United States 

Department of 

Agriculture 

Forest 

Service 

Southwestern 

Region 

MB-R3-16-7 

Final Supplement to the 

Final Environmental 

Impact Statement for 

Amendment of Forest 

Plans 

Arizona and New Mexico 
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Printed on recycled paper – May 2006
Final Supplement to the Final Environmental 

Impact Statement for Amendment of Forest 

Plans 

USDA Forest Service, Southwestern Region 

Arizona and New Mexico 

Lead Agency: USDA Forest Service 

Responsible Official: Harv Forsgren 

Regional Forester 

USDA Forest Service 

333 Broadway Blvd., SE 

Albuquerque, NM 87102 

For Information Contact: Rita Skinner 

Assistant Regional Environmental Coordinator 

USDA Forest Service 

333 Broadway Blvd., SE 

Albuquerque, NM 87102 

(505) 842-3125 

Abstract: The Forest Service, Southwestern Region, has prepared this “Final Supplement to the 

Final Environmental Impact Statement for Amendment of Forest Plans in Arizona and New 

Mexico” (FSFEIS) to disclose, review, and assess scientific arguments challenging the Agency’s 

conclusions over the northern goshawk’s habitat preferences. The supplement will update the 

final environmental impact statement (FEIS) which amended the 11 forest plans in the region for 

northern goshawk, Mexican spotted owl, and old-growth standards and guidelines in June 1996. 

This supplement to the FEIS has been prepared in accordance with an opinion filed November 18, 

2003, by the Ninth Circuit Court of Appeals (CV-00-01711-RCB) which held that the FEIS failed 

to disclose responsible scientific opposition that was addressed in the project record. The original 

Notice of Intent for this plan amendment was published in the Federal Register on June 24, 1992 

(57 FR 28171). 

This supplement addresses the issue of scientific arguments over the northern goshawk’s habitat 

preference and updates the “FEIS for Amendment of National Forest Management Plans in the 

Southwestern Region.” The FEIS includes guidelines for management of habitat for the Mexican 

spotted owl and northern goshawk. The FEIS was noticed for availability in the Federal Register 

on November 3, 1995 (60 FR 55841). The Record of Decision was signed June 5, 1996. Copies 

of the Final EIS and Record of Decision are available on the World Wide Web at 

http://www.fs.fed.us/r3/projects/index.shtml. 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans i
Summary 

The Forest Service, Southwestern Region, has prepared this “Supplement to the Final 

Environmental Impact Statement for Amendment of Forest Plans in Arizona and New Mexico” to 

disclose, review, and assess scientific arguments challenging the Agency’s conclusions over the 

northern goshawk’s habitat preferences. This supplement updates the final environmental impact 

statement (FEIS) which amended the 11 forest plans in the region for northern goshawk, Mexican 

spotted owl, and old-growth standards and guidelines in June 1996. The FEIS includes guidelines 

for management of habitat for the Mexican spotted owl and northern goshawk. The original 

Notice of Intent to prepare an environmental impact statement (NOI) for the plan amendment was 

published in the Federal Register on June 24, 1992 (57 FR 28171). The FEIS was noticed for 

availability in the Federal Register on November 3, 1995 (60 FR 55841). The Record of Decision 

was signed June 5, 1996. 

This supplement to the FEIS was prepared in accordance with an opinion filed November 18, 

2003, by the Ninth Circuit Court of Appeals (CV-00-01711-RCB) which held that the FEIS failed 

to disclose responsible scientific opposition that was addressed in the project record. This 

supplement to the FEIS addresses the issue of scientific arguments over the northern goshawk’s 

habitat preference and updates the “FEIS for Amendment of National Forest Management Plans” 

in the Southwestern Region. 

Background 

Based on concerns over the viability of the northern goshawk in the Southwestern United States, 

the USDA Forest Service (Forest Service) Regional Forester for the Southwestern Region 

(Arizona and New Mexico) created the Northern Goshawk Scientific Committee to review habitat 

management needs for the species. 

In August 1992, the Northern Goshawk Scientific Committee published General Technical Report 

RM-217, “Management Recommendations for the Northern Goshawk in the Southwestern United 

States.” This report concluded that the northern goshawk occupied a mosaic of forest types, forest 

ages, structural conditions, and successional stages in their daily foraging movements throughout 

the Southwest’s deciduous and mixed conifer forests. The report then set forth recommendations 

describing the desired balance of forest age classes or vegetation structural stages (VSS) for the 

nest area, post-fledging area, and foraging area of the goshawk’s range in the Southwestern 

United States. 

Previous to release of the technical report, on June 24, 1992, the Forest Service published a 

Notice of Intent to prepare an environmental impact statement amending forest land and resource 

management plans (forest plans) in the Southwestern Region to incorporate guidelines for habitat 

management of the northern goshawk. 

Following a request for public comment, the Forest Service received comments and letters from 

the Arizona Game and Fish Department, New Mexico Department of Game and Fish, and U.S. 

Fish and Wildlife Service, among others. The Arizona Game and Fish Department submitted a 

letter and accompanying report titled, “Arizona Game and Fish Department Review of U.S. 

Forest Service Strategy for Managing Northern Goshawk Habitat in the Southwestern United 

States.” This report presented a differing conclusion over the habitat preferences of the northern 

goshawk than that presented in General Technical Report RM-217. 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans iii
Summary 

iv Final Supplement to the Final Environmental Impact Statement for Amend of Forest Plans 

Much correspondence over the Forest Service’s General Technical Report RM-217 and the 

Arizona Game and Fish Department’s letter and accompanying report ensued between the Forest 

Service and Federal and state game management agencies. In addition, on June 15, 1994, the 

Forest Service completed the “Goshawk Opinion Paper: A Response to Arizona Game and Fish 

Department Review of U.S. Forest Service Strategy for Managing Northern Goshawk Habitat in 

the Southwestern United States.” 

Partially in response to public and Agency comment, the Forest Service created an interagency 

team, the Goshawk Interagency Implementation Team, to discuss implementation of General 

Technical Report RM-217 recommendations, as well as identify concerns raised by, and propose 

revisions to, those recommendations. 

In August 1994, the Forest Service issued the “Draft Environmental Impact Statement for 

Amendment of Forest Plans” (DEIS) which displayed and analyzed environmental impacts of 

alternative approaches to amending the region’s forest plans. Within its range of alternatives, the 

DEIS proposed an alternative consistent with the recommendations found in General Technical 

Report RM-217 (Alternative C). It also proposed an alternative (Alternative D) with a range of 

vegetative structural stages with higher percentages of old-growth percentages than found in 

Alternative C. Alternative D was patterned after DEIS comments submitted jointly by the Arizona 

and New Mexico state game agencies. State game agency input depicted in Alternative D is a 

slight variation of the recommendations developed by the Goshawk Interagency Implementation 

Team and of information depicted in the report RM-217. 

Following its issuance, the Forest Service offered, received, and considered public comments on 

the DEIS. Wildlife biologist D. C. Crocker-Bedford, the Arizona Game and Fish Department, the 

New Mexico Department of Game and Fish, and the Center for Biological Diversity, among 

others, submitted comments to the DEIS. These comments, once again, challenged General 

Technical Report RM-217’s conclusions on the habitat preferences of the northern goshawk. 

Several of the comment letters cited additional research and scientific studies that were released 

after publication of General Technical Report RM-217 and supported the position that the 

northern goshawk preferred vegetative structural conditions with higher proportions of dense 

canopy mature forests, particularly in the foraging areas. 

In October 1995, the Forest Service issued a “Final Environmental Impact Statement for 

Amendment of Forest Plans” (FEIS). The FEIS included minor changes to Alternatives C and D. 

Alternative D was revised to include standards and guidelines that reflect verbatim comments 

submitted by the Arizona Game and Fish Department and the New Mexico Department of Game 

and Fish resulting in a slight variation from the recommendations developed by the Goshawk 

Interagency Implementation Team and those detailed in General Technical Report RM-217. 

The FEIS also included an alternative that was developed to respond to the Mexican Spotted Owl 

Recovery Plan (Alternative G). Alternative G included standards and guidelines for the northern 

goshawk that were developed in early May 1995, and considered all known information from the 

Goshawk Interagency Implementation Team recommendations, Arizona Game and Fish 

Department and New Mexico Department of Game and Fish comments, and experience gained 

during implementation of interim direction. 

Following release of the FEIS, the Forest Service provided an opportunity to interested parties to 

submit comments. On June 5, 1996, the Regional Forester issued the “Record of Decision for 
Summary 

Amendment of Forest Plans: Arizona and New Mexico” (ROD) which selected Alternative G, as 

detailed in the FEIS, for implementation. 

An administrative appeal opportunity was afforded to those individuals and organizations who 

had been involved in the process. The Southwest Center for Biological Diversity, partnering with 

the Southwest Forest Alliance and the Forest Conservation Council, filed an administrative appeal 

on July 23, 1996. Their appeal was one of 13 appeals on the ROD. An appeal point in the 

Southwest Center for Biological Diversity appeal contended the Forest Service did not consider 

the best available scientific information. The June 5, 1996, Record of Decision was affirmed on 

all 13 appeals by the appeal deciding officer for the Chief of the Forest Service. 

In 2000, the Center for Biological Diversity filed suit charging the decision did not adequately 

evaluate opposing viewpoints in the FEIS. In adopting the ROD, the suit alleged the Forest 

Service failed to maintain the scientific integrity of its NEPA process because the FEIS failed to 

discuss or analyze reliable and relevant scientific studies describing the northern goshawk’s 

habitat and foraging needs. Specifically, plaintiffs claimed the FEIS omitted from its review any 

discussion of at least nine scientific studies and/or reports whose conclusions contradicted the 

findings and recommendations mentioned in the FEIS. 

The District Court granted summary judgment in favor of the Forest Service in a 2001 opinion. 

On November 18, 2003, the Ninth Circuit Court reversed and remanded the District Court’s 

opinion stating: 

While the Agency is not required to publish each individual comment in the final statement, 

the regulations clearly state that the Agency must disclose responsible opposing scientific 

opinion and indicate its response in the text of the final statement itself. The mere presence of 

the information in the record alone does not cure the deficiency here. 

Accordingly, we find that the Final EIS fails to disclose and discuss responsible opposing 

scientific viewpoints in the final statement itself in violation of NEPA and the implementing 

regulations. 

On October 1, 2004, the Environmental Protection Agency issued a Notice of Availability in the 

Federal Register (FR 59, 58911) of the Forest Service’s “Draft Supplement to the Final 

Environmental Impact Statement for Amendment of Forest Plans in Arizona and New Mexico.” 

This Notice of Availability initiated a 45-day public comment period on the draft supplement. The 

comment period ended on November 15, 2004. The Forest Service received a total of 11 

comment letters, including additional literature on the northern goshawk. 

This “Final Supplement to the Final Environmental Impact Statement for Amendment of Forest 

Plans in Arizona and New Mexico” is intended to remedy the deficiency found by the Ninth 

Circuit Court of Appeals. That is, disclose, review, and assess alternative points of view and 

scientific perspectives to those used by the Agency in formulating Alternative G, the preferred 

alternative. 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans v 
Summary 

Supplemental Pages 

This “Final Supplement to the Final Environmental Impact Statement for Amendment of Forest 

Plans in Arizona and New Mexico” contains replacement pages for pages 6 through 9 of Chapter 

2 and pages 19 through 23 of Chapter 3. 

vi Final Supplement to the Final Environmental Impact Statement for Amend of Forest Plans 
Contents

The following pages replace pages 6 - 9 in the “Final Environmental 

Impact Statement for Amendment of Forest Plans”......................................................1

The following pages replace pages 19 – 23 in the “Final Environmental 

Impact Statement for Amendment of Forest Plans”....................................................11

Supplemental Consultation and Coordination..............................................................49

Preparers and Contributors ..........................................................................................49 

List of Agencies, Organizations and Persons to Whom 

Copies of the Supplement to the FEIS Were Sent .......................................................49 

Literature Cited ...............................................................................................................55

Comments to the Draft Supplement to the Final Environmental Impact Statement 

for Amendment to Forest Plans, and Forest Service ResponsesError! Bookmark not defined. 

Forest Guardians..........................................................Error! Bookmark not defined.

Center for Biological Diversity....................................................................................75 

Carson Forest Watch..................................................................................................107 

Arizona Game and Fish Department..........................................................................112 

U.S. Environmental Protection Agency.....................................................................119 

B. Sachau ...................................................................................................................123 

Helen Snyder..............................................................................................................128 

Kaibab Band of Paiute Indians ..................................................................................131 

Harold C. Reynolds....................................................................................................133 

New Mexico Department of Game and Fish .............................................................138 

USDI Office of Environmental Policy and Compliance............................................142 

Appendices............................................................................Error! Bookmark not defined. 

Appendices A through AAJ are provided on the CD in PDF, 

however, they are summarized here for reference.

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans vii
The following pages 

replace pages 6 - 9 in the 

 “Final Environmental Impact Statement 

for Amendment of Forest Plans”

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 1
CHAPTER 2 - ALTERNATIVES

A. ALTERNATIVE DEVELOPMENT 

A preliminary review of Southwestern Region forest 

plans was conducted in 1993. The review identified 

the plan changes that would result from 

incorporating current Mexican spotted owl and 

northern goshawk management direction into 

existing forest plans. The Regional Forester also 

identified needed changes in the silvicultural 

emphasis, old-growth allocation and steep slope 

(40 percent+) logging practices. The review also 

identified other standards and guidelines in the 

forest plans that may conflict with the management 

direction proposed to be added to the forest plans. 

A proposed action was developed based on the 

forest plan review, current management knowledge 

for the Mexican spotted owl and northern goshawk, 

and the changes identified by the Regional 

Forester. A summary of the proposed forest plan 

changes was developed as a scoping report that 

was sent to the public for review in late 1993 (see 

Chapter 5 of this environmental impact statement 

for more information). 

The National Environmental Policy Act requires a 

“no action” alternative be developed for this 

environmental impact statement (see Alternative A). 

Alternative B was described in the scoping report as 

the initial proposed action. Three additional 

alternatives were developed in early 1994 based on 

comments received on the scoping report. 

Alternative C was developed by modifying 

Alternative B with the wording and content changes 

suggested by scoping report commenters. 

Alternative C was identified in the draft 

environmental impact statement (DEIS) as the 

proposed action of the Forest Service. Alternative D 

was developed from suggestions submitted by the 

Goshawk Interagency Implementation Team. 

Alternative E was developed from suggestions 

submitted by Applied Ecosystems, Inc. Alternative F 

was based on suggestions by the ApacheSitgreaves National Forests for an ecosystem 

approach to vegetation management. 

A DEIS was released for comment as documented 

in a Notice of Availability in the Federal Register on 

August 19, 1994. The notice identified a formal 

comment period ending on December 01, 1994 (a 

total of 104 days). Comments on the DEIS that 

were submitted late were considered if they were 

received prior to May 1, 1995 (a total of 151 extra 

comment period days). 

DEIS commenters suggested changes in several of 

the alternatives. All of the action alternatives 

depicted in the final EIS are within the range of 

environmental effects disclosed in the DEIS. The 

changes made in the FEIS are consistent with the 

intent of existing regulations (40 CFR 1503.4). A 

summary of the changes for each alternative 

follows. 

Alternative A was modified to reflect resource 

management direction in forest plans that existed 

prior to Forest Service adoption of special interim 

management guidelines for the Mexican spotted 

owl and northern goshawk. The public asked for 

this change to make the “no action” alternative a 

better baseline for comparison of the true resource 

and socio-economic impacts from adopting final 

Mexican spotted owl and northern goshawk 

guidelines. 

Alternative C was separated from Alternative F 

because comments received stated the 

presentation in the DEIS of the paired alternatives 

was confusing. This combined alternative was 

identified as the Agency’s preferred alternative in 

the DEIS. 

Alternative D was adjusted to reflect comments 

received from the Arizona and New Mexico state 

game agencies. The northern goshawk standards 

and guidelines depicted in Appendix E for 

Alternative D are a verbatim rendition lifted directly 

from their jointly submitted DEIS comment letter 

and replace input previously supplied from the 

Goshawk Interagency Implementation Team. The 

Mexican spotted owl standards and guidelines were 

adjusted to reflect information in the Mexican 

Spotted Owl Recovery Plan. 

Alternative E was not changed from draft to final 

EIS. 

Alternative G was added after the draft based on 

many comments received that the Agency needed 

to respond to the Mexican Spotted Owl Recovery 

Plan (MSORP). The MSORP was released for 

public review in March 1995. A team of Federal 

scientists, including a Recovery Plan Team 

member, developed Alternative G standards and 

guidelines for both birds in early May 1995 (see 

Chapter 4 for team information). This team 

translated the MSORP into forest plan standards 

and guidelines and also developed northern 

goshawk standards and guidelines considering 

2 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans
Chapter 2 – Alternatives 

existing Forest Service direction, Goshawk 

Interagency Implementation Team 

recommendations and the DEIS comment letter 

submitted by the state game agencies. 

Among avian biologists and within the research 

community there are commonly agreed upon 

components of goshawk biology, habitat needs, and 

management direction for management of the 

northern goshawk. These are the foundation from 

which goshawk guidelines in the action alternatives 

are developed. For this reason, action alternatives 

will have similar approaches to northern goshawk 

management direction. 

The primary difference between the action 

alternatives is variation in the standards and 

guidelines related to the foraging areas that will 

ultimately be included in the amendment of 

Southwestern Region forest plans. This variation 

represents differing scientific opinion on the 

characteristics of foraging areas used by goshawks. 

Appendix E of this FEIS contains the standards and 

guidelines applicable to each alternative. 

B. ALTERNATIVES DROPPED 

FROM DETAILED STUDY 

The original proposed action (Alternative B) 

depicted in the scoping report has been dropped 

from detailed study. The many commenters to the 

scoping report, both internal and external to the 

Agency, suggested wording changes that helped 

clarify the intent of the amendment. The changes 

are minor and have been incorporated in Alternative 

C. The expected environmental effects of 

Alternative B would not be any different that those 

expected for Alternative C. Alternative C has been 

carried forward as an alternative discussed in detail. 

C. ALTERNATIVES CONSIDERED IN DETAIL 

1. Objectives Common to Alternatives: The 

objectives stated in Chapter 1 of this environmental 

impact statement for the proposed action are 

exactly the same for all action alternatives. 

2. Alternative Mitigation: This environmental 

impact statement is a programmatic document. 

Site-specific mitigation measures have not been 

described for any of the alternatives. The wording of 

key standards and guidelines peculiar to each 

alternative are displayed in Appendix E. The broad, 

programmatic environmental effects of the 

alternatives are predicted based on the standards 

and guidelines in each alternative. Site specific 

environmental effects will be analyzed and 

disclosed during the Southwestern Region's 

Integrated Resource Management process for 

individual projects implemented under the umbrella 

of the amended forest plans. 

3. Alternative Descriptions: Six alternatives are 

displayed in detail in this FEIS. Each of the 

alternatives represent different ways to incorporate 

programmatic management guidance into project 

implementation, a different emphasis on 

management tools used and/or a different set of 

specific management direction (e.g., different 

wording for standards and guidelines). For specific 

details on how the standards and guidelines would 

vary by alternative, review Appendix E of this FEIS. 

A comparison of the basis for development of each 

alternative is summarized in Table 1 at the end of 

this section of the “Final Supplement to the Final 

Environmental Impact Statement.” 

Alternative A: Alternative A is the “no action 

alternative” required by National Environmental 

Policy Act regulations (40 CFR Part 1502.14(d)). In 

the context of this programmatic environmental 

impact statement, Alternative A would continue 

existing forest plan direction for Mexican spotted 

owl and northern goshawk management. Formal 

consultation related to the Mexican spotted owl 

would be sought on any and all forest management 

activities deemed to “may affect” the owl. New 

direction for the two birds would not be added to 

forest plans until they are revised beginning in 2005 

and ending in approximately 2010. Old-growth 

allocation percents would still vary from forest to 

forest. Even-aged management would be the 

emphasized silvicultural tool. The ApacheSitgreaves, Carson, Coconino, and Kaibab National 

Forest plans would maintain the existing Mexican 

spotted owl standard for a 300-acre core area 

around each occupied nest, even though on-theground management would be guided by biological 

opinions issued by the Fish and Wildlife Service. 

The Apache-Sitgreaves, Carson, Cibola, Coconino, 

and Prescott National Forest plans would maintain 

the existing northern goshawk standard for a 20- to 

30-acre core area around occupied nests. The 

Kaibab would provide eight chain buffers around 

occupied nests. No other northern goshawk 

protection would be provided. Steep slope (slopes 

40 percent+) harvest solely for timber production 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 3 
Chapter 2 – Alternatives 

purposes would still be a possible activity on the 

Apache-Sitgreaves, Gila, Lincoln, and Santa Fe 

National Forests, but not on any of the other 

forests. 

Alternative C: Alternative C would incorporate 

Mexican spotted owl and northern goshawk 

management direction into forest plans through the 

forest plan amendment process described in 

National Forest Management Act regulations (36 

CFR 219). Old-growth standards and guidelines 

would be the same for every national forest in the 

Southwestern Region. The specific areas for old 

growth allocation (20 percent) within each 

management area and old-growth block size would 

be determined during the site-specific Integrated 

Resource Management analysis conducted for 

specific projects. In areas where existing old growth 

was surplus to identified ecosystem needs, the best 

stands would be allocated to old growth. All existing 

old growth would be retained in areas where the 

old-growth age classes were deficit. Additional 

lands will be allocated and managed for future old 

growth where needed to meet the 20 percent 

guideline. Uneven-aged silvicultural practices will 

be emphasized over other methods. The option of 

using even-aged silvicultural methods would be 

determined in the Integrated Resource 

Management process during the site specific 

analysis for projects implementing forest plans. 

Mexican spotted owl guidance would follow the 

direction stated in Interim Directive 2 plus dispersal 

habitat considerations. Northern goshawk guidance 

would be very similar to that which is presented in 

the report “Management Recommendations for the 

Northern Goshawk in the Southwestern United 

States” (RM-217). 

Alternative D: This alternative is patterned after 

DEIS comments submitted jointly by the Arizona 

and New Mexico state game agencies. The 

standards and guidelines for northern goshawk 

management are a verbatim rendition from their 

comment letter. The state game agency input 

depicted in this alternative is a slight variation from 

the recommendations developed by the Goshawk 

Interagency Implementation Team and from 

information depicted in the report “Management 

Recommendations for the Northern Goshawk in the 

Southwestern United States” (RM-217). 

The management approach detailed in Alternative 

D is the Arizona and New Mexico state game 

agencies’ alternative which integrates selected 

scientific papers and their conclusions on northern 

goshawk habitat preferences together with the 

commonly agreed upon components of goshawk 

biology and habitat needs (See Table 2). This 

management approach is based heavily on the view 

that northern goshawk require foraging areas 

containing large, unbroken blocks of old forest. 

Alternative E: This alternative is patterned after 

scoping report comments received from Applied 

Ecosystems, Inc. Mexican spotted owl standards 

and guidelines generally follow Interim Directive 2 

like Alternative C, but define smaller core and 

territory acreages (core areas 300 to 400 acres; 

territories 750 to 950 acres). The northern goshawk 

standards and guidelines are similar to those in 

Alternative C, except there is less VSS class 4-6 

acreage and reduced canopy cover percents in the 

nonnest portion of the territory. Old growth would be 

allocated as 10 percent of the area with no specific 

block size minimum defined. Steep slope logging 

would be allowed for reasons other than timber 

production. Alternative E also includes the addition 

of standards and guidelines to guide ecosystem 

planning, to address forest health concerns and to 

guide implementation of other standards and 

guidelines. 

Alternative F: This alternative was developed by the 

staff on the Apache-Sitgreaves National Forests as 

an example of an ecosystem approach to 

management for the Mexican spotted owl. 

This alternative is like Alternative C except that a 

demonstration area would be established on the 

Apache National Forest to test an adaptive 

ecosystem approach to management of the mixedconifer type (i.e., primary Mexican spotted owl 

habitat). The total acres of mixed-conifer type on 

the Apache National Forest is 168,244. This 

demonstration area stratifies the mixed-conifer type 

into six ecological zones. 

Management emphasis for each zone would be in 

accordance with prescribed standards and 

guidelines to manage for specific vegetation desired 

condition in the mixed-conifer rather than the 

Mexican spotted owl guidelines depicted in 

Alternative C. The ecological zones are based on 

primary aspect and degree of slope. Zone 1 is 

North Aspect greater than 40 percent slope, Zone 2 

is North Aspect 20-39 percent slope, Zone 3 is 

North Aspect 0-19 percent slope, Zone 4 is South 

Aspect greater than 40 percent slope, Zone 5 is 

4 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 2 – Alternatives 

South Aspect 20-39 percent slope, and Zone 6 is 

South Aspect 0-19 percent slope. Overlapping 

these zones are areas that currently have 

administrative decisions that prohibit, or otherwise 

are set aside to not receive commercial timber 

harvest. These overlapping areas include: 

wilderness, primitive areas, research natural areas, 

all slopes greater than 40 percent, areas allocated 

for old growth through previous NEPA decisions, 

and old growth allocated through this proposal to 

protect Mexican spotted owl habitat. 

This combined area constitutes 71,223 acres of the 

total mixed conifer area (168,244 acres), or 42 

percent of the mixed conifer that would receive no 

commercial harvest under this proposal. Where 

commercial harvest is allowed, the following 

management emphasis will be applied: Zone 2 

(north-facing slopes) – would be managed for 

timber harvest only on slopes less than 40 percent 

and would emphasize uneven-aged condition 

utilizing single tree selection, Zone 3 (north-facing 

slopes) – would be managed for timber harvest but 

again would emphasize uneven-aged conditions 

using single tree selection, group selection, or small 

group shelterwood methods. In Zones 5 and 6 

(south-facing slopes), the area would be managed 

for a balance of an uneven-aged and even-aged 

condition. 

For all other areas of the region (including 

nonmixed-conifer zones on the Apache-Sitgreaves 

National Forests), all standards and guidelines as 

depicted in Alternative C would be implemented in 

this alternative. This alternative would still rely on 

the Integrated Resource Management process to 

make the site specific project design decisions. A 

brief comparison of the different zones in the 

Apache-Sitgreaves National Forests mixed-conifer 

is presented in Table 3 at the end of this chapter. 

Alternative G: This alternative was developed to 

respond to the Mexican Spotted Owl Recovery Plan 

(see Chapter 4 for Standard & Guideline Team 

information). Standards and guidelines for the 

northern goshawk were developed in early May 

1995, and considered all known information from 

the Goshawk Interagency Implementation Team 

recommendations, the Arizona state game agency 

letter that responded to the draft forest plan 

amendment, and experience gained during 

implementation of interim direction. Appendix E 

contains the specific language for standards and 

guidelines that are associated with this alternative. 

Under Alternative G, the standards and guidelines 

for managing across the landscape represent an 

ecosystem management approach. The approach 

used for managing goshawk habitat areas provides 

for many wildlife species, timber and forage. As a 

result, the standards and guidelines for ecosystem 

management in goshawk habitat areas are not 

focused on any single species or element. 

Alternative D & G: Alternative D is exactly like 

Alternative G with respect to Mexican spotted owl 

management guidance and silvicultural emphasis. 

Steep slope logging would be allowed for reasons 

other than timber production. Appendix E depicts 

the specific standards and guidelines for managing 

the forested areas. 

With respect to the northern goshawk, Alternative D 

differs from Alternative G in that Alternative D calls 

for higher stand densities outside of post-fledging 

family areas than called for in Alternative G. These 

areas include woodland, ponderosa pine, mixed 

conifer and spruce-fir forest cover types in the 

southwestern United States. In addition, all other 

forest types may be considered to be important 

habitat. Higher densities called for in Alternative D 

are designed to result in and promote a more 

closed canopy or denser forest with older trees in 

these areas. Alternative D also calls for the blocks 

with higher canopy closure to vary in size while 

Alternative G manages for the same canopy 

closures only within small groups. 

The intent of Alternative D is to sustain 

approximately 40 percent of the landscape in old 

forest (large old trees) through time. This will be 

achieved by maintaining the existing mature (VSS 

5) to old forest (VSS 6) structure across the 

landscape until an average of 20 percent of the 

landscape contains VSS 5 and 20 percent contains 

VSS 6 (AGFD, 1993). Similarly, Alternative G 

strives to maintain the same 20/20 percentage of 

VSS 5 and VSS 6 across the landscape. The 

difference between Alternatives D and G relative to 

mature and old forest is that Alternative D has an 

objective to sustain as much mature and old forest 

across the landscape as possible in larger blocks. 

Table 4 at the end of this section of the Supplement 

to the FEIS summarizes the habitat attribute 

differences for the northern goshawk between 

Alternative D and Alternative G. Both alternatives 

originate out of commonly agreed upon habitat 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 5 
Chapter 2 – Alternatives 

components for the northern goshawk. Table 4 

displays differing scientific viewpoints on northern 

goshawk management beyond the commonly 

ageed upon components in Table 1. Alternative D 

represents scientific viewpoints that call for larger 

blocks of old and mature forest than called for in 

Alternative G. 

D. FOREST SERVICE PREFERRED 

ALTERNATIVE 

The Forest Service preferred alternative is 

Alternative G. Alternative G was developed to 

respond directly to and implement the guidelines in 

the Mexican Spotted Owl Recovery Plan. It was 

developed in collaboration with the Fish and Wildlife 

Service (including a recovery team member). 

As new information becomes available during 

implementation of the Mexican Spotted Owl 

Recovery Plan, the standards and guidelines 

(Alternative G) incorporated by amendment in forest 

plans will be adjusted accordingly. 

As each national forest undertakes its respective 

forest plan revision, this amendment language will 

be reanalyzed in the context of any anticipated 

changes in current forest plan management 

direction. 

Chapter 3 contains a complete discussion of the 

expected programmatic cumulative effects from 

amending forest plans to include new standards 

and guidelines for the Mexican spotted owl and 

northern goshawk. Other forest plan standards and 

guidelines were also adjusted when they appeared 

to conflict with planned management direction for 

the two birds. 

Table 1. Comparison of Basis for Development of Alternatives 

Alt. Alternative Development Criteria 

A 

No Action Alternative – Required under the National Environmental Policy Act: Reflects resource management 

direction in forest plans that existed prior to Forest Service adoption of special interim management guidelines 

for the Mexican spotted owl and northern goshawk. 

B Initial Scoping Proposed Action – Dropped from Detailed Study 

C 

DEIS Proposed Action (Modification of Alternative B – Initial Scoping Proposed Action): Mexican spotted owl 

guidance would follow direction stated in Interim Directive 2 (June 1990, FSM 2676) plus dispersal habitat 

considerations. Northern goshawk guidance would be very similar to the “Management Recommendations for 

the Northern Goshawk in the Southwestern United States” (MRNG) (RM-217). 

D 

Adjusted Goshawk Interagency Implementation Team Recommendations – Reflects comments received from 

Arizona and New Mexico state game agencies. Northern goshawk standards and guidelines are verbatim from 

jointly submitted DEIS comment letter and replace input previously supplied from the Goshawk Interagency 

Implementation Team. The Mexican spotted owl standards and guidelines were adjusted to reflect information in 

the Mexican Spotted Owl Recovery Plan. 

E 

Applied Ecosystems, Inc. Suggestions – Mexican spotted owl standards and guidelines generally follow Interim 

Directive 2 (June 1990, FSM 2676). Northern goshawk standards and guidelines are similar to those in 

Alternative C. 

F 

Apache-Sitgreaves National Forests Suggestions – Mexican spotted owl guidance would follow direction stated 

in Interim Directive 2 (June 1990, FSM 2676) plus have a demonstration area on the Apache-Sitgreaves 

National Forests. Northern goshawk guidance would be very similar to the MRNG (RM-217). 

G 

Mexican Spotted Owl Recovery Plan Integration Alternative – Developed to respond to the Mexican Spotted Owl 

Recovery Plan. Standards and guidelines for the northern goshawk were developed in early May 1995, and 

considered all known information from the Goshawk Interagency Implementation Team recommendations, the 

joint Arizona and New Mexico game agencies letter that responded to the DEIS, and experience gained during 

implementation of the interim direction. 

6 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 2 – Alternatives 

Table 2. Commonly Agreed Upon Northern Goshawk Habitat Componets 

Component Description / Discussion 

Percent of Landscape in VSS 6 The overall landscape contains approximately 20 percent in VSS 6 (24+ d.b.h.). 

VSS 1 

Component 

Many of the food components (primary prey species) necessary for the reproductive 

biology of the northern goshawk require meadows and open areas (VSS 1). 

Nest Areas 

Habitat components (age class, canopy closure, density) of nest areas are commonly 

agreed upon and are essential for northern goshawk reproduction. Goshawks use the 

densest stands available for nest areas. Specific values of tree sizes, density and 

canopy closure vary depending on the characteristics of the ecosystem. 

Older Age 

Classes 

The importance and need of forests in older age classes (VSS 5 & 6) is widely 

recognized. However, the quantity and arrangement across the landscape of such age 

classes is not generally agreed upon, particulary in unpublished work. 

Growth Rates 

The knowledge that tree growth in the Southwest is a limiting factor in forest structural 

stage development is widely recognized. The rate of establishment and growth of 

forest structure and composition limits habitat both spatially and temporally. 

Snags & Down 

Woody Material 

The importance of snags and down woody material across the landscape is an 

important habitat element for maintenance of a prey base. 

Table 3. Comparison of Zones as Described in Alternative F 

Zone 

Delineation 

Slope (Percent) 

and Aspect Total Acres Available Treatment Acres Management Emphasis 

Zone 1 40 %+ Slopes 

North Aspects 23,915 None Natural Evolution 

Zone 2 20-39 % Slopes 

North Aspects 39,510 22,853 Uneven-aged – single tree 

selection only 

Zone 3 0-19 % Slopes 

North Aspects 35,000 29,918 Uneven-aged – all 

methods 

Zone 4 40 %+ Slopes 

South Aspects 11,470 None Natural Evolution 

Zone 5 20-39 % Slopes 

South Aspects 24,736 14,866 Balanced Uneven-aged 

and Even-aged 

Zone 6 0-19 % Slopes 

South Aspects 33,613 29,384 Balanced Uneven-aged 

and Even-aged 

TOTALS 168,244 97,021 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 7 
Chapter 2 – Alternatives 

Table 4. Habitat Attribute Differences between Alternative D and Alternative G for the Northern 

Goshawk 

Attribute Alternative Comparison 

Vegetation 

Types 

Alternative D only addresses ponderosa pine habitat. Alternative G addresses 

woodland, ponderosa pine, mixed conifer, and spruce-fir habitats. 

Target Tree Age 

in VSS 6 

Both alternatives call for 20 percent in VSS 6 (24”+ d.b.h.). Both alternatives call for the 

same target age of 250+ years for areas designated as post-fledgling family area (PFA). 

For the remainder of the landscape outside the post-fledging areas, Alternative D calls 

for a target age of 250+ years while Alternative G calls for 200+. The difference is that 

for a regulated forest on a 20-year entry, Alternative D will have fewer regeneration 

treatments or fewer openings than Alternative G per entry. 

Group Size Both alternatives call for management at the group, patch, site, and landscape levels.* 

Alternative D calls for canopy closure restrictions for not only the small group/patch 

scale, like G, but also at the site and landscape scale. Alternative D calls for: (1) up to 

20 percent of the landscape to be managed for even-aged management for sites up to 

100 acres in size; (2) large blocks of mature stands with densities managed at the site 

or landscape scale; and (3) retaining denser patches for hiding and thermal cover in 

addition to the percentages outlined for each VSS class. Alternative G mimics the 

natural forest conditions prior to settlement which consisted of small groups of trees and 

the canopy restrictions and stocking levels are based only at this small scale and 

tracked at the larger scales. 

Old Growth and 

Canopy Density 

of VSS 5 and 6 

Both alternatives require 20 percent of the area outside the nest areas and across the 

landscape be maintained in VSS 6 and 20 percent in VSS 5. VSS 5 areas meet most 

but not all of the criteria for old growth. However, the primary difference of Alternative D, 

from that of Alternative G, is management scale, densities and the limitations on 

regulation of the flow of VSS 5 and 6 across space and time. 

Canopy Density 

VSS 3 ( 9-

12”d.b.h.) 

Only Alternative D has canopy closure restrictions on VSS 3, thereby slowing growth 

and development into larger VSS classes. 

Hiding and 

Thermal Cover 

Allocations 

Only Alternative D retains guidelines for hiding and thermal cover allocations for 

goshawk prey and other wildlife. Alternative G calls for no allocations as it was not 

needed with the change from even-aged to uneven-aged management. 

Resulting 

Herb/Shrub 

Understory 

The herbaceous and shrub understory amounts are in direct proportion to canopy 

closure. The higher the closure, the less sunlight available to develop herb/shrub 

understories. Alternative D will have significantly less herb/shrub understory in the larger 

blocks of old and mature forest based on the projected crown closure and longer target 

ages resulting in less regeneration. 

Large Trees Both alternatives have similar target amounts for VSS 5 and 6. However, with the higher 

tree and crown densities in Alternative D, growth of individual trees will be significantly 

slower and the amount of time to restore large trees across the landscape will take 

significantly more time under Alternative D than that in Alternative G. Such increases 

may not be possible with higher stocking levels due to potential loss of forest structure 

from fire, insects, and disease. 

8 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 2 – Alternatives 

Attribute Alternative Comparison 

Spatial 

Distribution of 

Structural 

Components 

and VSS 

Classes 

Alternative D will have structural components and VSS classes significantly less 

spatially distributed across the landscape than Alternative G because of the broad 

scales at which densities are being managed. 

Even-aged vs. 

Uneven-aged 

Forest 

Structures 

Alternative G calls for uneven-aged management and resulting forest structure. 

Alternative D allows up to 20 percent of the landscape to have even-aged management 

with the remaining areas using uneven-aged management. Mixing management of 

uneven-aged at the group scale with even-aged at the site level restricts ability to 

provide all structural components, such as large trees, at the group level and achieve 

target percentages of age classes adequately distributed over space and time such as 

20 percent of VSS 6. 

* Long, J. N. and Smith, F. W. 2000 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 9 
The following pages 

replace pages 19 – 23 in the 

 “Final Environmental Impact Statement 

for Amendment of Forest Plans”

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 11
Chapter 3 – Affected Environment and Environmental Consequences 

TES Species (34) 

Affected Environment 

Within the Southwestern Region, there are 45 

species currently listed and 10 species proposed for 

listing under the Endangered Species Act (ESA). In 

addition, 414 species found within the region on 

national forests are considered to be “sensitive.” 

The region’s sensitive species program is designed 

to meet species needs, to maintain the species and 

their habitats, and to eliminate the need for listing 

under the ESA (Forest Service Manual 2670.21). 

The two species of concern for these plan 

amendments, the Mexican spotted owl and the 

northern goshawk are widespread throughout the 

Southwest and the threat to the species is based on 

habitat degradation on a landscape scale. 

Other sensitive species within this category include 

sharp shinned hawk, pine grosbeak, and the 

flammulated owl. Other species, like Gould’s wild 

turkey, are sensitive to landscape patterns; 

however, the reason the turkey is sensitive is due to 

limited habitat in the United States. The United 

States represents the northernmost extension of its 

range, and as such, it is rare because of this, not 

because of any changes to landscape patterns. 

Many rare species are vulnerable to disturbances 

due to their limited distribution. Most species 

require site specific mitigation that will be proposed 

and analyzed within the analyses of individual 

projects. An accepted ecological approach is to do 

analyses at multiple scales, one above and one 

below that needed to analyze the site specific 

action. This type of analysis can only be done at the 

project level and is beyond the scope of this 

regional programmatic analysis. 

Environmental Effects 

The implementation of new forest plan standards 

and guidelines on the ground will not 

instantaneously coincide with the issuance of the 

Record of Decision based on this FEIS. A transition 

period will be needed to achieve full implementation 

of the amendment. In the short term (5 to 10 years), 

the effect of the new standards and guidelines with 

respect to desired on-the-ground conditions will 

vary little between alternatives. The true 

ramifications of the differences between alternatives 

can be easily ascertained when reviewing expected 

long-term environmental effects. 

In all alternatives, the risk is high that catastrophic 

events will occur within the next decade (see 

analysis concerning forest health). With greater 

restrictions, as areas with high tree densities 

continue to increase in density, the associated 

susceptability to catastrophic events would also 

continue to increase. It is impossible to predict what 

the size or intensity will be for a given event. Even 

though fire and insects are a part of the ecosystem, 

current conditions are not “normal” and represent 

stressed ecosystems. The impact of any event will 

much more likely be catastrophic. Depending on the 

size of the event, there exists the potential of 

fragmenting the landscape which may greatly 

reduce the number of large old trees that currently 

exist. 

The areas most at risk to catastrophic events are 

those areas with the highest tree densities. These 

are the areas restricted or protected for the Mexican 

spotted owl and northern goshawk, and these are 

the areas of greatest importance to the 

conservation of these two species. What is 

sustainable for these two species as well as other 

species tied to old forests appears to not be 

sustainable in the long term (200+ years) due to 

losses to insects and fire. However, the ecosystem 

as a whole (ecosystem defined as the vegetative 

community with all of its associated animal 

component) must be sustainable. 

Alternative A is the “no action” alternative where 

existing forest plan direction is continued. This 

alternative would emphasize even-aged 

management with a rotation length not to exceed 

120 years in all areas outside of those allocated for 

old growth and wilderness. Cable logging is allowed 

on steep slopes. Protection for biological diversity is 

limited to mitigations for specific habitat needs. 

Mitigations are generally limited in scope (e.g., 

protection for the northern goshawk limited to a 

buffer around nest trees). Old growth associated 

species like the Mexican spotted owl and the 

northern goshawk will have limited habitat, primarily 

associated with the areas set aside for old growth 

and wilderness. Special habitat components, like 

snags and large down logs, are limited in scope 

with guidelines that include only a limited 

percentage of the suitable timber base. Surveys for 

the Mexican spotted owl and the northern goshawk 

are limited. For the northern goshawk, there is a 

12 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans
Chapter 3 – Affected Environment and Environmental Consequences 

heavy dependence on timber markers to find 

nesting sites. Existing grazing standards and 

guidelines generally call for the existing livestock 

stocking levels to be in line with capacity in the first 

or second decade. Not all existing forest plans have 

specific utilization rates for grazing animals. 

The existing forest land management plans 

throughout the region were determined not to be 

adequate for Mexican spotted owl and northern 

goshawk. The existing forest plans would also have 

an adverse affect on the listed Mt. Graham red 

squirrel and Sacramento Mountain thistle and may 

cause the following sensitive species to trend 

toward listing: northern goshawk, flammulated owl, 

sharp-shinned hawk, Kaibab squirrel, Jemez 

Mountains salamander, Sacramento Mountain 

salamander, Kaibab pincushion cactus, and Arizona 

leatherflower. 

Many sensitive aquatic species are also trending 

toward listing under current forest plan 

implementation due to grazing management. The 

species identified are limited to those within 

forested habitats. Many other species may be 

impacted by current management under existing 

forest plans; however, with the exception of grazing 

utilization rates, these species are in other habitats 

(e.g., desert, aquatic, etc.) and are outside the 

scope of this analysis. 

The flammulated owl and the sharp-shinned hawk 

depend on old growth and would be adversely 

impacted if old growth was limited only to that 

designated to be set aside. Conservation strategies 

have been or are being prepared for the Jemez 

Mountains salamander, Sacramento Mountain 

salamander, Kaibab pincushion cactus and may 

ultimately lead to amendment of forest plans. The 

Mount Graham red squirrel and Sacramento 

Mountain thistle have existing recovery plans. 

Alternatives C and F articulate the Mexican 

spotted owl and northern goshawk habitat 

requirements into standards and guidelines. This 

alternative does not represent the most current 

knowledge for the Mexican spotted owl that has 

been published in the recovery plan. The proposed 

demonstration area on the Apache-Sitgreaves 

National Forests in Alternative F would depart from 

the recovery plan. 

Because these alternatives do not fully implement 

the current Mexican spotted owl recovery plan, they 

would have an adverse affect on the Mexican 

spotted owl and, thus, may not lead to its recovery. 

Grazing utilization rates would be restricted to 

occupied owl and goshawk territories and would not 

be applied across the landscape. Numerous 

sensitive species tied to aquatic ecosystems may 

be impacted with a possible trend toward listing. 

The listed southwestern willow flycatcher would 

continue to be adversely affected due to current 

grazing management. 

Alternative D is very similar to Alternative G. The 

primary difference is that it is written in a more 

“regulatory” format. This alternative calls for territory 

establishment if a landscape approach is not used. 

It is recommended that a landscape approach be 

used (similar to Alternative G). Alternative G calls 

for additional surveys if needed while this 

alternative specifically calls for 2 years of surveys. 

Alternative D calls for all trees to be grown to at 

least 250 years, while Alternative G uses 200+. 

Alternative G recommends a range for reserve 

trees where Alternative D recommends four trees 

per acre in ponderosa pine. Alternative D 

recommends maintaining all existing standards and 

guidelines for hiding and thermal cover. Alternative 

G does not address hiding and thermal cover, thus 

there would be no change in these standards and 

guidelines. 

Alternative D addresses old growth as it relates to 

“blocks.” Alternative G proposes to restore or 

maintain a minimum of 20 percent of the landscape 

as old growth. It does not specify the use of 

“blocks.” Instead, patterns are to be provided that 

allow for a flow of the old-growth functions and 

interactions at multiple scales across the landscape 

through time. The 20 percent is the amount of the 

landscape and not specific acres. Alternative G is 

similar to Alternative D in that all existing old growth 

is to be maintained. 

The same standards for Mexican spotted owl 

described in Alternative G also apply for Alternative 

D. Therefore, the affects on the Mexican spotted 

owl will be the same: may affect, not likely to 

adversely affect. Grazing utilization rates would 

apply only to occupied territories; therefore, the 

effects of grazing on MSO will be the same as 

Alternatives C and F. 

In addition to may affect, not likely to adversely 

affect the Mexican spotted owl, Alternative D would 

have a beneficial affect on the following sensitive 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 13 
Chapter 3 – Affected Environment and Environmental Consequences 

species: flammulated owl, sharp-shinned hawk, and 

Kaibab squirrel. Without changes in grazing in all 

cover types, Alternative D would not change the 

current adverse impacts on aquatic species outside 

MSO and northern goshawk habitat identified in 

Alternative A. 

Alternative E stresses conditions that favor 

sustainability of vegetation over sustainability of the 

northern goshawk. This alternative has many 

benefits over the existing standards and guidelines 

currently found in existing forests plans. It is highly 

likely that, as we learn more about the ecosystem 

and the needs of specific wildlife species, desired 

vegetative conditions may approach what is 

described in this alternative. However, as stated in 

the section immediately before discussion of the 

individual alternatives, both the vegetative 

communities as well as the associated animal 

species must be sustainable but conditions 

described for either side are usually different due to 

the lack of knowledge concerning the ecosystems. 

Since this alternative does not fully implement the 

current Mexican spotted owl recovery plan, it would 

have an adverse affect on the Mexican spotted owl 

and may not lead to its recovery. Numerous 

sensitive species tied to aquatic ecosystems may 

be impacted with a possible trend toward listing. 

The listed southwestern willow flycatcher would 

continue to be adversely affected due to current 

grazing management. 

Standards and guidelines for the northern goshawk 

are limited only to occupied areas and do not allow 

for population expansion or shifts. Guidelines 

pertaining to nest size, percent of area in VSS 4, 5, 

and 6, and the number of reserve trees have lower 

values than those recommended within the 

goshawk recommendations. It is not clear how long 

trees would be allowed to grow. It is stated that old 

growth be limited to 10 percent of the land area 

under management. Trees outside of these oldgrowth areas will be allowed only enough time to 

grow to the size defined within the different VSS 

classes and the VSS 6 would not have the age that 

would exhibit old-growth characteristics. 

This alternative would have an adverse affect on 

the northern goshawk. It may also have an adverse 

affect on other sensitive species, i.e., sharp-shinned 

hawk and flammulated owl. Listed and sensitive 

species tied to aquatic ecosystems that are 

currently being impacted by the current application 

of grazing will continue their adverse impact or 

continue their trend toward listing. 

Alternative G incorporates the needs of the 

Mexican spotted owl and northern goshawk. The 

science used to determine these needs are 

contained in two publications, “Mexican Spotted 

Owl Recovery Plan” and “Management 

Recommendations for the Northern Goshawk in the 

Southwestern United States” (GTR RM-217, 1992). 

Both publications endorse the concept of managing 

ecosystems; however, only the recommendations 

for the northern goshawk incorporate a long-term 

approach. Recovery recommendations for the 

Mexican spotted owl are for the short term and take 

precedence over all other recommendations for 

nonlisted species due to its listed status under the 

Endangered Species Act. 

This alternative deals primarily with the habitat of 

these two species which consists of the forested 

ecosystems of pinyon-juniper, pine-oak, ponderosa 

pine, and mixed conifer. With the exception of 

grazing management modifications, existing 

standards and guidelines outside these ecosystems 

will remain essentially unchanged. 

Under the Mexican spotted owl recommendations 

all protected activity centers (PACs) and slopes 

greater than 40 percent will be protected with no 

timber harvest being allowed. All areas with 

ponderosa pine/gamble oak and mixed conifer 

vegetative types will be “restricted.” In restricted 

areas, all sites meeting “threshold” conditions will 

be maintained with no timber harvest of trees > 12" 

diameter at breast height (d.b.h.). Harvest of trees 

between 12" and 24" d.b.h. will only be allowed 

within restricted areas outside of those sites 

meeting target conditions and only on up to 20 

percent of the restricted areas. Trees over 24" 

d.b.h. will be maintained throughout the restricted 

and protected areas. Excess trees to be harvested 

will be based on a “Q” of 1.4 or less. A more 

detailed description is contained in “Draft Mexican 

Spotted Owl Recovery Plan,” March 1995. 

Under the northern goshawk recommendations all 

nest sites and post-fledgling areas (PFAs) will be 

restricted with higher stocking levels (canopy 

cover). All areas outside of PFAs will have the 

desired stocking levels correlating to an average of 

40 percent canopy cover with a high contrast both 

above and below. As stated above for both the 

Mexican spotted owl and northern goshawk, the 

14 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

landscape will contain trees that are uneven-aged 

allowing for more large, old trees. A more detailed 

discussion of the recommendations are contained 

in, “Management Recommendations for the 

Northern Goshawk in the Southwestern United 

States” (RM-217). 

Two listed species—Sacramento Mountains thistle 

and Mount Graham red squirrel—could be impacted 

due to the restrictions that would not allow the 

Forest Service to do any vegetative manipulation in 

“protected” areas (i.e., PACs, steep slopes, and 

stands that meet threshold conditions). Without 

being able to reduce fuels, the Mount Graham red 

squirrel will continue to be at greater risk to 

wildfires. Without being able to reduce tree 

densities and lessen the potential risks from 

catastrophic fires, springs and seeps containing 

Sacramento Mountains thistle will be impacted with 

the possible loss of springs and seeps. Within the 

limited habitat for these two listed species 

management activities necessary to implement their 

recovery plans will take precedence and will be 

exempt from the conflicting Mexican spotted owl 

standards and guidelines. Alternative G has the 

flexibility to mitigate any adverse impacts at a 

project or site level. 

In addition to the forest structure, the health of the 

herbaceous and shrub components of the 

ecosystem is also important for the prey species 

associated with the Mexican spotted owl and 

northern goshawk. To maintain this part of the 

ecosystem, grazing utilization rates are proposed. 

These rates differ based on range condition with the 

intent of maintaining good to excellent range 

conditions where they exist and to restore range 

that is in poorer condition. Ecologically it makes 

little sense to limit the utilization rate guidelines to 

only Mexican spotted owl and northern goshawk 

habitat; therefore, the utilization guidelines are 

being proposed across the landscape in all 

vegetation cover types. 

For all listed species, Alternative G may affect, but 

will not adversely effect any species. For all 

sensitive species, Alternative G may impact 

individuals, but no species will trend toward Federal 

listing and there will be no loss of viability. 

Due to the proposed grazing utilization rates there 

will be a beneficial effect on all listed and sensitive 

species tied to riparian and aquatic habitats where 

degradation of habitat due to grazing has been 

identified as the primary reason for listing (e.g., 

southwestern willow flycatcher) or for including a 

species within the regional sensitive species list 

(e.g., numerous native fish species). 

Brief Summary of the Management 

Recommendations for the Northern Goshawk 

Because the “Management Recommendations for 

the Northern Goshawk in the Southwestern United 

States,” (MRNG) (Reynolds et al. 1992) is the focus 

of the scientific debate, a summary of the MRNG is 

presented here for reference. 

At the core of the MRNG are the recommendations 

for management of three components of the 

northern goshawk’s home range: the nest area, the 

post-fledgling family area (PFA), and the foraging 

area. The authors of the MRNG state, “...the largest 

areas (acres) reported in the literature, rather than 

the average or smallest, were used when 

developing the management recommendations for 

the nest area, PFA and foraging area” (Reynolds et 

al. 1992, p 21). 

For the nest area, the MRNG suggests: (1) 

maintaining 3 suitable and 3 replacement nest sites 

totaling 180 acres; (2) all nest areas are best 

located one-half mile from each other; (3) in 

ponderosa pine 30-40 trees per acre, 16-22 inches 

d.b.h., 200+ years old and a canopy closure of at 

least 50 percent. 

For the PFA, the MRNG calls for: an area of 420 

acres not including the 180 acres for nest areas, 

centered around the nest area, with 60 percent in 

the oldest stands to include 2 snags per acre, 3 

large downed logs per acre and mature and old 

forest composed of live trees in clumps or stringers 

with interlocking crowns. In ponderosa pine forests, 

the MRNG calls for a minimum of 50 percent 

canopy cover with clumps of the mature (VSS 5) 

and old (VSS 6) forest age classes, and a minimum 

60 percent canopy cover within one-third of the midaged (VSS 4) clumps and 50 percent canopy cover 

within the remaining two-thirds of the mid-aged 

clumps of trees. 

For the foraging area in ponderosa pine, the MRNG 

suggest management on approximately 5,400 acres 

not including the nest areas and the PFA, 60 

percent of which should be in the 3 oldest age 

classes (mid-aged, mature and old forest), at least 

2 snags per acre, 3 downed logs per acre, a 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 15 
Chapter 3 – Affected Environment and Environmental Consequences 

minimum of 3-5 old large trees per acre in clumps 

with a minimum canopy closure of 40 percent within 

the clumps of mature and old live trees.

Review of Pertinent Information Concerning 

Habitat Management for the Northern Goshawk 

This section of the FSFEIS reviews and discusses 

scientific points of view, which differ from, or are 

contrary to those used to develop the MRNG, on 

which Alternative G is based. It provides an 

assessment of those differing points of view in 

terms of whether or not the findings in those papers 

would result in a change in the Agency’s preferred 

alternative, and ultimately its decision. 

This section also presents information which was 

developed after the 1996 amendment, but relates to 

the disclosure of pertinent information concerning 

northern goshawk habitat management. 

The discussion was facilitated by a review of the 

contrary scientific points-of-view written by 

Reynolds et al. 2001. This section then draws 

conclusions based in part on the review, thereby 

providing a reasoned discussion of the relevant but 

differing scientific points-of-view concerning habitat 

management for the northern goshawk. 

The scientific debate concerns the degree to which 

the northern goshawk requires old or mature forest 

with dense closed canopies. While all goshawk 

scientists agree that some old or mature forest is 

needed within goshawk home ranges, they differ 

over the necessary amount and arrangement of 

such forest. 

A. This review is based in part, on the following 

documents printed before the 1996 amendment: 

1. A 1986 paper by Crocker-Bedford and 

Chaney, titled “Characteristics of Goshawk 

Nesting Stands,” later published in 1988 in 

the Proceedings of the Southwest Raptor 

Management Symposium and Workshop, 

Tucson Arizona. 

2. A second paper by Crocker-Bedford titled 

“Goshawk Reproduction and Forest 

Management,” The Wildlife Society Bulletin

Vol. 18, No. 3, Fall 1990. 

3. A paper by Ward, Ward and Tibbitts, April 

1992, titled “Canopy Density at Goshawk 

Nesting Territories on the North Kaibab 

Ranger District, Kaibab National Forest,” 

Final Report, Arizona Game and Fish 

Department. 

4. A letter from the U.S. Fish and Wildlife 

Service on August 13, 1992, commenting 

on the “Recommendation for Goshawk 

Management in the Southwest Region.” 

5. An Arizona Game and Fish Department 

white paper of May 1993, outlining their 

concerns on the recommendations for 

goshawk management in the southwest 

region. 

6. A letter from New Mexico Department of 

Game and Fish, November 28, 1995, 

commenting on the “Final Environmental 

Impact Statement for Amendment of Forest 

Plans.” 

7. Eleven papers written and/or published 

prior to 1996, which reported on studies of 

northern goshawk habitat use and 

preferences: 

i) Fischer (1986) 

ii) Hargis et al. (1994) 

iii) Bright-Smith and Mannan (1994) 

iv) Austin (1993) 

v) Beier (1994) 

vi) Titus et al. (1994) 

vii) Crocker-Bedford (1994) 

viii) Crocker-Bedford (1995) 

ix) Snyder (1995) 

x) Woodbridge and Detrich (1994) 

xi) Titus et al. (1996) 

8. A document of December 1, 1994, titled 

“Comments on the Draft Environmental 

Impact Statement and Proposal to Amend 

Ten National Forest Land Management 

Plans” by Suckling et al. 

9. A document of March 1996, by The Wildlife 

Society, on Technical Review 96-2 of 

“Northern Goshawk and Forest 

Management in the Southwestern United 

States” by Braun et al. 

Key points from these documents are summarized 

as follows. 

16 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

A.1. Crocker-Bedford and Chaney (1988) reported 

on a 3-year study which evaluated nesting habitat 

of the northern goshawk on the North Kaibab 

Ranger District, Kaibab National Forest, in northern 

Arizona. Their results demonstrated that goshawks 

nest in the densest stands available under the 

conditions of the North Kaibab. They found that 

goshawks totally avoided nesting in stands with less 

than 60 percent canopy cover and most preferred 

having more than 80 percent canopy cover. Their 

study also showed that goshawk nesting stands 

had much higher densities of large trees than were 

otherwise present in the typical stand on the North 

Kaibab. 

A.2. In his 1990 paper, Crocker-Bedford reported 

on a study designed to test the adequacy of nest 

habitat buffers for maintaining goshawk 

reproduction. This study also occurred on the North 

Kaibab Ranger District. Although the data showed 

an average territory included 2.3 known nest trees, 

Crocker-Bedford believed there were 3. He also 

found that nest buffers, either large or small, did not 

maintain goshawk reproduction. Where timber 

harvest had occurred around buffers, reproduction 

rates were 75-80 percent lower and nestling 

production was 94 percent lower. Crocker-Bedford 

also noted that goshawk nesting density appeared 

to be closely associated with dense overstories and 

open understories. 

A.3. In their 1992, “Canopy Density at Goshawk 

Nesting Territories on the North Kaibab Ranger 

District, Kaibab National Forest,” report, Ward, 

Ward and Tibbitts discussed the results of their 

investigation on the relationship between goshawk 

breeding activity and canopy density on the North 

Kaibab Ranger District of the Kaibab National 

Forest. They found that active territories had a 

higher proportion of stands with 40-60 percent 

canopy closure than did inactive territories. They 

also found active territories had a greater 

percentage of stands with 60-80 percent canopy 

closure. They surmised that relatively closed 

canopy and mature forest conditions, recognized as 

critical goshawk nest stands, are also important 

across wider areas of goshawk home range. 

A.4. On August 13, 1992, the USDA Forest Service, 

Southwestern Region received a letter from the 

Regional Director of the Southwest Region of the 

U.S. Fish and Wildlife Service (Service) providing 

preliminary comments to the “Recommendations for 

Goshawk Management in the Southwest Region.” 

The Service stated, “The recommendations are 

founded on a series of premises which are poorly 

supported by the published data. They are: 

1. That little information is available on 

goshawk foraging habitat, but what exists 

suggests they are habitat generalists. 

2. That in the Southwest, goshawks are 

limited by prey abundance. 

3. That the most important goshawk prey 

species in the Southwest are known. 

4. That enough is known of the 14 prey 

species’ biology to define and manage for 

their habitats. 

5. That suitable goshawk foraging habitat and 

sufficient prey will be provided by managing 

for those prey species” (USFWS 1992, p 1). 

In their letter, the Service discussed their concerns 

with each premise individually. Concerning premise 

number one the Service stated, “A considerable 

body of literature contradicts the recommendations’ 

position that goshawk foraging habitat is poorly 

understood. This literature also contradicts the 

recommendations’ characterization of the goshawk 

as a ‘forest habitat generalist’ ” (USFWS 1992, p 1). 

The Service suggested that the recommendations 

used flawed reasoning in suggesting that, because 

goshawks may encounter a mosaic of forest types 

in their home ranges, they use all of those forest 

types. The Service then cites several authors 

(Fischer 1986, Kenward 1982, Bloom et al. 1985, 

Crocker-Bedford 1990) among others to support the 

argument that goshawks prefer to nest and forage 

in large tracts of closed canopy, older or mature 

forest. In a concluding statement, the Service 

noted, “The majority of published evidence 

suggests that the recommendations’ forest mosaic 

will be inferior or unsuitable goshawk habitat” 

(USFWS 1992, p 2). 

Concerning premise number two, the Service 

noted, “The recommendations’ observation that 

goshawks, like some other raptors, should be 

limited by prey availability is valid. However, the 

recommendations only consider simple prey 

abundance, not prey availability” (USFWS 1992, p 

2). The Service goes on to say, “Prey availability is 

a function of prey abundance, and the susceptibility 

of prey to the foraging ecology of the goshawk. 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 17 
Chapter 3 – Affected Environment and Environmental Consequences 

Plentiful literature demonstrates that the goshawk is 

specialized to capture prey in the complex structural 

environment of a forest” (USFWS 1992, p 3). 

In their comments on premise three the Service 

stated, “The Service believes the recommendations 

were developed with too little information on 

goshawk diets in the FS Southwestern Region” 

(USFWS 1992, p 3). And, “Creating the structural 

forest environment to which goshawks are adapted 

will create availability of prey” (USFWS 1992, p 4). 

Regarding premise four, the Service concluded, 

“The recommendations built a management 

prescription based on the vaguely understood 

habitat needs of 14 species, rather than the better 

understood habitat needs of the goshawk” (USFWS 

1992, p 4). 

In their summary statement regarding premise five 

the Service said, “The available information 

suggests that the converse is more scientifically 

sound. By providing the mature forest to which 

goshawks are behaviorally and morphologically 

adapted, prey availability will be provided” (USFWS 

1992, p 5). 

A.5. The Service, like the Arizona Game and Fish 

Department (AZGF), also commented on the use of 

minimum values instead of targets. The argument 

here is that by managing for minimum values, 

goshawk habitat quality will be degraded over time. 

In May of 1993, the AZGF released a document 

titled “Review of U.S. Forest Service Strategy for 

Managing Northern Goshawk Habitat in the 

Southwestern United States.” In that document 

AZGF raised a concern related to management of 

foraging areas for the northern goshawk, 

specifically that “application of the Interim 

Guidelines and Implementation Guidelines for the 

foraging area will result in forest conditions which 

do not adequately meet the needs of the goshawk 

and other wildlife species” (AZGF 1993, p 5). 

They further stated that they consider the goshawk 

a “forest habitat specialist” that is strongly 

associated with mature, dense forest structure in 

many forest types” (AZGF 1993, p 12). To support 

this argument the AZGF cited (Mannan and Smith 

1993, Austin 1991, Kennedy 1989, Hargis et al. 

1994, Crocker-Bedford 1990a, Fischer 1986 and 

Ward et al. 1992). The AZGF cited these studies as 

supporting the perspective that the northern 

goshawk and its prey prefer mature forest with 

dense canopies. The AZGF also stated a concern 

that more open foraging areas would give a 

competitive advantage to other raptors. 

A.6. In their letter of November 28, 1995, the New 

Mexico Department of Game and Fish (NMDGF) 

provided comments on the “Final Environmental 

Impact Statement for Amendment of Forest Plans in 

the Southwestern Region.” They stated “The 

Department finds the preferred alternative (G) to be 

a substantial improvement over the previous 

alternatives in the draft EIS, in that it appears that 

an opportunity to accomplish ecosystem 

management goals is provided” (NMDGF 1995, p 

1). The NMDGF did have two concerns: (1) that a 

lack of specificity in standards and guides may 

provide too much flexibility for interpreting the intent 

of management, and (2) that no discussion of the 

benefits of fire or insects to forest structure is 

provided. 

A.7. The following 11 papers are variously cited in 

the literature as supporting the argument that the 

northern goshawk is a habitat specialist that 

requires mature or old forest with large trees and 

dense canopies in both the nesting stand and the 

foraging area. 

A.7.i. Fischer (1986) studied three coexisting 

Accipiter species in Utah from 1982-85. The study 

area ranged in elevation from a high of 3,350 m, to 

a low of 1,370 m. Vegetation varied greatly by 

elevation consisting of Gambel’s oak, big-toothed 

maple, white fir, Douglas-fir, quaking aspen, spruce, 

and sub-alpine fir. Fischer measured 16 habitat 

variables including canopy height, canopy depth, 

tree density and tree diameter. 

Fischer found that northern goshawks used 

available habitat non-randomly, showing a strong 

preference for white fir/Douglas-fir woodland. On 

several occasions he observed northern goshawks 

capture prey in open areas such as ski trails and 

avalanche zones. Fischer stated, “It was obvious 

that these open areas were hunted, even though 

few radio locations were recorded there” (Fischer 

1986, p 10). Fischer found that the prey of the 

northern goshawk included appreciable numbers of 

both birds and small mammals. Fischer found the 

dominant mammals in the diet of the northern 

goshawk to be ground squirrels, rock squirrels and 

chipmunks. None of these species are old-growth 

obligates. Fischer (1986) further stated, “Northern 

18 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

goshawks, the largest species, foraged significantly 

more often in more open forest types” (p 15). 

A.7.ii. Hargis et al. 1994, conducted a study of 

habitat use by northern goshawks on the Inyo 

National Forest located on the eastern slopes of the 

southern Sierra Nevada Mountains in California. 

They radio tracked eight females and two males 

over three summers. They found that the 10 adults 

they tracked were associated with 6 territories. The 

results of this study are widely cited by other 

authors. However, their results are often only 

partially cited (personal communication on April 2, 

2004, between Dr. Hargis and Wally Murphy). 

In the Discussion and Management Implications 

section of their document Hargis et al. (1994) 

reported, “By using areas that were geographically 

removed from their nest stands, goshawks were 

able to include vegetation types and patterns that 

were generally uncommon, such as riparian 

vegetation, wet meadows, and old-growth stands 

adjacent to meadows or pumice flats” (p 72). 

“Our telemetry data indicated that perched 

goshawks tended to be found in well-canopied 

stands with large trees. These locations may have 

provided hunting perches, thermal cooling, or 

protective cover.” And, “The selection of areas with 

high diversity corresponds to the degree of 

interspersion used by common goshawk prey 

species” (Hargis et al. 1994, p 72). 

“Regardless of the absolute values, goshawks in 

our study selected stands that were denser than the 

average available, both for nesting and foraging, as 

measured by basal area, canopy closure, and the 

number of trees in all five diameter classes.” 

Furthermore, “...the selection for stands with the 

most canopy cover and largest diameter trees can 

be translated to the site potential for different 

regions. Yet our study indicates that goshawks 

select areas that are vegetatively diverse for 

foraging, including numerous aggregations of 

mature trees for nest stands and perch sites” 

(Hargis et al. 1994, p 73). 

In conclusion Hargis et al. (1994) stated, within the 

home range of the goshawk, “...emphasis should 

be placed on creating or maintaining vegetative 

diversity, retaining mature timber around permanent 

water sources and along forest-open edges, and 

ensuring that a portion of the range provides forest 

stands that have structural attributes similar to 

those found at the nest site for each particular 

geographic area” (p 73). 

A.7.iii. In 1993, Mannan and Smith produced a 

document titled, “Habitat Use by Breeding Male 

Northern Goshawks in Northern Arizona, Final 

Report,” USDA Forest Service Cooperative 

Agreement No. 28-C1-556. In 1994, after changing 

senior authors, Bright-Smith and Mannan published 

the results of the same study in Studies of Avian 

Biology No. 16:58-65, 1994. This review cites the 

second document. 

As a basis for their study, Bright-Smith and Mannan 

(1994) equipped five and nine male goshawks with 

radios in 1991 and 1992 respectively. The study 

was conducted on the North Kaibab Ranger District, 

Kaibab National Forest, in northern Arizona. The 

main pattern they found was the mean rank of 

relative preference of all hawks increased with 

increasing canopy closure. Bright-Smith and 

Mannan acknowledged the limitations of their 

measurements of canopy closure from aerial 

photos, but stated, “our findings support the general 

idea of maintaining relatively high canopy closure 

over a significant portion of areas managed for 

foraging goshawks” (Bright-Smith and Mannan 

1994, p 64). 

A.7.iv. As part of a Masters Degree program at 

Oregon State University, Austin (1993), studied 10 

radio-equipped northern goshawks on the ShastaTrinity and Klamath National Forests, in the 

Southern Cascade Mountains of northern 

California. In this study, Austin investigated home 

range size in relation to two objectives: (1) estimate 

the average home range, and (2) describe the use 

of habitats within home ranges by breeding 

goshawks. 

Austin (1993) found: (1) Goshawks selected the 

closed-mature/old-growth habitat with more than 40 

percent average canopy closure, and (2) early 

successional forest or unforested areas seemed to 

be less important, i.e., seedling/sapling/grass-forb. 

Because of her study, Austin (1993) recommended 

at least 20 percent of the management area be in 

closed-mature/old-growth habitat (trees greater 

than 21 inches d.b.h. and average canopy closure 

over 40 percent). 

A.7.v. Beier 1994, authored “Selection of Foraging 

Habitat by Northern Goshawks on the Coconino 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 19 
Chapter 3 – Affected Environment and Environmental Consequences 

National Forest,” Arizona Game and Fish 

Department Heritage Grant Project Number 1-

94025, Progress Report. Beier investigated habitat 

selection within the home range, rather than how 

home ranges are located in a larger landscape. 

Beier tracked 16 radio-tagged adult goshawks. 

Beier (1994) found prey abundance did not seem 

important in selection of foraging areas by 

goshawks. He stated, “The most striking finding 

was that used plots showed enormous variation in 

vegetation structure.” And, “...the range of sites 

used by goshawks was impressively broad...” 

(Beier 1994, p 4). He also found used plots had 

more trees overall, more trees in the 8-16" d.b.h. 

class and >16" d.b.h. size class, and more trees > 

18 m tall. 

A.7.vi. Titus et al. 1994, prepared a Final Annual 

Project Report, for the USDA Forest Service, 

Alaska Region, Tongass National Forest, “Northern 

Goshawk Ecology and Habitat Relationships on the 

Tongass National Forest.” This study had five 

objectives: 

1. Locate additional goshawk nest sites and 

characterize nest site objectives 

2. Determine goshawk home ranges and 

habitat associations using radio-telemetry 

3. Evaluate the diet of goshawks during the 

nesting period 

4. Determine the short-term dispersal 

distances and survival rates of juvenile 

goshawks when possible, and 

5. Assess sub-specific variation in A.g. laingi

for Southeast Alaska. 

Relevant to this discussion, Titus et al. found that 

83 percent of the goshawk nests they discovered 

were located in old-growth stands and 17 percent 

were located in 90+ year-old, second-growth 

stands. 

A.7.vii. In May of 1994, Crocker-Bedford prepared 

“Conservation of the Queen Charlotte Goshawk in 

Southeast Alaska” as an appendix to “A Proposed 

Strategy for Maintaining Well-Distributed, Viable 

Populations of Wildlife Associated with Old-Growth 

Forests in Southeast Alaska” by Suring et al. 

Crocker-Bedford reported, “Closed canopies appear 

to provide preferred microclimate in the nesting 

stand, increased productivity of some important 

prey species, and reduced competition and 

predation by open-forest raptors.” And, “In 

southeast Alaska 92 percent of the relocations on 

radio-tagged goshawks were in old-growth forests 

having over 8 mbf/ac. Old-growth having over 20 

mbf/ac. was most preferred” (Crocker-Bedford 

1994, p 1). 

Crocker-Bedford cited numerous authors including: 

Allen 1978, Speiser and Bosakowski 1987, 

Reynolds et al. 1992, Hall 1984, and Hennessy 

1978, to support the argument that goshawks 

typically nest in taller mature or old-growth forest 

stands, either coniferous or deciduous, which have 

relatively dense canopies. Crocker-Bedford and 

Chaney (1988) stated, “a demonstrated preference 

(use compared to availability) for nesting in stands 

of large trees with dense canopies (P < 0.0001), 

and suggested such preference was associated 

with similar stands in the vicinity used for foraging” 

(Crocker-Bedford 1994, p 8). It was also noted that 

closed canopies may be associated with overall 

prey abundance. 

A.7.viii. Crocker-Bedford 1995, published an 

abstract of a paper presented at the annual meeting 

of Raptor Research Foundation, Goshawk 

Symposium, November 3, 1994, Flagstaff, Arizona, 

titled “Northern Goshawk Reproduction Relative to 

Selection Harvest in Arizona.” In an abstract of his 

presentation, Crocker-Bedford separated 53 nest 

clusters into four categories: 12 in assumed home 

ranges which had received little or no harvesting 

(1973-1986), 14 which had selection harvesting on 

10-39 percent of each home range area, 16 which 

had harvesting on 40-60 percent of each home 

range area and 11 which had selection harvesting 

between 1973-1986 on 70-90 percent of each home 

range. For the four categories respectively, 

occupancy rates were 83 percent, 43 percent, 31 

percent and 0.00 (P, 0.001). Crocker-Bedford 

summarized his conclusion with, “These and other 

data could indicate some real decline in the local 

breeding population and productivity, and/or 

represent movement of successful breeders from 

more logged to less logged areas” (CrockerBedford 1995, p 43). 

A.7.ix. In April 1995, H. Snyder published a Final 

Grant-In-Aid report for the Arizona Game and Fish 

Department titled, “Apache Goshawk Conservation 

Biology in Southeast Arizona.” This study was 

20 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

based on a 1-year contract between the AZGF and 

Coronado National Forest. Snyder had eight goals, 

two of which are pertinent to this discussion: (1) to 

produce a database containing nest-area locations 

and habitat measurements, including maps and 

photographs, for use by resource managers; and 

(2) to describe the foraging range and habitat 

utilization of selected pairs in three different 

habitats, with emphasis on the use by the Apache 

goshawk of oak woodlands. Snyder noted, “Most 

goshawk habitat on the study area is extremely 

disjunct, and in the case of these four pairs a 

complete search was relatively easy because the 

area was relatively small and much of the 

intervening terrain was sparsely vegetated with 

rocky outcrops and cliffs.” And, “It is interesting that 

no nests were found in aspens although a special 

effort was made to search for nests in these trees” 

(Snyder 1995, p 16 and 22). Snyder also reported 

a minimum of 50 percent or greater canopy closure 

at nest sites. 

A.7.x. In 1994, Woodbridge and Detrich published 

“Territory Occupancy and Habitat Patch Size of 

Northern Goshawks in the Southern Cascades of 

California,” in Studies in Avian Biology No. 16:83-

87. In this study, Woodbridge and Detrich describe 

spatial patterns of habitat use by nesting goshawks 

at four levels of resolution: nest trees, nest stands, 

territories (clusters of nest stands), and spacing 

between territories. Woodbridge and Detrich found 

the following: (1) mean occupancy rates of habitat 

components increased as spatial scale increased 

from nest trees to nest stands and (2) nest stand 

clusters, despite intensive timber harvest and 

fragmentation of mature forest, supported high 

densities of nesting goshawks. 

A.7.xi. Building on an ongoing study (discussed 

under A.7.vi.), Titus et al., 1996, reported results 

from multiyear goshawk nest surveys on the 

Tongass National Forest in Southeast Alaska. This 

study had the same five objectives as noted in 

A.7.vi: Titus et al. (1996) found that after three field 

seasons the total number of known nest sites in 

southeast Alaska was low compared to other parts 

of the country. Nest site productivity averaged 2.3 

young/nest. For comparison purposes goshawk 

habitat in Southeast Alaska is far too different from 

ponderosa pine forest in the Southwest to make 

valuable comparisons (see Reynolds 2004). 

A.8. On December 1, 1994, a coalition of 

environmental groups led by the Southwest Center 

for Biological Diversity provided “Comments on the 

Draft Environmental Impact Statement and 

Proposal to Amend Ten National Forest Land 

Management Plans,” prepared by Suckling et al. In 

this document, Suckling et al. provided an extensive 

review and critique of the “Management 

Recommendations for the Northern Goshawk in the 

Southwestern United States” (MRNG), pages 17-

28. 

In their assessment, Suckling et al. began by 

critiquing two basic assumptions in the MRNG: 

• “Goshawks do not require extensive stands 

of canopied forest, but do require high 

levels of interspersion. 

• Goshawks are dependent upon prey 

abundance not availability, and therefore do 

not directly select for forest structure” 

(Suckling et al. 1994, p 17). 

In critiquing the first assumption, Suckling et al. 

(1994) noted, “None of the voluminous goshawk 

literature is cited to support these very 

unconventional notions of ecosystem management 

and goshawk ecology” (p 18). And, “Goshawk 

literature is relatively consistent in strongly 

associating goshawks in the United States with 

extensive forests or large stands of mature and oldgrowth trees” (p 19). Suckling et al. cites at least 35 

papers to support this objection. 

From these citations, Suckling et al. conclude the 

following: goshawk nesting habitat is generally 

mature and extensive, nest productivity increases 

with amount of mature forest, re-occupancy rates 

are higher in extensive mature forest, home ranges 

are smaller and overlap is greater in more extensive 

forests, logging in mature and old-growth forests 

diminishes the habitat elements necessary for 

successful nesting and foraging, logging fragments 

contiguous forest tracts making less suitable 

goshawk habitat, intra/interspecific competition for 

nest sites and prey items is increased by forest 

fragmentation and predation on goshawks may be 

increased by forest fragmentation. 

In critiquing assumption two, Suckling et al. (1994) 

noted, “It is true that goshawks use a variety of 

forest types as foraging areas. It does not follow, 

however, that they are forest generalists. 

Goshawks are forest specialists with a strong and 

demonstrated preference for mature forests” (p 25). 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 21 
Chapter 3 – Affected Environment and Environmental Consequences 

Suckling et al. (1994) also noted, “Studies not cited 

by the MRNG suggest goshawks require mature 

forest structures for foraging” (p 26). 

To support this argument Suckling et al. cite Fischer 

1986, Fischer and Murphy 1986, Widen 1989, 

Austin 1991 and 1993, Hargis et al. 1993, and 

Crocker-Bedford and Chaney 1988, among others. 

A number of these papers have been reviewed, in 

this document. 

A.9. In March 1996, The Wildlife Society released 

“Northern Goshawk and Forest Management in the 

Southwestern United States,” Technical Review 96-

2 by Braun et al. This document emerged from a 

request by the Arizona Chapter of The Wildlife 

Society for the formation of a panel of scientists to 

review the interim guidelines and related forest 

management activities in the Southwest. The 

review team was formed jointly by The Wildlife 

Society and the American Ornithologists Union. 

The panel was requested to review the scientific 

basis for the goshawk interim management 

guidelines resulting from the “Management 

Recommendations for the Northern Goshawk in the 

Southwestern United States.” The panel’s specific 

charges were to: (1) review the scientific literature 

concerning northern goshawk biology and 

management in the Southwest; (2) evaluate the 

scientific basis and policy guidance for the interim 

guidelines; (3) perform an on-the-ground inspection 

of forest management conditions in the Southwest 

relative to implementation of the interim guidelines; 

and (4) prepare a report outlining the review panel’s 

findings and recommendations. 

In making their report, the review panel came to 12 

conclusions: 

1. “The scope and review of the biology of 

northern goshawks in the ‘Management 

Recommendations’ are excellent.” 

2. The “Management Recommendations”

represent an innovative approach to forest 

management because they encourage 

forest managers to consider forest 

ecosystems as assemblages of interacting 

species of plants and animals. 

3. The “Management Recommendations” and 

related USFS policy lack substantive 

considerations for evaluating the 

effectiveness and testing the consequences 

of implementing these practices. 

4. No evidence was presented to indicate that 

northern goshawk populations are 

declining, threatened, or endangered in the 

Southwest or anywhere in its range, and we 

found no evidence of a long-term decline in 

goshawk breeding populations... 

5. The complexity of detail for silvicultural 

treatments in the “Management 

Recommendations” indicates a preciseness 

of management that cannot, and probably 

need not uniformly be achieved over large 

areas... 

6. Surveys of goshawks should be 

standardized and conducted in all 

southwestern forests to establish baseline 

data on population status and trends in all 

seasons, and to monitor the status of 

goshawks. 

7. Northern goshawks use a variety of 

forested habitats during the nesting 

period... 

8. Significant research should be conducted 

on habitat and prey requirements during the 

nonnesting period (September - March). 

9. Implementation of prescriptions in the 

“Management Recommendations” must be 

carefully considered and recognize the 

diverse growing conditions and inherent 

heterogeneity of southwestern forests. 

10. In the absence of frequent ground fire, 

healthy southwestern ponderosa pine 

forests need management... the 

“Management Recommendations” should 

contribute to a healthy, heterogeneous 

forest... 

11. Proper management of southwestern 

forests must involve an 

ecosystem/landscape approach and should 

not be narrowly focused on one species... 

the “Management Recommendations” 

represent a major step toward research and 

management of ecosystems at a landscape 

scale... 

22 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

12. The public needs to learn ponderosa pine 

forests in the Southwest were open and 

park-like in the pre-settlement period...” 

(Braun et al. 1996, p 10-11). 

B. New information concerning management of 

northern goshawk habitat has also become 

available since the 1996 regional amendment and 

significant points of these papers are summarized 

in the following review. 

1. A paper by Beier and Drennan titled “Forest 

Structure and Prey Abundance in Foraging 

Areas of Northern Goshawks,” published in 

Ecological Applications, 7(2), 1997. 

2. A document of October 30, 2001, titled 

“Review of Supplemental Information 

Relevant to Habitat Management for the 

Northern Goshawk in the Southwestern 

United States” by Reynolds et al. 

3. Reynolds et al. 2003, Rocky Mountain 

Research Station Progress Report titled 

“Population Ecology, Demographics, 

Habitat, and Genetics of the Northern 

Goshawk on the Kaibab Plateau, Arizona.” 

4. An unpublished paper by Crocker-Bedford 

dated April 10, 2003, titled “Habitat Effects 

on Northern Goshawks.” 

5. A review of January 9, 2004, by R. T. 

Reynolds of over 180 documents including 

peer-reviewed publications, theses, reports, 

and draft manuscripts for information on 

how goshawks use habitats in both the 

breeding season and winter, titled “Is the 

Northern Goshawk an Old-growth Forest 

Specialist or a Habitat Generalist?” 

6. A 2004 Wildlife Society Technical Review 

04-1, titled “The Status of Northern 

Goshawks in the Western United States,” 

by Anderson et al. 

7. Thirteen additional papers which studied 

habitat associations of northern goshawks 

published since 1996: 

i) Patla (1997) 

ii) Widen (1997) 

iii) Good (1998) 

iv) Reynolds and Joy (1998) 

v) Lapinski (2000) 

vi) Boal et al. (2001) 

vii) Ingraldi (2001) 

viii) Stephens (2001) 

ix) Bloxton (2002) 

x) Finn et al. (2002) 

xi) Joy (2002) 

xii) Drennan and Beier (2003) 

xiii) La Sorte et al. (2004) 

Key points from these documents are summarized 

as follows. 

B.1. We begin our review of this latest information 

with a review of a paper by Beier and Drennan 

(1997) that was published in Ecological Applications

Vol. 7, No. 2. This paper reported findings that are 

similar to Beier (1994), e.g., that goshawks 

apparently did not select foraging sites based on 

prey abundance and goshawks selected foraging 

sites that had higher canopy closure and greater 

density of trees than other areas studied. 

Data from Beier and Drennan (1997) show a mean 

canopy closure of 48.3 percent on plots used by 

goshawks with 21 trees per acre (extrapolated from 

smaller plots) greater than 16 inch d.b.h. In the 

MRNG, the recommended mean canopy cover 

within the PFA (minimum of 50 percent within the 

mature and old age classes) and within the foraging 

areas (minimum of 40 percent within the mature 

and old age classes) should approximate or exceed 

the 48.3 percent cover at foraging sites reported by 

Beier and Drennen. 

B.2. In October 2001, the Northern Goshawk 

Scientific Committee (NGSC) produced a “Review 

of Supplemental Information Relevant to Habitat 

Management for the Northern Goshawk in 

Southwestern United States” (Reynolds et al.) for 

the Southwestern Region of the USDA Forest 

Service. In this document the NGSC reviewed 9 of 

the 11 papers previously discussed and disclosed 

in A.7. The NGSC noted that only two of the papers 

were published in peer-reviewed journals, the other 

seven consist of an unpublished progress report, 

agency reports, a thesis, and a published but not 

peer-reviewed abstract. 

The NGSC made the following findings concerning 

Austin (1993): 

1. The study was more applicable to mixed 

conifer rather than ponderosa pine forests. 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 23 
Chapter 3 – Affected Environment and Environmental Consequences 

2. Home ranges were 22 percent larger than 

the largest home ranges reported in other 

North American studies. 

3. Findings on habitat use are potentially 

flawed because of failure to determine or 

report the degree of location error during 

radio-telemetry studies. 

4. Data support the desired future condition 

identified in the MRNG in that the MRNG in 

ponderosa pine call for 20 percent of the 

home range in trees 100-140 years old, 20 

percent of the home range with trees 140-

185 years old, and 20 percent of the home 

range with trees 180-235 years old. Austin 

recommends this proportion of age classes 

is expected to provide the large trees with 

lifted crowns and open understories. 

The NGSC made the following findings concerning 

Beier (1994): 

1. The study was conducted in Southwest 

ponderosa pine forest. 

2. Findings are potentially confounded by 

several factors including whether observed 

goshawks were actually foraging versus 

participating in other activities while 

perching or flying, incorrectly identifying the 

actual “kill site” by a predator that may stop 

a number of times on the way to a nest with 

a prey item, and confusing a “kill site” with 

the site where a prey was first detected (a 

critical factor in foraging site selection) by 

the predator with prey that often move 

some distances during escape attempts. 

3. “Beier’s finding that prey numbers were the 

same in used and unused sites does not 

necessarily support his conclusion that 

goshawks did not pay much attention to 

prey density” (Reynolds et al. 2001, p 7). 

4. In spite of all this, Beier’s finding that 

goshawks prefer large trees and a diversity 

of vegetation is consistent with the MRNG 

(see previous discussion). 

5. Beier’s prey census study did not include 

two important northern goshawk prey items 

in the southwest—Abert’s squirrel and red 

squirrel—potentially confounding the counts 

of prey in used vs. unused foraging sites. 

6. Despite the small sample size, Beier’s data 

support the MRNG in that foraging 

goshawks prefer large trees and a diversity 

of vegetation provided by 20 percent of the 

home range in trees 100-140 years old, 20 

percent of the home range with trees 140-

185 years old and 20 percent of the home 

range with trees 180-235 years old. The 

NGSC recommended a high level of 

interspersion of structural stages and 

advocated clumping large old trees with 

interlocking crowns.

The NGSC made the following conclusion 

concerning Crocker-Bedford’s 1994 paper: “All 

topics in the 15 documents reviewed by CrockerBedford were effectively addressed by the Scientific 

Committee in the development of the MRNG” 

(Reynolds et al. 2001, p 12). However, the NGSC 

reviewed 3 of 15 pre-1992 documents cited by 

Crocker-Bedford that were published in peerreviewed journals. 

Hogland (1964) (Crocker-Bedford p 20), which was 

published in a German journal, reported juvenile 

goshawks dispersed >30 miles from nest sites in 

Sweden. Because the NGSC recommended 

implementing the MRNG in landscapes, adequate 

habitat should be available for dispersing juveniles. 

Kostrzewa (1987) (Crocker-Bedford p 10), also in a 

German journal, reported, in a study area 

containing only 16.4 percent forests, goshawks 

nested further from openings than other hawks in 

Germany. In an effort to prevent southwestern 

forests from becoming fragmented, the NGSC 

recommended overstory canopy cover up to 70 

percent (MRNG p 7, Table 1; p 16) with openings 

no larger than 2 acres in size, no greater than 200 

feet across. 

Shuster (1976) (Crocker-Bedford, p 40 Table 1) 

reported on nesting density of goshawks in 

Colorado. According to Crocker-Bedford, Shuster 

found 3 pairs of goshawks per 10,000 acres in 

areas of Colorado where there was little timber 

harvest and as timber harvest increased, the 

number of goshawk nests per 10,000 acres 

decreased. Nesting density was not discussed in 

the MRNG; however, NGSC concluded studies of 

goshawk nest densities often lacked pre-timber 

24 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

harvest controls, and nest densities are likely to 

differ among localities, forest types, and years, 

making comparisons equivocal. 

The NGSC made three conclusive statements 

regarding the Crocker-Bedford (1995) paper and 

the goshawk guidelines: 

1. The MRNG recognized that logging 

probably affects goshawks. 

2. A 12-year study of nesting goshawks on the 

North Kaibab Ranger District identified 102 

territories (Reynolds et al. 2003) indicating 

that the goshawk population there may not 

have declined. 

3. The NGSC noted that Crocker-Bedford 

(1994 and 1995) was considered during the 

development of the MRNG. 

The NGSC made the following findings regarding 

the consistency of findings in Hargis et al. (1994) 

with the MRNG. Hargis et al. (1994) concluded that, 

within the home range of the goshawk emphasis 

should be placed on creating or maintaining 

vegetation diversity, retaining mature timber around 

permanent water sources and along forest-open 

edges, and ensuring that a portion of the range 

provides forest stands that have structural attributes 

similar to those found at the nest site for each 

particular geographic area. 

The NGSC made the following findings concerning 

Mannan and Smith (1993): 

1. The Mannan and Smith study included only 

ponderosa pine and mixed conifer forests. 

2. Home ranges were intermediate in size to 

those reported in other studies. 

3. The authors were only able to study 

goshawk use/avoidance of canopy cover 

categories and they were unable to partition 

their canopy cover categories and not 

forest age classes. 

4. The determination of use or avoidance of 

“edge” in the study appeared confounded. 

5. Canopy cover diversity was consistent with 

the MRNG. 

6. Overall Mannan and Smith findings support 

the MRNG for 40-60 percent canopy cover 

in ponderosa pine and 60-70 percent in 

mixed conifer. They also stated the 

distance to edge that Mannan and Smith 

reported is equivocal. 

The NGSC made the following findings concerning 

Snyder (1995) as it relates to the MRNG: 

1. The MRNG did not address Madrean 

evergreen forest. 

2. Canopy cover recommendations in the 

MRNG are consistent with Snyder’s 

findings. 

3. The MRNG did not address Mearns quail (a 

common prey species in Madrean forests) 

as a prey item. 

4. Extensive searches for goshawk nests are 

required before population trends can be 

established. 

5. Snyder’s report is supportive of the desired 

forest conditions found in the MRNG 

because of diversity of vegetation that 

goshawks utilized in the study area. 

The NGSC made several findings concerning Titus 

et al. (1994), however, these findings are not 

reported here because the extreme differences in 

habitat between Southwest ponderosa pine forests 

and forests in southeastern Alaska make 

comparisons to the MRNG difficult, if not 

impossible. 

The NGSC made the following findings concerning 

Woodbridge and Detrich (1994): 

1. The forest types in the Woodbridge and 

Detrich study are similar to southwestern 

forests. 

2. The NGSC prevented extensive 

fragmentation of forests by tree harvests as 

was the case in the Woodbrideg and 

Detrich study area. 

3. The NGSC also recognized the importance 

of nest areas, nest sites, and nest trees for 

breeding goshawks. 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 25 
Chapter 3 – Affected Environment and Environmental Consequences 

4. Some of the findings are not pertinent 

because implementation of the MRNG do 

not result in large-scale fragmentation and, 

therefore, do not suggest amending the 

MRNG. 

In summary, the NGSC found the new information 

in the nine cited papers supported the MRNG and 

none of the new information warranted amending 

the MRNG. 

B.3. Reynolds et al. (2003) is a progress report 

concerning the long-term northern goshawk study 

on the Kaibab Plateau in northern Arizona. The 

study has four objectives related to goshawk habitat 

management: (1) Identify the distribution, density, 

vital rates and genetic structure of the northern 

goshawk population on the Kaibab Plateau; (2) 

identify factors such as habitat, food, predators, 

competitors, short- and long-term weather patterns, 

and interactions among these factors that are 

limiting the population of goshawks on the Kaibab 

Plateau; (3) identify the effects of forest 

management on both the vital rates of the Kaibab 

Plateau goshawk population and on each of their 

population limiting factors limiting the goshawk 

population; and 4) identify habitat elements that 

differentiate high quality from low quality habitat by 

investigating the relationship between the long-term 

demographic performance of individual goshawks 

on territories and the landscape-level composition 

and structure of the habitat within their territories. 

One hypothesis being tested is that goshawk 

reproduction may be affected as much by food 

abundance as by habitat structure. The food 

abundance hypothesis is based on the idea that 

increased primary forest productivity during wet 

years results in abundant foods (mast seeding, 

insects), increased populations of birds and 

mammal prey, and increased breeding by 

goshawks. 

Reynolds et al. (2003) reported “Goshawks on the 

Kaibab Plateau have a high annual fidelity to their 

territories” (p 6). And, “Overall, 95% of males and 

94% of females remained on their original territories 

from one year to the next” (p 6). Furthermore, 

“Failure of a nest attempt in a previous year had 

little influence on either territory or mate fidelity” (p 

7). They concluded, “These data, when coupled 

with estimates of adult survival, fidelity, and 

dispersal, suggest that competition for breeding 

territories on the Kaibab may be high as a direct 

result of a saturated breeding population” (p 8). 

Reynolds et al. (2003) also reported, “On higher 

quality territories, the amount of deciduous 

vegetation and forest openings increased with 

distance for circle plots; whereas, proportions of 

these habitats decreased with distance from 

random locations” (p 9). And, “The number and 

size of openings within a goshawk’s territory and 

foraging range are, therefore, important to the 

goshawk’s reproductive success” (p 10). 

In summary, Reynolds et al. (2003) pointed out, 

“The evidence is mounting that prey abundance 

varies in response to variations in forest productivity 

(e.g., cone crops, understory plant production) and 

short- and long-term weather patterns (wet vs. dry 

periods)” (p 10). 

B.4. In an April 10, 2003, paper, Crocker-Bedford 

updated his previous 2001 literature review on 

“Habitat Effects on Northern Goshawks,” citing a 

number of authors who support the position that 

goshawk nest sites include larger trees and denser 

overstory canopies than the surrounding landscape. 

Also cited were Beier and Drennan (1997), and 

Good (1998), to make the point that goshawk 

foraging areas are composed of stands of larger 

trees, dense overstories, and fewer shrubs and 

saplings and they found no association between 

foraging locations and the actual density of potential 

prey. 

In summary, Crocker-Bedford (2003) stated, “Up to 

some point, larger stands of mature forest are 

better for both nesting and foraging than smaller 

stands (a few studies).” And, “Although individual 

goshawks are not everywhere obligates of mature 

forests, such habitat may be important for the 

survival of the species” (p 3). 

B.5. On January 9, 2004, Reynolds produced a 

report, “Is the Northern Goshawk an Old-growth 

Forest Specialist or a Habitat Generalist?” based on 

a review of over 180 documents, including peerreviewed publications, theses, reports and draft 

manuscripts related to the northern goshawk, that 

may have had information on how goshawks used 

habitats during the breeding and winter seasons. 

The following statements are from the “Findings 

and Synthesis” section of Reynolds (2004): 

26 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

1. Clearly, both nesting and foraging 

goshawks use nearly every forest and 

woodland habitat type that occurs within the 

hawk’s geographic range. 

2. The diversity of vegetation types within the 

home ranges of goshawks increased with 

increasing distance from the nest. 

3. Even within nest areas themselves, the 

habitat structure was variable depending on 

forest type. 

4. In territories lacking old forests, goshawks 

nest in mid-aged forests. 

5. Only one report found that goshawks 

extensively used old-growth forests versus 

other forest age classes. 

6. The high density of goshawks on the 

Kaibab Plateau (a disturbed habitat) 

strongly suggests that goshawks are not 

old-growth obligates. This does not mean 

that goshawks avoid old growth or do not 

use old growth: it simply shows that 

goshawks can live and reproduce in forests 

other than old growth. 

7. Much of the variation in habitats used 

appears to be related to the local 

availability of habitats in combination with 

an apparent opportunistic nature of 

goshawks. 

8. During the breeding season, nesting 

goshawks are energetically limited to a 

finite space surrounding the nest. 

9. During winter, when goshawks are not so 

space limited, their wider range allows them 

to use a greater variety of habitats. 

10. Goshawks may prefer certain habitat 

compositions and structures to others and 

may, therefore, not use habitats within their 

home ranges in direct proportion to each 

habitat’s occurrence. 

11. The sum of evidence reviewed argues 

much of habitat use by goshawks appeared 

to be related to differences among habitats, 

in prey abundance and prey availability. 

Thus, goshawks may nest, or forage, more 

often in habitats, or mixes of habitats, 

where prey is more abundant. Much of the 

diversity of vegetation types and conditions 

used by goshawks appears to be related to 

the diverse habitats that many prey species 

of goshawks use although there is some 

contrary evidence of this perspective. 

12. Clearly, goshawks are opportunistic; they 

use a wide variety of habitats and take 

whatever prey presents itself provided they 

can detect and pursue it. 

13. A high interspersion of prey habitats 

probably benefits the energetics of foraging 

goshawks by providing an overall greater 

diversity of prey species and reduces the 

travel time between patches of foraging 

goshawks. 

In conclusion, Reynolds (2004) noted, “Goshawks 

breed in most forest and woodland types that occur 

in their geographic range... and in some localities in 

open shrub, tundra, or riparian areas... where they 

nest in small patches of trees but hunt in the open.” 

And, “Much of the diversity of vegetation types used 

by goshawks may be related to the availabilities of 

different prey species in each of those vegetation 

types” (p 6). 

The above conclusions support Reynolds, et al. 

(1992) and Reynolds et al. (1996) findings that 

northern goshawk habitat conservation plans 

should include goshawk (nesting, foraging) and the 

habitats of all major prey species in a local goshawk 

food web. While some authors have argued 

goshawks require closed canopy, mature forest for 

nesting and foraging, research is increasingly 

showing that goshawks use a variety of forest and 

woodland types and age classes and, in some 

areas, hunt extensively in openings and in edges 

along openings (Reynolds 2004). 

B.6. In 2004, The Wildlife Society released 

Technical Review 04-1 “The Status of Northern 

Goshawks in the Western United States,” Anderson 

et al. (2004). The Raptor Research Foundation Inc. 

and The Wildlife Society jointly formed a technical 

review committee to: (1) determine if there is 

evidence of a population trend in northern 

goshawks in the western U.S., excluding Alaska; (2) 

determine if there is evidence that goshawks 

nesting in the eastern and western United States 

represent distinct, genetically unique populations; 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 27 
Chapter 3 – Affected Environment and Environmental Consequences 

and (3) evaluate evidence for northern goshawk 

habitat relationships, including any association with 

large, mostly unbroken tracts of old-growth and 

mature forests. 

Charge number three is at the heart of the 

Southwestern United States goshawk habitat 

debate. The Wildlife Society committee concluded, 

“Given the current knowledge of goshawk-habitat 

relationships, it is not scientifically defensible to 

solely use the distribution and abundance of latesuccessional forest as a surrogate measure to infer 

goshawk status, population trend, and habitat 

quality” (Anderson et al. 2004, p 18). 

B.7. As with the 11 papers noted in A.7., the 

following 13 papers are variously cited as 

supporting the argument that the northern goshawk 

is a habitat specialist that requires mature or old 

forest with large trees and dense canopies in both 

the nesting stand and the foraging area. Further, 

goshawks avoid open areas and young stands, and 

that harvesting reduces occupancy and ultimately 

population density.

B.7.i. Patla (1997) studied a population of northern 

goshawks for 6 years from 1989 to 1995 on the 

Targhee National Forest in eastern Idaho and 

western Wyoming. The study included 31 territories 

located in Douglas-fir and lodgepole pine and 

focused on nesting habitat over large areas, and 

the effects of timber harvesting on both habitat and 

reproductive success. The most common harvest 

method was clearcutting. Patla evaluated five 

spatial scales: the nest tree, nest plot, nest area, 

post-fledgling family area and the forage area. Her 

study area consisted of steep mountainous terrain 

in the upper Snake River basin. Vegetation included 

sub-alpine fir, Engleman spruce, whitebark pine, 

Douglas-fir, quaking aspen and lodgepole pine. 

Patla found 27 of the 31 territories were occupied at 

least once during the study. Sixty-four percent of 

nest territories had some timber harvest while 35 

percent were undisturbed. Patla found significant 

differences in productivity between years with 

weather being the dominant factor. The study found 

five prey items dominated the diet of the northern 

goshawk: snowshoe hare, Uinta ground squirrel, 

ruffed grouse, blue grouse, and red squirrel. One 

male goshawk fed almost exclusively on ground 

squirrels. Patla’s observations were very similar to 

Fischer’s (1986), “I observed goshawks hunting 

ground squirrels in open areas of grass or sage 

meadows at three different locations” (Patla 1997, p 

43). Patla found that sage/shrub cover in the 

foraging area was positively correlated with 

occupancy of the goshawk territory. The study 

results suggest the importance of sage/shrub cover 

in providing consistent foraging opportunities for 

northern goshawks. She also found that occupancy 

rates of pre-harvest nesting territories were higher 

than post-harvest territories but the differences 

were not significant. 

Patla concluded, within the PFA and FA, the MRNG 

recommendation for retention of 60 percent cover in 

mid-aged, mature and old forest stands (20 percent 

in each category) were very close to the average 

proportion of total mature forest cover found within 

estimated goshawk PFAs and FAs on the Targhee 

National Forest. 

B.7.ii. In a 1997 paper, Widen reported on broad 

scale goshawk population trends and status in 

Fennoscandia, as well as habitat needs and 

preferences. Widen (1997) concluded, goshawk 

populations in Fennoscandia have declined 50-60 

percent from the 1950s to the 1980s. During the 

same time, roughly 40 percent of the forested land 

had been cleared. Widen cited his 1989 study 

which found goshawks strongly preferred large 

patches and mature forest. However, “large patch” 

was not defined. Widen also concluded, hunting 

habitats are more crucial than nesting habitats. 

B.7.iii. Good (1998) monitored eight male 

goshawks during the summers of 1996 and 1997 on 

the Medicine Bow National Forest in south central 

Wyoming. Vegetation was dominated by lodgepole 

pine with Douglas-fir, subalpine fir, limber pine, 

ponderosa pine and quaking aspen comprising the 

rest of the tree component. Good looked at four 

factors that affect relative use of goshawk kill areas: 

(1) prey abundance, (2) habitat characteristics, (3) 

landscape patterns, and (4) habitat needs of prey 

species. 

Good (1998) found that on average goshawks did 

not return more often to sites with greater prey 

abundance. Goshawks returned most often to sites 

with gentler slopes, fewer ground shrubs, greater 

density of trees 23 cm d.b.h., and sites dominated 

by lodgepole pine adjacent to clearcuts with 

inclusions of small openings. Good also found that 

goshawks did not return frequently to sites with 

greater canopy coverage but made kills in a wide 

range of habitat structure. 

28 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

B.7.iv. Based on data collected from 1991 through 

1996, Reynolds and Joy (1998) reported on the 

distribution of nesting pairs, annual proportion of 

pairs laying eggs, nesting success, fecundity, 

fledgling sex ratio, mate and territory fidelity, and 

natal and breeding dispersal of goshawks on the 

Kaibab Plateau in Northern Arizona. They also 

provided an estimate of the minimum number of 

monitoring pairs necessary to accurately determine 

occupancy rates, production of fledglings and 

nesting success to be 40 pairs. 

From 1991 through 1996, Reynolds and Joy 

banded 429 goshawks in the study area including 

86 males, 87 females and 256 nestlings. Brood size 

ranged from 1 to 3 nestlings and annual nesting 

success ranged between 72-86 percent. The sex 

ratio of broods was 54.3 percent female and 45.7 

percent male. Reynolds and Joy (1998) found 107 

nest territories which they estimated to be 73 

percent of the potential territories on the Kaibab 

Plateau. 

In conclusion, they noted in spite of low male 

survival, there is evidence that the goshawk 

population on the Kaibab is both saturated and 

relatively stable and the high annual rate of 

occupancy of territories by goshawks is suggestive 

of a saturated population. Reynolds and Joy (1998) 

also suggest that to determine goshawk fecundity 

would require a sample size of between 80 and 100 

pairs. 

B.7.v. Lapinski (2000) reported on a master’s study 

she conducted on goshawk nest production and 

habitat use for 4 years beginning in 1996 and 

ending in 1999. Lapinski found 36 active historic 

nests and captured and placed transmitters on 6 

adult goshawks including 1 male. The study was 

conducted in the Upper Peninsula of Michigan. 

Lapinski found nest success to be 1.14 young 

fledged per year with a predation rate of 25 percent. 

Based on a personal communication, she 

speculated that fisher predation may be facilitated 

by reductions in continuous cover of mixed 

hardwood-conifer forests. She found that goshawks 

neither selected nor avoided a variety of habitat 

types in the Upper Peninsula of Michigan other than 

a selection for hardwood cover types. She also 

found that prey availability (ruffed grouse and 

snowshoe hare) was an important part of habitat 

selection by goshawks. Home ranges of goshawks 

in the Upper Peninsula of Michigan were smaller 

than those in the West. 

B.7.vi. Boal et al. (2001) studied goshawks in 

Minnesota for 3 years from 1998-2000. Habitats 

included hardwood and conifer forests consisting of 

aspen, paper birch, red oak, white pine, and red 

pine. Boal et al. classified stands as young 0-25 

years, mature 25-50 years and old <50 years. Boal 

et al. located 53 nest areas and radio tagged 33 

adults (18 males and 15 females). Eighty-one 

percent of the nests were in aspen, 11 percent in 

paper birch and 4 percent in white pine. Fledgling 

success was 1.75 young per nest. Boal et al. found 

early successional upland hardwoods were the 

most common habitat type for foraging goshawks. 

Mature early and mature late successional upland 

conifers were preferred for breeding. Goshawk 

home ranges also had high levels of downed wood, 

high stem densities, dense canopies and 

unobstructed lower canopies. 

B.7.vii. Ingraldi (2001) studied northern goshawks 

for 7 years on the Apache-Sitgreaves National 

Forests in east-central Arizona. The study had three 

purposes: (1) estimate adult and post-fledgling 

survival rates; (2) estimate percent of nests active, 

active nests that produce young, primary sex ratio, 

and fledgling per nest; and (3) model the status and 

population trend of northern goshawks on the 

Apache-Sitgreaves National Forests in east-central 

Arizona. 

Vegetation in the study area is typical of the 

Mogollon Rim, dominated by mixed conifer, 

ponderosa pine, white fir, aspen and gamble oak. 

Ingraldi found over the 7-year period, mean territory 

activity rate was 48 percent with a mean failure rate 

of 31 percent. Ten territories produced 52 percent 

of the young. Mean fecundity rate was 46 percent. 

Ingraldi noted occupancy rate was a poor indicator 

of population status while the number of fledglings 

per active nest was a much better indicator of 

population performance. Finally, Ingraldi (2001) 

noted although some territories were attractive for 

nests they were not suitable for producing young. 

B.7.viii. Stephens (2001) studied the wintering 

ecology of northern goshawks for two seasons 

(1998/99 and 1999/2000) in the Uinta Mountains in 

northern Utah. The predominant vegetation in the 

study area included spruce-fir, lodgepole pine, 

ponderosa pine, Douglas-fir and pinyon/juniper 

woodlands. Stephens radio tagged 18 goshawks (7 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 29 
Chapter 3 – Affected Environment and Environmental Consequences 

male and 11 female). Stephens found 40 percent of 

marked males and 90 percent of marked females 

migrated during winter. Most goshawks migrated to 

lower elevation pinyon/juniper woodlands which he 

called an important wintering ground. Goshawks 

also used agricultural areas, sagebrush and 

cottonwood riparian forests during winter. 

Stephens also measured several habitat 

parameters: canopy closure, tree density, tree 

height, tree diameter, sapling density, shrub density 

and slope. Stephens found lodgepole pine and 

mountain fir were selected in higher proportions 

than their availability in the study area. Oak, 

ponderosa pine and lowland riparian were also 

present in higher percentages than in the study 

area. Stephens noted wintering goshawks selected 

forested landscapes with high canopy closure both 

during the day and at night. 

B.7.ix. Bloxton (2002) studied northern goshawks 

from 1996-2000 in managed forest settings in 

western Washington during the breeding season. 

Bloxton looked at prey abundance, space use and 

demography. Eight of the nine territories used to 

assess special use occurred on intensively 

managed private forest lands. Bloxton radio tagged 

29 goshawks and monitored 23 territories to 

determine occupancy and reproductive success. 

Bloxton found weather during La Nina years had a 

significant effect on prey availability, habitat use 

and mortality of goshawks. Bloxton determined blue 

and ruffed grouse, band-tailed pigeons, northern 

flying squirrels, snowshoe hares and Douglas’ tree 

squirrels dominated goshawk diets. 

Bloxton documents goshawks successfully hunting 

in all forest types and successional stages except 

recent clearcuts and shrub/sapling stages. However 

goshawks tended to hunt in stands with larger 

diameter trees even though kills were recorded in 

everything from open 13-year-old regeneration units 

to 200-year-old growth stands. As such there was 

substantial variation among kill sites. 

B.7.x. Finn et al. (2002) studied breeding ecology 

and habitat use by northern goshawks in western 

Washington from 1996 through 1998. Finn et al. 

found 12 of 30 historic sites to be occupied. They 

classified habitat by LANDSAT imagery including 

six forested habitats and three non-forest habitats. 

Finn et al. (2002) noted, goshawks appeared to 

respond to habitat features at a variety of spatial 

scales and habitat configurations. They found that 

landscapes surrounding occupied nest sites were 

dominated by late-seral forest and to a lesser 

degree by mid-seral forest. Nest sites had large 

uniform tree patches. The percent of stand initiation 

cover (trees less than 7 years old) increased as 

spatial scale increased. At nest stands, stand 

initiation cover increased to a maximum of 17 

percent. Finn et al. (2002) found goshawks nested 

in mature forest stands (trees older than 40 years) 

surrounded by late seral forest. Finn et al. (2002) 

also concluded that goshawk needs at large scales 

can be met in a variety of ways that may be 

compatible with the needs of other species or that 

allow managers to balance biological and economic 

objectives. 

B.7.xi. Joy (2002) developed a dynamic model 

aimed at predicting goshawk nesting habitat. The 

study area was the North Kaibab Ranger District in 

Arizona. Joy also assessed the relationship 

between abundance, distribution and demographic 

performance of goshawks and the range of habitat 

conditions supporting the population. Joy (2002) 

stated, “because of the nesting requirements of the 

goshawk, the vegetation types associated with 

nest-tree plots are not likely to be in proportion to 

those observed on the study area outside of the 

nest areas” (p 24). Joy also found the most 

common habitat variables distinguishing goshawk 

territories were the amount and arrangement of 

ponderosa pine, mixed conifer, deciduous trees, 

openings, and overall diversity of vegetation types. 

Joy showed that higher quality goshawk territories 

contained smaller and fewer openings than random 

plots. 

B.7.xii. Drennan and Beier (2003) studied 13 adult 

wintering goshawks for 2 winters (1994-1995 and 

1995-1996) and found most female goshawks 

stayed near their nesting territory while male 

goshawks moved to lower elevation pinyon-juniper 

areas. Wintering male goshawks preyed on cottontailed rabbits and Abert’s squirrels. They also found 

when selecting a foraging site within a home range 

and habitat type, goshawks selected sites in 

moderately dense, mature forests where they could 

use their maneuverability to capture prey. They also 

noted this pattern was consistent during the 

breeding season. 

B.7.xiii. La Sorte et al. (2004) studied habitat 

associations of sympatric red-tailed hawks and 

nothern goshawks at two spatial scales around nest 

sites during the breeding season. The study 

occurred on the Kaibab Platuea in northern Arizona. 

30 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

La Sorte et al. found red-tailed hawk nests were 

located on steep north slopes, containing abundant 

shrubs. Red-tailed hawk nests were also higher in 

the tree than goshawk nests and had less overhead 

cover. Conversly, goshawk nests had higher 

overhead cover, little understory shrubs, and were 

lower in the canopy with no aspect affiliation. The 

investigators concluded that their results were 

consistant with other studies that documented 

goshawks nesting in areas of high canopy closure, 

mature trees and open understories which 

corresponds to the management of a post-fledgling 

family area outlined in Reynolds et al. 1992. 

C. Finally, this review is based on the following 

recent documents, developed since the draft 

supplement to the final environmental impact 

statement was published. 

1. Two papers published in 2005, titled 

“Sampling Considerations for Demographic 

and Habitat Studies of Northern Goshawks” 

and “Patterns of Temporal Variation in 

Goshawk Reproduction and Prey 

Resources.” 

i) Reynolds et al. (2005) 

ii) Salafsky and Reynolds (2005) 

2. Four “in press” papers received by the 

Forest Service in 2005. 

i) Reynolds et al. (in press, a) 

ii) Reynolds and Joy (in press) 

iii) Reynolds et al. (in press, b) 

iv) Wiens et al. (2006) 

3. A recent paper by Greenwald et al. (2005), 

titled “A Review of Northern Goshawk 

Habitat Selection in the Home Range and 

Implications for Forest Management in the 

Western United States” and a response to 

this paper by three of the MRNG primary 

authors. 

i) Greenwald et al. (2005) 

ii) Reynolds et al. (in review) 

Key points from these documents are summarized 

as follows. 

C.1.i. In their paper titled “Sampling Considerations 

for Demographic and Habitat Studies of Northern 

Goshawks,” Reynolds et al. (2005) reported on the 

results of 12 years of goshawk nest monitoring on 

the North Kaibab. Reynolds et al. used markrecapture methodology from 1991-2002 to 

determine distribution, vital rates, abundance, 

fidelity to mate and nest territory, natal and 

breeding dispersal, and habitat occupancy of 

breeding goshawks. The number of known 

breeding territories increased from 37 in 1991 to 

121 in 2002. By 2002, about 95 percent of the 

Kaibab National Forest had been searched. They 

defined a breeding territory as an area exclusively 

occupied by a pair of goshawks during a breeding 

season. Using this method, Reynolds (unpublished 

data) found that paired goshawks had strong site 

fidelity to their breeding territory. They located 

territories using two protocols: systematic foot 

searches for goshawks and their nests and 

broadcast vocalizations from stations along transect 

lines. 

Reynolds et al. (2004) reported that over years, 

goshawks often have alternative nest sites. To 

ensure the best possible results they employed a 

within-territory nest search protocol. Nests were 

“used” if eggs were laid, or eggs were not laid but 

evidence of occupancy was obvious. They found 

that there was large temporal variation in the 

frequency of egg laying, some pairs going 7 years 

between laying events. On average 63 percent of 

the nests were successful. There were 273 

alternate nest sites in 91 territories. Annually 64 

percent of the breeding population used alternate 

nest sites. Sample sizes of 60-80 territories in good 

years and 80-100 territories in bad breeding years 

were necessary to gain adequate estimates. In 

summary, their study showed that, because 

breeding varied temporally and spatially and 

detectability of nonbreeders was low, accurate 

estimates of the numbers of nests and nest location 

greatly depends on the sampling effort. Reynolds et 

al. (2005) recommend a minimum of 8 years of 

searches to adequately sample an area for 

occupancy of breeding territories. 

C.1.ii. Salafsky and Reynolds (2005) studied 

goshawk productivity in relation to prey base 

productivity and abundance in an effort to 

determine if prey availability limited goshawk 

productivity. The study was conducted on the 

Kaibab Plateau in northern Arizona. Their 

objectives were to determine if prey resources limit 

the reproductive rates of goshawks with relatively 

diverse diets, and describe how changes in prey 

populations may influence goshawk productivity. If 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 31 
Chapter 3 – Affected Environment and Environmental Consequences 

prey was limiting then variations in productivity 

should be associated with variations in prey 

abundance. Salafsky and Reynolds (2005) found 

variation in both goshawk productivity and prey 

density across sampling year, with goshawk 

productivity taking a significant decline between 

2000 and 2001 which correlated with significant 

declines in prey density during the same time 

period. Goshawks were found to consume a wide 

variety of prey items 710 from 30 individual prey 

species. Seven species made significant 

contributions to goshawk diets. They found a strong 

positive correlation between total prey density and 

goshawk productivity from 1999-2002. Red squirrel 

was the only prey species found to have a 

significant positive relationship with goshawk 

productivity. Since this species does not hibernate 

it remains available year-around. 

Salafsky and Reynolds (2005) found high temporal 

correlations between goshawk productivity and 

annual prey densities. They state “Therefore it 

appears that goshawk reproduction on the Kaibab 

Plateau responded to inter-annual increases in prey 

density” (p 243). 

C.2.i. In their as yet unpublished paper titled “An 

Ecosystem-Based Conservation Strategy for the 

Northern Goshawk,” Reynolds et al. (in press, a) 

describe the process they used to develop 

Southwestern goshawk conservation strategy1

(SWGS), described the potential for its broad 

application in western forest landscapes, describe 

its compatibility with the restoration of ecological 

forest processes, and summarize implementation. 

The SWGS is based on describing desired habitat 

conditions based on the life history and habitats of 

the northern goshawk, the life histories and habitats 

of its primary prey, and the ecology and dynamics 

of the forests it inhabits. The premise is that a 

conservation strategy that addresses all the stages 

of a species’ life history, the physical and biological 

factors that limit its populations, the members of its 

ecological community, and the special and temporal 

dynamics of the ecosystem it occupies, should be 

robust to failure. They review goshawk life history, 

goshawk limiting factors, goshawk habitat, goshawk 

prey, geographical and annual variation in goshawk 

diets, determine goshawk diets, develop suites of 

important prey species, prey habitats, forest 

 

1 The Southwestern goshawk conservation strategy 

(SWGS) is synonymous with the MRNG.

ecology and synthesis of these components. From 

here they review the development and 

implementation of vegetation structural stages or 

VSS classes. Concerning the implementation of the 

SWGS they note, “Specific management actions 

and the intensity that they are applied should be 

contingent on the differences between the existing 

conditions of a focal area and the desired 

conditions” (Reynolds et al. in press, a, p 18). 

Reynolds et al. (in press, a) also note, “The desired 

forest conditions described in the SWGS resembled 

the historical conditions of southwestern ponderosa 

pine forests described by Pearson (1950) and 

White (1985). These similarities suggest that 

implementing the SWGS would move forests 

toward restoration of presettlement conditions” (p 

21). They also describe the SWGS as a multispecies strategy because it was based on the 

habitats and ecological relationships of many plant 

and animals in the goshawk food web. 

C.2.ii. In a publication titled “Demography of 

Northern Goshawks in Northern Arizona, 1991-

1996,” Reynolds and Joy (in press) document a 

study of 282 goshawk nesting attempts on 107 

territories on the Kaibab Plateau in northern Arizona 

from 1991-1996. As a result of the study they 

report on the distribution and density of breeding 

pairs, inter-annual variations in proportions of pairs 

breeding and reproduction, fledgling sex ratios, 

territory fidelity, and survival of adult goshawks. 

This study presents the first 6 years of a 15-year 

study. 

Reynolds and Joy found that all but 2 of the 107 

territories contained active nests in 1 or more 

breeding seasons, and the annual percentage of 

nests failing did not differ significantly between 

years (14-28 percent). The mean number of 

fledglings produced and successful nests declined 

from the better breeding years of 1991-1993. Of 

282 nesting attempts in which eggs were layed, 46 

(16 percent) were known to have failed. Combining 

years there were 126 females (54.3 percent) and 

106 (45.7 percent) males from 125 broods. 

Because they had surveyed a high percent of the 

national forest and the Grand Canyon National 

Park, Reynolds and Joy were able to determine that 

the 107 known nesting territories comprised about 

73 percent of the potential nesting population in the 

study area. Of the 105 territories that layed eggs 

56 percent contained more than 1 nest, 41 percent 

32 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

more than 2 nests, 12 percent had 3 alternate 

nests, and 4 percent more than 4 alternate nests. 

Annual turnover of adults on territories varied from 

10-40 percent for males and 0-50 percent for 

females. Both male and female breeders showed 

high fidelity to nesting territories. Survival rates for 

males were constant at (0.69) and for females at 

(0.87). They also determined that goshawk 

territories on the Kaibab Plateau are spatially and 

temporally fixed. 

C.2.iii. In their as yet unpublished paper titled “A 

Review and Evaluation of Factors Limiting Northern 

Goshawk Populations,” Reynolds et al. (in press, b) 

conducted a literature review for factors potentially 

limiting goshawk populations. They also evaluated 

the relative importance of the potential limiting 

factors and discussed how and what scale these 

factors operate to limit goshawk populations. 

Reynolds et al. (in press, b) evaluated goshawk 

behavior, food, vegetation composition and 

structure, predators, competitors, disease, and 

weather. They limited their review to factors 

affecting goshawk reproduction and survival. 

Their evaluation of territoriality showed that it can 

constrain breeding populations by limiting the 

number of breeding individuals, however, variations 

within and among landscapes may vary greatly thus 

effecting the spacing of breeders across any given 

landscape. Limiting factors concerning vegetative 

composition were investigated for both the nest and 

foraging areas. Based on their review, they 

determined that structure in nest stands is more 

important than tree species composition. Reynolds 

et al. (in press, b) report that while many studies 

implicitly or explicitly point to mature and old forest 

as important to goshawk occupancy and 

reproduction, none determine whether or how 

goshawk actually use any of the vegetation types or 

seral stages found in circular plots. 

Reynolds et al. (in press, b) challenge the 

conclusions on foraging areas reported by Beier 

and Drennan (1997), Drennan and Beier (2003) and 

Good (1998) by stating, “We believe, however, that 

inference about choice of hunting habitat based on 

foraging/kill site data are equivocal for several 

reasons. First the presumed foraging/kill sites may 

not have been the sites where a goshawk first 

detected the prey... Second, goshawks frequently 

move their prey after killing it... Third, studies using 

indices of prey abundance fail to account for 

variation in bird and mammal detection probabilities 

due to among-plot difference in vegetation 

structure” (Reynolds et al. in press, b, p 13 and 14). 

They conclude that the idealized home range 

contains a diversity of vegetation types and seral 

stages, including small openings, to provide the 

habitats of the goshawk’s diverse suit of prey 

(Reynolds et al. 1992). 

Based on their review of prey availability Reynolds 

et al. (in press, b) conclude that the density, 

physiological condition, and survival of goshawk 

fledglings, juveniles and adults appears to be 

directly related to food availability. Therefore, it is 

an important and ubiquitous factor limiting goshawk 

reproduction and survival. 

In their summary, Reynolds et al. (in press, b) point 

out that no study to their knowledge quantified a 

direct relationship between goshawk survival and 

vegetation composition and structure, either in 

breeding habitats or in winter habitats, although 

some evidence suggests that predation on 

goshawks may be higher in non-forested habitats. 

They also note that considerable evidence suggests 

that vegetative structure at nest sites and foraging 

sites and the abundance and availability of food 

were the primary factors limiting goshawk 

reproduction and survival. The strength of these 

conclusions are likely to depend on factors such as 

the number of species within the prey base, 

whether or not prey populations fluctuate in 

synchrony, spatial variation in composition and 

structure of vegetation and abundances of 

predators and competitors. 

C.2.iv. In their as yet unpublished paper titled 

“Post-fledgling Survival of Northern Goshawks: The 

Effects of Prey Abundance, Weather, and 

Dispersal,” Wiens et al. (2006) investigated postfledgling and post-independence survival of 89 

radio marked juvenile goshawks produced from 48 

nests in northern Arizona from 1998-2001. The 

overall goal was to identify critical periods of postfledgling survival and to determine what ecological 

factors are most strongly limiting to goshawk 

productivity at the level of juvenile survival. 

Specifically they addressed age, gender and cohort 

specific survival rates, the relative importance of 

environmental factors to survival and to estimate 

the importance of fledging and post-independence 

on juvenile survival rates. 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 33 
Chapter 3 – Affected Environment and Environmental Consequences 

Wiens et al. (2006) tracked 41 of 89 juveniles until 

they recovered the radio or found the bird dead. 

They recorded eight mortalities (five females and 

three males) during the fledgling dependency 

period. Based on evidence found at the recovery 

sites, three died from predation or injuries 

attributable to predation, three from starvation and 

two unknown causes. By week 13 they were only 

able to detect 15 of 64 remaining radio-marked 

juveniles. An additional 6 mortalities (4 females 

and 2 males) occurred during the 5-week period 

following independence whereas 10 mortalities (7 

males, 3 females) occurred between weeks 13 and 

40 post-fledgling. A total of 24 hawks were 

recovered dead during the study, with predation 

accounting for 46 percent of the mortality. 

Wiens et al. (2006) concluded that post-fledgling 

survival of juvenile goshawks was consistently high 

among years and most strongly related to fledgling 

age, annual changes in prey abundance, gender 

related difference in body condition. Contrary to 

predictions they found no evidence that heavy 

precipitation affected juvenile survival. 

C.3.i. Greenwald et al. (2005), conducted a 

literature review of all published and unpublished 

North American telemetry-based studies withinhome-range habitat selection by northern 

goshawks. They only considered radio telemetry 

studies of habitat selection because in their words 

“such methodology represents the sole means to 

collect a relatively unbiased sample of locations for 

a wide-ranging predator like the goshawk, allowing 

statistical comparison of habitat use verses 

availability” (p 121). Greenwald et al. (2005), 

reported that 9 of 12 studies demonstrated 

selection for stands with higher canopy closure, 

larger tree size and greater numbers of large trees 

than found in random sites. Selection for stand 

diversity was inconclusive. However they reported 

that, “There was great variation in stand vegetation 

diversity among the studies” (p 123). They further 

noted that most studies found that goshawks 

avoided openings and logged early seral stands. 

They also reported that four studies determined that 

goshawks did not select stands for prey abundance. 

Goshawks in winter continued to select stands with 

higher canopy closure. They cite five studies that 

suggest that timber harvest reduces occupancy. 

They rejected the assumption that foraging 

goshawks use habitat opportunistically. They also 

conclude that food availability was not found to limit 

goshawk productivity in occupied territories. 

Greenwald et al. (2005), concluded by stating, “In 

sum, based on apparent inconsistencies between 

subsequent research and Reynolds et al. (1992), 

we recommend adaptation of the management 

guidelines to incorporate results of numerous 

studies conducted since 1992” (p 128). 

C.3.ii. In this unpublished paper titled, “Habitat 

Conservation of the Northern Goshawk in the 

Southwest United States: Response to Greenwald 

et al. 2005,” three of the primary authors of the 

southwest goshawk management guidelines 

respond to Greenwald et al. (2005). They begin 

with “Here we show that Greenwald’s et al. (2005) 

conclusion derives from misunderstandings of the 

desired habitat conditions described in the MRNG, 

a poor understanding of the ecological factors 

limiting goshawk populations, a failure to 

understand goshawk forest habitat as dynamic 

ecosystems, incomplete reviews of the literature, 

and inclusion of studies with limited samples of 

goshawks” (Reynolds et al. in review, p 1 and 2). 

While Greenwald et al. (2005) insist that mature to 

old-growth forest are necessary for goshawks, 

Reynolds et al. (in review) answer with “The 

literature on prey life histories and habitats 

indicated that mid-aged to old forests were the most 

important habitat for most goshawk prey species 

followed in importance by small open areas 

(Reynolds et al. 1992)... Thus, MRNG desired 

landscapes had as much old forest with small 

interspersed openings as could be sustained” (p 2 

and 3). The mosaic of vegetation structural stages 

(VSS) outlined in the MRNG resemble the pattern 

of presettlement ponderosa pine in which trees 

were strongly aggregated into groups of 3-44 trees 

occupying 0.2-0.3 ha (Cooper 1961, White 1985). 

Tree groups, and occasional individual trees, were 

typically separated by variable-sized, but small 

openings into which roots of the grouped trees 

spread (Pearson 1950). Reynolds et al. (in review) 

further explain their silvicultural and biological 

rationale by addressing the sustainability of old 

forest with small openings, which are similar to the 

patchiness found in presettlement ponderosa pine, 

with lifted canopies, interlocking branches, 

extensive shading, with snags, downed logs and 

woody debris, along with brushy understories. 

Reynolds et al., (in review) point out several studies 

that Greenwald et al. (2005) did not include in their 

literature review (Drennan and Beier 2003 and 

Stephens 2001). They note that there are wide 

habitat differences in goshawk habitat use between 

34 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

dry pinyon-juniper woodlands and mesic coniferous 

rain forests in Alaska. Reynolds et al. (in review) 

conclude, “Such extensive variation in vegetation 

structure (big trees, little trees, no trees; closed 

canopy, open canopy, no canopy) leads us to 

conclude that tree size, canopy cover, canopy 

layers, and woody debris are not always factors 

limiting goshawk populations as posited by 

Greenwald et al. (2005)” (p 6). 

In their 2005 response to Greenwald et al. (2005), 

Reynolds et al. (in review) address the “prey base” 

habitat issue brought up by the former. They state, 

“Greenwald’s et al. (2005) suggestion of 

inadequacy of the MRNG is based on their 

misrepresentations of the desired habitat conditions 

for goshawks and their prey described in the 

MRNG.” Further, “Equating the desired openings 

described in the MRNG to historical clearcuts is 

misleading” (p 7). Greenwald et al. (2005) admit 

openings may benefit ground squirrels, a major item 

in western goshawk diets, and they also ignore 

rabbits as a food source. 

Next, Reynolds et al. (in review) address the 

inadequacies of several studies cited by Greenwald 

et al. (2005). Greenwald et al. did not include all 

radio telemetry studies as they claim (see Younk, 

1996). Also at least 12 studies reviewed by 

Greenwald et al. (2005) included fewer than 10 

radio-tagged goshawks and 1 study included only 2 

birds. Because of the lack of a robust sample size 

in these studies they are unlikely to adequately 

describe all of the habitats used by goshawks. 

Reynolds et al. (in review) then address forest 

structure and prey abundance. Greenwald et al. 

(2005) cite four studies that in their view 

demonstrate that goshawk select for forest structure 

and not for prey abundance. Reynolds et al. (in 

review) point out the potential problems with the 

approach taken in these studies. First is the 

assumption that radio-located goshawks were 

actually hunting when located and not involved in 

some other activity, and that kill sites were indeed 

the spot where the kill was made i.e. goshawks had 

not moved their kill. Reynolds et al. (in review) 

believe that the MRNG provide the best vegetative 

structure giving access to abundant prey. 

Next Reynolds et al. (in review) address the issue 

of close canopy forests introduced by Greenwald et 

al. (2005). Reynolds et al. (in review) point out that 

the five studies cited by Greenwald et al. (2005) 

were not specifically designed to test or determine 

habitat surrounding goshawk nests. Thus, they 

could only hypothesize concerning goshawk habitat 

relationships. 

Reynolds et al. (in review) then point out numerous 

studies relating goshawk reproduction to 

surrounding landscape habitats; La Sorte et al. 

(2004), Joy (2002), Desimone (1997), Maurer 

(2000), Clough (2000), Daw and DeStefano (2001) 

and McGrath et al. (2003). Finally, Greenwald et al. 

(2005) cited Crocker-Bedford’s (1990) 3-year study 

in which he reported significantly lower nest 

occupancy and productivity of goshawks in areas 

that had been only lightly harvested verses those 

areas that had been more heavily harvested. 

However, 15 years of study on the Kaibab Plateau 

has shown that there is great temporal and spatial 

variation in goshawk productivity (Reynolds et al. 

and Reynolds and Joy in press). “While CrockerBedford (1990) concluded that heavier cutting 

reduced occupancy and reproduction compared to 

light cutting, we show... that demonstrating the 

effects of tree cutting on reproduction is not always 

straight forward even with long-term data” 

(Reynolds et al. in review, p 16). 

Therefore, Reynolds et al. (in review) disagree with 

Greenwald’s et al. (2005) statements that, 

“recommendations focusing on increasing prey 

abundance at the expense of forest structure...are 

not likely to increase goshawk occupancy rates.” 

And, “The multiple species, ecosystem approach of 

the MRNG addresses the most ubiquitous factors 

appearing to limit goshawk populations: Food 

abundance, food availability, and suitable nest 

habitat” (Reynolds et al. in review, p 17 and 18). 

Discussion on Literature Review

As stated in Anderson et al. (2004), most biologists 

can agree on managing northern goshawk habitat 

at three spatial scales: the nest, nest stand and 

foraging area. The scientific debate has been stated 

in terms of the degree to which the northern 

goshawk should be considered a habitat specialist, 

requiring large tracts of old-growth forest, closed 

canopies, large trees and, further, that they avoid 

open areas, young stands, edges and areas with 

high vegetation diversity. 

The contrary point of view is that the northern 

goshawk is a habitat generalist capable of utilizing a 

variety of habitats, especially for foraging 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 35 
Chapter 3 – Affected Environment and Environmental Consequences 

(Reynolds, 2004). However, only 1 (southeast 

Alaska) of the 180 documents reviewed by 

Reynolds (2004) showed the northern goshawk 

strictly using old growth. 

Proponents of the goshawk specialist theory cite 

various scientific literature to support their 

arguments as to habitat requirements or habitats 

that are avoided or not used by the northern 

goshawk. 

In support of the contention that goshawks require 

closed canopy (> 40 percent) old-growth forest 

throughout their home range, proponents variously 

cite: Austin 1993, Beier and Drennen 1997, Boal et 

al. 2001, Bright-Smith and Mannan 1994, Drennan 

and Beier 2003, Hargis et al. 1994, Stephens 2001, 

Ward et al. 1992, Patla 1997, Finn 2002, La Sorte 

et al. 2004, Joy 2002, and Ingraldi 2001. 

There appears to be no debate that goshawks will 

use areas of high-canopy closure within their home 

range, especially in the nest stand. One interesting 

anomaly here is silvics of ponderosa pine forests. 

Older ponderosa pine forests, particularly on drier 

sites found in the Southwest, generally do not 

provide high levels of canopy closure due to the 

open nature of their crowns and generous spacing 

of the trees at older ages (150+ years). 

Debate over the amount and extent of old growth or 

whether the northern goshawk is an old-growth 

obligate is substantive. Reynolds (2004), points out 

the wide variety of habitats used by the goshawk for 

nesting and foraging and questions whether all of 

these habitats are replete with old-growth forest. 

Clough (2002), found goshawks nesting in very 

young stands 17 of 19 times. In their review of the 

status of the northern goshawk in the western 

United States, Anderson et al. (2004) concluded, 

“Given the current knowledge of goshawk-habitat 

relationships, it is not scientifically defensible to 

solely use the distribution and abundance of latesuccessional forest as a surrogate measure to infer 

goshawk status, population trend and habitat 

quality” (p 18). 

In support of the contention that goshawks require 

large trees in their home range, proponents cite: 

Austin 1993, Beier and Drennan 1997, Bloxton 

2002, Boal et al. 2001, Good 1998 and Hargis et al. 

1994. 

There appears to be no substantive debate 

concerning the use of large trees in the home range 

of the northern goshawk especially for nesting and 

perching. However, Clough (2002) found 17 of 19 

goshawk nests in open forests with 65 percent of 

the PFA dominated by small sized trees. 

Proponents of the goshawk specialists theory often 

cite literature in support of their arguments that 

northern goshawks select habitats that lack edge, 

vegetation diversity, forest edges, openings in the 

canopy and they specifically do not select habitats 

based on prey abundance as follows: Austin 1993, 

Beier and Drennan 1997, Bloxton 2002, Boal et al.

2001, Bright-Smith and Mannan 1994, Titus et al. 

1996, Fischer 1986, Lapinski 2000, Joy 2002, La 

Sorte et al. 2004, Good 1998, and Drennan and 

Beier 2003. 

Reynolds (2004) points out northern goshawks 

occupy a wide variety of habitats as documented in 

the scientific literature including: ponderosa pine 

with pinyon-juniper woodland stringers, pine-oak 

woodland, ponderosa pine, Douglas-fir western 

hemlock, Douglas-fir, mixed conifer, aspen, 

lodgepole pine, paper birch, beech, hardwoodhemlock, etc. 

Widen (1989), Kenward and Widen (1989), Younk 

and Bechard (1994), as well as Joy (2002), report 

finding that northern goshawks utilize habitats with 

relatively high prey abundance and availability. It 

should also be noted Beier and Drennan (1997), 

Drennan and Beier (2003), and Good (1998), did 

not explain how kill sites were located, therefore, it 

is impossible to tell where the actual taking of prey 

occurred, especially since various methods yield 

various results as to habitat associations, Reynolds 

(2004). 

Kenward (1982), Kennedy (1989), Hargis et al.

(1994), Titus et al. (1994), Younk and Bechard 

(1992) and (1994), and Clough (2002), all reported 

northern goshawks using young stands, forest 

edges and openings. 

Proponents of the goshawk specialist’s theory 

supporting the argument that timber harvesting 

reduces goshawk nest occupancy, reduces 

goshawk nesting density and threatens population 

viability cite: Crocker-Bedford (1990), CrockerBedford (1995), Ward et al. (1992), Patla (1997), 

Finn (2002), La Sorte et al. (2004), Joy (2002), and 

Ingraldi (2001). 

36 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

The North Kaibab Ranger District of the Kaibab 

National Forest has been treating forest stands 

following the management recommendations 

outlined in GTR-RM 217, Reynolds et al. (1992), 

and the Preferred Alternative in the Regional Forest 

Plan Amendment 1996 for the past 7 years (See 

Table 5). During that time, they treated an average 

of 2,719 acres per year averaging 4,994 MBF 

harvested annually. 

Table 5. Timber Harvest on the North Kaibab 

Ranger District of the Kaibab National Forest 

Year Acres Treated Volume-MBF 

1998 1,143 4,855 

1999 7,697 9,137 

2000 4,509 7,968 

2001 3,116 6,631 

2002 1,255 3,838 

2003 620 1,163 

2004 696 1,386 

Totals 19,036 34,960 

Means 2,719 4,994 

During the same period, Joy (2002) reported that 

northern goshawk territory occupancy on the 

Kaibab Plateau remained stable while nesting 

success varied by year. 

Woven into the debate on whether goshawks are 

old-growth, closed-canopy forest obligates or are 

opportunists that use a variety of habitats, are great 

differences in habitats of primary goshawk prey 

species and the necessary entry of goshawks into 

these habitats to capture prey. 

In their review of the pre-1996 literature (Appendix 

H) the NGSC concluded the MRNG provided for the 

foraging needs of the goshawk by providing suitable 

(and sustaining) foraging habitat (40 percent of the 

landscape is mature and old forests, and small 

openings) for both the goshawk and its major prey 

species. 

National Forest Surveys and Monitoring 

National forests in the Southwestern Region have 

been monitoring northern goshawks for over 10 

years. Beginning in 1991, a standardized protocol 

became available for conducting goshawk surveys. 

This protocol included standard procedures for 

timing, intensity and duration of goshawk surveys. 

The tables displayed in Appendix AM summarize 

the data from those surveys. 

The total number of post family-fledgling areas 

(PFAs) within the Southwestern Region has steadily 

increased from 272 in 1991, to 683 in 2004. Over 

that same period, the individual national forests in 

the region monitored an average of 333 PFAs per 

year. 

As reported in Reynolds et al. (2003), northern 

goshawk productivity on many national forests in 

the region was down during the recent drought. The 

summarized information is reported by post familyfledgling area. The post family-fledgling area is 

described on page 13 of the MRNG (Reynolds et al. 

RM GTR 217, August 1992). 

During the 1991 to 2004 time period, volume of 

timber sold and harvested within the Southwestern 

Region has steadily decreased (see Table 6). 

Corresponding monitoring data over the same time 

period in the region shows that the percent of total 

PFAs that produced fledglings, percent of total 

PFAs occupied but didn’t produce, and percent of 

total PFAs with at least one goshawk present has 

also steadily declined. This data trend is consistent 

with Reynolds et al. (2003) as described above. 

Table 6 Regional Timber Harvest Data 

(CCF = Hundred Cubic Feet) 

Year CCF Sold CCF Cut 

1988 392.6 485.2 

1989 357.4 496.9 

1990 305.2 433.2 

1991 282.3 344.1 

1992 163 291.8 

1993 153 190.6 

1994 119.1 115.5 

1995 85.7 99.6 

1996 33.3 46.3 

1997 88.9 83.2 

1998 43.1 34.9 

1999 72 83.7 

2000 68.6 65.4 

2001 81.3 70.5 

2002 65.6 70.9 

Total 2,311.1 2,911.8 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 37 
Chapter 3 – Affected Environment and Environmental Consequences 

It is statistically unsound to draw many conclusions 

on a regional scale from the individual national 

forest’s northern goshawk monitoring data due to a 

number of factors, including: 

1. Forest monitoring protocol was developed 

before recent literature concluded that more 

nest site searches are necessary to 

validate absence or presence (See Boyce, 

et al. 2005). 

2. Variation of data and results among and 

between forests is wide. 

3. There is a wide variety of environmental 

variables unique to many forests which 

have influence over the results. 

4. As stated in Reynolds et al. (2005), recent 

research has indicated that necessary 

sampling efforts to accurately estimate the 

reproductive status of northern goshawks 

indicate that current sampling protocols 

may be insufficient. 

Reynolds et al. (2005) report the difficulty of 

finding and monitoring breeding goshawks 

determined during 14 years of intensive 

mark-recapture study of nesting goshawks 

on 121 territories. This difficulty stems from 

their elusive behavior, their complex forest 

habitats, and their annual frequent use of 

many widely-dispersed alternate nests 

within their breeding territories. Because 

not all goshawks breed every year (only 

breeding goshawks can be detectability 

with reliability), as many as 8 years of 

repeated searching is needed to 

unequivocally classify areas as 

“unoccupied” by territorial breeding 

goshawks (Reynolds et al. 2005). 

Further, alternate goshawks nests can be 

further than 1.5 miles apart and between 

55-76 percent of goshawks laying eggs in a 

given year moved to an alternate nest 

(Reynolds et al. 2005), making the 

monitoring of goshawk reproduction and 

other vital rates difficult. 

A review of the goshawk literature makes it 

apparent that few studies of breeding 

goshawks have been conducted with the 

necessary sampling effort to make 

reasonable comparisons with the densities 

and vital rates reported on the Kaibab 

Plateau (Reynolds and Joy in press, 

Reynolds et al. 2005). 

5. Determining the stability of northern 

goshawk populations, the principal 

objective of a 14-year study of the goshawk 

population on the Kaibab Plateau, has 

proven to be a very complex problem 

because goshawk populations are affected 

not only by the availability of forest habitats 

but also by the availability of food. Each 

species of goshawk prey is, in turn, affected 

by the abundance of their habitats, the 

quality of which varies according to drought 

versus wet periods (Salafsky 2004). 

Summaries and corresponding graphs of monitoring 

data are displayed for each national forest in the 

Southwestern Region beginning in 1991 and ending 

in the 2004 field season in Appendix AM. 

Summary Discussion 

The Preferred Alternative (Alternative G) 

implements “Management Recommendations for 

the Northern Goshawk in the Southwestern United 

States” (RM-217) as supplemented by management 

guidelines for Mexican spotted owls developed in 

response to the “Mexican Spotted Owl Recovery 

Plan.” The recommendations in RM-217 are based 

on a synthesis of published literature and other data 

establishing: 

• In the southwestern United States, 

goshawks utilize a variety of vegetation 

communities including ponderosa pine, 

mixed species, spruce-fir and woodland. 

• Goshawk nest areas, which may include 

more than one nest, contain one or more 

stands of large old trees with a relatively 

dense canopy cover. The size of these nest 

areas has been noted to be approximately 

30 acres. Most goshawks have two to four 

alternate nest areas within their home 

range. Alternate nest areas may be used in 

different years. 

• The post fledging-family area surrounds the 

nest site and typically includes a variety of 

forest types and conditions. It represents an 

area of concentrated use by the goshawk 

38 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

family from the time the young leave the 

nest until they are no longer dependent on 

the adult for food (up to 2 months postfledging). These areas have a variety of 

forest conditions; however, the vegetation 

structure generally resembles that found in 

the nest stands with patches of dense 

trees, developed herbaceous and/or 

shrubby understories. All vegetation 

structures have habitat attributes critical for 

goshawk prey. 

• Goshawks forage in larger areas 

surrounding the nesting areas. These areas 

are approximately 5,400 acres in size. 

There is evidence that goshawks use 

mature and old forest within these areas 

more heavily than they use other seral 

stages. However, goshawks use available 

habitats (openings) opportunistically which 

suggests the choice of foraging habitat by 

goshawks may be as closely tied to prey 

availability as to habitat structure and 

composition. 

While there is general agreement among scientists 

on the above points, a handful of papers have been 

cited as evidence that goshawks require foraging 

areas containing large, unbroken blocks of old 

forest. Primary findings in these papers are detailed 

above in the section titled “Review of Pertinent 

Information Concerning Habitat Management for 

the Northern Goshawk.” 

Some of these papers were cited in the Arizona and 

New Mexico game agencies’ response to the DEIS. 

That response used the papers, in part, as the 

basis for an alternative set of recommendations for 

northern goshawk management that placed more 

emphasis on large blocks of old forest. Those 

alternative recommendations are represented in 

this supplement to the FEIS as Alternative D. 

Recommendations for nesting and post-fledging 

areas in Alternative D are virtually identical to the 

recommendations in Alternative G. Major 

differences between the alternatives focus on the 

composition and management of foraging areas. 

Highlights include: 

• Alternative G would manage forested 

portions of foraging areas on the equivalent 

of a 200-year rotation. Alternative D would 

use the equivalent of a 250-year rotation. 

• Both alternatives would require 20 percent 

of the foraging area be composed of VSS 

6. Alternative G would count all patches of 

old-growth, no matter how small, in 

determining whether the 20 percent was 

being maintained. Alternative D would 

require that the VSS 6 be maintained in 

larger blocks (> 100 acres). 

• Alternative G calls for uneven-aged 

management in the resulting forest 

structure. Alternative D allows up to 20 

percent of the landscape to have evenaged management with the remaining 

areas using uneven-aged management. 

The recommendations embodied in Alternative D 

and G reflect different interpretations of the 

literature. As such, some have characterized this 

difference as a debate about whether the goshawk 

is a habitat generalist or an old forest specialist. 

Actually, the interpretations are not that different. 

The two sets of recommendations for nesting areas 

and post-fledging areas are virtually identical. For 

foraging areas, both recognize the need for large 

areas containing a variety of vegetation types but 

including an old forest component. The difference 

between these viewpoints focuses primarily on the 

question: How much old forest is required and how 

should old forest be distributed across the foraging 

areas? 

The available scientific information does not provide 

direct answers to this question. It should be noted 

that of the initial 11 papers reviewed in this 

supplement in support of the opposing scientific 

view (documents A.7.) only 2 (Hargis et al. 1994; 

Woodbridge and Detrich 1994) of the 11 documents 

were published in peer-reviewed journals. The other 

nine consisted of unpublished progress reports to 

granting agencies (Beier 1994; Mannan and Smith 

1993; Snyder 1995), unpublished agency reports 

(Crocker-Bedford 1994; Titus et al. 1994), an 

unpublished thesis (Austin 1993), and a published, 

but not peer-reviewed, abstract (Crocker-Bedford 

1995). 

Recommendations in Alternative G are based on 

RM-217 which synthesized studies of: (1) 

knowledge of the life-history, ecology, behavior, and 

diets of goshawks; (2) vegetative composition of 

sites at which goshawks were actually detected 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 39 
Chapter 3 – Affected Environment and Environmental Consequences 

during foraging activities; and (3) the natural history 

and habitat of 14 important goshawk prey species. 

The recommendations embodied in Alternative D 

were based on studies that indicated significant 

goshawk use of old forest for foraging. Furthermore, 

it should be noted that these studies do not provide 

information that could be directly used to determine 

necessary amounts and distribution of old forest in 

foraging areas. The recommendations in Alternative 

D represent a different set of working hypotheses 

concerning the need for old growth within foraging 

areas. The studies cited in the joint Arizona and 

New Mexico game agencies’ letter, along with other 

studies cited in the legal challenge to the FEIS, 

could also be considered consistent with the 

recommendations in RM-217 as detailed in section 

B.2. 

In summary, there is some difference of opinion 

concerning appropriate amounts and distribution of 

closed canopy old forest in goshawk foraging areas. 

The Preferred Alternative (Alternative G) continues 

to rely on the scientific information synthesized in 

RM-217 for the following reasons: 

• None of the available scientific information 

directly answers the question of how much 

old forest is needed in goshawk foraging 

areas and how should it be distributed. RM217 represents a reasonable interpretation 

of that literature based on an extensive 

review of scientific literature. While 

recognizing the importance of mature and 

old forest to goshawks and many of their 

prey, the actual recommended amount of 

mature and old forests in RM-217 was 

determined by the growth dynamics of 

forests. Based on forest dynamics, the 

maximum amount of mature and old forest 

(to 240 years) in a sustaining forest 

landscape is 40 percent (20 percent in 

mature, 20 percent in old forest) (Reynolds 

et al. 1992). 

• RM-217 brings together information on 

habitat used by goshawks and habitat used 

by their principle prey species and forest 

dynamics. Thus, it is a systems-based 

recommendation that attempts to provide 

for both goshawks and the faunal 

community that supports them, all within 

constraints imposed by the dominant 

vegetation comprising a forest type. 

• The recommendations in RM-217 would 

result in large-scale forest composition and 

structure that is consistent with our 

knowledge of the historical range of 

variability of the forests in the Southwest. 

Such forest structure could be reliably 

sustained over time. Forest composition 

and structure resulting from the 

recommendations contained in Alternative 

D would be much more difficult to sustain. 

Proposed Listing of Northern 

Goshawk Under the Endangered Species Act 

On June 29, 1998, the U.S. Fish and Wildlife 

Service (USFWS) announced a 12-month finding 

on a petition to list the northern goshawk in the 

contiguous United States west of the 100th meridian 

under the Endangered Species Act, as amended. 

After review of all available scientific and 

commercial information, the USWFS found that 

listing the population was not warranted (63 FR 

35183) (Appendix K). 

The conclusions on which the USFWS based its 

finding are relevant to the discussion here. In 

announcing its finding, the USFWS stated that it 

based its finding on the following conclusions: 

1. While forest management (i.e., timber 

harvest and fire exclusion) has changed the 

vegetation characteristics throughout much 

of the western United States, the goshawk 

continues to be well-distributed throughout 

its historic range. 

2. The USFWS found no evidence to 

conclude that the goshawk population is 

declining in the western United States, that 

habitat is limiting the overall population, that 

there are any significant areas of 

extirpation, or that a significant curtailment 

of the species’ habitat or range is occurring. 

3. The petition contended the goshawk is 

dependent on large, unbroken tracts of old 

growth and mature forest and asserted that 

declines in such forests were placing the 

species in danger of extinction. However, 

neither the petition nor other information 

available to the USFWS supported this 

claim. 

40 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

4. The USFWS “found that while goshawks 

frequently use stands of old growth and 

mature forest for nesting, overall the 

species appears to be a forest habitat 

generalist in terms of the variety and age 

classes of forest types it uses to meet its 

life history requirements” (63 FR 35184). 

Data Quality Act Petition on 

Northern Goshawk Science 

On January 17, 2003, a petition to correct 

information disseminated by the USDA Forest 

Service, namely the “Management 

Recommendations for the Northern Goshawk in the 

Southwestern United States” (RM-217), was filed 

on behalf of four requesters (Coalition of Arizona 

and New Mexico Counties, Northern Arizona 

Loggers Association, Washington Contract Loggers 

Association, and William K. Olsen (primary 

contact)). The petition addressed alleged multiple 

information quality violations and errors in RM-217 

and attempted to display the errors and violations 

were of such significance and magnitude that 

corrections alone were not adequate, and 

withdrawal of RM-217 was the only appropriate 

remedy. This petition was one of five requests for 

correction regarding the northern goshawk filed 

under the United States Department of Agriculture 

(USDA) Information Quality Act Guidelines and 

Data Quality Act (DQA) (Public Law 106-554 §515). 

The petition alleged violations of the science 

supporting such topics as nest area size, quantity 

and stand structure, post-fledging family areas, 

canopy cover, goshawk prey species and desired 

foraging area conditions, vegetative structural 

stage, as well as others. 

The petition provided comment on the literature 

cited within RM-217. In addition, it listed an 

additional 12 references used in formulation of the 

petition. Only the USFWS 1998 finding on the listing 

of the northern goshawk dealt directly with the 

species. Other papers referenced in the petition 

addressed topics such as silviculture, probability 

and statistics, and songbirds. 

On July 25, 2003, following a review of the 

information challenged in the request (petition), the 

Agency found no significant errors requiring 

substantive changes to RM-217. The review did 

discover eight minor errors. None of the errors 

affected the desired forest conditions or the specific 

management recommendations. In one of these 

errors, RM-217 misquoted a single reference. The 

misquote did not change or influence the outcome 

of the management recommendations. 

The January 17, 2003, request to retract (withdraw) 

RM-217 was denied because no significant errors 

were found and no substantive changes were 

needed. An erratum was distributed with the 

publication that corrected the errors. 

Following this determination, a September 4, 2003, 

Request for Reconsideration of the January 17, 

2003, petition was filed under United States 

Department of Agriculture (USDA) Information 

Quality Act Guidelines and Data Quality Act (DQA) 

(Public Law 106-554 §515) on behalf of the same 

four requesters. The request primarily addressed 

perceived procedural errors in the review process, 

with additional comment on the topics displayed in 

the original petition. 

The USDA convened a panel to review the Request 

for Reconsideration even though RM-217 is 

considered non-influential information by the Forest 

Service. The panel consisted of three participants—

one each from the Natural Resources Conservation 

Service, Food Safety Inspection Service, and 

Forest Service. 

Following careful examination and thoughtful review 

of the Request for Reconsideration, the panel 

affirmed the Forest Service response and found no 

compelling evidence to support retraction or 

amendment of the original July 25, 2003, Agency 

response. The panel determined that the initial 

Agency response was conducted with a great deal 

of care and due diligence, resulting in identification 

of eight technical errors unrelated to the request for 

reconsideration, which the Agency corrected. In 

addition, an extensive scientific review was 

conducted by the Agency in examination of the 

claims of the requester. 

The panel found that RM-217 was the product of 

extensive peer review in the scientific community 

qualified to produce the specified data and 

recommendations. 

Following a request by the Coalition of Arizona and 

New Mexico Counties, the Data Quality Act Petition 

and Request for Reconsideration were reviewed for 

the presentation of new information (science) 

related to the northern goshawk. 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 41 
Chapter 3 – Affected Environment and Environmental Consequences 

The review found no new information was 

presented within the DQA petition that had not been 

already integrated into the discussion. The review 

panel found, and documented in its January 8, 

2004, correspondence that the “request was 

developed as a surrogate ‘peer comment’ on the 

overall document.” [RM-217] The panel continued 

by stating, “The request was also based upon a 

directed policy outcome rather than identifying a 

clear informational deficiency.” Subsequent review 

of literature used in this supplement verified that no 

new information was displayed in the petition that 

has not already been integrated herein. 

Threatened and Endangered Species, 

Critical Habitat and Section 7(a)(2) 

Consultation of the ESA 

Listed Species and Critical Habitat 

The number of species listed as threatened or 

endangered and the number of species with 

designated critical habitat that occur in the USDA 

Forest Service’s Southwestern Region has changed 

over time. Changes have occurred for several 

reasons: new listings and delistings, litigation 

supporting listings, and litigation challenging the 

validity of listings. For example, the peregrine falcon 

was delisted, the Chiricahua leopard fog was listed, 

and designated critical habitat for the loach minnow, 

spikedace and cactus ferruginous pygmy owl was 

designated, withdrawn and re-designated, and as a 

result of litigation the designated population 

segments of gray wolves was rendered invalid. 

Currently there are 30 endangered and 15 

threatened species, 2 proposed species, 13 

designated critical habitats and 3 proposed critical 

habitats, 3 experimental populations, 1 proposed 

experimental population, and 10 candidate species 

in the Southwestern Region (Table 7). 

Table 7. Federally Listed, Proposed, and Candidate Species, and Designated or Proposed Critical 

Habitats in the Southwestern Region 

Common Name Scientific Name Federal Status Critical 

Habitat 

MAMMALS 

Black-footed ferret Mustela nigripes Endangered No 

Black-tailed prairie dog Cynomys ludovicianus Candidate NA 

Jaguar Panthera onca Endangered No 

Lesser long-nosed bat Leptonycteris curasoae 

verbabuenae 

Endangered No 

Mexican gray wolf Canus lupus Experimental nonessential NA 

Mexican long-nosed bat Leptonycteris nivalis Endangered No 

Mount Graham red squirrel 

Critical Habitat 

Tamiasciurus hudsonicus 

grahamensis 

Endangered 

Designated 

Yes 

Ocelot Leopardus (=Felix) pardalis) Endangered No 

BIRDS 

Bald eagle Haliaeetus leucocephalus Threatened No 

Cactus ferruginous pygmy owl Glaucidium brasilianum cactorum Endangered Yes, but 

none in 

Action Area 

California condor Gymnogyps californianus Experimental nonessential NA 

Least tern (interior pop.) Sterna antillarum Endangered No 

Mexican spotted owl 

Critical Habitat 

Strix occidentalis lucida Threatened 

Proposed 

Proposed 

42 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

Common Name Scientific Name Federal Status Critical 

Habitat 

Northern aplomado falcon Falco femoralis septentrionalis Endangered 

Proposed 

Experimental nonessential 

No 

Southwestern willow flycatcher Empidonax traillii extimus Endangered No 

Yellow-billed cuckoo Coccyzus americanus Candidate NA 

Yuma Clapper rail Rallus longirostris yumanensis Endangered No 

FISH 

Apache trout Oncorhynchus apache Threatened No 

Arkansas River shiner 

(Canadian R. pop. only) 

 

Critical Habitat 

Notropis girardi Threatened 

Designated 

Yes 

Chihuahua Chub Gila nigrescens Threatened No 

Colorado Pikeminnow 

Critical Habitat 

Ptychocheilus lucius Endangered 

Designated 

Yes 

Colorado Pikeminnow Ptychocheilus lucius Experimental nonessential NA 

Desert pupfish 

Critical Habitat 

Cyprinodan macularius macularius Endangered 

Designated 

Yes 

Gila chub 

Proposed Critical Habitat 

Gila intermedia Proposed 

Endangered 

Proposed 

Proposed 

Gila topminnow Poeciliopsis occidentalis Endangered No 

Gila trout Oncorhynchus gilae Endangered No 

Little Colorado Spinedace 

Critical Habitat 

Lepidomeda vittata Threatened 

Designated 

Yes 

Loach minnow 

Critical Habitat 

Tiaroga cobitis Threatened 

Designated 

Yes 

Razorback sucker 

Critical Habitat 

Xyrauchen texanus Endangered 

Designated 

Yes 

Rio Grande silvery minnow 

Critical Habitat 

Hybognathus amarus Endangered 

Designated 

Yes 

Sonora chub 

Critical Habitat 

Gila ditaenia Threatened 

Designated 

Yes 

Spikedace 

Critical Habitat 

Medu fulgida Threatened 

Designated 

Yes 

Yaqui catfish 

Critical Habitat 

Ictalurus pricei Threatened 

Designated 

Yes 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 43 
Chapter 3 – Affected Environment and Environmental Consequences 

Common Name Scientific Name Federal Status Critical 

Habitat 

Yaqui chub 

Critical Habitat 

Gila pururea Endangered 

Designated 

Yes 

Zuni bluehead sucker Castostomus discobolus yarrowi Candidate NA 

AMPHIBIANS/REPTILES 

Boreal Toad Bufo boreas Candidate NA 

Chiricahua leopard frog Rana chiricahuensis Threatened No 

New Mexican ridge-nosed 

rattlesnake 

Crotalus willardi obscurus Threatened No 

Sonora tiger salamander Ambystoma tigrinum stebbinsi Endangered No 

INVERTEBRATES 

Alamosa springsnail Pseudotryonia alamosae Endangered No 

Gila springsnail Pyrgulopsis gilae Candidate NA 

Huachuca springsnail Pyrgulopsis thomsponi Candidate NA 

New Mexico springsnail Pyrgulopsis thermalis Candidate NA 

Sacramento Mountains 

checkerspot butterfly 

Proposed Critical Habitat 

Euphydryas anicia cloudcrofti Proposed 

Endangered 

Proposed 

Proposed 

Stephan’s riffle beetle Heterelmis stephani Candidate NA 

Three forks springsnail Pyrgulopsis trivialis Candidate NA 

PLANTS 

Arizona agave Agave arizonica Endangered No 

Arizona cliff-rose Purshia (=Cowania) subintegra Endangered No 

Arizona hedgehog cactus Echinocereus triglochidiatus var. 

arizonicus 

Endangered No 

Canelo hills ladies’-tresses Spiranthes delitescens Endangered No 

Fickeisen plains cactus Pediocactus peeblesianus var. 

fickeiseniae 

Candidate NA 

Holy ghost ipomopsis Ipomopsis sancti-spiritus Endangered No 

Huachuca water umbel 

Critical Habitat 

Lilaeopsis schaffneriana ssp. 

recurva

Endangered 

Designated 

Yes 

Kuenzler hedgehog cactus Echinocereus fendleri var. kuenzleri Endangered No 

Pima pineapple cactus Coryphantha scheeri var. 

robustispina 

Endangered No 

Sacramento Mountains thistle Cirsium vinaceum Threatened No 

Sacramento prickly poppy Argemone pleiacantha spp. 

Pinnatiseca 

Endangered No 

San Francisco Peaks groundsel 

Critical Habitat 

Senecio franciscanus Threatened 

Designated 

Yes 

Todsen’s pennyroyal Hedeoma todsenii Endangered Yes, but 

none in the 

Region 

Zuni fleabane Erigeron Rhizomatus Threatened No 

44 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Chapter 3 – Affected Environment and Environmental Consequences 

Endangered Species Act Consultations 

The current 11 national forests land and resource 

management plans (LRMPs), as amended, are 

covered by numerous Endangered Species Act 

(ESA) Section 7 consultations. Refer to the 

following: 

LRMP Consultations 

There have been 6 formal ESA § 7 consultations in 

the region, covering each of the 11 LRMPs and 

their amendments. These include: 

1. The initial consultation on each LRMP in 

the region (Table 8). 

2. The November 25, 1996, jeopardy and 

adverse critical habitat modification 

biological opinion (BO) on the existing 

LRMPs for the Mexican spotted owl (U.S. 

Fish and Wildlife Service (FWS) 1996; 

#000032 RO). 

3. The November 25, 1996, non-jeopardy and 

no adverse critical habitat modification BO 

on the 1996 Regional LRMP Amendment to 

the region’s LRMPs for the Mexican spotted 

owl (U.S. Fish and Wildlife Service 1996b; 

000031RO). 

4. The December 19, 1997, non-jeopardy and 

no adverse critical habitat modification 

BO/Conference Opinion (CO) for all 

federally listed or proposed species and 

designated or proposed critical habitats 

other than the Mexican spotted owl, which 

included what has become known as the 

“Seven Species Direction” (U.S. Fish and 

Wildlife Service 1997; 000087RO). 

5. The January 17, 2003, non-jeopardy BO on 

the proposed implementation rate for the 

grazing Standards and Guidelines (S&Gs) 

(U.S. Fish and Wildlife Service 2003; 

000031RO). 

6. The June 10, 2005, Programmatic 

Biological and Conference Opinion on the 

continued implementation of the 11 national 

forest LRMPs as amended (U.S. Fish and 

Wildlife Service 2005; 2-22-03-F-366). 

Each of these consultations is discussed 

below. 

Initial Consultation on Each 

National Forest LRMP in the Region 

The LRMPs for the 11 national forests in the region 

were developed from 1985 to 1988 and each 

national forest prepared a biological evaluation (BE) 

for its LRMP. Consultation was done for all “may 

affect” determinations for the species and critical 

habitats that were federally listed or proposed when 

the LRMPs were developed. The FWS issued a 

Biological Opinion and Conference Opinion on each 

LRMP between 1985 and 1987, all with 

non-jeopardy/no adverse critical habitat 

modification opinions (Table 8). 

Table 8. LRMP Consultations for the 11 National Forest in the Southwestern Region

National Forest LRMP Approval Date Consultation Date 

(FWS Consultation No.) 

Apache-Sitgreaves October 1987 May 6, 1986 (No. 2-21-83-F-016) 

Carson October 1986 September 2, 1985 

Cibola July 1985 February 13, 1985 

Coconino August 1987 December 1986

Coronado August 1986 December 6, 1985 

Gila November 1986 October 4, 1985 (No. 2/ES-SE 000087RO) 

Kaibab April 1988 February 27, 1987 

Lincoln October 1986 July 19, 1985 (No. 2-22-83-F-032) 

Prescott August 1987 March 4, 1986 (No. 2-21-83020) 

Santa Fe September 1987 August 11, 1986 (No. 2-22-86-F-043) 

Tonto October 1985 July 26, 1985 (No. 2-21-83-F-13) 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 45
Chapter 3 – Affected Environment and Environmental Consequences 

46 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 

Jeopardy Biological Opinion 

on the Existing LRMPs for the 

Mexican Spotted Owl and Critical Habitat 

After the Mexican spotted owl was proposed on 

November 4, 1991, and listed as threatened on 

March 16, 1993, the Forest Service began 

conferencing and consultations on site-specific 

projects. The Forest Service initiated informal 

consultation on the Mexican spotted owl and critical 

habitat for its existing LRMPs on September 6, 

1995. After submitting the biological assessment on 

September 22, 1995, the Forest Service and FWS 

met five times in October 1995, to discuss 

additional information needs. The Forest Service 

submitted additional information and formal 

consultation was initiated on November 9, 1995. A 

jeopardy and adverse critical habitat modification 

BO for the existing LRMPs was issued on 

November 25, 1997, but a non-jeopardy/no adverse 

modification BO issued the same day for the 

amended LRMPs rendered this consultation moot 

(see below). 

Non-Jeopardy Biological Opinion 

on the Amended LRMPs for the 

Mexican Spotted Owl and Critical Habitat 

The Forest Service, in cooperation with the FWS 

and with input from the Mexican Spotted Owl 

Recovery Team, amended the Standards & 

Guidelines (S&Gs) of the existing LRMPs to 

conform to the management recommendations in 

the “Mexican Spotted Owl Recovery Plan.” The 

amended S&Gs were incorporated into the region’s 

11 LRMPs on June 5, 1996. 

On July 14, 1995, the Forest Service submitted a 

BA and requested formal consultation on 

Alternative G in the “Draft Environmental Impact 

Statement – Amendment of LRMPs.” On October 

10, 1995, the Forest Service submitted the 

“Supplemental Biological Assessment - 

Environmental Impact Statement Amending the 

LRMPs to Incorporate Standards and Guidelines for 

the Mexican Spotted Owl and Northern Goshawk” 

and additional data and information. The FWS 

issued a non-jeopardy/no adverse modification BO 

on the region-wide amendment on November 25, 

1997. 

Non-jeopardy Biological Opinion on the 

Amended LRMPs for Federally Listed Species 

Other Than the Mexican Spotted Owl 

In January 1996, the Forest Service and FWS 

signed an agreement on procedures for 

consultation on the region’s 11 LRMPs for all listed 

and proposed species and critical habitats (except 

the Mexican spotted owl and critical habitat, which 

were covered in two separate BOs described above). 

The Forest Service requested initiation of formal 

consultation/conferencing on May 15, 1996. The 

FWS sent a draft BO/CO to the Forest Service on 

September 18, 1997, and issued a final nonjeopardy/no adverse modification BO/CO on 

December 19, 1997. 

Consultation on the Proposed 

Implementation Rate for the Grazing Activities 

The June 1996, region-wide LRMP amendment 

contained livestock grazing S&Gs that are applicable 

in Mexican spotted owl nesting and foraging habitat. 

The Forest Service prepared a BA and requested reinitiation of consultation on November 7, 2002. A 

request for formal consultation was sent to FWS on 

November 7, 2002. The FWS issued its non-jeopardy 

BO on January 15, 2003. 

Most Recent LRMP Consultation 

In February 2003, the Forest Service and FWS 

began discussions about the continued relevance of 

the existing LRMP consultations. In early April 2003, 

the Forest Service re-initiated consultation on the 11 

LRMPs and the 1996 region-wide LRMP 

amendment. 

On June 2, 2003, the Forest Service and FWS 

completed a consultation agreement for the 2003 

regional LRMP consultation. On June 4, 2003, the 

FWS concurred with the list of species to be 

considered in the consultation. The Forest Service 

completed a biological assessment on the continued 

implementation of the 11 national forest LRMPs as 

amended on April 8, 2004. On June 10, 2005, the 

FWS completed the programmatic biological and 

conference opinion on the continued implementation 

of the 11 national forest LRMPs, as amended. 

Consultation Conclusion 

The preferred alternative is to implement Alternative 

G, as described in the “Final Environmental Impact 

Statement for Amendment of Forest Plans” 

(November 1995) and the “Final Supplement to the 

Final Environmental Impact Statement for 

Amendment of Forest Plans in Arizona and New 

Mexico.” This alternative is, in effect, a continuation 

of current forest plan direction related to the northern 

goshawk, Mexican spotted owl, and old growth. The 

scope of this action includes all 11 Southwestern 

Region national forests in Arizona and New Mexico 
Chapter 3 – Affected Environment and Environmental Consequences 

and is considered to have a short term (5 to 10 

years) lifespan. Each of the region’s forest plans 

are scheduled for revision beginning in 2005. 

Alternative G was developed to respond to the 

Mexican Spotted Owl Recovery Plan. It was 

developed in collaboration with the U.S. Fish and 

Wildlife Service (including a recovery team 

member). Standards and guidelines for the northern 

goshawk were developed in early May 1995, and 

considered all known information from the Goshawk 

Interagency Implementation Team 

recommendations, the joint Arizona Game and Fish 

Department and New Mexico Department of Game 

and Fish letter that responded to the draft, and 

experience gained during implementation of the 

interim direction. 

The Agency has assessed the need for section 7 

consultation on the current SFEIS for the northern 

goshawk and concluded that the current section 7 

consultation that applies to the 11 national forest 

land and resource management plans and the 

regional amendment June 5, 1996, are unaffected 

by and provide section 7 coverage for the current 

northern goshawk SFEIS. 

On July 15, 2005, the Agency sent a letter to the 

U.S. Fish and Wildlife Service requesting validation 

of the section 7 assessment. On September 1, 

2005, the Agency received a reply to its request 

validating out assessment of the need for section 7 

review of the NGH SFEIS. The USFWS stated, “We 

agree that selecting Alternative G results in no 

change in management direction for all land and 

resource management plans for all 11 national 

forests and grasslands in the Southwestern Region. 

Further, we also agree with your assessment that 

section 7 consultation is not needed on the 

supplemental Final EIS because the affects to listed 

species from Alternative G (i.e. 1996 Regional Plan 

amendments) have already been addressed in the 

Service’s recent June 10, 2005, Biological Opinion.”

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 47
Supplemental Consultation and Coordination

Preparers and Contributors 

The Forest Service consulted the following individuals, Federal, State, and local agencies, tribes 

and non-Forest Service persons during development of this supplement to the final environmental 

impact statement: 

Interdisciplinary Team Members 

Douglas A. Boyce, Jr., Alaska Issues Coordinator, USDA Forest Service, Pacific Northwest 

Research Station, Forest Sciences Laboratory, Juneau, AK 

Regis Cassidy, Regional Silviculturist, USDA Forest Service, Southwestern Region, 

Albuquerque, NM 

Peter Gaulke, Regional Environmental Coordinator, USDA Forest Service, Southwestern 

Region, Albuquerque, NM 

Russel T. Graham, Research Forester, USDA Forest Service, Intermountain Research Station, 

Moscow, ID 

Richard Holthausen, National Wildlife Ecologist, USDA Forest Service, Watershed, Fish, 

Wildlife, Air and Rare Plants, Flagstaff, AZ 

Patrick L. Jackson, Appeals and Litigation Coordinator, USDA Forest Service, Southwestern 

Region, Albuquerque, NM 

Keith Menasco, Wildlife Biologist, T.E.A.M.S., USDA Forest Service, Pacific Southwest 

Region, Flagstaff, AZ 

Wally Murphy, Regional Threatened and Endangered Species Program Coordinator, USDA 

Forest Service, Southwestern Region, Albuquerque, NM 

Richard T. Reynolds, Research Wildlife Biologist, USDA Forest Service, Rocky Mountain 

Region, Fort Collins, CO 

Rita Skinner, Assistant Regional Environmental Coordinator, USDA Forest Service, 

Southwestern Region, Albuquerque, NM 

Lou Woltering, Deputy Director of Wildlife, Fisheries and Rare Plants, USDA Forest Service, 

Southwestern Region, Albuquerque, NM 

List of Agencies, Organizations and Persons 

to Whom Copies of the Supplement to the FEIS Were Sent 

This supplement to the final environmental impact statement has been distributed to individuals 

who specifically requested a copy of the document. In addition, copies have been sent to the 

following Federal agencies, federally recognized tribes, State and local governments, and 

organizations representing a wide range of views regarding the management of national forests in 

the Southwestern Region of the USDA Forest Service. 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 49
Supplemental Consultation and Coordination 

50 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 

Federal Agencies 

U.S. EPA, Region IX, San Francisco, CA 

Fort Apache Agency, Bureau of Indian Affairs, Whiteriver, AZ 

U.S. Bureau of Land Management, Roswell, NM 

U.S. Fish & Wildlife Service, Flagstaff, AZ 

U.S. Fish & Wildlife Service, Phoenix, AZ 

U.S. Fish & Wildlife Service, Regional Office, Albuquerque, NM 

National Park Service, Washington, DC 

Rocky Mountain Forest Range Experimental Station, Flagstaff, AZ 

Federal Highway Administration – CFLHD, Lakewood, CO 

Natural Resources Conservation Service, Alamogordo, NM 

U.S. Fish & Wildlife Service, Southwestern Region, Albuquerque, NM 

Advisory Council on Historic Preservation, Washington, DC 

USDA APHIS PPD/EAD, Riverdale, MD 

Rural Utilities Service, Washington, DC 

USDA, Natural Resources Conservation Service, Washington, DC 

USDA, National Agricultural Library, Beltsville, MD 

Bureau of Land Management, New Mexico State Office, Santa Fe, NM 

National Marine Fisheries Service, Long Beach, CA 

Deputy Assistant Secretary of Defense (E), Arlington, VA 

U.S. Air Force, Environment, Safety, and Occupational Health, Washington, DC 

Army Corps of Engineers, Dallas, TX 

U.S. Navy, Environmental Protection Division, Washington, DC 

U.S. Environmental Protection Agency, Washington, DC 

U.S. Environmental Protection Agency, Dallas, TX 

U.S. Department of the Interior, Washington, DC 

National Park Service, Lakewood, CO 

U.S. Coast Guard, Marine Environment and Protection Division, Washington, DC 

Federal Aviation Administration, Fort Worth, TX 

Federal Highway Administration, Olympia Fields, IL 

Tribal 

Gila River Indian Community, Sacaton, AZ 

Ramah Navajo Chapter, Ramah, NM 

San Carlos Apache Tribe, San Carlos, AZ 

Tohono O'Odham Nation, Sells, AZ 

Tonto Apache Tribal Council, Payson, AZ 
Supplemental Consultation and Coordination 

Mescalero Apache Tribe, Div. of RM&P, Mescalero, NM 

Five Sandoval Pueblos, Inc., Bernalillo, NM 

White Mountain Apache Tribe, Outdoor Rec, Whiteriver, AZ 

Ysleta del Sur Pueblo, El Paso, TX 

Southern Ute Tribe, Ignacio, CO 

Pueblo of San Juan, San Juan Pueblo, NM 

Pueblo of Taos, Taos, NM 

Pueblo of Zuni, Zuni, NM 

Kaibab Paiute Tribal Council, Fredonia, AZ 

Pueblo of San Felipe, San Felipe Pueblo, NM 

Cocopah Indian Tribe, Somerton, AZ 

Havasupai Tribal Council, Supai, AZ 

Pueblo of Laguna, Laguna Pueblo, NM 

Colorado River Indian Tribe, Parker, AZ 

Pueblo of Jemez, Jemez Pueblo, NM 

Pueblo of Santa Clara, Espanola, NM 

Hualapai Tribe, Peach Springs, AZ 

Chairman Ute Mountain Ute Tribe, Towaoc, CO 

Quechan Indian Tribe, Yuma, AZ 

San Juan So. Paiute Tribe, Tuba City, AZ 

Ak-Chin Indian Community, Maricopa, AZ 

Pueblo of Isleta, Isleta Pueblo, NM 

Navajo Nation, Window Rock, AZ 

White Mountain Apache Tribe, Whiteriver, AZ 

Mohave-Apache, Fountain Hills, AZ 

Pueblo of Zia, Zia Pueblo, NM 

Pueblo of Picuris, Penasco, NM 

Yavapai-Prescott Tribe, Prescott, AZ 

Governor, Pueblo of Cochiti, Cochiti Pueblo, NM 

Eight Northern Indian Pueblo Council, San Juan Pueblo, NM 

Pueblo of San Idelfonso, Santa Fe, NM 

Mescalero Apache Tribe, Mescalero, NM 

Pueblo of Santa Ana, Bernalillo, NM 

Pueblo of Sandia, Bernalillo, NM 

Pueblo of Nambe, Santa Fe, NM 

Pueblo of Acoma, Acoma, NM 

Pueblo of Santo Domingo, Santo Domingo Pueblo, NM 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 51 
Supplemental Consultation and Coordination 

Pascua Yaqui Tribe, Tucson, AZ 

Hopi Tribe, Kykotsmovi, AZ 

Pueblo of Pojoaque, Santa Fe, NM 

Jicarilla Apache Tribe, Dulce, NM 

Pueblo of Tesuque, Santa Fe, NM 

Alamo Chapter, Navajo Nation, Magdalena, NM 

Tohajiilee, Navajo Chapter, Tohajiilee, NM 

Apache Indian Tribe of Oklahoma, Anadarko, OK 

Comanche Tribe of Oklahoma, Lawton, OK 

Cheyenne-Arapaho Tribes of OK, Concho, OK 

Wichita & Affiliated Tribes, Anadarko, OK 

Fort Still Apache Tribe, Apache, OK 

San Carlos Agency, Bureau of Indian Affairs, San Carlos, AZ 

State and Local Governments 

Arizona Game & Fish Department, Flagstaff, AZ 

Arizona Game & Fish Department, Mesa, AZ 

Arizona Game & Fish Department, Kingman, AZ 

Eastern Arizona Counties Organization, St. Johns, AZ 

Greer Fire District, Greer, AZ 

Lincoln County, Board of Commissioners, Carrizozo, NM 

Northern AZ University, School of Forestry, Flagstaff, AZ 

Mohave County Public Land Use Commission, Kingman, AZ 

New Mexico State University, Las Cruces, NM 

San Miguel County, Las Vegas, NM 

Lincoln County, Carrizozo, NM 

Eddy County, Carlsbad, NM 

Otero County, Alamogordo, NM 

Village of Angel Fire, Angel Fire, NM 

New Mexico Dept. of Game & Fish, Santa Fe, NM 

Greenlee County, Clifton, AZ 

Coalition of Arizona/New Mexico Counties, Glenwood, NM 

NM Department of Agriculture, MSC APR, Las Cruces, NM 

Hidalgo County Public Land Advisory Committee, Animas, NM 

Business and Special Interest Groups 

Blue Ribbon Coalition, Pocatello, ID 

Chiricahua Regional Council, Portal, AZ 

52 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
Supplemental Consultation and Coordination 

Mesa Four Wheelers, Mesa, AZ 

New Mexico Cattle Growers Assn., Albuquerque, NM 

Sacramento Grazing Assn., c/o Jimmy Goss, Weed, NM 

Carson Forest Watch, Llano, NM 

The Nature Conservancy, Tucson, AZ 

Sierra Club, Tularosa Basin Group, Alamogordo, NM 

Sierra Club, Pajarito Group, Los Alamos, NM 

Tierra y Montes SWCD, Las Vegas, NM 

Center for Biological Diversity, Tucson, AZ 

New Mexico Audubon Council, Los Alamos, NM 

Southwest Forest Alliance, Flagstaff, AZ 

Wildlife Management Institute, Ft. Collins, CO 

Defenders of Wildlife, Washington, DC 

Evans Ranches, Alpine, AZ 

Salt River Project, Environmental Services, Phoenix, AZ 

Sandia Peak Ski Co., Albuquerque, NM 

Ski Apache, Manager, Ruidoso, NM 

Chilton Ranch & Cattle Co., Arivaca, AZ 

Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 53 
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56 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans 
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Department of Wildlife, Independence Mining Company, and USDA Forest Service, 

Humboldt National Forest. 

Younk, J. V. and M. J. Bechard. 1994. Breeding ecology of the northern goshawk in highelevation aspen forests of northern Nevada. Studies in Avian Biology 16:119-121. 

 (Appendix AP) 

60 Final Supplement to the Final Environmental Impact Statement for Amendment of Forest Plans