no 

more than two breeding seasons would limit the duration any one PAC would be impacted. An 

implementation plan would be designed to ensure helicopter operations (i.e. helilanding locations, 

flight patterns) would minimize impacts to nesting owls (see Design Features).
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 315

Cumulative Effects

Cumulative effects are the same in nature as that of Alternative 2, but would be slightly less since 

no trees greater than 18 inches dbh would be cut in PACs, and no trees greater than 24 inches dbh 

would be cut in recovery habitat. This is not expected to change the cumulative effects from that 

analyzed for Alternative 2 because even given the limited removal of large trees in Alternative 2, 

there would still be ample large trees to meet desired conditions when averaged across the project 

area.

Determination of Effect

Crown Fire Potential would be reduced in MSO habitats reducing the potential loss of 

habitat to wildfire.

Trees would be thinned up to 5 inches dbh and dead and down material would be piled by 

hand and burned on approximately 122 acres within the Schultz nest core Approximately 

20 percent of the nest core would be deferred from treatment to maintain pockets of 

denser trees intended to provide more structural diversity for prey.

There would be no helicopter logging or temporary roads construction in nest cores or 

recovery nest/roost habitat.

With the exception of hauling there would be no thinning, burning or road 

construction/obliteration in nest cores during the breeding season. 

With the exception of snag retention patches, there would be a loss of snags on 267 acres 

in protected and 425 acres recovery habitat in areas where helicopter logging is the 

harvest method.

Ground disturbance would impact 728 acres along with the construction of 7.5 miles of 

temporary roads and 1.4 miles road reconstruction in MSO habitat may have short term 

impacts to plant cover. 

There would be 3,954 acres of vegetation treatments in protected and 2,584 acres in 

recovery habitat that may have short term impacts but would have long term benefits by 

improving habitat resilience and improving structure and function.

Thinning activities would occur during the breeding season in the project area. 

Implementation would be designed to limit the number of breeding seasons so that any 

individual PAC would not have thinning activities occurring during the breeding season 

for more than two breeding season. Monitoring would be used to inform treatment 

schedules. 

Hauling would occur within a quarter-mile of Schultz, Archies, Weimer Springs, Detoros, 

Mormon Mountain, and Moore Well-Rock Dike nest cores. There would be an estimated 

4,700 truckloads that would haul on these routes. 

Burning activities would be coordinated with the district biologist and would be designed 

to limit smoke during the breeding season. Pile burning would be completed in the winter 

and initial prescribed burning would be completed in the fall/winter within PACs. 

Other activities, such as thinning, burning and temporary roads may have short term 

impacts but would have long term benefits by improving habitat resilience and structure 

and function.

The MSO monitoring plan is designed to evaluate the effects of prescribed fire and 

hazardous fuels reduction treatments on spotted owl habitats, and to measure retention or 

movement towards MSO desired conditions. This monitoring plan would provide 

valuable information on the effects of these activities on MSO and their habitat. 
Chapter 3: Affected Environment and Environmental Consequences

316 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Based on the above analysis it is my determination that the project’s activities may adversely

affect the Mexican spotted owl and its critical habitat.

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Alternative 4 proposes the minimal amount of treatment necessary to meet the purpose and need. 

Treatments are proposed for those areas with dense fuel loading where topography aligns with 

dominant winds and the probability of severe effects to soil resources from a wildfire is greater, 

based on FLAMMAP modeling. Table 118 summarizes the acres of treatments proposed in MSO 

habitats.

Table 118: Alternative 4 - Acres of Treatments in MSO Habitat

Treatment Name Protected Habitat Recovery Habitat

Mixed Conifer Fuels 

Reduction

0 542

Ponderosa Pine Fuels 

Reduction – Hand 

thinning

0 86

Ponderosa Pine Fuels 

Reduction 

0 277

MSO PAC Fuels 

Reduction (wet mixed 

conifer) 

0 0

MSO PAC Fuels 

Reduction

2077 0

MSO PAC Fuels 

Reduction- Hand 

Thinning

228 0

MSO Nest Fuels 

Reduction – Burn Only

0 0

MSO Nest Fuels 

Reduction – Hand 

Thinning 

122 0

MSO Recovery 

Nest/Roost

0 22

Totals 2427 927

Effects from Thinning and Prescribed Burning

This alternative would have the least amount of thinning and prescribed burning in MSO habitats 

of all the alternatives. For the MM area, not treating the wet mixed conifer would result in less 

opportunity for creating openings within aspen stands to promote aspen regeneration within 

protected habitat in the MM area. Heavy fuel loading would continue to be present in many 

portions of the project area as dead and down material would remain on site, thereby increasing 

the chance for more severe wildlife effects if one were to occur. This would also not encourage 

stand heterogeneity in many areas within the project boundary, resulting in less diversity of prey 

habitat. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 317

The Spruce Avenue Wash was identified as a high priority area due to the fuel loading, 

topography, size and also its location relative to the City of Flagstaff and MSO PACs. The 

portion of the Elden MSO PAC within the Spruce Avenue Wash would also be treated under the 

same parameters described in Alternatives 2 and 3.The Schultz MSO PAC and nest core were 

identified in conjunction with the FWS as high priority areas, and would also receive the same 

treatment described for Alternatives 2 and 3. No treatment in other nest cores would occur under 

this alternative. Treatments in both the Schultz and Elden PACs and the Schultz nest core would 

reduce the crown fire potential in those PACs ( Table 119and Table 120).

There would be no cable corridors or areas harvested by cable or helicopter logging within 

protected or recovery habitat, and temporary roads would be reduced slightly within these 

habitats (3.1 miles in protected habitat and 4.4 miles in restricted; see Table 121). This alternative 

would not require the Forest Plan amendment to include cutting trees greater than 24 inches dbh

in recovery habitat. This alternative would have fewer snags and large trees removed from MSO 

habitats than Alternative 2 and 3, but would have more removed than Alternative 1. 

Table 119 and Table 120 below summarize the post-treatment Crown Fire Potential for DLH and 

MM. Under Alternative 4, Crown Fire Potential 20 years after implementation would be greatly 

reduced in three of the four PACs in the DLH and in the recovery habitat, at the same time 

shifting the majority of the habitat to surface fire. The largest benefit in PACs would occur in the 

Schultz PAC where thinning is proposed within 80 percent of the nest core. Acres of treatment 

are less than the other action alternatives; Alternative 4 shows fewer acres shifting from crown to 

surface fire in the four DLH PACs. Crown fire potential increases in the recovery nest/roost 

habitat and in the Orion Springs PAC. This means that even though these stands are receiving 

treatment, it is not intense enough to show a large decrease in crown fire potential (Wes Hall, 

personal communication, 1/21/2014). For the MM area, crown fire potential after implementation 

of Alternative 4 would greatly reduce active crown fire potential in each of the six PACs and all 

of the recovery habitat would also shift a majority of the acres to a surface fire rating. 

Overall, this shift in fire type from active to surface would result in the majority of MSO habitat 

in a condition where low intensity, frequent fire would occur maintaining the historical, 

ecological role of fire.

Table 119: Alternative 4 Post Treatment Crown Fire Potential in MSO Habitats, DLH

Dry Lake Hills (Schultz Wildfire Weather Conditions)

MSO PAC

Name Surface % Passive % Active %Total

Recovery

Mixed Conifer 824 46% 195 11% 740 41% 1794

Recovery -

Nesting/Roosting 32 29% 15 14% 59 55% 109

Recovery 

Pine Oak 202 73% 8 3% 67 24% 278

Protected PAC Mt Elden 248 40% 26 4% 353 56% 628

Protected PAC Orion Spring 105 32% 9 3% 214 65% 329
Chapter 3: Affected Environment and Environmental Consequences

318 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Dry Lake Hills (Schultz Wildfire Weather Conditions)

Protected PAC Schultz Creek 650 99% 1 0% 8 1% 660

Protected PAC Weatherford2 70 43% 0 0% 88 55% 161

Table 120: Alternative 4 Post Treatment Crown Fire Potential in MSO habitats, MM

Mormon Mountain (Schultz Wildfire Weather Conditions)

MSO PAC Name Surfac

e

% Passive % Activ

e

%

Total

Recovery 758 99% 0 0% 4 0% 764

Recovery

Nest/Roost 21 100% 0 0% 0 0% 22

Protected PAC

Weimer 

Springs 496 24 4% 63 11% 582

Protected PAC

Mormon 

Mountain

North 452 85% 55 9% 105 17% 610

Protected PAC

Mormon 

Mountain 63 74% 43 29% 42 28% 148

Protected PAC

Moore Well

Rock Dike 14 42% 2 11% 6 26% 21

Protected PAC Lockwood 139 63% 2 1% 9 6% 149

Protected PAC De Toros 216 33% 113 17% 328 50% 660

With fewer acres of treatment, thinning treatments could potentially be accomplished in a shorter 

time frame, reducing the duration of noise disturbance during the MSO nesting season. 

Ground Disturbance 

Ground disturbance would be primarily from operation of equipment, landings and temporary 

roads. Of the 2,918 acres of ground based harvest method in MSO habitat, approximately 2,077 

acres are protected habitat and 841 acres are recovery habitat. Roughly 408 acres (14 percent) 

could be impacted by compaction, rutting, and/or exposure of bare mineral soil. Table 121

summarizes the acres of temporary roads required within MSO habitats for Alternative 4.

Table 121: Alt 4 - Number/Acres of Temp and Relocated Roads in Protected (by PAC) and 

Recovery Habitat

Protected 

PAC Name Miles of Temp Roads/ Relocated Roads

DeToros .5/.1

Lockwood .2/0

Moore Well –Rock Dike 0/0
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 319

Protected PAC Name Miles of Temp Roads/ Relocated Roads

Mormon Mountain .5/0

Mormon Mountain North .5/.4

Weimer Springs 0/0

Schultz Creek 1.2/.1

Mount Elden .2/0

Orion Spring 0/0

Weatherford2 0/0

Total Protected 3.1/.6

Recovery

Recovery Habitat Type

Recovery Habitat DLH - 3.5/.9

MM - .9/0

Recovery Nest/Roost DLH - 0/0

MM – 0/0

Total 4.4/0.9

No temporary roads would be constructed in MSO nest cores, reducing the potential for adverse 

effects to nesting owls. Temporary roads, landings and skid trails would be needed in PACs and 

recovery habitats in order to accomplish thinning treatments; however all would be rehabilitated 

after harvesting. This alternative would have 3.1 miles of temporary roads in protected habitat 

and 4.4 miles in recovery habitat. The construction of temporary roads would remove important 

habitat components such as large trees, snags, and downed wood on approximately 5.3 acres 

(assuming a 14-foot wide road) in protected habitat, and 7.5 acres in recovery habitat. Road 

relocations would be needed in order to accomplish thinning treatments with 0.6 mile in protected 

habitat and 0.9 mile in recovery habitat, affecting approximately 1.0 and 1.6 acres, respectively.

Effects from Disturbance from Project Implementation

This alternative would have the least amount of total disturbance from project implementation. 

There would be no disturbance from helicopter operations or cable logging corridors. Although 

the same haul routes would be used, there would not be as many vehicle trips required and the 

duration of the project would be shorter than the other action alternatives: approximately 6,800 

total vehicle trips in the DLH and 4,700 in MM compared to 9,000 in DLH and 4,800 and 4,700 

in MM for Alternatives 2 and 3, respectively.

Cumulative Effects

Cumulative effects are similar to Alternatives 2 and 3, but would be slightly less since no trees 

greater than 18 inches dbh would be cut in PACs, and no trees greater than 24 inches dbh would 

be cut in recovery habitat. This is not expected to change the cumulative effects conclusions from 

that analyzed for Alternative 2 because even given the removal of large trees in Alternative 2, 

there would still be ample large trees to meet desired conditions when averaged across the project 

area.

This alternative would remove many fewer snags compared to Alternatives 2 and 3 and thus 

would not have similar cumulative effects from snag removal. This alternative would include 

removal of snags on up to 16 acres where there is temporary road construction or road 

reconstruction. This could combine cumulatively with impacts to snags from adjacent treatments

that result from the 4FRI project, which is also likely to remove a small number of snags for 

temporary road construction. This cumulative effect is of most importance in the MM treatment 
Chapter 3: Affected Environment and Environmental Consequences

320 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

area where there is more overlap with 4FRI treatments and snag numbers are currently not 

meeting desired conditions in protected or recovery habitat.

Determination of Effect

Crown Fire Potential would be reduced in MSO habitats reducing the potential loss of 

habitat to wildfire.

Trees would be thinned up to 5 inches dbh and dead and down material would be piled by 

hand and burned on approximately 122 acres within the Schultz nest core Approximately 

20 percent of the nest core would be deferred from treatment to maintain pockets of 

denser trees intended to provide more structural diversity for prey.

There would be no cable corridors, helicopter logging operations, or temporary roads 

construction in nest cores or recovery nest/roost habitat.

There would be no thinning, burning road construction or obliteration activities within 

nest cores during the breeding season, and with the exception of hauling, no individual 

PAC would be impacted for more than two years.

Hauling would occur within a quarter-mile of Schultz, Archies, Weimer Springs, 

DeToros, Mormon Mountain, and Moore Well-Rock Dike nest cores. There would be an 

approximate 4,700 truckloads that would haul on these routes. 

There would be no significant loss of snags, large trees or other key habitat components 

in MSO habitats.

Ground disturbance would impact 408 acres along with the construction of 7.5 miles of 

temporary roads and 1.5 miles of road relocations in MSO habitat may have short term 

impacts to plant cover.

There would be 2,427 acres of vegetation treatments in protected and 927 acres in 

recovery habitat that may have short term impacts but would have long term benefits by 

improving habitat resilience and improving structure and function.

Burning activities would be coordinated with the district biologist and would be designed 

to limit smoke during the breeding season. Pile burning would be completed in the winter 

and prescribed burning would be completed in the fall/winter within PACs. 

Other activities, such as thinning, burning and temporary roads may have short term 

impacts but would have long term benefits by improving habitat resilience and structure 

and function.

The MSO monitoring plan is designed to evaluate the effects of prescribed fire and 

hazardous fuels reduction treatments on spotted owl habitats, and to retain or move 

towards MSO desired conditions. This monitoring plan would provide valuable 

information on the effects of these activities on MSO and their habitat. 

Based on the above analysis it is my determination that the project’s activities may adversely

affect the Mexican spotted owl and its habitat. The project activities may affect, but are not likely 

to adversely affect MSO critical habitat.

Bald Eagle

Analysis Methods

The following evaluation criteria were used to compare environmental consequences for

alternatives:

Removal of potential habitat

Disturbance from project implementation
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 321

Affected Environment

The bald eagle was removed from the list of threatened and endangered species August 8, 2007 

(USDI 2007). Eagles are currently protected under the Golden and Bald Eagle Protection Act and 

bald eagles are a Forest Service Sensitive species.

The DLH area does not have occupied or potential nesting or roosting habitat. Though the MM

area does not contain any known bald eagle nests or winter roosts, it is within one mile of 

Mormon Lake and as such provides potential nesting and roosting habitat. The nearest 

documented winter roost is located approximately two miles southeast of the project boundary at 

Mormon Lake. Groups of old growth ponderosa pine that are dominated by large, tall trees with 

open canopies occur throughout the MM area. Roosts on the Coconino National Forest are often 

associated with water bodies large enough to support reliable populations of fish and waterfowl 

(Dargan 1991). Although the project area does not contain any such water bodies, bald eagles 

may still establish roosts in the area, given the presence of suitable tree stands and the proximity 

of Mormon Lake as a reliable prey source. Recruitment of future suitable winter roost habitat has 

been reduced by wildfire suppression, facilitating the expansion of dense stands of small trees and 

preventing the development of large diameter trees and snags. 

As mentioned above, there are no known nesting bald eagles within the project area. The closest 

known breeding bald eagles use three nests along Lower Lake Mary that are located 

approximately 4, 5 and 7 miles north of the MM area, respectively. In Arizona, bald eagles 

typically nest within one mile of a major river or water body, and most breeding areas contain 

riparian vegetation (Driscoll et al. 2006). These components are not present within one mile of 

the DLH and it is unlikely that that project area would provide nest sites for bald eagles in the 

future. 

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions would remain in their current condition, notwithstanding natural processes. 

Because there would be no habitat altering activities or disturbance associated with project 

implementation, this alternative would have no direct effect on the bald eagle. However, dense

forest conditions would still occur and the high fire hazard potential would continue to place

potential bald eagle roosting and foraging habitat at risk with respect to stand-replacing fire, 

resulting in indirect adverse effects.

Tree densities would continue to be high, slowing their growth into larger diameter classes and

thereby limiting the development of larger diameter (greater than 18 inch dbh) trees important 

for roosting and perching. This would have an indirect adverse effect on bald eagle habitat.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to bald eagle habitat and adjacent 

forest lands. The cumulative effects of the No Action Alternative would be to increase the number 

of acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest 

conditions would continue to place bald eagle habitat and adjacent habitat at risk of stand-
Chapter 3: Affected Environment and Environmental Consequences

322 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

replacing fire. The fire hazard would increase over time as vegetation would continue to grow and

fuel would continue to accumulate. Forests would continue to be susceptible to the effects of 

climate change including vulnerability to insects, disease, and high severity fire, thus continuing

to have a negative effect to potential bald eagle habitat.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Direct effects would be from activities that cause disturbances (smoke, auditory or visual) to bald 

eagles within or adjacent to the project. Under Alternative 2, there would be no direct effects to 

nesting or roosting eagles as the nearest breeding area is four miles from the project and the

nearest roost is two miles away, and noise generated from these activities is not expected to be 

audible at the nearest nest or roost sites. Smoke from burning in the Mormon Mountain project 

area is expected to settle within the low lying areas of the Lake Mary Watershed and could 

adversely affect nesting eagles. Spring or summer burning in the Mormon Mountain project area 

would be coordinated with the District Biologist and FWS personnel if any of the three eagle 

nests are occupied. Typically nesting can be confirmed by May.

Skyline logging uses a system of cables to drag logs of whole trees from the cutting unit to a 

roadside landing. It is used on sites that are too steep for ground based operations. Roughly 

parallel “corridors” for the skyline needs to be placed every 100 to 140 feet. These corridors are 

approximately 12-feet wide and must have all trees removed from them to facilitate yarding. 

Much of this area contains large (greater than 24 inches dbh) pre-settlement trees and snags. 

Roughly 45 acres of potential nesting/roosting would be denuded by cable corridors (Wildlife 

Specialist Report, Appendix C). This loss of large trees would be compensated as treatments are 

designed to grow trees into the larger size classes over time. 

In addition, cable logging requires that all hazard trees are removed from the entire area that is 

cable logged to provide for safety of personnel on the ground outside of protected machinery. A 

design feature requires biologists to identify patches of snags up to 10 acres in size to allow for 

retention of some snags in these areas. Not taking into account these patches, there would be 

approximately 61 acres in potential bald eagle nesting/roosting habitat where all snags could be 

removed to provide for safety (Wildlife Specialist Report, Appendix C). 

Under Alternative 2, mechanical treatments, broadcast and pile burning and hauling of timber 

may cause visual or auditory disturbance to foraging bald eagles. This disturbance would be

localized, of short duration and low intensity and may impact individuals but is not likely to cause

a trend toward listing or loss of viability.

Indirect effects to the bald eagle include effects to eagle habitat, eagle prey species, or prey

species habitat. There are no anticipated adverse effects to prey species or prey species habitat. 

Indirect effects to habitat would occur from treatments that modify the number of trees in a group 

of suitable roost trees, as eagles prefer to roost in large trees within close proximity to other large

trees. However, thinning would improve old tree longevity, resulting in beneficial effects. Design 

features to protect snags would reduce the number of snags and logs burned through a 

combination of burning techniques and lining (see Design Features). Recruitment snags would

be identified from live trees that exhibit defects ideal for wildlife. For example, trees with spiked 

tops, lightning strikes, mistletoe brooms, or fading crowns.

In addition, Alternative 2 would include developing old-growth stands in 74 percent of the MM 

area that may be used as future winter roost sites for bald eagles.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 323

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half 

mile buffer. Effects for a period of 20 years beginning with implementation of the project were 

considered. There is no effect to nesting eagles as there are no nesting eagles present within the 

project area; however, there may be possible short-term disturbance to potential roosting

habitat with long term benefits. Short term disturbance to foraging bald eagles would occur

during thinning and broadcast burning activities and may cause eagles to forage in nearby areas 

for the duration of the activity. These short-term impacts added to similar impacts from past,

present, and reasonable foreseeable projects (including 4FRI and Mormon Lake Basin Fuels 

Reduction Projects) were considered. Implementation of other fuels reduction project activities 

could occur simultaneously; however, it is not anticipated to combine to cause a negative

effect. Vegetation treatments in adjacent projects would also improve tree vigor and growth, 

and vegetative structural stage diversity, thus promoting the growth of larger trees and habitat 

components for eagles as well as the forest’s resiliency to climate change. Other cumulative

effects include hazard tree removal for powerlines, communication sites and highways, which 

have reduced the number of snags and large trees for perching along potential winter foraging 

areas in the project area; however it is not anticipated to combine to cause a negative effect. 

Determination of Effect

The project’s activities may impact individuals but is not likely to cause a trend toward listing or 

loss of viability.

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Effects to bald eagle habitat are similar as Alternative 2 in that the treatments and desired 

conditions would be the same; however the distribution of snags and large trees would be more 

consistently random due to the absence of proposed cable corridors and areas where snags would 

be removed for safety purposes. Treatments would utilize ground-based harvesting across the 

majority of the project area, and helicopter would not be used in the MM area where bald eagles 

are known to occur. This would reduce the number of large trees and snags cut within potential 

bald eagle nesting/roosting habitat in the MM area.

Since no helicopters would be used to harvest trees in the MM area, there would be no potential 

for noise disturbance from helicopters to bald eagles. Fuels reduction treatments may cause visual 

or auditory disturbance to foraging eagles. 

Cumulative Effects

Cumulative effects are the same as Alternative 2.

Determination of Effect

The project’s activities may impact individuals but are not likely to cause a trend toward listing or 

loss of viability.
Chapter 3: Affected Environment and Environmental Consequences

324 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Effects to bald eagle habitat are similar to Alternative 3 as there would be no cable corridors or 

areas harvested by cable or helicopter logging required to accomplish thinning treatments 

reducing the need to remove potential perch or roost trees. 

There would be 630 fewer acres of thinning and burning treatments in MM, where bald eagle 

habitat occurs, reducing the development of larger size classes to only those areas to be treated. 

Cumulative Effects

Cumulative effects are the same as the other action alternatives, but to a slightly lesser extent as 

fewer acres would be treated. 

Determination of Effect

The project’s activities may impact individuals but is not likely to cause a trend toward listing or 

loss of viability.

Northern Goshawk

Analysis Methods

The following evaluation criteria were used to compare environmental consequences for all

alternatives:

VSS distribution and canopy cover within post-fledgling family area (PFA) and areas 

outside PFAs

Canopy cover within post-fledgling family area, nest stands and foraging area

Disturbance from project implementation. Short-term would be generally one year post 

treatment depending upon climate and moisture. Long-term would be a period of twenty 

years and would include implementation of all vegetation treatments including initial and 

maintenance burning. 

Affected Environment

Northern goshawk habitat exists within and adjacent to the project area. All potential nesting and 

foraging habitat not overlapping with MSO PACs in the project area and a half-mile buffer was 

surveyed for northern goshawks in 2012 and 2013 according to Region 3 protocol. East-west 

transects were established, with survey points mapped every 260 meters (853 feet). Transects 

were 302 meters apart (989 feet), and points along each transect were offset from those along the 

adjacent transect(s), such that they occurred at the midpoint between survey points along the 

adjacent transect(s). A total of 824 call points were surveyed.

Three post-fledging family areas (PFAs) intersect the project area: Schultz, Orion and Thicket. 

Existing nest stands and alternate nest stands totaling 180 acres or more have been delineated for 

each of the three existing PFAs. All three PFAs were surveyed in 2013 with no detections. 

Table 122 summarizes the acres of PFAs and nest stands and Figure 71 (DLH) and Figure 72

(MM) display these habitats within the project area. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 325

Table 122: NOGO PFA and Nest Stand Acres in the Project

PFAs Name Total PFA Acres PFA Acres within 

Project

Total Nest 

Stand Acres

Nest Stand 

Acres within 

Project

Thicket 650 423 181 50

Orion 777 391 190 21

Schultz Pass 612 393 183 100

Total 2039 1207 554 171

Other PFAs not listed above that are within the Action Area (project area plus a 0.5 mile buffer) 

include Bear. 

Wildfire suppression has led to accumulations of dense, small-diameter, young ponderosa pine 

trees within and adjacent to the PFAs that pose an increased risk of catastrophic fire in northern 

goshawk habitat. These conditions also promote risk of disease, inhibit recruitment of important 

habitat features such as old-growth trees and snags, and restrict the conditions necessary to 

support a variety of prey species for northern goshawks. 

Existing Vegetative Structural Stages (VSS) distribution within the PFA, including the 

alternate nest area, is predominately VSS 3 and 4. Outside the PFA the existing VSS

distributions include VSS 3, VSS 4 and VSS 6 classes with VSS 3 and VSS 4 predominate.
Chapter 3: Affected Environment and Environmental Consequences

326 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 71: Dry Lake Hills NOGO PFAs
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 327

Figure 72: Mormon Mountain NOGO PFAs

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. The No Action Alternative would have no direct effect on goshawks. However, dense

forest conditions would still occur and the high fire hazard potential would continue to place

goshawk habitat at risk with respect to stand replacing fire. Vegetative structural stage

distributions as outlined in the Forest Plan and Management Recommendations for the Northern

Goshawk in the Southwestern United States (Reynolds 1992) would never be attained.

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile 

buffer, and includes effects for a period of 10 years beginning with implementation of the project.

The No Action Alternative would maintain the current fire risk to northern goshawk habitat and 

adjacent forest lands. The cumulative effects of the No Action Alternative would be to increase

the number of acres of National Forest System lands that are vulnerable to severe fire effects, as 

dense forest conditions would continue to place goshawk habitat and adjacent habitat at risk of 

stand-replacing fire. The fire hazard would increase over time as vegetation would continue to

grow, fuel continue to accumulate, and the impacts of climate change continue, thus continuing

to have negative effects to northern goshawk.
Chapter 3: Affected Environment and Environmental Consequences

328 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Effects from Thinning and Prescribed Burning

Under Alternative 2, all treatments in goshawk habitats are designed to move toward the 

desired conditions as identified in the Northern Goshawk Management Guidelines (Reynolds 

et. al). Treatments are designed to maintain large snags, large logs and develop trees into the 

larger size classes. Typically snags would not be targeted for removal.

Under Alternative 2, approximately 178 acres would be treated within the Orion and Schultz 

PFAs with a prescription specifically designed to meet goshawk guidelines for PFAs, and 46 

acres would be treated with a prescription specifically designed to meet the guidelines for nest 

stands. For LOPFAs, the alternative proposes 1,739 acres of ponderosa pine fuel reduction with 

136 acres of hand thinning proposed. In areas where MSO habitat overlaps with goshawk 

habitat, MSO guidelines and desired conditions would take precedence. MSO treatments would 

move toward an uneven-aged condition; however they would likely exceed canopy cover 

standards so these acres would not move toward the desired structural stage distribution 

identified in the goshawk guidelines.

Treatments would alter VSS class distribution, changing the project area from one dominated 

by VSS 3 more toward the desired future condition, although still not meeting the desired future

condition. Although the desired future condition would not be met immediately after

implementation, the forest structure would be such that it would be moving towards it

(Silviculture Specialist Report). Alternative 2 would offer higher quality foraging habitat over

time due to improved habitat conditions for prey species.

Under Alternative 2, snags and large trees would be cut for cable corridors within the Orion 

PFA. All snags within the 60 acres proposed for harvesting by cable logging within the Orion 

PFA could be cut for safety reasons. There would be a loss of snags and downed logs during

broadcast burning, although many would be protected using appropriate ignition and piling 

techniques, and lining of most snags and large logs (see Design Features). In addition, after 

burning, trees would be felled to replace logs burned up during prescribed fire to meet forest plan

guidelines. Recruitment snags would be identified from live trees that exhibit defects ideal for 

wildlife. For example, trees with spiked tops, lightning strikes, mistletoe brooms, or fading 

crowns.

Reduction of snags and logs would have a negative impact on numbers of prey items, thus

prey availability, for northern goshawk. The impact of this effect is expected to lessen in the

long-term as snags are cut or fall and become logs; however the number of snags would continue

to be in short supply due to an existing shortage of snags in some stands. The number of snags is

expected to increase in the future as other trees grow, age, and die. Under this alternative, the

resiliency of the area to withstand wildfire would improve due to the increase of crown base

height and the reduced ground fuels. This alternative would have the most impact to dead and 

down woody material, gambel oak and snags. 

There are potential direct effects from smoke. Smoke could affect nesting and feeding

behavior. Avoiding burning near goshawk nesting areas during critical periods in the goshawks

life cycle is important. Smoke accumulation during times when goshawks are incubating eggs 

and tending nestlings and fledglings could cause adults to leave the area; this in turn could
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 329

cause reproductive failure for the year. Goshawk may be flushed from nest sites and/or

change their foraging behavior due to smoke accumulation. This could cause goshawks to

expend more energy and/or cause them to be detectable to predators during movements. 

Smoke from broadcast burning may disturb individual birds, although this would be a shortterm effect (1-3 days) and of low intensity (drift smoke). Activities would be temporally and

spatially separated, which would reduce overall effect and thus not affect the overall

distribution of northern goshawk. Impacts from smoke would also be reduced by the

coordination of timing and type of burning with wind direction, topography, time of year and

distance to the goshawk nesting area.

Effects from Ground Disturbance

In addition to thinning and burning cable corridors and temporary road construction would be 

required to implement this alternative. Table 123 summarizes the acres of cable corridors, 

temporary roads and road relocations that are proposed in northern goshawk habitats. 

Table 123: Alt. 2 - Cable Corridors (Acres) and Temporary Roads (Miles) in NOGO Habitat

PFA Name Acres with 

Skyline/

Excaline 

Harvest Method 

in PFA

Acres with 

Skyline/Excaline 

Method in Nest

Areas

Acres of 

Cable 

Corridor in 

PFA

Miles of Temp 

Road/Road 

Relocation in PFA

Miles of 

Temp 

Road/Road 

Relocation in 

Nest Areas

DLH 60 0 8 1.4/.9 .4/.5

Mormon Mtn. 0 0 0 .3/.3 .18/0

Total in PFAs 60 0 8 1.7/1.2 .5/.5

Outside of 

PFAs 

DLH – 182*

MM- 0

N/A 39* DLH - 15.6/.23

MM – 3.51/.24

N/A

*Acres outside of MSO habitat.

Prescribed burning, thinning, temporary road construction and rehabilitation and corridor 

construction may indirectly affect the goshawk by changing the goshawks habitat structure

(snags, downed logs, woody debris, vegetative structural stages, and dense canopy cover). In 

addition, the proposed activities may change the structure of goshawk prey species’ habitat,

affecting the abundance and composition of prey species. Although treatments, especially

prescribed burning, may have adverse effects to prey species and their habitat in the short-term

(generally one year, depending on climate and moisture), the proposed treatments may increase

diversity of vegetative conditions, which would provide for a diverse prey base. Overall this 

would have an indirect beneficial impact on goshawks.

Effects from Noise Disturbance

Disturbance to raptors and in many instances can cause nest abandonment or changes in home 

range (Anderson et. al. 1990). Monitoring of motorized use on northern goshawk, however, has 

showed very little effect on individual goshawks, causing biologists to consider motor vehicle use 

a “minor stressor” (Slausen and Zielinski 2008). A noise study on goshawks conducted by Grubb 

et al. (1998) found that logging trucks did not elicit a discernible response when they passed 

within 0.3 mile (500 meters) of active nests. However, in an experimental study on the Kaibab 

NF, Grubb et al. (2012) found no evidence that the awareness of noise generated from logging 

trucks was correlated with actual negative effects to nesting northern goshawks. The observed 
Chapter 3: Affected Environment and Environmental Consequences

330 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

response from nesting goshawks was limited to, at most, looking in the direction of the hauling 

road (Grubb et al. 2012). Noise disturbance could be caused by project implementation activities 

including thinning and burning, road construction and maintenance, hauling of logs to areas 

outside of the project, and road rehabilitation. Noise from mechanical treatments are not likely to

directly affect nesting goshawks as no thinning would occur within nest stands during the 

breeding season. Implementation would be designed to limit disturbance in each PFA to two 

breeding seasons to reduce the duration of disturbance.

Cumulative Effects

There are additional indirect effects from vegetation modification activities occurring in other 

projects, including hazard tree removal for powerlines and highways, as well as tree removal for

development of state and private lands. Grazing can temporarily reduce vegetative cover. The 

DLH area is currently deferred from grazing. The MM area is managed on deferred rotational and 

deferred rest rotation grazing systems designed to allow forage a chance to recover from 

livestock grazing, reducing the potential for cumulative impacts. Generally, projects are designed 

to move toward the desired conditions for northern goshawks as identified in the Forest Plan.

Cumulatively, these projects and activities may impact northern goshawks but are not likely to

cause a trend toward listing or loss of viability.

Determination of Effect

Although there are many positive effects, Alternative 2 would also have some negative effects to 

northern goshawk. Alternative 2 would largely benefit goshawks by improving habitat and 

moving toward a more uneven-aged structure with greater understory composition and reduced 

fire behavior. However, the loss of snags within drainages in the Orion PFA for corridor 

construction and the loss of snags in LOPFAs would have a minimal negative impact to 

important habitat components. Hauling activities on main haul routes could occur within 0.3 

mile of nest stands, potentially impacting nesting goshawks within the Schultz and Thicket 

PFAs. Thinning activities in PFAs during the breeding season could impact nesting however; 

disturbance would be limited to two breeding seasons. Project activities may impact northern

goshawks but are not likely to cause a trend toward listing or loss of viability.

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Effects to northern goshawk habitat would be similar to those described under Alternative 2 in 

that the treatments and desired conditions would be the same; however the distribution of snags 

and large trees would be more consistent due to the absence of proposed cable corridors. 

Treatments would utilize ground-based harvesting across the majority of the project area, with 

helicopter logging for critical areas that are too steep, rocky or inaccessible to be treated with 

steep-slope machinery. Helicopter logging would occur in the Orion PFA under this alternative, 

which would remove all snags on steep slopes within the 39 acres of the PFA. In addition, snags 

would also be removed in areas LOPFAs where helicopter logging is proposed. A design feature 

would require biologists to identify patches of snags up to 10 acres in size to allow for retention 

of some snags in these areas. Not taking into account these patches, there would be approximately 

1,251 acres of LOPFAs where all snags could be removed to provide for safety.

The use of helicopter logging would require landings where trees are processed at the landing 

area with a processor. Helicopter paths would be reviewed to exclude flights over occupied nest 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 331

locations during the northern goshawk breeding season (see Design Features specific to 

Alternative 3).

Under Alternative 3, there would be fewer miles of temporary roads needed within PFAs and 

LOPFAs than for Alternative 2 (see Table 123 for Alternative 2 and Table 124 for Alternative 3), 

reducing short term ground disturbance in these habitats. 

Table 124: Alt. 3 - Miles of Temporary Roads in NOGO Habitat

Area Miles of Temp Road/Relocated 

Road in PFAs

Miles of Temp Road/Relocated 

Road in Nest Areas

Acres Harvested by 

Helicopter

Dry Lake 

Hills 1.1/.9 .2/.5 39

Mormon 

Mtn. .3/.3 .2/0 0

Total in 

PFAs .9/1.2 .4/.5 39

Outside of 

PFAS

DLH – 11.1/.2

MM – 2.4/.2 N/A 1,251

Cumulative Effects

The cumulative effects are the same as in Alternative 2.

Determination of Effect

Although there are many positive effects, Alternative 3 would also have some negative effects to 

northern goshawk. Alternative 3 would largely benefit goshawks by improving habitat and 

moving toward a more uneven-aged structure with greater understory composition and reduced 

fire behavior. However, the loss of snags within the Orion PFA for safety purposes in areas 

harvested by helicopter would have a minimal negative impact to important habitat components. 

Helicopter operation could occur within the Orion PFA during the breeding season. Hauling 

activities on main haul routes could occur within 0.3 mile of nest stands, potentially impacting

nesting goshawks within the Schultz and Thicket PFAs. Project activities may impact northern

goshawks but are not likely to cause a trend toward listing or loss of viability.

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Alternative 4 would treat 73 acres less in PFA habitat than the other action alternatives. This 

alternative would not include treating within the Orion PFA; only those treatments previously 

approved through the Jack Smith Schultz Forest Health and Fuels Reduction project would occur. 

There would also be 4,100 acres that would not be treated, and therefore those acres would not be 

developing toward a more uneven-aged structure. 
Chapter 3: Affected Environment and Environmental Consequences

332 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Effects from Ground Disturbance 

Ground disturbance would be primarily from mechanical operations, construction of landings and 

temporary roads. Table 125 summarizes the miles of temp roads and road relocations in northern 

goshawk habitats. 

Table 125: Alt. 4 - Miles of Temporary and Relocated Roads in NOGO Habitat

PFA Name Miles of Temp Road/Relocated Road in 

PFAs

Miles of Temp Road/Relocated Road in Nest

Areas

Dry Lake Hills .5/.9 .22/.5

Mormon Mtn. .3/.3 .2/0

Total in PFAs .9/1.2 .4/.5

Outside of 

PFAS

DLH – 9.1/.2

MM – 2.4/.2

N/A

Alternative 4 would not require cable corridors, cable or helicopter logging to accomplish 

thinning treatments reducing the site specific loss of snags. Less area would be treated 

mechanically requiring less ground disturbance than the other action alternatives. The number of 

temporary roads would also be less than the proposed action resulting in less short term 

disturbance to prey habitat. 

Disturbance from Project Implementation

This alternative would have the least amount of disturbance from project implementation. There 

would be no disturbance from helicopter operations, steep-slope machinery or cable logging 

operations. Although the same haul routes would be used, fewer vehicle trips would be required 

and the duration of the project would be shorter than the other action alternatives.

Cumulative Effects

Cumulative effects are the same as Alternative 2 and 3, but to a lesser degree due to fewer acres 

being treated. 

Determination of Effect

Although there are many positive effects, Alternative 4 would also have some negative effects to 

northern goshawk. Alternative 4 would largely benefit goshawks by improving habitat and 

moving toward a more uneven-aged structure on treated acres with greater understory 

composition and reduced fire behavior. Hauling activities on main haul routes could occur 

within 0.3 mile of nest stands during the breeding season, potentially impacting nesting 

goshawks within the Schultz and Thicket PFAs. Project activities may impact northern

goshawks but are not likely to cause a trend toward listing or loss of viability.

American Peregrine Falcon

Analysis Methods

The following evaluation criteria were used to compare environmental consequences for all

alternatives:

Prey species habitat

Disturbance from project implementation
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 333

Affected Environment

The essential habitat for peregrine falcon includes rock cliffs for nesting and a large foraging

area. Suitable nesting sites on rock cliffs have a mean height of 200 to 300 feet. The MM area 

lacks steep cliff sites potentially suitable for nesting by this species. The DLH area includes one 

eyrie within the project, northwest of the Devils Head communication facility, and another 

approximately 0.6 mile east of the project area on the southern face of Mt. Elden. Peregrines 

prey mainly on birds found in wetlands, riparian areas, meadows, parklands, croplands, 

mountain valleys, and lakes within a 10 to 20 mile radius from the nest site. Peregrines likely

forage in the DLH area. Prey species include bats, mammals and birds. The peregrine breeding

season is from March 1 to August 15.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Under the No Action Alternative, there would be no direct or indirect effects to peregrines. There

would be no change to the prey species base, and no change in falcon hunting patterns within 

associated forest structure.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to peregrine falcon habitat and 

adjacent forest lands. The cumulative effects of the No Action Alternative would be to increase

the number of acres of National Forest System lands that are vulnerable to severe fire effects, as 

dense forest conditions would continue to place peregrine falcon habitat and adjacent habitat at 

risk of stand-replacing fire. The fire hazard would increase over time as vegetation would 

continue to grow, fuel would continue to accumulate, and the impacts of climate change would 

continue to affect forest health, thus continuing to have negative effects to peregrine falcon.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Peregrines could be directly impacted if project activities disturb breeding birds. No treatments are 

proposed at the peregrine eyrie within the project, and direct effects from thinning or burning are 

not expected because no thinning or burning activities would take place within one-quarter mile of 

an active eyrie during the breeding season (see Design Features). No direct or indirect effects are 

expected to the East Elden eyrie due to the distance from the project and the location of the eyrie 

in an area where smoke is not anticipated to settle. 

Under Alternative 2, there would be indirect effects from the modification of vegetation. Thinning 

could adversely affect the prey base on a short-term basis by impacting individuals of prey species

due to disturbance of prey species’ habitat and harm from fire. However, over the long- term, an 

increased diversity of vegetative structural stages and improved understory vegetation would 

increase prey species, resulting in indirect beneficial impacts. Thinning of the forest would 

increase sight distance for foraging peregrine falcons, which facilitates hunting conditions, 

resulting in an indirect beneficial impact.
Chapter 3: Affected Environment and Environmental Consequences

334 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Cumulative Effects

Under Alternative 2, there would be an additive effect from activities that modify vegetation. 

Other projects where thinning occurs could affect the prey base on a short-term basis by

impacting individuals of prey species due to disturbance of prey species’ habitat and harm from 

fire. However, projects would be implemented at different times and different locations, thus

disturbances to the prey base would be minimized. An additional cumulative effect includes 

unmanaged climbing in areas where peregrine falcons are known to nest. In the last ten years, 

rock climbing has doubled, which could result in peregrine nesting success. Cumulatively, these

projects and activities may impact peregrine falcons but are not likely to cause a trend toward 

listing or loss of viability.

Determination of Effect

The project’s activities may impact individuals but is not likely to cause a trend toward listing or 

loss of viability.

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Effects to peregrine falcon habitat are similar as those discussed for Alternative 2 in that the 

treatments and desired conditions would be the same; however the distribution of snags and large 

trees would be more consistent due to the absence of proposed cable corridors. Treatments would 

utilize ground-based harvesting across the majority of the project area, with helicopter logging for 

critical areas that are too steep, rocky or inaccessible to be treated with steep-slope machinery. 

As a result of harvesting by helicopter, snags would be removed from 972 acres of foraging 

habitat, which could affect the distribution of bats, birds and small mammals. However this 

would have little impact to peregrines due to the large area available for foraging in the 10-20 

mile radius of the known nest sites. 

The use of helicopter logging would require landings where trees are processed at the landing 

area with a processor. Ellis and Ellis (1991) indicate that buffer zone of 500-m (1638ft) or less

for helicopter overflights would minimize flush response and any potential effects on nesting 

habitat. The recommendation of no activities within one-quarter mile of an occupied eyrie would 

include helicopter use to limit disturbance to nesting birds. An implementation guide would be 

developed prior to implementation to ensure helilandings and helicopter flight patterns limit 

disturbance to nesting peregrines (see Design Features).

Cumulative Effects

Cumulative effects are the same as Alternative 2.

Determination of Effect

The project’s activities may impact individuals but is not likely to cause a trend toward listing or 

loss of viability.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 335

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Effects to peregrine falcon habitat would be similar as the other action alternatives; however there 

would be a total of 3,459 acres of vegetation treatment in peregrine falcon habitat within the DLH 

area, 2,504 acres less than the other action alternatives. The distribution of snags and large trees 

would be more consistent due to the absence of cable corridors and areas harvested by cable or 

helicopter logging. 

Under Alternative 4, there would be less foraging habitat with improved vegetative structural 

stages and understory diversity, although there would still be an indirect beneficial affect for 

peregrines.

Cumulative Effects

Cumulative effects are the same as Alternative 2, though to a lesser degree as fewer acres would 

be treated.

Determination of Effect

The project’s activities may impact individuals but is not likely to cause a trend toward listing or 

loss of viability.

Navajo Mogollon Vole

Analysis Methods

The following evaluation criteria were used to compare environmental consequences for 

alternatives:

Amount and distribution of habitat

Disturbance from project implementation

Affected Environment

Navajo Mogollon voles occupy meadows and riparian areas above the Mogollon Rim associated 

with ponderosa pine or other coniferous forests. They also occur within forested areas where tree

densities are low. They rely on grasses and other herbaceous vegetation for food or cover. Vole

runways have not been documented in the project area; however, vole populations likely occur in 

the project area. Potentially suitable habitat within the project area is currently 60 acres of

grassland habitat, and any openings within the ponderosa pine and mixed conifer.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Under the No Action Alternative, there would be no disturbance and no direct effects. Although 

habitat would continue to be provided for this species, most of the forested area within the project 

is currently in a moderately-closed to closed condition, which provides low quality habitat for the

Mogollon vole. Under the No Action Alternative, openings would not be created and canopy 
Chapter 3: Affected Environment and Environmental Consequences

336 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

closure would not be reduced, thus there would no benefits to the vole. Favorable habitat would 

decrease over time as conifers encroach into meadows and canopy closure increases, resulting in 

an indirect adverse effect. In addition, high fire hazard potential would persist, and a large crown 

wildfire event would have the potential to affect many individuals.

Loss of vegetative cover removes food and shelter for voles and this alternative would have the 

highest level of loss or degradation in grasslands and vegetation types used by this vole. 

Cumulative Effects

The No Action Alternative would maintain the current fire risk to vole habitat and adjacent forest 

lands. The cumulative effects of the No Action Alternative would be to increase the number of 

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest 

conditions would continue to place vole habitat and adjacent habitat at risk of stand-replacing fire.

Climate change would continue to contribute to this risk. The fire hazard would increase over

time as vegetation would continue to grow and fuel would continue to accumulate, continuing to 

have a negative effect on Navajo Mogollon vole.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, thinning and broadcast burning and ground disturbing activities may disturb 

individual voles, resulting in direct adverse effects. Broadcast burning, harvest activities, 

temporary road construction and corridors would result in the removal of cover and food; it is 

anticipated that grasslands, open areas and rehabilitated roads would rebound afterwards, with 

more vigorous herbaceous vegetation and healthier understory habitats. Additionally, such

activities would occur across the project area at different times; thereby reducing impacts to this 

species. In addition, the effect would be short-term, generally one year, depending on climate and 

moisture. The reduction of dense forest canopy and increased growth in the herbaceous vegetation 

on the forest floor would result in indirect beneficial impacts to the vole. Forest conditions after 

treatment would improve vole habitat within the project area.

Temporary roads construction would disturb four acres of grassland habitat, and the designation 

of use for administrative purposes would continue to permanently reduce the quality of this 

unique habitat for voles. 

This alternative would provide the most habitats for voles than the other alternatives due to the 

proposed treatments in mixed conifer and ponderosa pine opening the canopy, and also the 

creation of cable corridors, which would provide additional food and cover for voles.

Cumulative Effects

Recreation (e.g., hiking, biking, and camping) and road travel pose an adverse effect to voles due

to soil and vegetation disturbance and soil compaction. This would combine with the Mount 

Elden Dry Lake Hills Recreation Planning Project’s proposed action to reduce vole habitat. 

Recreational activities would continue to occur in the project area, resulting in decreased habitat 

for voles; however, forest management practices that promote herbaceous growth could lead to 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 337

increased vole populations. There are additive effects of reduction of understory vegetation by 

livestock grazing in the MM area. Livestock grazing would combine with short-term loss of 

understory vegetation from burning and harvest activities. The MM area is managed on a deferred 

rotational and rest rotational grazing system designed to allow forage a chance to recover from 

livestock grazing, reducing the potential for cumulative effects. Development of private and state 

land has the greatest potential impact to vole habitat. Cumulatively, these projects and activities

may impact the Navajo Mogollon vole but are not likely to cause a trend toward listing or loss of 

viability.

Determination of Effect

Although there are many positive effects, Alternative 2 would have some short term negative 

effects to Mogollon vole. The project’s activities may impact individuals but is not likely to cause

a trend toward listing or loss of viability.

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Effects to Mogollon vole habitat are similar to those described for Alternative 2 in that the 

treatments and desired conditions would be the same; however there would be fewer openings

due to the absence of proposed cable corridors. Treatments would utilize ground-based harvesting 

across the majority of the project area, with helicopter logging for critical areas that are too steep, 

rocky or inaccessible to be treated with steep-slope machinery. No cable logging would occur 

under this alternative, which would reduce the need to remove the large trees and logs on steep 

slopes and also the need to create corridors. Large snags cut for safety would be left on site, 

improving habitat. As with Alternative 2, this alternative would permanently impact four acres of 

grassland habitat with construction of a temporary road and the designation to maintain it for 

administrative use.

This alternative would provide more vole habitat than Alternative 1 but less than Alternative 2 as 

additional habitat would not be produced by creating corridors. 

Cumulative Effects

Cumulative effects are the same as Alternative 2.

Determination of Effect

Although there are many positive effects, Alternative 3 would have some short term negative 

effects to Mogollon vole. The project’s activities may impact individuals but is not likely to cause

a trend toward listing or loss of viability.

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Effects to Mogollon vole habitat are similar to those discussed for Alternatives 2 and 3; however 

there would be fewer openings due to the absence of proposed cable corridors. This alternative 

would treat 3,080 acres less habitat than the other action alternatives, including seven less acres 

of grassland treatment, and so providing the least habitat improvement for this vole. As discussed 
Chapter 3: Affected Environment and Environmental Consequences

338 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

under the other action alternatives, Alternative 4 would permanently impact four acres of 

grassland habitat with construction of a temporary road and the designation to maintain it for 

administrative use.

Cumulative Effects

Cumulative Effects

Cumulative effects are the same as Alternative 2 and 3.

Determination of Effect

Although there are many positive effects, Alternative 4 would have some short term negative 

effects to Mogollon vole. The project’s activities may impact individuals but is not likely to cause

a trend toward listing or loss of viability.

Allen’s Lappet-browed Bat, Pale Townsend’s Big-eared Bat

Analysis Methods

The following evaluation criteria were used to compare environmental consequences for all

alternatives:

Amount and distribution of habitat

Disturbance from project implementation

Affected Environment

Surveys of two tanks within the project area were completed the summer of 2013 with eleven

different bat species captured. Allen’s lappet-browed bats and Pale Townsend’s big-eared bats

were not detected during these efforts. Townsend’s big-eared bats were documented to use caves 

on the Flagstaff and Red Rock Districts; however no roosts were located within the project area. 

There are two documented caves within the DLH area; however no bat use has been recorded. 

Townsend’s big-eared bats were not documented using ephemeral trees/snags as roosts on the

Coconino, although they likely do. 

Suitable habitat for Allen’s lappet-browed bat would be large snags used for roosting and

foraging habitat including areas with water and insects. The presence and regeneration of snags

and/or dead and dying trees with loose bark, dispersion of habitat types and structure within 

habitat including openings, montane meadows, or openings with wet soils with diverse vegetative 

herbaceous ground cover and species composition to support prey items. Pools, tanks, and 

openings with wet ground also support prey. Potential habitat for Allen’s lappet-browed bats and 

Pale Townsend’s big-eared bats include approximately 6,260 acres of ponderosa pine, 4,169 acres 

of mixed conifer and 60 acres of grassland within the FWPP.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Under the No Action Alternative, there would be no disturbance and no direct effects to these bat 

species. Low-quality habitat would still exist for these species; however, the high fire hazard 

potential would persist, and a large crown wildfire event could have the potential to affect 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 339

individuals, resulting in indirect adverse effects. Under the No Action Alternative, there would be

no disturbance and no direct effects.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to bat habitat and adjacent forest 

lands. The cumulative effects of the No Action Alternative would be to increase the number of

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest

conditions and the effects of climate change would continue to place bat habitat and adjacent 

habitat at risk of stand-replacing fire. The fire hazard would increase over time as vegetation 

would continue to grow and fuel would continue to accumulate, continuing to have a negative

effect to Allen’s lappet-browed and Pale Townsend’s big-eared bats.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, thinning and broadcast burning activities could potentially disturb bats if 

they are roosting in snags within the project area. Allen’s lappet-browed bats rely on snags for 

ephemeral roosts and are thought to select taller snags closer to forest roads as maternity roosts, 

and so are vulnerable to increased harvest of these structures along roads, (Solvesky and 

Chambers 2009, Wisdom and Bate 2008). 

Roughly 241 acres of potential roosting habitat would be denuded by cable corridors under this 

alternative. This alternative would result in the greatest decrease in snags by cutting cable 

corridors, removing snags for safety and burning on the most acres. These effects would

primarily result in effects of localized extent. The physical appearance of corridors may provide 

similar habitat characteristics of roads for bats and may provide additional habitat for this 

species. The reduction of dense forest canopy and creation of edges by creating corridors would 

increase growth in herbaceous vegetation on the forest floor, resulting in indirect beneficial 

impacts to bats. Maintaining or creating snags post-implementation in key areas along openings 

and corridors may provide additional habitat for this bat. Forest conditions after treatment would 

improve bat habitat within the project area. 

Cable logging requires that all hazard trees are removed from the entire area that is cable logged 

to provide for safety of personnel on the ground outside of protected machinery. A design feature 

requires biologists to identify patches of snags up to 10 acres in size to allow for retention of 

some snags in these areas. Not taking into account these patches, there would be approximately 

1,049 acres in potential bat roosting habitat where all snags could be removed to provide for 

safety.

Overall, the project is designed to grow trees into larger size classes, providing more 

recruitment snags over the long term. Snag densities on a project-level scale would not change 

considerably. Alternative 2 would reduce bat roosting habitat, but at the same time would 

create more improved foraging habitat than Alternative 4. Snags in key areas such as south and 

southwestern slopes in the DLH would not change for any of the alternatives as no treatments 

are proposed in these areas. 

Alternative 2 is expected to result in a slight short-term decrease in snags followed by an increase

over the long-term at the project level, but with a long-term decrease of snags in corridors and 

areas harvested by cable logging. Snags and recruitment snags would be removed to create 

corridors and snags would be removed in areas harvested by cable logging. However this loss of 
Chapter 3: Affected Environment and Environmental Consequences

340 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

snags is not expected to affect the overall distribution of Allen’s lappet-browed bats and Pale 

Townsend’s big-eared bats on the forest.

Broadcast burning would result in the removal of cover and food; however it is anticipated that 

meadows and open areas would rebound afterwards with more vigorous herbaceous vegetation 

and healthier understory habitats. 

Under Alternative 2, there would be indirect effects from the modification of vegetation. 

Thinning, burning, construction of temp roads and corridors could adversely affect the prey base 

on a short-term basis by impacting individuals of prey species due to disturbance of prey species’

habitat and harm from fire. However, over the long- term, an increased diversity of vegetative 

structural stages and improved understory vegetation would increase prey species, resulting in 

indirect beneficial impacts.

Cumulative Effects

Ungulate grazing within the project area reduces understory vegetation, which reduces plant 

availability to adult insects, a primary food source. The Dry Lake Hills has been deferred from 

grazing and has not been grazed by cattle in over 10 years. The Mormon Mountain project area 

is managed on deferred rotational and deferred rest rotation grazing systems designed to allow 

forage a chance to recover from livestock grazing, reducing the potential for cumulative impacts. 

Other projects that may add to the loss of snags include powerline maintenance and removal of 

hazard trees along roads and trails. Cumulatively, these projects and activities may impact 

Allen’s lappet-browed bats or Pale Townsend’s big-eared bats, but are not likely to cause a trend 

toward listing or loss of viability.

Determination of Effect

Although there are positive effects, Alternative 2 would also have some negative effects. 

Alternative 2 would largely benefit Allen’s lappet-browed bats and Pale Townsend’s big-eared 

bats by improving understory diversity and increasing prey habitat across the project. There 

would be a loss of snags and recruitment snags in concentrated areas where corridors are 

constructed and areas are harvested by cable logging; however at a project level, snag loss would 

be minimal. The project’s activities may impact individuals but is not likely to cause a trend 

toward listing or loss of viability.

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Effects to Allen’s lappet-browed bat and Pale Townsend’s big-eared bat habitats are similar as 

under Alternative 2; however the distribution of snags and large trees would be more consistent 

due to the absence of proposed cable corridors. Treatments would utilize ground-based harvesting 

across the majority of the project area, with helicopter logging for critical areas that are too steep, 

rocky or inaccessible to be treated with steep-slope machinery. There would be 972 acres 

harvested by helicopter logging in Allen’s lappet-browed and Pale Townsend big-eared bat

habitat, which would reduce snags on steep slopes and reduce potential roosting habitat. This loss 

of snags is not expected to affect the overall distribution of these bat species on the forest.

Alternative 3 would provide slightly less bat roosting habitat than Alternative 1 and more than 

Alternative 2 as no cable corridors would be required. On the other hand, this alternative would 

create less foraging habitat than Alternative 2 with reduced openings for corridors. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 341

Cumulative Effects

Cumulative effects are the same as Alternative 2.

Determination of Effect

The project’s activities may impact individuals but is not likely to cause a trend toward listing or 

loss of viability.

Alternative 4: Minimal Treatment

Direct & Indirect Effects

This alternative would treat approximately 3,118 fewer acres of habitat than the other actions 

alternatives, providing the least habitat improvement for these bat species by limiting the ability 

to create openings within the forest canopy to provide for more understory diversity in both the 

ponderosa pine and mixed conifer habitats. Cable and helicopter logging would not occur, 

reducing the number of snags needed to be cut for safety purposes and thereby reducing the 

potential for site specific impacts.

Cumulative Effects

Cumulative effects are the same as Alternative 2 and 3, but to a slightly lesser degree as fewer 

acres would be treated.

Determination of Effect

Although there are mostly positive effects, Alternative 4 would also have some negative effects. 

Alternative 4 would largely benefit Allen’s lappet-browed bats and Pale Townsend’s big-eared 

bats by improving understory diversity and increase prey habitat across the project where 

treatments are proposed. The project’s activities may impact individuals but is not likely to cause

a trend toward listing or loss of viability.

Spotted Bat

The following evaluation criteria were used to compare environmental consequences for 

alternatives:

Amount and distribution of habitat

Disturbance from project implementation

Affected Environment

Roost site characteristics are poorly known for this species, but limited observations suggest that 

spotted bats roost singly in crevices, with rocky cliffs and surface water characteristic of localities 

where they occur. It has been found from low desert areas in southwestern Arizona to high desert 

and riparian habitat in the northwestern part of the state. It has also been found in conifer forests 

in northern Arizona (Kaibab Plateau) and other western states. There are no roost locations 

known to occur on the Forest. This species is a habitat generalist and could forage across the 

entire Forest.
Chapter 3: Affected Environment and Environmental Consequences

342 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Under the No Action Alternative, there would be no disturbance and no direct effects.

Low-quality foraging habitat would still exist for this species; however, the high fire hazard 

potential would persist, and a large crown wildfire event could have the potential to affect 

individuals, resulting in indirect adverse effects.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to bat habitat and adjacent forest 

lands. The cumulative effects of the No Action Alternative would be to increase the number of

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest

conditions would continue to place bat habitat and adjacent habitat at risk of stand-replacing fire. 

The fire hazard would increase over time as vegetation would continue to grow and fuel would 

continue to accumulate, continuing to have a negative effect to spotted bat.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, disturbance to the spotted bat from thinning and prescribed burning

activities is highly unlikely. Isolated occurrences of disturbance may impact individuals but 

because this bat roosts singly, proposed activities would not have an impact on an entire 

colony of spotted bats. 

Broadcast burning would result in the removal of cover and food; however it is anticipated that 

meadows and open areas would rebound afterwards, with more vigorous herbaceous vegetation 

and healthier understory habitats. Indirect effects would result from vegetation modification 

activities such as thinning and prescribed burning and ground disturbing activities (cable 

corridors, temporary roads and landings). These activities would disturb or remove understory

vegetation, subsequently reducing availability to insects. These effects would be short-term 

and would be minimized due to activities being temporally and spatially separated. In contrast, 

reducing canopy closure, removing trees in corridors and creating edges, restoring meadows 

and broadcast burning would encourage the development of understory vegetation, increasing

availability of food for the bat over the long-term. 

Cumulative Effects

The cumulative effects area considered includes the project area and all projects (past, present and 

reasonably foreseeable) that are within the project area that have the potential to impact spotted

bats were analyzed. Ungulate grazing within the project area reduces understory vegetation, 

which reduces plant availability to adult insects, a primary food source. Approximately half of the

project area is currently not being grazed by livestock and the remainder is managed on a

rotational grazing system designed to allow forage a chance to recover from livestock grazing,

reducing the potential for cumulative impacts. Cumulatively, these projects and activities may

impact spotted bat but are not likely to cause a trend toward listing or loss of viability.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 343

Determination of Effect

Although there are mostly positive effects, Alternative 2 would also have some short-term 

negative effects from disturbance during implementation. Alternative 2 would largely benefit 

spotted bat by improving understory diversity and increase prey habitat across the project. The

project’s activities may impact individuals but is not likely to cause a trend toward listing or loss 

of viability.

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Effects to spotted bat habitat are similar as under Alternative 2; however the distribution of snags 

and large trees would be more consistent due to the absence of proposed cable corridors. 

Treatments would utilize ground-based harvesting across the majority of the project area, with 

helicopter logging for critical areas that are too steep, rocky or inaccessible to be treated with 

steep-slope machinery. Helicopter logging would be used on steep slopes which would require 

the removal of snags on approximately 972 acres of spotted bat foraging habitat, all within the 

DLH area. 

Cumulative Effects

Cumulative effects are the same as Alternative 2.

Determination of Effect

Although there are mostly positive effects, Alternative 3 would also have some negative effects. 

Alternative 3 would largely benefit spotted bats by improving understory diversity and increase 

prey habitat across the project. The project’s activities may impact individuals but is not likely to 

cause a trend toward listing or loss of viability.

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Effects to spotted bat habitats are similar as Alternative 2 and 3; however there would be no 

helicopter or cable logging, so there would be no added effect from the loss of snags within these 

areas. 

Cumulative Effects

Cumulative effects are the same as Alternative 2 and 3, but to a slightly lesser degree as fewer

acres would be treated.

Determination of Effect

Although there are mostly positive effects, Alternative 4 would also have some negative effects. 

Alternative 4 would largely benefit spotted bat by improving understory diversity and increase 

prey habitat across the project. The project’s activities may impact individuals but is not likely to 

cause a trend toward listing or loss of viability.

Northern Leopard Frog

The following evaluation criteria were used to compare environmental consequences for 

alternatives:
Chapter 3: Affected Environment and Environmental Consequences

344 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Impacts to potential habitat

Affected Environment

There are no known existing or historic locations of northern leopard frogs within the project, 

though livestock tanks in the project area provide potential habitat for northern leopard frogs 

throughout the year. According to the Coconino National Forest Natural Resource Information 

System database (NRIS), there are three waters with potential habitat for leopard frogs: Schultz

Tank, Pushout Tank, and Weimer Spring. Dry Lake Tank, within the project area but located on 

private land, may provide additional habitat. Because of the high potential for northern leopard 

frogs near the Mormon Lake area, tanks and springs within one-half mile of the Mormon Lake 

project and within the project’s watershed were surveyed in 2013. Of the 44 tanks surveyed, one 

tank, within a half mile of the MM area, was found to have northern leopard frogs present. 

Chytrid fungus and non-native predators have been identified as major mechanisms causing 

declines in northern leopard frogs across their range.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Under the No Action Alternative, habitat conditions for wildlife would remain in their current

condition, notwithstanding natural processes. The No Action Alternative would have no direct

effect on northern leopard frog. However, dense forest conditions would still occur and the high 

fire hazard potential would persist. Large crown-wildfires could adversely affect potential habitat 

by destroying understory and overstory vegetation. As a result overland flow would increase, and 

soil erosion would increase with potentially high sediment loads. Water quality would be

adversely affected on a wide-scale basis, and potentially in occupied habitat within the Mormon 

Mountain/Lower Lake Mary Watershed, resulting in indirect adverse effects.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to northern leopard frog habitat 

and adjacent forest lands. The cumulative effects of the No Action Alternative would be to 

increase the number of acres of National Forest System lands that are vulnerable to severe fire

effects, as dense forest conditions would continue to place frog habitat and adjacent habitat at risk 

of stand-replacing fire. The fire hazard would increase over time as vegetation would continue to

grow and fuel would continue to accumulate, continuing to have an adverse effect to northern 

leopard frog. 

Effects Common to All Action Alternatives

Direct & Indirect Effects

Under Alternatives 2, 3 and 4, there would be no direct effects to northern leopard frog eggs, 

larvae, or adults from project activities as leopard frogs are not present within the project, and 

implementation of soil and watershed best management practices (BMPs) would curtail soil 

erosion and minimize inflow into potential leopard frog habitat. Indirect effects would be from 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 345

reducing the potential for stand-replacing wildfire within the MM area and thereby reducing the 

potential of adverse impacts to leopard frog habitat within the Lower Lake Mary Watershed.

Cumulative Effects

Alternatives 2, 3 and 4 would add to other past and reasonably-foreseeable projects within the 

Lower Lake Mary Watershed that have or are planned to reduce the potential for stand-replacing 

wildfires, thereby reducing the potential for adverse effects from increased overland flow and soil 

erosion with potentially high sediment loads in potential and occupied habitat within the Lower 

Lake Mary Watershed, resulting in indirect beneficial effects.

Determination of Effect

The action alternatives would largely benefit northern leopard frogs by reducing the potential for 

stand replacing wildfires, thereby reducing the potential adverse effects to habitat. Although 

project activities could cause increased soil erosion with potential sediment loads in potential and 

occupied habitat, BMP’s would curtail soil erosion and minimize effects. The project’s activities 

may impact northern leopard frog but would not lead to a trend to listing or loss of viability. 

Snags and Logs

Snags and logs are important elements of the structure and function of ponderosa pine, mixed 

conifer and aspen, and are also important to bird and small mammal communities. 

Analysis Methods

The following evaluation criteria were used to compare environmental consequences for 

alternatives:

Snag and log densities 

Snag and log locations

Forest Plan Standards and Guidelines

For areas outside of PFAs (snags are 18” or larger dbh and 30’or larger in height, logs are 12” dbh 

and at least 8’ in length)

Ponderosa pine - Leave at least 2 snags, 3 downed logs, and 5-7 tons of woody

debris per acre.

Mixed conifer, Spruce - fir – Leave at least 3 snags, 5 downed logs and 10-15 

tons of woody debris per acre.

Aspen- Retain trees greater than 12 inches diameter at breast height (dbh) and nest 

trees. Within 10K blocks at least 50 percent of the forested land meets 2 snags per 

acre. In high priority areas including both edge habitats adjacent to meadows or

water and interior stands, manage for an average of 2.8 snags per acre. Provide for 

down woody debris.

For areas within MSO Recovery or Protected habitat:

Retain substantive amounts of snags 18 inches in diameter and larger and down 

logs over 12 inches midpoint diameter

Affected Environment

Project (Ecosystem Management Area)
Chapter 3: Affected Environment and Environmental Consequences

346 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

In 2002 the Forest estimated that trends for snags in ponderosa pine habitats were probably

declining (USDA Forest Service 2002a). However, a recent study by Ganey and Vojta (2007)

conducted on the Coconino and Kaibab National Forests within the ponderosa pine and mixed 

conifer habitats indicates that, at least in the short term, snag numbers are increasing and would

continue to increase and densities of large snags would increase (Ganey and Vojta 2007). Despite

these increases, densities of large snags (greater than 18 inches dbh) would remain below Forest 

Plan guidelines. The models used by Ganey and Vojta provide a useful tool for modeling snag

dynamics at a landscape scale but are not suitable for modeling snag dynamics at the stand level. 

Snag and log data were collected for both the FWPP project areas. Snags greater than 12 inches 

dbh and greater than 18 inches dbh meet Forest Plan standards for the project area.

Cover Type (Mid-Scale)

At the mid-scale level, snags greater than 12 inches dbh meet Forest Plan standards in all cover 

types across the FWPP area; however, snags greater than 18 inches dbh are below standards in the 

mixed conifer and aspen cover types in the DLH and the ponderosa pine cover type in MM. In

ponderosa pine, the average density of snags greater than 18 inches dbh per acre in is 2.1 in the 

DLH and 0.7 in MM. In mixed conifer, the average density of snags greater than 18 inches dbh

per acre is 2.4 in DLH and 9.3 in MM. For aspen, the average density of snags greater than 18

inches dbh per acre is 0.1 in the DLH area; there is no aspen cover type on MM. 

Site/Stand Level (Small Scale)

Snag data was not collected for every stand in the project; however, the data collected shows that 

not all stands meet the Forest Plan guidelines.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Table 126 below summarizes the existing snags (Alt.1) and the change in snag densities for each 

alternative immediately after treatment.

Table 126: Snags/acre > 18" diameter breast height (dbh) and > 12" DBH immediately after 

treatment by alternative

Description Snag Size Alt. 1 Alt. 2 Alt. 3 Alt. 4

Project Area

Dry Lake Hills >12” 6.4 5.1 5.1 5.5

>18” 2.2 2.2 2.1 2.2

Mormon Mountain >12” 10.6 10.1 10.5 10.8

>18” 3.6 3.5 3.7 3.7

Cover Type Dry Lake Hills

Ponderosa Pine >12” 3.6 3 3.2 3.3

>18” 2.1 1.9 1.9 1.8

Mixed Conifer >12” 8.8 7.4 6.8 8.4

>18” 2.4 2.4 2.3 2.6

Aspen >12” 19.9 19.9 19.9 19.9

>18” .1 .1 .1 .1

Cover Type Mormon Mountain Ponderosa Pine >12” 3.9 4.6 4.6 4.6
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 347

Description Snag Size Alt. 1 Alt. 2 Alt. 3 Alt. 4

>18” .7 .7 .7 .7

Mixed Conifer >12” 23.4 20.9 22.2 22.4

>18” 9.3 8.4 9 9

Wet Mixed Conifer >12” 25.8 21 21.4 25.8

>18” 12.1 11 11.2 12.1

Under the No Action Alternative, there are no treatment effects. The high fire hazard potential in 

the project area would persist. In the event of a large crown-wildfire, widespread loss of snags

and logs would occur. Generally, snags remaining after a crown-wildfire would have decreased 

longevity and value to wildlife. High tree densities would remain, limiting growth of large

diameter trees and thereby limiting replacement snags and logs.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to snags and logs within the 

project and adjacent forest lands. The cumulative effects of the No Action Alternative would be to 

increase the number of acres of National Forest System lands that are vulnerable to severe fire

effects, as dense forest conditions would continue to place wildlife cover at risk of stand-replacing

fire. The fire hazard would increase over time as vegetation would continue to grow and fuel 

would continue to accumulate.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Snags and logs are important elements of the structure and function of ponderosa pine, mixed 

conifer and aspen, and are important to bird and small mammal communities. Losses of snags and

logs from prescribed burning in ponderosa pine and mixed conifer habitats would occur under this 

alternative; however, snags continue to fall and provide new logs on the forest floor. Fire

damaged trees and recruitment snags would provide additional snags following prescribed fire.

Project Area (Landscape Scale)

Under Alternative 2, both project areas would meet Forest Plan guidelines immediately after 

treatment. Large snags (greater than 18 inches dbh) fall slightly below standards in MM 20 years 

post-treatment. At 40 years post-treatment snags begin to decline slightly for both project areas.

Cover Type (Mid-Scale)

Snags would continue to exceed standards and guidelines post-treatment in MM and would be 

slightly reduced in DLH. 

For ponderosa pine, snags greater than 18 inches dbh would be reduced to just below Forest Plan 

guidelines immediately after treatment in the Dry Lake Hills, with no change in large snag 

densities in the ponderosa pine in Mormon Mountain.

For aspen, the post-treatment density of snags would remain the same immediately after 

treatment and 20 years post-treatment. Within 40 years there would be no aspen snags 

remaining due to loss of snags with no immediate recruitment of larger size classes. 
Chapter 3: Affected Environment and Environmental Consequences

348 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

None of the cover types currently meet the Forest Plan standard for snags at the mid-scale level. 

There may be an additional loss of snags from burning; however, burning may also create new 

snags. Overall the project is designed to grow trees into larger size classes providing more 

recruitment snags over the long term.

Site/Stand (Small Scale)

There would be a direct effect of loss of snags from corridors and a loss of snags from areas 

harvested by cable logging. In ponderosa pine there would be a loss of snags on approximately 

378 acres, and in mixed conifer there would be a loss of snags on approximately 912 acres. 

Design features have been incorporated to provide for patches of snags up to 10 acres in size to 

serve as reserve areas within these units. Additionally, some snags cut for safety purposes would 

be left on site to provide increased logs where needed. This loss of snags would not meaningfully 

affect the average snags per acre on a landscape or project level, but it would have noticeable 

impacts on a site specific level. In addition, there would be a direct effect of loss of snags and

logs during initial entry and maintenance prescribed fire; however, with the anticipated mortality

associated with prescribed burning snags and logs would be created to offset the direct effect

(Fuels and Fire Specialist Report). These effects would be minimized since snags necessary to 

meet wildlife management objectives would be fire-lined or replaced. Loss of large logs would

be minimized though ignition techniques and possibly fire-lining. 

Although fire can have a detrimental effect on pre-burn snags, it can cause live trees to die

and become snags after fire. With the retention of yellow pine trees, recruitment snags and

old growth recruitment site management, some trees would in time naturally convert to snags. 

This natural conversion of snags to logs would contribute to additional numbers of snags and

logs on the ground. The less competition between trees for moisture, nutrients, and sunlight,

the larger they would grow prior to becoming snags. Larger diameter snags (greater than 18

inches dbh) are necessary to meet Forest Plan guidelines. Recruitment snags would be 

identified and retained from live trees that exhibit defects ideal for wildlife. For example, trees 

with spiked-tops, lightning strikes, mistletoe brooms, or fading crowns.

Alternative 2 would have the greatest impact to snags on a site/stand level. 

Cumulative Effects for All Action Alternatives

The cumulative effects boundary is the FWPP project area. Past timber harvest and illegal 

fuelwood activities have reduced snag densities to below Forest Plan recommendations in some

stands. Snags were removed during forest harvest because of potential fire and safety hazards, 

and many thought they had poor aesthetic value and were indicative of an unhealthy forest. Snags 

are especially vulnerable to bark beetle infestation, illegal fuelwood cutting, and ongoing projects 

that remove hazard trees such as APS hazard tree removal along powerlines and telephone lines.

The past outbreak of bark beetle infestations has killed trees thus creating snags, therefore 

increasing snags in pockets across the landscape. However, insect attacks result in rapid 

deterioration of snags, decreasing their longevity and value to wildlife. Some bug-killed trees 

would topple over and become downed logs. Bug killed logs would compensate for a portion of 

the loss of large logs due to burning activities.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 349

Other fuels reduction and forest restoration project are designed to develop larger trees which 

provide recruitment for large snags. These projects would combine with FWPP to provide for 

snags in the long term across the landscape. 

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Project (Landscape) and Cover Type (Mid-scale)

Landscape scale and mid-scale effects to snags are similar to those described under Alternative 2 

in that the described treatments and desired conditions would be the same and the same number 

of acres would be treated. However effects to snags and logs differ between alternatives at the 

stand level. 

Project (Landscape)

Under Alternative 3, both project areas would meet Forest Plan guidelines immediately after 

treatment. Large snags (greater than18 inches dbh) would fall slightly below standards in MM 20 

years post-treatment. At 40 years post-treatment, snags would begin to decline slightly for both 

project areas.

Cover Type (Mid-scale)

Under Alternative 3, ponderosa pine post-treatment snags greater than 12 inches dbh meet Forest 

Plan standards in all cover types across the FWPP area; however, snags greater than 18 inches dbh

would continue to be below standards in the ponderosa pine, mixed conifer and aspen in the DLH

area and the ponderosa pine in the MM area.

For aspen, the post-treatment density of snags would remain the same immediately after 

treatment and 20 years post treatment. Within 40 years there would be no aspen snags 

remaining. 

None of the cover types currently meet the Forest Plan standard for snags or logs at the mid- scale 

level. There may be an additional loss of snags from burning; however, burning may also create 

new snags. Overall the project is designed to grow trees into larger size classes providing more 

recruitment snags over the long term.

Site/Stand (Small Scale)

Alternative 3 would impact snags on a site/stand level due to removal for safety reasons during 

helicopter operations and would not meet Forest Plan standards in some stands immediately after 

treatment. In the long-term (approximately 20- 40 years after treatment) snags would increase as 

trees would in time naturally convert to snags. Recruitment snags would be identified and 

retained from live trees that exhibit defects ideal for wildlife. No cable logging would occur 

under this alternative, which would reduce the need to remove the large trees and snags on steep 

slopes and also the need to create corridors. The areas proposed for harvest by helicopter logging 

would still need to have hazard trees removed. Alternative 3 would treat approximately 972 acres 

with helicopter logging with most snags cut for safety purposes. Design features have been 

incorporated to provide for patches of snags up to 10 acres in size to serve as reserve areas within 

these units. 
Chapter 3: Affected Environment and Environmental Consequences

350 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Project (Landscape) and Cover Type (Mid-scale)

On a landscape and mid-scale level, effects to snags would be similar to those discussed under

Alternatives 2 and 3 in that the treatments would be the same. However Alternative 4 would treat 

approximately 3,136 fewer acres, having less incidental loss from implementation. Direct loss of 

snags would be less than the other action alternatives on a project level and in all cover types 

except ponderosa pine, where snag loss is slightly higher. 

Site/Stand (Small Scale)

Under Alternative 4, there would be only incidental change in snag densities at the site/stand 

level. No cable logging or helicopter logging would occur under this alternative, which would 

reduce the need to remove snags on steep slopes and also the need to create corridors.

Alternative 4 would have the least impact to snags on a site/stand level. 

Wildlife Cover

Hiding and thermal cover are important forest attributes for wildlife habitat. Hiding cover is 

defined as in the Forest Plan as, “vegetation capable of hiding 90% of a standing deer or elk 

from human view at a distance of 200 feet or less.” Tree trunks and foliage as well as shrubs 

and herbaceous vegetation offer hiding cover, as do topographic features, such as rock 

outcroppings and terrain breaks. Thermal cover is defined in the Forest Plan as, “a stand of 

coniferous trees tall enough to allow animal movement and bedding with a high degree of 

crown closure.” Thermal cover offers protection from heat and cold. High tree crown closure 

also provides hiding cover from aerial predators (Forest Plan pg. 124). Combination cover 

includes stands that have both hiding and thermal cover qualities.

Affected Environment

The Forest Plan requires 30 percent cover within Management Area 3 (ponderosa pine and mixed 

conifer on slopes less than 40 percent) and Management Area 4 (ponderosa pine and mixed 

conifer on slopes greater than 40 percent) in a 10K block outside the Urban Rural Influence Zone 

(URIZ) and Wildland Urban Interface 1U (FMAZ 1U). FWPP includes five 10K blocks: Elden, 

Fort Valley, Joys, Pine Grove and Wallace 10Ks. For this project, wildlife cover was analyzed on 

a stand by stand basis across Management Area 3 and Management Area 4 in each of the five 

10K blocks. Key wildlife cover areas are steep slopes and drainages across the project. Oak is 

interspersed throughout the ponderosa pine and provides wildlife hiding cover. Generally the 

multi-storied structural character of mixed conifer provides wildlife a combination of thermal and 

hiding cover. Overall, existing wildlife cover percentages in all five 10K Blocks are greater than 

cover percentages required under Forest Plan direction.

The following evaluation criteria were used to compare environmental consequences for all

alternatives:

Amount of cover

Type of cover (thermal, hiding, and combination)

Location of cover

Analysis Methods
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 351

Wildlife Cover for FWPP was determined with the following information:

Wildlife cover was documented at points along goshawk survey transects across most

of the project area outside of PACs. Points were mapped at most 1000 foot intervals 

along transect that was at most 850 feet apart. Points were offset along neighboring 

transects by 500 feet. At each point, surveyors determined if there was hiding cover, 

thermal cover or a combination of both cover types.

Orthophoto quadrants were overlaid with transect cover data to determine if 

points provided a good representation of the stand vegetative structure.

Topographic maps were reviewed to determine if there were cover effects from 

topographic features and to determine if slopes are inoperable due to steep or rocky

terrain. 

Field examinations were conducted to evaluate cover distribution needs and to 

determine whether other factors contributing to effective cover were present.

Assumptions made to determine cover remaining after treatments:

Ponderosa pine and mixed conifer fuel reduction treatments would retain thermal and 

hiding cover values in 60 percent of the area. The remaining 40 percent could be in 

openings or groups of VSS 3 (9-12-inch dbh trees). Typically trees 9 to 12 inches in 

diameter are not large enough to provide thermal cover and basal area/canopy would be 

reduced to allow for tree growth thereby reducing wildlife hiding cover immediately 

after treatment. In the long-term seedlings and saplings would grow in openings and 

VSS 3 would develop into larger size classes with higher canopies to provide hiding and 

thermal cover. 

MSO PAC treatments would retain both hiding and thermal cover values in 80 percent

of the area.

Wet mixed conifer, MSO nest and recovery nest/roost treatments would retain cover 

values.

Thin from below to 9 inch treatments would retain thermal cover values and remove 

hiding cover values.

Grassland restoration treatments would remove hiding and thermal cover values.

Aspen restoration treatments would remove thermal cover and maintain hiding cover.

Northern goshawk PFA fuels reduction treatments would retain hiding and thermal 

cover values in 70 percent of the area.

Goshawk nest fuels reduction treatments would maintain hiding and thermal cover.

Burn only stands would maintain thermal and hiding cover values.

Stands would maintain hiding cover values where steep slopes are present and 

provide cover effects.

Skyline corridors would reduce hiding and thermal cover within the 12-foot wide 

corridor (parallel corridors for the skyline need to be placed every 100 to 140

feet). 

Openings cut for developing VSS 1 and VSS 2 would not provide thermal or hiding

cover immediately after treatment, although these areas would provide hiding cover

approximately 20 years after treatment when seedlings and saplings begin to grow. 
Chapter 3: Affected Environment and Environmental Consequences

352 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Under the No Action Alternative there would be no change from existing conditions.

Current conditions exceed Forest Plan direction. A surplus of thermal and hiding cover for

wildlife would be maintained across the project area. However, as dense forest conditions 

would still occur, the high fire hazard would continue to place wildlife cover at risk with 

respect to stand-replacing fire.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to wildlife cover within the project 

and adjacent forest lands. The cumulative effects of the No Action Alternative would be to 

increase the number of acres of National Forest System lands that are vulnerable to severe fire

effects, as dense forest conditions would continue to place wildlife cover at risk of stand-replacing

fire. The fire hazard would increase over time as vegetation would continue to grow and fuel 

would continue to accumulate.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Horizontal and vertical diversity are both important components of cover. Alternative 2 would

maintain hiding cover at least 200 feet wide around dependable waters (Schultz Tank, Pushout 

Tank and Weimer Spring) and within MSO protected and recovery nest/roost habitats and northern 

goshawk nest stands. These areas provide cover for big game species as well as attributes for 

resident songbirds, raptors, turkey and other wildlife. Alternative 2 would still provide cover and

vertical diversity for most species and would meet Forest Plan direction.

This alternative would reduce thermal and hiding cover across in all 10K blocks except Ft. Valley 

10K. There would be an additional 3 percent (196 acres) loss of a combination of thermal and 

hiding cover from the creation of cable corridors in Elden10K and 2 percent (45 acres) loss of a 

combination of thermal and hiding cover in the Pine Grove 10K.This reduction would still

provide adequate cover for most species and exceed Forest Plan direction.

Cumulative Effects

The cumulative effects boundary is the project area. Roads and trails within and adjacent to cover 

sites provide access to recreation activities, thereby reducing effectiveness of that cover for some

species due to human disturbance. The Travel Management Rule (TMR) analysis was completed 

for the Forest (Sept. 2011) and identified a desired road system; post-TMR projects evaluate 

closure/decommissioning of roads not on that identified system, and would get rid of un-needed

roads. The FWPP is such a project, and the existing road system is expected to change as a result

with fewer miles of road ultimately existing in order to attain a manageable and sustainable road 

system. With the implementation of similar adjacent projects, such as 4FRI, the road density is 

anticipated to continue to decrease, thereby cumulatively improving the effectiveness and quality 

of cover across the district.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 353

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Effects to cover would be similar to those described under Alternative 2; however no cable 

logging would occur under this alternative, which would reduce the need to remove the large 

trees and snags on steep slopes and also the need to create corridors, though this alternative would 

still require hazard (snag) tree removal in areas proposed for helicopter logging. Alternative 3 

would provide more cover than Alternative 2 due to the lack of cable corridors. 

Cumulative Effects

Cumulative effects would be the same as Alternative 2.

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Effects to cover would be similar to those of Alternatives 2 and 3; however there would be less 

area where cover attributes were reduced. No cable logging or helicopter logging would occur 

under this alternative, which would reduce the need to remove large trees and snags on steep 

slopes and also the need to create corridors. Also approximately 3,135 fewer acres would be 

treated, resulting in the same continued high vegetative density in those untreated acres as in the 

No Action Alternative. This alternative maintains the most cover of the action alternatives in 

Elden and Pine Grove 10Ks, the same amount of cover in Ft. Valley and Wallace10Ks and less in 

Joys 10K. 

Cumulative Effects

Cumulative effects are the same as Alternative 3, but to a lesser degree as fewer acres would be 

treated.

Management Indicator Species (MIS)

The working draft Forest-wide assessment Management Indicator Species Status Report for the 

Coconino National Forest (USDA 2013) summarizes current knowledge of population and 

habitat trends for species identified as MIS for the Coconino National Forest. Arizona Game and 

Fish Department provides annual population trend updates by Game Management Unit (GMU)

for game species (i.e. elk, turkey, mule deer, and pronghorn). This information when available is 

used to augment the MIS report. Below are descriptions of each of the management indicator

species identified for management areas (MAs) within the analysis area, and a discussion of the

relationship of the effects of each project alternative on forest-level population and habitat trends 

for each of these species. MSO protected habitat treatments may include both mixed conifer and 

ponderosa pine cover types. 

MIS for this project are evaluated based on management area types located within the project 

area. The MAs listed in the following table, with associated indicator species, and are indicated 

to be present within the project boundary. MIS species excluded from analysis due to lack of 

indicator habitats or features are listed here but not included in the analysis. These species 

include juniper (plain) titmouse, cinnamon teal, Lucy’s warbler, yellow-breasted chat, and 

macroinvertebrates. These are a subset of the forest-wide management areas and management 
Chapter 3: Affected Environment and Environmental Consequences

354 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

indicator species. Refer to the Forest Plan for a complete list of management areas and associated 

management indicator species. Table 127 describes MIS and the habitat components they are

indicators for.

Determination of MIS to analyze for this project was based on MA types located within the 

project area. Table 127 lists the MAs present within the project area and the MIS associated with 

each MA, as specified in the Forest Plan. 

Table 127: MAs within the FWPP with the Associated MIS

MANAGEMENT 

AREA (MA)

MANAGEMENT INDICATOR 

SPECIES

ACRES 

WITHIN 

DLH AREA 

ON FS 

LANDS

ACRES 

WITHIN 

MORMTN 

AREA ON 

FS LANDS

TOTAL

ACRES 

WITHIN 

FWPP

ON FS 

LANDS

MA 3 -Ponderosa Pine 

and Mixed Conifer 

<40% Slopes

Abert squirrel, red squirrel, 

Mexican spotted owl, elk, 

northern goshawk, pygmy 

nuthatch, turkey, and hairy 

woodpecker

2890 2619 5509

MA 4 -Ponderosa Pine 

and Mixed Conifer 

>40% Slopes

Abert squirrel, red squirrel, 

Mexican spotted owl, elk, 

northern goshawk, pygmy 

nuthatch, turkey, and hairy 

woodpecker

3389 345 3734

MA 5 - Aspen Red-naped sapsucker, mule deer 89 2.0 91

MA 6 – Unproductive 

Timber Land 

Elk, mule deer, Abert squirrel and 

hairy woodpecker

672 N/A 672

MA 8 -Pinyon-Juniper 

Woodland >40% Slopes

Juniper (plain) titmouse, mule 

deer and elk

15 N/A 15

MA 9 – Mountain 

Grassland

Elk, pronghorn antelope 46 N/A 46

MA10-Grassland and 

Sparse Pinyon-Juniper 

Above the Rim

Pronghorn antelope 140 N/A 140

MA 15 – Developed 

Recreation Site

N/A N/A 9 9

MA18 – Elden 

Environmental Study 

Area 

N/A 268 N/A 268

Electric N/A 20 N/A 20
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 355

MANAGEMENT 

AREA (MA)

MANAGEMENT INDICATOR 

SPECIES

ACRES 

WITHIN 

DLH AREA 

ON FS 

LANDS

ACRES 

WITHIN 

MORMTN 

AREA ON 

FS LANDS

TOTAL

ACRES 

WITHIN 

FWPP

ON FS 

LANDS

PVT. N/A 40 N/A 40

*Forest habitat acreage for MAs provided by FSVeg/RMRIS stand database. These acres may 

vary slightly from the Vegetation Section, which identifies acres of cover types.

Analysis Methods

The following evaluation criteria were used for MIS to compare environmental consequences for

alternatives:

Indicator Habitat Quantity

Indicator Habitat Quality

Affected Environment for all MIS

Habitat requirements and forest-wide habitat trend as reported in USDA (2013) are summarized 

in Table 128 for each MIS analyzed in this report, and a summary of the findings of the forestwide habitat trend for the species is also included. For a detailed description of the forest-wide 

population trend, species account, habitat requirements, and forest-wide habitat trends for each 

MIS, refer to USDA (2013), a copy of which is filed in the project record.

During northern goshawk surveys completed in 2013, all observations of MIS at each of the 824

call points were noted. Number of call points where MIS individuals or signs thereof were 

observed is reported in Table 128.

Table 128: MIS and Forestwide Population Trend, Important Habitat Components, and 

Forestwide Component Trends

MIS

Forest 

Population 

Trend Indicator Habitats1

Habitat 

Component 

Trend

Acreage 

in Project 

Area

Forestwide 

Acreage 

(PNVT 

Acres)

# Call 

Points 

where 

Observed

Abert’s Squirrel Stable Early seral PIPO Increasing 62592807,424 28

Elk Stable to 

Increasing

Early seral PIPO Increasing 62592807,424

Early seral MC Increasing 0 79,060 5

Early seral S-F Increasing 0 13,942

Hairy 

woodpecker

Slightly 

Increasing

Snag component of 

PIPO

Increasing 62592 807,424

19 Snag component of 

MC

Inconclusive 4158 79,060

Snag component of SFInconclusive 013,942

Mexican 

spotted owl

Stable to 

Declining

Late seral MC Increasing 4158 79,060 0

Late seral S-F Increasing 0 13,942

Red-naped 

Sapsucker Declining Early seral aspen Declining 0

3,450 0

Mule deer Declining Early seral aspen Declining 0 3,450 20 Early seral P-J Increasing 0 601,829
Chapter 3: Affected Environment and Environmental Consequences

356 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

MIS

Forest 

Population 

Trend Indicator Habitats1

Habitat 

Component 

Trend

Acreage 

in Project 

Area

Forestwide 

Acreage 

(PNVT 

Acres)

# Call 

Points 

where 

Observed

Northern 

goshawk

Stable to 

Declining Late seral PIPO Increasing 62592 807,424 0

Pronghorn Stable Early and late seral 

Grassland

Stable to 

declining 60 266,049 0

Pygmy 

Nuthatch

Stable to 

Declining

Late seral PIPO Declining 62592 807,424 46

Red Squirrel Stable

Late seral MC Increasing 4158 79,060 28 Late seral S-F Increasing 0 13,942

Turkey Stable Late seral PIPO Increasing 62592807,424 1

Notes:

1 MC = Mixed Conifer, PIPO = Ponderosa Pine, P-J = Pinyon-Juniper, S-F = Spruce-Fir

2 Total acres of ponderosa pine in the project area

Table 129 summarizes the total acres of habitat being treated by alternative for each MIS. Table 

130 summarizes the acres of habitat that would be changed for each MIS from the creation of 

cable corridors resulting in an indicator habitat type conversion. Table 131 summarizes the acres

treated by cable or helicopter logging resulting in a loss of snags and/or large trees, changing the 

habitat quality for species with snags and/or late seral as an indicator habitat. 

Table 129: MIS Habitat Treated by Alternative (Acres/% of Forest-wide habitat)

MIS Species Current Forest-wide

Habitat

No Action Alt. 2 Alt.3 Alt. 4

Abert Squirrel 490,000 0 4865/0.9 4865/0.9 3846/0.7

Red Squirrel 42,000 0 3986/9.5 3986/9.0 1896/5.0

Mexican Spotted Owl 42,000 0 3986/9.5 3,986/9.0 1896/5.0

Northern Goshawk 193,812 0 4865/3.0 4865/3.0 3846/2.0

Pygmy Nuthatch 193,812 0 4865/3.0 4865/3.0 3846/2.0

Turkey 193,812 0 4865/3.0 4865/.3.0 3846/2.0

Elk 22,188 Pipo-0 Pipo-4865/21

MC-3986/18

Pipo-4865/21

MC-3986/18

Pipo-3846/17

MC- 0 MC-1896/9.0

Hairy Woodpecker 231,812 Pipo-0 Pipo-4865/2.1

MC-3986/1.7

Pipo 4865/2.1

MC 3986/1.7

MC-3986/.02

Pipo-3846/1.7

MC -0 MC-1896/0.8

Red-naped Sapsucker 3,450** 0 22/0.6 22/1.0 2/.05

Mule Deer 3,450** 0 22/0.6 22/1.0 2/.05

Antelope 161,000 0 60/.04

01

60/.04 53/.03

** Undetermined in MIS report. Forest Plan identifies 3,450. Much of the aspen is found is the mixed 

conifer cover type.

Table 130: Effects to MIS indicator habitat quantity by alternative (Acres/% of Forest-wide 

habitat)

MIS Species Current Forest-wide

Habitat

No Action Alt. 2 Alt.3 Alt. 4

Abert Squirrel 490,000 0 +63/+.01 -0/.0 -0/0

Red Squirrel 42,000 0 -178/-.0.4 -0/.0 -0/0

Mexican Spotted Owl 42,000 0 -178/-0.4 -0/.0 -0/0

Northern Goshawk 193,812 0 -63/-.03 -0/.0 -0/0

Pygmy Nuthatch 193,812 0 -63/-03 -0/0 -0/0
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 357

MIS Species Current Forest-wide

Habitat

No Action Alt. 2 Alt.3 Alt. 4

Turkey 193,812 0 -63/-03 -0/.0 -0/0

Elk 22,188 Pipo 0 Pipo+63/+0.3

MC+178/+0.3

Pipo 0/0

MC 0/0

Pipo 0/0

MC 0 MC 0/0

Hairy Woodpecker 231,812 Pipo 0 Pipo -378/-0.2

MC -912/-0.4

MC – 1,057/

Mm

MC-284/

Pipo-296/-0.1

MC-676/-0.3

Pipo 0/0

MC -0 MC 0/0

Red-naped Sapsucker 3,450* 0 0/0 0/0 0/0

Mule Deer 3,450* 0 0/0 0/0 0/0

Antelope 161,000 0 0/0 0/0 0/0

** Undetermined in MIS report. Forest Plan identifies 3,450. Much of the aspen is found is the 

mixed conifer cover type

Table 131: Effects to MIS habitat quality by alternative (Acres/% of Forest-wide habitat)

MIS Species Current Forest-wide

Habitat

No Action Alt. 2 Alt.3 Alt. 4

Abert Squirrel 490,000 0 +63/+.01 0/0 -0/0

Red Squirrel 42,000 0 -912/-2.2 -676/-1.6 -0/0

Mexican Spotted Owl 42,000 0 -912/-2.2 -676/-1.6 -0/0

Northern Goshawk 193,812 0 -378/-0.2 -296/-0.2 -0/0

Pygmy Nuthatch 193,812 0 -378/-.0.2 -296/-.0.2 -0/0

Turkey 193,812 0 -378/-0.2 -296/-0.2 -0/0

Elk 22,188 Pipo 0 Pipo+63/+.01

MC+178/+0.8

Pipo 0/0

MC 0/0

Pipo 0/0

MC 0 MC 0/0

Hairy Woodpecker 231,812 Pipo 0 Pipo-378/-0.2

MC -912/-0.4

MC – 1,057/

Mm

MC-284/

Pipo-296/-.01

MC-676/-.01

Pipo 0/0

MC 0 MC 0/0

Red-naped Sapsucker 3,450* 0 0/0 0/0 0/0

Mule Deer 3,450* 0 0/0 0/0 0/0

Antelope 161,000 0 +9/ +<.01 +9/+<.01 +9/+<.01

** Undetermined in MIS report. Forest Plan identifies 3,450. Much of the aspen is found is the 

mixed conifer cover type.

Abert Squirrel

Affected Environment

Population trend. The forest-wide population trend is inconclusive since there is little forestspecific data. Statewide information indicates a stable trend for hunter harvest of squirrels. Abert 

squirrels are currently found throughout the ponderosa pine in the project area. Abert squirrel 

nesting habitat includes high canopy cover with interlocking canopies, multi-storied structure, 

high basal area with 18 inch dbh trees distributed throughout.

Habitat trend, early seral stage ponderosa pine. Forest-wide trend is slightly increasing. 

Although the age class distribution is shifting slightly, the proportion of the forest in un-evenaged conditions has stayed about the same. 

The project area currently exhibits good quality habitat for Abert squirrel.
Chapter 3: Affected Environment and Environmental Consequences

358 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. The No Action Alternative would have no direct effect on Abert squirrel forest-wide

habitat or population trends. However, dense forest conditions would still occur and the high fire

hazard potential would continue to place squirrel habitat at risk with respect to stand replacing

fire, resulting in an indirect adverse effect. The project area would continue to be lacking in the

higher basal areas made up of large trees that provide high quality nesting habitat. Foraging

habitat would continue to be limited as large tree basal areas would remain lower and densities 

higher reducing tree growth rates and limiting cone production.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to squirrel population or habitat 

trends. The cumulative effects of the No Action Alternative would be to increase the number of

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest

conditions would continue to place populations and habitat at risk of stand-replacing fire. The

fire hazard would increase over time as vegetation would continue to grow and fuel would 

continue to accumulate. The No Action Alternative would not add any additional disturbance to 

wildlife species or modify habitat components within the analysis area.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alterative 2, the best quality nesting habitat would be reduced to lower quality 

nesting habitat. Mid-seral stage ponderosa pine habitat would be reduced as trees grow into 

larger size classes. Group sizes would vary across the landscape, with groups up to 0.7 acres in

size with crowns that have interlocking canopies. Trees would grow into the larger diameter class

at a faster rate than under the No Action Alternative. Although mid-seral habitat quality would be

reduced, this action alternative would continue to provide recruitment, nesting and foraging

habitat for Abert squirrels in the project area. There would be a complete loss of indicator 

habitat on approximately 63 acres where cable corridors would be created. This reduction in

habitat quality is too small to alter the Forest-wide habitat or population trends.

Cumulative Effects

There would be no alteration to forest-wide habitat or population trends from Alternative 2. Past 

fuel reduction treatments have reduced habitat quality due to lower tree densities and lack of 

interlocking crowns; however, MSO protected habitat and northern goshawk PFAs have similar 

habitat qualities as those required for higher quality Abert squirrel habitat and densities. These

protected habitats are scattered across the landscape and provide habitat for squirrels. Past fuel

treatments have maintained large trees across the landscape and are reducing competition between 

trees for water and nutrients thereby moving toward the larger VSS size classes, which are

important for Abert squirrels.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 359

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to Abert squirrel habitat would be similar as Alternative 2; however there would be no 

cable corridors created in this alternative with no additional loss of habitat. This alternative may 

have a slight change to mid-seral ponderosa pine; however, this reduction in habitat quality is too

small to alter the Forest-wide habitat or population trends.

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Alternative 4 would treat 3,846 acres of ponderosa pine with a fuels reduction treatment. This 

alternative would treat the fewest acres of Abert squirrel habitat compared to the other action 

alternatives. This alternative may have a slight change to mid-seral ponderosa pine; however this

reduction in habitat quality is too small to alter the Forest-wide habitat or population trends.

Red Squirrel

Affected Environment

Red squirrels were documented to occur in both the DLH and MM project areas. Red squirrel 

and their caches were documented and caches were mapped in areas surveyed for northern 

goshawks.

Population trend. Forest-wide population trend is assumed to be stable given the relatively stable 

state-wide trend in tree squirrel harvest. The Heritage rating in Arizona is S5, indicating a secure

population in the state. As with the Abert’s squirrel, very little population data is available for this 

species Forest-wide or for larger regions. The relationship of active primary caches during the 

fall and winter can be used to determine squirrel populations (Vahle and Patton 1983). No 

population estimates have been made on the Coconino National Forest. 

Habitat trend, late seral mixed conifer and spruce-fir. Forest-wide trend is slightly increasing. 

Forest structure is moving toward more un-even-aged conditions. 

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. The No Action Alternative would have no direct effect on red squirrel forest-wide

habitat or population trends. However, dense forest conditions would still occur and the high fire

hazard potential would continue to place squirrel habitat at risk with respect to stand replacing

fire, resulting in an indirect adverse effect. Foraging habitat would continue to be limited as tree

basal areas would remain lower and densities higher reducing tree growth rates and limiting cone

production.
Chapter 3: Affected Environment and Environmental Consequences

360 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Cumulative Effects

The No Action Alternative would maintain the current fire risk to squirrel population or habitat 

trends. The cumulative effects of the No Action Alternative would be to increase the number of

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest

conditions would continue to place populations and habitat at risk of stand-replacing fire. The fire

hazard would increase over time as vegetation would continue to grow and fuel would continue to 

accumulate. The No Action Alternative would not add any additional disturbance to wildlife

species or modify habitat components within the analysis area.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, mixed conifer fuels reduction would reduce overall stand densities, which 

would result in greater tree vigor and increased resistance to insect and disease. With the 

exception of openings, treatments will increase the late-seral component of the mixed conifer. 

This would create better quality habitat, resulting in an indirect beneficial effect. There would be 

a loss of approximately 178 acres of indicator habitat from the creation of cable corridors. Areas 

treated with cable logging would require the removal of snags in an additional 734 acres of red 

squirrel indicator habitat, reducing habitat quality. Biologist would coordinate patch placement 

with existing red squirrel caches however; some caches would have snags removed. With the 

exception of cable corridors and areas harvested by cable logging, a minimum of one cache per 

two acres would be identified and all trees would be retained within a 26-foot radius. Additional 

caches would be protected outside of cable logging units to compensate for the reduced quality 

within the cable logged units (see Design Features). Although there would be a loss of indicator 

habitat with reduced quality in a small percentage of habitat, this reduction is too small to alter 

the forest-wide habitat or population trend for red squirrels. Treatments proposed for this project

would provide protection from stand- replacing crown fires to squirrel habitat within the project 

area.

Changes in red squirrel occupancy would be monitored under all alternatives. Rocky Mountain 

Bird Observatory (RMBO) will be conducting pre-treatment monitoring the summer of 2014 and 

in addition to songbirds, surveyors will be collecting red squirrel occupancy data across the 

project area. This and subsequent post-treatment data collection of project area changes in 

densities can be compared to ongoing Forest-wide survey densities to help determine if changes 

are treatment related or at a larger scale. Another potential monitoring plan includes monitoring to 

establish long-term trends in populations and habitat use and the effects of forest restoration on 

red squirrels. A proposal from AZGFD is described in Appendix B.

Cumulative Effects

The cumulative effects boundary for red squirrel is the project area. There would be no alteration

to forest-wide habitat or population trends and there would be no cumulative effect from past, 

present or foreseeable projects. Past fuel reduction treatments included very few acres of 

treatments in mixed conifer habitat. Wilderness, MSO protected habitat and northern goshawk 

PFAs have similar habitat qualities as those required for higher quality red squirrel habitat and 

densities. These protected habitats are scattered across the landscape thereby providing habitat for 

squirrels.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 361

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to red squirrel habitat would be similar as Alternative 2; however the distribution of snags 

and large trees would be more consistently random due to the absence of proposed cable 

corridors. Treatments would utilize ground-based harvesting across the majority of the project 

area, with helicopter logging for critical areas that are too steep, rocky or inaccessible to be 

treated with steep-slope machinery. There would be no loss of indicator habitat from cable 

corridors; however, habitat quality would be reduced on approximately 676 acres of indicator 

habitat proposed for helicopter logging from the removal of snags for safety. This reduction of 

snags could reduce potential nest structures for red squirrels and reduce the quality of cache sites. 

Biologist would consider caches when identifying patches of snags to be maintained reducing the 

potential elimination of nest sites in these areas. This reduction in habitat quality is too small to

alter the forest-wide habitat or population trends.

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to indicator habitat would similar to those described for Alternatives 2 and 3; however 

there would be no increased loss of habitat quality from snag removal as there would be no cable 

or helicopter logging in this alternative. This alternative treats the least acres in mixed conifer 

habitats. Under Alternative 4, the wet mixed conifer belt and MSO nest cores would not be 

treated in the Mormon Mountain area, with a total of 1,896 acres treated in mixed conifer, 2,090

acres less than Alternative 2 and 3. This reduction in treatment acres would reduce the number of 

caches that could be impacted by project implementation; however there would be 2,090 less 

acres where large trees and recruitment snags would be developed into the future reducing long 

term sustainable of indicator habitat.

Mexican Spotted Owl (MSO)

Affected Environment

Population trend. Overall, the forest-wide population trend is not known for certain, but may be 

stable to declining. A few new PACs are still being found on the Forest, and occupancy rates are 

up and down. The only demography study done on the Coconino National Forest indicated a

declining trend, but the study did not span a sufficient time period to make long-term population 

trend estimates, and climatic factors are thought to play a significant role in influencing survival

and reproduction of owls (Seamans 2002).

Habitat trend, late seral mixed conifer and spruce-fir. Forest-wide trend is slightly increasing. 

These forest types are moving toward a more even-aged structure. 
Chapter 3: Affected Environment and Environmental Consequences

362 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. The No Action Alternative would have no direct effect on MSO forest-wide habitat or 

population trends. However, dense forest conditions would still occur and the high fire hazard 

potential would continue to place owl habitat at risk with respect to stand replacing fire, resulting

in an indirect adverse effect. For additional information about impacts to MSO, see analysis in 

TES section above.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to MSO population or habitat 

trends. The cumulative effects of the No Action Alternative would be to increase the number of

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest

conditions would continue to place populations and habitat at risk of stand-replacing fire. The fire

hazard would increase over time as vegetation would continue to grow and fuel would continue to 

accumulate. The No Action Alternative would not add any additional disturbance to wildlife

species or modify habitat components within the analysis area.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, there are approximately 3,986 acres that are proposed for treatment in mixed 

conifer. Uneven-aged management would reduce overall stand densities which would result in 

greater tree vigor and increased resistance to insect and disease. Prescribed burns would be of low

intensity. Vegetation treatments would create openings for development of VSS 1 and VSS 2 

reducing late-seral habitat by 20 percent within treated areas. With the exception of cable 

corridors, there would not be a noticeable difference in the number of 18 inch dbh trees across the 

landscape. This alternative would remove late seral indicator habitat on 178 acres from the 

creation of cable corridors. There would be an additional reduction of habitat quality for 912 acres 

harvested by cable logging, where snags would be cut for safety purposes. This loss of habitat and 

reduction of habitat quality is too small to alter the Forest-wide habitat or population trends. 

Alternative 2 would provide protection from stand-replacing crown fires to remaining MSO 

habitat within the project area.

Cumulative Effects

There would be no effect to forest-wide habitat or population trends and there would be no 

cumulative effect from past, present or foreseeable projects. Past fuel reduction treatments have 

included very few acres of treatments in mixed conifer habitat.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 363

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to MSO habitat would similar as Alternative 2; however there would be no reduction of 

habitat quantity due to the absence of proposed cable corridors. Treatments would utilize groundbased harvesting across the majority of the project area, with helicopter logging for critical areas 

that are too steep, rocky or inaccessible to be treated with steep-slope machinery. Helicopter 

logging would require additional removal of snags for safety in 676 acres reducing habitat 

quality. This loss is too small to alter the Forest-wide habitat or population trend for MSO. 

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to indicator habitat would similar to Alternatives 2 and 3; however there would be less 

acres treated in mixed conifer habitats. Under Alternative 4, the wet mixed conifer belt and MSO 

nest cores on MM would not be treated; however treatments would occur above and below that 

belt, and treatments would still occur within the Schultz nest core and PAC and a portion of the 

Elden PAC in the DLH. Alternative 4 would treat 1,896 acres in mixed conifer, 2090 acres less 

than Alternatives 2 and 3. This reduction in treatment acres would reduce the area treated to 

develop into old growth.

Northern Goshawk

Affected Environment

Population trend. The forest-wide trend is stable to declining. Although the Forest has some 

information on territory occupancy and reproduction, these data are not designed to detect 

changes in population trend. The total number of territories has increased, and state-wide BBS

data indicate a significant increase, but some indicators of occupancy and productivity appear to 

be declining on the Forest. Monitoring and surveys are ongoing on the forest. There are three

post-fledgling family areas (PFA) delineated within the FWPP.

Habitat trend. Late seral –stage ponderosa pine. The Forest-wide habitat trend for late-seral 

ponderosa pine is increasing slightly. Although the age class distribution of ponderosa pine is 

shifting slightly, the proportion of the forest in uneven-ages conditions has stayed about the 

same. 

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Indicator habitat conditionsfor goshawks would remain in their current condition, notwithstanding

natural processes. The No Action Alternative would have no direct effect to forest-wide habitat or 

population trends for northern goshawk. However, dense forest conditions would still occur and

the high fire potential would continue to place goshawk habitat at risk with respect to stand
Chapter 3: Affected Environment and Environmental Consequences

364 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

replacing fire, resulting in an indirect adverse effect to habitat. The desired conditions for

sustaining and developing late seral ponderosa pine habitat would never be attained. For additional

information about impacts to northern goshawks, see analysis in TES section above.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to goshawk population or habitat 

trends. The cumulative effects of the No Action Alternative would be to increase the number of

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest

conditions would continue to place populations and habitat at risk of stand-replacing fire. The fire

hazard would increase over time as vegetation would continue to grow and fuel would continue to 

accumulate. The No Action Alternative would not add any additional disturbance to wildlife

species or modify habitat components within the analysis area.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, the quantity and quality of late-seral (VSS 5 and 6) goshawk indicator 

habitat would increase, resulting in a direct beneficial effect to habitat Under Alternative 2, trees 

would grow into the larger diameter classes at a faster rate than compared to the No Action 

Alternative. This alternative would increase late-seral stage habitat and would offer higher 

quality nesting habitat over time due to the increase in the acres of VSS 5 and 6 stands, resulting

in a direct beneficial effect to habitat. Management of old growth, MSO habitat and northern

goshawk PFAs under Alternative 2 would provide habitat for the northern goshawk. This 

alternative is expected to have no effect to the forest-wide population trends for the northern

goshawk. The increase in development in late-seral stage habitat is beneficial, but the amount of 

change is not enough to change forest-wide habitat or population trend.

There would be a complete loss of indicator habitat on 63 acres where cable corridors would be 

created. There would be an additional loss of habitat quality for 378 acres harvested by cable 

logging due to the removal of snags for safety purposes. This reduction in habitat quantity and 

quality is too small to alter the forest-wide habitat or population trends.

Cumulative Effects

There are additional indirect effects from vegetation modification activities occurring in other 

projects, including hazard tree removal for powerlines and highways, as well as tree removal for

development of state and private lands. Generally, projects on the National Forest are designed to 

move toward the desired conditions for northern goshawks as identified in the Forest Plan.

Cumulatively, these projects combined with the effects from Alternative 2 would have no effect 

to the forest-wide population or habitat trend for the northern goshawk.

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to northern goshawk indicator habitat would be similar as Alternative 2; however there 

would be no additional loss of habitat quantity due to the absence of proposed cable corridors. 

Treatments would utilize ground-based harvesting across the majority of the project area, with 

helicopter logging for critical areas that are too steep, rocky or inaccessible to be treated with 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 365

steep-slope machinery. Helicopter logging on 296 acres of indicator habitat would require the 

removal of snags for safety purposes reducing habitat quality. This reduction in habitat quality or 

quantity is too small to alter the Forest-wide habitat or population trends.

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to northern goshawk habitat would be similar to Alternatives 3 and 4; however, there 

would be fewer acres treated in ponderosa pine indicator habitat. Under Alternative 4, there 

would be no additional loss of habitat quantity from cable corridors or reduced quality from loss 

of snags as no areas would be harvest by cable or helicopter logging. Alternative 4 would treat 

3,846 acres in ponderosa pine, 1,019 less than Alternatives 2 and 3, reducing the acres that would 

develop into old growth. This alternative would not reduce habitat quality or quantity enough to 

change the forest-wide habitat or population trends.

Pygmy Nuthatch

Affected Environment

Population trend. The forest-wide trend is stable to declining. Globally, nationally, and for 

Arizona, populations are considered to be secure. Pygmy nuthatches have been observed 

throughout the project area.

Habitat trend; late seral stage ponderosa pine. Forest-wide, the trend is increasing slightly. 

Although the age class distribution is slightly shifting, the proportion of the forest in unevenaged conditions has stayed the same. Overall, snags are thought to be increasing in the

ponderosa pine and would continue to increase and densities of large snags would increase

(Ganey and Vojta).

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. The No Action Alternative would have no direct effect on pygmy nuthatches. 

However, dense forest conditions would still occur and the high fire hazard potential would 

persist, resulting in an indirect adverse impact.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to pygmy nuthatch population or 

habitat trends. The cumulative effects of the No Action Alternative would be to increase the 

number of acres of National Forest System lands that are vulnerable to severe fire effects, as 

dense forest conditions would continue to place populations and habitat at risk of stand-replacing 

fire. The fire hazard would increase over time as vegetation would continue to grow and fuel 
Chapter 3: Affected Environment and Environmental Consequences

366 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

would continue to accumulate. The No Action Alternative would not add any additional 

disturbance to wildlife species or modify habitat components within the analysis area.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, trees would grow into the larger diameter classes at a faster rate than 

compared to the No Action Alternative. This alternative would increase late-seral stage habitat

and would offer higher quality nesting habitat over time due to the increase in the acres of VSS 5 

and 6 stands, resulting in a direct beneficial effect to habitat. Management of old growth, MSO 

habitat and northern goshawk PFAs under Alternative 2 would provide habitat for the pygmy

nuthatch. 

There would be a complete loss of indicator habitat on 63 acres where cable corridors would be 

created. There would be an additional loss of habitat quality for 378 acres harvested by cable 

logging due to the removal of snags for safety purposes. This reduction in habitat quantity and 

quality is too small to alter the Forest-wide habitat or population trends.

Cumulative Effects

There are additional cumulative effects from vegetation modification activities occurring in other 

projects, including hazard tree removal for powerlines and highways, as well as tree removal for

development of state and private lands. Generally, projects on the National Forest are designed to 

move toward the desired conditions for pygmy nuthatch. Cumulatively, these projects combined 

with Alternative 2 would have no effect to the forest-wide population or habitat trend for the

pygmy nuthatch.

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to pygmy nuthatch indicator habitat would be similar as Alternative 2; however there 

would be no additional loss of habitat quantity due to the absence of proposed cable corridors. 

Treatments would utilize ground-based harvesting across the majority of the project area, with 

helicopter logging for critical areas that are too steep, rocky or inaccessible to be treated with 

steep-slope machinery. Helicopter logging on 378 acres of indicator habitat would require the 

removal of snags for safety purposes reducing habitat quality. This loss of habitat quality would 

be too small to alter the forest-wide habitat or population trends.

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to pygmy nuthatch habitat would be similar to Alternatives 3 and 4; however, there would 

be fewer acres treated in ponderosa pine indicator habitat. Under Alternative 4, there would be no 

additional loss of habitat quantity from cable corridors or reduced quality from loss of snags as no 

areas would be harvested by cable or helicopter logging. Alternative 4 would treat approximately 

3,846 acres in ponderosa pine, 1,019 less than Alternatives 2 and 3, reducing the acres of 

indicator habitat that would be treated to develop into larger size classes. This alternative would 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 367

not reduce habitat quality or quantity enough to change the forest-wide habitat or population 

trends. 

Turkey

Affected Environment

Population trend. The forest-wide trend is increasing. The trend was variable in the early part of

the Forest Plan implementation period (late ‘80s and early ‘90s), although AZGFD standard 

survey procedures did not provide good data due to low number of observations along survey

routes. AZGFD developed a better index of turkey populations in the mid1990s. Data from 1997-

2001 indicate a modestly increasing trend. For the last five years, Game Management Unit

(GMU) 7 shows a relatively stable trend, with all other GMUs showing a general increasing trend

for both percent of archery elk hunters seeing turkeys and the number of turkeys seen per day

(USDA Forest Service 2002). 

Habitat trend; late-seral ponderosa pine. The age class distribution of ponderosa pine has 

remained essentially the same, dominated by mid-seral stage stands, with some loss of oldgrowth and older trees, and some early-seral stage habitat created by wildfire. The project area

provides both roosting and nesting habitat for turkey. Turkey was documented at one call point 

within the project area.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. The No Action Alternative would have no direct effect on turkey. However, dense

forest conditions would still occur and the high fire hazard potential would persist, resulting in an 

indirect adverse effect. There would be no effect to the forest-wide population or habitat trend for 

turkey.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to turkey population or habitat 

trends. The cumulative effects of the No Action Alternative would be to increase the number of

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest

conditions would continue to place populations and habitat at risk of stand-replacing fire. The fire

hazard would increase over time as vegetation would continue to grow and fuel would continue to 

accumulate. The No Action Alternative would not add any additional disturbance to wildlife

species or modify habitat components within the analysis area.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, with the exception of cable corridors, all yellow-barked ponderosa pine trees

within turkey roosting and nesting habitat would be retained while old tree longevity is improved.
Chapter 3: Affected Environment and Environmental Consequences

368 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Furthermore, old growth recruitment areas are identified within turkey habitat and would add to 

the potential numbers of turkey roost tree groups. Trees would grow into the larger diameter

classes at a faster rate than compared to the No Action Alternative. Alternative 2 would offer 

higher quality roosting habitat over time due to the increase in VSS 5 and 6 stands. 

There would be a complete loss of indicator habitat on approximately 63 acres where cable 

corridors would be created. There would be an additional loss of habitat quality for 379 acres 

harvested by cable logging due to the removal of snags for safety purposes. This reduction in

habitat quantity and quality is too small to alter the forest-wide habitat or population trends.

Cumulative Effects

There are additional cumulative effects from vegetation modification activities occurring in other 

projects, including hazard tree removal for powerlines and highways, as well as tree removal for

development of state and private lands. Generally, projects on Forest Service lands are designed 

to move toward the desired conditions for turkey. Cumulatively, when combining the effects from 

these projects with the effects from Alternative 2, there would not be an effect to the forest-wide 

population or habitat trend for turkey.

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to turkey indicator habitat would be similar as Alternative 2; however there would be no 

additional loss of habitat quantity due to the absence of proposed cable corridors. Treatments 

would utilize ground-based harvesting across the majority of the project area, with helicopter 

logging for critical areas that are too steep, rocky or inaccessible to be treated with steep-slope 

machinery. Helicopter logging on 378 acres of indicator habitat would require the removal of 

snags for safety purposes, reducing habitat quality in those areas. This loss of habitat quality 

would be too small to alter the forest-wide habitat or population trends.

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to turkey habitat would be similar to Alternatives 3 and 4; however, there would be fewer 

acres treated in ponderosa pine indicator habitat. Under Alternative 4, there would be no 

additional loss of habitat quantity from cable corridors or reduced quality from loss of snags as no 

areas would be harvest by cable or helicopter logging. Alternative 4 would treat 3,846 acres in 

ponderosa pine, 1,019 less than Alternatives 2 and 3, reducing the acres that would be treated to 

develop into larger size classes. This alternative would not reduce habitat quality or quantity 

enough to change the forest-wide habitat or population trends. 

Elk

Affected Environment

The analysis area provides summer range for elk and is located within AZGFD GMU 7E (DLH) 

and 6A (MM). GMU 7 shows a generally increasing trend in elk numbers. The AZGFD Draft Elk 

Management Plan’s (November 2013) management objective is to continue to reduce the 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 369

population for the two year period covered by this plan and then stabilize the following years. For 

GMU 6A, the objective is to stabilize this population.

Population trend. The forest-wide trend is stable. Elk numbers on the Forest increased

in the early to mid-1990s, with a gradual decline through 2001 to roughly the 1980s level. 

Elk are found throughout the project area but not in high numbers.

Habitat Trend; early seral ponderosa pine. The forest-wide trend for early-seral ponderosa 

pine, pinyon juniper, mixed conifer and spruce-fir is increasing slightly. 

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. Under the No Action Alternative, there would be no direct effect on population trends 

for elk. However, dense forest conditions would still occur and the high fire hazard potential 

would persist, resulting in an indirect adverse effect on habitat. Dense forest conditions would not

reduce pressure to aspen which are documented to have limited regeneration due to dense forest 

conditions. 

Cumulative Effects

The No Action Alternative would maintain the current fire risk to elk population and habitat 

trends. The cumulative effects of the No Action Alternative would be to increase the number of

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest

conditions would continue to place populations and habitat at risk of stand-replacing fire. The fire

hazard would increase over time as vegetation would continue to grow and fuel would continue to 

accumulate. The No Action Alternative would not add any additional disturbance to wildlife

species or modify habitat components within the analysis area.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Alternative 2 would increase the amount of early-seral stage ponderosa pine by 63 acres and 

increase early-seral stage mixed-conifer by 178 acres through the creation of cable corridors

resulting in a direct beneficial effect on habitat. Additionally, open canopy areas in ponderosa

pine and mixed conifer would increase throughout the project area, increasing foraging habitat 

quality and quantity for elk. This is anticipated to distribute elk foraging throughout the project

area. This increase in habitat quality and quantity is too small to alter forest-wide population and 

habitat trends. 

Cumulative Effects

Other projects across the forest were designed to move toward a more open forest structure 

improving indicator habitat for elk. This project would combine with other projects to increase 

habitat. There would be no effect to forest-wide population or habitat trends.
Chapter 3: Affected Environment and Environmental Consequences

370 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to elk habitat would be similar to Alternative 2; however there would be no increase in 

early-seral habitat due to the absence of proposed cable corridors. These changes are too small to 

alter the forest-wide habitat or population trends. 

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to elk indicator habitat would similar to Alternatives 2 and 3; however there would be 

fewer acres treated to increase indicator habitat. Alternative 4 would treat 3,845 acres in 

ponderosa pine, acres 1,020 less than Alternatives 2 and 3. This alternative would still have 

beneficial effects by creating openings within the ponderosa pine and thereby improving 

vegetative diversity, resulting in improved habitat. This alternative would have the least amount 

of increased indicator habitat of all the action alternatives.

Hairy Woodpecker

Affected Environment

Hairy woodpeckers are fairly common in conifer forest types within the project area.

Population trend. The forest-wide trend is stable, or slightly increasing. Minor population 

decreases occur on a short-term scale of 1-3 years, but are generally followed by a recovery

(USDA 2002). Hairy woodpeckers were documented to occur throughout the project area.

Habitat trend; snag component of ponderosa pine, mixed conifer, and spruce fir. Ponderosa 

pine snags are increasing, and the large snag component is stable. Large snags remain below 

Forest Plan guidelines. The best information available indicates conflicting trends for mixedconifer and spruce-fir snags, both overall and the large tree component. Regardless, snags 

remain below Forest Plan standards.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. The No Action Alternative would have no direct effect on hairy woodpeckers. 

However, dense forest conditions would still occur and the high fire hazard potential would 

persist, resulting in indirect adverse effects.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to hairy woodpecker population 

and habitat trends. The cumulative effects of the No Action Alternative would be to increase the 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 371

number of acres of National Forest System lands that are vulnerable to severe fire effects, as 

dense forest conditions would continue to place populations and habitat at risk of stand-replacing 

fire. The fire hazard would increase over time as vegetation would continue to grow and fuel 

would continue to accumulate. The No Action Alternative would not add any additional 

disturbance to wildlife species or modify habitat components within the analysis area.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, management of old growth, MSO habitats, northern goshawk PFAs and 

snags would provide habitat for the hairy woodpecker. Alternative 2 progresses stands to larger 

VSS classes providing for more recruitment snags over the long-term; however there may be

some losses of snags immediately after treatment, which would slightly reduce habitat quantity

and quality over the short-term. There would be an additional 378 acres of ponderosa pine and 

912 acres of mixed conifer where a majority of snags would be lost due to the creation of cable 

corridors and harvesting with cable logging which requires snags to be cut for safety purposes. 

Design features include saving patches of snags within areas cable logged to ensure a more 

consistent distribution of snags. This loss of snags would not alter enough habitat to affect the 

forest-wide habitat or population trend for the hairy woodpecker.

Cumulative Effects

The continued development of private land would reduce habitat for these species. Removal of 

hazard trees for powerlines, trails and roads would reduce snags and habitat for snag- dependent 

species. However, these activities combined with the effects of Alternative 2 are not expected to 

reduce habitat quality enough to alter forest-wide population or habitat trends.

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to hairy woodpecker indicator habitat would be similar to Alternative 2; however the loss 

of snags would be less due to the absence of proposed cable corridors, which would reduce the 

need to remove snags. Treatments would utilize ground-based harvesting across the majority of 

the project area, with helicopter logging for critical areas that are too steep, rocky or inaccessible 

to be treated with steep-slope machinery. Snags would be removed on 296 acres of ponderosa 

pine and 676 acres of mixed conifer to in areas logged by helicopter for safety purposes. Design 

features would reduce the impact of this safety measure by providing patches of snags up to 10 

acres in size in these areas to distribute snags more consistently across the landscape. 

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to hairy woodpecker indicator habitats would similar to Alternatives 2 and 3; however 

there would be fewer acres treated in ponderosa pine and mixed conifer habitats. No cable 

logging or helicopter logging would occur under this alternative, which would reduce the need to 

remove snags on steep slopes and also the need to create corridors. Under Alternative 4, the wet 

mixed conifer belt and MSO nest cores would not be treated in the MM area. Alternative 4 would 
Chapter 3: Affected Environment and Environmental Consequences

372 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

treat 3,846 acres in ponderosa pine and 1,896 acres in mixed conifer, 1,019 acres and 2,090 acres 

less than Alternatives 2 and 3, respectively.

Mule Deer

Affected Environment

Population trend. The forest-wide trend is declining. The number of deer seen per hour and the

number of fawns per 100 does from 1985 through 2001 varies, but the trend is declining. In

good years, fawn production has been at levels minimal to sustaining populations, but in poor 

precipitation and forage years, fawn production has not kept up with mortality rates.

Habitat Trend; early-seral stages of aspen.

Aspen: Forest-wide trend is declining. Some early-seral stage stands are being created through

wildfire and management activities, but recruitment is limited primarily due to grazing by

animals. Management activities have not been implemented to a level, or over enough area, to

prevent loss of aspen patches and provide adequate aspen recruitment. There are 22 acres of 

aspen cover type and varying sizes and distribution of patches of aspen within the mixed 

conifer. 

Pinyon Juniper: Forestwide, early-seral pinyon juniper is increasing slightly.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. The No Action Alternative would result in continued loss of aspen habitat for mule

deer, resulting in a direct adverse effect to habitat. Pine encroachment and browsing by ungulates 

would continue to reduce the ability of sites to develop into mature aspen stands important to

mule deer. Dense forest conditions would still occur and the high fire hazard potential would 

persist, resulting in additional indirect adverse effects on habitat. However, this alternative would 

have no direct effect on forest-wide population or habitat trends.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to mule deer population or habitat 

trends. The cumulative effects of the No Action Alternative would be to increase the number of 

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest 

conditions would continue to place populations and habitat at risk of stand-replacing fire. The fire

hazard would increase over time as vegetation would continue to grow and fuel would continue to

accumulate. The No Action Alternative would not add any additional disturbance to wildlife

species or modify habitat components within the analysis area.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 373

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, aspen restoration treatments would increase early-seral aspen habitat 

slightly, resulting in a direct beneficial effect to habitat. Alternative 2 would treat 22 acres of 

late-seral aspen, less than 1 percent of forest-wide habitat. Additional acres would be treated 

within the mixed conifer cover type to promote aspen recruitment within the mixed conifer. 

Treatments would maintain late-seral aspen while improving recruitment. This alternative would

contribute positively to the forest-wide habitat but would not treat enough to change the forestwide habitat trend. Mule deer utilize a variety of habitats and this improvement in early seralstage aspen would not change the forest-wide population trends.

Cumulative Effects

Alternative 2 would have no effect to forest-wide population or habitat trends; however there

would be a slight beneficial effect to forest-wide habitat from aspen treatment. Combined with 

effects from past, present or reasonably foreseeable projects, no cumulative effects to population 

trends are anticipated. Past and current livestock and ungulate grazing and browsing has

contributed to the declining habitat trend; however treatments proposed for the project area are

still anticipated to have a slight beneficial effect to habitat and would combine with other projects 

designed to improve aspen regeneration on the Forest.

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to mule deer and mule deer habitat would be similar to Alternative 2. Treatments would 

utilize ground-based harvesting across the majority of the project area, with helicopter logging for 

critical areas that are too steep, rocky or inaccessible to be treated with steep-slope machinery. No 

cable logging would occur under this alternative, which would reduce the need to create corridors 

thereby reducing the creation of openings that may help to promote aspen regeneration within the 

mixed conifer. 

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to indicator habitat would be similar to Alternatives 2 and 3; however there would be 

fewer acres treated in mixed conifer and aspen habitats. Under Alternative 4, the wet mixed 

conifer belt and MSO nest cores on MM would not be treated. Alternative 4 would treat 1,896

acres in mixed conifer across the project area. This reduction in treatment acres would reduce the 

number of patches of aspen that may be treated within the mixed conifer, and the aspen 

component could be lost overtime. This alternative treats the least amount of aspen of all the 

action alternatives; however, it would not result in a change in mule deer forest-wide population 

or habitat trends.
Chapter 3: Affected Environment and Environmental Consequences

374 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Red-naped (Yellow-bellied) Sapsucker

Affected Environment

Population Trend. Available population data on the Forest comes from Christmas bird

count, Breeding Bird Surveys, and long-term research conducted along the Mogollon Rim. 

Collectively, these data indicate that red-naped sapsucker populations fluctuate overtime, 

but are indicate that the trend is probably declining (USDA 2013).

Habitat Trend for late seral aspen. Forest-wide trend is declining. The MIS report did not state

an amount of late-seral aspen. On the Forest, mid-to late-seral stage aspen are declining, due to

both natural causes and management actions to regenerate stands. Some early-seral stage stands

are being created through wildfire and management activities, but recruitment is limited primarily

due to grazing by animals. Management activities have not been implemented to a level, or over

enough area, to prevent loss of aspen patches and provide adequate aspen recruitment. For the

FWPP area, the average density of aspen snags 18 inches dbh and greater is 0.1 per acre;

however snags greater than 12 inches dbh are 20 per acre. Current snag densities in aspen 

provide habitat for red-naped sapsuckers. The lack of recruitment for late-seral stage aspen is a 

concern as these snags would become logs, another important habitat component.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. The project area contains 22 acres of late seral aspen or less than one percent of forestwide habitat. The No Action Alternative would result in continued loss of aspen habitat for

sapsuckers, resulting in an indirect adverse effect to habitat. Pine encroachment and browsing by

ungulates would continue to reduce the ability of sites to develop into mature aspen stands 

important to sapsuckers. Dense forest conditions would still occur and the high fire hazard 

potential would persist, resulting in additional indirect adverse effects on habitat. Late-seral aspen 

would be lost with no young aspen to replace it. This could potentially cause a decline in 

population trends forest-wide, resulting in an indirect adverse effect to population trends.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to red-naped sapsucker population 

and habitat trends. The cumulative effects of the No Action Alternative would be to increase the 

number of acres of National Forest System lands that are vulnerable to severe fire effects, as 

dense forest conditions would continue to place populations and habitat at risk of stand-replacing 

fire. The fire hazard would increase over time as vegetation would continue to grow and fuel 

would continue to accumulate. Late- and early-seral aspen would continue to be lost due to 

conifer encroachment and ungulate grazing and browsing, resulting in a loss of forest-wide habitat 

and therefore a loss of forest-wide population.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 375

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Alternative 2 would treat 22 acres of late-seral aspen, or less than one percent of forest-wide

habitat. Treatments would maintain healthy late-seral aspen and would treat unhealthy stands with 

high tree mortality to encourage recruitment. Late-seral aspen would be expected to increase over 

the long term. Alternative 2 would contribute positively to the forest-wide habitat trend. 

Cumulative Effects

Past and current livestock and ungulate grazing and browsing has contributed to the declining

habitat trend; however continued authorization of livestock grazing through the NEPA process 

minimizes the effects of livestock grazing on herbaceous ground cover from managed livestock

use. However, some negative effects to the quality and quantity of wildlife food and cover may

occur due to ungulate grazing and browsing. Alternative 2 combined with past, present and 

reasonably foreseeable projects are anticipated to have beneficial effect to forest-wide population 

and habitat trends.

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to red-naped sapsucker habitat would be similar to Alternative 2; however the distribution 

of snags and large trees would be more consistently random due to the absence of proposed cable 

corridors. Treatments would utilize ground-based harvesting across the majority of the project 

area, with helicopter logging for critical areas that are too steep, rocky or inaccessible to be 

treated with steep-slope machinery. No cable logging would occur under this alternative, which 

would reduce the need to remove the large trees and logs on steep slopes and also the need to 

create corridors. This would reduce the number of large trees and snags cut within PACs and wet 

mixed conifer in the MM area.

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to indicator habitat would be similar to Alternatives 2 and 3; however there would be 

fewer acres treated in mixed conifer and aspen habitats. Under Alternative 4, the wet mixed 

conifer belt and MSO nest cores on MM would not be treated; however treatments would occur 

above and below that belt and within the Schultz MSO nest core on DLH. Alternative 4 would

treat approximately 1,896 acres in mixed conifer. This reduction in treatment acres would reduce 

the number of patches of aspen that may be treated within the mixed conifer and the aspen 

component could be lost overtime. This alternative treats the least amount of aspen of all the 

action alternatives; however it would not result in a change in the red-naped sapsucker forestwide population or habitat trends.
Chapter 3: Affected Environment and Environmental Consequences

376 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Pronghorn Antelope

Affected Environment

Population trend. The forest-wide population trend is stable. Pronghorn population indicators 

have fluctuated since the late 1980s, with fawn:doe ratios showing greater fluctuation than 

number of pronghorn observed per hour. Within the range of fluctuations, the population appears 

to be relatively stable, with fawn:doe ratios increasing somewhat over approximately the last 10 

years. The Dry Lake Hills project area is in GMU 7 and Mormon Mountain is in GMU 6A. 

Pronghorn have not been documented in either project area. 

Habitat trend; early-and late-seral grasslands. Habitat trend is stable to declining. Although 

the total amount of grassland habitat has generally remained stable, habitat quality is stable to 

declining due to tree encroachment, fire suppression, long-term climatic changes, short-term 

drought, and ungulate grazing. Meadows and openings have been negatively affected by pine

encroachment fragmenting habitat for pronghorn. There are 60 acres of grassland habitat 

within the project area. 

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions for wildlife would remain in their current condition, notwithstanding natural 

processes. Under the No Action Alternative, grassland restoration would not occur, and

favorable habitat for pronghorn would decrease over time as conifers would continue to encroach 

into those grasslands, resulting in an indirect adverse impact to habitat. Dense forest conditions 

would still occur and the high fire hazard potential would persist, resulting in an indirect adverse

impact. However, the No Action Alternative is expected to have no effect on forest-wide

population trends.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to antelope population or 

habitat trends. The cumulative effects of the No Action Alternative would be to reduce the 

grassland acres within National Forest System lands, as dense forest conditions would continue

to place populations and habitat at risk of habitat loss. The fire hazard would increase over time 

as vegetation would continue to grow and fuel would continue to accumulate, continuing to 

have a negative effect on grassland habitats.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, 60 acres of grasslands would be restored, resulting in direct beneficial effect 

to habitat. Grassland restoration would increase vegetative species composition and diversity and

improve the distribution and diversity of vegetative ground cover. Alternative 2 would result in 

both an increase of habitat and an increase in habitat quality for pronghorn. However, the

increase in habitat quality is too small to alter forest-wide population trends.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 377

Cumulative Effects

Alternative 2 would have no effect to forest-wide population trends; however there would be a

beneficial effect to habitat trends from grassland restoration treatments. Combined with effects 

from past, present or reasonably foreseeable projects, no cumulative effects to population trends 

are anticipated. Past and current livestock and ungulate grazing and pine encroachment has

contributed to the declining habitat trend; however treatments proposed for the project area are

still anticipated to have beneficial effects to habitat.

Alternative 3 & 4 

Direct, Indirect & Cumulative Effects

Effects to pronghorn habitat from Alternatives 3 and 4 would be similar to Alternative 2 in that 

the treatments and desired conditions would be the same. Alternative 4 would treat 53 acres of 

grassland habitat in the DLH area, 7 acres less than Alternatives 2 and 3. This change in habitat 

quality is not enough to change the forest-wide habitat or population trend for pronghorn.

Migratory Birds

Affected Environment

President Clinton signed Executive Order 13186 on January 10, 2001, placing emphasis on 

conservation of migratory birds. This order requires that an analysis be made of the effects of 

Forest Service actions on Species of Concern listed by Partners in Flight and the Birds of

Conservation Concern, the effects on Important Bird Areas (IBAs) identified by Partners in

Flight (Latta, et al. 1999), and the effects to important overwintering areas.

Within the project area there are mixed conifer, ponderosa pine, aspen and grasslands 

habitat types. A portion of the MM area is within the Anderson Mesa Important Bird Area 

(IBA). There are no important overwintering areas within FWPP.

Species of Concern Listed by Partners in Flight and USFWS

The Arizona Partners in Flight (APIF) Plan and the Birds of Conservation Concern

(BCC) lists priority species of concern. A total of 14 species have been identified as species of

concern in FWPP habitats. Project effects to Mexican spotted owl, northern goshawk and rednaped sapsucker are discussed in detail under the Threatened, Endangered, Sensitive Species and 

MIS sections of this report. Refer to Table 132 for the additional neotropical migratory bird 

species addressed in this analysis.

The following table summarizes the PIF priority species and BCC, and those that are or have the 

potential to occur in the analysis area by habitat type and associated habitat needs. The Wildlife 

Specialist Report contains more detailed information about the species listed below.

Table 132: Acres of Migratory Bird Habitat within the FWPP Area

Species Habitat Acres of Habitat within the Project

Olive-sided

Flycatcher Mixed Conifer

DLH- 3118

MM – 1051
Chapter 3: Affected Environment and Environmental Consequences

378 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Species Habitat Acres of Habitat within the Project

Cordilleran

Flycatcher

Ponderosa Pine

DLH – 4336

MM - 1923

Olive Warbler

Greater Pewee

Grace’s Warbler

Lewis’ Woodpecker

Flammulated Owl

Purple Martin

Swainson’s Hawk

High Elevation Grassland

DLH – 60

MM – 0

Grasshopper Sparrow

Swainson’s Hawk

Western Burrowing 

Owl 

Ferruginous Hawk

Red-naped Sapsucker Aspen DLH – 22

Mm -

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Under the No Action Alternative, there would be no changes in the project area. Habitat

conditions for birds would generally remain the same, notwithstanding natural processes. The No 

Action Alternative would have no direct effect on migratory birds. However, dense forest 

conditions would continue to place forest-dwelling migratory bird habitat at risk with respect to 

stand-replacing fire, resulting in indirect adverse effects.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to migratory bird habitat and 

adjacent forest lands. The cumulative effects of the No Action Alternative would be to increase

the number of acres of National Forest System lands that are vulnerable to severe fire effects, as 

dense forest conditions would continue to place migratory bird habitat and adjacent habitat at risk 

of stand-replacing fire. The fire hazard would increase over time as vegetation would continue to

grow and fuel would continue to accumulate, continuing to have a negative effect to migratory

birds. Unintentional take could occur to migratory birds if habitat is not protected. The No Action 

Alternative when added to past, present and reasonably foreseeable future actions would put 

migratory bird habitat at greater risk.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 379

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Under Alternative 2, northern goshawk, Mexican spotted owl, ferruginous hawk, burrowing owl, 

and red-naped sapsucker are discussed in previous pages of this report. Proposed activities may

affect these species directly through habitat modification, or indirectly through changes in prey

populations.

Under this alternative, approximately 4,865 acres of ponderosa pine habitat would be treated. 

Of that, 2,201 acres is pine/oak. Eight species have been identified as species of concern in 

pine-pine/oak habitats. They are northern goshawks, Cordilleran flycatchers, olive warblers, 

greater pewee, Grace’s warbler, Lewis’s woodpecker, flammulated owl and purple martin. 

Species associated forest openings and edges such as the purple martin would benefit from 

fuels reduction treatments. Due to the creation of openings within the project, there would be a

slight increase in prey availability within the project. Through vegetation modification this 

project would create some open habitat and reduce tree densities which favor early succession

birds. However, the project area would continue to support mostly mid-succession and latesuccession vegetation stages. Burning would likely have short-term beneficial effects by

temporarily increasing insect abundance.

There would be 63 acres of late-seral ponderosa pine and 178 acres of mixed conifer lost from 

the creation of cable corridors, which require the removal of all trees and snags. Additionally, 

snags would be cut for safety purposes in 315 acres of ponderosa pine and 734 acres of mixed 

conifer proposed for cable logging. This would reduce habitat for species associated with snags 

such as purple martin, Lewis’ woodpecker, flammulated owls and olive-sided flycatchers. 

Alternative 2 would treat 3,986 acres of mixed conifer habitat. Most of the high species rich

areas are associated with MSO habitat in the project, and treatments are designed to maintain 

habitat components important for these species as well as forest- dwelling passerine birds.

Under Alternative 2, 22 acres of aspen would be treated. Areas of aspen within the wet mixed 

conifer would also be treated to create small openings to promote regeneration. Species richness 

is associated with aspen and red-naped sapsuckers are the species of concern listed for this 

habitat. Aspen treatments would result in increased size class distribution, increased health, 

growth and vigor and would increase biodiversity within aspen stands. These treatments would

move toward improving habitat not only for red-naped sapsucker but also for a multitude of

passerine birds that use this habitat.

This alternative would treat 60 acres of grassland habitat. Species associated forest openings 

and edges such as the purple martin, Swainson’s hawk, ferruginous hawk, burrowing owl and 

grasshopper sparrow would benefit from restoration treatments including grassland

restoration.

In all habitat types, disturbances to individuals from thinning, burning and associated smoke

may cause individuals to temporarily move to other areas. Individuals may be directly 

impacted if burning occurs during times when young are unable to relocate. The effects from 

smoke and fire would be isolated, of low intensity and short duration. Burning would likely

have long-term beneficial effects by increasing insect abundance post-burn.
Chapter 3: Affected Environment and Environmental Consequences

380 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Effects from vegetation modification and burning treatments would be beneficial due to the 

creation of openings and more edge effect, the retention of snags and large trees in most areas, 

with the exception of cable corridors and areas harvested by cable or helicopter logging. MSO 

protected habitat and developing old growth would continue to provide habitat for species that 

require old growth coniferous forests such as the flammulated owl and cordilleran flycatcher.

Under the Alternative 2, unintentional take could occur. When prescribed burning occurs during

the spring and early summer, there could be some take of migratory birds from smoke impacting

breeding birds and potentially impacting nesting success. Unintentional take could occur if 

occupied snags are burned or cut for safety purposes during implementation.

Design features, such as limiting the duration and timing of operations in MSO and goshawk 

habitats, lining of snags and logs, lighting techniques designed to reduce the loss of snags and the 

marking of snag patches up to 10 acres in size in areas logged by cable have been incorporated to 

reduce the potential for unintentional take to occur.

Cumulative Effects

The area of analysis is the project area. Other cumulative effects that occur within the project 

area include recreational activities and hazard tree removal. Ongoing recreational activities may

result in disturbance of migratory birds. Removal of hazard trees for powerlines, trails and roads 

would reduce snags and reduce habitat for snag dependent species. Present and future forest 

health project activities have common objectives to improve current conditions by improving soil 

conditions, reducing competition of trees, managing for return of the large tree components and 

providing snags, logs and coarse woody debris in sufficient quantity to provide for raptor species.

Under Alternative 2, treatments would provide protection from stand-replacing crown fires to 

high species rich habitats. The amount of impacts from vegetation treatments that would 

occur to migratory birds from implementation of Alternative 2 when added to past, present 

and reasonably foreseeable future actions is not likely to occur to an extent that there would 

be a measureable negative effect on migratory bird populations.

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to migratory bird habitats would be similar to Alternative 2; however the distribution of 

snags and large trees would be more consistently random due to the absence of proposed cable 

corridors. Treatments would utilize ground-based harvesting across the majority of the project 

area, with helicopter logging for critical areas that are too steep, rocky or inaccessible to be 

treated with steep-slope machinery. Areas helicopter logged would require the removal of most 

snags for safety purposes. There would be 296 acres of ponderosa pine and 676 acres of mixed 

conifer harvested by helicopter logging resulting in a loss of snags and potential unintentional 

“take” of migratory birds as noted above.

Design features, such as limiting the duration and timing of operations in MSO and goshawk 

habitats, lining of snags and logs, lighting techniques designed to reduce the loss of snags and 

the marking of snag patches up to 10 acres in size in areas logged by helicopter have been 

incorporated to reduce the potential for unintentional take to occur. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 381

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to migratory bird habitats under this alternative would be similar to Alternative 2 and 3; 

however there would be fewer acres treated in pine, pine/oak and mixed conifer habitats. 

Alternative 4 would treat 3,846 acres ponderosa pine, 1,896 acres in mixed conifer, 53 acres in 

grasslands and 2 acres of aspen. This reduction in treatment acres would reduce the number of 

migratory birds that could be impacted by project implementation; however there would also be 

fewer acres of habitat improvement. 

This alternative would have the least amount of disturbance to migratory birds because there 

would fewer acres treated and no cable corridors or harvesting by cable or helicopter logging

would be required for implementation. Additionally, there would be no noise disturbance 

associated with helicopter logging. 

Bald and Golden Eagle Protection Act

Affected Environment

All golden and bald eagles, regardless of status, are protected under the Bald and Golden Eagle 

Protection Act (Eagle Act). This analysis determines if take is likely to occur with 

implementation of the action alternatives. Take is defined as to “pursue, shoot, shoot at, poison, 

wound, kill, capture, trap, collect, molest, or disturb.” Disturb is further defined “to agitate or 

bother a bald or golden eagle to a degree that causes, or is likely to cause, based on the best 

scientific information available, 1) injury to an eagle, 2) a decrease in its productivity, by 

substantially interfering with normal breeding, feeding, or sheltering behavior, or 3) nest 

abandonment, by substantially interfering with normal breeding, feeding, or sheltering behavior”

(72 Fed. Reg.31132).

The U.S. Fish and Wildlife Service (FWS) recommends using Conservation Assessment and 

Strategy for bald eagles in Arizona (Driscoll et. al. 2006) in conjunction with the Bald Eagle 

National Guidelines (USDI 2007) to protect bald eagles in Arizona. For golden eagles, the FWS 

has issued a report titled Interim Golden Eagle Technical Guidance: Inventory and Monitoring 

Protocols; and Other Recommendations in Support of Golden Eagle Management and Permit 

Issuance (Page et. al 2010).

For bald eagles, details of the existing condition can be found is this document where bald eagles 

are addressed as a Forest Service Sensitive species. 

Golden eagles are found nesting in a wide variety of habitats from arid desert scrub to open 

conifer forests. No matter what habitat they choose in the state, topography features include tall 

cliffs or canyon in which to construct a nest and nearby large open areas to forage for prey 

(AGFD 2005). Most golden eagles nesting in Arizona are primarily residents, remaining within or 

near their home range throughout the year. In Arizona, cliff ledges are the most common nesting 

substrate used by golden eagles, but they would also use tall trees (esp. ponderosa pine), junipers, 

rock outcrops, and in rare cases, transmission towers (Glinski et.al. 1998 in AGDF 2005).

Sightings of golden eagles have been documented and winter surveys are conducted annually on 

the Flagstaff Ranger District adjacent to the analysis area. Bald eagle annual winter surveys also 

document golden eagle sightings. There is a confirmed golden eagle nest within the Action Area. 
Chapter 3: Affected Environment and Environmental Consequences

382 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Golden eagles often nest in areas of high rabbit populations. Golden eagles are well known for 

subduing large prey; however most of their diet consists of ground squirrels, rabbits, and prairie 

dogs. The project has limited foraging habitat for golden eagles with approximately 60 acres of 

grassland that could provide potential habitat. 

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Habitat conditions would remain in their current condition, notwithstanding natural processes. 

Because there would be no habitat altering activities or disturbance associated with project 

implementation, this alternative would have no direct effect on the golden eagle. However, dense

forest conditions would still occur and the high fire hazard potential would continue to place

potential golden eagle nesting and foraging habitat at risk with respect to stand-replacing fire, 

resulting in indirect adverse effects.

Tree densities would continue to be high, slowing their growth into larger diameter classes and

thereby limiting the development of larger diameter (greater than 18 inch dbh) trees important 

for roosting and perching. This would have an indirect adverse effect on golden eagle habitat.

Cumulative Effects

The No Action Alternative would maintain the current fire risk to eagle habitat and adjacent forest 

lands. The cumulative effects of the No Action Alternative would be to increase the number of 

acres of National Forest System lands that are vulnerable to severe fire effects, as dense forest 

conditions would continue to place eagle habitat and adjacent habitat at risk of stand-replacing

fire. The fire hazard would increase over time as vegetation would continue to grow and fuel 

would continue to accumulate, continuing to have a negative effect to golden eagle.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Direct effects would be from activities that cause disturbances (smoke, auditory or visual) to 

golden eagles within or adjacent to the project. Under Alternative 2, there would be no direct 

effects to nesting or roosting eagles as the nearest nesting eagle is over one-half mile from the

project, and noise generated from these activities is not expected to be audible at the nearest nest 

site. The nest location occurs on a cliff face on a raised topographic feature and it is not expected 

that smoke would settle around the nest long enough to cause discernible effects to golden eagles 

because of the air movement in away from this landscape scale feature. Smoke is expected to 

dissipate and settle in low lying areas overnight, eliminating the potential to impact nesting eagles 

outside of the project. 

Under Alternative 2, mechanical treatments, broadcast and pile burning and hauling of timber 

may cause visual or auditory disturbance to foraging golden eagles. This disturbance would be

localized, of short duration and low intensity and may impact individuals but is not expected to 

result in “take” of golden eagles.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 383

Indirect effects to the golden eagle include effects to eagle habitat, eagle prey species, or prey

species habitat. There are no anticipated adverse effects to prey species or prey species

habitat. Indirect effects to habitat would occur from treatments that modify the number of 

trees in a group of suitable roost trees, as eagles prefer to roost in large trees within close 

proximity to other large trees. However, thinning would improve old tree longevity, resulting

in beneficial effects. Lining of snags would reduce potential mortality to these components 

from burning activities. In addition, Alternative 2 would include developing old-growth 

stands in 31% of the area that may be used as future nest or perching sites for golden eagles.

There would be no effect to nesting eagles; however, there may be possible short-term 

disturbance to potential roosting habitat with long term benefits. Short term disturbance to 

foraging eagles would occur during thinning and broadcast burning activities and may cause

eagles to forage in nearby areas for the duration of the activity.

Cumulative Effects

Short-term impacts associated with Alternative 2 added to similar impacts from past, present, and 

reasonable foreseeable projects were considered. Implementation of other fuels reduction project 

activities could occur simultaneously; however, it is not anticipated to combine to cause a

negative effect. Other cumulative effects include hazard tree removal for powerlines, 

communication sites and highways, which have reduced the number of snags and large trees for 

perching along potential winter foraging areas in the project area. However, these activities 

combined with this project’s activities are not anticipated to “disturb” eagles to the degree 

identified in the Act. 

Determination of Effect

This determination is based on the above analysis for golden eagles and the analysis in this 

document where bald eagles are addressed as a Forest Service Sensitive species. The project’s

activities would not lead to “take” of golden eagles or bald eagles.

Alternative 3: Proposed Action without Cable Logging

Direct, Indirect & Cumulative Effects

Effects to golden eagle habitat would be similar to Alternative 2; however the distribution of 

snags and large trees would be more consistently random due to the absence of proposed cable 

corridors. Treatments would utilize ground-based harvesting across the majority of the project 

area, with helicopter logging for critical areas that are too steep, rocky or inaccessible to be 

treated with steep-slope machinery. No cable logging would occur under this alternative, which 

would reduce the need to remove the large trees and logs on steep slopes and also the need to 

create corridors. 

The use of helicopter logging would require landings where trees area processed at the landing 

area with a processor. There are no documented nests within the project however; a previouslyused nest is located within one-half mile of the project boundary. Helicopter flights in close 

proximity to nesting eagles could affect breeding success. Helicopter paths would need to be 

reviewed to exclude flights over occupied nest locations during the golden eagle breeding season 

(see design features specific to Alternative 3).
Chapter 3: Affected Environment and Environmental Consequences

384 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Determination of Effect

The project’s activities would not lead to “take” of golden eagles or bald eagles. 

Alternative 4: Minimal Treatment

Direct, Indirect & Cumulative Effects

Effects to golden eagle habitat would similar to Alternatives 2 and 3 in that the described 

treatments in Appendix A, Table 1 and desired conditions would be the same; however there 

would not be as many acres treated. Treatments would utilize ground-based harvesting across the 

majority of the project area, and helicopters would not be used, reducing the potential for noise 

disturbance from overflights to nests within the action area. No cable logging would occur under 

this alternative, which would reduce the need to remove the large trees and logs on steep slopes 

and also the need to create corridors. 

Determination of Effect

The project’s activities would not lead to “take” of golden eagles or bald eagles. 

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

Amendment 1: The effect of this Forest Plan amendment would be to facilitate more flexible 

management based on the updated 2012 MSO Recovery Plan rather than the 1987 Coconino 

National Forest Plan, which still depends on language from the original 1995 MSO Recovery 

Plan. Two primary reasons were cited for the original listing of the Mexican spotted owl in 1993: 

historical alteration of its habitat as the result of timber-management practices; and, the threat of 

these practices continuing as evidenced in existing national forest plans. The danger of standreplacing wildland fire was also cited as a threat at that time. Since publication of the 1995 

Recovery Plan, we have acquired new information on the biology, threats, and habitat needs of 

the spotted owl. The primary threats to its population in the U.S. (but likely not in Mexico) have 

transitioned from timber harvest to an increased risk of stand-replacing wildland fire. Recent 

forest management now emphasizes sustainable ecological function and a return toward presettlement fire regimes, both of which are more compatible with maintenance of spotted owl 

habitat conditions than the even-aged management regime practiced at the time of listing. 

Conversely, southwestern forests have experienced larger and more severe wildland fires from 

1995 to the present than previous to 1995. Climate variability combined with current forest 

conditions may also synergistically result in increased loss of habitat from fire. The 

intensification of natural drought cycles and the ensuing stress placed upon forested habitats 

could result in even larger and more severe wildland fires in owl habitat.

Within the Forest Service’s Region 3, Southwest Region (including the Coconino National 

Forest), National Forest Plans were amended in 1996 to incorporate management 

recommendations presented in the 1995 Recovery Plan for the Mexican spotted owl. Since the 

1995 Recovery Plan was published, our knowledge has increased. Given these changes and new 

information, it is now clear that managing according to the 1995 Recovery Plan does not facilitate 

recovery of the owl given high fire risk. The overriding effect of this Forest Plan amendment will 

be to facilitate management to reduce risk of severe fire hazard in and adjacent to MSO habitat 

and thus it is expected to more effectively contribute to MSO recovery in the project area over the

next several decades. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 385

Amendment 2: The effects of treatments on slopes > 40 percent are analyzed for each species in 

the following report. This amendment would allow equipment to operate on steep slopes. The use 

of steep slope equipment with enclosed cabs allows for people to be protected from potential 

falling trees reducing the need to cut hazard trees to insure their safety. This amendment allows 

us to better meet the desired future conditions for wildlife.

Scenery

Methodology

This evaluation applies current National Forest Scenery Management methodology in conjunction 

with existing Forest Plan direction. This analysis relies on field studies and photography from the 

treatment area, as well as coordination with project interdisciplinary team members, and 

consideration of public preferences for scenery. Cumulative scenic quality was within the 

geographic scope of scenic attributes and landscape character in the ponderosa pine and mixed 

conifer forests of the Coconino National Forest.

Integration of this scenery analysis assures the FWPP is consistent with scenery-related Forest 

Plan direction, USFS policies, and applicable elements of USFS Visual Management and Scenery 

Management systems. Refer to Appendix B of the SMS Handbook #701 for a complete list of 

references requiring Forest Service management of scenery and aesthetics (Forest Service 2000). 

The project would help achieve the desired conditions for scenery as defined in the Forest Plan: 

“Maintain and enhance visual resource values by including visual quality objectives in resource 

planning and management activities” (1987, as amended).

Visual Management System (VMS)

Currently the scenery resources of Coconino National Forest (CNF) are managed through the 

application of the VMS. The VMS was adopted by the Forest Service in 1974. The culmination of 

the VMS were Visual Quality Objectives (VQOs) prescribed in the Forest Plan for all lands 

within CNF. The VQO classifications range from Preservation, Retention, Partial Retention, 

Modification, to Maximum Modification. For a full synopsis of each VQO see National Forest 

Landscape Management: Volume 2, Chapter 1, The Visual Management System (Forest Service

1975). 

The Forest Plan is currently being revised and will be transitioning to Scenery Management 

System (see next section). For this project, the updated SMS inventory for the CNF will be 

incorporated and integrated at a project scale until Forest Plan Revision is completed. This action 

follows existing Forest Plan direction: “Review the VQO inventory as a part of project planning 

and make necessary corrections/refinements following field checking (USDA-Forest Service 

2000). It also follows Forest Service direction “begin using the concepts and terms contained in 

this Handbook (Landscape Aesthetics, A Handbook for Scenery Management) as you work on 

new projects or initiate forest plan revisions” (Forest Service 2000).

Scenery Management System (SMS)

The VMS process has been updated in the Scenery Management System (SMS). Handbook 

direction outlining the inventory and transition process from VMS to SMS may be found in 

Landscape Aesthetics: A Handbook for Scenery Management (Forest Service 2000). Full 

adoption of the SMS is to occur as each National Forest revises its Land Management Plan. For 

Forests not currently undergoing the LRMP revision process, or for those requiring extensive 
Chapter 3: Affected Environment and Environmental Consequences

386 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

time for revision, application of the SMS will occur at the project level. This is the case for the 

Coconino National Forest.

Scenic Integrity Objectives (SIOs) are used in the SMS in much the same way as VQOs are used 

in VMS. The Scenic Integrity or "intactness" of national forest lands is the means by which 

proposed alterations to the land are evaluated. Scenic Integrity is produced from the combined 

inventory of scenic attractiveness, viewing distance from the observer, and concern level of forest 

visitors. Scenic Integrity Objectives (SIO) are established for the forest and can be applied at the 

forest, management area or treatment area (USDA-Forest Service 2000). SIOs range from Very 

High, meaning the landscape character is unaltered, to Very Low, meaning the landscape 

character is highly altered. Intermediate levels include High (landscape character appears 

unaltered), Moderate (landscape character is slightly altered), and Low (landscape character is 

moderately altered). Another basic premise of the SMS is landscape character, which gives a 

geographic area its visual and cultural image. It consists of a combination of physical, biological 

and cultural attributes that make each landscape identifiable and unique. Landscape character 

embodies distinct landscape attributes that exist throughout an area (Forest Service 2000). Table 

133 compares the Visual Management System rankings and terminology with the Scenery 

Management System.

Table 133: Scenic integrity-visual quality and perception crosswalk (Forest Service 2000)

Scenic Integrity 

(both Existing 

and Objective)

Visual Quality 

Objective

The Forest’s Scenic Integrity as people perceive 

it 

Very High Preservation Unaltered; landscape character is intact

High Retention Appears unaltered; deviations to landscape 

character are not evident

Moderate Partial Retention Slightly altered; deviations are subordinate to 

landscape character being viewed

Low Modification Moderately altered; deviations begin to dominate 

the valued landscape character being viewed

Very Low Maximum 

Modification

Appears heavily altered; deviations may strongly 

dominate the valued landscape character. 

Unacceptably 

Low

Unacceptable 

Modification

Appears extremely altered; this level is only used 

to inventory existing scenic integrity. It is never 

an objective on National Forest System lands.

Analysis Process

The FWPP project is being planned as a large scale fuels reduction project with activities planned 

on about 8,000 acres on the Flagstaff Ranger Districts of the Coconino NF. The proposed 

activities and type of the project make it an appropriate candidate for SMS refinements for 

managing and sustaining scenic quality within an ecosystem management context.

The purpose and need of this analysis is focused on fuels reduction. SMS Appendix J (USDAForest Service 2007) recognizes that disturbances across the landscape can be beneficial, and 

even critically important to forest health and sustainability, but they can also have detrimental 

impacts to scenery. Appendix J approaches landscape assessments by replacing corresponding 

sections within Chapter 2 – Scenic Integrity, and refines and supplements parts of Chapter 1 –

Landscape Character, Chapter 5 – Scenery Management System Application and the Glossary of 

Landscape Aesthetics, A Handbook for Scenery Management. The alternative method to 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 387

Handbook Chapter 2 presented here is based on the use of two indicators for evaluating scenery: 

Scenic Integrity and Scenic Stability.

SMS Appendix J clarifies of the definition of scenic integrity in which it becomes an indicator of 

visible disturbance to the valued scenery, rather than ecosystem intactness or an immeasurable 

blend of the two. It adds a second scenery indicator, Scenic Stability, to identify and measure the 

sustainability of the valued scenery. Use of this indicator ensures that the sustainability of scenery 

is addressed as an issue and integrated into the project. 

Overview of Issues Addressed

Disturbances across the landscape can be beneficial and even critically important to forest health 

and sustainability and to the safety of forested communities but can also have detrimental impacts 

to scenery.

Two issues were identified and will be analyzed in this section. The first was identified during 

project scoping in 2013 relating to scenery (Forest Service), and the second is required by the 

Forest Plan as a measure of progress toward desired conditions for scenery.

1. What are the potential impacts to scenic resources as a result of implementation due to the 

highly valued viewsheds contained within the project area? 

Measure: Comparison of existing scenic character to desired scenic character (descriptive). 

Scenic character descriptions encompass both ecological components and cultural values. 

Existing scenic character provides a baseline to compare the anticipated changes from the 

proposed action and whether this will make progress toward the desired scenic character.

Measure: Description of expected disturbance and duration of disturbance upon completion of the 

project (years).

2. Will progress be made toward desired scenic integrity objectives and scenic stability? 

Measure: Comparison of projected progress toward scenic stability and scenic integrity (acres).

Affected Environment

Sense of Place: Mount Elden and the Dry Lake Hills are one of the dominant elements forming 

Flagstaff’s sense of place nestled among the volcanic field of the San Francisco Peaks. Similarly, 

Mormon Mountain serves as the backdrop to the community of Mormon Lake, Arizona. The 

mountains have been resources for humans through time providing water, forest products, forage 

for livestock, habitat that supports game and wildlife, and as a part of people’s lives and culture. 

Local residents as well as visitors from the state, region, country and internationally (Forest 

Service 2012) enjoy the scenic beauty of this place as noted in the National Visitor Use 

Monitoring Surveys. The mountains are a reminder of seasonal change, as well as viewing 

pleasure. The project areas are highly visible from major highways in the surrounding area 

including Interstate 40, US Highway 89A, and State Highway 64, and Forest Road 3 (Lake Mary 

Road), as well as the BNSF railroad which includes Amtrak passenger train service. Thousands of 

people travelling through the area view the attractive picture of the small town in the 

mountainous setting and the small community of Mormon Lake seating between the mountain 

and lake. As such, these areas a part of each community’s image and sense of place.
Chapter 3: Affected Environment and Environmental Consequences

388 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

The FWPP’s forested character and important role in for forest users and visitors is documented 

in the Coconino’s recreation niche (Forest Service 2008):

“The Coconino NF is a special place because of its elevation differences ranging 

from 2,600 to 12,633 feet supporting diverse animal life, plant life, climate, seasonal 

opportunities, and geology. Prehistoric and historic cultures had strong connections 

to this landscape which today inspires visitors and has a restorative effect.”

Existing Landscape Character: The DLH portion of the project area is in the San Francisco 

Peaks Landscape Character Zone landscape character type. It is characterized by ponderosa pine, 

mixed conifer (added by author), and spruce-fir forests with inclusions of aspen adding variety to 

the landscape year round. Desired conditions for scenery would be to “move toward historic, preEuropean settlement conditions. Forests would be characterized by uneven-aged groups of pines, 

widely spaced...” (Forest Service 2011). 

The MM portion of the project area is in the Ponderosa Pine landscape character zone. Vegetation 

is composed mostly of ponderosa pine forests, with this area being part of the largest contiguous 

stand of ponderosa pine in the world. Some mixed conifer forests with inclusions of aspen can be 

found on Mormon Mountain (Forest Service 2011).

Landform: The igneous rocks of the San Francisco Mountain volcanic center are variable and 

complex (Holm 1988). Elden Mountain is a dacite structure with sedimentary rock outcrops that 

are tilted and faulted. Dry Lake Hills were uplifted during the formation of Elden Mountain. 

There are numerous basalt flows from Dry Lake Hills through Switzer Mesa, some are covered 

by dacite flows from Elden Mountain and later andesite flows. The Mormon Mountain volcanic 

field is in the transition between the Basin and Range and Colorado Plateau (Gust and Arculus 

1986). It is composed of igneous rocks including basalt, andesite, dacite and rhyodacite. These 

volcanic origins result in rocky outcrops and formations as shown in Figure 73.

Figure 73: Rocky outcrops on Mt Elden. (photo courtesy of Mountain Project, 

taken by JJ Schlick)

The landforms have had minor 

modifications as forest roads, 

recreation facilities and trails have 

been built. There is also evidence in 

places where past vegetation 

manipulation has occurred such as 

stumps, cull logs and so on.

Structural modifications are 

noticeable and detract somewhat 

from the scenic qualities of the areas.

Waterform: Seeps, springs and stream courses are minor attributes of the landscape character. 

They contribute to the valued image of the landscape. There are two main drainages in the DLH-
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 389

portion of the project area; Schultz Creek and Spruce Avenue Wash (see more details in Soil and 

Water Specialist report). These drainages are both tributary to the Rio De Flag. Schultz Creek 

joins the Rio De Flag just south of the Museum of Northern Arizona on State Highway 180. 

Spruce Avenue Wash joins Switzer Canyon Wash prior to entering the Rio De Flag just southeast 

of the intersection of East Butler Avenue and South 4th Street in Flagstaff, Arizona.

There are two main stream courses with headwaters in the MM portion of the project area that 

enter Lake Mary, Newman Canyon and an unnamed stream course (Runyon 2014). Roughly 44

percent of the project area (1300 acres) drains through Newman Canyon. Except for roughly 22 

acres (less than 1 percent) of the project area that drains through Railroad Wash entering roughly 

the upper portion of Upper Lake Mary, surface flow from the remainder of the project area is 

directed through an unnamed drainage entering the upper end of Upper Lake Mary.

Vegetation: The overstory vegetation is the most dominant scenic attribute in the project area.

Both DLH and MM have coniferous cover in most places. In the lower elevations, ponderosa pine 

is prevalent. With increased elevation or northerly aspects, the vegetation changes to mixed 

conifer. There are scattered clumps of aspen, Gambel oak, and juniper depending of moisture, 

elevation and aspect. The understory vegetation is a minor scenic attribute largely because it is 

overtopped by dense coniferous vegetation.

Aspen is an important visual component in the project area, both for the contrasting color, scale 

and texture that stands provide and for the seasonal color change that attracts viewers to the area. 

Gambel oak is also an important visual component. Oak trees provide a contrast in color, texture 

and scale. Both aspen and Gambel oak are sparsely scattered throughout the project area.

The project area’s dominant scenic identity is the conifer forest with some rocky outcrops 

overlaying moderate to steeply sloping volcanic landforms as noted in the examples shown 

below. The project areas are viewed from the foreground, middleground and background 
Chapter 3: Affected Environment and Environmental Consequences

390 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 74: Almost contiguous coniferous forest common in the project areas, as 

shown in Dry Lake Hills.

from roads and trails. Grassland openings less than 5 acres in size are difficult to distinguish due 

to dense vegetation, but some do exist. Other scenery attributes include volcanic rocks and 

outcrops of all sizes. Seasonal changes including reliable winter snowfall accents the scenery as 

do wildlife sightings of birds and mammals. Research shows that such diversity of scenery 

attributes supports a positive viewing experience for people traveling through or recreating within 

the project area, and supports the quality of life for local residents and visitors (Ryan 2005).

Ecosystem Context

This section provides a link between scenery and the ecosystems in the project area. A scenic 

stability analysis was completed (see the Scenery Specialist Report) that identifies and measures 

the sustainability of the valued scenery attributes. Scenic Stability considers the condition of the 

valued scenery attributes identified in the scenic character description of the Flagstaff Watershed 

Protection Project. It evaluates whether their condition is within the historic range of variability 

reference conditions, the range of conditions that indicate a properly functioning ecosystem.

Stability also considers stressors that can affect scenery such as wildfire and insects and disease. 

Stressors may not threaten scenic attributes when the forest is functioning within reference 

conditions, but may become detrimental when the forest functions outside of these ranges.

Vegetation and landform both offer significant opportunities for scenery. The steep slopes of the 

DLH and MM make them a dramatic landscape features. Rocky outcrops and formations 

contribute to the unique identity of the mountain, and contribute to the complexity of planning 

management activities that may occur there. The vegetation carpets the landscape and provides 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 391

the character of the area. There are also significant risks present in these landscapes due to the 

density of the forest, lack of fire, high quantities of fuels and steepness of the topography.

Vegetation is the dominant scenery attribute of the FWPP project areas. Both ponderosa pine and 

mixed conifer are identified as dominant attributes. Several aspects of vegetation have been 

evaluated as related to the desired conditions noted above. Age and size class diversity and tree 

density are evaluated comparing historic conditions to the existing condition.

Water form as defined for scenery management refers to surface water occurrence and 

characteristics (Forest Service 2000). No water form related attributes will be considered because 

of the lack of perennial surface flow or ponding. Rather than consider stream channels as water, 

they will be addressed under landform. Stream channels will be considered as a minor scenery 

attribute related to the potential risks associated with wild fire, intensive weather conditions (that 

could result in flooding), and damage to large watershed landscapes. 

Landform is identified as a minor scenic attribute. As noted above, stream channels were 

evaluated as part of the landform, and roads are evaluated as they relate to soil stability and 

human caused changes.

Table 134 summarizes the scenic stability analysis for the project areas. For detailed information 

and analysis of the scenery attributes refer to the Scenery Specialist Report, located in the project 

record.

Table 134: Summary of scenery stability evaluation with condition and risk ratings.

Scenery 

Attribute 

Existing Condition Scenic 

Attribute 

Condition

Scenic 

Attribute 

Risk

Major 

Scenery 

Attributes: 

Ponderosa 

Pine and 

Mixed 

Conifer

Ponderosa pine and mixed conifer 

forests within the project are generally 

denser and more continuous than in 

reference conditions and 

accumulations of forest litter and 

woody debris are much higher than 

would have occurred under the 

historic disturbance regime. Lack of 

fire disturbance has led to increased 

tree density and fuel loads that 

increase the risk of 

uncharacteristically intense wildfire 

and drought-related mortality. There 

is a high risk of insect and/or disease 

outbreak, which is also a function of 

increased tree density.

Poor High

Major 

Scenery 

Attributes: 

Ponderosa 

Pine and 

Mixed 

About five percent of the ponderosa 

pine and 35% of mixed conifer are 

classified in the old forest cover type 

(VSS 6 per table 4). The Coconino NF 

Management Plan (Forest Plan) 

direction is for a minimum of 20% 

Poor High
Chapter 3: Affected Environment and Environmental Consequences

392 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Scenery 

Attribute 

Existing Condition Scenic 

Attribute 

Condition

Scenic 

Attribute 

Risk

Conifer allocated to old growth. Most sites 

currently do not fully meet the 

minimum criteria for ponderosa pine 

or mixed conifer old growth 

conditions as listed in the forest plan.

Major 

Scenery 

Attributes: 

Ponderosa 

Pine and 

Mixed 

Conifer

Use of the bark beetle hazard model 

for southwestern ponderosa pine and 

draft Ips hazard model indicates 

approximately 8 percent of the 

ponderosa pine analysis area has a 

low bark beetle hazard rating, while 

21 percent of the area has a moderate 

rating and the remaining 71 percent 

has a high hazard of beetle attack. 

Evaluation of the ponderosa pine 

dwarf mistletoe infection shows 

approximately 66 percent of the area 

is not infected or has a low infection 

level, with less than 20% of the trees 

infected.

Fair Moderate

Major 

Scenery 

Attributes: 

Ponderosa 

Pine and 

Mixed 

Conifer

Over 65% of Dry Lake Hills and 75% 

of Mormon Mountain have extreme 

fire hazard ratings.

In the Dry Lake Hills, 88% of the 

project is in Fire Regime I, Condition 

Class 326. At Mormon Mountain, 88% 

of the area is in Fire Regime I, 

Condition Class 3.

Approximately 51% of Dry Lake 

Hills and 70% of Mormon Mountain 

have potential for crown fire.

Poor High

Minor 

Scenery 

Attribute: 

Stream 

Channels

The majority of soils in the MM 

analysis area have moderate soil 

erodability factors due to steep slopes.

Poor High

The scenery attribute condition for 

existing roads is strong, and they are 

at low risk because they receive 

regular maintenance as part of the 

designated system of roads. Scenery 

attribute condition for temporary 

roads is fair, and stressors are 

Fair Moderate

 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 393

Scenery 

Attribute 

Existing Condition Scenic 

Attribute 

Condition

Scenic 

Attribute 

Risk

moderate.

The scenic stability determination finds that of the scenery attributes selected and evaluated for 

the existing condition, four are at high risk and two at moderate risk. This would mean that there 

is HIGH risk to MOST attributes and FEW are stable. For this project scenic stability is VERY 

LOW. Most dominant scenery attributes of the valued scenic character are seriously threatened or 

absent due to their conditions and ecosystem stressors, and are not likely to be sustained. The few 

that remain may be moderately threatened but are likely to be sustained.

Cultural Context

The project area is highly visible and viewed by large numbers of people form from important 

heavily used travel corridors, including Interstate 40, Highways 89 and 180, Forest Road 3 (Lake 

Mary Road) and secondary travel-ways through the forest. Beyond the project area, private 

landowners and hikers, mountain bikers, equestrians and scenic drivers view the planning areas 

and the surrounding landscapes from the trails and recreation sites as well as homes, backyards 

and porches. The landscapes they view on a daily basis are likely very important to their quality 

of life. Gobster (1996) contends that “in forests...people form perceptions of place based on what 

they see and experience from an aesthetic point of view”. 

In the 2010 National Visitor Use Monitoring survey (Forest Service 2012), visitor satisfaction 

was measured. Over 90 percent of those surveyed indicated high satisfaction for the condition of 

the scenery. The importance of the surrounding forested environment and attractive scenery are 

also repeated themes mentioned in the Flagstaff Regional Plan 2030 (City of Flagstaff 2013The 

benefits of high-quality scenery are numerous despite the fact that a dollar value is seldom 

assigned to it, except in regard to real estate appraisals and overall tourism revenue to 

communities.

Desired Scenic Character

The desired scenic character (DSC) identifies the most aesthetically desirable set of valued and 

sustainable scenic character attributes as possible given the multiple land uses compatible with a 

particular landscape. Based on the purpose and need and proposed action, Table 135 provides a 

comparison of existing conditions, desired conditions, and desired scenic character. Progress 

toward the DSC is achievable through the project level activities proposed in this project in the 

long term. Since the activities required to move the project toward desired conditions are 

substantial in some areas, short term interim scenic integrity levels would be employed during 

implementation.

Interim scenic integrity levels acceptable during implementation would follow the Forest Plan 

guidance that SIO in the treatment area may drop one level during project implementation in the 

short term, but must meet or exceed the mapped SIO in the long term. For example, areas mapped 

with an SIO of high can move down to moderate in the short term, but must meet high SIO in the 

long term. Implementation of the FWPP project could take up to ten years to complete, short term 

effects could last as long as ten years following project completion. Long term effects would be 

eleven years and beyond.
Chapter 3: Affected Environment and Environmental Consequences

394 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 135: Comparison of existing conditions and desired scenic character.

Existing Condition Desired Scenic Character

Lack of recurring fire has 

resulted in proliferation of 

smaller trees that have reduced 

or replaced openings

Scattered groups of trees with grassy openings between 

that provide natural contrast and species diversity. A 

mosaic of openings and groups of trees allows existing 

scenic views and attributes to be seen.

Lack of age and size class 

diversity and trend toward 

even-aged structure. In areas 

with uneven-aged structure 

there is a lack of age and size 

class diversity.

Uneven aged groups of trees – all age and size classes 

present, but distributed across the landscape in groups and 

clumps. Different sizes and forms create variety and 

pattern across the landscape that is characteristic of the 

ponderosa pine forest and is the dominant visual element. 

Uneven aged groups of trees are also desirable in the 

pinyon-juniper woodlands.

Reduced tree vigor and health 

leading to lack of resilience to 

disease, intense wildfire

Forest health is improved resulting in better resilience. 

Scenic attributes are sustainable into the future. 

Under representation of old, 

mature trees 

Large old mature trees are a prominent component of the 

uneven aged forest. The form and shape of large trees and 

presence of a mature forest structure is critical to the 

landscape character of the ponderosa pine and mixed 

conifer forests. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 395

Existing Condition Desired Scenic Character

Small trees reduce or remove 

openings, reduce sunlight to the 

forest floor resulting in sparse 

understory vegetation and lack 

of stability of stream courses.

Diversity of species and healthy understory vegetation is 

critical to the composition and attractiveness of forest 

settings. Diverse forest communities include trees, shrubs, 

grasses and forbs native to the area. The aesthetic 

experience of the ponderosa pine and mixed forest 

increases when the species diversity includes both fine and 

coarse textures, patterns, scales and colors.

Stream channels provide scenic diversity and are important 

components of the forests. They contrast with forested 

settings and different plant species are often present. They 

provide important views. 

Fire regimes have shifted to 

lower frequency high severity 

surface and crown fires.

Fire evidence is reintroduced as a natural element of the 

scenery in an irregular mosaic of burn patches and as 

maintenance burning occurs, with low to moderate burn 

severity. Burning is essential in order to re-establish scenic 

stability. 

Existing roads are maintained 

and temporary roads are used 

then restored maintaining the 

existing landscape character.

Forest roads provide important viewing platforms for 

scenery. Restoration of roads closed in TMR and 

temporary roads re-establishes native vegetation and move 

these places toward the characteristic landscape, and 

improves the scenic quality of these areas. Restoration 

improves the contrast between roadbeds and the naturally 

occurring landscape. 

Scenic Integrity Objectives (SIOs)

The SIOs for the project area are illustrated in Figure 75 and Figure 76. For the FWPP project, 

these represent the long term goal for fuels reduction, and are incorporated in the desired 

conditions as proposed above. Almost all of the project areas are mapped as SIO high, and the 

remaining small areas are mapped as moderate. 
Chapter 3: Affected Environment and Environmental Consequences

396 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 75: Scenic Integrity Objectives for Dry Lake Hills.

Figure 76: Scenic Integrity Objectives for Mormon Mountain.

Per the SMS Handbook (Forest Service 2000): high scenic integrity refers to landscapes where 

the valued landscape character “appears” intact. Deviations may be present but must repeat the 

form, line, color, texture and pattern common to the landscape character so completely and at 

such a scale that they are not evident. Moderate scenic integrity refers to landscapes where the 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 397

valued landscape character “appears slightly altered.” Noticeable deviations must remain visually 

subordinate to the landscape character being viewed. 

Scenic Integrity

At the lower elevations of DLH and MM, ponderosa pine vegetation forms a dense coniferous 

cover. The pine trees have a somewhat spreading conical, upright form with brown to black tree 

boles and olive-green fine textured needles. Deciduous trees have a wider, shorter shape in 

contrast to the conical pine trees. Oak and aspen have moderately coarse textures and in growing 

seasons, a brighter green colors that is readily visible in contrast to the olive green conifers. This 

color contrast is even more noticeable in the fall when the deciduous tree leaves turn colors. In 

winter, the lighter grey bark color of the deciduous species contrasts with the brown/black of pine 

tree boles. Below the pine trees is a sparse understory of shrubs, grasses and forbs. The 

understory is mostly a low, fine textured form, although downed logs and rock outcrops provide 

contrast to the uniform texture. Understory colors include greens, tans, and shades of grey. In 

drainages there are shrubby species that add complexity in the midstory complexity of form, as 

well as contrasts in color, texture and pattern.

In the mixed conifer, the narrow, conical nature and varying colors of the different species is more 

noticeable. Less of the tree bole is visible and the tree branches extend down closer to the forest 

floor. There is little understory vegetation under the dense mixed conifer trees. Where openings 

are present, there is a grass-forb understory. In places, aspen is mixed with conifers and provides 

a contrast in color, texture and shape. Meadows provide welcome views as well as low, uniform 

and finely textured shapes.

The vegetation offers opportunities for ecosystem improvement. The current excessive vegetation 

density and hazardous fuels conditions are inconsistent with the DSC and scenic stability. Among 

the many potential scenery attributes that are under-represented are large, old trees, diverse age 

groups and mature forest structures (especially aspen and pines as individual trees and groups), 

meadows, and a diverse understory with shrubs, grasses and forbs. Many meadow areas have 

decreased in size and are being encroached upon by conifers, and/or are obscured from view by 

dense coniferous vegetation in ponderosa pine, mixed conifer types. Inter-tree spaces have mostly 

disappeared.

The dense conifer vegetation obscures visibility to even nearby volcanic rock forms and outcrops, 

and the understory is often sparse and lacks diversity. Many “view windows” outward to adjacent 

areas and to other noticeable landforms are obscured by vegetation. In addition, human 

constructed features including buildings, recreation sites, roads, and trails, as well as management 

activities such as logging and fire suppression have interrupted and diminished scenic vegetation 

attributes in most places within the project area. The sum of these occurrences has resulted in 

forest canopy that is excessively dense and uniform, or, fragmented in patterns and shapes 

inconsistent with the historic, vegetative mosaic.

Existing roads in the area also offer opportunities for ecosystem improvement. Many of the high 

clearance and closed roads run straight up and down slopes. Relocation of forest system roads 

that have overly steep sections would improve their stability. Forest roads create linear features 

through the landscape. These linear roads and cleared areas contrast with the characteristic 

landscape. They also provide viewing platforms into the project area as well as from the mountain 

into the surrounding landscape.
Chapter 3: Affected Environment and Environmental Consequences

398 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Environmental Effects

Spatial and Temporal Context for Effects Analysis

The timeframes for direct and indirect effects will include the potential for scenery disturbances 

up to ten years following project implementation. The analysis area for direct and indirect effects 

is the project area. The timeframe for cumulative effects is 20 years and the area includes the 

north section of the Coconino National Forest.

Alternative 1: No Action

Direct & Indirect Effects

If no actions were implemented, the project area would continue to be mostly natural-appearing 

for several years. Important scenery attributes such as open and diverse overstory vegetation and 

healthy understory would continue to have overly dense growing conditions and views into and 

out from the forest would be blocked by trees. The large, old tree character that historically 

contributed to the attractiveness of the area would be limited. Historic fire regimes would not be 

re-established, limiting nutrient recycling and allowing the density of forest fuels to increase. 

Existing steep roads closed in the Travel Management decision and those with overly steep 

segments would not be restored or relocated. These would continue to be used, torn up and 

contrast with nearby scenery. Stream channels would remain sparsely vegetated due to existing 

forest density. There would be no potential for a more diverse understory plant component. 

At some point, overstocked vegetative conditions may be attacked by insects or disease, or 

experience an uncharacteristically large and intense wildfire that would burn much of the 

vegetation that is the dominant scenic attribute. While some insect and disease activity occurs 

every day, the overly dense conditions combined with extreme weather events characteristic of 

climate change could allow these to escalate and become wide spread. Large, high intensity fires 

have become more common with increasing tree density and lack of a regular fire regime. Large 

scale events such as these would be outside the range of historic variability. (See the Fire & Fuels 

and the Silviculture Specialist Reports for more details about tree density, insects and disease and 

fire risk and effects.)

In the event of an uncharacteristic high severity wildfire such as the Schultz Fire, the existing 

landscape character would be suddenly altered with little opportunity to slow or control the 

change. The SIOs in the project area would have to be remapped and uncharacteristic high 

severity, large-scale wildfire would redefine and reshape the existing landscape character for 

decades if not centuries. Figure 77 shows an example of high intensity wildfire during the Radio

Fire on Mt. Elden in 1977 (left) and an example of the effects on the landscape following the

Schultz Fire in 2010 (right).

The appearance and character of the area would shift from green and densely forested to burnt, 

patchy and open. The overstory component and green canopy would be absent or drastically 

reduced, depending on the severity of the fire. For a at least a decade, the landscape would be 

dominated by blackened, dead standing trees; if allowed to come down on their own, the trees

would likely fall in a dense, jack-straw pattern. Although short term, smoke from high intensity 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 399

Figure 77: Example of high intensity wildfire on Mt Elden, and effects on 

vegetation following Schultz Fire

wildfire would cause scenic quality to be diminished and if thick enough, would obscure views to 

nearby scenic attributes.

In the short term following high intensity fire, emergency fire suppression actions such as fire 

lines and emergency post-fire rehabilitation treatments could result in unnatural linear 

disturbances on the landscape. With rehabilitation and other mitigation measures, the immediate 

impacts of the suppression and emergency treatments should not be evident to the casual forest 

visitor within 2 to 3 years of completion, although effects from the fire itself would remain visible 

much longer. For two to three growing seasons, the blackened, exposed ground surfaces would be 

highly visible due to lack of vegetation. Sedimentation and erosion would increase, raveling soils 

that would take a long time to revegetate. Eventually these areas would be covered with spotty 

vegetation and invasive weeds until native material became established. Within 5 years, the 

effects of the fire would begin to be viewed in a somewhat more positive light as the shrubby 

understory became more abundant. There is some risk that a vegetation type change could occur 

especially if there is wide spread drought, and/or if trends toward higher temperatures, and less 

annual precipitation continue. There is some evidence of this potential in the Radio Fire area 

where ponderosa pine seedlings were planted but unsuccessful in restoring the forest. These 

changes would be visible throughout the project area in the foreground of Forest roads and trails, 

and as middle ground and background views from communities within the project area, trails, and 

developed recreation sites.

Initial public reaction to a large-scale fire tends to be negative, as many people do not consider 

extensive, blackened landscapes to be natural or beneficial (Ryan 2005). These effects are often 

perceived by local residents as devastating to their community and way of life; non-local forest 

visitors may regard the effects of a catastrophic fire as interesting and something “to be seen” but 

also as a degradation of the scenic quality.

Indirect effects of high intensity wildfire include short term and temporary smoke that would 

affect nearby subdivisions, Flagstaff, and as with large, high acreage blazes, could affect Sedona 

and Verde Valley, Winslow, Holbrook, Mogollon Rim communities, Grand Canyon and residents 

of the Navajo Nation. Effects would include smoky conditions and decreased visibility, and 

would last until the fire was contained and declared as “out.”

There could be wide spread flooding and sediment transport into nearby communities and 

neighborhoods. Other indirect effects of high intensity wildfire could include damage to the 

project area watersheds with subsequent effects to local reservoirs, the City of Flagstaff water 

system, and the scenic character of locally important recreation sites such as Mormon Lake, 
Chapter 3: Affected Environment and Environmental Consequences

400 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Upper and Lower Lakes Mary, the Rio de Flag, as well as hiking trails, driving for pleasure, 

scenery and wildlife viewing opportunities and others. Many times flooding and sediment 

transport would continue to occur for many years and even a decade after the wildfire.

Under this alternative, there would be no opportunities to enhance and improve scenic resources 

or achieve the desired condition since there would be no thinning or other treatments. It would 

maintain the existing landscape character in the short term, but in the long term the existing 

landscape character would decline.

Cumulative Effects

The following is list of actions relating to scenic attributes, landscape character and scenic 

integrity considered in the cumulative effects analysis for this project:

Past activities that created the current conditions include grazing, the evolving forest 

management practices related to timber harvest and fire suppression, drought, disease and 

insect infestations, dispersed and developed recreation, and utility corridor clearing.

Present and future activities such as vegetation management, fuels management, utility 

corridor clearing and new utility corridors, and other management activities (e.g. noxious 

weeds treatments). These activities could occur on private lands as well.

The cumulative effects of past management activities are visible as the existing conditions. 

Vegetation management practices, fire suppression, and over grazing have resulted in the current 

mostly even-aged forest structure, overstocked conditions, and sparse understory trees, shrubs, 

grasses and forbs. 

The short term cumulative effects (1-5 years) of the No Action Alternative combined with similar 

current and future restoration treatments and prescribed burning projects are expected to be 

negligible, unless additional large scale, high severity wildfires occur in the ponderosa pine type. 

If wildfires burn large areas, the scenic quality would be decreased, and there would be long term 

negative changes (10 to 100 years) in scenic character. The scenic attributes that contribute to 

high scenic integrity, such as an open forest with tree groups of varying ages, sizes and shapes, 

large, mature trees, and healthy, diverse understory would not be present. The scenic impact of a 

high-severity wildfire would combine with scenic impacts from adjacent land development, 

powerline development and maintenance, and impacts from dispersed recreation use to result in a 

cumulative impact so that scenic integrity is greatly diminished in areas burned for up to a decade 

or more. In some places there would be a chance that climate change could contribute to type 

changes in parts of the ponderosa pine forest so that these characteristics would be replaced with 

difference landscape characteristics, which would also cumulatively impact scenic attributes.

In the absence of large, high severity wildfires, long term cumulative effects of the No Action 

alternative and present and future vegetation management and prescribed burning projects would

be small and localized. In the absence of large scale treatment, the scale of treatments that are 

currently accomplished would not result in improvement to scenic stability or scenic integrity. 

The desired landscape character of an open forest with tree groups of varying sizes, shapes and 

ages, presence of large, mature trees, and healthy, diverse understory would not be met. This 

could combine with scenic effects such as scenic impacts of bare ground from grazing and 

recreation use and scenic effects from unhealthy forest conditions resulting from disease and 

drought to result in a trend toward declining landscape attributes, and less sustainable landscape 

character.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 401

This alternative would not meet the project’s desired conditions or Forest Plan direction. It would 

not move the project area toward scenic stability. Over time, scenic stability would decrease and 

move to no stability. No action would result in continuation of current risks to scenic attributes 

and it is reasonable to assume that these risks increase each year and could be exacerbated by 

climate change. The No Action Alternative would not meet long-term scenic integrity objectives 

since these are dependent upon improving the condition of scenic attributes so that they are more 

resilient to ecological stressors.

Irretrievable and Irreversible Commitment of Resources

This alternative does not propose changes and thus does not have any irretrievable and 

irreversible commitment of resources except for those associated with a high-severity wildfire, 

discussed above. 

Effects Common to All Action Alternatives

Direct & Indirect Effects

Campfire Closure Order: The campfire closure order would have a positive effect of scenic 

stability throughout the DLH portion of the project area. The measure would help to reduce the 

potential for human-caused wild fire and subsequent detrimental effects on scenery.

Presale Activities: Numerous activities occur prior to project implementation. Trees are marked 

either as “leave trees” (those to be left on site, typically using orange paint), or as “cut trees” 

(those to be removed, typically using blue paint). Sale boundaries are also marked to delineate the 

edges of the project. Potential skid trails, landings, road improvements or reroutes are identified 

and many other activities. One noticeable activity is the boundary and tree marking. 
Chapter 3: Affected Environment and Environmental Consequences

402 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 78 provides examples of tree/boundary marking using orange (leave tree) paint. Design 

features provided for the project would help minimize visibility by marking the trees on the side 

away from roads and trails.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 403

Figure 78: Tree and boundary marking pre-project actions would be noticeable 

from roads, trails and recreation sites near or within the project.

Conventional Ground Based Harvesting: Conventional logging typically has moderate short 

term effects to scenery. During implementation, in most cases whole trees are cut and moved to a 

“landing” near a haul road. At the landing, the limbs and tops are removed, and the clean logs are 

decked to be loaded and hauled away. After the trees have been thinned, the slash remains either 

to be treated in the forest or piled at landings. Effects of logging operations typically include 

trampling of existing vegetation where equipment is operating, creation of linear skid trails where 

vegetation is trampled or completely removed exposing bare soil, creation of linear log landings 

where vegetation has been trampled or removed and bare soil is exposed, and piles of cull logs 

not suitable for commercial uses. After logs or useable material is removed, most slash would be 

treated or if biomass removal is possible most slash would be chipped and loaded into trucks. At 

landings, slash piling may include bulldozers pushing slash into large piles (10-20 foot wide piles, 

often 10 feet tall) which can trample vegetation and cause bare soil to be exposed. For the 

purposes of restoring landings and skid trails, a small amount of slash may be retained to scatter 

and cover the bare ground. Dust from equipment would impair visibility in the immediate areas 

where activities are taking place. This would be short term and confined to the area around the 

equipment.

Chipping: Production of biomass by chipping and hauling the material off site generally results in 

fewer effects. It is not without effects to scenery, these would include dust and smoke from 

operation of equipment and additional trucks hauling material from the site. There would also be 

loud noise associated with chipping and blowing material into trucks that may disrupt the viewing 

experience. Since chipping occurs on site the duration of the noise would last longer than hand or 

machine piling. 

Figure 79 shows an example of slash chipping.
Chapter 3: Affected Environment and Environmental Consequences

404 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 79: Slash chipper in operation (Photo courtesy of R & S Biomass 

Equipment)

Hand Thin and Pile: Hand thinning usually has little or no short term effects on scenery. Trees 

are cut down, cut into segments and piled so that it can be treated as shown in Figure 80. Effects 

may include slash from limbing and topping trees. Project design features require most slash to be 

treated. There are about 15 acres proposed to be treated in place, effects would be similar to hand 

thin and pile.

Figure 80: Hand piled slash.

Machine Piling: Bulldozers push slash into large piles (10-20 foot wide piles, often 10 feet tall) 

which can trample vegetation and cause bare soil to be exposed as shown in Figure 81. Dust is 

created during piling but would be a short term effect confined to the immediate area where the 

equipment is working. When the piles are later burned, the heat from the fire can sterilize the 

ground underneath. The burned areas are susceptible to invasive weeds, and it may take several 

years for native vegetation to re-establish. The ground disturbance resulting from using machines 

to pile slash would be noticeable for three to five years after project completion, depending on 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 405

how quickly the areas revegetate. Scraped trees would heal or scars would become less noticeable 

over time.

Figure 81: Machine piles are larger than hand piles and create more ground 

disturbance.

Cut to length: The cut to length system utilizes a harvester and forwarder (see Harvest 

Systems/Methods Descriptions in Chapter 2 for more information). Effects of the steep slope 

harvesting equipment would be similar to those included in ground based logging noted above.

Aspen Treatments. Aspen treatments to stimulate new sprouting require protection from 

ungulate browsing following treatments. A variety of treatments would be used including removal 

of invading conifers within 100 feet of aspen clones, prescribed fire, ripping, planting, fencing 

and/or cutting of aspen to stimulate root sprouting. Many aspen clones currently have dead and 

down and dead standing trees. Treatments are small scale and would not be very noticeable with 

the exception of fencing. Fencing would introduce new linear and unnatural features into the 

landscape. Use of the fewest contrasting materials would help to make the fencing less noticeable. 

Protection of sprouts is usually required for many years after treatment so that the sprouts grow 

large enough to withstand ungulate browsing. It is expected fencing would remain at least 10 

years, and possibly longer before it could be removed. It would result in a longer term visual 

disturbance. It is desirable to keep aspen a part of the ecosystem if successful these treatments 

would result in improved scenic quality and landscape character.

Grassland Treatments. These treatments would involve removal of encroaching conifers and 

restoration of presettlement tree density and patterns. There would be short term negative effects, 

but soon after these areas would show improved scenic quality and landscape character.

Electronics Site Structure Protection. The telecommunication sites would receive thinning 

treatments. These are permitted facilities that provide important services to the public and they 

need to be protected. These locations would be thinned to 20 to 40 basal area. Thinning will open 

up views to the equipment and facilities in place making the contrast between the constructed 

facilities and surrounding landscape more obvious. At these sites, scenic integrity would only be 

maintain; it would not be improved.
Chapter 3: Affected Environment and Environmental Consequences

406 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Strategic Placement of Treatments: Strategic mechanical and fuels treatments would have 

relatively small effects on scenic quality immediately after treatment. Strategic fuels treatments 

would enhance fire control lines enabling prescribed fire to be safely implemented. They include 

hand thinning or use of machinery equipped with cutting or grinding heads on 300 feet either side 

of control lines. Slash is treated within the cleared area, and this becomes the staging area for 

implementing prescribed burning blocks. Effects include short term introduction of linear features 

throughout the area. Upon completion of prescribed burning it is expected that the linear features 

would not be as noticeable because the density of trees on either side of the treatment areas would 

be thinned and/or burned reducing the number of trees and creating a more irregular boundary.

Fuels reduction and reintroduction of fire would have moderate effects on scenic quality 

immediately after treatment, and low effects after repeat burning.

Pile Burning: Effects from pile burning would be primarily limited to the immediate dead and 

live fuels of the slash pile, although some scorching and mortality of residual trees would be 

expected. Following burning, the bare areas are susceptible to invasive species. Mitigation 

measures for invasive species would include monitoring and treating infested areas. The hand 

piled areas are expected to revegetate within 1 to 3 years following burning, machine piled areas 

are expected to revegetate within 3-5 years following burning. If areas where piles were burned 

are not naturally restored, it may be necessary to scratch in seed and soil from unburned areas in 

order to assure vegetative cover.

Prescribed Fire: Prescribed fire would be used on much of the project areas with the procedures 

tailored to fit the treatment types. Fire may be used in conjunction with mechanical treatments or 

singly. The objective of prescribed burning is to reduce fuel loading, raise crown base heights and 

reduce live tree density. Repeat or maintenance burning would help maintain these objectives. 

Repeat burning in ponderosa pine would occur every five to seven years. In mixed conifer on 

steep slopes, there may be only one broadcast burn because of the difficulty of implementation in 

these fuel types and terrain, and because the historic fire return interval is historically longer than 

the life of this project.

Depending on fire severity, effects would include: charred soil and vegetation immediately 

following burning; charred bark up to 10 feet from the ground; needle and leaf scorch typically 

less than 20 feet from the ground; and, loss of understory trees, trees with old scars or trees with 

large accumulations of dead fuels at their base. In areas of moderate to high severity, openings 

may be created as a result of more extensive tree mortality. The presence of charred surface 

vegetation and red or black trees would present a contrast to the otherwise green surroundings. 

These contrasts would soften and become less noticeable within two or three growing seasons 

after project completion as the understory component (i.e., grass, aspen and shrubs, etc.) moves 

in, as singed but not dead trees recover and green up, and as dead standing trees fall down. 

Effects may last longer and be more pronounced in areas of moderate to high fire severity, but 

these areas would be localized and limited. Repeat burning would temporarily blacken the forest 

floor, some charred bark, and scorch or burn of some understory trees and shrubs. These effects 

typically soften after one year, and are less noticeable to the casual observer after 2 to 3 years.

Smoke from pile burning and prescribed burning creates short term and temporary effects on 

scenic quality. During implementation, smoke would obscure views of the surrounding terrain 

and mountains. Effects to residents and visitors in the project areas may be dissatisfaction that 

their views are obstructed, and scenic features are obscured. Very smoky conditions typically 

occur during the first entry of prescribed burning due to heavy fuel loadings. There can be 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 407

lingering smoke for two weeks to a month after burning as stumps, large logs and roots smolder. 

Smoke from repeat burns should lessen, since less fuel would be consumed.

There may be indirect effects of smoke as well since it drifts and is pushed by air currents. 

Nearby developed recreation sites, houses and subdivisions, and the communities may experience 

reduced visibility and smoky conditions. Dispersed campers and other recreationists may 

experience reduced visibility and smoky conditions in some places near the project area.

Transportation System. Transportation systems used under all action alternatives would utilize a 

combination of existing Forest Service system roads, Forest Service system roads that are 

relocated to reduce erosion, previously decommissioned roads, new temporary roads and 

temporary roads that would be placed on existing road prisms. The approximately 4.38 miles of 

roads that are no longer needed for management of national forest lands would also be 

decommissioned under this EIS.

The Flagstaff Ranger District is concurrently conducting an environmental analysis of nonmotorized recreation for trails, special uses and facilities in the Mt. Elden-Dry Lake Hills 

(MEDL) area. Much of MEDL planning area overlaps with the FWPP project area. There is the 

possibility that new temporary roads constructed under the FWPP could at a later time be 

converted to recreational trails. The EIS currently being prepared for FWPP will not analyze for 

the possible environmental effects of any future road to trail conversion within the project area. It 

will only analyze for the construction, use and rehabilitation of new temporary roads, not their 

possible conversion to a trail. If any road to trail conversion is considered under the MEDL 

environmental assessment, those environmental effects would be analyzed under the MEDL 

environmental assessment. In the FWPP project, three roads (about two miles total) would be 

partially relocated for use as haul routes for log trucks and eliminate overly steep grades. The 

unused road prisms would be restored.

Road maintenance activities would improve the condition of the existing road system, and this 

would be beneficial for scenery. Relocation of segments of existing roads would add new 

unnatural linear features into the landscape. Trees would be removed, soil exposed, and roadbeds 

constructed including drainage features. The old road alignments were very steep and relocation 

would also have beneficial effects on scenery since they would follow more natural contour lines 

when completed. In addition the former roadbed segments would be restored.

Construction of approximately 18 miles of temporary roads would result in extensive short term 

effects on scenery. Effects are similar to road relocation noted above, although the temporary 

roads would be restored after use. Design features would be used to close entrance points and 

Best Management Practices for watershed would ensure drainage is re-established and the roads 

can rehabilitate. The temporary roads would begin to recover and should be mostly recovered and 

less noticeable to the casual observer in 5 to 10 years after the project is completed, and the roads 

are rehabilitated. 

Figure 82 provides an example of an active temporary road and Figure 83 shows a temporary 

road 5 years after restoration. These photos are taken at different locations. Some roads may take 

longer to fully revegetate and others may take a shorter amount of time.
Chapter 3: Affected Environment and Environmental Consequences

408 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 82: Active temporary road (Coconino NF).

Figure 83: A temporary road five years following rehabilitation (Coconino NF).

Road decommissioning of 4 miles of roads would entail obliteration whereby road surfaces may 

undergo some or all of the following actions: rip and seed or mulched with slash, inside ditches 

filled, road prisms outsloped, culverts and fill materials removed, stream crossings re-contoured, 

unstable sidecast or cutslopes removed or stabilized, and entrances blocked to prevent future 

access. These would have moderate short term effects to scenery. Design features would help 

assure these roads to a more stable status. The obliterated roads would begin to recover after 

treatment and would be mostly recovered and less noticeable to the casual observer in 5 to 10 

years.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 409

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

In addition to effects common to the action alternatives noted above, Alternative 2 proposes to 

use mechanical treatments on steep slopes using cable logging systems.

Cable Logging: Cable systems are used to transport cut logs to centralized processing areas and 

typically have extensive, short term effects to scenery. Trees are cut and limbed, and then cables 

pull the trees to the landing area. Many cut trees are transported along a common corridor which 

can be up to 1000 feet long and are about 12 feet wide. In order to remove trees in a large area, 

corridors would be established about every 100 to 140 feet. Effects typically include scraping and 

loss of limbs on remaining trees as a result of adjacent trees being felled or transported, creation 

of linear corridors, slash, creation of large, cleared landings where logs are decked and equipment 

can be accommodated (moved and turned). Following log removal, activity slash must be treated. 

Methods may include bunching and piling slash mechanically which can trample vegetation and 

cause bare soil to be exposed, hand piling, and lopping and scattering.

1. What are the potential impacts to scenic resources as a result of implementation due to 

the highly valued viewsheds contained within the project area? 

Measure: Comparison of existing scenic character to desired scenic character (descriptive). 

Scenic character descriptions encompass both ecological components and cultural values. 

Existing scenic character provides a baseline to compare the anticipated changes from the 

proposed action and whether this will make progress toward the desired scenic character.

The project area’s dominant scenic character is the almost continuous conifer forest with some 

rocky outcrops overlaying moderate to steeply sloping volcanic landforms. The project areas are 

viewed from the foreground, middleground and background from roads and trails. Grassland 

openings less than 5 acres in size are difficult to distinguish due to dense vegetation, but some do 

exist. Other scenery attributes include volcanic rocks and outcrops of all sizes. Seasonal changes 

including reliable winter snowfall accents the scenery as do wildlife sightings of birds and 

mammals. Research shows that such diversity of scenery attributes supports a positive viewing 

experience for people traveling through or recreating within the project area, and supports the 

quality of life for local residents and visitors (Ryan 2005).

Vegetation and landform both offer significant opportunities for scenery. The steep slopes of the 

DLH and MM make them a dramatic landscape features. Rocky outcrops and formations 

contribute to the unique identity of the mountain, and contribute to the complexity of planning 

management activities that may occur there. The vegetation carpets the landscape and provides 

the character of the area. There are also significant risks present in these landscapes due to the 

density of the forest, lack of fire, high quantities of fuels and steepness of the topography.

Alternative 2 would treat about 85 percent of the 10,544 acre project area. The treatments 

involving mechanical treatments and prescribed fire would make the most progress over the next 

20 years toward fuels reduction and the desired scenic character, and follow up burning would 

help to maintain gains made by the treatments. These long term gains would assure the desired 

scenic character is maintained. Mixed conifer treatments and burning would make more short 

term gains in scenic character because there is no follow up burning proposed. The short term 

gains would make some progress toward maintaining the desired scenic character. Treatments for 

MSO and goshawk nest cores would show less progress toward meeting fuels reduction and 
Chapter 3: Affected Environment and Environmental Consequences

410 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

desired scenic character due to specific wildlife habitat requirements. Much of the ponderosa pine 

and mixed conifer forest would be more resilient and would more closely resemble historic 

conditions. Uneven aged groups of trees of all age and size classes would be better represented. 

Under represented old, mature trees would be retained and new trees would be recruited to help 

meet the deficit. It is anticipated that there would be improvement in understory vegetation in all 

areas receiving treatment, but the mechanically treated and burned areas are expected to improve 

the most (Noble 2011). Stream course channels would have a more diverse and healthy 

understory that would help protect them if wildfires do occur. The existing road system would be 

maintained, about 4 miles of roads would be decommissioned and all temporary roads would be 

rehabilitated.

Measure: Description of expected disturbance and duration of disturbance upon completion 

of the project (years).

The short term effects common to all action alternatives have been described earlier. These 

provide information about expected short term effects during implementation. Project 

implementation may take at least ten years, but not all areas would be treated at the same time. 

Table 136 provides an estimate of the expected time post implementation for the desired 

landscape character features of the scenery to recover and improve.

Table 136: Estimated scenic recovery times by treatment type, Alternative 2

Estimated Recovery Time Post 

Implementation

Treatment Type Acres 1-3 years 3-5 

years

5-10 years

Aspen 22 hand cut/pile X* X*

Burn Only 270 burn only X

Electronic Site 18 ground based N/A**

Goshawk Nest Fuels 

Reduction

100 ground based X

Goshawk PFA Fuels 

Reduction

60 cable

299 ground based X

X

Grassland Restoration 60 ground based X

Mixed Conifer Fuels 

Reduction

514 cable

626 ground based X

X

Mixed Conifer Fuels 

Reduction - Hand Thin

132 hand cut/pile X

MSO Nest Fuels Reduction - 663 burn only X
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 411

Estimated Recovery Time Post 

Implementation

Burn Only

MSO Nest Fuels Reduction -

Hand Thin

122 hand cut/pile X

MSO Nest Roost Recovery -

Burn Only

37 burn only X

MSO Nest Roost Recovery -

Hand Thin

99 hand cut/pile X

MSO PAC Fuels Reduction 432 cable

2312 ground based

15 treat in place X

X

X

MSO PAC Fuels Reduction -

Hand Thin

202 hand cut/pile X

MSO PAC Fuels Reduction -

Wet Mixed Conifer

33 cable

147 hand cut/pile X

X

Ponderosa Pine Fuels 

Reduction

252 cable

2370 ground based X

X

Ponderosa Pine Fuels 

Reduction - Hand Thin

150 hand cut/pile X

*Dependent upon treatment type and if fencing is used. Fencing effects are longer lasting because trees must grow to an 

adequate size to withstand ungulate browsing. **Existing structure and facilities would keep the SIO at moderate.

2. Will progress be made toward desired scenic integrity objectives and scenic stability? 

Measure: Comparison of projected progress toward scenic stability and scenic integrity 

(acres).

The scenic integrity objective is the degree to which the landscape is free from visible 

disturbances that detract from the natural or socially valued appearance. As noted in the proposed 

Forest Plan revision, vegetation treatments should contribute toward the scenic integrity of the 

desired landscape character (Forest Service 2013). The scenic integrity objectives maps were

presented earlier in Figure 75 and Figure 76. 

Approximately 87 percent of the project area at DLH is mapped with a high scenic integrity 

objective, and about 73 percent of MM is mapped as high. This alternative would have the most 

short term negative effects to scenery due use of the cable logging system in about 20 percent of 
Chapter 3: Affected Environment and Environmental Consequences

412 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

the DLH area and about 3 percent of the MM area. The cable corridors created would introduce 

linear elements up and down the slopes. The corridors would occur about every 12 feet. Since 

these logging systems have not been used locally, it is difficult to predict how the areas would

recover. In background views, it would be more difficult to distinguish the cable corridors since 

the existing patterns of vegetation and large rock outcrops already create irregular patterns in the 

landscape. In middleground views, it would be easy to distinguish the linear corridors shapes of 

individual trees, openings and rock outcrops. In the foreground, the corridors are very obvious. 

The following set of figures show examples of cable logging corridors in Montana. Figure 86

through Figure 88 show examples of cable logging corridors from the Trapper-Bunkhouse 

Stewardship Project on the Bitterroot National Forest in Montana. The first photo (Figure 84) 

shows a corridor in mixed conifer or spruce-fir vegetation soon after harvest in a foreground 

view; 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 413

Figure 85 shows cable corridors in middleground view. Figure 86 through Figure 88 show before 

and after photos in different seasons. It is anticipated recovery could take five to ten years and 

possibly longer until the tree canopies close so that the linear corridors are not as obvious. In the 

foreground, disturbance to the individual trees, branches and understory plants would be visible. 

The corridors would be more obvious.

Figure 84: Cable corridor in foreground view, Lolo National Forest

 
Chapter 3: Affected Environment and Environmental Consequences

414 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 85: Cable corridors in middleground view, Clearwater National Forest

Figure 86: Before cable harvesting begins, Bitterroot National Forest
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 415

Figure 87: One year after cable harvesting in winter, Bitterroot National Forest

Figure 88: Summer two years after cable harvesting, Bitterroot National Forest

The overall scenic integrity for the entire project would be lowered during and for five to ten 

years following project implementation. Interim measures would be used during implementation 
Chapter 3: Affected Environment and Environmental Consequences

416 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

activities whereby the in high scenic integrity areas, approximately 8,20327 acres, would drop to 

moderate until project completion and for 5 to 10 years following. All of the cable treatment acres 

are in high scenic integrity objective areas. Burn only, hand thin and pile would be expected to 

recover fastest and cable logged areas the slowest. The 1,311 acres of the projects that are 

already moderate SIO would not require interim measures. Following implementation there 

would be improvement in the scenic integrity of the areas with a moderate objective.

The scenic stability determination finds that of the scenery attributes selected and evaluated for 

the existing condition, four are at high risk and two are at moderate risk. This would mean that 

there is HIGH risk to MOST attributes and FEW are stable. For this project scenic stability is 

VERY LOW. Most dominant scenery attributes of the valued scenic character are seriously 

threatened or absent due to their conditions and ecosystem stressors, and are not likely to be 

sustained. The few that remain may be moderately threatened but are likely to be sustained.

Assuming hand and mechanically treated areas would have piles burned and there would be 

follow up prescribed fire, these conclusions can be made:

Following recovery, there would be improvement in the scenic stability and scenic integrity of 

most areas. The main exception is the electronic sites where the existing structures and facilities 

will keep these areas at a moderate scenic integrity. There would be less improvement in scenic 

stability in MSO nest and roost areas and potentially in goshawk nest cores because specific 

wildlife habitat requirements. There may also be slightly less improvement in the mixed conifer 

areas because repeat burns are not planned. Other areas would show improved scenic stability 

especially with return burns. The existing road system used for hauling timber and/or biomass 

would be maintained and stable. Four miles of decommissioned roads would stabilized and be 

restored, improving scenic stability and scenic integrity. Temporary roads used for 

implementation would be restored. Over time this would maintain or improve scenic stability and 

scenic integrity. 

Cumulative Effects

The actions relating to scenic attributes, landscape character and scenic integrity considered in the 

cumulative effects analysis for this alternative are the same as those described for the cumulative 

effects analysis for the No Action Alternative. 

The cumulative effects of past management activities are visible as the existing conditions. 

Vegetation management practices, fire suppression, and over grazing have resulted in the current 

even-aged forest structure, overstocked conditions, sparse understory trees, shrubs, grasses and 

forbs, conifer encroached meadows and savannas.

The short term cumulative effects (1-5 years) of Alternative 2 combined with similar current and 

future restoration treatments and prescribed burning projects are expected to be widespread. 

There will be evidence of restoration treatments, and the scenic quality would be decreased in 

some places in most of the ponderosa pine on the Coconino and Kaibab NF. For example, in areas 

where restoration treatments result in skid trails or removal of vegetation for staging areas or log 

decks, there could be a cumulative impact to scenic attributes where activities such as dispersed 

recreational use, grazing, or adjunct private land or infrastructure development is also occurring. 

In general these cumulative impacts to scenic attributes would be localized in scale (1-10 acres) 

and are most likely to be of short-term duration (1-5 years).

 

27 Project areas total acres minus no treatment
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 417

In the long term (5 to 20 years), there would be large and widespread improvement in the health 

and sustainability of scenic attributes that make up the landscape character of the ponderosa pine 

forest. Forest users would experience an open forest with tree groups of varying ages, sizes and 

shapes, large, mature trees, and healthy, diverse understory. In many places, the scenic integrity 

objectives would be met.

When natural stressors such as wildfires or insect outbreaks occur, or human activities such as 

new utility corridors, or development of a new recreation site, or a new private subdivision is 

developed, the cumulative effects of Alternative 2 and other projects would result in small and 

localized changes in the scenic character of the ponderosa pine forest. When drought conditions 

or unusual weather events as a result of climate change occur, the ponderosa pine forest would be 

healthier and more resilient to such events, thus counteracting the effects of climate change which 

are likely to detract from scenic attributes. The overall trend from this alternative would be 

toward improving landscape attributes, and sustainable landscape character.

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Alternative 3 would include the effects common to all alternatives and all action alternatives and 

would employ helicopter yarding.

Helicopter Yarding: Helicopter logging typically has moderate effects on scenery. Trees are 

typically cut and limbed leaving slash behind, but it is possible to transport whole trees. Logs 

would have cables attached, then would be lifted up and transported away from the cutting area to 

central locations (log decks) where the logs are detached from the cables. If whole trees are 

transported, they must be limbed at the log deck creating very large quantities of slash. 

Equipment such as grapplers are used at the log decks to stack logs and load them into trucks for 

transport. Effects include scraping and loss of limbs on existing trees as a result of adjacent trees 

being felled or transported, creation of large, cleared landings where slash may be piled, logs are 

decked and equipment can be accommodated (moved and turned) and helicopters can be landed. 

Following log removal, activity slash must be treated which may include bunching and piling 

mechanically which can trample vegetation and cause bare soil to be exposed, hand piling, and 

lopping and scattering. The effects of slash treatment are short term depending on how slash is 

treated. Hand piling creates noticeable piles, but after these are burned, there is a shorter recovery 

time than with mechanical piling. Lop and scatter results in untreated slash since it is allowed to 

remain in an area until it is burned. Ryan (2005) found this is not as acceptable as when slash is 

treated either by chipping or piling. Mechanical piling may include bulldozers pushing slash into 

large piles which can trample vegetation and cause bare soil to be exposed. When these large 

piles are burned the soil can be sterilized lengthening the time needed for the burned areas to 

rehabilitate.

1. What are the potential impacts to scenic resources as a result of implementation due to 

the highly valued viewsheds contained within the project area? 

Measure: Comparison of existing scenic character to desired scenic character (descriptive). 

Scenic character descriptions encompass both ecological components and cultural values. 

Existing scenic character provides a baseline to compare the anticipated changes from the 

proposed action and whether this will make progress toward the desired scenic character.
Chapter 3: Affected Environment and Environmental Consequences

418 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

The project area’s dominant scenic character is the almost continuous conifer forest with some 

rocky outcrops overlaying moderate to steeply sloping volcanic landforms. The project areas are 

viewed from the foreground, middleground and background from roads and trails. Grassland 

openings less than 5 acres in size are difficult to distinguish due to dense vegetation and 

encroachment, but some do exist. Other scenery attributes include volcanic rocks and outcrops of 

all sizes. Seasonal changes including reliable winter snowfall accents the scenery as do wildlife 

sightings of birds and mammals. Research shows that such diversity of scenery attributes supports 

a positive viewing experience for people traveling through or recreating within the project area, 

and supports the quality of life for local residents and visitors (Ryan 2005).

Vegetation and landform both offer significant opportunities for scenery. The steep slopes of the 

DLH and MM make them a dramatic landscape features. Rocky outcrops and formations 

contribute to the unique identity of the mountain, and contribute to the complexity of planning 

management activities that may occur there. The vegetation carpets the landscape and provides 

the character of the area. There are also significant risks present in these landscapes due to the 

density of the forest, lack of fire, high quantities of fuels and steepness of the topography.

Alternative 3 would treat about 85 percent of the 10,544 acre project area. Many of the treatments 

would make progress over the next 20 years toward fuels reduction and the desired scenic 

character, and follow up burning in the ponderosa pine would help to maintain gains made by the 

treatments. Treatments for MSO and goshawk nest cores would show less progress toward 

meeting fuels reduction and desired scenic character due to specific wildlife habitat requirements. 

Much coniferous forest would be more resilient and would more closely resemble historic 

conditions, although lack of follow up burning in the mixed conifer vegetation will result in less 

progress toward the desired scenic character. Uneven aged groups of trees of all age and size 

classes would be better represented. Under represented old, mature trees would be retained and 

new trees would be recruited to help meet the deficit. Stream course channels would have a more 

diverse and healthy understory that would help protect them if wild fires do occur. The existing 

road system would be maintained, about 4 miles of roads would be decommissioned and all 

temporary roads would be restored. These actions would maintain or improve scenic stability and 

scenic integrity.

Measure: Description of expected disturbance and duration of disturbance upon completion 

of the project.

Overall scenic integrity would be lowered for a shorter time during and for about five years 

following project implementation. Interim measures would be used during implementation 

activities whereby the in high scenic integrity areas, approximately 6,481 acres, would drop to 

moderate until project completion and for about 5 years following. Burn only, hand thin and pile 

and burn only would be expected to recover fastest and the steep slope and helicopter yarded 

(depending upon whether whole tree or log transit is used) areas the slowest. See Table 137 for an 

estimate of recovery time by treatment type. This would ensure adequate time for closed and 

decommissioned roads to naturalize, evidence of logging activities to recover, trailside vegetation 

to re-establish and initial prescribed fire activities to soften. The 1,311 acres of the projects that 

are already moderate SIO would not require interim measures.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 419

Table 137: Estimated recovery time by treatment type for the Dry Lake Hills and 

Mormon Mountain areas, Alternative 3.

Estimated Recovery Time Post 

Implementation

Treatment Type Acres 1-3 years 3-5 

years

5-10 years

Aspen 22 hand cut/pile X* X*

Burn Only 270 burn only X

Electronic Site 18 ground based N/A**

Goshawk Nest Fuels 

Reduction

100 ground based X

Goshawk PFA Fuels 

Reduction

39 helicopter

320 ground based

X***

X

Grassland Restoration 60 ground based X

Mixed Conifer Fuels 

Reduction

425 helicopter

733 ground based

X

X

Mixed Conifer Fuels 

Reduction - Hand Thin

85 hand cut/pile X

MSO Nest Fuels Reduction -

Burn Only

663 burn only X

MSO Nest Fuels Reduction -

Hand Thin

122 hand cut/pile X

MSO Nest Roost Recovery -

Burn Only

37 burn only X

MSO Nest Roost Recovery -

Hand Thin

99 hand cut/pile X

MSO PAC Fuels Reduction 267 helicopter

2520 ground based

X

X

MSO PAC Fuels Reduction -

Hand Thin

202 hand cut/pile X
Chapter 3: Affected Environment and Environmental Consequences

420 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Estimated Recovery Time Post 

Implementation

MSO PAC Fuels Reduction -

Wet Mixed Conifer

766 ground based X

Ponderosa Pine Fuels 

Reduction

242 helicopter

2389 ground based

X

X

Ponderosa Pine Fuels 

Reduction - Hand Thin

150 hand cut/pile X

*Dependent upon treatment type and if fencing is used. Fencing effects are longer lasting because trees must grow to an 

adequate size to withstand ungulate browsing. **Existing structure and facilities would keep the SIO at moderate. ***If 

slash is left on site and has to be gathered into slash piles, there would be longer recovery time (closer to 5 years)

2. Will progress be made toward desired scenic integrity objectives? 

Measure: Measure: Comparison of projected progress toward scenic stability and scenic 

integrity (acres)

The scenic stability determination finds that of the scenery attributes selected and evaluated for 

the existing condition, five are at high risk and one is at moderate risk. This would mean that 

there is HIGH risk to MOST attributes and FEW are stable. For this project scenic stability is 

VERY LOW. Most dominant scenery attributes of the valued scenic character are seriously 

threatened or absent due to their conditions and ecosystem stressors, and are not likely to be 

sustained. The few that remain may be moderately threatened but are likely to be sustained.

The scenic integrity or degree to which the landscape is free from visible disturbances that 

detracts from the natural or socially valued appearance (Forest Service 2007). The majority of 

both DLH and MM are shown as high scenic integrity, with small amounts of moderate. 

Minimum scenic integrity is achieved through activities that reduce or minimize visual 

disturbances in the landscape (Forest Service 2007). This project has extreme fire hazard in most 

of the area, and it is necessary to move the existing ecosystem conditions towards desired 

conditions. 

This alternative would have the short term negative effects to scenery using ground based 

treatments and helicopter yarding. There would be fewer effects than with Alternative 2 where 

cable logging is proposed.

Assuming hand and mechanically treated areas would have piles burned and there would be 

follow up prescribed fire, these conclusions can be made:

Following recovery, there would be improvement in the scenic integrity of most areas. The main 

exceptions are the electronic sites where the existing structures and facilities would keep these 

areas at a moderate scenic integrity. There would be less improvement in scenic stability in MSO 

nest and roost areas and potentially in goshawk nest cores because specific wildlife habitat 

requirements. There may also be slightly less improvement in the mixed conifer areas because 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 421

repeat burns are not planned. Other areas would show improved scenic stability especially with 

return burns. The existing road system used for hauling timber and/or biomass would be 

maintained and stable. Four miles of decommissioned roads would stabilized and be restored, 

improving scenic stability and scenic integrity. Temporary roads used for implementation would 

be restored. Over time this would maintain or improve scenic stability and scenic integrity. This 

alternative would result in slightly more improvement in both scenic stability and scenic integrity.

Cumulative Effects

The cumulative effects for Alternative 3 are the same as those discussed under Alternative 2. 

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Alternative 4 would have the same effects as those common to all action alternatives. This 

alternative would be similar to Alternatives 2 and 3; however the purpose of Alternative 4 is to 

implement the minimum amount of treatment necessary to meet the purpose and need. 

1. What are the potential impacts to scenic resources as a result of implementation due to 

the highly valued viewsheds contained within the project area? 

Measure: Comparison of existing scenic character to desired scenic character (descriptive). 

Scenic character descriptions encompass both ecological components and cultural values. 

Existing scenic character provides a baseline to compare the anticipated changes from the 

proposed action and whether this will make progress toward the desired scenic character.

The project area’s dominant scenic character is the almost continuous conifer forest with some 

rocky outcrops overlaying moderate to steeply sloping volcanic landforms. The project areas are 

viewed from the foreground, middleground and background from roads and trails. Grassland 

openings less than 5 acres in size are difficult to distinguish due to dense vegetation and 

encroachment, but some do exist. Other scenery attributes include volcanic rocks and outcrops of 

all sizes. Seasonal changes including reliable winter snowfall accents the scenery as do wildlife 

sightings of birds and mammals. Research shows that such diversity of scenery attributes supports 

a positive viewing experience for people traveling through or recreating within the project area, 

and supports the quality of life for local residents and visitors (Ryan 2005).

Vegetation and landform both offer significant opportunities for scenery. The steep slopes of the 

DLH and MM make them a dramatic landscape features. Rocky outcrops and formations 

contribute to the unique identity of the mountain, and contribute to the complexity of planning 

management activities that may occur there. The vegetation carpets the landscape and provides 

the character of the area. There are also significant risks present in these landscapes due to the 

density of the forest, lack of fire, high quantities of fuels and steepness of the topography.

Alternative 4 would treat about 55 percent of the 10,544 acre project area. The areas treated 

would make the least progress over the next 20 years toward fuels reduction and the desired 

scenic character, and follow up burning would help to maintain gains made by the treatments. 

Treatments for MSO and goshawk nest cores would show less progress toward meeting fuels 

reduction and desired scenic character due to specific wildlife habitat requirements. About 62 

percent of the coniferous forest would be more resilient and would more closely resemble historic 

conditions, although lack of repeat burning in mixed conifer forests would make less progress 
Chapter 3: Affected Environment and Environmental Consequences

422 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

toward scenic stability. In these places uneven aged groups of trees of all age and size classes 

would be better represented. Under represented old, mature trees would be retained and new trees 

would be recruited to help meet the deficit. Stream course channels in treated areas would have a 

more diverse and healthy understory that would help protects them if wildfires do occur.

Approximately 5,800 acres would not be treated (includes about 1,600 acres in the Orion Timber 

Sale that would not receive additional treatment and the no treatment areas of rock and the 

pipeline). The remaining almost 4,200 acres not proposed for treatment would stay in the existing 

condition.

The existing road system would be maintained, about 4 miles of roads would be decommissioned, 

and all temporary roads would be restored. These actions for roads would maintain or improve 

scenic stability and scenic integrity.

Measure: Description of expected disturbance and duration of disturbance upon completion 

of the project.

Although this alternative would make the least progress toward the purpose and need, there 

would be less disturbance and fewer short term negative effects with this alternative than with 

either Alternatives 2 or 3. Table 138 shows the estimated time needed post implementation.

Table 138: Estimate of recovery time following implementation, Alternative 4.

Estimated Recovery Time Post 

Implementation

Treatment Type Acres 1-3 years 3-5 

years

5-10 years

Aspen 2 hand cut/pile X* X*

Burn Only 67 burn only X

Electronic Site 18 ground based N/A**

Goshawk Nest Fuels 

Reduction

100 ground based X

Goshawk PFA Fuels 

Reduction

286 ground based X

Grassland Restoration 53 ground based X

Mixed Conifer Fuels 

Reduction

542 ground based X

Mixed Conifer Fuels 

Reduction - Hand Thin

0 hand cut/pile
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 423

Estimated Recovery Time Post 

Implementation

MSO Nest Fuels Reduction -

Burn Only

MSO Nest Fuels Reduction -

Hand Thin

122 hand cut/pile X

MSO Nest Roost Recovery -

Burn Only

0 burn only

MSO Nest Roost Recovery -

Hand Thin

MSO PAC Fuels Reduction 2160 ground based X

MSO PAC Fuels Reduction -

Hand Thin

228 hand cut/pile X

MSO PAC Fuels Reduction -

Wet Mixed Conifer

766 ground based X

Ponderosa Pine Fuels 

Reduction

2166 ground based X

Ponderosa Pine Fuels 

Reduction - Hand Thin

86 hand cut/pile X

2. Will progress be made toward desired scenic integrity objectives? 

Measure: Comparison of projected progress toward scenic stability and scenic integrity 

(acres)

The scenic stability determination finds that of the scenery attributes selected and evaluated for 

the existing condition, five are at high risk and one is at moderate risk. This would mean that 

there is HIGH risk to MOST attributes and FEW are stable. For this project scenic stability is 

VERY LOW. Most dominant scenery attributes of the valued scenic character are seriously 

threatened or absent due to their conditions and ecosystem stressors, and are not likely to be 

sustained. The few that remain may be moderately threatened but are likely to be sustained.

The scenic integrity or degree to which the landscape is free from visible disturbances that 

detracts from the natural or socially valued appearance (Forest Service 2000). The majority of 

both DLH and MM are shown as high scenic integrity, with small amounts of moderate. 

Minimum scenic integrity is achieved through activities that reduce or minimize visual 

disturbances in the landscape (Forest Service 2000). This project has extreme fire hazard in most 
Chapter 3: Affected Environment and Environmental Consequences

424 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

of the area, and it is necessary to move the existing ecosystem conditions towards desired 

conditions. 

This alternative would make the least progress toward scenic stability, but would have the least 

short term negative effects to scenery using ground based treatments. There would be fewer 

effects than with Alternative 2 where cable logging is proposed or 3 where helicopter yarding 

would be used.

Overall scenic integrity would be lowered for about the same over durations, but implementation 

would take less time. Interim measures would be used during implementation activities whereby 

the in high scenic integrity areas, approximately 567728 acres, would drop to moderate until 

project completion and for about 5 years following. Hand thin and pile and burn only would be 

expected to recover fastest and the steep slope and ground based conventional logged areas the 

slowest. See Table 138 for an estimate of recovery time by treatment type. This would ensure 

adequate time for closed and decommissioned roads to naturalize, evidence of logging activities 

to recover, trailside vegetation to re-establish and initial prescribed fire activities to soften. The 

about 670 acres of the projects that are already moderate SIO would not require interim measures. 

Assuming hand and mechanically treated areas would have piles burned and there would be 

follow up prescribed fire, these conclusions can be made:

Following recovery, there would be improvement in the scenic integrity in about 62 percent of the 

area. The remaining area would remain at existing conditions. The main exceptions are the 

electronic sites where the existing structures and facilities would keep these areas at a moderate 

scenic integrity. There would be no improvement in scenic stability in MSO nest and roost areas 

and less improvement in goshawk nest cores because specific wildlife habitat requirements. There 

may also be about half the improvement in the mixed conifer areas in addition to these areas not 

receiving repeat burns. Other areas would show improved scenic stability especially with return 

burns.

The main difference in this alternative is that the scenic stability, already very low would only be 

improved in about 62 percent of the area. The remaining almost 4,200 acres would show no 

improvement at all.

Scenic integrity would be improved in about 62 percent of the area. On about 4,200 acres, the 

scenic integrity would be maintained in the short term but would begin to deteriorate in the long 

term. While strategic placement of treatments would help to mitigate wildfire starts, there would 

still be a distinct possibility of similar effects from wildfire in the untreated areas as noted in the 

existing condition and No Action Alternative.

The existing road system used for hauling timber and/or biomass would be maintained and stable. 

Four miles of decommissioned roads would stabilized and be restored, improving scenic stability 

and scenic integrity. Temporary roads used for implementation would be restored. Over time this 

would maintain or improve scenic stability and scenic integrity. This alternative would result in 

slightly more improvement in both scenic stability and scenic integrity.

 

28 Project areas total acres minus no treatment
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 425

Cumulative Effects

Cumulative effects for this alternative would be the same as Alternatives 2 and 3 but to a 

somewhat lesser degree due to fewer acres proposed for treatment.

Irreversible and Irretrievable Commitments of Resources

The action alternatives focus on reduction of fuels to reduce the threat of high severity wildfire 

and subsequent flooding in two key areas near the City of Flagstaff, Arizona: the DLH portion of 

the Rio de Flag Watershed north of Flagstaff, and the MM portion of the Upper Lake Mary 

Watershed south of Flagstaff. As such, there is no irretrievable or irreversible commitment of

scenic resources.

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

Amendment 1: Modify Forest Plan language to allow mechanical treatments in MSO PACs up to 

18 inches dbh and hand thinning treatments up to 9 inches dbh and prescribed burning within 

MSO nest/cores. The monitoring requirement specified under the Forest Plan would be amended 

to include the monitoring plan developed by the Forest Service, U.S. Fish and Wildlife Service, 

and the Rocky Mountain Research Station referenced in the following section titled, 

“Monitoring.” This amendment would also remove timing restrictions within MSO PACs for the 

duration of the FWPP project. Treatments within PACs would be accomplished as quickly as 

possible to reduce the duration of impacts, and would be coordinated with FWS. The purpose of 

this amendment would be to facilitate treatment in high-priority locations such as Mexican 

spotted owl occupied habitat to prevent high-severity wildfire. This is based on language in the 

Mexican Spotted Owl Recovery Plan (2012), which states, “[wildfires] result in the most 

significant alteration of owl habitat and hence, have the greatest potential for loss of habitat.”

Effects to Scenic Resources

Amendment would have positive effects for many of the desired scenic character attributes as 

noted above and would improve scenic stability and improve scenic integrity. Since treatments 

would be coordinated with Fish and Wildlife Service to meet habitat requirements, it would also 

meet the desired condition of large old mature trees are a prominent component of the uneven 

aged forest. The form and shape of large trees and presence of a mature forest structure is critical 

to the landscape character of the ponderosa pine and mixed conifer types.

Amendment 2: Removing language restricting mechanical equipment to slopes less than 40 

percent and language identifying slopes above 40 percent as inoperable. This amendment would 

allow mechanical harvesting on slopes greater than 40 percent within the project area. 

It would be necessary to allow for use of specialized mechanical equipment to cut and remove 

trees on steep slopes to reduce the risk of high-severity wildfire in this project area due to the 

preponderance of areas with greater than 40 percent slope in the project area. Furthermore, since 

the Forest Plan was written and amended, mechanized ground-based equipment has progressed to 

be able to operate on steep slopes more effectively. While this specialized equipment is not 

commonplace in this region due to the high cost of its use, the approval of the City bond makes 

the use of such equipment a possibility for this project. In order to be able to utilize such 

equipment to treat slopes above 40 percent in the project area and meet the purpose and need, this 

Forest Plan amendment is needed.
Chapter 3: Affected Environment and Environmental Consequences

426 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Effects to Scenic Resources

Use of specialized equipment would have short term negative effects to scenery, but would 

enable much more treatment of vegetation than the current limits in the Forest Plan. Over the long 

term (10-20 years) there would be more improvement to scenic stability if the specialized 

equipment were able to operate on greater than 40 percent slopes than not. Since so much of the 

project areas are departed from historic conditions and at high risk from stressors including 

wildfire, intensive weather events, climate change and insects and disease these more intensive 

management actions are needed (Guido 2011). Scenic integrity would be maintained or improved 

over the long term as well. 

Economics

This section will address the cost of implementing FWPP. This estimation includes the following 

costs: surveying and marking cultural sites, marking and cruising timber, road construction, road 

rehabilitation, road maintenance, preparing contracts, project administration, harvesting trees, 

hand thinning and prescribed burning. It does not include the cost of preparing the Environmental 

Impact Statement for the project.

Methodology

Implementation of the Flagstaff Watershed Protection Project would require several types of fuel 

reduction methods and other actions that are related to their implementation. Costs to undertake 

these activities have been estimated using a variety of methods. These costs are only estimates. 

Actual implementations cost, especially for logging systems not commonly used in northern 

Arizona, may vary substantially. The activities that have been analyzed for and the methodology 

that was used to estimate their costs are: 

Cultural Resource Survey Cost

A cultural resource survey and marking of cultural resource sites has already been completed for 

the project area. The project has been cleared for cultural resources. However if the chosen 

alternative includes temporary roads outside of existing, surveyed prisms, additional surveys may 

need to be performed. It is likely that these acres would be small and the survey completed “in 

house” by the Forest Service. These costs were provided by the Flagstaff District archaeologist, 

based on past experienced costs.

Sale Preparation Cost

Sale preparation costs are all costs associated with locating harvest units, timber marking and 

timber cruising. These costs were provided by the Flagstaff District timber management officer 

based on past experienced costs. 

Sale Administration Cost

This is the cost to supervise the logging done by a contractor and to administer the contract. 

These costs were estimated by the Flagstaff District timber management office based on past 

experienced costs.

Temporary Road Construction and Rehabilitation Cost

This is the estimated cost for a contractor to construct new temporary roads and rehabilitate the 

road prism after use. It was estimated using the costs provided in the inter-regional cost guide.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 427

Construction of Relocated System Roads Cost

This is the estimated cost for a contractor to build relocated system roads. It was estimated using 

the costs provided in the inter-regional cost guide.

Road Rehabilitation Cost (Not including new temporary roads)

This is the estimated cost for a contractor to rehabilitate existing system roads that are to be 

decommissioned, roads that are already decommissioned and in need of rehabilitation and 

existing non-system roads that are in need of rehabilitation. It was estimated using the costs 

provided in the inter-regional cost guide.

Prescribed Burning Cost

This is the cost to carry out prescribed burning. It was estimated by the Flagstaff District assistant 

fire management officer (fuels) based on past experienced costs.

Net Timber Value

Net timber value is the value of the timber to be harvested as it stands on the stump; it is also 

referred to as stumpage value. This is the monetary amount that a contractor would be willing to 

pay the government for the timber or the amount that the contractor would need to be paid in 

order to harvest and haul the timber from the site. 

In May of 2012, the Forest Service awarded the Four Forest Restoration Initiative (4FRI) 

contract. This contract specifies a product value for each geographic working circle within the 

4FRI contract area. 4FRI will be the major market for timber produced from the Flagstaff Ranger 

District until at least 2021, which will be the end of the current contract period. The value of 

timber in the working circle that FWPP is located within, is a positive $3.50/ green ton for logs 

greater than 5 inches on the small end (i.e. the contractor pays the government for the timber) The 

material that is smaller than this, including limbs and tops, has a negative value of $3.50/green 

ton (i.e. the government pays the contractor $3.50/green ton to remove this material from the 

site). 

This EIS assumes that these product values indicate the current market value for timber cut on 

FWPP for ground based harvesting. However due to the steep terrain on much of FWPP, more 

expensive logging systems capable of working on these steep slopes, such as skyline, steep slope 

cut to length and helicopter are under consideration. These systems would have a higher logging 

cost than conventional ground based logging. Conventional ground based logging has the lowest 

logging cost per ton of any logging system. In order to account for the cost of these higher priced 

systems and the effect they have on net timber value, logging cost was calculated for all systems 

and net timber value was adjusted to reflect the increased cost of these more expensive logging 

systems. For example if a ground based logging cost is calculated to be $25/ton and has a product 

value of $3/ton and a skyline logging system has a cost of $48/ton, then this increased cost would 

be subtracted from the ground based product value of $3/ton to show the net timber value of the 

timber harvested with a skyline system. This calculation would be: $3/ton (product value of a 

ground based system) - $23/ton (increased cost of a skyline system) = a negative $20/ton product 

value for the timber harvested with a skyline system. Trees down to a 4-inch dbh were used in 

logging cost calculations.

It is estimated that of the standing stem volume in the project area, 85 percent is sawlog size with 

a value to the government of $3.50/ton, and 15 percent is smaller than this with a value to the 

government of -$3.50/ton. This yields a composite value for $2.45/ton of stem material logged. 
Chapter 3: Affected Environment and Environmental Consequences

428 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

It is also estimated that there is approximately 5 tons/acre of branches that would be bought in 

from the harvest units when stems are logged. This material can be burned at the landing or 

utilized. If it is utilized it would cost the government $3.50/ton to have it removed. 

All logging cost was estimated using the Forest Service’s log cost program (USDA FS, version 

13.1). 

Affected Environment

As discussed under Chapter 1, during the November 2012 elections, residents of Flagstaff, AZ 

approved a $10 million bond to support forest restoration work within key watersheds on the 

Coconino National Forest and State of Arizona lands. This is one of only a handful of examples in 

the country where forest restoration work on the National Forests is being funded by a 

municipality, and the only known instance where such an effort is funded from municipal bonds. 

Additional funding for the planning effort has been leveraged from the Forest Service in order to 

retain as much of the bond money for implementation as possible.

Environmental Effects

Each alternative is discussed individually, followed by a comparison of costs by alternative (Table 

142).

Alternative 1: No Action

Direct & Indirect Effects

Cultural Resource Cost

A contract for cultural resource survey has already been completed and a cost incurred.

Cultural resource survey = $72,000

Marking of cultural resource sites = $4,000

Forest Service Contract Admin. Cost = $26,000

Total Cultural Resource Cost = $102,000

Sale Preparation Cost

No sale preparation would be done under this alternative and no cost incurred.

Sale Administration Cost

No sale administration done would be under this alternative and no administrative cost incurred.

Temporary Road Construction and Rehabilitation Cost

No temporary roads would be built under this alternative and no costs incurred

Construction of Relocated System Roads

No road construction of relocated system roads would be done under this alternative and no cost 

incurred.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 429

Road Rehabilitation Cost

No road rehabilitation would be done under this alternative and no cost incurred.

Hand Thinning Cost

No hand thinning would be done under this alternative and no cost incurred

Prescribed Burning Cost

No prescribed burning would be done under this alternative and no cost incurred.

Net Timber Value

No logging would be done under this alternative and no cost incurred or timber value generated.

Cumulative Effects

Cumulative effects do not apply to costs; costs are not effects.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Cultural Resource Survey and Site Marking Cost

Cultural resource survey = $72,000

Marking of cultural resource sites = $4,000

Forest Service contract administration cost = $26,000

Survey new road locations= $2,160

Total Cultural Resource Survey and Site Marking Cost = $104,160

Sale Preparation Cost

7,109 acres of sale preparation @ $120/acre = $853,080

4 task orders/timber sale contracts@ $4,500/contract = $18,000

Total sale preparation cost = $871,080

 

Sale Administration Cost

7,109 acres of timber sale to administer @ $50/acre = $355,450

Temporary Road Construction and Rehabilitation Cost

14.64 miles of temporary road construction and rehabilitation @ $15,089/mile = $220,903

Construction of Relocated System Roads

1.57 miles of system road relocated @ $11,885/mile = $18,659

Road Rehabilitation Cost

6.03 miles of road rehabilitations @ $9,319/mile =$56,194 (includes 1.44 miles of road 6277)
Chapter 3: Affected Environment and Environmental Consequences

430 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Hand Thinning Cost

846 Acres @ = $719,100/acre 

Prescribed Burning Cost5,818 acres of slopes under 40% @ $500/acre =$2,919,546

3,107 acres of slopes over 40% @ $750/acre = $2,331,750

Total prescribed burn cost = $5,251,296

Net Timber Value

Net timber value under this alternative is a positive $274,908. Logging cost calculations for 

Alternative 2 are shown in Table 139.

Table 139: Logging cost summary, Alternative 2

Logging 

System

Stump to 

Truck Cost 

($/tons)

Volume/ac

(tons)

Acres Total 

Volume

(tons)

Timber 

Value 

($/ton)

Net Timber 

Value by 

Logging 

System ($)

Groundbased 

Mechanical

$27 49 5818 285,082 +$2.45 +$698,451

SkylineMachine 

Cut

$35 38.5 393 15,130 ($5.55) ($83,971)

SkylineHand Cut$41 38.5 271 10,433 ($11.55) ($120,501)

ExcalineMachine 

Cut

$32 38.5 455 17,517 ($2.55) ($44,668

Excalinehand Cut$37 38.5 172 6,622 ($9.55) ($49,996)

Total 7109 334,784

Non-stem

Biomass

N/A 5 7109 35,545 ($3.50) ($124,407)

Total 

Value

+$274,908

Cumulative Effects

There would be no cumulative environmental effects under this alternative.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 431

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Cultural Resource Survey and Site Marking Cost

Cultural resource survey = $72,000

Marking of cultural resource sites = $4,000

Forest Service contract administration cost = $26,000

Survey new road locations= $1,820

Total Cultural Resource Survey and Site Marking Cost = $103,820

Sale Preparation Cost

7,137 acres of sale preparation @ $120/acre = $856,440

4 task orders/timber sale contracts@ $4,500/contract = $18,000

Total sale preparation cost = $874,440

Sale Administration Cost

7,137 acres of timber sale to administer @ $50/acre = $356,850

Total Sale Administration Cost = $355,450

Temporary Road Construction and Rehabilitation Cost

9.91 miles of temporary road construction and rehabilitation @ $15,089/mile = $149,532

Construction of Relocated System Roads

1.57 miles of system road relocated @ $11,885/mile= $18,659

Road Rehabilitation Cost

6.03 miles of road rehabilitations@ $ 9,319/mile = $56,194 (includes 1.44 miles of road 6277)

Hand Thinning Cost

832 acres @ $850/acre = $707,200/acre 

Prescribed Burning Cost5,818 acres of slopes under 40% @ $500/acre =$2,919,546

3,107 acres of slopes over 40% @ $750/acre = $2,331,750

Total prescribed burn cost = $5,251,296

Net Timber Value

Net timber value under this alternative is a negative $992,747. Logging cost calculations for 

Alternative 3 are shown in Table 140.
Chapter 3: Affected Environment and Environmental Consequences

432 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 140: Logging cost summary, Alternative 3

Logging 

System

Stump to 

Truck 

Cost 

($/ton)

Volume/ac

(tons)

Acres Total 

Volume

(tons)

Timber 

Value 

($/ton)

Net Timber 

Value by 

Logging 

System ($)

Groundbased 

Mechanical

$27 49 5818 285,082 +$2.45 +$698,451

Steep Slope 

Cut to length

$33 38.5 346 13,321 ($3.55) ($47,298)

Helicopter $70 38.5 973 37,460 ($40.55) ($1,519,003)

Total 7137 335,863

Non-Stem

Biomass

N/A 5 7137 35,685 ($3.50) ($124,897)

Total Value ($992,747)

Cumulative Effects

There would be no cumulative environmental effects under this alternative.

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Cultural Resource Survey and Site Marking Cost

Cultural resource survey = $72,000

Marking of cultural resource sites = $4,000

Forest Service contract administration cost = $26,000

Survey new road locations= $1,780

Total Cultural Resource Survey and Site Marking Cost = $103,780

Sale Preparation Cost

5,264 acres of sale preparation @ $120/acre = $631,680

2 task orders/timber sales @$4,500/each = $9,000

Total sale preparation cost = $640,680

Sale Administration Cost

5,264 acres of timber sale to administer @ $50/acre = $263,200

Total Sale Administration Cost = $263,200

Temporary Road Construction and Rehabilitation Cost

9.20 miles of temporary road construction and rehabilitation @ $15,089/mile = $138,819
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 433

Construction of Relocated System Roads

1.57 miles of system road relocated @ $11,885/mile= $18,659

Road Rehabilitation Cost

6.03 miles of road rehabilitations@ $ 9,319/mile= $ 56,194 (includes 1.44 miles of road 6277)

Hand Thinning Cost

438 Acres @ = $372,300/acre 

Prescribed Burning Cost5,297 acres of slopes under 40% @ $500/acre =$2,648,500

 505 acres of slopes over 40% @ $750/acre = $378,750

Total prescribed Burn cost =$3,027,250

Net Timber Value 

Net timber value under this alternative is a positive $539,823. Logging cost calculations for 

Alternative 4 are shown in Table 141.

Table 141: Logging cost summary, Alternative 4

Logging 

System

Stump to 

Truck Cost 

($/ton)

Volume/ac

(tons)

Acres Total 

Volume

(tons)

Timber 

Value 

($/ton)

Net Timber 

Value by 

Logging 

System ($)

Groundbased 

Mechanical

$27 49 5,264 257,936 +$2.45 +$631,943

Total 5,264 257,936 +$2.45 +$631,943

Non-Stem

Biomass

5 5,264 26,320 ($3.50) ($92,120)

Total 

Value

+$539,823

Cumulative Effects

Cumulative effects do not apply to costs; costs are not effects.

Comparison of Costs by Alternative

A comparison of costs to implement this project is shown in Table 142. All costs are subtracted 

from net timber value to arrive at a total estimated cost to implement the project. 

Table 142: Comparison of costs per alternative

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Cultural Resource Survey 

Cost

$102,000 $104,160 $103,820 $103,780

Sale Preparation Cost $0 871,080 874,440 640,680
Chapter 3: Affected Environment and Environmental Consequences

434 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Sale Administration Cost $0 355,450 356,850 263,200

Temp Road Construction 

and Rehabilitation

220,903 149,532 138,819

Construction of Relocated 

System Roads Cost

$0 18,659 18,659 18,659

Road Rehabilitation Cost $0 56,194 56,194 56,194

Hand Thinning $0 719,100 707,200 372,300

Prescribed Burning $0 5,251,296 5,251,296 3,027,250

Costs of Implementation, 

(not including net timber 

value)

$102,000 $7,596,842.00 $7,517,991.00 $4,620,882.00

Net Timber Value $0 +$274,908 ($992,747) +$539,823

Total Implementation Cost 

(Net Timber Value minus 

Cost of Implementation)

($102,000) ($7,319,774) ($8,508918) ($4,079,279)

Invasive Plant Species

Methodology

The Noxious or Invasive Weed list for Coconino, Kaibab, and Prescott National Forests was 

reviewed for this project. Data sources used in preparation of this report include survey data and 

reports collected by District and Supervisor’s Office crews in past field seasons. Additional 

resources include forest weed files and past survey documents.

Data Sources

Noxious or invasive weed species survey, inventory, and treatment data from NRIS 

database

Forest Plan, 1987, as amended

Final Environmental Impact Statement for the Integrated Treatment of Noxious or 

Invasive Weeds for Coconino, Kaibab, and Prescott National Forest (USDA FS 2005); 

also rreferred to as Weeds FEIS. 

Incomplete and Unavailable Information

On the Forest, surveys for noxious or invasive weeds are typically conducted on a project-byproject basis. No such survey effort has occurred specifically for FWPP at this time; however 

previous surveys conducted for other similar fuels reduction and forest health projects has 

occurred within and adjacent to the project area (see Existing Conditions). Before the beginning 

of project-related ground-disturbing activities, an inventory of noxious or invasive weeds would 

occur in project operating areas, along access routes and in areas immediately adjacent to the 

project area. Existing infestations would be prioritized for treatment or avoided during project 

implementation. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 435

Affected Environment

Existing Conditions

Noxious or invasive weeds can alter ecosystem processes, species composition, species richness, 

biodiversity, hydrologic functions and soil characteristics (Harrod, 2001). Noxious or invasive 

weeds can also affect structure and function of native ecosystems and can affect factors such as 

fire interval and intensity, and successional pathways.

Information about populations of noxious and invasive plant species inside and adjacent to the 

project boundaries and areas adjacent are from survey efforts related to other projects that 

occurred between 2004 and 2012 (Table 143). Infestations during previous survey efforts ranged 

from a few scattered plants to more dense populations. 

Figure 89 and Figure 90 depict known locations of noxious or invasive weed populations in and 

adjacent to the DLH and MM areas. Species known to be present are described in detail below. 

Table 143: Noxious or invasive weed species detected in or adjacent to DLH and 

MM

Common 

Name

Species1Species 

Rank

Objectives Documented Locations

Leafy spurge Euphorbia 

esula

1 Eradicate In vicinity of Mormon Mountain project area

Musk thistle Caruus 

nutans

8 Eradicate Adjacent to Dry Lake Hills project area

Diffuse 

knapweed

Centaurea 

diffusa

9 Contain/Control Within and adjacent to Dry Lake Hills project 

area

Scotch thistle Onopordum 

acanthium

11 Eradicate/Control Adjacent to Dry Lake Hills project area

Dalmatian 

toadflax

Linaria 

dalmatica

18 Contain/Control Within Dry Lake Hills and adjacent to both 

project areas

Bull thistle Cirsium 

vulgare

20 Contain/Control Adjacent to Dry Lake Hills project area

Cheatgrass Bromus 

tectorum

22 Contain/Control 

specific 

populations

Adjacent to Dry Lake Hills project area

1Each species is rated by the perceived severity and risk to Forest resources and is based on invasiveness and the 

predicted success of control measures of each species as analyzed in the Weed FEIS. The ratings were taken 

from the FEIS.
Chapter 3: Affected Environment and Environmental Consequences

436 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Figure 89: Known locations of noxious and invasive weed species in and adjacent 

to the DLH area
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 437

Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 439

Figure 90: Known locations of noxious and invasive weed species in and adjacent to MM area

Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 441

Leafy spurge (Euphorbia esula)

Leafy spurge is an insidious weed from Eurasia that is very difficult to control. Roots of this 

species form extensive underground systems that can extend over 30 feet into the soil, and 

laterally as well. Seeds, forcefully expelled, can travel up to 15 feet from the original plant. The 

milky latex found in leafy spurge causes lesions around the eyes and mouth when eaten by cattle

and some wildlife species. Largely, this species is confined to Brolliar Park, which is 

approximately 8 miles south of the Mormon Mountain project area, but in 2013, a small but dense 

population of leafy spurge was incidentally found just south of Forest Road (FR) 90 and the 

community of Mormon Lake. Since this species is the highest ranked noxious and invasive weed 

species on the Forest and FR 90 and MM have not been surveyed for it, leafy spurge will be 

considered in the effects analysis for this proposed project in the MM area. 

Musk thistle (Carduus nutans)

Musk thistle (also known as nodding plumeless thistle) is a biennial that is found mainly in 

disturbed soils growing on roadsides, pastures, and forestlands. If not promptly controlled, this 

species can quickly form a monoculture, out-competing native vegetation. Populations have been 

reported in various locations in and around Flagstaff including along Highway 180 north of town 

to the Forest boundary. In the DLH area, two small populations were found in 2004 north of FR 

420, near Orion Spring.

Diffuse knapweed (Centaurea diffusa)

Diffuse knapweed is an annual or short lived perennial and typically invades roadsides and 

rangelands. This plant is allelopathic, meaning it has the ability to release chemicals into the soil 

which inhibit the growth of other species in the immediate area. A highly competitive plant, 

diffuse knapweed can exclude desirable species reducing ground cover and increasing soil 

erosion. Populations have been located throughout the Flagstaff area. This species has not been 

documented in the FWPP area but has been found along Highway 180 from the Flagstaff to the 

Forest boundary and northeast of the DLH area along FR 420 and 743.

Scotch thistle (Onopordum acanthium)

Scotch thistle is a large biennial thistle, native of Europe and eastern Asia. Characteristics of this 

species include broad, spiny stems with vertical ribs, large, spiny leaves with dense hairs, and 

violet to reddish flower heads. Scotch thistle grows in disturbed habitats and waste areas and 

reproduces solely from seed. Seeds are equipped with structures known as pappi, which allow the 

seeds to disperse on wind currents. Scotch thistle has not been documented in either project area 

but has been found along Highway 180 between Flagstaff and the Forest boundary.

Dalmatian toadflax (Linaria dalmatica)

Dalmatian toadflax is a perennial forb that reproduces from both seeds and underground root 

stalks. Dalmatian toadflax populations may not be observed for many years but will re-establish 

through existing seed bank and root stalks. Due to the reproductive advantage and aggressive 

nature, this plant has the potential to exclude native vegetation. Dalmatian toadflax is widespread 
Chapter 3: Affected Environment and Environmental Consequences

442 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

in the ponderosa pine forest type across the Forest. Numerous small infestations have been 

documented in the DLH area and areas adjacent to both project areas, often limited to a few 

plants scattered over large areas. 

Bull thistle (Cirsium vulgare)

Bull thistle is a biennial thistle that regenerates from short-lived seed. This plant invades slash 

piles, old log decks, roadsides, pastures, and other disturbed sites. Bull thistle is found 

throughout the Coconino National Forest, mainly in the ponderosa pine type. Numerous small 

infestations have been recorded adjacent to the DLH area; these are mainly limited to roadsides, 

past timber harvest areas, and old burns.

Cheatgrass (Bromus tectorum)

Cheatgrass is a winter or spring annual grass widely distributed throughout North America and is 

common in disturbed sites. If a population becomes dense enough and large enough it can 

change the fire regime of an ecosystem. No populations have been documented in either project 

area, but cheatgrass has been found near the junction of FRs 420 and 555 just outside the DLH

area boundary.

Desired Conditions

In the FWPP boundaries, desired conditions for noxious or invasive weed species are to prevent 

the introduction and establishment of new populations and to control and contain current 

populations. Use of best management practices (BMPs) as outlined in Appendix B of the Weeds

FEIS would help prevent the introduction of new populations and the spread of existing 

populations. 

Environmental Effects

Assumptions

This analysis is based on the following assumptions:

The mitigation measures and design features would be incorporated into project design 

and implementation

All treatments would occur as analyzed in the various specialists reports 

Areas to be treated would be for surveyed noxious or invasive weeds before treatments 

are implemented

These factors should be considered when identifying survey needs:

o Likelihood of any of the species addressed in this document occurring within the 

treatment area

o Amount of disturbance. For example, surveys may not be needed in areas 

scheduled for prescribed burning if the treatments are scheduled to be of low 

intensity. 

The larger the acreage of potential ground disturbance, the greater the area that would

need to be surveyed and treated for noxious and invasive weed species prior to and after 

treatments. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 443

Spatial and Temporal Context for Effects Analysis

The definitions of short-term and long-term effects for this analysis are the same as those used for 

soils in the Soil and Water Resources analysis: short-term effects are those that last 5 years or less 

and long-term are those that last longer than 5 years (see the Soil and Water Resources section 

and/or report for more details). Similarly, the cumulative effects boundary for this analysis is the 

planning boundaries of both project areas and the timeframe for projects included in the 

cumulative effects analysis is 15 years. This includes 5 years prior to the start of the project and 

10 years afterward to include implementation and 5 years post-implementation.

Past, Present, and Foreseeable Activities Relevant to Cumulative Effects Analysis

Activities in the project areas that are likely to cause ground disturbance and therefore contribute 

to cumulative impacts to noxious or invasive weeds include vegetation management and 

recreation activities. The potential effects of the following activities were considered in the 

cumulative effects analysis:

Vegetation management projects including Four Forest Restoration Initiative (4FRI) and 

Eastside and Jack Smith Schultz Fuels Reduction projects

Wildfire and related suppression activities

Livestock and wild ungulate grazing

Travel Management Rule (TMR)

Mount Elden/Dry Lake Hills Recreation Planning Project

Lands projects including Mormon Mountain communication tower maintenance and 

Arizona Power Service (APS) transmission line construction

Climate change

General recreation activities such as dispersed camping, hiking, biking, and hunting

Alternative 1: No Action

Direct & Indirect Effects

There would be no direct effects to noxious or invasive weeds from project-related activities as 

result of the FWPP as no actions would occur under this alternative.

Under this alternative, factors that contribute to fire hazard ratings such as high canopy cover, 

high stocking rates and fuel build up from down and dead logs would not be reduced. The risk of 

wildfire transitioning to crown fires would continue to increase in portions of the project area. 

Severe wildfires often result in complete removal of tree canopy, complete loss of ground cover 

and understory plant community and alteration of soil structure and nutrients. These conditions 

provide potential sites for noxious or invasive weed establishment through creation of bare soil, 

increased light, and absence of competition from desirable native plant species. Therefore, the 

increased risk of severe wildfire would continue to increase the risk of noxious or invasive weeds 

establishing in both project areas.

Wildfire, fires suppression activities, and the alteration of the fire regime have affected all 

vegetation through an increase in canopy cover, a decrease in density of understory vegetation, 

decrease in species composition of understory vegetation, and a decrease in ground cover of 

understory vegetation. Hydrologic function has also been altered due to past land management. 

Fire suppression has increased the risk and severity of wildfires across the landscape and 

increased the risk of soil disturbance, loss of the native plant community and alteration of habitat 
Chapter 3: Affected Environment and Environmental Consequences

444 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

from wildfire and suppression activities. As a result, the healthy resilient plant community that 

would be present in many areas is absent and there are fewer desirable understory species present 

to provide competition that would help reduce the potential invasion from noxious or invasive 

weeds. Additionally, humans and equipment involved in fire suppression activities can disperse

noxious or invasive weed propagules into unaffected areas through attachment of seeds and 

contaminated soils to boots and tires.

Cumulative Effects

The following is an analysis of the potential cumulative effects from past, present/on-going, and 

reasonably foreseeable future projects on the abundance and distribution of noxious or invasive 

weeds in the project areas. These include vegetation treatments, fire suppression, recreation uses, 

grazing, restoration work, TMR, climate change and lands projects such as power lines and 

communication towers. 

Livestock grazing can affect noxious or invasive weeds through soil disturbance, trampling, 

consumption of desirable plants that could provide competition for noxious or invasive weeds, 

and possible introduction of propagules by cattle as seeds and contaminated soil can be 

transported on their hooves and coats. Seeds can also be transported through the feces of cattle. 

Potential effects of livestock grazing past, present, and future, are limited to the MM area as no 

grazing has occurred in the DLH for approximately 17 years and the allotment has been 

permanently deferred from grazing per the 2010 Peaks Allotment Decision Notice. 

Grazing and browsing by wild ungulates including elk and deer has occurred across both project 

areas. Similar effects to those describe for livestock would be expected to occur. It should be 

noted that the numbers of these animals is under the control of the AZGFD, not the Forest 

Service.

There are past, on-going, and reasonably foreseeable future vegetation management projects in in 

both project areas. In DLH, past and on-going activities include Fort Valley Experiment Forest 

and Eastside and Jack Smith Schultz Fuels Reduction projects. On MM, past and on-going 

projects include removal of vegetation and associated ground disturbance for maintenance of the 

MM communication site and construction of the APS Mormon Mountain line. The one proposed 

vegetation management project in both areas is 4FRI, which is currently undergoing the NEPA 

process, and includes vegetation treatments and restoration activities. Mechanized, ground-based 

thinning and prescribed fire treatments as a result of these projects would cause disturbances to 

soils and loss of native vegetative cover that can result in the spread of noxious and invasive 

weeds. These effects are expected to be minimal since similar mitigation measures as proposed 

for the action alternatives for this project would be implemented, minimizing the amount of 

disturbance to soils and potential spread of weeds. The reduction in hazardous fuels from these 

projects would also reduce the likelihood of an uncharacteristic wildfire and the resulting effects 

to noxious or invasive weeds. 

Cumulative effects from human activities such as dispersed recreation, hiking, biking, horseback 

riding, hunting, and fire-wood gathering have occurred and will continue to occur in both the 

project areas. Effects of these activities include ground disturbance and possible dispersal of 

noxious or invasive weeds into or across the project area. Effects would be expected to occur in 

small areas scattered across the project areas. As a result, their contribution to cumulative effects 

would be expected to be insignificant.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 445

The TMR Record of Decision was signed September 28, 2011. The cumulative effects to this 

project could be both positive and negative. The TMR decision resulted in a reduction in the 

numbers of motorized routes open to the public and the elimination of cross country travel. This 

decreases the effects of motor vehicles, including crushing of native plants, creating areas of bare 

soil, transporting weed propagules and increasing the risk of noxious or invasive weeds 

establishing in the area. Another action that could occur is the decommissioning and obliteration 

of non-system roads through additional NEPA analyses in accordance with the TMR-designated 

road system. Such roads would require disturbing activities to help return the road corridor to preroad conditions. Ground disturbing activity may contribute to the spread of weeds by eliminating 

competition from existing vegetation and creating bare ground that can be easily invaded than in 

undisturbed sites. Mitigation measures and design features similar to those for the action 

alternatives for the Flagstaff Watershed Protection Project would be implemented during these 

activities, so cumulative effects from TMR would be minimal.

The proposed Mt. Elden – Dry Lake Hills Recreation Planning Project would address the 

increasing demand for recreational opportunities in the Flagstaff area. It will look at creating new 

or re-locating existing trails; consolidating, re-locating, or expanding existing trailheads; 

constructing a hang glider launch pad; and establishing new trailheads with associated parking 

areas either within or immediately adjacent to the FWPP analysis area. In addition to the 

potential effects of users of these trails, ground-disturbing activities related to this project could 

promote the introduction or spread of noxious or invasive weeds across the Dry Lake Hills adding 

to the effects of the Flagstaff Watershed Protection Project. As discussed for vegetation treatments 

and TMR, mitigation measure and design features would be incorporate into the planning and 

implementation of the project, reducing potential additive effects.

Disturbance is a major factor in noxious weed invasions. Global climate change is expected to be 

a source of widespread disturbances. Higher temperatures would occur and precipitation cycles 

would be modified from current patterns over large areas. The warmer climate conditions may 

affect ecosystems by altering biotic and abiotic factors and increase the extent and severity of 

disturbances for some species (Bradley, et al 2010; Hellmann, et al 2008; Middleton, 2006). 

Larger and more frequent fires are expected (Marlon et al. 2009). Climate may favor the spread of 

invasive exotic grasses into arid lands where the native vegetation is too sparse to carry a fire. 

When these areas burn, they typically convert to non-native monocultures and the native 

vegetation is lost (USFS 2010).

Effects Common to Alternatives 2, 3, and 4

Direct & Indirect Effects

All three action alternatives include burn only treatments, hand thinning treatments, and 

mechanized thinning treatments on slopes less than 40 percent. Prescribed burning would also be 

performed after various thinning treatments. This section describes the potential effects of these 

activities on noxious or invasive weeds in FWPP.

Direct effects of management activities include ground-disturbing activities that have the 

potential to increase the acreage and/or density of the existing infestations within the project area. 

Disturbance may contribute to the spread of weeds by eliminating competition from existing 

vegetation and creating bare ground that can be more easily invaded than in undisturbed areas. 

The level of disturbance is important. Severe disturbance removes competitive vegetation, alters 
Chapter 3: Affected Environment and Environmental Consequences

446 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

nutrient composition, and creates bare soil, increasing the potential for invasion or spread of 

noxious or invasive weeds. Management activities that would create localized severe disturbances 

include pile burn sites, log decks, bare soil created through road construction and 

decommissioning, and tire tracks created by machinery during mechanical thinning (see Soils & 

Water Resources section for more detail). Other management activities, such as broadcast burning 

and hand thinning, would also be sources of disturbance but levels would be minimal.

The majority of the analysis area (approximately 55 percent for Alternatives 2 and 3 and 50

percent for Alternative 4) would be treated by mechanized, ground-based harvesting and yarding 

methods on slopes less than 40 percent. Ground-based harvesting involves the use of either 

wheeled or tracked machinery in contact with the ground surface to both cut trees and remove 

them from the harvest area to landings in a process called yarding (see the Harvest 

Systems/Methods Descriptions in Chapter 2 for more details). This method of harvesting causes 

soil disturbance along a network of temporary roads, skid trails, and landings needed to 

accomplish thinning, increasing the risk of invasion and spread of noxious or invasive weeds. 

Treatments that reduce the tree canopy and lower the stand density would indirectly impact 

understory plants, including noxious or invasive weeds, by increasing sunlight and available 

nutrients and temporarily decreasing competition between and amongst tree species. Such 

favorable conditions for noxious or invasive weeds could increase the size and density of existing 

populations in areas where weed infestations already exist and susceptibility of invasion into new 

areas. These effects would be minimized by incorporating the mitigation measures and BMPs 

described in Chapter 2 and in the Invasive Plant Species Specialist Report, such as survey and 

treatment of weeds prior to project implementation.

A minor amount of hand thinning using chainsaws and hand piling of downed material would be 

implemented in the various action alternatives. Hand thinning would result in minimal impacts to 

soils since no construction of temporary roads would be needed and no equipment would be used 

removal or transport of materials. As a result, soil disturbance and potential impacts to noxious 

or invasive weeds would be negligible. 

As described in the Soil and Water Resources section, the road system needed to conduct logging 

operations has been identified as the largest contributor to bare mineral soil of a harvest operation 

(Megahan and King, 1972). Temporary roads are constructed during timber harvesting to 

facilitate access to timber stands and are rehabilitated after treatment by restoring the roadbed to 

its pre-disturbance condition to the extent possible. Some of the proposed temporary roads in the 

FWPP would be constructed on existing road prisms that were previously Forest Service system 

roads.

Potential direct and indirect effects of temporary road construction, road maintenance or 

obliteration include disturbance and increased risks of dispersal of existing weed species and 

populations and introduction of new species. The density of noxious or invasive weeds tends to 

be greater along roadways than in interior areas with fewer disturbances (Fowler et al, 2008). 

These potential impacts can be mitigated by following the mitigation measures and BMPs

described in Chapter 2 and in the Invasive Plant Species Specialist Report. Roads that would be 

obliterated as part of FWPP would be complementary to the goals of TMR.

Burning is a disturbance that can release nutrients, reduce plant competition, increase the amount 

of available sunlight and increase bare soil. Prescribed burning may have direct and indirect 

effects to on all understory vegetation depending on fire severity, including existing noxious or 

invasive weed populations within the project area. In the FWPP, most prescribed burning would 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 447

be of low severity with low soil heating, retention of most ground litter and little or no change in 

mineral soil and therefore minimal effects on the abundance of noxious or invasive weeds 

(Fowler et al, 2008; Collins et al, 2007). In some areas, moderate to high severity fire may occur 

during a prescribed burn, resulting in similar effects to those described for pile burning or 

wildfires (McGlone and Egan, 2009). 

Pile burning would create localized severely burned areas. Potential consequences include the 

reduction or loss of the seed bank on these sites (Korb, 2001); death or reduction of soil 

organisms on the pile sites (Raison, 1979; Ballard, 2000; Korb et al., 2004) and development of 

hydrophobic soil (Kaye and Hart, 1998; Ballard, 2000). Pile sites are more prone to invasion from 

noxious or invasive weeds than surrounding areas and may contribute to the persistence and 

spread of noxious or invasive weeds in treated areas. Pile burning sites would constitute a very 

small portion of the project area (i.e., less than 5 percent). To minimize these effects, previously 

disturbed areas including old pile sites or previously used decking areas would be used where 

available instead of creating new sites within the project area. Additionally, pile sites would be 

monitored after burning occurs to identify and treat any weed infestations. Management actions 

can be mitigated by following the BMPs described in Appendix B of the Weed FEIS and Chapter 

2 of this document. 

Cumulative Effects

Cumulative effects as described under the no action alternative would be combined with 

direct/indirect effects to noxious or invasive weeds for all alternatives as described above. 

Effects of all the activities in the project areas could result in short-term increases in the 

abundance and density of noxious or invasive species immediately following ground-disturbing 

activities. However, with the distribution of ground-disturbing activities across the project areas 

at different times and the implementation of mitigation measures to minimize effects, these 

impacts would be insignificant. Additionally, by reducing the risk of wildfire and related 

suppression activities and treating existing infestations in the project areas prior to project 

implementation, long-term effects of these activities would likely result in a decrease in the 

number and size of infestations and the rate of spread.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

In this section, only the differences between Alternative 2 and the other action alternatives will be 

discussed. 

Two different methods of cable yarding are proposed under this alternative: skyline and excaliner.

As described in detail in the Soil and Water Resources section, the types of ground disturbance 

created by cable yarding are the same as for ground-based mechanized harvesting but the 

magnitude of disturbance is lower for cable yarding. Knowing this, Alternative 2 would be 

expected to have the highest amount of soil disturbance from mechanized thinning of the three 

action alternatives: 1,169 acres in DLH and 106 acres in MM. Additionally, Alternative 2 

requires the largest mileage of temporary roads to be created and rehabilitated: 17.4 miles in DLH

and 3.6 in MM. As a result, Alternative 2 would disturb the largest area of the three action 

alternatives, increasing the risk for the invasion or spread of noxious or invasive weeds in the 

project areas. As discussed before, the risk of invasion and spread would be minimized through 

the mitigation measures and BMPs described in Chapter 2 and in the Invasive Plant Species 

Specialist Report.
Chapter 3: Affected Environment and Environmental Consequences

448 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

In this section, only the differences between Alternative 3 and the other action alternatives will be 

discussed. 

There are several differences between Alternatives 2 and 3. First, no cable yarding would occur 

in either project area under this alternative. Instead, 973 acres in DLH would be mechanically 

thinned and yarding would occur by helicopter. Since helicopters would be used to transport logs 

to landings, there would be no need for cable corridors, resulting in a reduction in potential soil 

disturbance. 

Another difference is thinning and yarding by specialized equipment on slopes greater than 40 

percent would occur on 273 acres in DLH and on 73 acres in MM. This would be done with 

either multi-wheeled harvesters or track mounted levelling harvester designed for operation on 

steep slopes. As described in the Soil and Water Resources section, through use of BMPs, soil 

disturbance would be expected to be light to moderate on slopes where this equipment was used

and would be similar to the level of disturbance from ground-based thinning on slopes less than 

40 percent. Slash mats would be used to protect soils during implementation if exposure of bare 

mineral soil were to exceed 9 percent. These would protect soils from disturbance and reduce the 

potential impacts of noxious or invasive species in both project areas.

Implementation of these two methods would also result in a decrease in the number of temporary 

roads that would need to be created and rehabilitated under Alternative 3: 12.7 miles in DLH and 

2.5 miles in MM. 

Under Alternative 3, the decrease in acres of soil disturbance under this alternative through the 

use of different harvest methods and the related decrease in miles of roads created and 

rehabilitated would result in a decreased risk of invasion or spread of noxious or invasive weeds 

when compared with Alternative 2. 

Alternative 4: Minimal Treatment

Under Alternative 4, treatments would occur on a smaller number of acres than under 

Alternatives 2 and 3: a reduction of 2,504 acres in DLH and 631 acres in MM. Additionally, 

there would be no treatments that involve cable or helicopter yarding or the use of specialized 

steep-slope equipment. While the same number of miles of temporary roads would be created 

and rehabilitated on MM under Alternatives 3 and 4, there would be a decrease of 1.1 miles 

created and rehabilitated between Alternatives 2 and 4. In DLH, there would be a decrease of 7.2 

and 2.5 miles of temporary roads under Alternative 4 when compared with Alternative 2 and 3, 

respectively. These differences would result in the least amount of soil disturbance of the three 

action alternatives and therefore the lowest risk of invasion or spread of noxious or invasive 

weeds.

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

Amendment 1 to the Forest Plan would allow mechanical treatments and hand thinning in 

Mexican spotted owl protected activity center treatments and prescribed burning within nest 

cores. The amendment would also allow removal of trees 24 inches dbh and greater in Mexican 

spotted owl protected or recovery habitat for cable logging corridors in order to facilitate 

treatments under Alternative 2. Implementation of this amendment would result in increases in 

the amount of soil disturbance in the project area since larger areas would be thinned and burned. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 449

This would result in a short-term increase in the risk of invasion and spread of noxious or 

invasive weeds. Over the long-term, improved vegetative ground cover would occur by 

providing conditions conducive to the establishment of a more vigorous understory of grasses, 

forbs and shrubs. This improvement in the health of vegetative ground cover would reduce the 

risk of the effects of high severity fire while improving the ability of native plants to compete 

with noxious and invasive weeds. Proposed population and habitat monitoring would not 

increase the risk of invasion or spread of noxious or invasive weeds as soil disturbance from these 

activities would be very limited or not occur.

Implementation of Amendment 2 to allow mechanical harvesting on slopes greater than 40 

percent within the project area would have similar impacts to those described for Amendment 1. 

A short-term increase in the risk of invasion and spread of noxious or invasive weeds would 

occur from the increase in soil disturbance on steep slopes. Over the long-term, this amendment 

would decrease the risk of high severity wildfire and improve the ability of native vegetation to 

compete with noxious or invasive weeds. This would result in a long-term decrease risk in the 

invasion or spread of noxious or invasive weeds.

Sensitive Plants

Methodology

This document discusses the effects of FWPP on one Region 3 sensitive plant species, Rusby

milkvetch, which occurs only in the Dry Lake Hills area of the project. No Region 3 sensitive 

plants have been found within the operational boundary of the Mormon Mountain portion of the 

project. 

There are no threatened or endangered plants within the project boundaries. 

Data Sources

Sources of information for this report were collected from the following resources:

Past surveys from the Jack-Smith Schultz Project.

Surveys in the Antelope Park area near Mormon Mountain in 2011. 

Location data for Astragalus rusbyi from the Arizona Heritage Database and Ecological 

Restoration Institute, Northern Arizona University. 

Location data from the NRM TESP/Invasives database

SEINet data. 

Forest Plan, as amended

Various files 

Affected Environment

Existing Condition 

Rusby milkvetch (Astragalus rusbyi)

Rusby milkvetch is an upright perennial herb with pinnately compound leaves of oval leaflets. 

No tendrils are present on the stem. The stem can be reddish in color with dark spots along the 
Chapter 3: Affected Environment and Environmental Consequences

450 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

stem. A distinguishing character is the presence of trigonus pods (triangular in cross section). 

Each seedpod also has a stipe, which is a narrow area at the base of the pod where it connects the 

plant. The flowers are white to cream color and pea-like and the plants bloom from May to 

September. This species is similar to the more common Astragalus recurvus and can be confused 

with it during identification. Habitats for Rusby milkvetch include aspen groves, mixed conifer, 

ponderosa pine/Arizona fescue, and ponderosa pine/gambel oak sites in dry or temporarily moist 

basaltic soils.

The range of Rusby milkvetch is limited to northern Arizona where it is mostly limited to areas 

north and west of the San Francisco Peaks. Some portions of the range have experienced large 

fires such as the Hochderffer and Horseshoe Fires in 1996, the Pumpkin Fire in 2000, the Leroux 

Fire in 2001, and the Schultz Fire in 2010. Surveyors detected numerous occurrences of Rusby 

milkvetch in the adjacent Hart Prairie Project (2010), Wing Mountain Project (2012) and the 

Jack-Smith/Schultz Project (2005). The Ecological Restoration Institute at Northern Arizona 

University has recorded numerous locations of Rusby milkvetch in several of their restoration 

projects, including the nearby Fort Valley and Gus Pearson Projects. Table 144 shows the 

locations of Rusby milkvetch within the project area and the proposed treatments under each 

action alternative within those areas (note: Rusby milkvetch is only known to occur in the DLH 

portion of this project). 

Table 144. Locations and sites containing Rusby milkvetch in the Dry Lake Hills portion of 

the project area, with proposed treatments for each action alternative.

Common 

Name

Date Location Sit

e

Alternative 2 Alternative 3 Alternative 4

Rusby

milkvetch

7/29/

2004

267 7 Ponderosa 

Pine Fuels 

Reduction

Ponderosa Pine 

Fuels 

Reduction

No Treatment

Rusby

milkvetch

5/28/

2013

267 18 MSO Nest 

Fuels 

Reduction -

Burn Only

MSO Nest 

Fuels 

Reduction -

Burn Only

No Treatment

Rusby 

milkvetch

7/29/

2004

267 37 Ponderosa 

Pine Fuels 

Reduction

Ponderosa Pine 

Fuels 

Reduction

No Treatment

Rusby 

milkvetch

5/28/

2013

267 9A MSO PAC 

Fuels 

Reduction

MSO PAC 

Fuels 

Reduction

No Treatment

Rusby 

milkvetch

2/18/

2009

267 15

A

Ponderosa 

Pine Fuels 

Reduction

Ponderosa Pine 

Fuels 

Reduction

No Treatment

Rusby 

milkvetch

2/18/

2009

267 16

B

MSO PAC 

Fuels 

Reduction

MSO PAC 

Fuels 

Reduction

No Treatment

Rusby 

milkvetch

2/18/

2009

267 35

B

MSO PAC 

Fuels 

Reduction

MSO PAC 

Fuels 

Reduction

No Treatment

Rusby 

milkvetch

7/29/

2004

277 2 Ponderosa 

Pine Fuels 

Reduction

Ponderosa Pine 

Fuels 

Reduction

Ponderosa 

Pine Fuels 

Reduction

Rusby 8/17/ 277 13 Goshawk PFA Goshawk PFA Goshawk 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 451

Common 

Name

Date Location Sit

e

Alternative 2 Alternative 3 Alternative 4

milkvetch 2005 Fuels 

Reduction

Fuels 

Reduction

PFA Fuels 

Reduction

Rusby 

milkvetch

7/29/

2004

277 1B Ponderosa 

Pine Fuels 

Reduction

Ponderosa Pine 

Fuels 

Reduction

Ponderosa 

Pine Fuels 

Reduction

Rusby 

milkvetch

8/17/

2005

277 36

A

Goshawk PFA 

Fuels 

Reduction

Goshawk PFA 

Fuels 

Reduction

Goshawk 

PFA Fuels 

Reduction

Rusby 

milkvetch

5/21/

2013

286 3A Ponderosa 

Pine Fuels 

Reduction

Ponderosa Pine 

Fuels 

Reduction

Ponderosa 

Pine Fuels 

Reduction

Rusby 

milkvetch

8/4/2

004

286 4A Ponderosa 

Pine Fuels 

Reduction

Ponderosa Pine 

Fuels 

Reduction

Ponderosa 

Pine Fuels 

Reduction

Rusby 

milkvetch

8/4/2

004

286 4B Ponderosa 

Pine Fuels 

Reduction

Ponderosa Pine

Fuels 

Reduction

Ponderosa 

Pine Fuels 

Reduction -

Hand Thin

Rusby 

milkvetch

7/28/

2004

287 2D MSO Nest 

Fuels 

Reduction -

Hand Thin

MSO Nest 

Fuels 

Reduction -

Hand Thin

MSO Nest 

Fuels 

Reduction -

Hand Thin

Rusby 

milkvetch

7/29/

2004

287 9A Mixed Conifer 

Fuels 

Reduction

Mixed Conifer 

Fuels 

Reduction

Mixed 

Conifer Fuels 

Reduction

Rusby 

milkvetch

8/2/2

004

287 9B Mixed Conifer 

Fuels 

Reduction

Mixed Conifer 

Fuels 

Reduction

No Treatment

Desired Condition 

The desired future condition for Rusby milkvetch is to maintain or increase the populations and 

potential habitat for it within the project area. Manual direction (FSM 2670.5(19)) emphasizes 

that management actions should avoid or minimize impacts to sensitive species. Mitigating 

measures should be incorporated into project design and implementation as necessary to 

minimize impacts to sensitive plants.

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

There would be no direct or indirect effects from management actions to Rusby milkvetch

because none of the activities considered in this analysis would occur. However under this 

alternative, the risk of high-severity wildfire would continue. Indirect effects to Rusby milkvetch 
Chapter 3: Affected Environment and Environmental Consequences

452 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

could occur from such a wildfire, and include impacts from the fire itself, suppression activities 

(e.g. fireline construction), and potential flooding post-fire. 

Cumulative Effects

The boundary for this discussion includes the range of Rusby milkvetch within the Coconino 

National Forest. The timeframe for this discussion is from 1999 when Rusby milkvetch was 

added to the Region 3 Sensitive Species list for Coconino National Forest. Effects to Rusby 

milkvetch before 1999 include past management actions by the U.S. Forest Service such as 

grazing, timber sales and prescribed burning within the project area and throughout its range. The 

effects of these actions are unknown but contribute to the current condition for the species and its 

habitat. The end point for this discussion is approximately 10 years into the future.

Cumulative effects from the No Action Alternative include the overall increased acreage on the 

Flagstaff Ranger District susceptible to high-severity wildfire.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects

Direct effects would include loss of individual plants or groups through management actions. 

Factors contributing to these effects would include disturbance from management actions such as 

activities associated with tree removal, prescribed burning, road reconstruction, maintenance and 

decommissioning, temporary road construction and decommissioning. Under this alternative, a 

series of corridors to accommodate cable logging would be established in areas with steep slopes. 

Activities associated with tree removal and prescribed burning may cause some immediate losses 

of individuals and groups but would beneficial in the long term by reducing competition from 

overstocked forests, increasing the amount of available sunlight and by increasing available 

nutrients. In a long-term ponderosa pine ecological restoration study in the Fort Valley 

Experimental Forest, Rusby milkvetch was an indicator species of tree thinning and prescribed 

burning, showing a positive response to treatments after five years (Laughlin et al, 2008). Some 

individuals may be lost during prescribed burning, especially in areas where only isolated 

individuals occur or in areas where plants were not detected during surveys. However prescribed 

burning may have beneficial direct and indirect effects on all understory vegetation including 

Rusby milkvetch. Burning is a disturbance that can release nutrients, reduce plant competition, 

and increase the amount of available sunlight light.

Most prescribed burning would be of low severity. In some cases, fire severity may be higher in 

limited areas depending on variables such as management goals, weather, fuel conditions and 

topography. In these areas, there would be limited negative direct effects through deaths of

scattered individuals or groups of Rusby milkvetch if they occur at that particular location. 

Limited loss of small groups of plants in these cases would not significantly contribute to the 

overall decline of populations of this species within the project area or over the range of Rusby 

milkvetch. The indirect effects of higher fire severity in these areas would be similar to those for 

slash pile burning, described below.

One of the associated activities with several treatments includes piling of slash from management 

activities. Slash piles may have negative direct and indirect effects on all understory vegetation 

including Rusby milkvetch. Slash pile construction could be a possible direct negative effect if 

the pile is placed in or near existing populations of Rusby milkvetch. Pile burning would create 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 453

locally severely burned areas at pile sites, which is a negative indirect effect. Consequences 

include, but are not limited to, the reduction or loss of the seed bank on these sites (Korb, 2001); 

death or reduction of soil organisms on the pile sites (Raison, 1979; Ballard, 2000; Korb et al.,

2004) and development of hydrophobic soil (Kaye and Hart, 1998; Ballard, 2000). Slash pile sites 

are more prone to invasion from noxious or invasive weeds than surrounding areas and contribute 

to the persistence and spread of noxious or invasive weeds in treated areas (Korb et al, 2004). 

Mitigation for these effects is to use previously disturbed areas including old pile sites or 

previously used decking areas where available instead of creating new sites within the forest.

An indirect effect of management actions within the potential habitat of Rusby milkvetch 

includes an increased risk of invasion from noxious or invasive weeds. These effects would be 

mitigated by incorporating the Best Management Practices described in Appendix B of Final 

Environmental Impact Statement for the Integrated Treatment of Noxious or Invasive Weeds, 

Coconino, Kaibab and Prescott National Forests (2005). Incorporation of the Best Management

Practices would mitigate the effects of increased disturbance from management activities, and 

help to control the spread and introduction of weeds within the habitat of Rusby milkvetch. See 

Appendix B for noxious for invasive weed locations.

Direct and indirect effects of temporary road construction, road maintenance, road reconstruction 

or decommissioning include destruction of individual plants, localized disturbance of suitable 

habitat and the potential introduction of noxious or invasive weeds. These effects would be 

mitigated by surveying the areas where activities would occur as well as nearby areas that may be 

disturbed and by avoiding existing plant populations. 

In this alternative, cable corridors would be established to facilitate removal of trees on steep 

slopes. Due to the steepness of the terrain, it may not be feasible to survey and avoid plants in 

these areas, which may result in loss of individuals or groups. All trees would be removed in the 

corridors, which are approximately 12 feet wide, resulting in a heavily disturbed area of 

approximately 191 acres total in the Dry Lake Hills. As a result, these areas may be more prone to 

weed infestations. This would impact the habitat of all understory plants including Rusby 

milkvetch. See the weed report for more details. 

The permanent campfire restriction proposed for the DLH area would help reduce the risk of 

human caused wildfires and would therefore reduce the risk of wildfire to understory plant 

communities including Rusby milkvetch. 

Cumulative Effects

The boundary for this discussion includes the range of Rusby milkvetch within the Coconino 

National Forest. The timeframe for this discussion is from 1999 when Rusby milkvetch was 

added to the Region 3 Sensitive Species list for Coconino National Forest. Effects to Rusby 

milkvetch before 1999 include past management actions by the U.S. Forest Service such as 

grazing, timber sales and prescribed burning within the project area and throughout its range. The 

effects of these actions are unknown but contribute to the current condition for the species and its 

habitat. The end point for this discussion is approximately 10 years into the future.

There are occurrences of Rusby milkvetch in previously analyzed fuels reduction projects 

including Eastside Fuels Reduction and Forest Health Project (2006), the Jack Smith/Schultz 

Fuels Reduction and Forest Health Project (2008), Hart Prairie Fuels Reduction and Forest Health 

Project (2010), Railroad Timber Sale (2010?) and Wing Mountain Fuels Reduction and Forest 

Health Restoration Project (2012). The effects of those projects were similar to the effects 

discussed above. Findings in those projects were “may effect but not likely to adversely to 
Chapter 3: Affected Environment and Environmental Consequences

454 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

adversely affect.” Mitigations for those projects have reduced the effects of these projects on 

Rusby milkvetch to non-significant levels. 

Fire suppression and past alteration of the fire regime through suppression have affected all 

vegetation including Rusby milkvetch through changes in tree density and understory species 

composition. Elimination of fire in the project area and throughout most of the range of Rusby 

milkvetch has allowed tree canopy and stand density to increase in some areas, reducing the 

abundance or eliminating of most understory species including Rusby milkvetch. The 

elimination of fire has also resulted in the increase in litter in some areas which has negatively 

affected understory plant species by eliminating plants and by contributing to the increase in fire 

spread, length of residence time of fire and fire severity. 

The Leroux Fire (2001) contained occurrences of Rusby milkvetch. Several of these occurrences 

were documented within the fire perimeter after the fire occurred. Manual, biological and 

chemical treatment of Dalmatian toadflax infestations have been conducted in the fire area but no 

adverse effects to Rusby milkvetch have been observed from these treatments. 

The Schultz Fire (2010) contained several occurrences of Rusby milkvetch. Some of these plants 

were eliminated in the fire and the habitat in some areas was severely altered. The effects of 

large, high severity wildfires such as the Schultz Fire last for many years and long-term alteration 

of habitat occurs. In addition to the wildfire itself, severe flood damage occurred in some areas as 

a result of the loss of vegetation and ground cover, severely altering the habitat for Rusby 

milkvetch in some areas. Management actions to reduce the flooding risk to private property 

include seeding, mulching, road reconstruction and maintenance and channel construction and 

maintenance. The extent of the effects to Rusby milkvetch and its habitat are unknown. These 

actions were authorized in several analyses including the Inner Basin Waterline Reconstruction 

Project (2011), three Categorical Exclusions for reforestation, hazard tree removal, and 

rehabilitation work (2011), and the Schultz Sediment Reduction Project (2012).

The Radio (1977) Fire and the rehabilitation efforts for it were past activities within the range of

Rusby milkvetch but are outside the timeframe of this discussion. Therefore, the effects of the fire 

and resulting management actions to control the fires and rehabilitate the effects are considered 

part of the existing condition. 

In a long-term ponderosa pine ecological restoration study in the Fort Valley Experimental 

Forest, Rusby milkvetch was an indicator species of tree thinning and prescribed burning, 

showing a positive response to treatments after five years (Laughlin et al, 2008).. Drought may 

also affect the occurrences of Rusby milkvetch. The species may be absent from certain areas 

during times of prolonged lack of precipitation and then re-emerge when conditions are more 

favorable. Additional restoration activities in the range of Rusby milkvetch include activities for 

aspen restoration, Bebb’s willow restoration and springs enhancement activities that will be 

authorized in the first EIS decision. All of these activities are small in areal scale but may affect a 

few individuals of Rusby milkvetch. 

Rusby milkvetch is grazed by cattle and wild herbivores and this may affect the ability to detect 

occurrences during certain times if plants have been recently eaten. The range of Rusby 

milkvetch within the project area includes only the DLH portion of the project. For the purposes 

of livestock grazing, this area is included in the Peaks Allotment which was analyzed for the 

reauthorization of cattle grazing in 2010. Portions of the Peaks Allotment that occur within the 

project area where not considered for reauthorization in the 2010 decision so no cattle grazing 

will occur in the portion of the DLH area affected by this analysis. Wild grazers may still 

consume Rusby milkvetch in the project area. Deer and elk may preferentially select legumes 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 455

when they find them. Small animals such as rodents may also eat Rusby milkvetch. The 

cumulative effects of grazing include past and present loss of individual plants to grazing animals 

and alteration of habitat through animal impacts such as trampling and compaction. 

Rusby milkvetch has been observed along the Schultz Trail, which is adjacent to the project area. 

Several of the locations detected by survey crews are along the trail. Trail users may impact 

individual plants at these locations through trampling and compaction of soil. Special use events 

may occasionally impact individual Rusby milkvetch plants but at a non-significant level. There 

are numerous user created trails in the Dry Lake Hills as well as recreational activities such as 

rock climbing and mountain biking. The effects of these activities on Rusby milkvetch are 

unknown but will be addressed in a future analysis for recreation in the Mount Elden Dry lake 

Hills Area. 

In 2000, the Forest withdrew the San Francisco Mountain and Mount Elden areas from mineral 

exploration. This withdrawal could have indirect long-term beneficial effects on species such as 

Rusby milkvetch by preserving habitat that might otherwise be altered through mineral 

exploration. 

A mining operation, the White Vulcan Mine altered potential habitat for Rusby milkvetch in the 

localized area of the mining operation. Active mining no longer occurs at the site and the mine 

has been rehabilitated. 

The Coconino National Forest implemented the Travel Management Rule in 2011. As a result, 

cross-country travel was eliminated and the mileage of roads open to public travel was reduced. 

This resulted in the reduction of the effects from motorized travel such as crushing of plants; 

damage to potential habitat such damage to soils and fragmentation of habitat. 

In 2005, the Forest signed a decision allowing expansion the facilities at the Arizona Snowbowl. 

Artificial snowmaking was part of this decision. To facilitate snowmaking, a waterline was 

constructed from wastewater treatment facilities in Flagstaff to the Arizona Snowbowl. During 

the construction of the waterline, several Rusby milkvetch plants were destroyed but the project 

finding of effect for the project was a “may effect but not likely to adversely affect” the existence 

of Rusby milkvetch. 

The management actions proposed for this project would have no significant negative effects on 

the overall distribution and abundance within the project area or within the total range of Rusby 

milkvetch, provided the mitigations recommended in this document are incorporated into the 

project design and implementation. The management actions would not significantly contribute 

to the cumulative effects discussed above, provided they are mitigated as recommended. The 

project would have beneficial direct and indirect effects on Rusby milkvetch by reducing fire risk 

and therefore the threat of severe wildfire within the potential habitat of Rusby milkvetch within 

the project area. Additionally, all understory plants including Rusby milkvetch would benefit 

from the reduction of tree density and canopy in certain areas of the project by reducing 

competition for nutrients, light and growing space. 

Routine road maintenance within the range of Rusby milkvetch may occasionally impact Rusby

milkvetch individuals but at non-significant levels.

As a result of the Schultz Fire and accompanying flooding (2010) major roads in the fire area 

were heavily damaged resulting in the need for major reconstruction on these roads. Some 

individuals of Rusby milkvetch may have been lost in these areas. The extent of the loss from 

management activities was likely small compared to the habitat alteration from the fire and flood.
Chapter 3: Affected Environment and Environmental Consequences

456 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Manual, chemical and biological control of noxious or invasive weeds in the range of Rusby 

milkvetch have occurred and will continue to occur. There is a slight but insignificant risk of 

damage or loss to individuals during the implementation of manual or chemical treatments. There 

is no risk to Rusby milkvetch from biological control because insects developed for biological 

control are species-specific. In the long-term, weed control will have beneficial effects to Rusby 

milkvetch by reducing competition from weeds and by improving habitat conditions. 

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

The effects of this alternative are similar to those for Alternative 2 except there would be no cable 

logging and therefore no creation of corridors. Tree removal on steep slopes would be facilitated 

by the use of specialized ground based equipment or by helicopters. There would be no highly 

disturbed areas for logging corridors such as those discussed in alternative 2. Therefore the 

acreage of severe disturbance would be lower for Alternative 3 than for Alternative 2.

All other effects of this alternative are the same as Alternative 2.

Cumulative Effects

The cumulative effects of this action are the same as those for Alternative 2. 

Alternative 4: Minimal Treatment

Direct & Indirect Effects

In comparison to Alternatives 2 and 3, fewer areas containing Rusby milkvetch would be treated. 

Many occurrences of Rusby milkvetch are in areas that would be untreated in this alternative due 

to steep slopes and inaccessibility. This would result in no disturbance to plants from management 

actions associated with tree removal in these areas. However, the risk of loss individual plants or 

alteration of habitat due to uncontrolled wildfire would remain higher as compared to Alternatives 

2 and 3 because fuels in these areas would not be reduced. 

No cable corridors would be constructed in this alternative. Therefore, the high levels of 

disturbance and associated impacts to Rusby milkvetch discussed in Alternative 2 above would 

not occur.

This alternative focuses on the area south and east of FR 420. The area above FR420 to the 

wilderness boundary would be treated under separate NEPA prepared for Jack-Smith/Schultz. 

The effects to Rusby milkvetch in that area have already been addressed and mitigation measures 

have been described in the Jack-Smith/Schultz analysis.

In this alternative, more hand thinning would occur compared to Alternatives 2 and 3. Therefore 

the levels of disturbance in areas of hand thinning are expected to be lower, especially in areas of 

steep slopes that would have been treated using cable logging or specialized equipment. 

In this alternative, fewer temporary roads would be built. Disturbance from road construction, 

maintenance and decommissioning that would occur as a result of these actions would therefore 

also be less when compared to Alternatives 2 and 3.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 457

Cumulative Effects

The cumulative effects of this action are the same as those for Alternative 2. 

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

Amendment 1 would incorporate the most recent Recovery Plan for Mexican Spotted Owl and 

would allow higher levels of thinning and burning within MSO habitat than was previously 

authorized. This would result in more open stand conditions as compared to past treatments in 

similar areas. The effects would be similar to those discussed for amendment 1 including higher 

levels of disturbance, more open conditions and reduced competition for resources. With the 

removal of timing restrictions for MSO, management activities would be allowed to occur during 

the growing season of Rusby milkvetch making the top portions of the plant more susceptible to 

destruction during activities as compared to treatment within MSO PACs in the past. This could 

lead to destruction of the above ground biomass of individual Rusby milkvetch plants during 

certain growing seasons, reducing such functions as the production of seed by these individuals. 

Amendment 2 would remove slope restrictions in the current Forest Plan, and would allow tree 

removal on slopes greater than 40 percent. Equipment such as cable logging, helicopter logging 

or specialized ground based equipment would be needed to accomplish the treatments. In this 

alternative, cable logging would occur and would result in the establishment of approximately 

191 acres of heavily disturbed areas. Individual or plant groups may be destroyed in these 

corridors during their establishment and use. The long-term effects are unknown but would result 

in open, treeless areas for a prolonged period of time. 

Recreation

Methodology

In addressing the recreation and wilderness conditions for the FWPP analysis area and the 

potential effects to these resources from the alternatives, the best available science was used, 

including relevant peer-reviewed literature, published reports from regulatory and land 

management agencies, existing resource inventories, field visits, and the professional judgment of 

the specialist(s). Literature and documents reviewed includes the Forest Plan, as amended and the 

draft revised Forest Plan. 

Recreation Opportunity Spectrum

The Forest Service uses the Recreation Opportunity Spectrum (ROS) to provide a framework for 

defining classes of outdoor recreation environments, activities, and experience opportunities 

(USDA Forest Service, ROS Primer and Field Guide 2011). The ROS is a land classification 

system that categorizes national forest land into six classes, each class being defined by its setting 

and by the probable recreation activities the setting offers. The six ROS classes are: primitive, 

semi-primitive non-motorized, semi-primitive motorized, rural and urban. ROS classifications 

within the analysis area were referenced to determine if any modifications would be necessary 

given the alternatives. 

The ROS classifications within the FWPP analysis area include: Semi-Primitive Non-Motorized 

(SPNM), Semi-Primitive Motorized (SPM) and Roaded-Natural (RN). The Kachina Peaks 

Wilderness, located directly north of the project area is Primitive (P).
Chapter 3: Affected Environment and Environmental Consequences

458 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

The Coconino National Forest is currently revising the Forest Plan, which could potentially 

change the ROS zones; however, the current draft of the revised Forest Plan does not reflect 

significant changes to the ROS classifications within the project area.

Affected Environment

Recreation use of the Coconino National Forest has grown rapidly over the last two decades, 

commensurate with the growth of the population in the southwest region. The Coconino National 

Forest is primarily visited for non-motorized activities such as hiking, backpacking, viewing 

wildlife, or viewing natural features. 

In 2012 and 2013 students from Northern Arizona University, FS personnel, members of Friends 

of Northern Arizona, and other volunteers conducted an informal survey of forest visitors at 

different trailheads for the Mount Elden / Dry Lake Hills area. The purpose of the survey is to 

assist forest personnel with the Mount Elden / Dry Lake Hills Planning Project.

In general, the survey was designed to better understand who currently uses the area, what type of 

recreational activities people enjoy in the area, and what forest visitors would like to see in the 

future. For example, survey results identified that walking/hiking is the most common trail use 

activity by forest visitors on the Mount Elden / Dry Lake Hills trail system. 

Recreation Activities within the Project Area

There are a number of developed recreation facilities and USFS trails within and/or adjacent to 

the FWPP analysis area. Also, the Kachina Peaks Wilderness is located just north of Forest Road 

(FR) 522 (Freidlein Prairie Road) near the northern boundary of the project area. The ROS 

classification within the analysis area includes Semi-Primitive Non-Motorized (SPNM), SemiPrimitive Motorized (SPM) and Roaded-Natural (RN). Additionally, the Coconino National 

Forest is concurrently conducting an environmental analysis of non-motorized recreation for 

trails, special uses and facilities known as the Mt. Elden – Dry Lake Hills Recreation Planning 

Project, also referred to as MEDL. 

Much of MEDL planning area overlaps 

with the Dry Lake Hills portion of the 

FWPP area.

The Mt. Elden/Dry Lake Hills region is 

one of the most popular and heavily 

used areas for recreational purposes on 

the Forest; largely because of its 

proximity to Flagstaff and the appealing 

forest topography and vegetation. The 

trail system is highly valued by the 

Flagstaff trail community including 

organizations such as Flagstaff Biking 

Organization, Coconino Horseman’s 

Alliance, Northern Arizona Trail 

Runners Association, Arizona Trail Association, Flagstaff Unified School District and others. The 

area provides thousands of forest visitors an opportunity to enjoy the great outdoors whether they 

are hiking, mountain biking, riding their horse, hunting, birding, dispersed camping, driving for 

pleasure, snowshoeing, cross-country skiing or rock climbing. Adjacent property owners walk 

Figure 91: Sunset Trail – Hiker enjoying the 

views and scenery.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 459

this area on a daily basis and the project area abuts Buffalo Park, a city-owned and managed park 

that also serves as a primary portal into the forest from Flagstaff. 

The Mt. Elden /Dry Lake Hills Trail System was dedicated in 1987. Within and/or adjacent to the 

analysis area there are six trailheads providing access to twelve designated USFS trails including 

portions of the Arizona National Scenic Trail, Flagstaff Loop Trail, and the historic Beale Wagon 

Trail. Currently Flagstaff Climbing operates under a special-use permit to provide guided 

climbing opportunities at West Elden (adjacent to Elden Lookout road – FR 557). There is a 

launch pad at the top of Mt. Elden in the Turkey Park area that is used by hang gliders and paragliders. Additionally, there are many organized recreation events that have been issued specialuse permits for over a decade, such as the Soulstice Mountain Trail Run sponsored by Northern 

Arizona Trail Runners Association. 

The Mt. Elden Environmental Study Area (ESA) was established in the mid-seventies. The ESA 

is a 400-acre parcel of land established as a study site and a bird sanctuary. As part of the ESA, 

there are four designated trails that provide interpretive opportunities for students and the general 

public. The western portion of the Mt. Elden ESA is located within the analysis area. The ESA is 

frequented by local school groups and is identified as a birding hotspot in many bird watching 

publications. 

Game management (hunting) unit 11M (Region II) is 

located in the analysis area just north of Flagstaff. The 

AZGFDt manages for the following species within this 

unit - antelope, black bear, elk, mule deer, and Merriam's 

turkey. The pronghorn hunt occurs in August thru 

September. The archery bear hunt in Unit 11M is 

combined with Unit 6B and occurs in the early fall. The 

elk hunt is September thru December, and the deer hunt is 

August thru January (AZGFD, 

website 2013).

Game management (hunting) unit 6A

(Region II) is located in the analysis 

area near Mormon Mountain. The 

AZGFD manages for the following 

species within this unit - black bear, 

elk, mule deer, Merriam's turkey, 

white-tailed deer, javelina, mountain 

Figure 92: Hunting Unit 11 M, AZGFD

Figure 93: Map of Hunting Unit 6A, AZGFD
Chapter 3: Affected Environment and Environmental Consequences

460 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

lion, bighorn sheep, tree squirrel, and waterfowl. 

On November 2, 2005, the Forest Service announced final travel management regulations 

governing OHVs and other motor vehicle use on national forests and grasslands. Under the new 

rules, forests that do not restrict OHV travel to "designated roads-and-trails" must do so. The 

Coconino National Forest signed a Record of Decision on the Travel Management Project on 

September 28, 2011 (USDA, TMR Record of Decision – Coconino NF 2011). Implementation of 

these new rules went into effect on May 1, 2012.

Forest Orders that affect recreation activities within the analysis area are Campfire Restrictions 

(Order Number 04-13-09-F), Camping/Campfires Prohibited (Order Number 04-112-R), Road 

Restrictions on Roads Being Obliterated (Order Number 04-99-10-E), Dispersed Camping Stay 

Limits (Order Number 04-99-08-R).

There is a proliferation of user-created or unauthorized trails within the analysis area. These trails 

have developed as a result of use by a variety of user groups - including hikers, runners, dog 

walkers, mountain bikers, equestrians, and motorcyclists. Also, it is common for many trail users 

(hikers, mtn. bikers, equestrians) to use old road beds or skid trails as well as old fire control lines 

used for prescribed fires.

Trails

The following USFS trails and/or segments of the trails are located within the analysis area. 

Table 145: USFS trails located within the FWPP analysis area

Name Length 

(miles) User Type Level of Use Season of Use

Lower Oldham #1 5.5 mi. Hiker, mtn. biker, equestrian moderate April - November

Brookbank #2 2.5 mi. Hiker, mtn. biker, equestrian moderate April - November

Sunset Trail #23 4.0 mi. Hiker, mtn. biker, equestrian moderate April - November

Pipeline #42 2.8 mi. Hiker, mtn. biker, equestrian heavy April - November

Little Elden #67 4.7 mi. Hiker, mtn. biker, equestrian moderate April - November

Upper Oldham 1.5 mi. Hiker, mtn. biker, equestrian low April - November

Rocky Ridge 

#153 2.2 mi. Hiker, mtn. biker, equestrian moderate April - November

*Arizona National 

Scenic Trail 9.8 mi. Hiker, mtn. biker, equestrian moderate to heavy April - November

*Fort Valley Trail 

System – Includes 

Secret and Upper 

Moto Trails

6.7 mi. Hiker, mtn. biker, equestrian, 

motorcyclists moderate April-November

*Mormon 

Mountain Trail 

#58

3.0 mi. Hiker, mtn. biker, equestrian moderate April-November

*Dairy Springs 

Trail #136 0.5 mi. Hiker (interpretive trail) moderate April-November

*Ledges Trail 

#138 1.0 mi. Hiker, mtn. biker, equestrian moderate April-November

*Segment or portion of the trail within or adjacent to the FWPP analysis area.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 461

The Flagstaff Loop Trail is approximately 42 miles in length and encircles the city of Flagstaff. It 

is comprised of many existing trails on different land jurisdictions. USFS trails as part of the 

Flagstaff Loop Trail within the project area include Lower Oldham #1, Rocky Ridge #153, and 

Pipeline #42. 

Trailheads

The following trailheads are located within and/or adjacent to the analysis area.

Table 146: USFS trailheads located within the analysis area

Name General Location Comment

Schultz Creek / Rocky Ridge TH Approximately 1⁄4 mile north of 

FR 420 and FR 557 junction

Facility includes parking 

area, information kiosk, 

trail signs, and a hitching 

post for equestrians.

Sunset TH Schultz Pass area (off FR 420)

Facility includes parking 

area, information kiosk, 

trail signs, and a hitching 

post for equestrians.

Schultz Tank TH Schultz Pass area (off FR 420)

Adjacent to the analysis 

area. Facility includes 

parking area, information 

kiosk, trail signs, and a 

single-vault toilet.

Buffalo Park TH Located off Cedar Avenue (near 

USGS buildings)

City of Flagstaff Park –

adjacent to project analysis 

area.

Mormon Mountain TH

Adjacent to Dairy Springs 

Group Campground (0.6 mi. 

west of FR 90)

Facility includes parking 

area, information kiosk, 

and trail signs.

FR 240/90 TH Located at the junction of FR 

240 and FR 90

TH parking area with 

kiosk to inform visitors 

about TMR guidelines.

There are several impromptu parking areas within the analysis area including along FR 557 where 

Lower Oldham and Rocky Ridge Trails junction. Forest visitors created this ad hoc parking site

by parking their vehicles just off the roadway to access West Elden climbing area and the nearby 

trails. Also, there is a popular parking area at the east end of FR 522, which provides access to 

Kachina Peaks Wilderness.

Recreation Special-Use Events

The following recreation special-use events (e.g. running, biking, hiking, etc.) take place within 

and/or adjacent to the analysis area.
Chapter 3: Affected Environment and Environmental Consequences

462 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 147: Special-use events that occur within the FWPP analysis area

Name /

Type of Event

# of 

Users

General 

Date(s)

Location 

(general route description) Notes

MBAA / Mtn. 

Biking Event 300 mid-May Fort Valley Trails to Dry Lake Hills

Stage at Fort 

Valley TH of off 

FR 164B.

Coconino County 

Parks & Rec Dept. 

/ Hiking Tour

22 per 

trip at 

7 trips 

(~144 

total)

June - Oct.

Mt. Elden and Dry Lake Hills 

Trails: Brookbank, Rocky 

Ridge, Fatman’s Loop

Issued a permit 

but not used due 

to limited interest; 

may pursue a 

future permit.

Shadows 

Foundation / 

10-mile and 10K 

Running Event

100 late June

Elden Lookout road (FR 557) 

to Sunset trail to Heart trail to 

Sandy Seep trail to Sandy 

Seep TH

Staged on private 

land at the jct. of 

FR 557 and 420 

Chiropractic Joint

/ Benefit Walk 75 mid-Sept. Elden Lookout Trail

NATRA /

Soulstice 

Mtn.Trail Run

225 mid-Oct.

Sunset TH to Brookbank trail 

to Little Gnarly trail to Schultz 

Creek trail to Sunset TH

14th year; stage at 

Sunset TH

Aravaipa Running

/ 50-mile Running 

Event

75 late Sept.

Lower Oldham Trail to Rocky 

Ridge Trail to Upper Oldham 

Trail to Sunset Trail to Heart 

Trail to Little Elden Trail to 

Little Elden Springs Rd. to 

Schultz Pass Rd. to Schultz 

Creek Trail

1

st year in 2012; 

staged @ Buffalo 

Park

Climbing

The West Elden climbing site is located within the project area – adjacent to Elden Lookout road 

at the jct. of Lower Oldham Trail. West Elden is one of Flagstaff’s oldest and most popular 

climbing areas. It is made up of an 80-foot tall Dacite cliff which hosts a large number of 

traditional routes. Over the years it has gained popularity and is now found on many websites and 

in a number of climbing publications.

Outfitter Guides / Youth Camp

Flagstaff Climbing, formerly called Vertical Relief, provides guided climbing opportunities at 

West Elden under a special-use permit. 

Mormon Lake Lodge provides horse-back riding in the forest under a special-use permit. They 

offer 1-hour, 2-hour, and half-day rides. They use trails and roads south of the FWPP analysis 

area near Mormon Mountain. The stables are generally open May-September.

Saint Joseph’s Youth Camp is located at the junction of FR 90 and FR 240, and is about 1.5 miles 

southeast of the FWPP boundary. The camp provides week-long activities for youth (ages 8 – 15) 

visiting from other parts of the state/country. Activities include arts and crafts, hiking, archery, 

horseback riding, mountain biking, campfire and telescope nights, and others. Some of these 

activities, such as hiking and mountain biking, can occur within the project area.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 463

Dispersed Camping

Dispersed camping has increased throughout the Flagstaff wildland urban interface in the past 

several years. In many areas, this has caused resource impacts such as soil compaction and 

erosion, loss of vegetation, increased fire risk, displacement of wildlife, and accumulation of trash 

and human waste.

To help prevent unacceptable resource damage, disturbance to wildlife and reduce fire risk from 

dispersed camping, the Forest Service has designated 14 campsites along FR 522 (Freidlein 

Prairie Road) for dispersed camping. Approximately 1 mile of FR 522 is along the northern 

boundary of FWPP.

The Coconino National Forest implemented new travel rules for motor vehicles on May 1, 2012, 

per the Travel Management Rule Record of Decision (signed September 2011). The Motor 

Vehicle Use Map (MVUM) is the legal document that shows where it is legal to drive a motor 

vehicle. The current map was published May 1, 2013. The MVUM is to be re-published every 

year.

The dot notations on the MVUM indicate corridors where vehicles can be driven off-road up to 

300 feet to accommodate "car camping.” These areas are known as “camping corridors.” Within 

the DLH portion of the FWWP analysis area, there is a 1-mile camping corridor located on FR 

420 (Schultz Pass Road) -approximately 1.5 miles north of the junction with FR 557 (Elden 

Lookout Road). Near Mormon Mountain, there is roughly a 4-mile camping corridor located on 

FR 132 - from the junction of FR 90 to the junction of FR 132D (USDA, MVUM – Coconino NF, 

2013).

Wilderness

The Kachina Peaks Wilderness, located approximately 6 miles north of Flagstaff, is adjacent to 

the FWPP analysis area. The U.S. Congress designated the Kachina Peaks Wilderness in 1984 

and it includes a total of 18,616 acres. The Kachina Peaks Wilderness is in close proximity to the 

northern boundary of the project area – near the junction of FR 522 and FR 6273. There is an ad 

hoc trailhead at this road junction that provides access to the Kachina and Weatherford Trails 

located within the Wilderness area.

Road System

Forest Service roads within and/or adjacent to the DLH area that are heavily used by 

recreationalists include FR 420 (Schultz Pass Road), FR 522 (Freidlein Prairie Road), FR 557 

(Elden Lookout Road), and FR 556 (Little Elden Springs Road). These roads provide 

recreationists with access to trailheads, dispersed camping sites, climbing and hang gliding 

locations, as well as hunting opportunities, recreational driving experiences, scenic and wildlife 

viewing, birding, and fuel-wood gathering. Forest roads are occasionally used for recreational 

special-use events (e.g. running or biking events), and also for shuttling purposes for activities 

such as downhill mountain biking (aka gravity riders).

FR 789 is a decommissioned road that begins at its junction with FR 420 (Schultz Pass Road). 

The old road location crosses Schultz Creek at this point and is currently closed with a gate. It 

then climbs to the mesa on top of the Dry Lake Hills and passes through a parcel of land owned 

by the Navajo Nation. The road passes close to the seasonal “dry lake” on the top of the Dry Hill

Hills and terminates on the western edge of the mesa. Much of FR 789 is used as a trail by hikers, 
Chapter 3: Affected Environment and Environmental Consequences

464 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

mountain bikers and equestrians – in particular, the segment from FR 420 to the top of the mesa 

where it serves as a link with Brookbank Trail. This portion of FR 789 is known as the “Little 

Gnarly Trail” by locals and trail guide maps/books. It is a popular route and is used on occasion 

for special-use running and biking events.

Forest Service roads within and/or adjacent to the Mormon Mountain area used by 

recreationalists include FR 90 (Mormon Mountain Road), FR 132, FR 132A, FR 240, and FR 

248. These roads are used by recreationalists in a similar fashion as the Dry Lake Hills area, 

except there is no mountain biking shuttling activity. Also, FR 90 is a critical access road for 

Mormon Mountain Lodge, Saint Joseph’s Youth Camp, Dairy and Double Springs Campgrounds, 

private residents, and a number of recreation residence or cabins located on the national forest via 

a special-use permit.

Environmental Effects

The timeframes for direct and indirect effects will include the potential for eight to ten years of 

project implementation, followed by a period of recovery lasting up to ten years. The analysis 

area for direct and indirect effects is the project area. The timeframe for cumulative effects is 20 

years and the area includes the Flagstaff Ranger District of the Coconino National Forest.

Alternative 1: No Action

Direct & Indirect Effects

Under the No Action Alternative, recreation activities would be managed as they currently are 

without impacts from fuels reduction treatments associated with FWPP other than those approved 

under previous decisions (e.g. Jack Smith Schultz and Eastside Forest Health and Fuels 

Reduction Projects). There would be no direct, indirect or cumulative effects to trail-use, 

dispersed camping, hunting, driving for pleasure, birding, climbing, special-use events (e.g. 

running or biking events), the Mount Elden Environmental Study Area and other recreational 

activities.

However, in the event of an 

uncharacteristic high severity wildfire 

such as the Schultz Fire (2010), the 

existing recreation infrastructure and 

activities could be drastically 

impacted. 

For example, several trails were 

severely damaged by the Schultz Fire 

and subsequent flooding - including 

Weatherford Trail #102, Waterline 

Trail, Deer Hill Trail #99, Little Elden 

Trail #69 and Little Bear Trail #112 

(see Figure 94). 

These trails were closed during and 

after the Schultz Fire for public safety 

and for resource concerns. The Deer 

Figure 94: Little Bear Trail, Post-Schultz Fire, 

October 2010
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 465

Figure 95: Widow-maker tree with 

detached limb (above); dead standing tree

with little holding wood (right); pictures 

from Waterline Trail damaged by Schultz 

Fire.

Hill Trail remains closed because many segments of the trail are considerably damaged; the trail 

will need to be relocated at a substantial economic cost before being re-opened. Also, the Little 

Elden Springs Horse Camp was closed during the Schultz Fire and subsequent flooding events. 

For many months after the fire, standing dead trees were a serious public safety hazard because 

they are more susceptible to falling due to their charred condition. It can take several years for 

these trees to fall on their own accord depending on a number of variables: weather and 

atmospheric conditions (e.g. wind, snow loading, freeze/thaw cycles, etc.); topography (e.g. 

aspect, slopes, etc.); burn-severity (e.g. impact to root system, burned tree bole – cat face, etc.); 

and ongoing flooding. Trees with a detached limb or tree top are referred to as “widow-makers” 

(Figure 95) because the object (e.g. detached limb) can become dislodged by wind and fall onto 

equipment and personnel. Across the nation, there have been a number of fatalities due to widowmakers. The Schultz Fire caused a number of impacts to trails, but subsequent flooding events 

were more detrimental and resulted in more 

significant damage to the trails. 

Large debris flows removed major 

sections of the trail – often 

completing removing any evidence 

of a trail and depositing large 

boulders and debris onto the trail 

(Figure 96).

The threat of catastrophic wildfires 

is increasing due to un-managed 

vegetation which would severely 

impact recreation values and 

experiences – similar to the 

Schultz Fire (see also the Fire & 

Fuels Specialist Report). Fires of 

greater intensity and scope, 

including stand replacement fires, can result in changes to the landscape, its character, and visual 

Figure 96: Debris flow onto Little Elden Trail, 

Post-Schultz Fire.
Chapter 3: Affected Environment and Environmental Consequences

466 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

quality. This would reduce or significantly diminish the quality of recreational settings and 

experiences that are desirable - including recreational driving, trail-use (e.g. hiking, biking, horseback riding), and hunting. Areas currently used for dispersed camping, recreation special-use 

events (e.g. running and biking events) and rock climbing would likely be unsafe and less 

appealing for these activities after such a fire – possibly resulting in closures (short-term and 

long-term depending on the severity). 

This alternative would not meet the project’s desired conditions or forest plan direction. It would 

not move the project area toward Restoration and Adaptation of Recreation Settings. No action 

would result in the current wildfire risks and declining forest health and it is reasonable to assume 

that these risks increase each year and could be exacerbated by climate change. A severe wildfire 

within the project area would change the landscape and likely alter the Recreation Opportunity 

Spectrum – resulting in diminished scenic qualities and detracting recreational values.

Cumulative Effects

The cumulative effects analysis area is the northern portion of the Coconino National Forest –

above the Mogollon Rim. The timeline for analysis is 20 years because most long-term effects of 

the alternatives are assessed out to a 20 year timeframe (with the exception of large scale high 

severity wildfire which is more difficult to project). 

The following is list of actions relating to recreation management and recreational activities

considered in the cumulative effects analysis for this project:

Past activities that created the current conditions include forest management practices 

related to timber harvest and fire suppression (i.e. Eastside Fuels Reduction Project, 

Schultz Fire), dispersed and developed recreation management – including construction 

of the Arizona Trail, Travel Management Rule, special-use events and outfitter guide 

operations.

Present and future activities such as vegetation management (i.e. 4FRI projects), trails

management – ongoing operation and maintenance of existing trails, and pending trail 

planning projects - Mount Elden / Dry Lake Hills Planning Project. 

The cumulative effects of past management activities are visible as the existing conditions. 

The short term cumulative effects (1-5 years) of the No Action alternative combined with similar 

current and future restoration treatments and prescribed burning projects are expected to be 

negligible, unless additional large scale, high severity wildfires occur in the northern portion of 

the Coconino National Forest. If a wildfire burned recreational infrastructure including USFS 

trails and recreational features (i.e. trailheads), there would be long term negative changes (10 to 

25 years). Trails impacted by a severe wildfire would be closed for public safety and it’s probable 

such trails would be damaged by subsequent flooding. This would result in long-term closures 

and displacement of trail use to other trail systems in northern Arizona. This could lead to an 

increase in the construction of un-authorized trails.

Irretrievable and Irreversible Commitment of Resources

This alternative does not propose changes and thus does not have any irretrievable and 

irreversible commitment of resources except those associated with a wildfire, described above.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 467

Effects Common to all Action Alternatives

Direct & Indirect Effects

Campfire Closure

The campfire closure order would impact recreationalists, most directly dispersed campers that 

would prefer to have a campfire throughout the DLH portion of the project area. The campfire 

closure order would likely result in less dispersed campers within the closure area because of 

campers seeking legal campsite locations to have a campfire. 

The campfire closure order would restrict campfires within the closure area indefinitely. This 

would displace the use of campfires to areas outside of the closure area. Also, the campfire 

closure order would help reduce the potential for human-caused wildfire and lessen the likelihood 

of a wildfire that could cause severe destruction and severely impact recreation opportunities 

throughout the DLH area for 10 – 20 years and possibly beyond.

Conventional Ground Based Harvesting

Conventional logging typically has some degree of short term to mid-term effects on recreational 

use and activities. During logging operations, areas would be closed to public access for safety 

purposes including roads, trails, and other recreation facilities (e.g. parking areas, trailheads, etc.). 

These temporary closures would directly affect a number of recreation activities such as driving 

for pleasure, dispersed camping, hunting access, trail use, special-use events (e.g. running and 

biking races, family re-unions, etc.), and outfitter guide operations (e.g. climbing). 

Mechanical treatments would likely have temporary effects on the quality of the experience for 

some forest visitors. The immediate and substantial change in appearance of treated sites results 

in an effect on the visual quality of the recreation driving experience (see the Scenery section). 

Mitigation measures include efforts to reduce scenery impacts, and limit forest treatment 

activities within the project area during high-use weekends and holidays (e.g. Memorial Day, 4th 

of July, Labor Day, etc.), especially in locations where recreation based infrastructure is located

(e.g. trails, trailheads, etc.). Also, temporary closures of forest roads and/or portions of the project 

area during implementation would be coordinated with AZGFD during hunting seasons to reduce 

impacts on hunters.

Mechanical treatments in the area open to dispersed camping would likely result in immediate 

changes to the quality and quantity of camping opportunities for both short-term and mid-term. 

The disturbance from mechanical thinning (temporary and skid road construction and use, tree 

removal, ground vegetation disruption, slash piles, etc.) can disrupt both the aesthetic and 

physical qualities that make a campsite desirable, including for persons seeking would, cover, etc. 

While sites could be rendered unusable by mechanical treatments, these effects will not be 

permanent, with use anticipated to increase in the mid to long-term. As initial ground disturbance 

heals, slash piles are burned and the beneficial effects of treatments become evident, the sites 

would likely be desirable again. It is likely that, in the short term (up to 1-2 years after 

mechanical treatment) that dispersed camping use would be displaced to other sites both inside 

and outside of the project area by the treatment activities. As a result of this displacement, use of 

existing sites that are not planned for treatment within the project area and sites outside the 

project area may see increases in use. This use is likely to lead to some effects to these sites from 

the increased use. However, as the overall amount of dispersed camping use to be displaced is 

relatively low, the associated effects of displace to other sites can also be seen as insignificant.
Chapter 3: Affected Environment and Environmental Consequences

468 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Logging operations in areas where Forest Service system trails exist would have immediate 

effects on the trails and the quality of recreational experience derived from them. The disturbance 

from mechanical thinning (temporary and skid road construction and use, tree removal, ground 

vegetation disruption, slash piles, etc.), while temporary, can impact sections of trails making 

them hard to follow and in some cases temporarily unusable. The duration of this effect would

likely last from a few months to possibly a few years, once the logging operations are concluded 

and trail rehabilitation work is completed. In addition, some trails may be used as temporary skid 

trails to move logs and slash, often resulting in ruts and damage to the trail tread (aka trail prism) 

and trail drainage structures (e.g. water bars, rolling dips, reverse grade, etc.) during 

implementation. Also, logging skid trails that cross or bi-sect a Forest Service system trail may 

cause similar impacts and can affect the drainage of the trail resulting in increased erosion during 

implementation. However, after implementation, contractors would be required to return the 

roads and trails to their previous (pre-disturbance) condition, and BMPs would decrease impacts 

associated with harvesting activities, including erosion and rutting. 

A number of trail mitigation measures and designed features were developed to minimize 

impacts, especially on the Arizona National Scenic Trail. These include: (1) crossing or using the 

Arizona National Scenic Trail as a skid trail would be done sparingly and only if no other 

alternative exists; (2) not implementing jack straw treatments within 1,000 feet of the Arizona 

National Scenic Trail; and (3) not using motorized equipment on National Scenic, Historic and 

Recreation Trails, or other forest system trails if these are used for control lines. Also, USFS 

single-track trails would be avoided for use as a skid trail or temporary road. Refer to Chapter 2 

for the full list of mitigation measures and design features for trails.

Social or unauthorized trails within the project area where logging operations occur would be 

directly impacted by mechanical treatments. Segments of these unauthorized trails would be 

affected by the development of temporary roads, skid trails, and roadside landings. The impacts 

from mechanical treatments to segments of unauthorized trails would result in ground 

disturbance, tree removal, and vegetation alterations. It is anticipated that such unauthorized trail 

segments would no longer be usable during and after logging operations as the contractor would 

not be required to return unauthorized trails to their pre-disturbance condition. There are no 

design features to rehabilitate unauthorized trails post-treatment. 

An indirect effect of conventional logging may result in the development of unauthorized trails as 

a consequence of temporary roads and mechanized skid trails. For timber extraction, temporary 

roads are created and rubber tired grapple skidders are used to drag whole trees to a roadside 

landing area – creating a skid trail. Once the logging operations are completed, these temporary 

roads and skid trails can inadvertently become unauthorized trails used by a number of forest

visitors including hikers, mountain bikers, equestrians, ATV enthusiasts, and motorcyclists. 

Mitigation measures to address this potential impact include the use of physical measures such as 

re-contouring, pulling slash and rocks across the line, placing cull logs perpendicular to the route, 

and disguising entrances onto temporary roads and skid trails to hasten the recovery. 

Special-use activities, such as running or biking events, that use trails or sites that are closed to 

public access during logging operations would be directly impacted. Also, permits would not be 

issued for family re-unions or other group activities within the project area during logging 

operations to ensure public health and safety. A coordinated effort would be made with sponsors 

of recreational special-use events to minimize the impacts on such events within the project area 

during implementation. Alternative locations would be identified to meet the needs of the specialuse event if logging operations conflict with preferred locations and cannot be resolved through 

timing.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 469

Direct effects on rock climbing use from treatment activities would be minimal and of short 

duration. It is likely that treatments in climbing areas would consist of hand thinning, mechanical 

pilling of slash, and burning. These activities would cause only temporary disturbance to rock 

climbing opportunities from noise and would only minimally and temporarily impact visual 

quality.

Logging operations proposed within the urban interface would have the immediate effect of noise 

and public safety hazards during mechanical treatment, and the disturbance to social trails and 

routes used by the public from vegetation removal, slash piles and other treatment effects. 

Mitigation measures and designed features, as described in Chapter 2, for recreation and scenery

would be implemented to minimize the impacts on forest visitors and recreational activities.

Roadside landing areas used for logging operations become trampled and denuded of vegetation. 

A short duration after logging operations are completed (i.e. 2-3 years) these landings become a 

desired dispersed camping/parking area for forest visitors. Additionally, forest visitors gathering 

fuel wood congregate to these areas because of the open access and abundance of slash and 

woody material.

Logging operations should not have a major effect on restricted motor vehicle use for the Mount 

Elden/Dry Lake Hills area, although the opening up of sites of trees would indirectly allow easier 

access for persons wanting to drive off road, and thus make it somewhat more difficult to 

administer off-road motorized travel restrictions.

Hand Thin and Pile

Hand thinning usually has little or no short term effects on recreation management. Trees are cut 

down, and then cut (lopped) into smaller lengths that are collected and stacked for future pile 

burning. Project design features would require most slash piles to be a safe and reasonable 

distance from trails and recreation facilities. Similar to roadside landings, forest visitors seeking 

fuel wood opportunities would likely harvest hand piles to remove logs and branches. Hand 

thinning and pile burning within the Mount Elden Environmental Study Area would help restore 

natural conditions. In the short-term (1-2 years) these operations would detract from the user 

experience due to visual impacts; however in the mid-to-long term (3-20 years) they would 

enhance the experience of those visiting the area by reducing the likelihood of a catastrophic fire 

and improving the diversity of vegetation and scenery.

Machinery on Steep Slopes

The effects of steep slope harvesting equipment would be similar to the ground based logging 

noted above. However, large rocks and other debris could become dislodged and move downhill 

from the equipment onto trails and roads below the harvesting operation. Project mitigation 

measures require the trail and road to be closed to public access during operations and that FS 

system trails are restored to USFS standards post-treatment. 

Aspen, Grassland and Electronic Site Protection Treatments

Aspen treatments to stimulate new sprouting require protection from ungulate browsing following 

treatments. A variety of treatments would be used including removal of invading conifers within 

100 feet of aspen clones, prescribed fire, ripping, planting, fencing and/or cutting of aspen to 

stimulate root sprouting. Many aspen clones currently have dead and down and dead standing 

trees. Treatments would not be very noticeable with the exception of fencing, which would not 

impede or cross a FS system trail when constructed. Thus there would be no direct or indirect 

effects on recreation use or activities.
Chapter 3: Affected Environment and Environmental Consequences

470 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

There would be no effects to recreation management from grassland restoration or electronic site 

structure protection activities. 

Prescribed Fire

Depending on fire severity, effects from prescribed burning would include: charred soil and 

vegetation immediately following burning; charred bark up to 10 feet from the ground; needle 

and leaf scorch typically less than 20 feet from the ground; and, loss of understory trees, trees 

with old scars or trees with large accumulations of dead fuels at their base. In areas of moderate 

to high severity, openings may be created as a result of more extensive tree mortality. 

Prescribed burning would create short term and temporary effects on recreation opportunities. 

Areas where these treatments are implemented may be closed to public access during operations 

for safety purposes. This may temporarily alter vehicular access (i.e. driving for pleasure, 

hunting, etc.), trail use, and other recreational activities such as dispersed camping and climbing. 

Recreationalists would not be able to access areas that are closed during burning operations. In 

addition, it may affect special-use events (e.g. running and biking races). Design features include 

working with event coordinators to minimize the impacts on such events within the project area 

during implementation. Alternative locations would be identified to meet the needs of the specialuse event if forest management activities conflict with preferred locations and cannot be resolved 

through timing. Pile burning treatments would have little effect on recreation management; it may 

require areas to be closed to public access during operations if public safety is a concern. Design 

features would ensure piles are at a safe and reasonable distance from trails and recreation 

facilities.

Prescribed burning operations may have the indirect effect of displacing general forest use short 

distances spatially as users (i.e. hikers, joggers, dog walkers, mountain bikers, equestrians, etc.) 

avoid slash piles, stump holes and other effects of treatment. As a result, new social trail networks 

could evolve.

Smoke from prescribed fire operations can negatively impact the health of forest visitors in the 

immediate area, especially people with respiratory problems. This could affect dispersed campers, 

hunters, and trail-users near the prescribed fire operations. However, direct effects of initial and 

maintenance burning on dispersed camping would be minimal and short term. Generally campers 

in areas to be burned are informed about the burning operation and are asked to leave for the 

duration of the burn for their safety. Smoke from burning could cause discomfort to campers in 

the project area during burning but usually disperses within 24 hours. For the duration of a few 

months after initial and maintenance burning, ash on the forest floor is likely to make camping 

less pleasurable as it tends to blow in light breezes and stick to surfaces like shoes, tents and 

clothing. During implementation, smoke could obscure views of the surrounding terrain and 

mountains. Effects to residents and visitors in the project areas may be dissatisfaction that their 

views and scenic features are obscured. Very smoky conditions typically occur during the first 

entry of prescribed burning due to heavy fuel loadings. There can be lingering smoke for two 

weeks to a month after burning as stumps, large logs and roots smolder. Smoke from repeat burns 

should lessen, since less fuel would be consumed.

There may be indirect effects of smoke as well since it drifts and is pushed by air currents. 

Nearby developed recreation sites, houses and subdivisions, and the communities may experience 

reduced visibility and smoky conditions. Dispersed campers and other recreationists may 

experience reduced visibility and smoky conditions in some places near the project area.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 471

Transportation System

Maintenance on roads within the project area would be necessary prior to implementation, 

including reconditioning and resurfacing of FR 420, 556 and 132.Road maintenance activities 

would improve the condition of the existing road system. This would have a direct short-term 

impact on forest visitors that intend to use the forest as these roads would be closed during 

maintenance operations. This would affect vehicular access for a number of different recreational 

activities including driving for pleasure, dispersed camping, hunting, climbing, special-use 

events, and trailhead access where applicable. Also, it would impact the many recreationalists 

who drive to top of Elden Lookout road (FR 556) to enjoy the views, picnic, access trails, hunt, 

hanglide, and those shuttling mountain bikes for downhill mountain biking. However, the road 

maintenance would benefit forest visitors accessing the area in vehicles in the mid and long term 

by improving the road 

Construction of temporary roads (approximately 21 miles under Alternative 2, 15 miles under 

Alternative 3, and 13 miles under Alternative 4) would result in moderate effects on recreation 

use and activities. The temporary roads, where they cross existing FS system trails and 

unauthorized trails, would close those segments of the trail and disrupt that use during logging 

operations; although the temporary roads would be rehabilitated after the thinning treatments are 

completed. Design features would be used to close entrance points and BMPs for watershed 

would ensure drainage is re-established and the roads can rehabilitate. The temporary roads 

would begin to recover and should be mostly recovered and less noticeable to the casual observer 

in 5 to 10 years after the project is completed, and the roads are rehabilitated. It would be 

anticipated that the temporary roads may receive inadvertent trail use post-treatment; this may 

include non-motorized and motorized use. Decommissioned roads would begin to recover after 

treatment and would be mostly recovered and less noticeable to the casual observer in 5 to 10 

years.

Cumulative Effects

The actions considered in this discussion are those that have occurred in the recent past (10 

years), as well as those reasonably foreseeable land management actions, and the cumulative 

effects of those actions and this proposal. Management activities that occurred prior to this time 

helped create the current condition described under the affected environment section. For this 

discussion, actions to consider are those that occur in areas immediately within or adjacent to the 

project area. These include, affect and are affected by: 

Ongoing dispersed camping within the project area, and on lands surrounding the project 

area. 

Ongoing dispersed recreation (day use) in and around the project area including mountain 

biking, rock climbing, recreational driving, hiking, horseback riding, etc. 

Ongoing latent community use and social trail use in and around the project area, including 

for access to general forest areas. 

Upcoming local, regional and national motorized access and Travel Management Rule policy 

changes for off-road vehicle use. 

Special uses and areas within the project area, including commercial operations such as 

climbing guides, riding stables. 

Areas where special restrictions are in place, such as motorized vehicle restrictions, shooting 

and camping restrictions, etc. 

Predominant semi-primitive non-motorized and semi-primitive motorized recreation settings, 

with some less highly developed settings in the area, would add to the presence of the desired 
Chapter 3: Affected Environment and Environmental Consequences

472 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

wildland recreation setting in the surrounding landscape. Surrounding areas are also likely to 

maintain and enhance some semi-primitive settings. The exact amount is unknown, but 

subsequent project work in these areas is intended to continue this trend.

Although it is difficult to estimate where displaced campers may go, it’s predicted that major 

forest roads outside of the treatment areas may see increased use, although this should not be a 

significant displacement, since there is not a significant amount of overnight camping in the 

project area now. As the current and historic camping use in the project area has been dispersed in 

nature, it is reasonable to assume that displaced campers would continue to seek this type of use 

here and in other areas. Displaced campers may add to current camping impacts in locations

adjacent to the project area causing a slight increase in resource impacts.

Alternative 2: Proposed Action with Cable Logging

Direct & Indirect Effects 

Under Alternative 2 the direct and indirect effects would be the same as those identified in the 

effects common to all action alternatives section above, but the addition of cable logging 

operations would most directly impact trail use and aesthetics within the project area. The 12-foot 

wide cable logging corridors would directly impact existing USFS trail and unauthorized trail 

activities where they intersect. 

The adjacent map (Figure 97) shows the location of USFS trails and the proposed cable logging 

locations. USFS trails that would be directly impacted by cable logging operations includes a 

good portion of Schultz Creek Trail, three segments of Brookbank Trail, Upper Oldham Trail, and 

Secret Trail near FR 6273 (see Table 148).
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 473

Figure 97: Alternative 2 Proposed Treatments with Trails and Roads Displayed
Chapter 3: Affected Environment and Environmental Consequences

474 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Table 148: USFS trails with segments located within proposed cable logging 

locations.

Trail Name *Length 

(mile)

Description of trail segment location and type of Logging Operation 

(Skyline or Excaline)

Schultz Creek 1.9 mi.

Two different segments of the trail within cable logging locations.

(1) Southern portion near jct. of Rocky Ridge Trail = 1.1 mi. –

Excaline

(2) Northern portion near jct. of FR 789 = 0.8 mi. – Skyline

Brookbank 1.0 mi.

Three different segments of the trail within cable logging locations.

(1) Sunset Trail jct. to the southwest = 0.5 mi. – Skyline

(2) Northeast of Dry Lake area = 0.4 mi. – Excaline

(3) Directly east of Dry Lake area = 0.1 mi. – Excaline

Upper Oldham 0.68 mi. Trail segment is in the upper portion of the trail – Skyline

Arizona 0.36 mi. Trail segment due east of FR 6356 - Excaline

Secret 0.25 mi. Trail segment is located north of FR 6273 – Excaline

*Denotes approximate length of the trail located within the proposed cable logging locations.

There are a number of unauthorized trails that would be directly impacted by the cable logging 

corridors as well; many of which have been named by local trail enthusiasts – including Middle 

Oldham, Steel Reserve, Private Reserve, Upper and Lower Wasabi, Jedi, Double D as well as 

others. The areas and trails being treated with cable logging systems would be closed to public 

use for public safety concerns during operations. The trail tread, soil and vegetation near these 

trail intersections would be significantly disturbed by the cable logging operations. This would 

disrupt trail use and other recreational activities in these areas during logging operations and 

likely until the sites can be properly rehabilitated and restored. In addition, the cable logging 

operations would directly affect the aesthetics in the areas being treated, which would impact the 

experience of forest visitors – especially those driving for pleasure seeking desired viewsheds 

(see the Scenery section of this chapter).

In addition, the hanglider launch pad above Devil’s Chair on Mount Elden is located adjacent to a 

cable logging location. This would require the launch pad to be closed, impacting the use by 

hangliders and paragliders during logging operations. Also, it may result in disturbance to the 

surrounding soil and launch pad itself.

USFS trails within close proximity to cable logging locations would be indirectly affected by this 

activity as it would impact use (e.g. trail closures during operations), could temporarily accelerate 

gravitational erosion and debris onto the trails as a result of cable logging operations, and a 

change in the vegetative composition which could affect the aesthetic value of the area to those 

using the trails. The following trails have a significant segment of the trail located within 500 feet 

of cable logging locations (Table 149). 

Table 149: USFS trails with segments located within 500 feet of cable logging 

locations (CLL)

Trail General description of trail segment location

Arizona Several segments of the trail are near CLL, especially just north of FR 789.

Schultz Most of the trail is located within or close proximity to CLL.

Secret There are a couple of segments near CLL – primarily near Orion Spring.

Sunset There are two segments near CLL – near the jct. of Brookbank Trail and near 

the Oldham Park area.
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 475

In addition, FR 420 and FR 557 are adjacent to cable logging operations and would have similar 

direct and indirect impacts as those using the trails. This would affect a number of recreational 

activities including driving for pleasure, hunting, and dispersed camping.

Cumulative Effects

The cumulative effects for Alternative 2 are the same as those identified in the Effects Common 

to All Action Alternatives section, but would also impact the MEDL planning project. The MEDL 

proposed action includes new trail construction, relocation of existing FS trails, incorporation of 

some user created trails (i.e. downhill mountain bike trails), an access trail for climbing at West 

Elden, and improving an existing hanglider launch pad in Turkey Park area. All of these proposed 

actions are either completely located within or have a significant portion located within the cable 

logging corridors and would be affected by such activity. 

Alternative 3: Proposed Action without Cable Logging

Direct & Indirect Effects

Alternative 3 would not have the impacts on recreational activities identified in the previous 

section from cable logging. However helicopter logging would likely increase the need for area 

closures for public safety because of the inherent danger with this type of activity. There may be 

an additional need to secure the closed areas from forest visitors to ensure public health and 

safety concerns. 

Cumulative Effects

The cumulative effects for Alternative 3 are the same as those identified in the Effects Common 

to All Action Alternatives section above.

Alternative 4: Minimal Treatment

Direct & Indirect Effects

Alternative 4 would have similar effects as those described in the Effects Common to All Action 

Alternatives section, except that the impacts are anticipated to be less than Alternatives 2 and 3 

due to fewer acres being proposed for treatment and a reduced mileage of temporary road 

construction. However the acres that would not be treated under this alternative would retain the 

same degree of wildfire risk as under the Existing Conditions and No Action Alternative. 

Cumulative Effects

The cumulative effects are the same as those identified in the Effects Common to All Action 

Alternatives section above.

Irreversible and Irretrievable Commitments of Resources

The action alternatives focus on reduction of fuels to reduce the threat of high severity wildfire 

and subsequent flooding in two key areas near the City of Flagstaff, Arizona: the Dry Lake Hills 

portion of the Rio de Flag Watershed north of Flagstaff, and the Mormon Mountain portion of the 

Upper Lake Mary Watershed south of Flagstaff. As such, there is no irretrievable or irreversible 

commitment of resources.
Chapter 3: Affected Environment and Environmental Consequences

476 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

Amendment 1: Modify Forest Plan language to allow mechanical treatments in MSO PACs up to 

18 inches dbh and hand thinning treatments up to 9 inches dbh and prescribed burning within 

MSO nest/cores. The monitoring requirement specified under the Forest Plan would be amended 

to include the monitoring plan developed by the Forest Service, U.S. Fish and Wildlife Service, 

and the Rocky Mountain Research Station referenced in the following section titled, 

“Monitoring.” This amendment would also remove timing restrictions within MSO PACs for the 

duration of the FWPP project. Treatments within PACs would be accomplished as quickly as 

possible to reduce the duration of impacts, and would be coordinated with FWS. The purpose of 

this amendment would be to facilitate treatment in high-priority locations such as Mexican 

spotted owl occupied habitat to prevent high-severity wildfire. This is based on language in the 

Mexican Spotted Owl Recovery Plan (2012), which states, “[wildfires] result in the most 

significant alteration of owl habitat and hence, have the greatest potential for loss of habitat.”

Effects to Recreation Management

Amendment 1 would have similar effects to recreation management as noted above. 

Amendment 2: Removing language restricting mechanical equipment to slopes less than 40 

percent and language identifying slopes above 40 percent as inoperable. This amendment would 

allow mechanical harvesting on slopes greater than 40 percent within the project area. 

It would be necessary to allow for use of specialized mechanical equipment to cut and remove 

trees on steep slopes to reduce the risk of high-severity wildfire in this project area due to the 

preponderance of areas with greater than 40 percent slope in the project area. Furthermore, since 

the Forest Plan was written and amended, mechanized ground-based equipment has progressed to 

be able to operate on steep slopes more effectively. While this specialized equipment is not 

commonplace in this region due to the high cost of its use, the approval of the City bond makes 

the use of such equipment a possibility for this project. In order to be able to utilize such 

equipment to treat slopes above 40 percent in the project area and meet the purpose and need, this 

Forest Plan amendment is needed.

Effects to Recreation Management

Use of specialized equipment to treat steep slopes would result in minimal impacts to 

recreationalists. It would require the closure of trails for public safety as noted above and in areas 

where trails and other recreation infrastructure is located. However, user created or unauthorized 

trails within these areas will be impacted by treatments. These unauthorized trails would not be 

rehabilitated after the treatment is completed and will likely result in displacing this type of 

activity. 

Heritage

Methodology

Heritage analysis was based on a review of previous heritage survey and previously recorded 

archaeological sites, as well as new survey conducted in support of the proposed action (Whiting 

2013). A literature review was conducted via the forest’s INFRA and geospatial databases, 

and archaeological and historic atlases. A sampling plan was developed based on geospatial 

modeling, including Terrestrial Ecosystem Units (TEU), slope, and elevation (see Haines and 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 477

Peters 2013 for technical details on sampling methodology) and received Arizona State Historic 

Preservation Office (SHPO) concurrence on January 6, 2014. 

The archaeological surveys addressed potential impacts resulting from the proposed undertaking 

including mechanical thinning, temporary road construction, road closure and decommissioning, 

helicopter logging, cable logging, prescribed fire, and more. The entire project area was sampled 

based on known and predicted site densities in addition to the mechanical and ground disturbing 

treatments proposed. Archaeological site density was determined through modeling of district 

GIS files. Surveys undertaken for the current project have resulted in coverage of 46 percent of 

the DLH area (1,595 previous survey and 1,908 sample survey) and 62 percent of the MM area

(499 previous survey and 1,355 sample survey) (Whiting 2013). 

Complete survey is considered one-hundred percent based on pedestrian surveys of no more than 

20 meters apart. Surface artifacts and features were identified and documented by use, date, 

phase, and cultural affiliation. Site condition was noted, with fire fuel loading evaluations also 

completed for each site. Fire tolerance of a site was determined through examining artifact and 

feature materials, on site fuel loads, standing dead trees, slash piles, and the fire return interval of 

the area (has the site burned before historically or prehistorically).

Since surveys were completed prior to development of this specialist report, we were able to use 

previously recorded sites along with sites identified through the current project’s sample survey to 

analyze effects to archaeological sites from project alternatives. 

As all sites considered unevaluated for or eligible the NRHP are managed for no effect or no 

adverse effect per federal law and local planning guidance, we were able to combine analysis for 

Alternatives 2, 3, and 4. The effects from Alternative 1 (No Action) are analyzed separately. 

Incomplete and Unavailable Information

We based this analysis predominately on a sample of previous heritage surveys in the project 

area. Samples represent, by nature, an incomplete body of archaeological data for a project area. 

Previous analyses of archaeological site density (Barrett 2010; Haines and Peters 2013) as well as 

review of historic atlases and other data sources, however, demonstrate a low likelihood of 

significant heritage resources in the low site density areas. Surveys undertaken for the current 

analysis confirm that site density is relatively low in this project, relative to other areas of the 

Flagstaff Ranger District. Thus, sample survey of those areas is both justified and appropriate for 

management purposes. 

Affected Environment

Existing Condition

Cultural Resource Surveys and Sites

During the last 40 years, 70 cultural resource surveys conducted in the analysis areas have 

resulted in coverage of 46 percent of the DLH area (1,595 previous survey and 1,908 survey for 

the current project) and 62 percent of the MM area (499 previous survey and 1,355 survey for the 

current project).
Chapter 3: Affected Environment and Environmental Consequences

478 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

The following summary of heritage resources in the analysis areas was developed from Haines 

and Peters (2013), Pilles and Stein (1981), and Whiting (2013). For specific information on sites, 

see Whiting (2013). 

There are 39 historic properties identified within the analysis areas through the 70 previous 

heritage inventories and consultation efforts. Of the 39 archaeological sites, 25 are prehistoric, 

one is protohistoric, 10 are historic, two are multi-component which means they include more 

than one temporal period, and one is the San Francisco Peaks TCP. Twenty-seven of the sites and 

the TCP are in DLH and the remaining 11 sites are in the MM area. These sites reflect the long 

history of human occupation and use of the area from late Archaic hunter gatherer period through 

the prehistoric and proto-historic periods and culminating with middle 20th century sites from 

Euro and Native American use and settlement of the area. 

The earliest sites date to the late Archaic/early Formative period (150 B.C. – A.D. 700) and are 

represented by a lithic scatter and a rock shelter. These sites are related to hunting and gathering 

activities that took place on the forest from approximately 3,500 to 1,300 years ago. 

Approximately half of the prehistoric sites represent the Formative Pueblo time period and most 

are categorized as Sinagua, based on diagnostic artifact and feature types. These sites include pit 

houses, small pueblos, a rock shelter and artifact scatters, and date from the Sunset to Turkey Hill 

phases. 

An unusual site is a Yavapai-affiliated artifact scatter in the MM area that dates from 

approximately A.D. 1400 to 1863 and spans the poorly represented Protohistoric Period on the 

forest.

About one third of the sites in the analysis areas have at least one component that dates to the 

historic period, with most sites dating to the Statehood period (1912-1946). These sites include 

the remains of the Schultz Pass Civilian Conservation Corps (CCC) Camp, historic roads, logging 

railroad lines that represent the logging economy of the early 20th century (Clark Valley and 

Mormon Mountain RR lines), a ranching line shack, and temporary historic-period camps and 

trash dumps. There is one site with a historic-period inscription that dates to the Territorial Period 

(1863-1912). 

Portions of the 86,000 acre San Francisco Peaks TCP are in the DLH area. The CNF has 

identified this TCP over many years of ongoing consultation with tribes about traditional locales. 

The San Francisco Peaks were determined eligible for the National Register under Criterion A for 

their cultural significance to the Acoma, Apache, Havasupai, Hopi, Hualapai, Navajo, Paiute, 

Yavapai, and Zuni people. This determination of eligibility came about as part of the settlement 

for the White Vulcan Mine (Pilles 2000). Although a formal boundary for the TCP has not been 

presented to the National Register of Historic Places for concurrence, a working boundary for the 

TCP was agreed to in consultation with 13 tribes and the Arizona State Historic Preservation 

Officer. This working, provisional boundary is co-terminus with the boundary of the area 

withdrawn from mineral entry as part of the White Vulcan Mine settlement agreement, and 

captures the DLH portion of this proposed project (Haines and Peters 2013: 14). 

Johnson (2013) documents tribal consultation efforts for this project. So far, there haven’t been 

any responses from tribes regarding effects to the TCP from these alternatives. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 479

All existing sites in the project area have the potential to increase the knowledge of human 

activities through various lines of research as well as assist in the interpretation of past human 

activities on the historic use of FWPP area to the public.

All NRHP eligible or unevaluated sites were evaluated for current conditions, research potential 

and tolerance to prescribed fire activities. At this time, 31 sites are managed as eligible or 

unevaluated to the NRHP and have some element that can potentially lead to further research and 

understanding of past human use of the area. Three sites are previously determined Not Eligible 

for inclusion to the National Register of Historic Places (NRHP) and we are recommending five 

sites identified during survey undertaken for the current analysis as Not Eligible to the NRHP. Of 

the thirty-one NRHP eligible or unevaluated sites, we have determined twenty-six sites to be fire 

tolerant (meaning that 26 of the 31 NRHP eligible or unevaluated properties can be burned in a 

light to moderate intensity prescribed fire without adverse effects). The fire intolerant sites consist 

of flammable materials within their boundaries and should be excluded from prescribed fire 

actions. 

Desired Condition

Heritage resources are protected and managed on the Coconino National Forest as mandated by 

the 1966 National Historic Preservation Act, as amended (NHPA), 36 CFR 800, Forest Service 

Manual 2360, American Indian Religious Freedom Act, Archaeological Resource Protection Act 

and the National Environmental Policy Act (NEPA). We also follow the Region 3 First Amended 

Programmatic Agreement Regarding Historic Property Protection and Responsibilities, and the 

Forest Plan, as amended. 

The archaeological resources in the project area have moderate to high levels of both live and 

dead fuels present in and around them. Mechanical thinning and prescribed burning around all 

sites, with burning within fire tolerant sites as well as hand thinning within some sites, could 

assist in reducing the threat of fire damage and associated suppression actions to these resources 

for the next 10-20 years. With expected future maintenance prescribed burning, these sites could 

be protected indefinitely from catastrophic wildfires.

The desired condition for heritage resources within the FWPP is to inventory properties within 

the analysis area, reduce fuel loading in and around all eligible or unevaluated historic properties 

and protect them from adverse effects resulting from project implementation activities, as well as 

risks from catastrophic fire and flooding. This strategy would assist in the preservation of site

integrity, retain integrity of fire sensitive components of sites, and limit the potential for 

emergency fire suppression ground disturbing actions. Such a strategy ensures the future research 

and interpretation potential for these irreplaceable historic resources. 

If additional TCPs are identified through tribal consultation on the Flagstaff Watershed Protection 

Project, all efforts would be made to reduce risk to the integrity of TCPs from catastrophic fire 

and flooding, improve conditions for plant gathering, and improve the health of TCPs, as 

perceived by practitioners. More details on efforts to protect and enhance conditions at TCPs have 

been submitted in a separate report on tribal consultation (Johnson 2013). 

Spatial and Temporal Context for Effects Analysis

We analyzed project activities in both the short and long term for this project. We also considered 

not just heritage sites in the analysis area but also heritage sites immediately adjacent to the 

project area for those that could be affected by proposed activities. Rather than consider the 
Chapter 3: Affected Environment and Environmental Consequences

480 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

effects of the proposal and each action alternative separately, we combined direct, indirect, and 

cumulative effects analysis where appropriate. 

Past, Present, and Foreseeable Activities Relevant to Cumulative Effects 

Analysis

The most closely related project or proposal relative to the Flagstaff Watershed Protection Project 

is the Four Forests Restoration Initiative (4FRI). Although the projects have different aims, the 

associated activities are similar in that fuels would be reduced and prescribed fire would be 

returned to the ecosystem. 

Other nearby projects and activities considered in the cumulative effects for this project include 

the ongoing Wing Mountain Fuels Reduction Project, special use events, the Fort Valley 

motorized trails, recreation use in the Dry Lake Hills area, hunter access and use, dispersed 

recreation, fuel wood gathering, the Mormon Mountain Communications Site, FH3 Tree Clearing 

Project, and future implementation of the Travel Management Rule. We also analyzed cumulative 

effects relative to past nearby projects and events, such as the 2010 Schultz Fire, the 1977 Radio 

Fire, Schultz Reforestation, Schultz Sediment Reduction, Arizona Trail Construction, grazing on 

the Peaks Allotment, past implementation of the Travel Management Rule, the Mormon Lake 

Fuels Reduction Project, thinning around forest communication towers from 2007-2008, and 

grazing on the Tinny Springs and Pickett Lake/Padre Canyon Allotments. 

Environmental Effects

Alternative 1: No Action

Direct & Indirect Effects

Existing fuels in and around archaeological sites would remain as they are and continue to 

increase. No action would result in an increase in fuels and in high intensity wildfires that these 

properties have not been subjected to in the past. This situation would be exacerbated by the 

effects of climate change which include warming temperatures. Sites would be exposed to intense 

heat which would damage artifacts and features. Since the project areas lie within wildland urban 

interface (WUI) areas, an increase in wildfires would lead to an increase in aggressive wildfire 

suppression actions and an increase in the possibility of damage to resources during suppression 

events. More wildfire suppression tactics would also lead to more subsurface artifact and feature 

damage. Fire suppression actions, particularly bulldozer operations, may damage or completely 

destroy surface and subsurface heritage resources resulting in the loss of those resources and their 

associated data. This would affect their eligibility for the National Register of Historic Places 

(NRHP). Catastrophic wildfire in the area may also impact the San Francisco Peaks TCP, altering 

important characteristics of the property. Effects would be short and long term (Deal 1999, 2001, 

and 2012; Jackson 1998; Oster et al, 2012; Rude and Jones 2012; Ryan et al. 2012). 

Over time, fuels would continue to increase in and around archaeological sites, which would keep 

them out of the visibility of public users, a beneficial effect. However, as stated above, increased 

fuels would have a long term negative cumulative effect if a wildfire burned over these sites 

because the sites would burn hotter and longer than expected in a managed, controlled burn 

setting. 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 481

Indirect effects from No Action would be an increase in erosion following a severe and 

catastrophic wildfire. An increase in erosion following a large wildfire would also lead to an 

increase in subsurface artifact and feature damage and a loss of artifact and provenience data. 

Cumulative Effects

Fuel loading in and around project area sites as they are today has the potential to contribute to 

adverse effects on heritage resources from a large-scale wildfire. Effects would occur from 

extensive heat during the wildfire, ground disturbing actions during emergency wildfire 

suppression actions on all sites, and post-fire erosion and flooding (Ryan et al. 2012: 11-14). No 

action would also result in an increase in fuels, catastrophic wildfire, and suppression actions that 

could potentially impact portions of the San Francisco Peaks TCP in the analysis area. These 

areas would also be affected by erosion following a catastrophic wildfire event. No action would 

potentially lead to impacts that would severely damage the significance of the property. 

Alternatives 2, 3 and 4 

Direct & Indirect Effects

Alternatives 2, 3, and 4 are handled collectively as we anticipate direct, indirect, and cumulative 

effects would be very similar. Heritage sites would be avoided by all ground-disturbing activities 

(including traditional ground-based logging equipment as well as cable logging and helicopter 

harvesting on steep slopes), and fire-sensitive sites would be protected from broadcast fire 

activities. In addition, fuels would also be reduced via hand falling within sites, to further 

improve and stabilize them. All activities would have No Adverse Effect to sites. 

Historic properties are highly vulnerable to the effects from authorized and unauthorized project 

activities as well as from the less tangible effects of benign neglect. Relevant issues emerging in 

heritage program management include not just site avoidance, but also the improvement of 

conditions at archaeological sites so that the sites are less vulnerable to the devastating effects of 

large scale wildfire (Haines and Lyndon 2010). 

Recent research analyzing the post-wildfire condition of sites that were previously avoided by 

thinning and prescribed fire activities (Lutes 2014) demonstrates that when sites are avoided and 

their fuels are not managed, these sites burn much hotter than their counterparts where the 

unnatural buildup of on-site fuels has been reduced. The situation is critical on national forests 

such as the Coconino, with a large and complex number of heritage resources. Thus activities 

such as low to moderate broadcast prescribed fire across archaeological sites and hand thinning 

within sites, would have a beneficial effect at individual sites and can help improve watersheds on

a landscape scale. 

Short Term Effects

Sites would not be adversely affected in either the short or long term per protection measures in 

the First Amended Region 3 Programmatic Agreement (PA) (US Forest Service 2003 and 2010). 

Fire intolerant sites will be excluded from prescribed burning and all sites eligible to or 

unevaluated for the NRHP would be avoided by mechanical ground disturbing activities. There 

are some short term effects of the project on heritage sites which may make them more visible 

(through tree cutting in the immediate vicinity) and temporarily reduce their ground cover 

(following broadcast fire). On-site soils should remain stable during and after project activities, 
Chapter 3: Affected Environment and Environmental Consequences

482 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

however, and the loss of ground cover at sites would be minimal and temporary. Additionally, 

ground cover would recover more quickly after a low intensity prescribed fire than after a high 

intensity wildfire, making the re-introduction of fire on the landscape under low to moderate 

conditions highly desirable for resource management. There could be an increase in visibility and 

possibly vandalism resulting from loss of ground cover can be mitigated through archaeological 

monitoring, public education, and law enforcement patrols. 

There is a possibility of increased visibility and/or vandalism issue for archaeological properties 

if the project is implemented, especially in areas with high overlapping recreational use, as in the 

DLH area. Much of the project area is used by local residents for recreation and the reduction of 

ground cover through thinning and burning has the potential to increase site visibility and 

vandalism issues. This situation can be mitigated through the measures previously identified.

Long term Effects

The long term benefit to sites from fuels reduction far outweighs any short term effects, as longterm adverse effects to heritage sites from large-scale wildfire can be extreme (Deal 1999, 2001, 

and 2012; Jackson 1998; Oster et al, 2012; Rude and Jones 2012; Ryan et al. 2012). Prescribed 

broadcast burning within fire tolerant archaeological sites would improve long term conditions at 

those sites as managers return fire to the ponderosa pine forests in the analysis areas. The return 

of fire to the landscape in order to reduce on-site fuels would reduce potential impacts to sites 

from climate change, such as rising temperatures and an increase in catastrophic wildfires on the 

landscape. 

Project activities authorized by the proposal and action alternatives would be designed to have No 

Adverse Effect and even improve the long term condition at heritage sites in the analysis area. 

This is due to the reduction of fuels at heritage sites and a decrease in likelihood that they would 

be adversely affected by extensive heat damage during a high intensity wildfire, or significantly 

affected by wildfire suppression tactics or post-fire flooding after project implementation. 

If the proposal or any action alternatives are implemented, there would be fewer emergency fire 

suppression activities and the potential for ground disturbing activities like bulldozer fire-line 

construction would be reduced in the future. This would lead to greater protection of National 

Register eligible heritage resources per the 1966 National Historic Preservation Act as amended, 

the Region 3 Programmatic Agreement, and the 1987 Coconino National Forest Plan. In addition, 

Erosion from high intensity fire through soil sterilization and complete loss of ground cover 

would be reduced through selective thinning and low intensity burning that would leave large 

portions of the existing ground cover intact. 

Cumulative Effects

Since many of the 4FRI project areas are near to FWPP project areas, those fuels reduction and 

landscape restoration activities would have a beneficial long term effect to archaeological sites, 

which would contribute to better overall forest health and archaeological sites that are less 

susceptible to the direct and indirect effects of large-scale wildfire. This project and 4FRI fuels 

reduction may also have a beneficial effect on springs in the San Francisco Mountain TCP, as has 

been demonstrated through collaborative forest restoration on the nearby Kaibab National Forest

(Weintraub et al. 2013) which has enhanced and improved tradition locales for tribal members. 

Cumulative effects from the action alternatives are anticipated to be minimal and can be reduced 

and/or mitigated through appropriate actions for this and other fuels reduction and watershed 
Chapter 3: Affected Environment and Environmental Consequences

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 483

protection projects on the forest. There would be no change in the current status or treatment of 

archaeological sites resulting from the project. If the action alternatives are implemented, there 

would be a reduced need for emergency suppression actions, and in the unlikely event that 

suppression actions are necessary, they would be minimal after treatment. 

Cumulative Effects Summary

All forest authorized activities, including but not limited to recreation use, grazing, and fuels 

reduction projects, are designed to have No Effect or No Adverse Effect to heritage sites. The 

action alternatives, when considered together with current and past projects, as well activities that 

will take place in the reasonably foreseeable future, would also have No Adverse Effect to sites. 

Sites unevaluated to or eligible for the NRHP would be avoided by all ground-disturbing 

activities, and would be enhanced through the application of broadcast prescribed fire, if they are 

not fire sensitive per the Region 3 PA (US Forest Service 2003). 

As the action alternatives are designed to improve conditions at archaeological sites through the 

reduction of fuels, they would have a beneficial effect to the condition and long-term stewardship 

of heritage sites. Thus, the cumulative effect of this project, even relative to activities that are not 

authorized by the forest, such as the 1977 Radio Fire and future wildfires, would be to 

significantly improve the condition of sites. 

Effects of the Forest Plan Amendments Proposed for Alternatives 2, 3 and 4

An analysis of the two proposed forest plan amendments was also completed. Proposed 

amendments include an amendment to use the revised Mexican Spotted Owl (MSO) recovery 

plan direction and one to remove the restriction of only using mechanical equipment on slopes 

less than 40 percent. The MSO amendment doesn’t have the potential to affect heritage sites. The 

amendment removing the 40 percent slope restriction for mechanical equipment will have No 

Adverse Effect to sites due to the extremely low potential for encountering archaeological 

resources in these locales. This is justified by current management direction in the Region 3 PA 

(2003) where heritage surveys are not required over 40 percent, owing to the low likelihood of 

sites. 
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 484
Chapter 4: Consultation and Coordination

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 485

Chapter 4. Consultation and Coordination

Preparers and Contributors 

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes 

and non-Forest Service persons during the development of this environmental assessment:

ID Team Members:

CORE MEMBERS RESPONSIBILITIES

Erin Phelps Project Manager & NEPA

Paul Summerfelt City of Flagstaff Representative

Beale Monday Fire/Fuels 

Tom Runyon Soils/Hydrology

Andy Stevenson Silviculture

Cary Thompson Wildlife

Debbie Crisp Threatened & Endangered Plant Species 

Jeremy Haines Heritage

Joe Luttman Timber/Economics

Frank Thomas GIS

Charlotte Minor Landscape Architect

Bob Rich Timber/Harvesting Methods/Economics

Mike Bathen Engineering

Julia Camp Invasive and Noxious Weeds

Brian Poturalski Recreation/Social

Craig Johnson Tribal Outreach and Consultation

CONSULTING MEMBERS RESPONSIBILITIES

Mary Lata Fire/Fuels Modeling

Wes Hall Fire/Fuels Modeling

Bill Elliot Soil Erosion/Hydrologic Modeling

Mandy Roesch Range

Brienne Magee Public Affairs

Judy Adams Lands Dept.

Jeanne Schofer Heritage Support

Mike Dechter NEPA Support

FEDERAL, STATE, AND LOCAL AGENCIES

The City of Flagstaff Coconino County Board of Supervisors

Flagstaff City Council Flagstaff Chamber of Commerce

United States Fish and Wildlife Service Arizona Game and Fish Department

United States Geological Survey

TRIBES

Fort McDowell Yavapai Nation

Havasupai Tribe

Hopi Tribe

Hualapai Tribe

Navajo Nation

Pueblo of Acoma

Pueblo of Zuni

San Carlos Apache Tribe
Chapter 4: Consultation and Coordination

486 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

San Juan Southern Paiute Tribe

Tonto Apache Tribe

White Mountain Apache Tribe.

Yavapai-Apache Nation

Yavapai-Prescott Tribe

ORGANIZATIONS

Rocky Mountain Research Station

Northern Arizona University

NAU Ecological Restoration Institute

Greater Flagstaff Forests Partnership

Center for Biological Diversity

Arizona Trail Association

Flagstaff Biking Organization

Grand Canyon Trust

Friend of Northern Arizona Forests

Wildearth Guardians

The Nature Conservancy

Sierra Club – Grand Canyon Chapter

NRCS
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 485

Chapter 5. References

References commonly used throughout multiple resource areas are listed first, followed by 

references cited by individual areas.

General

USDA Forest Service, Coconino National Forest. 1987 (as amended). Coconino National Forest 

Land and Resource Management Plan. Southwestern Region. Albuquerque, NM. 270pp.

USDA Forest Service. 2010. Southwestern Region Climate Change Trends and Forest Planning, 

A Guide for Addressing Climate Change in Forest Plan Revisions for Southwestern 

National Forests and National Grasslands. Southwestern Region. Albuquerque, NM. 

45pp.

Fire, Fuels & Air Quality

Cram, D.; Baker, T; Boren J. 2006. Wildland fire effects in silviculturally treated vs. untreated 

stands of New Mexico and Arizona. Research Paper RMRS-RP-55. Fort Collins. CO: 

U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 28 p.

Dickson, B. G. and B. R. Noon. 2006. Prescribed fire strategies to restore wildlife habitat in 

pondrosa pine forests of the intermountain West. USDA Forest Service, RMRS and 

Colorado State University, Final Report 03JV-11221607-116, 14 p. 

Dickson, Brett G., et al. 2006. Mapping the probabiily of large fire occurrence in northern 

Arizona, USA. Landscape Ecology 21.5: 747-761.

Fulé, P. Z, Crouse, J. E., Roccaforte, J. P., L. Kalies. 2012. Do thinning and/or burning treatments 

in western USA ponderosa or Jeffrey pine-dominated forests help restore natural fire 

behavior? Forest Ecology and Management 269:68-81.

Graham, R.T. et. al. 1999. The Effects of Thinning and Similar Stand Treatments on Fire 

Behavior in Western Forests. Gen. Tech. Rep. PNW-GTR-463. Portland, OR: U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Research Station. 27 p.

Havlina et al. 2010. Interagency Fire Regime Condition Class website. USDA Forest Service, 

USDA Department of the Interior, and The Nature Conservancy [www.frcc.gov].

Kalies. E. L., Chambers, C. L., and W. W. Covington. 2010. Wildlife responses to thinning and 

burning treatments in southwestern conifer forests: A meta-analysis. Forest Ecology and 

Management 259: 333-342.

LANDFIRE: LANDFIRE 1.1.0. Fire Regime Groups. [Homepage of the Landfire Project, U.S. 

Department of Agriculture, Forest Service; U.S. Department of the Interior], [Online]. 

Available: http://www.landfire.gov/ NationalProductDescriptions10.php [ 2011, 

December 20].
Chapter 5: References

486 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Litschert, Sandra E., Thomas C. Brown, David M.. Theobald. 2012. Historic and future extent of 

wildfires in the Southern Rockies Ecoregion, USA. Forest Ecology and Management 

269: 124-133.

Marlon, J.R., P.J. Bartlein, M.K. Walsh, S.P. Harrison, K.J. Brown, M.E. Edwards, P.E. Higuera, 

et al. 2009. Wildfire responses to abrupt climate change in Northern America. 

Proceedings of the National Academy of Sciences, 106, no. 8:2519-2524. 

Miller, C.I.; N.L. Stephenson; and S.L. Stephens. 2007. Climate Change and Forests of the 

Future: Managing in the Face of Uncertainty. Ecological Applications, 17(8): 2145-2151.

Savage, Melissa, and Joy Nystrom Mast. 2005. How resilient are southwestern ponderosa pine 

forests after crown fires? Canadian Journal of Forest Research, 35.4: 967-977. 

Scott , J.H. and R.E. Burgan. 2005. Standard Fire Behavior Fuel Models: A Comprehensive Set 

for Use with Rothermel’s Surface Fire Spread Model. Gen. Tech. Rep. RMRS-GTR-153. 

Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Research Station. 72 p.

Shepperd, W. D., Asherin, L. A. and C. B. Edminster. 2001. Using individual tree selection 

silviculture to restore Northern goshawk habitat: lessons from a Southwestern study. 

USDA Forest Service, Pacific Northwest Research Station, PNW-GTR-546, 10p.

Stoddard, M. T., McGlone, C. M., Fulé, P. Z., Laughlin, D. C. and M. L. Daniels. 2011. Native 

plants dominate understory vegetation following ponderosa pine forest restoration 

treatments. Western North American Naturalist 71 (2): 206-214.

Westerling, Anthony L. et al. 2006. Warming and earlier spring increase western US forest 

wildfire activity. Science 313.5789: 940-943.

Williams, Jerry. 2013. Exploring the onset of high-impact mega-fires through a forest land 

management prism. Forest Ecology and Management, 294:4-10. 

Youngblood, Andrew. 2009. Thinning and Burning in Dry Coniferous Forests of the Western 

United States: Effectiveness in Altering Diameter Distributions. Forest Science 56(1).

Forest Structure & Health

Abella, Scott R. 2008. Managing Gambel oak in southwestern ponderosa pine forests: the status 

of our knowledge. Gen. Tech. Rep. RMRS-GTR-218. Fort Collins, CO: U.S. Department 

of Agriculture, Forest Service, Rocky Mountain Research Station. 27 p.

Abella, S.R.; Denton, C.W. 2009. Spatial variation in reference conditions: Historical tree density 

and pattern on a Pinus ponderosa landscape. Canadian Journal of Forestry 39:2391-2403.

Abella, S.R.; Denton, C.W.; Brewer, D.G.; Robbie, W.A.; Steinke, R.W.; Covington, W.W. 2011. 

Using a terrestrial ecosystem survey to estimate the historical density of ponderosa pine 

trees. Research Note RMRS-RN-45. USDA Forest Service, Rocky Mountain Research 

Station, Fort Collins, CO. 9 pp.

Allen, S.R.; Savage, M.; Falk, D.A.; Suckling, K.F.; Swetnam, T.W.; Shulke, T.; Stacey, P.B.; 

Morgan, P.; Hoffman, M.T.; Klingel, J.T. 2002. Ecological restoration of southwestern 
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 487

ponderosa pine ecosystems: A broad perspective. Ecological Applications 12(5):1418-

1433.

Breece, C.R., Kolb, T.E., Dickson, B.G., McMillin, J.D., Clancy, K.M. 2007. Prescribed fire 

effects on bark beetle activity and tree mortality in southwestern ponderosa pine forest. 

Forest Ecology and Management. 255 (2008) 119-128.

Brown, P.M.; Kaye, M.W.; Huckaby, L.; Baisan, C. 2001. Fire history along environmental 

gradients in the Sacramento Mountains, New Mexico: Influences of local patterns and 

regional processes. Ecoscience 8:115-126.

Calder, W. John, Kevin J. Horn, and Samuel B. St Clair. 2011. "Conifer expansion reduces the 

competitive ability and herbivore defense of aspen by modifying light environment and 

soil chemistry." Tree physiology 31.6: 582-591.

Chojnacky, D.C., B.J. Bentz, and J.A. Logan. 2000. Mountain pine beetle attack in ponderosa 

pine: comparing methods for rating susceptibility. USDA Forest Service Research Paper, 

RMRS-RP-26, 10 pp.

Cocke A.E., Fule P.Z., Crouse J.E., 2005. Forest change on a steep mountain gradient after 

extended fire exclusion: San Francisco Peaks, Arizona, USA. Journal of Applied Ecology 

42, 814-823. 

Conklin, D.A., Fairweather, M.L. 2010. Dwarf Mistletoe Management and their Management in 

the Southwest. USDA Forest Service. Southwestern Region.

Conklin, D. A., & Geils, B. W. 2008. Survival and sanitation of dwarf mistletoe-infected 

ponderosa pine following prescribed underburning. Western journal of applied forestry, 

23(4), 216-222.

Cooper, C.F. 1960. Changes in vegetation, structure, and growth of southwestern pine forests 

since white settlement. Ecological Monographs 30:129-164.

Covington, W.W.; Moore, M.M. 1994a. Postsettlement changes in natural fire regimes and forest 

structure: Ecological restoration of old-growth ponderosa pine forests. Journal of 

Sustainable Forestry 2(1/2):153-181.

Covington W.W., Moore M.M. 1994b. Southwestern ponderosa pine structure: changes since 

Euro-American settlement. Journal of Forestry 92: 39-47.

Covington, W. W., Fule, P. Z., Moore, M. M., Hart, S. C., Kolb, T. E., Mast, J. N., Sackett, S. S., 

and M. R. Wagner. 1997. Restoring ecosystem health in ponderosa pine forests of the 

southwest. Journal of Forestry, 94 (4): 23-29.

Das, A., Battles, J., Stephenson, N. L., & van Mantgem, P. J. 2011. The contribution of 

competition to tree mortality in old-growth coniferous forests. Forest ecology and 

management, 261(7), 1203-1213.

DeMars, C.J., and B.H. Roettgering. 1982. Western pine beetle. USDA Forest Service Forest 

Insect & Disease Leaflet 1. 8 p.

Davis, Liane R.; Puettmann, Klaus J.; Tucker, Gabriel F. 2007. Overstory Response to 

Alternative Thinning Treatments in Young Douglas-fir Forests of Western Oregon. 

Northwest Science. 81(1): 1-14.
Chapter 5: References

488 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Dixon, Gary E. comp. 2002. Essential FVS: A user’s guide to the Forest Vegetation Simulator. 

Internal Rep. Fort Collins, CO: U. S. Department of Agriculture, Forest Service, Forest 

Management Service Center. 240p. (Revised: November 24, 2010)

Ehle, D.S.; Baker, W.L. 2003. Disturbance and stand dynamics in ponderosa pine forests in 

Rocky Mountain National Park, USA. Ecological Monographs 73:543-566

Evans, A.M., R. G. Everett; S.L. Stephens, J.A. Youtz. 2011. Comprehensive fuels treatment 

practices guide for mixed conifer forests: California, Central and Southern rockies, and 

the Southwest. USDA, Forest Service, Southwestern Region and The Forest Guild, 

Albuquerque, NM. 106 pp. 

Fairweather, M., Geils, B., and Manthei, M. 2008 Aspen Decline on the Coconino National 

Forest. In: McWilliams, M. G. comp 2008. Proceedings of the 55th Western 

International Forest Disease Work Conference; 2007 October 15-19; Sedona, AZ. Salem, 

OR; Oregon Department of Forestry.

Fiedler, C.E.; Arno, S.F.; Harrington, M.G. 1996. Flexible silvicultural and prescribed burning 

approaches for improving health of ponderosa pine forests. Pp 69-74 in Covington, W.W.; 

Wagner, P.K. (eds.). Conference on adaptive ecosystem restoration and management: 

Restoration of Cordilleran conifer landscapes of North America. General Technical 

Report RM-GTR-278. USDA Forest Service, Rocky Mountain Forest and Range 

Experiment Station, Fort Collins, CO.

Friederici, P. 2004. Establishing reference condition for southwestern ponderosa pine forest. 

Working papers in southwestern ponderosa pine forest restoration. Ecological Restoration 

Institute. Flagstaff, AZ. 16 p.

Frinkral, A.J.; Evans, A.M. 2008. Effects of thinning treatment on carbon stocks in a northern 

Arizona ponderosa pine forest. Forest Ecology and Management 255:2743-2750.

Fulé, P.Z.; Covington, W.W.; Moore, M.M. 1997. Determining reference conditions for ecosystem 

management of southwestern ponderosa pine forests. Ecological Applications 7:895–908.

Fulé, P.Z.; Crouse, J.E.; Heinlein, T.A.; Moore, M.M.; Covington, W.W.; Vankamp, G. 2003. 

Mixed-severity fire regime in high-elevation forest of the Grand Canyon, Arizona, USA. 

Landscape Ecology 18:465-486.

Fule, P.Z., Covington, W.W., Stoddard, M.T., Bertolette, D., 2006 “Minimal-Impact” Restoration 

Treatments Have Limited Effects on Forest Structure and Fuels at Grand Canyon, USA. 

Restoration Ecology Vol. 14, No. 3, pp.357-368

Ganey J.L, and Vojta S.C. 2011. Tree mortality in in drought-stressed mixed-conifer and 

ponderosa pine forests, Arizona, USA. Forest Ecology and Management 261 (2011) 162–

168

Gill, S.; Biging, G.S.; Murphy, E.C. 2000. Modeling conifer tree crown radius and estimating 

canopy cover. Forest Ecology and Management 126:405-416.

Grady, Kevin C. and Stephen C. Hart. 2006. Influences of thinning, prescribed burning, and 

wildfire on soil processes and properties in southwestern ponderosa pine forests: A 

retrospective study. Forest Ecology and Management Vol. 234. pp. 123-135.
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 489

Hayes, C. J., Fettig, C. J., & Merrill, L. D. 2009. Evaluation of multiple funnel traps and stand 

characteristics for estimating western pine beetle-caused tree mortality. Journal of 

economic entomology, 102(6), 2170-2182.

Heinlein, T. A., Moore M. M., Fule F. Z., and W. W. Covington, 2005. Fire history and stand 

structure of two ponderosa pine-mixed conifer sites: San Francisco Peaks, Arizona, USA. 

International Journal of Wildland Fire, 14: 307-320 

Hoffman, C., Mathiasen, R., & Sieg, C. H. 2007. Dwarf mistletoe effects on fuel loadings in 

ponderosa pine forests in northern Arizona. Canadian journal of forest research, 37(3), 

662-670.

Hurteau, M. and M. North. 2009. Fuel treatment effects on tree-based carbon storage under 

modeled wildfire scenarios. Frontiers in Ecology and the Environment, 7:409–414.

Hurteau, M. D., M. T. Stoddard, and P. Z. Fule. 2011. The carbon costs of mitigating highseverity wildfire in southwestern ponderosa pine. Global Change Biology, 17:1516–1521.

Kaye, M.W.; Swetnam, T.W. 1999. An assessment of fire, climate, and Apache history in the 

Sacramento Mountains, New Mexico, USA. Physical Geography 20:305-330.

Kenaley S.C., Mathiasen R.L., Daugherty C.M. 2006. Selection of dwarf mistletoe-infected 

ponderosa pines by Ips species (Coleoptera: Scolytidae) in northern Arizona. Western 

North American Naturalist 66(3): 279-284.

Kenaley S.C., R.L., Mathiasen, and E.J. Harner. 2008. Mortality Associated with a Bark Beetle 

Outbreak in dwarf mistletoe-infested ponderosa pine stands in Arizona. Western Journal 

of Applied Forestry 23: 113 - 120.

Keyser, Chad E.; Dixon, Gary E., comps. 2008 (revised February 3, 2010). Central Rockies (CR) 

Variant Overview – Forest Vegetation Simulator. Internal Rep. Fort Collins, CO: U. S. 

Department of Agriculture, Forest Service, Forest Management Service Center. 66p.

Kolb, T.E., Agee, J.K., Fule, P.Z., McDowell, N.G., Pearson, K., Sala, A., Waring, R.H. 2007. 

Perpetuating old ponderosa pine. Forest Ecology and Management, 249 (2007) 141-157.

Korb, J. E., Fule, P. Z., Stoddard M. T. 2012. Forest restoration in a surface fire-dependent 

ecosystem: an example from a mixed conifer forest, southwestern Colorado, USA. 

Unpublished. 

Laughlin, D.C.; Moore, M.M.; Bakker, J.D.; Casey, C.A.; Springer, J.D.; Fulé, P.Z.; Covington, 

W.W. 2006. Assessing targets for the restoration of herbaceous vegetation in ponderosa 

pine forests. Restoration Ecology 14:548-560.

Lezberg, Ann L.; Battaglia, Michael A.; Sheppard, Wayne D.; Schoettle, Anna W. 2008. 

Decades-old silvicultural treatments influence surface wildfire severity and post-fire 

nitrogen availability in a ponderosa pine forest. Forest Ecology and Management, 255: 

49-61 pps.

Long, J.N. and F.W. Smith. 1984. Relation between size and density in developing stands: a 

description and possible mechanism. For. Ecol. And Management 7:191-206.
Chapter 5: References

490 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Long, J.N., 1985 A Practical Approach to Density Management. Forestry Chronicle. February, pp 

23-27

Long, J. 2003. Disturbance Ecology. Continuing Education in Ecosystem Management for the 

Central and Southern Rockies and Great Basin. October 27 – November 7, 2003. Utah 

State University, Logan, Utah.

Long, J. N. and F. W. Smith. 2000. Restructuring the Forest. Goshawks and the restoration of 

southwestern ponderosa pine. Journal of Forestry, 98 (8): 25-30. 

Long, J.N. and T.W. Daniel. 1990. Assessment of growing stock in uneven-aged stands. Western 

Journal of Applied Forestry. 5:93-96.

Munson, S. and Anhold, J. 1995. Site risk ratting for mountain pine beetle in ponderosa pine. 

Unpublished paper on file at USDA Forest Service Intermountain Region State and 

Private Forestry, Forest Health Protection, Ogden UT, 1 p.

Manion, P.D. (1991). Tree Disease Concepts. 2nd ed. Prentice-Hall: New Jersey

Margolis, Ellis Q., Thomas W. Swetnam, and Craig D. Allen. 2011. Historical stand-replacing fire 

in upper montane forest of the Madrean Sky Islands and the Mogollon Plateau, 

Southwestern USA. Fire Ecology 7.3. 

Mast, J.N.; Fulé, P.Z.; Moore, M.M.; Covington, W.W.; Waltz, A.E.M. 1999. Restoration of 

presettlement age structure of an Arizona ponderosa pine forest. Ecological Applications 

9:228-239.

Mast, J.N.; Veblen, T.T.; Linhart, Y.B. 1998. Disturbance and climatic influences on age structure 

of ponderosa pine at the pine/grassland ecotone, Colorado Front Range. Journal of 

Biogeography 25:743-767.

McCusker N., 2012. Four-Forest Restoration Initiative Coconino and Kaibab National Forests 

Silviculture Specialist Report. USDA Forest Service.

McMillin J.D., 2008. Stand hazard rating for bark beetles attacking southwestern ponderosa pine. 

USDA Forest Service, Rocky Mountain Research Station. Unpublished.

McMillin, Joel D. et al. 2011. Draft hazard rating for Ips beetles during drought in Arizona. 

Unpublished paper on file at: U.S. Department of Agriculture, Forest Service, 

Southwestern Region, State and Private Forestry, Forest Health Protection, Flagstaff, AZ. 

1 p.

Menzel, J.P.; Covington, W.W. 1997. Changes from 1876 to 1994 in a forest ecosystem near 

Walnut Canyon, northern Arizona. Pp 151-172 in van Riper III, C.; Deshler, E.T. (eds.). 

Proceedings of the Third Biennial Conference of Research on the Colorado Plateau. 

Transactions and Proceedings Series NPS/NRNAU/NRTP-97/12. Dept. of the Interior, 

National Park Service. 256 pp.

Moir, W.H. 1966. Influence of ponderosa pine on herbaceous vegetation. Ecology 47:1045-1048.

Moir, W. H., Geils, B., Benoit, M. A., and D. Scurlock. 1997. Ecology of Southwestern 

Ponderosa Pine Forests. Pages 3-27 in Block, W. M. and D. M. Finch, tech. ed. Songbird 

ecology in southwestern ponderosa pine forests: a literature review. Gen. Tech. Rep. 
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 491

RM-GTR-292. Fort Collins, CO: USDA Forest Service, Rocky Mountain Forest and 

Range Experiment Station. 152 pp

Moore, M.M.; Huffman, D.W.; Fulé, P.Z.; Covington, W.W.; Crouse, J.E. 2004. Comparison of 

historical and contemporary forest structure and composition on permanent plots in 

southwestern ponderosa pine forests. Forest Science 50:62-176.

Naumburg, E.; DeWald, L.E. 1999. Relationships between Pinus ponderosa forest structure, light 

characteristics, and understory graminoid species presence and abundance. Forest 

Ecology and Management 124:205-215

Negrón, J.F., J.L Wilson, and J.A. Anhold. 2000. Stand conditions associated with roundheaded 

pine beetle (Coleoptera: Scolytidae) infestations in Arizona and Utah. Environmental 

Entomology 29: 20-27.

Negron, J.F., McMillin J.D., Anhold J.A., Coulson, D. 2009. Bark beetle-caused mortality in a 

drought-affected ponderosa pine landscape in Arizona, USA. Forest Ecology and 

Management. 257 (2009) 1353-1362.

Pearson, G.A. 1950. Management of ponderosa pine in the Southwest: As developed by research 

and experimental practice. Agriculture Monograph No. 6. USDA Forest Service, Fort 

Collins, CO. 34 pp.

Reineke, L. H. 1933. Perfecting a stand density index for even-aged forests. Journal of 

Agricultural Research 46(7):627-638.

Reynolds, R.T., A.J. Sanchez Meador, J.A. Youtz, T. Nicolet, M.S. Matonis, P.L. Jackson, D.G. 

DeLorenzo, A.D. Graves. 2013. Restoring Composition and Structure in Southwestern 

Frequent-Fire Forests: A science-based framework for improving ecosystem resiliency. 

Gen. Tech. Rep. RMRS-GTR-310. Fort Collins, CO: USDA Forest Service, Rocky 

Mountain Research Station. 76 p. 

Reynolds, R. T., Graham, R. T., Reiser, M. H., Bassett, R. L., Kennedy, P. L., Boyce, D. A., 

Goodwin, G., Smith, R., and E. L. Fisher. 1992. Management recommendations for the 

northern goshawk in the southwestern United States. Gen. Tech. Rep. RM-217. Ft. 

Collins, CO: USDA Forest Service, Rocky Mountain Forest and Range Experiment 

Station. 90 pp.

Ritchie, M. W., Wing, B. M., & Hamilton, T. A. 2008. Stability of the large tree component in 

treated and untreated late-seral interior ponderosa pine stands This article is one of a 

selection of papers from the Special Forum on Ecological Studies in Interior Ponderosa 

Pine-First Findings from Blacks Mountain Interdisciplinary Research. Canadian journal 

of forest research, 38(5), 919-923

Romme, W.H., M.L. Floyd, D. Hanna. 2009. Historical range of variability and current landscape 

condition analysis: South Central Highlands Section, Southwestern Colorado & 

Northwestern New Mexico. Colorado State University, Colorado Forest Restoration 

Institute, Fort Collins, CO and USDA Forest Service, Rocky Mountain Region, Golden, 

CO. 

Sánchez Meador, A.J.; Parysow, P.F.; Moore, M.M. 2010. Historical stem-mapped permanent 

plots increase precision of reconstructed reference data in ponderosa pine forests of 

northern Arizona. Restoration Ecology 18:224-234.
Chapter 5: References

492 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Schmid, J.M., and S.A. Mata. 1992. Stand density and mountain pine beetle-caused mortality in 

ponderosa pine stands. USDA Forest Service Research Note, RM-515.

Schmid, J.M., S.A. Mata, R.A. Obedzinski. 1994. Stand hazard rating ponderosa pine stands for 

mountain pine beetles in the Black Hills. USDA Forest Service Research Note, RM-529.

Schubert, Gilbert H. 1974. Silviculture of southwestern ponderosa pine: The status of our 

knowledge. Res. Paper RM-123. Fort Collins, CO: U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Forest and Range Experiment Station. 71 p.

Shepperd, W. D., Asherin, L. A., and Edminister, C. B. 2002. Using individual tree selection 

silviculture to restore northern goshawk habitat: Lessons from a southwestern study. 

Beyond 2001: A Silvicultural Odyssey to Sustaining Terrestrial and Aquatic Ecosystems. 

Proceedings from the 2001 National Silviculture Workshop, May 6 – 10, 2002, Hood 

River, Oregon. PNW-GTR-546. 

Smith, E. 2006. Historical range of variation and state and transition modeling of historical and 

current landscape conditions for mixed conifer of the southwestern U.S. Prepared for the 

USDA Forest Service, Southwestern Region by The Nature Conservancy, Tucson, AZ. 

31 p. 

Society of American Foresters. 1998. The dictionary of forestry. Bethesda, MD: 210 pp.

Society of American Foresters (SAF). 2005. Use of silviculture to achieve and maintain forest 

health on public lands. Position Statement Available at: 

http://www.safnet.org/policyandpress/psst/silviculture.pdf

Swetnam, T.W.; Baisan, C.H. 1996. Historical fire regime patterns in the southwestern United 

States since AD 1700. Pp 11-32 in Allen, C.D. (ed.). 2nd La Mesa Fire Symposium; Los 

Alamos, NM. General Technical Report RM-GTR-286. USDA Forest Service, Rocky 

Mountain Forest and Range Experiment Station, Fort Collins, CO. 216 pp.

USDA Forest Service. 1950’s. Coconino National Forest Land Historic Timber Atlas. 

Southwestern Region. (This is an unpublished document).

USDA Forest Service. 1996. Coconino National Forest Land and Resource Management Plan. 

Southwestern Region.

USDA Forest Service, 1992. Rocky Mountain Resource Information System Oracle User Guide. 

Southwestern Region.

USDA Forest Service. 1997. Plant associations of Arizona and New Mexico. 3rd ed. Vol. 1. 

USDA Forest Service, Southwestern Region, Albuquerque, NM. 291 pp.

USDA Forest Service, 2004. Forest Restoration and Fuels Reduction Thinning in the Southwest. 

Presented at the Regional Silviculture Workshop, Southwestern Region, June 17, 2004.

USDA Forest Service. 2008. Forest insect and disease conditions in the Southwestern Region, 

2007. USDA Forest Service, Southwestern Region, Forestry and Forest Health, PR-R3-

16-4, 47 p. Albuquerque, New Mexico.

USDA Forest Service. 2011. Forest insect and disease conditions in the Southwestern Region, 

2010. USDA Forest Service, Southwestern Region, Forestry and Forest Health, PR-R3-

16-7, 45 p. Albuquerque, New Mexico.
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 493

Vandendriesche, Don, comp. 2010. A compendium of NFS regional vegetation classification 

algorithms. Internal Rep. Fort Collins, CO: U. S. Department of Agriculture, Forest 

Service, Forest Management Service Center. 74p.

Wallin, K. F., Kolb, T. E., Skov, K. R., & Wagner, M. 2008. Forest management treatments, tree 

resistance, and bark beetle resource utilization in ponderosa pine forests of northern 

Arizona. Forest ecology and management, 255(8), 3263-3269.

Weaver, H. 1951. Fire as an ecological factor in southwestern ponderosa pine forests. Journal of 

Forestry 49:93-98.

Westerling, A. L.; Hidlago, H.G.; Cayan, D.R.; Swetnam, T.W. 2006. Warming and earlier spring 

increase western U.S. forest wildfire activity. Science. Vol. 313: 940-943.

White, A.S. 1985. Presettlement regeneration patterns in a Southwestern ponderosa pine stand. 

Ecology 66:589-594.

Wisdom, M.J., and Bate, L.J. 2008. Snag density varies with intensity of timber harvest and 

human access. For. Ecol. Manage. 255: 2085–2093.

Woolsey T.S. Jr. 1911. Western yellow pine in Arizona and New Mexico. USDA Forest Service, 

Bulletin 101. Washington, DC.

Zegler, T. J., Moore, M. M., Fairweather, M. L., Ireland, K. B., & Fulé, P. Z. 2012. Populus 

tremuloides mortality near the southwestern edge of its range. Forest Ecology and 

Management, 282, 196-207.

Soil & Water Resources

Arizona Department of Environmental Quality. 2012. 2010 Status of Water Quality Arizona’s 

Integrated 305(b) Assessment and 303(d) Listing Report, Publication Number EQR– 12-01

Arizona Department of Environmental Quality. 2008. Intergovernmental agreement between the 

State of Arizona and US Department of Agriculture, Forest Service Southwestern Region. 

February 15, 2008.

Berg, N.H.; Azuma, D.L. 2010. Bare soil and rill formation following wildfires, fuel reduction 

treatments, and pine plantations in the southern Sierra Nevada, California, USA. International 

Journal of Wildland Fire 19, 478-489.

Cooper, C. F. 1961. Controlled burning and watershed condition in the White Mountains of 

Arizona. Journal of Forestry Volume 59, No. 6. pp 438-442.

Covington, W.W., DeBano, L.F., 1990. Effects of fire on pinyon–juniper soils. In: Krammes, J.S. 

(Technical Coordinator), Effects of Fire Management of Southwestern Natural Resources. 

USDA For. Serv. Gen. Tech. Re RM-191, pp. 78–86.

Covington, W. W., P. Z. Fule, M. M. Moore, S. C. Hart, T. E. Kolb, J. N. Mast, S. S. Sackett, and 

M. R. Wagner. 1997. Restoring ecosystem health in ponderosa pine forests of the Southwest. 

Journal of Forestry 95:23-29.
Chapter 5: References

494 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Cram, D.S., T.T. Baker, A.G. Fernald, A. Madrid, and B. Rummer. 2007. Mechanical thinning 

impacts on runoff, infiltration, and sediment yield following fuel reduction treatments in a 

southwestern dry mixed conifer forest. Journal of Soil and Water Conservation, Vol. 62, No. 

5, pp. 359-366. 

Elliot, W.J., Miller, I.S., Audin, L. Eds. 2010. Cumulative watershed effects of fuel management 

in the western United States. Gen. Tech. Rep. RMRS-GTR-231. Fort Collins, CO: U.S. 

Department of Agriculture, Forest Service, Rocky Mountain Research Station. 299 p.

Elliot, W.E.; Foltz, R.B.; Robichaud, P.R. 2009. Recent findings related to measuring and 

modeling forest road erosion. In Anderssen, R.S.; Braddock, R.D.; Newham, L.T.H., eds. 

Proceedings of the 18th World IMACS / MODSIM Congress, Cairns, Australia, 13-17 July 

2009. International Congress on Modelling and Simulation. Interfacing Modelling and 

Simulation with Mathematical and Computational Sciences.

Elliot, William; Robichaud, Pete. 2005. Evaluating sedimentation risks associated with fuel 

management. Fuels planning: science synthesis and integration; environmental consequences 

fact sheet 8. Res. Note RMRS-RN-23-08-WWW. Fort Collins, CO: U.S. Department of 

Agriculture, Rocky Mountain Research Station. 2 p.

Elliot, W.J.; Robichaud, P.R. 2001. Comparing Erosion Risks from Forest Operations to 

Wildfire. In: Peter Schiess and Finn Krogstad, editors, Proceedings of The International 

Mountain Logging and 11th Pacific Northwest Skyline Symposium: 2001 - A Forest 

Engineering Odyssey. Seattle, WA: College of Forest Resources, University of Washington 

and International Union of Forestry Research Organizations. 78-89. Presented at The 

International Mountain Logging and 11th Pacific Northwest Skyline Symposium 2001,

December 10-12, 2001, Seattle, WA

Elliot, W.J.; Page-Dumroese, D.; Robichaud, P.R. 1999. The effects of forest management on 

erosion and soil productivity. Chapter 12 in Lal, R., ed., Soil Quality and Soil Erosion. Boca 

Raton, FL: CRC Press. 195-208.

Hann, W.; Shlisky, A.; Havlina, D., et al. 2004. Interagency fire regime condition class 

guidebook. Version 3.0, September 2010 available at http://www.frcc.gov.

Hill, G.W., T.A. Hales, and B.N. Aldridge. 1988. Flood Hydrology near Flagstaff, Arizona. U.S. 

Geological Survey, Water-Resources Investigation Report 87-4210.

Higginson, B. Hydrology Specialist Report, Schultz Burned Area Emergency Response. 2010. 

Korb, J.E, N.C. Johnson and W.W. Covington. 2004.Slash Pile Burning Effects on Soil Biotic 

and Chemical Properties and Plant Establishment: Recommendations for Amelioration. 

Restoration Ecology Vol. 12 No. 1, pp. 52_62 

Levick, L., J. Fonseca, D. Goodrich, M. Hernandez, D. Semmens, J. Stromberg, R. Leidy, M. 

Scianni, D. P. Guertin, M. Tluczek, and W. Kepner. 2008. The Ecological and Hydrological 

Significance of Ephemeral and Intermittent Streams in the Arid and Semi-arid American 

Southwest. U.S. Environmental Protection Agency and USDA/ARS Southwest Watershed 

Research Center, EPA/600/R-08/134, ARS/233046, 116 pp.
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 495

Lopes, V., Ffolliott, P., and Baker Jr., M. 2001. ”Impacts of Vegetative Practices on Suspended 

Sediment from Watersheds of Arizona.” Journal of Water Resources Planning and 

Management, 127(1), 41–47.

MacDonald, L.H, Stednick, J.D. 2003. Forests and water: A state-of-the-art review for Colorado. 

Colorado Water Resources Research Institute Rep. No. 196. Fort Collins, CO. Colorado State 

University. 65 p.

Megahan, W.F., King, J. G. 2004. Erosion, sedimentation, and cumulative effects in the Northern 

Rocky Mountains. In: Ice, G.G; Stednick, J.D. [Eds.]. A Century of Forest and Wildland 

Watershed Lessons. Bethesda, MD. Society of American Foresters. 9:201-222.

Megahan, W. F. and W. J. Kidd. 1972. Effects of logging and logging roads on erosion and 

sediment deposition from steep terrain. J. Forestry 70(3): 136-141.

Miller, G.N. Ambos, P.Boness, D. Reyher, G. Robertson, K. Scalzone, R. Steinke, and T. 

Subirge. 1995. Terrestrial Ecosystems Survey of the Coconino National Forest. USDA 

Forest Service, Southwestern Region. 405 pp. 

Neary, Daniel G.; Koestner, Karen A.; Youberg, Ann; Koestner, Peter E. 2012. Post-fire rill and 

gully formation, Schultz Fire 2010, Arizona, USA. Geoderma. 191: 97-104.

Neary, D.G., K. Ryan, L. DeBano. 2005. Wildland Fire in Ecosystems. Effects of Fire on Soil 

and Water. USDA Forest Service. RMRS-GTR-42-Volume 4. Ft Collins, CO. 250p.

Neary, D.G., C.C. Klopatek, L.F. DeBano, P.F. Ffolliott. 1999. Fire effects on belowground 

sustainability: a review and synthesis. Forest Ecology and Management 122, 51-71. 

Reeves, Derrick; Page-Dumroese, Deborah; Coleman, Mark. 2011. Detrimental soil disturbance 

associated with timber harvest systems on National Forests in the Northern Region. Res. Pap. 

RMRS-RP-89. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky 

Mountain Research Station. 12 p.

Rice, R. M.; Rothacher, J. S.; Megahan, W. F. 1972. Erosional consequences of timber 

harvesting: An appraisal. "Proceedings National Symposium on Watersheds in Transition. 

American Water Resources Association, Ft. Collins, Colorado, June 1972. p. 321-329.".

Robichaud, Peter R.; Elliot, William J.; Pierson, Fredrick B.; Hall, David E.; Moffet, Corey A.; 

Ashmun, Louise E. 2007. Erosion Risk Management Tool (ERMiT) user manual (version 

2006.01.18). Gen. Tech. Rep. RMRS-GTR-188. Fort Collins, CO: U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Research

Station. 24 p.

Robichaud, P.R., R.B. Foltz, and C.H. Luce. Sediment Problems: Strategies for 

Monitoring,Prediction and Control (Proceedings of the Yokohama Symposium, July 1993). 

IAHS Publ. no. 217, 1993.

Robichaud PR, MacDonald LH, Foltz RB (2005) Fuel management and erosion. In ‘Cumulative 

Watershed Effects of Fuels Management in the Western United States’. (Eds WJ Elliot, LJ 

Audin) USDA Forest Service, Rocky Mountain Research Station, General Technical Report, 

Ch. 5. 
Chapter 5: References

496 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Robichaud, P. R. and R. E. Brown. 1999. What happened after the smoke cleared: onsite erosion 

rates after a wildfire in Eastern Oregon. Presented at the Wildland Hydrology Conference, 

Bozeman, MT. American Water Resources Assoc. 419- 426

Seaber, P.R., Kapinos, F.P., and Knapp, G.L., 1987, Hydrologic Unit Maps: U.S. Geological 

Survey Water-Supply Paper 2294, 63 p. found at http://pubs.usgs.gov/wsp/wsp2294/

Stednick, J. D. 1996. Monitoring the effects of timber harvest on annual water yield. Journal of 

Hydrology 176(1/4): 79-95.

Troendle,C.A., L.H. MacDonald, C.H. Luce, I.J. Larsen. 2010. Cumulative Watershed Effects of 

Fuel Management in the Western United States .USDA Forest Service RMRS-GTR-231. 

USDA Forest Service. 1990. Soil and Water Conservation Practices Handbook. Forest Service 

Handbook 2509.22. USDA Forest Service, Southwestern Region. pp 83. 

_____. 1991. Soil Management Handbook. Forest Service Handbook 2509.22. USDA Forest 

Service, WO Amendment 2509.18-91-1. pp 10. 

_____. 2004. Forest Service Manual 2500, Water and Air Management. USDA Forest Service. 

May 26, 2004. 

_____. 2011a. Watershed Condition Framework (FS-977), USDA Forest Service. July 2011. 

_____. 2011b. Watershed Condition Classification Technical Guide (FS-978), USDA Forest 

Service. July 2011. 

Wischmeier, W. H., and Smith, D.D. 1978. Predicting rainfall erosion losses—a guide to 

conservation planning. U.S. Department of Agriculture, Agriculture Handbook No. 537

Wildlife

AGFD. 2003. Corynorhinus townsendii pallescens. Unpublished abstract compiled and edited by 

the Heritage Data Management System, Arizona Game and Fish Department, Phoenix, 

AZ 6pp. 

AGFD. 2013. Arizona Game and Fish Department Arizona Statewide Elk Management Plan 

Draft. November 20, 2013. 46pp. www.azgfd.com.

Anderson, David E, Rongstad, Orrin J. and Myrron, William R. 1990. Home-Range Changes 

in Raptors Exposed to Increased Human Activity Levels in Southeastern Colorado. 

Wildlife Society Bulletin: Vol. 18(2). 134-142 pp. 

Block, W.M., Ganey J.L., Scott, P.E., King, R. 2005. Prey ecology of Mexican spotted owl in 

pine-oak forests of northern Arizona. Journal of Wildlife Management 69:618-629.

Bushman E.S. and G.D. Therres. 1988. Habitat management guidelines for forest interior 

breeding birds of coastal Maryland. Maryland Dept. Natural Resources, Wildlife Tech. 

Publ. 88-1. 50pp.
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 497

Cockum, E.L. 1960. The recent mammals of Arizona: their taxonomy and distribution. 

University of Arizona Press, Tuscon.

Corman, T., C. Wise-Gervais. 2005. Arizona Breeding Bird Atlas. University of New Mexico 

Press. Albuquerque, NM. 636 pp.

Dargan, C.M. 1991. Roost site characteristics of bald eagles wintering in north-central Arizona. 

M.S. Thesis, Northern Arizona University, 73pp.

Dodd, N.L., S.S. Rosenstock, C.R. Miller, and R.E. Schweinsburg. 1998. Tassel-eared 

squirrel population dynamics in Arizona: index techniques and relationships to habitat 

condition. Arizona Game and Fish Department Technical Report 27, Phoenix, AZ.

49pp.

Delaney, D. K., T.G. Grubb, P. Beier, L.L. Pater, M.H. Reiser. 1999. Effects of Helicopter 

Noise on Mexican spotted Owls. J. Wildl. Mgmt. 63(1):60-76. 

Driscoll, J.T., K.V. Jacobson, G. Beatty, J.S. Canaca, J.G. Koloszar. 2006. Conservation 

Assessment and Strategy for the Bald Eagle in Arizona. Nongame and Endangered 

Wildlife Program. Arizona Game and Fish Department, Phoenix, Arizona. 69pp.

Ganey, J. L., and S.C. Vojta, 2011. Tree mortality in drought-stressed mixed-conifer and 

ponderosa pine forests, Arizona, USA. Forest ecology and management, 261(1), 162-

168.

Ganey, Joseph L., Vojta, Scott C. 2007. Modeling snag dynamics in Northern Arizona mixed 

conifer and ponderosa pine forests. Res. Pap.RMRS-RP66WWW. Fort Collins, CO: 

US Department of Agriculture, Forest Service, Rocky Mountain Research Station.

15p.

Ganey, Joseph L.; Block, Wouldiam M.; Ackers, Steven H. 2003.Structural characteristics of 

forest stands within home ranges of Mexican spotted owls in Arizona and New 

Mexico. Western Journal of Applied Forestry. July 2003. Vol. 18, no. 3:pp. 189-198.

Garnett, G.N., R.L. Mathiasen, and C.L. Chambers. 2004. A comparison of wildlife use in 

broomed and unbroomed ponderosa pine trees in northern Arizona. Western Journal of

Applied Forestry 19:42-46.

Grubb, T.G. and C.E. Kennedy. 1983. Bald eagle winter habitat on southwestern national 

forests. Research Paper RM-237. USDA Forest Service, Rocky Mountain Forest and 

Range Experiment Station, Fort Collins, CO. 13pp.

Grubb, T. G., L. L. Pater, D.K. Delaney. 1998. Logging Truck Noise near Nesting Goshawks. 

USDA Research Note RMRS-RN-3.

Hall, Wesley, 2014. Personal communication via email: “FWPP MSO CFP alts 2 and 3” from 

January 21. Flagstaff Watershed Protection Project. Coconino National Forest, 

Flagstaff, Arizona.

Hedwall, S.J., C.L. Chambers, S.S. Rosenstock. 2006. Red Squirrel Use of Dwarf Mistletoeinduced Witches Brooms in Douglas-fir. Journal of Wildlife Management. Vol.70, Issue

4, pp.1142-1147.

Hoffmeister, D. 1986. Mammals of Arizona. The University of Arizona Press. 602 pp. 
Chapter 5: References

498 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Jenness, J.S. 2000. The effects of fire on Mexican spotted owls in Arizona and New Mexico.

Master of Science Thesis. Northern Arizona University, Flagstaff, Arizona.131 pp.

Latta, M.J., C.J. Beardmore, and T.E. Corman. 1999. Arizona Partners in Flight Bird 

Conservation Plan. Technical Report 142. Version 1.0. Nongame and Endangered 

Wildlife Program. Arizona Game and Fish Department. 2221 W. Greenway Rd., 

Phoenix, AZ 85023-4399. 331 pp.

NatureServe Explorer: An online encyclopedia of life [web application]. 2009. Version 7.1. 

Arlington Virginia, USA: NatureServe. Last updated July 2013. Available:

http://www.natureserve.org/explorer. (Accessed January 30, 2013).

MacDonald, Kit. 2013. Personal communication with Tom Runyon. January 6. Flagstaff 

Watershed Protection Project. Coconino National Forest. Flagstaff, Arizona. 

Notaro, M., Mauss, A., & Williams, J. W. 2012. Projected vegetation changes for the American 

Southwest: combined dynamic modeling and bioclimatic-envelope approach. Ecological 

Applications, 22(4), 1365-1388.

Patton. D. R. , Vahle, J. R.. 1986. Cache and Nest Characteristics of Red Squirrel in an Arizona 

Mixed-Conifer Forest. Western Journal of Applied Forestry. Vol(1), No. 2.

Reynolds, R.T, R.T. Graham, M.H. Reiser, R.L. Bassett, P.L. Kennedy, D.A. Boyce, Jr., G. 

Goodwin, R. Smith, and E.L. Fisher. 1992. Management recommendations for the 

northern goshawk in the southwestern United States. Gen. Tech. Rep. RM-217. Ft. 

Collins, CO. U.S. Department of Agriculture, Forest Service, Rocky Mountain Forest 

and Range Experiment Station. 90 p.

Reynolds, R.T. Literature Review. 2004. Is the Northern Goshawk an old Growth Forest 

Specialist or a Habitat Generalist? U.S. Department of Agriculture, Forest Service, 

Rocky Mountain Forest and Range Experiment Station. 34 p.

Reynolds, Richard T.; Sánchez Meador, Andrew J.; Youtz, James A.; Nicolet, Tessa; Matonis, 

Megan S.; Jackson, Patrick L.; DeLorenzo, Donald G.; Graves, Andrew D. 2013. 

Restoring composition and structure in Southwestern frequent-fire forests: A sciencebased framework for improving ecosystem resiliency. Gen. Tech. Rep. RMRS-GTR310. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Research Station. 76 p.

Seamens, M. E., R.J. Gutierrez, C. A. May, and M. Z. Perry. 1999. Demography of two Mexican 

spotted owl populations. Conservation Biology. 13:744-754.

Seamens, M. E., R. J. Gutierrez, C.A. May. 2002. Mexican spotted owl (Strix 

occidentalis) population dynamics: influence of climate variation on survival 

and reproduction. The Auk 119(2):321-334.

Slauson, Keith M., Zielinski, William J. 2008. Northern goshawk monitoring in Lake Tahoe 

Basin: Monitoring plan development and protocol. Final Report. USDA forest Service, 

Pacific southwest Research station: Arcata, C.:

Solvesky, B. and C. Chambers. 2007. Bat Roost Inventory and Monitoring Project for Arizona

Game and Fish Department Region 2. Flagstaff, AZ.26 pp.
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 499

Solvesky, B. and C. Chambers. 2009. Roosts of Allen’s lappet-browed bats in Northern 

Arizona. Journal of Wildlife Mgmt. Vol73(5):677-682pp.

Sousa, P.J. 1987. Habitat suitability index models: hairy woodpecker. U.S. Fish Wildl. 

Service Biol. Rep.82 (10.146). 19pp.

States, J.S. and W.S. Gaud. 1997. Ecology of hypogenous fungi associated with 

ponderosa pine. [Patterns of distribution and scorocarp production in some 

Arizona forests. Mycologia 89:712-721.

Stalmaster, M.V. 1998. Effects of recreation activity on wintering bald eagles. Wildlife 

monograph. 137: 1-46.

Template for Assessing Climate Change Impacts and Management Options.2014. TACCIMO 

Climate Report: Coconino Naktional Forest 03-12-2014. Online: 

http://www.sgcp.ncsu.edu:8090/geospatialReport.aspx

USDA Forest Service. 1982. Analysis of the Management Situation, Coconino National Forest. 

Southwestern Region.

USDA Forest Service. 1987b. Environmental Impact Statement for the Coconino National Forest 

Plan. Southwestern Region. 438 p.

USDA Forest Service. 2013. Management Indicator Species Status Report for the 

Coconino National Forest. Working draft January 2013. Coconino National 

Forest, Flagstaff, Arizona. 118 pp.

USDA Forest Service. 2013. Request for Technical Assistance for the Designation of Mixed 

Conifer Recovery Nest/Roost Habitat for the Flagstaff Ranger District. On file at the 

Flagstaff District office. 

USDA Forest Service and Arizona Game and Fish Department. 1981. Arizona Wildlife and 

Fisheries Comprehensive Plan. Forest Service, Region 3.

USDA Forest Service and Arizona Game and Fish Department. 1990. Arizona Wildlife and 

Fisheries Comprehensive Plan: Coconino National Forest. Forest Service, Region 3. 24 

pp.

USDI Fish and Wildlife Service. 1973. Threatened wildlife of the United States. U.S. 

Department of the Interior. 289 pp.

USDI Fish and Wildlife Service. 1978. Determination of Certain Bald Eagle Populations as 

Endangered or Threatened, Final Special Rule, 17.41(a). Federal Register 43:6230-6233.

USDI Fish and Wildlife Service. 1982. Bald eagle recovery plan (southwestern 

population). US Fish and Wildlife Service, Albuquerque, NM. 74 pp.

USDI Fish and Wildlife Service. 1993. Endangered and threatened wildlife and plants; final rule

to list the Mexican spotted owl as a threatened species. Federal Register 58(49): 14248-

14271.

USDI Fish and Wildlife Service. 1995a. Endangered and threatened wildlife and plants; final 

rule to reclassify the bald eagle from endangered to threatened in all of the lower 48 

states. Federal Register 60:35999-36010.
Chapter 5: References

500 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

USDI Fish and Wildlife Service. 2004. Endangered and threatened wildlife and plants; final 

designation of critical habitat for the Mexican spotted owl. August 31, 2004. Federal 

Register 69(164): 53182-53230.

USDI Fish and Wildlife Service. 2007. National Bald Eagle Management Guidelines.

USDI Fish and Wildlife Service. 2007. Protection of Eagles; Definition of “Disturb”. Final Rule. 

Federal Register 72: 31132-31140

U.S. Fish and Wildlife Service. 2008. Birds of Conservation Concern 2008. United States 

Department of Interior, Fish and Wildlife Service, Division of Migratory Bird 

Management, Arlington, Virginia. 85 pp. [Online version available at 

http://www.fws.gov/migratorybirds]

U.S. Fish and Wildlife Service. 1995. Recovery plan for the Mexican spotted owl: Vol I. 

Albuquerque, New Mexico. 172 pp.

U.S. Fish and Wildlife Service. 2012. Final Recovery Plan for the Mexican Spotted Owl (Strix 

occidentalis lucida), First Revision. United States Fish and Wildlife Service. 

Albuquerque, New Mexico. USA. 413pp.

Vahle, R.J. and D.R. Patton. 1983. Red squirrel cover requirements in Arizona mixed 

conifer forests. Journal of Forestry Vol. 81(1): 14-15, 22.

Van Mantgem, P. J., Stephenson, N. L., Byrne, J. C., Daniels, L. D., Franklin, J. F., Fulé, P. Z., 

and Veblen, T. T. 2009. Widespread increase of tree mortality rates in the western United 

States. Science, 323(5913), 521-524.

Ward, J.P., Jr. 2001. Ecological responses by Mexican spotted owls to environmental variation 

in the Sacramento Mountains, New Mexico. Ph.D. Dissertation. Colorado State 

University, Fort Collins, Colorado.

Wisdom, M.J., L.J. Bate. 2008. Snag density varies with intensity of timber harvest and human 

access. Forest Ecology and Mgmt. 255:2085-2093. 

Scenery

City of Flagstaff. 2014. Flagstaff Regional Plan 2030. Online: 

http://www.flagstaff.az.gov/index.aspx?NID=2936 (accessed 2/4/14)

Guido, Zack. Extreme Events in the Southwest. CLIMAS. Online: 

http://www.climas.arizona.edu/feature-articles/sep-2011 (accessed 2/4/2014).

Gust, D.A. and R.J. Arculus. 1986. Petrogenesis of Alkalic and Calcalkalic Volcanic Rocks of 

Mormon Mountain Volcanic Field, Arizona. Contributions to Mineralogy and Petrology. 

94:416-426.

Holm, Richard F. 1988. Geologic Map of San Francisco Mountain, Elden Mountain and Dry 

Lake Hills, Coconino County, Arizona. USDI-US Geological Survey. 

Noble, Bill. 2012. Understory Response to Changes in Overstory Cover. Unpublished report, 

Coconino National Forest, Flagstaff, AZ. pp. 1-7, 21-30.
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 501

Ryan, Robert L. 2005. Social Science to Improve Fuels Management: A Synthesis of Research on 

Aesthetics and Fuels Management. GTR NC-261. St. Paul, MN: USDA Forest Service, 

North Central Research Station. 58 pp. Online: http://treesearch.fs.fed.us/pubs/13514

(accessed 2/4/2014)

USDA-Forest Service. 2012. 2010 National Visitor Use Monitoring: Visitor Use Report, 

Coconino NF. USDA Forest Service, Southwestern Region. Online: 

http://www.fs.fed.us/recreation/programs/nvum/ Use Round 3 (2010-2014),Southwest 

Region (R3), Coconino NF, when list of reports opens, choose “Satisfaction” and Percent 

Satisfied or “Demographics” and Origin of Respondents). (accessed 2/4/2014)

USDA Forest Service. 2013. Coconino National Forest Draft Land Management Plan. USDA 

Forest Service, Southwestern Region. pp. 178. Online: 

http://a123.g.akamai.net/7/123/11558/abc123/forestservic.download.akamai.com/11558/

www/nepa/69549_FSPLT3_1463838.pdf (accessed 2/4/14)

USDA-Forest Service. 2013a. Flagstaff Watershed Protection Project Scoping Summary. 

Available at Coconino National Forest, Flagstaff, AZ.

USDA Forest Service. 2011. Landscape Character Descriptions, Coconino National Forest. 

Prepared by Nicole Hill and Matthew Boisseau, Teams Enterprise Unit. Unpublished 

report. Available at Coconino National Forest, Flagstaff, AZ.

USDA-Forest Service. 2008. Recreation Facility Analysis, Action Plan for Coconino National 

Forest. Unpublished report. Available at Coconino National Forest, Flagstaff, AZ.

USDA-Forest Service. 2007. Appendix J: Recommended SMS Refinements. USDA Forest 

Service. On file at Coconino National Forest, Flagstaff, AZ. 33 pp.

USDA-Forest Service. 2000. Landscape Aesthetics: A Guide for Scenery Management, as 

revised. USDA Handbook 701. Online: 

http://library.rawlingsforestry.com/fs/landscape_aesthetics/ (accessed 2/4/14)

USDA-Forest Service. 1977. National Forest Landscape Management. Vol. 2. USDA Agriculture 

Handbook No. 462. 

Economics

USDA Forest Service March 2013. Cost Estimating Guide for Road Construction

USDA Forest Service Logcost program, (version 13.1)

Invasive Plant Species

Ballard, T.M. 2000. Impacts of forest management on northern forest soils. Forest Ecology and 

Management 133: 37-42.

Bradley, B. A., D.M. Blumenthal, D.S. Wilcove, and L.H. Ziska. 2010. Predicting plant 

invasions in an era of global change. Trends in Ecology and Evolution 25: 310-318. 
Chapter 5: References

502 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Collins, Barndon M., Jason J. Moghaddas and Scott L. Stevens. 2007. Initial changes in forest 

structure and understory plant communities following fuel reduction activities in a Sierra 

Nevada mixed conifer forest. Forest Management and Ecology 239: 102-111.

Fowler, J. F., C. Hull Sieg, B. G. Dickson, and V. Saab. 2008. Exotic plant species diversity: 

influence of roads and prescribed fire in Arizona ponderosa pine forests. Rangeland 

Ecology and Management 61: 284–293.

Harrod, Richy J. 2001. The effect of invasive and noxious plants on land management in eastern 

Oregon and Washington. Northwest Science 75(Special Issue): 85-90.

Hellmann J. J., J.E. Byers, B.G. Bierwagen, and J.S. Dukes. 2008. Five potential consequences 

of climate change for invasive species. Conservation Biology 22: 534–543.

Kaye, Jason P. and Stephen C. Hart. 1998. Ecological restoration alters nitrogen transformations 

in a ponderosa pine-bunchgrass ecosystem. Ecological Applications 8 (4): 1052-1060.

Korb, Julie E. 2001. Understory plant community dynamics in southwestern ponderosa pine 

forest restoration. PhD Dissertation. Northern Arizona University. Flagstaff, Arizona. 

120 pages.

Korb, Julie E, Nancy C. Johnson and W. Wallace Covington. 2004. Slash pile burning effects on 

soil biotic and chemical properties and plant establishment: recommendations for 

amelioration. Restoration Ecology 12: 52-62.

Marlon, J. R., P. J. Bartlein, M. K. Walsh, S. P. Harrison, K. J. Brown, and M. E. Edwards. 2009. 

Wildfire responses to abrupt climate change in North America. Proceedings of the 

National Academy of Sciences of the United States of America 106: 2519–2524. 

McGlone, Christopher M. and Dave Egan. 2009. The role of fire in the establishment and spread 

of nonnative plants in Arizona ponderosa pine forests: a review. Journal of the ArizonaNevada Academy of Science 41(2): 75-86.

Megahan, W. F. and W. J. Kidd. 1972. Effects of logging and logging roads on erosion and 

sediment deposition from steep terrain. Journal of Forestry 70(3): 136-141.

Middleton, B. A., 2006, Invasive species and climate change: U. S. Geological Survey Open-File 

Report: 2006-1153. 2 pp.

Raison, R.J. 1979. Modification of the soil environment by vegetation fires, with particular 

reference to nitrogen transformations review. Plant and Soil 51: 73-108.

USDA FS. 1998. Noxious weed strategic plan working guidelines, Coconino, Kaibab, and 

Prescott National Forests. 34pp.

______. 2005. Final Environmental Impact Statement for Integrated Treatment of Noxious or 

Invasive Weeds, Coconino, Kaibab and Prescott National Forests. 242pp.

Sensitive Plants

Ballard, T.M. 2000. Impacts of forest management on northern forest soils. Forest Ecology and 

Management 133: 37-42.
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 503

Kaye, Jason P., and Stephen C. Hart, 1998. Ecological Restoration Alters Nitrogen 

Transformations in a Ponderosa Pine-Bunchgrass Ecosystem. Ecological Applications 

8(4):1052-1060.

Korb, J.E. 2001. Understory plant community dynamics in southwestern ponderosa pine forest 

restoration. PhD Dissertation. Northern Arizona University. Flagstaff, Arizona. 120 

pages.

Korb, J.E., N.C. Johnson and W.W. Covington. 2004. Slash pile burning effects on soil biotic 

and chemical properties and plant establishment: recommendations for amelioration. 

Restoration Ecology 12: 52-62.

Laughlin, Daniel C., Jonathan D. Bakker, Mark L. Daniels, Margaret M. Moore, Cheryl A. Casey 

and Judith D. Springer. 2008. Restoring plant species diversity and community 

composition in a ponderosa pine-bunchgrass ecosystem. Plant Ecology 197: 139-151. 

Raison, R.J. 1979. Modification of the soil environment by vegetation fires, with particular 

reference to nitrogen transformations review. Plant and Soil 51: 73-108.

Recreation

AZGFD, Game Unit Map 2013. Online: http://www.azgfd.gov/h_f/hunting_units_11m.shtml

[Accessed October, 2013]

Cordell, H. Ken. 2008b. The latest trends in nature-based outdoor recreation. Forest History 

Today, spring 2008.

Cordell, H. Ken; Betz, Carter, J.; Green, Gary T. 2008c. Nature-based outdoor recreation trends 

and wilderness. International Journal of Wilderness, August 2008, Volume 14, Number 2. 

7-13 p.

Cordell, H. Ken; Betz, Carter, J.; Green, Gary T.; Mou, Shela. 2009. Recreation demand trends –

An update. USDA Forest Service, Southern Research Station. Available: 

http://www.srs.fs.usda.gov/trends/2009SERRkc.html [2009, August 18].

Pergams, Oliver R.W., Zaradic, P.A. 2008. Evidence for a fundamental and pervasive shift away

from nature-based recreation. Proc Natl Acad Sci. USA. 105:2295–2300.

Peters, P.A. “Chainsaw Felling Fatal Accidents” 1991. American Society of Agricultural 

Engineers. MI. Vol. 34, No. 6, pp. 2600-2608.

USDA Forest Service, 2009. National Visitor Use Monitoring Results: Coconino National 

Forest. February 2009, data collected FY2005. Online: 

http://apps.fs.usda.gov//nrm/nvum/results/Default.aspx. [Accessed September, 2013]

USDA Forest Service, ROS Primer and Field Guide 2011. 

USDA, TMR Record of Decision – Coconino NF 2011.

USDA, MVUM – Motor Vehicle Use Map, Coconino NF May 1 2013. 
Chapter 5: References

504 Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project

Heritage

Barrett, Chris (geospatial data product). 2010. Coconino National Forest Heritage Density Model. 

Geospatial data model available as a shapefile at the Coconino National Forest 

Supervisor’s Office, Flagstaff, AZ.

Deal, Krista. 1999. Effects of Prescribed Fire on Obsidian and Implications for Reconstructing 

Past Landscapes. Annual Meeting of the Society for California Archaeology, April 23-25, 

1999, Sacramento.

______. 2001. Fire Effects to Lithic Artifacts. Presented at NPS Cultural Resources Protection 

and Fire Planning Course, January 22-26, 2001, Tucson.

______. 2012. Fire Effects on Flaked Stone, Ground Stone, and Other Stone Artifacts. In 

Wildland Fire in Ecosystems: Effects of Fire on Cultural Resources and Archaeology 

General Technical Report No. RMRS-GTR-42-vol.3: Chapter 4, USDA Forest Service, 

Rocky Mountain Research Station, Fort Collins, Colorado. On File NPS Western 

Archaeological and Conservation Center, Tucson.

Haines, Jeremy D., and Michael Lyndon. 2010. Technical Specialist’s Report- Burned Area 

Emergency Rehabilitation, Flagstaff Ranger District, Coconino National Forest. 

Manuscript on file at the Supervisor’s Office, Coconino National Forest, Flagstaff, AZ. 

Haines, Jeremy D., and April Peters. 2013. An Archaeological Survey Proposal for the Flagstaff 

Watershed Protection Project: Dry Lake Hills and Mormon Mountain, Flagstaff Ranger 

District, Coconino National Forest. Manuscript on file at the Supervisor’s Office, 

Coconino National Forest, Flagstaff, AZ. 

Jackson, Robert J. 1998. Prescribed Fire and the Protection of Heritage Resources. A Heritage 

Resources Management Module, Prepared for the USDA Forest Service, Pacific 

Southwest Region, National Forests of the Sierra Nevada. Pacific Legacy, Inc. 

Sacramento.

Johnson, Craig. 2013. Draft Tribal Consultation Specialist Report, Flagstaff Watershed Protection 

Project, Coconino National Forest, Coconino County, Arizona. 

Lutes, Annie. 2013. Prehistory on Fire: A Qualitative Analysis of Second-Order Fire Effects on a 

Sample of Prehistoric Cohonina Sites on the Williams Ranger District of the Kaibab 

National Forest. Unpublished Master’s thesis, Northern Arizona University, Flagstaff, 

AZ. 

Oster, Elizabeth, Samantha Ruscavage-Barz, and Michael L. Elliot. 2012. The Effects of Fire on 

Subsurface Archaeological Materials. In Wildland Fire in Ecosystems: Effects of Fire on 

Cultural Resources and Archaeology General Technical Report No. RMRS-GTR-42-

vol.3: Chapter 7, USDA Forest Service, Rocky Mountain Research Station, Fort Collins, 

Colorado. On File NPS Western Archaeological and Conservation Center, Tucson.

Pilles, Peter J. and Pat H. Stein. 1981. A Cultural Resources Overview of the Coconino National 

Forest. Manuscript on file at the Coconino National Forest Supervisor’s Office, 

Flagstaff. 
Chapter 5: References

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 505

______. 2000. White Vulcan Mine Settlement Agreement and Mine Closure, CNF Heritage 

Report 1987-104W. Manuscript on file at the Coconino National Forest Supervisor’s 

Office, Flagstaff. 

Rude, Trish and Anne Trinkle Jones. 2012. Fire Effects to Prehistoric Ceramics. In Wildland Fire 

in Ecosystems: Effects of Fire on Cultural Resources and Archaeology General Technical 

Report No. RMRS-GTR-42-vol.3: Chapter 3, USDA Forest Service, Rocky Mountain 

Research Station, Fort Collins, Colorado. On File NPS Western Archaeological and 

Conservation Center, Tucson.

Ryan, Kevin C., Cassandara L. Koerner, Kristine M. Lee, and Nelson Siefkin. 2012.Effects of 

Fire on Cultural Resources- Introduction. In Wildland Fire in Ecosystems: Effects of Fire 

on Cultural Resources and Archaeology General Technical Report No. RMRS-GTR-42-

vol.3: Chapter 1, edited by Jones, A.T. and K.C. Ryan. USDA Forest Service, Rocky 

Mountain Research Station, Fort Collins, Colorado. On File NPS Western Archaeological 

and Conservation Center, Tucson.

USDA Forest Service. 2003. First Amended Programmatic Agreement Developed pursuant to 

Stipulation IV.A. of the Region 3 Regarding Historic Property Protection and 

Responsibilities; Appendix H: Standard Consultation Protocol for Rangeland 

Management. Programmatic Agreement on file at the Coconino National Forest 

Supervisor’s Office. Flagstaff, AZ.

______. 2010. First Amended Programmatic Agreement Developed pursuant to Stipulation IV.A. 

of the Region 3 Regarding Historic Property Protection and Responsibilities; Appendix J: 

Standard Consultation Protocol for Large-Scale Fuels Reduction, Vegetation Treatment, 

and Habitat Improvement Projects. Programmatic Agreement on file at the Coconino 

National Forest Supervisor’s Office. Flagstaff, AZ.

_______. 2013. Draft Environmental Impact Statement for the Flagstaff Watershed Protection 

Project, Coconino National Forest, Coconino County, Arizona. Manuscript on file at the 

Coconino National Forest Supervisor’s Office. Flagstaff, AZ.

Weintraub, Neil, Michael Lyndon, Leigh Kuwanwisiwma, and Stewart B. Koyiyumptewa. 2013. 

Walking the Land Together: Collaborative Restoration of TCPs and Cultural Landscapes 

on the Kaibab National Forest. Paper presented the Traditional Cultural Places 

Workshop/Arizona Historic Preservation Conference, Mesa, Arizona. 

Whiting, Joshua C. 2013. Flagstaff Watershed Protection Project Cultural Resources Inventory, 

Flagstaff Ranger District, Coconino National Forest, Coconino County, Arizona.

Transportation

USDA Forest Service. 1987. Coconino National Forest Land and Resource Management Plan, as 

amended. Flagstaff, Arizona.
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 506

Glossary

Active Crown Fire – A fire in which a solid flame develops in the crowns of trees, but the 

surface and crown phases advance as a linked unit dependent on each other. 

Age Class – A distinct aggregation (grouping) of trees originating from a single natural event 

commonly consisting of trees of similar age. 

Basal Area (BA) – the cross-sectional area of all trees, measured in square feet per acre. 

Biomass – Multiple definitions include: organic matter produced by plants and other 

photosynthetic organisms; total dry weight of all living organisms that can be supported at each 

level of a food chain or web; dry weight of all organic matter in plants and animals in an 

ecosystem; plant materials and animal wastes that functions as fuel for fire. 

Burn – An effect produced by heating. To undergo combustion, consuming fuel and giving off 

light, heat, and gasses. Also, an area where fire has occurred in the past. 

Canopy – A layer of foliage, generally the uppermost layer, in a forest stand. Can be used to refer 

to midstory or understory vegetation in multi-layered stands. 

Canopy Base Height (CBH) is a critical factor in crown fire initiation, and can be used as an 

indicator of the potential for crown fire initiation (Agee and Skinner 2005, Stratton 2009, Scott 

2003). The desired condition is for CBH to be greater than 18 feet in ponderosa pine. 

Canopy Bulk Density (CBD) – for ponderosa pine and pine-oak stands. CBD is a good indicator 

of potential active crown fire (Stratton 2009, Scott 2003). The desired condition is for average 

CBD to be less than 0.05 kg/m

3 

in ponderosa pine. 

Canopy Characteristics – Canopy characteristics include canopy cover, canopy base heights 

(CBH), and canopy bulk density (CBD) which contribute significantly towards the type of fire 

that can occur (Scott and Reinhardt 2001). Canopy cover, CBH, and CBD directly affect the 

incidence and behavior of crown fires and are used for modeling potential fire behavior (Scott 

2003, Scott and Reinhardt 2005, Agee and Skinner 2005). 

Canopy Cover – as used in modeling fire in the fire ecology analysis, canopy cover is the 

horizontal fraction of the ground that is covered directly overhead by tree canopy, the percent of 

vertically projected canopy cover in the stand (Scott and Reinhardt 2005). See the Forest 

Structure and Health section of Chapter 3 for details on how canopy cover was measured for this 

project. 
Glossary

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 507

Clean Water Act (CWA) – Act that provides the structure for regulating pollutant discharges to 

waters of the United States. The Act’s objective is “...to restore and maintain the chemical, 

physical, and biological integrity of the Nation’s waters,” and is aimed at controlling both point 

and non-point sources of pollution. The U.S. EPA administers the Act, but many permitting, 

administrative, and enforcement functions are delegated to state governments. In Arizona, the 

designated agency for enforcement of the Clean Water Act is the Arizona Department of 

Environmental Quality (ADEQ). 

Closed Road – Intermittent service roads that are closed to public vehicular traffic. However, 

these roads may be available and suitable for non-motorized uses. The closure period must 

exceed 1 year. Basic custodial maintenance is performed to keep damage to adjacent resources to 

an acceptable level and to perpetuate the road to facilitate future management activities. Emphasis 

is normally given to maintaining drainage facilities and runoff patterns. Planned road 

deterioration may occur at this maintenance level (USDA Forest Service 2005). 

Clump – A tight cluster of two to five trees of similar age and size originating from a common 

rooting zone that typically lean away from each other when mature. A clump is relatively isolated 

from other clumps or trees within a group of trees. A stand-alone clump of trees can function as a 

tree group. 

Condition Class (reference FRCC) – A measure of departure from reference conditions that can 

be used to determine how ‘at risk’ key ecosystem components are in the event of a disturbance 

event, such as fire. 

Conditional Crown Fire – A crown fire that is dependent on ladder fuels in adjacent stands in 

order for fire to access the crowns. In an area with conditional crown fire, ladder fuels are 

insufficient in a stand for crown fire to initiate, but canopy fuels are sufficient to support crown 

fire if it moves in from an adjacent stand. 

Controlled Burn – Synonymous with prescribed fire. 

Coarse Woody Debris (CWD) – woody debris larger than 7.5 cm (3 inches) in diameter 

(Graham et al. 1994). 

Cover Type – Refers to a forest or woodland type, such as ponderosa pine, pine-oak, or mixedconifer. 

Crown fire – A fire that advances from top to top of trees or shrubs more or less independent of a 

surface fire. Crown fires are sometimes classed as independent, conditional, or dependent (active 

or passive) to distinguish the degree of independence from the surface fire. Crown fires are 

common in coniferous forests and chaparral shrublands. 

Declining – The senescent (aging) period in the lifespan of plants that (for trees) includes the 

presence of large dead and/or dying limbs, snag-tops, large, old lightning scars, and other 

characteristics that indicate the later life-stages. 

Density-Related Mortality – Based upon established forest density/vigor relationships, densityrelated mortality begins to occur once the forest reaches 45 to 50 percent of maximum stand 
Glossary

508 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

density, and mortality is likely at density levels over 60 percent of maximum stand density (Long 

1985). 

Diameter at Breast Height (dbh) – A standard measure of tree diameter measured 

approximately 1.5 meters (4.5 feet) above the ground. 

Disturbance – Any relatively discrete event or series of events, either natural or human-induced 

that causes a change in the existing condition of an ecosystem, community, or population 

structure and alters the physical environment. 

Disturbance Regime – A set of recurring conditions due to a variety of disturbances (e.g., fire, 

flooding, insect outbreak) and their interaction, which characterize an ecosystem within a historic, 

natural, or human induced context, within a given climate. This set of recurring conditions 

includes a specific range for each of the attributes of these disturbances. These attributes include: 

frequency, rotation period, intensity, severity, seasonality, patch size and distribution, residual 

structure, causal agent, the relative influence of each causal agent, and how they interact (Suffling 

and Perera 2004). The attributes researchers choose to represent a regime will vary depending on 

a researcher’s area of interest (Sousa 1984, Pickett & White 1985, Agee 1993, Skinner and Chang 

1996, Turner et al. 2001). An accurate description of a disturbance regime must include the full 

range of disturbance events, including those that are rare. 

Diversity – The distribution and abundance of different plant and animal communities and 

species within the area covered by a land and resource management plan. 

Drought – Periods of abnormally dry weather sufficiently long enough to cause a serious 

hydrological imbalance. Drought is a relative term; therefore, any discussion in terms of 

precipitation deficit must refer to the particular precipitation-related activity that is under 

discussion. For example, there may be a shortage of precipitation during the growing season 

resulting in crop damage (agricultural drought), or during the winter runoff and percolation 

season affecting water supplies (hydrological drought). 

Duff – The fermentation and humus layer lying below the litter layer and above mineral soil; 

consisting of partially decomposed organic matter whose origins can still be visually determined, 

as well as the fully decomposed humus layer. This layer does not include the freshly cast material 

in the litter layer, nor in the post-burn-environment ash (Brown 2000). The top of the duff is 

where needles, leaves, fruits, and other castoff vegetative material have noticeably begun to 

decompose. Individual particles usually are bound by fungal mycelia. The bottom of the duff is 

mineral soil. There is a gradient, not a clear division between litter and duff. 

Ecological Restoration – The process of assisting the recovery of resilience and adaptive 

capacity of ecosystems that have been degraded, damaged, or destroyed. Restoration focuses on 

establishing the composition, structure, pattern, and ecological processes necessary to make 

terrestrial and aquatic ecosystems sustainable, resilient, and healthy under current and future 

conditions (USDA Forest Service 2008). 

Environmental Justice – The fair treatment and involvement of all people regardless of race, 

color, national origin, or income with respect to the development, implementation, and 

enforcement of environmental laws, regulations, and policies. The White House, with Executive 

Order 12898, elevated environmental justice issues to the federal agency policy agenda. EO 

12898 instructs each federal agency to identify and address “disproportionately high and adverse 

human health or environmental effects of its programs, policies, and activities on minority 

populations and low-income populations” (Clinton 1994). 
Glossary

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 509

Ephemeral Stream – A stream that flows only briefly during and following a period of rainfall 

in the immediate locality. 

Erosion – The wearing away of the land surface by rain or irrigation water, wind, ice, or other 

natural or anthropogenic agents that abrade, detach, and remove geologic parent material or soil 

from one point on the earth's surface and deposit it elsewhere. 

Even-aged Stand – A stand of trees composed of a single age class in which the range of tree 

ages is usually plus or minus 20 percent of rotation (SAF 2008). 

Even-aged Management – The application of a combination of actions that result in the creation 

of stands in which trees of essentially the same age grow together. Managed even-aged forests are 

characterized by a distribution of stands of varying ages (and, therefore, tree sizes) throughout the 

forest area. The difference in age between trees forming the main canopy level of a stand usually 

does not exceed 20 percent of the age of the stand at harvest rotation age. Regeneration in a 

particular stand is obtained during a short period at or near the time that a stand has reached the 

desired age or size for regeneration and is harvested. Clearcut, shelterwood, or seed tree cutting 

methods produce even-aged stands. 

Fire Adapted Ecosystem – An associated group of plant and animals that have made long-term 

genetic changes in response to the presence of fire in their environment. 

Fire Ecology – The study of fire’s interaction with ecosystems. 

Fireline Intensity – Rate of heat release in the flaming front. 

Fire Regime – A set of recurring fire conditions that characterize an ecosystem, within a historic, 

natural, or human induced context, within a given climate. This set of recurring conditions 

includes a specific range of attributes. Sugihara et al. (2006) use the following attributes: 

seasonality, frequency (fire return interval), intensity, severity, size, spatial complexity, and fire 

type. An accurate description of a fire regime will include the full range of fire events, including 

those that are rare and connect to the larger disturbance regime which contains the fire regime as 

a subset. There are five fire regimes: 

Fire regime I – 0 to 35 year frequency and low (surface fires most common, isolated torching 

can occur) to mixed severity (less than 75 percent of dominant overstory vegetation replaced)

Fire regime II – 0 to 35 year frequency and high severity (greater than 75 percent of dominant 

overstory vegetation replaced)

Fire regime III – 35 to 100 year frequency and low/mixed severity

Fire regime IV – 35 to 100 year frequency and high severity

Fire regime V – 100+ year frequency and high severity. 

Fire Regime Condition Class (FRCC) – An ecological evaluation protocol that uses three 

classes for describing the relative degree of departure from historical fire regimes. 

Fire Return Interval – The number of years between two successive fires in a designated area 

(i.e., the interval between two successive fires); the size of the area must be clearly specified 

(McPherson and others 1990). 
Glossary

510 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Fire Risk – In the context of technical risk assessments, the term “risk” considers not only the 

probability of an event, but also includes values and expected losses. Within wildland fire, ‘risk’ 

refers only to the probability of ignition (both man- and lightning-caused) (Hardy 2005). 

Fire Type – Flaming front patterns that are characteristic of a fire. 

First Order Fire Effects – Effects resulting directly from the fire, such as fuel consumption and 

smoke production. 

Forage – Browse and herbage which is available and can provide food for animals or be 

harvested for feeding; or to search for, or consume, forage (ITR 1734-4). 

Forbs – A broadleaved, herbaceous plant (e.g., columbine). 

Forest Health – The perceived condition of a forest derived from concerns about such factors as 

its age, structure, composition, function, vigor, presence of unusual levels of insects or disease, 

and resilience to disturbance. Note perception and interpretation of forest health are influenced by 

individual and cultural viewpoints, land management objectives, spatial and temporal scales, the 

relative health of the stands that comprise the forest, and the appearance of the forest at a point in 

time (SAF 2008). 

Fuel Loads – The amount of combustible material present per unit area. 

Group – A cluster of two or more trees with interlocking or nearly interlocking crowns at 

maturity surrounded by an opening. The size of tree groups is typically variable depending on 

forest community and site conditions and can range from fractions of an acre (a two-tree group) 

to many acres. Trees within groups are typically non-uniformly spaced, some of which may be 

tightly clumped (SAF 2008). 

Group Selection – A cutting procedure which creates a new age class by removing trees in 

groups or patches to allow seedlings to become established in the new opening (SAF 1998). 

Habitat: place where an animal or plant normally lives, often characterized by a dominant plant 

form or physical characteristic. Often described for individual species, e.g., spotted owl habitat, it 

is usually used as a generalization of where an animal may live (Fire Ecology Report 2013). 

Heritage Strategy – A strategy developed in consultation with the Arizona State Historic 

Preservation Officer to assist in reaching a “No Adverse Effect” determination for the project (see 

heritage specialist report). 

Heterogeneity – For the purposes of this analysis, heterogeneity refers to having bio-diversity in 

terms of habitat and forest structure across the landscape.

Historic Range of Variation (HRV) – Refers to ecosystem composition, structure, and process 

for a specified area and time period. Historic range of variation (HRV) is often used to determine 

our best estimate of “natural” conditions and functions, and thus is often our best estimate of the 

natural range of variation (NRV). Ecosystems change over time. It is assumed that native species 

have adapted over thousands of years to natural change and that change outside of NRV may 

affect composition and distribution of species and their persistence (4FRI Fire Ecology Report 

2013). 

Hydrologic Condition – The current state of the processes controlling the yield, timing, and 

quality of water in a watershed (FSM 2521.05). 
Glossary

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 511

Impaired Waters – Under section 303(d) of the 1972 Clean Water Act, states, territories, and 

authorized tribes are required to develop lists of impaired waters. These impaired waters do not 

meet water quality standards that states, territories, and authorized tribes have set for them, even 

after point sources of pollution have installed the minimum required levels of pollution control 

technology. The law requires that these jurisdictions establish priority rankings for waters on the 

lists and develop TMDLs for these waters. See the water quality and riparian specialist report for 

additional information. 

Invasive – any species which can establish, persist, and spread in an area, and be detrimental or 

destructive to native ecosystems, habitats, or species and difficult to control or eradicate. 

Ladder Fuel – Fuel, such as branches, shrubs, or an understory layer of trees, which allow a fire 

to spread from the ground to the canopy. 

Landscape-Scale – A spatial scale and extent expressed in geographic terms within which to 

target action, e.g., projects aimed at forest landscape restoration. In this analysis, the landscape 

scale for vegetation is the ponderosa pine extent. 

Large Tree – A large tree as defined in the revised Mexican Spotted Owl Recovery Plan (USDI 

2012) is a tree greater than 18-inch dbh. 

Litter – The top layer of the forest, shrubland, or grassland floor above the duff layer, including 

freshly fallen leaves, needles, bark, flakes, fruits (e.g., acorns, cones), cone scales, dead matted 

grass, and a variety of accumulated dead organic matter which is unaltered, or only slightly 

decomposed. This layer typically does not include twigs and larger stems. One rough measure to 

distinguish litter from duff is that you can pick up a piece of litter and tell what it was (a leaf or 

leaf part, a needle, etc.). Duff is generally not identifiable. There is a gradient, not a clear division 

between litter and duff. 

LOPFA – Landscapes outside of goshawk post-fledgling family areas as referenced in the Forest 

Plan. 

Management Area – The mission, goals, and objectives for the forest are realized by applying 

groups of management activities to specific units of land. Groups of management activities are 

called “prescriptions" and the land units are called "management areas." 

Mature Tree –A tree that has attained most of its potential height growth. 

Mechanical Treatment – Any activity (e.g., silvicultural thinning, biomass removal) performed 

by human-controlled tools (e.g., chainsaw, feller-buncher) that results in the removal or alteration 

of wood fiber. Does not include the use of fire. 

Mexican spotted owl habitat – Three levels of habitat management are described in the 

Recovery Plan: protected areas, restricted (recovery) areas; and other forest and woodland types. 

Monitoring – A systematic process of collecting and storing data related to natural systems at 

specific locations and times. Determining a system’s status at various points in time yields 

information on trends, which is crucial in detecting changes in systems. 

Mosaic – The spatial arrangement of habitat where there is stand heterogeneity, measured at 

many spatial scales from the patch, the stand, and the vegetative community.
Glossary

512 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Native species – a species which is an indigenous (originating where it is found) member of a 

biotic community. The term implies that humans were not involved in the dispersal or 

colonization of the species. 

Nest/Roost Recovery Habitat – Areas managed to replace nest/roost habitat lost to disturbance 

or senescence and to provide new nest/roost habitat for a recovering owl population (USDI 2012). 

Non-market Values – The benefits and values associated with National Forests that do not have 

a monetary price including clean water and air, biodiversity, forest products, and other goods and 

services. 

Nutrient Cycling (Soil) – The circulation of chemicals necessary for life, from the environment 

(mostly from soil and water) through organisms and back to the environment. 

Old Growth – The last stage in forest succession. Old-growth habitat is the sum of the physical 

and biological components of old-growth forest that are essential to maintaining populations of 

certain old growth dependent species of wildlife. 

Old Growth Protection and Large Tree Retention Strategy (OGP and LTRS) – Strategy 

developed by the 4FRI stakeholders in 2010 (finalized in 2011), which provides 

recommendations relating to the retention of large post-settlement and old growth trees. 

Passive Crown Fire – A fire in the crowns of the trees in which trees or groups of trees torch, 

ignited by the passing front of the fire. The torching trees reinforce the spread rate, but these fires 

are not basically different from surface fires. 

PFA – Goshawk post-fledgling family area as referenced in the Coconino Forest Plan. 

Pile Burning – Activity fuels, once piled by machine or by hand, are burned in place. 

Planned Ignition – The intentional initiation of a wildland fire by hand-held, mechanical, or 

aerial device where the distance and timing between ignition lines or points and the sequence of 

igniting them is determined by environmental conditions (weather, fuel, topography), firing 

technique, and other factors which influence fire behavior and fire effects (see prescribed fire). 

Pre-Commercial Thinning – The removal of trees not for immediate financial return but to 

reduce stocking to concentrate growth on the more desirable trees (SAF 2008). 

Prescribed Fire – A wildland fire originating from a planned ignition to meet specific objectives 

identified in a written, approved, prescribed fire plan for which NEPA requirements (where 

applicable) have been met prior to ignition (see planned ignition). 

Properly Functioning Condition (PFC) – A methodology for assessing the physical functioning 

of riparian and wetland areas. The term PFC is used to describe both the assessment process, and 

a defined, on-the-ground condition of a riparian-wetland area (National Riparian Service Team 

Definition, 2013).

Protected Habitat (Mexican Spotted Owl) – Protected habitat consists of protected activity 

centers (PACs) and reserved lands which include wilderness, research natural areas, wild and 

scenic rivers, and congressionally recognized wilderness study areas. The primary objective for 

protected habitat is the protection of the best available habitat for Mexican spotted owls while 

retaining management flexibility to abate high fire risk and to improve habitat conditions for the 

owl and its prey. 
Glossary

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 513

Proposed Action – In terms of the National Environmental Policy Act, the project, activity, or 

action that a Federal agency intends to implement or undertake (Coconino NF Forest Plan 

Glossary). 

Recovery Unit – A specific geographic area, identified mainly from physiographic provinces, 

used to evaluate the status of Mexican spotted owls and within which to develop specific 

management guidelines (USDI 2012). The recovery unit specific to this analysis is the Upper Gila 

Mountain Recovery Unit (RU), also referred to as the UGMRU. 

Recreational Opportunity Spectrum (ROS) – A classification system that describes different 

outdoor recreation settings across the forests using seven standard classes that range from 

primitive, undeveloped settings to urban, highly developed settings. Attributes typically 

considered in describing the settings are size, scenic quality, type, and degree of access, 

remoteness, level of development, social encounters, and the amount of on-site management. See 

the recreation and scenery report for additional information. 

Reference Condition (also referred to as Historic Reference Condition) – A range of 

conditions (found in the present or the past) against which the effects of past and future actions 

can be compared. These states can provide an explicit, historically-based context for comparing 

different management effects. Examples include periods before fire suppression or the arrival of 

an invasive species, or a similar but “healthier” modern ecosystem. Ideally, these environmental 

conditions are based on functioning ecosystems where natural ecosystem structure, composition, 

and function are operating with limited human intervention (very minor human-caused ecological 

effects). 

Regenerate – The act of renewing tree cover by establishing young trees naturally or artificially 

(SAF 2008). 

Residence Time – Time required for the flaming front of a fire to pass a stationary point at the 

surface of the fuel. The length of time the flaming front occupies one point; relates to downward 

heating and fire effects below the surface. 

Resiliency – The capacity of a (plant) community or ecosystem to maintain or regain normal 

function and development following disturbance (SAF 2008).

Resource Protection Measures – Measures (design features or mitigation) implemented to 

minimize nonpoint source pollution as outlined in the intergovernmental agreement between the 

Arizona Department of Environmental Quality and the Southwestern Region of the Forest Service 

(ADEQ 2008). 

Recovery Habitat (Mexican Spotted Owl) - Recovery habitat is ponderosa pine-Gambel oak 

habitat that does not meet the definitions of protected habitat, i.e., there are no known resident 

Mexican spotted owls, and is not considered a reserved land (e.g., designated wilderness, research 

natural areas, etc.). The objective in recovery habitat is to manage the landscape to maintain and 

create replacement owl habitat where appropriate while providing a diversity of stand conditions 

and stand sizes across the landscape. 

Riparian Area – Riparian ecosystems are distinguished by the presence of free water within the 

common rooting depth of native perennial plants during at least a portion of the growing season. 

Riparian ecosystems are normally associated with seeps, springs, streams, marshes, ponds, or 

lakes. The potential vegetation of these areas commonly includes a mixture of water (aquatic) and 

land (phreatic) ecosystems (Coconino NF Forest Plan Glossary). 
Glossary

514 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Road Decommission – Activities that result in the stabilization and restoration of unneeded roads 

to a more natural state (36 CFR 212.1, FSM 7705—Transportation System, USDA 2003). FSM 

7712.11- Exhibit 01 identifies five levels of treatments for road decommissioning which can 

achieve the intent of the definition. These include blocking the entrance, revegetation 

waterbarring, removing fills and culverts, establishing drainageways and removing unstable road 

shoulders, and full obliteration, recontouring, and restoring natural slopes. 

Road Reconstruction and Improvement – Any activity that results in an increase of an existing 

road’s traffic service level, expansion of its capacity, or a change in its original design function. 

Activities include, but are not limited to, the construction of bridges and major culverts, placing 

bar ditches, subgrade repairs, shoulder widening, lane widening, ditch widening, roadway prism 

widening, horizontal and vertical alignment changes, curve widening, and improving site distance 

at road intersections. Vegetation would likely be removed with these activities.

Road (Route) Obliteration – See road decommission. 

Road Realignment – Activity that results in a new location of an existing road or portions of an 

existing road and treatment of the old roadway. Generally, realignments are for the purpose of 

moving the road location to a more suitable area to mitigate impacts to streams, critical wildlife 

habitat, and other natural or cultural resources. Often, reconstruction is used interchangeably with 

road relocation. This activity includes creating a new road alignment in an upland position, 

installing the proper drainage features, signage, and surfacing on the new road alignment and the 

decommissioning of the old road alignment. The new road alignment would require the removal 

of vegetation at the new alignment site.

Scenery Management Systems (SMS) – Guidance developed by the Forest Service for 

managing scenery and determining the relative value and importance of scenery in the national 

forest (also see VMS and the scenery specialist report for additional information). 

Severity – The quality or state of distress inflicted by a force. The degree of environmental 

change caused by a disturbance (e.g., fire). 

Slash – The residue left on the ground after timber harvest or as a result of storms, fire, girdling, 

or poisoning. Slash includes unused logs, uprooted stumps, broken or uprooted stems and the 

heavier branchwood, lighter tops, twigs, leaves, bark, and chips. 

Snag – Standing dead tree from which the leaves or needles have fallen. 

Soil Function – The characteristic physical and biological activity of soils that influences 

productivity, capability, and resiliency (FSM 2521.05). 

Soil Productivity – The capacity of soil, in its normal environment, to support plant growth. 

(Soil) Tolerance – The point beyond which there is high risk that potential may be permanently 

altered or impaired through changes in specified physical, chemical, and biological factors 

brought about by management activities or natural events (FSM 2521.05). 

Spatial Pattern – Arrangement of forested areas and openings on the landscape. 

Spring – In this analysis, springs are natural water features that existed prior to Euro-American 

settlement and were probably functional due to lack of human disturbances (USDA 2009). 
Glossary

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 515

Stand – A contiguous area of trees sufficiently uniform in forest type, composition, structure, and 

age class distribution, growing on a site of sufficiently uniform conditions to be a distinguishable 

unit. Four classification characteristics are generally used to distinguish forest stands: biophysical site (soils, aspect, elevation, plant community association, climate, etc.), species 

composition, structure (density, and age (1-aged, 2-aged, uneven-aged)), and management 

emphasis (administrative requirements and local management emphasis that will shape structure 

over time). Based upon agency guidelines, the minimum stand mapping size is 10 acres. 

Stand Density – A measure of the degree of crowding of trees within stocked areas commonly 

expressed by various growing space ratios (e.g., height/spacing) (SAF 2008). 

Stand Density Index (SDI) – A measure of the stocking of a stand of trees based on the number 

of trees per unit area and diameter at breast height (dbh) of the tree of average basal area. It may 

also be defined as the degree of crowding within stocked areas, using various growing space 

ratios based on crown length or diameter, tree height or diameter, and spacing. The computed 

value of SDI is often compared to the species maximum to determine the relative "stand density" 

or stocking of the stand. 

Stand Structure – The horizontal and vertical distribution of components of a forest stand 

including the height, diameter, crown layers, and stems of trees, shrubs, herbaceous understory, 

snags, and down woody debris (SAF 2008). 

State Historic Preservation Office (SHPO) – The state office responsible for consultation and 

assistance regarding the presence and significance of cultural resources in a project area, efforts 

needed to find and evaluate them, whether the project will cause harmful effects to the cultural 

resource, and how to reduce or avoid the harm. 

Stratum/Strata (plural) – A layer of soil with internally consistent characteristics that 

distinguish it from other layers. 

Surface Fire – A fire that burns over the forest floor, consuming litter, killing aboveground parts 

of herbaceous plants and shrubs, and typically scorching the bases and crowns of trees. See also 

backing fire, crown fire, fire, flanking fire, ground fire, head fire, and understory fire. 

Surface Fuel – Fuels lying on or near the surface of the ground, consisting of leaf and needle 

litter, dead branch material, downed logs, bark, tree cones, and low stature living plants. See also 

duff, fuel, large woody debris, and litter. 

Target habitat -- a category of Mexican spotted owl recovery habitat intended to provide future 

nesting and roosting habitat (see definition for recovery habitat). A variety of forest structural 

attributes is used to define nesting and roosting habitat (summarized in table III.B.1 of the 

Recovery Plan and table C-2 of the draft Recovery Plan). The minimum values identified for the 

forest attributes represent the threshold for meeting nesting and roosting conditions (see the 

definition for threshold habitat). They can also be targets to be achieved with time and 

management. If less than 10 percent of the restricted habitat in ponderosa pine-Gambel oak 

qualifies as threshold habitat, the areas that can eventually achieve all threshold conditions 

simultaneously should be identified as target habitat and managed to achieve threshold 

conditions as rapidly as possible. Because no known Mexican spotted owl nests or roosts occur in 

restricted habitat, target habitat is considered future nesting and roosting habitat. 

Temporary Road or Trail – A road or trail necessary for emergency operations or authorized by 

contract, permit, lease, or other written authorization that is not a forest road or trail and that is 

not included in a forest transportation atlas (36 CFR 212).
Glossary

516 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Threatened and Endangered Species – Species identified by the Secretary of Interior in 

accordance with the 1973 Endangered Species Act, as amended. See the wildlife report for 

additional information. 

Threshold habitat - a category of Mexican spotted owl recovery habitat intended to provide for 

future nesting and roosting habitat (see definition for recovery habitat). A variety of forest 

structural attributes is used to define when nesting and roosting habitat is achieved (summarized 

in table III.B.1 of the Recovery Plan and table C-2 of the draft Recovery Plan). These values are 

targets that can be achieved with time and management (see definition for target habitat). When 

the minimum values identified for the forest attributes are met simultaneously, they represent the 

threshold of nesting and roosting conditions. Ten percent of restricted habitat in ponderosa pineGambel oak should be designated as threshold habitat. Management in threshold habitat cannot 

lower any of the forest attribute values below the nesting and roosting threshold unless a 

landscape analysis demonstrates an abundance of this habitat. Because no known Mexican 

spotted owl nests or roosts occur in restricted habitat, target habitat is managed as future nesting 

and roosting habitat. 

Total Maximum Daily Load (TMDL) – A written analysis that determines the maximum 

amount of a pollutant that a surface water can assimilate (the “load”), and still attain water quality 

standards during all conditions. The TMDL allocates the loading capacity of the surface water to 

point sources and nonpoint sources identified in the watershed, accounting for natural background 

levels and seasonal variation, with an allocation set aside as a margin of safety. See the Soil and 

Water Resources specialist report for additional information. 

Torching – See passive crown fire. 

Traditional Cultural Property (TCP) – Traditional use areas and places that have been used by 

cultural groups over generations. Natural springs are also considered TCPs and/or sacred sites by 

some tribes. Many plants are gathered for ceremonial on or near TCPs. 

Travel Management Rule (TMR) – On December 9, 2005, the Forest Service published the 

TMR. The agency rewrote direction for motor vehicle use on National Forest Service lands under 

36 CFR, Parts 212, 251, and 261, and eliminated 36 CFR 295. The rule was written to address at 

least in part the issue of unmanaged recreation. The rule provides guidance to the Forest Service 

on how to designate and manage motorized recreation on the Forests. The rule requires each 

National Forest and Grassland to designate those roads, motorized trails, and areas that are open 

to motor vehicle use. 

Trees Per Acre (TPA) – a count of the total number of trees on an acre. 

Unauthorized Road – A road that is not a forest road or a temporary road or trail and that is not 

included in a forest transportation atlas (36 CFR 212). 

Understory – The trees and other woody species growing under a more or less continuous cover 

of branches and foliage formed collectively by the upper portion of adjacent trees and other 

woody growth. In this analysis, the term understory is also referred to as “herbaceous 

understory.”

Uneven-aged Forests – Forests that are comprised of three or more distinct age classes of trees, 

either intimately mixed or in small groups. 

Uneven-aged Management – The application of a combination of actions needed to 

simultaneously maintain continuous high-forest cover, recurring regeneration of desirable 
Glossary

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 517

species, and the orderly growth and development of trees through a range of diameter or age 

classes (to provide a sustained yield of forest products). Cutting is usually regulated by specifying 

the number or proportion of trees of particular sizes to retain within each area, thereby 

maintaining a planned distribution of size classes. Cutting methods that develop and maintain 

uneven-aged stands are single-tree selection and group selection. 

Vegetation Structural Stage (VSS) – A method of describing forest age and tree size from 

seedling to old forests. The VSS classification is based on the tree size class with the highest 

square foot of basal area and is an indication of the dominant tree diameter distribution (see 

Forest Health and Structure section for details). 

Visual Management System (VMS) – The VMS was used to develop Visual Quality Objectives 

(VQOs) that are prescribed in the forest plan for all lands within the CNF. The VQO 

classifications range from Preservation, Retention, Partial Retention, Modification, to Maximum 

Modification. The VMS process has been updated in the Scenery Management System (SMS). 

See the scenery report for additional information. 

Watershed – The area that contributes water to a drainage or stream (Coconino NF Forest Plan, 

Glossary). 

Watershed Condition – The state of a watershed based upon physical and biological 

characteristics and processes affecting hydrologic and soil functions (FSM 2521.05). 

Watershed Condition Framework – A framework established by the Forest Service that 

provides a new consistent, comparable, and credible process for improving the health of 

watersheds on national forests and grasslands. The framework includes a technical guide which 

provides protocol for assessing watershed condition across all 193 million acres of National 

Forest System lands (http://www.fs.fed.us/publications/watershed). 

Water Quality – See Clean Water Act 

Water Yield – The total net amount of water produced including streamflow and groundwater 

Recharge (Coconino NF Forest Plan Glossary). 

Wildland Fire – A general term describing any non-structure fire that occurs in the wildland. 

Wildland Urban Interface (WUI) – The line, area, or zone where structures and other human 

development meet or intermingle with undeveloped wildland or vegetation fuels. WUI areas are 

spread across the project area and are located within or adjacent to the communities of Flagstaff. 

Woody Debris – The dead and downed material on the forest floor consisting of fallen tree 

trunks and branches.

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 519

Appendix A – Forest Plan Amendments

The following Forest Plan amendments are being done under the 2012 Planning Rule per 36 CFR 

219.17 (b)(2), which requires all Forest Plan amendments initiated after May 9, 2012 to utilize the 

2012 Planning Rule.

Amendment 1

Amendment 1 is a specific, one-time variance for managing MSO habitat in the FWPP project 

area. Once the project is complete, current Forest Plan direction would apply to the project area. 

The language proposed does not apply to any other forest project. 

Amendment 1 Description

Amendment 1 would update the terminology referring to MSO habitat types to reflect that of the 

2012 MSO Recovery Plan. Specifically, this amendment would update the definition of protected

habitat to exclude pine-oak and mixed conifer forests with slopes greater than 40 percent where 

timber harvest has not occurred in the last 20 years and instead including these areas as recovery 

habitat, and change “restricted” habitat to “recovery” habitat. 

This amendment would allow mechanical thinning within PACs and restricted habitat to reduce 

the risk of high-severity wildfire. Amendment 1 would change the treatment diameter limit of 9 

inches dbh to 18 inches dbh in ten MSO PACs29, and would allow the removal of larger trees 

(greater than 18 inches dbh in PACs and 24 inches dbh in recovery habitat) for cable corridor 

locations under Alternative 2 only. 

Amendment 1 would also allow hand thinning in the Schultz Creek nest core up to 5 inches dbh, 

and prescribed burning treatments within all MSO nest cores. The amendment would remove 

language referencing monitoring (pre- and post-treatment, population, and habitat); replacement 

language would defer to a monitoring plan developed specifically for this project by the Forest 

Service, U.S. Fish and Wildlife Service (FWS), and the Ecological Restoration Institute of 

Northern Arizona University. The monitoring plan is included in this document as Appendix B, 

and includes the details for sample selection, treatment specifics, measurement protocols

including timing, and planned analyses. The proposed monitoring plan would also pair treated 

and untreated (reference) PACs within the Dry Lake Hills and Mormon Mountain portions of the 

project and compare occupancy rates, reproduction rates, and habitat changes. Reference PACs 

would match the environmental conditions in PACs where treatments are proposed, as closely as 

possible. The monitoring plan would be finalized in conjunction with FWS consultation.

The amendment would allow the MSO nest roost recovery area identified within the project area 

to be treated to meet the minimum habitat requirements for MSO nest roost recovery habitat 

under the 2012 revised MSO Recovery Plan. 

Amendment 1 would also remove timing restrictions on treatments within ten MSO PACs for two 

breeding seasons in order to more quickly accomplish implementation and to limit the duration of 

impacts to MSO. Treatments would be prioritized to be accomplished within one to two breeding 

seasons, and would be coordinated with FWS. No one PAC would be treated for more than two 

 

29 Ten PACs within the FWPP boundary: De Toro’s, Lockwood, Moore Well, Mormon Mountain, Mormon Mountain 

North, Weimer Springs, Schultz Creek, Mount Elden, Orion Spring, and Weatherford 2
Appendix A – Forest Plan Amendments

520 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

breeding seasons. If treatments within a PAC extend beyond the two year timeframe, timing 

restrictions would apply for the subsequent years (March 1 – August 31). 

Timing restrictions would still apply for activities in nest cores, including hand thinning within 

the Schultz Creek nest core and prescribed burning within all nest cores.

Need for Plan Amendment

MSO PAC field reviews, data evaluation, and vegetation simulation modeling indicate that there 

is a need to mechanically thin trees greater than 9 inches dbh in ten PACs and greater than 24 

inches dbh in recovery habitat within the project boundary in order to facilitate treatments to 

achieve the purpose and need of the FWPP project: to reduce the risk of high-intensity wildfire 

and subsequent flooding. 

There is a need to treat within MSO nest/cores to remove fuels and reduce the risk of 

ecologically-damaging wildfire as leaving these areas untreated would not meet the purpose and 

need, and could also hinder the feasibility of prescribed burning in PACs. Lining the core areas 

would be expensive in terms of time, money, and other resource commitments, and would still 

leave these areas vulnerable to high-intensity wildfire. There is a need to treat MSO nest roost 

recovery habitat to meet the minimum habitat requirements for MSO nest roost recovery habitat 

under the 2012 revised MSO Recovery Plan due to the existing forest structure and to put that 

habitat on a trajectory toward desired conditions. 

There is a need to replace the monitoring language specified in the Forest Plan in order to better 

incorporate a monitoring plan tiered to the revised MSO Recovery Plan (USFWS 2012) and 

developed by the Forest Service, the Fish and Wildlife Service, and the Ecological Restoration 

Institute of Northern Arizona University. Monitoring assesses the effectiveness of management 

actions and provides the adaptive framework needed to develop successful management by 

assisting in determining the effects of thinning and burning on Mexican spotted owls and their 

habitat. The monitoring plan will be reviewed as part of the consultation process for treatments 

planned to occur within PACs.

Edited or added/new text is bolded in Table 150. Current Forest Plan direction related to MSO 

that would not be changed under this amendment is not included below. 

Table 150: Amendment 1: Current and Proposed MSO Forest Plan Language

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

MSO Standards

No corresponding direction currently exists. The Flagstaff Watershed Protection Project 

will comply with the biological opinion and 

monitoring protocol developed in 

consultation with the FWS.

Provide three levels of habitat management –

protected, restricted, and other forest and 

woodland types to achieve a diversity of habitat 

conditions across the landscape (p. 65).

Provide three levels of habitat management –

protected, recovery, and other forest and 

woodland types to achieve a diversity of habitat 

conditions across the landscape (p. 65).

Protected areas include delineated protected 

activity centers; mixed conifer and pine-oak 

forests with slopes greater than 40% where 

timber harvest has not occurred in the last 20 

years; and reserved lands which include 

wilderness, research natural areas, wild and 

Within the Flagstaff Watershed Protection 

Project boundary, protected areas include 

delineated protected activity centers; and 

reserved lands which include wilderness, 

research natural areas, wild and scenic 

rivers, and congressionally recognized 
Appendix A – Forest Plan Amendments

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 521

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

scenic rivers, and congressionally recognized 

wilderness study areas (Coconino NF Forest 

Plan, p. 65).

wilderness study areas. Recovery habitat 

includes pine-oak and mixed conifer forests 

on all slopes (Coconino NF Forest Plan, p. 

65).

Limit human activity in protected activity 

centers during the breeding season (Coconino 

NF Forest Plan, p. 65). 

Limit human activity in protected activity centers 

during the breeding season, except for the 

following PACs where implementation of 

treatments may occur the Flagstaff 

Watershed Protection Project boundary for 

no more than two breeding seasons: De 

Toro’s, Lockwood, Moore Well, Mormon 

Mountain, Mormon Mountain North, 

Weimer Springs, Schultz Creek, Mount 

Elden, Orion Spring, and Weatherford 2.

In protected and restricted areas, when 

activities conducted in conformance with these 

standards and guidelines may adversely affect 

other threatened, endangered, or sensitive 

species or may conflict with other established 

recovery plans or conservation agreements; 

consult with US Fish and Wildlife Service to 

resolve the conflict (Coconino NF Forest Plan, 

p. 65-1). 

In protected and recovery areas, when 

activities conducted in conformance with these 

standards and guidelines may adversely affect 

other threatened, endangered, or sensitive 

species or may conflict with other established 

recovery plans or conservation agreements; 

consult with US Fish and Wildlife Service to 

resolve the conflict (Coconino NF Forest Plan, 

p. 65-1). 

Monitor changes in owl populations and habitat 

needed for delisting (Coconino National Forest 

Plan, page 65-1). 

Monitoring of owl populations and habitat 

within the Flagstaff Watershed Protection 

Project boundary will follow the monitoring 

protocol developed and finalized through 

that project’s consultation with the US Fish 

and Wildlife Service.

MSO Guidelines

Harvest fuelwood when it can be done in such 

a way that effects on the owl are minimized. 

Manage within the following limitations to 

minimize effects on the owl (Coconino NF 

Forest Plan, p. 65-2). 

Retain key forest species such as oak. 

Retain key habitat components such as snags 

and large downed logs. 

Harvest conifers less than 9 inches in diameter 

only within those protected activity centers 

treated to abate fire risk as described below, 

except for the Clark PAC where trees less than 

16 inches diameter will be harvested. 

Harvest fuelwood when it can be done in such 

a way that effects on the owl are minimized. 

Manage within the following limitations to 

minimize effects on the owl (Coconino NF 

Forest Plan, p. 65-2). 

Retain key forest species such as oak. 

Retain key habitat components such as snags 

and large downed logs. 

Harvest conifers less than 9 inches in diameter 

only within those protected activity centers 

treated to abate fire risk as described below, 

except for the Clark PAC where trees less than 

16 inches diameter will be harvested and the

following PACs within the Flagstaff 

Watershed Protection Project boundary, 
Appendix A – Forest Plan Amendments

522 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

where trees up to 18 inches dbh will be 

harvested: De Toro’s, Lockwood, Moore 

Well, Mormon Mountain, Mormon 

Mountain North, Weimer Springs, Schultz 

Creek, Mount Elden, Orion Spring, and

Weatherford 2 PACS. Where cable logging 

occurs, all trees may be removed within 

cable logging corridors, including those 

above 18 inches in PACs and above 24 

inches in recovery habitat.

Treat fuel accumulations to abate fire risk. 

–Select for treatment 10% of the protected 

activity centers where nest sites are known in 

each recovery unit having high fire risk 

conditions. Also select another 10% of the 

protected activity centers where nest sites are 

known as a paired sample to serve as control 

areas (Coconino National Forest Plan, page 65-

2). 

–Designate a 100 acre "no treatment" area 

around the known nest site of each selected 

protected activity center. Habitat in the no 

treatment area should be as similar as possible 

in structure and composition as that found in 

the activity center. 

–Use combinations of thinning trees less than 9 

inches in diameter (or less than 16 inches in the 

Clark PAC), mechanical fuel treatment and 

prescribed fire to abate fire risk in the 

remainder of the selected protected activity 

center outside the 100 acre "no treatment" area. 

Treat fuel accumulations to abate fire risk. 

–Select for treatment 10% of the protected 

activity centers where nest sites are known in 

each recovery unit having high fire risk 

conditions. Also select another 10% of the 

protected activity centers where nest sites are 

known as a paired sample to serve as control 

areas (Coconino National Forest Plan, page 65-

2). 

–Designate a 100 acre "no treatment" area 

around the known nest site of each selected 

protected activity center. Habitat in the no 

treatment area should be as similar as possible 

in structure and composition as that found in 

the activity center. Within the Flagstaff 

Watershed Protection Project boundary, 

allow prescribed hand thinning of trees less 

than 5 inches dbh in 80% of the Schultz 

Creek nest core and prescribed burning in 

the following nest cores within the project 

boundary outside of the MSO breeding 

season: De Toro’s, Lockwood, Moore Well, 

Mormon Mountain, Mormon Mountain 

North, Weimer Springs, Schultz Creek, 

Mount Elden, Orion Spring, and 

Weatherford 2.

–Use combinations of thinning trees less than 9 

inches in diameter (or less than 16 inches in the 

Clark PAC), mechanical fuel treatment and 

prescribed fire to abate fire risk in the 

remainder of the selected protected activity 

center outside the 100 acre "no treatment" area 

except as follows:

Use combinations of thinning trees up to 18 

inches dbh within : De Toro’s, Lockwood, 

Moore Well, Mormon Mountain, Mormon 

Mountain North, Weimer Springs, Schultz 
Appendix A – Forest Plan Amendments

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 523

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

Creek, Mount Elden, Orion Spring, and 

Weatherford 2 PACs, mechanical fuel 

treatment and prescribed fire to abate fire in the 

remainder of the selected protected activity 

center outside the 100-acre nest core area. 

Treat fuel accumulations to abate fire risk. Pre 

and post treatment monitoring should be 

conducted in all protected activity centers 

treated for fire risk abatement. (See monitoring 

guidelines) (Coconino National Forest Plan, 

page 65-2). 

Monitoring of owl populations and habitat 

within the Flagstaff Watershed Protection 

Project boundary will follow the monitoring 

protocol developed and finalized through 

that project’s consultation with the US Fish 

and Wildlife Service.

Mixed Conifer and Pine-oak Forests (See 

glossary definition): Manage to ensure a 

sustained level of owl nest/roost habitat well 

distributed across the landscape. Create 

replacement owl nest/roost habitat where 

appropriate while providing a diversity of stand 

conditions across the landscape to ensure 

habitat for a diversity of prey species. The 

following table displays the minimum 

percentage of restricted area which should be 

managed to have nest/roost characteristics. The 

minimum mixed conifer restricted area 

includes 10% at 170 basal area and an 

additional amount of area at 150 basal area. 

The additional area of 150 basal area is +10% 

in BR-E and +15% in all other recovery units. 

The variables are for stand averages and are 

minimum threshold values and must be met 

simultaneously. In project design, no stands 

simultaneously meeting or exceeding the 

minimum threshold values should be reduced 

below the threshold values unless a districtwide or larger landscape analysis of restricted 

areas shows that there is a surplus of restricted 

area acres simultaneously meeting the 

threshold values. Management should be 

designed to create minimum threshold 

conditions on project areas where there is a 

deficit of stands simultaneously meeting 

minimum threshold conditions unless the 

district-wide or larger landscape analysis shows 

there is a surplus. This table has been modified 

to contain only information pertinent to the 

Coconino NF. (Coconino NF Forest Plan, 

pp.65-3 to 65-5). 

Mixed Conifer and Pine-oak Forests (See 

glossary definition): Manage to ensure a 

sustained level of owl nest/roost habitat well 

distributed across the landscape. Create 

replacement owl nest/roost habitat where 

appropriate while providing a diversity of stand 

conditions across the landscape to ensure 

habitat for a diversity of prey species. Nest 

roost recovery habitat in the Flagstaff 

Watershed Protection Project would be 

treated to meet or exceed the minimum 

habitat requirements for MSO nest roost 

recovery habitat under table C3 in the 2012 

revised MSO Recovery Plan. The variables 

are for stand averages, are minimum threshold 

habitat values, and must be met 

simultaneously. In project design, no stands 

simultaneously meeting or exceeding the 

minimum nest roost recovery habitat values 

should be reduced below threshold values 

unless a district-wide or larger landscape 

analysis of restricted areas shows that there is a 

surplus of restricted area acres simultaneously 

meeting threshold values. Management should 

be designed to create minimum threshold 

conditions on project areas where there is a 

deficit of stands simultaneously meeting 

minimum threshold conditions unless the 

district-wide or larger landscape analysis shows 

there is a surplus of restricted area acres 

simultaneously meeting the threshold values. 

Management should be designed to create 

minimum threshold conditions on project areas 

where there is a deficit of stands 

simultaneously meeting minimum threshold 

conditions unless the district-wide or larger 
Appendix A – Forest Plan Amendments

524 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

landscape analysis shows there is a surplus. 

This table has been modified to contain only 

information pertinent to the Coconino NF.

(Coconino NF Forest Plan, pp.65-3 to 65-5).

Current Coconino NF Forest Plan Direction Proposed New Standard or Guideline

Amendment 2

Amendment 2 Description

Amendment 2 would remove language restricting mechanical equipment to slopes less than 40 

percent and language identifying slopes above 40 percent as inoperable. This amendment would 

allow mechanical harvesting on slopes greater than 40 percent within the project area.

Need for Plan Amendment

It would be necessary to allow for use of specialized mechanical equipment to cut and remove 

trees on steep slopes to reduce the risk of high-severity wildfire in this project area due to the 

preponderance of areas with greater than 40 percent slope in the project area. Furthermore, since 

the Forest Plan was written and amended, mechanized ground-based equipment has progressed to 

be able to operate on steep slopes more effectively. While this specialized equipment is not 

commonplace in this region due to the high cost of its use, the approval of the City bond makes 

the use of such equipment a possibility for this project. In order to be able to utilize such 

equipment to treat slopes above 40 percent in the project area and meet the purpose and need, this 

Forest Plan amendment is needed.

Edited or added/new text is bolded in Table 151.

Table 151: Amendment 2: Current and Proposed Steep Slope Forest Plan 

Language

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

Inoperable Lands: Timber lands, usually 

greater than 40 percent slope, not meeting the 

Forest cable logging criteria. See Operable 

Lands for criteria definition (p. 252).

Inoperable Lands: Timber lands, usually 

greater than 40 percent slope, not meeting the 

Forest cable logging criteria and outside of 

the Flagstaff Watershed Protection Project 

boundary. See Operable Lands for criteria 

definition.

Operable Lands: Timbered lands, usually 40 

percent slope and greater, meeting the forest 

cable logging criteria. The cable logging criteria 

are: cut per acre must be 3 MMBF30 or greater; 

maximum yarding distance not to exceed 1,300 

feet (slope distance); volume from contiguous 

cable logging area must be at least 1 MMBF; 

sale area must also contain a minimum of 1 

Operable Lands: Timbered lands, usually 40 

percent slope and greater, meeting the forest 

cable logging criteria or within the Flagstaff 

Watershed Protection Project boundary. 

The cable logging criteria for areas outside of 

the Flagstaff Watershed Protection Project 

are: cut per acre must be 3 MMBF or greater; 

maximum yarding distance not to exceed 1,300 

 

30 MMBF (million board feet): A symbol to indicate one million board feet of wood fiber volume either in log form or 

after conversion to lumber (Forest Plan, p. 256)
Appendix A – Forest Plan Amendments

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 525

Current Forest Plan Direction Proposed New Standard or Guideline 

Language for FWPP

MMBF of conventional logging volume, or no 

less than a 50-50 mix; multi-span yarding is not 

required, and cable yarding areas must be 300 

to 400 acres in size to meet the cut per acre 

and 1 MMBF requirement (p. 258). 

feet (slope distance); volume from contiguous 

cable logging area must be at least 1 MMBF; 

sale area must also contain a minimum of 1 

MMBF of conventional logging volume, or no 

less than a 50-50 mix; multi-span yarding is not 

required, and cable yarding areas must be 300 

to 400 acres in size to meet the cut per acre 

and 1 MMBF requirement. Within the 

Flagstaff Watershed Protection Project 

area, harvesting activities are not confined 

by the cable logging criteria above, but 

rather are defined by that project’s NEPA 

analysis and decision. 
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 526
Appendix B – Monitoring Protocols

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 527

Appendix B – Monitoring Protocols

Proposed Mexican Spotted Owl Monitoring

As FWPP, fuels reduction and prescribed burning activities will occur within Mexican spotted 

owl protected activity centers (PACs). Protected activity centers are occupied habitat. The 

effects of these treatments to owls and nesting/roosting habitat are not fully known. The Mexican 

spotted owl Recovery Team thinks that PACs can be afforded substantial protection by 

emphasizing fuels reduction and forest restoration in surrounding areas outside of PACs and

nest/roost habitat, it is recognized that in some cases protection of nest/roost habitat and human 

communities requires these action to occur within PACs. The Mexican Spotted Owl Recovery 

Plan, First Revision (USFWS 2012) provides guidance for these treatments and emphasizes the 

need for monitoring and feedback loops to allow management to be adaptive. Well-designed 

monitoring will provide valuable information on the effects of these activities on the owls and 

their habitat. Therefore, the Forest Service is working with the U.S. Fish and Wildlife Service 

(FWS) and Rocky Mountain Research Station (RMRS) to propose a monitoring plan that should 

help us begin to understand the effects of thinning and burning on Mexican spotted owls and their 

habitat.

The proposed monitoring plan would pair treated and untreated (reference) PACs (treatments still 

to be determined) within the Dry Lake Hills (n=3) and Mormon Mountain (n=5) portions of the 

project and compare occupancy rates, reproduction rates, and habitat changes. 

Guiding Question:

Do planned treatments (e.g., thinning, prescribed fire) affect occupancy and reproductive 

rates in treated versus untreated PACs? 

Identified Response Variables:

Owl occupancy rate (corrected for detection probability; the percent of PACs occupied 

before and after treatments).

Owl reproductive output (the number of fledglings observed per adequately checked pair 

before and after treatments).

Habitat change (the immediate effect of a treatment type on key variables selected from 

Table C.1 showing description of desired conditions [DCs]) in forest and woodland cover 

types typically used by Mexican spotted owls for nesting and roosting. Analysis would 

incorporate what is retained as well as extent of change.

Planned Treatments:

Treatments will likely be variable in spatial extent and intensity (intensity measured by 

degree of change in key habitat variables related to DCs [see Table C.1]). 

General Study Design Approach:

For each treatment areas (Dry Lake Hills and Mormon Mountain) monitoring will 

contrast a set of reference PACs (with no planned treatments) to a set of treatment PACs. 
Appendix B – Monitoring Protocols

528 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Reference PACs will match the environmental conditions in PACs where treatments are 

proposed, as closely as possible.

o For the Mormon Lake project area treatments are proposed for the following 

PACs: Mormon Mountain North (040508), Red Raspberry (040503), Archies 

(040534), Weimer Springs (040532), and Detoros (040533). Reference PACs 

still need to be determined. Since the proposed areas for treatment are 

predominately mixed conifer, controls need to be similar. Three potential 

reference PACs Mormon Mountain (040551), Lockwood (040541), Moore Well 

(Rock Dike) (040511) overlap with the project area (149, 148, and 20 acres 

respectively. However, we may be able to use these PACs by proposing 

treatments that occur later in time or slightly modifying the project boundary. 

Lockwood PAC also overlaps with the identified potential “reference watershed” 

for a study being conducted in 4FRI. Two other possible reference PACs that do 

not occur within the project area are Dairy Spring (040507) and Mayflower Tank 

(040522). 

o For the Dry Lake Hills project area three PACs are proposed for treatment: Mt.

Elden (040202), Schultz Creek (040206), and Orion Spring (040207). Three 

potential reference PACs are: Snowbowl (040205)/Viet (040234), Little Spring 

(040227), and East Bear Jaw (040233).

PACs may be stratified by treatment type (once we know treatment types)

Sampling Considerations:

Identify set of PACs for a planned type of treatment.

Identify set of reference PACs for each geographic area and cover type.

Sample response variables for owls each year, using a design that allows estimation of 

effects to occupancy, detection probability, reproductive output, and habitat DCs.

Sample timing: one year pre-treatment, during treatment year, and one, three, and five 

years post-treatment.

Identify DC variables (Table C.1) that measure habitat change to calibrate treatment 

effects.

Potential Analytic Approaches:

Will depend on sample size.

Possibilities include: In development

Quality Control / Assurance

A monitoring plan will be written that includes the details for sample selection, treatment 

specifics, measurement protocols including timing, and planned analyses.

The monitoring plan will be reviewed as part of the consultation process for treatments 

planned to occur within PACs.
Appendix B – Monitoring Protocols

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 529

Red Squirrel Monitoring Plan

Red Squirrel Monitoring Proposal

9/30/2013

Prepared by: Fenner Yarborough and Andi Rogers, Arizona Game and Fish Department

Purpose and Need

The Flagstaff Watershed Protection Project (FWPP) is a cooperative effort between the City of 

Flagstaff, US Forest Service, and the State of Arizona to treat 15,000 acres. The primary purpose 

of the FWPP is to reduce the risk of high severity wildfire and subsequent flooding in two key 

watersheds around Flagstaff, Arizona: in the Dry lake Hills portion of the Rio de Flag Watershed, 

and the Mormon Mountain portion of the Upper Lake Mary Watershed. Treatments will include 

traditional logging, hand thinning, prescribed fire, helicopter logging, and cable logging. 

Red squirrels (Tamiasciurus hudsonicus) are primarily associated with mixed conifer forest in the 

Southwest. The red squirrel is a Management Indicator Species for the Coconino National 

Forest. Red squirrels play an important role in forest ecology and restoration, as they are 

excellent indicators of changes as a result of forest treatments. Red squirrels require a forest 

structure that provides large areas of closed canopy and large trees that produce an abundant cone 

crop. The purpose of this study is to initiate monitoring of red squirrels (Tamiasciurus 

hudsonicus) on the Coconino National Forest in order to establish long-term trends in populations 

and habitat use and the effects of forest restoration on red squirrels.

Study Sites

We would generate geographic information system (GIS) vegetation cover maps for conifer forest 

stands within the FWPP study area. We would locate study sites within GIS cover types white 

fir, Douglas fir, blue spruce, and Engelmann spruce. We would preferentially select large stands 

(big enough to contain two 600 m x 10 m) belt transects. We would place the trance starting 

point and bearing to insure that each transect was fully contained within the stand and well away 

from forest edges.

Methods

An index of red squirrel density will be determined by counting active, primary middens on each 

of two belt transects in a study site. One squirrel normally maintains and defends one primary 

midden. Thus, the density of active primary middens is a conservative estimate of squirrel 

density. Midden activity can provide a means for monitoring red squirrels in large areas. We 

would use active midden density in belt transects as an estimate of population size. 

We would follow the methods set up by Frey (2003) and set up two belt transects in each study 

area. The belt transects (600 m x 10 m) would be located throughout the FWPP project area that 

contain red squirrel habitat. The observer would walk each transect, maintain a bearing, and look 

for red squirrel middens within 5 m of each side of the transects. We would record data on each 

midden (size, age, activity, and location). We would collect habitat data related to forest structure

at random points along each transect. 

Analysis

We would test if red squirrel midden density differed by cover or vegetation type. We would 

determine if squirrel midden density changed pre and post treatment. We would also summarize 

mean tree density and size class (DBH) to summarize stand size structure of dominant conifer 

tree species across all red squirrel sampling transects pre and post treatment.

Expected Results

Our expected results could help refine habitat relationship patterns in order to better direct forest 

management in ways that will benefit this species.
Appendix B – Monitoring Protocols

530 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Literature Cited

Frey, Jennifer K. 2003. Initiation of Red Squirrel (Tamiasciurus hudsonicus) Monitoring on 

Carson National Forest, New Mexico. A Final contract R3-02-03-12 Completion Report 

Submitted to Carson National Forest, Taos, New Mexico.

Fire, Fuels & Air Quality

MONITORING FOR PRESCRIBED FIRE

The purpose of this document is to outline the protocols and standards used by fuels and fire 

personnel to monitor the fire effects on ecosystem components within areas burned by prescribed 

fire on the Flagstaff Ranger District of the Coconino National Forest.

Specific protocols have been developed from a combination of the Firemon and FSVeg protocols 

and following the DRAFT Region 3 Vegetation Monitoring/Sampling Protocols (updated 

December 2008) included in this 3 ring binder. The forest characteristics that are measured pre 

and post fire/prescribed burn and prescribed fire protocols are described below in detail and 

include overstory trees, pole sized tree or saplings, seedlings, snags, fuel loading, and CBI 

(composite burn index which assessed burn severity) which is solely performed postfire and 

under special severe wildfire or prescribed fire situations. CBI methodology and protocols will 

only be implemented when the District Fuels Specialist deemed necessary.

Prescribed Fire monitoring- CBI plot monitoring would not be performed for prescribed fire 

unless the fuel specialist has deemed it necessary. The following criteria can help with making 

the decision: Prescribed burn is >1000 acres and/or a broad range of fire effects resulted from the 

burn. 

All hard copies of data sheets/data collected needs to be stored in the 3 ring monitoring 

binder for each project area. Data sheets and photos should be placed in sheet protectors. 

Protectors would help maintain sheets when they are taken out into the field for postburn 

monitoring. 

All data should be entered into FSVeg as soon as possible after monitoring has been 

completed (pre and post). Tessa Nicolet can help with teaching how to set up criteria for 

entering and accessing data in FSVeg database. A NRM FSVeg profile (roles 

established- I think Shawn Martin is the contact) will need to be established in order to 

input data into FSVeg. 

Quality assurance of data collected needs to be performed. This requires Fuels Crew 

leader visiting each plot and ensuring that data collected by crew members has met within 

error range indicated on data collection sheets.

Error compared to plot checker: DBH (+ 0.2 in), Height (+ 2 ft), Crown Ratio (+ 

5%), CBH (+ 1 ft)

If plot checker finds many errors with the data, the plot needs to be remeasured. Any 

comments need to be made regarding differences in transect direction and/or plot center 

needs to regpsed using the averaging feature if the coordinates do not agree with actual 
Appendix B – Monitoring Protocols

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 531

location. These new coordinates need to be recorded on the data sheet and on plot 

location map. 

All pictures should be downloaded/saved onto the FS network drive as soon as possible 

after monitoring has been completed. Photos of plots preborn and postburn should also 

be printed out and placed in monitoring three-ring binder. Photos can be helpful in 

locating the plot especially if elk or other wildlife have ripped out rebar of the plot. 

During burning:

A FEMO/FOBs or someone who can spin weather/record weather observations and take 

pictures throughout the burn should be designated for every prescribed burn and during 

shifts when plots burn in a managed fire situation.

These weather observations and during burning photos should be filed in the 3 ring 

monitoring folder for that particular project area. 

It is also ideal if a burn boss packet is placed in the during burning section of the 3 ring 

binder to keep track of any special circumstances or additional information that may be 

useful during analysis of the pre and post-burn data.
Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 532
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 533

Appendix C – Law, Regulation & Policy 

Compliance

Fire, Fuels and Air Quality 

National Level Direction

Federal laws, regulations, and policies affecting this project include: 

Executive Order 13112; Invasive Species (64 FR 6183, February 8, 1999). The FWPP

proposes ground disturbing activities, such as mechanical thinning, and prescribed fire 

which may provide opportunities for invasive species to become established. To comply 

with this Executive Order, FWPP would monitor populations within the treatment area, 

and restore native species and habitat conditions in areas that are invaded. 

Organic Administration Act, June 4, 1897 (16 U. S. C. 551). This act authorizes the 

Secretary of Agriculture to make provisions for the protection of national forests against 

destruction by fire. The treatments proposed by FWPP would support the intent of the 

Organic Administration Act by reducing the potential for undesirable fire behavior and 

effects. 

National Environmental Policy Act of 1970. Compliance with this act requires analysis of 

proposed actions. Proposed treatments include prescribed fire and mechanical treatments, 

so the analysis includes the effects of prescribed fire as well as the resulting emissions. 

Clean Air Act (CAA), as amended 1977 and 1990. This act provides for the protection 

and enhancement of national air resources by regulating air emissions from stationary and 

mobile sources. This law authorized EPA to establish National Ambient Air Quality 

Standards (NAAQS) to protect public health and welfare and to regulate emissions of 

hazardous air pollutants. NAAQS were established for specific pollutants emitted in 

significant quantities throughout the country that may be a danger to public health and 

welfare. If an area does not meet or “attain” the standards, it becomes a non-attainment 

area and must demonstrate to the public and the EPA how it will meet standards in the 

future via a State Implementation Plan (SIP). Section 112 of the CAA addresses 

emissions of hazardous air pollutants, including smoke from wildfires and prescribed 

fires. Section 160 of the CAA requires measures “to preserve, protect, and enhance the air 

quality...” in national parks, national wilderness areas, national monuments, and other 

areas of special national or regional natural, recreational, scenic, or historic value, some 

are classified as Class I attainment areas. Implementation of the CAA is largely the 

responsibility of the states which may develop programs that are more restrictive than the 

CAA requires but never less. The CAA mandates states have a SIP to regulate pollutants. 

The FWPP proposes using prescribed fire on 8,938 acres. To ensure compliance with the 

CAA, emissions from these acres were evaluated to determine the potential effects. 

The “1995 Federal Wildland Fire Policy” is the principle document guiding fire management on 

Federal lands. The Policy was endorsed and implemented in 1995. The 1995 Federal Wildland 

Fire Policy was reviewed and updated in 2001 (Review and Update of the 1995 Federal Wildland 

Fire Management Policy, 2001). In 2003 the Interagency Strategy for the Implementation of 

Federal Wildland Fire Management Policy was approved. The 2003 Implementation Strategy was 

replaced in 2009 with the adoption of the Guidance for Implementation of Federal Wildland Fire 
Appendix C – Law, Regulation & Policy Compliance

534 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Management Policy which states that:

“Fire, as a critical natural process, will be integrated into land and resource management plans 

and activities on a landscape scale, and across agency boundaries. Response to wildland fire is 

based on ecological, social, and legal consequences of fire. The circumstances under which a fire 

occurs, and the likely consequences on firefighter and public safety and welfare, natural and 

cultural resources, and values to be protected dictate the appropriate management response to 

fire.”

The FWPP is not intended to dictate the appropriate response to wildfires. Action alternatives 

should increase the decision space for Agency Administrators for how to managed lightning 

caused fires when they occur, while reducing the potential for undesirable fire behavior and 

effects. The effects of planned ignitions (prescribed fires) are discussed. This document provides 

direction, consistent with the Coconino Forest Plan regarding the use of planned ignitions in the 

proposed treatment area.

State Level Direction

Arizona Department of Environmental Quality (ADEQ) air quality regulations: Smoke 

produced by prescribed fires is subject to regulation by EPA regulations as enforced by the 

ADEQ. The State of Arizona has a State Implementation Plan that outlines how the State is 

implementing the goals of the Clean Air Act, and Statutes that regulate burning, including burning 

on Federal lands. Two types of air quality impacts are addressed by these laws and regulations: 

health hazards from pollutants, and potential visibility impacts in Class I Air Sheds. 

The key policy resulting from the Enhanced Smoke Management Plan pertaining to prescribed 

burns in Arizona is Arizona Revised Statute Title 18 Chapter 2 Article 15. This law regulates fires 

managed on Federal and State lands, as well as on Tribal, private, and municipal jurisdictions 

where there is a Memorandum of Understanding with the Arizona Department of Environmental 

Quality (ADEQ). This Statute defines the request and approval process for all burns, and provides 

the mechanisms for tracking emissions from burns. Enforcement of this statute is facilitated by 

the Smoke Management Group, housed at ADEQ in the Air Quality Division. Prescribed fires 

implemented as treatments under the FWPP will be subject to these same regulatory policies and 

statutes and meet the Enhanced Smoke Management Plan. The State of Arizona has an Enhanced 

Smoke Management Plan (ESMP) that is consistent with the Western Regional Air Partnership 

(WRAP) Enhanced Smoke Management Programs for Visibility. The State of Arizona conducts 

annual meetings of all affected parties to discuss smoke management issues and objectives. This 

approach calls for programs to be based on the criteria of efficiency, economics, law, emission 

reduction opportunities, land management objectives, and reduction of visibility impacts. An 

Enhanced Smoke Management Plan (ESMP) comprises a series of key policies and management 

practices. In general the ESMP must specifically address visibility effects and apply to all fire 

sources as do all smoke management plans in the State of Arizona. The ESMP should also apply 

uniformly to source sectors or be tailored to source sectors and/or geographical areas. In addition, 

the ESMP must provide the opportunity to work collaboratively with state, tribal, local, and 

federal agencies, and private parties while considering the criteria of efficiency, economics, law, 

emission reduction opportunities, land management objectives, and reduction of visibility impact. 

Problem or Nuisance Smoke is defined by the Environmental Protection Agency (EPA) as the 

amount of smoke in the ambient air that interferes with a right or privilege common to members 

of the public, including the use or enjoyment of public or private resources. While there are no 

laws or regulations governing nuisance smoke, it can limit opportunities of land managers to use 
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 535

fire. Public concerns regarding nuisance smoke often occur long before smoke exposures reach 

levels that violate NAAQS (Achtemeir et al. 2001). “Probably the most common air quality issues 

facing wildland fire managers are those related to public complaints about nuisance smoke...about 

the odor or soiling effects of smoke, poor visibility, and impaired ability to breathe or other 

health-related effects. Sometimes complaints come from the fact that some people don’t like or 

are fearful of smoke intruding into their lives (Hardy et al. 2001b).” Prescribed fire treatments 

proposed though the action alternatives may result in an increase of Nuisance Smoke. 

Agency Level Direction

USDA Forest Service

Forest Service Manual 5100 (page 9) includes direction on USFS use of prescribed fire to meet 

land and resource management goals and objectives. The objectives of fire management on lands 

managed by the USFS are:

1. Forest Service fire management activities shall always put human life as the single, 

overriding priority.

2. Forest Service fire management activities should result in safe, cost-effective fire 

management programs that protect, maintain, and enhance National Forest System lands, 

adjacent lands, and lands protected by the Forest Service under cooperative agreement. 

Coconino National Forest Land & Resource Management Plan (Forest Plan)

Forest Plans provide specific goals, objectives, standards, and guidelines for management 

activities on National Forest lands. The Coconino National Forest (USDA 1987, as amended 

2012) has developed forest-wide and location-specific standards and guidelines for reducing the 

risk of severe fire effects to resources. 

The Forest Plan provides specific goals, objectives, standards, and guidelines for management 

activities on the Coconino National Forest. The forest-wide, management area (MA), or 

geographic area (GA) standards and guidelines have fire-related (management of or reduced risk 

to resources values from) relevance to this analysis. Directions for other resources aimed at 

reducing the risk of fire have been incorporated into this analysis as appropriate. 

Forest Structure and Health

Compliance with Forest Plan and Other Relevant Laws, Regulations, Policies and Plans 

Multiple-Use Sustained Yield Act of 1960. Requires that national forest lands shall be 

administered for a variety of multiple uses, and that all resources shall be maintained as 

renewable in perpetuity for regular periodic output of several products and services at a 

sustainable level.

National Environmental Policy Act of 1969 (NEPA). Established procedures for decision making, 

disclosure of effects, and public involvement on all major federal actions.

National Forest Management Act of 1976 (NFMA). The Coconino forest plan was developed in 

accordance with NFMA, as expressed by the 1982 planning rule.

While federal laws like the National Forest Management Act establish the regulatory 

requirements of forest management for federal agencies, the detailed direction that affects the 

project-level vegetation analysis being undertaken in this proposed action are contained in the 
Appendix C – Law, Regulation & Policy Compliance

536 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

forest plans for the Coconino National Forest (USDA 1987, as updated 2008). These include the 

goals, objectives, direction, and Forest-wide and Management Area standards and guidelines that 

have relevance to the proposed action.

Coconino National Forest Plan Management Areas

The project area includes 11 Management Areas (MA) as described in the Coconino NF forest 

plan (pp. 46 to 206-113). The two main management areas comprising the project include: 

Ponderosa pine and mixed conifer on less than 40 percent slopes (MA-03) makes up 

approximately 5,509 acres; and Ponderosa pine and mixed conifer on greater than 40 percent 

slopes (MA-04) makes up approximately 3,734 acres of the project area. The other management 

areas that are in the project area include: Aspen (MA-05) 91 acres; Unproductive Timber Land 

(MA-06) 672 acres; Pinon-Juniper Woodlands, greater than 40 percent slope (MA-08) 15 acres; 

Mountain Grasslands (MA-09) 46 acres; Grasslands and sparse Pinyon-Juniper Above the Rim 

(MA-10) 140 acres; Elden Environmental Study Area (MA-18) 268 acres; and Electronic Sites 28 

acres. An additional 40 acres is classified as private lands which were formerly private but are 

now Forest Service land. In addition two additional management areas overlay the above listed 

management areas. In the Dry Lake Hills part of the project the Schultz management area (MA36) overlays most of the project area. In the Mormon Mountain part of the project the Lake Mary 

Watershed Management Area (MA-35) also overlays most of this part of the project area. 

Insect and Disease Management - Cuts are designed to eliminate or reduce dwarf mistletoe 

infections to manageable levels (CFP, page70).

Integrated Stand Management (ISM) - Establish and maintain stand diversity through ISM to 

provide suitable habitat for wildlife in lands suitable for timber production, while maintaining or 

enhancing timber resource production and timber age class distribution (CFP, page70).

Uneven-aged management will be emphasized (CFP, MA3, page 123).

Manage oak to improve wildlife habitat. Maintain oak components wherever they occur (CFP, 

MA3, page 131).

The alligator juniper component of the ponderosa pine is managed primarily for maintaining and 

enhancing wildlife habitat (CFP, MA3, page 132).

Reduce competition between closely spaced trees in some areas, to promote future large trees 

faster and to achieve desired tree sizes and canopy closures outlined in the Forest Plan (Mexican 

spotted owl and northern goshawk habitat guidelines) (CFP, FLEA, page 206-75).

Reduce competition between closely spaced trees in some areas to promote health and resistance 

to insects and disease (CFP, FLEA, page 206-75).

Table 12. Vegetation Management Practices for ponderosa pine, oak and aspen vegetation types 

as it applies to uneven-aged harvest systems , stand improvement thinning, intermediate thinning, 

and prescribed burning (CFP, page 242-19).

Region Wide Forest Plan Amendment

Forest vegetation management direction in the Coconino National Forest Land Management Plan 

(USDA 1987, as updated 2008) was amended in 1996 through a region-wide amendment of all 

forest plans in Arizona and New Mexico (USDA 1996).
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 537

Mexican Spotted Owl Recovery Plan

A revised Mexican spotted owl recovery plan was developed and signed by the US Fish and 

Wildlife Service in December of 2012. This project will be utilizing the management 

recommendations in the revised recovery plan. 

Elements that relate to forest vegetation operations for the Mexican spotted owl include:

Provide habitat management for protected activity centers (PACs) and recovery habitat. Within 

PACs additional management consideration is given to the nest/roost core. Recovery habitat is 

classified into nest/roost and foraging/non-breeding. Recovery habitat includes all mixed-conifer, 

pine-oak, and riparian outside of PACs.

The revised MSO recovery plan identifies stand-replacing wildfires as the primary threat to 

spotted owl habitat. Management recommendations are outlined in the recovery plan in appendix 

C (pp 249 – 298) to guide land managers with reducing the fire risk within the PACs and 

recovery habitat. 

Protected activity centers (PACs)

All activities within the PAC should undergo consultation with the appropriate FWS office

No mechanical or prescribed fire during the breeding season

Removal of hardwoods, downed woody debris, snags, and other key habitat variables should 

occur only when compatible with owl habitat management objectives as documented through 

reasoned analysis

Light burning of surface and low-lying fuels may be allowed following careful review by 

biologist and fuel-management specialist. Generally, burns should be done during non-breeding 

season.

Mechanical treatments may be needed to reduce fire risk to owl/nest roost habitat. As a general 

guide, forest management programs in PACs should be structured as follows:

Conduct a landscape-level fire risk assessment to strategically locate and prioritize mechanical 

treatment units to mitigate the risk of large wildland fires while minimizing impact to PACs. 

Treatments should also strive to mimic natural mosaic patterns.

No mechanical or prescribed fire treatments should occur during the breeding season unless the 

PAC is unoccupied.

Recovery Habitats

Manage a minimum of 10% of the pine-oak and 25% of the mixed conifer for nest/roost habitat.

Manage recovery habitat for all stages of ecological succession. Maintain a mosaic of 

successional stages across the landscape.

Assess existing conditions at multiple spatial scales.

Treatments within recovery habitat nest/roost stands which meet the minimum desired conditions 

outlined on Table C.3 on page 278 of the MSO Revised Recovery Plan will not lower the 

conditions below those thresholds.
Appendix C – Law, Regulation & Policy Compliance

538 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

It is recommended that trees larger than 18 inches dbh not be removed in nest/roost recovery 

stands.

Maintain species diversity and allow for variation in stand structures including early seral species.

Strive to retain all trees greater than 24 inches dbh. Remove only to protect human safety and or 

property, or in situations where leaving large trees precludes reducing threats to owl habitat.

To the extent practical treatments should be designed to avoid the removal of trees over 18 inches 

dbh.

In pine-oak forests, retain existing large oaks and promote growth of additional oaks.

Northern Goshawk

Elements that relate to northern goshawk forest habitat apply to the forest and woodland 

communities described below that are outside of Mexican spotted owl protected activity centers 

and recovery habitat areas:

Manage for uneven-age forest conditions for live trees and retain live reserve trees, snags, 

downed logs, and woody debris levels throughout woodland, ponderosa pine, mixed conifer, and 

spruce-fir forest cover types. Manage for old age trees such that as much old forest structure as 

possible is sustained over time across the landscape. Sustain a mosaic of vegetation densities 

(overstory and understory), age classes and species composition across the landscape. 

Limit human activity in or near nest sites and Post-Fledgling Family Areas (PFAs) during the 

breeding season (March 1 through September 30).

The distribution of vegetation structural stages for ponderosa pine, mixed conifer and spruce-fir is 

10% grass/forb/shrub (VSS 1), 10% seedling-sapling (VSS 2), 20% young forest (VSS 3), 20% 

mid-aged forest (VSS 4), 20% mature forest (VSS 5), 20% old forest (VSS 6). Distribution of 

habitat structures should be evaluated at the ecosystem management area level, at the midscale 

such as drainage, and at the small scale of site.

Landscapes Outside Goshawk PFAs: 

Ponderosa pine: canopy cover for mid-aged forest (VSS 4) should average 40+%, mature forest 

(VSS 5) should average 40+%, and old forest (VSS 6) should average 40+%. Maximum opening 

size is up to 4 acres with a maximum width of up to 200 feet. Retain 1 group of reserve trees per 

acre of 3-5 trees per group for openings greater than 1 acre in size. Leave at least 2 snags per acre, 

3 large downed logs per acre, and 5-7 tons of woody debris per acre. Snags are 18 inches or larger 

dbh and 30 feet or larger in height, downed logs are 12 inches in diameter and at least 8 feet long, 

woody debris is 3 inches or larger on the forest floor, canopy cover is measured with vertical 

crown projection on average across the landscape. 

Identify and manage dispersal PFA and nest habitat at 2 to 2.5 mile spacing across the landscape.

Within PFAs:

Ponderosa pine: canopy cover for mid-aged forest (VSS 4) should average 1/3 60+% and 2/3 

50+%. Mature (VSS 5) and old forest (VSS 6) should average 50+%. 
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 539

Within Nesting Areas:

Thin from below with non-uniform spacing. Lopping and scattering of thinning debris is 

preferred if prescribed fire cannot be used. Piling of debris should be limited.

Elements that relate to forest vegetation operations for old growth allocation:

Seek to develop or retain old growth function on at least 20% of the naturally forested area by 

forest type in any landscape.

All analyses should be at multiple scales-one scale above and one scale below the ecosystem 

management areas.

Soil & Water Resources

Implementation of a proposed amendment to the Forest Plan to allow mechanical treatments in 

MSO PACs beyond 9 inches dbh, treatments in MSO restricted habitat above 24 inches dbh, and 

treatments and prescribed burning within MSO nest/cores would result in improved vegetative 

ground cover over the long term by providing conditions conducive to the establishment of a 

more vigorous understory of grasses, forbs and shrubs. This increased vegetative ground cover 

would improve nutrient cycling and soil stability while reducing the risks to soils, water quality, 

and watershed function from the effects of a high severity fire. Proposed population and habitat 

monitoring would not pose a risk to soil, watershed function, and water quality.

Implementation of a proposed amendment to allow mechanical harvesting on slopes greater than 

40 percent within the project area would facilitate thinning within the project area ultimately 

resulting in improved soil functioning and reducing the threat posed by a high severity fire to 

water quality, soil productivity and watershed function. Since the Forest Plan was written and 

amended, mechanized ground-based equipment has progressed to be able to operate on steep 

slopes without adverse impacts to soil resources. 

Table 152: Soil & Water Resource Compliance with Forest Plan and Other Relevant 

Laws, Regulations, Policies and Plans

MANAGEMENT 

AREAS (MA)

DESCRIPTION Standards and Guidelines FLMP page

Forest-wide Forest-wide Use Best Management Practices to 

reduce nonpoint source pollution

Amendment 3, 

replacement 

page 71

Forest-wide Forest-wide Plan for appropriate filter strips 

adjacent to streamcourses and/or 

riparian areas

Amendment 3, 

replacement 

page 71

Forest-wide Forest-wide Designate streamcourses and 

riparian areas to receive protection 

during projects

Amendment 3, 

replacement 

page 72

Forest-wide Forest-wide Maintain current satisfactory 

watershed conditions and improve 

unsatisfactory conditions to 

satisfactory by the year 2020.

Page 74

Forest-wide Forest-wide Plan projects, parts of projects, 

and/or management practices for soil 

and water resources improvement 

where watershed condition is 

unsatisfactory. Incorporate plans for 

Amendment 3, 

replacement 

page 72
Appendix C – Law, Regulation & Policy Compliance

540 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

MANAGEMENT 

AREAS (MA)

DESCRIPTION Standards and Guidelines FLMP page

soil and water improvements into 

project planning for other resources

3 Ponderosa Pine 

and Mixed 

Conifer less than 

40% slopes

Identify each terrestrial ecosystem 

and assess soil properties to 

determine:

Erosion hazard and on-site soil loss -

Soils with a potential erosion hazard 

rating of severe will require specific 

resource management activities in 

order to avoid severe impairment of 

soil productivity.

Amendment 

17, 

replacement 

page 120

Forest Plan p 

146

3 Ponderosa Pine 

and Mixed 

Conifer less than 

40% slopes

For each timber sale area, identify 

each terrestrial ecosystem and 

assess soil properties to determine:

Soils with severe potential for 

sheet and gully erosion, such as 

steep slopes, cinder cones, 

alluvial bottoms, and swales, that 

require specific resource 

management activities in order to 

avoid severe impairment of soil 

productivity.

Soil limitations for site preparation 

- Identify soils that present severe 

limitations for successful site 

preparation such as soils with 

severe erosion hazard and 

shallow soils. Require specific 

resource management activities 

where successful site preparation 

is limited by environmental factors 

in the terrestrial ecosystem.

Soil potential for reforestation -

Identify soils that are suitable or 

unsuitable for successful 

reforestation. Adjust stocking 

levels and require specific 

resource management activities 

where successful reforestation is 

limited by environmental factors in 

the terrestrial ecosystem.

Whether soils are suitable, 

unsuitable, or unproductive for 

timber management.

Soil limitations for timber harvest 

activities.

Soils with high potential to convert 

to another vegetative type such as 

oak, locust, or juniper as a result 

of timber management activities -

Modify timber management 

activities in these terrestrial 

Amendment 1, 

replacement 

page 136
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 541

MANAGEMENT 

AREAS (MA)

DESCRIPTION Standards and Guidelines FLMP page

ecosystems conversion by 

approved chemical or mechanical 

means or by prescribed fire.

3 Ponderosa Pine 

and Mixed 

Conifer less than 

40% slopes

Where open meadows in the 

pine/mixed conifer type are to be 

maintained, eliminate invading 

overstory vegetation, stabilize gullies 

to raise the water table, scarify the 

soil, and seed with appropriate grass 

and forage species. Control 

livestock grazing through 

management and/or fencing to 

establish the revegetation.

Amendment 

17, 

replacement 

page 120

3 Ponderosa Pine 

and Mixed 

Conifer less than 

40% slopes

Avoid or designate stream course 

crossings for skid trails. Limit to the 

minimum needed. Choose crossings 

with stable conditions or stable bed and 

bank material such as cobble or rock.

Amendment 1, 

replacement 

page 136

3 Ponderosa Pine 

and Mixed 

Conifer less than 

40% slopes

Restrict skidding and hauling to soil 

moisture conditions that do not cause 

excessive soil compaction, displacement, 

or puddling. 

Amendment 1, 

replacement 

page 136

9 Mountain 

Grassland

Manage mountain grasslands to 

achieve 90 percent of potential 

ground cover to prevent accelerated 

surface erosion and gully formation. 

Areas that presently do not meet 

these standards are scarified and 

seeded to bring ground cover to the 

desired level by the second decade. 

Restricting livestock may be 

necessary until revegetation.

Forest Plan,

P 160

9 Mountain 

Grassland

Identify each terrestrial ecosystem 

and assess soil properties to 

determine:

Soil potential for revegetation -

Identify soils that are suitable or 

unsuitable for successful 

revegetation, erosion hazard, and 

on-site soil loss. Soils with a 

potential erosion hazard rating of 

severe will require specific resource 

management activities in order to 

avoid severe impairment of soil 

productivity.

Forest Plan,

P 160
Appendix C – Law, Regulation & Policy Compliance

542 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Wildlife

Regulatory Framework

The Forest Service is legally required to comply with a number of federal regulatory requirements 

associated with various sections of the Endangered Species Act of 1973, as amended (ESA); the 

Bald and Golden Eagle Protection Act of 1940, as amended; Forest Service Manuals (FSM) 2620, 

2630, 2670, and 2672; Migratory Bird Treaty Act of 1918 (as amended); Executive Order 13186

(migratory birds), National Environmental Policy Act, 1969; National Forest Management Act, 

1976 (as amended); and the Coconino National Forest Land and Resource Management Plan 

(Forest Plan), 1987 (as amended).

The Endangered Species Act (ESA)

The Endangered Species Act (ESA) of 1973, as amended, provides that all Federal agencies 

utilize their authorities to carry out programs for the conservation of listed species. It prohibits 

any Federal agency from carrying out any action that is likely to jeopardize the continued 

existence of any listed species. It further requires federal agencies to consult with the Fish and 

Wildlife Service (FWS) on actions that are authorized, funded, or carried out by such agencies 

that may affect listed species and/or their designated critical habitat. The ESA mandates 

conference with the Secretary of the Interior whenever an action is likely to jeopardize the 

continued existence of any species proposed for listing as threatened or endangered, or whenever 

an action might result in destruction or adverse modification of critical habitat proposed for

listing.

Bald and Golden Eagle Protection Act (Eagle Act)

The Eagle Act, originally passed in 1940, prohibits the take, possession, sale, purchase, barter, 

offer to sell, purchase, or barter, transport, export, or import, of any bald or golden eagle, alive or 

dead, including any part, nest, or egg, unless allowed by permit (16U.S.C 668(a);50CFR 22).

“Take” is defined as to “pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest, 

or disturb” a bald or golden eagle. The term “disturb” under the Eagle Act was defined via a final 

rule published in the Federal Register on June 5, 2007 (72 Fed. Reg.31332). “Disturb” means to 

agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause, based on the

best scientific information available: 1) injury to an eagle; 2) a decrease in its productivity, by

substantially interfering with normal breeding, feeding, or sheltering behavior; or 3) nest 

abandonment, by substantially interfering with normal breeding, feeding, or sheltering behavior. 

The Fish and Wildlife Service recommends using the Conservation Assessment and Strategy for 

Bald Eagles in Arizona (Driscoll et al. 2006) in conjunction with the Bald Eagle National

Management Guidelines (USFS 2007) to protect bald eagles in Arizona.

Forest Service (FS) Sensitive Species

Sensitive species are defined as "those plant and animal species identified by a Regional Forester 

for which population viability is a concern, as evidenced by: 1) significant current or predicted 

downward trends in population numbers or density, or 2) significant current or predicted 

downward trends in habitat capability that would reduce a species' existing distribution (FSM 

2670.5(19)). It is the policy of the Forest Service regarding sensitive species to 1) assist states in 

achieving their goals for conservation of endemic species, 2) as part of the National 

Environmental Policy Act process, review programs and activities, through a biological 

evaluation, to determine their potential effect on sensitive species, 3) avoid or minimize impacts 

to species whose viability has been identified as a concern, 4) if impacts cannot be avoided, 

analyze the significance of potential adverse effects on the population or its habitat within the
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 543

area of concern and on the species as a whole (the Line Officer, with project approval authority, 

makes the decision to allow or disallow impacts, but the decision must not result in loss of species 

viability or create significant trends toward federal listing), and 5) establish management 

objectives in cooperation with the state when projects on National Forest system lands may have

a significant effect on sensitive species population numbers or distributions. Establish objectives 

for federal candidate species, in cooperation with the U.S. Fish and Wildlife Service and Arizona

State (FSM 2670.32).

Management Indicator Species (MIS)

A working draft forest-wide assessment entitled “Management Indicator Species Status Report 

for the Coconino National Forest” (USDA 2013) summarizes current knowledge of population 

and habitat trends for management indicator species on the Coconino National Forest. Additional 

site specific Game Management Unit (GMU) population information was provided by Arizona

Game and Fish Department with their annual survey results.

Migratory Bird Treaty Act

Executive Order 13186 (January 10, 2001) requires federal agencies to consider management 

impacts to migratory birds. Birds considered for these analyses were selected from species of

concern as listed by Partners in Flight (Latta, et al. 1999) and the USFWS Birds of Conservation 

Concern (USFWS 2009) and the determination of possible impacts that would occur if any one of 

the alternatives were implemented is disclosed. 

Coconino National Forest Land Management Plan (Forest Plan)

The Forest Plan determines standards and guidelines for snags and downed logs, wildlife cover, 

raptor nest buffers, old growth, turkey nesting and roosting habitat, and bear habitat. It also 

incorporates the 1996 Mexican Spotted Owl Recovery Plan and Northern Goshawk Management 

Recommendations. Two project-specific, non-significant amendments to the Coconino National 

Forest Land Management Plan are proposed for each action alternative. The first amendment 

would ensure the treatments proposed in MSO habitat align with the 2012 MSO Recovery Plan 

and would also remove timing restrictions within MSO PACs for the duration of the FWPP 

project. The second allows for mechanized harvest on slopes greater than 40 percent within the 

project area (see Appendix A for Forest Plan amendment descriptions). 

Scenery

Policy

Forest Service Handbook (FSH) 1909.13.13a, Chapter 10: “When pertinent to the issues...the 

Scenery Management System (SMS) should be used to describe...desired conditions and 

objectives.”

FSH 1909.13.2.3: “...”Also, see FSM 2380.61 for landscape aesthetics guidance.”

Forest Service Manual (FSM) 2380.43.5 “Ensure application of the principles of landscape 

aesthetics, scenery management, and environmental design in project level planning”

FSM 2380.61 “Refer to the following publications in the Department of Agriculture’s National 

Forest Landscape Management Series for technical guidance in managing landscape aesthetics 

and scenery.” The pertinent publication is USDA Ag Handbook 701, “Landscape Aesthetics: A 

Handbook for Scenery Management”. This Handbook directs identification of Desired Scenic 

Character (page 1-3 and 5-5), as does its most recent update “Appendix J Recommended SMS 

Refinements” 2007, and the “Region 5 SMS Implementation Process” 5/2009.
Appendix C – Law, Regulation & Policy Compliance

544 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

FSM 2020.5 “Sustainability. Meeting needs of the present generation without compromising the 

ability of future generations to meet their needs. Sustainability is composed of desirable social, 

economic, and ecological conditions or trends interacting at varying spatial and temporal scales, 

embodying the principles of multiple-use and sustained-yield (FSM 1905).”

The following USDA handbooks establish a framework for management of scenic resources.

These handbooks were written when the visual management system (VMS) was in place. 

Although the VMS has now been replaced by the scenery management system, the handbooks 

still apply to management of scenic resources.

National Forest Landscape Management Volume 1. Agriculture Handbook 434: 1973

Roads, Chapter 4, Agriculture Handbook 483: 1977

Timber, Chapter 5, Agriculture Handbook 559: 1980

Fire, Chapter 6, Agriculture Handbook 608: 1985

Recreation, Chapter 8, Agriculture Handbook 666: 1987

Landscape Aesthetics, A Handbook for Scenery Management, Agriculture Handbook 701: 

revised 2000.

Forest Service manual direction provides further clarification to utilize the Scenery Management 

System in forest and project planning and implementation, including sections 2380.3, 2382, and 

2382.3: 

2380.3, Policy: It is Forest Service policy to: 

Inventory, evaluate, manage, and, where necessary, restore scenery as a fully integrated part of 

the ecosystems of National Forest System lands and of the land and resource management and 

planning process.

Employ a systematic, interdisciplinary approach to scenery management to ensure the integrated 

use of the natural and social sciences and environmental design.

Ensure scenery is treated equally with other resources.

Apply scenery management principles routinely in all National Forest System activities.

2382, Scenery Management: Managing scenery on National Forest System lands entails:

1. Completing and maintaining an inventory of landscape aesthetics and scenery resources. 

Establishing goals and objectives for the management of scenery on all National Forest 

System lands.

2382.3 - Forest Plan Revisions and Scenery Management System

Update the scenery inventory using the Scenery Management System in Agriculture Handbook 

701 (FSM 2380.61, para. 2). The recommended timeframe for updating the scenery inventory is 

prior to or at initiation of Forest land and resource management plan revisions.

The table below summarizes the existing Forest Management Plan direction. It is followed by the 

proposed Revised Forest Management Plan direction
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 545

Table 153: Summary of the existing Forest Plan management direction for scenery (Forest 

Service 1987)

DESCRIPTION Forest Plan Management Direction FLMP page

Goals Maintain and enhance visual resource values by including 

visual quality objectives in resource planning and 

management activities.

Replacement 

p.22

Forest-wide Projects are planned to meet or exceed visual quality 

objectives (VQO).

Review the VQO inventory as a part of project planning 

and make necessary corrections/refinements following 

field checking. Use VQO inventory to analyze impacts to 

VQO classes due to management activities such as timber 

sales, range projects, and firewood sales. Use the current 

Forest Visual Resource Management Inventory that lists 

VQO Forest-wide in conjunction with Forest Plan MA 

Map and descriptions to plan projects.

Allow only one classification movement downward unless 

a larger movement is justified after doing an environmental 

analysis for emergency situations such as removal of fire 

damaged timber or I&DC control needs.

Replacement 

p.60

Forest-wide ...design timber management activities to integrate 

considerations for economics, water quality, soils, wildlife 

habitat, recreation opportunities, visual quality, and other 

values.

Replacement 

p.23

Ponderosa Pine 

and Mixed 

Conifer less than 

40% slopes

Stand size, except managed old-growth stands, foreground 

Retention areas, or stands resulting from catastrophic 

events, such as wildfires or epidemic insect infestation, is 

between 10 and 100 acres unless larger or smaller stands 

are approved by the Forest Supervisor. Exceptions are 

stands managed for conversion to aspen and those managed 

as Gambel Oak nonindustrial wood, which can be as small 

as 5 acres and 1 acre, respectively and have maximum 

sizes of 10 and 40 acres, respectively. Also stands having a 

VQO of foreground Retention can be 2.5 acres. Stands are 

defined in the environmental documentation (ISM Phase 

IX) and documented in the timber sale project plan (ISM 

Phase X). Silvicultural treatments are designed to improve 

age class distribution within a 10K Block. The goal is to 

attain differences between adjacent timber stands by the 

time the first regeneration period is completed, which is 

Replacement Pg. 

129


Appendix C – Law, Regulation & Policy Compliance

548 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

The Coconino NF is in the process of revising its forest management plan. A review of the current 

draft (Forest Service 2013) includes the following information:
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 549

Ponderosa 

Pine

Desired 

Conditions

At landscape scale:

1. Ponderosa Pine has a mosaic of trees with varying age classes 

and understory vegetation which provide habitat for a variety of 

species, including Mexican spotted owls and northern goshawks, 

and ground fuels conducive to low-severity fires. 

2. The composition, structure, and function of vegetation 

conditions are resilient to the frequency, extent, and severity of 

disturbances and climate variability that is similar to conditions 

prior to 1850 (pre-fire disruption

17

). The landscape is a 

functioning ecosystem that contains its components, processes, 

and conditions that result from endemic levels of disturbances 

(e.g. insects, diseases, fire, and wind), including snags, downed 

logs, and old trees. Grasses, forbs, shrubs, and needle cast (e.g., 

fine fuels), and small trees maintain the natural fire regime. 

Organic ground cover and herbaceous vegetation provide 3 

Frequent, low-severity fires (Fire Regime I) are characteristic in 

this PNVT, including throughout northern goshawk home ranges. 

Spatial heterogeneity and discontinuous crowns (interspaces 

between groups and single trees) prevents fire spread. Natural 

and human disturbances are sufficient to maintain desired overall 

tree density, structure, species composition, coarse woody debris, 

and nutrient cycling. 

4. At the landscape scale and as shown in table 9, Ponderosa 

Pine is composed of trees in structural stages that range from 

young to old and are dominated by ponderosa pine trees. Forest 

appearance is variable but generally uneven-aged and open; 

occasional areas of even-aged structure are present. Forest 

arrangement is in individual trees, small clumps, and groups of 

trees interspersed within variably sized openings of grasses, 

forbs, and shrubs that are similar to historic patterns. Openings 

typically range from 10 percent in more productive sites to 70 

percent in the less productive sites. The size and shape of trees, 

number of trees per group, and number of groups per area are 

variable across the landscape. Denser tree conditions exist in 

some locations such as north-facing slopes and canyon bottoms. 

protection of soil, moisture infiltration, and contribute to plant 

and animal diversity and to ecosystem function.

5. Ponderosa Pine is composed predominantly of vigorous trees, 

but declining trees are a component. Declining trees are well 

distributed across the landscape and may occur as clumps or 

individual trees. They provide for snags, top-killed, lightningscarred and fire-scarred trees, and coarse woody debris (greater 

than 3-inch diameter, including large logs). 

6. Old growth structure occurs throughout the landscape, 

generally in small areas as individual old-growth components, or 

as clumps of old growth. Consistent with vegetative 

characteristics of a frequent, low severity fire regime, old growth 

is a component of uneven-aged forests, generally comprised of 

groups of similarly aged trees and single trees interspersed with 

open grass–forb–shrub interspaces, but occasionally, it occurs in 

larger even-aged patches where local microsites facilitate less 

frequent fire regimesWithin group variability may be low but 

Pg. 52-54
Appendix C – Law, Regulation & Policy Compliance

550 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Desired 

Conditions 

for Scenic 

Resources

1. The scenic values of the Coconino NF are conserved and 

enhanced. Visitors see that the forest is being actively managed 

through visual cues such as seeing firebreaks with native 

wildflowers, grasses, and forbs; some fire effects; and tree 

thinning to frame views from trails and developed recreation 

sites. 

2. Vegetation treatments contribute to the scenic integrity of the 

desired landscape character (see chapter 3, “Management 

Areas”), especially in highly sensitive areas. Managementcreated debris, such as slash along Concern Level 1 and 2 travel 

routes, are located and arranged to minimize their visual 

disturbance in the immediate foreground (up to 300 feet), and 

slash piles in that immediate foreground are not evident once they 

are burned or scattered. Openings and stand boundaries are 

naturally shaped and are oriented to contours and existing 

vegetation patterns to blend with existing landscape 

characteristics, except where other natural resource concerns 

require minimal treatment along powerline corridors.

5. Long term soil and plant productivity, proper functioning 

ecosystems, and clean water are considered important 

components of scenic quality. Rock pits, borrow areas, open pit 

mines, and restored gullies have very low scenic integrity and are 

not seen from visually sensitive travelways and viewing points to 

the extent possible. Cultural and historic features, young cinder 

cones, and lava flows are recognized for their inherent scenic 

values. Native plant rehabilitation is carried out in disturbed areas 

to speed scenic quality recovery. Natural land forms and 

vegetation are used, to the extent possible, to screen facilities 

from important viewing locations such as scenic trails and 

byways.

Pg. 113-114

Objectives 

for Scenic 

Resources

1. Rehabilitate at least 25,000 acres that do not meet the desired 

scenic integrity objective (SIO) by at least one level within 15 

years of plan approval.

Pg. 114
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 551

Guidelines 

for Scenic 

Resources

1. To maintain SIOs, management activities that are inconsistent 

with the SIO and whose effects persist in the long term should not 

occur unless a decision is made to change the SIO44. Site-specific 

exceptions can be made based on lower site productivity, soil 

conditions, and climate without changing the SIO. Additional 

mitigation measures may be needed in these cases. 

2. To maintain consistency with the Scenery Management 

System in the long-term: 

• Deviations45 in areas with high SIO should not be evident even 

if they are present. 

• Deviations in areas with moderate SIO should be allowed but 

remain visually subordinate to the landscape being viewed. 

• Deviations in areas with low SIO should borrow valued 

attributes from the landscape being viewed, even though the 

deviations may begin to dominate the views. 

4. Visually attractive live and dead trees, some large woody 

debris, and understory shrubs foreground (half a mile or less)

should be favored when leaving vegetation in the of Concern 

Level 1 and 2 travel routes in order to enhance the desired 

landscape character.

5 Stems should be flush cut, if possible, or cut less than 6 inches 

above ground (uphill side) in the immediate foreground (300 feet 

or less) of Concern Level 1 and 2 travel routes where topography 

and operational safety allows in order to minimize the scenic 

impact of management activities. 

6. When possible, new log landings, roads, and designated skid 

trails should be located out of view of Concern Level 1 and 2 

travel routes to avoid observation of bare mineral soil. When 

avoiding these locations is not possible, the evidence of these 

activities should be restored following completion of the activity 

to harmonize with the surrounding landscape. 

7. To minimize disruption of the visual landscape, straight lines 

and geometric shapes should be avoided at the edges of openings 

and stand boundaries. 

8. Evidence of fire activitiesshould be dominant for no more 

than 3 years after burning in areas of high scenic integrity and 5 

years in moderate scenic integrity in order to maintain SIOs.

Pg. 114
Appendix C – Law, Regulation & Policy Compliance

552 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Desired 

Conditions 

for Pine Belt 

Management 

Area

Scenery –

Desired 

Landscape 

Character

1. The Pine Belt MA itself is flat to gently sloping with scattered, 

steeper landforms including Mormon Mountain, lands around 

Kendrick Peak, the West Clear Creek drainage, Walnut Canyon, 

Pumphouse Wash, Fry Canyon, Saddle Mountain, a number of 

prominent hills and mountains in the northern portion of the 

management area and various escarpments throughout. On the 

northern end, evidence of volcanic geology is more common. 

2. This area is valued for its continuous stands of uneven-aged 

ponderosa pine, old-growth “yellow-belly” ponderosa pine 

stands, and beautiful lakes for boating and fishing. This 

management area is comprised of Ponderosa Pine and PiñonJuniper Woodlands vegetation types which cluster around broad 

expanses of grassy openings and picturesque lakes. Ponderosa 

pine is all-aged and includes large trees with open, well-formed 

crowns. The forest is generally open and park like with a diverse 

understory of grasses and shrubs. Tree conditions in places such 

as north-facing slopes and canyon bottoms are sometimes more 

dense. The distribution and class of trees across the landscape 

corresponds with the ecological desired conditions for this 

vegetation type. Old growth ponderosa pines as groups or as 

individual specimens provide a valued landscape feature that 

adds to the sense of diversity and discovery in this zone. Snags, 

top-killed trees, down logs, and other evidence of fire and wind 

disturbance occur individually and in patches of varying sizes. 

They provide an intriguing feature whose distribution on the 

landscape varies over time. Standing dead trees provide character 

and wildlife habitat and some are retained (see the desired 

conditions for the ponderosa pine vegetation type for more 

information).

4. Gambel oak and aspen provide a desirable visual contrast to 

the evergreen pine in fall. In winter, this management area 

provides recreationists a white, snow-covered landscape that 

contrasts with evergreen trees. In the summer, it provides cool 

shady areas for a variety of recreation activities. Arizona walnut

trees in Walnut Canyon provide a valued scenic feature in this 

management area that contributes an interesting bark and texture 

against the winter sky and yellow fall color.

Pg. 119-120
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 553

San Francisco 

Peaks 

Management 

Area

Scenery –

Desired 

Landscape 

Character

(also apply to 

Fort 

Valley/Mount 

Elden MA 

and Pine Belt 

MA)

2. Vegetation varies along the elevation gradient from open 

ponderosa pine stands with views of the surrounding landscape to 

sun-dappled shade of Spruce-Fir and Mixed Conifer to rocky and 

sparsely vegetated alpine communities. Within these vegetation 

types, steep, cool drainages, and fire disturbance create 

microclimates with a surprising diversity of landscape features 

such as high elevation mountain meadows, communities of 

bristlecone pine, and aspen that contrast with dark evergreen 

surroundings. Aspen and grasslands, in particular, create openings 

that provide a sense of the surrounding landscape. The lower 

slopes of this MA gradually flatten and blend into the 

surrounding plateau.

Pg. 121

Flagstaff 

Neighborwoo

ds 

Management 

Area

Scenery

1. Natural landscape is highly valued by local residents and 

visitors. National Forest System lands provide the backdrop for 

the community’s character while accommodating features that are 

more typical of an urban or rural setting. Infrastructure and 

developments that serve a broad public interest are sometimes 

evident but still subordinate to the landscape. Recreation 

developments contribute to the area’s unique sense of place 

through use of native materials; mimicking line, form, color, and 

texture of the surrounding landscape; or use of identifiable Forest 

Service symbols and historic features.

Pg. 123

Invasive Plant Species

Below is a partial list of federal and state laws, executive orders, and Forest direction pertaining 

to project-specific planning and environmental analysis for this project as they relate to invasive 

plant species. 

Coconino National Forest Land and Resource Management Plan, 1987 (as amended).

Resource Planning Act, 1974 (as amended). This act directs the National Forest Service 

to inventory, protect and address the effects to natural resources. 

Multiple-Use Sustained-Yield Act of 1960. This act designates multiple uses with equal 

standing in the National Forests. These include recreation, range, timber, watershed, 

wildlife and fish. It introduces the principles of multiple use and sustained yield on the 

National Forests. 

National Environmental Policy Act, 1969. This act requires all federal agencies to 

analyze the effects of management actions and prepare Environmental Assessments or 

Environmental Impact Statements to address these impacts (depending on the complexity 

of the project). 
Appendix C – Law, Regulation & Policy Compliance

554 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

National Forest Management Act, 1976 (as amended); 36 CFR 219. The NFMA Act 

originated as an amendment to the Resources Planning Act (1974) to address legal 

challenges. It provided direction requiring an interdisciplinary and systematic approach to 

resource management and provided for public input on preparing and revising forest 

plans. 

Executive Order 13112 of 1999, regarding noxious weed or invasive plant species 

control. This executive order is one of the founding directives of the noxious or invasive 

weed control on National Forest system lands. 

Forest Service Manuals 2900 and 2150 and Regional Supplement No. 2100-98-1, 

regarding noxious weed control. 

Noxious Weeds Strategic Plan Working Guidelines– Coconino, Kaibab, and Prescott 

National Forests (1998). These working guidelines were developed by the three forests to 

manage noxious or invasive weeds. Noxious weed invasions were recognized as an 

emerging issue and growing problem. 

Arizona State regulations R3-4-244, R3-4-245 require that the landowner must have an 

active management program to prevent further spread of weeds and reduce numbers of 

existing populations. 

Final Environmental Impact Statement for the Integrated Treatment of Noxious or 

Invasive Weeds, Coconino, Kaibab and Prescott National Forests within Coconino, Gila, 

Mojave and Yavapai Counties, Arizona (USFS, 2005), incorporated into the Forest Plan 

by Plan Amendment 20 (2005). 

Recreation

Current management direction for recreation resources on the Coconino National Forest can be 

found in the following documents on file at the Coconino National Forest’s District offices:

1987 USDA Forest Service Coconino National Forest Land and Resource Management Plan 

(Forest Plan) and all subsequent amendments (USDA, 1987).

36 CFR Part 294 Special Areas

FSM 2300 – Recreation, Wilderness and Related Resource Management

Recreation Opportunity Spectrum (ROS) Users Guide

The table below summarizes the existing Forest Plan direction.

Table 154: Summary of the existing Forest Plan management direction for 

Recreation and Wilderness (Forest Service, 1987)

DESCRIPTION Forest Plan Management Direction page(s)

Goals

Manage the recreation resource to increase opportunities for a wide 

variety of developed and dispersed experiences (Recreation).

Maintain and variety of Forest trails that include foot, horse, 

bicycle, and motorized trails, and challenge and adventure 

opportunities, as well as opportunities for the handicapped 

22, 25
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 555

DESCRIPTION Forest Plan Management Direction page(s)

(Recreation).

Manage off-road driving to provide opportunities while protecting 

resources and minimizing conflicts with other users (Recreation).

Provide a wilderness management program that achieves high 

quality wilderness values while providing for quality wilderness 

recreation experiences (Wilderness).

Provide an area for environmental educational opportunities for the 

public school system, youth organizations, and the general public 

by maintaining the ecosystem and developing interpretive facilities 

(Elden Environmental Study Area).

Forest-wide

Issue and administer dispersed recreation special-use authorizations 

to provide needed recreation opportunities, minimize user conflicts, 

and ensure public safety and resource protection (Recreation).

Review the ROS inventory as part of the project planning and make 

necessary corrections/refinements following field checking. Use 

the ROS inventory to analyze impacts to ROS classes due to 

management activities such as timber sales, range projects, and 

firewood sales (Recreation).

Dispersed recreation areas are managed at standard service level 

(Recreation).

Manage areas for public safety, resource protection, compliance 

checks, and capacity monitoring (Recreation).

Wildernesses are managed to maintain wilderness quality and to 

maintain use within capacity. Manage to provide a quality 

experience for people while protecting wilderness resources 

(Wilderness).

51, 57, 

105

MA 1 

Wilderness

Enforce provisions of 36 CFR, part 261 and Title 16 U.S.C. 

regarding prohibitions in wilderness.

Use the Limits of Acceptable Change (LAC) concept for 

establishing objectives, standards, and monitoring levels for 

wildernesses, as outlined in FS 2320.

106

MA 3 

Ponderosa Pine 

and Mixed 

Conifer, less 

than 40 percent 

Manage dispersed recreation at the Standard Service Level.

Manage the Mt. Elden/Dry Lake Hills to maintain a semi-primitive 

non-motorized ROS class. 

119
Appendix C – Law, Regulation & Policy Compliance

556 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

DESCRIPTION Forest Plan Management Direction page(s)

slopes

MA 4

Ponderosa Pine 

and Mixed 

Conifer, greater 

than 40 percent 

slopes

Recreation use is concentrated on trails passing through the area 

because of the steepness and the amount of debris on the ground. In 

addition, some steep slopes are scenic backdrops for sensitive 

recreation viewpoints.

Recreation use is largely limited to hiking and hunting.

Manage with emphasis on wildlife habitat and dispersed recreation.

Manage the Dry Lake Hills – Mt. Elden area for dispersed 

recreation and wildlife habitat and a semi-primitive non-motorized 

ROS class.

Manage Mt. Elden/Dry Lake Hills for visual quality objective of 

Retention. 

138, 

139,

140

MA 18 

Elden 

Environmental 

Study Area

Emphasize environmental education opportunities for the Flagstaff 

Public Schools and the general public by maintaining the 

ecosystem and developing interpretive facilities. Non-motorized 

dispersed recreation is encouraged.

Plan and support uses and trail in conjunction with the curriculum 

needs of the Flagstaff Public Schools.

197, 

198

FLEA 

Amendment 17

Area-Wide 

Goals and 

Objectives for 

ROS

There is a range of recreational setting opportunities for people to 

enjoy the area’s many scenic and aesthetic qualities.

The diversity and quality of recreation opportunities, settings, and 

experiences are within acceptable limits of change to ecosystem 

stability and condition. 

Evidence of human activities and developments such as roads, 

trails, and facilities, is visually subordinate to the natural-appearing 

landscape. 

206-62

FLEA 

Amendment 17

Area-Wide 

Goals and 

Objectives for 

Camping

Dispersed campsites are maintained to protect forest resources and 

maintain visitor experience. 206-63

FLEA 

Amendment 17

Rock climbing areas are managed and maintained for appropriate 

experience, natural settings, attributes, and conditions, considering 

ROS objectives, wildlife, heritage, and soil and water resources.

206-66
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 557

DESCRIPTION Forest Plan Management Direction page(s)

Area-Wide 

Goals and 

Objectives for 

Rock Climbing

Rock climbing areas are managed in partnership with local rock 

climbers, climbing organizations, and outdoor recreationists.

FLEA 

Amendment 17

Area-Wide 

Goals and 

Objectives for 

Non-Motorized 

Trails

There are opportunities for a variety of trail experiences and 

challenges that are consistent with protection of sensitive resources, 

meet the needs of a diverse public, emphasize the natural 

environment, and meet ROS objectives. 

There is a network of trails linked to other trail systems, such as 

City and County trail systems. 

Trailheads are located in popular areas and provide adequate 

parking, signs, restroom facilities, public education, and resource 

management.

206-67,

206-68

Heritage

Federal Laws

Protection and management of heritage resource on National Forest System land is mandated by 

the 1966 National Historic Preservation Act, as amended (NHPA), 36 CFR 800, and Forest 

Service Manual 2360, American Indian Religious Freedom Act, Archaeological Resource 

Protection Act and the National Environmental Policy Act (NEPA). 

Programmatic Agreement

In addition, the Southwest Region has developed alternative procedures, per 36 CFR 800.14, in 

the form of the Region 3 First Amended Programmatic Agreement Regarding Historic Property 

Protection and Responsibilities. An appendix to this Agreement, APPENDIX J STANDARD 

CONSULTATION PROTOCOL FOR LARGE-SCALE FUELS REDUCTION, VEGETATION 

TREATMENT, AND HABITAT IMPROVEMENT PROJECTS establishes standard procedures for 

NHPA compliance for fuels reduction related undertakings. 

Coconino Forest Plan

The 1987 Coconino National Forest Land Management Plan as amended provides general 

direction for the management of historic and cultural resources significant to our national 

heritage. The plan provides direction for forest-wide management of cultural resources. General 

management direction for cultural resources is outlined below: 

The forest-wide standards and guidelines pertinent to this analysis are detailed in FLMP pp. 53-

54; Amendment 1, p. 50; Amendment 9, pp. 52-3 to 52-4; and the FSM, Section 2360. These are 

summarized below: 
Appendix C – Law, Regulation & Policy Compliance

558 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Forest Plan (1987)

Project undertakings are inventoried for cultural resources and areas of Native American 

traditional use. Inventory intensity complies with Regional policy, and the settlement agreement 

in the Save the Jemez Lawsuit, and is determined in consultation with the State Historic 

Preservation Officer (SHPO). Generally, inventory standards are:

One hundred percent survey of all projects causing surface disturbance;

When less than 100 percent survey is deemed appropriate, the proportion of survey is generally 

greater than 10 percent and is determined in consultation with the State Historic Preservation 

Officer. Factors determining the appropriate inventory sample include the nature and extent of 

project impact, site density, site type, and ground cover;

Consultation with appropriate Native American groups;

Consultation with the SHPO, and if necessary, the Advisory Council on Historic Preservation 

(ACHP) before project implementation. 

Gaps: None

Management strives to achieve a “No Effect” determination. Sites not evaluated are managed as 

‘Eligible” and avoided by all projects and undertakings. 

Gaps: In the case of the Flagstaff Watershed Protection Project, a determination of “No Adverse 

Effect” will be used to allow the use of prescribed fire across sites. This change in determination 

of effects is recommended in the next Forest Plan Revision. No Adverse Effect is also appropriate 

when using sample heritage surveys to support environmental planning analysis, as the case with 

the FWPP project (see Haines and Peters 2013 for details about the sampling strategy). 

In addition, although hand thinning within heritage sites is not explicitly in the current proposed 

action, such work is exempt from standard SHPO review and consultation by Appendix A (II) (Q) 

of the USFS Region 3 First Amended Programmatic Agreement and has no effect on historic 

properties. Therefore, if during the course of authorized activities, there is a need to thin within 

archeological sites, activities will take place according to Appendix J (II) of the USFS Region 3 

First Amended Programmatic Agreement and will occur within site boundaries, provided 1) 

cutting is accomplished using hand tools only; 2) large diameter trees are felled away from all 

features; 3) materials removed from the site are done so by hand; and 4 ) there is no dragging of 

logs, trees, or thinned material across or within site boundaries. There will be no use of vehicles 

or other mechanized equipment within site boundaries, no staging of equipment within site 

boundaries, and no slash piles within site boundaries. An archaeologist may be required to 

monitor activities within sites and this will be at the discretion of the District Archaeologist. 

Within project areas, site condition is monitored during and after project implementation.

Gaps: None

Sites listed on the National Register of Historic Places are visited at least biannually. 

Gaps: Limited by workloads and funding constraints

Cultural resource sites are interpreted through lectures, tours, papers, reports, publications, 

brochures, displays, films, trails, signs, and other means.
Appendix C – Law, Regulation & Policy Compliance

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 559

Gaps: Limited by funding constraints

Survey priorities are to: 1) Provide clearance for projects; 2) Fill in gaps in existing inventory 

coverage; 3) Survey areas of known high site density; and 4) Survey areas that would do the most 

to answer current archaeological questions.

Gaps: Limited by funding constraints 
560 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project
Index

Draft Environmental Impact Statement for the Flagstaff Watershed Protection Project 561

Index

Air Quality

Effects Analysis ...................................186

Alternative 1

No Action Alternative ............................58

Alternative 2

Proposed Action with Cable Logging 

Emphasis on Steep Slopes

Campfire Closure Order.....................68

Forest Plan Amendments....................68

Implementatation Methods.................66

Mitigation Measures Specific to 

Alternatives 2 & 3 ..........................78

Monitoring .........................................69

Road Decommissioning & Closures..74

Treatment Summary...........................59

Alternative 2: Proposed Action with Cable 

Logging Emphasis on Steep Slopes......58

Alternative 3

Proposed Action without Cable Logging

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

Alternative 4

Large Tree Retention Strategy ...............99

Minimal Treatment Approach................92

Economics...............................................430

Affected Environment..........................432

Environmental Effects .........................432

Fire & Fuels

Affected Environment..........................134

Fire Risk

Desired Condition ..................................11

Effects Analysis................................... 129

Existing Condtion ................................... 5

Need for Change ....................................11

Forest Structure & Forest Health

Desired Conditions................................ 20

Effects Analysis................................... 192

Existing Condition ................................ 12

Need for Change ................................... 28

Harvest Systems/Methods Descriptions... 47

Cable Logging/Skyline Yarding............ 52

Conventional Ground Based ................. 48

Cut to length.......................................... 51

Helicopter Yarding ................................ 55

Treating Fuels on Site ........................... 56

Heritage .................................................. 478

Affected Environment......................... 479

Environmental Effects......................... 482

Invasive Plant Species............................ 438

Affected Environment......................... 439

Environmental Effects......................... 444

Issues ........................................................ 42

Conservation of Large Trees................. 44

Mixed Conifer....................................... 43

Prescribed Burning/Maintenance.......... 44
562 Draft Envionrmental Impact Statement for the Flagstaff Watershed Protection Project

Restoration versus Fire Risk Reduction.43

Significance of Forest Plan Amendments

............................................................45

Visual Effects.........................................45

Overlap with 4FRI.......................................4

Project Milestones.......................................2

Recreation................................................459

Affected Environment..........................460

Environmental Effects .........................466

Scenery ....................................................389

Affected Environment..........................391

Environmental Effects .........................402

Sensitive Plants........................................451

Affected Environment..........................451

Environmental Effects .........................453

Soil & Water Resources.............................30

Desired Conditions ................................37

Effects Analysis ...................................265

Existing Conditions................................30

Need for Change ................................... 38

Strategic Placement of Treatments ........... 47

Tribal Consultation ................................... 42

Wildlife

Allen’s Lappet-browed Bat ................. 342

American Peregrine Falcon................. 336

Bald and Golden Eagle Protection Act 385

Bald Eagle........................................... 323

Effects Analysis................................... 293

Management Indicator Species........... 357

Mexican Spotted Owl.......................... 294

Migratory Birds................................... 381

Navajo Mogollon Vole ........................ 339

Northern Goshawk .............................. 327

Northern Leopard Frog ....................... 347

Pale Townsend’s Big-eared Bat........... 342

Snags and Logs................................... 349

Spotted Bat.......................................... 345

Wildlife Cover..................................... 354