United States Department of Agriculture

Final Programmatic

Environmental Impact Statement for 

Revision of the Coronado National Forest

Land and Resource Management Plan

Cochise, Graham, Pima, Pinal, and Santa Cruz Counties, Arizona, 

and Hidalgo County, New Mexico 

Volume 2: Appendix, Sections A through G

Forest Service Southwestern Region MB-R3-05-16 April 2018
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Note: We make every effort to create documents that are accessible to individuals of all abilities; however, 

limitations with our word processing programs may prevent some parts of this document from being 

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the Coronado National Forest at (520) 388-8300. 

Front cover photos (clockwise from upper left): Upper Kielberg in the Galiuro Mountains, Sky Island 

Scenic Byway, Ak Chin Basketmakers, Rustler Park, Parker Canyon Lake, adobe building at Kentucky 

Camp, poppies in the Santa Rita Mountains, and Mexican spotted owl.

Printed on recycled paper.
Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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Contents

Appendix A. Public Comments and Responses .......................................................................... 1

Introduction ................................................................................................................................. 1

Responses to Comments ............................................................................................................. 5

Appendix B. Coordination with Other Public Planning Efforts ........................................... 137

Summary ................................................................................................................................. 137

Counties .................................................................................................................................. 137

Community Wildfire Protection Plans .................................................................................... 148

Fire Management Plans ........................................................................................................... 148

Tribes ...................................................................................................................................... 149

State of Arizona ...................................................................................................................... 150

State of New Mexico ............................................................................................................... 158

Federal Agencies ..................................................................................................................... 165

Other Land Owners ................................................................................................................. 169

Conclusion .............................................................................................................................. 169

Appendix C. Timber Suitability ............................................................................................... 173

Appendix D. Crosswalk of Desert and Grassland Communities with Ecological Site 

Descriptions ................................................................................................................... 177

Appendix E. Range Suitability and Capability ....................................................................... 181

Determination of Lands Suitable and Capable for Livestock Grazing on the Coronado National 

Forest ....................................................................................................................................... 181

Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis ................. 187

All Forest Planning Species on the Coronado National Forest .............................................. 188

Appendix G. Methods of Analysis ............................................................................................ 215

Resource Assumptions and Methodologies ............................................................................ 215

Topic 1: Ecosystem Restoration and Resiliency ..................................................................... 215

Topic 2: Visitor Experiences ................................................................................................... 231

Topics 3, 4 and 5: Access; Open Space; and Collaboration, Communities, 

and Partnerships ......................................................................................................... 235

List of Tables

Table 133. Public comment codes and corresponding concern statement topics........................................... 2

Table 134. Explanation of forest plan resource coding used in responses...................................................... 5

Table 135. Explanation of forest plan component coding used in responses ................................................. 5

Table 136. Forest highways located on Coronado National Forest .............................................................167

Table 137. Potential impacts to forest management and relationship to the revised forest plan .................170

Table 138. Activities on adjacent lands that may impact forest management .............................................171

Table 139. Timber suitability assessment of Coronado National Forest lands............................................174

Table 140. Timber suitability assessment of Coronado National Forest lands comparing acres 

among alternatives ........................................................................................................................174

Table 141. Crosswalk of desert and grassland communities with ecological site descriptions for 

each mountain range in Santa Catalina, Nogales, and Sierra Vista ranger districts......................178

Table 142. Crosswalk of desert and grassland communities with ecological site descriptions for 

each mountain range in Douglas and Safford ranger districts.......................................................179
Contents

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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Table 143. Grazing capability calculations for the Coronado National Forest............................................182

Table 144. Acres of management areas unsuitable for grazing on the Coronado National Forest by 

alternative......................................................................................................................................184

Table 145. Key for associated habitat and ecosystem management area codes in wildlife and rare 

plants tables...................................................................................................................................187

Table 146. Wildlife and plant species considered in the analysis................................................................188

Table 147. Key for table 148.......................................................................................................................205

Table 148. Codes for plan components used in the species viability analysis.............................................205

Table 149. Vegetation condition class (VCC) descriptions.........................................................................217

Table 150. Vegetation condition class (VCC) and departure for each vegetation community*..................217

Table 151. Suitability of select special uses on the Coronado National Forest ...........................................237
Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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Appendix A. Public

Comments and Responses

Introduction

This appendix is a summary of public comments received by the U.S. Department of Agriculture, 

Forest Service (Forest Service, or agency) regarding the “Draft Programmatic Environmental 

Impact Statement for Revision of the Coronado National Forest Land and Resource Management 

Plan” and responses to those comments. The comment period ran from November 22, 2013 to 

March 6, 2014.We received 2,274 responses. Of these, approximately 1,647 were form letters; the 

remaining letters consisted of original responses or form letters plus responses.

A response is a single, whole submission that may take the form of a letter, email, fax, 

presentation at an organization-sponsored public meeting, or documented conversation. Each 

response may contain anywhere from one to several hundred comments.1

 Many of the responses 

were original, including those submitted by individuals and those from agencies and 

organizations. Some were form letters. Form letters are two or more letters that contain identical 

text but are submitted by different people. 

Each original letter and an example of the form letter were analyzed to ensure the concerns of all 

respondents were considered. In addition, if a respondent added information to a form letter, and 

the additional information was not redundant to the comment already in the form itself, this 

content also was analyzed. The interdisciplinary planning team prepared responses for each 

concern statement based on its merits, regardless of the source or whether the concern statement 

was expressed by many people or by one person. This appendix documents the Coronado 

National Forest’s responses to substantive comments, which are addressed as prescribed in 40 

CFR section 1503.4 in the following ways:

• modifying the proposed action alternative and alternatives

• developing or analyzing alternatives not given detailed consideration in the draft 

environmental impact statement

• supplementing, improving, or modifying the analysis that the draft environmental impact 

statement documented; 

• making factual corrections

• explaining why the comments need no further agency response

The comments were processed using content analysis, which is a systematic process designed to 

provide a mailing list of respondents, extract topics from each letter, evaluate similar topics from 

different responses, and identify specific topics of concern.

A summary analysis of the public comments is available in the project record and at the following 

webpage: 

http://www.fs.usda.gov/detail/coronado/landmanagement/planning/?cid=fswdev7_018702. 

 

1 Responses refer to single, whole submissions from respondents (e.g., letters, emails, faxes, presentations at public 

meetings). Comments refer to identifiable expressions of concern made within responses.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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Although the analysis attempts to capture the full range of concerns raised, it should be used with 

caution. The respondents are self-selected; therefore, their comments do not necessarily represent 

the sentiments of the entire population. The analysis attempts to provide fair representation of the 

wide range of views submitted but makes no attempt to treat input as if it were a vote or a 

statistical sample. In addition, respondents’ reasons for voicing viewpoints are varied, subtle, or 

detailed. In an effort to provide a succinct summary of all of the concerns raised, many subtleties 

are not conveyed in this summary.

Numbers that follow each topic heading and each concern statement correspond to the coding 

systems used in the content analysis process. The codes for the topic headings are listed below. 

The individual concern statements are coded to include the topic heading code as well as the 

concern statement identifier number. For example, code 10.3 at the end of a concern statement 

means it is the third comment under the topic heading “Decision Process.” Where a coded 

comment number does not match the numbering in the topic heading, it was likely moved to that 

section because the comment fits more appropriately under that topic.2

Table 133. Public comment codes and corresponding concern statement topics

Code No. Concern Statement Code Name

1 Air Quality Management 

2 Bicycling

3 Biological Resources Management

4 Border Patrol Activity

5 Climate Change

6 Comment Period Extension

7 Confirm receipt of letter

8 Coordination, Consultation

9 Cultural, History, Anthropology Management

10 Decision Process

11 Designated Wilderness Areas

12 Desired Conditions

13 Developed Recreation and Facilities

14 Dispersed Recreation Management

15 Domestic Livestock, Grazing Management

16 Economic and Social Actions, Analyses

17 Effects Analysis 

18 Enforcement

19 Fees and Permits

20 Fire and Fuels Management

21 Fuel Treatment, Reduction

22 Hunting, Shooting 

23 Illegal uses (border)

 

2 Due to the overlap of comments among many topics, the coding system is not precise.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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Code No. Concern Statement Code Name

24 Impacts of illegal uses

25 Individual Species

26 International Border issues

27 Invasive Vegetation Treatment

28 Issues, Alternatives 

29 Land Designations/Management

30 Land Ownership, Uses

31 Leasable Minerals

32 Minerals & Geology Management

33 Monitoring

34 Motorized Recreation Management

35 No Further Response Required

36 Objectives

37 Other Activities Management

38 Outreach/Education

39 Plan Components

40 Prescribed Burns

41 Proposed Action, Decision

42 Proposed Mines (e.g., Rosemont)

43 Public Health, Safety

44 Public Involvement 

45 Recreation Management

46 Recreational Access

47 Remove from mailing list 

48 Requests for Information

49 Resource & Area Management

50 Roadless Areas

51 Roles, Authorities

52 Saleable Minerals

53 Seasonal Closures/Access

54 Social Actions or Analyses

55 Soils Management

56 Standards and Guidelines (level of discretion)

57 Suppression

58 Transportation System Management (& non-rec. access)

59 Vegetation Management

60 Water, Watershed Management

61 Wildland/Urban Interface

62 Wildlife Corridors - general

63 Wildlife Corridors across International Border
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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Code No. Concern Statement Code Name

64 Wildlife/Animals Management

65 Withdrawal of Lands

The listed topic headings are grouped by the following broad categories: 

• Decision-making Process, Public Involvement, and Coordination 

• Draft Environmental Impact Statement, Alternatives, and Analysis

• Natural Resources Management

• Recreation Management

• Lands Management

• Socio-economic Concerns 

• Transportation Management 

• Administrative Comments

Some concern statements shown in the response to comments section are combinations of similar 

comments, with differences separated by a semicolon. For example, many people may have 

stated: “The Forest Service should coordinate with local and regional interests . . :,” but their 

specific information about that primary comment may differ like so:

• “to provide input into developing management direction 

• to leverage resources and funding

• to include the Southwestern Research Station, the Chiricahua Regional Council, grazing 

permittees, cabin owners, and local business, and scientific interest representatives” 

In those instances, the concern statement may be fairly long because it includes more specific 

information. 

There are numerous responses in appendix A utilizing a coding system to identify desired 

conditions, objectives, standards, and guidelines. The coding identifies first the forest plan 

resource code, then the forest plan component code, followed by the component number. For 

example, “Guideline ISM-G-1 will result in the removal of nonnative invasive plant and animal 

species where fish and other special status aquatic species occur,” refers to guideline 1 under 

invasive species management. The tables below provide the codes for the forest plan resource 

and the forest plan component. 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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Table 134. Explanation of forest plan 

resource coding used in responses

Abbreviation

Forest Plan Resource 

Codes

ARP Animals and Rare Plants

BIP Biophysical Features

COW Constructed Waters 

ISM Invasive Species Management

MIN Minerals

MTS Motorized Transportation

NWS Natural Water Sources

RAM Range Management

RIA Riparian

WET Wetlands

Table 135. Explanation of forest plan 

component coding used in responses

Abbreviation Component Code

DC Desired Condition

VO Vegetation Objectives

G Guideline

S Standard

O Objective

MA Management Approach

Responses to Comments

Decision-making Process, Public Involvement, and Coordination

Decision Process (10)

Concern Statement: The Forest Service should ensure that the plan adequately prioritizes 

multiple use requirements to comply with the National Forest Management Act and the MultipleUse Sustained-Yield Act. (10.01) 

Response: As indicated in the “Purpose of the Land and Resource Management Plan” section in 

chapter 1, the plan represents a revision of the 1986 Coronado National Forest Land and Resource 

Management Plan. This revision was conducted under the legal framework of the National Forest 

Management Act and the provisions of the 1982 Planning Rule. This provision has been updated 

and implied within the 2012 planning rule by continuing to allow the use of 1982 Planning Rule 

for plan revision initiated prior May 9, 2012 (36 CFR 219.17(b)(3)) 

Management of national forests is jointly based on the principles of conservation and multiple 

use. Multiple uses are prioritized and managed to be consistent with desired conditions for plan 

resource areas based on the evaluation of the effects analyses. The guiding principles for forest 

plans are closely tied with the goals established by the both acts. 

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

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

range, timber, watershed, and wildlife and fish purposes.”
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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

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

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

particular, include coordination of outdoor recreation, range, timber, watershed, wildlife 

and fish, and wilderness...”

To be complete, the revised forest plan document must be applicable with the goals of both of 

these acts. 

Concern Statement: The Forest Service should give greater weight to the interests of taxpayers 

than to those of mining companies. (10.02) 

Response: The Forest Service does not give greater weight to one resource interest over another.

The forest plan provides for the full scope of natural resource issues impacting the national forest.

Most of the guidance for mining is governed by law, regulation, and policy, which are outside the 

scope of the forest plan as described in chapter 3 of the environmental impact statement. Future 

projects and activities, of any kind, must be consistent with the forest plan and various laws, 

agency policy, and direction to manage vegetation and natural resources for multiple uses, all of 

which provide resource outputs for society, either directly or indirectly. 

Concern Statement: The Forest Service should clarify the process by which decisions on the 

plan will be made. (10.3) 

Response: As identified in the “Decision Framework” section of chapter 1 in this final

environmental impact statement, the regional forester for the Southwestern Region of the Forest 

Service is the responsible official who will decide whether to approve the proposed action or an 

alternative to the proposed action. The rationale for selecting a particular alternative will be 

thoroughly explained in the record of decision. Upon implementation, site-specific or 

programmatic forest plan amendments may occur in accordance with the “Changes to the Forest 

Plan” section of chapter 1 in the revised forest plan. 

Concern Statement: The Forest Service should revise and recirculate the draft environmental 

impact statement. (10.04) 

Response: The Coronado National Forest followed the public participation requirements 

outlined in the National Environmental Policy Act, National Forest Management Act, and 

provisions of the 1982 Planning Rule to develop the proposed plan and draft environmental 

impact statement and make them available for review during a 104-day public comment period. 

We analyzed public comments submitted and made adjustments to the plan and environmental 

impact statement based on this input. A summary of changes from the proposed plan and draft 

environmental impact statement can be found in chapter one of the final environmental impact 

statement.

Comment Period Extension (6)

Concern Statement: The Forest Service should extend the comment period, because not all 

affected stakeholders were properly notified. (6.01) 

Response: The Forest Service environmental assessment process requires a 90-day public review 

process for environmental impact statements. An extension of the required days is up to the 

discretion of the responsible official. The 90-day public review period began on November 23, 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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2013, the day after publication of a notice of availability of the draft environmental impact 

statement in the Federal Register by the U.S. Environmental Protection Agency. The comment 

period was extended an additional 14 days ending on March 6, 2014 to allow additional 

comments. In order to move from draft environmental impact statement to final environmental 

impact statement, the comment period must be suspended to allow comment analysis and updates 

to the document. See the “Public Involvement and Collaboration” section of the final 

environmental impact statement for a detailed description of the public comment period and 

analysis of comments.

Concern Statement: The Forest Service should extend the comment period because they did not 

provide sufficient notice to stakeholders in the process. (44.08) 

Response: The Forest Service environmental assessment process requires a 90-day public review 

process for environmental impact statements. An extension of the required days is up to the 

discretion of the responsible official. The 90-day public review period began on November 23, 

2013, the day after publication of a notice of availability of the draft environmental impact 

statement in the Federal Register by the U.S. Environmental Protection Agency. The comment 

period was extended an additional 14 days ending on March 6, 2014. In order to move from draft 

environmental impact statement to final environmental impact statement, the comment period 

must be suspended to allow comment analysis and updates to the document. See the “Public 

Involvement and Collaboration” section of the final environmental impact statement for a detailed 

description of the public comment period and analysis of comments. 

Concern Statement: The Forest Service should ensure that adequate public notice and 

involvement occurs to comply with the National Forest Management Act. (44.05, 44.07)

Response: We followed the public participation requirements outlined in the National 

Environmental Policy Act, National Forest Management Act, and provisions of the 1982 Planning 

Rule to develop the proposed plan and draft environmental impact statement and make them 

available for review during a 90-day public comment period. The 90-day public comment period 

for the Coronado National Forest draft land and resource management plan and draft 

environmental impact statement was extended through March 6, 2014. The 90-day public review 

period began on November 23, 2013, the day after publication of a notice of availability of the 

draft environmental impact statement in the Federal Register by the U.S. Environmental 

Protection Agency. It had been extended an additional 14 days ending on March 6, 2014. See the 

“Public Involvement and Collaboration” section of the final environmental impact statement for a 

detailed description of the public comment period and analysis of comments.

Coordination, Consultation (8)

Concern Statement: The Forest Service should provide staff to coordinate work with volunteers 

to lessen the effects of staff turnover. (8.06) 

Response: Staffing levels are not a forest plan-level decision. However, in the plan, individual 

resource or geographic areas, such as recreation or the Santa Catalina Ecosystem Management 

Area, include volunteer coordination as a plan management approach. 

Concern Statement: The Forest Service should include the local ranger district in the list of 

preparers. (8.29) 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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Response: The forest plan was updated under “List of Preparers” to include a statement that 

other staff, including those on the ranger districts, contributed to the development of the plan.

Concern Statement: The Forest Service should coordinate with local and regional interests: to 

provide input into developing management direction; to leverage resources and funding; to 

include the Southwestern Research Station, the Chiricahua Regional Council, grazing permittees, 

cabin owners, and local business and scientific interest representatives; to include inholding 

landowners and resident businesses; to include Hidalgo County on the list of Cooperating 

Agencies; including the County of Cochise and the City of Sierra Vista; on travel management 

needs; to comply with the National Forest Management Act; to protect the forest resources for 

future generations; and to inventory, monitor, protect, and restore water resources. (8.02) 

Response: We agree. One of the five topics the plan was built around was the need to improve 

collaboration and partnership relations with all the communities we serve. The plan does this by 

including desired conditions that reflect outcomes based on collaborative processes, identifying 

management approaches that emphasize collaboration, and reflecting an integrated approach to 

management of traditional uses and cultural resources.

Concern Statement: The Forest Service should coordinate with the Access Fund and the 

Southern Arizona Climbers Coalition because they will be allies in maintaining the resource. 

(8.03) 

Response: We agree with your comment. We consider the Access Fund and the Southern Arizona 

Climbers Coalition to be key partners in maintaining the very high quality climbing experiences 

available on the Coronado National Forest. The forest plan contains management approaches in 

the “Biophysical Features” and “Recreation” sections that encourage collaborating with partners 

and other stakeholders, and we added specific reference to the Access Fund and the Southern 

Arizona Climbers Coalition to these management approaches. 

Concern Statement: The Forest Service should ensure that power communication users 

coordinate with the Encroachment Board at Fort Huachuca as required by Arizona SB 1387. 

(8.04) 

Response: This is neither a forest plan-level decision nor a Coronado National Forest activity. 

The Forest Service communications leases require all users to comply with Federal, State, and 

local laws. The special uses management approach calls for the following: 

• maintaining existing communications sites and completing site management plans for all sites 

with the cooperation of communication site user groups

• continuing to establish user groups or organizations for each site

Concern Statement: The Forest Service should include a Memorandum of Understanding with 

the various Indian tribes to clarify how the agency and the tribes would engage in consultations.

(8.05) 

Response: We agree that establishing memorandum of understanding with tribes is beneficial. In 

chapter 2 under the “Tribal Relations” section, the following language was added as an additional 

management approach. 

“Cooperatively develop a memorandum of understanding with neighboring tribes for 

routine tribal consultation, policy development, proposed plans, projects, programs, and 

forest activities that have a potential to affect tribal interest.”
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

9 

Concern Statement: The Forest Service should clarify whether coordination with off-highway 

vehicle organizations has occurred. (8.07) 

Response: Chapter 1 of the environmental impact statement has a description of the public 

involvement and collaboration efforts that have been ongoing since 2005. This involvement 

included stakeholders and advocates for off-highway vehicle recreation. Special presentations 

were made on several occasions to the Arizona Access Coalition, the Cochise County Public 

Lands Advisory Committee, and the Hidalgo County Public Lands Advisory Committee, three 

groups that include representation of off-highway vehicle recreation interests. Many of these 

stakeholders are also involved with Coronado National Forest travel management planning 

which, although it is a separate process, is coordinated with the forest plan through other focus 

groups and meetings that provide opportunities for coordination, comments, and access to key 

agency personnel related to the forest plan revision efforts. 

Concern Statement: The Forest Service should coordinate with State and Federal wildlife 

agencies. (8.08). The Forest Service should consult with the U.S. Fish and Wildlife Service to 

comply with the Endangered Species Act. (8.16) 

Response: The Coronado National Forest coordinates closely with the U.S. Fish and Wildlife 

Service, the Arizona Game and Fish Department, and the New Mexico Department of Game and 

Fish. Those relationships are key to the management of wildlife on National Forest System lands.

Appendix B of the environmental impact statement describes our coordination with other agency 

planning efforts. An appendix to the forest plan, also named appendix B, describes how we work 

with the wildlife agencies. As part of our Endangered Species Act compliance process, Section 7 

(a)(1) of the act directs Federal agencies to aid in conservation of listed species and section 7 

(a)(2) requires that agencies, through consultation with the U.S. Fish and Wildlife Service, ensure 

their activities are not likely to jeopardize the continued existence of listed species or adversely 

modify designated critical habitat. The Forest Service consulted with, and received a favorable 

biological opinion from, the U.S. Fish and Wildlife Service. 

Concern Statement: The Forest Service should include policies that comply with the Religious 

Freedom Restoration Act, the American Indian Religious Freedom Act, and the United Nations 

Declaration on the Rights of Indigenous Peoples. (8.09) 

Response: The Religious Freedom Restoration Act and the American Indian Religious Freedom 

Act are among the laws the Forest Service complies with and those laws are identified in forest 

plan appendix E, “Other Sources of Information.” The United Nations declaration does not 

contain policy and procedures but does lay out goal statements that are reflected by the plan 

components in the “Cultural Resources” and “Tribal Relations” sections. In response to this 

comment, the declaration is now listed in the plan, appendix E.

Concern Statement: The Forest Service should consider using Southern Arizona Climbing 

Coalition as an ombudsman instead of creating a permit and reservation system. (8.10) 

Response: The plan is not going to create a permit and reservation system; however, the plan 

does contain language recommending the creation of a permitting system, should it be needed. 

This language is found in the “Recreation” section of the plan, management approaches. Any 

permit and reservation system that would be established would be subject to analysis under the 

National Environmental Policy Act.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

10

Concern Statement: The Forest Service should coordinate with Pima County and other 

stakeholders on mineral withdrawals to comply with the existing Memorandum of Understanding.

(8.11)

Response: We intend to continue coordinating with Pima County on all issues of common 

interest, in accordance with our existing memorandum of understanding. Mineral withdrawal 

actions are not a forest plan decision. However, the Forest Service may consider an administrative 

mineral withdrawal as outlined in Forest Service Manual 2760. Generally, a withdrawal is a 

management tool for withholding an area of National Forest System land from settlement, sale, 

location, or entry under some or all of the general land laws, including the mining and mineral 

leasing law, for the purposes of limiting activities under those laws to maintain other public 

values in the area, or reserving the area for a particular public purpose or program. These 

programs and purposes may include quality of scientific, scenic, historical, ecological, 

environmental, air, water resource, archaeological values, or other special purposes. Before 

recommending an administrative withdrawal for a certain area, the Forest Service must comply 

with the requirements under 43 CFR 2310.1-2 for consideration of alternative protection 

opportunities such as a right-of-way under section 507 of the regulation (43 U.S.C. 1767) or a 

cooperative agreement under sections 302(b) (43 U.S.C. 1732(b)) and 307(b) (43 U.S.C. 1737(b)) 

of the regulation, or other protection methods. These requirements are restated in the forest plan 

as guidelines under chapter 2 in the “Land Ownership Adjustments and Boundary Management”

section.

Concern Statement: The Forest Service should coordinate with the climbing community: to 

develop an access plan for climbing areas that is compatible with the revised forest plan; to make 

use of their GPS and mapping skills; to maintain and define use standards; because they are good 

stewards of the forest; to help achieve desired conditions and implement the regulations in the 

plan. (8.12)

Response: We agree, and we are working to improve communication and collaboration with the 

climbing community. We addressed rock climbing in the “General Description,” “Desired 

Conditions,” “Guidelines,” and “Management Approaches” sections in several areas of the forest 

plan. Rock climbing language can be found in chapter 2 of the forest plan in the “Biophysical 

Features” and “Recreation” sections. In addition, rock climbing in specific locations is addressed 

in chapter 4 in the Douglas, Nogales, and Santa Catalina Ranger District geographic areas. The 

forest plan directly addresses collaboration with the climbing community in the “Management 

Approach” found in the “Biophysical Features” section of chapter 2.

Concern Statement: The Forest Service should improve their collaboration with the White 

Mountain Apache Tribe to ensure that commitments are met. (8.13)

Response: The importance of cooperating with tribes and incorporating their perspectives, 

concerns, and traditional knowledge into management decisions are listed and discussed in 

chapter 2, “Tribal Relations,” management approaches section. They include working with the 

White Mountain Apache Tribe and taking its best management practices into account.

Concern Statement: The Forest Service should work with motorized user groups to encourage 

safe, responsible off-highway vehicle use and improve public outreach and education to assist in 

trail building and maintenance. (8.14)

Response: We agree and will continue to work with motorized user groups.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

11

Concern Statement: The Forest Service should collaborate with the climbing community on 

service projects; to preserve the environment, reduce erosion, and improve access; to address cliff 

management and seasonal closures; and to provide stewardship education stewardship and help 

with land management projects. (8.15)

Response: We agree. Rock climbing is addressed in the “General Description,” “Desired 

Conditions,” “Guidelines,” and “Management Approaches” in several sections of the forest plan. 

Rock climbing language can be found in chapter 2 of the forest plan within the “Biophysical 

Features” and “Recreation” sections. In addition, rock climbing in specific locations is addressed 

in chapter 4 within the Douglas, Nogales, and Santa Catalina Ranger District geographic areas. 

The forest plan addresses collaboration with the climbing community in the “Management 

Approach” found in the “Biophysical Features” section of chapter 2.

Concern Statement: The Forest Service should coordinate with adjacent landowners: to 

improve access to wilderness trailheads to help care for the land and manage resources; and to 

conserve the Galiuro landscape. (8.17)

Response: We agree that we should continue to coordinate with adjacent landowners in all areas 

of the Coronado National Forest. Management approaches in the “Recreation” section of the plan 

include: 

“Establishing an ongoing program and long-term partnerships to help the Forest Service 

maintain trails.” 

In the “Land Ownership and Boundary Management” section there are desired conditions that 

emphasize acquiring rights-of-way easements to maintain the integrity of resources and improve 

public access to Coronado National Forest lands. Management approaches in this section include 

working with landowners to preserve open space; and acquiring lands of other ownership that 

resolve public access issues, contain vital habitat, are water oriented, or provide public recreation 

opportunities.

Concern Statement: The Forest Service should coordinate with the Arizona Game and Fish 

Department and the New Mexico Department of Game and Fish to address state trust resources.

(8.18)

Response: The Forest coordinates with both Arizona Game and Fish Department and the New 

Mexico Department of Game and Fish. Appendix B of the environmental impact statement

summarizes the coordination with other planning efforts including with those agencies. 

Concern Statement: The Forest Service should identify Pima County as a partner for wildlife 

habitat, watershed, and fire management activities to further the goal of increasing collaboration. 

(8.19)

Response: Appendix B of the environmental impact statement summarizes the coordination with 

other planning efforts including Pima County. Additionally, the Pima County Sonoran Desert 

Conservation Plan is cited as a source document for the forest plan. We also collaborate with the 

Cienega Corridor Conservation Council and the Cienega Watershed Partnership, which include 

representation from Pima County. The forest plan encourages coordination with counties, and 

county comprehensive plans can be used as a source of information on the history of land use in

the region, the patterns of development, desired conditions, and current county land use policies
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

12

Concern Statement: The Forest Service should acknowledge that permittees are stakeholders 

and address their needs in the plan. (8.21)

Response: We agree permittees are important stakeholders. The forest plan supports continuation 

of livestock production to provide social and ecological benefits. The “Range Management”

section of the forest plan contains plan components and management approaches, many of which 

address the needs of livestock grazing permittees.

Concern Statement: The Forest Service should clarify the notification requirements to ensure 

that required consultation with Tribal governments will occur. (8.22)

Response: The Coronado National Forest follows law, policy, guidance, and directives on 

communication and notification to tribes. Consultation with tribes and the importance of 

incorporating their perspectives, concerns, and traditional knowledge into management decisions 

are listed discussed in chapter 2, “Tribal Relations,” management approaches section. 

Concern Statement: The Forest Service should provide education and outreach to all user 

groups to reduce erosion impact from trails. (8.23)

Response: The forest plan supports education and outreach to all groups to reduce impacts from 

trails. See chapter 2, “Recreation” for more information.

Concern Statement: The Forest Service should collaborate with the mining industry on the plan.

(8.24)

Response: We agree we should continue to collaborate with the mining industry on the plan and 

other minerals management activities. We have added the following management approach to the 

“Minerals” section of the plan to emphasize that intention: “Coordinate with operators, 

permittees, other agencies, and stakeholders during the environmental review of proposed mineral 

operations.” 

Concern Statement: The Forest Service should consult with Native American Tribes. (8.26)

Response: Throughout the planning process, we have reached out to tribes and offered 

opportunities to consult on the forest plan. The importance of cooperating with tribes and 

incorporating their perspectives, concerns, and traditional knowledge into management decisions 

are listed discussed in forest plan chapter 2, “Tribal Relations,” management approaches section, 

and in forest plan appendix B, “Proposed and Probable Management Practices.” 

Concern Statement: The Forest Service should include the climbing community in cliff 

management projects and seasonal raptor and bighorn closures. (8.28)

Response: The forest plan contains management approaches in the “Biophysical Features” 

section that emphasizes engaging caving and climbing organizations in cliff management 

activities. The forest plan does not address closure orders for bighorn sheep and seasonal raptor. 

These items are addressed on a case-by-case basis on individual units and not at the forest level. 

We agree recreation groups and other public stakeholders should be included in this decisionmaking process, and it should be addressed based on the circumstances for each district. 

Concern Statement: The Forest Service should collaborate with the climbing community to 

cooperatively manage climbing as an unpermitted, low-impact recreation activity. (14.03, 14.08, 

14.09, 14.11)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

13

Response: Rock climbing is addressed in several areas of the forest plan in the “General 

Description,” “Desired Conditions,” “Guidelines,” and “Management Approaches” sections. 

Rock climbing language can be found in chapter 2 of the forest plan in the “Biophysical Features”

and “Recreation” sections. In addition, rock climbing in specific locations is addressed in chapter

4 in the Douglas, Nogales, and Santa Catalina Ranger District geographic areas. The forest plan 

addresses collaboration with the climbing community in the management approach found in the 

“Biophysical Features” section of chapter 2.

Public Involvement (44)

Concern Statement: The Forest Service should clarify why comment letters were not cleared for 

posting quickly and why some comments have been removed. (44.02, 44.03)

The Forest Service should clarify what is considered proprietary or sensitive resource information 

as it relates to letters being unavailable in the public reading room. (44.04)

Response: Comment letters were posted to the following website: https://cara.ecosystemmanagement.org/Public/ReadingRoom?project=31147. We monitored comments and letters that 

contained sensitive information and did not make those available via the webpage. Letters 

become unavailable in the public reading room when they contain information pertaining to 

sensitive resource information such as nesting locations, dens, burial sites, or gravesites. Further, 

letters containing tribal-related topics pertaining to Native Americans, sovereignty, or Indians are 

also flagged as potentially sensitive information and not available for public viewing. Letters in 

these categories and letters that contain threats or offensive language remain unavailable in the 

public reading room until they are reviewed by agency officials and manually released.

Concern Statement: The Forest Service should provide easy access to the public reading room 

for all documents and those received via email. (44.01, 44.09)

Response: Public comments are available on the internet at https://cara.ecosystemmanagement.org/Public/ReadingRoom?project=31147. 

Concern Statement: The Forest Service should provide an automated response to the sender that 

email comments were received. (44.06)

Response: The Forest did not send an automated response upon receipt of a letter. An automated 

response for all comments and letters is beyond the requirements for the acceptance of public 

comment. 

Outreach/Education (38)

Concern Statement: The Forest Service should improve conservation education for canyon 

users, Forest Service staff, scientists, and students in areas such as Portal and Cave Creek. (38.01, 

38.05)

Response: Although specific conservation education programs are not a plan-level decision, the 

forest plan provides guidance that encourages conservation education. Specifically, chapter 2, the 

“Recreation” section includes the following desired condition statement: 

“Interpretation and visitor education programs help visitors understand how to reduce 

their impacts on ecosystems, and visitors actively help support the Coronado National 

Forest’s efforts to protect natural resources and wilderness values.” 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

14

This section also includes the following management approach: 

“Developing interpretive facilities and conservation education programs to provide 

opportunities for visitors and the increasingly urban population in southeastern Arizona 

to learn about and appreciate nature and wild places.” 

Concern Statement: The Forest Service should allow the Southwestern Research Station to 

continue with the current permitting system to allow research and study to continue under the 

current system. (38.03)

Response: The permitting system for the Southwestern Research Station special use permit is not 

a plan-level decision. However, we recognize the research station as an important partner, 

especially as a source of science that can be used to inform management. A management 

approach emphasizing the importance of collaborating with the research station has been added to 

the forest plan in chapter 4, “Geographic Areas,” “Chiricahua Ecosystem Management Area.”

Concern Statement: The Forest Service should continue to allow access to the national forest in 

support of outreach and education, balance the educational and recreational mission of wilderness 

with natural resource protection, and add educational signage to the national forest to improve 

education and highlight the unique values of the forest. (38.02, 38.04)

Response: Education, balancing wilderness with natural resource protection, and interpretation 

and visitor education programs are found in chapter 2 of the plan in the “Recreation” section. 

Interpretation and visitor education programs help visitors understand how to reduce their impacts 

on ecosystems, and visitors actively help support the Coronado National Forest’s efforts to 

protect natural resources and wilderness values.

Although specific conservation education programs are not a plan-level decision, the forest plan 

provides guidance that encourages conservation education. Specifically, chapter 2, the 

“Recreation” section includes the following desired condition statement: 

“Interpretation and visitor education programs help visitors understand how to reduce 

their impacts on ecosystems, and visitors actively help support the Coronado National 

Forest’s efforts to protect natural resources and wilderness values.” 

This section also includes the following management approach: 

“Developing interpretive facilities and conservation education programs to provide 

opportunities for visitors and the increasingly urban population in southeastern Arizona 

to learn about and appreciate nature and wild places.” 

Concern Statement: The Forest Service should improve their community outreach because 

communication with the local community requires greater effort to improve the community's 

involvement and increase public meeting attendance. (39.06)

Response: We recognize the need to improve community outreach. As described in chapter 1, 

“Summary of the Analysis of the Management Situation,” improving community outreach was 

identified early on in the plan revision process as one of the five basic topics around which the 

plan was developed. Topic 5, “Communities, Collaboration, and Partnerships” is analyzed in the 

environmental impact statement, and a comparison of how well each alternative meets this need 

for change is found in chapters 2 and 3 of the document.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

15

Concern Statement: The Forest Service should lead a class on indoor and outdoor climbing.

(38.07)

Response: This comment is outside the scope of the plan. Classes on indoor and outdoor 

climbing are not within the jurisdiction of the Forest Service. They are offered by groups such as 

Outdoor Adventures and the Southern Arizona Climbers Coalition.

Desired Conditions and Objectives (12, 36)

Concern Statement: The Forest Service should eliminate social and economic attributes from 

desired conditions because desired conditions should only include landscape conditions. (12.01)

Response: Focusing on social and economic attributes helps create ties to the communities we 

serve; therefore, it is appropriate to include them in desired conditions. Part of the requirements 

of the National Forest Management Act is to identify and analyze the social and economic 

benefits attributed by the Coronado to the local community. Identifying the social and economic 

benefit is also a way to connect the agency’s motto, “caring for the land and serving the people”,

with the management actions that occur on the ground. 

Concern Statement: The Forest Service should amend the desired conditions to address the 

importance of spring ecosystems to address ecosystem resilience. (12.03)

Response: We agree with your comment. We have added springs ecosystems to the desired 

condition statement for natural water sources. 

Concern Statement: The Forest Service should revise the desired conditions for wilderness 

character to recognize that the untrammeled or wild nature is key to wilderness character. (12.04)

Response: The forest plan contains desired conditions and guidelines that address the 

untrammeled or wild nature of wilderness character. They include the following language:

Desired Conditions: “The ecological systems within wilderness areas across the 

Coronado National Forest vary naturally over time and space. Wilderness areas provide a 

wide variety of opportunities for exploration, solitude, natural risk, challenge, and 

primitive and unconfined recreation. Wild landscapes harbor the Coronado’s richest 

concentration of quiet places, with the sights and sounds of humankind substantially 

unnoticeable. Developments (e.g., fences, structures, and water containment features) are 

rare; those that exist offer visitors a glimpse of past cultures and traditional land uses.”

Guidelines: 1. Wilderness character should be maintained or improved. This includes 

untrammeled, natural, and undeveloped qualities, as well as opportunities for solitude or 

primitive and unconfined recreation.

Concern Statement: The Forest Service should include a structured process for choosing among 

objectives that would provide justification as to why a particular objective was chosen.

Additionally, the Forest Service should modify objectives that contribute to achieving desired 

conditions. (36.01, 36.02)

Response: Objectives were based on public input and developed by resource experts in each 

specialty area to achieve or move toward desired conditions in the most effective way. Objectives 

would be met by implementing site-specific projects, and they are not intended to be hierarchical.

Additionally, there is acknowledgement in the introduction to chapter 1 of the forest plan stating 

the objectives were developed and are strongly influenced by recent trends, past experiences and 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

16

anticipated staffing levels, and short-term budgets. The “Forest Plan Content” section of the plan 

further describes objectives.

Concern Statement: The following desired conditions should be added to this section to address 

the importance of springs ecosystems. Springs have the necessary soil, water, and vegetation 

attributes to be healthy and functioning. Water flow patterns, groundwater recharge rates, and 

geochemistry are similar to historic levels. The location and status of springs and water resources 

is known, organized, and available. Springs or other natural waters remain in a natural 

undeveloped state and are not modified for livestock and/or human consumption. (36.03)

Response: We agree springs are an important resource. The desired conditions for springs have 

been clarified in the definition of riparian areas in chapter 2 in the “Natural Water Sources” 

section.

Standards and Guidelines (level of discretion) (56)

Concern Statement: The Forest Service should analyze the effects of abandoning standards and 

guidelines for management of riparian areas to comply with the National Forest Management Act.

(56.01)

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

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

generations to meet their needs. The National Forest Management Act (section 6(e)(1)) states that 

in revising plans, “provide for multiple use and sustained yield of the products and services 

obtained therefrom in accordance with the Multiple-Use, Sustained-Yield Act of 1960, and in 

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

and wilderness ...” Changes in standards and guidelines are analyzed in the environmental impact 

statement. Since the no-action alternative is the current forest plan, any changes to the current 

plan standards and guidelines (deletions, modifications, additions) are reflected in the action 

alternatives, with the effects of the differences in alternatives (including the no action-current 

plan versus the action alternatives) being analyzed and documented in chapter 3 of the

environmental impact statement.

Standards and guidelines related to the management of riparian areas have not been abandoned, 

and can be found in chapter 2 of the “Forestwide Management” section under “Riparian Areas” in 

the revised forest plan.

Concern Statement: The Forest Service should incorporate standards and guidelines for water 

quality monitoring and pollution control to ensure that water quality will be maintained at a level 

needed to support aquatic ecosystems, recreational uses, and scenic values; to address water 

quality issues and comply with the National Forest Management Act; and for both perennial and 

seasonal watercourses. (56.02)

Response: This concern is addressed throughout the “Watershed” section of the plan, including 

guideline 1 as water quality is one of the items assessed through the watershed condition 

framework and classification system. Water quality is also addressed in the desired conditions, 

guidelines and management approaches of “riparian areas,” “natural water sources” and 

“wetlands”. We cooperate with Arizona Department of Environmental Quality and New Mexico 

Environment Department to meet defined water quality standards.

Concern Statement: The Forest Service should add guidelines to protect natural waters. (56.03)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

17

Response: The forest plan has five guidelines that protect and enhance natural water sources.

The guidelines include the following: 

• Projects in upland habitats adjacent to streams should be designed to minimize input of 

sediment to streams.

• Water quality, quantity, and aquatic habitat at natural springs and seeps should be protected or 

enhanced.

• Fuel buildup should be reduced around natural water sources to protect them from 

uncharacteristic fire effects.

• Management activities should not impair soil moisture recharge at outflows of natural water 

sources.

• Projects affecting perennial streams should be designed and constructed to allow for the 

natural instream movement of native fish, except where barriers are necessary to preclude the 

movement of nonnative species.

Concern Statement: The Forest Service should clarify the enforcement mechanism for 

guidelines as they relate to mining and the Rosemont Mine. (56.04)

Response: The description of “guidelines” in the forest plan can be found in chapter 1, in the 

“Content” section. Guidelines must be followed, but they may be modified somewhat for a 

specific project if the intent of the guideline is followed and the deviation is addressed in a 

decision document with supporting rationale. A minerals project may be reasonably modified, if 

necessary, to be consistent with a forest plan guideline, which becomes part of the approved 

permit including the compliance enforcement authorities associated with the permit. When 

deviation from a guideline does not meet the original intent, a plan amendment is required. 

Requirements for a plan amendment are found in Forest Service Manual 1926.5. 

The Rosemont project has undergone a separate project-specific environmental analysis, which is 

consistent with the 1986 plan, the forest plan in effect at the time of the Rosemont project 

decision. Please see http://www.rosemonteis.us. In that analysis, an evaluation of the proposed 

Rosemont project’s consistency with the 1986 forest plan is disclosed, including any required 

amendments.

Concern Statement: The Forest Service should include standards and guidelines for riparian 

areas to ensure that riparian areas are adequately protected from the impacts of grazing and other 

activities to comply with National Forest Management Act and the Endangered Species Act.

(56.05)

Response: The forest plan includes guidelines for protecting riparian areas in chapter 2, 

“Forestwide Management” and in the “Riparian Area,” “Range Management,” and “Motorized 

Transportation System” sections. The forest plan complies with the National Forest Management 

Act and the Endangered Species Act.

Concern Statement: The Forest Service should reconsider replacing the standards and 

guidelines of the existing plan with desired conditions and objectives because the proposed 

standards are limited in scope and effect and are not certain to contribute to species viability: to 

comply with the National Forest Management Act; because desired conditions do not constitute a 

plan; and to provide for sanctions for noncompliance. (56.06)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

18

Response: The forest plan contains standards and guidelines in addition to desired conditions

and objectives. Chapter 3 of the final environmental impact statement contains “Species Diversity 

and Viability” sections (under Environmental Consequences). The plan includes “plan decisions.”

Once approved, any substantive changes to a plan decision will require a plan amendment. Forest 

plan decisions include goals (desired conditions), objectives, standards, and guidelines. Desired 

conditions set forth the desired social, economic, and ecological attributes of the Coronado 

National Forest. They attempt to paint a picture of what we (the public and Forest Service) desire 

the forests to look like and the goods and services we desire them to provide. Desired conditions 

are normally expressed in broad, general terms and are timeless in that there is no specific date by 

which they are to be completed. Desired conditions may only be achievable over a long 

timeframe (in some cases, several hundred years). In some cases, a desired condition matches the 

current condition, and the goal is to maintain it. Desired conditions are aspirations and are not 

commitments or final decisions to approve projects.

Objectives are concise, time-specific statements of measurable planned results that make progress 

toward or maintain desired conditions. An objective forms the basis for further planning to define 

the precise steps to be taken and the resources to be used in achieving desired conditions. The 

objectives represent just some of the expected outcomes or actions required to accomplish 

movement toward desired conditions. Not every action or objective the Coronado National Forest 

may initiate is identified in the plan, just the primary ones.

Standards are constraints upon project and activity decision making. A standard is an absolute 

requirement to be met in the design of projects and activities. A project or activity is consistent 

with a standard when its design is in accord with the explicit provisions of the standard; variance 

from a standard is not allowed except by plan amendment.

Guidelines are components with which a project or activity must be consistent, in either of two 

ways:

• The project or activity is designed exactly in accord with the guideline; or

• A project or activity design varies from the exact words of the guideline, but is as effective in 

meeting the purpose of the guideline to contribute to the maintenance or attainment of the 

relevant desired conditions and objectives.

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

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

supporting rationale. When deviation from a guideline does not meet the original intent, a plan 

amendment is required.

The purpose of desired conditions is to set a plan of action with long-term goals to achieve on a 

Coronado. Although the desired condition may not be met within the planning period, it is still 

established as a goal to help set parameter for the management approach ad implementation. 

Objectives set up precise steps for resource management. Standards and guideline ensure we are 

complying with the National Forest Management Act. Standards set constraints on allowable 

actions for the resource, and guidelines require projects and activities to be consistent with the 

forest plan. 

Concern Statement: The Forest Service should include more standards in the plan because they 

are more binding than guidelines and goals; because priorities can change with changes in Forest 

Service management; and to protect natural waters. (56.07)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

19

Response: The forest plan contains components for natural waters, including desired conditions, 

objectives, and guidelines.

Objectives are concise, time-specific statements of measurable planned results that make progress 

toward or maintain desired conditions. An objective forms the basis for further planning to define 

the precise steps to be taken and the resources to be used in achieving desired conditions. The 

objectives represent just some of the expected outcomes or actions required to accomplish 

movement toward desired conditions. Not every action or objective the Coronado National Forest 

may initiate is identified in the plan, just the primary ones.

Standards are constraints on project and activity decision making. A standard is an absolute 

requirement to be met in the design of projects and activities. A project or activity is consistent 

with a standard when its design is in accord with the explicit provisions of the standard; variance 

from a standard is not allowed except by plan amendment.

Guidelines are components with which a project or activity must be consistent, in either of two 

ways:

• The project or activity is designed exactly in accord with the guideline; or

• A project or activity design varies from the exact words of the guideline, but is as effective in 

meeting the purpose of the guideline to contribute to the maintenance or attainment of the 

relevant desired conditions and objectives.

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

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

supporting rationale.

All of these plan components are binding. When projects activities do not meet the forest plan 

guidelines, the project has to be either dropped or modified to meet the plan components or the 

plan must be amended to ensure all plan components are met, based on the intent of the guideline 

that was developed. The plan components can be found in chapter 2, in the “Forestwide 

Management,” “Natural Waters” sections of the forest plan.

Concern Statement: The Forest Service should include standards and guidelines related to Total 

Maximum Daily Loads (TMDLs) to ensure that the plan will help improve impaired waterbodies.

(56.08)

Response: In the forest plan, chapter 2, the forestwide guidelines and management approaches 

for natural water sources provide guidance to help meet total daily maximum loads. In the 

environmental impact statement, chapter 3, the “Water Resources – Affected Environment” and 

“Water Resources – Environmental Consequences” sections provide total daily maximum load

analysis. 

Concern Statement: The Forest Service should include standards and guidelines to limit 

impacts on watershed health: to address impacts from recreation, mining, timber harvesting, 

water diversion, road construction and maintenance, and grazing; and to prohibit road 

construction, motorized recreation, mining, logging, and grazing within at-risk watershed areas.

(56.09)

Response: The forest plan contains plan components, including standards and guidelines, that 

address watershed health, See the “Forestwide Management” section in chapter 2 of the forest 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

20

plan. Many of the standards and guidelines that address watershed health and protection measures

related to recreation, mining, timber harvestings, road construction, and grazing are contained in

sections outside of the watershed guidelines. The “Watershed” section under “Forestwide 

Management” has a list of general standards and guidelines that apply to the watershed health and 

function; however, specific guidelines to address these resources are located in subsequent 

resource areas. 

Concern Statement: The Forest Service should include standards for wildlife connectivity to 

provide accountability and strategy to reach the desired conditions that require coordination with 

other land management agencies, private landowners, land developers, counties, transportation 

authorities, land trusts, conservation organizations, Fort Huachuca, the Western Regional 

Partnership, the Arizona Wildlife Linkages Workgroup, and public wildlife agencies to ensure 

biological connectivity and secure habitat linkages between forest units. (56.10)

Response: The forest plan contains management approaches that address coordination with 

county, municipal, State, and Federal agencies; adjacent landowners; and nongovernmental 

organizations to ensure habitat connectivity between sky islands is preserved, restored, and 

enhanced for wildlife using corridors between ecosystem management areas of the Coronado.

Forest plan components for protecting animals and rare plants are also found in various other 

sections of the forest plan in chapters 2, 3, and 4.

Concern Statement: The Forest Service should retain the standards for maintaining visual 

quality/scenic integrity and road density. (56.11)

Response: The Coronado National Forest is implementing scenery management. The forest plan 

contains desired conditions, guidelines and management approaches to maintain scenery. The 

plan provides guidance for managing road density by setting desired conditions for the various 

land use zones. In the Roaded Backcountry Land Use zone, the desired road density standard is 

inferred by desired conditions and a guideline that limit the level and type of development to 

protect the natural character inherent in this zone. 

Concern Statement: The Forest Service should provide standards and guidelines for surface

water and groundwater resources because mining activities can negatively impact groundwater 

resources. (56.12)

Response: Mining activities on National Forest System land are regulated by a variety of 

government agencies depending on the law, regulation, and policy or delegated authority. We do

not have jurisdiction over the surface water and groundwater quality and therefore has no 

authority to set standards and guidelines for these resources. We do identify management 

approaches. The Arizona Department of Water Resources has jurisdiction over surface water and 

groundwater quantity resources in the state. The Arizona Department of Environmental Quality 

has jurisdiction over surface water and groundwater quality in the state. We work with both 

agencies to protect water quantity (water rights and instream flows) and water quality (Clean 

Water Act requirements). Since the State has jurisdiction on water quantity and quality, we defer

to State standards and guidelines. Any mining project would need to obtain permits from the State 

agencies in order to operate on Federal land.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

21

Monitoring (33)

Concern Statement: The Forest Service should expand and support ecological monitoring to 

address the threats from climate change, increased usage rates, and distributions of invasive 

species to avoid monitoring results that are biased and narrow. (33)

Response: The 2012 Planning Rule requires that forest plans developed under prior planning 

regulations, including the 1982 Planning Rule, follow the updated 2012 rule guidance on the 

required content in the monitoring plan. The Coronado developed its plan monitoring program 

consistent with the requirements of the 1982 rule but also with an eye towards meeting the 2012 

rule monitoring requirements. See “Chapter 6. Monitoring and Evaluation” for a list of 

monitoring categories related to climate change and invasive species. Possible monitoring 

methods and data sources are shown in chapter 6, but these can be amended as new methodology 

and technology becomes available. Also see “Chapter 6. Monitoring and Evaluation” for changes 

between the draft and final plans.

Concern Statement: The Forest Service should clarify whether monitoring is required.(33.1)

Response: As stated in Chapter 6, “Monitoring and Evaluation”, monitoring and evaluation are 

separate and sequential activities required by National Forest Management Act regulations to 

determine how well the forest plan is working. Monitoring and evaluation are also required by the 

1982 Planning Rule to consider the effects of national forest management on land, resources, and 

communities adjacent to or near the national forest undergoing forest plan revision and the effects 

on national forest management of activities on nearby lands managed by other Federal or other 

government agencies or under the jurisdiction of local governments.

Proposed Action, Decision (41)

Concern Statement: The Forest Service should revise the EIS to include an analysis of the 

socio-economic impacts to owners of unpatented mining claims. (41)

Response: The forest plan does not contradict or impair the rights inherent to holders of 

unpatented mining claims, which include access to, and ownership of, locatable minerals when a 

mineral discovery has been made. The plan is in accordance with the General Mining Law of 

1872, as amended, and it also is accordance with subsequent laws that regulate the management 

of surface resources. As such, we are required under the National Environmental Policy Act 

(NEPA) to evaluate, disclose, and mitigate impacts to other natural resources and to 

socioeconomic resources; language in the revised forest plan follows this direction.

Concern Statement: The Forest Service should resolve inconsistencies between the EIS and the 

LRMP including inconsistent use of terminology and definitions, such as characterization of 

species and the definition of Wild Backcountry. (41)

Response: The plan and final environmental impact statement have been reviewed and revised to 

resolve inconsistencies between the documents as well as make other changes.

Concern Statement: The Forest Service should modify the table showing suitable uses to 

include activities in addition to the extractive uses. (41)

Response: Table 14 provides information on selected activities that may be allowed on the 

Coronado National Forest and is not inclusive of all activities that may be considered over the 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

22

planning period. Existing special uses may be reauthorized where they are not suitable on a caseby-case basis, except for uses that are not suitable forestwide.

Concern Statement: The Forest Service should acknowledge that suitability must be determined 

in the plan and may not be delegated to the discretion of the responsible official. (41.01)

Response: Responsible officials have the discretion to determine the scope and design in their 

project and activity decision making, within the constraints that they are consistent with the forest

plan, applicable law, regulations, and policy.

As discussed in the forest plan “Decisions” section of chapter 1, suitability is one of six plan 

decisions. Suitability is described as the appropriateness of applying certain resource management 

practices (uses) to a particular area of land. A unit of land may be suitable for a variety of 

individual or combined uses. Except for projects with a purpose of timber production, a project or 

activity can be consistent with plan suitability determinations in either of two ways: (1) a use for 

which the area is specifically identified in the plan as suitable, or (2) not a use for which the area 

is specifically identified in the plan as suitable, but is nonetheless appropriate for that location.

Concern Statement: The Forest Service should consider an aquatic conservation strategy to 

protect riparian resources and maintain species viability. (41.03)

Response: Chapter 2 of the forest plan includes elements in the desired condition that are aquatic 

related: wetlands, riparian areas, natural water sources, constructed water sources. The plan 

includes many components designed to enhance or restore native, warm water fish habitat. 

Examples include NWS-O-1 and NWS-O-2, which are objectives designed to acquire water 

rights on areas where fish occur as well as reconstruct springs to support native wildlife including 

fish. Guideline ISM-G-1 will result in the removal of nonnative invasive plant and animal species 

where fish and other special status aquatic species occur. The guidelines NWS-G-2, NWS-G-3, 

NWS-G-4, and NWS-G-5 allow for natural instream movement; reducing fuel build up; and 

protecting water quality, quantity, and habitat features at natural springs and seeps prioritized in

habitat where fish occur.

Concern Statement: The Forest Service should ensure the plan is consistent with other planning 

documents and improve the integration of the plan with local plans in order to combine 

preservation resources, efforts, and to meet shared goals. Including the Aravaipa Draft Ecosystem 

Management Plan, City of Sierra Vista planning documents, Cooperative Management Area 

agreement, Cochise County and City of Sierra Vista land use plans, and the Sonoran Desert 

Conservation Plan. (41.04, 41.06)

Response: The plan is consistent with other planning documents. Appendix B of the 

environmental impact statement discusses coordination with other public planning efforts in 

which we reviewed the planning and land use policies of other Federal agencies, State and local 

governments, and Indian tribes. This appendix includes consistencies, potential discrepancies, and 

recommendations for resolving inconsistencies among the other public plans. No major conflicts 

were identified. The main focus of the plan is ecosystem restoration and resilience which requires 

and “all-lands approach” and involves working with adjacent landowners and stakeholders and 

working together across boundaries to decide on common goals for the landscapes.

Concern Statement: The Forest Service should clarify the priorities in the plan to identify which 

goals will be given priority under circumstances of limited funding, and to identify which uses are 

most valuable and valued by the public. (41.09)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

23

Response: We developed realistic objectives, standards, and guidelines that can be implemented 

with anticipated future budgets (expected to be similar to current budgets). Chapter 1 of the plan 

acknowledges that objectives to achieve desired conditions are strongly influenced by recent 

trends, past experiences, and anticipated staffing levels and short-term budgets. Chapter 6 of the 

plan acknowledges the uncertainties related to monitoring and evaluation relative to funding and 

prioritization as required by the National Forest Management Act: 

“Budgetary constraints may affect the level of monitoring that can be done in a particular 

fiscal year. If budget levels limit the Coronado National Forest’s ability to perform all 

monitoring tasks, then those items specifically required by law are given the highest 

priority.”

Concern Statement: The Forest Service should ensure the plan meets legal requirements 

including the 1982 Planning Rule or the 2012 Planning Rule, National Forest Management Act, 

and NEPA. (41.10, 41.23)

Response: We followed the requirements outlined in the National Environmental Policy Act, 

National Forest Management Act, and 1982 planning rule regulations (as allowed by the 

transition language in the 2012 Planning rule at 36 CFR 219.17(b)(3)) to develop the forest plan 

and environmental impact statement. 

Concern Statement: The Forest Service should revise the forest plan to ensure the plan will 

result in achieving the desired conditions and ensure the plan has clear achievable objectives, 

expected outcomes, indicators of success, funding plans, and contingency plans. (41.12B)

Response: We developed realistic objectives, standards, and guidelines that can be implemented 

with anticipated future budgets (expected to be similar to current budgets). Chapter 1 of the plan 

acknowledges that objectives to achieve desired conditions are strongly influenced by recent 

trends, past experiences, and anticipated staffing levels and short term budgets. Desired 

conditions may be achievable over a long period or may be an existing condition on the Coronado 

National Forest. Desired conditions are described in chapter 1 of the forest plan.

The goal of the Coronado National Forest is to achieve the desired conditions through the plan 

components outlined in the proposed plan. Chapter 6 of the plan acknowledges the uncertainties 

related to monitoring and evaluation relative to funding and prioritization as required by the 

National Forest Management Act: 

“Budgetary constraints may affect the level of monitoring that can be done in a particular 

fiscal year. If budget levels limit the Coronado National Forest’s ability to perform all 

monitoring tasks, then those items specifically required by law are given the highest 

priority.”

For example, according to the plan in chapter 2, “Forestwide Management” section “Vegetative 

Communities,” Madrean pine-oak woodlands:

In Madrean pine-oak woodland communities, common animal species include the acorn 

woodpecker. The acorn woodpecker is a management indicator species for this 

vegetation community. Therefore monitoring and evaluation for Madrean pine-oak 

woodlands is based on the population and distribution of the acorn woodpecker. The 

following table outlines the monitoring and evaluation strategy for Madrean pine-oak 

woodlands which is directly linked to the objective of this vegetative community to treat 

at least 25,000 acres of Madrean pine-oak woodlands using wildland fire (planned and 

unplanned ignitions), prescribed cutting, and mastication every10 years.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

24

Monitoring and Evaluation for Madrean pine-oak woodland communities

Resource 

Area Monitoring Question

Possible 

Monitoring 

Methods and 

Data 

Sources

Frequency 

of 

Monitoring 

(Years)

Frequency 

of 

Evaluation 

(Years)

Data 

Precision 

and 

Accuracy

Madrean 

Pine-Oak 

Woodland

The acorn woodpecker is identified 

as a management indicator species 

in the Madrean pine-oak woodland. 

How have populations and 

distribution of acorn woodpeckers 

changed?

Population: 

numbers; 

distribution: 

via habitat.

5 5 B

Concern Statement: The Forest Service should revise the forest plan to emphasize managing the 

forest for ecosystem health rather than mining and reduce the emphasis on consumptive uses.

(41.12C)

Response: We do not give greater weight to one resource interest over another. The forest plan 

provides for the full scope of natural resource issues impacting the Coronado. Most of the 

guidance for mining is governed by law, regulation, and policy, which does not need to be 

repeated within the forest plan. Future projects and activities, of any kind, must be consistent with 

the forest plan and various laws, agency policy, and direction to manage vegetation and natural 

resources for multiple uses, all of which provide resource outputs for human society, either 

directly or indirectly.

The forest plan emphasizes ecosystem health in the desired conditions and plan components for 

vegetation communities in chapter 2. In particular, ecosystem restoration and resiliency is one of 

five key components analyzed in the plan which provides critical understanding of the 

biodiversity in ecosystems (including forests).

Concern Statement: The Forest Service should ensure the plan complies with multiple use 

requirements, conforms to mandatory requirements, and ensure that supporting data is accurate 

with claims substantiated by good science. (41.12D)

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

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

generations to meet their needs. The plan is in compliance with the legal requirements of the 

National Forest Management Act and Multiple Use–Sustained Yield Act, which requires forests to 

be managed using multiple-use, sustained yield principles. The National Forest Management Act

(section 6(e)(1)) states that in revising plans,

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

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

particular, include coordination of outdoor recreation, range, timber, watershed, wildlife 

and fish, and wilderness...”

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

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

range, timber, watershed, and wildlife and fish purposes.”
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

25

Development of the revised forest plan and plan components was based on the best available 

science and information; citations are provided throughout the environmental impact statement 

and revised plan. Consistent with the National Environmental Policy Act and Council on 

Environmental Quality regulations, we used a systematic, interdisciplinary approach in the 

planning and decision-making process, ensuring the integrated use of natural and social science 

and the environmental design arts. In particular, the revised plan responds directly to the purpose 

and need, including five identified needs for change, by providing new and updated direction 

based on the best available science. We revised or added plan components to reflect current 

scientific literature and information. For example, related to the “ecosystem restoration and 

resiliency” need for change, the revised forest plan prescribes new and updated direction 

regarding habitat conservation and restoration, species conservation, management of vegetative 

fuels, management of wildfire and ecological responses to it, management of invasive species, 

and dealing with the effects of climate change.

Concern Statement: The Forest Service should reorganize the plan for greater clarity by 

removing material from the plan that should be in the environmental impact statement and 

include general information on regulations in an appendix. (41.12E)

Response: We followed the requirements outlined in the National Environmental Policy Act, 

National Forest Management Act, and 1982 planning rule regulations to develop the draft forest 

plan and draft environmental impact statement. The planning team determined the current 

organization of the plan to be the most efficient within these requirements. 

Concern Statement: The Forest Service should address potential solar and wind energy 

development because these uses are incompatible with the scenic integrity and recreational values 

of the Forest. (41.13)

Response: Table 18 in chapter 5 of the plan identifies suitable and nonsuitable areas for other 

energy (developments), which includes wind turbines and solar panels. Development of wind and 

solar energy could only occur within identified suitable areas and would be consistent with the 

guidelines identified for scenery and recreation. Additionally, the Forest Service has agencyspecific guidance in law, regulation, and policies established at the national level when 

considering new energy projects including compliance with the National Environmental Policy 

Act.

Concern Statement: The Forest Service should enhance the proposed action to address modern 

principles of resource management, the special qualities of highly biodiverse forests, and climate 

change as an important stressor of forests. (41.14)

Response: The proposed action addresses resource management through identified standards, 

guidelines, objectives, and management approaches for resource management categorically 

broken down by ecosystem type and management areas. These management approaches were 

developed using best available science and professional judgments and included public input and 

collaboration with significant tribal involvement, which helped shape these approaches. The 

Forest Service believes modern principles of resource management are incorporated directly and 

indirectly in the plan.

The proposed action and alternatives were developed to address biodiversity and potential 

changes to the environment attributable to climatic change. The proposed action and alternatives 

respond to these issues to varying degrees by increasing plant community resilience and 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

26

addressing uncertainties associated with climate change impacts to habitat and water availability. 

The plan protects biodiversity by setting forth desired conditions, objectives, standards, and 

guidelines to maintain species diversity and species viability across the planning area. Ecosystem 

restoration and resiliency is one of five key components analyzed in the plan which provides 

critical understanding of the biodiversity in ecosystems (including forests).

Climate change is addressed indirectly throughout the proposed plan with desired conditions in 

the form of functional ecosystems and resilient landscapes. Climate change is addressed directly 

in desired conditions for response to climate change, management approaches, and monitoring 

plan implementation where appropriate. Appendix A of the forest plan provides a more detailed 

explanation of climate change patterns and trends in the Southwest and the potential implications 

to the Coronado National Forest and discusses the strategy the Coronado is using to address 

climate change. In addition, the “Response to Climate Change” section of chapter 2 discussed 

desired conditions and management approaches for climate change.

Concern Statement: The Forest Service should ensure that the travel management plan and the 

land management plan are consistent with one another: as it relates to decommissioning of roads,

as it relates to new road construction and improvements, as it relates to consistency with the 

Forest Service Manual, and as it relates to decision making and conservation-related management 

recommendations. (41.15)

Response: While the forest plan does not duplicate the Travel Management Rule or the 

directives related to it, it is consistent with both and is meant to be used along with the directives 

and the motor vehicle use map. The forest plan provides a framework to guide future changes to 

the transportation system, which can be found in chapter 2 under the “Motorized Transportation 

System” section. Potential changes to the Coronado’s transportation system would be evaluated 

in separate analysis through future project-level decision making such as the implementation of 

the Travel Management Rule (36 CFR§212). These decisions would be consistent with the 

National Environmental Policy Act and Forest Service manual and handbook direction and would 

include analysis and opportunity for public involvement. Site-specific travel management 

planning will use the framework set by the plan (such as desired conditions, standards, and

guidelines) and will consider potential resource impacts, access needs, public input, and 

alternative views. If undesirable resource conditions resulted from open roads, they could be 

addressed through site-specific evaluation and analysis.

Concern Statement: The Forest Service should use the word "mountain" instead of "sky island"

to reduce use of nontechnical vocabulary. (41.08)

Response: We determined that the existing wording is more concise given that sky islands are 

defined as isolated mountains surrounded by radically different lowland environments. As such, 

this has significant implications for natural habitats as demonstrated on the Coronado National 

Forest. Therefore, no changes were made between the draft and final versions of the revised plan.

Concern Statement: The Forest Service should modify figure 4-101 to include county 

boundaries. (41.11) 

Response: The county boundaries have been included in figures 1 and 2 in the forest plan.

Concern Statement: The Forest Service should have included Management Unit 16 in the draft 

environmental impact statement because it will cut off the north end of the Santa Rita Mountains 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

27

as a viable location for wildlife and the public should be provided an opportunity to comment. 

(41.05, 29.49)

Response: Including Management Area 16 in the revised plan prior to the Rosemont project 

decision being made would have been pre-decisional, both to the Rosemont project decision, and 

to the revised forest plan decision. Projects must be consistent with the Forest Plan in effect at the 

time the project decision is made, which the Rosemont project with its plan amendment was, as it 

was consistent with the 1986 forest plan, in effect at the time of the Rosemont project decision. 

There is no requirement to revisit project decisions made under a previous Forest Plan, when a 

new revised forest plan goes into effect. That said, the revised plan will be reviewed and potential 

adjustments may be made via a plan amendment to ensure consistency between the Rosemont 

project and revised forest plan if any adjustments are felt to be warranted.

Concern Statement: The Forest Service should provide an executive summary that clearly 

shows the proposed changes in the plan. (41.26)

Response: We determined an executive summary was not necessary and would not substantially 

differ from chapter 1 of the plan; therefore, no changes were made between the draft and final 

versions of the revised plan. Appendix H of the final environmental impact statement provides a 

crosswalk between key direction from the 1986 forest plan and the revised forest plan.

Concern Statement: The Forest Service should proceed with the proposed plan including the 

suitability, monitoring and evaluation, and climate change sections. The plan takes a proactive, 

science-based approach to managing the forest and promotes ecosystem restoration and resiliency 

and preservation of open space. (41.17, 41.21)

Response: Thank you for your comment.

Concern Statement: The Forest Service should provide justification for changing the current 

forest plan and evaluate the effectiveness of the 1986 plan. This should include identifying 

successes, failures, and inadequacies associated with desired conditions, objectives, and legal 

requirements of the 1986 plan. The public should be involved in this process. (41.18, 41.19)

Response: The National Forest Management Act requires forest plans be revised when 

environmental conditions, social conditions, or both have significantly changed and recommends 

a revision occur at least every 15 years (Coronado forest plan revision began in 2005). The 

original plan was used as a building block for the revised plan. Many of the original plan 

components were retained, some were modified, and some that were not within management 

control or that were already addressed by law, regulation, or policy were not carried forward. In 

the draft environmental impact statement, the 1986 plan served as the no action alternative and 

subsequently was the baseline of comparison for the other alternatives (see tables 6 and 7 of 

chapter 2) for side by side comparisons. Chapter 3 of the final environmental impact statement

provides thorough analysis of the no-action alternative (1986 plan) from the context of the five 

revision topics: ecosystem restoration and resiliency, visitor experience, access to National Forest 

System lands, preservation of open space, and communities, collaboration, and partnerships.

Extensive public involvement and collaboration, in addition to tribal consultation, has occurred in 

the development of the plan. See the “Public Involvement and Collaboration” section in chapter 1

of the environmental impact statement.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

28

Monitoring and evaluation are required by the National Forest Management Act for the revised 

forest plan to determine how well it is working. Monitoring and evaluation provide ongoing 

feedback about management effectiveness and keep direction found in the forest plan up to date 

and relevant by being responsive to changing conditions and issues—including public desires—

and to new information, such as research results or outcomes from management activities. 

Concern Statement: The Forest Service should include actions to ensure sustainability of 

multiple uses into the future and support research as a primary use to preserve the resources for 

future generations. (41.25, 41.25)

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

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

generations to meet their needs. The legal requirements of the National Forest Management Act 

and Multiple Use-Sustained Yield Act require forests to be managed using multiple use, sustained 

yield principles. The National Forest Management Act (section 6(e)(1)) states that in revising 

plans,

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

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

particular, include coordination of outdoor recreation, range, timber, watershed, wildlife 

and fish, and wilderness...”

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

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

range, timber, watershed, and wildlife and fish purposes.”

Further, plan direction to maintain or move toward desired conditions (including ecological, 

social, and economic) are in alignment with the Forest Service mission to “sustain the health, 

diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present and 

future generations”. They will also help us meet the intent of congressional mandates such as the 

Multiple Use-Sustained Yield Act of 1960 and the Healthy Forests Restoration Act of 2003.

Chapters 2 and 3 of the plan discuss multiple use topics, including those listed specifically by the 

Multiple Use-Sustained Yield Act.

Research is considered a special use and the forest plan incorporates general guidance under the 

“Special Use” section of chapter 2. In addition, provisions for research exist in specially 

designated areas including research natural areas, and zoological-botanical areas with specific 

direction for research in wilderness which can be found in the section “Research in Wilderness”

in the “Designated Wilderness Areas” section in chapter 3. It states the desired condition: 

“Wilderness areas provide an ideal outdoor laboratory for studying the natural 

environment in its most pristine form. Scientific studies allow for discovery of wilderness 

dependent information. Research contributes to the understanding of complex ecosystem 

interactions and disturbances, and aids managers in improving wilderness management 

strategies. Field studies do not detract from wilderness character.”

Across the Coronado, there are six research natural areas that are areas “the Forest Service has 

designated to be permanently protected and maintained in natural condition, so they may serve as 

experimental research controls and monitoring sites for the particular ecosystem they represent 

and used for education.” Comparison of monitoring data between areas where uses occur and 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

29

where they do not can inform discussions about the sustainability of particular uses or the need to 

make adaptive changes to the use.

Resource and Area Management (49)

Concern Statement: The Forest Service should retain the current special use permitting process 

and not add additional application or compliance requirements.

Response: Special uses are discussed in forest plan chapter 2 under the “Special Uses” section. 

The forest plan supports continued special use activities and provides desired conditions, 

objectives, standards, guidelines, and management approaches for administration of these uses. 

These plan components do not replace or remove the current special use permitting process. 

Permitting and compliance are generally covered in national policy and are therefore outside the 

scope of the forest plan

Concern Statement: The Forest Service should use and acknowledge volunteers for various 

projects including cave resource protection, trash removal, trail maintenance, trail technical 

expertise, preservation activities and reforesting Rustler Park and create a small fund to reimburse 

volunteers for their expenses. (49.03, 49.04, 49.12)

Response: The use of volunteers is included as a management approach for accomplishing plan 

desired conditions, objectives, standards, and guidelines. Volunteers are specifically mentioned in 

the forest plan under management approaches for invasive species, recreation, cultural resources, 

and the Pinaleño Ecosystem Management Area.

Additionally, the “Collaboration and Volunteers” section of forest plan appendix B supports 

volunteerism and identifies possible areas where volunteers could work well: 

“The Coronado National Forest intends to create increasing opportunities for volunteers 

and partners to be more active as part of national forest management.”

Volunteer reimbursement is directed by the Forest Service handbook and is outside the scope of 

this plan.

Concern Statement: The Forest Service should retain Management Areas 2A and 2B. (49.14)

Response: The basic concepts of former Management Areas 2A and 2B described under the 

1986 forest plan were carried forward in the proposed plan in the new Developed Recreation 

Management Area. This new management area was developed based on public input, 

administrative and other user needs, and comments received during the planning process.

Concern Statement: The Forest Service should maximize conservation and restoration efforts in 

particular by protecting desert ecosystems, springs, summits, Cave Creek Canyon, and Sky 

Islands by limiting human uses, actively managing the forest allowing for stewardship, and using 

fire to help improve forest health. (49.06, 49.07, 49.08, 49.10, 49.16, 49.17, 49.23, 49.27, 49.28)

Response: We agree with your comments and the forest plan includes components to address 

protecting desert ecosystems. See the following discussions: 

• “Desert Communities” in chapter 2

• “Forestwide Management,” Springs under “Natural Water Sources” in chapter 2
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

30

Cave Creek Canyon under the Chiricahua Ecosystem Management Area and the sky islands of the 

Coronado are addressed collectively throughout the plan based on “Forestwide Management,” 

“Management Areas,” and “Geographic Areas”.

Concern Statement: The Forest Service should ensure no one use precludes or significantly 

diminishes other uses. In particular, managing for biodiversity or ecosystem management should 

be avoided because this approach would conflict with the Multiple Use-Sustained Yield Act and 

inappropriately shift the agency’s authority/focus. (49.02, 49.15)

Response: We agree a focus solely on biodiversity over other uses would not meet the legal 

requirements of the National Forest Management Act or Multiple Use-Sustained Yield Act, which 

requires forests to be managed using multiple use-sustained yield principles. The plan contributes 

to ecological, social, and economic sustainability focused on meeting the needs of the present 

generation without compromising the ability of future generations to meet their needs. The plan 

gives direction to manage the Coronado National Forest consistent with the Multiple UseSustained Yield Act of 1960 and provide goods and services, including outdoor recreation, timber, 

range, watershed, wildlife, and fish.

Although the plan and environmental impact statement are organized by individual resources or 

uses, the development of the plan and environmental impact statement used an interdisciplinary 

process (see “List of Preparers” section in the forest plan and the “Consultation and 

Coordination” section in chapter 4 of the environmental impact statement) considering input from 

a wide range of stakeholders and resource specialists with the intent of providing direction for all 

forest natural resource management activities.

Future projects and activities must be consistent with the forest plan and various laws, and agency 

policy and direction to manage vegetation and natural resources for multiple uses, all of which 

provide resource outputs for human society either directly or indirectly.

Concern Statement: The Forest Service should clarify whether they will regulate activities on

the Coronado National Forest that will result in cumulative effects beyond the forest boundary.

(49.13)

Response: The environmental impact statement for the forest plan does consider activities on 

other ownerships to describe the potential cumulative environmental consequences on a particular 

resource. 

The plan is programmatic and does not identify (or prohibit) specific activities that may result in 

cumulative effects beyond the Coronado National Forest boundary. Activities would be addressed 

site specifically at the project level, which would include cumulative effects and would be 

consistent with the Council on Environmental Quality’s National Environmental Policy Act 

regulations 1508.7: 

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

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

actions regardless of what agency (Federal or non-Federal) or person undertakes such 

other actions.”

Additionally, many potential activities are guided by existing law, regulation, and policy, which 

are outside of the scope of the forest plan as described in chapter 3 of the environmental impact 

statement. Future projects and activities, of any kind, must be consistent with the forest plan and 
Appendix A. Response to Comments

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Revision of the Coronado National Forest Land and Resource Management Plan

31

various laws, agency policy, and direction. The plan provides protections (see standards and 

guidelines for each resource area and land use zones) to regulate activities and future activities on 

Coronado. Further, management approaches help guide decision making by the responsible 

official.

Concern Statement: The Forest Service should determine the suitability for timber production 

of portions of the national forest and review its prior classification of lands as unsuitable for 

timber production to comply with the National Forest Management Act and case law. (49.18)

Response: The forest plan follows Forest Service Handbook 2409.13, chapter 20 on evaluating 

lands suitable for timber production. Timber suitability is described in chapter 5 of the forest plan, 

and the process for determining timber suitability is described in appendix C of the environmental 

impact statement.

Concern Statement: The Forest Service should explain how suitability was evaluated. Including 

how staff experience was used and how needs and conditions were measured. (49.19)

Response: The forest plan follows Forest Service Handbook 2409.13 chapter 20 on evaluating 

lands suitable for timber production. Suitability determinations for timber production are

described in chapter 5 of the plan, and in appendix C of the environmental impact statement. 

Suitability for livestock grazing is described in chapter 5 of the forest plan and appendix E of the 

environmental impact statement. Suitability determinations for other resources are described in 

chapter 5 of the forest plan.

Concern Statement: The Forest Service should acknowledge that the historical range of 

variability is neither achievable nor sustainable in light of climate change, landscape 

fragmentation, and nonnative species invasions. (49.22)

Response: The historical range of variation may (a) provide information relevant to ecosystem 

resiliency or vulnerability to projected climate change effects and other disturbances; and (b) help 

to identify the most urgent ecosystem needs and effective restoration methods to increase 

resilience for a given ecosystem. We agree the historical range of variation may never be 

achievable given various ecological and social reasons. As such, it does not define desired 

conditions but provides valuable information for reference. It has been useful for understanding 

fire ecology and disturbance processes, watershed hydrological function, and distribution of plant 

and animal populations.

Concern Statement: The Forest Service should manage the lands for the people by providing 

for outdoor recreation, human occupancy, and use, and avoid restricting access to the forest. 

(49.25, 49.29)

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

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

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

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

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

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

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

range, timber, watershed, and wildlife and fish purposes.”
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

32

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

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

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

particular, include coordination of outdoor recreation, range, timber, watershed, wildlife 

and fish, and wilderness...”

The proposed plan provides broad guidance and information for project decision making and is 

strategic in nature. It does not contain project and activity decisions such as permitting or 

prohibiting occupancy, use, or access. Decisions to close or restrict access on the Coronado 

National Forest are determined during travel management planning. Public access determined by 

the travel management process is guided by the motor vehicle use map. As part of this process, 

we identified the road system needed for safe and efficient travel and for administration, 

utilization, and protection of National Forest System lands.

Additionally, the plan provides for a variety of recreation opportunities: motorized, 

nonmotorized, developed, dispersed, and everything in between. However, not every recreation 

opportunity can be found everywhere on the Coronado National Forest.

Concern Statement: The Forest Service should correct the description of the Huachuca 

Ecosystem Management Area to correctly refer to Red Rock Canyon. (49.26)

Response: The change has been made to the forest plan.

Concern Statement: The Forest Service should reconsider placing emphasis on open space as a 

value in the plan because this does not reflect the values of the nearby rural communities. (49.30)

Response: The topic of preservation of open space is addressed in the forest plan in the sections 

“Range Management” and “Land Ownership Adjustments and Boundary Management” because 

of its importance on a national, and local level. It is reflected in the Forest Service strategic plan

as well as a number of County strategic plans, including many of the counties surrounding the 

Coronado National Forest. It is a particularly important land use issue, given both the public’s 

desire to maintain the “rural character” of county lands and the need to accommodate rapidly 

growing populations in municipalities. The concept of preserving open space is widely 

recognized as a primary tool for sustaining ecosystem components and processes across 

landscapes.

Concern Statement: The Forest Service should use the Four Traditional Guiding Principles of 

the Elders Cultural Advisory Council when addressing climate change issues. (49.31)

Response: The importance of cooperating with tribes and incorporating their perspectives, 

concerns, and traditional knowledge into management decisions are discussed in chapter 2, 

“Tribal Relations,” in the management approaches section. This includes working with the White 

Mountain Apache Tribe and taking its best management practices into account.

Concern Statement: The Forest Service should finalize and implement the Mount Graham 

recovery plan. (49.32)

Response: On page 277 of the draft environmental impact statement, we acknowledged that a 

revision of this recovery plan is currently in preparation. When the recovery plan is finalized, the 

forest plan will comply with it under guideline ARP-G-1. The creation of a recovery plan is under 

the authority of the U.S. Fish and Wildlife Service rather than the Forest Service. We will assist in 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

33

this process as much as possible and will comply with it during project planning and 

implementation phases.

Roles, Authorities (51)

Concern Statement: The Forest Service should prohibit foresters from taking money from 

mining companies because it causes a conflict of interest. (51.01)

Response: This is outside the scope of the forest plan. 

Concern Statement: The Forest Service should have the authority to close areas to permit 

recovery and facilitate decision making. (51.02)

Response: This is outside the scope of the forest plan.

Concern Statement: The Forest Service should increase staffing on the forest to address 

increasing visitation rates and have a full-time presence. (51.03)

Response: Staffing levels are outside the scope of the forest plan.

Concern Statement: The Forest Service should explain why national forests are managed under 

the Department of Agriculture instead of the Bureau of Land Management. (51.04)

Response: This is outside the scope of the forest plan. Information on the history of the Forest 

Service can be found at: http://www.fs.fed.us/documents/USFS_An_Overview_0106MJS.pdf

Social Actions or Analyses

Concern Statement: The Forest Service should integrate tribal traditional ecological knowledge 

into the planning process. (54.01)

Response: Integration of tribal traditional ecological knowledge into the planning process is 

found in chapter 2 of the forest plan in the “Tribal Relations, Management” section. We are

working with tribes to collaborate in ecosystem restoration efforts.

Concern Statement: To comply with laws and the U.S. Constitution, the Forest Service should 

reconsider the deference provided to Native Americans’ practice of religion and ensure that the 

plan will protect the cultural and historical foundations of the way of life for Native American 

tribes, such as the Ndee. (54.02, 54.04)

Response: We agree that the practice of religion for federally recognized tribes on National 

Forest System lands should continue. Such practices are protected under laws and regulations in 

which the forest plan and forest management is compliant. Enforcement of these laws and 

regulations is not a forest plan component but is a requirement of the agency, regardless of the 

land management plan in effect.

Concern Statement: The Forest Service should provide for training of new employees about the 

forest’s unique legal relationship with the tribes to assist them in avoiding mistakes. (54.03)

Response: A discussion of training of new employees is found in chapter 2 of the plan in the 

“Tribal Relations; Management Approaches” section. The Forest Service will provide employees 

opportunities to receive training so they understand the unique legal relationship between the 

Federal government and Indian tribes.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

34

Concern Statement: The Forest Service should acknowledge the effect that forest management 

has on Native Americans, and that the public interest may not always coincide with tribal desires.

(54.05, 54.06)

Response: We agree forest management has different effects on the different communities we 

serve. The Forest Service is guided by law, policy, and guidance including the National 

Environmental Policy Act, which provides a framework to assess the impacts to communities 

including tribal communities. We are aware of cultural ties to the land and are working to build a 

collaborative relationship with the twelve neighboring tribes. We are working together to achieve 

mutual desired conditions and objectives and to collaborate on ecosystem restoration efforts and 

address tribal cultural needs and desires.

Draft Environmental Impact Statement, Alternatives, and 

Analysis

Effects Analysis (17)

Concern Statement: The Forest Service should revise the cumulative effects analysis to extend 

the timeframe and provide a more accurate disclosure of effects to include the motorized 

transportation system. (17)

Response: The temporal bound for the cumulative effects analysis is the same as the planning 

period (10 to 20 years). This period is consistent with section 219.10(g) of the 1982 Planning 

Rule, which states “a forest plan shall ordinarily be revised on a 10-year cycle or at least every 15 

years.” The intent of the Coronado National Forest is to revise the next forest plan in this planned 

timeframe. This timeframe is also consistent with the more recent 2012 Planning Rule, which 

would guide the next revision process. Section 291.7 of the 2012 Planning Rule reiterates 

direction from the National Forest Management Act, stating that “a plan must be revised at least 

every 15 years” (16 U.S.C. 1604(f)(5)). The 2012 Planning Rule further explains the cause for 

delay in recent plan revisions: “The efforts to produce a new planning rule over the past decade 

have contributed to the delay in plan revisions. With clarity and stability in planning regulations, 

land management planning can regain momentum and units will be able to complete revisions 

more efficiently” (36 CFR Part 219). 

The draft environmental impact statement does not include an analysis of the motorized 

transportation system, as noted in Chapter 3 under the “Visitor Experiences” section: 

“Under all alternatives, future changes in the miles of NFS roads and motorized trails 

would be evaluated site specifically as needs are identified and in accordance with the 

transportation analysis process and Travel Management Rule requirements”. 

The Coronado National Forest is currently evaluating the motorized transportation system on all 

five ranger districts through site-specific analyses, pursuant to the Travel Management Rule (36 

CFR §212). The forest plan and associated environmental impact statement are programmatic and 

do not repeat or revisit site-specific analyses already underway through the travel management 

planning process. The site-specific analyses for travel management include disclosure of effects 

to natural and cultural resources as well as cumulative impacts.

The forest plan provides desired conditions for the motorized transportation system that will be 

reflected in the site-specific travel management analyses. The plan also addresses the suitability 
Appendix A. Response to Comments

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Revision of the Coronado National Forest Land and Resource Management Plan

35

of motorized uses in different areas of the Coronado National Forest. In the “Recreation” section 

of chapter 2, the plan provides management approaches that include 

“implementing Travel Management decisions to expand semiprimitive nonmotorized 

opportunities, allocated motorized vehicle access points for dispersed recreation, increase 

fiscal efficiencies, reduce environmental impacts, and support quiet recreation 

experiences.” 

Forestwide standards and guidelines under the “Motorized Transportation System” section state 

that:

“Motor vehicle use is allowed on the designated system of roads and motorized trails 

shown on the motor vehicle use map that is available at each ranger district office. Motor 

vehicle use is prohibited in all other locations, unless it is specifically authorized by law, 

permit, and/or orders issued by the Forest Service in conjunction with resource 

management and public safety actions”. 

Concern Statement: The Forest Service should modify the effects analysis to: (1) comply with 

the 1982 Planning Rule and NEPA ensuring the effects are clearly disclosed and to analyze the 

effects of changing the forest plan, (2) complete more thorough disclosure of effects to the 

motorized transportation system and evaluate the effects of locatable minerals within the 

established land zones identified in the draft land and resource management plan and, (3) evaluate 

the effects of removing soil, watershed, and riparian standards from the plan. (17.01, 17.02, 

17.04, 17.05)

Response: (1) The effects analysis complies with the 1982 Planning Rule and the National 

Environmental Policy Act. The no-action alternative represents the 1986 plan and is analyzed in 

the environmental impact statement. Chapter 3 of the environmental impact statement analyzes 

the effects of changing the current plan to potentially one of the alternatives or proposed action 

and includes comparison to the 1986 forest plan. 

(2) The forest plan does not authorize or mandate any site-specific projects or activities such as 

motorized transportation or locatable minerals; therefore project-based effects are not considered 

in this analysis. The effects of motorized transportation and locatable minerals will be analyzed at 

the project level in site-specific National Environmental Policy Act documents at a future date.

Project-specific effects analysis will incorporate the desired conditions and guidelines for each 

land use zone as identified in the plan. In addition, the plan contains standards and guidelines for 

limiting motorized travel to designated roads and trails, and sets the framework for implementing 

the Travel Management Rule (see the “Motorized Transportation System” section in chapter 2 of 

the plan). The “Mineral Resources – Environmental Consequences” section in chapter 3 of the 

environmental impact statement discusses the effects of locatable minerals in wilderness and 

research natural areas. Additionally, mineral proposals would continue to follow the direction of 

laws, regulations, and policies.

(3) The effects of removing or modifying standards put forth in the 1986 plan, including those for 

watershed, soil, or riparian areas, are analyzed in chapter 3 of the environmental impact 

statement, which discloses the effects of no action (the 1986 forest plan) compared to the 

proposed action. 

Concern Statement: The Forest Service should analyze the consequences of eliminating 

regional guides. (17.03)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

36

Response: There is no longer a regional guide for the Southwestern Region. This was withdrawn 

as required by the 2000 Planning Rule (CFR 219.35(e), 2000 Planning Rule).

Issues, Alternatives (28)

Concern Statement: The Forest Service should reject Alternative 1 because it would unduly 

restrict a wide range of multiple uses and could restrict motorized access to the forest. (28)

Response: The Modified Proposed Action Alternative is selected as the new Coronado Forest 

Plan as it better meets the needs of all recreational activities including mountain biking. 

Alternative 1 would increase areas managed for wilderness character by approximately 14 percent

which could exclude some user groups because motorized and mechanized uses are prohibited in 

wilderness. Because of restrictive standards and guidelines for motorized and mechanical uses in 

wilderness, alternative 1 would marginally increase the cost and impede the accomplishment of 

forest health improvement projects that would benefit recreation settings and increase the 

complexity of fire management.

Concern Statement: The Forest Service should select Alternative 2, "Motorized Recreation 

Emphasis" to better manage OHV use to reduce conflicts between motorized and non-motorized 

users and add mitigation measures to protect the Arizona Trail. (28)

Response: Thank you for your comment. There are differing opinions regarding which 

alternative the responsible official should select. The responsible official will select an alternative 

based on the analysis presented within the environmental impact statement and public input. 

Alternative 2 is included in the final environmental impact statement and is analyzed in full.

The plan contains guidance that will help protect the Arizona Trail in Chapter 3, Management 

Areas, Arizona National Scenic Trail.

Concern Statement: The Forest Service should accept alternative 1 to increase wilderness 

because road density and visual quality standards would be strengthened and reject the alternative 

that increases motorized use because climate change is not adequately addressed, invasive species 

spread would increase, human-caused fires would increase and grassland communities and eagle 

populations would be negatively affected. (28.06, 28.11) 

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

environmental impact statement. Rationale for the selection of the modified proposed action 

alternative and the final plan are described in the record of decision document.

Concern Statement: The Forest Service should consider alternatives that maximize ecological 

systems for protection for wildlife, vegetation, riparian areas, watersheds, soils, range and 

incorporates the effects of climate change on the ecosystem. Additionally, Native American land 

management practices should be incorporated into this alternative. (28.03, 28.05)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

37

Response: All four alternatives have common objectives pertaining to wildlife, vegetation, water 

resources, soils, and grazing livestock which can be found in the “Revised Plan Content Common 

to all Alternatives” section of chapter 2 of the environmental impact statement. They include:

• conserve soil and water resources;

• cause no significant or permanent loss of productivity of the land;

• provide for and maintain a diversity of plant and animal communities to meet multiple use 

objectives;

• provide suitable, well-distributed habitat across the Coronado to ensure species viability; and

• include measures for preventing the destruction or adverse modification of critical habitat for 

threatened and endangered species.

The effects of climate change are analyzed for all alternatives and are discussed in chapter 3 of 

the environmental impact statement. In addition, the plan provides plan components and 

management approaches for each subject area. This management direction provides a framework 

to sustain native ecological systems by managing toward desired conditions that support native 

plant and animal diversity. The plan promotes resiliency for vegetation communities which are 

highlighted in the “Desired Conditions” section in chapter 2 of the plan. As a whole, the plan 

provides direction that contributes to ecological, social, and economic sustainability.

In the “Revised Plan Content Common to all Alternatives” section of chapter 2, three objectives 

pertain to Native American resources, relationships, and practices:

• require consultation with tribes about traditional resources, ties, and interests about sitespecific proposed actions

• recognize and respect the unique status of Native American tribes and their rights conveyed 

by trust and treaty with the United States

• protect heritage resources

An alternative exclusively addressing ecological systems was eliminated from detailed 

consideration because it would not meet the legal requirements of the National Forest 

Management Act or Multiple Use-Sustained Yield Act, which require forests to be managed using 

multiple use-sustained yield principles. The purpose of this analysis is to revise the current forest

plan to continue to meet the multiple use mandate,; maximization of ecological systems at the 

expense of other resources does not meet the purpose and need.

Concern Statement: The Forest Service should acknowledge that Tucson Electric Power 

Company may need to undertake alternative land sections to sustain service to the Bigelow, 

Elephant Head, and Melendrez [electronic] sites in alternatives 1 and 2. If no action or the 

proposed action is selected, no additional undertakings would need to occur by TEP. (28.04, 

28.07, 28.08, 28.09)

Response: The plan contains standards for communication sites and addresses utility lines 

connecting to communication sites; see the “Special Uses” section of chapter 2. Special use 

permitting [undertakings] is accomplished on a site-specific, case-by-case basis in conformance 

with Forest Service Handbook 2709.11 - Special Uses Handbook and in accordance with the 

National Environmental Policy Act through environmental analysis.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

38

Natural Resources Management

Air Quality Management (1)

Concern Statement: The Forest Service should include more information on abatement and 

sources of fugitive dust. (1.05, 1.06)

Response: The forest plan calls for meeting all air quality regulations and legal requirements. 

Fugitive dust resulting from Forest Service projects will be evaluated through the National 

Environmental Policy Act process on a case-by-case basis. In terms of abatement of fugitive dust, 

best management practices to mitigate the impact of particulates on air quality are developed at 

the project level on a case-by-case basis. The use of water to reduce fugitive dust is a common 

best management practice. We are required to meet all Arizona Department of Environmental 

Quality and New Mexico Environmental Department regulations, national ambient air quality 

standards, and the Clean Air Act.

Concern Statement: The Forest Service should retain the desired condition for air quality. 

Because it is consistent with the area's class 1 Clean Air Act designation. (1.02)

Response: Protection of the air quality in class 1 airsheds, including the Chiricahua Wilderness

and Galiuro Wilderness, are considered in all project analyses and retained in the forest plan

under the “Air” section in chapter 2, “Forestwide Management” in the “Desired Conditions,” 

“Guideline,” and “Management Approaches” sections.

Concern Statement: The Forest Service should include management practices for emissions 

from fire, PM10, and fugitive dust in cooperation with ADEQ. (1.01, 1.03)

Response: The environmental impact statement discusses the coordination that the Coronado

conducts with Arizona Department of Environmental Quality and the New Mexico 

Environmental Department to ensure that various factors that influence air quality related to 

prescribed fire are addressed appropriately by mitigation or avoidance to minimize adverse 

effects. This coordination involves balancing the timing, duration, location, and frequency of 

prescribed fires with other national forests and agencies to maintain air quality. In the forest plan,

we added a management approach to emphasize coordination with the State air quality agencies 

regarding all particulate matter and fugitive dust issues associated with Forest Service activities.

Concern Statement: The Forest Service should acknowledge that a General Conformity 

Determination by the Air Quality Division is not required because the project's total emissions 

would be less than the de minimis levels in Title 40 CFR section 51.853(b) and section 93.153(b).

(1.04)

Response: We agree the actions outlined in the forest plan do not warrant a general conformity 

determination, because there are no project-level decisions proposed in the documents.

Biological Resources Management (3)

Concern Statement: The Forest Service should avoid grouping Endangered Species Act (ESA) -

listed species with ecosystem diversity characteristics as a substitute for the obligation under ESA 

to consult on potential effects to listed species to comply with NFMA and the ESA. (3)

Response: The referenced ecological sustainability report is not a substitute for completing 

consultation with the U.S. Fish and Wildlife Service on listed species. The U.S. Forest Service 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

39

prepared and submitted a biological assessment (and an addendum in January 2017) evaluating 

24 listed species to U.S. Fish and Wildlife Service in May 2015, and U.S. Fish and Wildlife 

Service personnel issued a biological opinion in April 2017. In addition, the species viability 

assessment evaluated 437 species to identify threats, availability of suitable habitat, habitat 

trends, and population trends.

Concern Statement: The forest plan should focus on preserving biodiversity. (3.01, 3.04, 3.05)

Response: The concept of preserving biodiversity is central to the forest plan. Recognized early 

in the revision process as a need for change in the Comprehensive Evaluation Report (2009), 

ecosystem restoration and resiliency became one of the five topics the revised forest plan was 

developed to address. The specific needs for change related to biological diversity are listed on 

page 8 of the plan, and the related plan components are found in 25 sections related to 

“Forestwide Management,” as well as in the “Geographic Area” management direction. An 

important component of preserving biodiversity is providing for the viability of species. The 

results of the viability analysis are summarized in the environmental impact statement, chapter 3, 

in the “Species Diversity and Viability” section. From an initial list of 1,400 species, 437 species 

were evaluated closer to determine if viability concerns existed. Of these 437 species, 362 were 

found to have little to no risk to their viability. Seventy five species were found to have some risk 

to their viability. Analysis of these 75 species generated additional plan components to ensure 

their viability. The plan components that address viability concerns are found in tables 75, 105 

and 106 of the environmental impact statement. To summarize, findings confirm the revised 

forest plan will be effective in moving towards desired conditions for preserving biological 

diversity. 

Concern Statement: The Forest Service should address invasive species management in the 

forest plan. (3.02, 3.11) 

Response: Chapter 2 in the forest plan includes forestwide management for invasive species.

The section starts with the following desired condition statement: 

“Infestations of invasive exotic plants do not contribute to the loss of native species or 

impairment of ecosystem function. Invasive animals are nonexistent or occur in low 

numbers and do not significantly affect the productivity or sustainability of native 

wildlife.” 

There are specific objectives related to the invasive species buffelgrass in deserts. The forest plan 

then outlines an integrated pest management approach that includes detection and treatment, 

coordination with other agencies and neighboring jurisdictions, and using the program to help in 

recovery of federally listed threatened, endangered, or proposed species as well as Forest Service 

sensitive species. 

Concern Statement: The Forest Service should disclose the existing conditions of riparian and 

aquatic habitat and ecosystems and proposed protections for maintenance and restoration. The 

Forest Service should include standards and guidelines to protect these habitats. (3.09, 3.16, 3.17, 

3.19)

Response: Chapter 3 includes a section entitled “Species Diversity and Viability”, and it includes 

a description of the affected environment for all vegetation communities on the Coronado 

National Forest. The affected environment for montane meadows, wetlands, and riparian areas 

includes the habitat quality subsection for riparian habitat that describes the existing condition of 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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riparian areas to the extent that existing monitoring data allows. This section identifies the 

difficulty of applying a standard assessment protocol to a large variety of areas that each has very 

different vegetation potential. Nonetheless, the section states that, based on available data,

between 33 and 87 percent of transects show a stable or increasing trend.

Many of these habitats support, or have the potential to support, sensitive aquatic species and so 

these areas were given specific plan components to provide additional protection. As an example, 

the plan includes many components designed to enhance or restore native, warm water fish 

habitat. Examples include NWS-O-1 and NWS-O-2, which are objectives to acquire water rights 

on areas where fish occur as well as objectives to reconstruct springs to support native wildlife 

including fish. Guideline ISM-G-1 will result in the removal of nonnative, invasive plant and 

animal species where fish and other special status aquatic species occur. The guidelines NWS-G2, NWS-G-3, NWS-G-4, and NWS-G-5 allow for natural instream movement, reduce fuel build 

up, and protect water quality, quantity, and habitat features at natural springs and seeps prioritized 

in habitat where fish occur.

Concern Statement: The Forest Service should protect the sensitive areas of the forest to 

preserve research opportunities and protect them from further degradation. (3.06)

Response: The forest plan identifies special management areas to preserve the many research 

opportunities across the Coronado. Research natural areas and botanical and zoological areas are 

designated to ensure protection of specific biological and zoological communities. Research 

natural areas are areas the Forest Service has designated to be permanently protected and 

maintained in natural condition, so they may serve as experimental research controls and 

monitoring sites for the particular ecosystem they represent and used for education.

There are six existing research natural areas on the Coronado National Forest: Pole Bridge, 

Goodding, Elgin, Goudy Canyon, Butterfly Peak, and Santa Catalina. The Pole Bridge, Santa 

Catalina, Goodding, and Goudy Canyon Research Natural Areas overlap with designated 

wilderness areas. The Coronado National Forest currently has three proposed research natural 

areas, two of which are expansions of existing research natural areas: Canelo, Goodding 

Extension, and Pole Bridge Extension.

Concern Statement: The Forest Service should protect the South Fork, Cave Creek Canyon, 

Portal watershed to allow for the study of raptors. (3.13)

Response: We recognize the importance of Cave Creek Canyon as habitat for raptors. The forest 

plan establishes a special management area, Cave Creek Canyon Birds of Prey ZoologicalBotanical Area, with a desired condition that “The unique resources that provide habitat for the 

highest number of birds of prey in the U.S. are maintained or enhanced.” In response to concerns 

from many scientists that conduct research on raptors in the area, no extra restrictions on research 

were imposed. However, it should be noted that permits are required for collection of plants or 

animals in all zoological-botanical areas. The forest plan also carries forward the South Fork of 

Cave Creek Zoological-Botanical Area. A standard for this area requires a permit to conduct any 

scientific research that would involve leaving anything in the area.

Concern Statement: The Forest Service should prioritize maintaining ecosystem health and 

resilience to address changes from climate change. (3.12)

Response: We agree we should prioritize maintaining ecosystem health and resilience to address 

changes from climate change, and the forest plan does this. Ecosystem restoration and resiliency 
Appendix A. Response to Comments

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Revision of the Coronado National Forest Land and Resource Management Plan

41

is one of the 5 topics around which the forest plan was developed. Table 19 in the environmental 

impact statement displays the effectiveness of each alternative in addressing the need for 

ecosystem restoration (health) and resiliency. The forest plan addresses the components of 

resilient ecosystems throughout the “Vegetation Community” section, and in the “Natural and 

Constructed Water Sources” section.

Climate change is addressed directly in the first section of chapter 2, with desired conditions for 

the Coronado National Forest’s response to climate change. Management approaches are then 

described highlighting the importance of planning for disturbances, increasing water 

conservation, anticipating increased forest recreation and monitoring climate change influences as 

well as the effectiveness of adaptation approaches. There is additional direction concerning 

climate change found in forest plan appendix A, “Climate Change Trends and Coronado National 

Forest Land Management Planning.” 

Concern Statement: The Forest Service should revise the desired conditions related to 

extirpation of native species to account for the process of climate change. (3.18)

Response: We have modified the management approach in the “Animals and Rare Plants”

section as follows: 

“Considering the reintroduction of extirpated species to habitats that are reasonably 

assured to remain suitable through climate change.” 

An additional measure that is taken in the forest plan is the establishment of the Finger Rock 

Research Natural Area, dedicated to the study of climate change. This unique outdoor laboratory 

will encourage the study of how native species respond to climate change. The results of these 

studies can then be used to inform future management decisions regarding extirpated species. 

Concern Statement: The Forest Service should acknowledge that the principles of conservation 

biology are not scientific data and should not be used as the basis for addressing biological issues.

(3.03)

Response: We recognize various fields of study, such as conservation biology, have supporters 

and detractors. The forest plan was developed using best available science and professional 

judgments and includes public input and collaboration with significant tribal involvement, which 

helped shape approaches to natural resource management. Since we manage the land and habitats 

that plant and animal species are depend upon, our approach has been to manage the habitat to 

maintain resilience that will provide the life history requirements of the greatest number of 

species. An example of this approach is evident in the species viability approach to considering 

effects of management activities on wildlife species. In this case, a large list of 1,400 species was 

initially considered to identify those for which there may be viability concerns. Of these, 75 were 

identified that needed additional plan components to ensure that implementation of the plan 

would not result in lost viability. Specific components were developed and adopted. In this way 

species viability was not compromised and populations of these species have the best possibility 

of persisting through time.

Concern Statement: The Forest Service should revise the desired conditions relating to the 

collection of animals and plants to include mushrooms. (3.07)

Response: The forest plan includes fungi in the “Forest Products” section.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

42

Concern Statement: The Forest Service should acknowledge that recreational use poses a 

serious threat to animals and rare plants, from fires, soil compaction, destruction of vegetation, 

and diminished water quality. (3.08)

Response: These have been described in the viability analysis, biological assessment, biological 

evaluation, the plant and animal section, and consultation with the U.S. Fish and Wildlife Service.

Concern Statement: The Forest Service should confine restoration projects to small areas and 

provide for monitoring to allow for adaptive management and assessment of results. (3.10)

Response: The forest plan allows for restoration activities at multiple scales. Treatments are 

limited in certain places; however, larger treatments are appropriate in some circumstances to 

meet project goals. All projects are subject to National Environmental Policy Act analysis to 

determine appropriate scale. 

Monitoring and evaluation activities provide ongoing feedback about management effectiveness 

and are essential elements of an adaptive management cycle that includes problem identification, 

solution, and implementation. Monitoring and evaluation keep direction found in the forest plan 

up to date and relevant by being responsive to changing conditions and issues—including public 

desires—and to new information, such as research results or outcomes from management 

activities. 

Concern Statement: The Forest Service should use hierarchies of ecosystem type and scale to 

achieve desirable outcomes. (3.14)

Response: We agree. The forest plan includes management direction that applies at a forestwide 

scale, then downscales the scope of management direction to the ecosystem management area, 

land use zones, geographic areas, and special management areas. Forestwide management can be 

found in chapter 2 of the forest plan. Forestwide management contains plan decisions and other 

content for various resources that are applicable throughout the national forest, wherever the 

particular resource occurs. Forestwide management for vegetation communities is described at 

three scales: landscape scale, mid-scale, and fine scale. Management areas can be found in 

chapter 3 of the forest plan. Management areas contain plan decisions and other content that is 

applicable to a particular management area, which may occur in multiple places. The Coronado 

National Forest is divided into six management areas, including wilderness areas and land use 

zones. Geographic areas can be found in chapter 4 of the forest plan. Geographic areas describe

the management direction that applies to unique geographic areas called ecosystem management 

areas. These are unique places based on geography. This chapter also includes special 

management areas, which are also unique, with management direction that only applies to that 

place. We believe that this approach to hierarchies in management direction at multiple scales will 

provide the best means by which to achieve desirable outcomes for the multiple scales of 

ecosystems within the Coronado National Forest. 

Concern Statement: The Forest Service should ensure that the desired conditions related to 

animals and rare plants are modified to account for the international boundary fence. (3.15)

Response: The international boundary fence is outside the scope of the forest plan. The 

international boundary fence is not a Coronado National Forest activity. The wildlife movement 

corridors are identified in the “Animals and Rare Plants” section and desired conditions state that 

“forest boundaries are permeable to animals of all sizes and offer consistent, safe access for 

ingress and egress of wildlife.”
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

43

Climate Change (5)

Concern Statement: The Forest Service should consider and disclose the extent and degree to 

which climate change affects national forest lands and resources because climate change is likely 

to have significant effects on biodiversity, forests, and water availability to comply with NEPA.

(5)

Response: Appendix A of the plan entitled “Climate Change Trends and Coronado National 

Forest Land Management Planning” provides an overview of likely climate trends as shown by 

predictive models and the potential effects to forest resources such as biodiversity, surface water, 

forage for grazing, and recreational opportunities. The appendix also outlines strategies for 

management of ecosystems to promote resiliency into the future. The plan does not authorize a 

particular activity but provides guidance and desired conditions for site-specific projects that will 

be analyzed in accordance with the National Environmental Policy Act in the future. The Council 

on Environmental Quality issued guidance in 2016 to assist Federal agencies in their 

consideration of the effects of greenhouse gas emissions and climate change when evaluating 

proposed Federal actions in accordance with the National Environmental Policy Act. This 

guidance will be implemented for future projects tiered to the plan.

Concern Statement: The Forest Service should assess and disclose the potential contribution of 

multiple resource uses to regional and global climate change because the environmental 

consequences are significant. (5)

Response: The plan does not authorize a specific action for resource management so it is not 

possible to quantify the contribution of the plan to regional and global climate change. This type 

of analysis is most applicable at the project scale. For instance, one could evaluate the difference 

in greenhouse gas emissions between prescribed burning or mastication to reduce woody plant 

density and use this information to decide between alternatives. It is not currently feasible to 

quantify the indirect effects of individual or multiple projects on global climate change and 

therefore determining significant effects of those projects or project alternatives on global climate 

change cannot be made at any scale. 

Concern Statement: The Forest Service should include a commitment with objectives, 

guidelines, and mitigation strategies to address climate change including those developed for the 

Sky Island region, and Kaibab National Forest plan. (5.04, 5.05, 5.15, 5.16)

Response: The Coronado National Forest participated in the development of the Adaptation 

Action Plan for the Sky Island Region and is in the process of implementing various projects 

identified in the action plan to help achieve those goals. Climate change is addressed directly in 

the revised plan in the first section of chapter 2. Throughout the plan there are desired conditions 

and other components that represent and protect elements of functional ecosystems and resilient 

landscapes. The plan provides for maintaining attributes of resilient ecosystems throughout the 

“Vegetation Community” section, and in the “Natural and Constructed Water Sources” section. 

Appendix A of the revised plan entitled “Climate Change Trends and Coronado National Forest 

Land Management Planning” contains information on the threats climate change poses to the 

unique sky island habitats and potential climate change mitigation strategies.

Concern Statement: The Forest Service should include a more thorough discussion and 

disclosure of the effects of climate change on multiple resources (including vegetation and water), 

management strategies to adapt to climate change, and how this affects ranchers and adjacent land 

owners. (5.02, 5.03, 5.06, 5.08, 5.11)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

44

Response: Climate change is a new science and our understanding of the effects of climate 

change on forest resources continues to develop. The Forest Service is addressing climate change 

at the regional and national forest level and has developed the document, “Southwestern Region 

Climate Change and Forest Planning” (USDA Forest Service 2010) to help guide our 

management activities to adapt and respond to climate change. The forest plan contains a section 

outlining desired conditions and management approaches to help address climate change that 

follows regional direction. Further, plan components are found in the “Vegetation Communities” 

and “Natural Water Sources” sections that are designed to adapt those resources to climate 

change. We address climate change at the project level in all National Environmental Policy Act 

assessments, and any potential effects of our activities to ranchers or adjacent landowners would 

be analyzed and disclosed at that point. Multiple use activities are consistent with desired 

conditions for all plan resource areas and were considered in the effects analyses. Further, the 

plan components were developed to account for uncertainties related to climate change, and 

provide for resilience and adaptability Therefore, the plan components assessed and disclosed in 

the environmental impact statement account for climate change effects in the respective resources 

areas.

Concern Statement: The Forest Service should identify nonclimate stressors that are 

exacerbating the effects of climate change to allow for prioritization of these efforts and 

mitigation of these stressors to be incorporated into the plan. (5.07, 5.09)

Response: Nonclimate stressors that are likely to be affected by future climate variability are 

identified in chapter 3 of the environmental impact statement in the “Climate Change” section. 

These include insect infestation, disease, introduced species, fire, water use and demand, and 

increased socioeconomic demands. Potential climate change strategies for the Coronado National 

Forest are identified in appendix A of the plan. Although nonclimate stressors are not prioritized 

in this strategy, there are adaption options presented to mitigate the effects of these stressors. The 

plan components were developed considering climate change and climate effects and these effects 

were analyzed in the plan. The Forest Service is a multiple use agency. Multiple use and other 

activities are consistent with desired conditions for other plan resource areas and were considered 

in the effects analyses. Further, plan components were developed to account for climate change 

with management strategies such as resiliency and adaptability. For an example of this approach 

in the forest plan, see chapter 2, “Forestwide Management, Natural Water Sources and 

Constructed Waters.” 

Concern Statement: The Forest Service should consider the effects of grazing on climate 

change because livestock are a significant contributor to greenhouse gas emissions. (5.10)

Response: Concentrated animal feeding operations (feedlots which may have more than 50,000 

head) are known to contribute to carbon dioxide emissions because they have large quantities of 

decomposing manure which releases methane and carbon dioxide into the atmosphere. Grazing 

on the Coronado National Forest is widely distributed and the number of livestock on the 

Coronado at any given time is at a minimal density. Additionally, manure is not confined to one 

area. It is dispersed, and when it decomposes, it contributes to soil organic carbon and is available 

as soil nutrients for plant uptake and carbon sequestration. This results in total emissions being 

minimal and therefore not included in the environmental impact statement. 

Concern Statement: The Forest Service should include actions to promote carbon sequestration 

and storage in the “Management Approaches” sections. (5.12)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

45

Response: The proposed plan was developed in the context of a changing environment and 

includes a section related to climate change, as well as an appendix of climate change 

considerations in forest planning. Carbon storage was considered in the context of healthy 

ecosystems. As described in the environmental impact statement (“Climate Change –

Environmental Consequences” section), vegetation treatments under all alternatives, including

vegetation removal and planned fire ignitions, would improve the net carbon balance on the 

Coronado. This is particularly true for treatments in higher-elevation vegetation types carried out 

under the proposed action, alternative 1, and alternative 2. Although treatments would likely 

release carbon, they would improve the long-term sustainability of the ecosystem as a carbon sink 

(Hurteau et al. 2008). Studies have shown fire risk reduction and restoration treatments release 

less carbon than high-severity fire (Finkral and Evans 2008; Hurteau et al. 2008). Improved 

ecological conditions resulting from restoration of vegetation toward desired conditions and 

maintenance of a fire regime consistent with historical fire return intervals would reduce carbon 

dioxide emissions and improve the sustainability of carbon sequestration by soils on the 

Coronado.

Concern Statement: The Forest Service should revise the climate change analysis because the 

analysis relies on inaccurate models: to conform with the requirements of the Multiple UseSustained Yield Act, the National Forest Management Act, and National Environmental Policy 

Act and incorporate the best scientific information available; to reflect the difference between 

climate change and climate variability; to correct the discussion of flash flooding; to reflect that 

increased temperatures will likely alter plant communities even if precipitation remains the same;

to include contingency plans in case of flooding or debris flows; to reflect that increased 

temperatures and decreased precipitation will likely have significant effects on soil composition 

and biota; and to include impacts on recreational users. (5.13)

Response: The state of knowledge needed to address climate change at the national forest scale 

is still evolving. Because none of the current climate models, including multi-model ensembles, 

adequately resolves important topographic variations (mountain ranges) and phenomena, such as 

El Niño – southern oscillation or the North American monsoon, their results are imprecise and the 

subject of continuing research. However, these models do reproduce much of the underlying 

features of the Earth’s climate, and their basic structure has been proven in various experiments 

and forecasts of the weather systems from which climate is usually described. Therefore, these 

models remain a credible means of estimating potential future climate scenarios. Appendix A in 

the forest plan summarizes current and future climate trends at the regional and, if possible at the 

forest level. It also describes the difference between climate and weather, climate change and 

climate variability. The environmental impact statement discloses that the forest plan is consistent 

with the Multiple Use-Sustained Yield Act, National Forest Management Act, and National 

Environmental Policy Act, and that the specific requirements in the National Environmental 

Policy Act for the consideration of climate change and best available science have been met. 

Current scientific information regarding the effects of climate change on forest resources is 

incorporated in the revised forest plan. It is presented as a general description of anticipated 

changes in conditions as they are known to a reasonable level of certainty. It also outlines desired 

conditions for all vegetation communities to promote their increasing resiliency and adaptation 

capacity to changing conditions and other stressors, such as extended drought and warmer 

temperatures, which are projected to occur in the Southwest. In the environmental impact 

statement, effects of climate change, including potential increases of disturbance events such as 

flash flooding and debris flows are disclosed for all resource areas which could be affected, 

including recreation. 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

46

Concern Statement: The Forest Service should acknowledge the existence of a web-based 

clearinghouse for climate-change related information. (5.14)

Response: Thank you for your information regarding the existence of a web-based clearinghouse 

for climate-change related information. We will continue to use all available sources to obtain the 

best scientific information related to climate change.

Concern Statement: The Forest Service should reconsider the analysis of climate change

because climate change has not been scientifically proven. (5.01)

Response: The Forest Service has reviewed scientific literature related to climate change and 

developed the Southwestern Region Climate Change and Forest Planning document (USDA 

Forest Service 2010). The plan follows this regional direction.

Domestic Livestock, Grazing Management (15)

Concern Statement: The Forest Service should use distance from water as a criteria for 

determining grazing suitability. (15)

Response: The current forest plan analysis meets the regulations for identifying suitable and 

capable lands and trend. Subsequent site-specific National Environmental Policy Act analysis for 

each of the allotments is used to determine trend, information and to identify need for change in 

reference to capability issues. Suitability is the appropriateness of applying certain resource 

management practices to a particular area of land in consideration of the relevant social, 

economic, and ecological factors. Areas within the plan area are suitable if livestock grazing is 

compatible with the desired conditions as evaluated in the forest plan and environmental impact 

statement “Suitability” and “Capability” sections.

Concern Statement: The Forest Service should prohibit grazing to promote habitat values 

because it is not a fiscally responsible policy if adequate monitoring is not possible because of 

budget or manpower constraints. (15)

Response: The current forest plan analysis meets the regulations for identifying suitable and 

capable lands and trend. Subsequent site-specific National Environmental Policy Act analysis for 

each of the allotments is used to determine trend, information and to identify need for change in 

reference to capability issues. Suitability is the appropriateness of applying certain resource 

management practices to a particular area of land in consideration of the relevant social, 

economic, and ecological factors. Areas within the plan area are suitable if livestock grazing is 

compatible with the desired conditions as evaluated in the forest plan and environmental impact 

statement “Suitability” and “Capability” sections.

Concern Statement: The Forest Service should continue to allow grazing because ranchers

maintain water sources that are also used by wildlife as long as fencing is maintained to keep 

cattle out of riparian areas because there is no evidence that controlled grazing poses any threat to 

species. (15)

Response: The current forest plan analysis meets the regulations for identifying suitable and 

capable lands and trend. Subsequent site-specific National Environmental Policy Actanalysis for 

each of the allotments is used to determine trend, information and to identify need for change in 

reference to capability issues. Suitability is the appropriateness of applying certain resource 

management practices to a particular area of land in consideration of the relevant social, 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

47

economic, and ecological factors. Areas within the plan area are suitable if livestock grazing is 

compatible with the desired conditions as evaluated in the forest plan and environmental impact 

statement “Suitability” and “Capability” sections.

Concern Statement: The Forest Service should manage grazing in reference to drought, as a 

mechanical treatment tool and a means to enhance wildlife habitat. (15.01, 15.12, 15.13)

Response: The guidelines and management approaches outlined for range management in the 

forest plan provide management direction for site-specific grazing and adaptive grazing 

management, which includes management of livestock during drought. Guidelines 1 and 3 

provide for grazing management practices that can be modified to meet site-specific resource 

needs that include maintaining or enhancing wildlife habitat.

Concern Statement: The Forest Service should analyze and consider the impacts of grazing on 

vegetation and wildlife habitat, including effects of livestock waters. A grazing suitability and 

capability analysis should be conducted which considers appropriateness and topography to 

comply with the National Forest Management Act. (15.28, 15.19, 15.20, 15.18, 15.02, 15.21, 

15.24)

Response: We agree and have done so. The effects of grazing on vegetation, soil, and wildlife

habitat, including the effects of constructed waters used by livestock, are analyzed in chapter 3 of 

the environmental impact statement. Livestock grazing in relation to land topography is 

considered in the capability analysis of the forest plan (chapter 5) and in the environmental 

impact statement. The appropriateness of livestock grazing is determined in the suitability 

analysis and subsequent designation of suitable areas (forest plan chapter 5). The capability and 

suitability analyses included in the environmental impact statement meet the requirements of the 

1982 Planning Rule. Subsequent site-specific National Environmental Policy Act analysis for 

each grazing allotment is used to identify needs for changing management to meet desired 

conditions.

Concern Statement: The Forest Service should provide more specifics about grazing and permit 

holders, require grazing, provide for grassbanks and forage reserves, and use available unused 

allotments. (15.05, 15.06, 15.03, 15.17)

Response: The forest plan does not address grazing permit administration. Such administrative 

issues are addressed in the grazing and livestock use permit system (Forest Service Manual

2231.02) and grazing permit administration handbook (Forest Service Handbook 2209). The 

forest plan provides guidelines and management approaches that are key to implementing sitespecific grazing and adaptive grazing management. Under an adaptive management strategy for 

livestock grazing, active grazing allotments with a current National Environmental Policy Act

analysis can be used to provide range for permitted livestock.

Concern Statement: The Forest Service should provide for management to exclude or restrict 

grazing in riparian areas to protect riparian and wetland habitats. (15.26, 15.27, 15.04, 15.15, 

15.16)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

48

Response: The forest plan and environmental impact statement address the desired conditions 

and subsequent standards and guidelines in the “Wetlands” and “Riparian Vegetation” sections.

Management activities, including grazing, are addressed with the following guideline in the those

sections: 

“Management activities should only be allowed in wetlands and riparian areas if soil 

function and structure, hydrologic function and native mesic plant assemblages are 

sustained.”

The guideline was modified between the draft and final environmental impact statements to be 

more inclusive of activities and more specific about resource protection.

Concern Statement: The Forest Service should consider developing at least one alternative 

which looks at a reduction in livestock stocking levels of 25 percent and another at 50 percent. 

(15.29)

Response: The forest considered two reduced grazing alternatives but concluded the livestock 

grazing program has multiple mechanisms to evaluate, review, and adapt management as needed 

to effectively protect resources and respond to changing conditions. Effects from grazing in each 

range allotment are evaluated and adjusted (1) throughout the season, particularly when pasture 

rotation is being determined; (2) in detail at the beginning of the season when the annual 

operating instructions are determined; and (3) comprehensively on 10- to 15-year intervals, or 

more frequently when needed, as grazing is periodically reauthorized through the environmental 

analysis process. This allows needed adjustments to be made on a site-specific basis to maintain 

and move toward desired conditions for watersheds, wildlife habitat, and other resources. For 

these reasons, an alternative that would have a reduced level of grazing across the Coronado was 

not studied in detail.

Concern Statement: The Forest Service should clarify how decisions in reference to grazing 

rates, utilization, and range conditions take place. (15.10, 15.07, 15.08)

Response: The forest plan establishes desired conditions, standards, guidelines, and management 

approaches pertaining to range condition, including a guideline for light to moderate utilization of 

forage. Range conditions are evaluated periodically, and decisions on grazing rates and utilization 

are documented in a site-specific National Environmental Policy Act analysis.

Concern Statement: The Forest Service should authorize the voluntary, permanent retirement of 

grazing allotments by permittees for conservation purposes. (15.09)

Response: This is outside the scope of the forest plan. The authority to permanently retire an 

allotment from grazing is retained by the Forest Service and is not held by the permittee. 

Concern Statement: The Forest Service should clarify how grazing contributes to natural 

beauty, quiet places and is a working landscape. (15.11, 15.23)

Response: The forest plan addresses how permitted grazing contributes to natural beauty, quiet 

places, and a working landscape through the desired condition statement in the “Range 

Management” section. The statement describes the importance of supporting rural ranching 

communities. The ranches that hold a permit to graze livestock on the Coronado National Forest 

typically have additional grazing lands adjacent to the national forest as well. These ranches,

consisting of diverse land ownerships, create large working landscapes undeveloped by 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

49

urbanization. These landscapes complement the National Forest System lands and ultimately 

contribute to natural beauty and quiet places.

Concern Statement: The Forest Service should disclose the full costs and benefits of allowing 

grazing in the national forest because grazing typically costs the Forest Service more than it 

brings in including the benefits to rural communities versus the effects to the ecosystems of the 

forest. (15.14)

Response: The costs and benefits of livestock grazing on the Coronado National Forest are 

included in the “Social and Economic Sustainability” report. Where consistent with other 

multiple use goals and objectives, there is congressional intent to allow grazing on suitable 

National Forest System lands (Multiple Use and Sustained Yield Act of 1960, Wilderness Act of 

1964, Forest and Rangeland Renewable Resources Planning Act of 1974, Federal Land 

Management and Policy Act of 1976, National Forest Management Act of 1976). By regulation, 

forage-producing lands will be managed for livestock grazing where consistent with land 

management plans (36 CFR 222.2(c)). Where consistent with the goals and objectives of land and 

resource management plans, it is Forest Service policy to make forage from lands suitable for 

grazing available to qualified livestock operators (Forest Service Manual 2202.1, 2203.1).

Concern Statement: The Forest Service should expand prohibitions on grazing of sheep and 

goats and strengthen grazing restrictions to protect desert bighorn sheep and ensure native 

wildlife have sufficient forage and cover. (15.22, 15.25)

Response: We have developed grazing standards and guidelines to protect wildlife. Standard 1 in 

the “Range Management” section states, “Grazing permits will not be issued for domestic goats 

or sheep in the Galiuro or Santa Catalina Mountain Ranges.” Guideline 4 states, “Additionally, 

grazing management should retain ground cover sufficient for the forage and cover needs of 

native wildlife species.” Furthermore, there are no permits for sheep grazing on the Coronado 

National Forest, and site-specific National Environmental Policy Act analysis would be necessary 

to permit this class of livestock.

We updated the Santa Catalina Ecosystem Management Area section by adding an additional 

standard; the use of domestic sheep, goats, or both for grazing or packing will not be permitted 

due to the risk of disease transmission to bighorn sheep.

Leasable Minerals (31) and 

Minerals and Geology Management (32)

Concern Statement: The Forest Service should provide a table showing historic mining permits, 

define the measure of "high interest," and disclose how much exploration and extraction is 

anticipated. (32)

Response: The Forest does not have a table showing the historic mining permits issued on the 

Coronado National Forest because most of the records no longer exist in our files. We have 

geographic information system (GIS) database records of inventoried metals mines on the 

Coronado, showing several hundred historic mines, most commonly located on the Nogales and 

Sierra Vista Ranger Districts. Locatable mineral potential on the Coronado was assessed by the 

U.S. Geological Survey, resulting in the publication of “Mineral Resource Potential and Geology 

of Coronado National Forest, Southeastern Arizona and Southwestern New Mexico” (du Bray 

1996). This reference states that many parts of the Coronado National Forest have moderate to 

high potential for locatable minerals. The Rosemont Copper Project environmental impact 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

50

statement has been completed and a record of decision signed, indicating viable metal deposits 

occur on the Coronado. Other favorable host rock that could potentially contain similar metal 

deposits occur elsewhere on the Coronado. Future locatable minerals exploration and mining 

activities will depend on market conditions and the corresponding interest in these commodities. 

This interest cannot be predicted with certainty; however, the geology and mining history of the 

Coronado National Forest indicates moderate to high potential for these resources.

Concern Statement: The Forest Service should provide a map showing the location of all current 

mining claims and active and historic mine sites, and include discussion of their potential for 

environmental damage. The Forest Plan should also clarify the role of the General Mining Law of 

1872 in decision making. Additionally, the plan should explain the phrase “minimizing surface 

resource impacts, consistent with mining regulations and policy”. (32)

Response: The location of mining claims changes according to the economy, to legislation, and 

to changing technology affecting mineral potential. Because of this, a map of currently existing 

mining claims will be outdated in a few years or even months. However, this data is considered, 

along with existing and historic locatable minerals activity, as a part of any site-specific surface 

disturbing projects on the Coronado National Forest (both for minerals and other resource 

activities), as part of the National Environmental Policy Act analysis.

Decisions made on the Coronado National Forest must follow all pertinent statutes and 

regulations. This includes the General Mining Law of 1872, as amended, which conveys the right 

to an individual or corporation to locate, access, and extract locatable minerals. Subsequent laws, 

notably the National Environmental Policy Act, require the Forest Service to analyze the impacts 

to natural and socioeconomic resources from minerals exploration and mining activity, and to 

disclose and mitigate those impacts. We do not typically have the authority to deny a locatable 

minerals proposal, but we can modify the proposal to minimize impacts. We have greater 

discretion to deny access and recovery of saleable and leasable minerals.

Concern Statement: The Forest Service should properly consider mineral exploration and 

development in the planning area to comply with the 1982 Planning Rule and the Mining and 

Minerals Policy Act and coordinate with the Bureau of Land Management. (32)

Response: The intent of the Forest Plan is to broadly manage natural and socioeconomic 

resources, with more specific management of certain areas according to their unique 

characteristics. In the case of mineral resources, the economy and other constantly changing 

factors affect the possible land use, and in turn, the management strategy of a given area. An 

environmental impact statement and record of decision have been completed for the Rosemont 

Copper Project; however, no other large-scale mining projects are currently being proposed on the 

Coronado National Forest, and because of this, more specific management criteria are not called 

for in other areas. This follows the intent of section 219.22 of the 1982 Planning Rule. 

Additionally, the forest plan is responsive to the 1970 Mining and Minerals Policy Act in that it 

recognizes the metals and other mineral potential on the Coronado and does not preclude 

locatable mineral exploration and mining. At the same time, the management strategy takes into 

consideration direction from other pertinent statute, such as the National Environmental Policy 

Act, requires consideration of the potential impact to surface resources in the course of mineral 

and exploration activities, and the necessity of mitigation and reclamation to minimize these 

impacts. 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

51

Concern Statement: The Forest Service should revise the guidelines related to reclaimed mines 

because they are unobtainable. (32)

Response: The statement “mines and quarries are rarely seen” has been removed from the desired 

conditions for scenery in the final plan since it is highly subjective as to what constitutes a rare 

sighting and could be unobtainable depending on the interpretation. The desired condition 

statement in the final plan now reads, “Mined areas and quarries have been reclaimed and 

naturalized.” The desired conditions and guidelines in the Minerals section of the plan reinforce 

the Scenery guidelines and desired conditions. For instance, guideline #3 states that mining 

activities should incorporate reclamation measures that reduce contrasts (allow it to blend) with 

the surrounding landscapes. Specific reclamation actions are developed at the project level.

Concern Statement: The Forest Service should analyze the impacts of hard rock mining. (32) 

Response: It is assumed because of the 1872 mining law reference that the comment is referring 

to locatable minerals. The forest plan cannot override the General Mining Law of 1872, which 

provides for property rights in regards to locatable minerals, and reasonable access to those 

minerals. Impacts caused by locatable minerals operations are addressed in the National 

Environmental Policy Act (NEPA) analysis for each operation, and with the analysis, the effects 

are disclosed and then addressed through alternatives to the proposed action (the original proposal 

submitted in a plan of operations) and through mitigation. Conditions are added to the final plan 

of operations that are responsive to the National Environmental Policy Act analysis results.

The forest plan complies with the National Environmental Policy Act as shown in the “Minerals”

section of chapter 2, desired conditions:

“All mineral exploration and mining activities are operating in environmentally sound 

ways through protection and mitigation measures, including adequate post-mining 

reclamation assurances, to minimize environmental impacts to other National Forest 

resources. Abandoned and inactive mines disturbed by past mineral exploration and mine 

development have been returned to stable conditions and an appropriate, functioning, 

vegetative state, and do not pose health, safety, or environmental hazards. Mine 

reclamation should use a geomorphic approach that results in landforms similar to 

adjacent natural terrain and hydrologic functions similar to natural systems to minimize 

long-term monitoring and maintenance requirements”.

The “Minerals” section also has the following guideline:

“Mining activities should incorporate reclamation measures that reduce contrasts with the 

surrounding landscapes”.

The forest plan not only follows pertinent statute but also follows the direction of Forest Service 

regulations at 36 CFR 228, part A, and the 2810 section of the forest service manual. This 

direction specifies National Environmental Policy Act analysis will be done prior to approval of 

locatable minerals operations, operations will be reclaimed, and reclamation will assured through 

bonding. 

Concern Statement: The Forest Service should acknowledge that the economic value of the 

Mount Graham Recommended Wilderness Area is not just dependent on the mineral resources.

(32.01)

Response: Chapter 3 of the environmental impact statement in the “Mineral Resources” section 

under the “No Action Alternative, Locatable Minerals,” describes the economic effect of 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

52

withdrawing the Mount Graham Recommended Wilderness Area from mineral entry, if 

designated. This section focuses specifically on the economic effects of such a withdrawal to 

mineral resources and not on other Coronado National Forest resources. This section was updated 

to clarify that the economic effects are only referring to mineral resources. For more information 

regarding the effects on the Mount Graham Recommended Wilderness Area, see chapter 3 of the 

environmental impact statement, “Wilderness and Other Special Areas” section. While not 

explained in strictly economic terms, the effects of wilderness designation on goods and services 

available to the public are disclosed in chapter 3. For instance, the designation of an area as 

wilderness would limit mechanized vegetation treatments that could yield marketable wood 

products but would increase the nonmarket values of additional primitive recreational 

opportunities, protection of forest resources, or both.

Concern Statement: The Forest Service should define the standards for “reasonable protection 

of surface resources,” “environmentally sound,” and “the extent practicable” when making 

decisions about mineral extraction. (32.18, 32.44)

Response: The desired conditions in the forest plan for “environmentally sound” mineral 

development are agency policy provided by Forest Service Manual 2802 to “Ensure that 

exploration, development, and production of mineral and energy resources are conducted in an 

environmentally sound manner and that these activities are integrated with the planning and 

management of other National Forest resources.” The statements for “the extent practicable” and 

“reasonable protection of surface resources” are described in Federal regulations for locatable 

minerals under 36 CFR 228, subpart A. In general, the definitions of these statements may vary, 

and are dependent on a site-specific project.

Concern Statement: The Forest Service should include guidelines requiring Surface Use 

Determinations and coordination with BLM on mining proposals to perform validity exams.

(32.23, 32.41)

Response: The requirements for conducting surface use determinations and validity exams are

not a forest plan decision. The Forest Service directives regarding validity exams can be found in 

Forest Service Manual 2814.11 and directives regarding surface use determinations can be found 

in Forest Service Manual 2817.03a.

Concern Statement: The Forest Service should analyze the effects from closed or abandoned 

mines and whether the increased interest in locatable, leasable, or salable mining is long-term or 

short-term since mining has historically been a cyclical industry and mining creates conditions 

where environmental contamination occurs. (32.02, 32.28, 32.36)

Response: The environmental effects of closing or remediating abandoned mines are projectspecific and analyzed at the project level on a case-by-case basis. However, the effects of closing 

and remediating abandoned mines across the landscape are described in chapter 3 of the 

environmental impact statement under the “Mineral Resources” section. Level of interest in 

mineral-related activities, including locatable, leasable, and salable minerals, is not within the 

scope of the forest plan. 

Concern Statement: The Forest Service should identify areas that are incompatible with mining, 

target acquisition of mining claims in those areas because of their outstanding biological, cultural, 

recreational, scenic, and other resource values to protect the forest from the consequences of open 

pit mining. (32.09, 32.21, 32.32)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

53

Response: Several special management areas and land use zones are designated in the forest plan 

for their unique resources, such as biological, cultural, recreational, or other characteristics.

Desired conditions, objectives, standards, and guidelines are established for each of these areas, 

as well as individual resources in the forest plan. Proposed projects, including mineral projects, 

must be consistent with these forest plan components. The forest plan does not modify mineral 

rights. Mineral rights are established by law, and therefore are outside the scope of the forest plan.

Acquiring mining claims is not within the authority of the Forest Service. Future projects and 

activities, of any kind, must be consistent with various laws, agency policy and direction, and the 

forest plan.

Concern Statement: The Forest Service should revise the guidelines for reclamation and closure 

outcomes when mining is permitted to comply with the Organic Administration Act of 1897.

(32.22, 32.28)

Response The minerals guidelines were not modified. The intent of the minerals guidelines is to 

reduce impacts to resources. Compliance with laws, including the Organic Administration Act, is

not a forest plan component but a requirement of the agency, regardless of the land management 

plan in effect.

Concern Statement: The Forest Service should remove the mining standard relating to 

permanent structures because it is not consistent with the Mining and Minerals Policy Act.

(32.14)

Response: This standard was not modified as it does not restrict permanent structures considered 

reasonably incident to approved mineral operations. This standard is consistent with law, policy, 

and regulation for minerals management as listed in forest plan appendix E, “Other Sources of 

Information” under “Minerals.” This standard is also consistent with the Mining and Minerals 

Policy Act, which directs the Federal Government to foster and encourage private enterprise in 

the development of economically sound and stable domestic mining and minerals industries and 

the orderly and economic development of domestic mineral resources.

Concern Statement: The Forest Service should analyze the economic costs and benefits from 

permitting mining, such as Rosemont, the Rosemont mine will likely have some adverse 

economic effects, and include the amenity value of the forest. (32.27, 42.02)

Response: The effects of individual mining projects (including the Rosemont Mine) are projectspecific and not within the scope of the forest plan. Economic impacts of mining in the plan area, 

as a whole, are described in chapter 3 under the “Economic Conditions and Trends” section of the 

environmental impact statement. The project-specific economic analysis for the Rosemont Mine 

and related documents can be found at www.rosemonteis.us.

Concern Statement: The Forest Service should analyze the effects of mineral extraction as it 

relates to surface disturbance, municipal water supplies, and climate change and the amount of 

carbon released. (32.26, 32.39, 32.40, 31.01, 52.03)

Response: Mineral extraction activities and their effect on resources are project-specific and not 

a plan-level decision. However, impacts of mineral activities in the plan area, as a whole, are 

described in chapter 3 under the “Mineral Resources” section of the environmental impact 

statement. The environmental effects of mineral extraction are analyzed at the project level on a 

case-by-case basis.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

54

Concern Statement: The Forest Service should prohibit open pit mining or extraction activities, 

such as Rosemont Mine, that scars the land to preserve the long-term ecological and economical 

sustainability of the region. (32.45, 32.24, 42.04, 52.02, 52.04)

Response: The forest plan contains standards and guidelines aimed at minimizing adverse 

impacts from mineral extraction and mining activities on sensitive forest resources. Most of the 

guidance for mining is governed by law, regulation, and policy, which are outside of the scope of 

the forest plan as described in chapter 3 of the environmental impact statement. The Coronado 

National Forest follows the National Environmental Policy Act process in permitting new mineral 

extraction and mining activities, and all individuals have equal standing and opportunity to 

comment on projects and raise issues about the potential effects of mineral extraction and mining 

activities.

Concern Statement: The Forest Service should remove the guideline related to mining 

reclamation measures that reduce contrasts with surrounding landscapes because it is inconsistent 

with existing Forest Service regulations and could result in larger areas of disturbance. (32.13, 

32.13)

Response: This guideline is intended to help naturalize the landscape during reclamation 

activities. Specific reclamation measures to reduce contrast with surrounding landscapes will be 

developed at the project level on a case-by-case basis to meet this guideline, which is consistent 

with current regulation.

Concern Statement: The Forest Service should clarify how desired conditions for mineral 

activities will be met, their relationship to current laws, and how they will be met for Rosemont 

Mine. (32.04, 32.30)

Response: Most of the guidance for mining is governed by law, regulation, and policy, which are 

outside of the scope of the forest plan as described in chapter 3 of the environmental impact 

statement. Projects must be consistent with the forest plan in effect at the time the project 

decision is made. The Rosemont project, with its plan amendment, was consistent with the 1986 

forest plan, which was in effect at the time of the project decision. There is no requirement to 

revisit project decisions made under a previous forest plan, when a new revised forest plan goes 

into effect. That said, the revised plan will be reviewed and potential adjustments may be made 

via a plan amendment to ensure consistency between the Rosemont project and revised forest 

plan if any adjustments are felt to be warranted. The consistency of the Rosemont project with the 

1986 forest plan is described in the project-specific analysis at http://www.rosemonteis.us.

Concern Statement: The Forest Service should clarify the extent to which mining cannot be 

restricted on the forest, how it is outside the scope of forest planning, and how the effects will be 

managed and mitigated, and whether the extent of potential impacts from mining can affect the 

decision. (32.06, 32.15, 32.08)

Response: Most of the guidance for mining is governed by law, regulation, and policy, which is 

outside of the scope of the forest plan, as described in chapter 3 of the environmental impact 

statement. The Coronado National Forest follows the National Environmental Policy Act process 

in permitting new mineral extraction and mining activities, and all individuals have equal 

standing and opportunity to comment on projects and raise issues about the potential effects of 

mineral extraction and mining activities.
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In most locatable minerals operations, the Forest Service does not have the legal discretion to 

deny a proposal to explore for and remove the minerals. Locatable minerals include minerals that 

do not commonly form ore deposits, such as metals. The Forest Service does have the legal 

discretion to deny disposal of salable minerals, such as sand and gravel and common building 

stone. It also has some discretion over the conditions under which leasable minerals, such as oil, 

gas, and coal are disposed of.

Whenever a proposal is being considered and analyzed, comments received through the National 

Environmental Policy Act process are utilized to develop alternatives and mitigation to minimize 

the impact of mineral exploration, development and extraction on other resources. Conditions to 

the mineral operation, including for reclamation, will be added to the final approval, and 

compliance will be assured through measurements and reclamation bonding. 

Forest plan desired conditions for mineral operations will be considered in each analysis and will 

be met so far as pertinent statute and regulations allow. In situations where the Forest Service 

does not have the discretion to deny a proposed operation, or modify it to completely meet 

desired conditions, an amendment to the forest plan will be considered.

Concern Statement: The Forest Service should revise the text related to the authority to deny 

mineral activities to emphasize support for multiple use and give greater weight to developing 

mineral resources. (32.25, 32.31)

Response: Most of the guidance for mining is governed by law, regulation, and policy, which are 

outside of the scope of the forest plan as described in chapter 3 of the environmental impact 

statement. Future projects and activities, of any kind, must be consistent with the forest plan and 

various laws, agency policy, and direction to manage vegetation and natural resources for 

multiple uses, all of which provide resource outputs for human society, either directly or 

indirectly.

In most locatable minerals operations, the Forest Service does not have the legal discretion to 

deny a proposal to explore for and remove the minerals. Locatable minerals include minerals that 

do not commonly form ore deposits, such as metals. The Forest Service does have the legal 

discretion to deny disposal of salable minerals, such as sand and gravel and common building 

stone. It also has some discretion over the conditions under which leasable minerals, such as oil, 

gas, and coal, are disposed of.

Whenever a proposal is being considered and analyzed, comments received through the National 

Environmental Policy Act process are utilized to develop alternatives and mitigation to minimize 

the impact of mineral exploration, development and extraction on other resources. Conditions to 

the mineral operation, including for reclamation, will be added to the final approval, and 

compliance will be assured through measurements and reclamation bonding. 

Concern Statement: The Forest Service should acknowledge that they have discretion to deny 

mining, to provide a more realistic description of the agency's responsibilities, if the mine does 

not minimize impacts, and if the mining activities do not follow all other laws, regulations, 

treaties, and executive orders that protect public land resources. (32.37)

Response: The Forest Service regulatory framework related to mineral resources is described in 

chapter 3 of the environmental impact statement under “Mineral Resources.” Laws and 

regulations are not forest plan-level decisions. Project-level consistency with them is an agency 
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requirement as outlined in each individual statute, regardless of the land management plan in 

effect.

Concern Statement: The Forest Service should clarify that environmentally sound procedures 

are used on all existing mineral exploration and mining activities to be consistent with other 

language under “desired conditions.” (32.05)

Response: As stated in the “Minerals” section of chapter 2, “Forestwide Management” of the 

plan, it is Forest Service policy to support responsible, environmentally sound energy and mineral 

development and reclamation on the Coronado National Forest.

Concern Statement: The Forest Service should provide additional detail about how mining 

activities may affect management goals, including preservation of open space, protection of 

sensitive species and riparian habitat, ecosystem restoration and resiliency, and regional air 

quality and visibility goals. (32.35)

Response: The effect of proposed mining activities on management goals, including preservation 

of open space, protection of sensitive species and riparian habitat, ecosystem restoration and 

resiliency, and regional air quality and visibility goals, are analyzed at the project level on a caseby-case basis. However, impacts of mineral activities on these resources in the plan area are 

described in chapter 3 under the “Mineral Resources” section of the environmental impact 

statement. The effects of mining activities are project specific and are not described in the forest 

plan.

Concern Statement: The Forest Service should describe how the resource management 

direction related to riparian areas would protect resources affected by mining, including effects 

from the Rosemont Mine. (32.19)

Response: Desired conditions, objectives, and guidelines for riparian areas are described in 

chapter 2 of the forest plan. Any proposed project, including mining, must be consistent with 

these plan components. Projects must be consistent with the forest plan in effect at the time the 

project decision is made. The Rosemont project, with its plan amendment, was consistent with the 

1986 forest plan, which was in effect at the time of the project decision. There is no requirement 

to revisit project decisions made under a previous forest plan, when a new revised forest plan 

goes into effect. That said, the revised plan will be reviewed and potential adjustments may be 

made via a plan amendment to ensure consistency between the Rosemont project and revised 

forest plan if any adjustments are felt to be warranted. Project-specific environmental analysis 

and related documents for the Rosemont project can be found at http://www.rosemonteis.us.

Concern Statement: The Forest Service should provide additional data supporting the assertion 

that abandoned mines do not pose a threat to water quality. (32.34)

Response: This comment regarding abandoned mines is in reference to desired conditions in the 

forest plan, not existing conditions. Language from the desired conditions section under the 

“Minerals” heading in chapter 2 of the plan states:

"[a]bandoned and inactive mines disturbed by past mineral exploration and mine 

development have been returned to stable conditions . . . and do not pose health, safety, 

or environmental hazards,"
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As desired conditions, these are aspirations and additional data are not available. The full 

definition of the desired conditions plan component can be found in chapter 1 under the 

“Forest Plan Content” section.

Water quality is an important forest resource parameter. The forest plan has a number of desired 

conditions, guidelines, and management approaches relating to water resources:

• Desired Conditions under Watershed – Water quality meets Arizona and New Mexico water 

quality standards and supports designated beneficial uses and native and desired nonnative 

aquatic species.

• Guideline under Natural Water Sources – Water quality, quantity, soil function and structure, 

and wildlife habitat (including aquatic species habitat) should be protected or enhanced at 

natural springs and seeps.

• Management Approaches under Natural Water Sources – Implementing total maximum daily 

load plans to enable the Coronado to meet or exceed State of Arizona, State of New Mexico, 

or Environmental Protection Agency water quality standards for designated uses.

Concern Statement: The Forest Service should clarify why locatable minerals seem to be 

treated differently than leasable and salable minerals. (32.29)

Response: Management of locatable mineral resources on National Forest System lands are 

governed by specific laws, regulations, and policies as described in chapter 3 of the 

environmental impact statement under the “Mineral Resources” section. These statutes and 

directives are, in most cases, different than those governing leasable and salable mineral 

resources; therefore, the forest management of these resources also differs.

Concern Statement: The Forest Service should reconsider the standards and guidelines for 

mining because their implementation would be unduly burdensome and expensive, and because 

they are not sufficiently comprehensive, and will not result in the described desired conditions. 

The Forest Service should include standards to protect water resources and sensitive plant and 

animal habitat, to require scrutiny of open pit mining, and to outline areas that should be 

withdrawn because they are not economically feasible for open pit mining. (32.11)

Response: Desired conditions, objectives, and guidelines for resources managed by the Forest 

Service, such as water resources, plant and animal habitat, are described in chapter 2 of the forest 

plan. Standards and guidelines are purposely created to move toward desired conditions. Any 

proposed project, including mining, must be consistent with these plan components. Desired 

conditions, standards, and guidelines for mineral resources were developed for the forest plan 

using the best available science (see the analysis results and literature citations in the plan, 

environmental impact statement, and supporting plan record of documents). Forest Service policy 

also requires interdisciplinary specialists to use the best available science for their analyses at the 

project level, to inform the deciding official.

The Forest Service direction for withdrawals is outlined in Forest Service Manual 2760.

Generally, a withdrawal is a management tool for withholding an area of National Forest System 

land from settlement, sale, location, or entry under some or all of the general land laws, including 

the mining and mineral leasing law, for the purposes of limiting activities under those laws in 

order to maintain other public values in the area, or reserving the area for a particular public 

purpose or program. These programs and purposes may include quality of scientific, scenic, 

historical, ecological, environmental, air, water resource, archaeological values, or other special 
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purposes. Before recommending an administrative withdrawal for a certain area, the Forest 

Service must comply with the requirements under 43 CFR 2310.1-2 for consideration of 

alternative protection opportunities such as a right-of-way under section 507 of the regulations

(43 U.S.C. 1767) or a cooperative agreement under sections 302(b) (43 U.S.C. 1732(b)) and 

307(b) (43 U.S.C. 1737(b)) of the regulations, or other protection methods. These requirements 

are restated in the forest plan as guidelines under chapter 2 in the “Land Ownership Adjustments 

and Boundary Management” section.

Concern Statement: The Forest Service should identify all acts that modify the mining laws as 

applied to local areas. And identify how they protect National Forests from becoming mining 

districts. (32.20)

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

policy. References to relevant laws, regulations, or policies related to minerals are listed in 

appendix E “Other Sources of Information” of the plan. Future minerals projects and activities, of

any kind, must be consistent with the forest plan and various laws, agency policy, and direction to 

manage vegetation and natural resources for multiple uses.

Concern Statement: The Forest Service should clarify how the plan will protect surface 

resources if it can be modified to allow destructive mining projects. (32.03)

Response: Desired conditions, standards, and guidelines for mineral resources were developed 

and included in the forest plan to minimize adverse impacts from mineral activities on sensitive 

forest resources (see chapter 2 of the forest plan). The effects of specific proposed mining 

activities on surface resources are analyzed at the project-level on a case-by-case basis and are 

not described in the forest plan. Requirements for revisions and amendments to a forest plan are 

found in Forest Service Manual 1921.3 and 1926.5, respectively

Concern Statement: The Forest Service should analyze the impacts of adding Wild Backcountry 

and Scenic Resource areas on valid existing rights because this zoning will affect the mining 

claims and private in-holdings in these areas. (32.17)

Response: The designation of Wild Backcountry Land Use Zones will have no effect on mineral 

rights. Most of the guidance for minerals activities is governed by law, regulation, and policy, 

which are outside of the scope of the forest plan as described in chapter 3 of the environmental 

impact statement. The desired conditions and guidelines for the Wild Backcountry Land Use 

Zone are described in chapter 3 of the forest plan under the “Land Use Zones” section. The 

desired conditions and guidelines do not restrict minerals-related activities. No scenic resource 

areas are being proposed in the forest plan.

Concern Statement: The Forest Service should acknowledge the long-term value of wilderness 

is worth more than the short-term value from mineral extraction. (32.43)

Response: All National Forest System lands determined to meet wilderness capability 

requirements are considered potentially available for wilderness designation. However, the 

determination of availability is conditioned by the value of and need for the wilderness resource 

compared to the value of and need for other resources (see 2007 Forest Service Handbook

1909.12 chapter 72.2). The availability of an area for wilderness designation is based on the 

tradeoffs involved in managing the area for wilderness character versus current and potential 

future uses, including mineral resources. Refer to the Potential Wilderness Area Evaluation 
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Report for more detailed information and analysis of the potential wilderness areas considered for 

recommendation in the forest plan.

Concern Statement: The Forest Service should acknowledge that there are several reasonably 

foreseeable mining actions on the horizon. (32.42)

Response: Mineral activities and their effect on resources are project-specific and not a planlevel decision. The environmental effects of mineral extraction are analyzed at the project level 

on a case-by-case basis. A list of these proposed projects currently being analyzed can be found 

on the latest Coronado National Forest schedule of proposed actions.

Concern Statement: The Forest Service should acknowledge that taxpayers are subsidizing 

mineral extraction activities. (32.16)

Response: As a Federal agency, the Forest Service is funded by the Federal Government to 

manage natural resources-related activities on National Forest System lands, including mineralrelated activities; however, agency funding is outside the scope of the forest plan.

Concern Statement: The Forest Service should clarify the mechanisms proposed for managing 

and monitoring mineral ventures to avoid costly delays and encourage exploration and mining 

activities and how it plans to encourage mineral exploration and development. (32.07)

Response: While the forest plan provides some guidance for management of mineral-related 

activities, most of the guidance is governed by law, regulation, and policy which is outside of the 

scope of the forest plan, as described in chapter 3 of the environmental impact statement. During 

the development of the plan, the intent was not to repeat law, regulation, or policy. Those relevant 

laws, regulations, or policies are listed in appendix E, “Other Sources of Information” of the plan.

While the Forest Service manages some mineral related activities, it does not typically encourage 

or promote them.

Proposed Mines (42)

Concern Statement: The Forest Service should more accurately describe the nature and effects 

of the Rosemont Mine and whether the forest plan affects the mine. (42.03, 42.05)

Response: Projects must be consistent with the forest plan in effect at the time the project 

decision is made. The Rosemont project, with its plan amendment, was consistent with the 1986 

forest plan, which was in effect at the time of the project decision. There is no requirement to 

revisit project decisions made under a previous forest plan, when a new revised forest plan goes 

into effect. That said, the revised plan will be reviewed and potential adjustments may be made

via a plan amendment to ensure consistency between the Rosemont project and revised forest 

plan if any adjustments are felt to be warranted. The project-specific environmental analysis, 

including consistency with the 1986 forest plan, and any forest plan amendments, can be found at 

http://www.rosemonteis.us. 

Concern Statement: The Forest Service should recognize the pending amendment to the 

existing land and resource management plan that would facilitate construction and operation of 

the Rosemont mine to avoid administrative issues. (42.01)

Response: Projects must be consistent with the forest plan in effect at the time the project 

decision is made. The Rosemont project, with its plan amendment, was consistent with the 1986 

forest plan, which was in effect at the time of the project decision. There is no requirement to 
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revisit project decisions made under a previous forest plan, when a new revised forest plan goes 

into effect. That said, the revised plan will be reviewed and potential adjustments may be made 

via a plan amendment to ensure consistency between the Rosemont project and revised forest 

plan if any adjustments are felt to be warranted. The amendment to the 1986 forest plan related to 

the Rosemont project is project-specific and included in the project-level analysis. Projectspecific environmental analysis and related documents for the Rosemont project can be found at 

http://www.rosemonteis.us.

Concern Statement: The Forest Service should explain why the environmental impact statement

indicates that pollutant emissions will be calculated during site-specific review, but the Rosemont 

Mine environmental impact statement claimed there was insufficient data to quantify emissions.

(42.06)

Response: The effects of the Rosemont project are project-specific and not within the scope of 

the forest plan. Information regarding the Rosemont project can be found at 

http://www.rosemonteis.us. 

Saleable Minerals (52)

Concern Statement: The Planning Rule is the national model for the development of forest 

plans, and as such, should be followed in the Coronado National Forest (CNF) Plan. The CNF 

plan should not include hard rock mining because the Planning Rule does not address this 

resource use. (52)

Response: The forest plan is mandated by the National Forest Management Act NFMA and the 

1982 Planning Rule to address multiple resource use on the Coronado National Forest, including 

mining. In the case of this forest plan, the minerals include locatables, saleables, and potentially, 

leasables. Management of locatable mineral resources follows the General Mining Law of 1872, 

as amended, which means the Forest Service does not have the discretion to deny most locatable 

mineral mining and exploration proposals, once the proposed action is modified to address issues 

identified through National Environmental Policy Act analysis. Although the agency has greater 

discretion in saleables and leasables disposal and surface management, we still have to follow 

national direction and policy to consider exploration and extraction of these minerals. As such, it 

is reasonable to address mineral resource use and management in the forest plan.

Concern Statement: The Forest Service should be handling National Environmental Policy Act

compliance for hardrock mines to ensure that coordination with cooperating agencies is handled 

properly. (52.01)

Response: Coordination efforts with cooperating agencies during the project-specific National 

Environmental Policy Act analysis is considered at the project-level and is not a plan-level 

decision.

Fire and Fuels Management (20)

Concern Statement: The Forest Service should disclose the implications of climate change on 

wildland fire, fire danger and management options including the potential for large-scale, highintensity fires. (20.08, 20.14)
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Response: Climate change is addressed in "Forestwide Management" in chapter 2 of the forest 

plan and chapter 3 of the environmental impact statement. Appendix A of the plan also outlines 

the potential implications of climate change to the Coronado National Forest, which consist of a:

• projected increase in frequency of extreme weather events;

• projected increase in wildfire risk;

• projected increase in outbreaks of insect, diseases and nonnative invasive species;

• projected increase in demand for decreasing upland water supplies; and

• projected increase in national forest socioeconomic uses and demands.

Appendix A includes climate change effects on natural ecological processes, including wildfire, 

and outlines five potential strategies for management:

• Enhance adaptation by anticipating and planning for disturbances from intense storms

• Use a suite of adaptation options to manage ecosystems in the face of uncertainty

• Increase water conservation and plan for reductions in upland water supplies

• Anticipate increase in forest recreation use

• Monitor climate change influences and the effectiveness of adaptation approaches

Current scientific information regarding the effects of climate change on forest resources is 

incorporated in the revised forest plan. It is presented as a general description of anticipated 

changes in conditions as they are known to a reasonable level of certainty. It also outlines desired 

conditions for all vegetation communities to promote their increasing resiliency and adaptation 

capacity to changing conditions and other stressors, such as extended drought and warmer 

temperatures, which are projected to occur in the Southwest relating to climate change.

Concern Statement: The Forest Service should address how to limit the destruction from fires 

and resulting erosion and add restoration after fires to the management approaches. (20.03, 20.18)

Response: Limiting the destruction from wildfires is discussed throughout the plan in response 

to the need for change topic of “Ecosystem Restoration and Resiliency.” Forestwide desired 

conditions, as well as specific desired conditions for each vegetation community, describe 

conditions in which fire occurs in a natural role. Objectives provide actions to move towards 

desired conditions which include more natural fire regimes to help limit uncharacteristic fire 

effects. Restoration after fires will be determined at the project level on a case-by-case basis after 

each wildfire. Other post-wildfire programs address suppression damage; post-fire rehabilitation, 

restoration, and recovery (Forest Service Manual 2030); and nonfire emergency response.

Concern Statement: The Forest Service should prohibit vehicular access to remote areas and 

prohibit open fires during fire season to reduce the incidence of illegal fires. (20.05, 20.07)

Response: Prohibiting vehicle access and open fires during fire season is not a plan-level 

decision. This type of action is covered under the “Southeast Arizona Restriction Coordination 

Area Interagency Fire Restrictions and Closure Operating Plan.”

Concern Statement: The Forest Service should improve the management of the forest related to 

fire to address the variety of circumstances that exist in the forest. (20.02, 20.04)
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Response: The intent of the revised plan is to improve the overall management of the forest 

including fire. Please review the “Wildland-Urban Interface,” “Air” and “Cultural Resources” 

sections of the plan for additional fire management information relevant to the aforementioned 

themes. We developed the plan using the best available science (see the analysis results and 

literature citations in the plan and environmental impact statement, other sources of information 

forest plan appendix E under “Fire Management” and in the supporting project record of 

documents).

Concern Statement: The Forest Service should identify an official fire season for clarity and to 

develop habit and avoid spending money on large fires. (20.10, 20.19)

Response: These comments are outside the scope of the forest plan. Although statistics exist to 

help determine a “fire season,” this can vary from year to year depending on weather and fire 

occurrence. Other documents (“Southeast Zone Interagency National Fire Danger Operating 

Plan”) discuss potential fire season characteristics. Large fires need to be managed in some 

manner as dictated by policies outside the scope of the forest plan decision.

Concern Statement: The Forest Service should address the increasing number of unnatural fires, 

acknowledge that campgrounds are a significant source of fire danger, and determine how to 

distinguish between natural and unnatural fires. (20.01, 20.16)

Response: While the plan provides guidance for managing planned and unplanned ignitions, 

addressing the issue of increases in “unnatural” or human-caused fires is covered in other 

documents (Fire Prevention Plan, Fire Management Plan, Southeast Zone Interagency 

Restrictions and Closure Plan, Southeast Zone Interagency National Fire Danger Operating Plan)

and is outside the scope of the forest plan decision. The determination of fire cause is a standard 

practice and Forest Service policy that occurs with every fire.

Concern Statement: The Forest Service should increase fines for illegal fires and ban repeat 

offenders. (20.12)

Response: Laws, regulations, and their enforcement are not forest plan-level decisions. 

Enforcement is not a forest plan component but is a requirement of the agency, regardless of the 

land management plan in effect.

Concern Statement: The Forest Service should reconsider preventing fires in nonadapted desert 

communities, and provide justification for the approach. (20.15)

Response: Neither the plan nor the environmental impact statement include a management 

approach for preventing fire in desert communities. However, the environmental impact statement

analysis provides information on the nonfire-adapted characteristics of the desert communities 

and the plan provides guidance (chapter 2,” Forestwide Management,” “Desert Communities”) 

for managing this ecosystem, including limiting the use of wildland fire.

Concern Statement: The Forest Service should acknowledge that the safety of firefighters 

cannot be a coequal goal with the safety of the public. (20.17)

Response: This standard was included in the revised plan to reflect the 2001 Federal Wildland 

Fire Management Policy that “Firefighter and public safety are the first priority in every fire 

management activity.” This plan standard does not imply firefighter safety and public safety can 
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all be “maximized” on every incident but rather a balance must be found, with priority given to 

firefighter and public safety.

Concern Statement: The Forest Service should ensure that critical routes remain open during 

fire emergencies to provide access for fire fighters and egress for evacuees. (20.09)

Response: Road access during fire emergencies is not a plan-level decision. Road access during 

fire emergencies will be determined on a case-by-case basis depending on the circumstances at 

the time.

Concern Statement: The Forest Service should define “unplanned ignition” and determine the 

situations under which unplanned ignition would be allowed to continue. (20.06)

Response: “Unplanned ignition” is defined in the glossary of the plan under “Wildfire” as 

follows: 

Wildfire: An unplanned ignition caused by lightning, volcanoes, unauthorized and 

accidental human-caused actions, and escaped prescribed fires (synonym: unplanned 

ignition). 

The forest plan does not direct suppression or management of unplanned ignitions. The Coronado 

National Forest’s annual fire management plan provides the operational parameters whereby fire 

managers implement decisions at that level of detail. The fire management plan describes fire 

management strategies, tactics, and alternatives for fire management units, including when to let 

unplanned ignitions continue. The specific strategies chosen for the management of wildfires 

includes interdisciplinary input to assess site-specific values to be protected. Incident objectives 

and courses of action are developed to enhance or protect those values.

Concern Statement: The Forest Service should include landscape-scale fire planning in the plan 

that implements the Galiuro FireScape. (20.11)

Response: While the plan provides some guidance for landscape-scale fire planning, (chapter 2, 

“Wildland-urban Interface,” management approaches), the Galiuro FireScape is a project-level 

decision and is outside the scope of the forest plan decision.

Concern Statement: The Forest Service should not add an additional layer of management in 

the Cave Creek Birds of Prey Zoological-Botanical Area to deal with fire threat because 

additional management will not affect the fire threat. (20.13)

Response: The proposal to add the Cave Creek Canyon Bird of Prey Zoological Area is not 

driven by fire threat and is not meant to alter the impact that fire has on this area. Fire 

management in this proposed zoological-botanical area will be consistent with the objectives for 

forestwide vegetation communities and resources.

Fuel Treatment, Reduction (21)

Concern Statement: The Forest Service should clarify how fuels reduction will be 

accomplished given the limited funding available and provide for contingency plans if funding is 

not available (e.g., fuel treatment of the Pinaleño Ecosystem Management Area, as provided for 

in the draft plan). (21.02, 21.03)

Response: The objectives in the forest plan were developed to be realistic and able to be 

implemented with anticipated future budgets (expected to be similar to current budgets). Chapter
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1 of the plan acknowledges that “Variation in achieving objectives may occur during the next 15 

years because of changes in environmental conditions, available budgets, and other factors.”

Objectives are strongly influenced by recent trends, past experiences, and anticipated staffing 

levels and short-term budgets. Allocation of funds is outside the scope of the plan.

Concern Statement: The Forest Service should clarify when and how areas will be treated for 

fuel reduction and should not use fire as a restoration tool in certain vegetation communities.

(21.01)

Response: The forest plan is strategic in nature and does not include project and activity 

decisions. The objectives of the forest plan as they relate to “treatments” are based on the 

timeframe of every 10 years and the “how” is included in the objectives (i.e., wildland fire, 

prescribed cutting, mastication, or herbicides). Wildland fire is only considered as a viable tool in 

those vegetation communities that are fire adapted and have historically evolved with fire,

including Madrean encinal woodland, grassland, interior chaparral, Madrean pine-oak woodland, 

mixed conifer, and ponderosa pine-evergreen oak. For desert communities, the forest plan

includes a guideline that states “Wildland fire should not be used as a management activity, 

except as a strategy to control invasive vegetation.”

Concern Statement: The Forest Service should develop fire management standards and 

guidelines requiring analysis of spatial dimensions of local fire regimes to address the issue of 

slope and local topography in fire behavior. (21.04)

Response: This level of analysis is not conducted for a programmatic forest plan level decision. 

It is completed during project planning and the specific factors listed would be addressed there.

Spatial fire behavior modeling is commonly used at the project level to inform decision making 

when planning and managing wildland fire at the project level.

Concern Statement: The Forest Service should provide more information on the impact of 

snags and coarse woody debris on fires. (21.05)

Response: The desired conditions for woodland and forested vegetation communities include 

“well-distributed snags and coarse woody debris.” The desired conditions for these vegetation 

communities were developed using the best available science and supporting documents 

including the Mexican Spotted Owl Recovery Plan (2012). Snags and coarse woody debris are 

constituent elements related to Mexican spotted owl habitat and coincide with the historic 

structure of these vegetation communities under a more natural fire regime. The distribution of 

snags and coarse woody debris as described in the desired conditions of the forest and woodland 

vegetation communities will promote characteristic fire behavior and intensities rather than 

uncharacteristic fire impacts.

Concern Statement: The Forest Service should analyze the effect of slash fuels and treatment 

options on fire hazard and ecosystem resilience, and prioritize fuel treatments at locations where 

relatively little resource investment may create fire resistant conditions most efficiently. (21.06)

Response: This is outside the scope of the forest plan. This level of analysis is completed during 

project planning and the specific factors listed would be addressed there. The Coronado is not

considered a commercial timber-producing national forest and therefore does not manage largescale timber sales. Slash fuels produced from project-level activities such as prescribed cutting

are either removed through fuelwood sales, piled and burned on site, or lopped and scattered, 

leaving little residual fuel loading that would affect fire hazard.
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Prescribed Burns (40)

Concern Statement: The Forest Service should use prescribed fire because it helps reduce largescale fires. (40)

Response: Throughout the environmental impact statement, wildland fire (planned and 

unplanned ignitions) and natural disturbances are identified and evaluated as a means to attain 

vegetation desired conditions as identified in chapter 2 of the revised plan. The Coronado is not

considered a commercial timber-producing forest and therefore does not manage large scale 

timber sales. Slash fuels produced from project level activities, such as prescribed cutting, are 

either removed through fuelwood sales, piled and burned on site, or lopped and scattered, leaving 

little residual fuel loading that would affect fire hazard.

Concern Statement: The Forest Service should use techniques that mimic natural disturbance 

caused by fire, insects, or pathogens, including prescribed burning. (40.01, 40.04)

Response: Throughout the environmental impact statement, wildland fire (planned and 

unplanned ignitions) and natural disturbances are identified and evaluated as a means to attain 

vegetation desired conditions, as identified in chapter 2 of the revised plan.

Concern Statement: The Forest Service should allow prescribed fire in wilderness areas to 

reverse the effects of years of over-aggressive fire suppression. (40.02)

Response: The plan does allow prescribed fire in designated and recommended wilderness areas. 

Plan components that describe prescribed fire in wilderness can be found in chapter 3, in “Plan 

Components for All Designated Wilderness Areas,” “Fire in Wilderness.” Guideline 2 supports 

the use of prescribed fire in wilderness.

Concern Statement: The Forest Service should consider and disclose the effects of using 

prescribed fire. To reduce risk, provide ecosystem services, and regulate greenhouse gas 

emissions. (40.03)

Response: The “Vegetation Communities,” “Fuels and Fire” sections in chapter 3 of the 

environmental impact statement discuss the application of planned and unplanned ignitions on the 

landscape. It compares the existing vegetation condition class by alternative to determine the 

progress of moving toward desired conditions. It also outlines its emphasis of treatments near 

wildland-urban interface, thus reducing the hazards from uncharacteristic wildfires. Other 

sections in chapter 3 (e.g., “Soils,” “Water Resources,” “Species Diversity and Viability”) 

describe the effect of fire on resources that provide ecosystem services. As discussed in the “Air 

Quality” section, limits to smoke emissions (including greenhouse gases such as carbon dioxide) 

from prescribed fires and wildfires are imposed by the Arizona Department of Environmental 

Quality.

Suppression (57)

Concern Statement: The Forest Service should clarify that protection of cultural and biological 

values is of higher value than protection of structures (including University of Arizona 

equipment), when it comes to firefighting on the Coronado (especially Pinaleño Mountains).

(57.01, 57.02)

Response: In response to protecting values from fire, the forest plan reflects the 2001 Federal 

Wildland Fire Management Policy that “Firefighter and public safety are the first priority in every 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

66

fire management activity.” The plan also reflects the 2009 Guidance for the Implementation of 

the Federal Wildland Fire Management Policy, which lists nine guidelines, including:

“Managers will use a decision support process to guide and document wildfire 

management decisions. The process will provide situational assessment, analyze hazards 

and risk, define implementation actions, and document decisions and rationale for those 

decisions.” 

The forest plan does not imply protection of any one value is more important than the other, but 

rather a balance must be found between safety and cost, with priority given to firefighter and 

public safety.

Concern Statement: The Forest Service should switch to more natural fire management 

regimes, phasing out natural fire suppression because it is a waste of resources and 

counterproductive. (57.03, 57.04)

Response: The forest plan focuses on restoring natural fire regimes. In chapter 2 “Vegetation 

Communities,” the desired conditions for the fire-adapted vegetation communities describe the 

natural fire regimes for each community. There will always be some level of active fire 

management during natural ignitions needed due to the values at risk (wildland-urban interface, 

threatened and endangered species, infrastructure, and other values). The Coronado National 

Forest’s annual fire management plan provides the operational parameters whereby fire managers 

implement the decisions of the land management plan. The fire management plan describes fire 

management strategies, tactics, and alternatives for fire management units. The specific strategies 

chosen for the management of wildfires includes interdisciplinary input to assess site-specific

values to be protected. Incident objectives and courses of action are developed to enhance or

protect those values.

Wildland-urban Interface (61)

Concern Statement: The Forest Service should reconsider providing assistance to people who 

own property along the wildland-urban interface. (61.01)

Response: Providing assistance to people who own property along the wildland-urban interface 

is outside the scope of the forest plan. The forest plan only provides guidance for National forest 

System lands not adjacent lands. The plan does provide desired conditions and management 

approaches in chapter2, “Forestwide Management,” “Wildland-Urban Interface” that support and 

encourage planning and cooperation across jurisdictional boundaries as stated in the 2001 Federal 

Wildland Fire Management Policy and The National Cohesive Wildland Fire Management 

Strategy.

Concern Statement: The Forest Service should ensure that the desired conditions related to the 

wildland-urban interface are not interpreted as a mandate to act in overly ambitious ways. (61.02)

Response: Desired conditions are aspirational and not considered to be mandates or 

commitments or final decisions to approve projects. See the explanation for desired conditions 

under chapter 1, “Introduction, Forest Plan Content”.

Vegetation Management (59)

Concern Statement: The Forest Service should adopt the proposed plan for managing 

grasslands because it would improve the fire regime and improve habitat for grassland-dependent 

species. (59.01)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

67

Response: We agree the forest plan’s direction for the grassland communities facilitates the 

return to historical fire regime that would benefit grassland-dependent species.

Concern Statement: The Forest Service should include analysis of the rate of oak mortality on 

the forest and include management recommendations. (59.02)

Response: Management responses to specific mortality events are not a plan-level decision. 

These responses are specific to each event and will depend on specific tree species and mortality 

agents involved. Conditions to improve the overall health of the Coronado National Forest are 

addressed throughout the plan and are a primary aspiration of the desired conditions statements 

for each vegetation community in chapter 2 of the forest plan.

The Forest Service monitors forest insect and disease activity annually. This information is 

published in an annual Forest Insect and Disease Conditions report. Excessive tree mortality on 

the Coronado National Forest is investigated by local foresters and by forest health specialists 

from the Forest Service Arizona Forest Health Zone Office.

Concern Statement: The Forest Service should include standards to preserve, maintain and 

develop old growth forests and retain large trees. Old growth forests are valuable as research 

sites, carbon stores, climate change refugia, and wildlife habitat. Large trees are deficit across the 

landscape and are important to restoration efforts as large trees provide valuable habitat and are 

more resistant to fire. (59.03, 59.05, 59.18)

Response: Late-seral forests containing large trees are a primary component of the desired 

conditions and are addressed in the guidelines for the forest communities. Old growth is 

described in terms of forest structure and old growth components such as old trees, dead trees, 

downed wood, and structural diversity. The location of old growth shifts on the landscape over 

time as a result of tree growth and mortality. The definition of old growth can be found in the 

forest plan glossary. 

In ponderosa pine-evergreen shrub and dry mixed-conifer forests, old growth is addressed as finescale structure; in wet mixed-confer and spruce-fir forests, old growth is addressed as stand- and 

forest-level structure. Peer-reviewed (Reynolds et al. 2013) reconstructed conditions for 

southwestern ponderosa pine and frequent-fire mixed conifer (dry mixed-conifer) indicate that 

old-growth structure was not historically found in large contiguous areas, but rather at finer scales 

across the landscape. A strategy to enhance the development of old-growth forests includes 

restoring the composition and structure of frequent-fire forests (ponderosa pine and dry mixedconifer) so that they are less susceptible to large-scale severe wildfire and disease outbreaks that 

threaten trees reaching maturity (Reynolds et.al. 2013).

Concern Statement: The Forest Service should reconsider the standards allowing aquatic 

pesticides because they do not work and threaten Endangered Species Act-listed species. (59.04)

Response: If considered for treatment, pesticide use undergoes environmental analysis for 

potential impacts before it is used on a project-level basis. The guideline ISM-G-1 encourages the 

Coronado National Forest to remove invasive animals in aquatic habitat that supports native fish 

and other special-status aquatic species. Project-level analysis will determine how best to 

accomplish the goal of invasive species removal which may or may not include the use of aquatic 

pesticides. Such project-level analysis will comply with all applicable laws and regulations.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

68

Concern Statement: The Forest Service should identify and manage for Canelos Ladies Tresses 

and Huachuca water umbel. The Forest Service should add giant saguaro, Arizona white oak, 

Mexican blue oak, alligator juniper, and ponderosa pine as management indicator species. (59.06, 

59.07, 59.17)

Response: The forest plan includes guideline HUA-G-4, which recommends that grounddisturbing activities and vegetation management be designed to benefit or mitigate potential 

impacts to numerous special status plant species. While Canelo Hills ladies’ tresses are not 

specifically mentioned, project design will certainly include this plant because of its Federal 

listing status. Additionally, guidelines intended to improve riparian, meadow, and aquatic habitat 

and protect aquatic, meadow, and riparian species will benefit this species (MOM-G-1, 2, 

WET-G-1).

Management indicator species were selected based on the criteria that their population changes 

are believed to indicate the effects of management activities being emphasized in the plan 

alternatives, so that the effects of each alternative on fish and wildlife populations can be 

estimated (Forest Service Manual2605 and 2620). Page 324 of the draft environmental impact 

statement explained the process for selecting management indicator species. The management 

indicator species selected were included in part for ease of monitoring as well as their value and 

indicator of ecosystem health. Other species were considered but not included in the list based on 

the evaluation criteria.

Concern Statement: The Forest Service should consider the effects of timber and fuelwood 

harvest, mechanical treatments, and forest roads on soil, and on wildlife populations and habitats.

(59.08, 59.10, 59.21)

Response: The effects of timber and fuelwood harvest, mechanical treatments and forest roads as 

well as all other forest activities were assessed relative to threatened and endangered species in 

table 75 in chapter 3 of the environmental impact statement. In addition, the species viability also 

assessed these effects for Forest Service sensitive species and species of concern (chapter 3, 

“Species Diversity and Viability”). Vegetation management and National Forest System roads are 

also discussed in the “Soils” analysis in chapter 3 of the environmental impact statement. 

Timber and fuelwood harvest, mechanical treatments, and National Forest System roads require 

site-specific analysis and are not analyzed at the level of the forest plan. If these types of projects 

are proposed, effects of the activities will be analyzed at the project level on a case-by-case basis.

Concern Statement: The Forest Service should not equate post-fire logging with ecological 

restoration or forest management objectives because salvage logging causes more environmental 

damage than it solves. (59.09)

Response: We agree salvage logging does not equate with ecological restoration; however, 

salvage is a specialized tool for achieving objectives related to desired conditions, public health 

and safety, and economics (see standard VFP-S-2 in the “Forest Products” section of chapter 2, 

“Forestwide Management” in the forest plan). Furthermore, post-fire salvage logging is not a 

forest plan-level decision. Salvage logging will be evaluated at the project level at a case-by-case 

basis.

Concern Statement: The Forest Service should establish criteria for active and passive 

restoration of forest vegetation. The Forest Service should include restoration and reseeding 

under management approaches for all projects. (59.11, 59.12)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

69

Response: The forest plan promotes restoration through the desired condition statements and 

objectives for each vegetation community. The forest plan does not prescribe how criteria should 

be established or implementation should be accomplished. Those decisions are typically made at 

the project level. The best available science is used to help managers decide how to improve 

ecosystem resiliency through restoration treatments (Reynolds et al. 2013).

Similarly, the National Forest Management Act requires regeneration of trees (planting or 

seeding) within 5 years of the disturbance if natural regeneration does not occur; however, 

specific reforestation projects will be analyzed at the project level on a case-by-case basis at a 

future date. Post-fire reseeding is site-specific in accordance with burned area emergency 

response guidelines and forest service manual direction.

Concern Statement: The Forest Service should provide support for the claim that managed 

herbivory aids in sustaining or improving native vegetation cover and composition. (59.13)

Response: The effects of livestock grazing vary with timing, duration, and intensity. Negative 

effects of heavy grazing are well documented and include changes to vegetation structure and 

composition, soil structure, and water infiltration (Schussman and Smith 2006). An emerging 

research interest in the effects of well-managed grazing at light to moderate levels, as compared 

to grazing exclusion, has revealed benign or even beneficial effects to various rangeland 

ecosystem components or processes (Curtin 2008, Holechek 2004, Loeser et al. 2007, Sprinkle et 

al. 2007). Currently, stocking rates on the Coronado National Forest are light to moderate, which 

is consistent with sustaining rangeland native vegetation cover and composition (Holechek et al. 

1999).

Concern Statement: The Forest Service should consider wider use of stewardship contracting as 

a tool for vegetation treatments because it reduces the costs of vegetation treatment. (59.14)

Response: The plan does not preclude the use of stewardship contracts as a vegetation 

management tool; stewardship contracting is encouraged as a management approach of the 

“Forest Products” section in chapter 2. To clarify that stewardship contracting is encouraged, this 

management approach has been changed to read:

“Encouraging use of forest products through stewardship contracting in lieu of onsite 

burning or chipping.”

Concern Statement: The Forest Service should explain how the plan will address vegetation 

conditions that are divergent from reference conditions and should include a description of the 

process for prioritizing vegetation treatments to ensure that the desired conditions can be met.

(59.24, 59.15)

Response: The forest plan addresses vegetation conditions that are divergent from reference 

conditions through the plan objectives that describe treatments and treatment acres; these 

objectives can be found for each vegetation community in chapter 2 in the “Vegetation 

Communities” section. Objectives outline how the forest plan will move toward desired 

conditions, which, in most cases, mirror reference conditions. 

Generally, vegetation treatments will be prioritized based on proximity to the wildland-urban 

interface, presence of invasive species, and high departure from desired conditions.

Concern Statement: The Forest Service should include a vegetation map to disclose the location 

and extent of plant communities. (59.16)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

70

Response: The location and extent of vegetation communities are constantly shifting though 

time and space as disturbances impact communities. The tools used to measure and map 

vegetation communities are also evolving. We used a variety of vegetation maps to help develop 

the forest plan and environmental impact statement; these include Region 3 mid-scale mapping, 

potential natural vegetation type map, Integrated Lands Assessment Project maps, and 

LANDFIRE maps calibrated to local expertise. The management of specific areas is scaledependent and will be assessed in project-level decisions; at the scale of the forest plan, maps 

provide a perspective on extent, acreage, and distribution, but project-level plans are more 

specific to location. A link to forest vegetation maps has been added to the plan under “Vegetation 

Communities - General Description”. 

Concern Statement: The Forest Service should reconsider the emphasis given to manzanita 

control because it does not appear to be necessary because manzanita is a native species and an 

important wildlife food source. (59.19)

Response: Manzanita control is discussed in the environmental impact statement as a past action 

that occurred under the 1986 plan; the revised forest plan does not promote manzanita control. 

Under the 1986 forest plan, treatments targeting manzanita occurred in the grassland, interior 

chaparral, and Madrean encinal woodland communities (see the environmental impact statement, 

chapter 3, “No Action” discussion of grassland, interior chaparral, Madrean encinal woodland, 

and Madrean pine-oak woodland). The revised forest plan includes manzanita as a desired species 

in grassland, interior chaparral, Madrean encinal woodland, and Madrean pine-oak woodland 

communities (forest plan, chapter 2, desired conditions for grassland, interior chaparral, Madrean 

encinal woodland, and Madrean pine-oak woodland).

Concern Statement: The Forest Service should revise the vegetation elements of the plan: to 

acknowledge that there is no significant die-off of border piñon in the Coronado; to correctly 

identify locally harvested plants; to remove careless weed from the plants desired to be 

widespread; to correct the spelling of Pennisetum ciliare; to clarify that low elevation 

communities may not be fire adapted; to add a desired condition for rare plants; to ensure that 

extirpated species are reintroduced in areas that are likely to remain suitable through climate 

change; and to ensure that snags are provided for breeding, feeding, and shelter for species. (59.2)

Response: The reference to piñon die-off occurs in the forest plan, appendix A (“Climate Change 

Trends and Coronado National Forest Land Management Planning.” Appendix A is meant to give 

managers an idea of the kinds of changes possible under climate change; it is not meant to convey 

what has occurred or is currently occurring on the Coronado National Forest. We have clarified 

the statement regarding piñon die-off to read:

“For example, piñon pines recently experienced a severe dieback following extreme 

drought in northern Arizona and northern New Mexico, both directly and from increased 

insect attacks (Breshears et al. 2005).”

Rewording language in appendix A of the plan includes:

Climate change could have long-term impacts on many of the amenities, goods, and services from 

forests, including recreational opportunities, productivity of locally harvested plants such as 

several species of agave and cholla, prickly pear, mesquites, desert hackberry, grasses and sotols,

local economics through land use shifts from forest to other uses, forest real estate values, and tree 

cover and composition in urban areas, and associated benefits and costs

The spelling correction was made. The plan was also modified to clarify the following: 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

71

In fire-adapted ecosystems, fire-adapted native plants are abundant when fire is the critical catalyst 

used to establish the natural ecosystem process.

Reworded desired conditions for “animals and rare plants” now reads: 

Naturally occurring native ecosystems are present and sustainable across the Coronado National 

Forest, providing habitat to support a full complement of plants and animals, including sensitive 

and rare species.

By including the following under management approaches and guidelines, it is inferred under 

associated desired conditions in chapter 2 of the plan.

Management Approaches for Animals and Rare Plants - Considering the reintroduction of 

extirpated species to habitats that are reasonably assured to remain suitable through climate 

change.

Under guidelines for Madrean encinal woodland, the forest plan states, “Fuel reduction and 

habitat restoration projects should leave clusters of live trees, snags, and shrubs to benefit species 

that require these structures for breeding, feeding, shelter, and other habitat needs.”

Concern Statement: The Forest Service should clarify the discussion of suitable and unsuitable 

timber and how determinations were made. (59.22)

Response: Appendix C of the environmental impact statement discusses the timber suitability 

analysis. Unsuitable forest land is forest land not managed for timber production because: (a) 

Congress, the Secretary, or the Chief has withdrawn it; (b) it is not producing or capable of 

producing crops of industrial wood; (c) technology is not available to prevent irreversible damage 

to soils productivity, or watershed conditions; (d) there is no reasonable assurance based on 

existing technology and knowledge, that it is possible to restock lands within 5 years after final 

harvest, as reflected in current research and experience; (e) there is, at present, a lack of adequate 

information about responses to timber management activities; or (f) timber management is 

inconsistent with, or not cost efficient in, meeting the management requirements and multiple-use 

objectives specified in the forest plan.

Table 17 of the forest plan presents the timber suitability analysis. Approximately 86 percent of 

the Coronado is not considered productive enough for sustainable timber production. Of the 

remaining forest land, 75 percent has been withdrawn from public domain, primarily designated 

as wilderness. Of the nonwilderness forestland another 23 percent was removed because of poor 

or erosive soils. The remaining 45,657 acres are scattered in five mountain ranges across southern 

Arizona. Much of this timber land has been designated as habitat for threatened and endangered

species, either the Mexican spotted owl or the Mount Graham red squirrel; the rest is habitat for 

goshawk. Management for economical production of timber conflicts with objectives for habitat 

enhancement and protection, although timber harvest under prescriptions developed to maintain 

and protect habitat is not a conflict. Timber harvesting may occur; however, it will be to meet 

other plan objectives and not for the purpose of producing economically viable timber.

Concern Statement: The Forest Service should revise the guideline related to montane 

meadows to: comply with the Multiple Use-Sustained Yield Act and the National Forest 

Management Act and to be consistent with the travel management plan; to clarify that permitted 

water diversions should not alter the area of the meadow; and to prohibit motorized uses in these 

areas. (59.23)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

72

Response: In response to your comment, we added language to MOM-G-1 to ensure the integrity 

of montane meadows. Alterations to meadow area are necessary for meadow restoration 

treatments. MOM-G-1 now reads:

“Management activities in meadows should not be allowed unless impacts to meadow 

soils and hydrologic function and native plan assemblages can be mitigated.”

In regard to the MOM-G-2, the plan contributes to ecological, social, and economic sustainability 

focused on meeting the needs of the present generation without compromising the ability of 

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

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

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

The Multiple Use-Sustained-Yield Act of 1960 (section 1) states:

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

range, timber, watershed, and wildlife and fish purposes.”

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

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

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

particular, include coordination of outdoor recreation, range, timber, watershed, wildlife

and fish, and wilderness . . .”

The plan provides for a variety of recreation opportunities: motorized, nonmotorized, developed, 

dispersed, and everything in between. However, not every recreation opportunity can be found 

everywhere on the Coronado National Forest.

Site-specific travel management planning will use the framework set by the plan (desired 

conditions, standards, guidelines), including those for meadows and will consider potential 

resource impacts, access needs, public input, and alternative views. If undesirable resource 

conditions resulted from open roads, they could be addressed through site-specific evaluation and 

analysis. While the plan does not duplicate the Travel Management Rule or the directives, it is 

consistent with both and is meant to be used along with the directives and the motor vehicle use 

map.

Invasive Vegetation Treatment (27)

Concern Statement: The Forest Service should revise the desired condition for nonnative 

species to reflect that they are not desirable in any circumstance on the forest. (27.01)

Response: The desired condition was not modified. Not all nonnative plants are invasive. The 

Forest Service defines invasive as: 

“A nonnative species whose introduction is likely to cause or has the potential to cause 

economic or environmental harm to an ecosystem or harm to human health or 

commerce." (Executive Order 13112) 

Desired conditions for invasive species are covered in chapter 2 of the plan within the 

“Vegetation Communities,” “Desired Conditions,” “Landscape Scale” section: 

“Native plant communities dominate the landscape, while invasive species are 

nonexistent or in low abundance. Establishment of invasive plant species new to the 

Coronado National Forest is prevented, even as climate change may favor new invaders.”
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

73

Concern Statement: The Forest Service should remove penalties for the occurrence of lovegrass 

on monitoring sites and rangelands. (27.12)

Response: The presence of nonnative lovegrass on rangeland monitoring sites is an indicator of 

departure from desired conditions, according to ecological site guides developed and maintained 

by the Natural Resources Conservation Service 

(http://www.nrcs.usda.gov/wps/portal/nrcs/main/national/technical/ecoscience/desc/). The forest 

plan desired conditions for grasslands and woodlands are based on these ecological site guides. 

We monitor rangelands to determine whether existing conditions are moving toward, or departing 

from, desired conditions. The techniques used for monitoring rangelands are outlined in a 

management approach in the “Range Management” section of the plan. They include the 

“Southwestern Region Rangeland Management Training Guide,” “Technical Interagency Guide,” 

and “Principles of Obtaining and Interpreting Utilization Data on Rangeland.” Changing criteria 

for these rangeland monitoring protocols is not within the scope of the forest plan.

Concern Statement: The Forest Service should implement measures to prevent livestock from 

spreading weeds, including herding away from infested areas, reducing use of salt blocks, 

prohibiting use of motorized vehicles for herding, and addressing the problem with invasive 

plants in water tanks. (27.03, 27.11)

Response: Desired conditions for invasive species are covered in chapter 2 of the plan within the 

“Vegetation Communities,” “Desired Conditions,” “Landscape Scale” section:

“Native plant communities dominate the landscape, while invasive species are 

nonexistent or in low abundance. Establishment of invasive plant species new to the 

Coronado National Forest is prevented, even as climate change may favor new invaders.”

This goal will encourage the use of management practices that prevent the spread of weeds. The 

plan does not preclude grazing management options to prevent livestock from spreading weeds, 

and decisions about what options to use are made at a project level on a case-by-case basis.

Concern Statement: The Forest Service should use the full spectrum of prevention and control 

strategies for invasive species, including: requiring pelletized/weed-free feed use by outfitters, 

weed-free campsites, prohibiting grazing in weed-invested areas, and quarantining pack stock 

animals before entering wilderness; coordinating with partners; prioritizing invasive and 

nonnative species based on control feasibility, species life history; and protecting high priority 

intact areas. (27.02, 27.04, 27.06, 27.07, 27.10)

Response: Desired conditions for invasive species are covered in chapter 2 of the plan in the 

“Vegetation Communities,” “Desired Conditions,” “Landscape Scale” section:

“Native plant communities dominate the landscape, while invasive species are 

nonexistent or in low abundance. Establishment of invasive plant species new to the 

Coronado National Forest is prevented, even as climate change may favor new invaders.”

In the “Desert Communities” section in chapter 2 of the plan, the objective is to:

“Suppress or eradicate buffelgrass on 1,000 to 1,500 acres of Sonoran Desert every year 

using herbicide and manual methods.”

Management of campsites, outfitters, and users of pack stock are not plan-level decisions and will 

be made at the project level on a case-by-case basis.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

74

Concern Statement: The Forest Service should include removal of mesquite as a management 

approach to increase infiltration of precipitation and reduce runoff and erosion. (27.05)

Response: The plan does not preclude the removal of mesquite; however, any proposal would 

need to go through site-specific analysis. While the plan provides some guidance for managing 

mesquite and other woody species, mesquite removal is done at the project level and not at the 

planning level and is therefore outside the scope of the forest plan decision. In the “Grassland 

Communities” section in chapter 2 of the plan, desired conditions include 0 to 10 percent tree and 

shrub canopy cover.

Concern Statement: The Forest Service should include Johnson and Bermuda grasses to 

outcompete invasive species. (27.08)

Response: Bermuda grass and Johnson grass are not native and can be very invasive on the 

Coronado National Forest, particularly in riparian areas. Desired conditions for invasive species 

are covered in chapter 2 of the plan within the “Vegetation Communities,” “Desired Conditions,” 

“Landscape Scale” section: 

“Native plant communities dominate the landscape, while invasive species are 

nonexistent or in low abundance. Establishment of invasive plant species new to the 

Coronado National Forest is prevented, even as climate change may favor new invaders.” 

Management of individual species is done at the project level and not at the planning level and is 

therefore outside the scope of the forest plan decision. They will be treated on a case-by-case 

basis.

Concern Statement: The Forest Service should reconsider the removal of buffelgrass because 

they have exaggerated the problem. (27.09)

Response: The plan was developed using the best available science for invasive weed control 

(see the analysis results and literature citations in the plan, the environmental impact statement, 

and supporting plan record of documents). Buffelgrass is on the Arizona Noxious Weed List, 

which imparts a legal obligation to landowners (including the Forest Service) to control it. Laws,

regulations, and their enforcement are not forest plan-level decisions.

Soils Management

Concern Statement: The Forest Service should place more emphasis on, and establish better 

standards to address litter, bare soil, soil compaction, and erosion rates to protect the soil resource 

and provide for long-term sustainability. (5.01, 5.02, 5.03, 5.04, 5.05)

Response: The desired conditions for soil have been revised to incorporate guidance governing 

soil quality standards outlined in the “Technical Guidance for Soil Quality Monitoring in the 

Southwestern Region” (USDA Forest Service 2013). This document defines soil quality standards 

that include an assessment of compaction, erosion, bare soil and litter components in the overall 

rating of soil quality. The desired conditions now call for the soil resource to be “satisfactory” and 

to assure long-term sustainability.

Concern Statement: The Forest Service should clearly define acceptable erosion rates. And 

prohibit grazing in areas that do not meet the standard. (55.04)

Response: Standards for soil quality, including soil erosion, follow regional direction in 

“Technical Guidance for Soil Quality Monitoring in the Southwestern Region” (USDA Forest 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

75

Service 2013). Impaired or unsatisfactory soil conditions are addressed at the project level, 

grazing allotment analysis process.

Concern Statement: The Forest Service should give priority to constructing loose rock dams 

and gabions to reduce soil loss and restore vegetation. (55.06)

Response: Loose rock structures are allowed under the plan and would help meet desired 

conditions. Project-level structure proposals would need to go through site-specific National 

Environmental Policy Act analysis.

Water, Watershed Management (60)

Concern Statement: The Forest Service should provide information on the current water quality 

status of watercourses within Coronado National Forest. To ensure sufficient description of the 

affected environment. (60)

Response: In Arizona, the Arizona Department of Environmental Quality (ADEQ) has 

responsibility for measuring surface water quality and setting standards for acceptable levels of 

contaminants. In New Mexico, this is provided by the Surface Water Quality Bureau of the New 

Mexico Environment Department. The environmental impact statement includes best available 

science and data. Many water courses are in remote locations that are relatively unaffected by 

uses that affect water quality. Measurements are generally taken in larger streams where there is a 

higher likelihood of measuring potential impacts.

Concern Statement: The Forest Service should acknowledge the importance of ephemeral and 

intermittent streams in the section on Riparian Habitats and add them to the Natural Water 

Desired Conditions, Objectives, and Standards. (60)

Response: The “General Description of the Natural Waters” section has been modified to include 

ephemeral and intermittent streams. Also, a statement was added that streams mentioned 

generally in the “Natural Waters” section and in other sections of the plan refer to ephemeral, 

intermittent, and perennial streams. 

In the “Riparian” section, a few words were changed or added to be more inclusive of all stream 

types, including perennial, intermittent, and ephemeral.

Concern Statement: The Forest Service should include specific location and information on 

instream flow rights for Harshaw Creek in Appendix G, Table 23. (60)

Response: The original intent of appendix G, table 23 was not to analyze the purpose or 

environmental impacts of the instream flow water rights applications, but was merely to state that 

they exist. This table was removed from the revised forest plan as it didn’t provide useful

information. The location and information about a particular instream flow water right and any 

associated monitoring station(s), including Harshaw, can be provided upon request on a case-bycase basis.

Concern Statement: The Forest Service should clarify the expectations regarding monitoring of 

riparian areas. (60)

Response: The monitoring and evaluation strategy shown in chapter 6 of the plan includes 

resource area monitoring to assess riparian areas, natural water sources, constructed water 

sources, and watersheds. Monitoring would be established to determine if riparian areas on the 
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forest are at or moving towards desired conditions shown in the plan for riparian areas and 

wetlands. Possible monitoring methods are listed in chapter 6, but these may change as new 

technology and methodologies are developed to assess riparian health.

Concern Statement: The Forest Service should modify the guidelines for riparian areas to ensure

that effects to channel morphology from road construction are also considered. (60)

Response: The guidelines have been modified to include channel morphology as requested. 

Concern Statement: The Forest Service should modify the wetland standard to include a goal of 

increasing wetland habitat through restoration or creation. (60)

Response: The “Wetland” section has been substantially revised since this comment was 

received. Changes made to that section now include more discussion about restoration. In 

regards to standards and guidelines, a guideline was added that states that wetland conditions will 

be “kept the same or improved”. A management approach was added: “Cooperating with 

conservation groups and agencies to leverage resources and implement projects that remove 

invasive plants, plant native vegetation, or otherwise assist to restore wetlands”. These changes 

were made to incorporate more intent towards restoration.

Concern Statement: The Forest Service should include more information on the effects and 

location of the Patagonia Municipal Supply Watershed designation including information on the 

effects to hydrology, mining, and the economy. Some respondents feel that the designation should 

be reconsidered or rejected. (60.03, 60.10, 60.11, 60.17, 60.35, 60.46)

Response: Regulation in the U.S. Code (42 U.S.C. Part A (4)(a)) defines a public water supply as

follows: 

“The term ‘‘public water system’’ means a system for the provision to the public of water 

for human consumption through pipes or other constructed conveyances, if such system 

has at least fifteen service connections or regularly serves at least twenty-five 

individuals.”

The Forest Service regulation for management of municipal watersheds (36 CFR 251.9 (a)) 

states:

“The Forest Service shall manage National Forest watersheds that supply municipal 

water under multiple use prescriptions in forest plans (36 CFR part 219). When a 

municipality desires protective actions or restrictions of use not specified in the forest 

plan, within agreements, and/or special use authorizations, the municipality must apply to 

the Forest Service for consideration of these needs.”

The Town of Patagonia water system treats and distributes water to approximately 3,000 residents

and meets the legal requirements for a public water system. Recognition of the Town of Patagonia 

municipal supply watershed in the forest plan is in alignment with the legal requirements listed 

above. The watersheds will continue to be managed for multiple use and no restrictions are being

incorporated. The Town of Patagonia and the Forest Service entered into an agreement to allow 

the town to post the watershed as a municipal supply watershed, conduct education programs in 

the watershed, and sample water quality according to Arizona Department of Environmental 

Quality protocols. Since no restrictions are being placed on these watersheds, no effects are 

predicted. 
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Concern Statement: The Forest Service should clarify diversions of water in wet meadows to 

resolve apparent conflicts, and to prohibit such diversions. (60.19, 60.38)

Response: Guidelines for meadows are found in chapter 2 of the plan within the “Vegetation 

Communities” section. The forest plan states:

“Management activities in meadows should not be allowed unless impacts to meadow 

soils and hydrologic function and native plant assemblages can be mitigated.”

In addition, a standard within the “Wetlands” section is updated slightly; see bold text below.

Management activities will only be allowed in wetlands, including wet meadows, if 

vegetative communities (except noxious and/or invasive plants), soil function and 

structure, and hydrologic function are kept the same or improved.

Concern Statement: The Forest Service should clarify objectives and correct references related 

to instream flow information for both New Mexico and Arizona. (60.18, 60.21, 60.22)

Response: The forest plan includes the following objective: 

“Every 10 years, apply for at least 10 instream flow water rights on streams for recreation 

and wildlife purposes, prioritizing locations necessary for sustaining native fish 

populations and species of conservation concern.” 

We believe this objective reflects the importance of protecting the rights of the American public 

for instream flows. The State of New Mexico water law does not address instream flow water 

rights. State of Arizona water law addresses instream flow water rights and the nonconsumptive 

use for recreation and wildlife (including fish).

Concern Statement: The Forest Service should consider more specific standards and direction 

on the restoration of aquatic habitats (including: springs, seeps, riparian areas, water courses, wet 

meadows) to better protect these resources and provide water for wildlife and livestock. (60.16, 

60.25, 60.30, 60.33, 60.36, 60.43)

Response: The objectives for natural water sources are for three developed springs to be restored 

every 10 years and three stream restoration projects, development projects, or both every 10 years 

to benefit aquatic habitat and species. The requirements in the plan are a minimum; the Coronado 

National Forest can do more restoration than that required by the forest plan. The Coronado has 

implemented the watershed condition framework process to help identify priority watersheds in 

need of restoration (see http://www.fs.fed.us/publications/watershed/).

Other additions and changes were made to the draft forest plan in response to this concern 

statement; see below. 

In the “Natural Waters” section, under “Desired Conditions:” 

“Where springs or other natural waters have been modified for livestock, wildlife, and/or 

human consumption, those developments that are still needed for these purposes are 

operational. Those that are no longer needed are dismantled, shut down, or otherwise are 

not creating or adding to natural resource problems.”

In Natural Waters section, under “Guidelines:”

“Water quality, quantity, soil function and structure, and wildlife habitat (including 

aquatic species habitat) should be protected or enhanced at natural springs and seeps.”
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“Vegetation treatments should favor the retention of snags, large diameter woody debris, 

and growth of large riparian trees along stream channels.”

In Natural Waters section, under “Management Approaches:”

“Coordinating with conservation groups and agencies to do spring inventory, assessment, 

restoration, monitoring, and research.”

In Wetlands section, under “Management Approaches:”

“Cooperating with conservation groups and agencies to leverage resources and 

implement projects that remove invasive plants, plant native vegetation, or otherwise 

assist to restore wetlands.”

In Watersheds section under “Objective:”

“Complete essential projects identified in a Watershed Restoration Action Plan (WRAP) 

for at least one identified priority watershed every 10 years.”

In Watersheds section under “Guidelines:”

“Watershed Restoration Action Plans (WRAP) should be used to guide completion of 

essential watershed projects.”

In the “Watersheds” section, all management approaches discuss the promotion or 

implementation of projects that improve watershed function, which would include the areas 

described in the concern statement.

Concern Statement: The Forest Service should assess and protect groundwater conditions and 

related aquatic habitats and disclose the effects of the plan on these resources. (60.06, 60.07, 

60.20)

Response: The plan was developed using the best available science for groundwater (see the 

analysis results and literature citations in the plan, the environmental impact statement, and 

supporting plan record of documents). Page 185 of the draft environmental impact statement 

discussed groundwater and the numerous Forest Service groundwater policies such as Forest 

Service Manuals 2543 and 2560 and technical manual 2880. Numerous sections detail the risks to 

the resource (such as wildlife, natural waters, and aquatic habitat) from groundwater dewatering 

and withdrawal.

The “Natural Waters” section of the draft forest plan included measures that would protect 

groundwater and related aquatic habitats, though the description doesn’t specifically mention 

groundwater depletion as an overall concern for the resource. The revised forest plan has been 

updated to include it; see below:

“Water resources are also at risk due to increased drawdown of aquifers and competing 

demands for multiple uses.”

Groundwater depletion was also added to the “Constructed Waters” section:

“Water resources are also at risk due to increased drawdown of aquifers and competing 

demands for multiple uses.”
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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There aren’t any measures protecting groundwater resources in the Constructed Waters section, 

but the reason for this is described in the “Water Quantity – Groundwater” section of the final 

environmental impact statement:

“Because the vast majority of groundwater withdrawals in southeastern Arizona and 

southwestern New Mexico occur on lands outside the Coronado, the Forest Service has 

no influence on their control. Forest Service groundwater policy (Forest Service Manuals 

2560, 2880, and 2543) as well as agency technical guides provide direction for well 

drilling and pumping on the Coronado, specifying that these activities must not adversely 

affect connected riparian habitat and water quantity and quality. Because direction in the 

Forest Service Manual is considered adequate and groundwater withdrawal is governed 

by State regulations, additional management direction was not specified by any of the 

action alternatives and they are not analyzed in this final environmental impact 

statement.”

Concern Statement: The Forest Service should address the impacts of mining on domestic 

water supplies and riparian habitats. (60.13, 60.31)

Response: When projects related to existing mines or future mines are proposed, they must go 

through environmental analysis to disclose potential effects from the project including effects to 

riparian areas and communities. The sources of water, quantity, and legal availability are part of 

the disclosure.

Concern Statement: The Forest Service should provide more protection for riparian and other 

water sources by including these in desired conditions, objectives, and standards to acknowledge 

their importance and ensure their protection. (60.24, 60.28, 60.39, 60.42)

Response: Riparian areas are discussed in chapter 2 of the plan in the “Vegetation Communities” 

section on “Riparian Areas”. This section details the desired conditions, objectives, and 

guidelines which address the protection of riparian areas. We are concerned about protecting

riparian areas as demonstrated by the following guideline:

“Management activities should only be allowed in riparian areas if soil function and 

structure, hydrologic function and riparian plant communities (except noxious and/or 

invasive plants) are kept the same or improved.” 

Concern Statement: The Forest Service should assess all water rights within the forest and 

discuss how changes in the plan may affect owners and users. (60.02, 60.15)

Response: An assessment of water rights is outside of the scope of forest planning. Water rights 

are not within the jurisdiction of the Forest Service and are managed by the Arizona Department 

of Water Resources. 

Concern Statement: The Forest Service should prioritize water resources for springs and 

riparian areas and discuss biological importance including threatened and endangered species. 

(60.44, 60.45)

Response: We developed the plan using the best available science for water resources and 

riparian areas (see the analysis results and literature citations in the plan, the environmental 

impact statement, and supporting plan record of documents). Forest Service policy also requires 

interdisciplinary specialists to use the best available science for their analyses at the project level, 

to inform the deciding official. The forest plan addresses these topics in numerous locations 
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including in the “Vegetation” section, “Animals and Rare Plants” section, and “Natural and 

Constructed Water” section.

As stated in chapter 2 under “Watersheds – General Description”, we have a procedure for 

prioritizing watershed restoration which includes evaluating riparian and springs. This procedure 

is the watershed condition framework. In the framework, class 1 watersheds are defined as 

functioning properly, class 2 watersheds are functioning at risk, and class 3 watersheds are 

impaired function. The classes are based on four processes: aquatic physical processes, aquatic 

biological processes, terrestrial physical processes, and terrestrial biological processes. The 

watershed condition framework is used to identify priority watersheds for restoration treatments.

As stated in chapter 2 under “Response to Climate Change: Aquatic, wetland, and riparian 

systems”, these systems also contain many threatened and endangered species. They are 

dependent on water and thus vulnerable to shifts in precipitation regimes. They may be further 

threatened by increased human demand for water for use in grazing, agriculture, and municipal 

drinking water. 

It is noted throughout the document that both springs and riparian habitat are important 

environments for numerous wildlife species including a variety of threatened or endangered 

species including the threatened Chiricahua leopard frog and the endangered Gila chub.

As stated in chapter 2 under “Riparian Areas – Desired Conditions”, the ecological condition of 

riparian areas is resilient to animal and human use. 

As stated in chapter 2 under “Animals and Rare Plants – Guidelines”, activities occurring in 

federally listed species habitat should apply habitat management objectives and species protection 

measures from approved recovery plans and signed conservation agreements.

As stated in chapter 2 under “Natural Water Sources – General Description”, natural waters 

provide water sources that are vital to wildlife. Some species also need natural waters for other 

critical life history components (such as food, shelter, and reproduction). These include the 

Chiricahua leopard frog, Sonoran tiger salamander, Northern Mexican gartersnake, Gila chub, 

Gila topminnow and many species of insects with aquatic larvae. 

Concern Statement: The Forest Service should take a watershed approach to monitoring, 

assessment, management, and to prioritize areas for treatment. The Forest Service should 

coordinate with other land management agencies and partners using a watershed approach. 

(60.05, 60.07, 60.47)

Response: We agree and we are taking a watershed approach to monitoring, assessment, 

management, and to prioritize areas for treatment whenever possible. We have added a 

“Watershed” section to the forest plan to emphasize this approach. We are also actively 

coordinating with other land management agencies and partners, using a watershed approach. An 

example of this work is our participation in the Sky Island Restoration Collaborative, which is 

accomplishing watershed restoration projects in the Chiricahua Mountains.

Concern Statement: The Forest Service should ensure that access to all water-related facilities 

is maintained to avoid loss of facilities and property rights. (60.04)

Response: The forest plan describes the issue of access and management approaches to address 

this issue in numerous locations including pages 8, 73, 74, and 94
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Concern Statement: The Forest Service should revise the list of streams eligible for wild and 

scenic river designation. Because none of the streams listed meet the qualifications for 

designation. (60.12)

Response: All rivers on the Coronado National Forest were evaluated to determine their 

eligibility as wild, scenic, or recreational rivers. Sixteen river segments are eligible for 

designation (forest plan pages 120 and 121). Evaluation includes a specific set of criteria which 

must be used to develop the list. Revising the list would not be consistent with the criteria used.

Concern Statement: The Forest Service should add surface water runoff as a way that 

constructed waters are fed. (60.14)

Response: Constructed waters are fed by a variety of methods including natural springs, 

groundwater wells, or stream diversions (forest plan, page 61) and these include surface water 

runoff in the form of stream diversions.

Concern Statement: The Forest Service should manage surface and groundwater resources 

conjunctively to benefit cave fauna. (60.23)

Response: We manage surface and groundwater resources conjunctively to benefit cave fauna as 

outlined in the “Forest Service Technical Guide to Managing Groundwater” (FS-881 May 2007) 

and in chapter 2, “Forestwide Management” under “Biophysical Features”, “Desired Conditions”: 

“Water flowing into, from, or within the cave system is not altered or diverted in its flow; 

contains normally fluctuating background levels of sediment, organic matter, and 

dissolved minerals; and is not polluted.”

and in Chapter 2, “Forestwide Management” under “Biophysical Features”, “Guidelines”: 

“Surface management activities, including drilling, in the vicinity of cave and karst 

features should avoid actions that would significantly impact underground ecosystems by 

modifying drainage patterns, subsurface water and airflow, or other natural processes.”

Concern Statement: The Forest Service should revise desired conditions related to water flow 

and wetlands to better reflect current circumstances and science. (60.27)

Response: The plan was developed using the best available science for water flow (see the 

“Natural Water Sources” and “Constructed Waters” sections) and wetlands (see the “Wetlands” 

section). Also, see the analysis results and literature citations in the plan, the environmental 

impact statement, and supporting plan record of documents. Forest Service policy also requires 

interdisciplinary specialists to use the best available science for their analyses at the project level, 

to inform the deciding official.

Concern Statement: The Forest Service should include an analysis of water demands on 

development opportunities to ensure sustained yield to support multiple uses. (60.32)

Response: The plan would not preclude the analysis of water demands on development 

opportunities; however, any proposal would need to go through site-specific National 

Environmental Policy Act analysis. Forest Service policy already dictates sustained yield to 

support multiple uses.

Concern Statement: The Forest Service should proceed with the standard protecting existing 

wetlands. (60.37)
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

82

Response: The forest plan will allow the Forest Service to proceed with the standard protecting 

existing wetlands.

Concern Statement: The Forest Service should develop a drought policy to address the nature 

of drought and how to protect resources during drought. (60.40)

Response: Drought is a recurrent phenomenon of variable intensity and duration that has 

different effects on forest uses so that it would be extremely difficult to develop one overarching 

policy for all resources. It is more reasonable to account for mitigation of drought effects on a 

site-specific basis through project planning or implementation of adaptive management measures. 

Drought is discussed at length in chapter 2 of the plan in the “Response to Climate Change” 

section and in appendix A of the forest plan, “Climate Change Trends.” Protection and 

sustainability of individual natural resources and achieving desired conditions in the presence of 

recurring drought is the goal of the plan.

Concern Statement: The Forest Service should integrate the management approach related to 

water conservation into other sections of the plan. (60.48)

Response: Water conservation is discussed in chapter 2 of the plan in the “Response to Climate 

Change” section and in appendix A of the plan, “Climate Change Trends.” The “Watershed”

section, as written, focuses on water resources and conservation across the forest including each 

vegetative type. Additional aspects of water resources are given in wetlands and riparian 

vegetation type. 

Individual Species (25)

Concern Statement: The Forest Service should reconsider management direction for the Wet 

Canyon Talussnail because the snail is geographically restricted.(25)

Response: There is nothing in the revised plan to indicate that the management plan involves any 

area other than the 1,218 acres in the Pinaleño Mountains. 

Concern Statement: The Forest Service should acknowledge that jaguar sightings and 

population trends are likely related to human activity and that jaguars have not been harmed as a 

result of roads, habitat fragmentation, corridor blocking, or border security measures. The 

primary threat to jaguars has been from shooting. (25.01, 25.07, 25.13)

Response: The Forest Service relies on the information published by the U.S. Fish and Wildlife 

Service as to the threats and recovery of all endangered species including the jaguar. Page 231 of 

the draft environmental impact statement described the risk factors to jaguars and identifies 

shooting as the primary risk historically and to date. 

Neither the forest plan nor the environmental impact statement go so far as to speculate 

concerning the cause of increased or decreased sightings or population trends. These are in the 

realm of peer-reviewed scientific study. Project-specific effects to the species and its habitat are 

not considered at the forest plan level. The effects of road construction, habitat fragmentation, and 

border security projects are assessed at the time of their planning. 

Concern Statement: The Forest Service should adopt standards that protect the areas identified 

as critical jaguar habitat and jaguar. The Forest Service should assist in the recovery of the jaguar. 

(25.02, 25.09, 25.28)
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Response: The draft environmental impact statement, chapter 3, (pages 230 and 231) described 

actions being taken by the U.S. Fish and Wildlife Service, Arizona and New Mexico Game and 

Fish Departments, and scientific community to aid in recovery of the species. The forest plan 

includes plan guideline ARP-G-1, which guides the Coronado National Forest to comply with all 

signed recovery plans. We are a cooperating agency along with Arizona and New Mexico Game 

and Fish in the recovery of the species. 

Concern Statement: The Forest Service should identify and protect key refuge site of the 

lowland leopard frog and Gila chub to help preserve the species. (25.03)

Response: The environmental impact statement (see the “Regionally Sensitive Species and Other 

Forest Planning Species – Environmental Consequences” section) includes a list of sensitive 

species identifying the threats and plan components that address those threats. Lowland leopard 

frog is included in this list.

The Gila chub is a federally listed species. At the time of the listing, critical habitat was identified 

by the U.S. Fish and Wildlife Service specifically to protect “key refuge sites.” Critical habitat 

has been designated and includes several drainages in the Coronado National Forest. Moreover, 

guideline ARP-G-1 guides the Coronado to implement recovery plans including that of the Gila 

chub. 

Concern Statement: The Forest Service should include separate guidelines for the Apache 

goshawk because the species is different from the northern goshawk and is a candidate for listing 

under the Endangered Species Act. The Forest Service should revise the guideline for goshawks 

because it does not accurately represent the minimum numbers of nest areas required for 

reproductive success to accurately reflect the nesting habits of goshawks. The Forest Service 

should reconsider eliminating standards and guidelines for northern goshawk to comply with the 

National Forest Management Act and the National Environmental Policy Act. (25.04, 25.24, 

25.26)

Response: The goshawk guidelines were adopted throughout the Southwestern Region in 1996 

and apply to all subspecies of goshawk that occur on National Forest System lands in the region. 

These guidelines were carried forward into the forest plan and are found in chapter 2, “Animals 

and Rare Plants” section, guidelines 4a through 4d. The goshawk guidelines were developed by 

an interagency team of biologists that used the best available science to describe the requirements 

and develop management recommendations for this species. 

Concern Statement: The Forest Service should manage and conserve roosting habitat for bats 

including snags, caves, and abandoned mines. The Forest Service should include canyon bat in 

the list of common animal species for desert communities. The Forest Service should 

acknowledge that the forest is home to more than half of the bat species known from the United 

States and Canada, and that they are dependent on the availability of surface water for drinking. 

(25.02, 25.08, 25.15, 25.18)

Response: The desired conditions for the woodland and forest vegetation communities include 

statements for snag maintenance across the landscape (see chapter 2 of the forest plan, 

“Vegetation Communities,” sections on Madrean encinal woodland, Madrean pine-oak woodland, 

ponderosa pine-evergreen shrub, dry and wet mixed-conifer, and spruce-fir). 
Appendix A. Response to Comments

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We added snag retention to guidelines VME-G-1, VMP-G-2, VPP-G-3, VDM-G-3, and VWM-G4. The guidelines read: 

“Fuel reduction and habitat restoration projects should leave clusters of live trees, snags, 

and shrubs to benefit species that require these structures for breeding, feeding, shelter, 

and other habitat needs.” (VME-G-1)

“Clusters of trees, shrubs, and snags should be maintained in treatment areas to benefit 

species that require these structures for breeding, feeding, shelter, and other needs. Snags 

may not be retained if safety concerns exist.” (VMP-G-2)

“Fuel reduction or fuelwood gathering projects should retain some large-diameter trees, 

snags, and shrubs, and these should be protected well enough from scorching to survive 

subsequent burn treatments.”(VPP-G-3, VDM-G-3 and VWM-G-4)

We keep a list of common desert species for any habitat type. We acknowledge there is a diversity 

of bat species and have added the canyon bat to the common species list for desert communities 

in the plan. The forest plan includes plan components to protect and enhance many water 

resources. The plan components can be found in the “Natural Waters” and “Constructed Waters” 

sections in chapter 2.

Concern Statement: The Forest Service should note that the fungus that causes white-nose 

syndrome in bats has been renamed "Pseudogymnoascus destructans." (25.16)

Response: The environmental impact statement has been updated to reflect that the fungus that 

causes white-nose syndrome has been renamed Pseudogymnoascus destructans

Concern Statement: The Forest Service should clarify why there is no restriction on nighttime 

motorized travel in bat habitat. (25.20)

Response: Any restrictions on motorized travel on the Coronado would be considered during the 

travel management planning process. 

Concern Statement: The Forest Service should only close areas for peregrine falcon nesting if 

the birds are actually present. (25.10)

Response: Closure orders are outside the scope of the plan and are completed through a sitespecific National Environmental Policy Act analysis. 

Concern Statement: The Forest Service should reconsider eliminating standards and guidelines 

for Mexican spotted owl in order to ensure adequate protection of the species under the 

Endangered Species Act. (25.11)

Response: The forest plan includes guideline ARP-G-1 which guides us to comply with all 

signed recovery plans. The recovery plan for the Mexican spotted owl, finalized in 2012, includes 

much more comprehensive and current guidance than the1996 plan amendment. We will comply 

with the recovery plan. 
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

85

Concern Statement: The Forest Service should revise the plan as it relates to red squirrel in the 

following ways: (1) ensure that the population information is accurate; (2) include the 

observatory as a threat; (3) include a standard to remove Abert's squirrel from red squirrel habitat; 

(4) ensure that efforts to protect red squirrel will not diminish values for other species; (5) explain 

how impacts from climate change will not affect the squirrel during the life of the plan; (6) 

include plans for the completion and implementation of a revised Mount Graham Red Squirrel 

Recovery plan. (25.12)

Response: Population information for the Mount Graham red squirrel is obtained from annual 

interagency surveys conducted by the Forest Service, U.S. Fish and Wildlife Service, Arizona 

Game and Fish Department, and the University of Arizona squirrel lab. These population 

estimates are derived using scientifically appropriate survey methods, which involve surveying a 

subsample of middens (food cache sites), assessing activity level, and then extrapolating the 

results to the population level. The method is standardized and randomized to obtain the most 

accurate results possible, and a range of a single standard deviation in each direction is reported 

as well. 

Because the Mount Graham International Observatory is already installed and has not submitted 

plans to expand, the Forest Service must consider that the effects of the observatory have been 

documented and addressed under the existing National Environmental Policy Act documentation 

and the associated consultation documents (AESO 02-21-86-F-075) and as such is considered 

part of the baseline for effects to the squirrel.

The Arizona Game and Fish Department is charged with management of game and nongame 

wildlife species and takes the lead on manipulations of wildlife species. The Forest Service has

assisted, and may continue to assist, with removal of Abert’s squirrels to aid red squirrel 

populations, but the main efforts of the agency will focus on improving habitat characteristics 

(such as tree density, tree species composition, and fuels conditions) for red squirrels.

To the extent possible, all project planning is conducted alongside analysis of multi-species 

effects and benefits. These analyses are required under a number of regulations (including the 

Endangered Species Act) and policies (Forest Service Manual 2670.32 and 2670.22, and 36 CFR 

219.19) to ensure no one species is favored to the detriment of others.

Climate change may affect red squirrels during the life of the plan; however, the extent of these 

effects is not specifically quantifiable within the time period that will entail. The Forest Service is 

focusing on making habitats as resilient as possible to wildfire, insect infestations, and other 

factors in order to provide the most sustainability possible given the unknown nature of the 

effects of climate change.

In chapter 3 of the environmental impact statement, the “Species Diversity and Viability,” 

“Environmental Consequences” section acknowledges a revision of this recovery plan is currently 

in preparation. When finalized, the recovery plan will be complied with under ARP-G-1. The 

creation of a recovery plan is under the authority of the U.S. Fish and Wildlife Service, rather 

than the Forest Service. The Forest Service will assist in this process as much as possible and will 

comply with it during project planning and implementation phases.

Concern Statement: The Forest Service should describe how big-horned sheep would impact 

the Mount Lemmon area around Pusch Ridge. (25.14)
Appendix A. Response to Comments

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Revision of the Coronado National Forest Land and Resource Management Plan

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Response: The Bighorn Sheep Management Area overlaps the Pusch Ridge Wilderness. Its 

primary purpose is to enhance and protect bighorn sheep and their habitat. It is managed under a 

closure order which prohibits hiking more than 400 feet off a designated trail during the lambing 

season, as well as the prohibition of dogs in the management area year round. In all other 

considerations, wilderness management standards and guidelines are the driving consideration for 

activities in this area. As such, there are no effects to the Mount Lemmon area from the bighorn 

sheep closure. 

Concern Statement: The Forest Service should provide more information on the extent to which 

fencing is affecting antelope. The Forest Service should provide hiding cover and a robust small 

plant community to benefit antelope. The Forest Service should include a desired condition for 

survival of antelope fawns to expand the existing population to provide adequate hiding cover 

(25.17, 21.21, 21.22)

Response: We cooperate with Arizona and New Mexico Game and Fish Departments on the 

management of this species and habitat. The effects to the antelope from projects such as fencing 

are considered and can be mitigated at the project level. Also, in many situations, antelope habitat 

is enhanced as a benefit of management activities at the project level. Grassland community 

management activities fulfilling desired conditions, objectives and guidelines will improve hiding 

cover and small plant communities which benefit antelope populations.

Concern Statement: The Forest Service should acknowledge that California Gulch has a small 

but consistent population of five-striped sparrows. The Forest Service should acknowledge that 

the Santa Rita Mountains have some of the highest populations of Mearn's quail in the region. 

(25.19, 25.27)

Response: The Coronado is home to some of the greatest bird diversity in the United States and 

management of their habitat is an important aspect of the forest plan. Chapter 3 of the 

environmental impact statement includes a section dedicated to consideration of species protected 

by the Migratory Bird Treaty Act Executive Order 13186 and the 2008 memorandum of 

agreement between the Forest Service and the U.S. Fish and Wildlife Service concerning the 

conservation of migratory birds. While not specifically mentioned, the five-striped sparrow is a 

species covered by the Migratory Bird Treaty Act. The approach to habitat management in the 

forest plan focuses on creating resilient habitat that will support the life cycle needs of a large 

variety of wildlife including migratory birds such as five-striped sparrow. Approaches to 

managing habitat for resiliency can be found in the “Vegetation” section of chapter 3.

Concern Statement: The Forest Service should include the black-tailed prairie dog and 

pronghorn antelope as a management indicator species. (25.23, 25.24)

Response: The forest plan considered a variety of species during the process of determining 

management indicator species. Among the criteria for management indicator species was their 

distribution throughout their habitat available on the Coronado National Forest. Black-tailed 

prairie dogs do not currently occur on the Coronado National Forest so they are not an adequate 

indicator. The pronghorn also was not considered because of its limited distribution on the 

Coronado National Forest. 

Seasonal Closures/Access (53)

Concern Statement: The Forest Service should revise the objective related to installing closures 

at mines, caves, and adits to limit closures to on an as-needed basis, as requested by the public to 
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exclude caves, to clarify the costs and benefits of closing mines, and to ensure that closures are 

wildlife-friendly. (53.01)

Response: The objective of adding wildlife-friendly closures is to help meet the desired 

conditions for forestwide management of biophysical features. Any installation of wildlifefriendly closures at mines, caves, or adits would require separate site-specific analysis at the 

project-level, which includes public involvement and analysis of effects.

Wildlife and Animals Management (64)

Concern Statement: The Forest Service should clarify how wildlife and riparian areas will see 

increased protection under the new plan.

Response: Species viability assessments conducted as part of the planning process and reports 

potential effects of plan direction on federally listed species and designated critical habitat; 

species and habitat proposed for listing; Forest Service, Region 3 sensitive species, migratory 

birds, eagles, forest management indicator species; and other planning species for the Coronado. 

An assessment of species diversity for the Coronado was completed. The coarse-filter approach 

of the 1982 Planning Rule guided the forest plan revision team in prescribing management 

direction necessary to conserve the diversity of forest plant and animal communities. From an 

initial list of 1,400 species, 437 species (terrestrial, aquatic, and plant) were determined to have a 

potential viability concerns. Designated as “forest planning species,” they include 36 mammals, 

32 birds, 8 amphibians, 19 reptiles, 73 insects, 4 other invertebrates, 16 fish, 56 mollusks, 7 

fungi-lichen, 5 mosses-liverworts, and 181 plants. Species viability assessments for those 437

species have been prepared according to Forest Service policy (Forest Service Manual 2670) and 

documented in three specialist reports: the “Coronado Population Viability Assessment Report,” 

“Coronado draft environmental impact statement biological assessment” and “Coronado draft 

environmental impact statement biological evaluation.” See Species Diversity and Viability 

section in FEIS for more details. 

“Chapter 2 Forestwide Management” includes desired conditions, objectives, guidelines, and 

management approaches for riparian areas (page 51) and animals and rare plants (page 65). 

Guidelines for protecting animals and rare plants are also found in various other sections of 

chapters 2, 3, and 4. A change to the final plan from the draft plan includes a new guideline 

regarding conservation agreements. 

Concern Statement: The plan should provide an ecosystem approach to stop aquatic habitat 

degradation, maintain habitat and ecosystems that are currently in good condition, and to aid 

recovery of at-risk aquatic species and their habitat. (64)

Response: The “Natural Waters” and “Watershed” sections of the forest plan have been updated 

since the draft plan, including “General Description” and “Desired Condition” sections that better 

describe overall stream function. Desired conditions for riparian areas includes the statement: 

Habitat and ecological conditions are capable of providing self-sustaining populations of 

native, riparian-dependent plant and animal species. 

Also, there is more information on how stream channels should be protected and maintained in 

the course of Forest Service management. Standards, guidelines, and management approaches 

have been updated since the draft plan to include more protections for water sources, which will 
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in turn help to protect fish and wildlife populations. The importance of habitat connectivity is

asserted in the “Desired Conditions” of the “Natural Waters” and “Watershed” sections. 

Concern Statement: The Forest Service should protect Endangered Species Act-listed species 

and prevent species extinctions. (64.01, 64.13, 64.21)

Response: The Forest Service is required by law to adhere to Endangered Species Act 

regulations, and to consult with U.S. Fish and Wildlife Service on all projects with the potential to 

have an adverse impact on listed species. Additionally, we analyze effects to Endangered Species 

Act candidate species and Forest Service sensitive species at the project level to prevent a trend 

toward listing under the Endangered Species Act. 

Concern Statement: The Forest Service should ensure that adequate data are gathered and 

analyzed to meet species viability requirements of National Forest Management Act and to 

properly guide management decisions. (64.02, 64.10, 64.08, 64.25, 64.26)

Response: We prepared species viability assessments for 437 species according Forest Service 

policy, Forest Service Manual 2670, and these were documented in three specialist reports: 

“Coronado Population Viability Assessment Report,” the biological assessment for the draft 

environmental impact statement, and the biological evaluation for the draft environmental impact 

statement. These assessments considered factors such as availability and current conditions of the 

habitat, population occurrences and distribution, and threats from Forest Service management 

actions. See chapter 3 of the environmental impact statement for more information.

Concern Statement: The Forest Service should ensure appropriate wildlife access for wildlife 

species around manmade developments. (64.03, 64.04, 64.09)

Response: The forest plan desired conditions were intended to ensure that manmade features do 

not impede animal movement. Ramps have been or are being installed at many wildlife waters 

across the national forest to allow smaller species access and egress from water sources. 

Concern Statement: The Forest Service should modify wildlife standards to clarify that 

reintroduction will only occur when conditions are appropriate. The Forest Service should avoid 

species designations and reintroductions until they are substantiated by reproducible scientific 

data. (64.05, 64.27)

Response: Species reintroductions are coordinated with wildlife management agencies (U.S. 

Fish and Wildlife Service, and Arizona and New Mexico Game and Fish Departments) to 

reestablish native populations or to prevent a trend toward Endangered Species Act listing. Such 

actions are outside the scope of the forest plan.

Concern Statement: The Forest Service should protect wildlife from noise, including noise from 

mining activities. (64.06, 64.11)

Response: The forest plan proposes a number of management strategies to provide a diversity of 

wildlife habitats, including designated wilderness and roadless areas that would provide quiet 

wildlife habitat. The impacts of noise from mining activities on wildlife are determined during 

project-level National Environmental Policy Act analyses. 
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Concern Statement: The Forest Service should acknowledge the importance of the habitats 

provided by the Coronado National Forest to a number of special status and bird species of 

conservation concern. (64.07, 64.18, 64.20, 64.24, 64.29, 64.30, 64.32)

Response: Additional language has been added to the forest plan in the “Animals and Rare 

Plants” section to highlight the diversity of bird species in the Coronado National Forest. Sitespecific areas have been identified in the plan that help protect bird species habitats: Cave Creek 

Birds of Prey Zoological-Botanical Area (Chiricahua Ecosystem Management Area), South Fork 

of Cave Creek Zoological-Botanical Area (Chiricahua Ecosystem Management Area), Guadalupe 

Canyon Zoological Area (Peloncillos Ecosystem Management Area), Sycamore Canyon 

Important Bird Area (Tumacacori Ecosystem Management Area), and Appleton-Whittell 

Research Ranch (Huachuca Ecosystem Management Area). 

Concern Statement: The Forest Service should ensure that closure areas are supported by 

science and monitored for effectiveness. (64.16, 64.22)

Response: Closure areas are not a forest plan-level decision. The Forest Service uses the best 

information and data available, and cooperates with the U.S. Fish and Wildlife Service, and 

Arizona and New Mexico Game and Fish Departments when establishing closure areas to protect 

specific species during critical times of the year.

Concern Statement: The Forest Service should acknowledge that two additional sites on the 

national forest are being evaluated for inclusion as important bird areas. The Forest Service 

should consider the important bird areas identified by Audubon. (64.31, 64.33)

Response: The Forest Service does not designate important bird areas, and the forest plan does 

not include specific desired conditions or standards for important bird areas. However, in the 

environmental impact statement, the list of important bird areas on the Coronado National Forest

has been updated. 

Concern Statement: The Forest Service should work to protect existing habitat and restore 

ecological functions to counteract the severe habitat degradation from human uses. (64.17)

Response: Many forest plan components including objectives, standards, and guidelines were 

developed to do just that. Objectives VDM-O-1 and VWM-O-1 include the treatment of 13,800 

acres of dry mixed conifer and 2,400 acres of wet mixed conifer respectively every 10 years. As 

an example, the guidelines VDM-G-1, VDM-G-2, VDM-G-3, VDM-G-4, VDM-G-5, VWM-G-1, 

VWM-G-2, VWM-G-3, VWM-G-4, VWM-G-5, and VWM-G-6 are intended to restore mixed 

conifer forests to more natural conditions. Similar standards and guidelines exist for woodlands, 

grasslands, riparian areas, and desertscrub.

Concern Statement: The Forest Service should add a desired condition regarding the ability of 

wildlife to adjust their movements in response to climate change. (64.12)

Response: We have developed a desired condition to maintain viable wildlife corridors. Should 

problems be identified for individual species, including from climate change, this would be 

addressed on a case-by-case basis and not at the forest plan level. 

Concern Statement: The Forest Service should acknowledge the importance of warm-water fish 

species and provide management direction to protect them. (64.14)
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Response: The plan includes many components designed to enhance or restore native, warm 

water fish habitat. Examples include NWS-O-1 and NWS-O-2 which are objectives designed to 

acquire water rights on areas where fish occur as well as reconstruct springs to support native 

wildlife, including fish. Guideline ISM-G-1 will result in the removal of nonnative invasive plant 

and animal species where fish and other special status aquatic species occur. The guidelines 

NWS-G-2, NWS-G-3, NWS-G-4, and NWS-G-5 allow for natural instream movement; reduce 

fuel build up; and protect water quality, quantity, and habitat features at natural springs and seeps 

prioritized on habitat where fish occur.

Concern Statement: The Forest Service should ensure that wildlife populations are managed 

properly to support the recreation and tourism economy and for the preservation of the culture 

and lifestyles of the local (human) population. (64.15)

Response: The forest plan calls for healthy populations of native species to allow for hunting, 

fishing, and other wildlife-based recreation activities in the “Animals and Rare Plants” section.

Concern Statement: The Forest Service should acknowledge that the Rocky Mountain Research 

Station has developed a system for assessing vulnerability of species. (64.19)

Response: The Rocky Mountain Research Station has indeed published a general technical 

report entitled “A System for Assessing Vulnerability in Species” (GTR RMRS-GTR-257, Bagne 

et al. 2011). Although not specifically cited, this report was considered in the preparation of the 

forest plan and environmental impact statement.

Concern Statement: The Forest Service should ensure that wildlife surveys will occur after 

gates are installed. (64.23)

Response: Although not clear, the commenter is likely talking about installation of bat gates. 

Guideline BIP-G-5 calls for management and protection of bat roosts. Such management may 

include installation of bat gates. Such installation projects would be subject to environmental 

review and while not explicitly stated in the guideline, post installation monitoring is a typical 

part of gating projects.

Concern Statement: The Forest Service should monitor management indicator species 

population and habitat trends to comply with the National Forest Management Act. (64.28)

Response: The management approaches section in the “Animals and Rare Plants” section of 

chapter 2 proposes to use the results of management indicator species monitoring to design 

adaptive management strategies to meet species conservation needs.

Concern Statement: The Forest Service should increase the number of management indicator 

species in the plan: to represent ecosystem trends and to include species of high public concern 

and specialized habitat requirements to represent the range of habitats; to allow for successful 

monitoring of forest health; and to include the 32 management indicator species in the previous 

plan (39.01)

Response: Management indicator species were selected based on the criteria that their 

population changes are believed to indicate the effects of management activities being 

emphasized in the plan alternatives, so the effects of each alternative on fish and wildlife 

populations can be estimated (Forest Service Manual 2605 and 2620). Page 324 of the draft 

environmental impact statement explains the process for selecting management indicator species. 
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The management indicator species selected were included in part for ease of monitoring as well 

as their value as an indicator of ecosystem health. Other species were considered but not included 

in the list based on the evaluation criteria.

Wildlife Corridors – General (62)

Concern Statement: The Forest Service should protect wildlife linkages and habitat 

connectivity for a variety of species. (62.02, 62.03, 62.04, 62.05, 62.06, 62.07, 62.08, 63.01, 

63.03)

Response: The forest plan desired conditions in the “Animals and Rare Plants” section call for 

coordination with agencies, municipalities and private landowners to ensure habitat connectivity 

is maintained across the ecosystem management areas of the Coronado National Forest. 

Concern Statement: The Forest Service should address the effects of climate change on wildlife 

linkages. (62.01)

Response: The forest plan desired condition in the “Animals and Rare Plants” section calls for 

the maintenance of wildlife corridors and for an adaptive management approach to address 

impacts from climate change. 

Concern Statement: The Forest Service should include updated maps and models for 

connectivity in the region. (62.09)

Response: The map and boundary areas were selected using data from Arizona’s Wildlife 

Linkages Assessment, an interagency effort available at 

http://www.azdot.gov/Highways/OES/AZ_WildLife_Linkages/assessment.asp

Concern Statement: The Forest Service should encourage the use of wildlife-friendly fences 

and road infrastructure. (62.10)

Response: The forest plan desired conditions were intended to ensure that manmade features do 

not impede animal movement. Ramps have been or are being installed at many wildlife waters 

across the Coronado to allow smaller species access and egress from water sources. 

Wildlife Corridors across International Border (63)

Concern Statement: The Forest Service should provide high-priority protection to the Patagonia 

and Santa Rita Mountains as a critical wildlife corridor to ensure viable bi-national connectivity 

in the region for black bears, jaguars, ocelots, willow-leaf oak, and other species. (63.02)

Response: Jaguar critical habitat emphasizes the management of moving corridors including the 

Patagonia and Santa Rita Mountains. The forest plan includes a guideline (guideline 1 in the 

“Animals and Rare Plants” section) which guides the forest to comply with signed recovery plans 

including the jaguar and ocelot. Other species will benefit including black bears. We do not 

manage for willow-leaf oak as they do not occur on the Coronado National Forest. 
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Recreation Management

Bicycling (2)

Concern Statement: The Forest Service should acknowledge that mountain biking groups assist 

with trail maintenance. (2.01)

Response: We appreciate volunteers and work by user groups. The plan provides recreation 

guidance (chapter 2, “Recreation,” management approaches) that acknowledges these efforts.

Concern Statement: The Forest Service should retain existing and provide new mountain biking 

opportunities, including retaining the trails in Ku Chish, creating more beginner-friendly loops, 

creating more trails, creating more one-way trails, creating cross-country loops, and avoiding 

closing more trails. (2.02, 2.03, 2.04, 2.07)

Response: Providing mountain bike opportunities is addressed in the “Recreation” section

(desired conditions, guideline 1, management approaches 14 and 20) and “Public Access”

(guideline 4) sections in the plan. The Ku Chish Potential Wilderness Area is currently available 

for mountain biking. However, recommended wilderness areas may become congressionally 

designated wilderness areas and, at such time, mountain biking would be prohibited.

Concern Statement: The Forest Service should encourage mountain biking, because it supports 

health and the local economy. (2.04, 2.05)

Response: The forest plan supports mountain biking by providing a full array of recreational 

activities across the Coronado National Forest (see chapter 2; “Recreation” section desired 

conditions, and guideline 1). The environmental impact statement includes a socio-economic 

analysis that addresses the value of mountain biking (see chapter 3, “Communities, Collaboration, 

and Partnerships” section, “Economic Conditions and Trends” subsection.

Concern Statement: The Forest Service should open the Mount Graham area to mountain 

biking because the trails are well constructed and biking will not impair the wilderness character 

of the landscape. (2.06)

Response: The Mount Graham Astrophysical and Biological Research Area, designated in 1989 

by the Arizona-Idaho Conservation Act, is closed to all recreation access including mountain 

biking. The designation of this research area and the associated closure to recreation access was 

not a forest plan decision. Mountain biking is currently allowed on designated National Forest 

System trails in the Mount Graham Wilderness Study Area. The forest plan makes a 

recommendation to designate the Mount Graham Wilderness Study Area as a wilderness area and 

provides guidance to maintain the wilderness characteristics of this area until Congress takes 

action. Upon wilderness designation by Congress, the Mount Graham Wilderness Study Area 

would be closed to mountain biking in accordance with the Wilderness Act of 1964. However, 

there are many trails available for mountain biking on Mount Graham outside the recommended 

wilderness area and outside the research area.

Developed Recreation and Facilities (13)

Concern Statement: The Forest Service should allow use of campgrounds, and picnic areas, 

provide a host at Cochise Stronghold, provide staffing at the Visitor Information Center, and 

prohibit new developed campsites in montane meadows. (13.01, 13.02, 13.03, 13.04)
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Response: The plan would not preclude any of these suggestions. However, any proposal would 

need to go through site-specific analysis. The plan addresses the developed recreation sites and 

their locations in the “Recreation” section, in desired conditions and management approaches.

Dispersed Recreation Management (14)

Concern Statement: The Forest Service should disclose the amount of primitive and semiprimitive recreation opportunity spectrum classes that will be lost. (14.01)

Response: We define the recreation opportunity spectrum, including the primitive and semiprimitive classifications, in the glossary of the forest plan. A description of how the recreation 

opportunity spectrum applies to the forest plan can be found in chapter 2 in the “Recreation”

section. The forest plan considered the recreation opportunity spectrum framework in the 

development of land use zones, which are management areas defined by types of uses and the 

desired settings that would occur within them. Table 2 in chapter 3 provides the acreages in each 

of these land use zones. It is unlikely there will be any loss of primitive or semi-primitive 

settings.

Concern Statement: The Forest Service should manage the forest to promote a dark, clear, and 

transparent sky to support the astronomy community. (14.04)

Response: Dark skies are described in chapter 4 of the forest plan in the desired conditions for 

the Nogales and Safford Ranger District geographic areas. Desired conditions for dark skies are 

described for geographic areas that include developed astrophysical sites. The desired conditions 

in the Santa Catalina Ranger District section of chapter 4 were modified to include consideration 

for dark skies.

Concern Statement: The Forest Service should provide for quiet recreation zones to protect 

lands and wildlife to reduce noise impacts and the creation of illegal trails. (14.05)

Response: The forest plan provides management direction for quiet recreation in chapter 3 in the 

“Land Use Zones,” “Designated Wilderness Areas,” “Recommended Wilderness Areas” and 

“Wilderness Study Areas” sections.

Concern Statement: The Forest Service should reconsider reducing areas available for dispersed 

camping because limiting the areas available will increase the use and damage to those areas.

(14.06)

Response: Guidelines in the “Recreation” section of chapter 2 state recreation sites should be 

managed for capacities that do not cause unacceptable resource damage or impact the landscape 

character. Increasing the number of dispersed recreation campsites is not a plan-level decision. 

This concern would be determined at the project level on a case-by-case basis at a future date

while taking this forest plan guideline into account.

Concern Statement: The Forest Service should close the Cochise area to climbing because 

climbing has caused significant damage. (14.07)

Response: The “Environmental Consequences” section in the “Recreation” section of chapter 3 

addresses the effects of recreation activities, including rock climbing. Specific reference to the

Cochise area, located on the Douglas Ranger District, can be found in chapter 4 of the forest plan. 

The “Recreation” section of chapter 2 in the forest plan further addresses rock climbing in the 

desired condition statement and in the following guideline: 
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“Rock climbing should be managed to balance demand for the activity and the need to 

protect plants, animals, and other natural resources.”

Concern Statement: The Forest Service should clearly document the locations of defined 

dispersed camping sites on the west side of the ecosystem management area in the Dragoon 

Mountains. (14.10)

Response: While the plan provides some guidance for managing dispersed recreation, 

identification of dispersed camping areas can generally be found on visitor use maps and is 

outside the scope of the forest plan decision.

Fees and Permits (19)

Concern Statement: The Forest Service should reconsider phasing out permits for isolated 

cabins, privately owned buildings, and residences and should retire permits for recreation 

residences as they expire. (19.01, 19.02)

Response: The plan does not preclude any of these suggestions. However, any proposal would 

need to go through site-specific National Environmental Policy Act analysis. There is guidance 

for phasing out permits in the plan in the following objective in the “Special Uses” section.

“Phase out permits for isolated cabins and privately owned residences that are not part of 

the recreation residence program by 2028.”

Concern Statement: The Forest Service should implement the national standard for recreational 

residences for cabin residences with special use permits to encourage owners to repair their 

buildings and improve the visual appeal of the area. (19.03)

Response: While the plan provides some guidance for managing recreation residences, 

compliance is generally covered in national policy and is therefore outside the scope of the forest 

plan. However, the plan includes some management guidance in the “Recreation” section, 

guideline 4; “Scenery” section, desired conditions and guideline 2; and “Special Uses” section, 

guideline 1.

Concern Statement: The Forest Service should improve public understanding and support of the 

recreation fee program to comply with the Federal Lands Recreation Enhancement Act. (19.04)

Response: Improving public understanding and support of the recreation fee program is not a 

plan-level decision. This is addressed at the project level on a case-by-case basis.

Concern Statement: The Forest Service should continue to allow use of summer recreation 

residences. (19.05)

Response: The forest plan supports the continued use of recreation residences, which are defined 

as privately owned, noncommercial residences located on National Forest System lands and 

authorized by a recreation residence term special use permit. The forest plan only recommends 

phasing out permits for isolated cabins, privately owned buildings, and residences that are not 

part of the recreation residence program.

Hunting, Shooting (22)

Concern Statement: The Forest Service should permit off-road motor vehicle use to retrieve big 

game where such use does not negatively affect soils or vegetation. (22.01)
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Response: Off-road, motorized, big game retrieval is not a plan-level decision. This concern is 

addressed under the Travel Management Rule in travel management planning.

Concern Statement: The Forest Service should restrict hunting to ensure species are not 

overhunted and to protect public safety. (22.02, 22.03)

Response: Hunting is outside the scope of the forest plan, since it is managed by the Arizona and 

New Mexico Game and Fish Departments. This issue is addressed in the plan in the “Animals and 

Rare Plants” section, desired conditions, and management approaches.

Concern Statement: The Forest Service should restrict recreational shooting in some areas to 

provide safe recreation for other forest users and address the use of inappropriate targets 

(including glass). (22.04, 22.06)

Response: The plan would not preclude restricting recreational shooting in some areas or 

prohibiting inappropriate targets; however, any proposal would need to go through site-specific 

National Environmental Policy Act analysis.

Concern Statement: The Forest Service should prohibit hunting in the East Cochise Stronghold

to provide for the safety of other users. (22.05)

Response: While this is not a plan-level decision, East Cochise Stronghold is currently closed to 

hunting.

Motorized Recreation Management (34)

Concern Statement: The Forest Service should acknowledge that there is little evidence that 

aviation activities are a threat to nesting raptors.

Response: Related statements from the draft plan and draft environmental impact statement have 

been removed from the final plan and final environmental impact statement.

Concern Statement: The Forest Service should add new routes and looping routes, such as 

single track trails and routes that provide a backcountry experience. (34.01, 34.02, 34.07, 34.21,

34.23)

Response: The forest plan addresses this issue in chapter 2, “Motorized Transportation System,”

management approaches, and in “Recreation,” management approaches.

Concern Statement: The Forest Service should add the phrase “motorized single track” to the 

terms semi-primitive nonmotorized and semi-primitive motorized. (34.02, 34.20)

Response: This is not a forest plan-level decision. Adding "motorized single-track" to semiprimitive nonmotorized and semi-primitive motorized is already addressed in Forest Service 

policy.

Concern Statement: The Forest Service should include a standard limiting the use of vehicles to 

below 96 decibels. For all areas not identified for motorized recreation. (34.03)

Response: The forest plan addresses this issue in chapter 2, “Motorized Transportation System,”

through travel management. Areas not identified for motorized recreation have no motorized use.
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Concern Statement: The Forest Service should limit or restrict motorized recreation to protect 

quiet settings, wildlife, cultural resources, and vegetation. (34.05, 34.08, 34.09, 34.10, 34.16, 

34.25, 34.26, 34.27)

Response: These issues are addressed in chapter 2, “Motorized Transportation System,”

“Recreation,” and chapter 3, “Management Areas.”

Concern Statement: The Forest Service should partner with motorized groups to assist in trail 

creation and maintenance. (34.06)

Response: The forest plan addresses this in chapter 2, “Forestwide Management,” “Recreation,”

management approaches.

Concern Statement: The Forest Service should include ongoing maintenance for motorized 

travel management. (34.11, 34.14)

Response: The forest plan addresses this in the “Forestwide Management,” “Motorized 

Transportation System” section.

Concern Statement: The Forest Service should update the motorized recreation direction in the 

plan to address changes in population, behavior, and increased development. (34.12)

Response: The forest plan addresses this in the “Forestwide Management,” “Motorized 

Transportation System,” through the travel management process.

Concern Statement: The Forest Service should ensure that motorized access by special permit 

will be limited to that specific purpose to eliminate the ability to profit from exclusive access to 

the forest in the Galiuro Ecosystem Management Area. (34.13)

Response: Motorized access by special use permit is not a plan-level decision. The special use 

permit will be determined at the project level on a case-by-case basis.

Concern Statement: The Forest Service should proceed with the desired condition related to 

motorized recreation. (34.15)

Response: The forest plan will allow the Forest Service to proceed with the desired conditions 

related to motorized recreation.

Concern Statement: The Forest Service should acknowledge that the plan allows motorized 

vehicles on less than 1 percent of the forest. (34.17)

Response: Motorized recreation opportunities are available in all land use zones, which 

constitutes the majority of the Coronado National Forest (see environmental impact statement, 

table 2). However, off-road travel is prohibited on the majority of the Coronado.

Concern Statement: The Forest Service should consider implementing the National OffHighway Vehicle Conservation Council guidelines. (34.18, 34.19)

Response: The plan would not preclude incorporating national off-highway vehicle guidelines.

This is addressed in the plan in chapter 2, “Forestwide Management,” “Motorized Transportation 

System,” management approaches.
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Concern Statement: The Forest Service should minimize the impacts from motorized recreation

to comply with Executive Order 11644 and to protect special-status species. (34.24)

Response: While the plan provides guidance for managing impacts from motorized recreation, 

compliance with Executive Order 11644 is covered in national policy and is outside of the scope 

of this forest plan decision.

Concern Statement: The Forest Service should require permits for off-highway vehicles, jeeps, 

and other 4x4s to help fund trail repairs. (34.28)

Response: Requiring permits for motorized recreation is not a plan-level decision. The need for 

this will be determined on a case-by-case basis. Currently, the Forest Service collects fees through 

outfitter and guiding permits that can be used to maintain roads and trails. Additionally, the State 

of Arizona currently collects funds for off-highway vehicles, motorcycles, and some jeeps 

(through their off-highway vehicle program), which are dispersed though a grant process to 

maintain trails and roads.

Concern Statement: The Forest Service should control off-road vehicle use in the Redington 

Pass area. (34.29)

Response: Addressing off-road vehicle use in specific areas is not a forest plan-level decision.

Decisions relating to the control of off-road vehicle use are made during travel management 

planning. However, the forest plan designates land use zones for the Santa Catalina Ranger 

District in the Redington Pass area as motorized recreation and roaded backcountry. Non-roaded 

areas are designated as wild backcountry. This can be found in chapter 4, “Geographic Areas,”

“Santa Catalina Ranger District.”

Concern Statement: The Forest Service should revise the Douglas Ranger District map to 

remove indicated access through private property. (34.30)

Response: This is not a plan-level decision. This will be addressed during travel management 

map updates.

Recreational Access (46)

Concern Statement: The Forest Service should design and develop trails that provide visitor 

experiences that are in demand to address the root causes of illegal trail construction. (46)

Response: The existing network of system roads and trails is inevitably based on a legacy 

system. If resources were unlimited, the system could be changed as needed to be the best 

possible system based on any number of criteria. As it currently exists, there are not enough 

resources to maintain the existing system, let alone to construct more system. The existing legal, 

policy and regulatory framework (mostly travel management and the National Environmental 

Policy Act) currently does not allow for the Coronado’s network to be substantially reduced. 

Therefore, only small and focused changes are reasonable options. The forest plan would not 

preclude the creation of new trails and access; however, any proposal would need to go through 

site-specific analysis.

Concern Statement: The Forest Service should do the following for the Arizona National Scenic 

Trail: include a guideline protecting the trail, reconsider the desired conditions to allow for 

needed improvements and allow for construction of needed roads, and include cooperative 

management strategies with State and county agencies. (46.01, 46.02, 46.04, 46.06)
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Response: The forest plan would not preclude the inclusion of these concerns; however, any 

proposal would need to go through site-specific National Environmental Policy Act analysis. As 

stated in chapter 3 under the Arizona National Scenic Trail guidelines, trail protection is offered 

through the management of permitted special uses, placement of new road or motorized trail 

construction, placement of new utility corridors and utility lines, management of forest health 

projects and fire suppression to minimize impacts. Needed improvements are not precluded from 

desired conditions and forest plan allows that, near towns and developed recreation facilities, the 

Arizona Trail may become a more accessible and highly developed route with access to amenities 

via connector trails. 

As stated in “Management Approaches” section, we will work with adjacent landowners and 

agencies to maintain the trail corridor and the condition and natural character of the surrounding 

landscape. Furthermore, the trail will be managed consistent with the 1995 Arizona Trail 

Management Guide until a comprehensive management plan is completed. The 1995 Arizona 

Trail Management Guide includes minimum trail maintenance guidelines and calls for Arizona 

Trail Segment Stewards (volunteers) to work with local land management agencies on trail 

construction and maintenance. When the trail comprehensive management plan is completed, it 

will provide more detailed site-specific guidance for the trail which falls within the framework of 

the forest plan. 

Concern Statement: The Forest Service should retain or expand the existing recreational access

to address increasing usage rates. (46.03)

Response: The plan addresses this topic in chapter 2, “Forestwide Management,” “Public 

Access”.

Concern Statement: The Forest Service should clarify the intent of Public Access guidelines 3 

and 4. (46.05)

Response: Guideline 3 has been edited to add the words “Creation of or continued use” to the 

beginning of the sentence. This will clarify guideline 4. Use of National Forest System lands is 

not exclusive.

Forest Service Manual 2734 states:

“ . . . use, and maintenance of roads, trails, and highways across National Forest System 

lands all require some form of authorization.” 

Forest Service Manual 2730 states that whenever the Forest Service has current need for access 

across the lands of a party who is requesting access across National Forest System lands, the 

receipt of an adequate right-of-way from that party must be a condition of granting an easement.

Forest Service Manual 2730.2 states: 

“Cooperate with intermingled and adjacent landowners in developing roads that serve the 

needs of both parties through the exchange of rights-of-way.”

Forest Service Manual 2733.03 states:

“The permits or easements granted are nonexclusive.”

Concern Statement: The Forest Service should create a new trails (1) to connect the Pallisades 

parking area to the Sunset trail area, (2) from the Butterfly trailhead to the Control Road, (3) to 

connect Crystal Spring and the Control Road to the top of the Control Road, and (4) to connect 

Green Mountain and the top of the initial climb of Bug Spring Trail. (46.07, 46.08, 46.10, 46.12)
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Response: The plan would not preclude the creation of new trails and access; however, any 

proposal would need to go through site-specific National Environmental Policy Act analysis.

Forest Service Manual 5460.3 encourages the acquisition of rights-of-way to National Forest 

System lands. As access opportunities arise, they are worked on a case-by-case basis.

Concern Statement: The Forest Service should provide greater public access to address 

increasing population pressures to the Pinaleño Ecosystem Management Area, the Santa Teresa 

Ecosystem Management Area, and the Winchester Ecosystem Management Area to improve 

opportunities for dispersed recreation. (46.09)

Response: The plan would not preclude providing greater public access in the Pinaleño, Santa 

Teresa, and Winchester Ecosystem Management Areas; however, any proposal would need to go 

through site-specific National Environmental Policy Act analysis. Forest Service Manual 5460.3 

encourages the acquisition of rights-of-way to National Forest System lands. As access 

opportunities arise, they are worked on a case-by-case basis.

Concern Statement: The Forest Service should proceed with the plan as it relates to public 

access to allow legal, motorized access and to prohibit exclusive access by private developments 

and landowners. (46.11)

Response: The plan addresses public access to allow legal motorized access and to prohibit 

exclusive access.

Recreation Management (45)

Concern Statement: The Forest Service should increase the recreation facilities on the Peloncillo 

Management Area to enhance the economic benefit to local communities. (45)

Response: The plan would not preclude increasing recreational opportunities and facilities; 

however, any proposal would need to go through site-specific analysis.

Concern Statement: The Forest Service should analyze impacts from recreation including those 

resulting from increased recreational usage. (45.02)

Response: The environmental impact statement acknowledges population growth and increased 

use of the Coronado National Forest. The 1986 plan lacks specific direction to address increased 

use and associated impacts. The revised plan includes plan components that are responsive to 

recreation trends. The effects of increased recreation are not analyzed as part of the forest plan but 

the environmental impact statement acknowledges the population growth of southern Arizona and 

associated increased recreation use. 

Concern Statement: The Forest Service should emphasize quiet recreation in the plan: because 

these activities do not disturb the ecological balance and support the local economy; because 

solitude is difficult to find; to limit effects of motorized use in Gardiner Canyon; and to be 

consistent with the desire of the majority of the public. (45.03)

Response: The forest plan emphasizes quiet recreation (solitude) in wilderness, wild 

backcountry, and other areas, which comprise most of the national forest. In chapter 2,

“Forestwide Management,” in the “Recreation” section of the plan, a management approach has 

been added to emphasize quiet recreation. In addition, plan components support wildlife habitat 

protection of threatened and endangered species, which reduces noise seasonally. The plan 
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includes a land use zone for motorized recreation, which is intended to concentrate off-highway 

vehicle use.

Concern Statement: The Forest Service should maintain and preserve recreational opportunities 

and the recreation residence program, and ensure that public access is addressed. (45.05, 45.11, 

45.12)

Response: The forest plan supports these concerns. See chapter 2, “Recreation,” “Special Uses,”

and “Public Access.”

Concern Statement: The Forest Service should revise the plan to acknowledge that visitation is 

down at Cave Creek Canyon. (45.06)

Response: Acknowledgement of visitation numbers at Cave Creek Canyon is outside the scope 

of the plan.

Concern Statement: The Forest Service should consider formalizing some user-created trails.

(45.07, 45.08, 45.13)

Response: The plan does not preclude increasing recreational opportunities; however, any 

proposal would need to go through site-specific National Environmental Policy Act analysis.

Concern Statement: The Forest Service should avoid singling out rock climbing as causing 

recreation impacts and should include the impacts of other activities as well because there is no 

evidence to support the assertion that climbing is more impactful than other activities. (45.09)

Response: The plan and environmental impact statement address impacts from multiple 

recreation activities. In the plan, these are primarily found in the “Recreation” and “Motorized 

Transportation” sections. In the environmental impact statement, recreation impacts are primarily 

addressed in chapter 3, “Visitor Experience,” “Recreation,” and “Motorized Activities” sections. 

Guideline 6 in the plan addresses rock climbing:

“Rock climbing should be managed to balance demand for the activity and the need to 

protect plants, animals and other natural resources.” 

We think the growing interest and participation in rock climbing is a positive trend in recreation 

and natural resource stewardship. In our view, this guideline does not limit rock climbing and will 

enhance the rock climbing experience for all.

Concern Statement: The Forest Service should reconsider use of the terms “quiet recreation” 

and “quiet experiences” because they are subjective and reflect a bias against human uses. (45.14)

Response: Through our public scoping process for the plan, we identified five topics for the 

revised plan to address, where changes in management direction were needed. One of those 

topics, “Visitor Experiences,” included a need to address the slow loss of opportunities for quiet 

recreation. According to our public input, quiet recreation is a valued human use of the Coronado 

National Forest. We disagree that using the terms “quiet recreation” and “quiet experiences” 

reflects a bias against human uses.

Concern Statement: The Forest Service should revise descriptions for the Whetstone, Galiuro, 

Santa Teresa, Winchester, and Santa Catalina Ecosystem Management Area desired conditions to 

provide a more balanced description of the recreational settings available. (45.01, 45.04, 45.15, 

45.16)
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Response: Desired conditions for the Whetstone, Galiuro, Santa Teresa, Winchester, and Santa 

Catalina Ecosystem Management Areas reflect the dominant recreational settings that are 

desirable. They are not all-inclusive of the available settings but do reflect the type of access and 

facilities desired in those places.

Other Activities Management (37)

Concern Statement: Within the Mount Graham Astrophysical and Biological Research Area: the 

Forest Service should prohibit timber harvest; and the Forest Service should better define what 

traditional forest products can be harvested and at which level is appropriate. (37)

Response: Table 14 states timber harvest is only allowed in the Mount Graham Astrophysical and 

Biological Research Area for ecosystem restoration. Development of site-specific project 

recommendations for ecosystem restoration that would include removal of woody material would 

undergo review by appropriate resource specialists during the National Environmental Policy Act 

process and is outside the scope of the forest plan.

Concern Statement: The Forest Service should address the how the biomass industry could 

affect national forests and climate change impacts. (37)

Response: At this time, southern Arizona does not have a biomass industry that utilizes product 

from the Coronado National Forest and there is no foreseeable development of that industry. The 

environmental impact statement did disclose effects to forest products of the various alternatives, 

and how climate change may impact the availability of forest products such as fuelwood and saw 

timber. Forest products, especially those derived from wood fiber, would become available as a 

result of ecosystem restoration, habitat improvement, and fuels treatment projects. There is no 

timber resource suitable for commercial harvest on the forest.

Concern Statement: The Forest Service should analyze proposals for infrastructure development

and advocate for the protection of unique features. (37)

Response: This is outside the scope of the forest plan and would be addressed on a site-specific 

case-by-case basis.

Concern Statement: The Forest Service should disclose the impacts of removing rights-of-way 

and utility line corridors. (37)

Response: The final environmental impact statement does not address the potential economic 

impacts and unintended consequences to other entities through the dissuading influence of the 

forest plan on future long-term or permanent encumbrances on some National Forest System

lands. These issues would be addressed at the project level should public benefits outweigh the 

costs of the encumbrances.

Concern Statement: The Forest Service should improve the caves and karsts section by having 

a separate land use designation and/or a separate standalone section because they are a significant 

and complex resource that should be managed more effectively. Part of the cave and karst section 

should reference supplied cave and karst management documents. In particular, Cave Canyon in 

the Huachuca Mountains, Cave Canyon in the Santa Rita Mountains, and Peppersauce Cave 

should be protected because they are fragile resources and Peppersauce Cave is one of the biggest 

vandalism problems on the forest. To mitigate disturbance a 300-foot buffer zone around cave 

entrances should be created. A separate cave and karst management document should be 
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completed for changes not part of the forest plan. (37.02, 37.04, 37.05, 37.06, 37.08, 37.10, 

37.12)

Response: Cave and karst land use designation is not warranted as caves and karst topography fit 

well under biophysical features. We agree a cave and karst management guide is needed and we 

are currently developing one. This type of information is provided in the “Guidelines” section, 

though more detailed prescriptions would be provided for in the cave and karst management plan. 

Additional management guidelines are being developed in coordination with cave and karst 

stakeholders through the cave management plan process. As stated in the standards, caves that 

have been designated or nominated as “significant,” are managed to perpetuate those features, 

characteristics, values, or opportunities for which they were designated.

Concern Statement: On page 54, the Forest Service should revise the text to: (1) replace the 

word “often” with “may” and (2) amend the list of cave resources to include historical and 

archeological deposits, hydrological, and recreation resources. (37.07, 37.11)

Response: Your suggestion has been incorporated into the forest plan on page 54.

Concern Statement: The Forest Service should coordinate with cave and karst experts to ensure 

the plan includes adequate information on cave and karst management. (8.01)

Response: Cave resources are addressed in the forest plan in the “Biophysical Features” section. 

This section includes the following Management Approach: “Engaging caving organizations in 

cave management activities, such as seasonal surveys, closures, and wildlife-friendly gate 

development at specific sites.” The Forest Service also has policy and directives associated with 

cave and karst management (such as Forest Service Manual 2880). In addition, a cave 

management plan has recently been developed in collaboration with local Grottos. The forest plan 

incorporates this plan by reference.

Lands Management

Land Designations and Management (29)

Concern Statement: The Forest Service should discuss the two National Natural Landmark

(NNL) sites. (29)

Response: Thank you for your comment. The forest plan and final environmental impact 

statement have been updated to include descriptions of these two national natural landmark sites.

The plan components for the two geographic areas in which the national natural landmark sites 

are located provide adequate protection for the two landmarks.

Concern Statement: The Forest Service should revise the Galiuro Ecosystem Management Area 

objectives to continue to provide access to the area. (29)

Response: The forest plan would not preclude providing access; however, providing access in 

specific areas is not a forest plan-level decision. Any restrictions or additions to motorized travel 

on the Coronado would be considered during the travel management planning process. Sitespecific travel management planning will use the framework set by the plan (such as desired 

conditions, standards, and guidelines) and will consider potential resource impacts, access needs, 

public input, and alternative views. If issues resulted from open roads, they could be addressed 

through site-specific analysis. 
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In addition, the plan contains standards and guidelines for limiting motorized travel to designated 

roads and trails, and sets the framework for implementing the Travel Management Rule (see the 

“Motorized Transportation System” section, in chapter 2 of the plan).

Concern Statement: The Forest Service should reconsider the designation of the Cave Creek 

Canyon Birds of Prey area to avoid creating unnecessary restrictions on use because the costs and 

benefits of designation have not been fully disclosed. (29)

Response: The final plan and final environmental impact statement explain why the area is being 

proposed and includes the following standards and plan components:

In the South Fork of Cave Creek Zoological-Botanical Area and the proposed Cave 

Creek Canyon Birds of Prey Zoological-Botanical Area: 

• A special use permit is required for any plant or animal collection.

• A special use permit is required for scientific research that would involve 

placing anything on forest lands within the proposed zoological-botanical area.

These standards and plan components should not impact the average citizen visiting the area or 

most residents in the area. 

Concern Statement: The Forest Service should clarify the reason for the increased size of the 

study area for the Cave Creek Canyon Bird of Prey Zoological Botanical Area. (29)

Response: We are not sure which part of the document this concern statement is referencing. The 

size of the Cave Creek Bird of Prey Zoological-Botanical Area was proposed as 26,241 acres in 

the draft plan but is now proposed as 25,764 acres in the final plan. 

Concern Statement: The Forest Service should remove the reference to the Atascosa Lookout in 

the Tumacori Ecosystem Management Area because it has burned down. (29)

Response: The desired conditions for the Tumacacori Ecosysten Management Area have been 

updated in the forest plan to reflect that the Atascosa Lookout is no longer present.

Concern Statement: The Forest Service should clarify the description and location of the 

proposed Canelo Research Natural Area and explain why the area is needed. (29)

Response: The location of the proposed Canelo Research Natural Area was incorrectly identified 

in the draft land and resource management plan. The proposed Canelo Research Natural Area 

would set aside 386 acres of National Forest System lands in the southern portion of the 

Appleton-Whittell Research Ranch not the Elgin Research Ranch. This proposed research natural 

area will be managed to allow for monitoring long-term ecological changes in the absence of 

livestock grazing in an open oak (encinal) woodlands vegetation community.

Concern Statement: The Forest Service should include priority criteria for access within the 

Ecosystem Management Areas to explain how the sequence was determined and what factors 

could cause an adjustment. (29)

Response: Legal public access to any block of National Forest System land requires documented, 

legally supportable right to cross lands owned by one or more entities other than the Forest 

Service. Other than legal condemnation, to obtaining legal access requires other landowners to 

voluntarily cooperate with the Coronado and its partners, such as the Arizona Game and Fish 
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Department. Such cooperation usually involves payment and always involves the willing 

cooperation of the landowner. Successful acquisition of legal access occurs when a willing 

landowner and the agencies involved reach mutual agreement on the terms of the access—

including payment. In most cases, no payment or appraised value can induce an unwilling 

landowner to cooperate. Rather than prioritizing access, we believe working with cooperative 

landowners and cooperating agencies will prove successful.

Concern Statement: In addition to the current proposed special management/interest areas 

which include Finger Rock Canyon Research Natural Area, Cave Creek Canyon Birds of Prey 

Zoological Area, Pole Bridge Research Natural Area, Gooding Research Natural Area and Alder 

Canyon Research Natural Area, the Forest Service should add Agua Caliente Zoological Area, 

Alder Canyon Research Natural Area, Aliso Springs Riparian Preserve, Barfoot Zoological Area, 

Cañada del Oro Headwaters Research Natural Area, Madera Canyon Zoological-Botanical Area, 

Redrock Canyon Management Area, Rosemont Valley Historic Area, Scotia Canyon ZoologicalBotanical Area, and Southern Peloncillo Mountains Zoological-Botanical Area. The Forest 

Service should also include areas proposed by the Coronado Planning Partnership which includes 

the 10 Citizen’s Proposal and those proposed by Sky Island Alliance. Important Bird Areas 

should also be designated as special areas. These designations should occur to protect the areas, 

attract tourism, and attract nonmotorized recreationists. (29.01, 29.07, 29.09, 29.27, 29.43, 29.45)

Response: We are glad you support the proposed designations of research natural areas and 

zoological-botanical areas in the forest plan. Several of these were proposed by the Coronado 

Planning Partnership and Sky Island Alliance. In response to the proposals regarding other 

special areas, the forest plan contains the following guidance:

• The unique values of Alder Canyon are perpetuated (chapter 4, “Santa Catalina Ecosystem 

Management Area,” desired conditions).

• Aliso Springs provides habitat for native aquatic species.

• The wildlife and vegetation species in the area surrounding Barfoot Park are perpetuated 

(chapter 4, “Chiricahua Ecosystem Management Area,” desired conditions).

• Wilderness areas within Madera Canyon shall be managed at the highest possible scenic 

integrity level, with a level of very high (chapter 4, “Santa Rita Ecosystem Management 

Area,” standard). 

• Perennial streams, including Bear Canyon, Scotia Canyon, and Red Rock Canyon, provide 

year-round habitat for aquatic species. These streams generally have at least permanent pools 

of water, even when continuous flows cease during the driest seasons (chapter 4, “Huachuca 

Ecosystem Management Area,” desired conditions).

• Species that have historically moved freely between habitat in Mexico and within the 

Peloncillo Ecosystem Management Area continue to do so (chapter 4, “Peloncillo Ecosystem 

Management Area,” desired conditions).

• Management activities involving ground disturbance, vegetation management, or both should 

incorporate site-specific design features to benefit habitat for, or mitigate impacts to, rare or 

unique vertebrate, invertebrate and plant populations. For the Peloncillo Ecosystem 

Management Area, these species include, but are not limited to, Chiricahua mudwort, Copper 

mine milk-vetch, New Mexico bitterweed (chapter 4, “Peloncillo Ecosystem Management 

Area,” desired conditions).
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It should be noted that, as shown in the map of the Peloncillo Ecosystem Management Area in 

chapter 4, much of the southern Peloncillo Mountains already have special designations; the Bunk 

Robinson Wilderness Study Area will be managed to preserve wilderness character (chapter 3, 

Management Areas, Recommended Wilderness Areas and Wilderness Study Areas) and the 

Guadalupe Canyon Zoological-Botanical Area will be managed to perpetuate the unique 

resources that led its designation (chapter 4, Peloncillo Ecosystem Management Area). 

Further, the Forest Service has submitted applications for instream flow water rights in Red Rock 

Canyon and Scotia Canyon. Obtaining these rights will be paramount in sustaining the unique 

resources in those canyons.

For the rest of the areas, we agree they all have unique characteristics that should be perpetuated. 

We believe the forest plan provides management direction that will sustain those characteristics 

and determined that additional designation was not needed.

Concern Statement: The Forest Service should expand the Elgin Research Natural Area to 

include the portion within the Appleton-Whittell Research Ranch. (29.04)

Response: Desired conditions for the Elgin Research Natural Area and the Appleton-Whittell 

Research Ranch are found in the forest plan in chapter 4, “Geographic Areas,” “Huachuca 

Ecosystem Management Area.” They are managed in concert with each other. Each provides 

unique opportunities for researching grasslands. We believe the areas are complementary, and 

there would be no benefit to combining them into one research natural area.

Concern Statement: The Forest Service should protect wild and scenic rivers from the effects of 

mineral extraction. (29.08)

Response: The Coronado National Forest has eligible wild and scenic rivers, which are not 

currently withdrawn from mineral entry. The Forest Service direction for withdrawals is outlined 

in Forest Service Manual 2760. Generally, a withdrawal is a management tool for withholding an 

area of National Forest System land from settlement, sale, location, or entry under some or all of 

the general land laws, including the mining and mineral leasing law, for the purposes of limiting 

activities under those laws in order to maintain other public values in the area, or reserving the 

area for a particular public purpose or program. These programs and purposes may include 

quality of scientific, scenic, historical, ecological, environmental, air, water resource, 

archaeological values, or other special purposes. Before recommending an administrative 

withdrawal for a certain area, the Forest Service must comply with the requirements under 43 

CFR 2310.1-2 for consideration of alternative protection opportunities such as a right-of-way 

under section 507 of the regulation (43 U.S.C. 1767) or a cooperative agreement under sections 

302(b) (43 U.S.C. 1732(b)) and 307(b) (43 U.S.C. 1737(b)) of the regulation, or other protection 

methods. These requirements are restated in the forest plan as guidelines under chapter 2 in the 

“Land Ownership Adjustments and Boundary Management” section. There are currently no 

designated wild and scenic rivers.

Concern Statement: The Forest Service should avoid reducing the size of the existing Santa 

Catalina Research Natural Area. (29.25)

Response: The proposed reduction is carried forward from the 1986 plan. The reduction was 

proposed to eliminate areas that were heavily used as dispersed camping areas, which is an 

incompatible use in a research natural area. In addition, the boundary of the Santa Catalina 
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Research Natural Area was assessed as part of the research natural area assessment for the 

Coronado National Forest. This assessment supported the area proposed in the 1986 plan.

Concern Statement: The Forest Service should plan management of the zoological-botanical 

areas using a team of local research, business, and recreation interests. (29.26)

Response: The forest plan supports collaboration of all sorts and does not preclude collaboration 

in management of zoological botanical areas. 

Concern Statement: The Forest Service should acknowledge that the Cave Creek ZoologicalBotanical Area Fact Sheet may be misleading. (29.34)

Response: We did not generate a fact sheet associated with the Cave Creek Zoological-Botanical 

Area, and are not responsible for its content.

Concern Statement: The Forest Service should reword the first sentence of the wild 

backcountry general description to broaden the character and scope of the definition to ensure the 

public understands these areas are not managed as wilderness. In particular the first sentence 

should state: “The wild backcountry land use zone is managed . . . to support a range of primitive 

and semi-primitive recreational settings” and the description should include the following: “This 

land use zone is managed for primarily for a range of nonmotorized uses and motorized 

backcountry access. It includes Inventoried Roadless Areas, areas adjacent to Wilderness areas, 

other relatively primitive areas, and motorized access roads. This zone offers recreational 

opportunities in the primitive to semi-primitive recreation opportunity spectrum. It makes up 

628,500 acres, or about 35 percent of the Coronado National Forest.” (29.22, 29.24, 29.28)

Response: We determined the proposed wording was not substantially different and the existing 

wording is more concise. Therefore, no changes were made between the draft and final versions 

of the revised plan.

Concern Statement: Wild backcountry should be an extension of wilderness and motorized uses 

should be prohibited. In addition, the Forest Service should proceed with the designation of the 

Dragoon Ecosystem Management Area because resources will be protected from off-road 

motorized travel. (29.33, 29.40, 29.46, 29.52)

Response: The Wild Backcountry Land Use Zone is, for the most part, adjacent to wilderness 

areas. It allows existing roads to remain, and new roads are only allowed if they replace lost 

access. By allowing these roads to remain, wilderness areas are more accessible. Therefore, we 

believe allowing motorized uses in wild backcountry zone provides experiences that are different

from, but complementary to, wilderness. The Dragoon Potential Wilderness Area was considered 

in the environmental impact statement under alternative 1. It was not recommended for 

wilderness designation.

Concern Statement: The Forest Service should re-designate some roads as motorized increasing 

roaded access into the Wild Backcountry zone within all geographical areas and should explain 

how this designation influences travel management NEPA. (29.06, 29.13, 29.30) 

Response: The road designation is not a forest plan decision. However, travel management 

decisions are guided by the forest plan, including plan components for the Wild Backcountry 

Land Use Zone. The effects of designation of land use zones to various resources are disclosed in 
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107

chapter 3 of the environmental impact statement. All decisions for travel management are 

required to be consistent with the forest plan.

Concern Statement: The Forest Service should revise the description of roaded backcountry as 

the description is too narrow. It should be broadened to reflect that remote areas offer a range of 

semi-primitive recreational settings (both motorized and nonmotorized) where visitors can car 

camp, hike, hunt, and explore the forest and where there is a moderate probability of experiencing 

solitude. In the first sentence under “General Description” and in the second sentence under 

“Desired Conditions,” we recommend the term “quiet recreation” be deleted and replaced by 

standard terminology from the recreation opportunity spectrum. In addition, how will an 

emphasis on quiet recreation in roaded backcountry affect travel management? (29.03, 29.21, 

29.35)

Response: We determined the proposed wording was not substantially different and the existing 

wording is more concise. Therefore, no changes were made between the draft and final versions 

of the revised plan.

The forest plan provides guidance for quiet recreation in the form of desired conditions for 

wilderness and Wild Backcountry and Roaded Backcountry Land Use Zones. Decisions for 

decommissioning roads are not made in the forest plan but at a project level through the travel 

management process. The travel management process provides analysis of roads proposed to be 

decommissioned from the existing motorized transportation system for many reasons, including 

providing opportunities for quiet recreation. 

Concern Statement: The Forest Service should reconsider merging the designation of the 

Mount Graham Biological Research Area and the Mount Graham Astrophysical Site because 

these areas have different purposes and the uses are incompatible. (29.18, 29.29) 

Response: The Mount Graham Astrophysical and Biological Research Area was designated in 

1989 by the Arizona-Idaho Conservation Act; the area encompasses 2,881 acres. Modifying the 

direction of the act is outside of the scope of the plan.

Concern Statement: The Forest Service should ensure that public access [vehicular] is 

maintained into all the ecosystem management areas including wilderness for holders of property 

rights and those with transportation easements within these areas. (29.12, 29.17, 29.19, 29.32)

Response: The forest plan supports motorized access to all ecosystem management areas.

Management direction for access is found in chapter 3 of the forest plan. Motorized access into 

designated wilderness is prohibited by the Wilderness Act. Decisions to close or restrict access on 

specific roads were made during travel management planning. As part of that process, we

identified the road system needed for safe and efficient travel and for administration, utilization, 

and protection of National Forest System lands. Roads needed for transportation easements and 

holders of property rights were identified during that process. Roads not designated for motor 

vehicle use or displayed on the motor vehicle use map that are authorized by permitted use will 

be available to permittees under the terms of their permits.

Concern Statement: The Forest Service should rework the desired conditions for each 

ecosystem management area as the draft desired conditions give an unbalanced view of 

recreational use: [they] over-emphasizes nonmotorized (quiet) recreation while generally 

avoiding any mention of motorized access/recreation. (29.38)
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Response: We disagree that the ecosystem management area desired conditions give an 

unbalanced view of recreation use. Through our public scoping process for the plan, we identified 

five topics for the revised plan to address, where changes in management direction were needed. 

One of those topics, “Visitor Experiences,” specifically included a need to (1) address the slow 

loss of opportunities for quiet recreation, (2) provide overall guidance for motorized use the 

Travel Management Rule will reflect, and (3) address general suitability of motorized uses in 

different areas of the Coronado National Forest. 

The plan addresses these concerns in the ecosystem management area desired condition 

statements by providing guidance for (1) a full spectrum of recreation activities and for (2) 

adequate legal road access (see chapter 4, “Ecosystem Management Areas,” desired conditions). 

Another of the five topics, “Access to National Forest System Lands,” recognizes the need for 

legal rights-of-way for many areas of the national forest, primarily for roads available for 

motorized use. The plan addresses this concern by identifying and prioritizing public access 

needs, including motorized access. Forestwide, there are desired conditions for arterial, collector 

and local roads; and for a motorized transportation system that is environmentally sustainable and 

meets public needs and desires. There is also an objective for increasing the number of permanent 

legal access routes, and objectives for maintaining 350 miles of roads every year (see chapter 2, 

“Forestwide Management,” “Motorized Transportation System,” and “Public Access” sections).

Concern Statement: The Forest Service should continue to manage the Chiricahua Ecosystem 

Management Area to protect the natural character of the landscape and acknowledge that the 

National Audubon Society has designated this area as an Important Bird Area. Additionally, the 

Peloncillo Ecosystem Management Area should continue to be managed for livestock grazing and 

dispersed recreation. (29.49, 29.50, 29.51) 

Response: The forest plan supports continuing to manage the Chiricahua and Peloncillo 

Ecosystem Management Areas to protect the natural character of the landscape and the unique 

resources they contain. We have added an acknowledgement of the National Audubon Society 

important birding area designation to the description section of the Chiricahua Ecosystem 

Management Area. The forest plan supports this designation with the establishment of the Cave 

Creek Birds of Prey Zoological-Botanical Area. The forest plan also supports a continuation of 

livestock grazing and dispersed recreation in the Peloncillo Ecosystem Management Area.

Concern Statement: The Forest Service should ensure that designations are made in accordance 

with the spirit and direction of the acts/regulations that created them and ensure they (the 

designations) are reproducible by scientific data to avoid single purpose or non-use which may 

negatively impact Arizona Game and Fish Department wildlife management, the local economy, 

lifestyles, cultures, and/or heritage. (29.11, 29.37, 29.39)

Response: We understand your concern that special areas should not be designated for a single 

purpose or in a way that would negatively impact Arizona Game and Fish Department wildlife 

management, the local economy, lifestyles, cultures, or heritage. The forest plan proposes three 

types of management areas (designations): special areas, land use zones, and ecosystem 

management areas (geographic areas). Special areas are established at a national level through 

legislation (such as wilderness) or at a regional or local level through administrative action. Land 

use zones are defined by the types of uses and desired settings that would occur in them and 

ecosystem management areas are defined geographically to include one or more mountain ranges. 

Management areas are further described under the forest plan decisions section of chapter 1. 
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Special areas and management areas (designations) are components of the forest plan but are not 

plan decisions. 

All lands in the Coronado National Forest are managed for multiple uses under the Multiple UseSustained Yield Act, and they will not be managed for a single purpose. While there may be 

restrictions on some uses in some management areas, such as wilderness, opportunities for those 

uses will continue to exist outside wilderness. In our analysis of the forest plan, no negative 

effects of lands designations in the forest plan to wildlife management, local economies, 

lifestyles, cultures, or heritage were found, as disclosed in chapters 2 and 3 of the environmental 

impact statement. Chapter 5 of the forest plan discusses suitability for land uses where suitability 

is defined as the appropriateness of applying certain resource management practices (uses) to a 

particular area of land. Table 14 of chapter 5 identifies activities that may be allowed on 

Coronado National Forest and is not inclusive of all activities that may be considered. The 

identification of an area as suitable for various uses is guidance for project and activity decision 

making and is not a resource commitment or final decision; these would be made at the project 

level. Suitability is determined based on our team process done in accordance with the forest 

service manual and Southwestern Region guidance paper.

Land Ownership, Uses (30)

Concern Statement: The Forest Service should convey grazing lands along its boundaries to 

private ownership to preserve open space. (30.01)

Response: This is outside the scope of the forest plan. There are no Federal authorities allowing 

transfer of National Forest System lands to private ownership to preserve open space. National 

Forest System lands are, by nature, open spaces, and transfer to private ownership would not 

improve open spaces nor guarantee open space in perpetuity.

Concern Statement: The Forest Service should revise the Douglas Ranger District map to 

remove indicated access through private property. (30.02)

Response: This is outside the scope of the forest plan. Routes shown on the Coronado’s

recreation maps do not indicate legal access. They show the locations of the roads on the ground.

As private land ownership changes, access through those lands may also change.

Concern Statement: The Forest Service should acknowledge that the State and Federal 

Governments hold a sufficient amount of land to protect public interest. (30.03)

Response: This is beyond the scope of the forest plan. This forest plan only deals with the 

management of the National Forest System lands in the Coronado National Forest.

Concern Statement: The Forest Service should acknowledge that private property owners have 

the right to dispose of or exchange their property as they see fit within applicable law. (30.04)

Response: This is beyond the scope of the forest plan. The Forest Service has no control over 

private lands.

Concern Statement: The Forest Service should object to development along the forest boundary

because these areas pose significant fire management challenges. (30.05)

Response: This is beyond the scope of the forest plan. The Forest Service has no control over 

development of private lands adjacent to its boundaries. The Forest Service provides comments to 
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county and city entities on private land development proposals whenever possible, to address 

access and fire prevention and suppression issues.

Concern Statement: The Forest Service should revise the standards for the Mount Graham Red 

Squirrel Refugium to ensure that the Mount Graham Observatory will not be expanded. (30.06)

Response: The permit to the University of Arizona for the Mount Graham International 

Observatory only allows use of 8.6 acres. 

Concern Statement: The Forest Service should move forward with the acquisition of the land 

between the Galiuro Ecosystem Management Area and the Winchester Ecosystem Management 

Area. (30.07)

Response: This is beyond the scope of the forest plan. The Forest Service can only act upon 

specific land acquisition proposals through the General Land Exchange Act or through another 

act of Congress.

Concern Statement: The Forest Service should acquire adjacent or proximate non-Federal lands

to enhance public access to the forest. (30.08)

Response: This is beyond the scope of the forest plan. The Forest Service can't acquire lands 

outside of the congressionally designated national forest boundary. Each national forest may 

purchase lands from willing sellers when funds are available from the Land and Water 

Conservation Fund, which are competed for by all national forests. The Forest Service works with 

the Arizona Game and Fish Department to purchase access routes into National Forest System

lands to enhance public access to the national forest.

Concern Statement: The Forest Service should reconsider the Mount Graham International 

Observatory special use permit: to ensure that Native American sacred sites are adequately 

protected; because it is a poor place for astronomy; because the permit has been expired for 

nearly four years; because the only way to mitigate the effects of the observatory is to remove it; 

and to identify and analyze the biophysical and socio-cultural effects from observatory 

operations. (30.09)

Response: The permit to the University of Arizona for the Mount Graham International 

Observatory was issued on January 29, 2015. The effects of the Mount Graham International 

Observatory permit on traditional cultural properties and Native American sacred sites have been 

taken into account. The Mount Graham International Observatory was authorized by an act of 

Congress and cannot be removed by any action in this forest plan.

Concern Statement: The Forest Service should acknowledge the interest the Apache Tribe has 

in the lands in the Coronado National Forest. (30.10)

Response: We acknowledge the interest many tribes, including several Apache tribes, have in the 

management of the Coronado National Forest and provide opportunities for these tribes to 

comment on many projects occurring on National Forest System lands.

Concern Statement: The Forest Service should clarify the ownership and boundaries of Forest 

Service land managed by Audubon as the Appleton Whittell Research Ranch. (30.11)
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Response: This is beyond the scope of the forest plan. Ownership of National Forest System

lands used by the Appleton Whittell Research Ranch is vested in the United States. The boundary 

of Federal lands has been surveyed and monumented.

Concern Statement: The Forest Service should ensure that any affected district within the 

County will be compensated for any net loss of private lands with public lands of equal value.

(30.12)

Response: Land exchanges or any kind of land acquisition are outside of the scope of the forest 

plan.

Designated Wilderness Areas (11)

Concern Statement: The Forest Service should note the potential protective value of wilderness 

management to archaeological sites where archaeological values are considered in Potential 

Wilderness Area assessments. (11)

Response: The potential wilderness capability evaluation considered several basic characteristics 

that make an area appropriate and valuable for wilderness designation. The characteristics 

evaluated in this process include naturalness, undeveloped, opportunities for solitude, special 

values, and manageability. In the Potential Wilderness Area Evaluation Report, historic and 

prehistoric archeological sites were noted in the “Special Features” section for individual areas 

that contain these values. The presence of these archaeological values contributed to the 

capability rating for each area. A similar discussion of the benefits and potential protective value 

of wilderness can be found in the “Cultural Resources” section of chapter 3 in the final

environmental impact statement. 

Concern Statement: The Forest Service should reconsider the rating criteria for Potential 

Wilderness Areas because they seem artificially contrived and are too broad. The Forest Service 

should redo or delete the Wilderness Need Evaluation because it is seriously flawed. (11)

Response: Consistent with agency policy, the Forest Service completed an assessment of areas 

that meet the criteria for potential wilderness through the wilderness evaluation process. Forest 

Service policy and planning direction is found in the Forest Service Manual 1920 and Forest 

Service Handbook 1909.12. Forest Service Handbook 1909.12, chapter 70 (January 2007) is the 

policy direction that guides the wilderness evaluations.

This process consists of three steps: identification of potential areas, evaluation of potential areas, 

and recommendation of potential areas. The Coronado National Forest lands were thoroughly 

analyzed to determine which areas met the criteria for identification of potential wilderness; these 

criteria can be found in Forest Service Handbook 1909.12, chapter 71 and in chapter 1 of the 

Potential Wilderness Area Evaluation Report. 

The potential wilderness capability evaluation considered several basic characteristics that make 

an area appropriate and valuable for wilderness designation. The characteristics evaluated in this 

process include naturalness, undeveloped, opportunities for solitude, special values, and 

manageability. 

Potential wilderness areas were also evaluated for availability to consider the potential impact of 

wilderness designation on both current and future land uses and activities. Land uses and 

activities considered include recreation and tourism; wildlife species, population, and 
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management needs; water availability and use; livestock operations; timber; minerals; cultural 

resources; authorized and potential uses; and management considerations including fire, insects, 

disease, and presence of lands of other ownership. 

Lastly, potential wilderness areas were evaluated to determine the need for an area to be 

designated as wilderness. This analysis considered the degree to which the area contributes to the 

overall National Wilderness Preservation System. Need was analyzed on a regional basis and 

evaluated such factors as wilderness lands in the vicinity, visitor pressure, non-wilderness lands in 

the vicinity, primitive sanctuary for plants and wildlife, capacity of established wilderness areas, 

and wilderness areas with similar landforms and vegetation (Forest Service Handbook 1909.12,

chapter 72.3). 

The complete methodology and results of the wilderness evaluation process, including rationale

for why certain areas were or were not recommended, are documented in the Potential Wilderness 

Area Evaluation Report and Wilderness Need Evaluation Report (Forest Service 2012b), 

available in the plan set of documents and on the Coronado National Forest’s website at 

http://www.fs.usda.gov/detail/coronado/landmanagement/planning/?cid=fswdev7_018702.

Concern Statement: The Forest Service should reconsider designating the Mt. Fagan area as 

Wilderness because the descriptions of drug trafficking in the area are incorrect. (11)

Response: Consistent with agency policy, the Forest Service completed an assessment of areas 

that meet the criteria for potential wilderness through the wilderness evaluation process. Forest 

Service policy and planning direction is found in the Forest Service Manual 1920 and Forest 

Service Handbook 1909.12. Forest Service Handbook 1909.12, chapter 70 (January 2007) is the 

policy direction that guides the wilderness evaluations.

This process consists of three steps: identification of potential areas, evaluation of potential areas, 

and recommendation of potential areas. The Coronado National Forest lands were thoroughly 

analyzed to determine which areas met the criteria for identification of potential wilderness; these 

criteria can be found in Forest Service Handbook 1909.12, chapter 71 and also in chapter 1 of the 

Potential Wilderness Area Evaluation Report. 

Potential wilderness areas, including Mount Fagan, were evaluated by local Forest Service 

employees with direct knowledge of these areas. Ongoing illegal activity has been documented 

and confirmed by Forest Service personnel and U.S. Border Patrol agents who regularly patrol the 

Mount Fagan area. 

Concern Statement: The Forest Service should reconsider additional Wilderness Areas because 

mountain biking is not allowed in Wilderness Areas and because of the increased restrictions on 

motorized use and motorized tools. Wilderness designation is not always an appropriate, 

effective, efficient, economic, or wise use of land. (11)

Response: Consistent with agency policy, the Forest Service completed an assessment of areas 

that meet the criteria for potential wilderness through the wilderness evaluation process. Forest 

Service policy and planning direction is found in the Forest Service Manual 1920 and Forest 

Service Handbook 1909.12. Forest Service Handbook 1909.12, chapter 70 (January 2007) is the 

policy direction that guides the wilderness evaluations.

In the availability analysis of the potential wilderness area evaluation, the Forest Service analyzed 

the potential impacts of wilderness designation on both current and future land uses and activities. 
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Recreation (motorized and nonmotorized) was included in this evaluation of other land uses and 

activities. Potential wilderness areas received an availability rating that compared the value and 

need for wilderness to the value and need for other land uses, including mountain biking. These 

ratings can be found in appendix F of the Potential Wilderness Area Evaluation Report

(http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5440345.pdf). 

The effects of managing to preserve wilderness characteristics are analyzed in the environmental 

impact statement, under alternative 1. The complete methodology and results of the wilderness 

evaluation process, including rationale for why certain areas were or were not recommended, are 

documented in the Potential Wilderness Area Evaluation Report and Wilderness Need Evaluation

Report (Forest Service 2012b), available in the plan set of documents and on the Coronado 

National Forest’s website at 

http://www.fs.usda.gov/detail/coronado/landmanagement/planning/?cid=fswdev7_018702.

Concern Statement: The Forest Service should exclude the Ku Chish and Mt. Graham areas 

from Wilderness designation to allow for mountain biking access and to avoid restricting the 

ability to conduct projects to improve forest health, watershed, and riparian areas. (11)

Response: Consistent with agency policy, the Forest Service completed an assessment of areas 

that meet the criteria for potential wilderness through the wilderness evaluation process. Forest 

Service policy and planning direction is found in the Forest Service Manual 1920 and Forest 

Service Handbook 1909.12. Forest Service Handbook 1909.12, chapter 70 (January 2007) is the 

policy direction that guided the wilderness evaluations.

In the availability analysis of the potential wilderness area evaluation, the Forest Service analyzed 

the potential impacts of wilderness designation on both current and future land uses and activities. 

Recreation (motorized and nonmotorized) and management activities (e.g. fire, fuels, wildlife, 

vegetation, timber) were included in this evaluation of other land uses and activities. Potential 

wilderness areas received an availability rating that compared the value and need for wilderness 

to the value and need for other land uses, including mountain biking. The ratings for Ku Chish 

and Mt. Graham can be found in appendix F of the Potential Wilderness Area Evaluation report 

(http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5440345.pdf).

Project-specific analyses are conducted for all projects planned on the Coronado National Forest, 

including projects to improve forest health, watersheds, and riparian areas. Any projects proposed 

in wilderness will be analyzed for potential impacts to wilderness character and values. The 

effects of managing to preserve wilderness characteristics are analyzed in the environmental 

impact statement, under alternative 1.

The recommendation of new wilderness areas will influence the type of tool used to conduct sitespecific projects in the Ku Chish and Mt. Graham areas. The “Wilderness and Other Special 

Areas – Environmental Consequences” section of chapter 3 in the environmental impact 

statement describes the effects of wilderness recommendation on activities that traditionally 

involve motorized or mechanized equipment.

The forest plan makes wilderness recommendations; only Congress can designate a wilderness 

area. The plan provides guidance to maintain the wilderness characteristics of these areas until 

Congress takes action.
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Concern Statement: The Forest Service should explain the GIS criteria used in mapping 

Potential Wilderness Area boundaries and should remove "sights and sounds" arguments from 

Potential Wilderness Area evaluations. (11)

Response: Consistent with agency policy, the Forest Service completed an assessment of areas 

that meet the criteria for potential wilderness through the wilderness evaluation process. Forest 

Service policy and planning direction is found in the Forest Service Manual 1920 and Forest 

Service Handbook 1909.12. Forest Service Handbook 1909.12, chapter 70 (January 2007) is the 

policy direction that guides the wilderness evaluations.

Initial boundaries for potential wilderness areas were generated through a GIS exercise. The 

majority of boundary lines were drawn to follow natural features, such as ridgelines and high 

points, in the surrounding mountain ranges. In areas where no prominent features could be 

identified, boundaries follow the Coronado National Forest boundary. A portion of boundaries 

also follow existing roads and trails. The boundaries generated using GIS were then adjusted 

using local knowledge to remove conflicts and to make the boundaries more easily locatable on 

the ground.

The potential wilderness capability evaluation considered several basic characteristics that make 

an area appropriate and valuable for wilderness designation. The characteristics evaluated in this 

process include the following: natural, undeveloped, outstanding opportunities for solitude or 

primitive and unconfined recreation, special features and values, and manageability. The criteria 

for rating naturalness requires an evaluation of the “quality of night-sky as affected by light 

pollution.” The criteria for rating solitude requires an evaluation of the “opportunity to experience 

solitude and isolation from human activities while recreating in the area.” The impact of “sights 

and sounds” were considered as a component of these required criteria.

Concern Statement: The Forest Service should ensure that the following areas are preserved as 

Wilderness: the Whetstone Mountains; Cochise Head (Ku Chish); Cochise Stronghold (Dragoon 

Mountains); Tumacacori Highlands; Mount Graham ;Whitmire Canyon; Bunk Robinson; Mount

Graham addition; Mount Wrightson addition; Chiricahua additions; Pajarita additions; Galiuro 

addition; Santa Teresa additions; Deer Creek; Skeleton Canyon; and Devil's Kitchen. (11.03, 

11.07, 11.12, 11.16, 11.18, 11.21, 11.23, 11.33, 11.34, 11.35, 11.38, 11.40, 11.41, 11.46, 11.49)

Response: Consistent with agency policy, the Forest Service completed an assessment of areas 

that meet the criteria for potential wilderness through the wilderness evaluation process. Forest 

Service policy and planning direction is found in the Forest Service Manual 1920 and Forest 

Service Handbook 1909.12. Forest Service Handbook 1909.12, chapter 70 (January 2007) is the 

policy direction that guided the wilderness evaluation at the time it was conducted.

The areas listed in the concern statement above were analyzed in the Potential Wilderness Area 

Evaluation Report. Further analysis on the Whetstone, Ku Chish, Dragoon, Tumacacori, Mt. 

Graham, Whitmire Canyon, Bunk Robinson, Mount Graham Addition, Mount Wrightson 

Addition, Chiricahua Additions, Galiuro Addition, and Santa Teresa additions can be found in 

chapter 3 of the environmental impact statement, under the proposed action and alternative 1.

The potential wilderness area evaluation process consists of three steps: identification of potential 

areas, evaluation of potential areas, and recommendation of potential areas. The Coronado 

National Forest lands were thoroughly analyzed to determine which areas met the criteria for 
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identification of potential wilderness; these criteria can be found in Forest Service Handbook

1909.12, chapter 71 and also in chapter 1 of the “Potential Wilderness Area Evaluation Report.” 

The potential wilderness capability evaluation considered several basic characteristics that make 

an area appropriate and valuable for wilderness designation. The characteristics evaluated in this 

process are naturalness, undeveloped, opportunities for solitude, special values, and 

manageability. 

Potential wilderness areas were also evaluated for availability to consider the potential impact of 

wilderness designation on both current and future land uses and activities. Land uses and 

activities considered include recreation and tourism; wildlife species, population, and 

management needs; water availability and use; livestock operations; timber; minerals; cultural 

resources; authorized and potential uses; and management considerations including fire, insects, 

disease, and presence of lands of other ownership. 

Potential wilderness areas were evaluated to determine the need for an area to be designated as 

wilderness. This analysis considered the degree to which the area contributes to the overall 

National Wilderness Preservation System. Need was analyzed on a regional basis and evaluated 

such factors as wilderness lands in the vicinity, visitor pressure, nonwilderness lands in the 

vicinity, primitive sanctuary for plants and wildlife, capacity of established wilderness areas, and 

wilderness areas with similar landforms and vegetation (2007 Forest Service Handbook 1909.12 

chapter 72.3,). 

The complete methodology and results of the wilderness evaluation process, including rationales 

for why certain areas were or were not recommended, are documented in the Potential Wilderness 

Area Evaluation Report and Wilderness Need Evaluation Report (USDA Forest Service 2012b), 

available in the plan set of documents and on the Coronado National Forest’s website at 

http://www.fs.usda.gov/detail/coronado/landmanagement/planning/?cid=fswdev7_018702.

Concern Statement: The Forest Service should clarify the management direction for existing 

designated wilderness areas. (11.01, 11.14, 11.25)

Response: Management direction for wilderness areas can be found in chapter 3 of the plan 

within the “Plan Components for All Designated Wilderness Areas” section. More specific 

guidance can be found in chapter 3 of the forest plan in the “Individual Wilderness Area 

Direction” section. In addition to direction found in the forest plan, the Forest Service has 

developed individual management plans to guide the management of each wilderness area on the 

Coronado National Forest. These documents are available on the Coronado National Forest’s 

website at http://www.fs.usda.gov/main/coronado/home. 

Concern Statement: The Forest Service should ensure that guidelines regarding construction, 

insect and disease control, vegetation management, structures and prohibitions of use are 

consistent with the Wilderness Act and the wilderness characteristics described within this 

legislation. (11.05, 11.08, 11.09, 11.10, 11.24, 11.30, 11.45)

Response: The forest plan provides guidance to manage wilderness consistent with law and 

policy. Wilderness is managed according to the Wilderness Act of 1964 and Forest Service 

Manual 2300 chapter 2320 - Wilderness Management. Section 2(c) of the Wilderness Act 

provides the definition of wilderness, and Section 4(c) of the act specifically addresses prohibited 

uses in designated wilderness. Forest plan guidelines, including those that address construction, 

insect and disease control, vegetation management, structures, and prohibitions of use, were 
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developed to be consistent with these applicable laws and policies. The desired conditions and 

associated plan components were not modified.

Concern Statement: The Forest Service should clarify how wilderness designation would affect 

public access to the wilderness boundary. (11.13, 11.42)

Response: Public access to wilderness areas is unchanged by wilderness designation. Wilderness 

is managed according to the Wilderness Act of 1964 and Forest Service Manual 2300 chapter

2320 - Wilderness Management. Section 4(c) of the Wilderness Act specifically prohibits the use 

of motorized and mechanized equipment within wilderness areas.

Concern Statement: The Forest Service should reconsider trails management in designated 

wilderness areas to address soil erosion, primitive conditions, and new trail construction. (11.06, 

11.32, 11.43)

Response: Plan components that address trails management in designated wilderness areas can 

be found in chapter 3 of the plan in the “Plan Components for All Designated Wilderness Areas”

section. Under the “Trails and Signage in Wilderness” and “Soil and Water in Wilderness”

sections, guidelines state that new trail construction should only be considered if the objective is 

to enhance wilderness character. Site conditions for specific trails projects and maintenance will 

be analyzed at the site-specific, project level.

Concern Statement: The Forest Service should explain why cameras and remote sensing 

equipment should be avoided in wilderness. (11.04)

Response: The guidelines referencing “Research in Wilderness” can be found in the “Plan 

Components for All Designated Wilderness Areas” section in chapter 3 of the forest plan. Based 

on the long-term benefits produced from research efforts in wilderness areas, the guideline has 

been modified to state: 

“Installations, such as cameras and remote sensing equipment, should not detract from 

wilderness character and should be considered under the special use permitting process 

associated with research.”

Concern Statement: The Forest Service should explain the effect of wilderness expansion on 

use of mechanized equipment to maintain pre-existing water rights. (11.17)

Response: Consistent with agency policy, the Forest Service completed an assessment of areas 

that meet the criteria for potential wilderness through the wilderness evaluation process. Forest 

Service policy and planning direction is found in the Forest Service Manual 1920 and Forest 

Service Handbook 1909.12. Forest Service Handbook 1909.12, chapter 70 (January 2007) is the 

policy direction that guided the wilderness evaluations. 

The expansion of existing wilderness or addition of new wilderness areas will influence the type 

of tool used to maintain pre-existing water rights. The “Wilderness and Other Special Areas –

Environmental Consequences” section of chapter 3 in the environmental impact statement 

describes the effects of wilderness recommendation on activities that traditionally involve 

motorized or mechanized equipment.

Wilderness is managed according to the Wilderness Act of 1964 and Forest Service Manual 2300 

chapter 2320 - Wilderness Management. Section 4(c) of the Wilderness Act specifically prohibits 

the use of mechanized equipment in wilderness “except as necessary to meet minimum 
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requirements for the administration of the area for the purpose of this Act.” Specific proposed 

actions would be considered on a case-by-case basis with use of the “Minimum Requirements 

Decision Guide” (USDA and USDOI 2012). The guide is designed for use when making a

determination that one of the “prohibited uses” (listed in section 4(c) of the Wilderness Act) is the 

minimum necessary requirement. 

Concern Statement: The Forest Service should clarify whether managing for scenic integrity 

can override an individual wilderness management plan. (11.02)

Response: The proposed scenic integrity objective for wilderness is “very high”, which is 

consistent with wilderness management. A scenic integrity objective of very high allows natural 

processes such as wildfire, and this is supported by direction in Forest Service Manual 2380 

(Landscape Management), the Forest Service Handbook on Scenery Management, and the forest 

plan (see “Scenery,” desired conditions).

Concern Statement: The Forest Service should use current census data when making land use 

designation decisions, in order to accurately reflect the current demand for wilderness areas.

(11.11)

Response: Potential wilderness areas were evaluated to determine the need for an area to be 

designated as wilderness. This analysis considered the degree to which the area contributes to the 

overall National Wilderness Preservation System. Need was analyzed on a regional basis and 

evaluated such factors as wilderness lands in the vicinity, visitor pressure, nonwilderness lands in 

the vicinity, primitive sanctuary for plants and wildlife, capacity of established wilderness areas, 

and wilderness areas with similar landforms and vegetation (2007 Forest Service Handbook

1909.12 chapter 72.3).

The Forest Service developed the forest plan and supporting documents using the best available 

science and most current data on regional populations (including Census data) available at the 

time of development (see the analysis results and literature citations in the forest plan, the 

environmental impact statement, and supporting project record of documents).

Concern Statement: The Forest Service should acknowledge that the Kartchner Caverns are 

reliant on the Whetstone Potential Wilderness Area being managed properly. (11.12)

Response: The forest plan provides guidance for managing land and resources within the 

Coronado National Forest boundary. Management of the Kartchner Caverns State Park is not 

within the established authority of the Forest Service. The cumulative effects of recommended 

wilderness on all lands of other ownership within 100 miles of the Coronado National Forest can 

be found in the “Wilderness and Other Special Areas – Environmental Consequences” section of 

chapter 3 in the environmental impact statement. The forest plan recommends the Whetstone 

Potential Wilderness Area for wilderness designation and provides direction that it will be 

managed to preserve the wilderness character.

Concern Statement: The Forest Service should clarify the nature of the potential conflict 

between wilderness management and aquatic restoration activities in the Whetstone Proposed 

Wilderness Area. (11.15)

Response Project-specific analyses are conducted for all projects planned on the Coronado 

National Forest, including aquatic restoration activities. Any wetland restoration projects 

proposed in wilderness will be analyzed for potential impacts to wilderness character and values.
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The effects of managing to preserve wilderness characteristics are analyzed in the environmental 

impact statement, under alternative 1. The forest plan does not include site-specific proposals for 

aquatic restoration in the Whetstone Potential Wilderness Area

In the availability analysis of potential wilderness area evaluation, the Forest Service analyzed the 

potential impacts of wilderness designation on both current and future land uses, activities, and 

other resource management needs. Potential wilderness areas received an availability rating that 

compared the value and need for wilderness to the value and need for other land uses, including 

aquatic restoration activities. These ratings can be found in appendix F of the Potential 

Wilderness Area Evaluation Report

(http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5440345.pdf).

Concern Statement: The Forest Service should consider the effect of potential wilderness areas 

on use of the Arizona Trail by mountain bikers and bikepackers because the designation could 

force cyclists to use dangerous highways and roads. (11.19)

Response: The effects of wilderness recommendation on mountain biking can be found in the 

“Recreation – Environmental Consequences” section of chapter 3 in the environmental impact 

statement. Consistent with the Wilderness Act of 1964, mechanized uses (including mountain 

biking) would not be permissible in areas designated as wilderness.

If these areas were to become wildernesses, the Coronado would consider a bypass route for 

mountain bikes on the Arizona Trail. During planning and design of the bypass route, we would 

consider public safety.

Consistent with agency policy, the Forest Service completed an assessment of areas that meet the 

criteria for potential wilderness through the wilderness evaluation process. Forest Service policy 

and planning direction is found in the Forest Service Manual 1920 and Forest Service Handbook 

1909.12. Forest Service Handbook 1909.12, chapter 70 (January 2007) is the policy direction that 

guided the wilderness evaluations.

In the availability analysis of the potential wilderness area evaluation, the Forest Service analyzed 

the potential impacts of wilderness designation on both current and future land uses and activities. 

Recreation (motorized and nonmotorized) was included in this evaluation of other land uses and 

activities. Potential wilderness areas received an availability rating that compared the value and 

need for wilderness to the value and need for other land uses, including mountain biking. These 

ratings can be found in appendix F of the Potential Wilderness Area Evaluation Report

(http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5440345.pdf).

Concern Statement: The Forest Service should correct the evaluation of the Dragoon Potential 

Wilderness Area to reflect that helicopter surveys regularly occur over wilderness areas. (11.20)

Response: The Potential Wilderness Area Evaluation Report acknowledges helicopter surveys in 

the Dragoon Potential Wilderness Area. In the availability analysis of the potential wilderness 

area evaluation, the Forest Service considered the potential impacts of wilderness designation on 

both current and future land uses and activities. Potential wilderness areas received an availability 

rating that compared the value and need for wilderness to the value and need for other land uses, 

including wildlife habitat restoration and/or monitoring. These ratings can be found in appendix F 

of the report (http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5440345.pdf).
Appendix A. Response to Comments

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The Coronado National Forest used the wilderness evaluation process outlined in the 2007 Forest 

Service Handbook 1909.12, chapter 70; the areas assessed were identified as potential wilderness 

areas. Identification as a potential wilderness area does not confer any special status to an area 

nor require any additional management restrictions; it simply identifies which areas were assessed 

in the Potential Wilderness Area Evaluation Report.

The Coronado National Forest leadership team recommended four potential wilderness areas for 

wilderness designation; the Dragoon Potential Wilderness Area was not among them. The 

recommended wilderness areas are Ku Chish, Mount Graham, Chiricahua Addition North, and 

Whetstone Potential. 

Concern Statement: The Forest Service should prioritize protecting the corridor that links the 

northern end of the Galiuro Mountains Wilderness with the Aravaipa Canyon Wilderness because 

it is one of the most sensitive unprotected linkages in southern Arizona. (11.22)

Response: As part of the forest plan revision process, we identified and evaluated potential 

wilderness areas according to the procedure outlined in agency guidance (2007 Forest Service 

Handbook 1909.12 chapter 70). The Galiuro Addition Potential Wilderness Area, which is in the 

northern end of the Galiuro Mountains, was evaluated as part of this process. The results of this 

evaluation are available in the Coronado National Forest Potential Wilderness Evaluation Report. 

Four of 33 potential wilderness areas, not including the Galiuro Addition, were recommended for 

wilderness designation by the Coronado National Forest leadership team: Ku Chish, Mount 

Graham, Chiricahua Addition North, and Whetstone Potential. These potential wilderness areas 

were selected by the leadership team to complement the desired conditions stated in the revised 

plan. When selecting the recommended areas, the leadership team considered the positive and 

negative impacts associated with wilderness designation, as well as issues raised in public 

comments and through public workshops.

Concern Statement: The Forest Service should clarify whether the Powers Cabin serves any 

administrative use of wilderness. (11.26)

Response: Powers Cabin is listed on the National Register of Historic Places and provides 

opportunities for wilderness education and historic preservation. The facilities at Powers Garden, 

also in the Galiuro Wilderness, serve as an administrative site for staging and packing in the 

wilderness. The use at Powers Cabin is described in the “Individual Wilderness Area Direction”

section (under Galiuro Wilderness) of chapter 3 in the forest plan.

Concern Statement: The Forest Service should exclude existing mountain bike trails from the 

East Catalina Proposed Wilderness Area. (11.27)

Response: The Coronado National Forest leadership team recommended four potential 

wilderness areas for wilderness designation; the East Catalina Potential Wilderness Area was not 

among them. The recommended wilderness areas are Ku Chish, Mount Graham, Chiricahua 

Addition North, and Whetstone Potential. The forest plan will not restrict mountain bike use in 

the East Catalina Potential Wilderness Area.

Concern Statement: The Forest Service should explain why signs are needed in the Pajarita 

Wilderness Area. (11.28)

Response: Plan components that address signage in designated wilderness areas can be found in 

chapter 3 of the plan within the “Plan Components for All Designated Wilderness Areas” section. 
Appendix A. Response to Comments

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Desired conditions and guidelines state that signs in wilderness areas should give directional 

information to provide for recreation opportunities while maintaining wilderness resource values.

Concern Statement: The Forest Service should manage wilderness study areas using the 

principles of multiple use and sustained yield. (11.29)

Response: Wilderness study areas in the plan are managed to maintain their wilderness character, 

preserve or enhance scenic resources, and for primitive recreation settings (see guidelines 1

through 8 in the “Recommended Wilderness Areas and Wilderness Study Areas” section in 

chapter 3 of the plan) until further review and possible modification by the Chief of the Forest 

Service, Secretary of Agriculture, and the President of the United States. Congress takes action to 

formally designate these areas or to release them for multiple-use management (2007 Forest 

Service Handbook 1909.12, chapter 70, section 73.11). The project- or activity-level decision 

maker may exercise discretion in determining that proposed site-specific actions within a given 

wilderness study area are consistent with retaining the area’s wilderness characteristics.

Concern Statement: The Forest Service should expand the Ku Chish Proposed Wilderness Area 

to be contiguous with Chiricahua National Monument to maximize habitat protection. (11.31)

Response: The forest plan recommends the Ku Chish Potential Wilderness Area for wilderness 

designation. The Ku Chish area is contiguous with the Chiricahua National Monument (see 

Chiricahua Ecosystem Management Area map in the Douglas Ranger District section of chapter 4 

of the forest plan) in areas that meet agency policy for criteria for potential wilderness areas, as 

determined in the wilderness evaluation process. Forest Service Handbook 1909.12, chapter 70 

(January 2007) is the policy direction that guided the wilderness evaluations.

This process consists of three steps: identification of potential areas, evaluation of potential areas, 

and recommendation of potential areas. The Coronado National Forest lands were thoroughly 

analyzed to determine which areas met the criteria for identification of potential wilderness. 

Inventory and boundary delineation for these areas were determined based on the criteria found in 

the 2007 Forest Service Handbook 1909.12, chapter 71 and also in chapter 1 of the Potential 

Wilderness Area Evaluation Report. 

Concern Statement: The Forest Service should proceed with the wilderness designation for the 

lands within Fort Huachuca's radio testing area to support the local economy, maintain 

watersheds, and protect plants and birds. (11.36)

Response: The forest plan recommends the following areas for wilderness designation: Mount

Graham Wilderness Study Area, and Ku Chish, Chiricahua Addition North, and Whetstone 

Potential Wilderness Areas. The boundaries of Fort Huachuca’s radio testing area may include 

some of these lands; however, recommendations for wilderness areas on lands of other ownership 

are outside the scope of the forest plan decision.

Concern Statement: The Forest Service should note that proposed wilderness areas serve as 

potential jaguar corridors. (11.39)

Response: We recognize the importance of the lands we manage for recovery of the jaguar, 

including some areas analyzed as potential wilderness areas. The U.S. Fish and Wildlife Service

designated critical habitat for the jaguar in March of 2014. In that designation, certain corridors 

were identified as important for jaguar movement between the United States and Mexico on lands 

managed by the Coronado National Forest. ARP-G-1 ensures the Coronado National Forest will 
Appendix A. Response to Comments

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121

comply with the jaguar recovery plans. The Potential Wilderness Area Evaluation Report lists 

potential wilderness areas that contain potential jaguar corridors. This document is available in 

the plan set of documents and on the Coronado National Forest’s web site at 

http://www.fs.usda.gov/detail/coronado/landmanagement/planning/?cid=fswdev7_018702.

Concern Statement: The Forest Service should retain the wilderness guideline regarding 

gathering dead and downed wood. (11.44)

Response: Chapter 3, guideline 2 in the vegetation in wilderness states: “Gathering of dead and 

downed fuelwood should be limited to recreational campfire use.” This guideline has been 

retained.

Concern Statement: The Forest Service should acknowledge that the only legal designations of

wilderness study areas are those designated under section 603 of the Federal Land Policy and 

Management Act. (11.47)

Response: Section 603 of the Federal Land Policy and Management Act applies to designation 

of wilderness study areas on Federal lands managed by the Bureau of Land Management. The 

Forest Service process for wilderness evaluation is outlined in Forest Service Handbook 1909.12, 

chapter 70 (January 2007); the areas assessed were identified as potential wilderness areas. 

Identification as a potential wilderness area does not confer any special status to an area nor 

require any additional management restrictions; it simply identifies which areas were assessed in 

the Potential Wilderness Area Evaluation Report.

Wilderness study areas are managed to maintain their wilderness character, preserve or enhance 

scenic resources, and for primitive recreation settings (see guidelines 1 through 8 in the 

“Recommended Wilderness Areas and Wilderness Study Areas” section in chapter 3 of the plan) 

until further review and possible modification by the Chief of the Forest Service, Secretary of 

Agriculture, and the President of the United States. Congress takes action to formally designate 

these areas or to release them for multiple use management (2007 Forest Service Handbook 

1909.12, chapter 70, section 73.11).

The Forest Service has authority to provide management area guidance for recommended 

wilderness and wilderness study areas through law and policy. The Arizona Wilderness Act of 

1984 states,

“...areas recommended for wilderness designation [in revised land management plans] 

shall be managed for the purpose of protecting their suitability for wilderness 

designation...” (Section 103 (b)(4)). 

The Forest Service Manual gives a forest supervisor the responsibility to “Develop management 

direction for recommended wilderness . . .” (Forest Service Manual 1923.04c) and the regional 

forester the responsibility for “Approving management direction for recommended 

wilderness . . .” (Forest Service Manual 1923.04b).

The areas recommended for wilderness in the Coronado forest plan would not be managed as 

wilderness; they would be managed to protect their wilderness characteristics pending legislation 

and designation and to provide for existing uses where compatible. 

The direction provided in the “Recommended Wilderness Areas and Wilderness Study Areas”

section in chapter 3 of the plan would accomplish this requirement of the Arizona Wilderness Act 

of 1984 and the responsibilities found in Forest Service Manual 1923.04. 
Appendix A. Response to Comments

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122

The plan makes wilderness recommendations; only Congress can designate a wilderness. The 

plan provides guidance to maintain the wilderness characteristics of these areas until Congress 

takes action.

Concern Statement: The Forest Service should develop a volunteer wilderness stewardship 

program. (11.48)

Response: Plan components that address volunteer opportunities in designated wilderness areas 

can be found in chapter 3 of the plan. In an effort to encourage volunteer stewardship across all 

designated wilderness areas on the Coronado National Forest, the following management 

approach was added to the “Plan Components for All Designated Wilderness Areas” section:

“Coordinating with local user groups to develop a volunteer wilderness stewardship 

program, emphasizing nonconfrontational education and information sharing.”

Concern Statement: The Forest Service should include group size limits in wilderness areas to 

limit impacts from large equestrian groups. (14.02)

Response: Plan components that address equestrian use and group size limits can be found in 

chapter 3 of the forest plan within the “Designated Wilderness Areas” section. Management 

approaches in this chapter include engaging equestrian groups in collaborative trail maintenance 

and construction projects and long-term partnerships. Management approaches for all wilderness 

areas include adjusting group size if visitor use threatens the wilderness character. A specific 

management approach for the Rincon Wilderness encourages visitors to limit off-trail group size 

(including cross-country travel and at dispersed camping areas) to no more than six people and 

six riding or pack stock animals per group.

Roadless Areas (50)

Concern Statement: The Forest Service should acknowledge that some roadless areas include 

roads, and should seek technical corrections to the inventoried roadless areas

Response: In 2001, the Roadless Area Conservation Rule (36 CFR Part 294) was signed, and the 

current inventoried roadless areas were established. Boundaries were drawn using the data 

available at the time, and unfortunately the Coronado’s road data was not complete. While some 

roads are in the Coronado’s inventoried roadless areas, most are short segments at the ends of 

existing roads, and some have already been obliterated or will be during implementation of travel 

management. The environmental impact statement has been updated to acknowledge that there 

are some roads in inventoried roadless areas. The Roadless Area Conservation Rule (36 CFR Part 

294) does not allow corrections to inventoried roadless area boundaries during plan revision 

processes.

Withdrawal of Lands (65)

Concern Statement: The Forest Service should include an alternative that withdraws unique 

resource areas from mineral entry.

Response: The Forest Service does not have the authority to make mineral withdrawals. The 

agency does have the authority to recommend withdrawals of areas from mineral entry, but the 

actual withdrawal is subject to approval by the Bureau of Land Management and the Secretary of 

the Department of the Interior. In the past several years, the Bureau of Land Management has 

declined consideration of mineral withdraws requested by the Forest Service, and because of that, 
Appendix A. Response to Comments

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Revision of the Coronado National Forest Land and Resource Management Plan

123

the Forest Service is using other management tools to minimize mining and mineral exploration 

impacts. Furthermore, withdrawal only prevents the location of new mining claims, it does not 

prevent activity on existing valid claims.

Concern Statement: The Forest Service should withdraw Mount Graham from mineral entry to 

protect red squirrel habitat, and explain why impacts may be negligible because the average site is 

less than 2 acres. (65.04)

Response: In the section under “Mount Graham Red Squirrel and Critical Habitat” of the 

environmental impact statement, the sentence “The data on mineral exploitation indicates that 

these impacts may be negligible because the average site is less than 2 acres” was removed. This 

sentence was an editing error, left in from an older draft version of the document.

Mineral activity has the potential to impact the Mount Graham red squirrel by modifying 

available habitat and resources. Although facility development and mineral exploitation is 

restricted, new facilities and mineral exploration and extraction are not prohibited within the 

range of the squirrel. However, site-specific management plans would be developed for any new 

facilities, and these would be required to comply with the recovery plan guidelines to give 

adequate consideration for the welfare of the squirrel. 

The Forest Service direction for withdrawals is outlined in Forest Service Manual 2760.

Generally, a withdrawal is a management tool for withholding an area of National Forest System 

land from settlement, sale, location, or entry under some or all of the general land laws, including 

the mining and mineral leasing law, for the purposes of limiting activities under those laws in 

order to maintain other public values in the area, or reserving the area for a particular public 

purpose or program. These programs and purposes may include quality of scientific, scenic, 

historical, ecological, environmental, air, water resource, archaeological values, or other special 

purposes. Before recommending an administrative withdrawal for a certain area, the Forest 

Service must comply with the requirements under 43 CFR 2310.1-2 for consideration of 

alternative protection opportunities such as a right-of-way under section 507 of the regulation (43 

U.S.C. 1767) or a cooperative agreement under sections 302(b) (43 U.S.C. 1732(b)) and 307(b) 

(43 U.S.C. 1737(b)) of the regulation, or other protection methods. These requirements are 

restated in the forest plan as guidelines under chapter 2 in the “Land Ownership Adjustments and 

Boundary Management” section.

Concern Statement: The Forest Service should explain how means other than withdrawal will 

result in the same desired condition that withdrawal would because the certainty of withdrawal is 

preferable to unexplained methods of protection. (65.07)

Response: The forest plan and environmental impact statement do not specifically claim “means 

other than withdrawal will result in the same desired condition that a withdrawal would.” 

However, before recommending an administrative withdrawal for a certain area, the Forest 

Service must comply with the requirements under 43 CFR 2310.1-2 for consideration of 

alternative protection opportunities such as a right-of-way under section 507 of the regulation (43 

U.S.C. 1767) or a cooperative agreement under sections 302(b) (43 U.S.C. 1732(b)) and 307(b) 

(43 U.S.C. 1737(b)) of the regulation, or other protection methods. These requirements are 

restated in the forest plan as guidelines under chapter 2 in the “Land Ownership Adjustments and 

Boundary Management” section.
Appendix A. Response to Comments

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Revision of the Coronado National Forest Land and Resource Management Plan

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Concern Statement: The Forest Service should support the use of withdrawals from mining to 

protect special places and resources such as cultural resources, unique resource areas, unique 

waters, watersheds for cities and towns, ecosystem values, sensitive springs and seeps, wilderness 

study areas, and research natural areas. (65.01, 65.02, 65.05, 65.06, 49.21)

Response: The Forest Service supports the use of mineral withdrawals for the purpose of 

resource protection and the protection of improvements to National Forest System lands such as 

developed recreation sites. It should be noted, however, that approval of a withdrawal is at the 

discretion of the U.S. Department of the Interior and the Forest Service may only make 

recommendations for mineral withdrawals. Furthermore, while withdrawal from mineral location 

(for location of a mining claim) prevents the location of new claims, it does not inactivate 

existing mining claims. 

The Forest Service direction for withdrawals is outlined in Forest Service Manual 2760. 

Generally, a withdrawal is a management tool for withholding an area of National Forest System 

land from settlement, sale, location, or entry under some or all of the general land laws, including 

the mining and mineral leasing law, for the purposes of limiting activities under those laws in 

order to maintain other public values in the area, or reserving the area for a particular public 

purpose or program. Before recommending an administrative withdrawal for a certain area, the 

Forest Service must comply with the requirements under 43 CFR 2310.1-2 for consideration of 

alternative protection opportunities such as a right-of-way under section 507 of the regulation (43 

U.S.C. 1767) or a cooperative agreement under sections 302(b) (43 U.S.C. 1732(b)) and 307(b) 

(43 U.S.C. 1737(b)) of the regulation, or other protection methods. These requirements are 

restated in the forest plan as guidelines under chapter 2 in the “Land Ownership Adjustments and 

Boundary Management” section.

Concern Statement: The Forest Service should provide a map of those areas proposed for 

withdrawal from mining. And describe the criteria used for recommending these areas for 

withdrawal. (65.03, 65.08)

Response: The proposed action and alternatives 1, 2, and 3 include recommended wilderness

areas, which would be withdrawn if officially designated by legislation, but no other areas are 

being recommended for withdrawal. The no-action alternative, as part of the existing 1986 plan, 

does recommend withdrawal of some areas; however, the forest supervisor decided not to 

withdraw these areas after other methods of surface resource protection were identified. The

“Minerals” and “Wilderness” sections of the environmental impact statement have been updated 

to better describe and compare the alternatives with respect to recommended wilderness areas and 

the withdrawals associated with them if officially designated.

Concern Statement: The Forest Service should reconsider withdrawals of lands available for 

locatable minerals and seek out additional input from the mining industry and to avoid impacts on 

firefighters and border patrol agents. (65.09)

Response: The Forest Service supports the use of mineral withdrawals for the purpose of 

resource protection and the protection of improvements to National Forest System lands such as 

developed recreation sites. It should be noted, however, that approval of a withdrawal is at the 

discretion of the U.S. Department of the Interior. The Forest Service may only make 

recommendations for mineral withdrawals. Furthermore, while withdrawal from mineral location 

(for location of a mining claim) prevents the location of new claims, it does not inactivate 

existing mining claims. 
Appendix A. Response to Comments

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Revision of the Coronado National Forest Land and Resource Management Plan

125

All National Forest System lands determined to meet wilderness capability requirements are 

considered potentially available for wilderness designation and potential withdrawal by 

legislation. However, the determination of availability is conditioned by the value of and need for 

the wilderness resource compared to the value of and need for other resources (see the 2007 

version of FSH 1909.12, chapter 72.2). The availability of an area for wilderness designation is 

based on the tradeoffs involved in managing the area for wilderness character versus current and 

potential future uses, such as mineral resources and access. Refer to the Potential Wilderness Area 

Evaluation report for more detailed information and analysis of the potential wilderness areas 

considered for recommendation in the forest plan. The forest plan public involvement process, 

including scoping and comment periods and public meetings, allowed all individuals, including 

those in the mining industry, border patrol, and firefighters, an opportunity to comment on the 

forest plan and raise issues or concerns about the potential effects prior to the decision.

Transportation Management

Transportation System Management (58)

Concern Statement: The Forest Service should provide maps that clearly delineate the different 

types of roads in the forest to avoid conflicts between public visitors and private landowners. (58)

Response: The “Motorized Transportation System” section in chapter 2 of the forest plan states 

“The motorized transportation system available for public use is displayed on motor vehicle use 

maps.” Please refer to the motor vehicle use maps for information on roads under Coronado 

jurisdiction. The motor vehicle use map is the sole legally required depiction of roads on which 

the Forest Service shows the general public which roads, trails and areas are available for 

motorized use. This map is available on paper for free and is also freely available online. Other 

maps which depict roads on the Coronado do not show sufficient detail to be the sole basis for 

making travel decisions. 

Concern Statement: The Forest Service should clarify how road closure analysis is done, how 

decisions are made, who is part of the travel management process and explain that road closures 

do not expand nonmotorized recreation opportunities and are tied to site-specific conditions.

(58.01, 58.12, 58.23)

Response: While the plan provides some guidance for managing roads, density and closures, the 

travel management process is generally a separate analysis and is outside the scope of the forest 

plan decision.

Concern Statement: The Forest Service should provide maps showing designated areas where 

off-road vehicles are permitted in order to comply with Executive Orders 11644 and 11989 and to 

avoid land use/ownership conflicts. (58.02, 58.10)

Response: The Forest Service does provide maps showing designated areas where off-road 

vehicles are permitted. Contact your closest ranger district office to receive a map.

Concern Statement: The Forest Service should provide an accurate accounting of the 

existing/proposed motorized transportation system and its density and analyze the impacts 

(increased visitor use, erosion) of that system on all forest resources (e.g., vegetation, soil, 

montane meadows, wetlands). (58.03, 58.04, 58.11, 58.17, 58.22, 58.24)
Appendix A. Response to Comments

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126

Response: The plan provides guidance for managing road density by setting desired conditions 

for the various land use zones. There are no new roads allowed in wilderness, and only those 

roads needed to restore access are allowed in the Wild Backcountry Land Use Zone. The travel 

management process, which is guided by the forest plan, provides an accurate analysis of the 

existing and proposed motorized transportation system and the impacts on all Coronado National 

Forest resources. 

Concern Statement: The Forest Service should consider an alternative that features standards 

that prohibit new road and trail construction, require no net-increase of road density (limit to 1 

mile per square mile) and include an objective encouraging reduction of road density in key 

watersheds and riparian areas because roads cause significant erosion, resource damage and 

sediment loading. (58.05, 58.15, 58.25)

Response: An alternative was considered that would not allow new roads or unauthorized routes 

to be added to the transportation system. The forest plan provides a framework to guide new road 

construction to reduce impacts to sensitive resources. Potential changes or additions to the 

forest’s transportation system are not plan-level decisions and would be evaluated in separate 

analysis through implementation of the Travel Management Rule (73 FR 74689). As a result, this 

alternative was dropped from detailed consideration.

Concern Statement: The Forest Service should avoid decommissioning roads for the purpose of 

creating quiet recreation opportunities. There are sufficient quiet recreation opportunities already 

and too many roads to allow for adequate enforcement of quiet recreation. (58.14, 58.16)

Response: The plan provides guidance for quiet recreation in the form of desired conditions for 

wilderness and Wild Backcountry and Roaded Backcountry Land Use Zones. Decisions for 

decommissioning roads are made at the project level, through the travel management process. 

Concern Statement: The Forest Service should acknowledge that improvements may be needed 

to SR266, SR366, and SR92 to maintain or widen the roads and prevent damage to the 

environment. (58.26, 58.28, 58.31)

Response: This comment is outside the scope of the forest plan. State highway road 

improvements are not within the jurisdiction of the Forest Service. They are managed by the

Arizona Department of Transportation.

Concern Statement: The Forest Service should integrate the trail system with the Pima County 

Regional Trail System wherever possible and use local volunteers for trail maintenance. (58.08, 

58.27)

Response: This comment is outside the scope of the plan. While trail systems located in Pima 

County are not within the jurisdiction of the Forest Service, coordination with outside agencies 

are always considered when developing new trails or maintaining existing trails.

Concern Statement: The Forest Service should ensure all existing forest roads remain open to 

allow for drug interdiction and include access for firefighting as a desired condition. (58.29, 

58.30)

Response: The travel management process provides analysis of roads proposed to remain open, 

to be added, and decommissioned from the existing motorized transportation system. The U.S. 

Customs and Border Protection Agency provides input on roads necessary for drug interdiction 
Appendix A. Response to Comments

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127

during the travel management process. They also have the lawful right to utilize any area on the 

Coronado National Forest to do anything as long as they have an exigent reason for doing so. 

Roads are always open for access to fire crews during emergencies. Travel management is 

generally a separate analysis and is outside the scope of the forest plan decision.

Travel management is both a Code of Federal Regulations and policy, which we adhere to. It 

provides a scientific basis for recommendation of which roads to retain on the system and at what 

maintenance level, class of vehicle, season, etc. The forest plan should not address points that 

have already been addressed nationally elsewhere. Further, the U.S. Customs and Border 

Protection Agency has the lawful right to use anywhere on forest to do anything so long as they 

have an exigent reason for doing this, including on closed roads, on no roads and in wilderness 

areas. The U.S. Customs and Border Protection Agency needs are fulfilled through travel 

management and through an independent memorandum of understanding and memorandum of 

agreement.

Concern Statement: The Forest Service should ensure that roads covered by RS 2477 will 

remain open. (58.06)

Response: This comment is outside the scope of the forest plan. Congress has not delegated to 

the Forest Service the adjudicative authority to conclusively determine whether there is a valid 

Revised Statute 2477. Only a court of competent jurisdiction can conclusively make such a 

determination. The Forest Service has a policy in place to evaluate the acceptance and scope of 

the rights-of-way claimed (asserted) under RS 2477 by a public road agency such as a City, 

County, or State (Forest Service Manual 2734.51 - Policies and Administration for Rights-of-Way 

Granted by Revised Statute 2477).

Concern Statement: The Forest Service should include a guideline protecting or maintaining 

authorized routes connecting to existing roads on State Trust Land. (58.07)

Response: This comment is outside the scope of the forest plan. Approximately 8 million acres 

of State Trust land are available for recreation, but access is not guaranteed. Where existing, 

unrestricted, legal motor vehicle access exists to the Coronado, these roads on National Forest 

System land which connect to that access route are a high priority to retain as system roads. 

Where such legal access does not and cannot reasonably be expected to occur, such roads on 

forest land are a low priority to retain as system roads. For those roads on National Forest System 

land where such legal access is highly desired and a feasible method exists to obtain such legal 

access, the roads are analyzed on a case-by-case basis. The Forest Service is currently unable to 

legally accept an easement from State Trust land in the State of Arizona and must rely on partner 

organizations to obtain and hold such easements. The travel management process provides 

analysis for existing and proposed routes and is a separate procedure.

Concern Statement: The Forest Service should consider permitting paving of roads. To address 

dust, potholes, road cuts, safety, and noise. (58.09)

Response: The surface treatment of roads is not a forest plan-level decision. The paving of roads 

will be analyzed during the travel management process since it would require a change in the 

maintenance level of the road.

Concern Statement: The Forest Service should prohibit additional paving of campgrounds or 

roads and should add a latrine to John Hands picnic area. (58.21)
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Response: The surface treatment of roads is not a forest plan-level decision. The paving of roads 

and campgrounds will be analyzed during the travel management process since it would require a 

change in the maintenance level of the road. Addition of a latrine to John Hands picnic area 

would be addressed site specifically at the project level.

Concern Statement: The Forest Service should clarify that temporary roads are not permitted in 

inventoried roadless areas and that new roads are only permitted when needed to meet desired 

conditions. (58.13)

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

policy. Those relevant laws, regulations, or policies are listed in appendix E of the forest plan,

“Other Sources of Information.” The 2001 Roadless Rule establishes prohibitions on road 

construction, road reconstruction, and timber harvesting on 58.5 million acres of inventoried 

roadless areas on National Forest System lands. The public health and safety exception at 

paragraph (b)(1) in the final rule applies only when needed to protect public health and safety in 

cases of an imminent threat of a catastrophic event that might result in the loss of life or property. 

It does not constitute permission to engage in routine forest health activities, such as temporary 

road construction for thinning to reduce mortality due to insect and disease infestation. Paragraph 

(b)(3) permits the construction and reconstruction of a road pursuant to rights granted in statute or 

treaty, or pursuant to reserved or outstanding rights. These include, but are not limited to, rights of 

access provided in Alaska National Interest Lands Conservation Act, highway rights-of-way 

granted under Revised Statute 2477, and rights granted under the General Mining Law of 1872, 

as amended. Rights of reasonable access for mineral exploration and development of valid claims 

would be governed by the General Mining Law under any of the alternatives considered in the 

environmental impact statement. These rights of access may or may not include new road 

construction as discussed elsewhere in this preamble. Therefore, rights of access to locatable 

mineral exploration and development of valid claims would not be affected by the final rule or 

any of the alternatives analyzed in the environmental impact statement.

Concern Statement: The Forest Service should choose a better parameter for evaluating 

alternatives than potential jaguar mortality from vehicle collisions because there is no evidence 

that jaguars are at risk. (58.18)

Response: Impacts of roads on large carnivores include direct mortality from vehicle collisions. 

In our view, “no evidence of jaguar mortality from vehicle collisions” does not equate to “no 

risk”. Therefore, as stated in table 15 of the environmental impact statement, the parameter is a 

valid one. Impacts of roads on large carnivores include direct mortality from vehicle collisions, 

avenues for illegal shooting, direct habitat loss, and harassment. Areas where the ocelot and 

jaguar have occurred on the Coronado have low road densities and include portions of areas 

currently being considered for wilderness status.

Concern Statement: The Forest Service should clarify the process for opening trails within the 

Mount Graham Red Squirrel Refugium and the Mount Graham International Observatory because 

those areas are closed to the public without a permit from the University of Arizona. (58.19)

Response: The Mount Graham Refugium and Mount Graham International Observatory are 

administered through a special use permit to the University of Arizona. The policy for trail use is 

described in this permit, not in the forest plan.
Appendix A. Response to Comments

Final Programmatic Environmental Impact Statement for 

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129

Concern Statement: The Forest Service should consider including a link to the most recent 

version of the Arizona Department of Transportation Five-Year Program because it is updated 

annually. (58.20)

Response: The Arizona Department of Transportation Five-Year Program is considered and 

referenced in the environmental impact statement, appendix B. We appreciate the suggestion for 

including a link to the most recent version and will include it so reviewers of the environmental 

impact statement can see the most recent version.

Concern Statement: The Forest Service should analyze the effects of removing large tracts of 

land from access to vehicular traffic. (58.32)

Response: The draft environmental impact statement analyzed motorized activities on the 

Coronado on pp. 386-390. Under all alternatives, future changes in the miles of National Forest 

System roads and motorized trails would be evaluated site specifically as needs are identified and 

in accordance with the transportation analysis process and Travel Management Rule 

requirements.

Concern Statement: The Forest Service should clarify what is meant by “roads open to public 

unless restricted for administrative use.” (58.33)

Response: In the “Public Access” section of the forest plan, the desired condition states:

“Legal status deficiencies of the existing system of forest roads and trails have been 

resolved; these roads and trails are available for use by public lands users, unless 

restricted for administrative purposes.”

Roads restricted to administrative use include use by special use permittees, U.S. Customs and 

Border Protection personnel, and Forest Service personnel.

Socio-economic Concerns

Border Patrol Activity (4)

Concern Statement: The Forest Service should engage with Border Patrol agents to manage on 

the ground impacts from agent activities. (4.01)

Response: In the “Revision Topic 2: Visitor Experiences” section of the environmental impact 

statement, it states:

Border Patrol has a public lands liaison who works directly with the forest at both the 

district and forest level. This relationship affords both agencies to respond to immediate 

impacts to the environment, plan ahead and attempt to minimize Border Patrol impacts 

when operations are undertaken on the forest. For most activities the Border Patrol have 

land management agency liaisons and consultants that work with the U.S. Fish and 

Wildlife Service on threatened and endangered species.

The Coronado National Forest has also created a Forest Service border liaison position to work 

with the Border Patrol on resource issues.

Concern Statement: The Forest Service should prohibit border patrol activities within the 

Mount Graham Biological Research Area to avoid effects to the ecologically sensitive area. (4.02, 

23.03)
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Response: The Department of Homeland Security enabling legislation allows for interdiction 

activities on all National Forest System lands; therefore, it is outside the scope of the forest plan 

to limit the activities of the Border Patrol. In recommended wilderness areas, the Border Patrol 

has the authority to supersede management restrictions on motorized vehicle use during pursuit of 

a crime in progress. However, Border Patrol frequently works with the Forest Service to 

minimize resource impacts for planned activities.

Concern Statement: The Forest Service should limit activities in the border region over which 

they have control to take into account the effects of activities that are not within their control.

(4.03)

Response: The Forest Service takes into account known activities not under their control that

occur on National Forest System lands when planning for activities in the border region that are 

under Forest Service control. In the “Revision Topic 2: Visitor Experiences” section of the 

environmental impact statement it states:

Border Patrol has a public lands liaison who works directly with the forest at both the 

district and forest level. This relationship affords both agencies to respond to immediate 

impacts to the environment, plan ahead and attempt to minimize Border Patrol impacts 

when operations are undertaken on the forest. For most activities the Border Patrol have 

land management agency liaisons and consultants that work with the U.S. Fish and 

Wildlife Service on threatened and endangered species.

Concern Statement: The Forest Service should add the impacts of border migration and 

interdiction to the cumulative effects analysis. (4.04)

Response: Cumulative effects analysis of border migration and interdiction activities are not 

within a forest plan-level decision. Those activities may be taken into account during individual 

project analysis.

Concern Statement: The Forest Service should insist that Border Patrol actions be consistent 

with the uses of the forest and that uses should go through a National Environmental Policy Act 

analysis. (4.05)

Response: The Border Patrol constantly works with the Forest Service to bring their interdiction 

activities more in line with Forest Service resource goals. In the “Public Safety and Illegal 

Activities – Environmental Consequences” section of chapter 3, under alternative 1, 

environmental consequences section, because of wilderness restrictions, law enforcement officers 

would have to access wilderness on foot or horseback. Helicopter patrols may be an option if 

approved by the regional forester after a minimum requirements decision guide analysis is 

completed for such actions in specific restricted areas. Also, all facilities constructed by the 

Department of Homeland Security go through a National Environmental Policy Act analysis on a 

project-by-project basis.

Cultural, History, Anthropology Management (9)

Concern Statement: The Forest Service should expand the list of items that are part of 

monitoring to include cultural resources. (9)

Response: We added cultural resources to the list of items that are part of monitoring. See chapter 

6 of the forest plan.
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Concern Statement: The Forest Service should improve the discussion of cultural resources, 

tribal relations, and plant and animal communities to American Indian communities, as well as 

the importance and intricate links of cultural, plant, animal, and water (springs) resources to 

respective ecological and biological communities. (9.01, 9.07, 9.11)

Response: The importance of plants and animals to tribes and objectives for involving tribes in 

consultation are emphasized in the “Tribal Relations” section of chapter 2, “Forestwide 

Management.” One of the objectives in that section is:

“Providing opportunities for tribal members to engage in traditional activities, such as the 

collection of medicinal plants, wild plant foods, basketry materials, and fuelwood for 

personal use.”

Concern Statement: The Forest Service should reconsider the definition of priority heritage 

assets to emphasize evaluating the archaeological or historical significance of a resource, and 

include state historic preservation registrars in the discussion of historic places. (9.02, 9.04)

Response: The definition of a priority heritage asset is standardized throughout the Forest 

Service as cultural resource sites and buildings listed on the National Register of Historic Places

and other sites where investment in interpretation or preservation activities has been made. One 

of the desired conditions in the “Cultural Resources” section of chapter 2 is the continued 

protection and preservation of these priority assets, and one of the objectives is conducting 

preservation and stabilization work at these sites. State Registers of Historic Places are reviewed,

but on Federal lands, the National Register of Historic Places is of greater importance. Desired 

conditions and objectives in the “Cultural Resources” section of chapter 2 include listing 

historically significant properties on the National Register of Historic Places.

Concern Statement: The Forest Service should proceed with the Native American Graves 

Protection and Repatriation Act repatriation of pre-1990 collections.

Response: In the draft forest plan, there was an objective to complete Native American Graves 

Protection and Repatriation Act repatriations of all items collected prior to 1990, within 5 years of 

plan approval. Since the draft plan was released, the Coronado National Forest has been 

successful in fulfilling its Native American Graves Protection and Repatriation Act obligations, 

and so we have deleted this forest plan objective.

Concern Statement: The Forest Service should acknowledge that there are many Native 

American tribes in the area and ensure Native Americans communities have access to Forest 

lands for traditional use, religious purposes, and resource procurement. (9.05, 9.06, 9.10)

Response: We acknowledge how important it is for tribes to have access to National Forest 

System lands for traditional use, religious purposes, and resource procurement. This is 

emphasized in the “Tribal Relations” section of chapter 2, under “Forestwide Management.” We

recognize tribes have cultural ties and knowledge about the lands currently managed by the 

Coronado National Forest. Many tribal members regularly visit these lands to gather traditional 

resources and to visit traditional cultural properties and sacred sites.

Concern Statement: The Forest Service should proceed with the goals for interpretive events, 

volunteer opportunities, and the “Rooms with a View” program. (9.08)
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Response: In the “Cultural Resources” section of chapter 2, the continued development of 

interpretive programs and the “Rooms with a View” program are identified as management 

approaches to be taken to meet objectives.

Concern Statement: The Forest Service should provide for increased and improved 

identification, assessment and protection of sites, districts, landscapes and traditional cultural 

places (e.g., the Santa Rita Mountains) having cultural and religious significance to Native 

Americans. (9.09, 9.12, 9.13)

Response: An objective for the identification of historic properties, including districts and places 

of importance to tribes is included in the “Cultural Resources” section in chapter 2 of the plan. 

One of the objectives in the “Tribal Relations” section is:

“Documenting the traditional and cultural importance of the Santa Rita Mountains, 

recognized by O’odham peoples as a place of traditional and cultural importance.”

Since the draft plan was written, the Santa Rita Mountains have been determined eligible for the 

National Register of Historic Places as the Ce:wi Duag Traditional Cultural Property important to 

the O'odham and other tribes. The forest plan updated the Santa Rita Ecosystem Management 

Area description to include recognition of this place of traditional importance to tribes (“Santa 

Rita Ecosystem Management Area – General Description” section).

Economic and Social Actions, Analyses (16)

Concern Statement: The Forest Service should acknowledge the economic role that outdoor 

education and recreation plays in the local economy, as well as the importance of ecotourism to 

the region while ensuring that economic activities benefit the entire community. (16.01, 16.07, 

16.05)

Response: The economic role that outdoor education and recreation play, ecotourism, and its 

community benefits are found in chapter 2 of the plan within the “Recreation; Desired 

Conditions” section. Recreation on the Coronado National Forest enhances the quality of life for 

residents and provides tourist destinations, which contribute to local economies. These benefits 

are described in the Social and Economic Sustainability Report and in chapter 3 of the 

environmental impact statement.

Concern Statement: The Forest Service should analyze the socioeconomic effects of the 

Municipal Supply Watershed designation for the town of Patagonia. (16.02)

Response: The recognition of the area serving the Town of Patagonia water system as a 

municipal supply watershed is not a forest plan decision. It is based on the following definition of 

a public water supply:

“The term ‘‘public water system’’ means a system for the provision to the public of water 

for human consumption through pipes or other constructed conveyances, if such system 

has at least fifteen service connections or regularly serves at least twenty-five 

individuals.” (42 U.S.C. Part A (4)(a))
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The Forest Service regulation for management of municipal watersheds (36 CFR 251.9 (a)) 

states:

“The Forest Service shall manage National Forest watersheds that supply municipal 

water under multiple use prescriptions in forest plans (36 CFR part 219). When a 

municipality desires protective actions or restrictions of use not specified in the forest 

plan, within agreements, and/or special use authorizations, the municipality must apply to 

the Forest Service for consideration of these needs.”

The Town of Patagonia water system treats and distributes water to approximately 3,000 residents

and meets the legal requirements for a public water system. Recognition of the Town of Patagonia 

municipal supply watershed in the forest plan is in alignment with the legal requirements listed 

above. The watersheds will continue to be managed for multiple use and no restrictions are being 

incorporated. The Town of Patagonia and the Forest Service entered into an agreement to allow 

the Town to post the watershed as a municipal supply watershed, conduct education programs in 

the watershed, and sample water quality according to Arizona Department of Environmental 

Quality protocols. Since no restrictions are being placed on the watershed, no effects are 

predicted.

Concern Statement: The Forest Service should revise the “Climate-Related Socioeconomic 

Demand” section to include more useful statistics to assess future demand. (16.03)

Response: We developed the plan using the best available science for “Climate-related 

Socioeconomic Demand” (see the analysis results and literature citations in the plan, the 

environmental impact statement, and supporting project record of documents). Forest Service 

policy also requires interdisciplinary specialists to use the best available science for their analyses 

at the project level to inform the deciding official.

Concern Statement: The Forest Service should disclose the source of funding for the plan, how 

funding will be secured, and include a discussion of the funding needed to support the 

alternatives. (16.04, 16.08)

Response: A discussion of funding for the proposed action as well as the alternatives is found in 

chapter 2 of the environmental impact statement in the “Comparison of Alternatives” section. The 

differences between alternatives are unlikely to affect forest expenditures and revenue. Therefore, 

the present value of costs is consistent across alternatives.

Concern Statement: The Forest Service should acknowledge that there is insufficient funding to 

maintain forest roads. (16.09)

Response: A discussion of the funding needed to maintain forest roads is found in chapter 2 of 

the plan in the “Motorized Transportation System” section, “Management Approaches” section. 

We are seeking road maintenance agreements with local government agencies and private 

organizations to supplement forest-funded maintenance.

Concern Statement: The Forest Service should revise the inadequate and incomplete economic 

analysis to include the economic contribution of hunting, an analysis of the cost to administer 

grazing, an analysis of the effects of withdrawals of lands from multiple use, and an economic 

sustainability analysis. (16.06, 16.10)

Response: We developed the plan using the best available science for the economic analysis (see 

the analysis results and literature citations in the plan, the environmental impact statement, and 
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supporting project record of documents). Forest Service policy also requires interdisciplinary 

specialists to use the best available science for their analyses at the project level, to inform the 

deciding official. Additionally, the cost and revenues by program area are reported in the 

“Economic” section of the final environmental impact statement. Detailed analysis of the grazing 

program was not provided because there was no difference between alternatives with respect to 

grazing.

Concern Statement: The Forest Service should recognize that Cochise County's recreation and 

tourism will be affected by the plan. (16.11)

Response: We agree and have added a topic regarding communities, collaboration, and 

partnerships that addresses the affected recreation and tourism of the six counties into which the 

Coronado National Forest extends, including Cochise County.

Enforcement (18)

Concern Statement: The Forest Service should provide more rangers in the national forest, to 

identify and repair erosion problems, increase enforcement to damage to the forest, and include 

an objective that includes quantitative goals for improved law enforcement. (18.01, 18.03)

Response: This is outside the scope of the forest plan. The Forest Service law enforcement 

staffing level is reflective of the budget allocated to the Forest Service from Congress. With the 

current staffing level, the law enforcement program identifies areas of increased criminal activity, 

negative impacts to the resources, and areas of decreased public safety. Each year objectives are 

set to decrease criminal activity, lessen impacts to the resources, and to increase public safety. At 

the end of each fiscal year, goals accomplished are evaluated by reviewing crime statistics and 

doing an inventory of impact areas.

Illegal Uses (23) and International Border (26)

Concern Statement: The Forest Service should include humanitarian activities in the formal 

management approaches to facilitate the preservation of lives along the border. (23.01, 23.02)

Response: Humanitarian activities are project-level decisions and are not within a forest planlevel decision.

Concern Statement: The Forest Service should provide support for statements regarding illegal 

users and fires. (23.04)

Response: It is difficult to determine and document fires that are set by illegal immigrants. All 

fires are documented and entered into the Coronado’s fire database, and this database was used to 

inform the forest plan and analysis in the environmental impact statement.

Concern Statement: The Forest Service should acknowledge that border patrol agents need to 

have access throughout the region to curtail the illegal transport of drugs, guns, and illegal aliens.

(23.05)

Response: The forest plan sets desired conditions for the border region that include an 

environment where the risks are predominantly natural, visitors do not feel threatened, and where 

illegal activities do not cause resource damage. We acknowledge the need for access on National 

Forest System lands by Border Patrol agents in the border region for interdiction purposes, and 

we work with them to ensure access is available in a manner that minimizes impacts to Coronado 
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National Forest resources. Allowing access to Border Patrol agents is an important safety matter

but is outside the scope of the forest plan.

Concern Statement: The Forest Service should analyze the effects of construction of roads and 

fences associated with the international border. (26.01)

Response: The analysis of impacts from facility construction is done at a project level and is not 

within a forest plan-level decision. Any new infrastructure proposed by the Department of

Homeland Security, Customs and Border Patrol, is analyzed by the Department and the Forest 

Service in their respective National Environmental Policy Act analysis processes.

Impacts of Illegal Uses (24)

Concern Statement: The Forest Service should analyze the effects of fires set by illegal aliens.

(24.01)

Response: The effects of fires set by illegal immigrants are not part of forest plan level analysis.

It is difficult to determine and document fires that are set by illegal immigrants. All fires are 

documented and entered into the Coronado’s fire database, and this database was used to inform 

the forest plan and analysis in the environmental impact statement.

Concern Statement: The Forest Service should acknowledge that issues related to 

undocumented aliens crossing the border are not part of the agency's mandate. (24.02)

Response: Acknowledgement of issues related to illegal immigration is not a forest plan-level 

decision. The Forest Service does not have an agency mandate to deal directly in the interdiction 

of illegal immigrants; however, Forest Service law enforcement officers must enforce Federal law 

on National Forest System lands regardless of who may have broken the laws.

Concern Statement: The Forest Service should address permittee management of issues relating 

to illegal activity along the border. (24.03)

Response: Addressing permittee issues related to illegal immigration is not a forest plan-level 

decision. Such incidents are managed on a case-by-case basis.

Concern Statement: The Forest Service should include efforts to remove trash left by illegal 

aliens. (24.04)

Response: The forest plan sets desired conditions for the border region that include an 

environment where trash is not commonly found. This guidance sets the stage for future projects 

to remove trash left by illegal immigrants when funding, equipment, and personnel become 

available.

Public Health and Safety (43)

Concern Statement: The Forest Service should assess the impacts on public safety including 

road safety. (43.01)

Response: Public safety is a major concern of the Forest Service but is outside the scope of the 

forest plan. Several Forest Service directives have been published to address the most common 

and general public safety issues, especially those involving safety along public and National 

Forest System roads. Assessments are conducted by Forest Service engineering and roadway 
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construction teams to determine possible hazards to the visiting public. Repair or abatement 

actions are initiated when a hazard may endanger the health and safety of those visiting the 

Coronado National Forest.

Administrative Comments

Confirm Receipt of Letter (7)

Concern Statement: The Forest Service should confirm receipt of letter.

Response: The Forest Service does not confirm the receipt of a letter; however, letters submitted 

for the Coronado National Forest Land and Resource Management Plan can be found at the 

following web site: https://cara.ecosystem-management.org/Public/ReadingRoom?project=31147

No Further Response Required (35)

Concern Statement: The Forest Service does not need to respond to these comments. Because 

they only acknowledge the work of the Forest Service because they only refer to comments 

submitted by others.

Response: Thank you for your comment.

Remove from Mailing List (47)

Concern Statement: The Forest Service should remove the respondent from the mailing list.

(47.01)

Response: We have removed individuals from the mailing list at the respondent’s request.

Requests for Information (48)

Concern Statement: The Forest Service should provide a compact disc of the draft forest land 

and resource management plan and draft environmental impact statement, a printed copy of the 

final land and resource management plan and environmental impact statement, and copies of the 

final decision. (48.01)

Response: The draft environmental impact statement and draft forest land and resource 

management plan are available via the following web site:

http://www.fs.usda.gov/detail/coronado/landmanagement/planning/?cid=fswdev7_018702. The 

Forest sent out compact discs that contained these documents and supplemental specialist reports 

to those who requested them. Printed copies of the forest plan, final environmental impact 

statement, and record of decision will likewise be available by request.
Final Programmatic Environmental Impact Statement for 

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Appendix B. Coordination

with Other Public Planning Efforts

Summary

Per the provision of the 1982 planning regulations, the responsible official shall review the 

planning and land use policies of other Federal agencies, state and local governments, and Indian 

tribes. This document, along with other planning efforts, contributes to that requirement.

Ecosystem restoration and resilience will be a main focus in the revised forest plan. The Chief of 

the Forest Service Tom Tidwell has called for an “all-lands approach” to accomplish ecosystem 

restoration. This will involve land owners and stakeholders working together across boundaries to 

decide on common goals for the landscapes they share.

In order to facilitate this “all-lands approach,” it is important to understand the goals and 

anticipated activities of our adjacent land owners. The following sections provide a summary of 

those goals and activities. 

Counties

The Coronado National Forest lies in five counties in Arizona: Cochise, Graham, Pima, Pinal, and 

Santa Cruz; and one county in New Mexico: Hidalgo.

County comprehensive plans can be used as a source of information on the history of land use 

within the region, the patterns of development, desired conditions, and current county land use 

policies. County governments hold no legal authority over independent jurisdictions such as 

Federal and state lands, incorporated cities and towns, or Native American tribal reservations. 

County land use in the planning area ranges from traditional uses such as farming and ranching in 

rural areas to denser concentrations of residential, industrial, and commercial uses in and around 

suburban (e.g., Douglas, Safford, Nogales) and urban areas (e.g., Tucson metropolitan area and 

Sierra Vista). One of the common themes is how, and whether, private owners and public land 

managers can manage the competing priorities of resource conservation and economic 

development—in particular how to cope with the growing demands for housing and recreation 

while preserving a shrinking natural resource base that contributes to Arizona’s highly valued 

“rural character.”

Comprehensive plans are summarized below for the five Arizona counties and one New Mexico

county in which the Coronado National Forest occurs.

Graham County Comprehensive Plan 

Like many areas throughout the Mountain West, patterns of existing land use in Graham County 

are rooted in the history of settlement by miners, ranchers, and farmers. The Graham County 

Comprehensive Plan marks 1872 as a milestone in development of the county after the 

establishment that year of a copper mine in the town of Clifton (then in Graham County). At 
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about the same time, farming communities were being established along the Gila River, which 

traverses the county from east to west (Graham County 1996). 

Today, Graham County remains an area of rich natural resources with a rural culture and an 

economy supported by continued copper mining, cotton farming, and cattle ranching. The Gila 

River is a vital source of water for approximately 52,000 acres of cultivable land in the county, 

much of which is dedicated to the production of cotton, a primary component of the county’s 

agricultural economy. Mining has also continued to play a major role in the development of 

Graham County. In addition to a number of small mines operating throughout the county, the 

Phelps-Dodge Corporation manages a large open pit mine north of Safford. Graham County is 

also home to the Large Binocular Telescope, the world’s most powerful optical telescope which 

was completed in 2004. For these reasons, the Graham County Comprehensive Plan emphasizes 

the importance of protecting both the natural resources and scenic beauty that are “essential to the 

economic stability and unique character and lifestyles” of the area (Graham County 1996). 

Graham County covers 4,650 square miles, making it the 12th largest of Arizona’s 15 counties. In 

addition to 22 square miles of water, the comprehensive plan identifies three basic geologic areas 

within Graham County: (1) the Gila River basin; (2) the mountain areas comprised by the Gila, 

Pinaleño, Santa Teresa, and Galiuro ranges; and (3) the high desert plains north of the Gila and 

Pinaleño Mountains. Graham County is also the home of Aravaipa Canyon and the Gila Box, the 

only two federally designated riparian areas in the United States as of 1996 (Graham County 

1996). 

The Graham County Comprehensive Plan identifies 15 land use zones in the county permitting 

uses from dense residential developments, such as mobile home and travel trailer parks, to 

manufacturing and industrial uses. The plan further classifies these zones into five broad land use 

categories: (1) urban residential, (2) rural residential, (3) agricultural and ranching, 

(4) commercial, and (5) manufacturing. 

Residential Land Use 

The urban residential classification includes single-family residential, manufactured, and mobile 

homes and multiple-family residential uses. Minimum lot sizes range from 5,000 square feet for 

manufactured and mobile homes to 10,000 square feet for multi-family residential parcels. Each 

parcel must be served by an approved domestic water supply system, and parcels less than 

10,000 square feet must also be served by an approved sewage collection and treatment system. 

The rural residential classification applies to agricultural-residential, single-family residential, 

residential recreation, and special development zones. Minimum lot sizes range from 

20,000 square feet for single-family residential uses to 3 acres for special development zones. 

Both light farming and home occupations are permitted in the zones, and approved domestic 

water supply systems are required for parcels less than 1 acre. Parcels in special development 

zones may serve mixed-use purposes, including residential, commercial, and manufacturing 

where a minimum of 3 acres are part of singular or joint-planned developments (Graham County 

1996). 

Commercial and Industrial Land Use 

Commercial land uses in Graham County are classified as commercial recreation, neighborhood 

commercial, or general commercial uses. Minimum lot sizes range from 10,000 square feet for 
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neighborhood and general commercial uses to 1 acre for commercial recreation uses. Rather than 

industrial land use, the Graham County Comprehensive Plan designates its fifth and final 

category as manufacturing land use. This category accounts for commercial manufacturing, 

general manufacturing, and unlimited manufacturing land use zones. Minimum parcel sizes range 

from 1 acre for commercial manufacturing to 5 acres for general and unlimited manufacturing 

zones. The plan stipulates that fencing or screening may be required for lots adjacent to 

nonindustrial uses and that one dwelling unit is allowed per parcel (Graham County 1996). 

There are three incorporated communities in the county: Safford, Thatcher, and Pima. 

Cochise County Comprehensive Plan 

The Cochise County Comprehensive Plan was adopted in 1984 and amended and readopted in 

2015. Like other comprehensive plans throughout the state, it alludes to a rural culture and 

lifestyle largely influenced by traditional land uses such as livestock production, farming, and 

mining. Like other plans in this region, it also states the purpose of assisting residents and 

planners in achieving a balance between urban, rural, and public land uses, which supports the 

protection of both the local economy and the county’s natural resource base. The plan makes 

specific mention of Fort Huachuca as a key player in the county’s history as well as a primary 

contributor to its current economic stability. Rather than a detailed guide to residential, 

commercial, and industrial zoning, the Cochise County Comprehensive Plan sets forth growth 

categories and plan designations, planning guidance for communities, and overall goals policies 

designed to support desired land use patterns in the county. The plan identifies goals and 

supporting policies for 11 elements: land use; affordable housing, neighborhood rehabilitation, 

and enterprise development; agriculture and ranching; economic development; renewable energy; 

federal government coordination; intergovernmental coordination; adequate facilities and service; 

rural character; transportation; and water conservation (Cochise County 2015). 

The plan divides the entire area of Cochise County, with the exception of incorporated cities, into 

four growth-area categories based on the area’s expected capacity for change. Urban growth areas 

(category A) are those that are experiencing an unusually high rate of growth and have the 

infrastructure and service capacity to support it. Community growth areas (category B) includes

transition areas adjacent to urban growth areas and unincorporated areas that are experiencing 

growth. Rural community areas (category C) are smaller rural community areas which 

demonstrate a slow rate of change and community attitudes that favor maintaining the existing 

neighborhood or rural atmosphere. Finally, rural areas (category D) include low growth, sparsely 

populated rural lands in the county that serve primarily as rural residential development and 

agricultural production areas rather than identifiable communities (Cochise County 2015). 

Within each of the growth categories described above, the Cochise County Comprehensive Plan

establishes seven distinct land use designations. The designations are intended to identify the 

existing character of smaller areas within specific growth categories. The “neighborhood 

conservation” designation identifies established areas that are primarily residential and will be 

afforded zoning protection to maintain the desired character and intensity of land use. An 

“enterprise” designation identifies areas with an established pattern of commercial and/or 

industrial land use. A “developing” designation indicates an area experiencing non-rural growth, 

that is expected to continue. It allows flexibility in determining both the character and intensity of 

future development. The “neighborhood rehabilitation” designation is applied to residential 

neighborhoods experiencing deterioration that show potential for revitalization. The “enterprise 
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redevelopment” designation is assigned to existing developed areas undergoing change that may 

be designated for improvement as a commercial or industrial area. The “rural residential” 

designation includes areas in category D (rural) areas with a definite pattern of residential 

development on larger lots, two acres or larger in size. Finally, the “rural” designation include 

those remaining lands in category D (rural) areas that are not designated “rural residential” with 

sparse populations, larger lots, agricultural production or grazing, and similar characteristics 

(Cochise County 2015).

Communities (cities or towns) in Cochise County that are adjacent, or close to, the Coronado 

National Forest are Willcox, Douglas, Portal, Benson, Sierra Vista, Tombstone, Bisbee, St. David, 

Elgin, and Sonoita.

Pima County Comprehensive Plan Update 

The Pima County Comprehensive Plan Update was specifically intended to reflect the land use 

policies, principles, and concepts identified in the Sonoran Desert Conservation Plan. Adopted in 

September 2001, the plan’s purpose is to contribute to the quality of the built environment as well 

as the effectiveness of the conserved environment and improve the status of the region’s fiscal, 

natural, and cultural resources (Pima County 2001). 

Over the last 100 years, Tucson’s urban area has expanded dramatically: from 2 square miles in 

1900, to 10 square miles in 1950, to 100 square miles in 1980, to nearly 200 square miles as of 

2001. Although population levels have experienced a similar increase, population density has not. 

In fact, the Pima County Comprehensive Plan suggests population density has actually declined 

from approximately 5,200 individuals per square mile in 1953 to only 2,400 per square mile 

today. The combined effect of population growth at low densities equates to a land consumption 

rate of nearly 7 square miles a year. At that rate of population growth, the land base of Tucson 

will nearly double over the next 20 years. Acknowledging that the conservation objectives of the 

Sonoran Desert Conservation Plan are not likely to be achieved in metropolitan areas, the 

comprehensive plan focuses its policies on over a million acres of land in unincorporated Pima 

County. Specifically, the comprehensive plan is aimed at responding to a current land market that 

encourages unregulated, leapfrog development, a leading cause of natural resource depletion and 

urban sprawl (Pima County 2001). 

The majority of the population of Pima County resides in the eastern portion of the county, where 

residential units are the primary use in the built environment. Since adoption of the Pima County 

Comprehensive Plan in 1992, residential development has proceeded at lower densities than 

intended, fueled by large-lot development and lot splitting, both of which contribute to continued 

urban sprawl. The comprehensive plan update states that between 1993 and 2000, the county 

received 496 requests for rezoning, 380 of which were approved. Of the 10,988 acres entailed in 

the rezoning requests, 6,480 acres (59 percent) were for residential uses while only 356 acres (3.2 

percent) were for commercial uses (Pima County 2001). 

Residential Land Use 

Regarding residential land use in Pima County, the comprehensive plan focuses on dynamic 

changes in the residential housing market over the last decade. It claims that between 1991 and 

2000, the number of housing units sold in the county nearly doubled while the average sale price, 

expressed in actual dollars, rose from $97,352 to $155,907. Meanwhile, the average square 
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footage of single-family residences has more than doubled since 1950. The plan goes on to 

explain that the local real estate market has benefited higher-income residents of Pima County but 

left an affordability gap for many low-income residents. According to the Tucson Association of 

Realtor’s residential sales statistics, less than 4 percent of all residential units sold in Pima County 

in 2000 were affordable for the lowest earning 20 percent of county residents. Meanwhile, the 

American Community Survey of 2000 found 47 percent of renters in Pima County were spending 

one-third or more of their household income on housing. This lack of affordable housing has 

contributed to detrimental land uses and unregulated development. The comprehensive plan also 

cites studies showing that despite growing more rapidly than many similar counties throughout 

the country, Pima County spent less on a per capita basis, collected less in growth-related fees, 

and provided less affordable housing programs than similarly situated county governments. In

response to these issues, the Pima County Comprehensive Plan Update establishes regional 

policies that create a mixed-use, compact-development land use designation and promote the 

creation of strategies to provide affordable housing to median, low, and very low income level 

households (Pima County 2001). 

The Tucson metropolitan area is adjacent to the Coronado National Forest in Pima County. Other 

communities near the forest are Oro Valley, Green Valley, and Sahuarita.

Sonoran Desert Conservation Plan 

Beginning in 1998, the Pima County Board of Supervisors initiated a review of previous county 

planning efforts with an eye toward integrating effective natural resource management with 

sustainable urban development. Although not a comprehensive plan in the traditional sense, the 

Sonoran Desert Conservation Plan addresses many of the critical land use planning issues 

currently faced by Pima County. Mindful of the distinct correlation between urban growth and 

consumption of natural resources, the Sonoran Desert Conservation Plan serves three primary 

purposes. It creates a science-based conservation plan, it supports the update to the Pima County 

Comprehensive Plan, and it ensures compliance with Federal regulations requiring protection of 

endangered species to be addressed through a multiple species conservation plan. A primary goal 

of the plan is to direct future urban growth in Pima County toward areas with the fewest natural, 

historic, and cultural resource values. In addition to guiding future land use decisions in the 

county, the plan is also intended to serve as a reference for allocation of public resources for 

acquisition of open space and protection of cultural resources. Given the plan’s emphasis on a 

comprehensive analysis of available science and the use of available geographic information 

system (GIS) data, an extensive list of stakeholders is credited with contributing to its 

development (Pima County 2004). 

Critical Habitat and Biological Corridors 

The Sonoran Desert Conservation Plan states that when the process of developing the plan began 

in 1998, basic information on the area’s most vulnerable species, biological standards, and 

distribution of vegetation were not compiled in a format that could serve as a starting point for 

conservation planning. Since that time, an intensive research effort involving members of the 

local, regional, and national science community has resulted in a list of species and maps of 

corridors for 9 mammals, 8 birds, 7 reptiles, 7 plants, 6 fish, 2 amphibians, and numerous 

invertebrates in need of habitat protection. The plan’s science technical advisory team identified 

the following priority habitats and corridors: Altar Valley, Baboquivari Mountains, Cienega 

Creek, Eastern Tucson Riparian Complex, Organ Pipe/Goldwater Complex, Sabino Canyon, San 
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Pedro River, Santa Rita Mountains, Silverbell Mountains, Tortolita Mountains, and Tucson 

Mountains (Pima County 2004). 

Riparian Protection 

The Sonoran Desert Conservation Plan claims that 60 to 75 percent of all species in Arizona rely 

on a riparian environment at some point during their life cycle. This assertion adds urgency to the 

need for riparian protection given that several perennial watercourses in Pima County have 

ceased flowing or have been significantly impacted by lower water tables. In addition to the 

obvious impact from development activities, the plan warns of the negative effects of 

groundwater pumping and the introduction of invasive, nonnative species into the county’s 

riparian areas. The plan cites previous riparian restoration and protection efforts in Cienega 

Creek, Tanque Verde Wash, San Pedro River, and Sabino-Bear Canyon as positive examples of 

conservation strategies that have not only protected wildlife and plants but also provided 

recreational opportunities, promoted groundwater recharge, protected water quality, and mitigated 

flooding. The plan’s science technical advisory team identified the following priority riparian 

resources: Rincon Creek, Cienega Creek, Arivaca Creek, Brown Canyon, Wakefield, Sutherland, 

Happy Valley, portions of San Pedro River, Davidson Canyon, Gardner Canyon, Madera Canyon, 

Agua Verde Wash, and Sopori/Papalote Wash (Pima County 2004). 

Mountain Parks 

The preservation of Pima County’s mountain areas began in 1929 with the establishment of 

Tucson Mountain Park. Since then, similar protection efforts have led to the creation of Tortolita 

Mountain Park, Ironwood Forest National Monument, Colossal Cave Mountain Park, Cienega 

Creek Natural Preserve, and Buehman-Bingham Natural Preserve. Nonetheless, the Sonoran 

Desert Conservation Plan states that a continuing decline in the county’s natural resource base 

shows this incremental approach to conservation over the last 70 years has not adequately 

protected vulnerable habitats and species. The plan’s science technical advisory team identified 

the following priority mountain parks and natural preserves: Buehman-Bingham Natural 

Preserve, Cienega Creek Natural Preserve, Santa Rita Mountain Park, Colossal Cave Mountain 

Park, Davidson Canyon Natural Preserve, Tucson Mountain Park, Catalina State Park, Tortolita 

Mountain Park, and Ironwood Forest National Monument (Pima County 2004). 

Cultural Resources 

The Sonoran Desert Conservation Plan notes Pima County has had a continuous human presence 

for approximately 12,000 years. In an effort to protect the county’s historical and cultural 

resources, the plan identifies numerous archaeological sites, historic buildings, national registers, 

historic communities, ghost towns, and historic trails as worthy of protection. An important task 

in delineating areas and sites for protection involved the development of digital data layers that 

compare core biological, habitat, and riparian areas with specific historic locations to determine 

where they overlap and where they are distributed separately. The Sonoran Desert Conservation 

Plan identified the following priority cultural resources: ancient Native American villages, the 

Mission San Xavier del Bac, Mexican and U.S. territorial-era ranches, Fort Lowell, historic 

mines, existing examples of traditional Sonoran and Victorian architecture, as well as several 

churches, schools, bridges, and parks, many of which lie at the core of the Tucson metropolitan 

area (Pima County 2004). 
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Ranch Conservation 

The Sonoran Desert Conservation Plan credits ranching with having been “the single greatest 

determinant of a definable urban boundary in eastern Pima County,” explaining that over half of 

the county’s 2.4 million acres of open land has been in continual use for the purpose of ranching 

enterprises. Expected benefits of ranch conservation identified by the plan include preservation of 

open space, mitigation of urban sprawl, and maintenance of habitat continuity and the rural 

heritage and culture of the Southwest. The primary threat facing ranchlands is urban 

encroachment and land fragmentation from conversion to real estate development. Ongoing 

drought, legal challenges to grazing leases, and lucrative land prices also contribute to the trend 

of ranch conversion. The Sonoran Desert Conservation Plan states that, currently, ranch 

conversion and fragmentation is greatest within a 25-mile radius of the Tucson urban core. The 

plan identifies a number of “subareas” where ranching comprises a significant proportion of land 

use and is supported by sufficient grazing capacity and stability to support future sustainable 

ranch use. These subareas are Altar Valley, Empire-Cienega Valley, Upper Santa Cruz Valley, San 

Pedro Valley, and the Ironwood Forest National Monument area of Avra Valley. Meanwhile, the 

plan identifies the central Santa Cruz Valley and portions of the Tortolita Fan as areas “least likely 

to retain ranch uses in the future” (Pima County 2004). 

Detailed maps of each of the protection areas under the Sonoran Desert Conservation Plan are 

available for viewing at http://www.co.pima.az.us/cmo/sdcp/maps.html

Pinal County Comprehensive Plan 

The Pinal County Comprehensive Plan stresses the cultural and economic importance of 

managing land use to protect the county’s natural resource base. Traditional land uses such as 

ranching, farming, and mining have experienced a gradual decline throughout the county. An 

increase in urban, commercial, and industrial developments has placed increasing pressure on the 

area’s natural resources. Protection of desert open space, wildlife corridors, and undeveloped 

mountain areas is seen as a critical step toward sustaining a rural lifestyle as well as the 

economically vital components of retirement housing and tourism (Pinal County 2001). 

Currently, Pinal County covers 3,441,920 acres, portions of which lie within the Gila River, AkChin, Tohono O’odham, and San Carlos Native American communities. In addition to several 

rapidly growing incorporated cities and towns, the county is home to the unincorporated 

communities of Arizona City, Dudleyville, Gold Canyon, Maricopa, Oracle, Picacho, Queen 

Valley, Red Rock, San Manuel, and Stanfield. The town of Oracle is adjacent to the Santa 

Catalina Mountains and the Coronado National Forest. The comprehensive plan specifically 

mentions maintenance of mountain views as vital to the long-term economic and environmental 

interests of the county. These mountains include the San Tans, Superstitions, Sierra Estrella, Santa 

Catalina, Table Top, Palo Verde, Casa Grande, Sacaton, Picacho Peak, Sawtooth, Tortolita, Black, 

and Samaniego Hills (Pinal County 2001). 

Adopted in December 2001 and amended in December 2004, the Pinal County Comprehensive 

Plan is seen as an important tool for managing land use during a period of dramatic growth and 

transition. In it, planners call for a reexamination of planning methods in order to ensure the 

sustainability of both the regional economy and standard of living in light of a projected 60 

percent increase in county population over the next decade. Stated objectives in the land use 

element of the comprehensive plan include the following: (1) more efficient land use enabled by 
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clustered development, architectural controls, and development standards; (2) an improved 

county roadway network that effectively links residential and employment centers while retaining 

panoramic views, natural washes, and wildlife habitat; and (3) a diverse mix of employment and 

housing opportunities that balances resource conservation and development needs. The 

comprehensive plan divides land use into several designations. The intent of the land use 

categories is to determine development patterns that will be both economically and 

environmentally sustainable during a period of rapid urban growth (Pinal County 2001). 

“Rural Areas” are areas suitable for lower-density development and uses such as agriculture, 

grazing, mining, sand and gravel operations, large acreage home sites, and small farms. Multifamily development is discouraged in rural areas and single-family residency should not exceed 

one dwelling unit per acre. 

The “Transitional Area” designation is used for areas that are predominantly rural but are 

expected to serve as future centers of growth. A primary purpose of this designation is to retain 

existing large tracts for potential development. Here again, maximum residential density is one 

single-family unit per acre. 

A “Foothill Area” designation is intended to preserve sensitive areas by limiting foothill 

development to low densities that are in harmony with the natural landscape. Maximum density is 

one dwelling unit per acre. 

The “Rural Community Area” designation signifies a rural area with the capacity to provide 

goods, services, and increased residential uses. Growth is typically slower in these areas and is 

dependent on the level of public services, facilities, and infrastructure. Future rural community 

areas should be designed to allow for commercial uses, governmental activity, health and 

educational facilities, industrial uses, and parks and open space. For planned area developments, 

under this designation, the maximum density is three-and-a-half single-family dwelling units per 

acre. This designation also allows for 5 attached homes (town houses, patio homes) per acre or 12 

multiple-family units (apartments) per acre (Pinal County 2001). 

The “Urban Area” designation is applied to areas with higher density residential development and 

the existing infrastructure to support larger populations. Urban areas primarily include towns and 

cities and are likely to account for the majority of future growth in Pinal County. The purpose of 

the urban area designation is to encourage the provision of high quality, efficient public services,

as well as diverse housing and employment opportunities. Maximum density guidelines are 3.5 

dwelling units per acre for planned area developments, 5 dwelling units per acre for attached 

homes, and 12 dwelling units per acre for multiple-family units. 

A “Commercial Activity Center” designation allows intense concentrations of commercial and 

high-density residential development. Land uses include retail stores and services, office 

development, business parks, and high density multi-family development. An expected benefit of 

this designation is the proximate location of housing and employment centers. Multiple-family 

housing density ranges from 12 to 20 dwelling units per acre with an ideal density of 16 dwelling 

units per acre. 

An “Interchange Mix Area” designation caters to the needs of travelers and businesses along the 

county’s highways. Land uses include, but are not restricted to, hotels and motels, vacation 

resorts, restaurants, recreational vehicle (RV) parks, service stations, and other small-scale 

commercial uses. 
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“Corridor Mix Areas” are similar to interchange mix areas in that they provide for a variety of 

land uses and intensities oriented toward and compatible with interstate highways. In addition to 

the land uses prescribed for interchange mix areas, corridor mix areas may include industrial 

parks, research and development facilities, light industry, warehousing, and recreation facilities. 

Open space, landscaping, and noise buffering are encouraged to ensure compatibility with 

adjacent land uses and traffic (Pinal County 2001). 

An “Industrial Area” designation applies specifically to areas suitable for industrial and other 

intense land uses. The plan specifies these areas will be concentrated and separated from 

residential and commercial uses to manage the impacts of heavy truck traffic, noise, vibration, 

light, dust, and odors. 

A “Mining Area” designation applies only to those areas where mineral resources have been 

identified or are likely to be identified in the future. The designation recognizes the rights applied 

to exploration, mining, and mineral resource processing. All mining operations within the county 

are required to comply with Federal, State, and local laws providing environmental protection. 

“Development Sensitive Areas” are intended to preserve natural resources and open space in 

areas that are particularly sensitive. Potential land uses are parks, ranching, livestock grazing,

conservation leases, guest ranches, and single-family uses. Density is not to exceed three-tenths 

dwelling units per acre. 

The “Natural Resource Area” designation is applied to private and public lands which may be 

enhanced by the maintenance of large, undivided parcels. Land uses may include river corridors, 

natural areas, livestock grazing, conservation leases, national forests, wilderness areas, and State 

Trust lands (Pinal County 2001). A detailed map of land use within Pinal County is available at: 

http://www.co.pinal.az.us/PlanDev/PDCP/files/CompPlanFinal2004.pdf 

In June 2015, Pinal County initiated a 60-day review period for major amendments to their 

Comprehensive Plan. Proposed 2015 amendments address health foods, green energy, medical 

marijuana, and a new housing development (Pinal County 2015). 

Santa Cruz County Comprehensive Plan 

Land use patterns in Santa Cruz County have long been shaped by the traditional activities of 

farming, ranching, and mining. Increasingly, however, development in the area is influenced by 

its proximity to the major international border crossing in the city of Nogales and by a burgeoning 

community of retirees. Adopted in June 2004, the Santa Cruz County Comprehensive Plan seeks 

to protect both natural resources and a rich cultural heritage by concentrating and regulating 

future land development (Santa Cruz County 2004). 

Historically, development in Santa Cruz County has been concentrated along the Santa Cruz 

River, a pattern sustained since the construction of Interstate 19, which follows the same northsouth orientation. The comprehensive plan claims that, between 1990 and 2000, the 

unincorporated areas of Santa Cruz County grew by 79 percent while the cities of Nogales and 

Patagonia experienced relatively minimal growth (7 percent and -4 percent respectively). Of all 

the growth in unincorporated areas, 93 percent occurred on the western side of the county along 

the I-19 corridor in the communities of Amado, Tubac, Rio Rico, and south to Nogales city limits. 

It is expected that development over the next decade will continue to be concentrated along this 
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corridor. The Santa Cruz County Comprehensive Plan projects a high rate of population growth 

(6.5 percent per annum through 2010) resulting from natural increase as well as substantial 

immigration from other areas (Santa Cruz County 2004). In anticipation of this growth trend, the 

comprehensive plan includes a specific element devoted to county growth areas. There are 7 

growth areas, each located west of the Santa Rita Mountains: the airport, Amado, the I-19 

Corridor (Rio Rico to Nogales), the Kino Springs Village Center, Rio Rico Drive East, Ruby 

Road, and Tubac. 

Given the likelihood for continued population growth and the resulting need for residential and 

commercial development, Santa Cruz County intends to concentrate future land use in a way that 

maintains a rural character, protects natural resources, and makes efficient use of existing and 

future infrastructure. While the comprehensive plan claims the county has a substantial amount of 

private, undeveloped land which is easily accessible from primary roadways, future growth is 

likely to have a pronounced impact on the county’s natural resources and existing development 

patterns. For instance, new development in the county has begun to shift from individual homes 

constructed on private lots to production housing. In the past 5 years, approximately 30 percent of 

requests for residential rezoning were for parcels larger than 100 acres. Of these, over 40 percent 

are at densities exceeding 4 dwelling units per acre. In response, the plan encourages maintaining 

existing land use intensities and densities in the Sonoita-Elgin area while allowing urban-style 

development in the Rio Rico area and, to some extent, around Tubac and Kino Springs. 

According to the plan, future employment centers will be focused south of Rio Rico along the I19 corridor, and commercial uses specific to the county’s tourism industry will be encouraged at 

the Sonoita crossroads of SR 82 and SR 83 (Santa Cruz County 2004). 

Based on the clear demarcation of land uses along the I-19 corridor and those in other locations 

throughout the county, the land use element of the comprehensive plan refers to two general types 

of land use intensities and densities: urban and rural. The land use categories described under 

each of these two classifications are described below. 

Rural Land Use 

The “Ranch 40” category signifies very low-density residential, ranching, agricultural, 

viticultural, low-impact tourism, or resource conservation uses. Maximum residential density in 

this category is 1 dwelling unit per 40 acres. A “Ranch” designation allows the same land uses as 

Ranch 40; however, in this category, maximum residential density is greater: 1 dwelling unit per 4 

acres. The “Public Lands” category includes all Federal public land managed by the Department 

of Agriculture and the Department of the Interior, as well as State lands managed by the State 

Parks Department. Land use in the “State Trust” category includes grazing and conservation as 

well as other uses in accordance with regulations of the State Land Department. Principle land 

uses in the “Preservation” category include historic sites, museums, research study areas, and 

permanent open space. Residential and light commercial uses related to the principle preservation 

function are also permitted. The “Local Services” designation is applied to areas whose primary 

land use includes retail, restaurants, tourism services, and low-impact neighborhood services 

(Santa Cruz County 2004). 

Urban Land Use 

Principle land uses in the “Low Density Residential” category include residential use as well as 

low-intensity tourism services, restaurants, and neighborhood services. Maximum residential 

density in these areas is 1 dwelling unit per acre. “The Medium Density Residential” category 
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allows residential, office, and commercial services with a maximum density of 3 dwelling units 

per acre. The principle land uses in the “High Density Residential” areas include residential, 

retail, office, and commercial services. Maximum density for single- and multi-family residences 

in this category is 10 dwelling units per acre. In the “Mixed Use” category, high-density 

residential uses are integrated with retail, services, and employment uses in areas accessible to 

infrastructure and public services. Maximum residential density in the mixed use category is 10 

dwelling units per acre. The “Regional Services” designation is applied to areas where the 

primary uses are high-intensity commercial, employment, and retail uses, which are regionally 

significant and are easily accessible from major transportation corridors and population centers. 

The primary land uses in the “Enterprise” category are heavy commercial and industrial 

enterprises with major employment potential. This category is situated to take advantage of 

facilities and major transportation corridors. 

A detailed map of land use in Santa Cruz County is available at http://scc-mail.co.santacruz.az.us/commdev/commdev1/Santa%20Cruz%20County%202004%20Comprehensive%20Pla

n.pdf 

Cities and towns in Santa Cruz County adjacent or close to the Coronado National Forest are

Nogales, Amado, Patagonia, and Arivaca.

Hidalgo County Comprehensive Plan

Hidalgo County is a sparsely populated, primarily agricultural area in the southwestern corner of 

New Mexico. Adopted in 2004, and updated and readopted in 2011, the Hidalgo County 

Comprehensive Plan identifies and analyzes growth and development issues and establishes a 

framework of community values, goals, and strategies to guide development over the next 20 

years. The plan defines a community vision and describes the seven elements of land and water, 

economic development, housing, transportation, infrastructure/community facilities, hazards 

mitigation, and implementation. For each element, existing conditions and issues are identified 

followed by values, goals, and implementation strategies (Hidalgo County 2011).

Communities (cities or towns) in Hidalgo County, New Mexico that are adjacent or near the 

Coronado National Forest include Rodeo and Cloverdale.

Conclusion for Counties

The Coronado revised forest plan would not conflict with the overall mission or goals of these 

counties or their plans.
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Community Wildfire Protection Plans 

Currently, six community wildfire protection plans outline goals for at-risk communities in and 

around the Coronado National Forest:

• Arivaca Sasabe Community Wildfire Protection Plan – November 2007

• Catalina Community Wildfire Protection Plan – September 2008

• Graham County Community Wildfire Protection Plan – November 2005

• Mount Lemmon Wildland-Urban Interface Plan for Forest Health Wildland Fire Management 

– July 2004

• Pinal County Community Wildfire Protection Plan – February 2009

• Sonoita Elgin Community Wildfire Protection Plan – December 2007

Community wildfire protection plans are developed by communities in response to the Healthy 

Forests Restoration Act of 2003 (HFRA). HFRA requires Federal agencies to collaborate with 

communities in developing hazardous fuel reduction projects and places priority on treatment 

areas identified by communities through the development of a community wildfire protection 

plan. A primary objective of a community wildfire protection plan is to help local governments, 

fire departments and districts, and residents identify at-risk public and private lands to better 

protect those lands from severe wildfire threat. Additional functions of a community wildfire 

protection plan are to improve fire prevention and suppression activities and identify funding 

needs and opportunities to reduce the risk of wildfire and enhance public and firefighter safety. 

Identifying at-risk areas and improving fire protection capabilities helps the communities to 

prioritize high-risk projects and expedites overall project planning. These plans are used by 

Coronado National Forest land managers to help prioritize areas for hazardous fuel reduction 

treatments adjacent to at-risk communities.

The Coronado revised forest plan would not conflict with the overall mission or goals of these 

plans.

Fire Management Plans 

The Coronado is bordered by other Federal land agencies that are required to have a fire 

management plan in place. Existing plans include:

• Saguaro National Park Fire Management Plan (July 2007)

• Coronado National Memorial Fire Management Plan (June 2005)

• Bureau of Land Management Safford-Tucson Fire Management Zone Fire Management Plan 

(September 2004)

Interagency Federal fire policy requires that every area with burnable vegetation must have a fire 

management plan. The plan provides information about the fire process for each land 

management agency and compiles guidance from existing sources such as land and resource 

management plans, national policy, and national and regional directives. Although agencyspecific guidance and direction may differ between agencies, the fire management plans listed 

above do not conflict with land management on the Coronado.
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The Coronado revised forest plan would not conflict with the overall mission or goals of these 

plans.

Tribes

Federally recognized American Indian tribes occupy about 53.5 million acres (7 percent) of land 

in the western states. The San Carlos Apache Reservation borders the north side of the Coronado 

National Forest. Tribes are legally considered to be sovereign nations, so the relationship between 

the Forest Service and the tribes is a government-to-government relationship. Tribes that enter 

into contracts with the Federal Government do so just as state governments or sovereign nations 

do.

However, the Federal Government also holds a special responsibility to consult with tribes over 

management issues that may affect them. This process is governed by a variety of Federal 

regulations and policies, including Forest Service Handbook 1509.13, the National 

Environmental Policy Act, the National Indian Forest Resources Management Act, the Tribal 

Forest Protection Act, the Archeological Resources Protection Act, and several presidential 

executive orders.

Tribes’ use of National Forest System land includes free, nonpermitted activities such as 

gathering boughs and basket materials as well as the use of products such as sawtimber. In 

addition, the Coronado National Forest includes traditional cultural places, the locations of which 

are known only to the tribes.

San Carlos Apache Tribe (Nde Nation)

Forest Management

A review of the San Carlos forestry website indicates that the tribe has a forest resources 

program, including timber sales, thinning, woodcutting, and fire activities.

Recreation and Wildlife

A recreation permit is required for nonmembers and allows entry on the reservation for any 

recreational activities (hike, picnic, tour, camping), other than hunting or fishing.

Wildlife resources include Rocky Mountain elk, Coues white-tailed deer, Rocky Mountain 

bighorn sheep, desert bighorn sheep, javelina, pronghorn antelope, black bear, mountain lion, 

wild turkey, predators, and other small game. The Drylake and Hilltop trophy elk units are 

managed for older age structure and have produced some of the largest elk in the world. 

Transportation

Information on transportation issues on the San Carlos Apache Reservation can be requested 

through the Intertribal Council of Arizona’s Transportation Working Group.

The Coronado revised forest plan would not conflict with the overall mission or goals of the San 

Carlos Apache Tribe or their plans.
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State of Arizona

Arizona Department of Environmental Quality

The Arizona Department of Environmental Quality’s mission is to protect and enhance public 

health, welfare, and the environment in Arizona. The agency serves as the State’s environmental 

regulatory agency in the areas of air and water quality and waste programs. Forest management 

activities strive to be in compliance with the applicable Arizona revised statutes (particularly Title 

49, which outlines specifics such as water quality standards and total maximum daily loads).

Arizona Department of Water Resources

The Arizona Department of Water Resources mission is to secure long-term dependable water 

supplies for Arizona. The department administers and enforces the State’s groundwater code and 

surface water rights laws. Title 45 of the Arizona revised statutes contains the provisions related 

to water and groundwater resources.

Arizona Department of Agriculture

The Arizona Department of Agriculture is the State’s regulatory agency for agriculture, including 

animals, plants, and environmental services. Title 3 of the Arizona revised statutes contains the 

provisions related to agricultural topics such as dangerous plant pests and diseases, pesticides, 

brands and marks, and seizure of livestock. 

Arizona Department of Transportation

The Arizona Department of Transportation (ADOT) is responsible for planning, building, and 

operating a state highway system and maintaining bridges. 

Improvement and Construction

The State Transportation Improvement Program (STIP) for Fiscal Years 2015-2019 was approved

in November 2014, and the 2015-2019 Five-year Transportation Facilities Construction Program

was approved in June 2014 (ADOT 2015). These documents identify priority and planned 

improvements and construction over the next five years. A variety of planned construction, 

improvements, and rehabilitation projects associated with the following highways may affect 

forest management:

• Interstates 10 and 19

• U.S. Highways 70 and 191

• State Routes 75, 77, 80, 82, 86, 90, 92, and 189

Long Range Planning

In May 2012, the Arizona Department of Transportation, the U.S. Forest Service Southwest 

Region, and the Central Federal Lands Highway Division approved and implemented the 2011 to 

2030, Arizona Forest Highway Long Range Transportation Plan. The plan gives the description 

and goals of the long range program of the Arizona Forest Highway Program. The guiding 

principles include access and mobility, economic vitality, safety, stewardship, and environmental 
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sensitivity. The plan provides a project selection process and funding and investment strategies to 

ensure that the forest highways are maintained.

The ADOT Long-Range Transportation Plan 2010 – 2035 was completed in November 2011 

(ADOT 2011). Key goals and strategies of the plan include:

• Improve Mobility and Accessibility – Implement critical and cost-effective investments in 

infrastructure to expand access to transportation, and optimize mobility and reliability in the 

transportation of passengers and freight.

• Preserve and Maintain the System – Maintain, preserve, and extend the service life of 

existing and future State transportation system infrastructure.

• Link Transportation and Land Use – Protect the capacity of the State transportation system 

by developing policies and partnerships that strengthen the coordination of land use and 

transportation planning and implementation. Objectives focus on coordinating with public 

agency land use planning.

• Support Economic Development – Develop and operate a State transportation system that 

provides predictable freight and people movement throughout the State to support a 

competitive and thriving economy for Arizona.

• Enhance Safety and Security – Continue to improve transportation system safety and ensure 

the security of the transportation system. Objectives are to maintain and enhance 

transportation safety, reducing crashes, injuries, and fatalities.

• Promote Natural, Cultural, and Environmental Resources – Protect and restore the 

natural, cultural, environmental resources of Arizona while improving and maintaining the 

transportation system. Objectives include: implement transportation solutions that improve 

mobility, enhance communities, and protect and restore the environment; implement an 

ecological connectivity approach to transportation planning and system development; 

collaborate with government agencies and other stakeholders to identify and consider natural 

habitats, the human environment, and protected natural or cultural resources when planning 

new or improved transportation services.

• Promote Fiscal Stewardship – Provide a sound financial base for Arizona’s transportation 

system through responsible management of public assets and resources, and identification 

and implementation of funding strategies to ensure long-term balanced investment in the 

State’s transportation system.

• Strengthen Partnerships – Develop and nurture partnerships that support coordination and 

integration of the Arizona Department of Transportation planning and investment in State 

transportation infrastructure with public and private organizations and agencies responsible 

for land use, conservation, and environmental planning, and freight infrastructure.

Scenic Byways

The Arizona Department of Transportation’s environmental and enhancement group prepared the 

Coronado Trail Corridor Management Plan in March 2005. This plan identifies the goals and 

objectives for the byway corridor.
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Arizona Game and Fish Department

The Arizona Game and Fish Department’s (AGFD) Strategic Plan for the Years 2007-2012 

Wildlife 2012 provides management direction for the department’s program of work. The plan 

contains several goals and objectives that may have an impact on Coronado National Forest 

management:

• Wildlife Resource Management: Conserve, preserve, enhance, and restore wildlife 

populations and their habitats.

♦ Conserve, preserve, enhance, and restore Arizona’s wildlife habitat and resources while 

balancing resource needs with recreational uses.

♦ Maintain or improve the quality and connectivity of habitats to support a diversity of 

wildlife species. 

♦ Minimize the negative impacts of invasive species on wildlife and their habitats. 

♦ Improve the status of wildlife, with particular emphasis on those species listed as 

Species of Greatest Conservation Need.

♦ Provide for sustainable use of wildlife by people.

• Wildlife Recreation – Increase the opportunity for the public to enjoy Arizona’s wildlife 

resources, while maintaining and improving wildlife resources. In addition, address the 

underlying reasons for denial of public access across private lands by providing technical and 

financial assistance to private land owners and educating the public about ethical use and 

habitat protection.

♦ Encourage continued compliance with regulations governing wildlife-related 

recreational activities.

♦ Promote public safety during wildlife-related recreation activities.

♦ Increase opportunities for use and enjoyment of wildlife.

♦ Increase participation in wildlife-oriented recreational activities.

♦ Provide access to public and other lands that are blocked by private lands.

• Public Awareness, Support, and Involvement - Maintain an informed and supportive public 

that recognizes its ownership and stewardship responsibilities for wildlife resources and helps 

to disseminate and act upon messages about watercraft safety and the safe, responsible, and 

ethical use of off-highway vehicles.

♦ Increase public awareness and support of the North American Model of wildlife 

management. The North American Model asserts that wildlife is held in public trust —

not owned by any one person or entity, regardless of whether the animal is on public or 

private land or water. Professionals manage wildlife based on the overall public good.

♦ Increase the percentage of the public that identifies the department as the State agency 

responsible for wildlife management in Arizona.

♦ Promote the widespread use of environmental education curriculum in public, private, 

charter, and home schools.

♦ Improve media and e-newsletter communication.

♦ Increase efforts to inform the public about living responsibly with wildlife.
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♦ Increase participation in hunter education, aquatic education, boating safety education,

and shooting sports programs.

• Off-Highway Vehicle, Watercraft, and Shooting Sports Recreation Goals - Increase the 

opportunity for the public to enjoy shooting sports. Encourage participation in education and 

information programs supporting safe and responsible use of off-highway vehicles and 

watercraft, while maintaining or improving wildlife resources and habitats.

♦ Encourage continued compliance with regulations governing watercraft, off-highway 

vehicle, and recreational shooting sports activities.

♦ Reinforce public safety during watercraft, off-highway vehicle, and recreational 

shooting sports activities.

♦ Increase management of off-highway vehicles and efforts to minimize their impacts on 

wildlife and wildlife habitat.

♦ Improve the watercraft recreational experience.

♦ Minimize impacts to aquatic resources from increased watercraft use.

♦ Increase participation in boating safety education and shooting sports programs.

♦ Continue to work with interested user groups and agencies to protect existing funding 

and acquire new funding sources dedicated to safe and responsible off-highway vehicle 

use.

• Customer Diversity – Increase customer diversity to better reflect the demographics of 

Arizona.

♦ Increase the diversity of department customers (culture, ethnicity, sex, age, income, and 

ability).

• Partnerships - Maintain and develop effective partnerships that enable the department and 

its partners to reach mutual goals.

♦ Enhance the department’s ability to manage wildlife resources.

♦ Reinforce responsible and safe OHV and watercraft recreation that minimizes impacts 

on wildlife resources and habitats.

♦ Provide recreational shooting opportunities through partnerships.

The Arizona State wildlife action plan, titled “Arizona’s Comprehensive Wildlife Conservation 

Strategy: 2005-2015,” was approved in 2006 and provides the vision for managing Arizona’s fish, 

wildlife, and wildlife habitats over the next 10 years. The plan contains several key elements

which may provide information to, or have an impact on, Coronado National Forest management:

• Species of Greatest Conservation Need – The Arizona Game and Fish Department

prioritized a list of species for conservation actions aimed at improving conditions for those 

species through intervention at the population or habitat level. Over 300 species were 

identified as being vulnerable or the species with the greatest conservation needs.

• Habitats of Greatest Conservation Need – The Arizona Game and Fish Department divided 

the state into 17 vegetation types. All of these habitats were treated as habitat in need of 

conservation. A statewide habitat analysis that answers the question of where to focus in each 

habitat has not been completed.
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• Stressors/Threats to Arizona’s Wildlife and Wildlife Habitats – The Arizona Game and 

Fish Department identified 70 stressors that have serious impacts to habitat in Arizona and an 

additional 4 stressors that act on species alone. The stressors were categorized into: a rapidly 

increasing human population, changes to water storage and delivery systems in the 

Southwest, alteration of communities by invasive nonnative species, and the ongoing drought 

and warming trend.

• Conservation Actions for Arizona’s CWCS – The Arizona Game and Fish Department

identified several action items to address stressors, these action items will be implemented 

where feasible and appropriate.

♦ Conserving Wildlife Habitat

 Promote the restoration and protection of aquifers, springs, streams, rivers, lakes, 

and riparian systems. Support regulations ensuring minimum instream flow and 

water rights for wildlife resources.

 Perform landscape classification analyses to identify sensitive habitats, core 

wildlife areas, and important wildlife corridors.

 Acquire ecologically important lands, access agreements, conservation easements, 

water rights, or some combination of these things.

 Support State planning efforts to address drought issues as they relate to wildlife 

resources.

♦ Maintaining and Reestablishing Habitat and Habitat Connectivity

 Promote maintenance and restoration of habitat connectivity by removing or 

modifying barriers, protecting corridors and riparian areas, and using wildlifefriendly roadway crossing structures.

 Promote maintenance and restoration of habitat connectivity by removing 

unneeded fences, by using wildlife-friendly barriers in future projects and when 

replacing old fences.

 Develop standards for new road, utility and power lines construction, and 

modification of existing structures and corridors to reduce impacts to wildlife.

♦ Wildlife Management

 Promote implementation of recovery plans, habitat conservation plans, and other 

cooperative agreements for sustaining wildlife resources. Develop plans to 

conserve priority conservation species (focal community; responsibility, and 

vulnerability categories) that are not sufficiently addressed under existing plans.

 Manage so as to sustain or enhance sport fish and native fish populations.

 Develop contingency plans for rapid salvage of wildlife populations threatened 

with extirpation in situations of imminent habitat loss.

 Maintain and construct new wildlife water developments. Encourage conversion of 

livestock waters so they are also continuously usable by wildlife.

 Collaborate with partners to evaluate sampling techniques, reduce duplication of 

effort, and develop pathogen decontamination protocols to limit impacts to 

wildlife.
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 Collaborate with partners on disease/pathogen/parasite issues to wildlife including 

development of action plans to manage existing sources, identify, and respond to 

new threats, and to educate the public.

 Evaluate, update, and enforce existing department regulations to address evolving 

concerns about hybridization, nuisance animals, illegal stocking, and spread of 

animals used for bait.

 Reduce/eliminate the effects of feral animal populations in sensitive habitats or 

near wildlife populations of concern.

♦ Public Education and Law Enforcement to Benefit Wildlife and Wildlife Habitat

 Educate the public about the impacts of free-ranging or feral animals, release of 

nonnative species, and illegal stocking of fish and live bait on wildlife resources. 

Increase enforcement of existing laws and promote more stringent laws prohibiting 

the release of domestic or nonnative animals into the wild.

 Utilize education and enforcement to promote human behavior that does not 

encourage wildlife to become a nuisance (for example: feeding wildlife, securing 

waste containers, and storage of food). Increase awareness of effects of feeding 

and litter on wildlife.

 Increase public awareness of how water conservation and ensuring instream flow 

can benefit wildlife.

 Encourage the use of low water use native plants in landscaping.

 Educate the public regarding identification of contaminants, release prevention, 

and impacts to wildlife and habitats. Promote alternatives that reduce release of 

contaminants.

 Encourage cooperative cleanup efforts of wildlife habitats.

 Increase public awareness of the potential effects of various types of recreation on 

wildlife resources. Encourage responsible outdoor recreation through education 

(for example: “Stay on the Trails,” “Leave No Trace,” “Be Bear Aware,” “Stop 

Aquatic Hitchhikers”), enforce existing laws, and encourage development of new 

legislation.

 Inform the public and land management agencies on the effects of illegal harvest 

of wildlife. Cooperate with land management agencies to increase enforcement of 

existing laws.

 Support prevention and suppression of accidental or arson-caused wildfire through 

information and education and enforcement of appropriate regulations.

 Educate the public on the importance of community focal species (including 

predators, prey, wide-ranging species, keystone species, etc.) for ecosystem health.

♦ Representing Wildlife Values in Multiple-Use Planning

 Provide recommendations to State and Federal partners on the development of new 

land management plans or revising existing plans as they relate to wildlife 

resources.

 Cooperate with State, Federal, tribal, and local government partners to develop and 

implement watershed management plans that incorporate wildlife and habitat 

values.
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 Prevent loss and degradation of sensitive habitats through involvement of planning 

efforts with local governments, private land owners, and agency and tribal land 

managers.

 Promote restoration of natural fire regimes for improving grassland and forest 

health.

 Promote adoption of sustainable forage management standards and guidelines for 

livestock and wildlife.

 Promote conservation of sensitive areas and habitats for wildlife.

 Encourage development and implementation of standards and guidelines for 

mining and landfill operations that consider the needs of wildlife resources.

 Encourage land management agencies to manage road and trail networks to ensure 

sustainable wildlife resources in balance with recreational opportunities, economic 

pursuits, and rural development.

 Coordinate with land managers, counties, municipalities, and private sector 

partners to promote ecologically sensitive design of recreational facilities such as 

campgrounds, parks, golf courses, ski resorts, etc.

♦ Representing Wildlife Values in Other Processes

 Coordinate to reduce impacts to wildlife along the U.S.-Mexico border.

 Encourage the operation of dams, canals, and diversions for improving or 

maintaining wildlife resources. Promote wildlife values in building new, 

renovating existing, or removing old water retaining structures.

 Promote programs for eliminating or limiting the spread of invasive plants and 

animals, and the recovery or reintroduction of native populations.

 Limit the spread of invasive plants and promote the restoration of native vegetation 

in disturbed areas.

 Support land management and regulatory agencies in enforcing best management 

practices to prevent the introduction of toxins into ecosystems.

 Promote the use of engineered wetlands, discharge basins, and augmented riparian 

vegetation to pretreat water prior to release into riparian systems. Promote the use 

of treated effluent to create wildlife habitat.

 Cooperate with land management agencies and municipalities on revising waste 

management plans to minimize impacts to wildlife resources.

Arizona State Land Department

The practice of allocating public lands for various beneficiaries in Arizona dates back to the 

founding of the territory in 1863. The current system of managing these lands, referred to as State 

Trust lands, was established with the Arizona State Land Department (ASLD) in 1915. 

Since its inception, the Arizona State Land Department has been granted authority over all trust 

lands as well as the natural products they provide. This authority over trust land is central to the 

department’s primary mission of maximizing revenues for its beneficiaries, a role that 

distinguishes it from other agencies charged with management of public lands (national parks, 

national forests, state parks, etc.). 
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As of 2008, the Arizona State Land Department managed over 9 million acres in land holdings 

for 14 beneficiaries, the most prominent of which is the K-12 public school system. Most of the 

State lands can be used for livestock grazing purposes only. Public use of the lands is regulated by 

permit. Recreational permit allows the signatory limited privileges to use State Trust Land for 

some recreation. Recreation under this permit is limited to hiking, horseback riding, picnics, 

bicycling, photography, sightseeing, and bird watching. Camping is restricted to no more than 14 

days per year. Off-highway vehicular travel on State Trust land is not permitted without proper 

licensing.

The Arizona State Land Department may dispose of (exchange) or lease the lands for natural 

resource use or commercial development purposes. Since State lands border much of the forests, 

any changes in management could affect management of the Coronado National Forest, 

especially for public access. The department prepares a 5-year plan that represents potential areas 

of concern to initiate land sales and long term leases. As of August 2017, this plan was not 

available. 

Arizona State Parks

The mission of Arizona State Parks is to manage and conserve Arizona’s natural, cultural, and 

recreational resources for the benefit of the people, both in our parks and through our partners 

(Arizona State Parks 2010). 

Arizona State Parks manages numerous parks across Arizona. Five of these parks are near or on 

the Coronado National Forest: Catalina State Park, Oracle State Park, Kartchner Caverns State 

Park, Sonoita Creek State Natural Area, and San Rafael State Natural Area. Catalina State Park is 

located on National Forest System land on the Coronado National Forest and is operated by 

Arizona State Parks.

Arizona State Parks have seen a continual increase in visitation over the years, with over 

1,000,000 visitors in 1985 to over 2,000,000 visitors in 2010 (Arizona State Parks 2010). The 

State and national financial crisis impacted the management of state parks. In fiscal year 2010, 

Arizona State Parks reduced the number of employees and closed 13 of its 28 parks (Arizona 

State Parks 2010).

The 2008 Arizona Statewide Comprehensive Outdoor Recreation Plan (SCORP) identifies the 

State’s outdoor recreation priorities. The priority issues include: secure sustainable funding; plan 

for growth and secure open space; resolve conflicts; improve collaborative planning and 

partnerships; respond to the needs of special populations and changing demographics; fill the 

gaps between supply and demand; secure access to public lands and across State Trust lands; 

protect Arizona’s natural and cultural resources; communicate with and educate the public 

(Arizona State Parks 2007). Several action items have the potential to influence National Forest 

System lands:

• Look holistically across geographic boundaries, disciplines, governments, private interests, 

and generations, and examine all benefits and costs, not just fiscal costs (in reference to 

growth).

• Expand options such as private land owner incentive programs and recreational liability laws, 

which would allow public access across private and State and Federal leased lands.
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• Provide for off-highway vehicle use on public lands but manage it properly, to reduce 

conflicts with other recreation users and minimize the activity’s impacts on natural and 

cultural resources, as is done for other recreational activities. Implement standards for 

constructing sustainable off-highway vehicle routes, involve user groups in planning, 

building, and maintaining satisfactory routes and facilities, and enact and enforce consistent 

off-highway vehicle laws and regulations.

• State and Federal agencies should implement coordinated interagency planning efforts for 

new recreational areas and trail systems to ensure an equitable regional distribution of desired 

recreational opportunities and access to natural environments.

The Statewide Comprehensive Outdoor Recreation Plan also identifies the major impacts and 

trends related to outdoor recreation in Arizona. Arizona offers a wide variety of outdoor 

recreation opportunities with 6 national forests, 21 national park sites, 8 national wildlife refuges, 

8 Bureau of Land Management field offices, 21 Indian tribes, 30 State parks, 23 State wildlife 

areas, and hundreds of county and city parks and recreation areas. These public lands provide 

opportunities for activities such as picnicking, developed and primitive camping, wilderness 

backpacking, hiking, mountain biking, horseback riding, cross-country skiing, wildlife watching, 

hunting, fishing, boating, water skiing, rock climbing, four-wheel driving, motorized trail biking, 

all-terrain vehicle riding, and snowmobiling, among others (Arizona State Parks 2007).

The “Arizona Trails 2010: State Motorized and Nonmotorized Recreation Trails Plan” provides 

information and recommendations to guide Arizona State Parks and other agencies in their 

management of trails. The priority recommendations for motorized trails are: protect access to 

trails/acquire land for public access; maintain and renovate existing trails and routes; mitigate and 

restore damage to areas surrounding trails, routes, and areas; and establish and designate 

motorized trails, routes, and areas. The priority recommendations for nonmotorized trails are

maintain existing trails, keep trails in good condition; and protect access to trails and acquire land 

for public access (Arizona State Parks 2009).

Conclusion for State of Arizona

The Coronado revised forest plan would not conflict with the overall mission or goals of the State 

of Arizona, its agencies, or plans.

State of New Mexico

New Mexico Environment Department

The New Mexico Environment Department’s mission is to protect and restore the environment, 

and to foster a healthy and prosperous New Mexico for present and future generations. The 

agency serves as the State’s environmental regulatory agency in the areas of air and water quality 

and waste programs. Forest management activities strive to be in compliance with the applicable 

New Mexico statutes, particularly Title 20, which outlines water quality standards and total 

maximum daily loads.
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New Mexico Office of the State Engineer/Interstate Stream 

Commission

The New Mexico Office of the State Engineer is charged with administering the state's water 

resources. The State Engineer has authority over the supervision, measurement, appropriation, 

and distribution of all surface and groundwater in New Mexico, including streams and rivers that 

cross state boundaries. The Interstate Stream Commission has broad authority to investigate, 

protect, conserve, and develop New Mexico’s waters including both interstate and intrastate 

stream systems. The commission is also authorized by statute to investigate and develop the water 

supplies of the state and institute legal proceedings in the name of the state for planning, 

conservation, protection, and development of public waters. Title 20 of the New Mexico statutes 

contains the provisions related to water and groundwater resources.

New Mexico Department of Agriculture

The New Mexico Department of Agriculture is the State’s regulatory agency for agriculture, 

including animals, plants, and environmental services. Title 21 of the New Mexico statutes 

contains provisions related to agricultural production such as dangerous plant pests and diseases, 

pesticides, brands and marks, and seizure of livestock. 

New Mexico Department of Transportation

The New Mexico Department of Transportation (NMDOT) is responsible for planning, building, 

and operating a state highway system and maintaining bridges. The New Mexico Department of 

Transportation Multimodal Transportation Plan contains direction for transportation and tourism. 

Multidisciplinary partnerships exist between State, Federal, local and tribal entities, and 

nongovernmental organizations concerned with environmental and cultural resource protection, 

tourism, economic development, and transportation. The current 2030 plan includes goals and 

objectives to combine scenic byways with state bicycle routes where appropriate to enhance

recreation and tourism potential. The New Mexico Tourism Department is promoting green 

tourism, including scenic byways, mountain bike, equestrian, and hiking access points among 

transportation-related infrastructure.

The Coronado National Forest in New Mexico is in the Southwest Regional Planning 

Organization. Under the new 2040 Transportation Plan (currently in draft, see discussion below), 

there are no transportation goals or objectives directly related to Coronado National Forest land 

management. Further, there are no scenic byways in the vicinity of the Coronado National Forest 

in New Mexico (NMDOT 2015).

Improvement and Construction

The Statewide Transportation Improvement Program (STIP) for Fiscal Years 2014-2017 was 

completed in July 2015. This document identifies planned improvements and construction over 

the next several years. The planned improvements to the following highways may affect forest 

management:

• Interstate 10 – FY2016 Pavement preservation and ramp reconstruction (from Lordsburg W. 

to 1 mile east of Lordsburg E. – NE of road forks)

• Interstate 10 – FY2015 Bridge preservation and approaches, roadway reconstruction, 

pavement preservation and drainage (5 miles west of Hidalgo/Grant County line)
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• Interstate 10 – FY2015 Bridge deck replacement (4 miles east of Lordsburg)

• Interstate 10 – FY2014 Bridge preservation (various National Highway System routes in 

Hidalgo County)

• Interstate 10 – Install roadway weather information system and sensors, conduct land 

management tests and establish land strips to reduce dust (from Arizona state line to junction 

with I-25 in Hidalgo County)

Long Range Planning

The New Mexico Department of Transportation is currently updating their long-range statewide 

transportation plan, the New Mexico 2040 Transportation Plan. As of May 2015, the goals and 

objectives of the plan were in draft form and undergoing public review. The full plan is scheduled 

for completion by October 2015. Key goals and strategies of the plan include:

• Operate with Transparency and Accountability – Build trust and leverage external support 

for transportation initiatives by coordinating early, often, and successfully with Federal, State, 

regional, Tribal, local, and other agencies to plan, fund, and implement projects and 

programs.

• Improve Safety for All System Users – Reduce fatalities and serious injuries through datadriven, innovative, and proactive processes that include examination of safety hot spots and 

systemic safety concerns.

• Preserve and Maintain our Transportation Assets for the Long Term – Develop and 

implement a “preservation-first” asset management strategy to ensure that the New Mexico 

Department of Transportation will maintain all existing and future elements of the state’s 

transportation system in a state of good repair.

• Provide Multimodal Access and Connectivity for Community Prosperity – Prioritize 

projects, programs, and activities that help minimize transportation infrastructure and service 

costs through coordination of transportation and land use planning (including site selection 

for public facilities).

• Respect New Mexico’s Cultures, Environments, History and Quality of Life - Minimize 

or avoid negative impacts of facility development and operations on the natural environment, 

where possible. Work proactively with public and private-sector partners to advance state, 

regional, and Tribal tourism and recreational goals while minimizing adverse impacts to 

cultural resources.

New Mexico Department of Game and Fish 

Forest plan revision on the Coronado National Forest considered and utilized results from the 

comprehensive wildlife conservation strategy for New Mexico. This strategy was developed by 

the New Mexico Department of Game and Fish. The focus of the strategy is on species of greatest 

conservation need and key wildlife habitats. The comprehensive wildlife conservation strategy

assessed the condition of key habitats, species of greatest conservation need, problems affecting 

species and habitats, desired future conditions, and prioritized conservation actions and 

monitoring needs. The overriding desired outcome is that the key habitats persist in the condition, 

connectivity, and quantity necessary to sustain viable and resilient populations of resident species 

of greatest conservation need and host a variety of land uses with reduced resource use conflicts. 
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The strategy’s desired outcomes were designed to conserve indigenous threatened or endangered 

wildlife and habitats to assure biodiversity. 

In developmental stages of Coronado National Forest plan revision, the comprehensive wildlife 

conservation strategy was referenced and high priority species of greatest conservation need were 

included in the species lists identified for the Coronado’s plan revision and then evaluated for 

viability.

Development of plan components is a process and outcome similar to comprehensive wildlife 

conservation strategy development and desired outcome determination. Coronado National Forest

personnel evaluated ecological sustainability through assessing vegetation type relationships to 

key habitat sustainability for associated species. Plan revision included developing a set of plan 

components that include:

• desired conditions of vegetation components;

• objectives that have timeframe and measurable outcomes defined; and

• guidelines that provide restrictions and/or limitations on management or activities.

The Coronado’s revised forest plan will complement the New Mexico comprehensive wildlife 

conservation strategy desired outcomes and benefit species through key habitat management on 

the Coronado National Forest.

The New Mexico Department of Game and Fish’s strategic plan for FY 2008 through FY 2012 

provides management direction for the department’s program of work. The plan contains several 

goals and strategies relevant to Coronado National Forest management:

• Sport Hunting and Fish Program: The department’s provision of statewide system for 

hunting activities and self-sustaining and hatchery-supported fisheries satisfies the 

participation expectations of New Mexico residents and takes into consideration hunter 

safety, quality hunts, high demand areas, guides and outfitters, quotas and local and financial 

interests.

♦ Develop education and outreach initiatives so that 75 percent of New Mexico’s hunting 

interests express understanding and support for the department’s game management 

strategies.

♦ Establish broadly-supported management objectives for 9 species of big game, 4 

species of small game, and 7 species of fish that maximize recreational and economic 

benefits within the context of relevant biological, ecological, physical, social, 

economic, political, spatial, and legislative factors.

♦ Ensure reported incidences of hunting accidents do not exceed 2 per 100,000 licensed 

hunters.

♦ Maintain an overall angler satisfaction rate of 80 percent regarding angler opportunity, 

fishing experiences, and the department’s management of sport fishing issues.

♦ Maintain hunting and fishing opportunities through public compliance with wildlife 

laws.

♦ Reach a level of public opportunity for recreational hunting and fishing as indicated by 

the sale of 350,000 and 400,000 licenses, respectively.
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♦ Restore up to 70 user-days of public hunting and up to 200 user-days of fishing 

opportunity for selected diminished game species and furbearers.

♦ Maintain hunting and fishing opportunities through prevention and control of wildlife 

diseases.

• Conservation Services Program: The department’s provision of information and technical 

guidance to hunters, anglers, nonconsumptive wildlife interests, the director and the State 

Game Commission, and all persons or agencies that manage lands results in the conservation 

and enhancement of wildlife habitat and recovery of indigenous species of threatened or 

endangered wildlife.

♦ Conserve, enhance, or positively affect an additional 500,000 acres of wildlife habitat 

statewide.

♦ Achieve a commission-approved framework that defines the purposes and policies 

governing acquisition, management, and use for State Game Commission properties 

and develop 10 wildlife area-specific management plans.

♦ Attain measurable progress toward the restoration of wildlife identified as being at risk 

of depletion or extinction.

♦ Ensure illegal take of threatened or endangered species or subspecies does not impede 

the prospects for their recovery.

♦ Provide an additional 10,000 experience-days of access annually to new year-round 

appreciative wildlife experiences on at least 10 State Game Commission wildlife areas 

or other lands and opportunities to participate in specialized New Mexico Department 

of Game and Fish conservation activities.

♦ Ensure all dams on State Game Commission property are deemed safe, operational, and 

in compliance with Dam Safety Bureau regulations.

• Wildlife Depredation and Nuisance Abatement Program: The department’s depredation 

and nuisance complaint administration and intervention processes meet the expectations of 

private landowners, leaseholders, and other New Mexicans for relief and preclusion from 

property damage, annoyances, and threats to public safety caused by protected wildlife.

♦ Resolve 95 percent of depredation complaints within one year of a problem being 

reported and verified.

♦ Ensure costs associated with depredation prevention and intervention are equitably 

distributed among all stakeholders.

♦ Ensure the department’s interventions and public awareness initiatives minimize the 

potential for harm to people during encounters with dangerous wildlife.

• Administration Program: The department’s provision of an adequate and flexible system 

for furnishing direction, oversight, accountability, and support to all divisions results in the 

attainment of planned outcomes for all department programs.

♦ Make decisions within the context of relevant biological, ecological, physical, social, 

economic, political, and legislative factors organized in spatial relationships.

♦ Ensure management and control of the department’s financial resources, assets, and 

procurements complies with applicable laws, regulations, and accounting and 

procurement standards.
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♦ Attain an expression of 85 percent executive and legislative branch confidence in the 

department.

♦ Ensure affected interests rate the department as a knowledgeable and competent 

manager of the state’s wildlife and are 75 percent satisfied with the department’s 

resolution of wildlife management issues.

♦ Develop a workforce composition in the department that is representative of the 

diversity of New Mexico’s population.

♦ Ensure at least 50 percent of the public understands and is aware of opportunities to 

participate in department programs.

♦ Expand programs to provide an objective, balanced approach to conserving the full 

array of New Mexico’s wildlife species and are provideoutcomes that meet the interests 

of the broad spectrum of people who seek wildlife-associated recreation and 

information.

♦ Ensure 100 percent of the department’s work force is equitably and consistently 

compensated.

♦ Attain an increase of $1 million in funding derived from federal grants and other 

partnerships.

♦ Ensure the department’s information technology operations meet CIO-approved 

information technology plan performance metrics.

The New Mexico State wildlife action plan, titled Comprehensive Wildlife Conservation Strategy 

for New Mexico, was approved in 2006 and provides the vision for managing New Mexico’s fish, 

wildlife, and wildlife habitats. The plan contains several key elements relevant to Coronado 

National Forest management: 

• Species of Greatest Conservation Need – The New Mexico Department of Game and Fish

prioritized a list of species for conservation actions aimed at improving conditions for those 

species through intervention at the population or habitat level. Over 450 species were 

identified as being vulnerable or the species with the greatest conservation needs.

• Identification of Key Habitats – The New Mexico Department of Game and Fish divided 

the state into 19 key landscape habitat types, including nine terrestrial and ten aquatic 

habitats. All of these habitats were treated as a habitat in need of conservation. 

• Significant Revelations in New Mexico’s Comprehensive Wildlife Conservation 

Strategy:

♦ New Mexico has 452 vertebrate, mollusc, and arthropod species of greatest 

conservation need. Significantly larger proportions of amphibians (58 percent) and 

crustaceans (91 percent) are recognized as species of greatest conservation need than 

other taxonomic groups. 

♦ The greatest diversities of terrestrial species of greatest conservation need are predicted 

to occur in the Apache Highlands, Arizona-New Mexico Mountains, and Chihuahuan 

Desert Ecoregions.

♦ The greatest diversities of aquatic species of greatest conservation need are predicted to 

occur in the Pecos, Rio Grande, and Gila watersheds.

♦ The most significant factors affecting the persistence of species of greatest conservation 

need statewide are those that cause habitat conversion, loss, and degradation.
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♦ Conversion to other uses, extraction of minerals or water, removal of biological 

resources, and pollution present the highest probability of altering New Mexico’s key 

habitats.

♦ Ephemeral natural catchments, perennial marsh/cienega/spring/seeps, and riparian 

habitats may be at a higher risk of alteration by multiple factors than other habitat types 

in New Mexico.

♦ The effects of oil and gas development on species of greatest conservation need and 

their key habitats are of most concern in the Southern Shortgrass Prairie, Colorado 

Plateau, and Chihuahuan Desert Ecoregions. Mining poses potential adverse effects in 

the Arizona-New Mexico Mountains Ecoregion.

♦ The Chihuahuan Desert, Arizona-New Mexico Mountains, and Southern Shortgrass 

Prairie Ecoregions have been subjected to significant habitat alterations as the result of 

off-road vehicle and other recreational uses and military activities.

♦ Nonnative aquatic species have considerable adverse effects upon native fish, molluscs, 

and crustaceans in New Mexico’s aquatic habitats. However, many nonnative species 

have been introduced to enhance sport fishing opportunity, and the challenge remains in 

balancing these interests with maintaining viable and resilient populations of native 

species.

♦ Findings to date suggest key areas upon which to focus conservation efforts in New 

Mexico may include riparian and aquatic habitats throughout the state, areas in the 

“boot heel” region of southwestern New Mexico extending northward into the Madrean 

habitats, and areas of the shortgrass prairie and western mountain ranges where they 

converge with Chihuahuan Desert and Pecos River habitats. These areas contain key 

habitats, have a high diversity of species of greatest conservation need, are subjected to 

a moderate to high magnitude of multiple habitat altering factors, and lack legal 

constraints or long-term management plans protecting them from habitat conversion.

♦ There is a strong need to fill the information gaps impeding assessment and 

conservation of New Mexico’s biodiversity through the collaborative and coordinated 

implementation of research, survey, and monitoring projects.

♦ The highest priority conservation action for both terrestrial and aquatic key habitats 

statewide is to work with federal, state, and private organizations, research institutions,

and universities to design and implement research, survey, and monitoring projects to 

enhance our understanding of species of greatest conservation need and their key 

habitats. Knowledge of species of greatest conservation need abundance and 

distribution and the connectivity and condition of key habitats is of particular interest 

as are studies that monitor the status of these species and identify and quantify factors 

limiting their populations.

♦ New Mexico Department of Game and Fish needs to create partnerships among local, 

state, federal, and tribal governments, non-government organizations, universities, and 

individuals to effectively forward our common wildlife conservation interests.

♦ New Mexico Department of Game and Fish will need to implement conservation 

strategies that are effective on a landscape scale.

♦ Perceptions and effectiveness can be greatly enhanced by involving private landowners 

and the agricultural industry in the comprehensive wildlife conservation strategy

implementation, review, and revision phases and otherwise providing them continual 
Appendix B. Coordination with Other Public Planning Efforts

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opportunities to inform and influence project development. New Mexico is 51 percent

rangeland, 2.4 percent cropland, and 0.3 percent pasture. Even primarily urban 

Bernalillo County, which includes less than 1 percent of the state’s total land area and 

30 percent of its population, produces $40 million in agricultural products and has 

numerous agriculture-related industries.

New Mexico State Land Department

Lands of the New Mexico State Land Office border parcels of the Coronado National Forest in 

southwestern New Mexico. The Enabling Act of 1910 and the Ferguson Act granted certain lands 

held by the Federal government to the territory of New Mexico. Under the terms of these land 

grants, it was stipulated that such lands, totaling 13.4 million acres, were to be held in trust for the 

benefit of the public schools and other specific beneficiary institutions. The land commissioner is 

charged with generating and maximizing revenue from state trust lands in order to support public 

education and other beneficiary institutions, while simultaneously striving to protect, conserve, 

and maintain the lands so they may be used by future generations. To maximize revenues, the 

land commissioner generates revenues by leasing lands for grazing, agriculture, commercial use, 

oil and gas drilling, mining, and other surface and subsurface activities. Management direction for 

New Mexico State lands is provided by the New Mexico Statewide Natural Resource Assessment

(John Romero, Asst. Commissioner, Field Div., pers. comm. w/ Cibola National Forest, July 29, 

2011).

Conclusion for State of New Mexico

The Coronado revised forest plan would not conflict with the overall mission or goals of the State 

of New Mexico, its agencies, or plans.

Federal Agencies

Bureau of Land Management

Portions of Bureau of Land Management lands administered by the Tucson, Safford, and Las 

Cruces Field Offices are located near, or adjacent to, the sky islands of the Coronado National 

Forest. Notable Bureau of Land Management areas near the Coronado are a globally significant 

bird area, the San Pedro Riparian National Conservation Area, and Las Cienegas National 

Conservation Area. There are numerous wilderness areas, including the world famous Aravaipa 

Canyon Wilderness. Willcox Playa National Natural Landmark is located between the Pinaleño 

and Chiricahua Mountains, and Guadalupe Canyon Outstanding Natural Area is just south of the 

Peloncillo Mountains. 

The 1991 Safford Ranger District resource management plan provides guidance to the district in 

the management of its resources. The plan addresses the following issues: access, area of critical 

environmental concerns and other types of special management areas, off-highway vehicles, 

riparian areas, wildlife habitat, lands and realty, outdoor recreation and visual resource 

management, energy and minerals, cultural resources, soil erosion, vegetation, water resources, 

air quality, and paleontological resources.

The focus of active management includes riparian improvement treatments, wildlife habitat 

improvement projects (including prescribed fire and suppression), soil erosion reduction, land 
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(vegetation manipulation) treatments (including mechanical, chemical, or prescribed fire), and 

fuelwood cutting. The majority of the public lands are managed to limit off-highway vehicle use 

to existing roads and trails. 

The largest Bureau of Land Management area adjacent or close to the Coronado National Forest 

is the Las Cienegas National Conservation Area (49,000 acres). The Las Cienegas Resource 

Management Plan (2002) emphasizes ecosystem management and the use of partnerships and 

collaboration to achieve desired resource conditions. Livestock grazing is to continue on public 

land allotments, with grazing operations incorporating variable stocking rates and flexible 

rotations. Two utility corridors were designated and a corridor for the Arizona Trail. Some roads 

are being closed or use is being restricted to provide a mix of motorized and nonmotorized 

recreation, to insure that desired resource conditions are met. Both mechanized and motorized 

vehicles are restricted to designated routes.

Future BLM Activities

The Bureau of Land Management has several ongoing projects (Aravaipa Ecosystem 

Management Plan, Proposed SunZia Southwest Transmission Line Project, and Chiricahua 

FireScape Project) which are near the Coronado National Forest. The Chiricahua FireScape 

Project planning area includes National Forest System lands on the Coronado National Forest.

Federal Highway Administration

The Forest Highways Program provides funding to resurface, restore, rehabilitate, or reconstruct 

designated public roads that provide access to or are within a national forest or grassland. The 

program is administered by the Federal Highway Administration’s Federals Lands Highway 

Office, in partnership with the USDA Forest Service and 41 State departments of transportation, 

in accordance with tri-agency agreements in each state. Funding is provided for the planning, 

design, construction, reconstruction, or improvement of designated forest highways—including 

bridges—that provide access to, or are within, a unit of the National Forest System. Funds can 

also be used to purchase transit vehicles and design, operate, and maintain public transit facilities 

on public lands.

Within the Forest Highway Program, the role of the Federal Highway Administration is to 

provide funding and design, and to act as lead Federal agency for environmental compliance 

purposes (e.g., National Environmental Policy Act) related to impacts of the Forest Highway 

Program. The role of the Forest Service is as the owner of the servient estate (underlying land 

manager) and steward of resources not explicitly related to the forest highway (table 136). The 

role of other public road agencies (i.e., State department of transportation, county) is as a partner 

that receives and owns, operates, and maintains the completed highway or highway segment as 

detailed in the highway easement deed, which they receive from Federal Highway 

Administration.

A key goal of the Forest Highway Program is to transfer ownership of the highway to a public 

road agency other than the U.S. Forest Service, when possible. When successful, this program 

places the operation and maintenance responsibility for the highway with an agency with direct 

access to U.S. Department of Transportation highway funding so the highway may be maintained 

to an appropriate standard of safety and efficiency. The Forest Service does not currently have 
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access to U.S. Department of Transportation funding other than through the transfer methodology 

of this program.

Table 136. Forest highways located on Coronado National Forest

Forest Highway Owner By Segment Road Type Condition

FH 32 (Chiricahua-Portal) USFS/.../.../CC Pvmt/Imp/Nat/Nat Exc/Good/Poor/Good

FH 34 (Swift Trail) ADOT Pvmt/Nat Fair/Good

FH 36 (Nogales-Palominas) SCC/USFS Pvmt/Nat Failed/Poor

FH 37 (SR-83) ADOT Pvmt/Pvmt Good/Poor

FH 38 (Ruby Road) USFS/.../SCC/PC Pvmt/Nat/Pvmt/Pvmt Failed/Poor/Failed/...

FH 39 (Catalina Hwy) PC Paved Good

Pvmt = Asphaltic Pavement; Imp = Aggregate Surfaced; Nat = Native Surfaced; CC = Cochise County; PC = Pima 

County; SCC = Santa Cruz County.

U.S. Fish and Wildlife Service

The U.S. Fish and Wildlife Service’s main role is to administer the Endangered Species Act. 

Section 7 (a)(1) of the Endangered Species Act directs Federal agencies to aid in conservation of 

listed species and section 7 (a)(2) requires that agencies, through consultation with the U.S. Fish 

and Wildlife Service, ensure that their activities are not likely to jeopardize the continued 

existence of listed species or adversely modify designated critical habitat. As projects and 

activities are planned, forest managers consult with the U.S. Fish and Wildlife Service.

The U.S. Fish and Wildlife Service also issues national polices to promote the conservation and 

recovery of listed species, including species recovery plans. They are in the process of developing 

a strategic plan to react to climate change.

The U.S. Fish and Wildlife Service manages the National Wildlife Refuge System. There are two 

refuges adjacent to the Coronado National Forest: Buenos Aires and Leslie Canyon. The 

emphasis of management in Buenos Aires National Wildlife Refuge is the reestablishment of a 

U.S. breeding population of masked bobwhite quail, as well as protecting and improving habitat 

for other endangered species. Leslie Canyon National Wildlife Refuge protects Yaqui chub and 

Yaqui topminnow, as well as a rare velvet ash-cottonwood-black willow gallery forest. The 

Coronado National Forest cooperates closely with the U.S. Fish and Wildlife Service, especially 

in endangered species protection and fire management activities.

The following are key elements that relate to planning in the draft U.S. Fish and Wildlife Service

report “Conserving the Future: Wildlife Refuges and the Next Generation.”

• Strategically conserving fish and wildlife

• Delivering fish and wildlife conservation

• Strategic growth

• Protecting wildlife: The role of conservation law enforcement

• Managing wildlife refuges for biological integrity, diversity, and environmental health

• Managing refuges to support ecological resilience and climate adaptation
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Issues, concerns, and systemic challenges in managing for biological integrity, diversity, and 

environmental health identified in the draft report are:

• fire management and emergency preparedness;

• farming;

• water supplies and aquatic ecosystems; 

• working beyond wildlife refuge boundaries; 

• ocean and marines conservation; 

• invasive species; 

• wilderness stewardship; 

• international connections; and 

• comprehensive conservation planning.

National Park Service

The Coronado National Forest shares boundaries with Saguaro National Park, Coronado National 

Memorial, and Chiricahua National Monument all managed by the National Park Service. The 

Coronado shares formal, coordinated management responsibilities with the National Park Service 

for natural resources, wildlife, and fire.

The National Park System of the United States comprises 384 areas covering more than 

83 million acres in 49 States, the District of Columbia, American Samoa, Guam, Puerto Rico, 

Saipan, and the Virgin Islands. These areas are of such national significance as to justify special 

recognition and protection in accordance with various acts of Congress. National Park Service 

goals articulated in the National Park Service Strategic Plan (http://planning.nps.gov/policy.cfm) 

for managing the natural and cultural resources as well as visitor experiences are to:

• preserve park resources;

• provide for the public enjoyment and visitor experience of parks; and 

• strengthen and preserve natural and cultural resources, and enhance recreational opportunities 

managed by partners.

Department of Defense

The Coronado National Forest shares a boundary with the Fort Huachuca Military Reservation. 

The Coronado and the fort share formal, coordinated management responsibilities for natural 

resources, wildlife, and fire.

The Department of Defense is steward of an estimated 29 million acres of land in the United 

States that contains both invaluable cultural and natural resources. In order to support military 

readiness while preserving the Nation’s natural and cultural heritage, the Department of Defense 

legacy resource management program was established by Congress in 1990. The goal of the 

legacy program is to protect, enhance, and conserve natural and cultural resources using the three 

principles of stewardship, leadership, and partnership. The program is focused on ecosystem 

management, regional widespread conservation, partnerships, multidisciplinary integrated 

conservation efforts, and technological implementation. 
Appendix B. Coordination with Other Public Planning Efforts

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The legacy program supports 12 areas of emphasis in order to preserve natural and cultural 

resources:

• Readiness and range sustainment

• Cooperative conservation

• Integrated natural resource management

• Regional ecosystem management initiatives

• National and international initiatives

• Invasive species control

• Monitoring and predicting migratory patterns of birds and animals

• Cultural resource management

• Historic preservation and force protection

• Native American issues

• Curation of archaeological collections, associated records and documents, and management 

of archaeological sites

• Program management

Conclusion for Federal Agencies

The Coronado revised forest plan would not conflict with the overall mission, plans, or goals of 

other Federal agencies.

Other Land Owners

The Coronado National Forest borders and surrounds lands of other ownership besides those 

listed above. There is no known inventory of these landowner’s activities and potential impacts to 

the Coronado. 

Conclusion

Overall, the revised forest plan is consistent the missions and goals of other agencies and 

planning efforts. However, other landowners and land policies or decisions have the potential to 

impact the Coronado National Forest and vice-versa. In development of the forest plan, these 

considerations were taken into account. Table 137 and table 138 identify some key potential 

impacts and describe how the plan deals with those impacts, as well as potential activities on 

adjacent lands that may impact forest management. No major conflicts with Forest Service 

planning have been identified at this time.
Appendix B. Coordination with Other Public Planning Efforts

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170

Table 137. Potential impacts to forest management and relationship to the revised forest plan

Potential Impacts/Issues How the Revised Forest Plan Addresses

Call for multiple use of the 

forests

The overall goal of managing National Forest System lands is to sustain the 

multiple uses of its resources in perpetuity while maintaining the long-term 

productivity of the land.

The plan carries out that goal.

Community growth demand The plan identifies a management emphasis to work with local communities 

to understand their community expansion needs and retain access to National 

Forest System land.

Danger from fire for 

residents living in a wildlandurban interface

The plan contains goals and objectives for effective treatments that will 

ensure that fires, when they do occur, are low to moderate severity; and that 

residents have the information they need to protect themselves and their 

property from fire and other risks in the wildland-urban interface.

Improve forest health and 

promote the restoration of 

forest ecosystems

The desired conditions describe a healthy, sustainable forest, and the 

objectives identify actions that will help restore ecosystems.

Maintain a healthy, 

sustainable forest that 

provides forest products for 

communities

Desired Condition: A sustainable supply of wood products (e.g., small 

roundwood, sawlogs, biomass, fuelwood) and other products (e.g., Christmas 

trees, beargrass, cactus, ferns, and fungi) are provided within the capacity of 

the land to produce these goods. Silvicultural treatments reflect natural 

disturbance regimes and contribute to ecosystem sustainability. Forest 

products, particularly those related to wood fiber, are made available as part 

of fuel treatment projects and restoration activities.

Support local, traditional 

custom and culture

The uses of livestock grazing, timber harvesting, mining, and hunting 

continue to be allowed in the plan. The plan recognizes that many local 

residents have traditional ties, such as forest product collection, hunting, 

holiday celebrations, and annual picnics. Ranchers continue to be an 

important part of the forest history, and their traditional uses remain an

important part of the economic and cultural landscape.

Protect private property 

rights

The plan honors the continuing validity of private, statutory, or pre-existing 

rights.

Consider local concerns; 

collaborate with government 

agencies; consult with tribes

Throughout the plan, there is a management emphasis on collaboration and 

cooperation with Federal, State, local governments, tribes, and stakeholders.

Growing demand for 

recreation (trails, designated 

OHV)

The plan offers a spectrum of recreation settings and opportunities varying 

from primitive to urban and dispersed to developed, with an emphasis on the 

natural-appearing character of the forests.

Although the plan does not identify specific new developments, it does allow 

for it if needed. The plan focuses on maintaining existing recreation 

opportunities and improving their quality.

Tribal use and traditional 

cultural properties

The plan provides guidance for protecting historic and prehistoric properties 

and sites, including known American Indian sacred places and traditional 

cultural properties, and for working with tribes to provide settings for tribal 

culture and uses.

Conserve, preserve, enhance, 

and restore wildlife and their 

habitat 

The plan provides guidance for well distributed habitat conditions that 

contribute to the recovery of federally listed species, and restoring vegetation 

conditions that support all wildlife.

Minimize impacts from 

invasive species 

The plan provides guidance for controlling or eradicating invasive species.
Appendix B. Coordination with Other Public Planning Efforts

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Potential Impacts/Issues How the Revised Forest Plan Addresses

Provide opportunities for 

shooting sports, off-highway 

vehicles

The plan continues to allow these activities.

Threats related to changes in 

water availability

The plan provides guidance for protecting all water sources

Threats related to changes in 

climate

The plan contains information and discussion about climate change and 

considerations for land management planning. 

Table 138. Activities on adjacent lands that may impact forest management

Activity Management Impact

Land exchanges (changes in 

ownership)

Wildlife habitat, ecological services, access, scenery management

Sale of Arizona State Lands Access

Development Wildlife habitat, ecological services, fire management, scenery management

Mining and quarrying Wildlife habitat, scenery management

Noxious and invasive weed 

treatments

Invasive species management, fire management 

References for Appendix B

Arizona Department of Agriculture. Annual Report FY2009-2010. Phoenix, AZ

Arizona Department of Transportation. 2015. Arizona State Transportation Improvement Program 

(STIP) Fiscal Years 2015-2019, and “2015-2019 Five-year Transportation Facilities 

Construction Program.” Phoenix, AZ. http://azdot.gov/docs/default-source/planning/stipfy-2015-2019.pdf?sfvrsn=6 

Arizona Department of Transportation. 2011. What Moves You Arizona, Long-Range 

Transportation Plan, 2010-2035. Phoenix, AZ. http://www.azdot.gov/docs/defaultsource/planning/lrtp-2011-1129.pdf?sfvrsn=2 

Arizona Department of Water Resources. 2011. Missions and Goals. Phoenix, AZ. 

http://www.azwater.gov/AzDWR/PublicInformationOfficer/MissionAndGoals.htm

Arizona Game and Fish Department. 2006. Arizona’s Comprehensive Wildlife Conservation 

Strategy: 2005-2015. Phoenix, AZ.

Arizona Game and Fish Department. 2007. Wildlife 2012 Strategic Plan. Arizona Game and Fish 

Department, Phoenix, AZ.

Arizona State Land Department. 2011. State Land Department Historical Overview. Phoenix, az. 

http://www.land.state.az.us/history.htm

Arizona State Parks. 2007. Arizona 2008 Statewide Comprehensive Outdoor Recreation Plan 

(SCORP). Phoenix, AZ.

Arizona State Parks. 2009. Arizona Trails 2010: A Statewide Motorized and Non-Motorized 

Recreational Trails Plan. Phoenix, AZ.
Appendix B. Coordination with Other Public Planning Efforts

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

172

Arizona State Parks. 2010. Arizona State Parks FY09/10 Annual Report July 1, 2009 – June 30, 

2010. Phoenix, AZ.

Bureau of Land Management. 1991. Safford District Resource Management Plan and 

Environmental Impact Statement. U.S. Department of the Interior Bureau of Land 

Management. Safford, AZ.

Bureau of Land Management. 2011. U.S. Department of the Interior Bureau of Land Management 

Arizona 2011 NEPA Project Log. 

Cochise County. 2015. Cochise County Comprehensive Plan. Cochise County, AZ. 

https://www.cochise.az.gov/planning-and-zoning/comprehensive-area-plans

Federal Highway Administration. 2010. Planning Update 1: Long Range Transportation Plan for 

Forest Highways in Arizona. U.S. Department of Transportation. Federal Highway 

Administration.

Federal Highway Administration. 2011. Who We Are. U.S. Department of Transportation. Federal 

Highway Administration. http://www.fhwa.dot.gov/whoweare/whoweare.htm

Forest Service. 2005. Socio-Economic Assessment for the Coronado National Forest. University 

of Arizona School of Natural Resources. Tucson, AZ.

Forest Service. 2008. Coronado National Forest Economic and Social Sustainability Assessment. 

United States Department of Agriculture Forest Service Southwestern Region Hidalgo 

County. 2011. Hidalgo County Comprehensive Plan. Hidalgo County, NM. 

http://swnmcog.org/images/Hidalgo_Comp_Plan_Dec_2011.pdf

New Mexico Department of Transportation (NMDOT). 2015. New Mexico Transportation Plan, 

Southwest Regional Transportation Plan. Southwest Regional Transportation Planning 

Organization. 

Pinal County. 2001. Pinal County Comprehensive Plan. Pinal County, AZ. 

http://www.pinalcountyaz.gov/ed/whypinalcounty/Pages/ComprehensivePlan.aspx

Pinal County. 2015. Public Notice: Pinal County Major Comprehensive Plan 60 Day Review, 

2015 Major Amendments.

San Carlos Apache Tribe. 2010. San Carlos Apache Tribe - Recreation and Wildlife. San Carlos, 

AZ. University of Arizona. http://www.scatrwd.com/

San Carlos Apache Tribe. 2011. San Carlos Forestry Web site. http://forestry.scatnsn.gov/publicweb/forestry.html

U.S. Fish and Wildlife Service. Consultations – Overview. United States Department of Interior 

U.S. Fish and Wildlife Service.
Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

173

Appendix C. Timber Suitability

The National Forest Management Act of 1976 requires that the suitability of National Forest 

System lands for various uses, including timber production, be identified and documented. 

National Forest System lands were reserved with the intent of providing goods and services to 

satisfy public needs over the long term, among which is a sustainable supply of forest products. 

The 1982 Planning Rule provisions require the responsible official to identify lands not suitable 

for timber production in the area governed by the forest plan (36 CFR 219.14). 

Forest Service Manual 1900 defines “forest land” as that which has at least 10 percent tree cover 

or which had such tree cover in the past, and which is not currently developed for non-forest uses, 

such as agriculture, providing improved pasture, residential or administrative areas, improved 

roads of any width, and adjoining road clearing and power line clearing of any width. It defines 

timber production as “the purposeful growing, tending, harvesting, and regeneration of regulated 

crops of trees for cutting into logs, bolts, or other round sections for industrial or consumer use.”

Forest land may be considered as “unsuitable” for timber production if any of the following 

apply:

a. Congress, the Secretary, or the Chief has withdrawn it from the public domain; 

b. it is not producing or capable of producing crops of industrial wood;

c. there is no technology available to prevent irreversible damage to soil productivity and/or 

watershed conditions; 

d. there is no reasonable assurance based on existing technology and knowledge that it is 

possible to restock lands within 5 years after final harvest, as reflected in current research 

and experience; 

e. there is currently a lack of adequate information about responses to timber management 

activities; and/or 

f. timber management is inconsistent with, or not cost efficient in meeting, the management 

requirements and multiple-use objectives specified in the forest plan.

Table 139 and table 140 report the results of a timber suitability analysis for the Coronado. In the 

tables, various categories of forest land are described, and the acres suitable (or unsuitable) for 

timber production are reported.

Lands having potential commercial-grade timber are located at very high elevations of mountain 

ranges on four ranger districts. These areas are isolated and difficult to access, making it 

extremely unlikely for a single processing facility to develop a feasible business model that could 

incorporate most timbered lands. None of the ranges contains more than 15,000 acres of 

commercial-grade timber, and most contain much less. Even in each range, timber lands are often 

separated by major topographic features, have little or no road access, or both. 

The most productive lands on the forest are mixed-conifer and spruce-fir forests in the Pinaleño 

Ecosystem Management Area on the Safford Ranger District. Here, a very large portion of the 

mixed-conifer community is in federally threatened Mexican spotted owl protected activity 

centers. The Mexican Spotted Owl Recovery Plan has restrictions on tree size and high-residual 
Appendix C. Timber Suitability

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

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density requirements in Mexican spotted owl protected activity centers; therefore, only narrow 

avenues of threatened Mexican spotted owl habitat could be managed for timber production. 

Similarly, the spruce-fir community on the Coronado is concentrated on the top of the Pinaleño 

Mountains, almost entirely within the federally endangered Mount Graham red squirrel refugium, 

where there are significant restrictions on residual densities.

Table 139. Timber suitability assessment of Coronado National Forest lands 

Category Description Acres

Coronado National Forest 

(total land)

All acreage comprising the forest 1,778,077

Non-forested lands Non-forested (less than 10

percent occupied by forest trees)

–1,538,340

Lands withdrawn from public 

domain

Designated wilderness areas, 

inventoried roadless areas, and 

private ownership 

–180,171

Lands having irretrievable 

resource damage

Lands having a 40 percent or 

higher slope and posing a severe 

erosion hazard

–1,496

Lands where there is no 

assurance of adequate stocking 

General ecosystem survey shows 

low stocking

–12,413

Lands tentatively suitable for timber production 45,657

Table 140. Timber suitability assessment of Coronado National Forest lands comparing acres among 

alternatives

Category Description No Action

Proposed

Action Alt. 1 Alt. 2 

Recommended as 

wilderness areas 

Acres not already 

subtracted above

0 –55 –1,136

Not cost efficient in 

meeting timber 

production objectives

Located in the Santa Rita, 

Huachuca, Pinaleño, Santa 

Catalina, and Chiricahua 

Ecosystem Management 

Areas

–40,657 –45,602 –44,520 –45,657

Land suitable for timber production 5,000* 0** 0** 0**

Land not suitable for timber production 1,773,077 1,778,077 1,778,077 1,778,077

*These acres are comprised of ponderosa pine-evergreen shrub and mixed-conifer communities and are located in the 

Santa Catalina and Chiricahua Ecosystem Management Areas

**Because the Coronado National Forest has zero acres suitable for timber production under the proposed action and 

alternatives 1 and 2, the long-term sustained yield calculation (LTSYC) and allowable sale quantity (ASQ) are zero 

as well.

Although management of Pinaleño lands to protect and maintain habitat for the owl and squirrel 

has supported commercial timber sales and will likely do so again, commercial timber production 

is expected to be very limited and driven by habitat restoration and protection rather than by 

commercial timber production. In this area, the Pinaleño Ecosystem Restoration Project, which is 

in progress, will produce over 10,000 hundred cubic feet of sawtimber and an equal amount of 
Appendix C. Timber Suitability

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poletimber. However, treatment costs will far exceed timber value, and as a result, 

implementation of the project is supported, in part, by a stewardship agreement. 

The second largest concentration of timber lands where it is not cost effective to manage for 

timber production is in the Chiricahua Ecosystem Management Area on the Douglas Ranger 

District in canyon stringers and near the summit, each requiring individual road systems. Widelydispersed stands in remote areas make commercial harvesting inefficient. Much of this land is 

also in Mexican spotted owl protected activity centers or in restricted owl habitat. Commercial 

timber may be removed at times, although it would be as a secondary or tertiary purpose. 

Treatment costs here would also exceed any potential value because of costs for hauling long 

distances. Currently, the closest sawmill is over 160 miles away from the Chiricahua Ecosystem 

Management Area. Portable milling equipment would be the most viable option for timber 

production here to provide pallet stock for Mexico’s import and export market.

The remaining lands that are not cost effective for timber production are located in the Huachuca, 

Santa Rita, and Santa Catalina Ecosystem Management Areas. Each is less than 5,000 acres. 

Commercial-grade timber in these areas is again located in canyon stringers and mountaintops. 

Often these stands are in Mexican spotted owl protected activity centers or in other restricted 

habitat. Small commercial sales of timber generated by forest and ecosystem restoration and 

community wildfire protection projects on the Santa Catalina Ecosystem Management Area may 

occur during the future life of the revised forest plan, but these would not be conducted with 

commercial-grade timber harvest as a primary purpose.

Since the 1986 forest plan became effective, three general trends have rendered the once 

marginally cost-effective timber production activity on the forest as economically infeasible. 

These are as follows:

1. The small sawmills operating in the 1980s have closed or refocused on other sources of 

timber. The small Dankworth Sawmill in Graham County no longer exists. Until the mid1980s, this sawmill processed timber from the Pinaleño Mountains. The larger Western

Pine Sawmill in Globe, Arizona also closed in the early 1980s. This mill at one time 

purchased much of the timber from the Pinaleño Mountains, Pinal Mountains (on the 

Tonto National Forest), and the San Carlos Indian Reservation. The San Carlos Apache 

Tribe has since rebuilt this sawmill to process timber from the reservation.

2. Lumber prices have been extremely low over the past 2 decades and are only now 

beginning to rise, making the overall economic contribution of forest products worse 

today than in 1986. The historic Summerhaven Sawmill, which closed in the mid-1990s, 

was the last sawmill operation in the Santa Catalina Mountains. 

3. The forest products industry has moved to a more concentrated production model that 

requires larger processing facilities, production of higher value engineered forest 

products, and a larger and more concentrated timber resource from which to operate. 

Projects requiring large capital investments could not be justified in southern Arizona due 

to the small scale and dispersed nature of the timber resource.

Small, niche, forest products enterprises that would be a good match for the timber resource on 

the Coronado have not developed at this time. Developing this business model would require a 

concerted effort from the Forest Service, a role better suited for the Forest Service’s State and 

Private Forestry program, which is not managed by the Coronado. Currently, development of a 

forest products industry in the Southwest is focused on the forests of northern Arizona and New 
Appendix C. Timber Suitability

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

176

Mexico. The Coronado would benefit from a Forest Service program similar to the one in New 

Mexico, the Collaborative Forest Restoration Program, that supports small community forest 

utilization projects. Because this program is limited to New Mexico by Congress, expanding this 

program to Arizona would require a change in statute.

In summary, the acreages listed in table 139 are not cost efficient for timber suitability because 

one or more of the following conditions apply: (1) small acreages of a highly dispersed timber 

resource; (2) limitations on harvesting related to habitat requirements and species protection 

restrictions for the federally listed Mexican spotted owl and the Mount Graham red squirrel; 

(3) long transport distances to timber processing facilities that are not economical; (4) a loss of 

industry and specialized skills required to harvest and process timber, or some combination of 

these things.
Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

177

Appendix D. Crosswalk of Desert and

Grassland Communities with Ecological Site 

Descriptions

The ecological site descriptions in table 141 and table 142 were used to develop desired conditions 

related to the plant composition and structure of the related vegetation communities.
Appendix D. Crosswalk of Desert and

Grassland Communities with Ecological Site Descriptions

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

178

Table 141. Crosswalk of desert and grassland communities with ecological site descriptions for each mountain range in Santa Catalina, Nogales, and 

Sierra Vista ranger districts 

Land Unit (MLRA) Santa Catalina Nogales Sierra Vista

Desert (40-1) Catalina Rincon Atascosa Santa Rita Tumacacori Huachuca Whetstone Patagonia

Acid igneous hills and pediment x x 

Loamy slopes x 

Limy slopes x 

Sandy wash x x 

Desert grasslands (41-3) Catalina Rincon Atascosa Santa Rita Tumacacori Huachuca Whetstone Patagonia

Acid igneous hills x x x x x x x

Basic igneous hills x x x x 

Limestone hills x x x x x x 

Acid igneous pediment x x x x x x x 

Loamy slopes x x x x x x x 

Limy slopes x x x x x x x 

Sandy wash x x x x x x x 

Plains grassland and savanna (41-1) Catalina Rincon Atascosa Santa Rita Tumacacori Huachuca Whetstone Patagonia

Acid igneous hills x x x x x x x 

Basic igneous hills and pediment x x x x x 

Limestone hills x x x x x x 

Acid igneous pediment x x x x x x 

Loamy slopes x x x x x x x x

Limy slopes x x x x x x x x 

Loamy upland x x x x x x 

Limy upland x x x x x 

Sandy wash x x x x x x x x 

Loamy bottomland x x x x x 
Appendix D. Crosswalk of Desert and

Grassland Communities with Ecological Site Descriptions

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

179

Table 142. Crosswalk of desert and grassland communities with ecological site descriptions for each mountain range in Douglas and Safford ranger 

districts 

Land Unit (MLRA) Douglas Safford 

Desert (40-1) Peloncillo Dragoon Chiricahua Pinaleño Santa Teresa Galiuro

Ecological Site Description 

Number as in ESIS

Acid igneous hills and pediment R040XA105AZ and R040XA121AZ

Loamy slopes R040XA109AZ

Limy slopes R040XA110AZ

Sandy wash R040XA115AZ

Desert grasslands (41-3) Peloncillo Dragoon Chiricahua Pinaleño Santa Teresa Galiuro

Acid igneous hills x x x x R041XC306AZ

Basic igneous hills x x x R041XC323AZ and R041XC330AZ

Limestone hills x x x R041XC307AZ

Acid igneous pediment x x x x R041XC322AZ

Loamy slopes x x x x x x R041XC314AZ

Limy slopes x x x x x x R041XC308AZ

Sandy wash x x x R041XC316AZ

Plains grassland and savanna (41-1) Peloncillo Dragoon Chiricahua Pinaleño Santa Teresa Galiuro

Acid igneous hills x x x x R041XA102AZ

Basic igneous hills and pediment x x x R041XA111AZ

Limestone hills x x x R041XA103AZ

Acid igneous pediment x x x x R041XA117AZ

Loamy slopes x x x x x x R041XA107AZ

Limy slopes x x x x x x R041XA104AZ

Loamy upland x x x x x R041XA108AZ

Limy upland x x x x R041XA105AZ

Sandy wash x x x x x x F041XA112AZ 

Loamy bottomland x x x x R041XA114AZ

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

181

Appendix E. Range Suitability and 

Capability

Determination of Lands Suitable and Capable for 

Livestock Grazing on the Coronado National Forest

Introduction

Procedures in the 1982 Planning Rule require that the suitability and capability of National Forest 

System lands for producing forage for grazing animals be determined in forest planning. 

Suitability is the appropriateness of applying certain resource management practices to a 

particular area of land in consideration of the relevant social, economic, and ecological factors. 

Capability is the potential of an area of land to produce resources and supply goods and services. 

Capability depends upon current conditions and site conditions such as climate, slope, landform, 

soils, and geology.

Suitability should be determined based on compatibility with desired conditions and objectives in 

the plan area. The responsible official shall not identify lands within the plan area as suitable for a 

certain use if that use is prohibited by law, regulation, or policy; would result in substantial and 

permanent impairment of the productivity of the land or renewable resources; or if the use is 

incompatible with the desired conditions for the relevant portion of the plan area. A designation of 

an area as suitable for a particular use does not mean that the use will occur over the entire area. 

Likewise, a determination that a particular use is not suitable in a management area does not 

mean that the use will not occur in specific areas. The identification of an area as suitable for 

various uses is guidance for project and activity decision making, and is not a resource 

commitment or final decision approving projects and activities. Final decisions on resource 

commitments are made at the project level. The final decision to authorize livestock grazing 

would be made at a project (allotment) level.

Capability

The capability of Coronado National Forest lands to produce forage for grazing animals was 

determined in the 1980s for the 1986 forest plan. Landscape-scale conditions that determine 

capability (such as landform, geology, slope, climate) have not changed significantly since the 

first evaluation, therefore, capability determined in the original is still applicable. Cyclical or 

temporal fluctuations in climatic conditions such as El Niño cycles or drought periods are not 

cause for reanalyzing capability, but are considered by Coronado National Forest personnel when 

making project-level grazing decisions and responded to through adaptive management. Current 

climate conditions and trends have not been shown to be outside of historical norms for the 

Southwest. What has changed since the original analysis is the availability of more accurate data 

and analysis tools. Capability for this plan was reassessed using corporate GIS data.

The Coronado National Forest constrains capability of lands for producing forage for livestock 

based on slope (less than 40 percent) and forage productivity (more than 100 pounds per acre per 

year). Forage productivity is not currently mapped at a scale fine enough to detect areas with less 
Appendix E. Range Suitability

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

182

than 100 pounds per acre per year and, so, capability is identified and mapped using slope as the 

sole criteria. However, lands with slopes greater than 40 percent are intermingled throughout 

grazing allotments and livestock will intermittently use these lands as they pass through them 

while traveling to other capable portions of the allotments. This intermittent use may, and often 

does, contribute in a limited way to the forage base for domestic livestock. The results of the 

analysis are displayed in table 143.

Table 143. Grazing capability calculations for the Coronado National Forest

Grazing Capability Analysis Acres

Gross area of the Coronado National Forest 1,789,934

Slopes greater than 40 percent 719,999

Lands tentatively capable for livestock grazing 1,063,935

Suitability

The Coronado National Forest has been managing grazing allotments since the forest was 

established, and more intensively managing them for the past 20 years. This experience is of great 

value when determining where grazing should and should not occur on the Coronado National 

Forest. Existing suitable and nonsuitable use identification in the 1986 forest plan is the starting 

point for identifying suitability of land use in the revised forest plan. Suitability for livestock 

grazing in the 1986 forest plan was determined following the procedures of the 1982 Planning 

Rule. Subsequent to publication of the 1986 plan, site-specific analysis of individual grazing 

allotments under the National Environmental Policy Act has been an ongoing process. This 

process ensures that livestock grazing is consistent with desired conditions and objectives for a 

particular management area or geographic area within a planning unit.

According to Southwestern Region guidance for determining suitability and capability for 

livestock grazing (USDA 2010), the scale of the suitability identification should be the same as 

the desired condition and objective descriptions. These may be management areas, land use 

zones, or ecological management areas. Although allotment level data is used in aggregate to 

determine landscape level suitability, identification of plan level suitability is not appropriate at 

the allotment scale. 

The following is the process used for completing the review of lands currently identified as 

suitable for livestock grazing, and for adjusting suitability determinations in the revised forest 

plan.

1. Review of lands suitable for livestock grazing in the 1986 forest plan. Management 

areas in the 1986 forest plan were, for the most part, delineated by the capability of lands 

to produce natural resources such as livestock forage and fuelwood, provide recreation 

settings, or emphasize unique biological resources. The 1986 forest plan identifies lands 

in Management Areas 2, 3, 4, 7, 9, 14 and part of 15 as suitable for livestock grazing. All 

lands in Management Areas 1, 2A, 2B, 3A, 3B, 8, and 8A are identified as not suitable for 

livestock grazing. 

2. Review of site-specific assessments to determine need for change. Compatibility with 

desired conditions is the basis for determining whether or not livestock grazing is suitable 

for a particular area. During the need for change analysis, comparisons between existing 
Appendix E. Range Suitability

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

183

conditions and desired conditions were made. Through a review of site-specific National 

Environmental Policy Act assessments for each individual grazing allotment it was 

determined that current identification of areas suitable for livestock grazing is not 

precluding the ability to manage those areas to achieve desired conditions, as evidenced 

by allotment-level decisions to continue to authorize grazing. This review confirmed that 

livestock grazing is suitable in areas where it is currently authorized.

3. Alignment of livestock grazing suitability with proposed management areas. 

Management areas in the proposed plan, alternative 1, and alternative 2 are different than 

in the 1986 forest plan. The proposed management areas are fundamentally based on 

social experiences, with the exception of research natural areas and zoological-botanical 

areas which emphasize unique biological resources. Review of steps 1 and 2 confirmed 

livestock grazing in designated grazing allotments is a suitable use. To align grazing 

suitability with the proposed plan and action alternatives, areas currently authorized for 

livestock grazing or where grazing is allowed in establishment records were intersected 

with the proposed management areas.

The following management areas would be suitable in the proposed plan and action alternatives:

• motorized recreation 

• roaded backcountry

• wild backcountry

• wilderness areas 

• recommended wilderness areas

• wilderness study areas

• Cave Creek Canyon Birds Of Prey 

Zoological-Botanical Area

• South Fork of Cave Creek ZoologicalBotanical Area

• Wild Chile Botanical Area

• Guadalupe Canyon ZoologicalBotanical Area

• Appleton-Whittell Research Ranch

• Arizona National Scenic Trail

Management areas identified as not suitable for livestock grazing in the proposed plan and action 

alternatives are the following:

• developed recreation

• Elgin Research Natural Area

• Goudy Canyon Research Natural Area

• Canelo Research Natural Area

• Santa Catalina Research Natural Area

• Butterfly Research Natural Area

• proposed Finger Rock Research Natural 

Area

• Wet Canyon Talussnail ZoologicalBotanical Area

• Mount Graham Astrophysical and 

Biological Research Area

• Pole Bridge Research Natural Area and 

proposed extension

• Goodding Research Natural Area and 

proposed extension

Table 144 identifies areas of the forest unsuitable for livestock grazing. The total area identified 

varies slightly by alternative due to changes in acreage of the developed recreation management 

area. Of the approximately 1,063,935 acres identified as tentatively capable for livestock grazing, 
Appendix E. Range Suitability

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

184

approximately 47,000 (see table 144 for exact acreages by alternative) acres were identified as 

not suitable due to incompatibility with desired conditions.

Table 144. Acres of management areas unsuitable for grazing on the Coronado National Forest by 

alternative

Management Area Proposed Action Alternative 1 Alternative 2

Developed Recreation* 36,774 35,495 36,294

Elgin Research Natural Area 245 245 245

Goudy Canyon Research Natural Area and 

proposed extension 558 558 558

Canelo Research Natural Area 386 386 386

Santa Catalina Research Natural Area 634 634 634

Butterfly Research Natural Area 1,058 1,058 1,058

Proposed Finger Rock Research Natural 

Area* 1,103 1,103 1,103

Wet Canyon Talussnail Area 1,218 1,218 1,218

Mount Graham Astrophysical and 

Biological Research Area 2,937 2,937 2,937

Pole Bridge Research Natural Area and 

proposed extension 582 582 582

Goodding Research Natural Area and 

proposed extension 2,213 2,213 2,213

Total area of management areas 

determined to be unsuitable for livestock 

grazing

47,708 46,429 47,228

Tentatively capable lands that are not 

suitable for livestock grazing due to 

incompatibility with desired conditions. 

31,730 30,763 31,251

* Livestock grazing is generally not suitable in the Developed Recreation Land Use Zone except for approximately 

12,206 acres within existing designated livestock grazing allotments.

Grazing allotments occur mostly in the grassland and Madrean encinal woodland vegetation 

communities. These two communities occupy approximately 66.7 percent or just over 1.1 million 

acres of the Coronado. These community’s current vegetative condition class has been identified 

in the “2009 Coronado National Forest Ecological Sustainability Report” (USDA FS 2009b). The 

vegetative condition class identifies the degree to which they differ from reference conditions 

(departure). Grasslands have a vegetative condition class of 3 or highly departed from reference 

conditions, while the Maderan encinal woodlands have a vegetative condition class of 2 or a low 

to moderate departed from reference conditions. 

The grassland community contains more invasive plants such as Lehmann lovegrass (Eragrostis 

lehmanniana) and weeping lovegrass (Eragrostis curvula) than any other community on the 

forest. In many areas, Lehmann lovegrass is now naturalized and forms monocultures that likely 

prevent the return of native grasses (Anable et al. 1992). Eradication may be possible with 

repeated application of herbicides, but the cost and negative effects of large-scale herbicide 

treatments make eradication impractical. There would also be a high likelihood of re-invasion of 
Appendix E. Range Suitability

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

185

treated sites, considering that large seed sources exist on adjacent ownerships. Although less 

desirable than native grasses for some species of wildlife, including seed-foraging rodents and 

birds (Bock et al. 1986), Lehmann lovegrass does fulfill the purposes for which it was initially 

seeded to protect soil from erosion and provide forage for livestock. Unlike situations where 

vegetation type conversion occurs due to the invasion of a nonnative species (e.g., conversion of a 

grassland to a shrubland), in areas where Lehmann lovegrass has become dominant, grassland 

ecosystem function, as a whole, has been maintained.

Currently, 27 percent of grasslands on the Coronado exist in an open native condition, 52 percent 

are shrub invaded, and 21 percent are open nonnative grasslands. Of the shrub-invaded areas, 

42 percent have the potential to be restored to an open native condition. Sixty-nine percent of 

grasslands on the Coronado are either in the open native or restorable native communities, with 

the remainder in nonnative or former grassland communities (USDA FS 2009b). The revised plan

defines desired conditions based on the reference conditions for grassland communities and 

provides management objectives and guidelines that would provide a framework for 

implementing site-specific projects to achieve desired conditions. These plan components would 

guide management through planned and unplanned ignitions and mechanical treatments on at 

least 72,500 acres every 10 years (7,250 acres per year) to maintain open, native grasslands with 

appropriate shrub and overstory cover.

Vegetation mapping indicates that currently, the Madrean encinal woodland is characterized by a 

diversity of structural stages; however, there is an overabundance of the late-seral and lack of 

mid-seral closed state when compared to the desired conditions of 0 percent for this class. Closed 

states generally have decreased grass and forb cover when compared to open canopy states. The 

revised plan defines desired conditions based on reference conditions for the Madrean encinal 

woodland and provides management objectives and guidelines as a framework for implementing 

site-specific projects to achieve these conditions. These forest plan components would guide 

management through an increase of wildfire treatments to treat 367,000 acres every 10 years to 

open tree and shrub canopies and promote understory grasses and forbs.

Summary

In summary, the plan level determination of suitability for livestock grazing differs between the 

1986 plan and the action alternatives because of differences in the criteria used for identification 

of management areas. 

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

187

Appendix F. Supplemental Information

for Wildlife and Rare Plants Analysis

Table 145. Key for associated habitat and ecosystem management area codes in wildlife and rare 

plants tables

Status

E = endangered

T = threatened

C = candidate

P = proposed

Ex = 

experimental/nonessential

NW = listing not warranted

D = delisted

PR = petitioned for relisting

SS = Forest Service sensitive 

species (Southwestern 

Region)

O = forest planning species or 

other status

MIS = management indicator 

species

Known or Likely 

Occurrences on Forest by 

Ecosystem Management 

Area

1 = Peloncillo

2 = Chiricahua

3 = Dragoon

4 = Tumacacori

5 = Santa Rita

6 = Huachuca

7 = Whetstone

8 = Pinaleño

9 = Winchester

10 = Galiuro

11 = Santa Teresa

12 = Santa Catalina

Associated Habitat*

A = Riparian

B = Spring

C = Lotic

D = Lentic

E = Cliff/rock

F = Terrestrial

G = Cave

H = Other

1 = Desert Communities

2 = Valley Grasslands

3 = Interior Chaparral

4 = Madrean Encinal/PJ

5 = Madrean Pine-Oak

6 = Ponderosa Pine

7 = Mixed-Conifer Forest

8 = Subalpine Forest

9 = Montane Meadow

* Alpha characters correspond to physical habitat components, while numerals correspond to biotic habitat components, 

based on potential natural vegetation types.
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

188

All Forest Planning Species 

on the Coronado National Forest

Table 146 shows all species that were considered in the coarse- and fine-filter analyses for species 

viability. See the key above (table 145) for letter and number code interpretations.

Table 146. Wildlife and plant species considered in the analysis

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Mammals

Jaguar Panthera onca E AF45 1, 2, 4, 5, 6, 7 F

Mount Graham red 

squirrel

Tamiasciurus 

hudsonicus grahamensis

E, MIS F78 8 F

Ocelot Leopardus pardalis E AF23456 1, 2, 4, 5, 6, 7 F

Lesser long-nosed bat Leptonycteris 

yerbabuenae

E FG1234 1 thru 12 F

Mexican long-nosed 

bat

Leptonycteris nivalis E FG23456 1 F

Mexican gray wolf Canis lupus baileyi E, Ep F45678 Extirpated C

Pocketed free-tailed bat Nyctinomops 

femorosaccus

SS E1-5 4, 5, 10, 12 C

Big free-tailed bat Nyctinomops macrotis O AEG12 2 C

Mule deer Odocoileus hemionus O F1-4 1 thru 12 C

White-tailed deer Odocoileus virginanus O F2-9 1 thru 12 C

[Desert] bighorn sheep Ovis canadensis 

[mexicana]

SS AE12 10, 12 F

Mesquite (Merriam’s) 

mouse

Peromyscus merriami SS AF1-2 4, 5, 6, 12 C

Mountain lion Puma concolor O F2-7 1 thru 12 C

Fulvous harvest mouse Reithrodontomys 

fulvescens

SS F2-4 1, 4, 5, 6, 7 C

Plains harvest mouse Reithrodontomys 

montanus

SS F2-4 3, 5, 6, 7 C

Arizona gray squirrel Sciurus arizonensis O A4-7 4, 5, 6, 12 C

Chiricahua [fox] 

squirrel

Sciurus nayaritensis 

chiricahuae

SS AF56 2 C

Yellow-nosed cotton 

rat

Sigmodon ochrognathus SS F4-9 2, 4, 5, 6, 12 C

Arizona shrew Sorex arizonae SS BC4-7 1, 2, 5, 6 C

Botta’s [Graham 

Mountains] pocket 

gopher

Thomomys bottae 

[includes grahamensis]

SS F1-9 1 thru 12 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

189

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Southern pocket 

gopher [includes 

Huachuca and Pajarito 

endemic forms]

Thomomys umbrinus 

[includes intermedius 

and quercinus]

SS F45 4, 5, 6 C

Black bear Ursus americanus O F2-9 1 thru 12 C

Pronghorn antelope Antilocapra americana O F2 1 thru 12 C

Northern pygmy mouse Baiomys taylori [ater] SS F2 1, 2, 4, 5, 6 C

Mexican long-tongued 

bat

Choeronycteris 

mexicana

SS AFG45 1, 2, 3, 4, 5, 6, 

7, 12

F

[Pale] Townsend’s bigeared batPlecotus townsendii 

[pallescens]

SS FG1234567 1 thru 12 F

[Greater] western 

mastiff bat

Eumops perotis 

[californicus]

SS AEF12 2 thru 12 C

Allen’s big-eared bat Idionycteris phyllotis SS AEG4567 2, 8, 10 C

Western red bat Lasiurus blossevillii SS AF24567 1, 2, 4, 5, 6, 7, 

8, 10

C

Western yellow bat Lasiurus xanthinus SS AF12345 1, 2, 4, 12 C

White-sided jackrabbit Lepus callotis SS FH2 1 (maybe) C

California leaf-nosed 

bat

Macrotus californicus SS EFG1 4, 5, 10, 12 C

Hooded skunk Mephitis macroura 

milleri

SS AEF1-7 1-12 C

White-bellied [longtailed] voleMicrotus longicaudus 

leucophaeus

SS F7-9 8 C

White-nosed coati Nasua narica SS AF2,4-6 2, 4, 6, 8 C

Cockrum’s gray shrew Notiosorex cockrumi SS AF24 2, 3, 4, 5, 6, 7 C

Birds

Southwestern willow 

flycatcher

Empidonax traillii 

extimus

E A F

Masked bobwhite Colinus virginianus 

ridgewayi

E F2 4 F

Mountain plover Charadrius montanus NW F4? Unknown F

Western yellow-billed 

cuckoo

Coccyzus americanus 

occidentalis

T A124 1 thru12 F

Mexican spotted owl Strix occidentalis lucida T, MIS F567 1 thru 12 F

Bald eagle Haliaeetus 

leucocephalus

T, D, 

SS

riverine, 

lacustrine

1 thru 12 C

American peregrine 

falcon

Falco peregrinus 

anatum

D, SS E1-7 1 thru 12 F

Cactus ferruginous 

pygmy-owl

Glaucidium brasilianum 

cactorum

D, PR, 

SS

A1 5, 6, 12 C

Northern Aplomado

falcon

Falco femoralis 

septentrionalis

Ex F2 1, 2 F
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

190

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Northern goshawk Accipiter gentilis SS F4-7 1 thru 12 F

Violet-crowned 

hummingbird

Amazilia violiceps SS A145 1, 2, 5, 6 C

Baird’s sparrow Ammodramus bairdii SS F2 1 to 12, but 

spotty and 

mostly in 

valleys below 

Forest

C

Arizona grasshopper 

sparrow

Ammodramus 

savannarum ammolegus

SS F2 1, 2, 4, 5, 6, C

Northern gray hawk Asturina (=Buteo) nitida 

maximus

SS A1-4 1, 4, 6 C

Common black-hawk Buteogallus anthracinus SS A1-2,6-8 6, 8, 12 C

Lucifer hummingbird Calothorax lucifer SS F12 1, 2, 6, 7 C

Northern beardless 

tyrannulet

Camptostoma imberbe SS A1-4 1, 4, 5, 6, 8, 

10, 12

C

Buff-collared nightjar Caprimulgus ridgwayi SS AEF12 1, 4, 12 C

Broad-billed 

hummingbird

Cynanthus latirostris SS A1-5 1-12 C

Montezuma quail Cyrtonyx montezumae F245 1, 2, 4, 5 C

Northern buff-breasted 

flycatcher

Empidonax fulvifrons 

pygmaeus

SS F5 1, 2, 5, 6, 12 C

Eared quetzal Euptilotis neoxenus SS F56 1, 2 C

White-eared 

hummingbird

Hylocharis leucotis SS A5-7 2, 6, 8 C

Wild turkey Meleagris gallopavo SS AF4-8 1, 2, 4, 5, 6, 8, 

10, 12

C

Whiskered screech owl Otus trichopsis SS AF45 1, 2, 4, 5, 7, 10 C

Rose-throated becard Pachyramphus aglaiae SS A124 4, 6 C

Varied bunting Passerina versicolor SS AF12 1, 2, 4, 5, 6, C

Band-tailed pigeon Patagioenas fasciata O F4-8 1 thru 12 C

Abert’s towhee Pipilo aberti SS A12 1-12 (mostly 

in deserts 

below forest)

C

Black-capped

gnatcatcher

Polioptilla nigriceps O A124 4, 5, 6 C

Elegant trogon Trogon elegans O A45 1, 2, 4, 5, 6 C

Thick-billed kingbird Tyrannus crassirostris SS A12 1, 2, 4, 6, 12 C

Amphibians

Sonora tiger 

salamander

Ambystoma mavortium 

stebbinsi

E AD2 6 F

Chiricahua leopard 

frog

Lithobates 

chiricahuensis

T ACD245 1, 2, 3, 4, 5, 6, 

10

F
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

191

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Arizona treefrog 

(Huachuca/Canelo 

distint population 

segment)

Hyla wrightorum NW AE45 6 F

Tarahumara frog Lithobates tarahumarae SS ACD24 5 C

Western barking frog Craugastor augusti 

cactorum

SS E245 4, 5, 6 C

Lowland leopard frog Lithobates yavapaiensis SS ACD12 4, 10, 11, 12 F

Plains leopard frog Lithobates blairi SS ACDF245 Formerly 2 C

Great Plains narrowmouthed toadGastrophryne olivacea SS ACDF1245 4, 5, 6, 12 C

Reptiles

New Mexico ridgenosed rattlesnakeCrotalus willardi 

obscurus

T AEF345 1 F

Northern Mexican 

gartersnake

Thamnophis eques 

megalops

T A234 4, 5, 6 F

Arizona striped 

whiptail

Aspidoscelis arizonae O (90-

DAY)

F2 8? 9? 10? C

Red-backed whiptail Aspidoscelis xanthonota O F1 4? C

Bezy’s night lizard Xantusia bezyi O E134 10? C

Giant spotted whiptail Aspidoscelis burti 

stictogramma

SS AF124 1, 4, 5, 6, 8, 9, 

10, 11, 12

F

Twin-spotted 

rattlesnake

Crotalus pricei SS E678 2, 5, 6, 8 C

Arizona ridge-nosed 

rattlesnake

Crotalus w. willardi SS AF459 5, 6, 7 C

Sonoran Desert tortoise Gopherus morafkai NW F12 4, 10, 12 C

Thornscrub hooknosed snakeGyalopion 

quadrangulare

SS F124 4 C

Sonoran mud turtle Kinosternon sonoriense O, MIS CDF245 1 thru 12 C

Slevin’s bunchgrass 

lizard

Sceloporus slevini SS AF56 1, 2, 3, 5, 6, 7 C

Chihuahuan blackheaded snakeTantilla wilcoxi O F567 4, 5, 6 C

Yaqui black-headed 

snake

Tantilla yaquia SS AF1245 1, 2, 4 C

Desert box turtle Terrepene ornata 

luteola

O F2 1 thru 12 C

Brown vinesnake Oxybelis aeneus SS F24 4 C

Green ratsnake Senticolis triaspis SS A4 1, 2, 4, 6 C

Mountain skink Plestiodon callicephalus SS AEF45 1, 4, 6 C

Gila monster Heloderma suspectum SS AF12 1 thru 12 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

192

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Fish

Gila chub Gila intermedia E C12 12 F

Yaqui chub Gila purpurea E C24 2 F

Yaqui catfish Ictalurus pricei E C2 2 F

Gila topminnow Poeciliopsis occidentalis E C124 6 F

Sonora chub Gila ditaenia T C24 4 C

Desert pupfish Cyprinodon macularius E C12 F

Spikedace Meda fulgida E C F

Loach Minnow Tiaroga cobitis E C F

Gila trout Oncorhynchus gilae T C5678 8 F

Apache trout Oncorhynchus gilae 

apachae

T C5678 8 F

Roundtail Chub Gila robusta P C F

Mexican stoneroller Campostoma ornatum SS C245 2 F

Sonora sucker Catostomus insignis SS C24 4, 5 F

Longfin dace Agosia chrysogaster SS C1-4 2, 4, 5, 6, 12 

(from D 

Mitchell, pers 

comm., 

1/24/07)

C

Desert sucker Catostomus clarkii SS C24 5, 10 F

Speckled dace Rhinichthys osculus O C124 6, 7, 10 C

Insects

Stephan’s riffle beetle Heterelmis stephani Extinct BC4 5 F

Sunrise skipper Adopaeoides prittwitzi O D 5, 6 C

Persephone’s darner Aeshna persephone O C5 2, 6 (at least) C

Huachuca giantskipperAgathymus evansi SS F45 6 F

False Ameletus mayfly Ameletus falsus O CF9 2, 12 C

Sabino dancer Argia sabino O? SS? C124 4, 12 C

A Notodontid moth Astylis biedermani O F24 2, 6 C

Patagonia eyed 

silkmoth

Automeris patagoniensis O F45 2, 6 C

A caddisfly Chimarra primula O C45 2 C

Maricopa tiger beetle Cicindela oregona 

maricopa

O A1-5 1, 2, 8, 11 C

A mayfly Cloeodes peninsulus O C4-7 2 C

Ball’s monkey 

grasshopper

Eumorsea balli O F3 6 C

Pinaleño monkey 

grasshopper

Eumorsea pinaleno SS F8 8 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

193

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Red whiskers 

grasshopper

Melanoplus desultorius O F2 1 thru 12 C

A spur-throat 

grasshopper

Melanoplus pinaleno O F79 8 C

A caddisfly Nectopsyche dorsalis O C2-5 4 C

A Notodontid moth Oligocentria delicata O F45 2, 3, 5, 6 C

Arizona snaketail Ophiogomphus 

arizonicus

SS AC6 6 + C

Desert shadowdamsel Palaemnema domina O AC12 10 C

Four-spotted 

skipperling

Piruna polingii SS AF1-7,9 2, 6 C

Arizona water penny 

beetle

Psephenus arizonensis O C45 2 C

Bluish fritillary Speyeria nokomis 

coerulescens

O AB567 5, 6, 12 C

A royal moth Sphingicampa raspa O F4 5, 6, C

A sphinx moth Sphinx smithi O F4 6 C

Spot-winged 

meadowhawk

Sympetrum signiferum O AC45 2, 6 C

A stonefly Taenionema jacobii O AC12 12 C

A lichen moth Agylla septentrionalis O unknown unknown C

A tiger moth Alexicles aspersa O unknown unknown C

Montane giant tiger 

beetle

Amblycheila baroni O FE4 "most" C

A stonefly Amphinemura apache O BC-unknown 2 C

A stonefly Amphinemura venusta O BC-unknown unknown C

Pima dancer Argia pima O BC-unknown unknown C

Sonoran bandedskipperAutochton pseudocellus O A4 formerly 2, 6 C

Atascosa gem 

grasshopper

Aztecacris gloriosus O F2 4 C

An underwing moth Catocala frederici O unknown Cochise Co. C

A caddisfly Chimarra adella O unknown unknown C

Glittering tiger beetle Cicindela fulgoris 

erronea

O unknown unknown C

Horn’s tiger beetle Cicindela hornii O F2 unknown C

Nevada tiger beetle Cicindela nevadica 

citata

O unknown unknown C

A Notodontid moth Cisthene coronado O AF45 4, 5 C

A grasshopper Conalcaea cantralli O unknown unknown C

A caddisfly Culoptila moselyi O AB678 2 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

194

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Arizona Cymbiodytan 

water scavenger beetle

Cymbiodyta arizonica SS ABCDunknown2 F

Mayan setwing Dythemis maya O unknown unknown C

Claw-tipped bluet Enallagma 

semicirculare

O unknown unknown C

A tiger moth Grammia allectans O unknown unknown C

Stone’s buckmoth Hemileuca stonei O F4 most area of 

SE EMAs

C

A Notodontid moth Heterocampa amanda O F5 4, 6 C

A Notodontid moth Heterocampa incongrua O F4 unknown C

Colorado hairstreak Hypaurotis crysalus 

intermedia

O F67 2, 5, 6, 8, 12 

and more at 

spp level

C

A lichen moth Inopsis funerea O unknown Cochise Co. C

A caddisfly Lepidostoma acarolum O unknown unknown C

Lichen grasshopper Leuronotina ritensis O FE5 Prob 5, 12 C

Bleached skimmer Libellula composita O unknown unknown C

A caddisfly Limnephilus granti O AC 8 C

A spur-throat 

grasshopper

Melanoplus chiricahuae O F6-9 2 C

A spur-throat 

grasshopper

Melanoplus magdalenae O F6-9 2 C

Sabino stonefly Mesocapnia werneri O unknown presumably 12 C

A caddisfly Metrichia arizonensis O unknown unknown C

A caddisfly Micrasema arizonica O unknown unknown C

Antioch potter wasp Microdynerus 

arenicolus

O unknown unknown C

A caddisfly Ochrotrichia argentea O unknown unknown C

A caddisfly Ochrotrichia rothi O unknown unknown C

A caddisfly Ochrotrichia spinulata O unknown unknown C

Alberta Arctic Oeneis alberta daura O unknown 8 (unless a 

mistake)

C

A caddisfly Polycentropus gertschi O unknown unknown C

Snow’s toothpick 

grasshopper

Prorocorypha snowi O unknown 5 C

Terloo’s sphinx Proserpinus terlooii O F24 Not sure: 

Cochise, Santa 

Cruz, and 

Pima Cos

C

A tiger moth Pygarctia neomexicana O unknown SE AZ C

A tiger moth Sonorarctia fervida O unknown Cochise Co. C

A caddisfly Tinodes parvulus O unknown unknown C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

195

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Cestus skipper Atrytonopsis cestus SS AEF(1)24 4, 5, 10, 12 C

Monarch butterfly Danaus plexippus O most 1 thru 12, but 

especially 

Canelo Hills 

during 

migration

C

Other 

Invertebrates

A cave obligate 

pseudoscorpion

Chitrellina chiricahuae O G4 2 C

Arizona cave 

amphipod

Stygobromus 

arizonensis

O CG4 2, 5, 6 F

A cave obligate 

pseudoscorpion

Tuberochernes ubicki O G4 5 C

A cave obligate spider Thymoites minero O unknown unknown C

Mollusks

Huachuca springsnail Pyrgulopsis thompsoni NW,SS BD245 6 F

Angulate 

woodlandsnail

Ashmunella angulata O EF456 2 C

Cave Creek 

woodlandsnail

Ashmunella 

chiricahuana

O EF67 2 C

Barfoot [“Bearfoot”] 

woodlandsnail

Ashmunella esuritor O EF56 2 F

Reed’s Mountain 

woodlandsnail

Ashmunella ferrissi O EF45 2 C

Horseshoe Canyon 

woodlandsnail

Ashmunella lenticula O EF45 2 C

Whitetail 

woodlandsnail

Ashmunella lepiderma O EF45 2 C

Huachuca 

woodlandsnail

Ashmunella levettei O EF4567 6 C

Chiricahua 

woodlandsnail

Ashmunella proxima O AE234567 2 F

Miller Canyon 

woodlandsnail

Ashmunella varicifera O EF4567 6 C

Shortneck snaggletooth Gastrocopta dalliana O ABEFH1234567 2, 3, 4, 5, 6, 7, 

8, 10, 12

C

Sonoran snaggletooth Gastrocopta prototypus O F245 2, 3, 6 C

Cross snaggletooth Gastrocopta quadridens O F789 2, 6, 8, 12 C

Arizona Holospira Holospira arizonensis O EF45 2 C

Cave Creek Holospira Holospira chiricahuana O EF45 2 C

Stocky Holospira Holospira ferrissi O ACEF1245 2, 3, 6 C

Silver Creek Holospira Holospira sherbrookei O E2 2 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

196

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Teasing Holospira Holospira tantalus O EF245 3 C

Whetstone Holospira Holospira whetstonensis O F245 7 C

Santa Rita rabdotus Naesiotus christenseni O unknown 5 C

Bearded mountainsnail Oreohelix barbata SS E4567 2 C

Huachuca 

mountainsnail

Oreohelix concentrata O E234567 3, 6, 7, 12 C

Pinaleño mountainsnail Oreohelix grahamensis SS EF67 8 F

Arizona mantleslug Pallifera pilsbryi O F67 12 C

Cayuse Physa Physella osculans O “aquatic” unknown C

Chiricahua 

mountainsnail

Radiocentrum 

chiricahuana

O AE456 2 C

Cave Creek 

mountainsnail

Radiocentrum clappi O E456 2 C

Ribbed pinwheel Radiodiscus 

millecostatus

O ABFG456789 2, 3, 6, 12 C

Apache talus snail Sonorella apache O E45 3 C

Rincon talus snail Sonorella bagnarai O F7 12 C

Happy Valley talus 

snail

Sonorella bequaerti O F2345 12 (if any) C

Horsehoe Canyon talus 

snail

Sonorella binneyi O F245 2 C

Quartzite Hill talus 

snail

Sonorella bowiensis O F45 2 (if any) C

Blue talus snail Sonorella 

caerulifluminis

O F24 unknown C

Clark Peak talus snail Sonorella christenseni SS E67 8 C

Madera talus snail Sonorella clappi O AEF456 5 C

Garden Canyon talus 

snail

Sonorella dalli O AF45 6 C

Bear Canyon talus 

snail

Sonorella danielsi O F45 6 C

Stronghold Canyon 

talus snail

Sonorella dragoonensis O EF4 3 C

Dragoon talus snail Sonorella ferrissi O E45 3 C

Galiuro talus snail Sonorella galiurensis O E124 10 (if any) C

Pinaleño talus snail Sonorella grahamensis SS EF567 8 C

Peloncillo talus snail Sonorella hachitana 

peloncillensis

SS EF4567 1 C

Mimic talus snail Sonorella imitator SS EF78 8 C

Whetsone talus snail Sonorella insignis O EF45 7 C

Wet Canyon talus snail Sonorella macrophallus SS AEF567 8 F
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

197

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Sonoran talus snail Sonorella 

magdalenensis

O EF245 4, 5 C

Pygmy Sonorella Sonorella micra O E5 2 C

Portal talus snail Sonorella neglecta O F4 2 C

Pungent talus snail Sonorella odorata O EF567 12 F

Big Emigrant talus 

snail

Sonorella optata O E45 2 C

Posta Quemada talus 

snail

Sonorella rinconensis O assume rock 

association

12 C

Rosemont talus snail Sonorella rosemontensis O E4 5 C

Sanford talus snail Sonorella tryoniana O AEF24 5 C

Chiricahua talus snail Sonorella virilis O E4567 2 C

Heart Vertigo Vertigo hinkleyi O F456 6 F

Fungi-Lichen

No common name Heterodermia 

appalachensis

O EF45 2, 5 C

Rugose skin lichen Leptogium rugosum O EF45 2, 5 C

No common name Omphalora arizonica O F7 5 C

No common name Xanthoparmelia 

ajoensis

O AF124 5 C

No common name Xanthoparmelia 

dissensa

O E24 2, 5, 8, 12 C

No common name Xanthoparmelia 

huachucensis

O E24 4, 5, 6 C

No common name Xanthoparmelia 

nigropsomifera

O E2 4, 12 C

Mosses-Liverworts

Ehrenberg’s barbula 

moss 

Barbula ehrenbergii 

(=Barbula bolleana)

O unknown unknown C

No common name Mannia californica O AE45 4, 12 F

No common name Plagiochasma wrightii O AE4 2, 4 F

Agoyan cataract moss Scopelophila cataractae O unknown unknown C

No common name Tayloria splachnoides O unknown unknown C

Plants

Canelo Hills 

ladies’tresses

Spiranthes delitescens E RIP, SPG: 

GRA, ENC

HUA F

Pima pineapple cactus Coryphantha scheeri 

var. robustispina

E F12 5, 6 F

Huachuca water umbel Lilaeopsis schaffneriana 

var. recurva

E ABD1245 6 F

Lemmon’s fleabane Erigeron lemmonii NW ROC: PIO HUA F
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

198

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Parish’s Abutilon Abutilon parishii SS AE12 4, 5, 12 F

Milfoil acacia Acacia millefolia O F234 2, 3, 5, 7, 9, 12 C

Thread-leaf gianthyssopAgastache rupestris O F4 4, 5, 10 C

Santa Cruz striped 

agave

Agave parviflora ssp. 

parviflora

SS F24 4, 5, 6 C

Trelease agave Agave schottii var. 

treleasei

SS F234 12 C

Toumey agave Agave toumeyana O F1-5 8 C

Goodding’s onion Allium gooddingii SS F78 12 C

Redflower onion Allium rhizomatum 

(=glandulosum)

O AF245 2, 6 C

Santa Rita yellowshow Amoreuxia gonzalezii SS EF2 5 F

Arizona slimpod Amsonia grandiflora SS F4 4, 6 C

False indian-mallow Anoda abutiloides O F1-4 4, 5, 12 C

Cliff brittlebush Apacheria 

chiricahuensis

O E5 2, 3 C

Rincon Mountain 

rockcress

Arabis tricornuta SS F5-79 2, 5, 6, 12 C

Southwestern white 

pine dwarf-mistletoe

Arceuthobium blumeri O Parasitic on SW 

White Pine; F7

2, 8, 10, 11, 12 C

Western spruce dwarfmistletoeArceuthobium 

microcarpum

O Parasitic on 

spruce; F8

8 C

Lemmon milkweed Asclepias lemmonii SS F45, disturbed 2, 5, 6 C

Greene’s milkweed Asclepias uncialis ssp. 

uncialis

SS F259; disturbed 

areas

6 C

Halfmoon milk-vetch Astragalus allochrous 

var. playanus

O F259 1 thru 12 C

Copper Mine milkvetchAstragalus cobrensis 

var. maguirei

SS A45 1, 2 F

Huachuca milk-vetch Astragalus hypoxylus SS F4 6 F

Ashen milk-vetch Astragalus tephrodes 

var. brachylobus

O unklnown 8 C

Windham’s scale 

cloak-fern

Astrolepis windhamii O F234 2, 3, 4, 6, 12 C

Ayenia Ayenia truncata (= A. 

glabra)

SS F12 5 F

Tucson Mountain 

spiderling

Boerhavia megaptera O F12 12? C

Wright’s bluestem Bothriochloa wrightii O F45 6 C

Santa Rita gramma Bouteloua eludens O F2 4, 5, 12 C

Parry’s gramma Bouteloua parryi O F2 1, 2, 3, 7, 9, 5, 

12

C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

199

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Rothrock’s gramma Bouteloua rothrockii O F2 1 thru 12 C

Resin-leaved brickellbushBrickellia baccharidea O EF1-4 2, 4, 5, 6, 1 2 C

Lemmon's beggar-ticks Brickellia lemmonii var. 

lemmonii

O F6 1, 2 C

Mt. Davis brickellbushBrickellia parvula O AE6 12 C

Sonoran brickell-bush Brickellia simplex O F4-6 1, 2, 6 C

Arizona brome Bromus mucroglumis O AEF?? 2, 5, 6, 12 C

Elusive browallia Browallia eludens SS AF45 6 F

Arizona bluehearts Buchnera arizonica O A4 4 C

Chiltepin Capsicum annuum var. 

glabriusculum

SS AF24 2, 4 C

Chihuahuan sedge Carex chihuahuensis SS AD5-7,9 2, 5, 6, 8, 12 F

Cochise sedge Carex ultra SS AB45 1, 2, 3, 4, 5, 6, 

10

F

Trans-Pecos indian 

paintbrush

Castilleja nervata SS F456 2, 5, 12 C

Graceful lip fern Cheilanthes yavapensis O A124 5, 8, 10, 12 C

Soft Mexican-orange Choisya dumosa var. 

mollis

SS F45 4 F

Rose-color thistle Cirsium rothrockii O F4-6 2, 3, 6, 8 C

Mexican hemlockparsleyConioselinum 

mexicanum

SS F67 5, 6 C

Recurved corycactus Coryphantha recurvata SS F234 4 F

Smooth baby-bonnets Coursetia glabella SS F45 2, 6 F

Pointed cat’s-eye Cryptantha muricata 

var. denticulata

O AF5 8 C

Los pinitos dodder Cuscuta 

dentatasquamata

O unknown 5 C

Cochise dodder Cuscuta mitriformis O A6 2 C

Santa Rita dodder Cuscuta odontolepis O unknown 2 C

Narrow-leaf (Wiggins) 

swallow-wort

Cynanchum wigginsii 

(=Metastelma 

mexicanum)

SS F4 4, 6, 12 C

Gentry’s indigobush Dalea tentaculoides SS A45 4 C

Oakwoods prairiecloverDalea versicolor var. 

sessilis

O F1-4 1, 2, 3, 4, 5, 6, 

8, 12

C

Chiricahua Mountains 

larkspur

Delphinium andesicola O F67 2, 6, 8, 12 C

Rocky Mountain 

larkspur

Delphinium scopulorum O A5 2, 5 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

200

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Metcalfe’s tick-trefoil Desmodium metcalfei SS AF245 4, 5, 6 C

Heller’s whitlow-grass Draba helleriana var. 

bifurcata

O E78 2, 8, 12 C

Rock whitlow-grass Draba petrophila var. 

viridis

O E4-7 (6, 12) 1 thru 

12

C

Standley’s whitlowgrassDraba standleyi O E4-8 2 C

Pinewood drymary Drymaria effusa var. 

effusa

O F56 2, 4, 5, 6, 8, 12 C

Arid throne fleabane Erigeron arisolius SS F24 2, 3, 4, 5, 6, 9 F

Arizona fleabane Erigeron arizonicus O EF4-8 2, 6 C

Heliograph Peak 

fleabane

Erigeron heliographis SS E78 8 C

Chiricahua fleabane Erigeron kuschei SS E67 2 C

Pringle’s fleabane Erigeron pringlei O AE7 5, 8 F

Winn Falls fleabane Erigeron scopulinus O E6-8 2 C

Arizona wildbuckwheatEriogonum arizonicum O F1; disturbed 

areas

1, 2, 3, 7, 8, 9, 

10, 11

C

Arizona eryngo Eryngium 

sparganophyllum

O A456 5, 12 F

Orcutt’s foxtail cactus Escobaria orcuttii O E12 1, 2 C

Bisbee’s pincushion 

cactus

Escobaria vivipara var. 

bisbeeana

O F2 1, 2, 4, 5, 6, 7, 

11, 12

C

Bigelow’s 

thoroughwort

Eupatorium bigelovii O AE7 8 F

Goodding’s ash Fraxinus gooddingii O F24 4 C

Chihuahua ash Fraxinus papillosa O F45 1, 2, 3, 4, 5, 6 C

Wright’s milkpea Galactia wrightii var. 

mollissima

unknown 8 C

Chiricahua gentian Gentianella wislizeni SS F679 2 F

Chiricahua vervain Glandularia 

chiricahensis

O F6-9 2, 6 C

Bartram’s stonecrop Graptopetalum 

bartramii

SS EF45 2, 3, 4, 5, 12 C

Chihuahuan stickseed Hackelia ursina O F56 2, 5, 8, 10, 12 C

Ribbed mock 

pennyroyal

Hedeoma costatum O E5, disturbed 2 C

Arizona false 

pennyroyal

Hedeoma dentata O EF6; disturbed 1 thru 12 C

Santa Catalina 

burstwort

Hermannia pauciflora O EF1 12 F

Rutter’s golden-aster Heterotheca rutteri SS disturbed;F24 4, 5, 6 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

201

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Chiricahua Mountain 

alumroot

Heuchera glomerulata SS AB24567 2, 8, 10, 12 C

Coral-bells Heuchera sanguinea O unknown 2, 5, 12 C

Crested coralroot Hexalectris arizonica SS F2456 2, 3, 4, 5, 6, 7, 

9, 12

C

Coleman’s coralroot Hexalectris colemanii SS A24 5 F

Purple-spike coralroot Hexalectris warnockii SS F45 2, 6 F

Lemmon’s hawkweed Hieracium lemmonii O AF67 2, 5, 6, 12 C

Rusby’s hawkweed Hieracium rusbyi SS F7 2, 6, 8, 12 C

Pinaleño Mountains 

rubberweed

Hymenoxys ambigens 

var. ambigens

O F4 8, 11 C

Pinaleño Mountains 

rubberweed

Hymenoxys ambigens 

var. floribunda

O F4,5,6 2, 3 C

New Mexico 

bitterweed

Hymenoxys ambigens 

var. neomexicana

SS F4 1 C

Rincon bitterweed Hymenoxys 

quinquesquamata

O F5 2, 5, 6, 12 C

California satintail Imperata brevifolia O AB1-4 12 C

Huachuca Mountain 

morning-glory

Ipomoea plummerae 

var. cuneifolia

O F9 2, 4, 5, 6 C

Lemmon’s morninggloryIpomoea tenuiloba var. 

lemmonii

O F1-4 2, 4, 5, 6 C

Thurber’s morninggloryIpomoea thurberi O F24 2, 4, 5, 6 C

Cochise woolwort Laennecia eriophylla O F24 4, 5, 6 C

White Mountain 

bladderpod

Lesquerella pinetorum O F2-4 2, 8, 11 C

Lemon lily Lilium parryi SS A678 2, 5, 6 C

Chiricahua mudwort Limosella pubiflora SS BC4-7 1, 2 F

Arizona gromwell Lithospermum confine O unknown 2 C

Sonoran trefoil Lotus alamosanus SS AB4 4 C

Huachuca Mountain 

lupine

Lupinus huachucanus SS F4, disturbed 2, 5, 6 C

Lemmon’s lupine Lupinus lemmonii SS F6 3, 5, 12 C

New Mexico lupine Lupinus neomexicanus O F4-8, disturbed 2, 8, 12 C

Giant-trumpets Macromeria viridiflora O F6 2, 5, 6, 7, 12 C

Stebbins desertdandelionMalacothrix stebbinsii O F12 5, 12 C

Graham nipple cactus Mammillaria grahamii 

var. oliviae

O F12 2, 4, 5, 6 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

Final Programmatic Environmental Impact Statement for 

Revision of the Coronado National Forest Land and Resource Management Plan

202

Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Little nipple cactus Mammillaria heyderi 

var. bullingtoniana 

(=aplanata)

O F124 1 C

Little nipple cactus Mammillaria heyderi 

var. macdougalii

O F1-4 3, 4, 5, 7, 12 C

Arizona manihot Manihot davisiae SS F12 5, 12 C

Netted globeberry Margaranthus 

solanaceus (=lemmonii)

O F124 2, 3, 5, 6, 8, 12 C

Spreading marina Marina diffusa O F5 6 C

Balbis (=Huachuca 

milkweed vine)

Matelea (=Pherotrichis) 

balbisii

O F45 6 C

Southwest 

monkeyflower

Mimulus dentilobus O AB24 5 F

Bamboo muhly Muhlenbergia dumosa O F124 4, 12 C

Sycamore muhly Muhlenbergia elongata 

(=M. xerophila)

SS AEF45 4, 5, 12 C

Southwestern muhly Muhlenbergia palmeri 

(=M. dubioides)

SS AF1-4 4, 5, 6, 12 C

Arizona yellowhood Nissolia wislizeni O F2 6 C

Gray’s cloakfern Notholaena grayi ssp. 

sonorensis

O E1-4 1thru 12 C

Lemmon's cloak-fern Notholaena lemmonii O E234 4, 12 C

Texas false-garlic Nothoscordum texanum O F24 6, 12 C

New Mexico pricklypearOpuntia phaeacantha 

var. laevis

O EF124 4, 5, 12 C

Toumey groundsel Packera neomexicana 

var. toumeyi

SS F567 2, 6, 12 C

Virlet’s paspalum Paspalum virletii SS F24 4, 5 C

Foetid passionflower Passiflora foetida 

(assume var. arizonica)

SS F12 4 C

Beardless chinch weed Pectis imberbis SS F24, disturbed 5, 6 F

Three-leaved cliffbrake Pellaea ternifolia ssp. 

arizonica

O E5 3, 6 C

Mt. Graham 

beardtongue

Penstemon deaveri O F6-9 8 C

Catalina beardtongue Penstemon discolor SS E456 4, 9, 10, 11, 12 C

Superb beardtongue Penstemon superbus O AF12 1, 3, 5, 6, 11, 

12

C

Western gold fern Pentagramma 

triangularis ssp. 

maxonii

O F1-5 4, 6, 12 C

Cochise rock daisy Perityle cochisensis SS E456 2 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

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Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Slimlobe rock daisy Perityle dissecta O E124 1, 2, 3, 5, 7, 8, 

9, 10, 11, 12

C

Supine bean Phaseolus supinus 

(=Maroptilium 

supinum)

SS F24 2, 4, 5, 6, 12 C

Santa Catalina 

Mountains phlox

Phlox tenuifolia O F1-4 10, 12 C

Rough mistletoe Phoradendron 

bolleanum ssp. 

pauciflorum

O F2-6, parasitic 

on ABCO, esp

2, 3, 4, 5, 6, 7, 

9, 12

C

Broad-leaf groundcherryPhysalis latiphysa SS F12 8 F

No common name Pinaropappus roseus 

var. foliosus

O F69 2, 6, 12 C

Pringle’s popcornflowerPlagiobothrys pringlei O F12 2, 3, 5, 7, 9, 12 C

Leafy Jacob’s-ladder Polemonium 

foliosissimum var. 

flavum

O F67 8 F

Hinkley’s Jacob’s 

ladder

Polemonium 

pauciflorum hinckleyi

SS AE678 2 F

White-flowered 

cinquefoil

Potentilla albiflora SS F6-9 8 F

Chiricahua cinquefoil Potentilla rhyolitica var. 

chiricahuensis

SS E7 2 C

Huachuca cinquefoil Potentilla rhyolitica var. 

rhyolitica

SS E7 5, 6 F

Navajo cinquefoil Potentilla subviscosa 

var. subviscosa

O F67 1 thru 12 C

Thurber’s cinquefoil Potentilla thurberi var. 

atrorubens

O AF679 8 C

Thurber’s cinquefoil Potentilla thurberi var. 

thurberi

O AF679 2, 12 C

Wheeler’s cinquefoil Potentilla wheeleri O F789 6 C

Gentry’s bare-ray-aster Psilactis gentryi SS AF5679 6 C

Whisk fern Psilotum nudum SS AF1 4 F

Frogbit buttercup Ranunculus 

hydrocharoides var. 

stolonifer

O ABD6 2, 6 C

Redberry buckthorn Rhamnus crocea ssp. 

pilosa

O F1-4 2, 3, 5, 7, 9, 12 C
Appendix F. Supplemental Information for Wildlife and Rare Plants Analysis

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Common Name Scientific Name Status

Associated 

Habitat

Ecosystem 

Management 

Area

Coarse 

or Fine 

Filter

Seemann (Hartweg’s) 

groundsel

Roldana hartwegii 

(=Senecio hartwegii, 

with syn = S. seemannii, 

S. carlomasonii, and R. 

carlomasonii)

O AF4-7 2, 4, 5, 6 C

Blumer’s dock Rumex orthoneurus SS AB789 2, 6, 8 C

Catalina Mountain sage Salvia amissa SS A124 9, 10, 12 C

Chiricahua Mountain 

brookweed

Samolus vagans SS AB45 2, 4, 5, 6, 12 C

Huachuca Mountains 

skullcap

Scutellaria tessellata O F24 2, 3, 4, 5, 6, 7, 

9, 12

C

Huachuca groundsel Senecio multidentatus 

var. huachucanus

SS EF567 2, 5, 6 C

Long-flower 

tubetongue

Siphonoglossa 

longiflora

O F12 12 C

Arizona blue-eyedgrassSisyrinchium arizonicum O F679 2, 6, 12 C

Nodding blue-eyed 

grass

Sisyrinchium cernuum SS AB1245 2, 4, 5, 12 C

Timberland blue-eyegrassSisyrinchium longipes O BF678 2, 8, 12 C

Arizona necklace Sophora arizonica O F124 7, 8 C

Porsild’s starwort Stellaria porsildii SS F79 2 F

Lemmon’s stevia Stevia lemmonii SS AEF56 5, 6, 12 C

Pinos Altos Mountains 

flameflower

Talinum humile SS F24 1, 6 C

Tepic flameflower Talinum marginatum SS E456 6 C

Aravaipa woodfern Thelypteris puberula 

var. sonorensis

SS ABE12 12 F

Sonoran noseburn Tragia laciniata SS AF56 4, 5, 6 C

Cusp clover Trifolium mucronatum 

ssp. lacerum

O AB4 6 C

Tumamoc globe-berry Tumamoca macdougalii SS F1 12 C

Arizona limestone 

rosewood

Vauquelinia californica 

ssp. pauciflora

O E24 1 C

Sunflower golden-eye Viguiera dentata var. 

lancifolia

O F1-6 4, 5, 6, 12 C

Ponderosa violet Viola umbraticola SS A5 5, 6, 12 C

Cochise woodsia Woodsia cochisensis O BE245 2, 3, 4, 5, 6 F

Phillips’ cliff fern Woodsia phillipsii O AE5 2, 6, 12 C
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Table 147. Key for table 148

Section Subsection Plan Section Title

ARP Animals and Rare Plants

BIP Biophysical Features

EMA CAT Santa Catalina Ecosystem Management Area

EMA CHI Chiricahua Ecosystem Management Area

EMA DRA Dragoon Ecosystem Management Area

EMA HUA Huachuca Ecosystem Management Area

EMA PEL Pelancillo Ecosystem Management Area

EMA PIN Pinaleño Ecosystem Management Area

EMA RIT Santa Rita Ecosystem Management Area

EMA TUM Tumacacori Ecosystem Management Area

ISM Invasive Species Management

LOA OPS Land Ownership and Adjustment

MIN Minerals

MTS Motorized Transportation

NWS Natural Water Sources

RAM Range Management

REC Recreation

RIA Riparian Communities

VIC Vegetation - Interior Chaparral

VMP Vegetation - Madrean Pine-Oak

VWM Vegetation - Wet Mixed-Conifer

WET Wetlands

WIL PSR Pusch Ridge Wilderness

Table 148. Codes for plan components used in the species viability analysis

(G=guideline, S = standard, O = objective, MA = management approach)

Section Subsection Component No. Plan Component Language

ARP G 1 Activities occurring within federally listed species habitat 

should apply habitat management objectives and species 

protection measures from approved recovery plans.

ARP G 2 Where the Forest Service has entered into signed 

conservation agreements that provide guidance on 

activities or actions to be carried out by national forest 

staff, those activities or actions should be undertaken 

consistent with the guidance found within those 

conservation agreements.

ARP G 3A A minimum of three goshawk nest areas and three 

replacement nest areas should be located per goshawk 

territory. Goshawk nest and replacement nest areas should 

generally be located in drainages, at the base of slopes, and 

on northerly (NW to NE) aspects. Nest areas should 

generally be 25 to 30 acres in size.
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Section Subsection Component No. Plan Component Language

ARP G 3B Goshawk post-fledging areas (PFAs) of approximately 420 

acres in size should be designated surrounding the nest 

sites.

ARP G 3C In goshawk foraging areas and PFAs, groups of three to 

five reserve trees should be retained within managementcreated openings greater than 1 acre in ponderosa pineevergreen shrub and dry mixed-conifer communities, and 

six reserve trees should be retained within managementcreated openings greater than 0.5 acre in wet mixed-conifer 

and spruce-fir communities.

ARP G 3D In occupied goshawk nest areas, human presence should be 

minimized between March 1 and September 30.

ARP G 4 Active raptor nests on cliff faces should be protected from 

disturbance during the nesting season.

ARP G 6 Identified bat roosts should be protected from disturbance 

during periods of bat occupancy. During nonoccupancy 

periods, activities should not modify biophysical features 

that contribute to roost habitat quality or contribute to the 

spread of diseases harmful to bats unless unavoidable in 

order to meet statutory requirements, such as mining law 

or laws to protect public health and safety.

BIP G 1 Talus slopes should not be altered and materials should not 

be removed from them. In areas that harbor talussnails, 

vegetation treatments should be designed to retain 

microhabitat characteristics for endemic snails and other 

talus-dependent species unless as needed to meet statutory 

requirements, such as mining law or laws to protect public 

health and safety.

BIP G 2 Management activities should be designed to avoid or 

minimize the alteration of naturally occurring rocky 

outcroppings or cliff faces.

BIP G 5 Identified bat roosts should be managed to provide for the 

enhancement and protection of bat populations. Protection 

measures may include seasonal closures, public education, 

and wildlife-friendly gates.

EMA CAT G 1 During vegetation treatments, mesic microenvironments 

for woodland and talus snails endemic to the Santa 

Catalina EMA should be protected (e.g., trees near rocky 

features, islands of shrubs within talus slopes, riparian 

colluvia, large logs, scattered rocks on shady hillsides).
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Section Subsection Component No. Plan Component Language

EMA CAT G 2 Management activities involving ground disturbance, 

vegetation management, or both should incorporate sitespecific design features to benefit habitat for, or mitigate 

impacts to rare or unique vertebrate, invertebrate and plant 

populations. For the Santa Catalina Ecosystem 

Management Area, these species include, but are not 

limited to:

• Aravaipa woodfern

• Arizona eryngo

• Arizona manihot

• Rusby's hawkweed

EMA CHI G 2 During vegetation treatments, considerations of mesic 

microenvironments for woodland and talus snails endemic 

to the Chiricahua EMA should be incorporated (e.g., trees 

near rocky features, islands of shrubs within talus slopes, 

riparian colluvia, large logs, scattered rocks on shady 

hillsides).

EMA CHI G 3 Management activities involving ground disturbance, 

vegetation management, or both should incorporate sitespecific design features to benefit habitat for, or mitigate 

impacts to, rare or unique vertebrate, invertebrate and plant 

populations. For the Chiricahua Ecosystem Management 

Area, these species include, but are not limited to:

• Chiricahua fleabane

• Chiricahua gentian

• copper mine milk-vetch 

• Hinkley’s Jacob’s ladder

• Porsild’s starwort

• purple-spike coralroot

• Rusby’s hawkweed 

• smooth baby-bonnets

EMA CHI S 2A Within South Fork of Cave Creek Zoological-Botanical 

Area: A special use permit is required for any plant or 

animal collection.

EMA CHI S 2B Within South Fork of Cave Creek Zoological-Botanical 

Area and the proposed Cave Creek Canyon Birds of Prey 

Zoological-Botanical Area: A special use permit is 

required for scientific research that would involve placing 

anything on National Forest System lands within the 

proposed zoological-botanical area.

EMA DRA G 3 Management activities involving ground disturbance 

and/or vegetation management should incorporate sitespecific design features to benefit habitat for, or mitigate 

impacts to, rare or unique vertebrate, invertebrate and plant 

populations. For the Dragoon Ecosystem Management 

Area, these species include, but are not limited to: 

Coleman’s coral-root and Purple-spike coral-root.
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Section Subsection Component No. Plan Component Language

EMA HUA G 1 In aquatic habitats occupied by Arizona treefrog, water 

levels should be maintained or enhanced during breeding 

season to a level adequate to support reproduction. 

EMA HUA G 2 Impacts from management actions such as grazing, 

vegetation treatments, and recreation should be mitigated 

within Arizona treefrog habitat.

EMA HUA G 3 During vegetation treatments, mesic microenvironments 

for woodland and talus snails endemic to the Huachuca 

EMA should be protected (e.g., trees near rocky features, 

islands of shrubs within talus slopes, riparian colluvia, 

large logs, scattered rocks on shady hillsides).

EMA HUA G 4 Management activities involving ground disturbance, 

vegetation management, or both should incorporate sitespecific design features to benefit habitat for, or mitigate 

impacts to rare or unique vertebrate, invertebrate and plant 

populations. For the Huachuca Ecosystem Management 

Area, these species include, but are not limited to:

• beardless chinch weed

• Cochise woolwort

• elusive browallia

• Huachuca cinquefoil

• Huachuca milkvetch

• Huachuca water umbel

• Pima pineapple cactus

• purple-spike coralroot

• Rusby’s hawkweed

• smooth baby-bonnets

EMA PEL G 2 Management activities involving ground disturbance, 

vegetation management, or both should incorporate sitespecific design features to benefit habitat for, or mitigate 

impacts to, rare or unique vertebrate, invertebrate and plant 

populations. For the Peloncillo Ecosystem Management 

Area, these species include, but are not limited to:

• Chiricahua mudwort

• Copper mine milk-vetch 

• New Mexico bitterweed

EMA PIN MA 1 Considering mesic microenvironments for woodland and 

talussnails endemic to the Pinaleño Ecosystem 

Management Area (such as trees near rocky features, 

islands of shrubs within talus slopes, riparian colluvia, 

large logs, scattered rocks on shady hillsides) when doing 

vegetation treatments.
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Section Subsection Component No. Plan Component Language

EMA PIN G 1 Management activities involving ground disturbance, 

vegetation management, or both should incorporate sitespecific design features to benefit habitat for, or mitigate 

impacts to, rare or unique vertebrate, invertebrate and plant 

populations. For the Pinaleño Ecosystem Management 

Area, these species include, but are not limited to:

• broad-leaf ground-cherry

• leafy Jacob’s ladder

• Rusby’s hawkweed

• white-flowered cinquefoil

EMA PIN G 3A Within habitat for Mount Graham red squirrel (MGRS) red 

squirrel habitat needs should supersede the needs of all 

other species of plants and animals.

EMA PIN G 3B Within habitat for Mount Graham red squirrel, hiking use 

levels should not negatively impact MGRS habitat or 

individuals.

EMA PIN G 3C Within habitat for Mount Graham red squirrel, vegetation 

treatments should be designed and implemented to avoid 

disturbance of MGRS middens.

EMA PIN O 1 Every 10 years, treat the vegetation using wildland fire 

(planned and unplanned ignitions), prescribed cutting, and 

mastication on at least 25 percent of the Pinaleño 

Ecosystem Management Area to create resiliency to 

disturbances. Treatments will be consistent with the 

objectives for forestwide vegetation communities and 

resources.

EMA PIN S 2 Within habitat for the Mount Graham red squirrel, no new 

recreational residence or developed recreation areas will be 

established.

EMA RIT G 2 Management activities involving ground disturbance, 

vegetation management, or both should incorporate sitespecific design features to benefit habitat for, or mitigate 

impacts to, rare or unique vertebrate, invertebrate and plant 

populations. For the Santa Rita Ecosystem Management 

Area, these species include, but are not limited to:

• Arizona eryngo

• Arizona Manihot

• Ayenia

• beardless chinch weed

• Chisos Coralroot

• Cochise woolwort

• Huachuca cinquefoil

• Pima pineapple cactus 

• purple-spike coral-root

• Santa Rita yellowshow

• Southwest monkeyflower
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Section Subsection Component No. Plan Component Language

EMA RIT O 1 Every 10 years, treat the vegetation using wildland fire 

(planned and unplanned ignitions), prescribed cutting, and 

mastication on at least 20 percent of the Santa Rita 

Ecosystem Management Area to create resiliency to 

disturbances. Treatments will be consistent with the 

objectives for forestwide vegetation communities and 

resources.

EMA TUM G 2 In rocky stream areas where large granitic boulders occur, 

projects should be designed to minimize or avoid impact to 

Mannia californica and Plagiochasma wrightii habitat.

EMA TUM G 3 Within the Wild Chile Botanical Area:

a. Planned and unplanned ignitions should be used 

seasonally prior to wild chile flowering and fruiting.

b. Livestock grazing should be deferred during the 

growing season of wild chiles, approximately August 

to November.

c. Wild chile plants should be protected when highseverity fire threatens the population.

EMA TUM G 4 Management activities involving ground disturbance 

and/or vegetation management should incorporate sitespecific design features to benefit habitat for, or mitigate 

impacts to, rare or unique vertebrate, invertebrate and plant 

populations. For the Tumacacori Ecosystem Management 

Area, these species include, but are not limited to, the 

following:

• Cochise woolwort

• recurved corycactus

• soft Mexican-orange

• whisk fern

ISM G 1 Habitat improvement and aquatic restoration projects 

within or adjacent to water sources occupied by ranid 

frogs, northern Mexican gartersnake, Sonora tiger 

salamanders, or native fish should include provisions to 

remove nonnative invasive animals.

LOA OPS MAOpen Space1 Working with willing landowners, communities, local 

governments, and partners to promote voluntary open 

space conservation. Participating in local planning efforts 

regarding development or use of non-Federal lands as an 

information provider to help promote appropriate open 

space, access and recreation opportunities as well as to 

reduce ecological impacts and wildfire risks for 

communities.

MIN G 1 Talus slopes should not be used as a common variety 

mineral materials source where disturbance would 

destabilize the talus slopes and alter any endemic or rare 

species habitat or presence.
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Section Subsection Component No. Plan Component Language

MIN G 2 Mine reclamation should use a geomorphic approach that 

results in landforms similar to adjacent natural terrain and 

hydrologic functions similar to natural systems to 

minimize long-term monitoring and maintenance 

requirements.

MTS G 2 New road construction in meadows and wetlands should be 

avoided where physically or financially feasible. If these 

activities are unavoidable, they should be designed and 

implemented to minimize effects to waterflow, wetland 

recharge, and ecosystem function.

MTS G 3 New road construction in riparian areas should be avoided, 

except to cross the riparian area, unless alternate routes are 

physically or financially infeasible or have greater overall 

resource impacts. If these activities are unavoidable, they 

should be designed and implemented to minimize effects 

to natural waterflow and native vegetation communities.

NWS G 1 Projects in upland habitats adjacent to streams should be 

designed to minimize input of sediment to streams.

NWS G 2 Water quality, quantity, soil function and structure, and 

wildlife habitat (including aquatic species habitat) should 

be protected or enhanced at natural springs and seeps.

NWS G 3 Fuel buildup should be reduced around natural water 

sources to protect them from uncharacteristic fire effects.

NWS G 4 Management activities should not impair soil moisture 

recharge at outflows of natural water sources.

NWS G 8 Projects affecting perennial streams should be designed 

and constructed to allow for natural instream movement of 

aquatic species, except where barriers are necessary to 

preclude the movement of nonnative species.

NWS O 1 Every 10 years, apply for at least 10 instream flow water 

rights on streams for recreation and wildlife purposes, 

prioritizing locations necessary for sustaining native fish 

populations and species of conservation concern.

NWS O 2 Reconstruct at least 3 developed springs every 10 years to 

provide aquatic habitat for the recovery of plant and/or 

animal species.

NWS O 3 Complete three stream restoration and/or development 

projects to benefit aquatic species of conservation concern 

every 10 years.

RAM G 3 Construction or reconstruction of livestock fencing and 

replacement of nonpermeable fencing where wildlife 

movement is restricted should be consistent with the 

appropriate state wildlife agency standards1 for safe 

passage of wildlife and/or species-specific fencing 

guidelines developed at the local or regional level.
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Section Subsection Component No. Plan Component Language

RAM G 4 Grazing management practices should be designed to 

maintain or promote ground cover that will provide for 

infiltration, permeability, soil moisture storage, and soil 

stability appropriate for the ecological zone. Additionally, 

grazing management should retain ground cover sufficient 

for the forage and cover needs of native wildlife species.

RAM G 7 Grazing intensity, frequency, occurrence, and period 

should provide for growth and reproduction of desired 

plant species while maintaining or enhancing habitat for 

wildlife.

RAM S 2 New issuance, renewal, modification, and management of 

grazing permits shall comply with the Coronado National 

Forest’s “Stockpond and Aquatic Habitat Management and 

Maintenance Guidelines for the Chiricahua Leopard Frog.” 

Additionally, for the San Rafael Valley and surrounding 

areas, permits shall comply with the Coronado National 

Forest’s “Stockpond Management and Maintenance Plan 

for the Sonora Tiger Salamander.”

RAM S 3 In areas occupied by lowland leopard frogs, stock ponds 

will be managed according to the general guidance, as 

applicable, of the Coronado National Forest’s Stockpond 

and Aquatic Habitat Management Guidelines for 

Chiricahua Leopard Frog (if lowlands are included in the 

revised guidelines, then this no longer applies).

REC G 6 Rock climbing should be managed to balance demand for 

the activity and the need to protect plants, animals, and 

other natural resources.

RIA G 2 Management activities should only be allowed in riparian 

areas if soil function and structure, hydrologic function and 

riparian plant communities (except noxious and/or invasive 

plants) are kept the same or improved.

RIA G 3 Vegetation treatments should favor the retention of snags, 

large diameter woody debris, and/or growth of large 

riparian trees along stream channels.

VIC G 1 Vegetation treatments in interior chaparral should provide 

for maintaining a sustainable population of paniculate 

agaves.

VMP G 1 Vegetation treatments in Madrean pine-oak woodlands 

should provide for maintaining a sustainable population of 

paniculate agaves.

VWM G 3 Vegetation treatments should be designed to create stand 

conditions that enhance cone production of white fir, 

corkbark fir, Engelmann spruce, and Douglas-fir in order 

to provide a reliable Mount Graham red squirrel food 

source.

WET G 1 Management activities should only be allowed in wetlands, 

including wet meadows, if vegetative communities (except 

noxious and/or invasive plants), soil function and structure, 

and hydrologic function are kept the same or improved.
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Section Subsection Component No. Plan Component Language

WET O 1 Restore native vegetation and natural waterflow patterns 

on at least 10 wetland sites every 10 years.

WET S 1 The total acreage of existing wetlands will not be 

diminished due to management activities.

WIL PSR G 1 Recreation facilities should not be developed in the Pusch 

Peak area.

WIL PSR G 2 Trailhead parking areas should be designed to passively 

limit visitor use at levels that maintain wilderness 

character.

WIL PSR O 1 Annually, treat 200 to 1,000 acres of exotic invasive grass 

populations (primarily buffelgrass and fountain grass) on 

the southwest slopes of the Pusch Ridge Wilderness.

1. For Arizona Game and Fish Department, refer to the most recent wildlife water development standards; for New 

Mexico Game and Fish Department, use available habitat or species-specific guidelines.

Final Programmatic Environmental Impact Statement for 

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Appendix G. Methods of Analysis

This appendix provides details about assumptions and methods used in the effects analyses 

disclosed in this environmental impact statement, supplementing those described for individual 

resources in chapter 3 and/or filed in the administrative record of this National Environmental 

Policy Act review. Certain assumptions common to all resource analyses include the following:

• No direct environmental effects will result from the administrative action of developing or 

revising the land and resource management plan. Proposed actions will not be approved or 

otherwise authorized based on the content of the forest plan; however, they must be 

consistent with plan components, which include desired conditions, objectives, standards, 

guidelines, designation of management areas, suitability determinations, and monitoring 

requirements. 

• Components of the forest plan reflect current Federal, State, and local laws and regulations, 

and USDA and Forest Service policy.

• Future funding for projects governed by the forest plan will be similar to that of the past 5 

years.

• Effects analyses are applicable for the expected life of the forest plan, which is estimated to 

be from 10 to15 years, unless otherwise noted in chapter 3.

• Individual proposed actions are not evaluated in this final environmental impact statement 

nor are they defined by specific location, design, and extent. Rather, the effects described are 

generic and are used to compare the relative effects of alternatives on a forestwide basis. 

• Monitoring during the life of the plan will be used to measure the continued applicability of 

plan components and the need for future amendments.

Resource Assumptions and Methodologies

Resource-specific assumptions and methods used in assessing the relative benefits of and 

challenges presented by direction in a revised forest plans proposed by each alternative are 

described below under separate headings for the five Coronado plan revision need-for-change 

topics. Because this programmatic environmental impact statement does not quantify site-specific 

effects, methods traditionally used in effects analysis, such as air quality or hydrologic modeling, 

are not applicable.

Topic 1: Ecosystem Restoration and Resiliency

Vegetation Communities

Methodology and Analysis Process

Potential natural vegetation types are coarse ecosystem types that share similar geography, 

vegetation, and historical disturbance processes, such as fire and drought. Their common 

characteristics are evident when natural disturbance regimes and biological processes prevail. 

Potential natural vegetation types correlate to the vegetation communities described in the 

“Vegetation Fuels and Fire” section of the final environmental impact statement. In cases where 
Appendix G. Methods of Analysis

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216

certain potential natural vegetation types are not well represented on the Coronado, they are 

combined under a single vegetation community for the purpose of effects analysis. For example, 

the montane meadow and wetland vegetation communities were not discernible from potential 

natural vegetation type mapping; therefore, they are evaluated with the community in which they 

occur, and the 111 acres of piñon-juniper woodlands were combined with the Madrean encinal 

woodlands for ease of analysis.

Reference conditions for forest vegetation, for the most part, are based on conditions that existed 

between the years 1000 to 1880 AD, before major contemporary human factors affected the 

landscape3 (USDA FS 2009b). To assess the sustainability of various vegetation communities, 

current conditions were compared to reference conditions that were identified from a recent 

review of published scientific literature. This range of variation is reflective of natural disturbance 

regimes. 

Sources of information used to describe reference (baseline) conditions of vegetation include the 

“Coronado Ecological Sustainability Report” (USDA FS 2009b) and the “Coronado 

Comprehensive Evaluation Report” (USDA FS 2009c). These are used, in turn, to identify desired 

conditions (USDA FS 2009d) and Coronado forest plan potential plant community descriptions 

(Robinett 2010). Desired conditions were developed to balance ecological, social, and economic 

sustainability. These are included in the revised plan proposed by the action alternatives and are 

the basis of the following analysis.

For many of the vegetation communities, current conditions and desired conditions are 

represented quantitatively as seral stage distributions. Distributions were modified from the 

ecological sustainability report to better represent current conditions and to fit the inputs and 

parameters of the model used to predict future changes. With this approach, comparable data were 

maintained among current, desired, and projected future conditions.

In addition to the vegetation mapping that informed current conditions, a vegetation condition 

class (VCC) analysis was used to quantify the current composition and structure of forest 

vegetation communities in terms of departure from the reference conditions. Vegetation condition 

class is a discrete metric that quantifies the degree to which current vegetation conditions are 

departed from simulated historic vegetation reference conditions. It is calculated using methods 

described in the Interagency Fire Regime Condition Class Guidebook, Version 3.0, 2010, based 

on changes in species composition, structural stage, and canopy cover. LANDFIRE (2012) 

version 1.1.0 (“Refresh 2008”) data were used to conduct this assessment. The LANDFIRE data 

were locally critiqued and updated to reflect recent disturbances, including wildfires through 2011 

as well as data regarding the spatial distribution of invasive buffelgrass and fountain grass. 

Vegetation condition class assesses vegetation departure only and does not include fire frequency 

and severity departure. However, because 90 percent of vegetation communities on the Coronado 

National Forest are fire adapted, and about 80 percent are adapted to frequent fire, there is a 

strong correlation between vegetation departure and the departure of fire frequency and severity. 

Further description of the vegetation condition class analysis is provided in the Analysis of 

 

3 It should be noted that many of the large-scale human disturbances known to impact vegetation and ecological 

processes, such as extensive livestock overgrazing, damming of rivers, canal construction, railroad logging, and fire 

regime alteration, were widespread in the area prior to establishment of the Coronado. The notable exception was 

active fire suppression, which was implemented in the national forests as a standard management practice in the 

early part of the century.
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Vegetation Condition on the Coronado National Forest (Helmbrecht 2013) found in the planning 

record. Three vegetation condition classes describe low departure (VCC 1), moderate departure 

(VCC 2), and high departure (VCC 3; see table 149).

Table 149. Vegetation condition class (VCC) descriptions

Vegetation 

Condition Class

Range of Stratum 

Vegetation Departure Description

VCC 1 ≤ 33% Similar to the reference condition

VCC 2 > 33% to ≤ 66% Moderately departed from the reference condition

VCC 3 > 66% Highly departed from the reference condition

The vegetation communities used in the draft proposed plan and the LANDFIRE biophysical 

setting classifications used in the vegetation condition class assessment are similar in concept—

they both represent the site potential under the historical disturbance regime—but the actual 

classes used by each differ. Although there are spatial discrepancies, to maintain consistency with 

the revised forest plan, the vegetation condition class analysis results are organized by vegetation 

community. The Analysis of Vegetation Condition on the Coronado National Forest (Helmbrecht 

2013) contains further discussion of the analysis and data limitations.

The vegetation condition class analysis was conducted at a scale appropriate to reflect the 

discontinuous “sky island” character of the forest. The departure of specific communities from 

vegetation condition class results were tabulated for each ecosystem management area. For this 

analysis, vegetation condition class departure results are summarized by vegetation community 

(table 150). Percent departure represents the overall stratum departure for the vegetation 

community across the forest. For example, the desert community is 59 percent departed from 

reference conditions across the forest, placing it in VCC 2, or moderate departure. Detailed 

vegetation condition class information by ecosystem management area can be found in appendix 

C of the Analysis of Vegetation Condition on the Coronado National Forest report (Helmbrecht 

2013).

Table 150. Vegetation condition class (VCC) and departure for each vegetation community*

Vegetation Community Departure VCC Description

Desert 59% 2 Moderate departure

Grassland 81% 3 High departure

Interior chaparral 78% 3 High departure

Madrean encinal woodland 35% 2 Low to moderate departure

Madrean pine-oak woodland 50% 2 Moderate departure

Ponderosa pine-evergreen shrub 81% 3 High departure

Dry mixed-conifer 69% 3 Moderate to high departure

Wet mixed-conifer 58% 2 Moderate departure

Spruce-fir 34% 2 Low to moderate departure

Montane meadows, wetlands, and riparian areas 60% 2 Moderate departure

* Vegetation condition class departure was calculated from a weighted average based on each vegetation community 

and the acreage represented on the mountain ranges.
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State and transitions models played a prominent role in the plan revision process in the 

Southwestern Region. The Vegetation Dynamic Development Tool (VDDT) is a state and 

transition model developed by the Southwestern Region and the Coronado National Forest, and 

calibrated by Forest Vegetation Simulator (FVS) outputs. For the plan revision analysis, the 

Vegetation Dynamic Development Tool was used to quantify projected future vegetation 

conditions in forested and woodland communities. This approach allowed for the quantitative 

comparison of the effects of vegetation management under each alternative. Projected changes in 

vegetation from reference conditions appear as “departure” percentages, which are a measure of 

trends toward achieving desired conditions. In some cases, departure is also used to show strength 

of a trend; however, in this analysis, departure percentages often vary little by alternative, and 

trends are difficult to predict. Projected future vegetation conditions in the desert, grassland, and 

interior chaparral communities were estimated using the ecological sustainability report (USDA 

FS 2009b), published literature, and local expertise.

Vegetation conditions on the Coronado National Forest and data (FVS outputs) that informed 

Vegetation Dynamic Development Tool modeling were affected by wildfires that have occurred 

since modeling was completed in 2009. Consequently, assumptions were made as to how fire 

affected current conditions, Vegetation Dynamic Development Tool modeling results, and 

movement of vegetation toward desired conditions. In areas affected by fire, burn severity 

mapping informed predictions of vegetation change. In areas unaffected by fire, it was assumed 

that seral stages remain present in the same proportions; therefore, original Vegetation Dynamic 

Development Tool projections still apply to those areas. The Coronado National Forest updated 

modeling to encompass all alternatives and vegetation communities and the effects of the 2011 

fire season. This updated information improved the vegetation analysis.

Assumptions and Limitations

In the analysis for vegetation, fuels, and fire, the following additional assumptions and limitations 

were made:

• There are minor, acceptable inconsistencies between the number of acres on the forest 

between the Coronado National Forest administrative boundary and the potential natural 

vegetation types GIS data layer. 

• The Interagency Prescribed Fire: Planning and Implementation Procedures Guide continues 

to provide clear direction regarding the use of planned ignitions (USDA and USDOI 2008).

• Acres treated, from both mechanical and fire treatments, are effective and improve (or 

reduce) departure because they alter vegetation composition and structure (e.g., tree density, 

crown base heights, and fuel load and arrangement) and move the vegetation community 

toward reference conditions. 

• A set acreage would be treated (both mechanical and fire) each year and varies by vegetation 

community and alternative. The actual acres treated may fluctuate yearly due to the number, 

timing, and location of wildfire starts; National Environmental Policy Act analysis 

completed; availability of resources; weather conditions; fuel conditions; and smoke 

management and socio-political factors (e.g., burn bans or fire restrictions). Unpredictable 

factors such changes in Federal or regional fire policy may also influence actual acres burned. 

The number of acres treated is dependent on many variables, few of which are within the 

Coronado’s direct control. 
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• Plan objectives are achievable considering budgets, project planning timelines, and external 

factors (e.g., weather conditions and fuel conditions) over the next 10 years.

• Plan objectives are achievable because there are no major changes in policy or other factors 

over the next 10 years.

• Treatment objectives utilizing wildland fire assume a portion of the acres treated will be 

accomplished through unplanned ignitions. Wildland fire utilized to meet forest plan 

objectives burns characteristically in the vegetation community and contributes to the 

movement toward desired conditions.

• These acreage assumptions are based on past and predicted opportunities and consider fuel 

conditions, smoke management factors, and treatment effectiveness.

• Low-severity fires result in less than 25 percent replacement of the dominant overstory 

vegetation when burned, whereas mixed-severity fires result in 25 to 75 percent replacement 

of the dominant overstory vegetation, and stand-replacing fires result in greater than 

75 percent replacement of the dominant overstory vegetation.

• There is no surrogate for the occurrence or application of fire; it is critical to ecological 

restoration.

• The vegetation communities adapted to frequent fire have been without fire for at least 

100 years, therefore, movement toward historic fire return intervals will take time.

• The effect of 2011 fires on current conditions was informed by the distribution of burn 

severities and likely transition between seral states based on state and transition models.

• Reference and desired conditions represent identical conditions, except where wildland-urban 

interface dictates vegetation structure, composition, and fuel loadings that support lowintensity surface fire to reduce the impacts of wildfire on communities. The distribution of 

reference seral stages was not changed to reflect desired conditions; therefore, tables that 

report seral stage distributions, desired conditions, and reference conditions can be used 

interchangeably.

Soils

Assumptions and the approach to comparing the relative effectiveness of plan alternatives are 

reported in the text of the soils discussion in chapter 3. No models are available to predict trends 

and future foreseeable conditions for soil resources, in particular, soil condition, soil productivity, 

or soil organic matter. However, qualitative inferences can be made and estimated which provide 

insight into future soil condition primarily by using knowledge about present disturbances and 

their effect on erosion processes, soil compaction, and nutrient cycling. 

According to Southwestern Region supplement to Forest Service Handbook 2509.18, soil 

condition is a combined function of soil hydrology, soil stability, and nutrient cycling. Current 

Coronado soil condition ratings reported in this environmental impact statement are based on how 

departed soils are from the historic range of natural variability. 

The relative value of plan components among alternatives were described in terms of the 

differences in the number of acres treated to improve soil and vegetation conditions between the 

alternatives, or in the number of acres protected by a wilderness designation.
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Water Resources

Following is a brief description of the methodologies and/or approaches used to evaluate

direction of the alternatives related to watershed condition, water quality, and water yield and 

availability (quantity). Effects on water resources are not site specific because of the 

programmatic nature of this environmental impact statement. Much of the background 

information is excerpted from the Ecological Sustainability Report for the Coronado National 

Forest (Forest Service 2007, from Brown et al. 1974). 

Water Quality

Water quality data reported in this environmental impact statement was obtained from the results 

of analysis reported by Arizona Department of Environmental Quality and the New Mexico 

Environment Department. The “Water Resources” section in chapter 3describes water quality 

standards and use criteria established by both state agencies. No modeling was conducted as part 

of the water quality effects analysis. 

Water Quantity – Surface Water

Information reported in chapter 3 about water yield and availability is excerpted from the 

“Ecological Sustainability Analysis” report cited above. The plan alternatives differ in the number 

of instream flow rights applications that will be monitored and submitted to the Arizona 

Department of Water Resources. Methods will follow Arizona Department of Water Resources 

guidelines. No modeling was conducted as part of the environmental consequences analyses.

Water Quantity – Groundwater

Groundwater use and quality is regulated by the States of Arizona and New Mexico. No modeling 

was conducted for the environmental consequences analyses.

Watersheds

An initial assessment of watershed conditions was made using the national watershed condition 

framework and assessment tool. Watershed condition was determined in accordance with 

direction in Forest Service Manual 2521.1. No modeling was conducted for the environmental 

consequences section.

Air Quality

The air quality analysis in this environmental impact statement reports the relative effects of the 

alternatives qualitatively because of the programmatic nature of the proposed action. 

Management actions in the short term (15 years) are assumed for this analysis. 

At the site-specific or project level, air quality analyses use technical models to estimate the 

incremental concentration of various air pollutants that will be added to ambient concentrations, 

to which national ambient air quality standards apply. Resource analysts must make assumptions 

about these factors. However, at a programmatic, forestwide scale, the uncertainties associated 

with these assumptions are too great to allow for reliable analysis using these tools. Thus, effects 

on air quality reported in this environmental impact statement are qualitative, not quantitative, 

and significance is not based on effects on ambient concentrations of national ambient air quality 

standards.
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Rather than the guidance presented by each of the alternatives, the extent of smoke effects from 

wildfires on the Coronado National Forest will depend on numerous location-specific factors that 

are difficult to predict over the long term. These include but are not limited to, dispersion and 

dilution parameters, live and dead fuel conditions, wind direction and speed, firing techniques, 

timing, and duration of ignition, and various fuel arrangements and loading.

The time of year burns take place is a factor that greatly influences ventilation and would have 

more effect on smoke impacts than number of burn days or acreage burned per day; however, this 

factor is more appropriately evaluated at the project level. While the factors influencing smoke 

production do vary by season, the plan alternatives do not contain direction or restrictions about 

seasonality of burning that would drive difference between the alternatives. Project-level 

decisions about when to burn would vary by the specifics of the site conditions and the desired 

conditions for the project. In addition, climate change may add increased uncertainty when 

predicting the season of implementation.

Uncharacteristic wildfires are those that occur under vegetative and climatic conditions that are 

not typical to the vegetation types’ historic fire regime. In many cases, uncharacteristic wildfires 

occur under hotter, drier conditions with more continuous fuel, and they grow faster and produce 

more smoke than fires that burn under conditions that are closer to the historic range of 

variability. When natural caused wildfires occur under conditions closer to this range, the agency 

may be able to manage them to maintain the historic range of variability and to benefit wildlife, 

soils, watersheds, and other ecological components of the respective ecosystem.

Species Viability

Wildlife, Fish, and Rare Plant Population Viability

Purpose of Analysis 

The 1982 implementing regulations define a viable population as: “one which has the estimated 

numbers and distribution of reproductive individuals to insure its continued existence is well 

distributed in the planning area.” The population viability assessment is the means by which the 

Coronado National Forest ensures that viable populations are maintained as management 

direction within the revised forest plan is implemented, once approved.

General Caveats

No downstream or off-forest species were included. Extirpated species were generally not 

included unless there was reason to believe the species was likely to become reestablished in the 

reasonably foreseeable future or if habitat restoration would set the groundwork for 

recolonization.

Taxonomic and Nomenclatural Standards

U.S. Forest Service Washington Office direction specified the use of the Integrated Taxonomic 

Information System4 as the taxonomic standard for animals. The system is inconsistent in the use 

of common names and does not recommend standard English names. Whenever possible, we 

 

4

The Integrated Taxonomic Information System database is available at http://www.itis.gov.
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used the standard English names recommended by the professional societies that publish peerreviewed lists. In some cases, species not considered valid in the Integrated Taxonomic 

Information System were either deleted from further consideration or their taxonomic equivalents 

were retained, depending on the biological interpretation of the taxonomy. Personal 

communication (December 2010, L. Jones, Coronado National Forest) with Integrated Taxonomic 

Information System personnel revealed that taxonomy and nomenclature of most taxonomic 

groups are not current, so this was considered in our final selection of taxonomies (i.e., scientific 

names).

The Forest Service standard for plants is USDA Plants.5 In cases where information in the Plants 

database was outdated, we used best available science to make taxonomic decisions.

Forest Planning Species

“Forest planning species” is a descriptive term developed by forest planning staff to describe 

species selected for detailed analysis during the population viability assessment process. Species 

not included in this designation, but occurring on the Coronado National Forest, are assumed to 

be viable because their populations and habitats are significantly well distributed such that there 

are no perceived risks to viability.

Based on the Region 3 guidance, the list of forest planning species includes threatened, 

endangered, and candidate species; rare species; U.S. Forest Service Southwestern Region 

sensitive species; and other species of conservation concern. Each of these categories is described 

subsequently in further detail. Numerous species share multiple designations and require that 

conflicting taxonomies and nomenclature be resolved on a case-by-case basis.

Threatened, Endangered, and Candidate Species

Species in this category are federally listed as threatened, endangered, or candidate species under 

the Endangered Species Act of 1973. A list was compiled in August 2010 using the U.S. Fish and 

Wildlife Service Arizona Ecological Services website6 for all counties in the planning area (i.e., 

the Coronado National Forest). Species known, or believed, to occur in the boundaries of the 

Coronado National Forest were retained as forest planning species (although some extirpated or 

potentially occurring species were also retained, as mentioned previously), including those 

occurring in both New Mexico and Arizona portions of the Coronado National Forest.

 

5 USDA Plants is an online database available at http://plants.usda.gov.

6 Lists are available at http://www.fws.gov/southwest/es/arizona/Threatened.htm#CountyList
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Rare Species

Rare species are those ranked within NatureServe7 as G1-G3 (rounded)8 in February 2006, when 

the list was initially compiled. Species believed to occur on the Coronado National Forest were 

retained as forest planning species. Species that had questionable taxonomy and nomenclature 

(“Q”, according to NatureServe) were generally not retained (although not without exception; 

NatureServe is not the standard for taxonomy or nomenclature so deletions were made on a caseby-case basis).

Sensitive Species

All species on the most recent (October 2007) Forest Service Southwestern Region (Region 3) 

sensitive species list were retained as forest planning species, if they occur within the boundaries 

of the Coronado. Infraspecific designations of taxa on the sensitive species list were often not 

recognized by the Integrated Taxonomic Information System, USDA Plants, or NatureServe, so 

most of these taxa were considered at the species level.

Other Species of Conservation Concern

Species not fitting into one of the above categories were added to the list when concerns about 

their populations warranted additional consideration. Not all are considered rare, but all are of 

conservation concern. For example, white-tailed deer is a commonly hunted species that is of 

conservation concern because habitat quality is deteriorating. Another example is the monarch 

butterfly, a species that is still common and widespread (e.g., G5 in NatureServe), but populations 

and habitats are declining. State game and fish departments of Arizona and New Mexico helped 

compile this portion of the forest planning species list. Commonly hunted and fished animals 

were often included in this list, as were species of greatest conservation need (a designation of 

species of conservation concern for each State).

Information Collection and Best Available Science

Prior to assessing the viability of populations of forest planning species, information on the 

natural history of each species was compiled. Because of the sheer number of species (about 

1,500 initially considered), budget constraints required that information collection contributing to 

the best available science be efficient but not exhaustive. The following sections describe the 

types of information collected in physical and electronic media.

Hard Copy References

The first approach to finding natural history information was seeking readily available reference 

books. For example, Hoffmeister’s “Mammals of Arizona” (1986) and Kearny and Peebles’ 

“Arizona Flora” (1960) were the primary depositories of knowledge at the time they were 

published and contributed a wealth of information on taxonomic classification, historical 

population trends, and expected range. When reference books were not sufficient, other literature 

was used, including Arizona Game and Fish Department’s plant and animal abstracts. These 

 

7 NatureServe is an online, status-ranking resource available at http://www.natureserve.org/explorer/index.htm

8 NatureServe Global (G) Conservation Status Ranks consider each species’ status rangewide (ranges extend beyond 

forest boundaries in almost all cases) and are described as follows: G1=Critically Imperiled; G2=Imperiled; 

G3=Vulnerable; G4=Apparently Secure; and G5=Secure (definitions of G-ranks and more information available at 

http://www.natureserve.org/explorer/ranking.htm)
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unpublished reports9 are extremely valuable synopses of known information up to the time they 

were produced; thorough abstracts sometimes included all the information needed for an 

assessment. Further literature searches were completed by species at the University of Arizona, 

primarily using two indices: BIOSIS Biological Abstracts and Zoological Record.10 Resources 

listed in these indices were obtained through the University of Arizona, the U.S. Forest Service 

Rocky Mountain Research Station, or other publication outlets. Additional reputable resources 

were used whenever available; these included agency technical reports, professional anecdotes, 

personal communications, and unpublished data.

Online References

When the process of gathering natural history information began in 2005, online resources were 

limited and the most useful resources included sites such as NatureServe and BISON-M.11 By 

2010, the pool of readily available useful information had greatly increased. For species requiring 

updated information, the Google and Google Scholar search engines typically provided useful 

information on the first three pages of returns; these included online databases, scientific and 

academic research (including several theses and dissertations), and professional publications, 

among others. Additionally, when the Forest Service incorporated DigiTop,12 many new and 

previously unavailable references became accessible. New or recently updated websites, such as 

those following, provided supplemental natural history information when publications or other 

references were insufficient:

• Madrean Archipelago Biological Assessment (http://www.madrean.org/maba/symbflora)

• Southwest Environmental Information Network (or SEINet) for distribution maps and 

locality information (http://swbiodiversity.org/seinet/index.php)

• Butterflies and Moths of North America (http://www.butterfliesandmoths.org)

• Butterflies and Moths (http://www.butterflies-moths.com/index.html)

• eFloras (http://www.efloras.org/index.aspx): the online version of Flora of North America 

(http://www.fna.org) 

• Consortium of North American Lichen Herbaria (http://symbiota.org/nalichens)

• New Mexico Rare Plants (http://nmrareplants.unm.edu)

Documenting Information Resources

References were noted in a single column of the population viability spreadsheet (as described 

below). NatureServe natural history information was printed out and retained for most species, as 

were the Arizona Game and Fish Department’s plant and animal abstracts; electronic copies of 

the versions used during the assessment were also stored in Adobe’s portable document format 

 

9 Although portions of many of the abstracts are available online (at www.azgfd.gov/w_c/edits/species_concern.shtml), 

these references are discussed in the “Hard Copy” section because expanded versions containing locality information 

are maintained in hard copy format at the supervisor’s office.

10 Both databases are Thomson Scientific products of Thompson Reuters (more information at 

www.thompsonreuters.com).

11 Biologic Information System Of New Mexico (BISON-M) contains species accounts for vertebrates and 

invertebrates in New Mexico and Arizona; it is available at www.bison-m.org.

12 DigiTop is USDA’s Digital Desktop Library, a service available to employees of certain USDA agencies at 

http://digitop.nal.usda.gov
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(PDF). Online publications were sometimes printed but always retained as PDFs. Book covers 

and relevant book pages were scanned and retained as PDFs as well. Some references are only 

available for viewing in the University of Arizona library, and so these were not reproduced. 

Information acquired from online databases was almost always saved in PDF format. All 

electronic copies are filed on a Forest Service server and are included within the official project 

record. URLs are not always permanent, so they were generally not recorded, except as a 

reference by name or in this document.

Population Viability Assessment Process

Complementary goals of the assessment were to create a repository of information on potentially 

at-risk species across the Coronado; to identify management risks of those species, as well as the 

extrinsic factors that forest managers cannot control; to determine whether management direction 

within the revised forest plan is sufficient to mitigate management risks to species; and to inform 

the development of additional plan direction that would ensure viable populations of all forest 

planning species13 across the Coronado National Forest. The population viability spreadsheet14 is 

the means by which Coronado National Forest biologists streamlined the process to accomplish 

these goals.

Population Viability Spreadsheet

The population viability spreadsheet is the backbone of the viability assessment: it includes all 

species that were carried into analysis (i.e., forest planning species). Earlier iterations of working 

drafts are electronically archived, and contain many more species as filtering occurred over time. 

Each workbook of the spreadsheet corresponds to a taxonomic group (e.g., mollusks, mammals, 

birds, etc.) or contains metadata (e.g., codes or references). For taxonomic-group workbooks, 

each row represents a species and each column contains recorded information needed to complete 

the assessment. Columns are either stand-alone or grouped within a broader heading that 

correspond to the role needed for analysis. They are arranged left-to-right, correspondingly 

described15 top-to-bottom, as follows:

Background Information

• Scientific name

• Common [or standard English] name

• Status

• Occurrence

• G-Rank [NatureServe, 2006 or updated]

• Range and distribution [narrative, globally to locally]

• Physical habitat [narrative]

• Biotic Habitat [narrative]

 

13 Note that any species that occurs on the forest but is not considered a “forest planning species” is assumed to be 

viable because their populations and habitats are significantly well distributed such that there are no perceived risks 

to viability.

14 The spreadsheet is a Microsoft Excel file retained within the official project record.

15 Further descriptions of each column heading can be found within the metadata segment of the population viability 

spreadsheet.
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• Associated species [narrative]

• Population information [narrative]

• Notes [general, narrative]

• References [resources cited]

Evaluation Criteria

• Cells [physical and biotic habitat components]

• Ecosystem management area(s) of species’ occurrence]

• Threats and risks [narrative]

• Suitable habitat [yes or no] 

• Habitat trend [qualitative]

• Population trend [qualitative]

Coarse Filter

• Plan content (forestwide) [locator for applicable plan content]

• Risks mitigated [yes or no]

• Notes [narrative, on mitigation of risk or population viability concerns at coarse-filter level]

Fine Filter

• Plan content (specific) [locator for applicable plan components]

• Risks mitigated [yes or no]

Extrinsic Factors

• Beyond Forest Service control [yes or no]

• Notes [on role of extrinsic factors for population viability and risk mitigation concerns]

Assessment within the Spreadsheet

Because most of the pertinent information is within the columns of the spreadsheet, it serves as a 

stand-alone document allowing Coronado biologists to assess population viability for each 

species, although always in combination with professional judgment. The process of making an 

assessment basically begins on the left side of the spreadsheet and proceeds to the right, with each 

set of columns informing the next. The following discussion summarizes the information used in 

making an assessment.

Background Information

This furthest left section of the spreadsheet helped paint a picture of the overall natural history of 

the species. There is information on distribution, from the global scale to local scale; habitat use; 

references; and so on. It does not include extraneous information not usually needed for an 

assessment, such as a species description. The narratives in the “Background Information” 

columns were used to populate fields in the “Evaluation Criteria” section. Background 

information was often referred to iteratively during the assessment process.
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Evaluation Criteria

This section is nonnarrative (except for “Threats and Risks”), containing concise biological 

interpretation of the information presented in the “Background Information” section. Evaluation 

criteria were used in conjunction with revised forest plan direction to determine whether risks to 

population viability have been sufficiently mitigated.

• Threats and Risks. These were summarized from references only; the biologists did not 

populate this field with their own interpretations or conjecture. However, many references did 

not specify potential threats. In most of these cases it was possible to build plan components 

that would contribute to a species’ viability without knowing specific threats. For example, if 

the precise locality is known for a rare plant, then logic dictates the site should be considered 

for mitigation during large, ground-disturbing activities. Additionally, planning biologists 

extrapolated likely threats by considering the natural history features of a plant or animal. For 

example, a rare wetland-associated species would almost certainly be threatened by draining 

wetland habitat.

• Cells. A coding system was developed to assign physical and biotic attributes of habitat to 

each species, based on information contained in background information. (The coding system 

began as cell designations at junctures in a matrix – hence the name “Cells” – but were later 

simplified and listed in the Metadata workbook of the spreadsheet.) Codes A through H refer 

to biophysical attributes (e.g., riparian, lotic, cave, terrestrial) used by the species, while 

codes 1 through 9 refer to vegetation communities (e.g., desert communities, Madrean 

encinal woodland) where the species occur(s); these classifications were derived from The 

Nature Conservancy’s potential natural vegetation types.16 In some instances, a species may 

not actually “use” the vegetation community per se, but the classification places parameters 

on the range of elevation where management activities are likely to occur. For example, an 

aquatic insect may be affected by runoff from vegetation treatments upslope; therefore, those 

upslope vegetation communities would be included in this column.

• Ecosystem Management Areas. Codes corresponding to each of the Coronado National 

Forest’s ecosystem management areas are listed in this column to designate which mountain 

range(s) the species occurs in, or is likely to occur in. Most ecosystem management areas are 

made up of a single mountain range, although some are actually contiguous clusters of 

smaller mountain ranges, isolated from one another by desert and grassland valleys. 

Generally species that are endemic or limited to one or two ecosystem management areas are 

considered more likely to be at risk from extinction or extirpation (either of which would 

result in a failure to maintain well-distributed, viable populations) than those that are more 

widely distributed.

• Suitable Habitat. If a specific habitat type can be associated with a given species, and that 

habitat type is present on the Coronado National Forest, this column is noted affirmatively. 

Nearly every species retained in the most current version of the spreadsheet is designated as 

such, except in rare circumstances; earlier versions included more species for which habitat 

was not available, but these were filtered out over time because species for which no habitat 

occurs are not likely to be present on the Coronado and, therefore, do not require a viability 

assessment. The cases in which this column reflects unknown or no suitable habitat are when 

habitat association is uncertain, when species occurrence on the Coronado National Forest is 

 

16 The Nature Conservancy assessments of potential natural vegetation types are filed in the administrative record. 
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likely but undocumented; and where habitat previously existed on the Coronado and is likely 

to be restored through management actions or natural recovery.

• Habitat Trend. The condition of each species’ habitat was based on historical, current, and 

projected future condition of vegetation communities, as well as site-specific considerations, 

such as recent fire activity or invasive species encroachments. Trends were based on 

reference condition, given the assumption that management would continue as described in 

the 1986 forest plan. A “-” suggested a downward trend in habitat quality, quantity, 

distribution, or some combination of those things. A “+” suggested a stable or upward trend 

in habitat quality, quantity, distribution, or some combination of those things. Determining 

habitat trend was not always straightforward; however, there were at least two scales to 

consider and more than one vegetation type is typically used by each species. Trends in 

vegetation and habitat quality at the forestwide scale differ among vegetation types and 

between historical and projected conditions. A species might occupy vegetation communities 

that are both downward and upward trending at the different timescales. At the ecosystem 

management area or more local level, trends were also evaluated using a detailed map of fire 

regime condition class, which displays the degree of departure of fire regime and vegetation 

community characteristics from reference condition. Other sources of information were also 

used to determine habitat trend, such as the presence of invasive species and land use 

patterns. Thus, each habitat trend determination was distilled from multiple data sources on a 

case-by-case basis. Rarely, a “U” (indicating “unknown”) was entered into the column for a 

particular species where there were large gaps in knowledge.

• Population Trend. The trend in distribution and abundance of a species was recorded using 

“-” (indicating a declining trend), “+” (indicating a stable or increasing trend), “0” (indicating 

unknown or unlikely species presence on the Coronado), and “U” (indicating an unknown 

population trend). Information in this column was based purely on literature sources that 

specifically addressed population trend, lending to frequent determinations of unknown. 

These were difficult to interpret, but didn’t always imply elevated risk to a species, since 

endemism and natural rarity are not uncommon in this ecological region.

Coarse-Filter/Fine-Filter

Species viability was assessed using the coarse-filter/fine-filter approach.17 At the coarse-filter 

level, broad management practices that focus on minimizing departure of current condition from 

reference condition at the ecosystem and forestwide scales are sufficient to minimize risks to 

viable populations of most species. In order to assess this, a primary tool in assessing whether 

forestwide plan components will be sufficient to ensure population viability is the vegetation 

condition class. The vegetation condition class indicates vegetation condition departure from 

reference conditions and was incorporated in this portion of the assessment. A more thorough 

discussion of habitat communities, departure from reference condition, and the expected effects 

of the no-action alternative and the proposed action on departure levels may be found in the 

“Species Diversity” section of this document.

With respect to the revised forest plan, components that address whole vegetation communities 

and forestwide program administration (such as range, animals and rare plants, or recreation) are 

considered under the coarse filter. The kinds of species that might “fall through the coarse filter” 

are those whose risks to viability are not addressed sufficiently by forestwide management 

 

17 This approach was standardized by Region 3 for all national forests in the plan revision process. 
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practices; in these cases, vegetation structure and composition departure from reference 

conditions cannot be addressed for these species, or the protections provided by coarse-filter plan 

components are inadequate to ensure the viability of the species. These situations tend to arise for 

species that are local endemics; species whose habitat is not well distributed; species whose 

habitat is well distributed but not occupied; species whose habitat is in poor ecological condition; 

or species that require fine-scale habitat components.

At the fine-filter level, additional conservation approaches are necessary to mitigate risks to 

population viability. Typically, these are in the form of ecosystem management area-specific plan 

components, or plan components that address particular natural history traits or specific risk 

factors.

In some cases, the risks to species viability cannot be mitigated with either coarse-filter or finefilter management approaches because the limiting factors are beyond Forest Service control. 

These are known as extrinsic factors. Examples include a changing climate, long-term drought, 

disease, and invasive species. Often, while managers cannot entirely eliminate extrinsic factors, 

they may be able to minimize their effects on species, either through mitigation (e.g., exclosures 

to protect against exotic species) or active management (e.g., targeting an area for ecosystem 

restoration to benefit a particular species or species group); both approaches are incorporated to 

some degree in plan components of the revised forest plan.

The coarse-filter/fine-filter approach is documented on the right side of the population viability 

spreadsheet, with a section for each scale. These columns are the culmination of the viability 

assessment, offering a determination of population viability for each forest planning species 

based on revised plan direction. Because the columns serve virtually the same purpose in both the 

fine- and coarse-filter sections and are given similar headers, they are described in summary 

below.

• Plan Content (Forestwide or Specific). Plan content is the text portion of a forest plan that 

includes plan components and other plan content.18 Plan components consist of desired 

conditions (or goals), objectives, guidelines, standards, suitability, special areas, and 

monitoring; other plan content includes general descriptions, management approaches, 

background information, and all appendices.19 Codes were developed to describe both plan 

components and other plan content for each section of the revised forest plan;

20 the codes that 

are relevant to each species or the risks facing each species are listed in the plan content 

column(s) of the population viability spreadsheet, with either forestwide (i.e., coarse-filter) 

direction, and/or ecosystem management area- or species-specific (i.e., fine-filter) direction. 

Conceptually, conservation approaches at the coarse- and fine-filter levels would provide

sufficient protections for each species to be given a viable determination. While other plan 

content cannot be used to assess population viability (because any guidance or aspirations 

contained therein are nonbinding), codes describing other plan content were included in these 

columns to paint a complete picture of management intention with respect to each species.

 

18 Once approved, plan components are plan decisions; substantive plan decisions can only be modified with a plan 

amendment, while non-substantive decisions and other plan content can be modified through an administrative 

correction.

19 For an explanation of these categories of content, see chapter 1 of the revised plan.

20 Codes are described in a worksheet of the population viability spreadsheet titled PlanComponentCodes.
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• Risks Mitigated (both Coarse- and Fine-filter). These columns are the evaluation criteria 

and plan components used to ascertain whether risk factors have been sufficiently mitigated 

to achieve population viability for each species. Provisions of the 1982 Rule require that the 

forest “maintain viable populations of all existing native and desirable nonnative species well 

distributed across the planning area [Coronado National Forest].” In other words, for every 

population occurring on the Coronado: (1) the species is secure and well distributed in the 

planning area; (2) plan components have mitigated direct risks to the species; and/or (3) plan 

components provide guidance to restore ecosystem resiliency where the species occurs. In 

theory, the Coronado must meet these conditions for all species known to be present; 

however, in cases where insufficient natural history information is known to design 

meaningful plan components, or for species with threats that are largely beyond the control of 

the forest, conservation measures contained within the plan are presumed to meet these 

conditions. Consequently, determinations in the “Risks Mitigated” columns are noted as such: 

“Y”, if at least one of the three above conditions is met; “N”, if none of the above conditions 

were met; or “P”, if restoration and mitigation plan components are presumably beneficial to 

the species. For “Y” and “P” determinations, the forest has met requirements to maintain 

viable populations as described by provisions of the 1982 Rule. Any “N” determinations led 

to development of ecosystem management area- or species-specific conservation measures at 

the fine-filter scale.

• Notes. Under the coarse-filter section, justification or additional information pertaining to the 

risks mitigated determinations are contained within the “Notes” column. For example, if a 

species is given a determination that seems contrary to the progression of information in the 

spreadsheet, there should be an explanation. Also, any intuitive information on threats or 

mitigations would be incorporated here.

• Extrinsic Factors includes two columns (“Beyond FS Control” and “Justification”) to 

document whether there are factors beyond Forest Service control that limit the forest’s 

ability to provide for viable populations, including a short justification.

FEIS Alternatives

The population viability assessment was composed for the revised forest plan, but not completed 

to the same extent for the no action or subsequent alternatives. However, the no-action alternative

is very different from the revised forest plan and alternative 1, and those two alternatives are 

different in one important feature (14 parcels of additional areas managed for wilderness values in 

alternative 1), but otherwise plan components and other plan content are largely the same, except 

with regards to the areas managed for wilderness characteristics. Alternative 2 differs from the 

revised forest plan in areas managed for wilderness characteristic and motorized recreation, but 

most components were the same as the other action alternatives. Separate population viability 

assessments were not completed for each alternative. Rather, the biology specialist report and 

final environmental impact statement compared alternatives for forest planning species as a 

whole, as well as for functional groups of species, such as cave-dwellers, rock-dwellers, aquatic 

species, sensitive species, threatened and endangered species, and management indicator species. 

Findings

In summary, a total of 437 species were assessed for potential population viability concerns. The 

population viability spreadsheet lists references from which these summaries were derived. 

Species population viability findings are discussed in the “Regionally Sensitive Species and Other 
Appendix G. Methods of Analysis

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Forest Planning Species – Environmental Consequences” section of the final environmental 

impact statement. 

Topic 2: Visitor Experiences

Recreation

The recreation opportunity spectrum provides a framework that allows administrators to manage 

and users to enjoy a variety of recreation environments. The recreation opportunity spectrum is 

not a land classification system; it is a management objective, a way of describing and providing 

a variety of recreation opportunities (USDA FS 1982). The recreation opportunity spectrum 

provides a framework for stratifying and defining classes of outdoor recreation environments, 

activities, and experience opportunities. The settings, activities, and opportunities for obtaining 

experiences have been arranged along a spectrum divided into seven classes. The names of the 

classes are descriptive to provide utility in land management planning and other applications. 

Each class is defined in terms of its combination of activity, setting, and experience opportunities 

(USDA FS 1990). Opportunities for experience along the spectrum represent a range from a very 

high probability of solitude, self-reliance, challenge, and risk (i.e., primitive) to a very social 

experience where self-reliance, challenge, and risk are relatively unimportant (i.e., rural or urban) 

(USDA FS 1990). 

The basic assumption underlying the recreation opportunity spectrum is that quality in outdoor 

recreation is best assured through provision of a diverse set of opportunities. Providing a wide 

range of settings varying in level of development, access, and other factors insures the broadest 

segment of public will find quality recreational experiences, both now and in the future. Although 

the notion of quality is relative—a value judgment—the concept of quality can be stated for 

management decision purposes in this way: quality depends on what experiences the individual is 

looking for, how much of it is realized, and the degree of satisfaction (USDA FS 1990). A 

recreation opportunity setting is defined as the combination of physical, biological, social, and 

managerial conditions that give value to a place. Thus, an opportunity includes qualities provided 

by nature (vegetation, landscape, topography, scenery), qualities associated with recreational uses 

(levels and types of use), and conditions provided by management (developments, roads, 

regulations). By combining variations of these qualities and conditions, management can provide 

a variety of opportunities for recreationists (USDA FS 1990).

Recreation opportunity spectrum mapping for the Coronado was completed in the early 1980s 

and used in the 1986 forest plan. Since that time, there have been changes to the Coronado 

National Forest boundary (such as the addition of Catalina State Park and improved ALP GIS 

land management boundaries), forest plan amendments that altered recreation opportunity 

spectrum settings (including the Smithsonian Base Camp and Mount Graham International 

Observatory), and improved road system and recreation site mapping (GPS and GIS). All of these 

affect recreation opportunity spectrum maps. The Coronado is currently remapping the recreation 

opportunity spectrum using new data and information, and the new maps will be complete before 

forest plan revision is complete. Because roads affect recreation opportunity spectrum settings, 

the maps will likely need to be updated once travel management is complete. The general settings 

across the forest will remain largely the same, but acres of each setting (as shown in the 

environmental impact statement) will change.
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The national visitor use monitoring project is a nationwide survey conducted on every national 

forest every 5 years. The surveys are in-person exit interviews and are administered at sites 

selected from a stratified random sample based on level of use (high, medium, and low) and type 

of site (day use, overnight, general forest, and wilderness). The sample is used to estimate forestlevel visitation data based on a model that is designed based on nationwide trends and 

assumptions. This ensures all national forest visitor estimates are comparable. The corresponding 

limitation is that it cannot be generalized below the forestwide level without supplemental 

collections. The reliability of the data also is dependent upon the consistent classification of sites 

and survey design as well as the assumption that the on-the-ground conditions are not very 

unusual. For example, a year with no snow and lengthy forestwide fire closures would yield very 

low results because of an abnormal amount of canceled survey days and reduced winter 

recreation. This report uses data from the 2007 survey because the more recent 2012 survey data 

were not available. Visitation in this survey is measured in site visits, which are “the entry of one 

person onto a national forest site or area to participate in recreation activities for an unspecified 

period of time” and national forest visits, which can be composed of multiple site visits. National 

visitor use monitoring does not identify the type of recreation preferred by visitors or track how 

visitors whose desired activities is not offered are displaced. It only captures the activities of the 

person surveyed during the particular national forest visit being counted (USDA FS 2012).

In the analysis for this resource, the following additional assumptions were made:

• Recreation demand is generated by population changes and economic conditions more 

strongly than by plan direction. 

• The budget for constructing and maintaining developed recreation facilities will be flat to 

decreasing in the future except in areas that have been converted to fee sites or concessionaire 

contracts.

Road system changes are analyzed in the “Motorized Transportation” section of the 

environmental impact statement.

Scenery

In 1986, when the Coronado National Forest Land and Resource Management Plan was adopted, 

scenic resources had been inventoried and analyzed using the Visual Management System as 

outlined in Forest Service Handbook 462 (USDA 1974). This system, which was released in 

1974, established standards of measurement (i.e., visual quality objectives) for assessing 

proposed and existing impact to scenic quality. 

In 1995, after 20 years of experience with the Visual Management System and after additional 

research in the public and private sectors, the Forest Service revised the system and replaced it 

with the Scenery Management System. This revised system is described in Agricultural 

Handbook 701, Landscape Aesthetics: A Handbook for Scenery Management (USDA 1995). The 

scenery management system was used in combination with the visual management system in this 

analysis because the Scenery Management System will not fully replace the Visual Management 

System on the Coronado National Forest until the revised forest plan is adopted. 

Although both systems manage scenic resources, there are differences between them. Most 

concepts are the same in both systems, but often terminology has changed. Both systems establish 

objectives (visual quality objectives or scenic integrity objectives) to measure the degree of 
Appendix G. Methods of Analysis

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alteration or deviation permissible in a landscape. The definitions for these objectives are similar, 

but application is slightly different. 

The Visual Management System measures alterations in terms of the degree of acceptable 

alteration of the characteristic landscape where any human alterations or changes in the landscape 

would be considered negative. The Visual Management System Handbook also establishes 

durations of impact for visual quality objectives: retention should be accomplished during project 

operation or immediately after project completion; partial retention should be accomplished as 

soon after project completion as possible or at a minimum within the first year; modification 

should be accomplished in the first year; and maximum modification within 5 years (USDA 

1974). 

The Scenery Management System measures deviations from the existing landscape character, and 

ecosystems provide the environmental context. With ecosystems providing the context, no 

specific duration of scenic impacts are assigned to a scenic integrity objective, but rather the 

focus is on movement toward the desired landscape character (USDA 1995). It should be noted 

that although specific timeframes are not assigned in the Scenery Management System 

Handbook, duration of impacts are always considered in site-specific project planning and 

analysis with the direct intent to provide high quality scenery and achieve the highest scenic 

integrity possible (USDA 1995). The Scenery Management System also recognizes positive 

cultural landscapes or cultural scenic attributes where some human alterations have become 

accepted over time to become expected images or valued features in the landscape contributing to 

high-quality scenery. 

The Scenery Management System, as outlined in Agricultural Handbook 701, is today’s best 

science to achieve high-quality scenery as an outcome of national forest ecosystem management 

practices. System inventories were completed for the Coronado as part of the forest plan revision 

process. 

The very high, high, and moderate scenic integrity objectives result in a relatively naturalappearing landscape. It is important for national forests to manage scenery at this level. “Research 

has shown that high-quality scenery, especially that related to natural-appearing forests, enhances 

people’s lives and benefits society” (USDA 1995). It should also be noted that, according to 

Floyd Newby’s findings, “people expect to see natural or natural-appearing scenery,” (USDA 

1995). Furthermore, “research shows that there is a high degree of public agreement regarding 

scenic preferences. This research indicates that people value most highly the more visually 

attractive and natural-appearing landscapes” (USDA 1995).

Gobster (1994) summarizes preferred scenic settings as having four common attributes: large 

trees; smooth, herbaceous ground cover; an open mid-story canopy with high visual penetration; 

and vistas with distant views and high topographic relief. Visual access, or how far one can see 

into a forest, is also a preferred scenic setting (Ryan 2005). In the long term, when these scenic 

preferences are part of the desired landscape character, scenic resources will have higher scenic 

quality if visual access is achieved or enhanced.

The 1992 visual quality objectives GIS corporate data layer was reviewed as part of this analysis. 

The data layer did not always have a direct correlation to Scenery Management System 

inventories due to differences in handbook direction and how the inventories were completed. 
Appendix G. Methods of Analysis

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Methodologies used for scenery management mapping on the Coronado National Forest can be 

found in the Coronado National Forest Scenery Management System Implementation Guide

(USDA FS 2013a).

In the analysis for this resource, the following additional assumptions have been made:

• The principles of scenery management and environmental design will be applied in projectlevel planning in all National Forest System activities.

• Scenery management techniques and principles will be used to mitigate any future sitespecific land altering activity or introduced elements on the land, to achieve and maintain 

desired scenic integrity objectives and landscape character goals.

• Scenery management accomplishments and success of mitigation measures in meeting scenic 

integrity objectives will be measured. Monitoring will be conducted to determine how 

projects and programs are affecting scenery. 

• Changes in scenery and changes in public expectations related to landscape aesthetics and 

scenery will be monitored and documented (Forest Service Manual 2382 – Scenery 

Management). Changes in public expectations related to landscape aesthetics and scenery 

would most likely be monitored at a regional or national level but may also be assessed 

during scoping for site-specific projects and review of current research when completing 

scenery analyses for site-specific projects.

Scenery inventory GIS data layers will be reviewed during future project-level analysis and 

updated as ground truthing occurs to keep the data layers accurate and relevant.

Designated Areas and Other Special Places

Wilderness 

Methods to evaluate potential wilderness areas for future recommendation are in the Coronado 

National Forest Potential Wilderness Area Evaluation Report and the Potential Wilderness Area 

Need Evaluation, which are filed in the administrative record of this National Environmental 

Policy Act review.

Wild and Scenic Rivers

The evaluation process that identified Coronado streams and segments eligible for future listing 

as wild and scenic rivers is described in the Coronado National Forest Eligibility Analysis for 

Wild and Scenic Rivers, which is filed in the administrative record of this National 

Environmental Policy Act review.

Research Natural Areas

Records describing how and when already designated forest research natural areas were 

established and the evaluation process used to recommended new research natural areas are filed 

in the administrative record of this National Environmental Policy Act review. 

Zoological and Botanical Areas

The analysis focuses on both designated and proposed zoological-botanical areas on the 

Coronado. These areas are described using information from available literature and from field 
Appendix G. Methods of Analysis

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235

visits conducted since the 1986 forest plan became effective. The scientific and research interest 

and significance is described within this information. Management concerns were also identified. 

The alternatives are compared based on how they would protect and preserve the ecological 

features and conserve the scientific values of these areas. This was a qualitative analysis. 

Since the forest plan provides a programmatic framework that guides site-specific actions but 

does not authorize, fund, or carry out any project activity, there are implications or longer term 

environmental consequences of managing the Coronado National Forest under this programmatic 

framework. Thus, the focus of this environmental analysis is on the consequences of the 

alternatives on the desired conditions for the zoological and botanical area resources.

Motorized Transportation

Information related to the forest road system was obtained from the INFRA database of National 

Forest System roads and the Coronado GIS database. The INFRA database stores many types of 

tabular data. GIS and INFRA are linked to ensure consistency of both and are updated continually 

to reflect actual conditions in the field. GIS layers delineating new proposed wilderness areas, 

special interest management areas, and wildlife habitat management areas were used. The road 

mileage by operational maintenance level was obtained from INFRA.

Topics 3, 4 and 5: Access; Open Space; 

and Collaboration, Communities, and Partnerships

Discussion about how these topics were evaluated is in the respective sections for these topics in 

chapter 3. Additional details about methods and approaches are provided below.

Forest Products

The alternatives were compared on the basis of how they would provide forest product resources 

to the public. This was a qualitative analysis. Related methodologies are discussed in this 

appendix and in the text of the environmental impact statement under the headings for vegetation, 

fuels and fire, communities, and tribal relations.

Heritage Resources and Tribal Relations

Information from the Coronado database, heritage program files, State historic preservation 

offices, and museums in Arizona and New Mexico was collected and reviewed. These included, 

but were not limited to, an inventory of known sites, archaeological site densities, and cultural 

sensitivity of different parts of the Coronado. This information was used to describe current 

conditions and potential effects on heritage resources.

In order to evaluate the archaeological sensitivity of different parts of the Coronado National 

Forest, environmental variables such as geological substrate, slope, aspect, existing vegetation, 

historical vegetation, moisture, and soil type, were considered. These variables are important 

when considering the relationships between the environment and prehistoric land use patterns.

Areas of traditional cultural importance to modern Southwestern Indian tribes were factored into 

the determination of overall sensitivity of heritage resources. The degree to which the site 
Appendix G. Methods of Analysis

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sensitivity was upgraded for cultural sensitivity is based upon the relative traditional importance 

of an area, as understood by the Coronado National Forest heritage resources staff from various 

outreach interactions with 12 tribes with ties to southeastern Arizona.

In the analysis of plan direction of each alternative on heritage resources, additional assumptions 

included (1) analysis and impacts to cultural resources from site-specific actions will be 

addressed at the time site-specific decisions are made; and (2) populations in Arizona will 

continue to increase, putting further demands on Coronado National Forest resources that may be 

incompatible with cultural uses and historic preservation.

Lands and Special Uses

Data and information related to the use of forest lands for permitted special uses were obtained 

from the Forest Service special uses database, the Coronado National Forest GIS database, 

special use program records and permit files, and Federal, State and local databases. The special 

uses database provided the legal coordinates of various special use areas to determine the 

compatibility of current use with recommended new wilderness and other special areas.

The special uses database provided the type, number, and status of special use authorizations on 

the forest. Some use codes were combined into the general categories listed in Forest Service 

Handbook 27091.11, Chapter 50 – Terms and Conditions Use Chart. Current special use 

authorizations were tallied for applications approved, pending signature, and to be issued 

contemporaneously with preparation for of this environmental impact statement. Inaccuracies in 

the database tally include accounting for permits that have expired but remain reported as issued 

and may not be reissued or closed, and expired permits for which uses are ongoing but are 

currently not authorized or counted. Short-term permits are not separated from long-term permits 

in the total authorizations. 

Various acreages and miles of specific features and were obtained from the Coronado GIS 

database. Reviews of private property in relation to proposed wilderness and other special areas 

used information and data from the counties in which the districts are located and Coronado GIS 

land ownership files. Suitability of lands on the Coronado for various special uses was 

determined primarily on the basis of revised forest plan direction for specific management areas 

and staff on-the-ground experience with administration of special uses over a period of 40 years. 

Each special use was also evaluated relative to the needs of the public user and resource 

conditions in each management area.

The columns in table 151 show the suitability of specific management areas for select special use 

categories. Energy corridors are linear strips of land identified for the present or future location of 

a utility right-of-way (e.g., above- or below-ground electric transmission line, gas pipeline). Other 

energy developments include the infrastructure associated with the provision or transport of 

energy (e.g., dam, biomass power generation, wind turbines, solar panels). Communication sites 

acceptable on National Forest System lands used are identified in appendix C of the revised forest 

plan. Motorized outfitter and guide uses are conducted by various types of vehicles and include 

hunting, fishing, and “ecotours” for wildlife viewing. Military training includes tracking classes, 

frequency testing, unmanned aerial vehicle use and testing, and downed pilot search and rescue. 

Treasure trove is the exploration for buried treasure. Department of Homeland Security, Customs, 

and Border Protection uses include foot, equestrian, vehicle and aerial patrols, vehicle-mounted 

camera deployment, and forward operating camps.
Appendix G. Methods of Analysis

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Table 151. Suitability of select special uses on the Coronado National Forest

Management Area

Energy 

Corridor Other Energy

Comm. Site1

(Excl. DHS)6

Motorized 

Outfitting and 

Guiding

Military 

Training

Recreation 

Event

DHS/CBP 

Activities6

Wild Backcountry Not suitable Not suitable Suitable1 Not suitable Suitable Suitable Suitable3

Roaded Backcountry Suitable Suitable Suitable1 Suitable Suitable Suitable Suitable

Motorized Recreation Suitable Suitable Not suitable Suitable Suitable Suitable Suitable

Developed Recreation Not suitable Not suitable Suitable1 Not suitable Not suitable Not suitable Suitable

Wilderness Area, 

Wilderness Study Area, 

and Recommended 

Wilderness Area

Not suitable Not suitable Not suitable Not suitable Not suitable Suitable2 Suitable3

Arizona National Scenic 

Trail (within 1/2 mile)5

Not suitable Not suitable Not suitable Not suitable Not suitable Suitable2 Suitable3, 4

Research Natural Areas Not suitable Not suitable Not suitable Not suitable Suitable Suitable2 Suitable4

Wet Canyon Talussnail 

Zoological Area

Not suitable Not suitable Suitable1 Not suitable Not suitable Suitable2 Suitable4

Mount Graham 

Astrophysical and 

Biological Research 

Area

Not suitable Not suitable Not suitable Not suitable Not suitable Not suitable Suitable3, 4

Appleton-Whittell 

Research Ranch

Not suitable Not suitable Not suitable Not suitable Suitable Suitable2 Suitable4

Wild Chile Botanical 

Area

Not suitable Not suitable Not suitable Not suitable Not suitable Suitable2 Suitable4

1. Communication uses at approved sites only, excluding Department of Homeland Security

2. Approved on a case-by-case basis

3. Nonmotorized use only, helicopter landings at authorized sites.

4. No forward operating camps.

5. Uses that will not substantially interfere with the nature and purposes of the trail.

6. DHS/CBP = Department of Homeland Security/Customs and Border Protection
Appendix G. Methods of Analysis

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Social and Economic Analyses

The methodology and approach to the analysis of socioeconomic resources is explained in detail 

in the “Communities – Environmental Consequences” section in the final environmental impact 

statement.

Livestock Grazing

The alternatives were compared on the basis of how they would affect management of livestock 

grazing on the forest. This was largely a qualitative analysis for most effects under all 

alternatives. 

In the analysis for this resource, the following assumptions were made:

• Market demands for livestock products are highly variable. We assumed current market 

demands for livestock products would continue through the next several decades with a 

continuing demand for grazing of the National Forest System lands. 

• Livestock grazing use would be authorized dependent on forage availability.

• The Arizona Game and Fish Department manages populations of big game (i.e., mule deer, 

elk, pronghorn antelope, and bighorn sheep).