United States

Department of

Agriculture

Forest

Service

Southwestern

Region

Record of Decision

Santa Fe Municipal

Watershed Project

Espanola Ranger District

Santa Fe National Forest

Santa Fe County, New Mexico
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Record of Decision

Santa Fe Municipal Watershed Project

Santa Fe National Forest

Southwestern Region

USDA Forest Service

In cooperation with:
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Location and Project Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Partnerships and Public Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Public Comments on the Draft EIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Purpose and Need . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Selected Alternatives C1 and D1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Thinning and Slash Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Fuel Breaks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Broadcast Burning . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Reasons for My Selection of Alternatives C1/D1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Summary of Rationale for C1/D1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Selected Option A: No Roadside Wood Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Non-Selected Option B: Thin the Larger Conifers on 100 Acres . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Alternatives Considered and Eliminated From Detailed Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Mitigation and Monitoring Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Prescribed Burning and Risk of Escape Fire . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Air Quality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Soil and Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

Riparian Ecosystems and Aquatic Habitat . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

Terrestrial Habitat and Associated Wildlife . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Heritage Resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Permits and Agency Approvals Required . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

Findings Required By Other Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

National Environmental Policy Act (NEPA) and 40 CFR 1500 Regulations . . . . . . . . . . . . . . . . . . . . . . . . . 13

National Forest Management Act (NFMA) 36 CFR 219 Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

National Historic Preservation Act (NHPA) and 36 CFR 800 Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Endangered Species Act (ESA) and 50 CFR 402 Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Migratory Bird Treaty Act (MBTA) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

Clean Water Act, 40 CFR 130 regulations and State Water Quality Standards . . . . . . . . . . . . . . . . . . . . . 15

Floodplains and Wetlands, Executive Orders 11988 and 11990 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Clean Air Act, 40 CFR 50 regulations and Air Quality Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Environmental Justice, Executive Order 12898 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Administrative Appeal Provisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Implementation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Contact . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Table of Contents
Santa Fe Municipal Watershed Project Record of Decision 1

Introduction

I am pleased to announce that we have completed the

detailed analysis process and Final Environmental

Impact Statement (EIS) for the Santa Fe Municipal

Watershed Project. The Final EIS consists of the Draft

EIS as published, along with an Errata Sheet comprising minor corrections and clarifications to the Draft

EIS, an updated Appendix B: Monitoring Plan, and an

Appendix C: Response to Comments. We did not write

a new EIS because the changes in response to public

comments on the Draft EIS were minor and confined to

factual corrections, clarifications, and other responses

that did not warrant further agency action {40 CFR

1503.4 (c)}. Regulations require circulating only changes

to the Draft EIS rather than rewriting and circulating

the entire EIS when changes are minor {40 CFR

1500.4(m)}. Based on a thorough review of public

comments, I determined that there was no need to

modify alternatives, develop and evaluate new alternatives, or supplement or modify the analysis in the Draft

EIS in order to make an informed decision on this

project in accordance with National Environmental

Policy Act (NEPA) regulations.

As Forest Supervisor for the Santa Fe National Forest,

I have made this fuel reduction project in the Watershed a top priority in an attempt to protect the City of

Santa Fe and it’s water supply from the potentially

devastating impacts of a large catastrophic fire. The

Watershed supplies 40 percent of the City’s water, and

currently contains thousands of acres of exceptionally

dense forests that are highly vulnerable to the kind of

raging crown fires experienced last year in New Mexico

and throughout the U.S. This is a very serious problem. If we do not substantially reduce the number of

trees that blanket this area, we can expect a high

severity fire that will decimate the Watershed, threaten

the City with loss of homes and businesses, cause

massive soil and debris flows into the Santa Fe River

and it’s water supply reservoirs, and send muddy flood

waters through Santa Fe’s streets and downtown area.

We know we cannot prevent a wildfire from ever burning in the Watershed. However, it would be irresponsible

for me not to take immediate action to reduce the

numbers of trees that form hazardous fuel loads in the

Watershed, to the extent necessary to limit the magnitude and intensity of any fires that might occur.

It is my decision to implement fuel reduction treatments described in the EIS for the Santa Fe Municipal

Watershed Project as Alternatives C1 and D1, together

with Option A (No Wood Removal), along with all

mitigation measures identified in the EIS (pp. 27-32)

and the comprehensive monitoring and adaptive management plan outlined in Appendix B as updated.

Record of Decision

Location and Project Area

This Record of Decision describes the selected alternatives and how I arrived at this selection after comparing

the tradeoffs among the various alternatives and options, and considering public comments received on

the Draft EIS.

This decision applies to national forest lands identified

in the EIS as the “project area” (pp. viii, 1); situated in

the upper Santa Fe River canyon that directly borders

the City of Santa Fe, in northern New Mexico, Township

17 North, Ranges 10 and 11 East. The project area

consists of 7,270 acres within the Watershed, just

below the Pecos Wilderness boundary and south of

Hyde Park Road (State Highway 475). The selected

alternative may also be applied on City-owned land and

private land within the project area, with the owner’s

consent.

This project area consists of primarily 80 to 90-yearold ponderosa pine forest with small patches of other

vegetation types. It extends 7 miles up the Santa Fe

River canyon to a steeper area where the vegetation

changes to a moist, mixed conifer forest. Elevations

range from 7,000 to 8,500 feet, and there are no

perennial streams in the project area other than the

Santa Fe River.

A Department of Agriculture Closure Order has kept

the Watershed closed to public use since 1932. Direction in the 1987 Forest Plan along with the 1996

administrative closure order reinforce the 1932 order.

The project area lies within an inventoried roadless

area and is predominantly unroaded. An administrative access road runs through the canyon bottom, from

the end of Upper Canyon Road—a narrow and winding

residential road—to the wilderness boundary. The

steep canyon slopes and lack of access roads within the

Watershed, or suitable haul roads outside the Watershed, created a formidable challenge in planning for

fuel reduction in this area. Options for disposing of the

woody fuels were quite limited.

Partnerships and Public

Involvement

The City of Santa Fe was a cooperating agency and

partner in the planning of this project. The Mayor and

City Councilors toured the project area and met with

us on this project, and we worked closely with the City’s

Sangre de Cristo water department. We also took

Santa Fe County Commissioners, State Senators and

other government officials to the demonstration sites

in the Watershed.
2 Santa Fe Municipal Watershed Project Record of Decision

The planning team reached out extensively to solicit

input from the public, as well as from scientists with

specialized knowledge regarding thinning and burning

treatments designed to reduce potential wildfire severity. I felt that by using the best available science,

combined with a truly open and collaborative public

participation process, I could make an informed decision about how to reduce fuel loads while maintaining

the ecological integrity of the natural resources in the

Watershed. The analyses for soil, water, and aquatic

and terrestrial biota were contracted out to respected

experts in those fields. The environmental contractors,

together with over 16 resource specialists from the

Forest Service, conducted a thorough analysis of the

relevant issues and alternatives. They utilized over 200

published scientific research papers, as referenced

throughout the EIS. Research scientists from colleges,

universities, and research stations were enlisted to

advise the project planning team, participate in a community forum, and independently review the Draft EIS.

In our collaborative process, we frequently met with

interested agencies and organizations, including Santa

Fe Watershed Association, Forest Watch, The Nature

Conservancy, Forest Trust, Audubon Society, Sierra

Club, Bosque del Rio, the State Environment Department, and many interested citizens. We met with over

15 civic groups and neighborhood associations in Santa

Fe including Thousand Friends of New Mexico, Voices of

Santa Fe, Network Neighborhood Association, and others. We presented information to the City Council, and

they passed a resolution in support of the preferred

thinning and burning alternatives. We engaged the

public early in the process so citizens could participate

in clarifying the problems and developing possible solutions. We created small thin-and-burn demonstration

sites in the Watershed, and led monthly public field

trips to those sites. We distributed informational brochures, held community meetings, provided an

information website, and engaged the media in maintaining the community dialogue regarding this project.

The NEPA process officially began on July 17, 2000

when the Notice of Intent to prepare an EIS was published in the Federal Register. The Notice of Availability

for the Draft EIS was published in the Federal Register

on April 13, 2001. However, we released the Draft EIS

on the internet and to the media in mid-March to allow

for some additional public review time. The 45-day

public comment period ended on May 29, 2001, and a

specialized “content analysis team” systematically compiled, categorized and coded the comments. We then

responded in writing to the comments received (see

Final EIS Appendix C: Response to Comments).

Public Comments on the Draft EIS

In reviewing public comments, there appeared to be a

clear understanding and support for the need to reduce

fuel loads and the associated risk of a catastrophic

crown fire. There was widespread support for the

selected treatment of thinning the small trees, followed

by burning the thinning slash and remaining hazardous fuels as necessary. Only a few individuals favored

the no action alternative. A few who generally approved

of the thinning and burning asked for a more limited

approach, while others asked for more extensive and

aggressive treatment. Most people gave recommendations about specific environmental protection or

monitoring measures they would like to see included

with the project. I found the vast majority of these

suggestions to be consistent with the features described

for the selected alternatives, such as using contour

felling, retaining the largest trees, leaving some

unthinned patches, not clearcutting the fuelbreaks,

thinning to variable densities, restoring historic lowintensity fire regimes, staying out of the riparian zone,

implementing in stages, and using monitoring results

to adjust treatments over time. In general, there were

only a few points of debate or concern over specific

treatment methods or components, such as concerns

about the use of feller-buncher machines and creation

of fuelbreaks. We also received detailed recommendations about monitoring methods, which were either

already in the monitoring plan or will be evaluated by

the monitoring committee. Some comments were outside the scope of this fuel reduction project, such as

those about recreational access, wilderness designation, and reintroduction of native wildlife species. The

largest volume of comments came from east-side residents who favored Option A, expressing strong concerns

about wood being hauled down narrow and historic

residential roads. Most people were opposed to Option

B. Along with the comments I’ve mentioned in this

section, I carefully considered all the public comments

before making this project decision. I did not treat them

as votes, so the number of form letter copies and

petition signatures had little bearing on my decision. I

focused instead on the substance of the comments.

Please review the public comments and responses in

Appendix C.

Purpose and Need

The EIS (pp. 3-5) makes it clear that the primary

purpose of the project is to reduce the hazardous fuel

loading, consisting of hundreds of small trees per acre,

in order to decrease the likelihood of a high-severity
Santa Fe Municipal Watershed Project Record of Decision 3

crown fire. It states that this is needed to protect the

municipal water supply and restore sustainable watershed conditions. It also states that the secondary

purpose is to increase herbaceous ground cover to

improve long-term soil stability and vegetative diversity. All of the action alternatives analyzed in the EIS

addressed this purpose and need, and I compared each

alternative to this purpose and need as a key criteria for

my decision.

Issues

“Issues” are the concerns about effects of the proposed

actions (EIS pp. 11-13). The following were identified

as the significant issues, which were used to develop

management alternatives, mitigation measures and

monitoring requirements {40 CFR 1500.4g, 1500.5d,

1501.7(2,3), 1502.2b}:

- Risk of escaped fire from prescribed burns.

- Risk of smoke impacts from prescribed

burns.

- Traffic impacts from wood hauling trucks

(accidents, noise, traffic delays, vibration

damage to historic homes and properties,

and road damage).

- Worker safety hazards and efficiency problems due to steep slopes, loose soil, and

lack of road access.

Other issues (concerns) about the proposed treatments were not considered “significant” because the

impacts were likely to be negligible once the mitigation

and monitoring requirements are applied to minimize

potential adverse effects (see EIS Comparison of Alternatives, pp. 33-40). Thus, the following issues were

used to design specific mitigation and monitoring

measures listed in this document, but they did not play

a major role in the decision making process: insect

infestations from slash piles; increases in soil erosion

or stream sedimentation; reduction in soil productivity

under burned slash piles; increases in the spread of

invasive plants; reduction in shading near the river

causing elevated stream temperatures; noise disturbance to wildlife species; reduction in closed canopies

or other habitat features causing impacts to wildlife

species; and damage to archaeological sites from thinning or burning.

Selected Alternatives C1 and D1

Thinning and Slash Disposal

The selected manual and machine thinning alternatives (C1 and D1 respectively) involve first cutting down

the smallest trees from the slopes that are feasible to

thin (not too steep), within a selected portion of the

project area. The thinning will create a tremendous

volume of slash. Hauling the slash out of the Watershed is not a viable option for most of this project area

due to the steep slopes and lack of road access. Other

slash disposal methods, such as chipping and spreading the chips, were also determined to be impractical or

unfeasible (EIS pp.155-161). Thus, these alternatives

involve piling or scattering the hazardous slash (woody

stems and branches less than 6-inch diameter), and

later burning the slash under appropriate weather and

fuel conditions (EIS pp. 16, 53). After treatment, an

average of 50-100 of the largest trees per acre will be

left standing and the cut tree stems over 5-6 inch

diameter, which are not considered hazardous fuels,

will remain on the ground. These contour-felled down

logs will aid in controlling erosion and runoff, and

improve nutrient cycling, vegetative productivity and

habitat diversity (EIS p. 53, 97).

In the first year, one portion of the project area will be

thinned and slash piled manually by crews with chain

saws, and another portion of the project area will be

thinned with feller-buncher machines that cut the

trees and then lay them on the ground. The relative

safety, effectiveness and environmental effects of these

two thinning methods will be monitored and evaluated

prior to determining whether or not to continue using

one or both of these methods in subsequent years.

After the slash is burned, in piles or as scattered slash,

monitoring results will again be used to compare any

obvious differences between the various thinning and

slash burning methods.

Riparian areas will not be thinned, and it is likely that

several unthinned and unburned patches will remain

after the entire Watershed has been treated. If surrounded by treated areas, untreated patches should

not pose a significant fire threat to the Watershed.

Fuel Breaks

Fuelbreaks are considered a high priority component

of the selected alternatives, particularly the fuel break

on the southern ridge line. Some people expressed

concerns about the width, number of trees to be cut, or

potential impacts to soils, wildlife, or firefighter safety.
4 Santa Fe Municipal Watershed Project Record of Decision

However, based on the scientific research and analysis

in the EIS, and the type of “shaded” fuelbreaks proposed

for this project, I firmly believe they are essential in

meeting objectives for this area. Also, see the EIS

Appendix C: Response to Comments, Comments 24-29.

The main points that I considered in approving the

fuelbreaks are as follows, based on the EIS and EIS

Appendix C. Fuelbreaks will primarily consist of narrow

areas along some of the ridges in the project area where

the trees will be thinned to a lower density than on the

side slopes. The shaded fuelbreaks prescribed for the

Watershed will not look like clearcuts or fragment

wildlife habitat, as some people feared. They will contain approximately 20-30 of the largest trees per acre,

along with grasses, forbs, shrubs and down logs. This

post-treatment tree density will be within the historic

range of variability for ponderosa pine forest ecosystems in the Southwest, particularly on ridges that tend

to have fewer trees than the drainages. Ground vegetation is expected to increase—not be reduced—within

these fuelbreaks, due to the increase in sunlight reaching the forest floor. Windthrow does not tend to occur

in ponderosa pine fuelbreaks. Fuelbreaks have proven

to be very effective in slowing down or stopping a

running crown fire. They provide a safe area for fire

suppression personnel and helicopters, and a good

containment boundary for prescribed burns. Shaded

fuelbreaks applied in New Mexico have not been found

to cause detrimental impacts to soil or wildlife. The

primary fuelbreak and highest priority for treatment in

the Watershed is along the southern ridge, due to the

topography, fuels, human activity areas along the perimeter (ignition sources), and prevailing southwesterly

winds.

Broadcast Burning

Research studies and field experience have shown that

low intensity broadcast burns can be used to effectively

reduce surface and ladder fuels, and promote growth of

ground vegetation (EIS pp. 53-54). However, broadcast

burning poses a risk of an escaped fire outside the burn

unit, and may create short-term smoke impacts down

canyon from the project area. I take these issues quite

seriously, and I asked the planning team to analyze

alternatives that do not include broadcast burning.

However, these alternatives (B2, C2, D2) were found to

be substantially less effective in meeting fuel reduction

objectives. Thus, to minimize the risks of escaped fire

and smoke accumulations, numerous mitigation and

monitoring requirements will be employed and strictly

enforced (see those listed in this document).

Results from monitoring will be used to determine what

modifications, if any, to make in the burn prescriptions,

and whether any of the remaining unthinned patches

should be broadcast burned in order to meet fuel

reduction objectives. Unthinned patches will not be

burned unless completely surrounded by pre-treated

areas and other fuel breaks such as a road, river, or rock

cliff. Portions of thinned and unthinned areas may be

burned together if that improves our ability to control

the burn and meet objectives. We will not conduct

burns in the Watershed if there are any uncertainties

about the appropriateness of the weather and fuel

conditions, and the availability of qualified personnel

and contingency resources.

Reasons for My Selection of

Alternatives C1/D1

The treatments described in Alternatives C1 and D1

(EIS pp. 22-25) have been consistently demonstrated to

be very effective in reducing fuel volumes and breaking

up fuel continuity, thereby limiting the ability of a

surface ignition to become a raging crown fire (EIS pp.

43-56). The more acres treated with these thinning and

slash disposal actions, the lower the risk of a crown fire

(EIS p. 55). Therefore, Alternatives C1 and D1 best meet

the purpose and need for this project compared to other

alternatives, by mechanically thinning the most acres,

burning the slash residues, and allowing for low intensity surface burns where necessary to meet fuel reduction

objectives (EIS pp. 43-56). By allowing for periodic, low

intensity surface broadcast burns in this fire-adapted

ponderosa pine ecosystem, we also improve our ability

to establish herbaceous vegetation, stabilize the soil,

encourage nutrient cycling and enhance habitat diversity.

Some people expressed concerns about the use of fellerbuncher thinning machines (Alternative D1). They are

concerned that this alternative may eliminate job opportunities for locals, and that the machines may cause

excessive soil erosion, runoff, or other undesirable

impacts. I understand the concerns expressed, however, I would like to allow for both manual and machine

thinning to be done in the beginning under a short-term

contract, so we can monitor and compare each method

and determine which method(s) should continue to be

used in this area. Machine thinning offers the most

expeditious way to thin a large landscape area, thereby

minimizing the chance of experiencing a severe fire

prior to completing fuel reduction treatments. A fellerbuncher operator can do as much thinning work in a

day as 8 men with chain saws. It is also shown to
Santa Fe Municipal Watershed Project Record of Decision 5

provide for better worker safety compared to manual

thinning crews, particularly in steep roadless areas.

Feller-bunchers are used on similar projects throughout the West including New Mexico, with good results

and safety records. While it is true that forestry

businesses in New Mexico do not currently own these

machines, this situation may change as it has in other

western states. We cannot guarantee that a manual or

machine thinning contract will be awarded to an in

state business, due to Federal contracting regulations.

It is our goal to provide local employment opportunities

whenever possible, and the numerous thinning projects

we are offering throughout the forest should provide

plenty of job opportunities for qualified local thinning

crews.

To avoid impacts due to operator negligence, all thinning contracts will have strict provisions governing

conduct, specifications and penalties for non-compliance. The machines may not drag the logs, and may

often operate on frozen or snow-covered ground, which

minimizes soil disturbance. The machines will disturb

the soil to some degree, but studies reveal that they

would not be expected to cause excessive compaction,

erosion or reductions in long-term soil productivity

(Final EIS, Appendix C, Comment 25). Noise from

feller-bunchers is equal to or less than that from

manual crews with chain saws. Scientific research,

combined with field observations of feller-bunchers

conducting thinning operations, and the determinations made in the EIS by the soil scientists, hydrologists,

wildlife biologists and others who analyzed the potential impacts from the feller-bunchers, all indicate that

these machines should not incur any significant adverse effects (See Final EIS Appendix C: Response to

Comments, Comments 25-29, and EIS pp. 25, 33-37,

72, 78, 86, 97, 104, 112).

I weighed the advantages of Alternative D1 with the

disadvantages, such as the fact that more smoke

(smoldering time) is expected from burning the bundles

of whole trees compared to burning scattered or piled

slash (EIS p. 112), and the fact that we currently don’t

have thinning machine operators in New Mexico. After

careful consideration, I decided that it is important to

have the flexibility to use the machines to meet fuel

reduction objectives as needed, and to be able to

compare the actual effects of the two methods with

effects predicted in the EIS.

The use of manual and machine thinning in Alternatives C1 and D1 provide for the greatest control over

forest stand densities. These alternatives allow us to

create a variable density mosaic that mimics natural

fire disturbance patterns in ponderosa pine forests.

Forest structure will shift from being dominated by

trees less than 12 inches in diameter, to one dominated

by trees greater than 12 inches in diameter, resembling

a more mature pine forest. The analysis in the EIS

indicated that implementing these alternatives would

be expected to have these additional benefits: improve

nutrient cycling and nutrient availability thereby enhancing long-term soil productivity; increase coverage

and diversity of ground vegetation thereby increasing

soil stability and habitat diversity; enhance tree growth

and vigor by reducing competition; reduce susceptibility to insects and disease; increase the abundance of

down logs that provide moist microclimates for establishment of herbaceous vegetation; increase the

structural diversity of the forest; promote mature

forest characteristics that improve habitat for special

status indicator species like goshawks; increase aspen

regeneration that further enhances habitat diversity

and resistance to wildfires, and other benefits. See EIS

pp. 52-55, 69-72, 86, 96-97, 104-105 for details. The

only unavoidable adverse effects anticipated to occur

from implementation of these alternatives are temporary increases in noise disturbance, short-term smoke

effects, and minor short-term increases in soil erosion

and stream sedimentation (EIS p. 135).

The other management alternatives did not meet the

project’s purpose and need as well as Alternatives C1

and D1, for the following reasons:

Alternative B1: This alternative treats most of the

project area with prescribed fire rather than manual or

machine thinning, in order to complete the treatments

in the shortest amount of time and with the least risk

to worker safety. However, research and experience

have shown that thinning with prescribed burns is not

nearly as effective as mechanical thinning (with saws)

in controlling the density of forest fuels. In addition,

this alternative would have the highest risk of an

escape fire and result in more days of nuisance smoke

compared to other alternatives.

Alternative B2: This alternative excludes the use of

prescribed broadcast burns to address the key issues

of escape fire and smoke, and limits mechanical thinning to gentle slopes near the existing road to address

the key issue of worker safety. This alternative does

not treat enough acres to fully meet fuel management

objectives, and was determined to be the least effective

of the six action alternatives analyzed.

Alternatives C2 (manual thin) and D2 (machine

thin): These alternatives also exclude the use of

prescribed broadcast burns in order to address the key

issues of escape fire and smoke, while mechanically

thinning as many acres as possible in the project area.

If I selected either or both of these alternatives, I forego
6 Santa Fe Municipal Watershed Project Record of Decision

the option of using prescribed broadcast burns in this

area as a tool to further reduce fuel loads, which could

result in leaving unacceptable fuel loads that continue

to create a crown fire risk. Alternatives that don’t allow

for low intensity surface burns are also less effective in

establishing ground vegetation and improving soil qualities and habitat diversity.

I understand the public concerns and risks associated

with conducting a prescribed burn in this Watershed

adjacent to the City of Santa Fe. I do not discount the

fact that prescribed burning in the Watershed is likely

to create some undesirable smoke impacts for some

people during the mornings following a burn day, and

there is always a risk that a spot fire could potentially

occur outside the defined burn unit. However, I had to

weigh these potential risks against the high probability

of a large uncontrolled wildfire that would create heavy,

long lasting smoke accumulations and devastating

impacts to the community and water supply (see EIS pp.

48-56, 109-112).

Summary of Rationale for C1/D1

In summary, I selected Alternatives C1 and D1 because

I feel it is important to have some flexibility over the next

5 to 8 years to use either manual or machine thinning

methods, based on the results from monitoring these

methods in selected portions of the project area. I also

believe it is critical to reduce the volume of thinning

created slash through carefully planned and implemented burns, and to allow for the option of using low

intensity surface burns where needed to further reduce

forest fuels and encourage growth of ground vegetation.

Based on the analysis described in the EIS, Alternatives

C1 and D1, together with the comprehensive mitigation

and monitoring requirements listed in this document,

will provide the most effective fuel reduction methods to

reduce the risk of a catastrophic fire and will incur

minimal risk of any significant adverse environmental

impacts.

Based on all the reasons stated for selecting Alternatives C1/D1 (with Option A) for implementation, I also

consider these alternatives to be the “environmentally

preferred alternatives” for this project {identified in

accordance with 40 CFR 1505.2 (b)}. Even though other

alternatives are perhaps lighter on the land because

they thin or burn fewer acres or do not use a machine

to thin the trees, Alternatives C1/D1 will be the most

effective in reducing the risk of experiencing a catastrophic fire in the project area. The analysis in the EIS

shows that the greatest potential for environmental

harm is from the no action alternative, and secondly

from alternatives that are not as effective in reducing

hazardous fuels, due to the high probability of experiencing severe crown fires in this area. Options A and B

each affect less than 2 percent of the project area, so

they had no real bearing on my selection of the environmentally preferred alternative. The next sections describe

my reasons for selecting Option A and not selecting

Option B.

Selected Option A:

No Roadside Wood Removal

The proposed action that generated the most public

comment and concern was the removal of wood from the

Watershed through the east-side neighborhoods of Santa

Fe. The planning team originally estimated that 560

acres of the 7,270-acre project area were accessible to

the service road, including both City and National

Forest lands. Many people said they would like to see

the wood put to a beneficial public use. Hence, we

originally proposed removing the small wood products

from those roadside acres in order to provide firewood

and local jobs, rather than leaving all the logs on site.

When the public voiced concerns about the potential

impacts of hauling wood through their narrow residential roads and historic neighborhoods, the planning

team identified this as a key issue and developed Option

A-No Roadside Wood Removal to avoid the potential

impacts (EIS pp. 12, 26 and 119-120).

Upon further field reconnaissance, we have determined

that substantially less ground is feasible for wood

removal. Of the 300-350 acres originally estimated for

removal from City lands in the Watershed, it appears

there are only approximately 50 roadside acres realistically available. The City’ contractor is proceeding with

removing woody fuels less than 6-inch diameter from

those 50 acres. We currently estimate that there are

only 50-120 acres on national forest land in the Watershed that may be feasible for wood removal (about 2

percent of the project area). The size and species of the

wood to be thinned is of low value relative to other small

wood products sold in Santa Fe (see Appendix C,

Comment 43, “cost versus value”). In addition, we

expect fuel reduction thinning in roaded portions of the

national forest outside the Watershed will yield at least

10,000-15,000 cords of firewood annually, in addition

to a million board feet of other small products.

I reviewed many letters of concern about hauling out the

wood. There is an increased risk of traffic accidents

associated with adding haul trucks to such narrow,

low-standard roads that are used by pedestrians, school

children, bicyclists, tourists, and commuters who live,

work and recreate on these roads. There are no side-
Santa Fe Municipal Watershed Project Record of Decision 7

walks or crosswalks, and there is a day care center and

at least 3 schools along these roads. The potential

hazards along Upper Canyon and adjacent roads are

greater than those on most national forest haul routes.

The Historic Santa Fe Foundation and others expressed major concerns about possible vibration

damage from haul trucks to historic structures listed

on national and state registers of historic places, as

well as to old adobe homes along the road. According

to our informal traffic counts and additional information from residents, residents are already experiencing

traffic delays, road damage, safety hazards and other

problems associated with current traffic loads relative

to the design of the road. Upper Canyon Road is heavily

used by residents, tourists, visitors to the Audubon

Center, water treatment plant employees, as well as

Forest Service and City employees, and others who

work in the Watershed. Thus, I must consider the

cumulative effects of incrementally adding to the truck

traffic on these roads.

At this time, I do not believe it is prudent or necessary

to approve additional wood removal from the minor

acreage of accessible national forest land in this project

area. This decision is based on considering: (a) public

concerns and potential impacts associated with adding

to the truck traffic in this area; (b) the small volume of

low-quality wood products that could come from this

area; (c) the large amount of wood products anticipated

from roaded areas on the forest; (d) the 1-2 days of extra

slash burning that may be needed if we leave the cut

wood on these acres; and (e) leaving the logs and

burning the slash on these acres rather than hauling

the material out will not reduce our ability to meet fuel

reduction objectives.

Non-Selected Option B: Thin

the Larger Conifers on 100 Acres

This option was developed to address the project’s

purpose and need, in light of the fact that some very

dense patches of conifers exist in the canyon bottom.

I fully considered the tradeoffs involved in this option

that involves thinning the larger trees (up to 24-inch

diameter) on 100 acres scattered in small patches

across the canyon bottom. The conifers are larger in

the canyon bottom near the river due to the higher site

productivity there compared to the side slopes. In

order to open up these dense conifer patches such that

they would discourage crown fire activity, numerous

trees both large and small would need to be cut and the

slash burned.

The EIS described the advantages of implementing this

option, such as reducing the potential for severe crown

fire effects and enhancing re-establishment of soil

stabilizing herbaceous vegetation by creating openings

in the canopy (EIS pp. 51, 78). However, most of those

who commented on the EIS expressed concerns with

this option, and forest ecologists consulted believed

that the disadvantages of cutting down these large

trees outweighed the potential fuel reduction advantages. Trees over 16-inch diameter are a very rare

habitat component in this area (EIS, pp. 86, 98). In

addition, the planning team had some concerns about

having exceptionally large volumes of down logs left in

areas where wood removal is not feasible. Therefore,

after considering the various tradeoffs expressed and

considering the small acreage affected by this option,

I decided not to select Option B.

Alternatives Considered and

Eliminated From Detailed Study

Many alternatives were considered and eliminated

from detailed study. Public comments received on the

EIS asked that we reconsider the following alternatives

that were described and eliminated in the Draft EIS:

using horses or mules; chipping the slash: building

new roads; using goats to reduce fuels, and the Forest

Conservation Council alternative to limit thinning to

trees 6-inch diameter or less along with prescribed

burning. I reconsidered these alternatives and still

believe the reasons previously described for their elimination are valid and well supported by scientific analysis,

so there is no reason to analyze them any further.

Please refer to the rationale for their dismissal in the

EIS (pp. 155-162) and in Appendix C: Response to

Comments (Comments 11-18).

Mitigation and Monitoring

Requirements

I have selected all of the mitigation measures described

in the EIS (pp. 27-32) and the monitoring requirements

described in the EIS Appendix B, as summarized in

this section, to be implemented as part of the selected

alternatives. By incorporating these requirements

with the design features of the treatment alternatives

(from EIS pp. 15-19), I believe that all practical means

to avoid or minimize environmental harm have been

adopted. Monitoring items summarized in this section

are identified with an asterisk (*). Monitoring provides

a quality control and adaptive management strategy.

By monitoring and evaluating the effects of treatments,

we can make appropriate modifications, assess resource trends and apply new knowledge to future

projects.
8 Santa Fe Municipal Watershed Project Record of Decision

Prescribed Burning

and Risk of Escape Fire

• Keep the size of slash piles generally less

than 6 to 8 feet in diameter by 5 to 6 feet high.

• Burn slash piles during times of cool temperatures and high humidity when the fuels

surrounding the piles have high fuel moisture.

• Avoid having tightly compacted piles in order to increase ventilation, combustion and

fuel consumption. During the burning, tend

the piles to assure that larger pieces of fuel

are consumed.

• Consider covering the piles with plastic when

they are built, to keep the piles dry for later

burning.

• Develop detailed broadcast burn plans, and

conduct broadcast burning only in accordance with those plans. Several Forest Service

officials will review the burn plans. Burn

methods must be those proven safe and

effective, and be modeled using a fire behavior computer model to validate they will meet

burn objectives with minimum risk of fire

escape.

• Design burn units to reduce the risk of

escape, based on size of unit, accessibility,

topography, fuel type, fuel load, weather,

time of year, etc.

• Ensure the perimeter of each broadcast burn

unit is surrounded by existing openings

such as reservoirs, streams, roads, or trails,

or treated areas where fuels have been reduced. Firelines may be built around the

burn unit by clearing the fuels to mineral

soil with hand tools.

• Locate fuel breaks where they will be most

effective in controlling the burns, such as

along ridges, drainages or other topographic

breaks, taking into consideration fuel type

and fuel loading.

• Prior to burning, complete the “go/no go”

checklist, risk assessments and daily review

checklists in the burn plans.

• Prior to ignition, ensure that there are adequate fire engines and water tanker trucks

on site and contingency suppression resources available, as indicated in the sitespecific burn plan. Do not ignite broadcast

burns when the Southwest Area’s “preparedness level” is at III or higher. This indicates

that contingency resources may not be available due to other fire activity in the Southwest.

• For some of the more complex broadcast

burn units, consider having a helicopter

with water dropping capability, and/or an

air tanker available on standby. Also consider laying down fire (water) hose around

the perimeter of the broadcast burn unit and

having portable water tanks and pumps in

place prior to ignition.

• Ensure that fire personnel implementing

broadcast burns have the appropriate knowledge, skills and qualifications for a

complex-rated burn. Personnel conducting

the broadcast burns should also be qualified

for fire suppression positions as a contingency in the event of an escape fire situation.

• Plan for and locate burn implementation

personnel in safe and strategic areas for

monitoring and containing the broadcast

burn.

• Exclude certain areas from the broadcast

burn unit where because of stand density or

topography, there would be a risk of high

intensity fire behavior and escaped fire.

• After the flames from the broadcast burn

have subsided, mop-up (extinguish) any hazardous heat concentrations along or adjacent

to the fireline that could threaten to cross

the line.

• * Prior to ignition and during the burn,

monitor the current and 3 to 10-day weather

forecasts from the National Weather Service

Fire Weather Forecaster in Albuquerque,

NM, plus daily spot weather forecasts, for

trends in temperature, relative humidity,

wind, frontal passages, etc.

• * Prior to ignition, monitor (via computers)

the forest’s 5-day energy release component

(ERC) from the forest’s weather stations. The

ERC is related to energy or heat that will be

released in a fire. The ERC is an indicator of

the relative dryness of the fuel, which dictates how hot a fire will burn. Do not

broadcast burn when the ERC is above 65.
Santa Fe Municipal Watershed Project Record of Decision 9

All large wildfires on the forest have occurred when the ERC has been above 68.

• * Prior to ignition and throughout burn

implementation, monitor and record fuel

moistures. Do not broadcast burn when live

fuel moistures are below 100 percent. Do

not broadcast burn complex burn units

when the Palmer Drought Index (PDI) indicates a moderate or higher drought index.

This will reduce the likelihood of an escape

fire and lessen the chance of killing desired

trees.

• * During prescribed burns, monitor and

record the observed fire behavior, and compare it with predicted fire behavior in the

burn plan. Evaluate the results to modify

future burn plans and burns. Patrol the

area during the burn to ensure that the fire

stays within the burn unit. Monitor daily

until the burn has been declared out. Have

an aerial observer over the area when broadcast burning the complex units. If a fire

should spread outside the burn unit, all

ignitions will cease until the spot fire is

controlled. The prescribed fire burn boss

will decide if the burn should continue

based upon prescription criteria and observed fire behavior.

• * After implementation, monitor the reduction in live fuel loads, including changes in

canopy structure and ladder fuels, and

compare with project objectives.

Air Quality

• Avoid broadcast burning on days when

mixing heights are less than 1,641 feet and

transport winds are less than 4 mph, in

order to get the best lifting and dispersion of

smoke. This should allow for burning to

occur during periods of sufficient atmospheric instability, but not during instability,

to improve smoke dispersal.

• Plan activities so that air quality will meet

applicable Federal, state and local regulations, including protection of Class I air

sheds such as the Pecos Wilderness (described in air quality section of EIS) (Forest

Plan, page 80).

• The amount of soil in piles and windrows

will be minimized to reduce smoldering.

• Notify the local agencies and the public

through radio, TV, newspapers, and/or personal contacts at least a week in advance of

the broadcast burns as well as a day before

the burn.

• Obtain a burn permit from the State Environment Department at least a month before

ignition as outlined in the New Mexico Smoke

Management Memorandum of Understanding.

• Continue to provide educational materials

on the benefits and tradeoffs of prescribed

burning, including signs along Hyde Park

Road, contacts in campgrounds, and so on.

Include educational information in firewood

permits on correctly storing and burning

firewood to minimize smoke.

• * Monitor particulate matter from smoke.

As a minimum, set up a particulate matter

monitor device along Upper Canyon Road to

record particulate levels of smoke that may

drift down canyon into the city during the

evening or morning hours after burning. If

particulate matter approaches the National

Ambient Air Quality Standards, take corrective measures to reduce smoke and notify

the New Mexico Environment Department

Air Quality Bureau.

• * Conduct visual monitoring continuously

through the burn periods. Behavior of the

smoke plume will be monitored as well as

visibility conditions along all major roads in

the area of the burn. If smoke becomes a

serious problem, stop ignition or initiate

fire suppression to reduce the generation of

smoke. If smoke starts to settle and limit

motorist visibility along Hyde Park Road,

Canyon Road, U.S. Highway 84/285, or

other major travel ways, take immediate

measures to alert motorists of the danger,

contact the appropriate state or local traffic

control agencies, and close roads where

necessary to avoid traffic accidents.

Soil and Water

• Directionally fell “contour logs” on steep

slopes as soil erosion barriers.

• Do not exceed low to moderate fire intensity

during broadcast burning (flame height of 1

to 4 feet) to help maintain soil productivity,
10 Santa Fe Municipal Watershed Project Record of Decision

minimize erosion, and prevent detrimental

amounts of ash, sediment, nutrients, and

debris from entering water bodies (consistent with features common to all action

alternatives).

• Prohibit vehicle use of roads or trails in the

Watershed during periods of wet weather

unless the roads have a stable surface and

sufficient drainage to prevent undesirable

erosion or sediment runoff impacts.

• If fire suppression becomes necessary, do

not allow any fire retardant drops within 400

feet of surface water (Santa Fe River or

reservoirs), to minimize risk of contaminating the water supply.

• *Before prescribed burning, monitor soil

moisture levels. Soil moisture levels should

be at least 11-15 percent to maintain longterm soil productivity and improve the chance

for vegetative response after burning.

• * Monitor the change in soil erosion (movement) to ensure it is within acceptable limits.

If soil erosion exceeds standards, take corrective action and modify treatments as

needed. (Forest Plan, pages 76 and 80).

• * After two full growing seasons following a

thinning and burning treatment, measure

the amount of vegetative ground cover. Apply native grass seeds (or plantings) where

determined necessary by the forest soil scientist to re-vegetate specific bare soil areas

for erosion and sediment (runoff) control,

such as where ground vegetation is less than

10-20 percent coverage. A realistic goal for

the granitic soils in this area is to achieve 30-

50 percent ground cover.

• *After the first growing season following slash

pile burning, monitor soil impacts by having

a soil scientist check the soil under the piles.

Where necessary and feasible, rake, till, and

seed areas under burned slash piles to promote vegetative response.

• * Monitor water quality in key locations to

aid in identifying and correcting any problems and to ensure that water quality will

continue to meet drinking water standards

(Forest Plan, page 80). Monitor sediment,

turbidity and total suspended solids, as well

as water chemistry parameters.

• * Monitor changes in peak flows before and

after thinning, as well as subsequent changes

in stream morphology, to determine whether

treatments are causing any detrimental affects to the stream channel.

Riparian Ecosystems

and Aquatic Habitat

• Do not pile slash within 15 feet of perennial

streams (Santa Fe River) to reduce the chance

of ash entering the water following slash

burning.

• Avoid piling slash in or adjacent to patches

of young cottonwoods in the riparian corridors to protect them from mortality during

burning.

• Manage riparian areas in accordance with

legal requirements regarding floodplains and

wetlands; protect the productivity and diversity of riparian-dependent species,

emphasizing protection of soil, water, vegetation, wildlife, and fish resources. Manage

in accordance with Forest Plan guidelines

regarding ground cover, shade, bank cover,

streambed sedimentation, plant composition, plant structure, and crown cover (Forest

Plan, pages 79-80).

• Do not conduct thinning activities within the

riparian area or within 15 feet of the riparian

area (riparian is defined in the section on

Aquatic Habitat).

• Locate log landing areas outside sensitive

areas including riparian areas, wetlands and

wet meadows, and special status species

habitat (Forest Plan, page 73). Once landings are no longer needed, rip and re-vegetate

landing sites as needed to recover site productivity (Forest Plan, page 78).

• Directionally fell trees away from all stream

channels to help reduce slash accumulations within drainage bottoms and to avoid

the need to turn trees around in or near

riparian corridors. (Forest Plan, page 78)

• Retain all willow, alder, and cottonwood

trees in riparian areas. This is consistent

with features common to all alternatives.
Santa Fe Municipal Watershed Project Record of Decision 11

• * Monitor changes in fish habitat before and

after implementation, including changes in

aquatic insects, to ensure that thinning

and burning activities do not adversely

affect aquatic habitat or fish.

• * Monitor for increases in stream temperature following any thinning in the canyon

bottom near the riparian area which could

degrade aquatic habitat.

• * Monitor changes in the number of active

beaver dams before and after treatment to

ensure that treatment activities are not

having adverse affects on the existing beaver population.

Terrestrial Habitat

and Associated Wildlife

• If any proposed, threatened, endangered,

or sensitive plant or animal species are

discovered during project implementation,

stop work in the immediate vicinity of the

species until a Forest Service wildlife biologist or plant ecologist has investigated and

recommended the appropriate protective

measures. These measures may include

restricted operating periods, no-activity

zones, protection or creation of snags, or

other measures.

• If a northern goshawk nest is found, stop

work within 30 acres of the nest site. Do not

conduct broadcast burning during May or

June within the nest area to avoid the

potential for crown fire or smoke to drive the

birds off or consume the nest tree (Forest

Plan, Appendix D, pg. 10).

• Apply other standards/guidelines for potential northern goshawk habitat, as detailed

in Forest Plan, Appendix D, pages 6-10,

including the following features common to

the design of all action alternatives: retain

large snags and down logs wherever possible; retain old age trees and the mature/

old forest structure; sustain a mosaic of

vegetation densities, age classes and species composition across the landscape;

increase herbaceous vegetation to provide

for goshawk prey species and to maintain

satisfactory soil conditions; use R3 protocol

to survey for goshawks (surveys were completed and no goshawks found); have

variable canopy coverage (averaging about

40 percent) with openings up to 4 acres

each while retaining at least two small

groups of trees per acre with minimum 12-

inch diameters.

• Avoid cutting trees containing a squirrel

nest or having large piles of cones at the

base of the tree, as well as any adjacent tree

with a crown interlocking the nest tree and

a diameter equal to or greater than the nest

tree.

• Retain (do not cut) at least 15 percent of the

mature and older mast-producing stands

in pinyon/juniper and oak zones (Forest

Plan, page 65).

• Within one-quarter mile of perennial water

(Santa Fe River) do not burn two slash piles

per acre so they may be used as potential

nest cover for wild turkey. These piles should

be at least 3-feet high by 10-feet wide (Forest Plan, page 65).

• Retain all sound snags, except within fuel

breaks and 100 to 300 feet from the edge of

fuel breaks if the snag may pose a hazard

during broadcast burning. Retain at least

220 snags or potential snags per 100 acres

where consistent with fuel management

objectives. Particular attention will be given

to retaining trees with dead or broken tops,

heart rot, and lightning scars, in order to

maintain and promote habitat for cavity

nesting or roosting species (Forest Plan,

page 72).

• Retain trees over 20-inch diameter within

200 feet of major ridges, cliffs, and openings

(except snags that must be cut for fuel

breaks), to provide perch and roost trees for

raptors. This requirement is consistent with

features common to all action alternatives

(Forest Plan, page 66).

• Retain at least five large down logs per acre

where consistent with fuel loading objectives. The desired goal is to have logs at least

11 inches in diameter and 15 feet long, in

various stages of decomposition (Forest Plan,

page 62).

• When cutting trees over 12-inch diameter,

leave two or three of the stumps per acre at

a height of 12 inches above the ground to
12 Santa Fe Municipal Watershed Project Record of Decision

serve as plucking posts for raptors and feeding and “lookout stations” for small rodents.

• Wherever possible without sacrificing fuel

reduction objectives, retain two thickets of

small trees per acre for cover and foraging

areas for flammulated owls and neotropical

migratory birds.

• Expand aspen stands where possible by

reducing the amount of shading and competition from conifers, and using prescribed

burns to stimulate sprouting of aspen (Forest Plan, page 74). This measure is consistent

with features common to all action alternatives.

• Retain (do not cut) oaks (Quercus gameli)

and shrubs, such as wild rose (Rosa spp.),

mountain mahogany (Cercocarpus

montanus), Rocky mountain maple (Acer

glabrum), currants (Ribes spp.), and raspberry (Rubus spp.).

• * Monitor the effects of treatment on wildlife

habitat, recording changes in the following

key habitat components: overstory tree composition, structure and density; and retention

of existing large snags and hardwood trees.

• * Monitor for changes in populations of

breeding birds and small mammals.

• * Monitor for increases in invasive plants

where soil is disturbed by management activities. Take corrective action as indicated

by monitoring results.

Heritage Resources

• Survey for and mark heritage resource sites

according to specifications provided in FSM

2309.24 and FSH 2361.28.

• Avoid all known (marked) heritage resource

sites during tree thinning, firewood collecting, constructing firelines, maintaining and

improving roads, and other land disturbing

activities associated with the project.

• Avoid burning perishable remains on heritage resource sites, and protect heritage

resources having exposed burnable materials, through one or more of the following

methods (determined by a Forest Service

archaeologist): digging or burning firelines

around the site; clearing fuels away from the

site; directing the fire away from the site;

foaming and/or covering wooden structures

with a fire shelter; or other protective measures. Exclude burning entirely from sites if

protective measures cannot be effectively

applied.

• Directionally fell trees away from known

(marked) heritage resource sites.

• Do not build slash piles in or near heritage

resource site boundaries.

• If previously undocumented heritage resource sites are discovered during project

activities, stop all work in the immediate

vicinity of the site and do not restart until

authorized by a Forest Service archaeologist.

• If it is not possible to avoid or protect heritage resource sites during thinning or

burning operations, or if mitigation measures prove unsuccessful, then data recovery

may be conducted.

• If Native American tribes or other traditional

communities express concerns about traditional use areas that may be affected by

management activities, mitigation may include avoidance of those areas during

operations, or other measures determined

through consultation with the affected tribe

or community.

• * Monitor to determine if any heritage resource sites were damaged during thinning

or burning operations. If any site has been

damaged, a Forest Service archaeologist will

determine the appropriate corrective actions

to take to minimize the risk in the future. If

damage to a heritage resource site is discovered during project implementation, stop all

work within the immediate vicinity of the

site, evaluate the damage and determine

what corrective measures are needed. Do

not resume work until authorized by a Forest Service archaeologist.

Permits and

Agency Approvals Required

The EIS (p. 13) lists four permits or authorizations that

must be obtained prior to implementing the project.

One has already been obtained—the consultation and
Santa Fe Municipal Watershed Project Record of Decision 13

concurrence from U.S. Fish and Wildlife Service on the

Biological Assessment. The remaining three are hereby

incorporated by reference into this Record of Decision.

Findings Required By Other Laws

The planning and decision making process for this

project was conducted in accordance with all applicable laws, regulations, policies and plans. This section

briefly describes my findings regarding the legal requirements most relevant to this project decision.

National Environmental Policy Act

(NEPA) and 40 CFR 1500 Regulations

I find that the planning and decision making process

for this project was conducted in accordance with the

requirements in NEPA and its implementing regulations, based on the contents of the EIS and supporting

documents in the project record.

One person who commented on the Draft EIS was

concerned that it did not adequately analyze the impacts of all alternatives, including the no action

alternative. However, in reviewing the EIS I found

nearly 100 pages that clearly describe the direct,

indirect and cumulative impacts of each alternative

including the no action alternative (EIS Chapter 3,

including 11 separate sections devoted to cumulative

effects). The interdisciplinary team analyzed two no

action alternatives: one that assumes no change from

status quo conditions (as a baseline) and one that

assumes a high-severity wildfire would occur, based on

the calculated 99 percent probability for such a fire

within the next 20 years (see Appendix C, Comments 1

& 19).

National Forest Management Act

(NFMA) and 36 CFR 219 Regulations

I find that the selected alternatives are consistent with

the 1987 Santa Fe National Forest Plan, as amended,

which sets forth programmatic direction in accordance

with NFMA. This is based on the following factors:

• The descriptions in the EIS of selected alternatives and mitigation measures (pp. 15-32),

as well as descriptions of environmental consequences (EIS Chapter 3) are clearly

consistent with the Forest Plan goals described for wildlife and fish, cultural

resources, soil and water, and riparian (Forest Plan pp. 19-20).

• The Forest Plan’s forest-wide standards and

guidelines were incorporated by reference on

pages 5 and 10 of the EIS, and used to

develop the alternatives to ensure Plan consistency (EIS p. 15).

• The mitigation measures for the selected

alternatives include and reference the applicable forest-wide standards and guidelines,

in order to help ensure compliance with the

Forest Plan.

• The EIS describes project conformance with

Forest Plan direction for management area

“O”, as amended in 1996, which applies to

the Santa Fe Municipal Watershed (Forest

Plan pages 155-156). The management area

emphasis is “water quality production,” and

the primary purpose for this project is to

“...protect the municipal water supply and

restore sustainable watershed conditions”

(EIS p.5). Forest Plan management area

direction specifically states that prescribed

fire may be used to reduce fuels. Management area direction does not prohibit

thinning, nor does it address thinning specifically, which means thinning is an allowable

use in this management area. Thinning is

specifically allowed by forest-wide direction

that states “use pre-commercial thinning to

control stocking that will meet management

objectives as identified in management areas

and in stand specific prescriptions” (Forest

Plan p. 71). The project does not involve

regulated or commercial timber production

and is, therefore, consistent with the management area designation of “non-suitable

timber lands.”

• By not building roads in this area, this project

is consistent with the Forest Plan and with

the agency’s 2001 Roadless Area Conservation Strategy for inventoried roadless areas.

• The EIS Appendix C: Response to Comments,

Comments 6-8, also discloses information

regarding consistency with specific Forest

Plan requirements.

I also find that the selected alternatives comply with

the seven management requirements in 36 CFR

219.27(b) regarding vegetation manipulation, because

the project:

1. Is best suited to the multiple-use goals established for the area considering the various
14 Santa Fe Municipal Watershed Project Record of Decision

physical, biological, social, economic and other

impacts as stated in the regional guide and

Forest Plan. The thinning and burning features and methods have been used

successfully in the past, and effects predicted

in the EIS are consistent with forest plan

goals, as previously described.

2. “Assures adequate restocking...”. This provision is not applicable to this type of fuel

reduction thinning project. Restocking requirements apply to regeneration harvest

treatments.

3. Is not chosen primarily because it will give the

greatest dollar return or the greatest output of

timber. This project is not expected to generate revenues or timber outputs. It is expected

to cost $3-4 million to implement (EIS p. 124).

This is less that the predicted cost of the no

action alternative that presumes a large crown

fire would very likely devastate the Watershed

and result in costs exceeding $150 million.

4. Is chosen after considering potential effects

on residual trees and adjacent stands. The

EIS describes the post-treatment effects on

residual trees and adjacent stands as a beneficial effect because it leaves all the key

components of the ecosystem, including the

largest trees, snags, down logs, and shrubs,

in a more variable density distribution over

the landscape that mimics natural fire disturbance patterns in ponderosa pine forests.

5. Avoids permanent impairment of site productivity and ensures conservation of soil and

water resources. The EIS provides ample

evidence that long-term site productivity will

be maintained, and soil and water resources

will not be adversely impacted by the selected

alternatives (pp. 73-75, 135).

6. Provides the desired effects on water quantity

and quality, wildlife and fish habitat, regeneration of desired tree species, forage

production, recreation uses, aesthetic values,

and other resource yields. The EIS (Chapter

3) describes how the action alternatives are

expected to have desired effects on all of these

resources.

7. “Is practical in terms of transportation and

harvesting requirements....” This is not applicable to this project, as there will be no

harvesting or transportation of wood products from national forest lands in this project.

National Historic Preservation Act

(NHPA) and 36 CFR 800 Regulations

I find that this project is consistent with the requirements of Section 106 of the National Historic Preservation

Act, based on the following factors:

• Prior to implementation in any given portion

of the project area, the forest will complete

the process required by Section 106 of the

National Historic Preservation Act in accordance with the Programmatic Agreement for

the Santa Fe Municipal Watershed Project

signed by the Advisory Council on Historic

Preservation (Council, the New Mexico State

Historic Preservation Officer SHPO and USDA

Forest Service, Region 3, Regional Forester

(36 CFR 800.14(b)(3)) (Project Record). Consultation with the Advisory Council and the

SHPO for this project has been ongoing, and

the Council and the SHPO have approved the

survey and clearance protocols being used

for this project.

• The documentation of project area surveys

and Section 106 consultation procedures are

tiered through the agreement mentioned

above to the Programmatic Agreement for

Wildland Urban Interface Hazardous Fuels

Reduction Projects signed by the Council,

SHPO and Regional Forester on July 19,

2001.

• A heritage resource impact analysis was completed (EIS pp. 125-130), and additional

details are contained in the specialist’s report

(Project Record). Archaeologists who prepared

this analysis concluded that the selected

treatments offer the best protection for heritage resources in the area compared to the no

action or more limited treatment alternatives

because these other alternatives leave heritage resources highly vulnerable to damage

or destruction by wildfires (EIS pp. 128-130).

• Tribes have been contacted regarding identification of potentially affected historic

properties as required under 36 CFR

800.4(a)(4) (Project Record). To date, tribes

have not revealed any traditional cultural or

other historic properties of concern in the

project area.

• Mitigation measures and monitoring requirements listed in this document and in the

Final EIS Appendix B help ensure compliance with these requirements. “Mitigation
Santa Fe Municipal Watershed Project Record of Decision 15

and monitoring measures are expected to be

effective in creating a low risk of damage to

heritage resources based on past experience

with similar thinning and burning projects

on the Santa Fe National Forest” (EIS, p.

129).

Endangered Species Act (ESA)

and 50 CFR 402 Regulations

I find that the project is consistent with this Act and it’s

implementing regulations, based on the following factors:

• The required biological assessment and consultation with U.S. Fish and Wildlife Service have

been completed for this project, under the Regional Biological Assessment & Evaluation (BA&E)

for Wildland-Urban Interface Fuels Treatment

(USDA FS 2001; Project Record and

www.fs.fed.us/r3/wui).

• The U.S. Fish and Wildlife issued a Biological

Opinion that concurred with the Regional BA&E.

The BA&E and Biological Opinion conform to

Endangered Species Act regulations (available on

the internet at www.fs.fed.us/r3/wui).

• The EIS shows tht all ESA listed species known to

occur in Santa Fe County were considered (Table

31, p. 99), and that none are known to occur or

likely to occur in the project area, which contains

very minor amounts of potential habitat for Mexican spotted owl and southwestern willow

flycatcher (p. 99).

• Surveys were completed for spotted owl and none

were found (Project Record). The project area

contains no occupied habitat, critical habitat, or

“protected activity centers” for any listed species.

The EIS states that the action alternatives would

have no adverse impacts to threatened or endangered species and would likely improve habitat

diversity, prey species habitat, and mature forest

characteristics (pp. 103-105).

• The EIS states that treatments would have no

negative effect on potential flycatcher habitat,

and treatments just outside the riparian buffer

may improve potential flycatcher habitat by increasing the abundance of riparian vegetation.

Migratory Bird Treaty Act (MBTA)

I find that the project is consistent with this Act, as well

as recent agency guidelines for conformance with the

MBTA, based on the following factors:

• No “Important Bird Areas” as defined by Partners

In Flight occur on the Santa Fe National Forest.

• The comprehensive wildlife analysis in the EIS

includes consideration of the Priority Species

identified by Partners In Flight that may occur in

the project area. The EIS considered all birds,

amphibians, reptiles and mammals that may

have suitable habitat in any of the five vegetation

types that occur in the project area (p. 87-89).

• The EIS disclosed effects of the project for these

bird species (pp. 89-98). The analysis considered

over 30 migratory bird species that use ponderosa pine stands comprised of 5 to 12-inch

diameter trees with 40-100 percent canopy cover

(Table 27, p. 90), that dominate the project area.

The analysis considered effects to migratory birds

associated with snags, down logs, riparian and

other habitat types (pp. 85-98 and Tables 25-30).

• Analysis in the EIS shows that the project provides an opportunity to restore and enhance

wildlife species richness for migratory birds, compared to current conditions that have low habitat

diversity (pp. 90-91, 95-97).

• The monitoring plan includes surveys of migratory birds and small mammals before and after

treatment to track changes in populations (Appendix B: Monitoring Plan).

Clean Water Act, 40 CFR 130 Regulations

 and State Water Quality Standards

I find that the project is consistent with this Act and its

implementing regulations and is expected to adhere to

State water quality standards, based on the following

factors:

• The project area contains only one perennial

stream—the Santa Fe River. Water quality for the

river within the project area meets water quality

standards for its designated uses, and the designated uses reflect the highest water quality

classification in the state’s classification system

(EIS p. 60).
16 Santa Fe Municipal Watershed Project Record of Decision

• The effects of the action alternatives upon surface

water quality were carefully analyzed in the EIS

(pp. 60, 68, 71, 72, 74), which states “The actions

alternatives are not expected to adversely impact

water quality and would not have an incrementally additive effect on water quality problems

experienced in downtown Santa Fe and below the

City limits” (p. 74). The EIS also states that if a

large fire occurs under the no action alternative,

that water quality standards would not be met and

water quality would be seriously impaired (pp. 60,

73, 74).

• The New Mexico Environment Department Surface Water Quality Bureau was involved in the

planning of this project, and continues their involvement in monitoring the effects of selected

treatments. They will monitor turbidity, suspended solids and peak flows from paired (treated

and untreated) subbasins established for monitoring purposes, as well as water chemistry

parameters and stream geomorphology along the

Santa Fe River (Appendix B: Monitoring Plan).

• Best Management Practices were used to design

the mitigation measures that help avoid or minimize impacts to water quality (EIS p. 29), as listed

in this document.

Floodplains and Wetlands,

Executive Orders 11988 and 11990

I find that the project is consistent with the Executive

Orders intended to protect floodplains and wetlands,

based primarily on the following factors:

• Thinning and slash disposal activities will not

occur within or impact any wetlands, riparian

areas, or the riparian buffer zone (EIS pp. 84-86)

• The EIS analyzes the vegetation and peak flows in

the Santa Fe River floodplain (p. 58-59, 70, 72, 79-

83, Figure 45-47). Most of the project area lies

below McClure Reservoir where water flows are

regulated. Treatments are not expected to cause

peak flows that would alter the existing floodplain

(EIS p. 70, 72). However, I should note that the no

action alternative with wildfire would be expected

to have a 30 percent chance of creating a major

flood that would impact residential, historic and

commercial districts in the100-year floodplain in

Santa Fe (EIS pp. 64-67).

Clean Air Act, 40 CFR 50

Regulations and Air Quality Standards

I find that this project is consistent with Clean Air Act

and Air Quality Standards, based on the following

factors:

• The project area lies within an air shed that meets

air quality standards.

• The planning team consulted with New Mexico

Environment Department Air Quality Bureau in

the planning process to ensure consistency with

state standards.

• The analysis in the EIS includes models for daily

burning emission estimates including carbon monoxide and particulate matter from prescribed

burns. It identifies the sensitive receptors for

smoke (p. 108), and considers potential short and

long-term effects on: Class I wilderness, regional

haze, visibility, human health, and other factors

(pp. 108-112).

• The analysis in the EIS compares the effects of the

action alternatives to the National Ambient Air

Quality Standards (NAAQS) set by the Environmental Protection Agency to ensure compliance

with the Clean Air Act (p. 106-112), and concludes

that “Based on experience conducting an average

of 12,000 acres of prescribed burning per year on

the Santa Fe National Forest, surrounding communities are not likely to experience prolonged

periods of heavy smoke, and we are not likely to

exceed air quality standards or cause air quality

alerts” (p. 112).

Environmental Justice, Executive Order

12898

I find that the selected alternatives would not disproportionately impact minority or low-income populations,

based on the assessment regarding the effects of the

alternatives on environmental justice contained in the

EIS (p.117, 121), along with the social impact analysis

on pages 113-121.
Santa Fe Municipal Watershed Project Record of Decision 17

Administrative Appeal Provisions

This decision is subject to appeal pursuant to 36 CFR

215.7. As stated in 36 CFR 215.11, an appeal may be

filed by any person or non-Federal organization. A

written appeal must be submitted within 45 days after

the date that the notice of this decision is published in

the Albuquerque Journal. Appeals must meet the

content requirements of 36 CFR 215.14. Appeals must

be submitted to:

USDA Forest Service

Southwestern Regional Office

ATTN: Appeal Deciding Officer

333 Broadway Blvd., SE

Albuquerque, NM 87102

Implementation

If no appeal is received, implementation of this decision

may occur after 5 business days from the close of the

appeal filing period. If an appeal is received, implementation may not occur for 15 days following the date of

appeal disposition.

Contact

For more information about the project, please contact

John Miera, Espanola District Ranger (505-753-7331)

or William Armstrong (505 438-7845).

Leonard Atencio Date

Forest Supervisor
18 Santa Fe Municipal Watershed Project Record of Decision