United States Department of Agriculture

Bill Williams Mountain Restoration 

Project 

Final Environmental Impact Statement

Kaibab National Forest

Coconino County, Arizona

Forest Service Southwest Region MB-R3-07-22 July 2015
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BILL WILLIAMS MOUNTAIN RESTORATION PROJECT

Final Environmental Impact Statement

Kaibab National Forest

Coconino County, Arizona

All or portions of Sections 1-3, 10-15, 22-27, & 34-36, T21N R1E; Sections 4-10, 15-22, & 27-31, T21N 

R2E; and Sections 31-33, T22N R2E, Gila & Salt River Meridian 

Lead Agency: USDA Forest Service

Responsible Official: Danelle D. Harrison

District Ranger

Williams Ranger District

742 South Clover Road 

Williams, AZ 86046 

For Information Contact: Marcos Roybal

Project Leader

Williams Ranger District

742 South Clover Road 

Williams, AZ 86046 

Abstract: The Kaibab National Forest proposes mechanical treatments and prescribed burning on 

approximately 15,200 acres on and surrounding Bill Williams Mountain to reduce the risk of high intensity 

stand-replacing wildfire, improve forest health, and protect the watershed for the City of Williams. This final 

environmental impact statement (FEIS) documents the analysis of four alternatives (including a “no action” 

alternative). Alternative 2 is the preferred alternative.

This FEIS and the draft record of decision are subject to objection pursuant to 36 CFR 218.8, Subparts A and 

B. For more information on how to file objections see the project website at: 

http://www.fs.usda.gov/project/?project=34690 or contact Mark Herron, Forest NEPA Coordinator, at 928-

635-8200. 

Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Summary i

Summary

The Kaibab National Forest proposes to treat approximately 15,200 acres with mechanized equipment and 

prescribed fire. The area affected by the proposal is located adjacent and up to approximately 4 miles southsouthwest of the City of Williams, Arizona and includes Bill Williams Mountain, which is the primary watershed 

and municipal water supply for the City of Williams, has historic and cultural value, and has an important 

communication site for Northern Arizona. This action is needed to improve the health and sustainability of 

forested conditions on and surrounding Bill Williams Mountain by reducing hazardous fuels and moving 

vegetative conditions in the project area toward the desired conditions. This work would be done to directly and 

indirectly improve the watershed conditions contributing to the City of Williams water supply.

Bill Williams Mountain is the primary watershed for the City of Williams. A major wildfire and subsequent 

flooding would be devastating to Williams and surrounding communities, as well as downstream to the Havasupai 

Tribe from Cataract Canyon. There is a multi-million dollar communication site at the top of Bill Williams 

Mountain that is extremely important to Northern Arizona and the loss of all or part of this site would disrupt 

emergency communications that are vital to this area.

Three large wildfires in Northern Arizona between 2010 and 2014 and the ensuing monsoon rains highlighted the 

values-at-risk in the project area and the need for treatment on Bill Williams Mountain.

In the early part of 2011, the forest invited the public and various interested parties to participate in numerous 

informal “brainstorming” sessions where participants were solicited for ideas, questions, and concerns about 

treating hazardous fuels on Bill Williams Mountain. All of the ideas and comments we received were helpful in 

refining a proposal for the project area. 

A Notice of Intent (NOI) was published in the Federal Register on Thursday, April 21, 2011 formally initiating 

scoping of the proposed action and seeking public comment on the proposal. Using the comments that were 

received from the public, other agencies, and interested and affected tribal governments and communities during 

scoping of the proposed action, a list of significant and non-significant issues (see Section 1.8 Issues) was 

identified. 

These issues led the team to develop and consider alternatives to the original proposed action. Four alternatives 

were analyzed in detail and several alternatives were considered but eliminated from detailed study. The four 

alternatives analyzed in detail include; Alternative 1 - No Action alternative, Alternative 2 - Modified Proposed 

Action, and Alternatives 3 and 4 which were developed to address one or more significant issues associated with 

the modified proposed action. The original proposed action has been modified since the DEIS and SDEIS were 

released and is now called the modified proposed action. 

Major Conclusions: The analysis by resource specialists indicates all of the action alternatives would reduce 

hazardous fuels and the risk for high intensity stand-replacing wildfires and allow for the reintroduction of fire as 

a natural part of the ecosystem. The action alternatives would reduce fuel buildup and help prevent the spread of 

wildfire onto private property and into drainages leading to the City of Williams’ reservoirs.

Currently and under the no action alternative, approximately 61% of the project area has the potential for active 

crown fire. Under the action alternatives, this is reduced to approximately 18% for Alternative 2 (the preferred 

alternative), 27% for Alternative 3 and 35% under Alternative 4. Under Alternative 2 only, approximately 8,900 

acres of ponderosa pine forest surrounding the base of Bill Williams Mountain would have reduced stand 

densities similar to pre-settlement reference conditions. Timber stands would be thinned and grouped which 

would break up the continuity of the forest and increase forest diversity, tree vigor and stand resiliency. The 

reduction of tree densities on steep slopes would improve forest health by reducing competition for nutrients, and 

would protect the loss of specialized wildlife habitat from fire and forest disease and pests.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

ii Summary

Treating fuel accumulations would abate fire risks to Mexican Spotted Owl habitat, while conserving existing 

nesting and roosting habitat. Reducing mistletoe infection levels would allow for more sustainable management of 

uneven-aged condition over time. Alternatives 2, 3, and 4 would remove poorly located roads out of drainage 

bottoms. Alternatives 2 and 3 would allow the construction of a new and more sustainable road system that would 

also provide access for the fuel treatments. The total net number of miles of open roads would remain essentially 

the same under all of the alternatives. The purpose and need for action would be best achieved with 

implementation of Alternative 2 – the Modified Proposed Action.

Based upon the effects of the alternatives, the responsible official will decide whether to select the modified 

proposed action or one of the alternatives and what mitigation and/or monitoring measures would be required 

during implementation.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Table of Contents iii

Table of Contents

Summary .................................................................................................................................................................... i

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

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

1.2 Background................................................................................................................................................. 1

1.3 Purpose and Need for Action...................................................................................................................... 3

1.4 Modified Proposed Action ......................................................................................................................... 3

1.5 Management Direction ............................................................................................................................... 4

1.6 Decision Framework .................................................................................................................................. 4

1.7 Public Involvement and Project History ..................................................................................................... 4

1.8 Issues .......................................................................................................................................................... 5

1.8.1 Significant Issues Remedied by Implementing Mitigation Measures .............................................. 6

1.8.2 Significant Issues Remedied by Implementing Different Alternatives ............................................ 7

Chapter 2. Alternatives, Including the Modified Proposed Action...................................................................... 9

2.1 Introduction ................................................................................................................................................ 9

2.1.1 Changes from the DEIS .................................................................................................................... 9

2.1.2 Primary Changes Between the DEIS and FEIS ................................................................................ 9

2.2 Silvicultural Prescription and Fuels Treatment Descriptions ..................................................................... 9

2.2.1 Aspen Release ................................................................................................................................ 10

2.2.2 Bugbane Area Thinning ................................................................................................................. 11

2.2.3 Irregular Shelterwood ..................................................................................................................... 11

2.2.4 Modified Intermediate Thinning .................................................................................................... 12

2.2.5 Modified Group Selection .............................................................................................................. 14

2.2.6 Selection Thinning ......................................................................................................................... 16

2.2.7 Prescribed Burning ......................................................................................................................... 17

2.2.8 Thin from Below ............................................................................................................................ 17

2.2.9 Woodland Thinning ........................................................................................................................ 18

2.2.10 Activity Slash Treatments .............................................................................................................. 20

2.2.11 Whole Tree Yarding and Machine Piling ....................................................................................... 20

2.2.12 Hand Piling ..................................................................................................................................... 20

2.2.13 Lopping .......................................................................................................................................... 20

2.2.14 Crushing ......................................................................................................................................... 20

2.2.15 Thinning Strategies in Woodland Sites and Sites with Woodland Species .................................... 20

2.3 Harvest Systems Machinery and Methods ............................................................................................... 20

2.3.1 Conventional Ground Based .......................................................................................................... 21

2.3.2 Helicopter Yarding ......................................................................................................................... 24

2.3.3 Steep Slope Ground-Based ............................................................................................................. 24

2.4 Alternatives Considered in Detail............................................................................................................. 26

2.4.1 Alternative 1 – No Action .............................................................................................................. 26

2.4.2 Alternative 2 – The Modified Proposed Action ............................................................................. 26

2.4.3 Alternative 3 ................................................................................................................................... 28

2.4.4 Alternative 4 ................................................................................................................................... 30

2.4.5 Mitigation and Monitoring ............................................................................................................. 32

2.4.6 Alternatives Considered but Eliminated from Detailed Study ....................................................... 42

2.4.7 Comparison of Alternatives ............................................................................................................ 44

Chapter 3. Affected Environment and Environmental Consequences .............................................................. 57

3.1 Introduction .............................................................................................................................................. 57

3.2 Silviculture ............................................................................................................................................... 57

3.2.1 Affected Environment .................................................................................................................... 58

3.2.2 Direct and Indirect Effects ............................................................................................................. 65

3.2.3 Summary Comparison of Alternatives ........................................................................................... 83

3.2.4 Cumulative Effects ......................................................................................................................... 84
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

iv Table of Contents

3.3 Fire and Fuels Management ..................................................................................................................... 87

3.3.1 Introduction and Affected Environment ......................................................................................... 87

3.3.2 Direct and Indirect Effects ............................................................................................................. 88

3.3.3 Fire and Fuels Cumulative Effects ............................................................................................... 101

3.4 Air Resources ......................................................................................................................................... 101

3.4.1 First Order Fire Effects Model Results - Air Resources .............................................................. 102

3.4.2 Air Resources Cumulative Effects ............................................................................................... 103

3.4.3 Summary Comparison of Alternatives ......................................................................................... 104

3.5 Soils and Watershed ............................................................................................................................... 108

3.5.1 Affected Environment .................................................................................................................. 108

3.5.2 Direct and Indirect Effects ........................................................................................................... 128

3.5.3 Cumulative Effects ....................................................................................................................... 151

3.5.4 Climate Change ............................................................................................................................ 158

3.6 Transportation......................................................................................................................................... 160

3.6.1 Affected Environment .................................................................................................................. 160

3.6.2 Environmental Effects .................................................................................................................. 161

3.6.3 Transportation System Economics ............................................................................................... 162

3.7 Wildlife ................................................................................................................................................... 165

3.7.1 Wildlife of Highest Conservation Concern .................................................................................. 165

3.8 Invasive Species ..................................................................................................................................... 228

3.8.1 Affected Environment’s Existing Condition ................................................................................ 228

3.8.2 Environmental Consequences ...................................................................................................... 231

3.9 Rare Plants .............................................................................................................................................. 234

3.9.1 Affected Environment .................................................................................................................. 234

3.9.2 Direct and Indirect Effects ........................................................................................................... 239

3.9.3 Cumulative Effects ....................................................................................................................... 240

3.9.4 Cumulative Effects ....................................................................................................................... 250

3.10 Rangeland Resources .............................................................................................................................. 251

3.10.1 Affected Environment .................................................................................................................. 251

3.10.2 Direct and Indirect Effects ........................................................................................................... 253

3.10.3 Cumulative Effects ....................................................................................................................... 255

3.11 Recreation Resources ............................................................................................................................. 256

3.11.1 Existing Condition ........................................................................................................................ 256

3.11.2 Desired Condition......................................................................................................................... 258

3.11.3 Direct and Indirect Effects Analysis............................................................................................. 259

3.11.4 Cumulative Effects ....................................................................................................................... 263

3.12 Scenic Resources .................................................................................................................................... 265

3.12.1 Affected Environment .................................................................................................................. 265

3.12.2 Introduction .................................................................................................................................. 265

3.12.3 Project Level Scenic Inventory .................................................................................................... 265

3.12.4 Direct, Indirect, and Cumulative Effects ...................................................................................... 273

3.13 Cultural and Tribal Resources ................................................................................................................ 285

3.13.1 Cultural Resources and Heritage Desired Future Conditions ....................................................... 285

3.13.2 Affected Environment .................................................................................................................. 285

3.13.3 Direct and Indirect Effects ........................................................................................................... 287

3.13.4 Cumulative Effects ....................................................................................................................... 288

3.14 Implementation Economics .................................................................................................................... 289

3.14.1 Introduction, Methodology, and Analysis Process ....................................................................... 289

3.14.2 Affected Environment .................................................................................................................. 291

3.14.3 Environmental Effects .................................................................................................................. 291

3.15 Socio Economics .................................................................................................................................... 296

3.15.1 Affected Environment .................................................................................................................. 296

3.15.2 Direct and Indirect Effects ........................................................................................................... 297

3.15.3 Cumulative Effects ....................................................................................................................... 298
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Table of Contents v

3.16 Lands and Minerals ................................................................................................................................ 298

3.16.1 Affected Environment .................................................................................................................. 298

3.16.2 Existing Condition ........................................................................................................................ 299

3.16.3 Direct, Indirect, and Cumulative Effects ...................................................................................... 299

3.17 Other Disclosures ................................................................................................................................... 300

3.17.1 Environmental Justice .................................................................................................................. 300

3.17.2 Short-term Uses and Long-term Productivity .............................................................................. 301

3.17.3 Unavoidable Adverse Effects ....................................................................................................... 301

3.17.4 Irreversible and Irretrievable Commitments of Resources ........................................................... 302

3.17.5 Cumulative Effects ....................................................................................................................... 302

3.17.6 Other Required Disclosures .......................................................................................................... 302

Chapter 4. Consultation and Coordination ........................................................................................................ 305

4.1 Preparers and Contributors ..................................................................................................................... 305

4.1.1 ID Team Members ........................................................................................................................ 305

4.1.2 Federal, State, and Local Agencies .............................................................................................. 305

4.1.3 Tribes ............................................................................................................................................ 305

4.1.4 Others ........................................................................................................................................... 305

4.2 List of Agencies, Organizations and Persons to Whom Copies of the DEIS, SDEIS, and FEIS Were Sent306

4.3 Tribal Consultation Summary ................................................................................................................ 306

4.3.1 Tribal Concerns with the Bill Williams Restoration Project ........................................................ 308

Glossary ................................................................................................................................................................. 311

References Cited ................................................................................................................................................... 313

Index ...................................................................................................................................................................... 325

Appendices ............................................................................................................................................................ 329

Introduction ........................................................................................................................................................ 329

Appendix A: Project Maps ..................................................................................................................................... 330

Appendix B: Response to Comments, Draft Environmental Impact Statement and Supplemental Draft 

Environmental Impact Statement ........................................................................................................................... 343

Response to Comments: Draft Environmental Impact Statement ...................................................................... 344

Comment Letter 1: Dick Artley ...................................................................................................................... 344

Comment Letter 2: Todd G. Geiler ................................................................................................................ 344

Comment Letter 3: Larry Smart ..................................................................................................................... 345

Comment Letter 4: Mark Worden .................................................................................................................. 345

Comment Letter 5: EPA ................................................................................................................................. 346

Comment Letter 6: Stroud (via mail) ............................................................................................................. 347

Comment Letter 7: James Benham ................................................................................................................. 347

Comment Letter 8: Debra Noel ...................................................................................................................... 349

Comment Letter 9: David Farley .................................................................................................................... 350

Comment Letter 10: Sierra Club .................................................................................................................... 351

Comment Letter 11: Arizona Game and Fish Department ............................................................................. 374

Comment Letter 12: Center for Biological Diversity ..................................................................................... 378

Comment Letter 13: Marlin ............................................................................................................................ 385

Comment Letter 14: Stroud (received at a public meeting regarding the availability of the DEIS for 

comment) ........................................................................................................................................................ 385

Response to Comments: Supplemental Draft Environmental Impact Statement ............................................... 387

Comment Letter 1: Dick Artley ...................................................................................................................... 387

Comment Letter 2: Jean Public ...................................................................................................................... 387

Comment Letter 3: Erica Prather .................................................................................................................... 388

Comment Letter 4: EPA ................................................................................................................................. 391

Comment Letter 5: USFWS ........................................................................................................................... 391

Comment Letter 6: Center for Biological Diversity and Wild Earth Guardians ............................................ 393

Comment Letter 7: Sierra Club ...................................................................................................................... 405

Appendix C: Issue Processing Report .................................................................................................................... 408
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

vi Table of Contents

Appendix D: Past, Present, and Reasonably Foreseeable Future Actions .............................................................. 424

Appendix E: Silvicultural Treatments in Pre-Settlement Patches of Forest in MSO Protected Habitat and the 

Arizona Bugbane Botanical Area ........................................................................................................................... 427

Methods for Delineating Pre-Settlement Patches ............................................................................................... 427

Treatments in MSO Protected Habitat ............................................................................................................... 427

Treatments in the Arizona Bugbane Botanical Area .......................................................................................... 428

List of Tables

Table 2-1. Silvicultural and fuels treatments for all action alternatives .....................................................................9

Table 2-2. Ponderosa pine modified group selection outside of goshawk PFAs .....................................................15

Table 2-3. Ponderosa pine modified group selection goshawk PFAs outside of nest site........................................16

Table 2-4. Physical characteristics to consider when choosing leave trees ..............................................................18

Table 2-5. Comparison of alternatives – key features1

 .............................................................................................44

Table 2-6. Comparison of alternatives – summary of effects on resources ..............................................................46

Table 3-1. Bill Williams vegetation cover types ......................................................................................................58

Table 3-2. Estimated stand percentages of interspace and canopy cover between alternatives after treatment year*

 ..........................................................................................................................................................................66

Table 3-3. Ponderosa pine forest: Snags, logs, dead and downed material (mid-scale) and tree group canopy cover

 ..........................................................................................................................................................................70

Table 3-4. Mixed conifer forest: snags, logs, dead and downed material (mid-scale) and tree group canopy cover

 ..........................................................................................................................................................................74

Table 3-5. Ponderosa pine forest 18"+ trees per acre ...............................................................................................82

Table 3-6. Mixed conifer forest 18”+ trees per acre .................................................................................................83

Table 3-7. Percent of Bill Williams Area with Each Fire Type Potential, Post Treatment ......................................93

Table 3-8. Flame lengths under 8 feet in the project area ........................................................................................93

Table 3-9. Fire and fuels extension to the FVS post treatment results by alternative ..............................................97

Table 3-10. Percent area in each FRCC by alternative post treatment .....................................................................99

Table 3-11. Relative ranking for each alternative ..................................................................................................107

Table 3-12. Terrestrial Ecosystem Units within the Project Area ..........................................................................110

Table 3-13. Predicted Soil Erosion Hazard by TEU within the project area ..........................................................111

Table 3-14. Estimated vegetation, litter, and total vegetative ground cover in the project area.............................115

Table 3-15. Revegetation potential within the project area ....................................................................................117

Table 3-16. Timber harvest limitations within the project area ..............................................................................118

Table 3-17. Subwatershed (HUC12) names, codes, condition ratings, acreages, and associated percentages of total 

project area .....................................................................................................................................................121

Table 3-18. Watershed condition indicator summary for watersheds that occur in the project area ......................123

Table 3-19. Subwatershed (HUC12) names, acreages, and associated percentages of each that comprise the City 

of Williams Municipal Watershed ..................................................................................................................123

Table 3-20. Reservoirs, associated water storage capacities, and percentages of total municipal surface water in 

the City of Williams Municipal Watershed ....................................................................................................124

Table 3-21. Best Management Practices (BMPs) for the project ...........................................................................129

Table 3-22. Predicted soil erosion hazard by TEU where road obliteration would occur within the Project Area 137

Table 3-23. Predicted soil erosion rates and sediment yield by TES mapping unit in the Project area where forest 

thinning treatments would be conducted ........................................................................................................139

Table 3-24. Predicted soil erosion rates and sediment yield for watersheds in the Project Area where forest 

thinning treatments would be conducted. .......................................................................................................140

Table 3-25. Predicted soil erosion rates and sediment yield for Terrestrial Ecosystem Units Where Permanent 

Roads Would be Constructed and Maintained ...............................................................................................141

Table 3-26. Predicted Soil Erosion Rates and Sediment Yield for Terrestrial Ecosystem Units Where Temporary 

Roads Would be Constructed and Maintained ...............................................................................................142

Table 3-27. Terrestrial Ecosystem Survey map unit acreages and associated erosion hazard ratings for areas where 

strategic fuels treatments would be conducted ...............................................................................................143
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Table of Contents vii

Table 3-28. Predicted sediment delivery rates for watersheds in the Bill Williams Mountain Restoration Project 

area under low severity prescribed fire treatments (USDA 2010)..................................................................144

Table 3-29. Predicted sediment delivery rates for watersheds in the Project Area ................................................145

Table 3-30. Predicted sediment delivery rates for watersheds in the project area where 50 percent of prescribed 

burn treatment results in low soil burn severity, 25 percent results in moderate burn severity, and 25 percent 

results in high burn severity ...........................................................................................................................146

Table 3-31. Terrestrial Ecosystem Survey map units within the Arizona Bugbane Botanical Area ......................146

Table 3-32. Terrestrial Ecosystem Units and associated erosion hazard ratings that would be excluded from 

ground-based harvesting systems under Alternative 3 within the Project Area .............................................147

Table 3-33. Terrestrial Ecosystem Survey map units and associated erosion hazard ratings for operability zones 1, 

2, and 6 with slopes less than 40 percent ........................................................................................................148

Table 3-34. Predicted sediment yield in year of disturbance and annual hillslope erosion by TES mapping unit in 

operability zones 1, 2 and 6 ............................................................................................................................149

Table 3-35. Predicted soil erosion rates and sediment yield for watersheds in the Bill Williams Mountain 

Restoration Project area where forest thinning treatments would be conducted under Alternative 4 ............149

Table 3-36. Predicted sediment yield and hillslope erosion rates and for Terrestrial Ecosystem Units where 

temporary roads would be constructed and maintained under Alternative 4 .................................................150

Table 3-37. Past projects in the Project Cumulative Effects Analysis Area...........................................................152

Table 3-38. Current projects in the Project Cumulative Effects Analysis Area .....................................................152

Table 3-39. Reasonably foreseeable projects in the Project Cumulative Effects Analysis Area ...........................152

Table 3-40. Current activities and associated acreages that occur in the same watersheds (HUC12) as the proposed 

Project .............................................................................................................................................................154

Table 3-41. Approximate Miles of Existing Roads within the Project Area ..........................................................160

Table 3-42. Approximate miles of roads that are poorly located and proposed for obliteration ............................160

Table 3-43. Comparison of Road Mileages by Alternative ....................................................................................161

Table 3-44. Road Cost/Mile by Construction Phase and Road Type .....................................................................162

Table 3-45. Road Cost by Alternative ....................................................................................................................163

Table 3-46. List of wildlife species of conservation concern considered in this analysis ......................................166

Table 3-47. MSO habitat within the Bill Williams Mountain Restoration Project Area........................................169

Table 3-48. Habitat/Vegetation Type and the Desired Condition of these types on the Bill Williams Mountain 

Restoration Project Area .................................................................................................................................170

Table 3-49. Comparison of Treatment Method by Action Alternative in Acres of MSO Habitat .........................172

Table 3-50. FS Veg. Model Run Tables Showing; Existing and After-Treatment Effects from the Modified 

Proposed Action on Key Habitat Components for the MSO (Protected Habitat and Mixed Conifer Nest/Roost 

Replacement Recovery Habitat) .....................................................................................................................174

Table 3-51. FS Veg. Model Run Tables Showing; Existing and After-Treatment Effects from the Modified 

Proposed Action on Key Habitat Components for the MSO (Pine-Oak Nest/Roost Replacement Recovery 

Habitat and Pine-Oak Recovery Habitat) .......................................................................................................175

Table 3-52. Past projects in the Project Cumulative Effects Analysis Area...........................................................190

Table 3-53. Current projects in the Project Cumulative Effects Analysis Area .....................................................190

Table 3-54. Reasonably foreseeable projects in the Project Cumulative Effects Analysis Area ...........................190

Table 3-55. List of actions considered in the cumulative effects analysis for this project .....................................191

Table 3-56. Acres of different goshawk habitat within the project area.................................................................193

Table 3-57. Count of Grace’s Warbler by year on KNF (RMBO website) ............................................................206

Table 3-58. Grace’s Warbler Density Estimates (RMBO Website) .......................................................................207

Table 3-59. Count of Western Bluebird by year (Rocky Mountain Bird Observatory Website) ...........................211

Table 3-60. Western Bluebird Density Estimates (Rocky Mountain Bird Observatory Website) .........................211

Table 3-61. Count of Ruby-crowned kinglet by year on KNF (RMBO website) ..................................................215

Table 3-62. Ruby-crowned Kinglet Density Estimates (RMBO Website) .............................................................215

Table 3-63. Trends in Pronghorn Populations based on AGFD data (McCall 2014) .............................................221

Table 3-64. List of migratory birds of conservation concern that occur on the Kaibab National Forest, with notes 

on whether they occur or have habitat within the project area .......................................................................222

Table 3-65. Forest Planning Species classified as having Restricted Distributions or Narrow Endemic species ..227

Table 3-66. Invasive plant species documented within a 1-mile buffer of the project area ...................................228
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

viii Table of Contents

Table 3-67. Recreation Opportunity Spectrum Classification for the Project Area ...............................................258

Table 3-68. Scenic integrity, visual quality objective, and perception crosswalk (USDA FS 1995, 2-4) ..............258

Table 3-69. Acres for Alternative 2 by Recreation Opportunity Spectrum and Treatments ..................................261

Table 3-70. Acres for Alternative 3 by Recreation Opportunity Spectrum and Treatments ..................................262

Table 3-71. Acres for Alternative 4 by Recreation Opportunity Spectrum and Treatments ..................................263

Table 3-72. Scenic integrity objectives for the proposed treatment methods .........................................................279

Table 3-73. Scenic Integrity Objectives by Operability Zone for Alternative 3 ....................................................282

Table 3-74. Scenic integrity objectives by operability zone for Alternative 41

 ......................................................284

Table 3-75. Logging cost summary Alternative 2 ..................................................................................................292

Table 3-76. Logging cost summary Alternative 3 ..................................................................................................293

Table 3-77. Logging cost summary Alternative 4 ..................................................................................................294

Table 3-78. Estimated Implementation Costs by Alternative .................................................................................296

Table 4-1. Summary of tribal consultation on the Bill Williams Restoration Project ............................................306

List of Figures 

Figure 1-1. Photo comparison of reference and current conditions in the Bill Williams Restoration Project Area ... 2

Figure 2-1. 1 An example of a shelter wood treatment showing larger trees left in place to provide shelter for a 

seed source for younger trees to grow .............................................................................................................. 12

Figure 2-2. A modified Intermediate thinning selects the nicer trees to leave and generally thins the smaller trees 

while creating more historic spatial patters like groups and clumps with interspace between them ................ 13

Figure 2-3. A modified group selection creates regeneration within a group selection area at a smaller scale of up 

to four acres ...................................................................................................................................................... 14

Figure 2-4. An illustration of spatial arrangement of leave groups that shows an average of 40 to 60 percent 

canopy closure at the group level ..................................................................................................................... 15

Figure 2-5. A selection thinning selects the nicer trees to leave and thins more of the smaller trees to create 

historic structure which is less dense ................................................................................................................ 17

Figure 2-6. Keen’s classification of ponderosa pine trees based on age and vigor .................................................. 19

Figure 2-7. Wheeled fellers-buncher (photo courtesy of John Deere) ..................................................................... 22

Figure 2-8. Tracked boomed feller buncher (photo courtesy of John Deere)........................................................... 22

Figure 2-9. A rubber tired grapple skidder (photo courtesy of John Deere) ............................................................ 23

Figure 2-10. A loader places manufactured logs onto a truck for transportation to a mill ....................................... 23

Figure 2-11. A helicopter lifting a tree off the ground with a 150-200’ long line .................................................... 24

Figure 2-12. A forwarder carrying logs on 65% slope; forwarders work in a harvester’s trail loading cut logs into 

log bunks on the machine; these logs are carried to a roadside landing free of the ground ............................. 25

Figure 2-13. A spider or steep slope excavator working on a steep slope ................................................................ 25

Figure 2-14. Diagram showing the approximate buffer zones for the Arizona Bugbane Botanical Area mitigation 

measures ........................................................................................................................................................... 36

Figure 3-1. Vegetative structural stages (VSS) ........................................................................................................ 57

Figure 3-2. Ponderosa pine cover type by vegetative structural stages (VSS) under current condition compared to 

desired condition .............................................................................................................................................. 59

Figure 3-3. 40 year measure of ponderosa pine forest sustainability in the project area .......................................... 59

Figure 3-4. 40 year measure of bark beetle risk and sustainability for the ponderosa pine forest ........................... 60

Figure 3-5. Percent of trees per acre high levels of dwarf mistletoe infection in the ponderosa pine forest ............ 61

Figure 3-6. Dwarf mistletoe rating of extremely infected DM stands in ponderosa pine forest .............................. 62

Figure 3-7. Mixed conifer forest VSS current condition compared to balanced multi-aged condition .................... 63

Figure 3-8. Forty year measure of mixed conifer forest sustainability ..................................................................... 63

Figure 3-9. 40 year measure of bark beetle risk and sustainability for mixed conifer forest ................................... 64

Figure 3-10. Percent of TPA infected of extremely infected DM stands in mixed conifer forest ............................ 64

Figure 3-11. DM rating of extremely infected DM stands (mixed conifer cover type)............................................ 65

Figure 3-12. Ponderosa pine forest (mid-scale): VSS 1 & 2 .................................................................................... 67

Figure 3-13 Ponderosa pine forest (mid- scale): VSS 3 ........................................................................................... 67

Figure 3-14. Ponderosa pine forest (mid-scale): VSS 4 ........................................................................................... 68

Figure 3-15. Ponderosa pine forest (mid-scale): VSS 5 ........................................................................................... 68
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Table of Contents ix

Figure 3-16. Ponderosa pine forest (mid- scale): VSS 6 .......................................................................................... 69

Figure 3-17. Mixed conifer forest (mid-scale): VSS 1 & 2 ...................................................................................... 71

Figure 3-18. Mixed conifer forest (mid-scale): VSS 3 ............................................................................................. 72

Figure 3-19. Mixed conifer forest (mid-scale): VSS 4 ............................................................................................. 72

Figure 3-20. Mixed conifer forest (mid-scale): VSS 5 ............................................................................................. 73

Figure 3-21. Mixed conifer forest (mid-scale): VSS 6 ............................................................................................. 73

Figure 3-22. 40 year measure of bark beetle risk and sustainability for all alternatives in the ponderosa pine forest76

Figure 3-23. Forty year measure of bark beetle risk and sustainability for all alternatives in the mixed conifer 

forest ................................................................................................................................................................. 77

Figure 3-24. Percent of TPA infected of extremely infected DM Stands (ponderosa pine forest)........................... 78

Figure 3-25. Dwarf mistletoe rating of extremely infected DM stands (ponderosa pine forest) .............................. 78

Figure 3-26. Mixed conifer % of TPA infected of extremely infected DM stands (ponderosa pine) ...................... 79

Figure 3-27. Mixed conifer % of TPA infected of extremely infected DM Stands (Douglas-fir) ........................... 79

Figure 3-28. Mixed conifer dwarf mistletoe rating of extremely infected DM stands (ponderosa pine) ................. 80

Figure 3-29. Mixed conifer dwarf mistletoe rating of extremely infected DM stands (douglas-fir) ........................ 81

Figure 3-30. Map of the Bill Williams Mountain project area demonstrating the distribution of fire potential for 

Alternative 1 ..................................................................................................................................................... 89

Figure 3-31. Map of the Bill Williams Mountain project area demonstrating the distribution of fire potential for 

Alternative 2 ..................................................................................................................................................... 90

Figure 3-32. Map of the Bill Williams Mountain project area demonstrating the distribution of fire potential for 

Alternative 3 ..................................................................................................................................................... 91

Figure 3-33. Map of the Bill Williams Mountain project area demonstrating the distribution of fire potential for 

Alternative 4 ..................................................................................................................................................... 92

Figure 3-34. Habitat stratum fire type potential ....................................................................................................... 95

Figure 3-35. Percent FRCC for each alternative .................................................................................................... 100

Figure 3-36. Particulate Matter 2.5 in pounds per acre of emissions for Prescribed Fire and Wildfire by alternative103

Figure 3-37. Arizona Smoke Management Map .................................................................................................... 104

Figure 3-38. Terrestrial Ecosystem Units within the Bill Williams Mountain Restoration Project Analysis Area109

Figure 3-39. Predicted Soil Erosion Hazard within the Project Area ..................................................................... 112

Figure 3-40. Hydrologic soil groups within the Project Area ................................................................................ 114

Figure 3-41. Terrestrial Ecosystem Units and their associated Timber Harvest Limitations within the Project Area119

Figure 3-42. Bill Williams Mountain Restoration Project in relation to subwatersheds (HUC12) ........................ 122

Figure 3-43. Bill Williams Mountain Restoration Project area in relation to the City of Williams Municipal 

Watershed ....................................................................................................................................................... 125

Figure 3-44. Mexican spotted owl habitat within the Project Area ........................................................................ 167

Figure 3-45. Priority Pre-settlement patches (281 acres) for MSO conservation ................................................... 171

Figure 3-46. Northern Goshawk PFAs with the Project Area ................................................................................ 194

Figure 3-47. Grace’s Warbler Density Estimates (Rocky Mountain Bird Observatory Website).......................... 207

Figure 3-48. Western Bluebird Density Estimates (Rocky Mountain Bird Observatory Website) ........................ 212

Figure 3-49. Ruby-crown Kinglet Density Estimates (Rocky Mountain Bird Observatory Website) ................... 216

Figure 3-50. Pronghorn habitat on the Kaibab National Forest .............................................................................. 220

Figure 3-51. Invasive plants within a 1-mile buffer of the project areas ................................................................ 230

Figure 3-52. Arizona Bugbane (Actaea arizonica) in the Project area ................................................................... 236

Figure 3-53. Arizona Bugbane sprouting in July 2014 in an area burned by 2014 Slide Fire ............................... 238

Figure 3-54. The Hat Grazing Allotment and the Project Boundary ...................................................................... 252

Figure 3-55. Finger Rock formation on Bill Williams Mountain ........................................................................... 266

Figure 3-56. Bill Williams Mountain in a background view from downtown Williams, AZ ................................ 268

Figure 3-57. Foreground mixed conifer on top of Bill Williams Mountain, and looking to background at Williams, 

AZ ................................................................................................................................................................... 269

Figure 3-58. Photo of the western slopes of Bill Williams Mountain .................................................................... 271

Figure 3-59. Forest Plan scenic integrity objectives ............................................................................................... 278

Figure 3-60. Example of strategic fuels treatment near Elk Ridge Ski Area (prior to burning) ............................. 280

Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 1. Purpose of and Need for Action 1

Chapter 1. Purpose of and Need for Action

1.1 Document Structure 

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

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

Impact Statement discloses the direct, indirect, and cumulative environmental impacts that would result from the 

modified proposed action and alternatives. The document is organized into four chapters: 

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

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

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

the public responded. 

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

of the agency’s proposed action as well as alternative methods for achieving the stated purpose. These 

alternatives were developed based on significant issues raised by the public and other agencies. This 

discussion also includes mitigation measures. Finally, this section provides a summary table of the 

environmental consequences associated with each alternative. 

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

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

organized by resource area. 

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

consulted during the development of the environmental impact statement. 

• Appendices: The appendices provide more detailed information to support the analyses presented in the 

environmental impact statement such as the existing and desired conditions report, public comments and 

responses, etc.

• Index: The index provides page numbers by document topic. 

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

planning record located at Williams Ranger District office in Williams, Arizona.

1.2 Background 

Bill Williams Mountain lies just southwest of Williams, Arizona and has an elevation of 9,256 feet. It was 

identified by both the City of Williams and the USDA Forest Service as a critical resource deserving special 

protection from uncharacteristic wildfire in the Greater Williams Area Community Wildfire Protection Plan 

(2005). 

There is a multi-million dollar communications site on the top of the mountain providing communications towers 

for the Arizona Department of Public Safety, USDA Forest Service, Arizona State Land Department, Burlington 

Northern Santa Fe railroad and several other governmental and private enterprises. The north side of the mountain 

is home to a small ski resort, and private property; homes and other infrastructure surround the base of the 

mountain. It is an important sacred site and traditional use area for several Native American tribes, and has been 

determined eligible as a traditional cultural property under the National Historic Preservation Act.

Bill Williams Mountain is also the apex of six watersheds, including the Sycamore and Hell Canyon watersheds 

to the south and east, the Cataract Creek and Spring Valley Wash watersheds to the north, and the Ash Fork Draw 

and Upper Partridge Creek watersheds to the west. The City of Williams relies heavily on three of these 

watersheds to provide clean and abundant water to the local reservoirs as their municipal water source. 

Two large wildfires in Northern Arizona in 2010 along with the Slide Fire in Oak Creek Canyon in 2014 and the 

ensuing monsoon rains highlighted the values-at-risk in the project area and the need for treatment on Bill 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

2 Chapter 1. Purpose of and Need for Action

Williams Mountain. The Eagle Rock Fire on Sitgreaves Mountain burned approximately 3,500 acres on the 

Kaibab National Forest and on the 15,200 acre Schultz Fire on the neighboring Coconino National Forest the 

Schultz Fire where a ten-year old girl lost her life in the flooding that happened after the Schultz Fire burned. 

Both fires involved area closures, and evacuations.

These high-intensity stand-replacing wildfires led to flooding, erosion and sedimentation problems as well as 

landscapes and habitats that will take decades to recover. A high-intensity stand-replacing wildfire on Bill 

Williams Mountain could result in the loss of critical emergency communications systems; the silting in of 

reservoirs that act as municipal water sources as well as reductions in water quality; the loss of irreplaceable 

cultural and tribal resources; the loss of recreational areas and opportunities; the loss of important wildlife habitat; 

and the potential loss of lives and homes.

Vegetation treatments and prescribed burning have been planned and implemented in many areas surrounding the 

mountain, such as within the City and Twin Project area boundaries. However, experiences from 2010 and lessons 

learned from previous years have guided a reevaluation of the treatments within these areas and the urgency and 

need to treat the steep slopes of Bill Williams Mountain. It is time to take significant steps to reduce hazardous 

fuels and reduce the risk of a high intensity stand-replacing fire near the City of Williams and within its municipal 

watershed.

Figure 1-1 shows two photos of Williams, Arizona. The photo on the left was taken southwest of Williams, AZ in 

the 1890s and overlooks town. The photo on the right was taken from approximately the same location in 2011. 

Since the forested condition in the foreground of the picture on the left does not appear to have been logged (i.e. 

there are no visible stumps in the openings), it provides a good example of the reference conditions for portions of 

the project area. Comparison of the two pictures demonstrates how open forested conditions were and how dense 

they have become.

Figure 1-1. Photo comparison of reference and current conditions in the Bill Williams Restoration Project Area

The Bill Williams Mountain Restoration Project was initiated in 2011. Since then, a Draft Environmental Impact 

Statement (DEIS) and Supplemental Draft Environmental Impact Statement (SDEIS) have been released and the 

project is now in the Final Environmental Impact (FEIS) stage. The original proposed action has been modified 

since the DEIS and SDEIS were released and is now called the modified proposed action. Section 1.5, 

Management Direction, has been added to provide information on and show consistency with the Kaibab National 

Forest Revised Forest Plan (2014). The original proposed action was described using operability zones. The 

modified proposed action uses treatment methods to describe the thinning activities that are proposed for the 

project. Alternatives 3 and 4 were not modified for treatment methods and are still described with operability 

zones. Sections 1.5 and 2.1 include more detailed information on the changes from the DEIS and changes in 

terminology and treatment methods. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 1. Purpose of and Need for Action 3

1.3 Purpose and Need for Action 

The purpose of the Bill Williams Mountain Restoration Project is to improve the health and sustainability of 

forested conditions on and surrounding Bill Williams Mountain by reducing hazardous fuels and moving 

vegetative conditions in the project area toward the desired conditions. This work would be done to directly and 

indirectly improve the watershed conditions contributing to the City of Williams water supply.

The purpose and need for action is derived from the differences between existing conditions and desired 

conditions in the project area. The desired conditions are based on management direction in the 2014 Land and 

Resource Management Plan for the Kaibab National Forest, and reference conditions for vegetation in the project 

area.

There is a need for:

• Reducing the risk for high intensity, stand-replacing wildfires; 

• Reintroducing fire as a natural part of the ecosystem;

• Reducing fuel buildup to help prevent the spread of wildfire onto private property and into drainages 

leading to the City of Williams reservoirs; 

• Reducing overall stand densities and moving stand conditions toward forest structures considered to be 

more typical of forest structure under pre-settlement fire regimes;

• Treating fuel accumulations to abate fire risks to Mexican spotted owl habitat, while conserving existing 

nesting and roosting habitat; 

• Improving tree vigor and stand resiliency; 

• Improving the diversity of age classes and structure of woody vegetation; 

• Improving ground cover, including down woody debris, fine litter and herbaceous understory composition 

and productivity; 

• Reducing mistletoe infection levels to more manageable levels where the area can be managed in an 

uneven-aged condition over time; 

• To provide forest products, such as firewood, for people living in Williams, AZ and the surrounding area, 

in order to meet their needs for forest and wood products, while protecting these resources for future 

generations; and 

• To improve the motorized transportation system to provide for a more sustainable road system where 

poorly located roads are relocated or obliterated. 

1.4 Modified Proposed Action

To meet the purpose and need for action, the Kaibab National Forest proposes to treat stands on and surrounding 

Bill Williams Mountain with mechanized equipment and prescribed fire. 

A combination of commercial timber harvest treatments and non-commercial mechanical treatments is proposed 

on approximately 15,200 acres. Mechanized treatments include hand felling, ground-based logging systems, 

steep-slope logging systems, helicopter logging, along with machine and hand piling. These treatments would thin 

stands to meet or move them toward the desired conditions and in some stands, non-commercial treatments may 

be the only treatments feasible/necessary to achieve resource objectives. 

Prescribed fire is also proposed on approximately 15,200 acres of the project area. In some areas, prescribed fire 

would be used in conjunction with mechanical treatments to achieve restoration and fuel treatment objectives. In 

other areas where operability is limited and more costly, only prescribed burning may be used to meet resource 

objectives.

A detailed description of Alternative 2, the modified proposed action, is provided in Chapter 2 (Section 2.4.2).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

4 Chapter 1. Purpose of and Need for Action

1.5 Management Direction1

The 2014 Land and Resource Management Plan for the Kaibab National Forest Land (Forest Plan) provides 

direction for all resource management programs, practices, uses, and protection measures on the Kaibab National 

Forest. This action responds to the goals and objectives outlined in the Forest Plan and helps maintain and/or 

move the project area towards desired conditions described in this plan.

Forest Plan Revision. During the first three years of development, the Bill Williams Mountain Restoration 

Project was designed under the framework provided by the 1988 Kaibab National Forest Plan, as amended (1988 

Forest Plan). A revised Land and Resource Management Plan was issued in early 2014, superseding the 1988 

plan. As a result, the ROD for the Bill Williams Mountain Restoration Project is being issued under the 2014 Land 

and Resource Management Plan for the Kaibab National Forest. The Bill Williams Mountain Restoration Project 

follows the new Forest Plan. 

Forest Plan Consistency. The FEIS and ROD for the Land and Resource Management Plan for the Kaibab 

National Forest, and the associated “Land and Resource Management Plan for the Kaibab National Forest,” (U.S. 

Forest Service 2014), were adopted pursuant to the National Forest Management Act (16 U.S.C. 1604) and its 

implementing regulations at 36 CFR 219 to provide strategic direction (desired conditions and objectives) and to 

set parameters on land and resource use activities (standards and guidelines).

A consistency review for the Bill Williams Mountain Restoration Project with the Forest Plan resulted in a 

determination that implementing the modified proposed action or any of the action alternatives would be 

consistent with the revised plan and would result in conditions that are consistent with management direction in 

the plan. 

1.6 Decision Framework 

Based on the purpose and need for action, the findings in the Final Environmental Impact Statement (FEIS) and 

supporting project record, and consideration of the best available science, the responsible official will decide:

1. whether to select the modified proposed action or one of the alternatives; and

2. what mitigation and/or monitoring measures will be required during implementation of the modified 

proposed action or any alternative selected.

1.7 Public Involvement and Project History 

Public involvement for this project began prior to the publication of the Notice of Intent (NOI) to prepare an 

Environmental Impact Statement (EIS). The forest invited the public and various interested parties to participate 

in numerous informal “brainstorming” sessions during January, February and March of 2011. Participants were 

solicited for ideas, questions, and concerns about treating hazardous fuels on Bill Williams Mountain, and thereby 

improving forest health near the City of Williams.

Where possible, the input received was incorporated into the purpose and need for action and the desired 

conditions for the project area. Many overarching themes were repeated during these discussions. For example, 

many statements were made about the need to avoid incidents like the Schultz Fire as well as the flooding events 

that followed. Others stated consideration should be given to the cost-benefits of treating the fuels now versus 

trying to suppress a high-intensity, stand-replacing wildfire. All of the ideas and comments received are 

appreciated and were helpful in refining a proposal for this project area. 

The NOI was published in the Federal Register on Thursday, April 21, 2011. The NOI asked for public comment 

on the proposal by May 23, 2011. In addition, as part of the public involvement process, the forest invited public 

 

1 The purpose and need for action is derived from the differences between existing conditions and desired conditions in the 

project area. FEIS Desired conditions are based on management direction in the 2014 Kaibab Forest Plan, and reference 

conditions for vegetation. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 1. Purpose of and Need for Action 5

comment and participation through listing the project in the Schedule of Proposed Actions (SOPA); posting the 

scoping packet online (http://fs.usda.gov/goto/kaibab/projects); and mailing letters to potentially interested 

persons, tribal governments, and State and other Federal agencies. Three letters and six emails were received from 

this effort. A scoping meeting was also hosted at the Williams Ranger District on Wednesday May 11, 2011 to 

discuss the proposed action and accept comments. The forest received nine written comments as well as several 

oral questions and comments that were recorded at the public scoping meeting. 

Using the comments received from the public, other agencies, and interested and affected Tribal governments and 

communities during scoping of the proposed action, the Interdisciplinary team (IDT) identified a list of significant 

and non-significant issues and alternatives to the proposal (see Section 1.8, Issues). 

The Notice of Availability for the DEIS appeared in the Federal Register on Friday, July 13, 2012, initiating the 

45-day public review period. This review period ended on Monday August 27, 2012. Comments on the draft 

were reviewed and changes based on some of those comments were incorporated into this FEIS. Responses to 

comments can be viewed in appendix B. 

A Supplemental DEIS (SDEIS), published in the federal register on November 8, 2013, was developed to provide 

additional information and clarification for portions of the project, including updates to the analysis in the DEIS 

based on new information that had emerged since the original analysis was completed, as well as clarify portions 

of the project. This updated information for the project related to the original proposed action and included: 

• Consistency checks for the 1988 Forest Plan, as amended and the revised 2014 Land and Resource 

Management Plan for the Kaibab National Forest.

• Clarification on the 1988 Forest Plan amendment language that was included in the project at the time the 

SDEIS was released.

• Two additional non-significant amendments to the 1988 Forest Plan related to 24-inch tree retention and 

treatments in the 100-acre Mexican spotted owl [MSO] core area. Since the project will now be 

implemented under the 2014 revised forest plan, the FEIS no longer requires any forest plan 

amendments.”

• Clarification on how snags would be addressed in this project, including an additional project mitigation 

measure tied to snags and down woody debris. 

• The addition of three project mitigation measures tied to wildlife habitat protection.

• Clarification at the time that 31 acres of cable logging* treatments were proposed within the Bill Williams 

Mountain Mexican spotted owl protected activity center. *Cable logging is no longer included in the 

project.

• Information on the project-level pre-decisional administrative review process that had recently gone into 

effect (36 CFR Part 218) and how it applied to this project. 

The Forest collaborated with the U.S. Fish and Wildlife Service throughout all phases of project development, 

especially as it pertains to conservation of Mexican spotted owls (see section 3.7 of chapter three for more 

information).

1.8 Issues 

The Forest Service separated the issues identified during the public scoping process into two groups: significant 

and non-significant issues. Significant issues were identified as those directly or indirectly caused by 

implementing the proposed action. Non-significant issues were identified as those: 1) outside the scope of the 

proposed action; 2) already decided by law, regulation, forest plan, or other higher level decision; 3) irrelevant to 

the decision to be made; or 4) conjectural and not supported by scientific or factual evidence. The Council on 

Environmental Quality (CEQ) NEPA regulations explain this delineation in Sec. 1501.7, “...identify and eliminate 

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

review (Sec. 1506.3)...” A list of non-significant issues and explanations regarding their categorization as nonsignificant may be found in the Issue Processing Report (Appendix C). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

6 Chapter 1. Purpose of and Need for Action

The USDA Forest Service identified the following significant issues from scoping efforts. They are grouped as to 

whether the issue can be remedied by implementing a mitigation measure or an alternative to the modified 

proposed action and they have been reworded to reflect cause-and-effect statements.

1.8.1 Significant Issues Remedied by Implementing Mitigation Measures

Issue 1 – The Proposed Action may cause the loss of pre-settlement trees which will have potentially 

significant impacts on old growth recruitment and critical wildlife habitat. 

A mitigation measure has been developed to generally retain pre-settlement trees (FEIS, Section 2.4.5). Some 

pre-settlement trees may be incidentally taken due to harvesting operability and for reasons related to forest health 

and safety. A pre-settlement tree is generally a tree that was living prior to 1870.

Issue 2 – The proposed prescribed burning may increase debris flow and increase surface erosion which 

will result in ash filling a stock tank located on Benham private property and negatively affect the water 

treatment plant for the City of Williams. 

Implementation of Soil and Watershed Best Management Practices (BMPs) would reduce the potential for debris 

flows and surface erosion to impact a stock tank on Benham private property and the Water Treatment Plant for 

the City of Williams (see FEIS Chapter 3, Soils and Watershed). 

Issue 3 – The vertical arrangement of strategic fire lines around the proposed burn blocks may result in 

erosion problems. 

Implementation of Soil and Watershed Best Management Practices (BMPs) would reduce the likelihood of 

erosion problems such as soil loss and down cutting from construction of strategic fuels treatment lines (see FEIS 

Chapter 3, Soils and Watershed). 

Issue 4 – The project may negatively impact the growth and productivity of Native American medicinal and 

ceremonial plants.

A mitigation measure has been developed to minimize impacts to Native American medicinal and ceremonial 

plants in consultation with the Tribes (FEIS, Section 2.4.5).

Issue 5 - The proposed project has not been designed to retain a sufficient amount of large logs and other 

dead and down material compatible with MSO needs and primary constituent elements of MSO critical 

habitat. 

A mitigation measure has been developed to retain large down logs and woody debris where possible and when 

needed to meet desired conditions (FEIS, Section 2.4.5). Where possible, direct ignition of large down logs and 

woody debris will be avoided in the project area to meet desired conditions. 

Issue 6 – The proposed action may degrade wildlife habitat because of the proposed treatments in dwarf 

mistletoe stands.

A mitigation measure has been developed to retain some dwarf mistletoe as a natural component in stands (FEIS, 

Section 2.4.5).

Issue 7 – The proposed action includes new road construction and temporary road construction which may 

negatively affect the watershed.

Implementation of Soil and Watershed Best Management Practices (BMPs) would reduce the potential for 

impacts from road construction to the watershed (see FEIS Chapter 3, Soils and Watershed).

An alternative was considered but eliminated from detailed study that would include no new road construction or 

temporary road construction (FEIS, Section 2.4.6).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 1. Purpose of and Need for Action 7

Issue 8 – The Proposed Action would not follow all recommendations for management of MSO habitat per 

the Final Rule for designation of Critical Habitat (FWS 2004) because it would reduce shade below 40% 

across a large portion of MSO Critical Habitat.

A mitigation measure has been developed to retain more trees per pre-settlement evidence (FEIS, Section 2.4.5) in 

order to retain 40% shade in MSO Critical Habitat in all action alternatives.

1.8.2 Significant Issues Remedied by Implementing Different Alternatives

Issue 9 – The Proposed Action would not follow all recommendations for management of Mexican Spotted 

Owl (MSO) habitat per the MSO Recovery Plan because it would cut trees greater than 9” diameter breast 

height (dbh) in a MSO Protected Activity Center (PAC) and other Protected Habitat.

Alternatives 3 and 4 were originally developed in response to this issue, and do not include thinning trees above 

9” dbh in MSO habitat except in the strategic fuels treatment areas (FEIS, Section 2.2). *Note: the 2012 Revised 

Recovery Plan no longer has this recommendation. 

Indicator: Acres of PAC and Protected Habitat thinned above nine inches dbh 

Issue 10 – The Proposed Action would implement three site specific Forest Plan amendments that are not 

needed to meet restoration objectives.

In the DEIS, alternatives 3 and 4 responded to this issue because they did not include any site specific forest plan 

amendments. This is no longer an issue because the modified proposed action (project) was found to be consistent 

with the components of the revised forest plan and thus no longer requires any forest plan amendments. 

Issue 11 – The Proposed Action would negatively affect wildlife and cultural resources due to road 

construction and its associated impacts (e.g. habitat loss, fragmentation, compaction, etc.). 

Mitigation measures have been developed to protect cultural resources (FEIS, Section 2.4.5).

Alternative 4 was partially developed to respond to this issue. It does not include any new permanent system road 

construction (FEIS, Section 2.4).

Indicator: a) Miles of new road construction

Issue 12 – The Proposed Action would allow cable logging which is not ecologically sound because it would 

harvest old growth trees.

In the DEIS, Alternatives 3 and 4 responded to this issue. They did not include the use of cable logging systems 

to treat vegetative conditions on steep slopes within the project area (DEIS, Section 2.2). In responding to 

comments on the DEIS, Alternative 2 – Modified Proposed Action no longer includes cable logging. The areas 

originally planned for cable logging would be harvested by helicopter or steep slope equipment. 

Issue 13 – The Proposed Action would allow mechanical treatment in the Arizona (AZ) bugbane botanical 

area which would invite non-native invasive species and damage the populations.

Mitigation measures have been developed to prevent and control the spread of non-native invasive species within 

the project area (FEIS, Section 2.4.5).

Alternative 4 responds to this issue because it does not include mechanical treatments (except for hand-felling 

techniques) in the AZ bugbane botanical area (FEIS, Section 2.2). 

Indicator: a) Acres of AZ bugbane botanical area potentially impacted by mechanized equipment
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

8 Chapter 1. Purpose of and Need for Action

Issue 14 – The Proposed Action would mechanically treat approximately 15,200 acres, which would impact 

wildlife viability, soil conditions and water resources, when the objectives could be achieved primarily 

through prescribed burning.

An alternative was considered but eliminated from detailed study that would only utilize prescribed burning 

techniques (FEIS, Section 2.4). 

Additionally, the No Action Alternative responds to this issue in several ways because it does not include any 

mechanical treatments or prescribed burning on steep slopes within the project area, except in those areas already 

covered under the City and Twin Projects (Decision Notice/Finding of No Significant Impact (DN/FONSI) 2005; 

DN/FONSI 2005 respectively). The No Action alternative will serve as the baseline for comparing the effects and 

anticipated effectiveness of each alternative in meeting the purpose and need.

Indicators: a) Wildlife viability, b) Soil erosion hazard, c) Short-term effect on water quality and yield, d) 

Long-term effect on water quality and yield

Issue 15 – The Proposed Action includes mechanical treatments and prescribed burning on steep slopes 

which could cause erosion and sedimentation and subsequently affect water sources and properties 

downstream.

The No Action alternative responds to this issue in several ways because it does not include any mechanical 

treatments or prescribed burning on steep slopes within the project area, except in those areas already covered 

under the City and Twin Projects (DN/FONSI 2005; DN/FONSI 2005 respectively). The No Action alternative 

will serve as the baseline for comparing the effects and anticipated effectiveness of each alternative in meeting the 

purpose and need. 

Indicator: a) short-term effect on water quality and yield, b) long-term effect on water quality and yield

Issue 16 – The Proposed Action includes the use of a helicopter logging system which is expensive and a 

significant disturbance to wildlife and nearby residents.

For the DEIS, Alternative 4 was partially developed to respond to this issue. It does not include the use of 

helicopter logging systems to treat vegetative conditions on steep slopes within the project area (DEIS, Section

2.2). In response to comments regarding the high cost of helicopter logging Alternative 2 - Modified Proposed 

Action the acreage proposed for helicopter logging has been reduced from 3,500 acres to approx. 1,060 acres. 

Indicators: a) acres treated with helicopter logging, b) estimated cost, and c) wildlife viability.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 9

Chapter 2. Alternatives, Including the Modified Proposed 

Action

2.1 Introduction 

This chapter describes and compares the alternatives considered for the Bill Williams Mountain Restoration 

Project. It includes a description of each alternative considered. Maps for the alternatives can be found in 

Appendix A. This section also presents the alternatives in comparative form, clearly defining the differences 

between each alternative and providing a clear basis for choice among options by the decision maker and the 

public. Some of the information used to compare the alternatives is based upon the design of the alternative and 

some of the information is based upon the environmental, social and economic effects of implementing each 

alternative.

2.1.1 Changes from the DEIS

The U.S. Forest Service (Forest Service) received public and agency comments regarding the DEIS and SDEIS. 

Some comments included concerns related to: forest plan amendments, the high cost of the helicopter logging, 

the effects of cable logging, and effects to Mexican spotted owl habitat. In responding to these comments, the 

proposed action has been modified and the specialist reports have been updated. No additional alternatives have 

been proposed or evaluated in the FEIS.

A range of comments also brought attention to concerns about creating new system roads. This persuaded the IDT 

to revisit the proposed transportation system and explore possibilities to utilize more temporary roads for better 

project access. As a result, new forest system road construction was reduced from approximately 23 miles to 15 

miles. This will ultimately provide for a better transportation system for the project area once the project is 

implemented (as described in the transportation resource section of chapter 3 FEIS).

2.1.2 Primary Changes Between the DEIS and FEIS

• All specialist reports were updated to reflect the desired conditions, objectives, guidelines and standards 

from the 2014 Forest Plan. 

• Removal of forest plan amendments. 

• All specialist reports were updated for Alternative 2 – Modified Proposed Action.

• Responses to comments for the DEIS and SDEIS have been added to the FEIS in Appendix B. 

• The Existing and Desired Conditions Report (Appendix E in the DEIS) was removed because the 

specialist reports now include the information related to desired conditions. 

• Appendix E, Silvicultural Treatments in Pre-Settlement Patches, was added to the appendices. 

• Additional literature citations have been added to the references cited.

2.2 Silvicultural Prescription and Fuels Treatment Descriptions 

Silvicultural and fuels prescriptions have been clarified for all action alternatives. Table 2-1 lists the types of 

silvicultural and fuels treatments for the action alternatives in the Bill Williams Mountain Restoration Project.

Table 2-1. Silvicultural and fuels treatments for all action alternatives

Silviculture and Fuels Treatment Prescription Type Alt 2 Alt 3 Alt 4

RX Burn Overlapping Mechanical 

Treatment

Reduce Dead and Down 

Fuels

15,202 15,202 11,505

Burn Only Reduce Dead and Down 

Fuels

0 0 3,697

Bugbane Botanical Area Bugbane Area Thinning 604 604 215
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10 Chapter 2. Alternatives, Including the Modified Proposed Action

Silviculture and Fuels Treatment Prescription Type Alt 2 Alt 3 Alt 4

MSO Core No Mechanical Cutting 103 103 103

Mixed Conifer Protected Habitat Modified Intermediate 

Thinning 

1,313 0 0 

Mixed Conifer Protected Habitat Thin From Below 0 1,313 151

Mixed Conifer Protected Habitat (Currently 

Meeting)

Thin From Below 11 11 0 

Mixed Conifer Recovery Habitat Nest Roost 

(Currently Meeting)

Thin From Below 45 45 0 

Mixed Conifer Recovery Habitat Nest Roost 

(Not Currently Meeting)

Thin From Below 22 22 22

Mixed Conifer Recovery Habitat Nest Roost 

(Not Currently Meeting, High DM Levels)

Irregular Shelterwood 79 79 0 

Ponderosa Pine Protected Habitat Modified Intermediate 

Thinning

408 407 0 

Ponderosa Pine Recovery Habitat Nest 

Roost (Currently Meeting)

Thin From Below 26 26 26

Ponderosa Pine Recovery Habitat Nest 

Roost (Not Currently Meeting)

Thin From Below 146 146 146

Ponderosa Pine Recovery Habitat Selection Cutting 3,359 0 0 

Ponderosa Pine Recovery Habitat (High 

DM Levels)

Irregular Shelterwood 0 2,121 2,121

Ponderosa Pine Recovery Habitat Group Selection (Modified) 0 1,239 1,239

Ponderosa Pine (Outside of MSO Habitat) Selection Cutting 4,784 0 0 

Ponderosa Pine (Outside of MSO Habitat) Group Selection (Modified) 0 2,572 2,017

Ponderosa Pine (High DM Levels) Irregular Shelterwood 0 2,212 1,825

Ponderosa Pine (Goshawk Nest) Thin From Below 695 695 695

Ponderosa Pine (PFA, High DM Levels) Irregular Shelterwood 234 234 234

Ponderosa Pine (PFA, Low DM Levels) Group Selection (Modified) 723 723 723

Woodlands Protected Habitat Thin From Below 84 84 0 

Woodlands Woodland Thinning 2,330 2,330 1,876

Woodlands (PFA) Thin From Below 8 8 8 

Grasslands Selection Cutting 64 64 64

Aspen Aspen Release 51 51 0 

Mountain Mahogany Selection Cutting 40 40 40

Rock Selection Cutting 23 23 0 

2.2.1 Aspen Release

This treatment would remove most conifers within aspen stands in order to release aspen from other tree 

competition. Where aspen have severe damage and/or disease some aspen may be felled in order to stimulate new 

sprouting of aspen. Where aspen stands have good access, the entire aspen stand or a portion of the stand may be 

fenced in order to protect new aspen sprouts from elk browsing and to protect larger aspen from damage from elk 

rubbing and scraping. Dead aspen and other species of snags that could fall on the fence would be removed in 

order to protect the fence.

In aspen sites where all or almost all of the aspen have died, some planting of aspen may be done in combination 

with aspen fencing. Aspen planting stock would be selected from nearby sites of the same elevation. In more 

inaccessible aspen sites, conifers and dead aspen (dead less than 10” in diameter) would be felled and left in place 

in order to impede some elk access to the aspen and to give aspen sprouts some protection from elk browsing. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 11

These felled trees would generally not be lopped in order to create as much of an obstruction to elk access as 

possible. 

2.2.2 Bugbane Area Thinning

This treatment is specific to the boundary of the Arizona Bugbane Botanical Area of approximately 604 acres in 

size and is located on the south slopes of the mountain, extending from the top to the bottom. Silviculture 

treatments would not be conducted within the actual population, or inner buffer zone. Some fuels treatments may 

occur in the inner buffer zone to meet objectives.

Treatments in the inner buffer zone and in pre-settlement patches for the conservation of Arizona bugbane would 

maintain the integrity of the overstory canopy and reduce the potential of crown fire. The inner buffer would 

generally be thinned-from-below of conifers 9” DBH in size. Within presettlement patches other incidental 

suppressed, young, and intermediate trees may be removed to promote gap dynamics. The remainder of the 

Arizona Bugbane botanical area would generally be thinned-from-below of conifers 12” DBH in size. To reduce 

the potential of crown fire, larger trees may be removed to promote interspace between presettlement patches.

2.2.3 Irregular Shelterwood

An irregular shelterwood (Figure 2-1) is proposed in sites with moderate to heavy mistletoe infection levels to 

regenerate trees on greater than 20% of the site by removing most or all of the mistletoe infected trees in heavily 

infected areas. In these regeneration areas the objective is to develop new trees that are free of mistletoe 

infections. Most vigorous non-infected trees would be retained as either a seed source or as a younger age class in 

these regeneration areas. In areas of sites that have no to lighter mistletoe infections, conifers would be 

irregularly thinned to a specified leave density. Most mistletoe infected trees would be removed from these areas 

in order to protect surrounding regeneration areas from future mistletoe infection. Sites selected for this treatment 

generally have mistletoe infection levels that are too high to successfully manage as an uneven-aged site with the 

group selection treatments. The intent of this prescription is to retain some of the available uneven-aged structure 

while developing a new age class of trees over 25 to 70% of the site that is mostly mistletoe free.

Over time and with future treatments these sites can be managed closer to the regulated uneven-aged conditions 

specified in the forest plan. Pockets of heavy mistletoe infection with larger tree groups may be regenerated. 

Outside of these regeneration areas, the rest of the site would be thinned to groups of trees with interspaces 

surrounding groups. Interspaces between group crowns would be 50 foot to 100 foot with an approximate 

average of 75 foot. Individual large trees may exist between groups. Groups would be irregular in shape and size 

from 1/5 to 1 acre in size approximate average of 1/10 acre. Density within groups would be thinned to 40 to 100 

square feet basal area per acre with an irregular spacing.
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12 Chapter 2. Alternatives, Including the Modified Proposed Action

Figure 2-1. 1 An example of a shelter wood treatment showing larger trees left in place to provide shelter for a seed 

source for younger trees to grow

2.2.4 Modified Intermediate Thinning 

A modified intermediate thinning technique (Figure 2-2) is designed to enhance growth, quality, vigor and 

composition of forested stands of trees. The reason this treatment is modified from the traditional intermediate 

thinning definition is due to two things: overall objective of the treatment to manage for current and future habitat 

and would not have a future overstory removal; and second a patch (forest) matrix (interspace of lower tree 

density) design allows for uneven aged treatments to occur at smaller scales. In general, trees are thinned to reach 

the desired leave tree density, horizontal diversity and vertical diversity. Leave trees would be left both 

individually and in small to medium sized groups of two to twelve trees per group. Spacing within the groups 

themselves would be irregular. This treatment would lead to a mosaic of different tree densities across the site. 

There would be openings around these tree groups and they could become larger as group size becomes larger. 

Groups of trees may stand as individual groups in the interspace or be combined as a patch. The USFS and 

USFWS worked together to identify pre-settlement patches (i.e., dense forest patches dominated by trees that 

occurred on the landscape prior to Euro-American settlement and persist today) to be maintained. The two 

silviculture treatments types within pre-settlement patches would be single, aka. individual, tree selection or thinfrom-below treatments.

Due to the high number of large trees within patches, average residual post-treatment densities would generally 

exceed 80 ft2/acre and some may range up to 160 ft.2/ acre. Patches dominated by pre-settlement trees would be 

thinned from below to reduce ladder fuels, and canopy gaps would be created where possible. Mitigation 

measures to conserve pre-settlement and 24”+ DBH trees would drive prescriptions to mimic forest gap 

dynamics. For example, gaps may be formed in areas that lack pre-settlement and 24”+ DBH trees. Gap 

dynamics are the change in space and time in the pattern, frequency, size, and successional processes of forest 

canopy gaps caused by the fall or death of one or more canopy trees which creates a canopy gap. The fall or death 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 13

of one or more canopy trees is where the new cohort of trees recruits into a patch. Suppressed or intermediate 

trees up to 24” DBH, mainly 18”DBH and below would be removed to mimic gaps for regeneration recruitment. 

To create variability and vertical structure, some young (<5” DBH), intermediate (5-9” DBH), and suppressed 

trees would be retained in areas of lower fire hazard. Examples of such areas include moist drainages or 

depressions. Single tree selection would be used in pre-settlement patches where the forested area is not 

dominated by pre-settlement trees, and would strive to maintain all size classes of trees. This means that a 

substantial amount of vertical diversity of smaller trees would occur within canopy openings and under residual 

trees. Canopy openings for regeneration are very small because they can be created by removing a single, mature 

tree). These mature trees can be up to 24” DBH. The different age classes of trees would be intermixed and close 

enough to each other that individual tree groups are not readily apparent. A diversity of age/size classes is 

intimately mixed, and this treatment focuses on sustaining mature and pre-settlement trees into the future.

Intermediate thins would have an average basal area of 80 ft.2 As pre-settlement patches and smaller tree groups 

would be managed for higher basal areas, the matrix around these patches and groups would be managed for 

lower basal areas. Lower basal areas in the matrix would promote more diverse horizontal structure and reduce 

the probability of stand-replacing wildfire in pre-settlement patches and groups. Tree groups outside of presettlement patches would range from 60-160 ft2. Tree groups managed for higher basal areas would be 

dominated by trees >18” DBH. Tree groups managed for lower basal areas were historically open. Trees > 18” 

DBH would represent the majority of the basal both in and outside of pre-settlement patches. Although the actual 

leave tree density would be fairly variable across the site depending on group and patch size and spacing, the 

overall average density would meet the specified leave tree density of each prescription. 

Figure 2-2. A modified Intermediate thinning selects the nicer trees to leave and generally thins the smaller trees 

while creating more historic spatial patters like groups and clumps with interspace between them
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14 Chapter 2. Alternatives, Including the Modified Proposed Action

2.2.5 Modified Group Selection

The modified group selection treatment (Figure 2-3 and Figure 2-4) is done in sites that are predominantly evenaged, and is considered modified from the traditional group selection definition because there would be areas 

intended to remain in an open grassy state surrounding tree groups. This treatment attempts to regenerate 

ponderosa pine on 10 to 20% of each site by creating 1⁄4 to 2 acre openings across each site. Opening sizes may be 

up to 4 acres in size where there are large pockets of dwarf mistletoe-infected pine. These openings are referred to 

as “regeneration areas”. Zero to 20 square feet basal area per acre of the largest non-mistletoe-infected pine 

available can be retained in regeneration areas. When regeneration areas are over one acre in size, a minimum of 

one group of three to five non-mistletoe infected ponderosa pines could be retained per acre.

Regeneration areas would generally be chosen in areas where tree groups from the middle size classes except in 

pockets of heavy mistletoe infection where some larger sized tree groups may be regenerated. Outside of these 

regeneration areas, the rest of the site would be thinned to groups of trees with interspaces surrounding groups. 

Interspaces between group crowns would be 50 foot to 100 foot with an approximate average of 75 foot. 

Individual large trees may exist between groups. Groups would be irregular in shape and size from one fifth of an 

acre to one acre in size approximate average of one tenth acre. Density within groups would be thinned to 40 to 

100 square feet basal area per acre with an irregular spacing. Overall stand basal area average is approximately 

30 to 50 square feet basal area per acre with an average of 40 square feet basal area per acre. Table 2-2 and Table 

2-3 are used as a guide for implementation and show a Ponderosa Pine Modified Group Selection Outside of 

Goshawk PFAs and nest site.

Figure 2-3. A modified group selection creates regeneration within a group selection area at a smaller scale of up to 

four acres
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Chapter 2. Alternatives, Including the Modified Proposed Action 15

Figure 2-4. An illustration of spatial arrangement of leave groups that shows an average of 40 to 60 percent canopy 

closure at the group level

Table 2-2. Ponderosa pine modified group selection outside of goshawk PFAs
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16 Chapter 2. Alternatives, Including the Modified Proposed Action

Table 2-3. Ponderosa pine modified group selection goshawk PFAs outside of nest site

2.2.6 Selection Thinning

Figure 2-5 Shows a selection thinning treatment that selects the nicer trees to leave and thins more of the smaller 

trees to create historic structure which is less dense. These treatments would move tree density, spatial orientation, 

and structure closer towards historical reference conditions. Evidence of trees that existed such as fallen trees, 

stumps, yellow pine, and stump holes is used as a baseline for tree density and grouping. Generally pine and/or 

juniper are thinned to low stocking levels. Oak density control would be accomplished with repeat broadcast 

burning. Mistletoe infection is not as important as a selection factor for tree removal for restoration treatments as 

it is for other vegetative treatments because in selection thinning the groups of trees are separated by larger open 

interspaces that are maintained over time. These open spaces isolate the mistletoe infections within individual 

groups of trees. This allows a greater number of large trees with mistletoe infections to be retained than the other 

treatments. This treatment attempts to move forest density and distribution to lower levels. One to two post 

treatment younger trees would be retained per each piece of evidence. All other trees, excluding oaks and pre 

settlement trees would be removed. Generally, the largest, most fully crowned trees would be retained as leave 

trees but some vigorous younger trees of various age classes would be retained in order to develop an open 

uneven-aged site. Some sites may have more trees of various age classes or show a lack of evidences; these areas 

would follow the modified group selection treatment. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 17

Figure 2-5. A selection thinning selects the nicer trees to leave and thins more of the smaller trees to create historic 

structure which is less dense

2.2.7 Prescribed Burning

Prescribed under burning is proposed for the entire Bill Williams Mountain project area, and would reduce fuel 

loadings on the forest floor and reduce fuel ladders by thinning smaller trees, stimulate the production and 

improve the distribution of grasses and forbs, aid in restoring the grass/forb nutrient recycling processes, reduce 

the potential of crown fires by effectively treating activity created slash and previously existing woody debris and 

allow fire to move across the landscape for resource benefits. The initial prescribed burn for areas proposed may 

be implemented either prior to or following vegetative treatments. The use of adaptive management (flexible 

timing and sequence of treatments) would be implemented to allow managers to consider changing markets and 

funding levels. This strategy, refined over time, would best utilize available funding and respond to changing 

situations while the project is being implemented. 

Maintenance or re-entry burns would occur up to 10 years in ponderosa pine and 5-25 years for mixed conifer 

following initial burning, and within a 40-year timeframe, in order to maintain an effective fuel break and further 

reduce the potential of crown fires. It is intended that there would be no future need for reevaluation decision for 

re-entry burns due to meeting the objective of maintaining the desired condition of dead and downed fuels and 

regeneration. If there are no issues and conditions are not markedly different, this re-evaluation would be 

documented and filed in the original project record and the maintenance burning could occur. 

2.2.8 Thin from Below

This is generally low thinning of ponderosa pine, mixed conifer and sometimes juniper and oak. Trees are 

generally thinned up to 9 to 12 inches in diameter, often with spacing of 20 to 30 feet between leave trees with 

even higher spacing on very poor nonproductive sites. Table 2-4 lists the physical characteristics considered when 
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18 Chapter 2. Alternatives, Including the Modified Proposed Action

choosing leave trees. And, Figure 2-6 shows Keen’s classification of trees based on age and vigor. Trees 

mistletoe infected may be removed to a higher diameter than the specified maximum diameter for thinning for 

each site. Sites are noncommercial for timber harvest due to a variety of factors including low volume, steepness, 

poor access, isolation, and rockiness. This treatment maybe commercial or noncommercial thinned with the use of 

mechanized equipment. This treatment would increase stand vigor, increase stand growth, and reduce risk of 

catastrophic wildfire. In the future as larger trees develop on these sites and value increases, commercial 

treatments may become feasible. At this time, group selection may be implemented to start moving these sites 

towards uneven-aged management as specified in the forest plan. Maintenance or re-entry thinning would occur 

to maintain the desired condition for up to 20 years to maintain the desired condition. 

Table 2-4. Physical characteristics to consider when choosing leave trees

2.2.9 Woodland Thinning

This treatment accomplishes a low thinning in woodland areas (juniper woodlands, pinyon juniper woodlands, 

oak woodlands, and hardwood sites). Juniper and/or ponderosa pine are thinned to a specified average spacing. 

Specified spacing may range from 25 to 100 feet between leave trees. Trees are thinned up to a specified diameter 

(generally from 9 to 14” diameter) above which all larger trees are retained. Dwarf mistletoe infected ponderosa 

pine may be removed to a larger diameter than the specified diameter for thinning.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 19

Figure 2-6. Keen’s classification of ponderosa pine trees based on age and vigor
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20 Chapter 2. Alternatives, Including the Modified Proposed Action

2.2.10 Activity Slash Treatments

Activity slash treatments would follow vegetative treatments and reduce the amount of woody debris created by 

felling trees, as well as treating pre-existing fuels. These treatments would reduce the immediate fire risk and 

prepare these areas for future prescribed burning in order to meet project objectives. Where it is feasible, there 

would be piling or removal of most activity slash in the project area. Activity slash may be removed from the site 

to be utilized or sold for biofuels. Several types of treatments would be used to accomplish fuels reduction 

objectives and may include the following:

2.2.11 Whole Tree Yarding and Machine Piling

This commercial harvest method leaves very little activity slash on site as the whole tree is taken to the landing 

where limbs and unmerchantable boles are piled for later burning. This method involves a bulldozer or grapple 

piling machine that moves ground fuels into large piles that would be burned in 18 to 24 months when the slash 

has dried. Piles may also be used or sold for biofuels. Most of the fuels to be piled would be generated by the 

proposed thinning or commercial harvest treatments. Some areas of existing natural fuels may also require piling.

2.2.12 Hand Piling

Slash that is created would be piled by hand. This type of treatment may be used in areas more sensitive to 

disturbance or areas with visual concerns. Piles would be burned in approximately 18 to 24 months. 

2.2.13 Lopping 

This type of treatment involves cutting and scattering slash, so slash height is not more than two feet high. Low 

slash heights reduce fire behavior and intensity, and make future prescribed burning more effective. The slash 

also dries out faster, decreasing the availability of bark beetle brooding sites.

2.2.14 Crushing 

Heavy equipment is run over activity slash to reduce its total height and to partially mix it in with the upper layers 

of the soil. The slash mixed with the soil would be less flammable and would break down more quickly back into 

the soil. 

Commercial vegetative treatments using timber sales would accomplish these slash treatments by using whole 

tree skidding, machine piling, or hand piling during timber sale implementation. There may be some areas that 

are too steep or rocky for whole tree skidding or machine piling. In these areas lopping or hand piling may be the 

only options available for activity slash treatment.

2.2.15 Thinning Strategies in Woodland Sites and Sites with Woodland 

Species

For felling of trees with chainsaws or shearing machines, treatment slash could be offered as personal use or 

commercial fuelwood. Treatment slash may be lopped and scattered, piled and burned, chipped, masticated, 

and/or broadcast burned. Felling of trees with a commercial fuelwood sale or as personal use fuelwood, a followup contract would often be necessary in order to remove smaller trees not utilized for fuelwood. The remaining 

slash treatment remaining after fuelwood removal may be lopped and scattered, piled and burned, and/or 

broadcast burned. Mulching or grinding of trees with mechanical tree mulcher with the resulting mulch would be 

scattered to reduce excess accumulations, and t would later be broadcast burned. 

2.3 Harvest Systems Machinery and Methods 

The following descriptions of harvesting systems, machinery and methods are described to provide background 

and context for the proposed treatments and the associated effects analyses in Chapter 3. All of the following 

systems, machinery, and methods are analyzed for use, and the actual equipment used would depend on the final 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 21

decision and the contractor procured during implementation. The photos are examples and are not necessarily 

representative of what would be used within the Bill Williams Mountain Restoration Project area.

2.3.1 Conventional Ground Based

Conventional ground based harvest systems typically consist of several machines that all perform specialized 

functions. First a feller-buncher cuts the trees with a high speed disc saw and then places them into bunches for 

subsequent removal. Wheeled fellers-bunchers, (Figure 2-7) are the dominant felling machines used in northern 

Arizona and operate well, up to approximately a 25% slope. Beyond 25% it is often necessary to use a tracked 

boomed feller-buncher (Figure 2-8) that has leveling capability and is capable of operating on steep slopes. These 

leveling feller-bunchers can work on up to 55% slopes but very rocky ground can limit their operation. 

A rubber tired grapple skidder, (Figure 2-9) then drags whole trees that have been bunched by the feller-buncher, 

to a roadside landing area. At the landing, a processor, removes limbs from trees and cuts them into log length. 

Finally, a loader (Figure 2-10) places manufactured logs onto a truck for transportation to a mill. Logging slash, 

(limbs and tops) generated at the landing can be burned on site or chipped and removed as biomass. Conventional 

ground based harvesting is generally limited to slopes of 40% or less. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

22 Chapter 2. Alternatives, Including the Modified Proposed Action

Figure 2-7. Wheeled fellers-buncher (photo courtesy of John Deere) 

Figure 2-8. Tracked boomed feller buncher (photo courtesy of John Deere) 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 23

Figure 2-9. A rubber tired grapple skidder (photo courtesy of John Deere) 

Figure 2-10. A loader places manufactured logs onto a truck for transportation to a 

mill
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24 Chapter 2. Alternatives, Including the Modified Proposed Action

2.3.2 Helicopter Yarding

Helicopter logging or yarding is a very simple logging method. Trees are felled either by hand or mechanically 

and then lifted free off the ground with a helicopter equipped with a 150-200’ long line, (Figure 2-11) and flown 

to a roadside landing. Either logs or whole trees may be removed. However, flying whole trees with limbs and 

tops attached can significantly raise logging cost, as limbs and tops have little to no commercial value and are 

expensive to fly. Helicopter yarding is an extremely expensive method due to the high cost of operating a 

helicopter. If whole trees are flown, the tree is processed at the landing area with a processor.

Figure 2-11. A helicopter lifting a tree off the ground with a 150-200’ long line

2.3.3 Steep Slope Ground-Based

Cut to length: The cut to length, (CTL) harvest system consists of a harvester that cuts trees with a bar saw and 

then, without releasing them from its cutting head, delimbs and processes them into logs. Limbs and tops are 

placed in front of the machine and are crushed down as the harvester moves ahead. A forwarder, (Figure 2-12) 

then follows in the harvester’s trail and loads the cut logs into log bunks on the machine. These logs are carried to 

a roadside landing free of the ground. Repeated trips by the forwarder on the trail crush the slash into the ground. 

If it is desirable to remove more of the slash, it is possible to only process the tree to the extent needed to get it on 

the forwarder. In some instances it may be possible to not process the tree at all and take it to the landing in tree 

length form. The stem then must be processed into logs at the landing. This double handling of the log by the 

harvester to cut and then later process the tree reduces the cost- effectiveness of the method and does not place 

slash on the skid trails.

In the past CTL has been limited to slopes of approximately 40%, however recent developments in technology 

now allow some models of harvesters and forwarders to operate on slopes of up to 65% slope for downhill 

forwarding and 45% uphill. Rocks that protrude from the ground over about 12” limit operability; however rocks 

that are embedded in the ground without a vertical side above ground do not impede operation greatly. On very 

steep or rocky sites a steep slope excavator, commonly known as a “spider” may be used to treat fuels (Figure 2-
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Chapter 2. Alternatives, Including the Modified Proposed Action 25

13). Spiders are designed to work in extremely difficult topography. While they are most often used as an 

excavator for piling or digging, they can be equipped with a harvester head and can cut, buck and pile standing 

trees. Their legs operate independently and they push themselves uphill with their boom. They can maneuver 

around and over fair sized boulders that would limit operations of other machines such as harvesters and fellerbunchers. 

Figure 2-12. A forwarder carrying logs on 65% slope; forwarders work in a harvester’s trail loading cut logs into log 

bunks on the machine; these logs are carried to a roadside landing free of the ground

Figure 2-13. A spider or steep slope excavator working on a steep slope
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26 Chapter 2. Alternatives, Including the Modified Proposed Action

2.4 Alternatives Considered in Detail 

The USDA Forest Service developed four alternatives, including the No Action and Modified Proposed Action 

alternatives, in response to issues raised by the public. 

2.4.1 Alternative 1 – No Action 

Under the No Action alternative, current management would continue in the project area. This alternative would 

not implement any new treatments or actions described in the proposed action (or other action alternatives 

described below). The no action alternative would not fulfill the purpose and need for action and represents a 

continuation of the existing conditions and management along with the continued risk of stand-replacing wildfire. 

Some of the project area falls under the City (thinning and prescribed burning) and Twin (prescribed burning 

only) Projects. These projects do not include any activities on slopes over 40 percent in the south and southwest 

portions or the project area, so thinning would not occur in the majority of the project area. Prescribed burning is 

approved in the City and Twin Projects for slopes below 40 percent in the project area

2.4.2 Alternative 2 – The Modified Proposed Action

To meet the purpose and need for action, the Kaibab National Forest proposes the following activities under 

Alternative 2 – The Modified Proposed Action.

2.4.2.1 Mechanical Treatments

Alternative 2 - The Modified Proposed Action includes a combination of commercial timber harvest treatments 

and non-commercial mechanical treatments on approximately 15,200 acres. Treatments would thin stands to meet 

or move them toward the desired conditions; in some stands, non-commercial treatments may be the only 

treatments feasible/necessary to achieve resource objectives.

The Modified Proposed Action uses the term “treatment methods” instead of “operability zones”; a change in 

terminology from the DEIS. In the DEIS, the original proposed action used “operability zones” as a way to 

describe the harvest methods that would be implemented to achieve the desired conditions. (Map 1 DEIS, 

Appendix A). These operability zones share common operational attributes such as topography, terrain and 

potential logging system. In response to comments, cable logging and excaline operability zones were removed 

from the Proposed Action, contributing to the Modified Proposed Action. The removal of the cable logging and 

excaline operability zones created gaps in the operability zone numerology and on the Alternative 2 Operations 

Map.

In addition, the Modified Proposed Action includes 500 acres of no mechanical treatment and limited treatment in 

the 103 acre MSO core.

Within the remaining operability zones, these adjustments could not be well articulated, and in an effort to 

simplify discussing treatment opportunities, the Modified Proposed Action uses the term “treatment methods” 

instead of “operability zones”. 

Alternative 2 – Modified Proposed Action includes the following mechanical treatment methods and acres:

• Approximately 1,060 acres of thinning using helicopters to remove materials (reduced from 3,500 acres in 

the original proposed action). 

• Up to 2,400 acres of steep slope (between 40 - 60 %) ground-based thinning using harvester/forwarders as 

well as steep slope excavators (spiders) for fuels reduction work while conserving snags. Using this steep 

slope ground based equipment would allow Alternative 2 – Modified Proposed Action to be implemented 

more efficiently, safely, and with lower cost per acre.

• Approximately 500 acres were designated as being non-conifer forest and would not receive any 

mechanical fuels treatment.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 27

• Approximately 11,100 acres of conventional ground based treatment using feller-bunchers and grapple 

skidders treatment.

• Some areas throughout the project area may have standing and down fuels piled and burned rather than 

removed. 

2.4.2.2 Post-Mechanical Treatments

Activity slash treatments would be accomplished using whole-tree skidding, machine piling, hand piling, 

mulching, crushing, commercial/personal use fuelwood sales, lop and scatter, and/or prescribed burning. 

Rehabilitation and reclamation of areas impacted from treatments would occur to ensure the health and 

productivity of the forested ecosystem is sustained. This would include work in aspen sites to protect newly 

developing aspen sprouts from elk and deer browsing with fencing and jack-strawing of activity slash.

2.4.2.3 Strategic Fuels Treatments 

Strategic fuel treatments designed specifically to enhance control lines would be implemented to enable land 

managers to achieve resource objectives with prescribed fire while serving to protect important resources. 

Treatments would reduce surface, ladder, and canopy fuels (i.e. fuel loading) up to 300 feet along both sides of 

control lines. The potential locations of these lines are illustrated in Map 2 (FEIS, Appendix A) and mitigation 

measures (FEIS, Chapter 2 Section 2.4.5) have been developed should additional control lines be necessary. 

Approximately 2,500 acres2

 would receive non-commercial treatments and fuels would most likely be thinned by 

hand-felling techniques or, where practical, machinery equipped with cutting or grinding heads. These treatments 

represent the minimum acreage needed to prepare stands on steeper slopes for prescribed burning and would be 

combined with mechanical treatments where possible.

2.4.2.4 Prescribed Fire

Prescribed fire would be used on approximately 15,200 acres of the project area. In some areas, prescribed fire 

would be used in conjunction with mechanical treatments to achieve restoration and fuel treatment objectives. In 

other areas where operability is limited and more costly, only prescribed burning may be used to meet resource 

objectives; this would be dependent on implementation of the strategic fuel treatments designed to enhance 

control lines (described above). 

• Prescribed burning may be implemented across the project area either prior to or following the 

mechanical treatments, with the exception of areas on steep slopes requiring the strategic fuels treatments 

described above. In most areas of the project, prescribed fire will follow mechanical treatments. Areas to 

be burned will be grouped into several burn units using natural and man-made features, such as roads, 

trails, and natural rock stringers, for control lines. The size, location, timing, and sequence of burning will 

consider impacts, such as smoke and risk of fire escape, to downwind communities and users of the 

National Forest.

• A combination of firing techniques, including ground and aerial ignitions, would be used to accomplish 

objectives and minimize the risk to human resources.

• Because the intent of prescribed burning is to reduce fuel loading, raise crown base heights and reduce 

live tree density, maintenance burning would be required every few years.

2.4.2.5 Transportation

Alternative 2-Modifed Proposed Action includes:

• Constructing approximately 15 miles (a reduction of 8 miles from the original proposed action) of new, 

permanent roads to provide sustainable access for ground-based logging treatments (Map 3, FEIS, 

 

2 Please note the proposed action in the scoping packet indicated that 1,500 to 2,500 acres would be treated as part of the 

strategic fuels treatment. In order to simplify the analysis, this has been clarified to indicate that approximately 2,500 acres 

would be treated; the maximum acreage that would be impacted.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

28 Chapter 2. Alternatives, Including the Modified Proposed Action

Appendix A). Sustainable access is a road system that will require less long-term maintenance and is 

located to allow logging access (Map 3, DEIS, Appendix A. 

• Constructing approx. 16 miles of temporary roads that would be obliterated after use. 

• Obliterating approx. 23 miles of poorly located roads (Map 4, FEIS, Appendix A). 

• Approximately 4 miles of existing road would be relocated to improve drainage. Additional drainage 

structures would be installed as needed on existing roads throughout the project area. 

Map 5 (FEIS, Appendix A) illustrates the transportation system after implementation of the project. The newly 

constructed roads would only be open for administrative use following implementation. The resulting open road 

system after implementation would reflect the June 2011 travel management decision (Map 6, FEIS, Appendix A). 

2.4.2.6 Trails

Because of the proposed changes to the transportation system, Alternative 2 would extend the Bixler Trail by 

converting a portion of Forest Service Road (FSR) 45 (from Bixler saddle south) to a non-motorized trail, 

constructing approximately 1 mile of new trail, and constructing a new trailhead and parking area along FSR 122 

(shown on Map 5, FEIS, Appendix A). This action will met the intent of the purpose and need of improving the 

motorized transportation system to provide for a more sustainable road system where poorly located roads are 

relocated or obliterated.

2.4.2.7 Aspen Restoration

Aspen treatments would include falling to stimulate new sprouting of aspen. Where aspen stands have good 

access, the entire aspen stand or a portion of the stand may be fenced in order to protect new aspen sprouts from 

elk browsing and to protect larger aspen from damage from elk rubbing and scraping. Some planting of aspen 

may be done in combination with aspen fencing. Aspen planting stock will be selected from nearby sites of the 

same elevation.

In more inaccessible aspen sites, conifers and dead aspen (dead less than 10” in diameter) will be felled and left in 

place in order to impede some elk access to the aspen and to give aspen sprouts some protection from elk 

browsing. These felled trees will generally not be lopped in order to create as much of an obstruction to elk access 

as possible. Most of the aspen sites are identified in the acreage amount but there are a few scattered aspen sites 

that are very small (less than 1 acre in size) that were missed in the aspen site inventory. 

2.4.2.8 Implementation

Implementation of the proposed action would begin in 2015 and would occur as funding and/or favorable 

conditions allow. 

2.4.3 Alternative 3

The main differences from the Modified Proposed Action and Alternative 3 are no ground based thinning 

operations on slopes greater than 40% (these areas would be treated via helicopter), thinning in MSO PAC and 

MSO mixed conifer recovery nest roost habitat would be restricted to 9 inches DBH and below, and no prescribed 

burning in the Arizona Bugbane Botanical Area. 

MSO PAC and recovery MSO nest roost habitat on slopes greater than 40% would be thinned to 9” DBH. 

To meet the purpose and need for action, the Kaibab National Forest proposes the following activities under 

Alternative 3.

2.4.3.1 Mechanical Treatments

Alternative 3 includes a combination of commercial timber harvest treatments and non-commercial mechanical 

treatments on approximately 15,200 acres. Treatments would thin stands with mechanized equipment to meet or 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 29

move toward the desired conditions; in some stands, non-commercial treatments may be the only treatments 

feasible/necessary to achieve resource objectives.

The operability zones portrayed in Map 7 (DEIS, Appendix A) are used to define Alternative 3 and illustrate the 

location of mechanical treatments within the project area. These zones share common operational attributes such 

as topography, terrain and potential logging system. 

Ground-based logging systems would be used to treat up to 11,150 acres within these zones and are limited in use 

to slopes less than 40%.

Ground-based logging systems would be used to treat up to 70 acres within zone 3. Due to the location of this 

zone near the top of the mountain and the only roaded access along Forest Service Road (FSR) 111 (Bill Williams 

Mtn. Rd), this zone would require specialized equipment (e.g. forwarder). Additionally, this zone would require 

an adverse skid to reach FSR 111. Then, due to the switchbacks along FSR 111 near the summit, skidding would 

also be required down FSR 111 to reach a suitable landing. Initial reviews of this zone indicate that the proposed 

ground-based logging system within this zone would be the most economically feasible treatment option; 

however, helicopter logging systems may also be utilized.

Helicopter logging would be used within this zone to treat approximately 3,980 acres due to steep slopes and 

limited access.

2.4.3.2 Post-Mechanical Treatments

Activity slash treatments would be accomplished using whole-tree skidding, machine piling, hand piling, 

mulching, crushing, commercial/personal use fuelwood sales, lop and scatter, and/or prescribed burning. 

Rehabilitation and reclamation of areas impacted from treatments would occur to ensure the health and 

productivity of the forested ecosystem is sustained. This would include work in aspen sites to protect newly 

developing aspen sprouts from elk and deer browsing with fencing and jack-strawing of activity slash.

2.4.3.3 Strategic Fuels Treatments 

Strategic fuel treatments designed specifically to enhance control lines would be implemented to enable land 

managers to achieve resource objectives with prescribed fire while serving to protect important resources. 

Treatments would reduce surface, ladder, and canopy fuels (i.e. fuel loading) up to 300 feet along both sides of 

control lines. The potential locations of these lines are illustrated in Map 2 (FEIS, Appendix A) and mitigation 

measures (FEIS, Chapter 2 Section 2.4.5) have been developed should additional control lines be necessary. 

Approximately 2,500 acres3

 would receive non-commercial treatments and fuels would most likely be thinned by 

hand-felling techniques or, where practical, machinery equipped with cutting or grinding heads. These treatments 

represent the minimum acreage needed to prepare stands on steeper slopes for prescribed burning and would be 

combined with mechanical treatments where possible.

2.4.3.4 Prescribed Fire

Prescribed fire would be used on approximately 14,710 acres of the project area. In some areas, prescribed fire 

would be used in conjunction with mechanical treatments to achieve restoration and fuel treatment objectives. In 

other areas where operability is limited and more costly only prescribed burning may be used to meet resource 

objectives; this would be dependent on implementation of the strategic fuel treatments designed to enhance 

control lines (described above). 

• Prescribed burning may be implemented across the project area either prior to or following the 

mechanical treatments, with the exception of areas on steep slopes requiring the strategic fuels treatments 

 

3 Please note the proposed action in the scoping packet indicated that 1,500 to 2,500 acres would be treated as part of the 

strategic fuels treatment. In order to simplify the analysis, this has been clarified to indicate that approximately 2,500 acres 

would be treated; the maximum acreage that would be impacted.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

30 Chapter 2. Alternatives, Including the Modified Proposed Action

described above. In most areas of the project, prescribed fire will follow mechanical treatments. Areas to 

be burned will be grouped into several burn units using natural and man-made features, such as roads, 

trails, and natural rock stringers, for control lines. The size, location, timing, and sequence of burning will 

consider impacts, such as smoke and risk of fire escape, to downwind communities and users of the 

National Forest.

• A combination of firing techniques, including ground and aerial ignitions, would be used to accomplish 

objectives and minimize the risk to human resources. 

• Because the intent of prescribed burning is to reduce fuel loading, raise crown base heights and reduce 

live tree density, maintenance burning would be required every few years.

2.4.3.5 Transportation

Alternative 3 includes:

• Constructing approximately 22 miles of new roads to provide sustainable access for ground-based logging 

treatments (Map 8, DEIS, Appendix A). 

• Constructing approximately 16 miles of temporary roads that would be obliterated after use (Map 8, 

DEIS, Appendix A).

• Obliterating approximately 24* miles of poorly located roads (Map 4, DEIS, Appendix A). * There were 

four miles of roads that were listed in the DEIS to be obliterated that were intended to be open under 

TMR.

Map 9 (DEIS, Appendix A) illustrates the transportation system after implementation of the project. Most of the 

newly constructed roads would be closed following implementation and allowed to re-vegetate naturally; 

additionally, drainage features such as culverts will be removed to minimize the long-term maintenance 

investment of retaining these roads. The resulting open road system after implementation would reflect the June 

2011 travel management decision (Map 6, DEIS, Appendix A). 

2.4.3.6 Trails

Because of the proposed changes to the transportation system, Alternative 3 would extend the Bixler Trail by 

converting a portion of Forest Service Road (FSR) 45 (from Bixler saddle south) to a non-motorized trail, 

constructing approximately 1 mile of new trail, and constructing a new trailhead and parking area along FSR 122 

(shown on Map 9, DEIS, Appendix A). This extension of the Bixler Trail will address the need of providing a 

more sustainable road system by repurposing a poorly located closed road. 

2.4.3.7 Implementation

Implementation of Alternative 3 would begin in 2015 and would occur as funding and/or favorable conditions 

allow.

2.4.4 Alternative 4 

The main differences between Alternative 4 and the Modified Proposed Action are no helicopter logging, no new 

permanent system road construction, only prescribed burning on slopes greater than 40%, except for strategic fuel 

lines.

To meet the purpose and need for action, the Kaibab National Forest proposes the following activities under 

Alternative 4.

2.4.4.1 Mechanical Treatments

Alternative 4 includes a combination of commercial timber harvest treatments and non-commercial mechanical 

treatments on approximately 11,150 acres. Treatments would thin stands with mechanized equipment to meet or 

move toward the desired conditions; in some stands, non-commercial treatments would be the only treatments 

implemented to achieve resource objectives.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 31

The operability zones portrayed in Map 10 (DEIS, Appendix A) are used to define Alternative 4 and illustrate the 

location of treatments within the project area. These zones share common operational attributes such as 

topography, terrain and potential logging system. 

Ground-based logging systems would be used to treat up to 11,150 acres within these zones and are limited in use 

to slopes less than 40%.

2.4.4.2 Post-Mechanical Treatments

Activity slash treatments would be accomplished using whole-tree skidding, machine piling, hand piling, 

mulching, crushing, commercial/personal use fuelwood sales, lop and scatter, and/or prescribed burning. 

Rehabilitation and reclamation of areas impacted from treatments would occur to ensure the health and 

productivity of the forested ecosystem is sustained. This would include work in aspen sites to protect newly 

developing aspen sprouts from elk and deer browsing with fencing and jack-strawing of activity slash. 

2.4.4.3 Strategic Fuels Treatments

Strategic fuel treatments designed specifically to enhance control lines would be implemented to enable land 

managers to achieve resource objectives with prescribed fire while serving to protect important resources. 

Treatments would reduce surface, ladder, and canopy fuels (i.e. fuel loading) up to 300 feet along both sides of 

control lines. The potential location of these lines are illustrated in Map 2 (DEIS, Appendix A) and mitigation 

measures (FEIS, Chapter 2 Section 2.4.5) have been developed should additional control lines be necessary. 

Approximately 2,500 acres would receive non-commercial treatments and fuels would be thinned by hand-felling 

techniques. These treatments represent the minimum acreage needed to prepare stands on steep slopes for 

prescribed burning. 

2.4.4.4 Prescribed Fire

Prescribed fire would be used on approximately 14,710 acres of the project area. In some areas, prescribed fire 

would be used in conjunction with mechanical treatments to achieve restoration and fuel treatment objectives. On 

steep slopes only prescribed burning would be used to meet resource objectives; this would be dependent on 

implementation of the strategic fuel treatments designed to enhance control lines (described above).

• Prescribed burning may be implemented across the project area either prior to or following the 

mechanical treatments, with the exception of areas on steep slopes requiring the strategic fuels treatments 

described above. In most areas of the project, prescribed fire will follow mechanical treatments. Areas to 

be burned will be grouped into several burn units using natural and man-made features, such as roads, 

trails, and natural rock stringers, for control lines. The size, location, timing, and sequence of burning will 

consider impacts, such as smoke and risk of fire escape, to downwind communities and users of the 

National Forest.

• A combination of firing techniques, including ground and aerial ignitions, would be used to accomplish 

objectives and minimize the risk to human resources. 

• Because the intent of prescribed burning is to reduce fuel loading, raise crown base heights and reduce 

live tree density, maintenance burning would be required every few years.

2.4.4.5 Transportation

Alternative 4 includes:

• Constructing approximately 38 miles of temporary roads that would be obliterated after use (Map 11, 

DEIS, Appendix A).

• Obliterating approximately 24* miles of poorly located roads (Map 4, DEIS, Appendix A). *There were 

four miles of roads that were listed in the DEIS to be obliterated that were intended to be open under 

TMR.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

32 Chapter 2. Alternatives, Including the Modified Proposed Action

Map 12 (DEIS, Appendix A) illustrates the transportation system after implementation of the project. The 

resulting open road system after implementation would reflect the June 2011 travel management decision Map 6 

(DEIS, Appendix A).

2.4.4.6 Implementation

Implementation of Alternative 4 would begin in 2015 and would occur as funding and/or favorable conditions 

allow.

2.4.5 Mitigation and Monitoring

The mitigation and monitoring measures designed specifically for the Bill Williams Mountain Restoration Project 

are described below in Section 2.4.5. The effectiveness of the mitigations measures is disclosed in Chapter 3 of 

the Environmental Impact Statement as the analyses for each alternative assumes the appropriate mitigations have 

been implemented. Monitoring measures are included in the project to ensure best management practices and 

mitigation measures are being implemented and that the objectives of the project are being met. 

2.4.5.1 Mitigation

The Forest Service employs several measures to reduce or prevent negative impacts to the environment in the 

planning and implementation of management activities. The application of these measures begins at the planning 

and design phase of a project. The Forest Plan Standards and Guidelines and the direction contained in the 

Watershed Conservation Practices Handbook (FSH 2509.25) are the first protection measures to be applied to a 

project. Both of these sources are incorporated by reference and are not reiterated here. Additional site-specific 

mitigation measures have been developed for this project, and are presented below. Unless specified otherwise, 

each mitigation measure applies to all action alternatives.

Wildlife

Mexican Spotted Owls

1. All treatment methods (thinning and burning) would occur outside of the Mexican spotted owl (MSO) 

breeding season (March 1 – August 31) in the Protected Activity Center (PAC) and within a 1⁄4 mile buffer 

around the PAC. Haul routes in the PAC and within 1⁄4 mile of the PAC will restrict speeds to 15 MPH or less. 

If no MSO are detected using formal monitoring protocol, implementation could begin at the discretion of the 

south zone wildlife biologist and district ranger.

2. Retain an average of at least 3 snags (>18” DBH) per acre, 5 downed logs (>12” midpoint diameter) per acre, 

and 10-15 tons of woody debris per acre (including downed logs) in mixed conifer forest and any forested 

habitat within the Bill Williams PAC.

3. Retain an average of at least 2 snags per acre, 3 downed logs per acre, and 3-10 tons of woody debris per acre 

(including downed logs) in ponderosa pine (including pine-oak) forest. 

Retention of these features would be measured at the mid-scale (approximately the 100-acre scale). 

Emphasize retention of snags that were created from trees that died slow deaths, not those created by highseverity fire or insect infestation. In order to retain desired snag densities, the following measures will be 

taken:

4. Snags >24” DBH would only be removed from pre-settlement patches when they are hazardous to operators.

5. Design helicopter and logging units to maintain groups and clumps of snags >18” DBH in the forested matrix 

outside pre-settlement patches.

6. In recovery habitat, attributes that have the potential to provide future nesting habitat would be maintained or 

encouraged to develop through management where they occur at low levels according to recommendations 

found in MSO Recovery Plan. These include large Gambel oaks, large conifers, and large snags, large down 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 33

logs and a canopy cover that maintains 40 percent minimum in pine-oak and 60% minimum in mixed conifer 

ground shading. 

7. Conservation measures require minimizing effects to large oaks, large snags (all decay stages), and large 

downed logs using the MSO Recovery Plan guidelines. This project protects, where available, and 

encourages the development of large snags (all decay stages), large downed logs, grasses, forbs, and shrubs 

using these recovery plan guidelines.

Bald Eagles 

8. Do not disturb breeding bald eagles during the breeding season. Maintain a 660 ft. buffer of no disturbance 

around active bald eagle nests from November 1st-June 30th, and maintain a 0.5 mile buffer around active 

eagle nests from January 1st-July 15th. No breeding bald eagles have been documented within 0.5 miles of 

the project area as of 2014. 

9. Project activities and special uses should incorporate recommended measures for eagle management such as 

temporary closures to limit human disturbance in the vicinity of eagle nests. 

Northern Goshawks

10. Limit human disturbance associated with the project implementation of Post-fledgling Family Areas (PFA’s) 

during the breeding season (March 1st – September 30th). 

11. Goshawk nest areas are multi-aged forests dominated by large trees with interlocking crowns and are 

generally denser than the surrounding forest. 

Additional Mitigation Measures for Wildlife Habitat Protection

12. Peregrine falcon habitat: Prohibit activities which disturb nesting birds between March 15 and August 15. 

13. Raptors other than MSO and Northern Goshawk: retain raptor nest tree-groups and a non-activity buffer: 

restrict activities within 300 yards of active raptor nest sites between April 1 and August 15.

14. Red squirrel habitat: Maintain the overstory integrity 1/2 chain (33 ft.) from red squirrel caches, and where 

operationally feasible, reduce direct disturbance to known caches.

15. Arizona Black Rattlesnake: Avoid management practices with potential to impact hibernacula; avoid 

temporary road construction within 300 feet of identified hibernacula locations. Within a quarter of a mile of 

known hibernaculum conduct prescribed fires from November 1 to March 31 to minimize impacts to snakes, 

and ignite slash piles in the winter or only on one side of the pile to allow for snakes to escape from the other 

side.

Habitat Attributes

16. Minimize the loss of pre-settlement trees, regardless of mistletoe infection. Where pre-settlement trees 

infected with mistletoe exist, leave additional post-settlement trees in groups to promote the abundance of 

large trees across the landscape ranging from 18”+ to 24”+ dbh). Note that pre-settlement trees will be 

visually identified.

17. Retain at least 3 snags (>18” DBH) per acre, 5 downed logs (>12” midpoint diameter) per acre, and 10-15 

tons of woody debris per acre (including downed logs) in mixed conifer forest and any forested habitat within 

the Bill Williams PAC. Retain at least 2 snags per acre, 3 downed logs per acre, and 5-7 tons of woody debris 

per acre (including downed logs) in ponderosa pine (including pine-oak) forest. Retention of these features 

will be measured at the mid-scale such as drainage (approximately the100-acre scale). Emphasize retention of 

snags that were created from trees that died slow deaths, not those created by high-severity fire or insect 

infestation. In order to retain desired snag densities, the following measures will be taken: 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

34 Chapter 2. Alternatives, Including the Modified Proposed Action

a. Strive to conserve snags >18” DBH in pre-settlement patches (identified in desired conditions which are 

included in each specialist report unless they pose a risk to operator safety. Where snags are present in 

these patches, use alternate fuels treatment methods (e.g., thin from below, piling, burning). 

b. Design cutting units to maintain small clumps of snags >18” DBH in the forested matrix outside presettlement patches and on slopes >40%. 

Vegetation 

18. Due to potential bark beetle infestation problems, avoid non-commercial thinning that will create excessive 

amounts of activity slash between the dates of January 1 and July 1, especially near private property.

Range 

19. Post-fire grazing should not be authorized until district range staff confirm range readiness. When necessary, 

pastures scheduled for burning will be rested for at least one growing season prior to and following prescribed 

burning. Soil stability and plant health will be assessed prior to the authorization of grazing in prescribed 

burned areas.

Rare Plants

20. Known and newly discovered populations of rare plant species will be protected to limit negative impacts 

(e.g. where possible road construction will avoid known plant populations). 

21. Project design would incorporate measures to protect and provide for rare and narrow endemic species where 

they are likely to occur.

22. Rare plant surveys and surveys for Native American medicinal and ceremonial plants, such as Porter's 

licorice-root (syn. osha root, Ligusticum porteri); within the project area will occur where suitable habitat 

exists. The extent and scale of these surveys will be dependent upon funding. 

Noxious Weeds 

23. Implement “Appendix B: Design Features, Best Management Practices, and Mitigation Measures” identified 

in the “Final Environmental Impact Statement for Integrated Treatment of Noxious or Invasive Weeds on the 

Coconino, Kaibab, and Prescott National Forests within Coconino, Gila, Mojave, and Yavapai Counties, 

Arizona” (2005).

24. All ground-disturbing projects would assess the risk of noxious weed invasion and incorporate measures to 

minimize the potential for the spread of noxious and invasive species. New populations would be monitored, 

and treated as soon as possible. 

25. Treatment approaches should use integrated pest management (IPM) practices to treat noxious and nonnative 

invasive species. IPM includes manual, biological, mechanical, and herbicide/pesticide treatments. 

Mitigations specific to the Arizona Bugbane Botanical Area

Arizona bugbane is a sensitive species on the Kaibab National Forest, and management area has been set aside for 

it on Bill Williams Mountain. The Arizona Bugbane Botanical Area is comprised of 490 acres on the northwest 

slope of Bill Williams Mountain. The Arizona Bugbane Conservation Assessment and Strategy (1995) developed 

in conjunction with the USFWS contains direction on several management concerns including degradation of the 

integrity of the ecosystem, which focuses on preservation of the shaded habitat needed for the species, grazing 

impacts, recreation impacts, mining, pesticide use and natural threats including certain plant diseases. The Kaibab 

National Forest has been working closely with USFWS to develop mitigation measures for the Arizona Bugbane 

Botanical Area. An updated conservation agreement for the plant is being developed for the Kaibab and 

Coconino National Forests that will guide future management of this important plant. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 35

26. There would be a "limited treatment buffer zone" surrounding the "inner buffer zone" (see Figure 2-14) where 

the only treatment would be ladder fuel reductions to protect the overstory canopy. The fuels that may be 

removed in the limited treatment buffer zone are those posing an immediate threat to the overstory canopy 

from fire. The buffer would be clearly flagged prior to any project-related activities.

27. The exact location of the inner buffer zone and the limited treatment buffer zone boundaries would be 

determined and mapped collaboratively on the ground by fuels, silviculture, soils, and rare plant specialists. 

Buffer zone boundaries would be based on fuels, topography, slope, aspect, and adjacent habitats and plant 

communities. Specific polygons delineating buffer zone boundaries will be incorporated into the project 

implementation plan following the FEIS.

28. Existing Arizona bugbane populations would not be directly ignited during prescribed burning.

29. Deciduous trees > 5" DBH or shrubs > 5" DRC within the Botanical Area would not be removed during 

thinning operations. Where safe and practical, minimize the loss of deciduous trees and shrubs >12" DRC.

30. Trees within the botanical area that are part of the upper canopy and contribute to suitable habitat would not 

be removed during thinning. Areas within the botanical area not contributing to suitable habitat where 

portions of the upper canopy may be removed would be identified by silviculturists and rare plant specialists. 

31. Fell trees near existing Arizona bugbane populations away from the populations.

32. Treated slash in areas of the Botanical Area with soils at high risk of unacceptable erosion would be handpiled. Grapple piling may be used on stable soils if monitoring demonstrates acceptably low impacts to soils.

33. Dozers may be used for fireline construction only on former roads or in consultation with the soils and rare 

plant specialists.

34. The botanical area would not be seeded following thinning or burning treatments in order to prevent the 

introduction of invasive species and to prevent attracting wild ungulates to the area.

35. Once completed, monitoring recommendations from the new Arizona Bugbane Conservation Assessment and 

Strategy would be incorporated into the project implementation plan.

36. Buffer zones will be determined based on fuels, topography, slope, aspect, and adjacent habitats and plant 

communities.

37. Specific polygons delineating buffer zone boundaries will be incorporated into the project implementation 

plan.

38. Flexibility is incorporated into these mitigation measures so that fuels may be manipulated within the buffer 

zones while maintaining the overall objectives of protecting the specific habitat components that provide for 

the site's micro-climate. More specifically, fuels that directly threaten the Arizona bugbane population through 

heating, or that may increase the risk of crown fires may be removed from the buffer zones.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

36 Chapter 2. Alternatives, Including the Modified Proposed Action

Figure 2-14. Diagram showing the approximate buffer zones for the Arizona Bugbane Botanical Area mitigation 

measures

Cultural Resources

The following mitigation measures are in accordance with Appendix J of the First Amended Programmatic 

Agreement (PMOA 2009) between Region Three, Arizona, New Mexico, Oklahoma, and Texas State Historic 

Preservation Officers, and the Advisory Council on Historic Preservation. Prior to the various project 

implementation phases, project managers must consult with archaeologists who will then flag or paint site 

boundaries for avoidance. If any unrecorded heritage resources are discovered during project implementation, all 

project related activities will cease immediately and the consultation process as outlined in Section 800.13 of the 

Advisory Council on Historic Preservation’s regulations 36 CFR Part 800 will be initiated. 

39. Pre-commercial thinning, roundwood and sawtimber thinning: These activities “have predictable effects and 

a very low likelihood of affecting historic properties.” (PMOA 2009). If known historic properties are within 

these types of project areas, the sites would be flagged. Hand treatment will be allowed within site boundaries 

but the fuels would be hand carried and piled outside of site boundaries. Mechanical timber harvesting, 

helicopter logging, cable logging, skidding, crushing: Prior to any proposed mechanical treatments project 

managers must consult with heritage specialists prior to project implementation to ensure the boundaries of 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 37

sites within the treatment areas are flagged or painted for avoidance. An archaeologist will also show the 

project managers and equipment operators how to distinguish the areas to be avoided, and give them a contact 

name if a previously unrecorded site is uncovered due to the project activities. 

40. Prescribed Fire: All fire sensitive sites will be flagged for avoidance, and in some cases black lined. Project 

and fire managers must consult with archaeologists, prior to implementing burn activities, to ensure that onsite fuels are such that they will not burn with prolonged or extreme heat. If necessary, excess fuels will be 

removed by hand from sites. 

41. Mechanical and Hand Piling: All known eligible or unevaluated heritage resource sites would be flagged for 

avoidance, thus all wood piling and heavy machinery activities will be conducted outside of site boundaries, 

except for sites that are bisected by Forest Service System Roads. In those cases, all activities will be confined 

to the road prisms. 

42. Fire-line Construction: All planned fire-lines must avoid known heritage resource sites. Planned fire lines 

constructed with bulldozers can occur within previously surveyed areas where known sites have been flagged 

for avoidance by archaeologists. If lines are proposed to be constructed in areas that have not been evaluated 

by archaeologists, these areas will require additional survey prior to fire-line construction. In the event that 

emergency dozer fire-lines are warranted, fire managers must contact the district archaeologist immediately 

so that site avoidance and mitigation measures can be devised and employed as needed.

43. Road Maintenance/Construction: Engineers use road graders to conduct routine road maintenance activities 

within existing road prisms and features. No protective or mitigation measures are required in areas that have 

undergone previous surveys and where no heritage resource sites are known to exist. New road construction 

may occur only in previously surveyed areas that contain no eligible or unevaluated sites. If new roads are 

proposed in unsurveyed areas, the project area must first be surveyed for heritage resources and an 

amendment to the project clearance drafted.

Scenic Resources 

The Recreation Opportunity Spectrum/Scenery Management System (ROS/SMS) Guidebook states recovery 

timelines for Scenic Integrity Objectives (SIO) 2 and SIO 3 of one year and two years respectively, after 

implementation. The Kaibab National Forest Recreation Opportunity Spectrum and Scenery Management 

Guidebook, Appendix B allows for the SIO to drop one level during critical project and management activities, 

such as the restoration of Bill Williams Mountain. It is unlikely that the SIO recovery to satisfactory levels will 

meet the expected timelines; therefore, SMS direction for the SIO levels 2 and 3 would be met within 5-10 years 

after project completion. Although this represents a short term deviation from this guideline the intent of the 

guideline will be met in 5 to 10 years.

44. When thinning forest vegetation geometric shapes will not be introduced and high contrast will be avoided 

between treatment locations. Feather edges of treatment areas to reduce the contrasting scenery of these 

edges.

45. Prescribed burn blocks will not have geometrical shapes and fire lines will be constructed, wherever possible, 

to reduce the contrast so that they are not noticeable in the middle and background views. 

46. Control lines will be rehabilitated by re-contouring berms, pulling logs and rocks across the lines and 

disguising entry and exit points. 

47. In grassland restoration treatments, slash needs to be hand piled and burned within the first 300 feet of the 

foreground. Beyond 300 feet in middle-ground and background areas, slash must be treated. 

48. Hand pile in the first 300 feet and burn activity generated slash in the foreground areas of sensitive travel 

corridors (County Road ((CR)) 73, Forest Road ((FR)) 173B, FR 106, FR 111, FR 108, FR 122) and 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

38 Chapter 2. Alternatives, Including the Modified Proposed Action

surrounding the new and existing trailheads, Forest Trails (FT 38, FT 21, FT 72, FT 124, FT 46, FT 130). 

Beyond 300 feet, slash must be treated.

49. New and temporary road construction inside of sensitive travel corridors will use native materials for riprap. 

Develop and review slope stabilization materials with the Landscape Architect prior to construction. Try to 

balance cut and fill. If constructed slopes are necessary, stabilize slopes using best management practices or 

rehabilitate slopes by roughening surface, seeding with weed-free native species and mulching. Do not leave 

“eye brows” at the tops of cut slopes.

50. Roads that are considered unnecessary for further management of the mountain will be decommissioned once 

work is completed. Roads must be effectively closed at entry/exit points preferably with large boulders and/or 

logs and allowed to re-vegetate naturally, or will be scarified, seeded (with native species) and mulched to 

promote vegetation. Road bed will be stabilized per best management practices. Berms will only be used if 

there is no other effective means of closing off these roads. 

51. Tree marking within 150 feet from Forest Roads and Forest Trails (includes roads number CR 73, FR 106, FR 

111, FR 108, FR 122 and trail numbers FT 38, FT 21, FT 72, FT 124, FT 46, FT 130) shall be done in a 

manner to minimize visibility. Butt marks may face roads and trails.

52. Utilize existing skid roads and landings to the extent possible.

Recreation Resource

53. In Semi-primitive Non-motorized (SPNM) areas (Approx. 2,698 acres):

a. Approximately 2/3 of a mile of re-opened Maintenance Level (ML) -1 roads will be required for the 

project. The roads will be closed to continued use and restored to original conditions when the projects 

are completed. The same measures will be in place for all landings and skid trails. 

b. Activity generated slash must be treated. Slash treatment should generally occur within one year after 

treatment. (For much of the SPNM area it is expected that little slash will be generated, as the whole tree 

would be removed in alternatives that have helicopter logging operations.)

c. Flush cut or low cut stumps to 6” in the foreground of travel corridors that will remain open. Flush cut or 

low cut to 8” in middle-ground or background areas.

54. In Semi-Primitive Motorized (SPM) areas (Approx. 4,910 acres):

a. Activity slash in foreground areas of SPM will be piled and burned, which will include along all new and 

existing roadways located in this ROS class. Slash will be treated throughout the ROS, mostly through 

burning within 2 years, where possible.

b. Flush cut or low cut stumps to 6” in the foreground of travel corridors. This will include all the new roads 

added within this ROS. Flush cut or low cut to 8” in middle ground or background areas.

c. Do not establish personal use or commercial use fuelwood cutting areas in this class. Prohibit motorized 

cross country travel for fuelwood cutting.

55. In Roaded Natural (RN) areas (Approx. 8,776 acres):

a. Temporary roads will be obliterated when projects are completed. Roads that are considered unnecessary 

for further management of the mountain will be decommissioned once work is completed. Roads must be 

effectively closed at entry/exit points preferably with large boulders and/or logs and allowed to revegetate naturally, or will be scarified, seeded (with native species) and mulched to promote vegetation. 

Road bed will be stabilized per best management practices. Berms will only be used if there is no other 

effective means of closing off these roads.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 39

b. In foreground areas of travel corridors stumps should be cut as low as possible or flush cut. If it is not 

possible to flush cut, a common practice is to angle the cut away from trails and roads where they would 

be visible.

c. Hand pile slash within the first 300 feet of developed recreation sites, private homes, Forest Trails, 

trailheads and Forest Roads (CR 73, FR 106, FR 111, FR 108, FR 122 and surrounding the new and 

existing trailheads and Forest Trails (FT 38, FT 21, FT 72, FT 124, FT 46, FT 130). Beyond 300 feet in 

middle-ground and background areas, slash must be treated. When possible, activity created slash in 

foreground areas must be treated within one year in areas adjacent to and visible from developed 

recreation sites, private homes, Forest Trails and Forest Roads, and within two years in the rest of this 

ROS class.

56. In Rural (R) areas (Approx. 1,282 acres):

a. Temporary roads will be obliterated when projects are completed. ML-1 roads must be effectively closed 

at entry and exit points with large boulders and/or logs by pulling debris and rocks across roads.

b. Stump heights shall be flush cut, generally less than 6”, or as low as possible on larger diameter trees.

c. Fire control lines will be disguised in foregrounds of sensitive travel corridors, and areas next to 

communities/private lands, and developed recreation sites by pulling debris and rocks across the lines, 

and disguising entrance/exits.

d. Hand pile visible slash within the first 300 feet of developed recreation sites, private homes, Forest Trails, 

trailheads and surrounding the existing trailheads and Forest Trails (FT 124, FT 46, and FT 130). Beyond 

300 feet in middle-ground and background areas, slash must be treated. Where possible, activity created 

slash must be treated within one year in areas adjacent to and visible from developed recreation sites, 

private homes, Forest Trails and Forest Roads, and within two years in the rest of this ROS class.

57. During project implementation, especially during mechanical treatments, temporary road and trail closures 

will be implemented at the authorized officer’s discretion for health and safety. 

Mitigation Measures to Address Tribal Concerns

58. Consider all requests to issue temporary closures within the project area to accommodate ceremonial use 

as authorized in the Food, Conservation, and Energy Act of 2008, SEC. 8104.

59. Ensure that free-use permits for the collection of tree boughs, thinning slash, branches and other nonmerchantable timber are readily available to tribal members for fuelwood or personal ceremonial use. 

60. Coordinate with the Hopi Tribe to provide timbers for the purpose of rebuilding kivas and clan houses, 

and for other traditional and cultural purposes. The Hopi Tribe will provide for the transport of all such 

materials. The Forest will work with additional tribes to provide forest products for similar requests. 

61. Maintain the confidentiality of specific ceremonial sites and traditional collecting areas. During 

implementation, coordination and monitoring will occur to ensure specific ceremonial sites are avoided 

by project activities, or the Forest will work with the affiliated Tribe to develop site-specific mitigation 

measures. 

62. Invite the Havasupai Tribe to monitor the project during implementation. The Forest will work with all 

tribes to coordinate project monitoring by tribal representatives upon request.

63. Contract with the Hualapai Tribe to perform plant surveys conducted within the project area under a grant 

funded by the Coconino County Resource Advisory Committee. This work began in the fall of 2012.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

40 Chapter 2. Alternatives, Including the Modified Proposed Action

64. Continue to work with tribes to identify traditionally important plant species and populations that occur 

within the project area, and facilitate the sustainable collection of these resources for traditional and 

cultural purposes. Monitoring of known or newly documented collection sites will occur within the 

project area during implementation. Newly documented populations will be recorded and mapped for 

consideration as collection sites.

2.4.5.2 Monitoring

Monitoring is gathering information, observing processes, and examining the results of management activities to 

provide a basis for evaluation. Monitoring is done at both the project and Forest Plan level. The Bill Williams 

Mountain Restoration Project contains project specific monitoring. It also includes Forest Plan monitoring and 

evaluation items where appropriate. Monitoring in the Bill Williams Mountain Restoration Project includes 

implementation monitoring and evaluation to guarantee that Best Management Practices and Forest Plan 

Standards and Guidelines are being incorporated during the project activities, as well as effectiveness monitoring 

and evaluation to determine whether objectives of the project are being met. Below are monitoring measures that 

would be incorporated into this project.

Wildlife

Mexican Spotted Owls

1. Survey suitable MSO nesting/roosting habitat in the project area prior to implementation, either during the 

year of implementation or one year prior to implementation.

2. Dependent on available resources, post-treatment monitoring would occur 1-2 years after the first thinning or 

burning treatments within protected habitat. Attributes to monitor include units/acre and/or basal area of oaks 

and other hardwoods greater than or equal to 10 inches DRC, trees 12-18 inches dbh), trees greater than or 

equal to 18 inches dbh, down logs greater than or equal to12 inches midpoint diameter, snags greater than or 

equal to 18 inches dbh, and coarse woody debris.

3. Incidental take monitoring would include information such as when or if the project was implemented, 

whether the project was implemented as proposed and analyzed in the site-specific BO, breeding season(s) 

over which the project occurred, and relevant owl survey information. 

Northern Goshawk

4. Wildlife biologists would survey in and around northern goshawk nest areas and PFAs to monitor occupancy 

and reproductive success after project implementation.

Fuels Management

5. Pre- and post-burn monitoring would be accomplished using various fuels surveys to determine the success in 

reducing fuel loads and fire risk (canopy closure, fuel ladders, duff and litter layer depths, etc.) of first-entry 

treatments. Successive maintenance burning will be monitored post-treatment to determine success in further 

reducing fuel loads and fire risk.

Rare Plants

6. Known locations of rare plant populations within the project area will be monitored throughout project 

implementation and thereafter to minimize disturbance and provide for protection.

Noxious Weeds

7. Monitor the project area for noxious weeds for at least three years following both mechanical and burning 

treatments. Control weeds as necessary following the 2005 decision for Integrated Treatment of Noxious or 

Invasive Weeds on the Coconino, Kaibab, and Prescott National Forests.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 41

Heritage Resource 

8. 20% of all fire sensitive sites will be monitored post fire implementation pursuant the 2004 PMOA between 

R3, Arizona, New Mexico, Oklahoma and Texas SHPOs and the Advisory Council and the 2009 Kaibab 

Heritage Fire Strategy between the Kaibab and the AZSHPO. Sites will be monitored during and post project 

implementation.

Monitoring specific to the Arizona Bugbane Botanical Area

9. The Arizona Bugbane Botanical Area would be monitored throughout project implementation and thereafter 

for invasive plant species until the area has adequate native plant establishment to limit future invasions. 

Invasive plant species will be treated as necessary. 

10. Effectiveness monitoring within the botanical area and existing Arizona bugbane populations will occur 

throughout project implementation to ensure adequate protection.

Scenic Resources 

11. Closures of temporary or ML-1 roads will be monitored following closure to ensure effectiveness. Additional 

enforcement and physical measures will be taken to restrict unauthorized road use.

12. Treatment of activity created slash will be monitored to assure timeliness and compliance with the ROS and 

SIO guidebook.

Soil and Watershed 

13. During Timber Harvest Activities - The timber sale administrator will monitor the implementation of BMP’s 

during timber harvesting activities. Notes taken by the timber sale administrator would be used to track any 

issues or problems with BMP implementation. The Forest Soils and Watershed Specialist will provide 

assistance as needed by the timber sale administrator to provide clarification of BMP’s specified in the 

Environmental Impact Statement (EIS).

14. Timber Sale Closure - The timber sale administrator will verify that the timber sale purchaser has 

implemented all erosion control measures prior to the closure of the timber sale. Primary responsibility will 

be that of the timber sale administrator with assistance from the forest soils and watershed specialist if 

needed.

15. Broadcast and Pile Burning - The district fire management officer would verify that all erosion control 

measures associated with all burning activities have been implemented. The forest soils and watershed 

specialist would provide assistance, if needed.

16. Effectiveness Monitoring - Within the first 5 years following timber sale closure, BMP’s are evaluated for 

effectiveness. Monitoring would concentrate on such items as erosion control measures for skid trails, log 

landing or decking areas, road maintenance, road obliteration, and burned areas. The forest soils and 

watershed specialist would conduct a soil condition evaluation within cutting units. Focus on such items as 

vegetative ground cover, coarse woody debris, erosion, soil compaction, and soil displacement would occur. 

All monitoring results would be documented. Primary responsibility is with the Williams District Ranger and 

the forest soils and watershed specialist.

17. Follow Up - Documented information obtained from monitoring is used to adjust BMPs as necessary and to 

improve implementation and effectiveness of BMPs. Information regarding monitoring results and 

recommended changes to BMPs will be made available to the Arizona Department of Environmental Quality 

(ADEQ) for review as specified in the Intergovernmental Agreement between the State of Arizona and U.S 

Department of Agriculture, Forest Service Southwestern Region. Primary responsibility is with the Williams 

District Ranger and the forest soils and watershed specialist.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

42 Chapter 2. Alternatives, Including the Modified Proposed Action

2.4.6 Alternatives Considered but Eliminated from Detailed Study

Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable alternatives 

and to briefly discuss the reasons for eliminating any alternatives that were not developed in detail (40 CFR 

1502.14). Public comments received in response to the Proposed Action provided suggestions for alternative 

methods for achieving the purpose and need. Some of these alternatives may have been outside the scope of the 

project, duplicative of the alternatives considered in detail, or determined to have components that would cause 

unnecessary environmental harm or unnecessary safety concerns. Therefore, a number of alternatives were 

considered, but not considered in detail for reasons summarized below. 

• An alternative was considered but eliminated from detailed study that would only utilize prescribed 

burning techniques to meet the desired conditions. It was determined a prescribed burn on the steep slopes 

within the project area could not be implemented safely or without causing an undue risk to life and 

property due to a lack of control features that would help contain the fire to a specific area. Even in 

consideration of the City Project which surrounds the base of Bill Williams mountain south and southwest 

of town, the treatments associated with that project do not create a sufficient enough fuel break near 

Clover Hill (which is just above City and Santa Fe reservoirs) and the ski area to safely contain a 

prescribed burn onto federal lands. Additionally, this alternative would not meet the purpose and need for 

action because it would not provide for forest products, and would not effectively meet the need to reduce 

stand densities. As Kaufmann et al. (2005) demonstrates, the best way to restore forested stands that are 

denser than historical times is through mechanical prescribed cutting. Current conditions in the ponderosa 

pine and frequent fire mixed conifer forests have accumulations of live and dead woody material that can 

lead to uncharacteristic and undesirable fire effects. With a “hands-off approach”, fire and other natural 

disturbances are the only available mechanisms for making progress toward reference conditions. Under 

current conditions, when wildfires occur, they typically either do not do enough to lift tree crowns and 

open up tree density, or they burn with high intensity, resulting in the loss of ecosystem diversity, 

structure, and process.”

• An alternative was considered but eliminated from detailed study that would implement a permanent 

campfire ban within the project area. This alternative was eliminated from detailed study because it would 

not meet the purpose and need for action (Section 2.4.6) and was outside the scope of the project because 

they are plan-level decisions that must be accompanied by closure orders. It would not reduce hazardous 

fuels and would not move vegetative conditions in the project area towards the desired conditions. While 

escaped campfires pose a hazard to the watershed, forest managers already possess the ability and 

discretion to implement campfire bans and restrict campfire use within the project area when conditions 

warrant.

• An alternative was considered but eliminated from detailed study that would not construct any temporary 

roads or new system roads. This alternative was eliminated from detailed study because it would not meet 

the purpose and need for action (Section 2.4.6). While hand crews can be used in areas that have no roads 

to treat areas to move toward the desired conditions, there is a need to improve the motorized 

transportation system in the project area to provide for a more sustainable road system where poorly 

located roads are relocated. This alternative would not allow the relocation of poorly located roads 

because construction of new roads would be necessary to replace the access to the area. Additionally, this 

alternative was eliminated because Alternative 1, the No Action Alternative, does not include any 

temporary roads or new system road construction and addresses this issue.

• An alternative was considered but eliminated from detailed study that would conserve trees larger than 16 

inches diameter at breast height (dbh) outside of a well-defined wildland-urban interface (WUI) zone 

comprising a one-quarter (1/4) mile distance from established residential and other community 

infrastructure. This alternative would implement a 16 inch diameter cap on treatments outside of the WUI. 

This alternative was suggested to the Forest Service by the Center for Biological Diversity (CBD) and 

their reasons for suggesting the alternative (as written in their 2011 scoping comments). This alternative 

was eliminated from detailed study for the following four reasons: 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 43

1. CBD states “A size threshold of 16-inches dbh consistently defines “large” trees in the literature on 

southwestern ponderosa pine forests (Abella et al. 2006, Friederici 2003).” The definition of a large 

tree is somewhat subjective and neither the Forest Service nor the literature CBD cites defines “large” 

trees as those being greater than or equal to 16 inches dbh. Friederici (2003) discusses the debate 

about diameter caps within the context of the experimental plots of the Greater Flagstaff Forest 

Partnership and does not define large trees as those greater than or equal to 16 inches dbh, rather he 

discusses how a 16 inch diameter cap was implemented to address political concerns at the expense of 

restoration objectives. Abella et al. (2006) focuses its research on 16 inch trees because that “size has 

been widely proposed in the Southwest” and states “Consensus disintegrates...when attention turns to 

thinning young, post settlement trees of relatively large diameter (often defined as > 16 in.) emphasis 

added.” Additionally, Abella et al. (2006) states that “[diameter] caps are a one-size-fits-all policy” 

and recognizes how management decisions regarding diameter caps should consider management 

objectives and desired future stand conditions. The Forest Service does not define large trees as those 

above a certain diameter because it recognizes that different sizes of trees provide different functions 

within the ecosystem, which is why the effects to several different diameter classes of trees are 

analyzed in Chapter 3. Chapter 3 discloses the environmental effects of thinning trees across varying 

diameter classes to meet ecological objectives. 

2. While CBD suggests a WUI zone comprising a one-quarter (1/4) mile distance from established 

residential and other community infrastructure, the Region 3 supplement to Forest Service Manual 

5140 (effective 09/07/2010) states that 

WUI includes those areas of resident populations at imminent risk from wildfire, and human developments 

having special significance. These areas may include critical communications sites, municipal watersheds, 

high voltage transmission lines, observatories, church camps, scout camps, research facilities, and other 

structures that if destroyed by fire, would result in hardship to communities. These areas encompass not 

only the sites themselves, but also the continuous slopes and fuels that lead directly to the sites, regardless 

of the distance involved.

Following the Region 3 definition of WUI and the recommendations in the Greater Williams Area 

Community Wildfire Protection Plan (2005), the entire project area is considered within the WUI. 

This is essential because the purpose and need of the project is to protect the watershed and reduce 

the threat of high intensity stand-replacing wildfires. The rationale for such large zones is that 

wildfires in recent history, under critical fire danger conditions, have demonstrated rapid rates of 

spread over great distances in a single burning period, posing threats to communities and 

infrastructure miles from the point of origin.

Achieving desired conditions for the entirety of the CWPP WUI zones is a long-term aspiration, but it 

is not within the capacity of the Forest Service to achieve within the projected life of the CWPP WUI 

plan. Also, these zones do not cover many other highly valued human developments at risk on, and 

adjacent to, the Kaibab NF. For the purposes of the CWPP WUI plan, the WUI area is refined to a 

buffer around WUI values to focus more intensive treatments where they will have the most impact 

for fire protection, and includes the following lands:

 Half-mile buffer around all private lands. 

 Half-mile buffer around administrative sites, fee use cabins, fire lookouts, developed 

campgrounds, day use picnic areas, and facilities managed under special use permits.

 Half-mile buffer around at-risk communication sites.

3. A significant issue was identified from the scoping comments that reflected the importance of 

retaining pre-settlement trees (see Issue 1). In order to address the issue, the Forest Service developed 

a mitigation measure designed to retain where possible all pre-settlement trees. Pre-settlement trees 

are generally defined as those trees greater than 140 years old and are more indicative of the 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

44 Chapter 2. Alternatives, Including the Modified Proposed Action

vegetative reference conditions than an arbitrary diameter cap. The effects analysis in Chapter 3 

discloses the effectiveness of the mitigation measure for each alternative analyzed in detail.

4. A 16 inch diameter cap would not meet the Purpose and Need for Action (Section 1.3) and not meet 

or move vegetative conditions toward the goals and objectives of the Forest Plan. The Forest Service 

has a vast amount of experience analyzing and implementing restoration projects (with and without 

diameter caps) in the Southwest. For example, on the Williams Ranger District we have recently 

worked on the Spring Valley Urban/Wildland Interface Fuels Reduction Project (decision signed in 

1999), the Frenchy Vegetation/Fuels Management Project (decision signed in 2003), the Dogtown 

Fuels Reduction Project (decision signed in 2004), the City Project (decision signed in 2005), and the 

McCracken Project (decision signed in 2012). Our experience has shown that projects with diameter 

caps do not adequately reduce the risk for a stand-replacement fire because stand density and canopy 

closure can remain high. Additionally, projects with diameter caps are likely to create more of an 

even-aged forest structure (because more trees are retained in the older age classes) and are not likely 

to create or maintain vegetation structural stage (VSS) classes 1 & 2 where openings and young trees 

dominate the landscape. Also, it is difficult to manage for uneven aged management when there are 

too many mistletoe infection centers in the overstory; our Forest Plan directs us to manage for 

uneven-aged stand structure.

• An alternative was considered but eliminated from detailed study that would represent the “Citizen’s 

Alternative” as suggested by WildEarth Guardians (see their 2011 scoping comments for details). This 

alternative would implement a 12 inch diameter cap and was eliminated for the same reasons as the 

alternative described above that was suggested by the Center for Biological Diversity; a 12 inch diameter 

cap would not meet the Purpose and Need for Action (Section 1.3) and not meet or move vegetative 

conditions toward the goals and objectives of the Forest Plan. Other portions of the alternative such as 

treatments in the WUI (see discussion point #2 above); fuel breaks (Strategic Fuel Treatments); restoring 

natural fire regimes (see Section 1.3 Purpose and Need for Action) and prescribed fire (Section 2.2); 

protection of soils (DEIS Appendix B Soil and Watershed Best Management Practices); mitigation and 

monitoring measures (Section 2.4.5 are already incorporated and considered in the proposed action. 

2.4.7 Comparison of Alternatives

This section provides a comparison of the key features of the alternatives analyzed in detail (Table 2-5) and a 

summary of the effects of implementing each alternative (Table 2-6). Information in the tables is focused on 

activities and effects where different levels of effects or outputs can be distinguished quantitatively or 

qualitatively among alternatives. 

Table 2-5. Comparison of alternatives – key features1

Key Feature Unit of Measure

Alternatives

Alternative 1 

No Action

Alternative 2 

Modified 

Proposed Action Alternative 3 Alternative 4

Mechanical 

Treatments

Acres using groundbased logging 

equipment

0 11,220 11,220 11,150

Acres using a cable 

logging system2

0 0 0 0 

Acres using a 

helicopter logging 

system

0 ~1,060 3,980–4,050 0 

Strategic Fuels 

Treatments3

Acres of noncommercial fuels 

treatments to enhance 

control lines

0 2,500 2,500 2,500

Prescribed Fire Acres of prescribed 

burning

0 15,200 14,710 14,710
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 45

Key Feature Unit of Measure

Alternatives

Alternative 1 

No Action

Alternative 2 

Modified 

Proposed Action Alternative 3 Alternative 4

Transportation1 Miles of new road 

construc

0 15 22 0 

Miles of temporary 

road construction

0 16 16 38

Miles of road 

obliterated

0 23 24 24

Miles of road relocation 0 4 4 4 

Trails Conversion of FSR 45 

to non-motorized trail

No Yes Yes No

Conversion (miles) of 

FSR 45 to nonmotorized trail

0 1 1 0 

Construction of a new 

Bixler trailhead

No Yes Yes No

Forest Plan 

Amendments

No forest plan amendments are needed now that there is a revised forest plan

Note that the strategic fuels treatment acres and acres of prescribed burning overlap with the mechanical treatments.

1 Acreages and mileages are approximate.

2 There is no longer any cable logging included in this project.

3 This acreage of treatment overlaps with other areas because there is the potential the area may be treated with either mechanized 

equipment or with hand-felling techniques.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

46 Chapter 2. Alternatives, Including the Modified Proposed Action

Table 2-6. Comparison of alternatives – summary of effects on resources

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Silviculture

Tree Density Maintains highest tree density of 

alternatives

Reduces tree density and 

creates lowest tree density of 

alternatives

Reduces tree density Reduces tree density except in 

inoperable areas for ground 

based equipment.

Vegetative Structural 

Diversity

Lowest diversity; little new 

development of new tree age 

classes, grasses/forbs/shrubs

Increased diversity; highest 

development of new tree age 

classes, grasses/forbs /shrubs; 

most uneven-aged structure 

over time of all alternatives

Increased diversity; develops 

new age classes of trees, 

grasses/forbs/shrubs; will lose 

uneven-aged structure over time

Increased diversity; develops 

new age classes of trees, 

grasses/forbs/shrubs; will lose 

uneven-aged structure over time. 

Inoperable areas will be similar 

to Alt 1.

Large Trees Retention Retains all large trees initially; 

large oak, aspen, and juniper 

would be lost over time; large 

trees will remain at high risk due 

to wildfire, bark beetle attacks, 

and heavy competition

Largest initial reduction of large 

trees of alternatives; growth 

increases allows higher number 

of large trees than no-action in 

20 and 40 years; highest 

increase in longevity of large 

trees of alternatives

Retains most existing large trees 

initially; retains and develops 

most large trees of alternatives in 

40 years; increased longevity of 

large trees

Retains most existing large trees 

initially; retains and develops 

most large trees of alternatives in 

40 years; increased longevity of 

large trees. Inoperable areas will 

be similar to Alt 1.

Forest Health Poorest forest health; mistletoe 

continues to increase and 

intensify over time; stand and 

individual tree vigor and growth 

decrease over time; highest 

susceptibility to epidemic bark 

beetle attack and 

uncharacteristic stand-replacing 

fires 

Best forest health of 

alternatives; lowest mistletoe 

levels; highest stand and 

individual tree growth and vigor; 

lowest susceptibility to epidemic 

beetle attack and 

uncharacteristic stand-replacing 

fires 

Improved forest health; reduced 

mistletoe levels; increased tree 

growth and vigor; reduced 

susceptibility to epidemic bark 

beetle attack and 

uncharacteristic stand 

replacement fire

Improved forest health; reduced 

mistletoe levels; increased tree 

growth and vigor; reduced 

susceptibility to epidemic bark 

beetle attack and 

uncharacteristic stand 

replacement fire. Inoperable 

areas will be similar to Alt 1.

Old Growth Meets forest plan minimum 

allocation; retains most area of 

alternatives closest to plan 

specified old growth 

characteristics

Meets forest plan minimum 

allocation; retains least area of 

alternatives closest to plan 

specified old growth 

characteristics

Meets forest plan minimum 

allocation

Meets forest plan minimum 

allocation
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 47

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Snags and Downed Logs Retains all snags and downed 

logs initially; develops most 

snags and downed logs of all 

alternatives over time

Retains most snags and 

downed logs initially (some may 

be lost to prescribed burning 

and helicopter logging but this is 

mitigated); develops fewest 

snags and downed logs over 

time

Retains most snags and downed 

logs initially (some may be lost to 

prescribed burning and 

helicopter logging, but this is 

mitigated); develops more snags 

and downed logs over time than 

alternative 2

Retains most snags and downed 

logs initially (some may be lost to 

prescribed burning but this is 

mitigated); develops more snags 

and downed logs over time than 

alternative 2. Inoperable areas 

will be similar to Alt 1.

Fire and Fuels Management

Active Crown Fire Potential 61% of area demonstrates 

potential for active crown fire.

Reduces area for potential 

active crown fire to 18%.

Reduces area for potential active 

crown fire to 27%.

Reduces area for potential active 

crown fire to 35%.

Historic Fire Regimes and 

Condition Class

Fire regime is significantly 

altered from historic range. High 

risk of losing key ecosystem 

components.

Moves most of the area to a fire 

regime within historical range. 

Risk is low of losing key 

ecosystem components.

Moves less than half of the area 

to historic fire regime range. 

Some of the area likely to 

regress more rapidly in future.

Moves less than half of the area 

to historic fire regime range. 

Ecosystem components likely 

lost in future. Some of the area 

likely to regress more rapidly in 

future.

Firefighter Ability to Direct 

Attack

Provides little opportunity for 

firefighters to safely attack an 

emerging fire directly. This 

affects potential costs and 

containment size.

Makes over half of the project 

area available for direct attack. 

Fires likely to be contained 

quickly in these areas.

Under half of the area available 

for direct attack tactics.

A third of the area available for 

direct attack tactics. This affects 

potential costs and containment 

size.

Effects to the Steep Slopes 

of Bill Williams Mountain

Heavy fuel loadings, low canopy 

base heights and dense canopy 

bulk exist. Area has high 

potential for uncharacteristic fire 

which directly affects wildlife 

habitat, watershed and plant 

communities.

Fuel loadings are reduced, 

canopy base heights increased 

and canopy bulk densities are 

lowered leaving less potential 

for large areas of crown fire. 

Habitat, watershed and plants 

more defendable from 

uncharacteristic fire.

Fuel loadings are reduced, 

canopy base heights increased 

and canopy bulk densities are 

lowered leaving less potential for 

large areas of crown fire. Habitat 

and watershed are more 

defendable than Alt. 1 or 4, but 

not as much as 2. Rare plant 

species will continue to be at risk 

from uncharacteristic fire as well 

as a large area of risk on the 

north face of the mountain.

Fuel loadings are potentially 

increased, canopy base heights 

increased and canopy bulk 

densities are lowered. Habitat 

and watershed have high 

potential of uncharacteristic fire 

and potential increase in 

mortality during prescribed fire 

due to densities. Rare plant 

species at high risk of high fire 

severity.

Air Resources
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

48 Chapter 2. Alternatives, Including the Modified Proposed Action

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Particular Matter 2.5 

Emissions

Does not produce emissions 

during prescribed fire activities or 

mechanical treatments.

Produces emissions from 

prescribed fire and mechanical 

treatments during 

implementation.

Produces emissions from 

prescribed fire and mechanical 

treatments during 

implementation.

Produces emissions from 

prescribed fire and mechanical 

treatments during 

implementation but less than 

alternatives 2 and 3.

Soil and Water Quality

Soil 

Disturbance/Displacement

No new soil disturbance or 

displacement would occur

1,600 to 2,300 acres are 

expected to exhibit some level 

of soil disturbance in the form of 

topsoil displacement and minor 

profile redistributions from 

mechanical equipment used to 

fell, bunch, skid, and land logs 

and fireline installation. These 

disturbances will be of short 

duration as sites will stabilize 

and revegetate within 1 to 5 

years. Adverse disturbance will 

be minimized by implementation 

of Best Management Practices 

(BMPs) and Soil and Water 

Conservation Practices 

(SWCPs) as outlined in Table 3-

21. 

This Alternative would achieve 

desired condition for soils and 

watershed by removing 

sufficient canopy cover to allow 

sunlight to penetrate to the 

forest floor, increasing the 

growth response of grasses, 

forbs and shrubs. Fine roots 

and vegetative ground cover 

provided by grasses and forbs 

can more effectively protect 

soils from erosion by wind and 

water than forest litter alone.

While the types of disturbances 

would be similar to Alternative 2, 

fewer acres (approx. 50-100 ac.) 

are expected to exhibit soil 

disturbance since areas 

proposed for cable logging would 

be excluded under this 

Alternative, reducing the amount 

of felling, yarding, landing, and 

hauling. However, this alternative 

would not fully achieve the 

desired condition for soils in the 

project area since higher residual 

tree canopy cover would 

intercept more sunlight than 

Alternative 2 in untreated areas 

and areas where diameter limits 

would restrict tree canopy and 

basal area reductions, 

decreasing light penetration to 

the forest floor, thus decreasing 

the response of grasses and 

forbs which provide maximum 

protection of soil surfaces from 

wind and water erosion.

Soil disturbance types would be 

similar to Alternatives 2 and 3 

with fewer acres (approx. 400-

625 ac.) expected to exhibit soil 

disturbance since areas 

proposed for cable and 

helicopter logging would be 

excluded under this Alternative 

reducing the amount of felling, 

yarding, landing, and hauling. 

However, this alternative would 

substantially reduce the acreage 

that progresses toward desired 

condition for soils in the project 

area since approximately 4,000 

acres would exhibit higher 

residual tree canopy cover that 

would intercept more sunlight 

than Alternatives 2 or 3. The 

reduced light penetration to the 

forest floor would result in a 

corresponding decrease in the 

response of grasses and forbs 

necessary to protect soil 

surfaces from wind and water 

erosion.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 49

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Soil Erosion No soil erosion above current 

levels would occur. The 28 miles 

of poorly located roads that 

would be obliterated under the 

Action Alternatives would 

continue to erode, further 

decreasing soil productivity in 

these areas and contributing to 

downstream surface water 

quality degradation.

Erosion potential is expected to 

increase on 10 to 15 percent of 

areas treated mechanically due 

to removal or displacement of 

ground cover. This erosion 

would be short term (1 to 5 

years), localized, and mitigated 

with implementation of BMPs 

and SWCPs. 

Erosion potential on Terrestrial 

Ecosystem Survey (TES) map 

units currently in unsatisfactory 

condition would be reduced due 

to introduction of additional 

Coarse Woody Debris (CWD) 

on soil surfaces in these map 

units.

Erosion potential is expected to 

increase approximately the same 

amount as Alternative 2 on areas 

treated mechanically since the 

same number and lengths of skid 

trails and roads and number of 

landings are expected to occur. 

Since fewer trees would be 

removed, traffic on these areas 

would be reduced slightly. 

Erosion would be short term (1 to 

5 years), localized, and mitigated 

with implementation of 

appropriate BMPs and SWCPs. 

Erosion potential on TES map 

units in unsatisfactory condition 

would be reduced due to 

introduction of additional CWD 

on soil surfaces in these map 

units.

Erosion potential is expected to 

increase approximately the same 

amount as Alternatives 2 and 3 

on areas treated mechanically 

since the same number and 

lengths of skid trails and roads 

and number of landings are 

expected to occur. Soil erosion 

potential would not increase in 

areas not treated. Since fewer 

trees would be removed and 

fewer acres treated, traffic on 

these areas would be reduced 

slightly. Erosion on treated areas 

would be short term (1 to 5 

years), localized, and mitigated 

with implementation of 

appropriate BMPs and SWCPs. 

Erosion potential on TES map 

units in unsatisfactory condition 

in operability zones 3, 4, 5, and 7 

(106 ac.) would remain in 

unsatisfactory condition and 

would not be improved through 

introduction of additional CWD 

on soil surfaces in these map 

units.

Soil Compaction No additional areas of soil 

compaction would occur

Approximately 1,600 – 2,300 

acres are estimated to exhibit 

varying degrees of soil 

compaction, depending on the 

number and locations of skid 

trails, landings, and roads, 

timing of activities, and types of 

machinery and manual 

treatments employed. Some 

dispersed soil compaction 

would likely occur in areas 

where trees are mechanically 

felled and bunched prior to 

skidding, yarding, and landing.

Slightly fewer acres are expected 

to exhibit soil compaction since 

cable logging would be excluded 

under this Alternative. Fewer 

acres would be treated and fewer 

large trees would be felled, 

bunched, skidded to landings, 

and hauled. However, the 

number of skid trails and 

landings would be approximately 

the same as Alternative 2.

Soil compaction would be similar 

to Alternative 3 since cable 

logging and helicopter yarding 

would be excluded under this 

Alternative. However, in 

remaining area to be treated 

using ground-based machinery 

the number of skid trails and 

landings would be approximately 

the same as Alternative 2.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

50 Chapter 2. Alternatives, Including the Modified Proposed Action

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Soil Nutrient Cycling No changes to nutrient cycling 

would occur.

Soil nutrient cycling would 

progress toward desired 

conditions as litter layers are 

replaced, CWD is increased, 

and the understory of grasses, 

forbs, and shrubs improves. 

Fine roots of grasses and forbs 

would improve soil aggregate 

stability, water infiltration, and 

decrease soil bulk densities.

Soil nutrient cycling would 

progress toward the desired 

condition in treatment areas, but 

not to the extent provided by 

Alternative 2. Less light would 

penetrate the forest canopy and 

reach the forest floor, resulting in 

a sparser understory vegetative 

community. Duff would continue 

to provide soil nutrients and 

contribute to soil profile 

development, but not to the 

extent that grasses, forbs, and 

associated litter would.

Soil nutrient cycling would 

progress toward the desired 

condition, but not to the extent 

provided by Alternative 2. 

Substantial acreage would 

remain untreated under this 

Alternative, limiting the acreage 

of soils that would progress 

toward desired condition. Duff 

would continue to provide soil 

nutrients and contribute to soil 

profile development, but not to 

the extent that grasses, forbs, 

and associated litter would.

Herbaceous Ground Cover Herbaceous ground cover would 

continue to decline as forest 

canopies continue to close, soil 

duff layers increase, and fuel 

loads continue to increase

Herbaceous ground cover 

would be greater than the No 

Action Alternative within one to 

five years following thinning 

treatments since more open 

stand structures would occur 

following thinning.

Fewer trees would be removed 

during thinning, resulting in less 

open stand structure and less 

light penetration to the forest 

floor. Herbaceous ground cover 

would therefore be less than 

Alternative 2, but greater than 

Alternative 1.

Herbaceous grown cover would 

be less than in Alternative 2, and

potentially more than in

Alternative 3.

Soil Course Woody Debris 

(CWD) Component

TES map units that do not 

currently have adequate CWD 

would exhibit a gradual increase 

in CWD over a long period of 

time through tree mortality and 

decadence. However, these 

TES units would not benefit from 

the introduction of CWD that 

would occur rapidly through 

vegetation treatments proposed 

under Alternatives 2 through 4

because there is currently a lot of 

CWD on the ground. 

Vegetation treatments would

increase CWD in unsatisfactory 

TES units, improving nutrient 

stores and protecting soil 

surfaces under this Alternative.

On TES map units that currently 

have excess CWD, prescribed 

burning or piling followed by use 

of prescribed fire would bring 

CWD levels to desired 

conditions of 5 to 7 tons per 

acre.

Vegetation treatments will 

increase CWD in unsatisfactory 

TES units, improving nutrient 

stores and protecting soil 

surfaces under this Alternative. 

On TES map units that have 

excess CWD, treatments would 

achieve the same desired 

conditions with regard to CWD 

as Alternative 2.

Vegetation treatments will 

increase CWD in unsatisfactory 

TES units, improving nutrient 

stores and protecting soil 

surfaces under this Alternative. 

On TES map units that have 

excess CWD, treatments would 

achieve the same desired 

conditions with regard to CWD 

as Alternative 2.

With exclusion of cable logging 

and helicopter use, substantially 

fewer acres would be treated, 

limiting the acreage of soils that 

would progress toward desired 

condition with regard to the CWD 

component.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 51

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Soil Heating and Water 

Repellency (Hydrophobicity)

There would be no soil heating or 

additional soil water repellency 

(hydrophobicity) under the No 

Action Alternative. However, 

conditions would be conducive to 

increased hazard of high severity 

wildfire that would result in large 

areas of hydrophobic soils that 

would be prone to erosion and 

sediment delivery to ephemeral 

and intermittent drainages.

Areas where pile burning is 

conducted, and some areas 

where prescribed burning is 

conducted would exhibit 

hydrophobic soil conditions and 

soil sterilization caused by rapid 

oxidation of soil minerals and 

organic matter. The occurrence 

of these conditions would 

depend primarily on the timing, 

duration, type, and intensity of 

fire use. 

Vegetation treatments would 

produce more open stand 

conditions, including canopy 

gaps that would reduce fire burn 

severity and minimize areas of 

hydrophobic soils. The greatest 

risk of increased areas of 

hydrophobic soils would be 

where prescribed burning is 

conducted prior to forest 

thinning. 

These treatments would reduce 

the risk of high severity wildfire 

and associated adverse impacts 

to soils and watersheds.

The effects of this Alternative are 

similar to those of Alternative 2. 

However, there would be fewer 

piles to burn or less scattered 

activity-related woody debris 

under this Alternative since

fewer trees would be removed in 

Mexican spotted owl (MSO) 

protected activity centers 

(PACs), pine/oak habitat, and the 

ponderosa pine type where 

slopes exceed 40 percent. 

While this alternative would 

reduce the risk of high severity 

wildfire and associated adverse 

impacts to soils and watersheds, 

it would not be to the extent 

provided by Alternative 2.

The effects of this Alternative are 

similar to those of Alternatives 2 

and 3. However, there are 

substantially fewer acres treated 

and therefore fewer piles to burn 

or less scattered activity-related 

woody debris under this 

Alternative since

cable logging and helicopter 

yarding are excluded.

While this alternative would 

reduce the risk of high severity 

wildfire in areas where groundbased logging occurs, other 

areas would remain at risk of 

high severity wildfire and 

associated soil heating and 

hydrophobicity since they would 

not be treated.

Soil Organisms No changes to soil organism 

populations would be introduced 

as a result of this project under 

the No Action Alternative.

Soil organism populations are 

expected to decline for short 

periods (1 to 3 years) in areas 

of soil disturbance, compaction 

and where fire is introduced. 

Soil organism populations are 

expected to recover rapidly 

under this alternative as greater 

sunlight would reach the forest 

floor, increasing soil biological 

activity.

Soil organism populations are 

expected to decline for short 

periods (1 to 3 years) in areas of 

soil disturbance, compaction and 

where fire is introduced. Soil 

organism populations are 

expected to recover more slowly 

under this Alternative in MSO 

PACs and pine/oak habitat 

where slopes exceed 40 percent 

since less light would penetrate 

to the forest floor to warm soils 

and increase soil biological 

activity.

Soil organism populations are 

expected to decline for short 

periods (1 to 3 years) in areas of 

soil disturbance, compaction and 

where fire is introduced. Soil 

organism populations would be 

unaffected in areas excluded 

from cable logging and helicopter 

yarding.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

52 Chapter 2. Alternatives, Including the Modified Proposed Action

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Water Quality There would be no changes to 

surface water quality as a result 

of this project under the No 

Action Alternative.

No detectable change in 

downstream water quality is 

anticipated.

No detectable change in 

downstream water is anticipated.

No detectable change in 

downstream water is anticipated.

Water Yield There would be no changes to 

water yield as a result of this 

project under the No Action 

Alternative 

Since only a small percentage 

of each 6th-level watershed is 

being treated, only minor 

increases in water yield are 

expected. Within the project 

area, increased soil moisture 

and groundwater recharge can 

be expected as tree basal area 

is reduced.

Since only a small percentage of 

each 6th-level watershed is 

being treated, no detectable 

change in water yield is 

expected. Within the project 

area, increased soil moisture and 

groundwater recharge can be 

expected as tree canopy and 

numbers are reduced. This effect 

will be slightly less than 

alternative 2 as fewer trees are 

removed.

No detectable change in water 

yield is expected under this 

Alternative. While increased soil 

moisture and groundwater 

recharge can be expected in 

treatment area, there would be 

substantially fewer acres treated 

under this Alternative.

Wildlife

Mexican Spotted Owl (MSO) Perpetuates high probability of 

active crown fire that would 

degrade most or all MSO habitat. 

Will likely lead to a scenario 

similar to Pumpkin Fire of 2000 

(where an entire Protected 

Activity Center was consumed by 

stand-replacing wildfire).

Most reduces probability of 

active crown fire in MSO 

habitat. Uneven-aged 

management most sustainably 

conserves MSO habitat at or 

toward desired conditions.

Moderately reduces probability of 

active crown fire in MSO habitat. 

Even-aged management (9" 

diameter cap on tree-cutting) 

moderately conserves MSO 

habitat at or toward desired 

conditions, although in an 

unsustainable manner.

Least reduces probability of 

active crown fire in MSO habitat, 

but is still preferable over 

Alternative 1. Prescribed fire 

alone does little to conserve 

MSO habitat at or toward desired 

conditions.

Northern Goshawk Perpetuates high probability of 

active crown fire that would 

degrade most or all goshawk 

habitat.

Most protects nest areas and 

Post-Fledging Family Areas 

(PFAs) from active crown fire. 

Most restores landscapes 

outside goshawk PFAs toward 

conditions to which the species 

adapted and evolved. 

Alternatives 2-4 have identical 

effects on goshawk nest areas 

and PFAs, in terms of 

vegetative treatments.

Moderately protects nest areas 

and PFAs from active crown fire. 

Moderately restores foraging 

areas (i.e., landscapes outside 

PFAs) toward conditions to which 

the species adapted and 

evolved.

Least protects nest areas and 

PFAs from active crown fire. 

Least restores foraging areas 

toward conditions to which the 

species adapted and evolved. 

Alternatives 2-4 have identical 

effects on goshawk nest areas 

and PFAs, in terms of vegetative 

treatments
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 53

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Bald Eagle and Sensitive 

Species, Management 

Indicator Species, and 

Migratory Birds

Perpetuates encroachment of 

habitat by invading conifers.

Most restores habitat. Somewhat restores habitat. 

Effects of Alternatives 3-4 are 

identical.

Same as Alternative 3. 

Sensitive Species, 

Management Indicator 

Species, and Migratory Birds 

that Primarily Use Forests 

and Woodlands that are 

Denser or with More Closed 

Canopies

Perpetuates high probability of 

active crown fire that would 

degrade most or all densely 

forested habitat.

Most restores habitat toward 

pre-settlement conditions. Most 

protects historically dense areas 

from active crown fire. Most 

reduces tree density in currently 

dense areas that were 

historically open.

Moderately restores habitat 

toward pre-settlement conditions. 

Moderately protects historically 

dense areas from active crown 

fire. Moderately reduces tree 

density in currently dense areas 

that were historically open.

Least restores habitat toward 

pre-settlement conditions. Least 

protects historically dense areas 

from active crown fire. Least 

reduces tree density in currently 

dense areas that were 

historically open.

Rare and Narrow Endemic 

Species

Perpetuates high probability of 

active crown fire that would 

degrade most or all densely 

forested habitat.

Most restores habitat toward 

pre-settlement conditions. Most 

protects historically dense areas 

from active crown fire. Most 

reduces tree density in currently 

dense areas that were 

historically open.

Moderately restores habitat 

toward pre-settlement conditions. 

Moderately protects historically 

dense areas from active crown 

fire. Moderately reduces tree 

density in currently dense areas 

that were historically open.

Least restores habitat toward 

pre-settlement conditions. Least 

protects historically dense areas

from active crown fire. Least 

reduces tree density in currently 

dense areas that were 

historically open.

Road-Related Concerns for 

General Wildlife 

Conservation

Road-related habitat degradation 

does not occur.

Road-related habitat 

degradation occurs under this 

Alternative. Alternatives 2 and 

3 are identical in terms of roadrelated effects on wildlife.

Road-related habitat degradation

is higher under this Alternative 

than under Alternative 2. 

Road-related habitat degradation 

is least under this Alternative.

Recreation

1. % of area of each 

Recreation Opportunity 

Spectrum (ROS) class in 

treatment (for project area)

1. 0% for all ROS Classes, inside 

of the project area.

1. 30% of Roaded (R), 82 % of 

Roaded Natural (RN), 95% of 

Semi Primitive Motorized 

(SPM), 100% of Semi Primitive 

Non-Motorized (SPNM)

1. 30% of R, 82 % of RN, 95% of 

SPM, 100% of SPNM

1. 30% of R, 70% of RN, 83% of 

SPM, 18% of SPNM

2. Ability to maintain

recreation settings over time

2. Decreased 2. Increased 2. Increased 2. Slightly Increased

3. Displacement of 

Recreationists

3. Little to no displacement of 

recreationists, except due to fire 

activity

3. Short-term Increase in the 

displacement of recreationists 

during implementation

3. Short-term Increase in the 

displacement of recreationists 

during implementation

3. Slightly less Short-term 

Increase in the displacement of 

recreationists during 

implementation

Scenic Resources
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

54 Chapter 2. Alternatives, Including the Modified Proposed Action

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Scenic Resources No short-term impacts.

There is the potential for 

unnaturally large, stand-replacing 

wildfires to dramatically change 

the scenic attractiveness of the 

area, and to the chance of 

achieving the desired landscape 

character for many decades.

Short-term effects while 

management activities are 

taking place and about 5 years 

following completion.

Most improved ability to protect 

and maintain scenic resources 

in the project area. Meets forest 

plan scenic integrity objectives 

in project area.

Short-term effects while 

management activities are taking 

place. Improved ability to protect 

and maintain scenic resources. 

Meets forest plan scenic integrity 

objectives in project area.

Somewhat improved ability to 

protect and maintain scenic 

resources in the project area. 

Makes least progress toward 

meeting forest plan scenic 

integrity objectives in the project

area.

Range

Potential Change in Forage 

Production

None initially; Abundance and 

productivity will decrease in the 

long-term; Species richness may 

decline in the long-term.

Greatest increase in understory 

abundance and productivity of 

all alternatives; Species 

richness may increase.

Increase in understory 

abundance and productivity; 

Species richness may increase.

Increase in abundance and 

productivity; Species richness 

may increase. Least change of 

action alternatives.

Heritage

Cultural Resources The continued deposition of fuels 

increases the likelihood of a high 

intensity stand-replacing wild fire 

on Bill Williams Mountain. It is 

likely that many of the prehistoric 

and especially the few sites with 

combustible features would 

suffer adverse effects from 

intense fire effects and post-fire 

erosion.

Reducing the amount of dead 

and down woody debris, ladder 

fuels, and unnaturally high tree 

density would greatly reduce 

the risk of effects to heritage 

resource sites from 

uncharacteristic wildfire. The 

activities associated with 

treatments including skidding, 

crushing, road construction and 

obliteration under this 

alternative could potentially 

affect cultural resource sites 

adversely. Heavy machinery 

used to build roads and skid 

trees across sites can result in 

impacts that include rutting, 

erosion, dislocation or breakage 

of artifacts and features, and 

the general destruction of sites 

and site stratigraphy

Same as Alternative 2. Similar to effects in Alternative 2 

and 3; however, because the 

steep slopes of Bill Williams 

Mountain would not be treated, 

most of the heritage resources 

which are located downslope 

would be vulnerable to the 

effects of post fire flooding and 

erosion following a high intensity 

stand-replacing fire.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 2. Alternatives, Including the Modified Proposed Action 55

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Traditional Cultural Property 

(TCP) and Tribal

The continued deposition of fuels 

in the area would increase the 

likelihood of a high intensity 

stand-replacing wild fire on Bill 

Williams Mountain. It is likely that 

the Bill Williams Mountain 

Traditional Cultural Property, its 

scenic integrity, and plants 

collected by tribes and used for 

ceremonial purposes would 

suffer adverse effects from 

intense fire behavior.

Reducing the amount of dead and 

down woody debris, ladder fuels, 

and unnaturally high tree density 

would greatly reduce the risk of 

effects to the TCP from standreplacing wildfire; treatments will 

open the forest canopy and alter its 

scenic integrity and potentially 

affect plants collected for 

ceremonies and medicinal use. 

This alternative could also 

temporarily disrupt ceremonies,

could affect traditionally gathered 

plants. 

Same as Alternative 2. Similar to the effects in 

Alternative 2 and 3; however, 

because the steep slopes of Bill 

Williams Mountain would not be 

treated, the TCP would be

vulnerable to the effects of post 

fire flooding and erosion.

Weeds and Rare Plant Species

Rate of Introduction and 

Spread of Invasive Weeds 

(Short Term)

No effect Greatest potential increase of 

all alternatives.

Potential increase Potential increase

Rate of Introduction and 

Spread of Invasive Weeds 

(Long Term)

Greatest increase of all 

alternatives following intense 

wildfire.

Potential increase or decrease; 

Increase less than that of 

alternative 1 following an 

intense wildfire.

Potential increase or decrease; 

Increase less than that of 

alternative 1 following an intense 

wildfire.

Potential increase or decrease; 

Increase less than that of 

alternative 1 following an intense 

wildfire.

Rare Plant Species (Short 

Term) 

No Effect Improvement in habitat quality 

for Forest Service Sensitive 

species; Potential reduction in 

habitat quality for Arizona 

bugbane of all alternatives.

Improvement in habitat quality for 

Forest Service Sensitive species; 

Potential reduction in habitat 

quality for Arizona bugbane.

Improvement in habitat quality for 

Forest Service Sensitive species; 

Potential reduction in habitat 

quality for Arizona bugbane.

Rare Plant Species (Long 

Term) 

Greatest potential reduction in 

habitat quality for all species and 

of all alternatives.

Improvement in habitat quality 

for Forest Service Sensitive 

species; Potential reduction in 

habitat quality for Arizona 

bugbane.

Same as Alternative 2. Same as Alternative 2

Lands and Minerals

Threat to Communication 

Site 

Highest risk of loss due to 

uncharacteristic fire

Least amount of risk of all 

alternatives

Less risk than alternatives 1 and 

4, but more risk than alternative 

2 

Less risk than alternative 1, but 

more risk than alternatives 2 and 

3 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

56 Chapter 2. Alternatives, Including the Modified Proposed Action

Resource and Unit of 

Measure

Alternatives

Alternative 1, No Action

Alternative 2, Modified 

Proposed Action Alternative 3 Alternative 4

Social and Economic

Social Impacts High-risk of undesirable 

consequences

Moderate short-term impacts Moderate short-term impacts Moderate short-term impacts

Economic Impacts No cost to implement, however, 

the risk of high costs to mitigate 

high intensity fire and flooding 

would be similar to costs in 

Alternative 3.

The cost to implement is 

approximately $9.7 million.

The cost to implement is 

approximately $23.7 million.

The cost to implement is 

approximately $7.2 million.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 57

Chapter 3. Affected Environment and Environmental 

Consequences

3.1 Introduction 

This chapter summarizes the physical, biological, social, and economic environments of the project area and the 

effects of implementing each alternative on that environment. It also presents the scientific and analytical basis for 

the comparison of alternatives analyzed in detail (Chapter 2 Section 2.4.7). The best information available was 

used to discuss the affected environment and environmental consequences of the action alternatives and the best 

available science was considered throughout the discussions presented within this chapter. Desired conditions for 

the project area have also been woven into this chapter. The specialist reports in the project record for the Bill 

Williams Mountain Restoration Project are hereby incorporated by reference to supplement the sections in this 

chapter.

3.2 Silviculture

Vegetative Structural Stage (VSS) classification is a tool used in the analysis to determine separate age classes for 

an uneven-aged forest. This was determined to be appropriate due to the desire to manage and sustain uneven 

aged forest conditions in the revised forest plan. VSS is a generalized description of forest growth and aging 

stages based on the majority of the trees in the specific diameter distribution of a group of trees. See Figure 3-1

below for diameter distributions. The distribution and description of vegetation structural stages used for these 

prescriptions are the following: 10% grass/forb/shrub (VSS1), 10% seedling-sapling (VSS2), 20% young forest 

(VSS 3), 20% mid-aged forest (VSS4), 20% mature forest (VSS 5), 20% old forest (VSS6). ). VSS was used in 

project analysis to manage for replacement structural stages which assures continuous representation of 

regeneration and old growth over time. The use of VSS as a guide or an analysis tool does not violate the revised 

Kaibab Forest plan desired conditions, standards and guidelines. 

Figure 3-1. Vegetative structural stages (VSS) 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

58 Chapter 3. Affected Environment and Environmental Consequences

3.2.1 Affected Environment

The vegetative cover types for the Bill Williams Mountain Restoration Project (project area) are displayed in 

Table 3-1. Cover types are identified by areas with the highest representation of a vegetative species (stands). 

Depending on the complexity of cover types, stand sizes within the project area range from 1/10 of an acre to two 

hundred acres, averaging 45 acres. Smaller stands typically exist on Bill Williams Mountain slopes due to the 

high diversity of abiotic factors such as drainages, soils, slope and aspect.

Table 3-1. Bill Williams vegetation cover types

Vegetation Cover Type Acres % of Project

Ponderosa Pine 10,554 69 

Oak Woodland 717 5 

Douglas Fir 299 2 

White Fir 1,619 11

Pinyon-Juniper Woodlands 654 4 

Juniper Woodland 947 6 

Mixed-Hardwoods 146 <1

Aspen 140 <1

Grasslands 64 <1

Mountain-mahogany 40 <1

Rocklands 22 1 

TOTAL Treatment Acres 15,202 100

The base of Bill Williams Mountain is primarily surrounded by ponderosa pine forest. The southwestern slope of 

the mountain consists of ponderosa pine and gradually transitions to dry mixed conifer consisting of Douglas-fir 

and white fir at higher elevations. The northeastern slope of the mountain consists of Douglas-fir and white fir 

forests with scattered aspen and ponderosa pine which is primarily wet mixed conifer. Stands that average above 

40% slope represent 17% of the project area.

3.2.1.1 Ponderosa Pine Forest

The ponderosa pine forest makes up approximately 69% of the project area. Some ponderosa pine stands are 

found on the steep slopes of Bill Williams Mountain but are mainly found on and surrounding the lower slope. 

The presence of white fir, Douglas fir, woodlands, shrublands and grasslands occasionally occurs as small 

inclusions to the ponderosa pine forest. Based on the quality and density of Gambel oak within ponderosa pine 

forest, some stands were classified as pine-oak. Within the project area, there are 88 stands of pine oak, 

approximately 4,898 acres. Much of the ponderosa pine within the project area is dominated with the same age 

class, approximately 60 to 100 years old. This high density of even-aged ponderosa pine forest limits forest 

diversity, sustainability, health, and protection in and surrounding the project area (Allen et al. 2002, Binkley et al. 

2007, Cooper et al. 1960, Fettig et al. 2007, Stoddard et al. 2011, Triepke et al. 2011, Savage & Mast 2005, Strom 

& Fule 2007). Figure 3-2 displays the current distribution of VSS in the project area. 

Figure 3-2 also shows the current limited forest structural and age diversity in the majority of the ponderosa pine 

forest. There is currently a deficit of VSS 1, 2, 5 and 6 from multi-age balance. The VSS 3 and 4 are 

approximately doubled for their multi-aged condition. Limited diversity in forest structure exhibits uncertainty of 

forest sustainability (Binkley et al. 2007). Figure 3-3 shows the project area’s projected distribution of ponderosa 

pine forest VSS classes for 40 years as modeled in the Forest Vegetation Simulator (FVS).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 59

5% 6%

33%

38%

15%

3%

1%

6%

42%

36%

12%

3%

10% 10%

20% 20% 20% 20%

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

VSS 1 VSS 2 VSS 3 VSS 4 VSS 5 VSS 6

LOGPFAs

PFAs

Desired Condition

Ponderosa Pine Forest

Ponderosa Pine Forest 

PFAs

Balance Multi-aged

Figure 3-2. Ponderosa pine cover type by vegetative structural stages (VSS) under current condition compared to 

desired condition

4%

5% VSS 1 

6%

4%

VSS 2

33%

26%

23%

VSS 3

38% 40% VSS 4 38%

15%

20%

24%

VSS 5

3%

5% 6% VSS 6

39%

4%

9%

20%

24%

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

Present 2023 2043 2053

Desired VSS 3 to 6

Desired VSS 1 & 2

Balance Multi aged for VSS 3 to 6

Balance Multi aged for VSS 1 & 2

Figure 3-3. 40 year measure of ponderosa pine forest sustainability in the project area

Figure 3-3 also shows the majority of the ponderosa pine forest in the project area will remain dominated by a 

mid-aged forest (VSS4) for 40 years, limiting the sustainability of balanced VSS 1, 2 and 6 conditions. Figure 3-4

assumes disturbances such as fire, insect and diseases are static. Depending on the intensity and severity of fire, 

insect or diseases, the associated mortality would contribute to changes in structural diversity and sustainability 

(Binkley et al. 2007, Fettig et al, 2007, Strom & Fule 2007). The current condition of crown fire risk is discussed 

in the fuels section of this chapter. 

Research on bark beetles shows when trees are stressed from over stocking they are more susceptible to 

Dendroctonus (bark beetle) attack (Negron et al. 2000, Fettig et al. 2007). Figure 3-4 compares stand density by 

basal area (BA) to the risk of a bark beetle attack. Currently the majority of the ponderosa pine forest in the 

project area is at high risk to bark beetle attacks. For 40 years, the same areas maintain and increase a high risk of 

bark beetles attacks.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

60 Chapter 3. Affected Environment and Environmental Consequences

123

134

143 151 158

131

136

142

147

50

70

90

110

130

150

170

Present 2023 2033 2043 2053

Stand Basal Area > 8" DBH (ft2/Ac)

LOGPFA

PFA

Moderate Bark Beetle Risk

High Bark Beetle Risk Hazard

Ponderosa Pine Forest

Ponderosa Pine Forest 

Figure 3-4. 40 year measure of bark beetle risk and sustainability for the ponderosa pine forest

The high risk of bark beetle attack in the majority of the ponderosa pine forest displays concerns of a bark beetle 

build up and outbreak. Fettig et al. 2007 illustrates research on how Dendroctonus spp., specifically, prefer larger 

diameter trees when bark beetle risk is high. Dendroctonus target larger trees in an outbreak due to the increased 

tree stress brought on from lack of nutrients, water, competition and high tree density (Klenner & Arsenault 

2009). Depending on the intensity and severity of a potential bark beetle outbreak, mortality would contribute the 

change in structural diversity and sustainability (Negron 2009). 

The project area is also a home for chronic infections of dwarf mistletoe (DM). Conklin and Fairweather 2010 

recognize through various researches that DM affects a variety of insects, birds and mammals. It is also explained 

that DM changes forest structure. Hawksworth and Wiens 1996 explain how infection centers generally become 

more open over time, lowering canopy cover and basal area. The project area consists of approximately 5,178 

acres, 1/3 (34%) of the area proposed for treatment, of the ponderosa pine forest exhibiting high infection levels; 

these are areas where greater than 20% of the trees per acre (TPA) in a stand are infected. Fifty one percent of the 

ponderosa pine forest consists of moderate to low infection levels (lower than 20% of TPA infected). Figure 3-5 

illustrates the intensity of DM within the ponderosa pine stands of high infection levels. Modeled projections, 40 

years into the future, indicate that mistletoe infection levels would increase to 68%. High infection levels would 

decrease canopy cover and basal area, increase fire severity and forest structure would trend away from desired 

conditions (Hawksworth and Wiens 1996).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 61

47% 48%

58%

67% 68%

0%

10%

20%

30%

40%

50%

60%

70%

80%

Present 2023 2033 2043 2053

% Trees Per Acre DM Infected

Desired Condition

Figure 3-5. Percent of trees per acre high levels of dwarf mistletoe infection in the ponderosa pine forest

Figure 3-6 shows the severity of the high DM infected areas. Dwarf mistletoe rating (DMR) is used to quantify 

infection severity (Hawksworth 1977). The severity of DM in areas with high infection levels rises above 

extreme within a 40 year period. The DMR is associated with growth and mortality impacts. In areas of high DM 

infection, mortality can be expected due to the added stress leading to tree attacks and potential increased bark 

beetle populations (Conklin and Fairweather 2010). 

Conklin and Fairweather 2010 explain how DM rarely kills all the trees in a stand or results in sizable 

deforestation. Tree growth would decline as trees become dominated by stunted and deformed characteristics. 

Sacrificing desired productivity, habitat, and fire potential, DM infections beyond the foreseeable future can lead 

to an open, uneven aged forest, changing the structural diversity and sustainability. Sustainable uneven aged 

forest management in moderate to heavy DM infection areas is unlikely because mistletoe limits the development 

of new trees into older larger size classes (Conklin and Fairweather 2010). Other objectives such as meeting 

specific wildlife habitat values, sustainable uneven aged conditions, sustainable amount of large DM infected 

trees, lower fuel loading, decreased potential crown fire may be compromised if DM is untreated.

Dwarf mistletoe is an element of the forest landscape. There is a varied level of mistletoe across the landscape, 

comparable with historic conditions such that it does not impede achieving and sustaining desired uneven-aged 

forest conditions. Desired stand dwarf mistletoe infection levels do not exceed 20% infection of the host species 

(trees per acre basis), or 25% of the area infected for any given tree species (Conklin and Fairweather 2010). 

Dwarf mistletoe infections are irregularly distributed among tree groups, such that effects are limited to the forest 

group and patch scale. The desired condition is to reduce the amount of infection with the majority of stands in 

the uninfected to moderate infection range.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

62 Chapter 3. Affected Environment and Environmental Consequences

1.75 1.77

1.84

2.30 2.39

0

0.5

1

1.5

2

2.5

3

Present 2023 2033 2043 2053

Dwarft Mistletoe Rating (DMR)

Mean_DMR

High

Extream

Figure 3-6. Dwarf mistletoe rating of extremely infected DM stands in ponderosa pine forest

3.2.1.2 Mixed Conifer

Mixed conifer forests make up approximately 13% of the of the project area which consists of Douglas-fir and 

white fir stands. The majority of the mixed conifer stands are found on the steep slopes of Bill Williams 

Mountain. Mixed conifer consists of white fir, Douglas fir, woodland species, ponderosa pine and small patches 

of aspen. Age classes within the mixed conifer are highly variable due to historic land management practices.

The majority of the mixed conifer in the project area was historically dominated by ponderosa pine and Douglas 

fir, and is considered to be a dry (historic frequent-fire) mixed conifer forest type (Cocke et al. 2005). Fire 

exclusion has altered the project area’s mixed conifer by allowing grassy openings between forested areas to fill in 

with younger trees. Historically, fire reduced the density of younger trees competing against older trees. Portions 

of the mixed conifer type are in mid-succession or climax condition with an understory primarily of white fir. 

Over time, species composition within the entire mixed conifer type will shift from fire-resistant shade-intolerant 

species to non-fire-resistant shade-tolerant species dominance (Fule et al. 2009, USDA 1997). 

Most of the stands within the mixed conifer have currently transitioned and are dominated by shade tolerant 

species, mainly white fir. Some wet mixed conifer (historic infrequent fire) forest type can be found in isolated 

areas on the north facing slope and major drainages on Bill Williams Mountain. Cocke et al. 2005 show in studies 

on the San Francisco Peaks, approximately 30 miles west of the project area, how mesic species have encroached 

to lower altitudes and how mixed conifer forests densities have increased since 1876. They explain how these 

changes have created conditions opposite to those suitable for warmer, drier future climates that will display 

increased fire risk, setting the stage for sudden severe change. This type of response is also observed on Bill 

Williams Mountain. 

Within the mixed conifer forest, an increased amount of competition to the older age classes decreases their 

resistance and resilience to insect, diseases and inhibits low intensity fire under current conditions. Departure 

from forest conditions conducive to low intensity-frequent fire limits forest diversity, sustainability, health, and 

protection in and surrounding the project area (Cocke et al. 2005, Fule et al. 2009). Figure 3-7 displays the 

current distribution of VSS for the project area’s mixed conifer forest. 

Figure 3-7 also shows the current departure of forest structural and age diversity to the desired condition in the 

mixed conifer forest. There is currently a deficit of VSS 5 and 6 from the desired condition. Mid-aged VSS 3 and 

4 are in excess. There is active regeneration demonstrated in VSS 1 and 2. Departure from the balanced 

condition limits diversity in forest structure and would not provide for the desired uneven-aged structure over 

time. Figure 3-8 shows the project area’s mixed conifer forest VSS for 40 years.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 63

15%

10%

31%

24%

10%

8%

10% 10%

20% 20% 20% 20%

0

5

10

15

20

25

30

35

VSS1 VSS2 VSS3 VSS4 VSS5 VSS6

MC LOGPFA

Desired Condition

Figure 3-7. Mixed conifer forest VSS current condition compared to balanced multi-aged condition

15% 14%

16%

12% 11% 10%

13%

13%

VSS5

13%

31% 30%

27% 28%

27%

24% 23% 24% 24% 24%

8%

8% 8% 9%

8%

11%

14% VSS1 VSS2

VSS6

VSS3

VSS4

0%

5%

10%

15%

20%

25%

30%

35%

Present 2023 2033 2043 2053

Desired VSS1 & 2

Vesired VSS3 to 6

Balanced VSS 1 & 2

Balanced VSS 3 to 6

Figure 3-8. Forty year measure of mixed conifer forest sustainability

Figure 3-8 shows the majority of the mixed conifer forest in theBill Williams vegetation cover types in the project 

area will remain dominated by a mid-aged forest (VSS4) and young forest (VSS3) for 40 years, limiting the 

sustainability of desired VSS 5 and 6 conditions. Figure 3-7 assumes disturbances such as fire, insect and 

diseases are static. Depending on the intensity and severity of fire, insect or diseases, the associated mortality 

would contribute to changes in structural diversity and sustainability. The current condition of crown fire risk in 

mixed conifer is discussed in the fuels section of this chapter.

Mixed conifer species such as Douglas-fir and white fir are capable of living in conditions with higher tree 

densities. With the ability of some mixed conifer species to sustain higher densities, species such as ponderosa 

pine and Gambel oak become the first to be stressed and perish from competition. This is with the assumption of 

no interactions of other disturbance agents such as bark beetles and DM. Currently the majority of the mixed 

conifer forest in the project area is at high risk to bark beetle attacks, Figure 3-9. Modeled projections, for 40 

years show mixed conifer would have an increasing high risk of bark beetles attacks. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

64 Chapter 3. Affected Environment and Environmental Consequences

Dwarf Mistletoe also exists in the mixed conifer cover type. The project area contains approximately 720 acres of 

mixed conifer cover type exhibiting high DM infection levels (> 20% Infected TPA). 20% is a manageable level 

for sustainable uneven aged management over time. 64% of the mixed conifer cover type consists of moderate to 

low infection levels (< 20% Infected TPA). Figure 3-9 illustrates the intensity of DM within mixed conifer stands 

of high infection levels for Douglas-fir and ponderosa pine. Modeling 40 years into the future shows TPA 

infected increases to 75% for ponderosa pine and 42% for Douglas-fir. The reduction of DMR in Figure 3-10 is 

due to the added regeneration of non-infected trees combined with overstory mortality. Through time the 

regeneration becomes more infected and trends for DM infection in Douglas-fir again increases.

153

170

183

196

208

100

120

140

160

180

200

220

Present Day 2023 2033 2043 2053

Stand Basal Area > 8" DBH (ft2/Ac)

MC LOGPFA

High Bark Beetle Risk

Figure 3-9. 40 year measure of bark beetle risk and sustainability for mixed conifer forest

40%

52%

41% 39% 42%

61% 62%

70% 76% 75%

0%

10%

20%

30%

40%

50%

60%

70%

80%

Present 2023 2033 2043 2053

% of Douglas-fir DM Infected Trees Per Acre

Figure 3-10. Percent of TPA infected of extremely infected DM stands in mixed conifer forest 

Mixed Conifer Forest
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 65

1.91

2.40 2.34

1.57 1.59

2.84

2.56

2.97

3.16 3.18

0

0.5

1

1.5

2

2.5

3

3.5

Present 2023 2033 2043 2053

Dwarft Mistletoe Rating (DMR)

Mean Douglas-fir DMR

Mean Ponderosa Pine DMR

High

Extream

Figure 3-11. DM rating of extremely infected DM stands (mixed conifer cover type)

Figure 3-11 shows the severity of the high DM infected areas. The severity of DM in mixed conifer areas of high 

infection levels rise above extreme after present day. Analysis shows that ponderosa pine DMR keeps raising for 

the 40 year period while Douglas-fir DMR declines below extreme to high DMR. 

3.2.1.3 Aspen

There are 140 acres of aspen stands found within the project area. Isolated patches of aspen exist within the 

mixed conifer forest and are typically found on steep slopes. The aspen forest within the project area have been 

encroached on and suppressed by conifer species resulting in a decline to the population (Fairweather et al. 2008). 

3.2.1.4 Woodlands and Shrublands

Oak, juniper and pinyon woodlands make up approximately 15% of the project area. Stands typed mixed hard 

woods typically consist of Gambel oak, choke cherry, mountain-mahogany and cliff-rose. Shrublands are 

primarily mountain-mahogany and cliff-rose. Conifer species have been found encroaching on these stands and 

are evenly aged.

3.2.1.5 Grasslands and Rocklands

Grasslands have been encroached on for the past 140 years by ponderosa pine and juniper. In many areas, tree 

encroachment has reduced the grass and forage production below the stand’s potential (USDA 2005, Stoddard et 

al. 2011). Rocklands are a minor component of the project area but contain minor inclusions of aspen and conifer 

species.

3.2.2 Direct and Indirect Effects

3.2.2.1 Vegetation Structure and Dead and Downed Material

The primary management direction, for vegetative structure, in the Forest Plan is to manage for: uneven-age 

stand conditions, old age trees and old forest structure. Selection cutting methods and prescribed burning would 

also restore a surface fire regime, at the landscape scale, at frequencies within the historic range of variability 

(Reynolds et al 2013). These would need to be sustained over time along with a mosaic of vegetation densities, 

age classes and species composition across the landscape. The vegetation structure analysis assumes a projected 

treatment date of 2015, actual dates would be determined upon implementation. Overall, the alternatives differ 

based on the degree of openness and interspaces that would be created between tree groups. Selection cutting 

methods and prescribed burning would restore forest ecosystem resiliency by creating tree groups and interspaces 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

66 Chapter 3. Affected Environment and Environmental Consequences

at the fine scale, similar to historic conditions (Reynolds et al 2013). Groups of trees are defined as a cluster of 

two or more trees with interlocking or nearly interlocking crowns at maturity surrounded by an opening. Size of 

tree groups are typically variable depending on forest type and site conditions, and can range from fractions of an 

acre (a 2-tree group) to many acres. Trees within groups are typically not uniformly spaced and some may be 

tightly clumped. Selection cutting methods and prescribed burning would restore forest age and size diversity at 

the fine scale to create uneven-aged stand conditions, at the mid-scale, similar to historic conditions (Reynolds et 

al 2013). Interspaces are areas with native grass, forb, and shrub vegetation are variably shaped and typically 

range from 10 to 70 percent, with the more open conditions typically occurring on less productive sites. 

Table 3-2 shows how the alternatives would differ based on assumptions of how much potential interspace would 

be created. For example, in the ponderosa pine, forest alternative 3 and 4 would maintain the 20% interspace. 

Whereas alternative 1 would generally maintain its low amount of interspace compared to modified proposed 

action, which generally emphasizes an open forest strategy (Cooper 1960, Covington & Moore 1994, White 1985, 

Allen et al 2002). Assumptions for modified proposed action are guided by historic tree distribution in the project 

area and past projects on the Williams Ranger District that restored forest structure within the reference condition 

(Covington, W.W. and M.M. Moore. 1994). Modified proposed action would restore forest species composition 

at the mid-scale, similar to historic condition and at all scales, restore forest density to ranges reflective of the 

historic range of variability (Reynolds et al 2013). The purpose of Table 3-2 is to show, with generalized 

assumptions, how modified proposed action would provide more open pine conditions with a greater percentage 

of grass, forb, shrub openings surrounded by tree groups compared to the other alternatives. Assumptions are 

based on aerial imagery of the project area Table 3-3 and previous treatments.

Table 3-2. Estimated stand percentages of interspace and canopy cover between alternatives after treatment year*

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Ponderosa 

Pine* 

Interspace 5% 50-70% 20% 20%

Canopy 

Cover

95% 30-50% 80% 80%

Mixed 

Conifer*

Interspace 5% 10-50% 20% 20%

Canopy 

Cover

95% 50-90% 80% 80%

Pinyon 

Juniper

Interspace 20% 75% 75% 75%

Canopy 

Cover

80% 25% 25% 25%

* Percentages do not include, Arizona Bugbane Botanical Area, MSO PAC or Core, and Goshawk Nest. These areas will maintain a higher 

percentage of mid to late seral stages.

Ponderosa Pine Forest. Vegetation structures for approximately 91% of the ponderosa pine forest are displayed 

as VSS through time in Figure 3-12, Figure 3-13, Figure 3-14, Figure 3-15, and Figure 3-16. The other 9% of 

ponderosa pine forest consists of goshawk nest areas, portions of the bugbane botanical area and Mexican spotted 

owl recovery nest roost habitat. These areas are managed differently to meet the desired conditions for habitat 

needs. General management differences would strive for higher density and higher canopy cover. Further 

information and analysis of forest structure as it relates to northern goshawk and Mexican spotted owl habitat are 

discussed in the wildlife section of this chapter. For the following vegetation structure analysis, pine oak habitat 

is averaged within the ponderosa forest. Indirect effects are described as changes due to an increase or decrease 

of density from another VSS. The VSS forested group calculations do not include forest interspaces because 

interspaces are not intended to regenerate to seedling/sapling stage. Interspaces are expected to be maintained by 

low intensity fire. The alternatives’ effects are based on direct actions/no actions represented and how well each 

alternative meets the balanced condition and uneven aged forest 40 years into time.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 67

Ponderosa pine forested areas ranging from grass/forb/shrub to seedling/sapling stages (VSS1 and 2) would be 

regulated and implemented based on land area percentages. Natural regeneration was modeled every decade in 

each simulation as recommended (Rleveld 1978). In general, VSS1 and 2 groups have larger blackjack and 

yellow barked ponderosa pine scattered within to provide shelter and a seed source. Figure 3-12 demonstrates a 

lower amount than the balanced uneven-aged condition because of larger trees existing among VSS 1 and 2. The 

BA of VSS 1& 2 trees in the VSS 1 & 2 groups is dominant. It may only take 1 yellow barked pine mixed in to a 

VSS1-2 group to change the VSS designation. Figure 3-12 generally represents VSS 1 and 2 that are not 

dominated by larger trees. Most regeneration areas in alternative 3 and 4 are shown as larger VSS classes. In 

modified proposed action, most forested groups are uneven aged and represent higher VSS where active 

regeneration would exist. Some areas in modified proposed action represent true VSS1 and 2. Indirect effects 

from other VSS classes also changes VSS 1 and 2 percentages. Modeling shows direct effects between the 

alternatives on VSS 1 and 2 but does not incorporate events such as epidemic beetle kill and wildfires which can 

also increase grass/forb/shrub to seedling/sapling stages (White 1985). It is likely VSS 1 and 2 would increase 

within the project area under action alternatives from unplanned events (White 1985, Rleveld 1978). 

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

2013 2014 2023 2033 2043 2053

Percent VSS (%)

Ponderosa Pine Forest (Mid-scale):VSS 1 & 2

ALt1

Alt2

Alt3

Alt4

FOREST

PLAN

Balance

Multiaged

Figure 3-12. Ponderosa pine forest (mid-scale): VSS 1 & 2

0

5

10

15

20

25

30

35

40

2013 2014 2023 2033 2043 2053

Percent VSS (%)

Ponderosa Pine Forest (mid-scale): 

Percent VSS 3

Figure 3-13 Ponderosa pine forest (mid- scale): VSS 3
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

68 Chapter 3. Affected Environment and Environmental Consequences

The action alternatives for VSS 3, in all three scales, trend to acceptable levels directly after treatment where no 

action directly after treatment remains above 10 percent of the balanced condition. Through time at the fine and 

landscape scale, all action alternatives returned to the balanced condition, with modified proposed action 

becoming the best represented. Through time at the mid-scale, all alternatives show decline with alternative 1 

becoming the best represented. This can be explained with the nature of the initial cutting of the action 

alternatives (groupy clump vs uniformed spaced). Unlike the other alternatives, alternative 1 is left with uniform, 

even-aged growing condition taking up more growing space than if trees were grouped with interspaces. Through 

time, the reduction of VSS 3 at the mid-scale for the action alternatives increases growing space for VSS 4, 5 and 

6. Future tending of larger VSS classes would bring mid-scale averages toward a more balanced multi-aged 

condition. 

Figure 3-14 and Figure 3-15 show the effects to VSS 4, 5 and 6 by alternative. For all alternatives, mid-scale VSS 

4 shows that direct effects are minor. At the fine and landscape scale, a defined difference is shown between 

alternative 1 and 2. These differences specifically show alternative 1 moving directly away from the balanced 

multi-aged condition while modified proposed action moves toward it. Alternative 3 and 4 for each scale 

eventually meets the balanced multi-aged condition through time. 

Figure 3-14. Ponderosa pine forest (mid-scale): VSS 4

Figure 3-15. Ponderosa pine forest (mid-scale): VSS 5

0

10

20

30

40

50

60

2013 2014 2023 2033 2043 2053

Percent VSS (%)

Ponderosa Pine Forest (mid-scale): 

Percent VSS 4 

0

10

20

30

40

50

2013 2014 2023 2033 2043 2053

Percent VSS (%)

Ponderosa Pine LOGPFAs (midscale): Percent VSS 5
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 69

Indirectly from the majority of VSS 3 and 4 groups being treated, modified proposed action builds an excess of 

VSS 5. Alternative 1 falls directly aligned with balanced condition for VSS5. The excess of VSS 5 in modified 

proposed action indirectly relates to the future increases in VSS 6. Alternative 3 and 4 directly meet the VSS 5 

balance condition the best. Through time alternative 3 and 4 VSS 5 class will become older and larger, moving 

into VSS 6. Among the alternatives for VSS 6, modified proposed action moves the best toward multi-aged forest 

directly and through time. 

-10

0

10

20

30

40

2013 2014 2023 2033 2043 2053

Percent VSS (%)

Ponderosa Pine Forest (midscale): Percent VSS 6

Figure 3-16. Ponderosa pine forest (mid- scale): VSS 6

Other ponderosa pine forest components are displayed in Table 3-3. Canopy cover is displayed for VSS groups 

consisting of older trees. Canopy cover averages are similar by group VSS designation. In general, the effects to 

canopy cover are similar for all alternatives because these are classes with the least amount of treatment due to 

conserving presettlement trees and maintaining uneven-aged forest. 

The modified proposed action shows more of a deviation in VSS 4 canopy cover from the other alternatives but 

recovers through time. Mid-scale canopy cover is estimated in Table 3-4. The 18+ inches DBH snags, logs 

greater than 12+ inches in diameter at mid-point that are greater than 8 foot long and dead and downed material 

greater than 3 inches in diameter were analyzed at the midscale level. Table 3-3 snag analysis incorporates only

100% dead trees. Overall, the effects from the vegetative treatments with prescribed fire maintain current snag 

levels. Green snags are not included in the calculations. These are snags that are alive but act as snags by having 

dead and/or broken tops. These types of snags exist in the project area and would be conserved through 

mitigation. It is estimated with mitigation and 100% dead snags analyzed that 1 to 2 snags per acre would exist 

through time in the ponderosa pine forest. There is little helicopter removal for modified proposed action and 3 in 

ponderosa pine forest. Helicopter removals would directly decrease snag levels at the mid-scale but these 

numbers recover over time. This can be assured through tree mortality induced by prescribed burning and bark 

beetle kills. There, logs 12+ inches in diameter remain above 3 logs per acre for all alternatives. Dead and down 

material (greater than 3 inches and including logs) for all alternatives remain within 3 to 10 tons per acre. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

70 Chapter 3. Affected Environment and Environmental Consequences

Table 3-3. Ponderosa pine forest: Snags, logs, dead and downed material (mid-scale) and tree group canopy cover

Year

Snags 18"+ 

(Per Acre)

Logs 12"+ (Per 

Acre)

Dead and 

Down >3" 

(Tons/Acre)

VSS 4 Canopy 

Cover (%)

VSS 5 Canopy 

Cover (%)

VSS 6 Canopy 

Cover (%)

Alternative 1 (No Action, Excludes Wildfire) Bill Williams Mountain Project Ponderosa Pine Forest

2013 0.7 10 6 40 39 30

2014 0.7 10 6 49 49 43

2033 0.6 11 7 56 57 52

2053 0.8 12 9 61 60 57

Alternative 2 (Modified Proposed Action): Bill Williams Mountain Project Ponderosa Pine Forest

2013 0.7 10 6 40% 39% 30%

2014 0.7 4 3 28% 33% 24%

2033 0.8 7 5 43% 44% 36%

2053 0.9 8 5 55% 53% 45%

Alternative 3: Bill Williams Mountain Project Ponderosa Pine Forest

2013 0.7 10 6 40% 39% 30%

2014 0.7 4 3 33% 37% 29%

2033 0.6 7 5 46% 47% 41%

2053 0.6 8 5 55% 53% 50%

Alternative 4: Bill Williams Mountain Project Ponderosa Pine Forest

2013 0.7 10 6 40% 39% 30%

2014 0.7 6 3 37% 40% 34%

2033 0.7 8 6 52% 50% 45%

2053 0.6 9 6 58% 57% 53%

Mixed Conifer. Vegetation structures for 100% of the mixed conifer forest are displayed by VSS as modeled 

through time in Figure 3-17, Figure 3-18, Figure 3-19, Figure 3-20, and Figure 3-21. Reference the wildlife 

report for MSO mixed conifer analysis on habitat evaluation criteria. Vegetative indirect effects are based on 

changes in VSS percentage of representation. The prescriptions for mixed conifer vary based on alternative. 

Alternative 2 would thin mixed conifer forest to have interspace between patches of trees. Patches would be 

thinned to reduce the risk of crown fire and to move the forest to uneven-aged. The prescriptions for alternatives 

3 focus on thinning conifers from below to 9 inches DBH in MSO PAC and MSO mixed conifer recovery nest 

roost habitat. In alternative 4, mechanical treatment was deferred except for the strategic fuels locations. Fire 

was simulated under the various treatments. All action alternatives incorporate Arizona Bugbane Botanical Area 

mitigation measures.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 71

0.00%

5.00%

10.00%

15.00%

20.00%

25.00%

2013 2014 2023 2033 2043 2053

Percent VSS (%)

MixedConifer Forest (Mid-scale): :VSS 1 & 2

ALt1

Alt2

Alt3

Alt4

Balance 

multiaged

Figure 3-17. Mixed conifer forest (mid-scale): VSS 1 & 2

Mixed conifer forested areas of grass/forb/shrub to seedling/sapling stages (VSS 1 and 2) would be regulated and 

implemented based on land area percentages. Natural regeneration was modeled every decade in each simulation 

as recommended (Rleveld 1978). In general, VSS 1 and 2 groups have older mature Douglas fir, white fir and 

ponderosa pine within them. The BA of VSS 1& 2 trees in the VSS 1 & 2 groups is dominant. It may only take 1 

yellow barked pine mixed in to a VSS1-2 group to change the VSS designation. Figure 3-17 demonstrates a lower 

amount than the balanced multi-aged condition because of larger trees existing among VSS 1 and 2. In general, 

Figure 3-17 represents VSS 1 and 2 that are not dominated by larger trees. Alternative 1 shows a steady increase 

of VSS 1 and 2 through time. In alternative 2, most forested groups are uneven aged and are represented as 

higher VSS. Some areas in alternative 2 represent true VSS 1 and 2 with not too many large trees. Indirect 

effects from other VSS classes changes VSS 1 and 2 percentages. It is likely VSS 1 and 2 would increase within 

the project area under action alternatives (White 1985, Rleveld 1978). 

The action alternatives, displayed in Figure 3-18, for VSS 3 trend toward desired levels directly after treatment 

where no action remains outside of the balanced condition. At the fine scale and landscape level, all alternatives 

show a reduction in VSS 3 and quickly spike back up in the future. This is indirectly due to the increases and 

decreases of VSS 4, 5 and 6. The increase of VSS 3 is indirectly tied to the decrease of VSS 4. The benefit of 

these fluctuations through time can be observed in the stabilization of VSS 5 and 6 groups. The majority of the 

mixed conifer forest is designated as MSO nest/roost recovery habitat, and the Arizona Bugbane Botanical Area 

influence the resulting VSS 3 percentages because the desired conditions call for retaining more large and old 

trees. The reduction of VSS 3 for alternative 3 is due to thinning from below treatments. Indirectly, this would 

increase the percentage of VSS 4, 5 and 6 for alternative 3. A similar reduction, not reflected in the modeling, 

would be shown in alternative 4 due to the increased mortality from wildfire due to no vegetative treatment. The 

fire effect of increased fuel created by VSS 3 groups is discussed in the fuels section.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

72 Chapter 3. Affected Environment and Environmental Consequences

0

5

10

15

20

25

30

35

2013 2014 2023 2033 2043 2053

Percent VSS (%)

Mixed Conifer Forest (mid-scale): 

Percent VSS 3

Figure 3-18. Mixed conifer forest (mid-scale): VSS 3

Figure 3-18 shows how percentages stay above the balanced multi-aged condition. Alternative 2 returns the 

closest to the balanced multi-aged condition at the mid-scale. 

0

10

20

30

40

2013 2014 2023 2033 2043 2053

Percent VSS (%)

Mixed Conifer Forest (mid-scale): 

Percent VSS 4 

Figure 3-19. Mixed conifer forest (mid-scale): VSS 4

Figure 3-20 shows the analysis for mixed conifer VSS 5. All alternatives trend above the multi-aged condition 

with alternative 2 and 4 directly trending closer to the desired conditions. At the mid-scale, alternatives 1 and 4 

maintain mixed conifer forest below the multi-aged condition. 

Figure 3-21 shows the analysis for mixed conifer VSS 6. All alternatives trend toward the multi-aged condition 

with alternatives 3 and 2 directly trending faster. At the mid-scale, alternative 3 meets the multi-aged condition at 

the end of the 40 year period. At the fine and landscape scale, alternative 2 rises to the multi-aged condition and 

maintains itself around the threshold, while alternative 3 fully exceeds the multi-aged condition from the 

reductions of fire mortality VSS 3. Similar trends of alternative 3 could be seen in alternative 4 depending on 

mortality from burning. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 73

0

10

20

30

40

2013 2014 2023 2033 2043 2053

Percent VSS (%)

Mixed Conifer Forest (mid-scale): 

Percent VSS 5

Figure 3-20. Mixed conifer forest (mid-scale): VSS 5

0

5

10

15

20

25

2013 2014 2023 2033 2043 2053

Percent VSS (%)

Mixed Conifer Forest (mid-scale): 

Percent VSS 6

Figure 3-21. Mixed conifer forest (mid-scale): VSS 6

Other mixed conifer forest components are displayed in Table 3-4. Canopy cover is displayed for VSS groups 

consisting of older trees. Canopy cover averages are similar by group VSS designation. In general, the effects to 

canopy cover are similar for all action alternatives because these are classes with the least amount of treatment 

due to conserving presettlement trees and maintaining uneven-aged forest. Mid-scale canopy cover is estimated 

in Table 3-4. Eighteen + inch DBH snags, logs greater than 12+ inches in diameter at mid-point that are greater 

than 8 foot long and dead and downed material greater than 3 inches in diameter were analyzed at the midscale 

level. Figure 3-21 shows the snag analysis incorporates only 100% dead trees. Snags would be fallen in 

helicopter removal areas, which would affect snag levels at the mid-scale. In In Alternative 2, approximately 30% 

of the mixed conifer treatment would use helicopter removal. In Alternative 3, approximately 90%+ of the mixed 

conifer treatment would use helicopter removal. No helicopter logging would occur in alternative 4. Helicopter 

removals would directly decrease snag levels at the mid-scale but this recovers to the desired condition over time. 

This can be assured through tree mortality induced by prescribed burning and bark beetle kills. 

Overall, the effects from the vegetative treatments would decrease dead snags at the midscale. However, green 

snags are not in calculations. These are snags that are alive but act as snags by having dead and/or broken tops. 

Consistent with the plan guidelines, green snags or partial snags that exist in the project area would be conserved 

through mitigation measures. It is estimated with mitigation measures that three snags per acre would exist 

through time in the mixed conifer forest. Logs 12+ inches in diameter would remain above 3 logs per acre or 

above the desired condition for all alternatives. Dead and down material (greater than 3 inches and including 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

74 Chapter 3. Affected Environment and Environmental Consequences

logs) for all alternatives remain within 5 to 15 tons per acre. Heavier fuel loadings exist and would be maintained 

in wet mixed conifer areas for all alternatives.

Table 3-4. Mixed conifer forest: snags, logs, dead and downed material (mid-scale) and tree group canopy cover

Year

Snags 18"+ 

(Per Acre)

Logs 12"+ (Per 

Acre)

Dead and 

Down >3" 

(Tons/Acre)

VSS 4 Canopy 

Cover (%)

VSS 5 Canopy

Cover (%)

VSS 6 Canopy 

Cover (%)

Alternative 1 (No Action, Excludes Wildfire) Bill Williams Mountain Project Ponderosa Pine Forest

2013 2.5 16 11 58 55 57

2014 2.8 19 13 64 61 60

2033 1.3 24 16 68 68 65

2053 1.0 25 17 68 72 66

Alternative 2 (Modified Proposed Action): Bill Williams Mountain Project Ponderosa Pine Forest

2013 2.5 16 11 58 55 57

2014 2.8 8 6 55 53 54

2033 2.5 18 13 67 65 62

2053 1.4 21 13 73 66 63

Alternative 3: Bill Williams Mountain Project Ponderosa Pine Forest

2013 2.5 16 11 58 55 57

2014 1.0 4 3 47 38 42

2033 0.7 8 5 55 45 48

2053 0.6 9 6 53 55 37

Alternative 4: Bill Williams Mountain Project Ponderosa Pine Forest

2013 2.5 16 11 58 55 57

2014 2.8 18 12 60 56 56

2033 3.4 32 20 64 65 62

2053 1.9 35 20 63 67 62

Woodlands. Approximately 2,464 acres of woodlands are being managed as uneven-aged. This area includes 

pinyon juniper, juniper woodland, oak woodlands, and other hardwood forests. 

The no action alternative would allow these stands to continue to become denser with overstory vegetation over 

time. The productivity of grasses, forbs and shrubs in the understory would continue to decline as overstory trees 

became denser and outcompete understory vegetation for sunlight, moisture, and available nutrients (Moore et al 

2008). Over time, overstory vegetation in woodland sites would become less diverse for the following reasons: 

• Development of new age classes of trees would be impeded as the density of mid-aged trees increased 

(Moore et al 2008). 

• The longevity of large older trees would be decreased due to competition with an increasing density of 

mid-aged trees (Moore et al 2008). 

• Some tree species would be forced out over time as more aggressive, faster growing species overtop and 

outcompete these declining species for moisture and nutrients (Moore et al. 2008).

• As these woodland forests become denser over time, many stands would be placed at a higher risk of 

larger stand replacement fires than would have historically occurred within these vegetation types.

The action alternatives would reduce tree density in woodland stands. This would have the following effects on 

these stands:
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 75

• Production of grasses, forbs, and shrubs would increase in the understory. 

• A mix of trees of different ages and species would be allowed to develop over time.

• The longevity and vigor of larger older trees would increase over time because there would be less 

competition from mid-aged trees (ERI 2006). 

• Risk of large stand replacement fires would be reduced.

The action alternatives would release more understory vegetation and new age classes of trees in woodland forests 

than alternative 1 because there would be more trees removed. The action alternatives would create more 

openings along with a more mixed mosaic of vegetation in woodland forests because some mid-aged woodland 

trees would be removed. The action alternatives would be much more effective in restoring woodlands closer to 

desired conditions by reducing competition and creating a historic condition conducive for frequent fire. Due to 

no treatment of woodlands in alternative 1, a greater number of larger diameter trees would persist on the 

landscape than all the action alternatives. Snags and large downed logs for woodland stands are discussed in the 

wildlife section.

Grasslands. There are 64 acres of grassland within the project area. Under alternative 1 more trees would 

continue to regenerate and develop within the grasslands. The increasing density of trees over time would lead to 

the following effects within the grasslands of the project area:

• Productivity of grasses and forbs would continue to decrease as trees start to outcompete understory 

plants for light, moisture, and nutrients. 

• The size of open grasslands would continue to decrease as trees invade grasslands from the edges and 

continue to move towards the grasslands center. Some smaller grassland sites would likely be completely 

converted to forest (Moore and Huffman 2004). 

The action alternatives propose treatments to reduce tree density in grasslands that would lead to the following 

effects:

• Production of grasses and forbs would increase. 

• Grasslands would be maintained at or close to their historic distributions and sizes. 

• Grass cover would increase which would result in less erosion, particularly within grasslands that are 

being encroached upon by junipers. 

The action alternatives better restore grasslands because they would reduce competition from the overstory to 

understory grasses by providing more sunlight and nutrients to existing grasses. Diameter growth of trees in 

grasslands is often very rapid because grasslands are often found on more productive sites with deeper soil and 

there are fewer trees per acre thereby reducing competition that slows growth. Leaving trees in grasslands in 

alternative 1, would maintain the seed sources, which would increase the opportunities for further new tree 

regeneration. The action alternatives would remove seed sources from grasslands.

Aspen. There are 140 acres of aspen forest within the project area. Under the no action alternative, there would 

not be any conifer removal, fencing, or jackstrawing. As a result, most of the aspen forest would continue to 

decline for the following reasons: 

• Conifer species would continue to develop within aspen sites. As these conifers overtop and outcompete 

the aspens, the conifers would start to replace the aspen. Many of the aspen sites would likely be 

completely replaced by conifers (Cooper 1960). 

• Heavy elk and deer browsing within aspen sites impede the development of aspen sprouts. Sprouts would 

not develop into trees. Most aspen sites would vanish from the landscape as older aspen die off and 

younger aspen are not allowed to develop (Fairweather et al 2008). 

The action alternatives provide for removing conifer encroachment within aspen stands and protecting newly 

developing aspen sprouts from elk and deer browsing with fencing and jackstrawing of activity slash. These 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

76 Chapter 3. Affected Environment and Environmental Consequences

alternatives would attempt to restore aspen within some dead aspen sites that are no longer sprouting by planting 

aspen and fencing. These proposed treatments would maintain aspen clones in the project area. These treatments 

would increase the vigor and longevity of existing aspens while providing for development of new aspen trees 

over time. However, depending on whether the aspen falls within the Mexican spotted owl or Arizona bugbane 

habitat, some aspen stands would be managed to meet habitat management direction. Alternative 2 would best 

meet the desired conditions relative to aspen management.

3.2.2.2 Forest Health

Ponderosa Pine Bark Beetle Risk. Figure 3-22 demonstrates how the alternatives differ for bark beetle risk 

based on BA. All the action alternatives would directly decrease their bark beetle risk after treatment. An 

additional decrease would occur for all action alternatives after the treatment year due to the prescribed burning. 

This slight reduction in basal area would be enough to bring all action alternatives below the moderate bark beetle 

risk threshold 10 years after treatment. In the action alternatives, additional slash created from burning would not 

be a concern for increasing bark beetle populations due the increased tree vigor from the treatments (Fettig 2006). 

If a wildfire occurred under current conditions (no action alternative) many trees would die generating slash that 

would create conditions for bark beetle populations to rise (Fettig 2007). The residual living trees would be 

stressed and the combination of factors would put the area at increased risk for an epidemic beetle infestation 

under alternative 1.

Through time, the action alternatives increase their bark beetle risk and all remain under the extreme threshold for 

40 years. Alternative 2 remains the lowest bark beetle risk through the simulation.

0

20

40

60

80

100

120

140

160

180

2013 2014 2023 2033 2043 2053

Basal Area ft2/ac 

Alt1

Alt2

Alt3

Alt4

Figure 3-22. 40 year measure of bark beetle risk and sustainability for all alternatives in the ponderosa pine forest

Mixed Conifer Bark Beetle Risk. Figure 3-23 demonstrates how alternatives differ for bark beetle risk in the 

mixed conifer based on BA. All the action alternatives directly decrease the bark beetle risk after treatment with 

alternative 3 being the lowest. An additional decrease in risk would occur under all action alternatives after the 

treatment year due to the prescribed burning. This slight reduction in basal area would be enough to bring all 

action alternatives below the moderate bark beetle risk threshold for 10 years after treatment, except alternative 2. 

Alternative 2 would remain at moderate risk after treatment which barely missed the low threshold. The gradual 

reduction in basal area from the burning treatment is due to alternative 2 having the optimal structure for minimal 

mortality during a prescribed burning event (Sánchez Meador et al 2010). Alternative 4 shows a slight reduction 

in risk after thinning treatment and a large increase after the burning event. 

The large reduction of bark beetle risk after burning treatment is due to most of the mixed conifer in alternative 4 

not thinned. This type of reduction of bark beetle risk, at a minimum, can be expected with low intensity wildfire 

under alternative 1. Alternative 3 shows a large decrease of bark beetle risk after thinning treatment and a slight 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 77

decrease after burning. The concern with major reductions of bark beetle risk after a burning event is due to the 

increased slash and dead standing trees providing an optimal habitat for bark beetle populations to increase (Fettig 

2006). Epidemics are likely with the combination of decreased tree vigor, increased populations and tree 

competition (Fettig 2007).

Modeling shows that after 10 years the risk of bark beetle outbreaks would increase, but would remain under the 

high threshold for at least 40 years. Alternative 3 would maintain the lowest bark beetle risk of the action 

alternatives over time.

0

50

100

150

200

250

2013 2014 2023 2033 2043 2053

Basal Area ft2/ac 

Alt1

Alt2

Alt3

Alt4

Figure 3-23. Forty year measure of bark beetle risk and sustainability for all alternatives in the mixed conifer forest

Ponderosa Pine Dwarf Mistletoe (DM). The following DM analysis does not analyze DM outside of extremely 

infected stands. Figure 3-24 demonstrates how the alternatives changed the intensity of DM within the ponderosa 

pine forest based on percent of TPA infected amongst stands extremely infected. Trends for each alternative are 

different amongst alternatives because of the difference of treatments. Alternative 3 and 4 show similar trends, of 

decreased % of TPA infected. This is due to vegetative cuts focusing on DM in extremely infected areas. 

Alternatives 3 and 4 drop down to 30%, not making the desired condition for uneven aged management, and 

increase through time (Conklin and Fairweather 2010). This occurred due to the diameter limit of 24” in pine oak 

MSO habitat prevented some removal. Since Alternative 2 focused on densities based on pre-settlement evidence 

and historic forest structure of a pine savanna, DM remained highly represented in the stand structure.

The percentage of TPA infected rises and trends close to Alternative 1. Even though these two alternatives have 

similar trends, one major difference between the alternatives is how alternative 2 will isolate DM tree groups 

ultimately reducing the spread (Conklin and Fairweather 2010). Frequent fire through time, not modeled, will 

maintain grassy openings between groups, preventing regeneration between groups, reducing the spread. The 

interactions of DM and fire are explained in detail in Conklin and Fairweather 2011, and they explain where DM 

currently exist is similar to the historic distribution. The increased amount of trees on the landscape increased the 

intensity and spread. Conklin and Fairweather, 2010 recognize that burning in DM areas can reduce mistletoe 

infection levels within these areas by thinning out lower limbs infected with mistletoe through torching and 

having a higher likelihood of inducing mortality in mistletoe infected trees. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

78 Chapter 3. Affected Environment and Environmental Consequences

Conklin and Fairweather 2010 also express that today’s current departure from historic DM conditions are 

primarily the decreased amount of older trees infected with DM. Their recommendations have the caveat that 

historic DM conditions might not be desirable in areas critical for fire abetment. In the scenario of alternative 2, 

this is a situation where both fire abetment and development of large trees with DM can be met. Even though 

Alternative 1, 3 and 4 maintains the existing old infected trees, and provide for maintaining smaller diameter trees 

next to old infected trees, the development of old trees infected with DM into the future is questionable due to fire 

risk. 

47%

52%

54%

60%

63%

66%

30%

44%

40% 43%

50%

34%

53%

0%

10%

20%

30%

40%

50%

60%

70%

80%

2013 2014 2023 2033 2043 2053

Alt 1

Alt 2

Alt 3

Figure 3-24. Percent of TPA infected of extremely infected DM Stands (ponderosa pine forest)

Figure 3-25 demonstrates how the alternatives changed the severity of DM within the ponderosa pine forest based 

on DMR. The similar trends from percent TPA infected can be seen in DMR. Alternative 2 maintains a high 

infection level and gradually increases to extreme at the end of the simulation. Alternative 3 and 4 reduce to 

moderate levels and slowly increase to high, 40 years in the future. It is likely with future burning events, the 

DMR for alternative 2 would stabilize at moderate to high levels. 

1.75

1.56 1.59

1.75

2.00

2.20

0.61

0.92 0.76 0.93

1.22

0.42

0.61 0.70

1.20

0

0.5

1

1.5

2

2.5

3

2013 2014 2023 2033 2043 2053

Dwarf Mistletoe Rating (DMR)

Alt 1

Alt 2

Alt 3

Alt 4

High

Figure 3-25. Dwarf mistletoe rating of extremely infected DM stands (ponderosa pine forest)
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 79

Mixed Conifer Dwarf Mistletoe. The following DM analysis does not analyze DM outside of extremely infected 

stands. Figure 3-26 demonstrates how the alternatives changed intensity of DM for ponderosa pine within the 

mixed conifer forest based on percent of TPA infected amongst stands extremely infected. Alternative 3 moves 

the closest to the desired condition and stabilizes by the end of the simulation. The percent infected doesn’t fall 

any lower due to the variety of diameter limits in MSO and Arizona bugbane habitat. Alternative 2 and 4 fall 

below alternative 1 through time but steadily increase. The results of alternative 4 are directly due to deferral in 

most mixed conifer stands. The results for alternative 2 are directly due to maintaining uneven aged groups and 

not focusing as much on DM infection as alternative 3.

58%

46%

56%

63%

70%

44%

31% 29% 28% 28%

61% 63% 60%

64%

68% 70%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

2013 2014 2023 2033 2043 2053

Alt 1

Alt 2

Alt 3

Alt 4

Desired Condition

Figure 3-26. Mixed conifer % of TPA infected of extremely infected DM stands (ponderosa pine)

Figure 3-27 demonstrates how the alternatives change intensity of DM for Douglas-fir within the mixed conifer 

forest based on percent of TPA infected amongst stands extremely infected. In general, the action alternatives 

trend close or above alternative 1. This is due to diameter limitations from the variety of diameter limits from 

MSO protected, restricted and Arizona bugbane habitat. 

40%

50%

69%

45%

50% 59%

39% 41% 40%

41% 49%

42%

69% 57%

77%

78%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

2013 2014 2023 2033 2043 2053

Alt 1

Alt 2

Alt 3

Figure 3-27. Mixed conifer % of TPA infected of extremely infected DM Stands (Douglas-fir)
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

80 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-28 demonstrates how the alternatives changed the severity of DM for ponderosa pine within the mixed 

conifer forest based on DMR. Alternative 2 and 3 bring the DMR below extreme but don’t move below the high 

DMR because of the diameter limits on MSO and Arizona bugbane habitat. Alternative 3 has the best DMR 

through time. Alternative 2 slowly recovers to extreme levels.

1.91

2.45

2.69

1.38

1.53

1.85

1.59 1.89 1.76 1.86

1.95

2.38

3.03

1.58

2.36

0

0.5

1

1.5

2

2.5

3

3.5

2013 2014 2023 2033 2043 2053

Dwarf Mistletoe Rating (DMR)

Alt 1

Alt 2

Alt 3

Alt 4

High

Extream

Figure 3-28. Mixed conifer dwarf mistletoe rating of extremely infected DM stands (ponderosa pine)

Figure 3-29 demonstrates how the alternatives change the severity of DM for Douglas-fir within the mixed 

conifer forest based on DMR. After treatment, in alternative 2 and 4, DMR increases. Alternative 2 increases due 

to prescriptions focusing on multi age development of groups. Conversely DM was targeted in alternative 3 

resulting in a decrease of DMR. Alternative 3 doesn’t decrease below high due to diameter constraints in MSO 

and Bugbane habitats. Alternative 4 with the minimal amount of thinning in some mixed conifer and a prescribed 

burn, DMR increase the highest. Generally, what would be thinned in alternative 4 would be minimal at a small 

scale with the increase of DMR after the treatment year. The second increase in alternative 4 is due to additional 

mortality from burning, reducing stand densities and leaving trees with severe DMR, resulting in a high stand 

DMR. The major decrease in DMR for alternative 2 and 4 is due to the added regeneration after mortality. As the 

stands regenerated with younger age classes, infection levels of DMR decreased due to regeneration not being 

infected. By the end of the simulation period, the regeneration becomes more infected, causing severity to 

increase.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 81

2.84

2.30

1.63 1.80

2.06 2.21

1.83

1.39

1.20 1.20 1.23

2.70 2.63 2.64 2.76

2.95

0

0.5

1

1.5

2

2.5

3

3.5

2013 2014 2023 2033 2043 2053

Dwarf Mistletoe Rating (DMR)

Alt 1

Alt 2

Alt 3

Alt 4

Figure 3-29. Mixed conifer dwarf mistletoe rating of extremely infected DM stands (douglas-fir)

Aspen. The health of aspen stands in the project is best described by the effects of the vegetation structure within 

aspen clones. As seen in past fires on the Williams Ranger district, low intensity prescribed fire can increase the 

amount of seedlings and saplings per acre. Other areas show that exclusion of large ungulates also encourages 

aspen recruitment. Action alternatives would promote aspen health by preventing some level of suppression by 

encroaching conifers. 

Old Growth. Kaibab Forest plan (USDA 2014) defines old growth by the following:

Old growth in southwestern forested ecosystems is different than the traditional definition based on northwestern 

infrequent fire forests. Due to large differences among Southwest forest types and natural disturbances, old growth 

forests vary extensively in tree size, age classes, presence and abundance of structural elements, stability, and 

presence of understory (Helms 1998). Old growth refers to specific habitat components that occur in forests and 

woodlands—old trees, dead trees (snags), downed wood (coarse woody debris), and structure diversity (Franklin and 

Spies 1989, Helms 1998, Kaufmann et al. 2007). These important habitat features may occur in small areas, with 

only a few components, or over larger areas as stands or forests where old growth is concentrated (Kaufmann et al. 

2007). In the Southwest, old growth is considered “transitional” (Oliver and Larson 1996), given that the location of 

old growth shifts on the landscape over time as a result of succession and disturbance (tree growth and mortality). 

Some species, notably certain plants, require “old forest” communities that may or may not have old growth 

components but have escaped significant disturbance for lengths of time necessary to provide the suitable stability 

and environment.

In southwestern frequent-fire forests, old growth is naturally fragmented, and occurs as tree groups, clumps, 

individual trees, and occasional patches in an uneven-aged forest landscape. Research has demonstrated an 

inverse relationship between fire frequency and old-growth contiguity. In the ponderosa pine and frequent-fire 

ecosystems of Kaibab National Forest, local research has shown that old growth did not occur in large contiguous 

areas, but rather as fine-scale components of the uneven-aged system (Reynolds et al. 2013). There is no scientific 

basis to support managing for contiguous old-growth conditions at larger scales for these vegetation types on the 

Kaibab National Forest. 

The action alternatives provide for a flow of old-growth conditions and function over time at the fine, mid, and 

landscape scale. Spatial shifting or transition of old growth on the landscape over time would remain consistent 

with historic conditions. While alternative 2 allows for the removal of some large, mature, and old trees, the 

vegetation analysis demonstrates that results in a net gain of large trees over time, and more than any other 

alternative. Moreover, managing for restored forest conditions that are similar to natural conditions would restore 

resiliency and the evolutionary environment of these forests, providing the best opportunity for these forests to 

persist and adapt to future climates (Reynolds et al 2013).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

82 Chapter 3. Affected Environment and Environmental Consequences

The project provides habitat goshawk nest areas which are typically well-defined tree groups that meet the 

definition of old growth. The project also provides larger areas managed for MSO recovery nest/roost habitat, 

MSO PAC and Arizona bugbane which would be dominated by old growth patches and tree groups. 

Mitigation measures are in place for the project area to maintain and protect pre-settlement trees, the old trees that 

lived during the time period where natural functions such as frequent fire events persisted naturally under historic 

fuel loadings. The locations of these old trees across the landscape help define existing old growth on the ground. 

The project manages for old growth and old-growth components for all forest and woodland vegetation types, 

which activities maintain or make progress toward. Additionally, the project follows forest plan guidance to 

generally not remove structural components associated with old growth including large old ponderosa pine trees 

with reddish-yellow wide platy bark, mature trees with large dwarf mistletoe-induced witches’ brooms, large 

snags, partial snags, and trees (greater than 18 inches dbh.) with broken tops, cavities, sloughing bark, and 

lightning scars. In addition, the project would generally retain at least historic frequencies of trees by species 

across broad age and diameter classes at the mid-scale. As such, the largest and oldest trees are usually retained.

3.2.2.3 Large Trees across the Landscape

There is desire retain large trees across the landscape. The project is consistent with the forest plan desired 

conditions and standards and guidelines for ensuring large trees across the landscape. The desired conditions in 

the forest plan for Ponderosa pine at the mid-scale is for “basal area within forested areas generally ranges from 

20 to 80 square feet per acre, with larger trees (i.e. >18 inches in diameter) contributing the greatest percent of the 

total basal area” (FS Plan pg. 17). For mixed conifer the desired condition at the mid-scale is for “basal area 

within forested areas generally ranges from 30 to 100 square feet per acre, with larger trees contributing the 

greatest percent of the total basal area” (FS Plan pg. 22). Forest plan guidelines state that, “project design and 

treatment prescriptions should generally not remove: Large, old ponderosa pine trees with reddish-yellow, wide 

platy bark, flattened tops, with moderate to full crowns and large drooping or gnarled limbs” (FS Plan pg. 30). 

Project design and treatments incorporated desired conditions and mitigation measures. Mitigation measures 

ensure that this guideline is met.

This analysis measures large trees as numbers of trees remaining after treatment, growing space for allocated large 

tree and longevity of large trees. Large tree for this analysis will be defined as 18” + DBH trees due to the 

relationship to VSS 5 and 6 groups (starting with an average diameter of 18” DBH). VSS 5 and 6 group average 

diameter limits provide an ecological tie to large trees across the landscape.

Ponderosa Pine. Table 3-5 provides landscape averages of just ponderosa pine > 18” DBH per acre. There are 

slight differences between the alternatives. Since alternative 1 would not reduce insect and fire risk, it is less 

desirable for an alternative of large tree retention. Even though the quantitative analysis demonstrates there 

would be more trees, it is unlikely these trees will be sustained through time due to less growing space, and 

increased stress coupled with insects and diseases, and risk of high severity wildfire. Among the action 

alternatives, alternative 3 would maintain the most large trees though time, although alternative 1 would have the 

most large trees in the short term. The same trends of large tree retention can be observed in MSO habitat.

Table 3-5. Ponderosa pine forest 18"+ trees per acre

2013 2014 2023 2033 2043 2053

Alt1 8.1 8.3 10.4 13.4 16.4 18.2

Alt2 8.4 7.6 9.3 12.4 14.8 17.0

Alt3 8.3 7.5 9.3 13.5 17.3 20.1

Alt4 8.2 7.6 9.0 13.2 16.5 19.8

Mixed Conifer. Table 3-6 provides landscape averages of just ponderosa pine > 18” DBH per acre. There are 

slight differences between the alternatives. Since alternative 1 would not reduce insect and fire risk, it is less 

desirable for an alternative of large tree retention. Even though the quantitative analysis demonstrates more trees, 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 83

it is unlikely these trees will be sustained through time due to less growing space, and increased stress coupled 

with insects and diseases and risk of high severity wildfire. Alternative 4 is also less desirable due to unknown 

future insect and fire risk in the no thinned area or induced morality for prescribed burning. Among the action 

alternatives, alternatives 1 and 2 would result in the most large trees though time and alternative 2 and 3 would 

have the most large trees in the short term. The same trends of large tree retention can be observed in MSO 

habitat. 

Table 3-6. Mixed conifer forest 18”+ trees per acre

2013 2014 2023 2033 2043 2053

Alt1 12.4 12.5 14.0 15.8 19.9 23.0

Alt2 12.4 12.6 11.9 14.4 18.9 21.5

Alt3 12.4 12.6 11.9 12.9 16.4 18.9

Alt4 12.4 12.5 8.3 9.9 12.2 14.9

Treatment Longevity. Treatment longevity out lines future predictions of future management needs within the 

project area. Different alternatives per forested Community pose different needs based on the actions of all the 

alternatives. Alternative 1 does not include any treatments, so the ponderosa pine forest would remain in its 

current state, and would be depend on insect and disease epidemics and risk of loss from high intensity standreplacing wild fires (Donovan et al 2008, Fule 2008). Alternative 2 would thin the forest more than alternative 3 

and 4. This alternative would maintain the future need of timber harvest but not as readily as the other 

alternatives. The ability to maintain desired conditions using prescribed or natural fire would remain a viable 

option for a longer period of time in modified proposed action than alternatives 3 & 4. The use of maintaining 

desired condition with fire can rapidly treat the project area under minimal cost (Fule 2008). 

The forest density levels managed under alternatives 3 and 4 present a condition that would need to be reassessed 

in the future (Strom and Fule 2007). Up to 40 years into the future, additional efforts would be needed to create 

additional regeneration areas under group selection silvicultural uneven aged systems (Graham et al 2006). This 

would require the use of timber harvesting and prescribed burning. 

3.2.3 Summary Comparison of Alternatives

This analysis has established that alternative 1will result in the project area moving further away from desired 

conditions. The area will continue to be at a high risk of stand replacement fire. Bark beetle hazard risk would 

remain at extreme levels. Mistletoe infections will continue to spread and intensify and forest health will be 

reduced over much of the area. The area will move further away from the desired distribution of multiple age 

classes of trees because new age classes will not be able to establish in the understory due to dense over stories 

and disease. Desired vegetative conditions will not be sustainable over time. Grass, forb, and shrub production 

would continue to decline over time. 

Under alternative 1 meadows, savannahs, and forest openings will continue to be lost (unless created by 

destructive wildfires). Aspen will be lost over much of the project area over time as conifer over stories continue 

to displace them and because of the aspen’s inability to develop younger age classes due to heavy elk and deer 

browse. 

The primary difference between the action alternatives is that: Alterative 2 mimics historical forest conditions 

while alternative 3 & 4 will maintain forest conditions at higher densities. Uneven-aged forest conditions would 

be achieved in alternative 2 but would not be achieved in the mixed conifer for alternative 3 and 4. All the action 

alternatives meet the objective of mistletoe management. Alterative 2 does not primarily focus on mistletoe 

removal to meet the desired condition while tree removal in alternative 3 & 4 would be based on mistletoe 

infection. However, alternative 2 would focus on some mistletoe reduction within individual groups. Bark beetle 

hazard risk would be lowered to manageable levels for all action alternatives. Effectiveness for bark beetle hazard 

risk would be most effective under alternative 2, less effective for alternative 3, and least effective for action 

alternative 4 due to the no thinning on steep slopes. 
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84 Chapter 3. Affected Environment and Environmental Consequences

Other differences between the action alternatives include:

• Alternative 4 would develop more large snags and logs over time than the other action alternatives would; 

• Alternative 2 would more effectively open up meadows and create forest openings than the other 

alternatives would;

• Alternative 2 would more effectively release aspen than the other alternatives would; and

• Alternative 2 would more effectively release large oak, large juniper and yellow pine than the other 

alternatives would.

• Alternatives 3 and 4 initially retain more large trees than alternative 2. However, recruitment of large 

trees is higher in alternative 2 due to the reduced potential for high intensity stand-replacing wildfire and 

less competition.

3.2.4 Cumulative Effects

This section addresses the cumulative effects of the action alternatives when combined with past, present, and 

reasonably foreseeable future actions. The cumulative effects analysis area is the area containing ponderosa pine 

on the Williams Ranger District. This area was used for the cumulative effects analysis because it contains the 

majority of the forested communities which are primarily represented in the project (Mixed conifer, ponderosa 

pine and aspen). Grasslands and pinyon juniper woodlands occur as inclusions in the ponderosa pine type on the 

Williams Ranger District which is consistent with the project. The cumulative effects analysis area is 

approximately 324,558 acres in size. The analysis bounds the cumulative effects time frame to 10 years in the past 

and 10 years into the future. Ten years into the past is used because projects commonly take approximately 10 

years to complete. Ten years into the future is used because this is an amount of time to consider projects as 

reasonably foreseeable.

There are approximately 15,000 acres that have had some sort of mechanical vegetative treatment over the past 10 

years within the cumulative effects analysis area. Vegetative treatments are defined as a variety of silvicultural 

treatments that involve felling trees. These treatments included low thinnings, sanitation cutting, group selection 

cuts, and individual tree shelter wood cuts. These vegetative treatments included commercial logging or 

noncommercial thinning/sanitation, or often a combination of both. Vegetative treatments were often combined 

with follow-up activity slash treatments that included lopping, piling and burning, and/or prescribed broadcast 

burning. 

In the next 10 years, approximately 160,000 acres of vegetative treatments are planned within the cumulative 

effects analysis area. For the 20-year period, beginning 10 years ago and ending 10 years from now, an 

approximate total of 175,000 acres of vegetative treatments will be accomplished. This is approximately 54% 

percent of the cumulative effects analysis area.

Over the past 10 years, approximately 35,000 acres of the cumulative effects analysis area have been prescribed 

burned or have had an unplanned ignition managed for resource objectives. In the next 10 years, 40,000 acres of 

wildland fires are expected to occur within the cumulative effects area (this includes 20,000 acres planned for 

prescribed burning and an estimate based on the previous 10 year past occurrences of 20,000 acres of unplanned 

ignitions managed for resource objectives). Over a 20 year period, approximately 75,000 acres have had low 

intensity/beneficial fire. This represents 23 percent of the cumulative effects analysis area. Some of these burn 

areas will also have vegetative treatments during the 20 year analysis period.

The greatest change in the cumulative effects analysis area over the past 150 years has been the transition from 

very open pine forests or woodlands dominated by larger trees to much denser forests or woodlands dominated by 

small to moderate sized pine or other tree species. Trends in forest conditions over this time period for the 

cumulative effects area include:

• a greatly increased risk of high intensity stand-replacing fires;
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 85

• a vast reduction in forest openings and meadow/savannah areas along with associated understory 

vegetative species;

• a more uniform vegetative condition with limited diversity; 

• reduced forest health and vigor; and 

• an increased severity of dwarf mistletoe-infected pine.

The action alternatives and the vegetative treatments and wildland fires over the past 10 years and during the next 

10 years have and would help to reverse the trends listed above for portions of the cumulative effects area. 

Vegetative treatments and wildland fires for this 20-year period would promote the following changes in forest 

conditions for the cumulative effects analysis area:

• reduced risk of high intensity stand-replacing fires by opening up forest canopies and reducing understory 

fuels;

• creation of more openings in the forest canopy; restoration of natural meadows and savannahs; increased 

development of understory grasses/forbs/shrubs; increased vigor and sustainability of aspen clones; 

• a more diverse forest structure with a broader distribution of tree age classes; 

• increased stand vigor, increased forest resiliency, and faster growth and development of individual trees; 

and 

• decreased severity of dwarf mistletoe infections.

The above trends are localized throughout the cumulative effects area. Vegetative treatments generally have more 

of an impact in promoting the above trends than wildland fire alone. A combination of both vegetative treatments 

and wildland fire would have the greatest impact in promoting the above trends. In lieu of the upcoming 4FRI 

contract projected to implement previously approved projects and the 4FRI FEIS, the future for timber markets to 

accomplish multiple acres is likely. Limited budgets, poor timber markets, and other management constraints 

historically have reduced the ability to mechanically treat much of the area to move towards desired conditions. 

Future vegetative treatment projections may vary substantially based on demand for timber and variations in 

available budget.

In 20 year time period, the proposed action combined with the other past, present, and foreseeable actions, 54% of 

the cumulative effects analysis area would receive vegetative treatment and 23% of the area would have beneficial 

fire; the rest of the analysis area would remain untreated even though much of it has treatment needs to reduce the 

risk of loss due to uncharacteristic stand-replacing wildfire, to improve forest health, and to increase stand 

diversity. Scattered treatments throughout the analysis area would limit the size and intensity of wildfires. 

A number of large mature pines that are competing against younger trees in the cumulative effects analysis area 

have been decreasing over the last 60 years. This is the result of past harvest practices, increased mortality from 

heavy competition with dense smaller pine, and some loss from wildfires and prescribed burning. This decline 

has been slowed significantly as management direction has moved away from overstory removal cutting and 

selective overstory thinning. During the last 20 years, management in the cumulative effects analysis area has 

concentrated on maintaining large mature pine while rapidly developing pine in the smaller diameter classes to act 

as future replacements for these large trees. Management direction has also moved toward increasing the 

longevity of existing large oak, older large pine, and large juniper by reducing understory competition around 

these trees. Modeling in the areas receiving vegetative treatment in the last 20 years shows that current 

management techniques are actually increasing the number of large trees across the landscape and are also 

increasing the longevity of mature pine. Prescribed burning techniques have been refined over the past 20 years 

resulting in mitigation measures designed to reduce loss of large trees, these measures are incorporated into burn 

plans. 
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86 Chapter 3. Affected Environment and Environmental Consequences

3.2.4.1 Climate Change

All background information on climate change is from Malmsheimer et al. 2008. The project is proposed on a 

local scale and is not intended to have cumulative effects that are measurable on a global scale in regard to climate 

change. However, management of the project has a small scale effect on mitigating climate change when 

combined with other management actions regionally. Most of the Bill Williams Restoration project area is 

currently considered overstocked and at risk for high intensity stand-replacing fires which are the greatest cause of 

carbon release or greenhouse gases. The action alternatives would reduce the risk potential for stand-replacing 

fires. None of the alternatives affect climate change to any measurable level. The no action alternative has the 

highest potential to release carbon in a relatively large quantity over a short period of time due to the increased 

risk of a stand-replacing wildfire occurrence. Carbon will still continue to be stored under the no action 

alternative but at a slower rate than the action alternatives. The action alternatives would increase tree growth the 

most of all alternatives and will sequester the most carbon of the alternatives. The action alternatives are the most 

effective in creating a forest that would be the most resilient to climate change because it would have the lower 

density of trees. 

3.2.4.2 Forest Plan Compliance

The project is considered project-level planning which is the mechanism for plan implementation. Project 

planning translated the desired conditions and objectives in the plan into proposals that identify specific actions, 

design features, and project-level monitoring. Proposal development for projects addressed site-specific needs 

developed locally with input from experts and stakeholders and consideration of the most current and relevant 

information. Project decision will be made following public involvement and analysis. Important considerations 

in project development include consistency with the forest plan, consistency with higher-level direction, projects’ 

potential effects on achieving desired conditions at multiple scales, and feedback from project- and plan-level 

monitoring regarding the effects and effectiveness of management strategies. 

The silviculture prescriptions for the project used the design specifications from the vegetative management 

standards and guidelines in the forest plan. The project’s alternatives are consistent with the direction in this plan 

as well as with that from current law, regulation, and policy. The forest plan does not reiterate higher-level 

direction; instead, it includes a partial list of applicable laws, regulations, executive orders, and policy for 

reference in Appendix B of the forest plan. 

The project is consistent with the Forest Plan, its design and implementation considered its setting, the 

management area it overlaps, and the guidance for the resources and conditions of the area (e.g. cultural 

resources, nonnative species, geologic formations, wildlife, Arizona bugbane, WUI, developed recreation, 

National Scenic Trails , etc.). Additionally, it considered potential conflicts with other authorized projects and 

activities. Project design is consistent with Forest Plan direction including the Bill Williams Mountain 

Management Area direction.

Project specifications considered the desired conditions for all scales in the ponderosa pine and mixed conifer 

forest communities. The consideration of scale is important for evaluating progress toward desired conditions 

because the range of variability and distribution of conditions is affected by the scale at which they are viewed. 

For example, when desired conditions are articulated at larger scales, they represent an average of fine-scale 

conditions across broader areas. This may make conditions appear less variable when they are evaluated at large 

scales, even though variability exists at the smaller scales. 

Project-level monitoring and evaluation are the tools for gathering information on progress toward desired 

conditions, the effectiveness of forest plan implementation, and the appropriateness of Forest Plan direction. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 87

3.3 Fire and Fuels Management 

3.3.1 Introduction and Affected Environment

Fire behavior is the manner in which a fire reacts to available fuels, weather, and topography. A change in any of 

these components results in a change in fire behavior (DeBano et al 1998). Fire behavior is complex, with many 

contributing factors in the categories of topography (slope, aspect, elevation), weather (climate, air temperature, 

wind, relative humidity, atmospheric stability) and fuels (size, type, moisture content, total loading, continuity, 

arrangement) (Agee 1993). These three elements comprise the fire environment, surrounding conditions, 

influences, and modifying forces that determine fire behavior (NWCG 2004). 

Topography and weather at a given location are beyond the ability of management to control. Fuel hazard is the 

only controllable factor. Weather conditions such as drought, high temperature, low humidity, and high wind play 

a major role in the spread of wildfires and are influenced by topography and location of mountains as well as 

global influences such as La Niña and El Niño. Weather conditions are a major factor in the initiation and spread 

of all wildfires, but Omi and Martinson (2002), and Strom and Fulé (2007) found that stands with prior fuel 

treatments experienced lower wildfire severity than untreated stands burning under the same weather and 

topographic conditions. Fuel management modifies fire behavior, fire effects, and reduces fire suppression costs 

and danger (DeBano et al 1998). Manipulating fuels reduces fire intensity and severity, allowing firefighters and 

land managers more control of wildland fires by modifying fire behavior in the fire environment (Pollet and Omi 

2002). 

Fuel management can include reducing the loading of available fuels, lowering fuel flammability, or isolating or 

breaking up large continuous bodies of fuels (DeBano et al 1998). Fuels contribute to the rate of spread of a fire, 

intensity, flame length, fire residence time, and the size of the burned area (Rothermel 1983). Two contributing 

factors to stand destroying crown fire are surface fuels and canopy fuel distribution. Surface fuels play an 

important role within an ecosystem. Litter and duff layers help protect soil from erosion and provide nutrients to 

the soil. However, layers of duff and litter that are too thick suffocate soil and burn with high intensities which 

create longer flame lengths and residence time (amount of time fire is present in one spot). This causes higher 

severity or damage to existing vegetation. Coarse woody debris also has an important ecological role in soil 

erosion mitigation and for the wildlife habitat, but can also contribute to more severe fire behavior. 

Large diameter woody fuels or coarse woody debris have little influence on rates of spread of fire, but burn with 

higher intensity and with longer duration that could result in greater damage to soil (Brown et al. 2003, DeBano et 

al. 1998, Harmon et al. 1986). The existing surface fuel loading in the project area is measured to be 

approximately 18 tons per acres in ponderosa pine and pine-oak forest types. This increases in the dry mixed 

conifer forest to 30 tons per acre. Desired conditions for surface fuels are less than 7 tons per acre in pine-oak and 

Ponderosa pine forests and less than 15 tons per acre in dry mixed conifer forests.

Canopy fuel distribution and the risk of stand-replacing crown fire can be measured by looking at average canopy 

bulk density and canopy base height across an area. Canopy bulk density (CBD) is defined as the mass of 

available canopy fuel per unit volume (Scott and Reinhardt 2001). For any given tree species, widely spaced trees 

have a lower CBD, which makes it more difficult to maintain a crown fire. Stands with high CBD can also 

sustain a crown fire that initiated outside of the stand and becomes independent of surface fire intensity. While no 

definitive single CBD threshold exists, canopy bulk densities below 0.10kg.m3 are unlikely to support crown fire 

(Agee et al. 2000). 

Canopy base height (CBH) is the lowest height above the ground at which there is sufficient amount of canopy 

fuel to propagate fire vertically into the canopy (Scott and Reinhardt 2001). The lower the canopy base height the 

easier it is for a surface fire to initiate a crown fire (Van Wagner 1977). Canopy base height coupled with canopy 

bulk density allow managers to understand how likely a crown fire is to initiate and sustain itself across a stand.

Exiting conditions in the project area demonstrate canopy base height near 10 feet in pine type areas coupled with 

canopy bulk densities of 0.07kg/m3. Mixed conifer type area average a canopy base height of 4 feet and a canopy 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

88 Chapter 3. Affected Environment and Environmental Consequences

bulk density of 0.16kg/m3. Desired conditions for the Bill Williams Mountain project area would be to have 

average stand canopy base heights above 18 feet with canopy bulk densities below 0.05kg/m3 in ponderosa pine 

forest types and CBH above 10 feet with CBD of 0.08kg/m3 in dry mixed conifer types. These stand averages 

would mean that groups of trees can have higher densities if surrounded by areas of lower densities which would 

break up the continuity of canopy fuels and therefore crown fire. 

The desired conditions include a reduced potential for the project landscape to burn in a passive and/or active 

crown fire. Passive crown fire refers to fire that does not carry continuously through the crown fuels, but burns 

crown fuels intermittently, such as when individual trees or groups of trees torch. Active crown fire carries 

continuously through the canopy of trees. Current conditions show 61% of the project area has the potential to 

burn as an active crown fire and another 21% of the project area has the potential for passive crown fire.

3.3.2 Direct and Indirect Effects

3.3.2.1 FlamMap analysis results

The effect of changes in canopy openings and distribution of tree groups and clumps on potential fire behavior 

can be seen by looking at maps of potential fire type for the project area. Figure 3-30, Figure 3-31, Figure 3-32, 

Figure 3-33, and Figure 3-34 demonstrate the changes in fire behavior type and distribution based on the 

management alternative.

Alternative 1, the No Action Alternative represents current conditions for this landscape. Alternative 1 also 

demonstrates much of the project area exhibits active or passive crown fire (61% Active, 21% Passive). 

Alternative 2 shows a marked reduction in active crown fire (18%), which would indicate much less resistance to 

control and less spotting potential. It can also be seen that some areas with active crown fire are interspersed with 

surface fire types which could lead to opportunities for fire control during a wildfire. Alternative 3 exhibits a 

reduction in active crown fire, but it does not reduce crown fires south of and on the mountain. This is important 

because wind direction is primarily southwest and a fire would be lined up with the southern aspect slopes. When 

wind and slope are aligned, fire spread potential is increased. Southern aspects are typically drier (more time 

exposed to solar radiation) and therefore tend to have lower fuel moistures which directly affects combustion. 

Alternative 4 also shows a decrease in crown fire potential, but exhibits a greater area of continuous crown fire, 

especially on the slopes of Bill Williams Mountain. 
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Chapter 3. Affected Environment and Environmental Consequences 89

Figure 3-30. Map of the Bill Williams Mountain project area demonstrating the distribution of fire potential for 

Alternative 1
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

90 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-31. Map of the Bill Williams Mountain project area demonstrating the distribution of fire potential for 

Alternative 2
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Chapter 3. Affected Environment and Environmental Consequences 91

Figure 3-32. Map of the Bill Williams Mountain project area demonstrating the distribution of fire potential for 

Alternative 3
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

92 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-33. Map of the Bill Williams Mountain project area demonstrating the distribution of fire potential for 

Alternative 4
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Chapter 3. Affected Environment and Environmental Consequences 93

Table 3-7 shows an increase of passive crown fire in alternatives 2, 3 and 4 over alternative 1 because active 

crown fire changes to passive crown fire. Although in general an increase in torching behavior is perceived as 

potential fire control problems, it does represent a change from conditions conducive to active crown fire which 

has much more safety and control issues related to it.

Table 3-7. Percent of Bill Williams Area with Each Fire Type Potential, Post Treatment

Potential Fire 

Type

Alternative 1 

No Action

Alternative 2

Modified 

Proposed Action Alternative 3 Alternative 4

No Fire 1 1 1 1 

Surface Fire 17 54 42 31

Passive Crown 

Fire

21 27 30 33

Active Crown 

Fire

61 18 27 35

Surface fires typically allow direct firefighting tactics in a safe manner. It should be noted that rates of spread 

would increase over current conditions with more open canopy conditions although fire intensities and tree 

mortality would be much lower. More open canopy conditions allow for additional fine fuels to grow (grasses, 

forbs). Ecologically, this represents historic conditions but also equates to faster moving fires (rates of spread). In 

alternative 1, 15% of the area represents a rate of spread one type 3 engine crew could pick up in an hour. 

Flame lengths less than 8 feet can generally be attacked by engines and dozers, and those flame lengths less than 4 

feet by hand personal. This is another measure we can use to assess the differences between alternatives. The 

FlamMap data computed demonstrates in Table 3-8 that currently only 16% of the area is likely to burn with 

flame lengths under 8 feet during summer conditions. Alternative 2 alters the landscape to 59% while Alternative 

3 is 46% and Alternative 4 is 33%. This is a useful factor to consider in understanding the chances district 

resources may have in containing an undesirable fire at a small scale with minimal impacts to the landscape.

Table 3-8. Flame lengths under 8 feet in the project area

Flame Lengths 

under 8 feet

Acres

(% of area)

Alternative 1 2525 (16%)

Alternative 2 9114 (59%)

Alternative 3 7016 (46%)

Alternative 4 5121 (33%)

Prescribed fire control lines (referred to as strategic fuels treatments in the modified proposed action) are part of 

each of the action alternatives. Actual placement, need and specifications are to be determined once the chosen 
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94 Chapter 3. Affected Environment and Environmental Consequences

alternative is implemented as well as the need is identified. Typically, control lines are located in areas that are 

conducive to fire control naturally, or use existing manmade features such as roads. Fire modeling specific to the 

strategic fuels treatments was not done due to the fact the exact locations and specifications are not known. 

Although these features will be crucial to prescribed fire operations, it is unlikely they will change the landscape 

enough to be an effective change to the FlamMap modeling runs discussed in this report.

With alternative 2, 52% of the area is represented with that rate of spread. Alternative 3 produces 41% of the area 

and alternative 4 is 30% of the area. This is assumed equal grass crop production which could fluctuate over moist 

or dry years and produce different results. Fire management for the project area would need to take this in to 

account and aim to have fire represented over parts of the landscape on historic mean intervals to eliminate 

unnatural accumulations of fine fuels that would advance fire rates of spread to levels typical district crews could 

not quickly contain. 

The increase of fire rates of spread indicate the potential for fire to spread to areas with values at risk more 

quickly is higher. Prescribed fire or managing wildfires under low or moderate weather and fuel conditions would 

help alleviate these issues. The action alternatives would provide managers increased ability to consider these 

options. 

Wildlife attributes are an important consideration in the project area. The wildlife specialist report can be 

referenced for specific analysis and understanding of attributes other than fire type potential. Figure 3-34 breaks 

out some of the key wildlife strata within the project area and graphically illustrates potential changes per 

alternative to each feature. The MSO PAC is an area identified for protection measures in the MSO recovery plan 

and incorporated by reference in the Kaibab National Forest plan. If no treatment takes place (alternative 1), 83% 

of the PAC exhibits potential for crown fire. Also, with its location (slope), fires becoming established below it 

(downslope) are likely to adversely affect most or all of the PAC. A consideration of leaving the PAC as a dense 

forest with a heavy accumulation of fuels on the forest floor needs to be weighed against the survivability of the 

PAC as a whole if fire were to become established into it, either directly or from downslope. A trade off would 

have to be recognized in order to meet either of the above desired conditions and an understanding of the tradeoffs 

realized. 

The Arizona Bugbane Botanical Area can also be compared in Figure 3-34. The area has a population of Arizona 

bugbane (Actaea arizonica). Under alternatives 1, 3 and 4, little or no treatment would take place. With no 

treatment taking place, it can be assumed the plant would unlikely be radically altered by human disturbance. The 

future condition of the plant’s landscape cannot be determined, but its vulnerability to mass loss of current 

vegetation due to wildfire can be assumed. Current con ditions of the botanical area are dense stands of mostly 

mixed conifer forest with interlocked crowns and high fuel loadings on steep slopes, conducive to crown fires 

even under moderate fire danger conditions. These are factors directly related to loss of vegetation and soil 

erosion in many fires in the southwest. The tradeoffs to the value must be considered and weighed. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 95

Figure 3-34. Habitat stratum fire type potential

Note: Continued on next page. 

0

2000

4000

Acres

Potential Fire Type by Habitat Strata

Alternative 1 - No Action

Surface Fire

Passive Crown Fire

Active Crown Fire

0

1000

2000

3000

4000

Acres

Potential Fire Type by Habitat Strata

Alternative 2 - Modified Proposed Action

Surface Fire

Passive Crown Fire

Active Crown Fire

0

1000

2000

3000

Acres

Potential Fire Type by Habitat Strata

Alternative 3

Surface Fire

Passive Crown Fire

Active Crown Fire
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

96 Chapter 3. Affected Environment and Environmental Consequences

0

2000

4000

Acres

Potential Fire Type by Habitat Strata 

Alternative 4 

Surface Fire

Passive Crown Fire

Active Crown Fire

3.3.2.2 FVS/FFE Results

The Fire and Fuels Extension (FFE) to the Forest Vegetation Simulator (FVS) links models of fire behavior, fire 

effects, fuels loading and snag dynamics to tree growth metrics (Reinhardt and Crookston 2003). In this analysis 

basic outputs for Surface Fuel Loading, Crown Base Height and Crown Bulk Density were recorded using default 

parameters from the Central Rockies variant to FVS. Data used in FVS and FFE were from field sampled stand 

exams conducted in the Bill Williams Mountain area. Some outputs are divided into Severe and Moderate burning 

conditions which are defined by fuel moisture scenarios as follows for the Central Rockies variant.

All results from FFE are stand averages (but weighted by acres*) and therefore can give a general idea of what 

stand conditions look like but cannot address the spatial distribution of specific metrics. The desired conditions 

are for stand averages and therefore allow for some areas within a stand to be outside of the desired condition 

range but be surrounded with conditions closer to overall desired conditions. For example Crown Bulk Density is 

desirable below .08kg/m3 as an average over a mixed conifer stand. This could mean that many patches within 

the stand have much higher CBD but have interspaces between these dense clumps of trees where CBD is much 

lower than .08 and therefore the average for the stand is within acceptable limits. Where CBD is high, it is 

important to also have higher CBH (crown base height). Surface fuel loading is managed with fire and felling 

techniques to increase or decrease woody debris in different size classes.

Pinyon and juniper woodlands account for less than 10% of the project area. These areas were analyzed with 

FVS/FFE and recorded here to assist the wildlife biologists with their habitat analysis on the Forest’s 

Management Indicator Species.

It is important to consider the model assumptions over time and space as well as the scenarios when looking at the 

outputs in Table 3-9. The numbers represent modeling predictions that can be used as a comparison after different 

treatments (since the only differences are the treatments by alternative). The table numbers are shown at a 

common year once all the proposed treatments have been implemented (silvicultural thinning, pile burns and 

broadcast burns). They are used as a tool for potential effects comparisons. More discussion of this table and the 

results outputted by FVS/FFE can be found in Appendix D of the fire and fuels specialist report.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 97

Table 3-9. Fire and fuels extension to the FVS post treatment results by alternative

FVS/FFE Calculation Results Post Treatment

Forest 

Type Criteria

Desired 

Condition

Alternative 

1 

Alternative 

2 

Alternative 

3 

Alternative 

4 

Dry Mixed Conifer

Canopy Base 

Height (feet)

>10 4 12 20 10

Canopy Bulk 

Density (kg/m3)

<.08 0.15 0.06 0.05 0.07

Surface Fuel 

Loading (tons/acre)

<15 30 16 15 19

Ponderosa Pine

/Pine-Oak

Canopy Base 

Height (feet)

>18 10 22 22 21

Canopy Bulk 

Density (kg/m3)

<0.05 0.07 0.03 0.03 0.03

Surface Fuel 

Loading (tons/acre)

<10 19 8 8 8 

Pinyon-Juniper 

Woodlands

Canopy Base 

Height (feet)

>10 14 15 15 15

Canopy Bulk 

Density (kg/m3)

<.05 0.04 0.01 0.01 0.01

Surface Fuel 

Loading (tons/acre)

<6 8 3 3 3 

Note: Pinyon and juniper woodlands account for less than 10% of the project area. These areas were analyzed with FVS/FFE and recorded 

here to assist the wildlife biologists with their habitat analysis on the Forest’s Management Indicator Species. The numbers in this able were 

weighted by acre rather than stand to better represent actual data. For example, 1 stand could be 10 acres and another 100 acres. The 

average of the 2 stands is 50 acres. That doesn’t represent the landscape as well as weighting the 100 acre stand as more (as it is physically 

on the landscape).

3.3.2.3 FRCC Results

The Bill Williams Mountain project area exhibits three distinct vegetation types in relation to FRCC; ponderosa 

pine vegetation (including pine-oak types), dry mixed conifer vegetation and juniper woodlands (including pinyon 

pine intermix). Ponderosa pine type ecosystems are composed primarily of ponderosa pine, oak, and juniper 

depending on the stands development. Mixed conifer stands are composed of ponderosa pine, Douglas fir, white 

fir and aspen, with Douglas fir dominating in late stages of succession. Pinyon-Juniper vegetation consists of 

populations of pinyon pine and juniper with open, grassy areas intermixed. 

According to the Western United States Biophysical Settings Key (Comer et al. 2003), ponderosa pine and dry 

mixed conifer forests in the southwest have a dominant fire regime I and a mean fire interval of 2 to 10 years in 

Ponderosa pine and 5 to 25 years in dry mixed conifer. A fire regime I has a frequent fire interval with low to 

mixed severity. Fires typically maintained open areas and replaced or opened up areas that exhibited a more 

closed canopy. With the absence of fire both the Ponderosa pine and the mixed conifer stands have accumulated 

unnatural amounts of fuel primarily in the form of dense trees that would cause a natural fire to exhibit more 

extreme fire behavior. Both the Ponderosa pine and the mixed conifer have missed multiple natural mean fire 

intervals. With the combination of missed burn intervals, the encroachment of mixed conifer, and the 

accumulation of surface fuels, these areas are currently best represented as a condition class 3.

Under a no action alternative these areas would remain as a condition class 3 over time and could be expected to 

burn with uncharacteristic fire severity. The pinyon-juniper woodlands are identified with longer return intervals 

of mixed severity. These areas are experiencing loss of grasses, shrubs and pinyon pine due to drought tolerant 

juniper trees encroaching and establishing. 

In these vegetation types defined by Comer et al. (2003) the ability to create canopy openings, redistribute 

dominance to fire resistant tree species and allow for diversity in age classes are essential in moving stands 

towards a naturally functioning fire regime and therefore FRCC 1. Furthermore, forests in a fire regime I are 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

98 Chapter 3. Affected Environment and Environmental Consequences

maintained in that state by understory vegetation. Much of the forest structure was open canopy which resulted in 

healthy and vigorous understory plants that served as fuel to carry surface fire through these stands. Stands in 

FRCC 1 would demonstrate little potential for active crown fire and would experience relatively little overstory 

mortality post wildfire.

Areas where some canopy openings can be created and some sunlight can penetrate and invigorate understory 

forbs and grasses would have decreased threat of crown fire and would have a re-established understory that could 

support surface fire. If these areas do not contain a well balanced mix of strata with reproducing fire resilient 

species they are still considered departed, but not as departed as stands with closed canopy. These areas are 

classified as FRCC 2.

Continuous areas in an even aged condition with closed canopy are considered very departed from historical 

conditions. These areas would not be able to support understory vegetation and have potential for continuous 

crown fire. Using data from the silviculture report and looking at FFE and FVS stand data outputs it was 

determined that the action alternatives would all alter the current condition class of the project area.

Within the dominant vegetation categories shown in Table 3-10, there are distinct habitat features with specific 

attributes linked to them. Within the design of the project, some of these features’ desired conditions or 

restrictions by alternative may not meet historic fire regime characteristics. High density requirements (including 

Mexican Spotted Owl PAC and recovery habitat as well as Northern Goshawk post-fledgling family areas and 

nest stands) in these areas would decrease the ability to reduce canopy fuel continuity or for understory vegetation 

to respond to treatment. This habitat would be subject to diameter limits or basal area requirements which would 

constrict the ability to open canopy gaps and remove much of the uncharacteristic species as well as meet historic 

fire regime characteristics. This limits the potential to move the area to a FRCC 1.

Some areas have fire intolerant tree species that have encroached into the understory of the stands and are larger 

than potential diameter parameters. These areas would remain in or continue towards FRCC 3. Allowing for 

smaller diameter fire intolerant species to be removed and have small effects on canopy fuel discontinuity would 

move to a FRCC 2. No removal would meet and stay at FRCC 3 and be unsustainable over time. This section of 

the report is designed specifically towards comparisons to fire regime condition class and not to the potential 

desired habitat condition. Management implication in not returning those areas to historic conditions is discussed 

in section 2.4.7 (Summary Comparison of Alternatives). Table 3-9 displays the resulting approximate percentage 

of area in each fire regime condition class one year post treatment.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 99

Table 3-10. Percent area in each FRCC by alternative post treatment

Approximate Percent of Area by Fire Regime Condition Class

Dominant 

Vegetation 

Type FRCC

Desired 

Condition

Alternative 

1 No Action

Alternative 

2 Modified

Proposed 

Action

Alternative 

3 Alternative 4

Dry Mixed 

Conifer

FRCC 1 100 0 40 20 10

FRCC 2 10 20 15 15

FRCC 3 90 40 65 75

Ponderosa -

Pine - Oak

FRCC 1 100 0 80 53 53

FRCC 2 0 20 10 10

FRCC 3 100 0 37 37

Pinyon -

Juniper

FRCC 1 100 0 50 46 46

FRCC 2 100 50 54 54

FRCC 3 0 0 0 0 

Private or 

NonVegetated 

FRCC 1 FRCC not analyzed

FRCC 2

FRCC 3

The pie charts following demonstrate changes in FRCC distribution for the entire Bill Williams Mountain Project 

area for each alternative one year post completion of treatments. Alternative 1 (No Action) would maintain the 

area to 89% significantly altered from their historical range. It is likely that this percentage would continue to 

grow and likely be 100% in condition class 3 within 20 years. Alternative 2 restores 68% of the landscape to 

historic states and leaves only 10% of the area in danger of vegetative condition conversion or potential extreme 

change due to wildfire characteristics. Alternative 3 restores 45% of the area back to historic referenced 

conditions, but leaves 42% of the area still in condition class 3. Alternative 4 meets the desired condition the least 

of the action alternatives by moving 42% back to condition class 1 and 45% continuing in condition class 3. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

100 Chapter 3. Affected Environment and Environmental Consequences

FRCC 1

100%

FRCC 2

0%

FRCC 3

0%

FRCC Desired 

Condition

FRCC 1

0%

FRCC 2

11%

FRCC 3

89%

FRCC Alternative 1

Post Treatment

FRCC 1

68%

FRCC 2

22%

FRCC 3

10%

FRCC Alternative 2 

Post Treatment

FRCC 1

45% FRCC 2

13%

FRCC 3

42%

FRCC Alternative 3 

Post Treatment

FRCC 1

42%

FRCC 2

13%

FRCC 3

45%

FRCC Alternative 4 

Post Treatment

Figure 3-35. Percent FRCC for each alternative
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 101

3.3.3 Fire and Fuels Cumulative Effects

Vegetation treatments and lack of treatments, on the Williams Ranger District have contributed to the current 

vegetation conditions for the project area. Over the past 25 years, management surrounding the Bill Williams 

Mountain Project area has included prescribed burning, pile burning, mechanical thinning and various harvests as 

well as grazing and wildlife focused projects. Within the Kaibab National Forest boundary, four projects that are 

adjacent or in close proximity to the Bill Williams Mountain project area were considered for cumulative effects. 

These include: the City Project area (within the north and east part of Bill Williams Mountain project continuing 

north of Bill Williams Mountain); the Twin project (on the south and west sides of the Bill Williams Mountain 

project area); the Dogtown project area 2 miles east of the Bill Williams Mountain project area; and the 

McCracken project area directly south of the Bill Williams project area. All four of these areas are being treated 

for wildland urban interface protection from wildfire. 

These four projects include mechanical thinning and prescribed burning in phases over the next several years. The 

combined effect of these ongoing projects and foreseeable projects like 4FRI on the Williams Ranger District for 

restoration and fuel reduction provide for a mosaic of stand conditions, reducing the potential for high intensity 

stand-replacing wildfire, watershed projection, and allowing for wildlife habitat and vegetative diversity. This 

same mosaic would allow for a diversity of fire effects thereby increasing opportunities for the maintenance of 

forest structure and function using wildfire and prescribed fire in the long term future. 

All the action alternatives proposed in the Bill Williams Mountain Restoration Project area would continue to 

create a mosaic of fuel conditions on the Williams Ranger District and therefore be taking a step in protection of 

communities and important features of the forest. Each of these projects is managed to monitor and evaluate 

cumulative effects and considered prior to site specific implementation. Alternative 1 would not be consistent with 

the recent work of reducing fire severity potential in the wildland urban interface.

Maintenance burning for up to 40 years would allow fire mangers to maintain desired conditions. The ability to 

use naturally occurring wildfire at historic intervals to maintain desired conditions would likely be used in the 

future management of this project area. The cumulative effects of this type of management would greatly 

decrease future impacts to the surrounding area by maintaining fuels and vegetation in a natural state, decreasing 

smoke production from heavy amounts of accumulated fuels as well as reducing the need for future large scale 

mechanical treatments.

3.4 Air Resources 

The project area is heavily used as a recreation area for many people. This area represents clear and clean air for 

many visitors and is important to the continued health of surrounding communities both economically and 

physically. Smoke, in general, is a nuisance and can be adverse to health, but is also part of the natural 

disturbance associated with these types of ecosystems. Two criterion pollutants, carbon monoxide and particulate 

matter, are produced in wood smoke and are regulated by the Clean Air Act. The Arizona State Smoke 

Management Rule implements the Clean Air Act and contains regulations that all State and Federal natural 

resource agencies must follow before a prescribed burn is ignited.

Both prescribed fire and wildfire would create smoke, however the amount and timing of these smoke events can 

be mitigated with prescribed fire. Any prescribed burning would be conducted only with approved site specific 

burn plans with standard smoke management mitigation and approvals. Burning would be conducted in favorable 

atmospheric conditions so as to minimize effects from smoke to nearby communities, class 1 airsheds and 

recreationists. All burning would be conducted according to the Arizona State Smoke Management rule to 

mitigate smoke impacts. These regulations ensure that effects from all burning within the area are mitigated and 

that Clean Air Act requirements are met. The scenarios used in the FOFEM analysis of smoke impacts can be 

used as a benchmark of the types of conditions and fuel loading burns should be conducted in. In general, days 

with good transport winds and ventilation categories are ideal to burn on. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

102 Chapter 3. Affected Environment and Environmental Consequences

The City of Williams would have the most smoke impacts due to the proximity to the project area and that it lies 

in line with prevailing winds, therefore measures to mitigate long durations of smoke should be implemented. 

Prescribed fires are initiated under conditions that allow managers control and favorable effects. Prescribed fires 

would be conducted when conditions are such that overstory tree mortality will be low, which leaves much of the 

live-tree carbon pool intact. This results in less biomass being combusted than if the area were to burn under 

higher severity wildfire, therefore less carbon emissions are expected in controlled situations (Wiedinmyer and 

Hurteau 2010). 

Smoke impacts from wildfires are less easily mitigated. Wildfires primarily occur during summer months when 

the Williams Ranger District is most used by recreationists and therefore would most likely have more of an 

impact on recreation values. The amount of biomass consumed during a wildfire is also not easily mitigated. The 

more biomass consumed by fire, the more smoke would be produced. When comparing alternatives, all action 

alternatives propose prescribed burning which would have an impact on surrounding communities, but in a 

manageable manner. The outcome of these alternatives would also reduce the amount of biomass available to fire 

during wildfire which would reduce the impact of smoke from such a wildfire. Alternative 1 does not propose 

any prescribed burning; however, it would continue to maintain large amounts of biomass available for 

consumption in the event of a wildfire which would have direct and most likely unmanageable impacts on 

recreation and surrounding communities. 

Prescribed fire is regulated through a permitting process with the Arizona Department of Environmental Quality, 

which considers the overall effect and timing of such activities within each airshed. Following the permitting 

process would ensure that this project does not create regionally significant adverse effects on air quality.

3.4.1 First Order Fire Effects Model Results - Air Resources

The Arizona Department of Environmental Quality closely monitors, coordinates, and regulates prescribed 

burning to ensure emissions do not exceed federal and state ambient air quality standards. Pursuant to Arizona 

Revised Statute 18-2-15, federal and state land managers must submit an ADEQ Burn Plan, smoke dispersion 

map, and smoke modeling for all burn projects. Daily burn requests must be submitted and approved prior to any 

prescribed burning. The Bill Williams Mountain Project area lies within the Verde River Airshed. The area 

contains several smoke sensitive receptors including the City of Williams, Sycamore Canyon and the Verde 

Valley. Particulate matter 2.5 estimates were modeled with First Order Fire Effects Model (FOFEM) version 

5.21. The software default settings were used for equitable comparisons. Each of the four alternatives was run 

using the two main vegetative types and their corresponding acreages (ponderosa pine types and mixed conifer).

There were some assumptions made with the modeling. Under prescribed burning conditions in alternatives 2, 3 

and 4, the project would be burned in blocks. An estimate of 1,000 acres in the ponderosa pine type and 500 acres 

in the mixed conifer was used. Under the no action alternative (Alternative 1), no prescribed burning would take 

place. However, if a wildfire started in typical summer conditions, heavy resistance to control would be likely. It 

is conceivable the entire area could burn in a couple days. Prescribed fire would likely take multiple years to be 

implemented across the entire project area.

The comparison in Figure 3-35 is for the total acres that would be burned within a week. It needs to be noted that 

the amount of smoke 1,000 acres of prescribed fire produces is considerably less than 15,200 acres of wildfire 

smoke in the same short time period. Maintenance burning over a 40 year period would create less smoke than the 

initial prescribed burns due to less surface fuel and fewer crowns consumed. 

Wildfire estimates for the action alternatives in the figure estimated a wildfire post treatment without an historic 

fire return interval (maintenance burns). Alternative 3 and Alternative 4 allow for minimal cutting on steep 

slopes. Without the reduction of fuels via mechanical treatment, it is likely more of the tree crowns would burn 

due to increased ladder fuels (vertical propagation) as well as tighter and denser tree canopies. A canopy 

consumption estimate of 10% was used for alternative 2, 15% for alternative 3 and 35% for alternative 4 was used 

to illustrate this.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 103

In addition to the amount of raw material released into the atmosphere, ventilation, unit size, wind speed and 

direction, and proximity also affect smoke impacts. Ventilation is the degree to which smoke disperses into the 

atmosphere. Proximity is the distance from the source of smoke to the impacted area (generally residences). 

Ventilation would be improved during prescribed fire operations because ignition is usually limited to the best 

ventilation hours of the day. Conversely, wildfires burn during all hours of the day, including evenings and 

mornings compounding smoke impacts. In addition, the burn day would be selected when wind speed and 

direction would minimize smoke impact. Smoke impacts from prescribed burns would be further reduced by 

burning on days with good ventilation and safe appropriate winds. 

Alternative 1

Alternative 2

Alternative 3

Alternative 4

0 571500 1039500

1047000

12993900

3500100

8004500

12673500

Particulate Matter 2.5 production by Alternative

Prescribed Fire PM 2.5 Wildfire PM2.5

Figure 3-36. Particulate Matter 2.5 in pounds per acre of emissions for Prescribed Fire and Wildfire by alternative

3.4.2 Air Resources Cumulative Effects

The cumulative effects analysis area for air resources includes much of northern Arizona, includes current 

burning, and extends into the future for forty years. The project area itself lies within the Verde Valley Airshed, 

which covers much of the Williams Ranger District of the Kaibab National Forest, part of the Prescott National 

Forest, the west half of Coconino National Forest, as well as tribal, state, and private lands west of the Kaibab 

(see Figure 3-36).

The cumulative analysis of air resources is unique in that impacts are transient, and past impacts to air quality are 

usually not evident. On any given day, however, the cumulative impact of the smoke from a prescribed burn, 

combined with impacts from other prescribed burns, wildfires, residential wood combustion, traffic exhaust, 

fugitive road dust, and other sources of pollution can be substantial. In 1999, for example, over 200,000 acres in 

Arizona were treated with prescribed fire, producing about 35,000 tons of PM-10 emissions. At certain times of 

the year, especially in the fall, consideration of the cumulative impact is critical, as weather and fuel conditions 

are most conducive to prescribed burning, and multiple federal and state land management agencies are trying to 

meet their annual burning targets. Therefore, each project is managed to monitor and evaluate cumulative effects 

and considered prior to site specific implementation so as not to exceed air quality standards. Cumulative effects 

can be variable depending on other burning activities not managed by the Forest Service. These effects could 

include smoke sinking into the Verde Valley, impacting visibility of recreation areas, or overall air quality due to 

increased particulates, and weather conditions at the time the prescribed burns are implemented. Cumulatively 

there may be also reduced smoke effects from large stand replacing wildfires because the project area would have 

a reduced active crown fire.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

104 Chapter 3. Affected Environment and Environmental Consequences

3.4.3 Summary Comparison of Alternatives

All the action alternatives move the project area toward desired conditions. Alternative 1 continues the regression 

of the ecosystem toward more unsustainable characteristics. Canopies would continue to close and provide more 

continuous fuel across the landscape, increasing the potential for high severity crown fires. This can be concluded 

when comparing the amount of passive and active crown fire potential in Alternative 1 compared to Alternatives 

2, 3 and 4. Alternative 1 would maintain 82% of the area with potential for high severity fire effects, while 

Alternatives 2, 3 and 4 reduce this potential to 45%, 57%, and 68% respectively. 

The canopy fuel accumulation has negative effects on understory vegetation and would continue to suppress the 

production of forbs, grasses and shrubs. Over time it can be expected that most of the forest would have little to 

no understory due to sunlight not penetrating the canopy. The combination of abundant and continuous canopy 

fuels, the lack of understory vegetation and high severity fire potential maintains the area in a Fire Regime 

Condition Class of 3 into the foreseeable future. Alternatives 2, 3 and 4 begin to restore the area toward the 

desired condition of Fire Regime Condition Class 1. The fire and fuels analyses demonstrate that all action 

alternatives are preferable to the no action alternative; therefore, consideration of each action alternative should be 

weighed carefully. 

Figure 3-37. Arizona Smoke Management Map
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 105

When comparing the three action alternatives being proposed, a major difference in proposals on steep slopes 

becomes the ability to cut larger trees versus being limited to only cutting trees less than 9” in diameter or not 

cutting at all. From the silviculture analysis, the ability to cut trees greater than 9” dbh increases the ability to 

create openings. Alternative 3 is expected to create less than 10% opening on steep slopes. Alternative 4 is 

expected to create 0% openings while Alternative 2 would create 30%-40% openings. Several factors are 

important to consider when looking at management of the Bill Williams Mountain Restoration Project area and 

canopy openings. The following are just a few forest ecosystem components of importance in the analysis for the 

project; canopy continuity, understory vegetation and fire behavior. In general canopy openings have been greatly 

reduced during the 1900s by post settlement trees (Moore and Huffman 2004). 

Canopy openings provide for wildlife habitat, understory diversity (Kerns et al. 2003, Moore et al. 1999) and 

discontinuous canopy fuels, which in turn affect fire behavior. In this sense all three of these ecosystem 

components are interconnected. The ability to create canopy opening becomes very important to restoring the 

function and resiliency of the ecosystem. Having tree removal restrictions limits capabilities to create these 

openings. In looking at the FlamMap analysis results, the major difference between Alternative 2 compared to 1, 

3 and 4 is the amount of crown fire. Alternative 4 exhibits more areas with potential crown fire due to the 

inability to affect canopy fuels without removing more trees. 

The lack of reduction of canopy spacing is illustrated with the FlamMap runs. This would in turn affect how the 

area can be managed when faced with natural occurring wildfires. Wildfires that exhibit torching (passive crown 

fire) are more likely to produce lofted embers to start more fires, and generally burn hotter than a fire burning 

only surface fuels. These types of fires would cause higher severity and more ecosystem damage. 

Canopy openings and discontinuous canopy fuels also are an integral part of how well ecosystems that exhibit 

frequent low severity fire can be restored to a Fire Regime Conditions Class of 1. Each action alternative moves 

the Bill Williams Mountain ecosystem away from 100% of the area in FRCC 3. However, Alternative 2 restores 

and may maintain 68% of the area in FRCC 1 compared to 45% in Alternative 3 and 42% in Alternative 4. 

Furthermore, of the 13% of the area under Alternative 3 and 4 that is restored to FRCC 2 immediately post 

treatment, it is foreseeable some of it would regress back to FRCC 3 over 20 years as canopy cover closes. This 

difference over 20 years is a function of the ability to create canopy openings that are large enough and frequent 

enough to be maintained in an open state after 20 years of tree growth. Maintenance over a 40 year period will 

also sustain the desired conditions.

When looking at a smaller scale of the project, Bill Williams Mountain retains potential of damage from severe 

wildfires with each alternative. Alternative 2 restores approximately 40% of the mountain. This is greatly reduced 

in Alternatives 3 and 4 (20% and 10% respectively). The inability of alternatives 3 and 4 to allow for sufficient 

canopy openings would affect the ability to move or retain FRCC 1 in the future. Leaving vast areas in FRCC 2 

and 3 would add difficulties both in safety and meeting objectives for managers treating with prescribed fire as 

well as opportunities to manage wildfires to meet resource objectives and perform their natural role in the 

ecosystem.

In alternatives 3 and 4 prescribed fire would not be implemented in the Arizona Bugbane Botanical area. This 

could have direct effects to larger areas not receiving prescribed fire due to terrain and features not conducive to 

keeping fire from spreading into the Arizona Bugbane Botanical Area. Every acre in the project not treated is 

another opportunity for forest health degradation and increased risk for uncharacteristic, undesirable fire behavior. 

Even where areas are treated, fires from untreated areas gaining intensity and exhibiting extreme behavior can 

move into them and have more severe fire effects than a fire starting in the treated stand. Without removal of 

canopy density and reducing surface fuel loadings, the botanical area and adjacent slopes continue to have high 

potential for extreme fire behavior.

Alternative 4 would not allow thinning on the steep slopes of Bill Williams Mountain. This would limit the ability 

to reduce canopy density and create openings that would alter fire behavior and potentially transition a crown fire 

back to the surface. Prescribed burning on the mountain would be very difficult without the reduction of smaller 

diameter trees and the breakup of interlocked crowns. Tree mortality would be more likely without mechanical 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

106 Chapter 3. Affected Environment and Environmental Consequences

treatment and removal of slash, leaving the area in a state as likely, if not more likely, for potential extreme fire 

behavior and landscape dilapidation. 

Alternatives 2, 3 and 4 would increase surface fine fuels in the form of understory vegetation (grasses and forbs) 

due to canopy openings. Much of the species diversity in ponderosa pine forests is contained in understory 

vegetation (Moore et al. 1999). Understory vegetation can be >10 times higher in restored openings than under 

even sparse ponderosa pine cover (Clary 1975). This understory vegetation is important in supporting fire spread 

similar to that under which southwestern forests have evolved. This carrier of fire is needed in order to maintain 

forests over time with fire. Surface vegetation would also affect fire behavior. More fine surface fuels would 

increase surface fire rates of spread.

Reducing stand density can increase surface fire behavior. “Modifying canopy fuels as prescribed in this method 

may lead to increased surface fire intensity and spread rate under the same environmental conditions, even if 

surface fuels are the same before and after canopy treatment. Reducing CBD to preclude crown fire leads to 

increases in the wind adjustment factor (the proportion of 20-ft wind speed that reaches midflame height). Also, a 

more open canopy may lead to lower fine dead fuel moisture content. These factors increase surface fire intensity 

and spread rate. Therefore, canopy fuel treatments reduce the potential for crown fire at the expense of slightly 

increased surface fire spread rate and intensity. However, critical levels of fire behavior (limit of manual or 

mechanical control) are less likely to be reached in stands treated to withstand crown fires, as all crown fires are 

uncontrollable. Though surface intensity may be increased after treatment, a fire that remains on the surface 

beneath a timber stand is generally controllable.” (Scott 2003). 

Alternatives 3 and 4 would increase the difficulty to protect trees (compared to alternative 2), including the largest 

and oldest trees as identified as a guideline in the Kaibab National Forest Plan. Areas with heavier ladder fuels, 

greater tree densities and canopy characteristics are more likely to increase fire behavior during prescribed fire 

operations. Mortality could drastically increase, putting the trees desired at higher risk. Smaller trees may receive 

fire caused mortality as well. Initially, the crowns of these trees dry out and become a fully cured fine diameter 

fuel. This increases the potential for vulnerability of consumption (highly flammable) and initiating fire in the 

canopy during a wildfire. After a couple years of aging, the needles fall and increase the surface fuel loading. 

Several years later, the trees fall and once again increase the surface fuel loading. These conditions do not go 

towards the desired condition and increases the potential for fire caused mortality to all existing vegetation, 

including the >24” trees, if a wildfire were to enter the area. Alternative 1 does not have the chance of fire caused 

mortality by prescribed fire, but could reasonably encounter high levels of mortality in the event of a wildfire. 

Alternative 1 leaves fire managers with little opportunity of multiple management strategies other than full 

suppression if a wildfire were to establish in the project area or enter the project area. Safety would preclude the 

chances of fighting the fire from the head, ultimately limiting success of containing the fire spread quickly. 

Wildfires would unlikely be able to be managed for any objectives other than suppression, adding cost vs. benefit 

deficit. Alternatives 3 and 4 would have increased difficulty meeting objectives for prescribed burning than 

alternative 2, especially on the slopes of Bill Williams Mountain.

The FVS/FFE stats reflect numbers relating to the increased mortality potential of prescribed fires. Without 

reducing ladder fuels, the fire has an increased opportunity to rise vertically into the tree canopy. There, dense 

canopies transfer heat easier and passive or active crown fire may initiate, creating greater tree mortality. These 

trees eventually fall and become increased surface loading. Over time, the increased surface loading along with 

the residual trees reproducing (adding ladder fuels again) sets the stand dynamics back to increase fire behavior 

and tree mortality. At any of these stages, high mortality or intense burning of surface fuels could cause soil 

erosion, flash flooding to downslope residences, degradation of the City of Williams watershed and sediment fill 

up to water sources used by area wildlife and cattle. 

Part of the project area includes Mexican spotted owl habitat which is managed in accordance with the MSO 

Recovery Plan. The guidelines for threatened species requires that project activities occurring within federally 

listed species habitat should integrate habitat management objectives and species protection measures from 

approved recovery plans. The desired condition for areas within the project area, including the protected activity 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 107

center (PAC) is for multiple age classes of trees and to maintain species diversity. Some of these areas would 

remain as FRCC 3 or move to FRCC 2 in situations where some canopy can be affected without losing the desired 

BA. Some habitat can be restored to a FRCC of 1 where the species composition, structure and function of these 

stands would be in concert with a surface fire regime.

Alternatives 3 and 4 further restrict the ability to open canopy gaps, therefore in areas in the PAC, alternative 3 

and 4 would not move towards the desired condition of FRCC 1. Areas with trees of fire intolerant species that 

have encroached the understory of the stands and are larger than identified cutting parameters would remain as 

FRCC 3, while those where some smaller diameter fire intolerant species could be removed and have small effects 

on canopy fuel discontinuity would move to an FRCC 2. MSO also requires course woody debris as a desirable 

attribute. None of the action alternatives eliminate all course woody debris. A stand replacement type fire could 

potentially have this effect. Alternative 1 would be the most likely to experience this type of fire behavior.

Alternative 2 moves the analysis area the most towards a forest structure that is more likely to allow the desired 

conditions for the analysis area to be maintained with future fires for up to 40 years. Maintaining desired 

conditions with fire is less expensive than maintaining those conditions with mechanical treatment methods. 

Particle Matter 2.5 (produced in smoke) from prescribed fires would be inevitable. Alternative 2 allows for the 

removal of more secondary layer canopy than alternatives 3 or 4 and therefore produces less consumption 

produced emissions in smoke. This is due to a large percentage of the fire being surface fire. Alternative 3 limits 

tree removal to 9” dbh in MSO PAC and MSO mixed conifer recovery nest roost habitat. This would likely 

increase the amount of crowns that would be consumed during burning operations. Alternative 4 would likely 

have the highest amount of additional emissions from crowns burning of the 3 action alternatives. 

Table 3-11 shows the relative rating by alternative for quick comparison of how each alternative meets the desired 

condition. A point value of 1 was assigned to the alternative that most closely met the purpose and need for each 

element. The other alternatives were given a value of 0. If alternatives had equal values in meeting the purpose 

and need, they were both assigned a 1 value. Alternative 2 is the alternative that most closely meets the desired 

condition. 

In conclusion, the project area would benefit from each of the action alternatives from a potential fire severity 

perspective. The overall ecosystem health in the form of restoring the vegetation types to resilient and historic 

conditions would also benefit from all action alternatives although Alternative 2 provides the most opportunity to 

meet desired conditions.

Table 3-11. Relative ranking for each alternative

Criteria Alternative 1 Alternative 2 Alternative 3 Alternative 4

Canopy Base Height in mixed conifer 0 1 1 1 

Canopy Bulk Density in mixed conifer 0 0 1 0 

Surface Fuel Loading in mixed conifer 0 1 1 0 

Canopy Base Height in ponderosa 

pine

0 0 1 0 

Canopy Bulk Density in ponderosa 

pine

0 1 1 1 

Surface Fuel Loading in ponderosa 

pine

0 0 1 0 

Surface Fire percentage 0 1 0 0 

FRCC 1 in mixed conifer 0 1 0 0 

FRCC 1 in ponderosa pine 0 1 0 0 

PM2.5 emissions 0 1 0 0 

Flame Lengths under 8’ 0 1 0 0 

TOTAL 0 8 6 2
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

108 Chapter 3. Affected Environment and Environmental Consequences

3.5 Soils and Watershed 

3.5.1 Affected Environment

3.5.1.1 Soils

Elevations within the project area range from 6,460 to 9,256 feet. Slopes range from 5 to 120 percent with steeper 

slopes generally occurring at higher elevations on Bill Williams Mountain, Bixler Mountain and on hillsides of 

less prominent knolls within the project area. Figure 3-38 displays the locations of TES map units and their 

current condition. Table 3-12 provides a summary of the taxonomic classifications of TES map units in the 

project area and their associated acreages.

There are total of 15,200 acres of TES map units within the project boundary. Of these, approximately 13,662 

acres are in satisfactory condition. These soils are functioning properly with regard to soil stability, hydrologic 

regimes and nutrient cycles. There are 1,538 acres of TES map units, or approximately 10 percent, that are in 

unsatisfactory condition. Currently, TES map units 320, 402, 407, 525, 539, and 564 within the project area are in 

unsatisfactory condition due to erosion rates that are exceeding tolerance thresholds. 

Within the project area, there are approximately 8,064 acres of soils having slight erosion hazard, about 3,212 

acres of soils having moderate erosion hazard, and about 3,932 acres of soils having severe erosion hazard (Table 

3-13, and Figure 3-39). Technical definitions of erosion hazard ratings can be found in the Soils and Watershed 

Specialist’s Report (MacDonald 2012). Acres presented in Table 3-13 are for each map unit as a whole. There can 

be, and often are inclusions of different soil types within each TES map unit. Soils having single taxonomic 

classifications rarely, if ever, are mapped without including some areas of soils having other taxonomic 

classifications. As a result, most soils map units are comprised of the primary soil for which the unit is categorized 

and some soils that belong to other taxa. These latter soils are called inclusions or included soils.

Typically inclusions have properties and behavioral characteristics that are similar to those of the dominant soil or 

soils in the map unit, and therefore do not affect use and management. These are referred to as noncontrasting 

inclusions. They may or may not be noted in the map unit descriptions. Other inclusions may have properties and 

behavioral characteristics that deviate enough to influence use or management. These are referred to as 

contrasting inclusions. They generally occupy small areas and are inseparable on the soil maps due to the scale at 

which soils are mapped. The inclusions of contrasting soils are typically discussed in map unit descriptions. 

Sometimes inclusions are not mapped as they were not observed in the field. This typically occurs where soil 

patterns are so complex as to preclude a sufficient number of observations to identify all of the soils that occur 

within a given landscape. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 109

Figure 3-38. Terrestrial Ecosystem Units within the Bill Williams Mountain Restoration Project Analysis Area
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

110 Chapter 3. Affected Environment and Environmental Consequences

Table 3-12. Terrestrial Ecosystem Units within the Project Area

Map Unit 

Symbol

Soil Taxonomic 

Classification Soil Phase Acres

006 Pachic Argiborolls Deep clay loam 137

010 Typic Argiborolls Deep loam 262

20 Vertic Haplaquolls Deep clay 144

036 Pachic Argiustolls Deep gravelly clay loam 14

037 Aquic Haploborolls Deep gravelly very fine sandy loam 44

300 Udic Ustochrepts Very gravelly sandy loam 179

302 Typic Dystrochrepts Very gravelly sandy loam 88

304 Typic Eutroboralfs Moderately deep very gravelly loam 248

310 Typic Eutroboralfs Moderately deep very cobbly clay loam 2,008

320 Lithic Ustorthents Very gravelly sandy loam 328

322 Typic Dystrochrepts Moderately deep very gravelly sandy loam 1879

324 Typic Eutroboralfs Very gravelly loam 5,206

325 Udic Ustochrepts Deep gravelly loam 24

401 Mollic Eutroboralfs Gravelly clay loam 464

402 Mollic Eutroboralfs Moderately deep very cindery loam 327

405 Mollic Eutroboralfs Very gravelly clay loam 25

407 Typic Vitrandepts Moderately deep very cindery loam 114

507 Vertic Argiborolls Deep very gravelly clay loam 212

518 Lithic Argiborolls Very cobbly clay loam 463

519 Lithic Eutroboralfs Very cobbly clay loam 874

525 Typic Argiborolls Moderately deep very cobbly loam 118

537 Mollic Eutroboralfs Moderately deep very cobbly clay loam 1,177

539 Typic Argiborolls Moderately deep very cobbly loam 52

563 Mollic Eutroboralfs Moderately deep very cobbly clay loam 130

564 Typic Argiborolls Moderately deep very cobbly clay loam 599

565 Lithic Argiborolls Very cobbly clay loam 80

658 Eutric Glossoboralfs Cobbly loam 416

659 Eutric Glossoboralfs Cobbly loam 909

660 Typic Eutrochrepts Moderately deep very stony fine sandy loam 1,124

N/A Open water/wetland 17

Total 17,662
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 111

Table 3-13. Predicted Soil Erosion Hazard by TEU within the project area

Map 

Unit

Soil 

Condition

Erosion 

Hazard

Current 

Erosion 

Rate

Tons/Ac/Yr

Tolerance 

Erosion 

Rate

Tons/Ac/Yr

Potential 

Erosion 

Rate

Tons/Ac/Yr

Slope

(%) Acres1

6 Satisfactory Slight 0.65 2.71 2.10 0-5 137

10 Satisfactory Slight 0.53 2.71 2.47 0-5 262

20 Satisfactory Slight 0.12 3.64 0.93 0-5 144

36 Satisfactory Slight 0.36 2.71 0.85 0-5 14

37 Satisfactory Slight 0.24 3.64 0.85 0-5 44

300 Satisfactory Moderate 2.35 2.71 13.56 15-40 179

302 Satisfactory Severe 2.14 2.71 15.50 15-40 88

304 Satisfactory Slight 0.16 2.71 0.93 0-15 248

310 Satisfactory Moderate 1.70 2.71 12.38 15-40 2,008

320 Unsatisfactory Severe 1.94 1.82 16.75 40-80 328

322 Satisfactory Severe 1.42 2.71 19.59 40-80 1,879

324 Satisfactory Slight 0.20 2.71 0.93 0-15 5,206

325 Satisfactory Slight 0.20 2.71 1.25 0-15 24

401 Satisfactory Slight 0.16 2.71 0.93 0-15 464

402 Unsatisfactory Moderate 1.70 2.71 9.96 15-40 327

405 Satisfactory Slight 0.20 2.71 0.61 0-15 25

407 Unsatisfactory Severe 3.60 2.71 14.37 15-40 114

507 Satisfactory Slight 0.16 2.71 0.28 0-15 212

518 Satisfactory Slight 0.24 1.82 0.61 0-15 463

519 Satisfactory Slight 0.20 1.82 25.09 0-15 874

525 Unsatisfactory Severe 3.40 2.71 0.61 15-40 118

537 Satisfactory Slight 0.12 2.71 0.61 0-15 1,177

539 Unsatisfactory Severe 7.49 2.71 14.37 40-120 52

563 Satisfactory Slight 0.20 2.71 0.61 0-15 130

564 Unsatisfactory Severe 3.64 2.71 12.38 15-40 599

565 Satisfactory Slight 0.36 1.82 0.61 0-15 80

658 Satisfactory Slight 0.12 2.71 1.58 0-15 416

659 Satisfactory Moderate 2.71 2.71 24.04 15-40 909

660 Satisfactory Severe 1.86 2.71 14.29 40-120 1,124

Total 17,662

*acres are 

approximate

1 Acres are approximate. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

112 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-39. Predicted Soil Erosion Hazard within the Project Area
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 113

Hydrologic Soil Groups

Soils are classified into hydrologic soil groups (HSGs) to indicate the minimum rate of infiltration and runoff 

potential obtained for bare soil after prolonged wetting. This information is important to project and watershed 

planning since runoff determines, to a large extent, the flood hazard, the character and amount of stream flow, and 

the hazard of erosion from rainwater and snowmelt. The HSG designations are A, B, C and D, and are defined by 

Natural Resources Conservation Service (NRCS) as follows:

• Group A soils have low runoff potential and high infiltration rates even when thoroughly wetted. They 

consist chiefly of deep, well to excessively drained sands or gravels and have a high rate of water 

transmission (greater than 0.30 in/hr).

• Group B soils have moderate infiltration rates when thoroughly wetted and consist chiefly of moderately 

deep to deep, moderately well to well drained soils with moderately fine to moderately coarse textures. 

These soils have a moderate rate of water transmission (0.15-0.30 in/hr). 

• Group C soils have low infiltration rates when thoroughly wetted and consist chiefly of soils with a layer 

that impedes downward movement of water and soils with moderately fine to fine texture. These soils 

have a low rate of water transmission (0.05-0.15 in/hr). 

• Group D soils have high runoff potential. They have very low infiltration rates when thoroughly wetted 

and consist chiefly of clay soils with a high swelling potential, soils with a permanent high water table, 

soils with a claypan or clay layer at or near the surface, and shallow soils over nearly impervious material. 

These soils have a very low rate of water transmission (0-0.05 in/hr).

For the soils that occur within the project area and their associated acreages approximately 1% (114 acres) of the 

soils are in hydrologic soils group A; 26% (4,619 acres) are in hydrologic soils group B; 61% (10,811 acres) are in 

hydrologic soils group C; and 12% (2,101 acres) are in hydrologic soils group D. Figure 3-40 displays the 

location and extent of soils by their associated hydrologic soils groups. 

Vegetative Ground Cover

Vegetative ground cover is important for protecting soil surfaces from erosion and invasion by noxious weeds. 

The TES includes values for vegetative ground cover for each TES mapping unit. These values include both 

vegetation basal area and litter. Table 3-14 lists vegetative ground cover and associated acreages for each TES 

mapping unit in the proposed project area. 

Soil Organisms

Knowledge of specific fungal, bacterial, and arthropod populations is not available for analysis in this project. 

Biological soil crusts, commonly found in arid or semi-arid environments (USDA NRCS 1997) are not known to 

exist in the project area. However, cryptogrammic crusts have been identified in the same ecosystems as those 

found in the project area, including mixed conifer forests and pinyon-juniper woodlands (Beymer and Klopatek 

1992). It is possible that biological soil crusts occur within the proposed treatment areas.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

114 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-40. Hydrologic soil groups within the Project Area
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 115

Table 3-14. Estimated vegetation, litter, and total vegetative ground cover in the project area

Map 

Unit

Vegetation 

(Basal Area)

Litter 

(%)

Total Vegetative 

Ground Cover (%)

Natural Ground 

Cover (%)

6 25 5 30 80

10 5 35 40 80

36 15 5 20 85

37 25 5 30 80

300 5 40 45 85

302 10 40 50 70

304 10 35 45 85

310 10 40 50 85

320 3 55 55 85

322 8 60 65 85

324 5 35 40 80

325 10 35 45 75

401 10 45 55 75

402 10 35 45 70

405 10 20 30 80

407 12 22 35 75

507 10 5 15 75

518 20 5 25 70

519 5 25 30 70

525 5 30 35 85

537 5 40 45 85

539 10 20 30 65

563 10 20 30 70

564 10 20 30 70

565 10 5 15 65

658 8 50 60 85

659 11 45 55 85

660 4 45 50 85

In arid and semi-arid native vegetation communities, plants often exhibit patchy distributions that result in 

discontinuous fuel conditions and mosaics of fire intensities (Whisenant 1990). Biological soil crusts do not 

provide adequate fuel to carry a fire through interspaces, thereby serving as “refugia” to decrease the spread of 

fire and its intensity (Rosentreter 1986). The remaining unburned islands of vascular vegetation and biological 

soil crust provide propagules for reestablishment in burned areas. Johansen et al. (1993) observed that the 

structural matrix of soil biological crusts remained intact following low-intensity fire, indicating that lightly 

burned crusts still function to provide stability against erosive forces.

Populations of other soil organisms include mycorrhizal fungi, soil-dwelling arthropods, gastropods, nematodes 

and bacteria. All of these types of organisms are expected to occur within the proposed treatment areas.

Organic Matter

Organic matter in its various forms contributes to soil productivity. Humus is decomposed organic matter while 

duff, or litter, consists of relatively undecomposed or partially decomposed leaves, needles, and twigs that are still 

recognizable on the surface of soils. Coarse woody debris (CWD) consists of woody stems greater than 3 inches 

in diameter. Decomposing coarse woody debris can supply moisture to plants and animals after soils have dried. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

116 Chapter 3. Affected Environment and Environmental Consequences

All organic matter provides water and nutrients for soil organisms and plants. Because CWD is an important 

component of a functioning ecosystem, a portion of this material must be maintained (Graham et al. 1994). 

However, excessive accumulations of woody debris can result in fires that are extremely hot, resulting in large 

losses of soil organic matter (Harvey 1994). Currently, most soils within the project area exhibit an abundance of 

organic matter in a variety of size classes. Some map units that are currently rated unsatisfactory (i.e., 320, 402, 

407, 525, 539, and 564) generally exhibit less organic matter than required to maintain soil productivity and 

prevent soil loss. The locations of unsatisfactory TES units are depicted in Figure 3-41 and their areal extents are 

summarized in Table 3-12. 

Revegetation Potential

Revegetation potential refers to the probable success and ease in the establishment of native grasses. This 

potential rating is influenced by climate, soil characteristics, and slope. The rating system is based on use of a 

rangeland drill, broadcast seeder (hand held), and aerial seeding with no consideration for site preparation 

(removal of trees, etc.).

A low or moderate rating alerts the land manager to potential limitations for successful artificial revegetation of an 

area. Soils associated with a "high" rating offer the best opportunity for success. The udic/frigid combination 

offers the optimum soil climate for establishment of vegetation. Conversely, the aridic/thermic combination offers 

the most limiting soil climate for the establishment of vegetation. For the project area, Table 3-15 below displays 

the artificial revegetation potential. It is important to note that these potentials correspond to no site preparation 

or removal of trees. It is very likely that natural revegetation potentials would be higher than these values 

following vegetation treatments since soil moisture and light penetration to the forest floor would be increased. 

Practices that minimize soil disturbance such as churning of soil profiles would preserve native seed banks, thus 

improving natural revegetation. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 117

Table 3-15. Revegetation potential within the project area

Revegetation Potential Map Unit Symbol Acres

Moderate 6 44

10 127

300 179

302 50

304 248

324 4,705

325 24

401 269

405 25

407 104

507 11

537 1,074

563 130

658 416

659 854

Moderate Total 8,260

Low 310 1,934

320 328

322 1,779

518 169

519 743

525 74

539 12

564 477

565 80

660 1,109

Low Total 6,705

Grand Total 14,965

Note: Acres are approximate.

Timber Harvest Limitations

Timber harvest limitations are limits to be considered when evaluating the impact of timber harvest with regard to 

maintenance of soil productivity. Limits relate to year round or seasonal concerns and use of equipment as they 

relate to climate, soils characteristics, and landforms. A moderate or severe rating directs the land manager to 

areas that require mitigation in order to avoid impairment of soil productivity. Logging systems are proposed for 

this project that would adequately overcome most timber harvest limitations. Timing of logging operations can 

often be used to mitigate soil moisture problems. For example, logging can be performed during frozen ground or 

dry conditions to minimize risk of soil compaction and rutting and consequential erosion. Table 3-16 below 

summarizes timber harvest limitations by map unit within the Bill Williams Mountain Restoration Project area. 

Figure 3-41 depicts the locations of TEUs and their associated timber harvest limitations.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

118 Chapter 3. Affected Environment and Environmental Consequences

Table 3-16. Timber harvest limitations within the project area

Timber Harvest 

Limitations 

Map Unit 

Symbol Reason Acres1

Severe 6 Seasonally wet 44

10 Seasonally wet 127

36 Wetland soil <1

37 Seasonally wet <1

320 Severe erosion hazard, shallow soils, steep slopes 328

322 Severe erosion hazard, shallow soils, steep slopes 1,779

407 Severe erosion hazard, inherently unstable cindery 

soils

104

507 Trafficability problems when wet 11

539 Steep slopes, large surface rocks and rock outcrops 

common

12

565 Shallow soil depth and rock content inhibits 

regeneration

80

660 Severe erosion hazard, steep slopes, large rock 

common

1,109

Severe Total 3,594

Moderate 300 Risk of accelerated erosion 179

302 Risk of accelerated erosion 50

304 Trafficability problems, risk of compaction 248

310 Moderate erosion hazard, high rock content 1,934

324 Low bearing strength/trafficability problems when wet 4,705

325 Low bearing strength/trafficability problems when wet 24

401 Low bearing strength/trafficability problems when wet 269

402 Erosion hazard increases with removal of ground cover 247

405 Trafficability problems when wet, churning damages 

soil 

25

519 Large rock fragments common, shallow soils 743

525 Trafficability problems when wet, rock outcrops 

common

74

537 Trafficability problems when wet, large rock fragments 

common

1,074

563 Trafficability problems when wet, churning damages 

soil

130

564 Severe erosion hazard, trafficability problems when 

wet, churning damages soil productivity

477

658 Trafficability problems when wet, churning damages 

soil

416

659 Churning damages soil productivity 854

Moderate Total 11,446

Slight 518 Large rock fragments and rock outcrops common 169

Slight Total 169

Grand Total 15,210

1 Acres are approximate.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 119

Figure 3-41. Terrestrial Ecosystem Units and their associated Timber Harvest Limitations within the Project Area
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

120 Chapter 3. Affected Environment and Environmental Consequences

Effects of Roads to Soils and Watershed Resources

Currently, National Forest System roads within the project area occupy approximately 60 miles or 87.27 acres 

based on an average road width of 12 feet, including Forest Roads 108 and 122 which generally serve as the 

western and southern boundaries of the project area, respectively. In addition to National Forest System, nonsystem roads occur within the project area. Most of these roads are the result of indiscriminate route proliferation 

caused by disbursed camping, hunting, fuelwood gathering, and similar activities. 

All roads within the Bill Williams Mountain Restoration Project area are classified as Maintenance level 1, 2, or 

3. Maintenance level 1 roads are closed to vehicular traffic. The closure period must exceed 1 year. Basic 

custodial maintenance is performed to keep damage to adjacent resources to an acceptable level and to perpetuate 

the road to facilitate future management activities. Emphasis is normally given to maintaining drainage facilities 

and runoff patterns. Planned road deterioration may occur at this level. Appropriate traffic management strategies 

are “prohibit” and “eliminate.” Roads receiving level 1 maintenance may be of any type, class or construction 

standard, and may be managed at any other maintenance level during the time they are open for traffic. However, 

while being maintained at level 1, they are closed to vehicular traffic, but may be open and suitable for 

nonmotorized uses. There are approximately 20 miles of ML-1 roads within the project area.

Maintenance level 2 roads are open for use by high-clearance vehicles. Passenger car traffic is not a consideration. 

Traffic is normally minor, usually consisting of one or a combination of administrative, permitted, dispersed 

recreation, or other specialized uses. Log hauling may occur at this level. Appropriate traffic management 

strategies are either to (1) discourage or prohibit passenger cars or (2) accept or discourage high-clearance 

vehicles. There are approximately 31 miles of ML-2 roads within the project area.

Maintenance level 3 roads are open and maintained for travel by prudent drivers in standard passenger cars. User 

comfort and convenience are low priorities. Roads in this maintenance level are typically low speed, single lane 

with turnouts, and spot surfacing. Some roads may be fully surfaced with either native or processed material. 

Appropriate traffic management strategies are either “encourage” or “accept.” “Discourage” or “prohibit” 

strategies may be employed for certain classes of vehicles or users. There are approximately 9 miles of ML-3 

roads within the project area. These include FR108 which forms the western boundary of the project area, FR111 

which provides access to the top of Bill Williams Mountain, and FR106 which provides access to the Elk Ridge 

Ski Area.

It is likely that the majority of ML-1 and ML-2 roads are the result of historic logging practices and user-created 

recreational access routes. As a result, many of these roads are inadequately engineered, poorly located on the 

landscape and are consequently in a state of disrepair. Some of these roads are located near drainage channels or 

on ridge tops and are subject to erosion and sediment transport. Roads near drainages are contributing to 

degradation of surface water quality during snowmelt and following short duration high intensity monsoon 

storms. Some roads have eroded to the point where road surfaces are below the grade of the surrounding 

landscape, resulting in stormwater runon that then pools on road surfaces or flows down the travelway eroding the 

roadbed and entraining sediment in the storm flow. Where water pools in road surfaces, rutting is a problem. 

Where stormwater flows down road surfaces, rills and gullies are compromising road surfaces and water quality.

Road conditions were reviewed during field assessments. Many roads in the project area would not provide 

adequate access for mechanical vegetation treatments. Rutting, compaction, puddling, and erosion were observed 

on several roads in the project area. In some cases, these conditions were found to be adversely impacting water 

quality as a result of inadequate road surface drainage. The lack of adequate road drainage structures on many 

roads (i.e., waterbars, broad based dips, crowning, rolling the grade, etc.) is allowing stormwater to flow for 

considerable distances down road surfaces, entraining sediment, creating rills, and depositing sediment at stream 

crossings. Some roads in close proximity to ephemeral drainages have rills that are directly connected to the 

ephemeral streamcourses. Some roads have ruts that are conveying sediment-laden runoff directly to stream 

crossings. Where roads have inadequate cross drainage, stormwater is flowing directly across road surfaces, 

entraining road fill material and carrying it to ephemeral streamcourses.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 121

Water Resources

Watersheds. The Bill Williams Mountain Restoration Project occurs within six sixth-level (HUC12) hydrologic 

units or subwatersheds as shown in Figure 3-42. A watershed condition assessment was recently conducted in 

accordance with the Watershed Condition Framework (FS-977) and Watershed Condition Classification Technical 

Guide (FS-978) for all subwatersheds in the project area as part of a Forest-level assessment of watershed 

condition (Potyondy and Geier, 2010). This assessment is used to: 1) prioritize watersheds for restoration, 2) 

identify specific on-the-ground activities and the associated costs to maintain or improve watershed condition, and 

3) manage the data appropriately. Watershed conditions for the subwatersheds in the project area were classified 

using a core set of national watershed condition indicators. Twelve core watershed condition indicators were also 

evaluated for the watersheds in the project area. A summary of watershed conditions for the six watersheds in the 

project area is included in Table 3-17. 

Table 3-18 provides a summary by watershed of indicator ratings that resulted in the corresponding watershed 

condition rating found in Table 3-18. 

Table 3-17. Subwatershed (HUC12) names, codes, condition ratings, acreages, and associated percentages of total 

project area

Watershed Name

Hydrologic 

Unit Code 

(HUC12) Condition Rating

Watershed 

Acres

Project 

Area Acres

Cataract Creek Headwaters 150100040502 Functioning-at risk 16,694 5,148

Devil Dog Canyon 150602020202 Functioning-at risk 11,192 1,331

Dogtown Wash 150100040501 Functioning-at risk 11,659 816

Johnson Creek 150602010302 Functioning-at risk 30,847 2,719

Meath Wash 150602020203 Properly functioning 37,522 1,639

Upper Hell Canyon 150602020204 Impaired 29,239 6,007

Total 137,153 17,660
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

122 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-42. Bill Williams Mountain Restoration Project in relation to subwatersheds (HUC12)
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 123

Table 3-18. Watershed condition indicator summary for watersheds that occur in the project area

Watershed Name Reason For Condition Rating

Cataract Creek 

Headwaters

Functioning at risk due to reduced flows to springs and riparian areas; high 

road density; infrequent road maintenance; private septic systems present.

Devil Dog Canyon Functioning at risk due to low road maintenance; many stock tanks present.

Dogtown Wash Functioning at risk due to fire regime departed from reference condition; high 

road density; infrequent road maintenance; cinder pits and septic systems 

present; many stock tanks; 3 water wells and 2 reservoirs present.

Johnson Creek Functioning at risk due to reduced flows to springs and riparian areas; high 

road density; infrequent road maintenance; many roads near water courses; 

cinder pits present; many stock tanks, 1 well, and 4 reservoirs present.

Meath Wash Infrequent road maintenance; many stock tanks present.

Upper Hell Canyon Impaired due to unsatisfactory soils in watershed; reduced flows to springs 

and riparian areas; high road density; infrequent road maintenance.

City of Williams Municipal Watershed. The City of Williams Municipal Watershed is approximately 26,061 

acres in size (Figure 3-43). Table 3-19 below lists the eight subwatersheds and their associated acreages that occur 

within the Williams Municipal Watershed. Two of these subwatersheds, Cataract Creek Headwaters and Dogtown 

Wash, encompass more than 96 percent of the total municipal watershed area. 

Table 3-19. Subwatershed (HUC12) names, acreages, and associated percentages of each that comprise the City of 

Williams Municipal Watershed

Watershed Name

Hydrologic 

Unit Number 

(Huc12)

Total

Watershed

Acres

Percent of 

Williams 

Municipal 

Watershed

Acres in 

Project 

Area* 

Percent of 

Project 

Area

Dogtown Wash 150100040501 10,627 40.8 816 8.7

Cataract Creek Headwaters 150100040502 14,616 56.1 5,148 33.8

Upper Red Lake Wash 150100040503 681 2.6 0 0 

Upper Cataract Creek 150100040504 23 <0.3 0 0 

Johnson Creek 150602010302 70 <0.3 2,719 17.9

Upper Hell Canyon 150602020204 25 <0.3 1,639 10.7

Pitman Valley-Scholz Lake 150602020305 3 <0.3 0 0 

Big Spring Canyon 150602020307 9 <0.3 0 0 

1 Acres are approximate.

Citizens of Williams, Arizona depend on the Williams Municipal Watershed as a source of public drinking water 

and for other benefits that multiple use management of this watershed provides. The objective in managing the 

Williams Municipal Watershed is to recognize its water supply values and to provide management of its lands and 

resources to harmonize present and foreseeable resource uses with domestic water supply needs, protection of its 

water supply facilities and protection of the citizens of Williams from severe floods (Elson 1972). 

Runoff impounded in reservoirs serves as the main water supply for the City of Williams. Seven primary 

reservoirs surrounding the City are the source of surface water for municipal uses. These reservoirs have a 

combined water storage capacity of 2,755 acre-feet (897 million gallons) of water. Approximately 2,026 acre-feet 

or 73.6 percent of the available water storage occurs in the two largest impoundments, Dogtown Reservoir and 

Kaibab Lake. However, the majority of the City’s water supply (i.e., approximately 90 percent) originates from 

Dogtown Reservoir and City Dam. Groundwater from wells located near Dogtown Reservoir supplements surface 

water in the City municipal water supply. Table 3-20 provides a summary of reservoirs used for the municipal 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

124 Chapter 3. Affected Environment and Environmental Consequences

water supply for the City of Williams and their associated water storage capacities and percentage of total water 

storage capacity. Water from these reservoirs originates from winter precipitation, snow melt and summer 

precipitation. 

The annual water demand of the City of Williams is approximately 198,184,868 gallons or 101.37 acre-feet which 

includes billed water to customers, unmetered water used at city-owned facilities and landscapes, unaccounted-for 

water, process water used at the drinking water treatment plant, raw water used for golf course irrigation, and 

reclaimed water used for golf course irrigation. Processed water used at the drinking water treatment plant is nonpotable raw water used for filter backwash, sediment removal, and chemical feed, which amounts to 

approximately four percent additional water above total production (Pinkham and Davis 2002). Since the City of 

Williams does not recycle this water back into the water supply system, it is considered a water use. Monthly 

municipal water demand is highly variable. However, the months of highest water demand are typically June, 

July, and August of most years. Water demand is lowest during winter months and increases through spring, with 

highest usage occurring during summer. There has been an upward trend (11 percent) in water usage by the City 

of Williams between 2005 and 2010. 

Table 3-20. Reservoirs, associated water storage capacities, and percentages of total municipal surface water in the 

City of Williams Municipal Watershed

Reservoir Name

Water Storage 

Capacity

(Million Gallons)

Water Storage 

Capacity

(Acre-Feet)

Percent of Total 

Water Storage 

Capacity

Dogtown Reservoir 360 1,105 40.2

Kaibab Lake 300 921 33.4

Cataract Lake 109 335 12.2

Santa Fe Reservoir 70 215 7.8

City Dam 36 111 4.0

Upper and Lower Saginaw 22 68 2.4

Water that enters reservoirs either remains in storage, is withdrawn for use, is lost through dam spillage, or is lost 

through evaporation and infiltration. Evaporation and infiltration from the reservoirs is substantial every year. 

These losses exceed the city’s current annual water use (Pinkham and Davis 2002). When the reservoirs are full, 

they provide a 2.5 year water supply, given current average rates of water use. A two year drought results in 

significant stress on the City of Williams surface water supply. This occurred in 1996-1997, and again in 1999-

2000. Most of the water lost as spillage from reservoirs is lost from the water supply system. Although Kaibab 

Lake is downstream from Dogtown Reservoir on the same drainage, or stream channel, it is usually filled by 

surface runoff at approximately the same rate as Dogtown Reservoir. Most of the water that spills from Dogtown 

Reservoir is therefore subsequently spilled from Kaibab Lake (Thomsen 1969). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 125

Figure 3-43. Bill Williams Mountain Restoration Project area in relation to the City of Williams Municipal Watershed
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

126 Chapter 3. Affected Environment and Environmental Consequences

Since the 1996-1997 drought, the City of Williams has aggressively pursued development of reliable groundwater 

supplies. This program exemplifies the risks and costs of groundwater supply development in the region. The first 

well boring targeted an expected perched aquifer at 500-600 feet deep located west of the City. The well was dry. 

A second attempt, below the Santa Fe Dam, resulted in technical difficulties at approximately 2,000 feet of depth 

and was subsequently abandoned. A third attempt nearby struck water at 1,400 feet. This well is now producing at 

a peak flow of 110-120 gallons per minute (GPM), but only 20-25 GPM at maximum pumpage for more than 12 

hours. A fourth boring on KNF forestland in the vicinity of Dogtown Reservoir was also successful and now 

produces 220-240 GPM. The most recently developed well was drilled on the city’s rodeo grounds. This well 

produces approximately 220-230 GPM. The Dogtown and rodeo grounds wells are over 3,000 feet deep. To date, 

Williams has spent roughly seven million dollars for three producing wells and three dry wells. The three 

successful wells produce a combined 500 GPM. Williams intends to continue well development in coming years, 

depending on the City’s growth rate. 

Some regional water stakeholders, including the Havasupai Tribe, have expressed concern regarding impacts of 

the City of Williams well development program on springs and seeps in the Grand Canyon area. The City of 

Williams and the Havasupai Tribe have entered into an agreement regarding regional ground water management 

and water conservation efforts by the City of Williams. The agreement includes discussions of tribal sovereignty, 

the significance of the Coconino Plateau to the tribe, the importance of water on the Coconino Plateau, the 

importance of water conservation, and the effect of drought on the water resources of the City of Williams.

Specific agreement clauses address conditions under which the tribe would not contest or may contest well 

permits from the U.S. Forest Service and the city’s right to respond to opposition, monitoring of well levels and 

production, restrictions on provision of water by the city to residents outside the city, city opposition to Coconino 

County allowing home development in areas without water supply, mutual support for development of other water 

supplies, mutual opposition to large-scale development proposals that rely on groundwater development, 

continuation of water conservation efforts by the City of Williams, and the City’s support in principle for the 

tribe’s position that any decrease to the natural flow of Havasu Creek cannot be tolerated (Pinkham and Davis 

2002). 

Water Quality. Section 305(b) of the Clean Water Act requires states to assess and report on the water quality 

status of waters within the states. Section 303(d) requires states to list waters that are not attaining water quality 

standards. This is also known as the list of impaired waters. This information is reported to Congress on a 

nationwide basis. Arizona Department of Environmental Quality is responsible for conducting monitoring, 

assessment, reporting under CWA Sections 303(d) and 305(b), and TMDL development for the State of Arizona. 

Arizona's most recent Integrated Report (305(b) Water Quality Assessment and 303(d) list) is available from the 

Arizona Department of Environmental Quality (ADEQ). The Arizona Impaired Waters List can be found at: 

http://www.azdeq.gov/environ/water/assessment/assess2012_2014.html 

There are no perennial running waters within the project area; there is therefore no surface water quality data for 

the project area. No water bodies are listed as impaired within the project area on the Arizona 2006/2008 

Impaired Waters List. 

Stream Courses. Due to the relatively steep terrain, the Bill Williams Mountain vicinity exhibits a radial drainage 

pattern with high-gradient ephemeral and intermittent drainages flowing in all directions from the upper slopes of 

Bill Williams Mountain. Approximately 68.92 miles of streamcourses occur within the analysis area, with none 

having riparian reaches. Most of the streamcourses in the proposed project area are best characterized as 

ephemeral, or dry washes. However, three drainages that exhibit intermittent flow do occur within the project 

area. These include Cataract Creek, Dogtown Wash, and West Cataract Creek. These washes flow primarily 

during spring snowmelt and, to a lesser extent, during the summer monsoon. Refer to Table 1 in Appendix A of 

the Soils and Watershed Specialist’s Report for a summary of stream reaches and their associated lengths and 

names within the Bill Williams Mountain Restoration Project area.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 127

Wetlands and Springs. There are 32 livestock ponds, reservoirs, and natural depressions within the project 

boundary that impound water for a sufficient duration to exhibit some wetland characteristics and are therefore 

listed in the National Wetlands Inventory database of the U.S. Fish and Wildlife Service. The U.S. Fish and 

Wildlife Service is the principal Federal agency that provides information to the public on the extent and status of 

the Nation's wetlands. Through the National Wetlands Inventory, the agency has developed a series of topical 

maps to show wetlands and deep water habitats. These maps have been used extensively to make resource 

management decisions at the federal, state and local government levels. National wetlands data can be found at: 

http://www.fws.gov/wetlands/

There are three known springs located within the Bill Williams Mountain Restoration Project analysis area. These 

include Clover Spring (112°12’12.94”W, 35°13’53.48”N), Bennett Spring (112°12’46.80”W, 35°13’52.94”N), 

and Andrews Spring (112°15’22.76”W, 35°9’33.18”N). There is no information available regarding historic flow 

or water quality from these springs. The springs are best characterized as rheocrene – they flow directly from the 

ground resulting in a small stream. The three springs were surveyed on October 13, 2011 to assess spring 

conditions. Clover Spring has been altered through installation of a spring box. This infrastructure helps protect 

the spring source from potential contamination. 

Clover Spring flows for approximately 35 feet from the spring box to a small, oblong basin approximately 6 feet 

long and 4 feet wide. Water continues to flow at the surface for an additional 45-50 feet in a narrow channel 

before water infiltrates into the soil. Hydrophytic (i.e., wetland) vegetation occurs within and along the fringe of 

the channel and for an additional 15-20 feet below the location where surface flow terminates. Bennett Spring is 

undeveloped with no surface flow evident at the time of site investigation. Andrews Spring is also undeveloped 

with no observed surface flow at time of site visit. It is possible that Bennett and Andrews Springs flow only after 

winter snowpack has recharged groundwater and during or shortly after the summer monsoon season. 

Flood Zones. Flood zones are geographic areas defined by the Federal Emergency Management Agency (FEMA) 

according to varying levels of flood risk. These zones are depicted on a community's Flood Insurance Rate Map 

(FIRM) or Flood Hazard Boundary Map. Each zone reflects the severity or type of flooding in the area. Moderate 

to low risk areas in the project vicinity are identified as flood zone X and C and X. Flood zones B and X are 

defined as areas of moderate flood hazard, usually these areas are between the limits of the 100-year and 500-year 

floods. These designations include base floodplains of lesser hazards, such as areas protected by levees from 100-

year flood, or shallow flooding areas with average depths of less than one foot or drainage areas less than 1 square 

mile. Flood zones C and X are areas of minimal flood hazard, usually depicted on FIRMs as above the 500-year 

flood level. High risk areas are designated as zones A, AE, AH, and AO.

Flood zone A includes areas with a 1 percent annual chance of flooding and a 26 percent chance of flooding over 

the life of a 30-year mortgage. Because detailed analyses are not performed for such areas; no depths or base 

flood elevations are shown within these zones. Flood zone AE are areas of the base floodplain where base flood 

elevations are provided. Flood zone AH includes areas with a 1 percent annual chance of shallow flooding, 

usually in the form of a pond, with an average depth ranging from 1 to 3 feet. These areas have a 26 percent 

chance of flooding over the life of a 30-year mortgage. Base flood elevations derived from detailed analyses are 

shown at selected intervals within these zones. Flood zones AO are river or stream flood hazard areas, and areas 

with a 1 percent or greater chance of shallow flooding each year, usually in the form of sheet flow, with an 

average depth ranging from 1 to 3 feet. These areas have a 26 percent chance of flooding over the life of a 30-year 

mortgage. Average flood depths derived from detailed analyses are shown within these zones.

Within the Bill Williams Mountain Restoration Project area, there are approximately 17,511 acres of flood zone X 

(minimal flood hazard), 68 acres of flood zone A (high flood risk, depth and base flood elevation unknown) and 

69 acres of flood zone AE (high flood risk, depth and base flood elevation known). Flood zone A is located in the 

southwestern portion of the project area and is associated with Devil Dog Canyon. Flood zone AE is located near 

the northeastern boundary of the project area in the City of Williams and is associated with Cataract Creek.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

128 Chapter 3. Affected Environment and Environmental Consequences

3.5.2 Direct and Indirect Effects

Direct effects of an action are caused by the action and occur on site and affect only the area where they occur. 

Indirect effects are caused by the action and are later in time or farther removed in distance, but are still 

reasonably foreseeable. In general, direct and indirect effects to soils and forest hydrology as a result of the action 

alternatives include:

• Reduction of the forest canopy would decrease interception (precipitation captured by leaves, branches, 

and boles) and increases net precipitation reaching the soil surface.

• Partial removal of the forest overstory reduces transpiration (water lost from plants to the atmosphere).

• Reductions in interception and transpiration increase soil moisture content, water available for plant 

uptake, and water yield.

• Increased soil moisture and loss of root biomass can reduce slope stability.

• Increases in water yield after forest thinning are transitory and decrease over time as forests regrow unless 

subsequent treatments maintain initial post-treatment conditions. 

• When young, dense forests with high interception rates (or higher annual transpiration losses) replace 

mature forests with lower interception rates (or lower transpiration losses); water yield is reduced until the 

young forest matures and thins naturally or is thinned in treatments.

• Impervious surfaces (roads and trails) and altered hillslope contours (cutslopes and fillslopes) modify 

water flowpaths, increase overland flow, and deliver overland flow directly to stream channels. 

• Impervious native surfaces increase soil erosion.

• Altered hillslope contours and modified water flowpaths along roads increase risk of landslides. 

Table 3-21 lists the Best Management Practices (BMPs) as mitigation measures for the direct and indirect effects 

for the project. Effectiveness designations of 1 represent highly effective mitigation measures or Best 

Management Practices while designations of 2 represent moderately effective mitigation measures. Most adverse 

effects to soils and water resources can be minimized or mitigated through appropriate use of resource protection 

measures such as Best Management Practices (BMP’s) and Soil and Water Conservation Practices (SWCPs) as 

outlined in the National Core BMP Technical Guide (FS-990a)(USDA 2012) and Soil and Watershed 

Conservation Practices Handbook (Forest Service Handbook 2509.22)(USDA 1990).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 129

Table 3-21. Best Management Practices (BMPs) for the project

BMP # Mitigation Purpose

Effectiveness

BMP 

#1

Implement Best Management Practices where needed prior to project 

implementation.

To minimize impacts to soil and water resources from project 

implementation, to minimize non-point source pollution, to 

adhere to the Clean Water Act, and to adhere to the 

intergovernmental agreement between Region 3 of the Forest 

Service and the ADEQ.

1 

BMP 

#2

On areas where prescribed fire is to be used, fire prescriptions should be designed 

to minimize soil temperatures over the entire treatment area. Fire prescriptions 

should be designed so that soil and fuel moisture temperatures are such that fire 

intensity is minimized and soil health and productivity are maintained. 

To maintain long-term soil productivity. 1 

BMP 

#3

On areas where prescribed fire is to be implemented, retain approximately 3-7 

tons/acre of course woody debris in ponderosa pine and pinyon stands to be left 

on-site after the prescribed burns and fuelwood gathering. 

To maintain long-term soil productivity. 1 

BMP 

#4

On areas to be prescribed burned, if containment lines are put in place, rehabilitate 

lines after use by installing fireline BMPs. If line is only to be waterbarred, disguise 

the first 300 feet of line from roadways or otherwise restrict motorized access to 

discourage use.

To minimize soil detachment and delivery to stream courses 

as sediment.

1 

BMP 

#5

Do not blade roads when the road surface is too dry. If the road surface is too dry, 

water should be applied, or road blading should be scheduled when adequate 

moisture is present to complete road reshaping. 

To minimize soil particle detachment and fugitive dust, and to 

ensure the longevity of road surface material.

2 

BMP 

#6

All fueling of vehicles will be done on a designated upland site. If more than 1,320 

gallons of petroleum products are to be stored on site or if a single storage tank 

exceeds 660 gallons, then a spill prevention control and countermeasures (SPCC) 

plan will be prepared as per 40 CFR 112.

To prevent contamination of soil and water resources from 

accidental petroleum hydrocarbon spills.

1 

BMP 

#7

Clean all equipment prior to entry on site with a high pressure washer to remove 

mud, debris, and vegetative material from the equipment.

To minimize the spread of invasive or noxious weeds into the 

project area 

1 

BMP 

#8

Clean all equipment prior to leaving the project area with a high pressure washer to 

remove mud, debris, and vegetative material from the equipment.

To minimize the spread of invasive or noxious weeds to offsite areas and to prevent track-out of mud and debris onto 

public roadways.

1 

BMP 

#9

Temporary access routes for fuelwood gathering should not have long, straight 

runs down slopes that would re-direct or concentrate water flow. These access 

routes should also be located out of filter strips (exceptions are at approved 

crossings). 

To minimize the number of acres disturbed and to minimize 

potential adverse impacts to surface water quality.

1 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

130 Chapter 3. Affected Environment and Environmental Consequences

BMP # Mitigation Purpose

Effectiveness

BMP 

#10

Forest Service approved native seed should be broadcast over disturbed areas 

such as decommissioned roads, log landings, skid trails, and pile burning areas as 

necessary to stabilize soils. Seeding rates should be 8-10 lbs. per acre pure live 

seed. Recommended native species include:

Western wheatgrass (Pascopyrum smithii) 

Arizona fescue (Festuca arizonica) 

mutton grass (Poa fendleriana) 

sideoats grama (Bouteloua curtipendula) 

blue grama (Bouteloua gracilis) 

mountain muhly (Muhlenbergia montana) 

winterfat (Krascheninnikovia lanata) 

Seeding should only be conducted where there is insufficient woody debris to 

protect soil surfaces from erosion in order to minimize possible introduction of 

invasive plant species.

The seed mix can contain a mixture of all or some of these suggested species, 

depending on site considerations. 

Other acceptable erosion control measures include, but are not limited to, 

distributing slash, waterbarring (waterbars should not be more than two feet deep 

and require at least a ten foot lead out). Permanent water diversion structures are 

only to be installed using equipment with an articulating blade. 

To minimize soil loss and potential sedimentation of stream 

courses from harvesting operations and to minimize noxious 

weed spread and re-establish native vegetation 

1 

BMP 

#11

Road drainage is controlled by a variety of methods including rolling the grade, 

insloping, outsloping, crowning, water spreading ditches (turnouts), and cross 

drainage. Sediment loads at drainage structures can be reduced by installing 

sediment filters such as rock and vegetative energy dissipaters, and settling 

basins. 

To minimize soil movement and maintain water quality. 1 

BMP 

#12

Do not operate equipment when ground conditions are such that soil rutting, 

compaction or puddling can occur. 

To maintain long-term site productivity. 1 

BMP

#13

Treatment areas should be designed in a manner that minimizes soil disturbance 

and facilitates BMP implementation. TES maps should be reviewed for location of 

site specific BMP’s in specified TES map units. 

To maintain long-term soil productivity. 1 

BMP

#14

Activity generated slash from forest thinning are to be removed from stream 

courses and/or drainages. Trees are to be felled outside the stream courses 

and/or drainages and not across drainages. 

To protect surface water quality 1 

BMP

#15

Do not hand pile slash in designated stream courses or drainages, or other 

designated protected areas. 

To prevent organic matter loading of stream course and to 

prevent erosion and sedimentation of stream courses and 

water bodies.

1 

BMP

#16

Ensure that existing drainage structures on roads (rolling dips, culverts, rock 

crossings, etc.) are functioning correctly. 

To prevent erosion and sedimentation of stream courses and 

water bodies.

1 

BMP

#17

Lead out ditches (turnouts) should be maintained in a manner that does not allow 

sediment-laden runoff to enter stream courses and/or drainages.

To prevent erosion and sedimentation of stream courses and 

water bodies.

1 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 131

BMP # Mitigation Purpose

Effectiveness

BMP

#18

Adverse skidding (i.e., skidding upslope) should be avoided to the greatest extent 

practicable. 

To prevent excess rutting and compaction of soil surfaces 

and minimize downhill movement of slash and soils.

1 

BMP

#19

Machine piling of activity-related slash should be conducted with an excavator or 

track hoe with a bucket thumb rather than dozers to prevent soil being pushed into 

burn piles and minimize soil disturbance.

To prevent excess rutting and compaction of soil surfaces. 1 

BMP

#20

Harvesting contractors should not be permitted to proceed to subsequent pay units 

until all necessary soil stabilization measures are implemented.

To maintain soil productivity across all activity sites 

throughout the project duration. 

1 

BMP

#21

Primary skid trails should not occur within 1 chain (66 feet) of Streamside 

Management Zones or run parallel to stream courses in these areas. Where this 

BMP cannot be strictly adhered to, alternative BMPs (use of slash mats and timing 

of operations during dry conditions) shall be employed.

To prevent excessive soil disturbance in areas close to 

drainages

1 

BMP

#22

Skidder crossings of ephemeral drainages should be minimized and designated in 

timber harvest area maps and on the ground. 

To prevent excessive soil disturbance in areas close to 

drainages and protect surface water quality

1 

BMP

#23

Designated skid trails and log landings will be required within the Timber Sale 

Contract on all cutting units. Skid trail design should not have long, straight runs 

that would direct water flow. Skid trails should also be located out of filter strips 

(exceptions are at approved crossings). 

To minimize the number of acres disturbed. 1 

BMP

#24

Felling to the lead will be required within the Timber Sale Contract (TSC) to 

minimize ground disturbance from skidding operations

Felling of timber should be done in a manner that minimizes 

ground disturbance from skidding operations. 

1 

BMP

#25

On sites with impaired soils, do not prescribe burn without prior approval of a soil 

and water specialist.

To maintain vegetative ground cover and adequate organic 

matter to improve soil condition.

1 

BMP

#26

Where fuelwood sales are used to remove material, utilize created slash to cover 

and disguise temporary roads, minimize sediment movement from roads, and 

prevent unauthorized future use of temporary roads.

To minimize impacts from temporary roads by covering 

mineral soil, improving ground cover, providing mulch for 

plant re-establishment and minimizing potential sediment 

movement by increasing surface roughness.

1 

BMP

#27

Use the following BMP techniques to minimize sedimentation from road and trail 

construction and maintenance:

Outsloped road surface; Leadout ditches and relief culverts; Energy dissipators on 

culverts; revegetate cut and fill slopes; Riprap installation at stream crossings to 

protect water quality; Riprap or rock at intersections with paved public roads to 

prevent track-out of mud and debris Rolling grades.

Minimize sediment delivery to stream courses from road and 

skid trail construction and maintenance. 

Protect public safety by preventing deposition of mud and 

debris onto paved public roads.

1 

BMP

#28

After use, all temporary roads will be ripped to a shallow depth (<6”), seeded using 

the seed mix specified in BMP #10, drained through installation of necessary water 

diversion structures and covered with slash from landings.

To return temporary roads to productivity 1 

BMP

#29

Locate new trail segments on-contour to the greatest extent possible. If cut and fill 

is required to establish serviceable trails, preferred drainage is outsloping of trail 

surfaces. Utilize additional drainage features outlined in BMP #27 in design and 

maintenance of the trail as warranted.

To minimize soil erosion from skid trails 1 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

132 Chapter 3. Affected Environment and Environmental Consequences

Alternative 1 – No Action

This alternative would not authorize ground disturbance from mechanical vegetation and prescribed fire treatment

activities. As a result, there would be no risk to soil productivity from disturbance associated with these activities. 

Soil resources, however, would continue to be at risk from a wildfire as noted below. Trends indicate that fuel 

loading would continue to increase in both living biomass and woody detritus through natural forest ingrowth and 

tree encroachment into existing openings, resulting in increased risk of high severity wildfire. Ingrown 

understories can create ‘ladder fuels’ which allow ground fires to ascend and spread quickly as crown fires. 

Coarse woody debris would be expected to increase over time as small, medium, and large diameter material falls 

to soil surfaces and begins to decay. While the increased organic matter would improve soil quality in some 

regards (organic matter accumulation in subsurface horizons, microhabitat for soil organisms, increased shortterm water holding capacity, improved nutrient status, etc.) it would also result in an increased risk of high 

severity wildfires where fuel loading becomes excessive. The location, size and intensity of future wildfires 

cannot be estimated with reasonable accuracy, although some generalizations can be made.

High intensity wildfires tend to occur in areas where fuel loading and fuel distributions are sufficient to carry a 

fire. Typically, uncontrolled wildfires occur during the drier times of the year, yielding higher severity fires than 

would occur under prescribed fire conditions. The adverse effects of a high severity fire, such as the loss of forest 

floor organic matter, increased soil erosion, and changes in soil biota would be more widespread in an 

uncontrolled wildfire than under prescribed fire conditions where the size and intensity of the fire can be 

controlled. The primary impact of high intensity fire on soil productivity is the removal of surface organic matter, 

exposing soils to erosion by wind and rain. If surface organic matter is reduced (as happens with a high-intensity, 

long-duration fire) the cation exchange capacity, a measure of soil fertility, is also reduced and the ability of the 

soil to retain nutrients leached from ash decreases. 

There have been many examples of recent uncharacteristic high intensity stand-replacing wildfires occurring in 

the southwestern United States in areas that were originally open, fire-maintained forests (Rodeo-Chediski, 

Schultz, Horseshoe 2, Wallow, Las Conchas, etc.). Such events can have profound negative effect to soil 

properties and watershed conditions including: a) decreased soil productivity through loss of nutrient sources, b) 

soil hydrophobicity (i.e. the inability of soils to absorb water following precipitation resulting in increased 

overland flow c) increased susceptibility of soils to erosion by both wind and rainfall, d) sediment delivery to 

stream channels, e) surface water quality degradation, and f) downstream flooding, to name a few. Large standreplacing fires on the Kaibab National Forest historically have 10-25% of the burn acreage exhibiting high 

severity fire conditions. Therefore, if a 10,000 acre wildfire were to occur within the analysis area, approximately 

1,000 to 2,500 acres of high severity fire would be expected to adversely affect soil properties. 

The introduction of weeds and unwanted flora following a wildfire could lead to increased competition between 

less desirable invasive and noxious weeds and desirable native vegetation. Weeds can increase erosion, reduce soil 

moisture, and deplete nutrient levels (DiTomaso 2000). Because the roots of many noxious weeds are deeper than 

native grasses, they also contribute less organic matter near the soil surface than native vegetation.

Under Alternative 1 there would be no obliteration of roads that are currently contributing to loss of soil 

productivity and degradation of water quality. These roads would remain at risk of unauthorized use, further 

contributing to soil destabilization, loss of productivity, and adverse impacts to surface water quality. Ongoing 

road maintenance of ML-2 and ML-3 roads within the project area would continue as it has in the past.

This alternative would result in no additional acres of ground disturbance from mechanical vegetation treatments, 

piling of activity-related woody debris, construction and maintenance of permanent or temporary roads, 

construction and maintenance of trails and trailheads, fireline clearing, and the use of prescribed fire. 

Direct and Indirect Effects to Soils and Water Resources Common to All Action Alternatives

Potential effects of the action alternatives on soil productivity would include soil compaction, puddling, 

displacement, erosion, areas of high soil burn severity, loss of soil organic matter, short-term changes in soil 

moisture content, changes in nutrient cycles, changes in soil fauna, and introduction of invasive and noxious 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 133

weeds. These effects can result from mechanical and non-mechanical vegetation treatments (i.e., forest thinning), 

mechanical and non-mechanical piling of activity-related debris, fireline installation, use of prescribed fire, 

fuelwood gathering, and road construction, maintenance, and obliteration activities. Mechanical forest vegetation 

treatments and fuelwood gathering have the potential to adversely affect water quality through introduction of 

sediment and additional nutrients from decomposing woody debris, particularly in thinned areas adjacent to 

stream courses. Implementation of Best Management Practices (BMPs) and Soil and Water Conservation 

Practices (SWCPs) as specified in Table 3-21 would minimize adverse impacts to soils and water quality from 

these activities.

Soil compaction, puddling and displacement would primarily be limited to the transportation systems and high 

traffic areas within mechanical vegetation treatments such as existing National Forest System roads, temporary 

access roads, skid trails, log landings, debris piling areas, and areas where fireline construction and dispersed 

fuelwood gathering occur. Road closures and curtailment of mechanical vegetation treatments during wet weather 

conditions, implementation of timing restrictions for fuelwood gathering during wet weather, and designation of 

authorized access routes (skid trails and temporary roads) and log landing sites within the project area prior to 

project implementation would minimize adverse effects to soil productivity caused by these activities. With 

implementation of applicable BMPs and SWCPs as outlined in Table 3-21, most adverse effects to soils would be 

minimized or mitigated. Additionally, pedoturbation of soils caused by seasonal wetting and drying, freezing and 

thawing, and soil organism activity would naturally ameliorate some adverse effects to soils caused by the action 

alternatives.

The effects of the proposed forest restoration activities on erosion and sediment yields depend on methods and 

equipment used, skills of the equipment operators and personnel conducting the treatments, site-specific 

conditions, storm event timing and intensity, and prescribed fire locations and burn severities. 

The risk of short-term accelerated soil erosion would be expected to increase in areas where forest thinning and 

use of prescribed fire results in soil disturbance or complete removal of vegetative ground cover. These areas are 

expected to include skid trails, log landings, temporary access roads, obliterated roads, areas where dispersed 

fuelwood gathering occurs, installed firelines and strategic fuels treatment areas to support prescribed burning 

efforts, and National Forest System roads. Since forest vegetation treatments would be conducted using both 

mechanical and non-mechanical means, adverse impacts to soils resulting from vegetation treatments would be 

minimized or mitigated to the greatest extent practicable through use of appropriate treatment methods and 

machinery designed for site-specific conditions. 

As previously noted, operability zones were developed to illustrate the operational feasibility of mechanical 

treatments. Operability zones share common attributes such as topography (slope steepness) and terrain (surface 

roughness) and therefore guide the type of harvesting operation and equipment to be used within each zone. With 

appropriate and effective implementation of BMPs and SWCPs as outlined Table 3-21, most adverse effects to 

soil productivity caused by forest vegetation treatments would be minimized or mitigated. 

The removal of forest cover can decrease raindrop interception and evapotranspiration, which can increase water 

yields from treated areas (Bosch and Hewlett 1982, Stednick 1996). In areas where the annual precipitation is 

less than 20 in (500 mm), removal of the forest canopy does not typically increase annual water yields (Bosch and 

Hewlett 1982). In drier areas, such as the proposed project site, the decrease in interception and transpiration 

caused by forest thinning is usually offset by the increase in soil evaporative losses, resulting in no net change in 

runoff as long as factors affecting runoff processes are not changed (for example, soil compaction which causes a 

shift from subsurface flow to overland flow) (MacDonald and Stednick 2003). Evapotranspiration rapidly 

recovers with vegetative regrowth in partially thinned forests. Increases in runoff due to thinning operations 

rarely persist for more than 5 to 10 years. 

Thinning of forest cover on soils currently characterized as unsatisfactory would improve soil conditions over the 

long-term by improving soil moisture and allowing greater sunlight penetration to the forest floor (i.e., sunflecks) 

resulting in an increase in grasses, forbs and shrubs in the forest understory. The increased herbaceous vegetation 

would reduce soil erosion rates by providing vegetative and litter ground cover that would intercept rain before it 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

134 Chapter 3. Affected Environment and Environmental Consequences

can reach soil surfaces and detach and entrain soil particles in runoff water. Woody debris from forest thinning 

(i.e., slash) would be lopped and scattered where doing so would not result in excessive fuel loads and increased 

wildfire risk, further mitigating potential adverse effects to these soils. Fine woody debris that is incidental to 

forest vegetation treatments (i.e., needles, leaves, twigs, cones, bark, etc.) would also remain on the ground 

following mechanical treatments to protect soil surfaces from wind and water erosion.

Prescribed fire has the potential to impact water quality by increasing sediments, dissolved solids, and nutrients in 

streams. Dissolved nutrients in stream flow primarily originate from weathering of parent materials and soils, 

decomposition of plant material and other organic matter, and anthropogenic sources. Vegetative communities 

accumulate and cycle nutrients (Tiedemann et al. 1979, 1980). Fire can disrupt nutrient cycling and cause nutrient 

volatilization, leaching, and transformations. When vegetation is consumed by fire, some of the soil and organic 

matter nutrients such as nitrogen, phosphorus, copper, iron, manganese, and zinc are volatilized and lost from the 

system, while other nutrients such as calcium, magnesium, and potassium are converted into oxides and 

accumulated in ash (DeBano et al. 1998).

The mobility and concentration of nutrients in soils determines whether or not nearby water sources are at risk of 

contamination when prescribed fire is used. Nitrate is highly mobile and is therefore subject to risk of being 

leached from burned areas and transported to either surface or ground water. Phosphorus adsorbs readily to 

sediment and organic materials. Thus, phosphorus is usually transported to streams and water bodies through soil 

erosion. Rates of soil erosion and phosphorus contamination are generally dependent on soil characteristics and 

topographic relief of the site.

Prescribed fire has the potential to alter short- and long-term soil productivity and moisture content by changing 

the amount and type of vegetation, the amount of forest floor organic matter, and surface soil texture and 

wettability. Prescribed fires typically leave greater amounts of organic matter (duff, forest litter, and large and 

small woody debris) on soil surfaces than uncontrolled fires. These materials serve as nutrient sinks, prevent soil 

particle detachment caused by raindrop impact, and capture sediments that would otherwise be transported to 

stream channels and water bodies. Following low-intensity prescribed fires, an increase in grasses and other 

herbaceous vegetation often occurs. This rapid regrowth of ground cover further immobilizes nutrients in plant 

material.

Prescribed fires that remove large amounts of vegetation from a site have potential to alter watershed hydrology. 

As vegetation is removed, evapotranspiration in the watershed decreases, thus providing greater stream flow and 

overall water yield within the watershed. Water uptake from trees is species-specific. Conifers, which are the 

dominant vegetation type within project area, generally transpire greater quantities of water than hardwoods such 

as oaks and aspen. Dense foliage and longer growing seasons promote the higher overall water uptake in 

conifers. Additionally, conifers have relatively dense crowns that intercept rainfall and allow for greater 

evaporative losses. 

Once a site has undergone loss of vegetation and removal of the litter layer, surface water can cause erosion 

problems and result in higher stream discharges. Fires not only consume portions of the litter layer, but at high 

temperatures fires can also cause hydrophobic soil conditions, thus making soils more susceptible to erosion. 

DeBano and Krammes (1966) and Robichaud (2000) observed that water repellency was dependent on the heating 

temperatures of the soils. At typical wildfire soil profile temperatures (less than 500°F) when the soil was dry, 

soil hydrophobicity occurs at shallow depths (less than 1 inch). When soils are moist (i.e. conditions that 

commonly occur during prescribed fire in the spring and fall), soil hydrophobicity was less pronounced and only 

occurred after long heating times which would typically only occur during smoldering fires. Therefore, soil 

hydrophobicity under a prescribed fire scenario would likely be minimal throughout the majority of the treatment 

area.

Fire in southwestern ponderosa pine forests has been shown to generally increase soil moisture content (Ryan and 

Covington 1986, Ower 1985, Haase 1986). In a review of literature, Hungerford and others (1991) reported that 

burning can kill many kinds of bacteria, fungi and arthropods but the extent of this effect is dependent on the 

amount of heat generated by the fire and soil moisture content. To what extent these changes result in an 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 135

impairment or degradation of soil productivity is not clearly understood. Hungerford suggests that low to 

moderate intensity prescribed fires may have minimal long-term negative effect on soil microorganisms. Kaye 

and Hart (1998) found that microbial nitrogen transformation rates increased under restored forest conditions, 

relative to the controls, suggesting higher microbial activity in the restored areas. Neary and others (1999) 

caution against the adverse effects to soil microorganisms caused by fires that become intense or are too frequent. 

Researchers have recommended maintaining soil carbon pools to maintain biologic activity (Stark and Hart, 

1997), and recommend maintaining heterogeneity in burned areas to provide suitable sites from which the 

microflora and microfauna can reestablish in burned areas (Moldenke, 1999). Prescribed fires proposed under the 

action alternatives are expected to be of low severity with small areas of medium and high severity, retaining 

unburned islands and creating a mosaic of fire effects. Low and medium severity fires burn only a portion of the 

surface organic matter – leaving adequate soil cover over much of the burned area. In general, low severity 

prescribed fire does not cause excessive erosion or sediment transport since soil cover is retained in a 

discontinuous pattern across the landscape. This type of prescribed fire would not have a long-term adverse 

impact on soil moisture content or biota. The increase in understory vegetation would improve long term soil 

structure and porosity through increased fine root volume and vegetative litter, which are important habitat 

components for soil fauna that then incorporate organic matter into soil profiles and facilitate nutrient cycling.

Installation of firelines where they do not currently exist would expose soil surfaces, increasing the risk of erosion 

by both wind and rain. Areas of high severity fire may consume forest floor organic matter, leaving soil surfaces 

hydrophobic (i.e., repellant to water) and susceptible to erosion. Initially, the greatest risk of soil erosion would 

be expected to occur in areas where prescribed fire is implemented prior to forest thinning treatments. This is due 

to greater amounts of woody debris on the ground, higher stand densities and crown bulk densities at these 

locations, resulting in increased risk of high severity fire. Rehabilitation of firelines installed during prescribed 

burning would minimize adverse impacts to soil productivity from fireline installation. Implementing prescribed 

burning under conditions that would minimize high severity fire would minimize areas where soil organic matter 

is totally consumed and prevent hydrophobic soil conditions. 

Piling of activity-related debris (slash) would disturb soil surfaces, exposing them to direct raindrop impact and 

wind. On steep terrain this would increase localized, short-term erosion rates in areas where pile burning is 

conducted. These areas would constitute a very small percentage of the overall treatment area (i.e., less than 5 

percent), so these impacts are expected to be minor. Use of appropriate BMPs and SWCPs as outlined in Table 3-

21 would mitigate most adverse effects from piling of woody debris created during forest thinning operations. 

Additionally, use of excavators with hydraulic bucket thumb attachments would minimize soil disturbance 

resulting from machine piling more effectively than dozer piling. 

Burning of slash piles has been shown to negatively affect soil biotic and chemical properties due to intense soil 

heating (Korb et al, 2004 and Seymour and Tecle, 2004). It can result in soil sterilization, increased erosion risk 

and an increased risk of invasive and noxious weeds that displace native vegetation. Pile burning sites would 

constitute a very small portion of the project area (i.e., less than 5 percent). Monitoring of these sites for the 

presence of invasive or noxious weeds following pile burning, and treatment of any infestations found would 

mitigate most adverse effects to soils caused by pile burning of slash.

Soil organic matter serves as the long-term nutrient supply for all vegetation occupying a site. It also provides 

microhabitat for most soil organisms and improves soil chemical and physical properties including soil aggregate 

stability, increased porosity, improved water holding capacity, lower bulk densities, and nutrient cycling. Initially, 

there would be an expected short-term increase in soil organic matter as a result of mechanical vegetation 

treatments as woody debris is deposited on soil surfaces during treatments. Forest thinning would also allow 

greater light penetration to soil surfaces resulting in warmer soil temperatures.

The reduction in tree vegetative cover as a result of forest thinning would decrease evapotranspiration rates and 

therefore increase soil moisture. Warmer soil temperatures and greater soil moisture content would result in 

increased soil biological activity. Increased soil biological activity results in a proportional decrease in soil 

organic matter as organisms consume soil detritus. The eventual increase in understory vegetation would result in 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

136 Chapter 3. Affected Environment and Environmental Consequences

increased litterfall and deposition of organic matter onto soil surfaces. Broadcast prescribed fire would result in 

rapid oxidation of surface organic matter and living understory biomass, causing a release or transformation of 

some soil nutrients. 

Runoff from road surfaces can detach and transport the fine material from road prisms and ditches. Sediment 

delivery directly from road surfaces to water courses is difficult to estimate since it occurs as non-point runoff. 

Sediments delivered to streams from roadside ditches may have originated from sheet or rill erosion prior to 

entering road surfaces or drainage ditches. In the absence of vehicle traffic, sediment concentrations in road 

runoff decreases over time. However, vehicle traffic, particularly trucks, can pulverize road surface aggregates, 

resulting in more fine particles that are easily transported in runoff. Additionally, the pressure of vehicular tires 

on saturated road surfaces can force fine particles from below the surface to move upward to the surface (Truebe 

and Evans 1994). Road proximity and connectivity to drainages can strongly influence sediment delivery to 

watercourses and peak flows in streams. Roads within the project area intersect numerous ephemeral drainages. 

These points of intersection occur as both culverted crossings and low-water crossings. Road-stream intersections 

are the primary location where sediments are delivered to stream courses.

Approximately 23 to 24 miles of poorly located and infrequently maintained roads would be obliterated under all 

action alternatives. Road decommissioning would entail obliteration whereby road surfaces would be ripped and 

seeded or mulched, inside ditches would be filled, road prisms outsloped, culverts and fill materials removed, 

stream crossings re-contoured, unstable sidecast or cutslopes removed or stabilized, and entrances blocked to 

prevent future access. These activities would return unproductive or marginally productive soils to a more stable, 

productive status over the long term by improving water infiltration and vegetative ground cover and reducing 

erosion hazards. Sixteen stream crossings would be returned to a more natural condition, thus reducing runoff 

and sediment delivery into ephemeral stream channels. Adverse impacts to surface water quality caused by 

stormwater runoff from road surfaces would also be minimized. Current erosion rates for roads proposed for 

obliteration are at or above tolerance erosion rates. 

Upon completion of road obliteration activities, erosion rates for these roads are expected to approach natural 

erosion rates for TEUs where these roads occur. Approximately 40 acres currently occupied by roads would be 

returned to productive status under all Action Alternatives. Table 3-22 summarizes TES units and their associated 

acreages and erosion hazard ratings that would be improved through road obliteration. Based on the values in 

Table 3-22, an estimated 100 tons of soil loss per year could be eliminated as a result of road obliteration 

activities. With implementation of appropriate BMPs and SWCPS as outlined in Table 3-21, sediment delivery to 

water courses from road construction and maintenance can be minimized, but not eliminated entirely. 

An additional indirect effect may result from the spraying of noxious weeds as a mitigation measure prior to or 

following proposed vegetation treatments that may affect water quality, however the lack of perennial flowing 

water in the analysis area limits direct effects of spraying. The effects of spraying noxious weeds are covered in 

the FEIS for Integrated Treatment of Noxious or Invasive Weeds (2005). 

While there would likely be some short-term, localized adverse effects to watersheds from the action alternatives 

in the project area in the form of increased runoff from treated areas, increased sediment delivery to ephemeral 

drainages, and increased turbidity in surface water; long-term direct and indirect effects to watersheds would be 

improved of soil and watershed function due to greater ground cover of grasses, forbs, and shrubs which would 

improve soil stability, water holding capacity, increase sediment capture in surface runoff, and minimize runon to 

travelways and roadside ditches. Since treatments would be temporally sequenced (i.e., not occurring 

simultaneously, but instead implemented over time), the likelihood of large-scale soil erosion or sediment delivery 

to streams is minimal.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 137

Table 3-22. Predicted soil erosion hazard by TEU where road obliteration would occur within the Project Area

Map 

Unit

Erosion 

Hazard

Current 

Erosion Rate

Tons/Ac/Yr

Tolerance 

Erosion Rate

Tons/Ac/Yr

Potential 

Erosion Rate

Tons/Ac/Yr

Natural 

Erosion Rate

Tons/Ac/Yr Acres1

300 Moderate 2.35 2.71 13.56 0.28 0.75

304 Slight 0.16 2.71 0.93 0.04 2.93

310 Moderate 1.70 2.71 12.38 0.68 7.26

320 Severe 1.94 1.82 16.75 0.36 0.13

322 Severe 1.42 2.71 19.59 0.44 0.33

324 Slight 0.20 2.71 0.93 0.04 24.16

401 Slight 0.16 2.71 0.93 0.04 1.14

402 Moderate 1.70 2.71 9.96 0.26 0.39

507 Slight 0.16 2.71 0.28 0.00 0.21

518 Slight 0.24 1.82 0.61 0.04 0.05

519 Slight 0.20 1.82 25.09 0.00 0.88

525 Severe 3.40 2.71 0.61 0.23 0.35

537 Slight 0.12 2.71 0.61 0.00 0.40

658 Slight 0.12 2.71 1.58 0.04 0.94

659 Moderate 2.71 2.71 24.04 0.52 0.17

660 Severe 1.86 2.71 14.29 0.33 0.16

Total 40.26

1 Acres are approximate. 

Alternative 2 – Modified Proposed Action

Forest thinning. Under the modified proposed action, a combination of commercial timber harvest treatments 

and non-commercial mechanical treatments would occur on approximately 15,200 acres. Conventional groundbased logging systems would be used to treat up to 11,100 acres within the project area. Up to 2,400 acres of steep 

slope (i.e., between 40 and 60 percent slopes) thinning would be conducted using ground-based track 

harvesters/forwarders. Steep slope excavators (known as Spiders) would be used for fuels reduction treatments. 

An additional 1,060 acres would be thinned using helicopters to yard felled trees. Activity-related slash treatments 

would be accomplished using a suite of treatment options including whole-tree skidding to remove harvested 

trees, machine piling of non-merchantable material, hand piling of non-merchantable material, mulching, 

crushing, commercial and personal use fuelwood sales, lop and scatter, and/or prescribed burning.

Ground disturbing activities such as construction and maintenance of permanent and temporary roads, clearing of 

log landings, and use of skid trails and forwarding trails would be necessary to effectively implement mechanical 

treatments.

Approximately15 miles of permanent roads, 16 miles of temporary roads, 230 acres of log landings (based on an 

estimated average of one log landing of 0.25 acres in size per 12 acres of land treated), and 1,377 miles (1,669 

acres) of skidder and forwarder trails (based on estimated area of disturbance of 15 percent) would be necessary in 

these seven treatment methods to complete proposed mechanical vegetation treatments. Helicopter logging would 

require a log landing of approximately 2 acres in size plus a service landing for helicopter fueling and 

maintenance of approximately 1 acre.

Mechanized felling can disturb and compact soils, and the use of such machines is a potential source of erosion. 

However, since felling machines do not skid logs on the ground, they typically produce less potential for soil 

erosion and soil disturbance (and therefore erosion potential) than tractor or rubber-tired log skidders. The effects 

of felling on soil erosion rates are not usually studied independent of skidding and forwarding/yarding. Soil 

disturbance caused by trees striking the ground during felling is generally considered negligible.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

138 Chapter 3. Affected Environment and Environmental Consequences

Soil erosion rates resulting from forest thinning treatments tend to be positively correlated with the percentage of 

bare soil and the amount of surface soil disturbance, and these two factors are typically proportional to the number 

of trees being harvested (Haupt and Kidd 1965). In general, soil erosion rates are acceptably low when the 

proportion of bare soil is less than 30 percent (Robichaud 2010, Benavides-Solorio and MacDonald 2005; Swank 

et al 1989). In northern New Mexico, a series of rainfall simulations (6 in per hr. for one hour on successive days) 

was performed on control plots, lightly thinned plots with the slash piled, and lightly thinned plots with the slash 

scattered (Madrid 2005). The results indicate that thinning had no effect on runoff or the amount of bare soil, but 

the mean sediment yields from the second (wet) simulation on the thinned plots was up to three times higher than 

the mean sediment yield of 1.8 tons per acre from the control plots. 

The amount of soil disturbance caused by fuel reduction thinning would depend, to a large degree, on the amount 

and type of skidding and yarding activities. Tractor skidding and forwarding generally requires an extensive 

network of skid trails and roads. Helicopter logging typically results in the least soil disturbance since trees are 

lifted from the sites where felled and fully suspended over the ground until placed at the log landing. In a review 

of detrimental soil disturbance associated with timber harvest systems in the northern region of the USFS, Reeves, 

et al. found that the frequency of detrimental soil disturbance was greatest for ground-based logging systems 

followed by skyline, then helicopter logging systems (USDA 2011). Tractor skidding, therefore, is expected to 

produce the greatest amount of soil disturbance during logging, followed by forwarding, then helicopter yarding 

(Rice and others 1972; Stednick 1987). 

While thinning a stand of trees to a desired residual density requires access to the entire stand, pre-commercial 

thinning typically requires little or no yarding and can be one of the least disturbing forest management practices 

(Robichaud 2010). The amount of disturbance caused by skidding and forwarding would depend on site-specific 

characteristics, timing of operations, and the percentage of each stand that is thinned. Table 3-23 below 

summarizes modeled hillslope erosion and sediment delivery rates by TES mapping unit based on slope classes 

for forest thinning treatments under the Modified Proposed Action. Table 3-24 provides a summary of predicted 

hillslope erosion and sediment delivery for each watershed in the project area as a result of forest thinning 

activities.

Modeled soil erosion rates indicate that forest thinning could result in a slight increase in short term erosion for 

TEUs within treated areas followed by improved soil stability over the long term (Table 3-24). A predicted 

maximum of 117.3 tons of sediment delivered to ephemeral stream courses throughout the entire treatment area 

(15,138.4 acres) could occur as a result of forest thinning treatments under the modified proposed action. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 139

Table 3-23. Predicted soil erosion rates and sediment yield by TES mapping unit in the Project area where forest 

thinning treatments would be conducted

Map 

Unit

Slope

(%) Acres

Predicted Sediment 

Delivery in Year of 

Disturbance

(Tons/Sq Mi)

Average Annual Hillslope 

Erosion

(Tons/Sq Mi/Yr)

6 0-5 38 0.0 0.0

10 0-5 126 0.0 0.0

37 0-5 179 0.0 0.0

300 15-40 50 0.0 – 6.4 0.0 - 0.3

302 15-40 248 0.0 – 6.4 0.0 - 0.3

304 0-15 1,934 0.0 0.0

310 15-40 328 0.0 – 6.4 0.0 - 0.3

320 40-80 1,779 6.4 – 12.8 0.3 – 0.6

322 40-80 4,687 6.4 – 12.8 0.3 – 0.6

324 0-15 24 0.0 0.0

325 0-15 238 0.0 0.0

401 0-15 247 0.0 0.0

402 15-40 25 0.0 – 6.4 0.0 - 0.3

405 0-15 104 0.0 0.0

407 15-40 8 0.0 – 6.4 0.0 - 0.3

507 0-15 167 0.0 0.0

518 0-15 737 0.0 0.0

519 0-15 73 0.0 0.0

525 15-40 1,070 0.0 – 6.4 0.0 - 0.3

537 0-15 12 0.0 0.0

539 40-120 130 6.4 – 12.8 0.3 – 0.6

563 0-15 477 0.0 0.0

564 15-40 80 0.0 – 6.4 0.0 - 0.3

565 0-15 416 0.0 0.0

658 0-15 854 0.0 0.0

659 15-40 1,109 0.0 – 6.4 0.0 - 0.3

660 40-120 38 6.4 – 12.8 0.3 – 0.6
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

140 Chapter 3. Affected Environment and Environmental Consequences

Table 3-24. Predicted soil erosion rates and sediment yield for watersheds in the Project Area where forest thinning 

treatments would be conducted.

Watershed Name

Proposed Treatment 

Acres

Total Sediment 

Delivery In Year 

Of Disturbance

(Tons/Watershed)

Average Annual 

Hillslope Erosion

(Tons/Watershed

) 

Cataract Creek Headwaters 3,726 34.52 1.83

Devil Dog Canyon 868 4.89 0.41

Dogtown Wash 553 4.46 0.27

Johnson Creek 2,630 18.46 1.32

Meath Wash 1,564 8.83 0.74

Upper Hell Canyon 5,797 46.14 9.14

Grand Total 15,138 117.30 13.71

These erosion rates do not exceed tolerance erosion rates for any of the TES units within the project area as 

outlined in the Kaibab National Forest TES (Brewer et al. 1991). As grasses, forbs, and shrubs begin to occupy 

openings, a proportional decrease in accelerated soil erosion is expected. Many of the proposed vegetation 

treatment areas currently have relatively dense overstory conditions with ground cover consisting primarily of 

forest litter, including coarse woody debris, rather than herbaceous vegetation. These conditions do not provide 

the level of soil protection that vegetative ground cover and the associated fine root biomass provides. Vegetative 

ground cover and fine litter tend to improve soil aggregate stability and prevent soil particle detachment and 

transport through root anchoring and through root exudates and byproducts of organic matter breakdown that 

bind soil microaggregates. Forest thinning would provide more open tree canopies and stand structures that 

encourage development of vegetative ground cover, and logging debris such as tree limbs, tops, and nonmerchantable woody material would add to existing surface organic matter.

Forest canopy openings would allow sunlight and wind to penetrate, warm, and dry the debris, which could 

increase potential fire intensity and severity until the residual woody debris is treated or sufficiently decomposed 

to abate fire hazard. Overall, the long-term risk of stand-replacing wildfire that adversely affects soils would be 

reduced. Use of appropriate BMPs and SWCPs as outlined in Table 3-21 during project implementation would 

minimize or mitigate any adverse effects to soils or watersheds from forest vegetation treatments. It is very 

unlikely that all thinning treatments would be conducted concurrently, minimizing the potential for soil erosion 

from large areas and associated sediment delivery to ephemeral stream channels. soils would be reduced 

Permanent and Temporary Roads. Roads represent the greatest risk of accelerated soil erosion throughout the 

proposed project area. Although some roads within the project area have been installed and are maintained using 

Best Management Practices designed to prevent and minimize erosion and sedimentation from road surfaces, 

some roads in the project area exhibit excessive erosion and sediment delivery due to poor location and design 

combined with infrequent road maintenance. Practices such as broad-based dips, waterbars, lead-out ditches 

(turnouts), aggregate fill on road surfaces, filter fabric, sediment traps, seeding of ditches with native grasses, and 

filter barriers/check dams are commonly used to minimize soil particle detachment from road prisms and prevent 

surface water quality impacts from roads. These practices have been shown to be effective at mitigating erosion 

from road surfaces and protecting water quality (Burroughs and King 1989). 

Permanent road construction would require activities such as clearing, grubbing, sidecasting, cutting and filling, 

grading, compacting, and piling and burning of woody debris. Permanent road construction would commit areas 

incorporated into road prisms to non-productive status for the forseeable future (i.e., at least 50 years). Based on a 

traveled way width of 14 feet and a clearing width of 6 feet on each side of the traveled way for ditches and fill 

slopes, approximately 48 acres of land would be removed from timber and forage production within the project 

area under the Modified Proposed Action. Road surfaces typically have much lower infiltration rates than 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 141

undisturbed forest soils (Robichaud 2000) and therefore contribute to increased overland flow which can detach 

and entrain soil particles in stormwater runoff.

Temporary roads are generally minimum-standard roads designed for short-term use during a specific project. 

Usually, temporary roads are simply a bladed lane pushed into the project area with BMPs and SWCPs installed 

during construction. Use of temporary roads is typically limited to dry or frozen conditions to minimize rutting 

and compaction. Temporary roads would be stabilized and obliterated upon completion of activities. Based on a 

traveled way width of 12 feet and a clearing width of four feet on each side of the traveled way, approximately 39 

acres of land would be temporarily removed from timber and forage production. Obliteration activities such as 

decompacting, removal of temporary fill material, recontouring, placement of woody debris, and seeding with 

native grasses and forbs would facilitate rapid return of temporary roads to productive status. 

Table 3-25 and Table 3-26 provide predicted sediment delivery from construction and maintenance of permanent 

and temporary roads in the project area, respectively. The range of values given for road sedimentation represent 

the amount of sediment delivered across a buffer, and the amount delivered to a stream crossing. Roads with 

buffers greater than 1 ft. would generate less sediment. The summary table shows that roads generate significant 

amounts of sediment within a watershed, even when traffic is low. Road management strategies such as 

minimizing rutting, minimizing stream crossings, maximizing the use of buffers between roads and streams, and 

implementation and maintenance of BMPs and SWCPs have been shown to minimize soil erosion and 

sedimentation. 

Another alternative to reduce sedimentation from the road network is to reduce the road density within the 

watershed by removing roads that are no longer needed for modern timber operations. Sediment delivery 

associated with fuel management activities can be offset with a decrease in sediment from improved road 

management or a reduction in road density. Note that average annual erosion rates are the same as those for the 

year of disturbance. This is because roads generally have no protetive ground cover, so erosion rates from road 

surfaces generally remain constant throughout the life of the road. Temporary roads would be stabilized with 

BMPs and SWCPs designed to prevent erosion of road surfaces and sediment delivery to ephemeral channels. 

Therefore, average annual erosion rates following decommissioning of temporary roads are expected to be 

substantially lower than those predicted by the model. 

Table 3-25. Predicted soil erosion rates and sediment yield for Terrestrial Ecosystem Units Where Permanent Roads 

Would be Constructed and Maintained

Map Unit

Slope

(%) Acres of Roads

Predicted Sediment 

Delivery in Year of 

Disturbance

(Tons/Sq Mi)

Average Annual 

Hillslope Erosion

(Tons/Sq Mi/Yr)

0010 0-5 0.24 0.0 – 7.7 0.0 – 7.7

0304 0-15 2.20 7.7 – 9.3 7.7 – 9.3

0310 15-40 16.71 7.7 – 28.2 7.7 – 28.2

0324 0-15 20.55 0.0 – 9.3 0.0 – 9.3

0507 0-15 0.12 0.0 – 9.3 0.0 – 9.3

0519 0-15 0.24 0.0 – 9.3 0.0 – 9.3

0537 0-15 2.74 0.0 – 9.3 0.0 – 9.3

0564 15-40 4.46 7.7 – 28.2 7.7 – 28.2
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

142 Chapter 3. Affected Environment and Environmental Consequences

Table 3-26. Predicted Soil Erosion Rates and Sediment Yield for Terrestrial Ecosystem Units Where Temporary Roads 

Would be Constructed and Maintained

Map Unit

Slope

(%) Acres of Roads

Predicted Sediment 

Delivery in Year of 

Disturbance

(Tons/Sq Mi)

Average Annual 

Hillslope Erosion

(Tons/Sq Mi/Yr)

0010 0-5 0.82 3.6 – 7.7 3.6 – 7.7

0310 15-40 1.76 7.7 – 28.2 7.7 – 28.2

0320 40-80 0.19 18.5 – 56.8 18.5 – 56.8

0322 40-80 0.09 18.5 – 56.8 18.5 – 56.8

0324 0-15 11.02 0.0 – 9.3 0.0 – 9.3

0401 0-15 0.45 0.0 – 9.3 0.0 – 9.3

0402 15-40 0.17 7.7 – 28.2 7.7 – 28.2

0405 0-15 0.18 0.0 – 9.3 0.0 – 9.3

0507 0-15 0.08 0.0 – 9.3 0.0 – 9.3

0518 0-15 1.36 0.0 – 9.3 0.0 – 9.3

0519 0-15 4.58 0.0 – 9.3 0.0 – 9.3

0537 0-15 3.16 0.0 – 9.3 0.0 – 9.3

0563 0-15 0.37 0.0 – 9.3 0.0 – 9.3

0564 15-40 0.49 7.7 – 28.2 7.7 – 28.2

0565 0-15 0.14 0.0 – 9.3 0.0 – 9.3

0658 0-15 1.73 0.0 – 9.3 0.0 – 9.3

0659 15-40 0.19 7.7 – 28.2 7.7 – 28.2

0660 40-120 0.01 18.5 – 63.7 18.5 – 63.7

Predicted hillslope erosion and sediment delivery rates would not exceed tolerance thresholds for any TEUs 

within the project area as a result of road construction, maintenance or use. Decommissioning of 23 miles of 

poorly located and infrequently maintained roads and temporary roads would improve overall soil condition 

within the project area by returning unproductive areas to productive status. Based on an average road width of 

12 feet with no clearing width on either side, a conservative estimate of the areal extent of soils that would be 

improved through road obliteration would be approximately 33.5 acres. 

Bixler Trailhead and Trail. Conversion of approximately 1 mile of Forest Service Road (FSR) 45 (from Bixler 

saddle south) to a non-motorized trail would improve soil condition by eliminating the potential for motor vehicle 

traffic to occur on this road segment. This road is found in TES map units 302 (0.31 ac.), 310 (0.26 ac.), 322 (0.12 

ac.), 659 (0.06 ac.), and 660 (0.003 ac.). Pulverization of soil aggregates on the road surface and entrainment of 

soil particles in stormwater runoff would therefore be decreased on approximately 0.77 acres, or half of the 

existing road width of this segment of FSR 45 under this alternative. Implementation of recreational trail BMPs 

and SWCPs during construction and maintenance of the trail would minimize or mitigate any adverse effects to 

soils or watershed resources.

The proposed Bixler Trailhead and parking area would be approximately 0.25 acres in size and constructed in 

TES map unit 537. This portion of TES map unit 537 would therefore be removed from productivity for the 

foreseeable future (i.e., 50 years). The parking area would consist of native fill material and would be constructed 

using appropriate BMPs and SWCPs to minimize adverse impacts to surface water.

Prescribed Fire Treatments. Strategic fuel treatments to reduce surface, ladder, and canopy fuels would extend 

for up to 300 feet on each side of prescribed fire control lines. An estimated 2,500 acres would receive noncommercial vegetation treatments such as hand-felling techniques or, where practical, treatments would be 

conducted using mechanized equipment. These treatments would be necessary to prepare stands on steeper slopes 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 143

for prescribed burning. Where strategic fuels treatments are conducted using mechanical means, effects to soils 

resources would be approximately the same as mechanical forest thinning treatments.

Table 3-27 below summarizes approximate TES map unit acreages where strategic fuel treatments would be 

implemented. These treatments would result in removal of much of the woody vegetation and woody debris that 

contributes to soil stability and nutrient availability. However, these treatments would also reduce soil burn 

severity by removing materials that contribute to smoldering fire conditions resulting in soil hydrophobicity and 

the resulting increased stormwater runoff and entrainment and transport of soil particles. Long term soil 

conditions would be improved as strategic fuels treatment areas naturally revegetate with grasses, forbs and 

shrubs following use of prescribed fire.

Sediment delivery rates for prescribed fire within each HUC12 watershed were modeled using the Erosion Risk 

Management Tool (ERMiT) (Robichaud et al. 2006). Table 3-27, Table 3-28, and Table 3-29 provide a summary 

of predicted erosion rates and associated acreages within each HUC 12 subwatershed based on soil burn severities 

that bracket the possible range of effects from prescribed burning. Sediment yield estimates are based on a ten 

percent probability that calculated sediment yield rates would be exceeded in any given year following treatment 

for the five years modeled. This means that over the long term approximately 10 percent of precipitation events 

would result in sediment yields above those predicted. It does not mean that one out of every 10 events would 

result in sediment yields above those predicted by the model.

Table 3-27. Terrestrial Ecosystem Survey map unit acreages and associated erosion hazard ratings for areas where 

strategic fuels treatments would be conducted

Map 

Unit

Soil 

Condition

Erosion 

Hazard

Current 

Erosion 

Rate

Tons/Ac/Yr

Tolerance 

Erosion 

Rate

Tons/Ac/Yr

Potential 

Erosion Rate

Tons/Ac/Yr

Slope

(%) Acres1

10 Satisfactory Slight 0.53 2.71 2.47 0-5 9 

300 Satisfactory Moderate 2.35 2.71 13.56 15-40 104

302 Satisfactory Severe 2.14 2.71 15.50 15-40 29

304 Satisfactory Slight 0.16 2.71 0.93 0-15 2 

310 Satisfactory Moderate 1.70 2.71 12.38 15-40 206

320 Unsatisfactory Severe 1.94 1.82 16.75 40-80 135

322 Satisfactory Severe 1.42 2.71 19.59 40-80 778

324 Satisfactory Slight 0.20 2.71 0.93 0-15 248

401 Satisfactory Slight 0.16 2.71 0.93 0-15 1 

402 Unsatisfactory Moderate 1.70 2.71 9.96 15-40 40

537 Satisfactory Slight 0.12 2.71 0.61 0-15 7 

539 Unsatisfactory Severe 7.49 2.71 14.37 40-120 2 

658 Satisfactory Slight 0.12 2.71 1.58 0-15 132

659 Satisfactory Moderate 2.71 2.71 24.04 15-40 377

660 Satisfactory Severe 1.86 2.71 14.29 40-120 397

Total 2,467

1 Acres are approximate. 

The model resulted in 7,341 precipitation events and an annual average precipitation of approximately 22 inches 

based on 100-year mean annual averages. Approximately 650 precipitation events resulted in runoff estimates 

ranging from 1.3 inches to 2.0 inches. Annual runoff from winter snowmelt ranged between 0.65 and 1.4 inches. 

As shown in Table 3-28, low severity prescribed fire would result in minor increases in sediment delivery rates 

within each HUC12 subwatershed. Based on estimated sediment yield rates over the five year period following 

treatment, approximately 17,425 tons of soil loss is possible as a result of low severity prescribed fire treatments 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

144 Chapter 3. Affected Environment and Environmental Consequences

for the Bill Williams Mountain Restoration Project. Since prescribed burning treatments would be implemented 

in phases and not all within a single year, it is unlikely that large pulses of sediment would be transported from 

treated areas to drainages or downslope locations. Also, since forest thinning would be conducted in some of the 

prescribed fire treatment areas prior to burning, resulting in increased size and extent of forest openings and 

increased ground cover of grasses and forbs that help to carry fire and provide a mosaic of fire effects, recovery of 

areas treated with low severity prescribed fire is expected to be rapid.

Low severity fire rarely consumes all of the forest floor litter, leaving some protective ground cover intact. Some 

of the nutrients contained in the organic matter would be converted to inorganic forms which are then available 

for plant uptake. The increase in plant available nutrients would improve short-term soil productivity, resulting in 

a rapid growth response of herbaceous vegetative cover. Low severity prescribed fire is therefore expected to 

result in a minor short-term increase in soil erosion rates followed by long-term improvement in the stability, 

function, and productivity of forest soils in the project area. Since low severity fire has historically been a natural 

occurrence in these ecosystems, these impacts do not necessarily need to be construed as negative, as they could 

also occur after a naturally-caused wildfire. These vegetation types and associated soils are thus ecologically 

adapted to low severity fire, and to resulting fire impacts. Predicted five-year average erosion rates do not exceed 

tolerance erosion rates as outlined in Table 3-28 for any watersheds within the proposed project area.

Table 3-28. Predicted sediment delivery rates for watersheds in the Bill Williams Mountain Restoration Project area 

under low severity prescribed fire treatments (USDA 2010)

Watershed

Name

Total

Acres

Total Sediment Delivery

(Tons/Watershed) Five Year 

Average

Year 1 Year 2 Year 3 Year 4 Year 5 (Tons/Ac)

Cataract 

Creek 

Headwaters

5,148 2,899.04 2,424.25 556.42 526.25 259.64 0.26

Dogtown 

Wash

816 185.88 156.18 36.84 34.99 17.68 0.11

Johnson 

Creek

2,719 1,188.57 995.21 232.56 218.69 107.05 0.20

Upper Hell 

Canyon

6,007 3,334.53 2,770.03 618.63 577.63 284.64 0.25

Grand Total 14,690 7,608.02 6,345.67 1,444.45 1,357.56 669.01 0.82

Note: Sediment delivery rates were modeled for the year of prescribed fire use and four years following prescribed fire treatments.

The potential for moderate severity prescribed fire increases in areas where excessive fuel loads currently exist, 

where forest thinning does not adequately reduce tree density, and where forest thinning results in large amounts 

of woody debris within a given treatment area. There would be an increased risk of accelerated soil erosion where 

moderate severity prescribed fire occurs. Table 3-29 provides an estimate of sediment delivery based on moderate 

burn severity over 25 percent of the total prescribed burn treatment area with 75 percent representing low burn 

severity in each watershed. This is an unlikely scenario, but was included in this analysis since some areas may 

exhibit moderate burn severity and these potential impacts should be analyzed and disclosed. 

A more likely scenario would be the occurrence of small areas (0.10 – 3 acres) that exhibit moderate burn severity 

intermingled with areas dominated by low burn severity conditions. It cannot be predicted with accuracy where 

such conditions would occur within proposed treatment areas. With appropriate fuels management techniques 

such as lopping and scattering of activity-related woody debris and piling and burning debris where necessary, 

adverse impacts to soils caused by moderate severity fire would be minimized.

As shown in Table 3-29, prescribed fire that results in an average of 25 percent of treated watersheds exhibiting 

moderate burn severity would result in a proportional increase in sediment delivery to water courses of 

approximately 12 percent above low burn severity prescribed fire conditions for the five year average following 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 145

treatment. Sediment yields calculated by the ERMiT model indicate that erosion rates for moderate soil burn 

severity would begin to stabilize by the third year following treatment and become equal to sediment yields 

produced by low soil burn severity by year 3. Under this scenario, soil erosion rates would not exceed tolerance 

thresholds as outlined in Table 3-29 for any of the watersheds proposed for prescribed fire treatment.

Table 3-29. Predicted sediment delivery rates for watersheds in the Project Area

Watershed

Name

Total 

Acres

Total Sediment Delivery

(Tons/Watershed) Five Year 

Average

Year 1 Year 2 Year 3 Year 4 Year 5 (Tons/Ac)

Cataract 

Creek 

Headwaters

5,148 3,336.19 2,840.96 556.42 526.25 259.64 0.29

Dogtown 

Wash

816 212.62 181.58 36.84 34.99 17.68 0.12

Johnson 

Creek

2,719 1,371.46 1,163.86 232.56 218.69 107.05 0.23

Upper Hell 

Canyon

6,007 3,871.80 3,279.80 618.63 577.63 284.64 0.29

Grand Total 14,690 8,792.07 7,466.2 1444.45 1357.56 669.01 0.93

Note: Project area where 75 percent of each prescribed burn treatment results in low burn severity and 25 percent results in moderate burn 

severity (USDA 2010). Sediment delivery rates were modeled for the year of prescribed fire use and four years following prescribed fire 

treatments.

High severity prescribed fire would result in considerable risk of accelerated soil erosion where such conditions 

occur. While very unlikely, this would represent a worst case scenario with regard to the use of prescribed fire 

and would more accurately reflect soils response to wildfire. It is possible that small, isolated occurrances of high 

severity burn conditions would occur where excessive fuel loads exist or where conditions result in atypical fire 

behavior for brief periods. Such areas would likely exhibit accelerated soil erosion for longer periods and at 

greater rates than low or moderate soil severity burn areas due to high levels of consumption of forest floor fuels, 

vegetative cover, and soil seed banks leaving such areas unprotected and potentially hydrophobic. Predicted 

accelerated soil erosion rates for watersheds where 25 percent of each treatment area is subjected to moderate soil 

burn severity and 25 percent is subjected to high soil burn severity, with remaining watershed acreages (50 

percent) subjected to low soil burn severity are summarized in Table 3-30. 

As outlined in Table 3-30, prescribed fire that results in 50 percent of treated areas subjected to low soil burn 

severity, 25 percent subjected to moderate soil burn severity, and 25 percent subjected to high soil burn severity 

would result in a proportional increase in sediment delivery to water courses of 40 percent above the low soil burn 

severity values. While these rates would not be above tolerance erosion threshold rates outlined, they would 

result in substantial detrimental effects to soil productivity and stability as well as ephemeral and intermittent 

water courses and downstream waterbodies within and outside of the project boundary. These effects would 

include loss of soil A horizon thickness, soil hydrophobicity, increased stormwater runoff, stream sedimentation, 

channel embeddedness, increased surface water turbidity, and changes to surface water chemistry and temperature 

in drainages and impoundments. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

146 Chapter 3. Affected Environment and Environmental Consequences

Table 3-30. Predicted sediment delivery rates for watersheds in the project area where 50 percent of prescribed burn 

treatment results in low soil burn severity, 25 percent results in moderate burn severity, and 25 percent results in 

high burn severity

Watershed

Name

Total

Acres

Total Sediment Delivery

(Tons/Watershed) Five Year 

Average

Year 1 Year 2 Year 3 Year 4 Year 5 (Tons/Ac)

Cataract 

Creek 

Headwaters

5,148 4,727.90 3,925.30 1,040.37 842.55 397.78 0.42

Dogtown 

Wash

816 309.79 260.73 72.95 59.46 30.34 0.18

Johnson 

Creek

2,719 4,727.90 3,925.30 1,040.37 842.55 397.78 0.42

Upper Hell 

Canyon

6,007 2,002.00 1,660.52 453.61 364.79 173.39 0.34

Grand Total 14,690 11,767.59 9,771.85 2,607.3 2109.35 999.29 1.36

Direct and indirect effects to soils and watershed resources from prescribed fire treatments in Ecosystem 

Management Area 6 – the Arizona Bugbane (Actaea arizonica) Botanical Area (490 acres) would be similar to the 

use of prescribed fire in other watersheds in the analysis area. However, site-specific design features and 

mitigation measures have been developed to minimize or mitigate adverse effects to soils, vegetation, and water 

quality in this special habitat. Table 3-31 provides a summary of TES units that occur in the Arizona Bugbane 

Botanical Area and their associated acreages and erosion hazard ratings. With implementation of BMPs, SWCPs, 

and site specific design features and mitigation measures, direct or indirect adverse effects to these TES map units 

are not anticipated.

Table 3-31. Terrestrial Ecosystem Survey map units within the Arizona Bugbane Botanical Area

Map 

Unit

Erosion 

Hazard

Current 

Erosion Rate

Tons/Ac/Yr

Tolerance 

Erosion Rate

Tons/Ac/Yr

Potential 

Erosion Rate

Tons/Ac/Yr

Slope

(%) Acres1

302 Severe 2.14 2.71 15.50 15-40 4 

322 Severe 1.42 2.71 19.59 40-80 280

324 Slight 0.20 2.71 0.93 0-15 10

658 Slight 0.12 2.71 1.58 0-15 41

659 Moderate 2.71 2.71 24.04 15-40 73

660 Severe 1.86 2.71 14.29 40-120 83

Total 490

1 Acres are approximate. 

Alternative 3 

Forest thinning. Under Alternative 3, direct and indirect effects from forest thinning would be similar to those of 

Alternative 2 with the following exceptions: There would be no ground-based logging on slopes greater than 40 

percent; thinning in MSO PAC and MSO mixed conifer recovery nest roost habitat would be restricted to 9 inches 

DBH and below; and no prescribed burning in the Arizona Bugbane Botanical Area. There would therefore be no 

soil disturbance associated with ground-based logging on slopes greater than 40 percent. A projected maximum 

of 71 acres of potential soil disturbance from tree felling and forwarding would therefore not occur as a result of 

selection of Alternative 3. Additionally, 10 acres of soil disturbance from log landing installation and use (based 

on 0.25 acres of landings per 12 acres of land treated) would not occur under this alternative. If helicopter 

logging is employed on slopes greater than 40 percent, minimal damage to soils would be expected as a result of 

log extraction since logs would be fully suspended during transport from the sites where trees are felled to the log 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 147

landing. Table 3-32 provides TES map unit acres and associated erosion hazard ratings in areas that would be 

excluded from treatment using ground-based harvesting systems under Alternative 3.

Modeled hillslope erosion and sediment delivery rates for TES map units that would be excluded from ground 

based harvesting treatment under Alternative 3 are summarized in Table 3-32. Based on an anticipated area of 

disturbance of approximately 15 percent within each TES unit, predicted reductions in sediment delivery to water 

courses through ground-based harvesting would range from 0.62-1.34 total tons. Reduction in average annual 

hillslope erosion through exclusion of ground-based harvesting treatments would range from 0.029 to 0.063 tons 

per acre per year.

Table 3-32. Terrestrial Ecosystem Units and associated erosion hazard ratings that would be excluded from groundbased harvesting systems under Alternative 3 within the Project Area

Map 

Unit

Erosion 

Hazard

Current 

Erosion Rate

Tons/Ac/Yr

Tolerance 

Erosion Rate

Tons/Ac/Yr

Potential 

Erosion Rate

Tons/Ac/Yr

Percent

of Cable

Yarding

Treatmen

t 

Slope

(%) Acres

300 Moderate 2.35 2.71 13.56 0 15-40 9 

310 Moderate 1.70 2.71 12.38 0 15-40 1 

320 Severe 1.94 1.82 16.75 0 40-80 70

322 Severe 1.42 2.71 19.59 0 40-80 264

659 Moderate 2.71 2.71 24.04 0 15-40 57

660 Severe 1.86 2.71 14.29 0 40-120 71

Total 472

Since no wheels or tracks are disturbing soils on slopes greater than 40 percent under this alternative, the areal 

extent of soil disturbance is generally limited to areas where trees are felled and logs are landed (0.25 acres per 12 

acres treated). Helicopter yarding typically results in much less soil disturbance than ground-based logging 

systems since logs are fully suspended from the site where trees are felled to the landing. Log landings for 

helicopter yarding are typically larger than those for skidding and forwarding operations due to the rapid speed at 

which harvested volume is accumulated at the landing in relation to loading for haul in comparison to skidding 

and forwarding methods. 

It should be noted that under Alternative 3, forest restoration would not be fully achieved as removal of trees 

greater than 9 inches DBH in MSO PAC and pine/oak habitat where slopes exceed 40 percent would not occur. 

Soil stability and ecologic function in these areas would therefore not be improved. Soil stability would continue 

to depend primarily on forest litter to protect soil surfaces rather than vegetative ground cover. As previously 

discussed, vegetative ground cover provides better water infiltration, percolation, soil porosity, aggregate stability, 

and nutrient cycling than forest litter alone. However, the MSO PAC and pine/oak habitat where slopes exceed 40 

percent would be buffered by areas that receive full restoration treatment, thereby limiting the areal extent of areas 

at risk of high severity wildfire.

Permanent and Temporary Roads. Direct and indirect effects to soil resources from new road construction, 

maintenance, and use would be similar to the Modified Proposed Action. However, Alternative 3 would include 

construction of 22 miles of permanent roads, which are 7 more miles than under the Proposed Action. Based on a 

road width of 14 feet and a clearing width of 6 feet on each side of the traveled way for ditches and fill slopes, soil 

disturbance for permanent road access under Alternative 3 would be approximately 22 acres more than under 

Alternative 2 at 70.2 acres. Therefore, a combined total of 92.2 acres would be converted to unproductive status 

for permanent road installation. 

Direct and indirect effects to soils resources caused by obliteration of approximately 23 miles of poorly located 

roads would be the same as Alternative 2. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

148 Chapter 3. Affected Environment and Environmental Consequences

Bixler Trailhead and Trail. Since Alternative 3 is the same as the modified proposed action with regard to the 

Bixler trailhead and trail, direct and indirect effects to soils resources would be the same as the modified proposed 

action. 

Prescribed Fire Treatments. Direct and indirect effects to soils resources from prescribed fire treatments would 

be similar to the modified proposed action with the exception of the Arizona Bugbane (Actaea arizonica) 

Botanical Area which would not be subjected to prescribed fire. There would therefore be no direct or indirect 

effects to soils or watershed resources within the Arizona Bugbane Botanical Area as a result of prescribed fire 

use under Alternative 3. 

Alternative 4 

Forest thinning. Under Alternative 4, a combination of commercial timber harvest and non-commercial 

mechanical treatments would occur on approximately 11,150 acres. Mechanical vegetation treatments would be 

conducted only on slopes less than 40 percent. Table 3-33 provides a summary of TES map unit acreages and 

their associated erosion hazard ratings for areas mechanical vegetation treatments would be conducted under 

Alternative 4. Areas where slopes exceed 40 percent were excluded from the analysis of this alternative.

Table 3-34 below presents modeled sediment delivery and hillslope erosion rates by TES map unit based on slope 

classes for forest thinning treatments under Alternative 4. Table 3-35 provides a summary of hillslope erosion and 

sediment delivery for each watershed in the project area as a result of forest thinning activities under Alternative 

4. 

Table 3-33. Terrestrial Ecosystem Survey map units and associated erosion hazard ratings for operability zones 1, 2, 

and 6 with slopes less than 40 percent

Map 

Unit

Soil 

Condition

Erosion 

Hazard

Current 

Erosion 

Rate

Tons/Ac/Yr

Tolerance 

Erosion 

Rate

Tons/Ac/Yr

Potential 

Erosion 

Rate

Tons/Ac/Yr

Slope

(%) Acres

6 Satisfactory Slight 0.65 2.71 2.10 0-5 37.9

10 Satisfactory Slight 0.53 2.71 2.47 0-5 125.5

36 Satisfactory Slight 0.36 2.71 0.85 0-5 0.1

300 Satisfactory Moderate 2.35 2.71 13.56 15-40 130.3

302 Satisfactory Severe 2.14 2.71 15.50 15-40 17.2

304 Satisfactory Slight 0.16 2.71 0.93 0-15 248.3

310 Satisfactory Moderate 1.70 2.71 12.38 15-40 1,680.6

324 Satisfactory Slight 0.20 2.71 0.93 0-15 4,637.0

401 Satisfactory Slight 0.16 2.71 0.93 0-15 237.8

402 Unsatisfactory Moderate 1.70 2.71 9.96 15-40 199.9

405 Satisfactory Slight 0.20 2.71 0.61 0-15 24.9

407 Unsatisfactory Severe 3.60 2.71 14.37 15-40 104.1

507 Satisfactory Slight 0.16 2.71 0.28 0-15 9.3

518 Satisfactory Slight 0.24 1.82 0.61 0-15 167.1

519 Satisfactory Slight 0.20 1.82 25.09 0-15 737.0

525 Unsatisfactory Severe 3.40 2.71 0.61 15-40 52.7

537 Satisfactory Slight 0.12 2.71 0.61 0-15 1,069.7

563 Satisfactory Slight 0.20 2.71 0.61 0-15 129.8

564 Unsatisfactory Severe 3.64 2.71 12.38 15-40 477.0

565 Satisfactory Slight 0.36 1.82 0.61 0-15 80.1

658 Satisfactory Slight 0.12 2.71 1.58 0-15 342.1

659 Satisfactory Moderate 2.71 2.71 24.04 15-40 337.9

Total 10,920.86
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 149

Table 3-34. Predicted sediment yield in year of disturbance and annual hillslope erosion by TES mapping unit in 

operability zones 1, 2 and 6

Map Unit

Slope

(%)

Treatment

Acres

Predicted Sediment 

Delivery in Year of 

Disturbance

(Tons/Sq Mi)

Average Annual 

Hillslope Erosion

(Tons/Sq Mi/Yr)

6 0-5 37.9 0.0 0.0

10 0-5 125.5 0.0 0.0

36 0-5 0.1 0.0 0.0

300 15-40 130.3 0.0 – 6.4 0.0 - 0.3

302 15-40 17.2 0.0 – 6.4 0.0 - 0.3

304 0-15 248.3 0.0 0.0

310 15-40 1,680.6 0.0 – 6.4 0.0 - 0.3

324 0-15 4,637.0 0.0 0.0

401 0-15 237.8 0.0 0.0

402 15-40 199.9 0.0 – 6.4 0.0 - 0.3

405 0-15 24.9 0.0 0.0

407 15-40 104.1 0.0 – 6.4 0.0 - 0.3

507 0-15 9.3 0.0 0.0

518 0-15 167.1 0.0 0.0

519 0-15 737.0 0.0 0.0

525 15-40 52.7 0.0 – 6.4 0.0 - 0.3

537 0-15 1,069.7 0.0 0.0

563 0-15 129.8 0.0 0.0

564 15-40 477.0 0.0 – 6.4 0.0 - 0.3

565 0-15 80.1 0.0 0.0

658 0-15 342.1 0.0 0.0

659 15-40 337.9 0.0 – 6.4 0.0 - 0.3

Table 3-35. Predicted soil erosion rates and sediment yield for watersheds in the Bill Williams Mountain Restoration 

Project area where forest thinning treatments would be conducted under Alternative 4

Watershed Name Acres

Total Sediment 

Delivery in Year of 

Disturbance

(Tons/Watershed)

Average Annual 

Hillslope Erosion

(Tons/Watershed)

Cataract Creek Headwaters 2,261 42.70 7.11

Devil Dog Canyon 833 5.32 5.94

Dogtown Wash 476 4.81 5.48

Johnson Creek 1,884 18.46 4.72

Meath Wash 1,426 8.93 3.49

Upper Hell Canyon 4,243 46.37 1.92

Grand Total 11,123 126.59 28.66
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

150 Chapter 3. Affected Environment and Environmental Consequences

Permanent and Temporary Roads. Alternative 4 would include constructing approximately 38 miles of 

temporary roads that would be obliterated after use as well as obliterating approximately 24 miles of poorly 

located roads within the project area.

Based on a travelway width of 12 feet and a clearing width of four feet on each side of the travelway, 

approximately 92.1 acres of land would be temporarily removed from timber and forage production for temporary 

road access.

Table 3-36 provides a summary of modeled sediment delivery from construction, use, and maintenance of 

temporary roads under Alternative 4. As previously noted, the range of values given for road sedimentation 

represent the amount of sediment delivered across a buffer, and the amount delivered to a stream crossing. 

As shown in Table 3-36, temporary roads would result in an increased risk of short-term hillslope erosion and 

sediment delivery to surface waters during project implementation under Alternative 4. Temporary roads would 

be stabilized with BMPs and SWCPs designed to prevent erosion of road surfaces and sediment delivery to water 

bodies during road use. 

Table 3-36. Predicted sediment yield and hillslope erosion rates and for Terrestrial Ecosystem Units where temporary 

roads would be constructed and maintained under Alternative 4

Map Unit

Slope

(%) Acres of Roads

Predicted Sediment 

Delivery in Year of 

Disturbance

(Tons/Sq Mi)

Average Annual 

Hillslope Erosion

(Tons/Sq Mi/Yr)

0010 0-5 0.81 0.0 – 7.7 0.0 – 7.7

0300 15-40 0.35 7.7 – 28.2 7.7 – 28.2

0302 15-40 0.06 7.7 – 28.2 7.7 – 28.2

0304 0-15 0.07 7.7 – 9.3 7.7 – 9.3

0310 15-40 12.78 7.7 – 28.2 7.7 – 28.2

0322 40-80 0.10 18.5 – 56.8 18.5 – 56.8

0324 0-15 24.95 0.0 – 9.3 0.0 – 9.3

0401 0-15 0.38 0.0 – 9.3 0.0 – 9.3

0402 15-40 0.15 7.7 – 28.2 7.7 – 28.2

0405 0-15 0.15 0.0 – 9.3 0.0 – 9.3

0507 0-15 0.07 0.0 – 9.3 0.0 – 9.3

0518 0-15 1.28 0.0 – 9.3 0.0 – 9.3

0519 0-15 4.17 0.0 – 9.3 0.0 – 9.3

0537 0-15 3.87 0.0 – 9.3 0.0 – 9.3

0563 0-15 0.32 0.0 – 9.3 0.0 – 9.3

0564 15-40 2.84 7.7 – 28.2 7.7 – 28.2

0565 0-15 0.12 0.0 – 9.3 0.0 – 9.3

0658 0-15 2.32 0.0 – 9.3 0.0 – 9.3

0659 15-40 0.47 7.7 – 28.2 7.7 – 28.2

Obliteration activities would be the same as those proposed under Alternatives 2 and 3 and would hasten recovery 

of temporary road surfaces and return them to productive status over the long term. As a result, average annual 

hillslope erosion and sediment delivery rates following decommissioning of temporary roads are expected to be 

substantially lower than those predicted by the model. Since temporary roads would not all be constructed at 

once, but instead would be constructed as access to treatment areas is necessary, it is very unlikely that large 

pulses of erosion and sediment delivery from temporary roads would occur over a short timeframe (i.e., within a 

single year).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 151

Bixler Trailhead and Trail. There would be no construction of the new Bixler trailhead or proposed new trail 

segment under Alternative 4. There would therefore be no direct or indirect effects to soils resources as a result of 

these proposed activities under Alternative 4. 

Prescribed Fire Treatments. Direct and indirect effects to soils as a result of strategic fuel treatments would be 

the same as Alternatives 2 and 3. Direct and indirect effects to soils from use of prescribed fire would be the same 

as Alternative 3 since the Arizona Bugbane Botanical Area would be excluded from prescribed fire under 

Alternative 4.

3.5.3 Cumulative Effects 

Cumulative effects include the impacts on the environment which result from the incremental impact of the action 

when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or 

non-Federal) or person undertakes such other action (40 CFR § 1508.7). The geographic setting for the 

cumulative effects analysis for soils and watersheds includes all of the 6th-level (HUC12) hydrologic unit 

watersheds where the Bill Williams Mountain Restoration Project is located, which comprises approximate 

137,153 acres. The timeframe for past actions is 10 years, based on soil productivity, vegetative response, and 

coarse woody debris recovery within treated areas. Surface disturbing activities that are older than 20 years are 

assumed to be contributing negligible or no measurable cumulative effect within the analysis area

Following is a partial listing of actions considered in the cumulative effects analysis for this project:

• Activities such as vegetation management, fuels management, livestock grazing, recreational activities, 

and other management activities (e.g. noxious weeds treatments) have occurred in the past, are occurring, 

and are reasonably foreseeable actions on the Williams Ranger District. These activities could occur on 

private lands as well. 

• Firewood cutting has occurred in the past and would likely continue in the foreseeable future on the 

District and private lands within watersheds that include the project area. 

• Private landowners may harvest timber on their lands for lumber, fuelwood, or to reduce fire hazards. 

• Urban development and interface growth would continue on private lands. 

• Road construction, maintenance and right-of-way clearing can be expected to continue on non-National 

Forest System land. 

• Road maintenance, reconstruction, or decommissioning may occur with future vegetation management 

projects on National Forest System land. 

• Recreation activities are expected to continue to increase on the Forest. Future recreation projects may be 

developed. 

• There is a multi-million dollar electronics site on the top of Bill Williams Mountain that includes 

communications infrastructure for the Department of Public Safety, USDA Forest Service, Arizona State 

Land Department, Burlington Northern Santa Fe railroad and several other governmental and private 

enterprises. Several special use permits exist and continue to be requested for the communications site 

such as cell tower extensions, new outbuildings, etc.

• The north side of the mountain is home to a small ski and recreation area (Elk Ridge Ski and Outdoor 

Recreation Area) which operates periodically throughout the year with downhill skiing in the winter and 

tubing in the summer. 

Table 3-37, Table 3-38, and Table 3-39 provide a summary of past, present, and reasonably foreseeable projects 

considered in the soils and watershed cumulative effects analysis for this project.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

152 Chapter 3. Affected Environment and Environmental Consequences

Table 3-37. Past projects in the Project Cumulative Effects Analysis Area

Project

Year NEPA 

Completed Activities Status 

Williams High Risk Project 2001 Non-commercial thinning Completed

Clover High Fuels Reduction Project 2002 Non-commercial thinning Completed

Table 3-38. Current projects in the Project Cumulative Effects Analysis Area

Project

Year NEPA 

Completed Activities Status 

City 2005 Veg. Mgt.: TS, TSI, & BB; includes some 

temporary roads and dozer lines

Currently being 

implemented

Twin 2005 TSI & Fuel reduction; includes some 

temporary roads and dozer lines

Ongoing – Approx. 

40% implemented

Bill Williams Cap 2009 Fuel reduction / Hazard Tree removal on 6 

ac.

Implemented in 2010

Williams Ranger District Travel 

Management Project

2010 Prohibit cross-country travel (except as 

designated on Motor Vehicle Use Map 

(MVUM)); close 380 miles of system roads 

to motor vehicle use.

Implemented in July 

2011 with publication 

of MVUM

Hat Allotment Grazing Management 2010 Authorizes grazing Ongoing

EIS for Treatment of Noxious or 

Invasive Weeds

2004 Treatment of Noxious or Invasive Weeds Ongoing

Dogtown Project 2004 Timber Sale; Prescribed burning; Noncommercial thinningPending Sales; 

Ongoing burning

McCracken (WRD) 2012 Thinning (15,200 ac), Burning (17,000 ac), 

Grassland Restoration

Decision signed in 

Spring 2012.

Table 3-39. Reasonably foreseeable projects in the Project Cumulative Effects Analysis Area

Project

Year NEPA 

Completed Activities Status 

Four Forest Restoration Initiative 

(Multiple Projects)

2015 Restoration of Ponderosa Pine ecosystem 

(thinning, burning)

Planning team and 

collaborative group are 

completing the FEIS.

South Zone Travel Management 

Revision Project

2015 Revision to Travel Management Plan for 

South Zone of the Kaibab National Forest, 

including adding camping corridors and 

spur roads.

Public Scoping Packet 

Released in 2014. 

Analysis initiated.

Alternative 1 – No Action

The No Action Alternative would result in no vegetation or fuels reduction treatments being performed, no new 

road construction or road obliteration, and no unscheduled maintenance of existing roads in the project area. 

Therefore, there would be no direct effects to soils, water quality, ephemeral or intermittent stream channels, 

watershed condition, or changes to water yield as a result of the no-action alternative. However, land management 

activities and changing vegetative conditions throughout the last 100 years have produced an uncharacteristic 

accumulation of fuels and increased trees density within the project area. These conditions make wildfire a 

possibility and suppression exceedingly difficult. 

A high-severity fire is not certain to occur within the project area during any given timeframe. However, the 

occurrence of a high-severity wildfire would have an increased potential for profound adverse impacts to 

hydrologic systems in project area watersheds and downstream locations. Such a fire event would likely result in 

increased runoff and potential for soil erosion and sediment delivery to intermittent and ephemeral streams as a 

result of loss of forest interception of rainfall, reduced soil water infiltration rates, and the reduction of effective 

ground cover at the soil surface. The infrequent nature of ephemeral stream flow results in the potential for 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 153

sediment and ash to be stored within these stream channels and then transported during surface runoff events. 

This, in turn, could pose detrimental effects to surface water quality and water storage capacity, including 

impoundments that are the sources of the City of Williams municipal water supply. 

Other potential detrimental effects to hydrologic conditions in the project area and downstream locations could 

include the destabilization of the geomorphic conditions of stream channels due to excessive sediment delivery 

and debris loading, increased peak flows, and overall increases in average annual water yield resulting from loss 

of upslope interception, infiltration, and evapotranspiration. Ephemeral stream channels within high burn severity 

areas would lose their ability to buffer runoff from large rainfall events, resulting in increased channel scour and 

incision caused by accelerated runoff and erosion from severely burned watershed areas. Increased bedloads in 

stream channels effectively raises the elevation of stream bottoms, causing flood flows to exceed channel 

capacities, resulting in overland flooding. These conditions could result in increased flooding risk within the 100-

year floodplain of Cataract Creek located in the City of Williams and other downstream locations. 

Another effect is sediment and ash deposition in downstream roads, stock tanks and meadows, even if such areas 

may not have burned. In addition, sediment and ash-laden overland flows may damage low lying roads by 

eroding road traveled ways and filling culverts and low water crossings with sediment and debris. These are 

examples of why post-wildfire watershed conditions are significantly different from pre-fire or low-severity 

prescribed fire conditions.

Additional cumulative effects of the No Action alternative include ongoing erosion and sediment delivery to 

ephemeral channels from roads proposed for obliteration under the Action Alternatives. When combined with 

other activities in the proposed project area, sediment production from these roads could contribute to adverse 

impacts to downstream surface water quality if these roads remain in an unstable, eroding condition.

Alternative 2 – Modified Proposed Action 

Other ongoing projects in the same watersheds as the proposed Bill Williams Mountain Restoration Project and 

their associated acreages in each watershed are summarized in Table 3-40. 

Ephemeral and intermittent drainages in the project area respond to seasonal surface runoff (usually during snow 

melt and the summer monsoon season). Surface runoff potentially carries varying amounts of sediment, 

contributing to water turbidity. Turbidity is the water quality standard that is most likely affected by land 

management activities. Turbidity is a measure of particulate matter suspended in water. Typically, in wildland 

settings, turbidity is the existence of fine to very fine soil particles and organic matter in water. Sediment delivery 

ratios normally decline with increasing watershed area, resulting in dilution of sediment delivered to streams from 

a given activity. The ADEQ 305(b) Assessment and 303(d) Listing Report for 2010 was consulted to determine 

water quality status of streams that flow from the project area. There are no exceedances or impairments noted on 

either the 305(b) Assessment or 303(d) List for any stream segments within the proposed project boundary or 

within 50 miles downstream of the Bill Williams Mountain Restoration Project area. It is unlikely that the 

Modified Proposed Action would contribute enough sediment to ephemeral or intermittent drainages within the 

project area to result in impairment of any downstream water bodies. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

154 Chapter 3. Affected Environment and Environmental Consequences

Table 3-40. Current activities and associated acreages that occur in the same watersheds (HUC12) as the proposed Project

Watershed 

Name (HUC12)

Cataract Creek 

Headwaters

150100040502

Devil Dog Canyon

150602020202

Dogtown Wash

150100040501

Johnson Creek

150602010302

Meath Wash

150602020203

Upper Hell Canyon

150602020204

Watershed 

Acres (HUC12) 16,694 11,192 11,659 30,847 37,522 29,239

Activity Acres % of WS Acres % of WS Acres % of WS Acres % of WS Acres % of WS Acres % of WS

City Project 6,772 41 ---- ---- 2,492 21 2,422 8 ---- ---- 25 <1

Dogtown Project 11 <1 ---- ---- 2,280 20 ---- ---- ---- ---- 184 <1

Four Forest 

Restoration 

Initiative

11,436 69 2,845 25 11,543 99 7,260 24 2,719 7 19,343 66

McCracken 

Project

---- ---- ---- ---- 811 7 ---- ---- ---- ---- 8,575 29

Travel 

Management 

Rule

11,436 69 10,029 90 9,976 86 28,421 92 26,170 70 26,787 92

Twin Project 52 <1 821 7 435 4 1,141 4 1,567 4 8,180 28

Big Springs 

Allotment Grazing

---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 1,092 4

Chalender 

Allotment Grazing

13 <1 ---- ---- 1,700 15 ---- ---- ---- ---- 4 <1

Corva Allotment 

Grazing

---- ---- ---- ---- ---- ---- 8,150 26 ---- ---- ---- ----

Davenport Lake 

Allotment Grazing

473 2 ---- ---- 2,234 19 ---- ---- ---- ---- ---- ----

Double A 

Allotment Grazing

---- ---- ---- ---- ---- ---- 110 <1 ---- ---- ---- ----

Hat Allotment 

Grazing

2,730 16 10,920 97 3,658 31 13,028 42 20,570 55 25,809 88

Irishman Dam 

Allotment Grazing

---- ---- ---- ---- ---- ---- 5,440 18 5,787 15 ---- ----

Juan Tank

Allotment Grazing

2,071 12 ---- ---- ---- ---- 1,505 5 ---- ---- ---- ----

Pine Creek 

Allotment Grazing

1,893 11 ---- ---- 1,628 14 ---- ---- ---- ---- ---- ----

Seven C Bar 

Allotment Grazing

---- ---- ---- ---- ---- ---- ---- ---- 294 <1 ---- ----

Sitgreaves 

Allotment Grazing

---- ---- ---- ---- 231 2 ---- ---- ---- ---- ---- ----

West Bear 

Allotment Grazing

---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 12 <1
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 155

Vegetation Treatments and Timber Harvesting. Vegetation management projects such as commercial timber 

harvesting, pre-commercial forest thinning, and fuelwood gathering reduce overstory cover in the short-term but 

typically result in an increase in understory vegetation within three to five years following treatment. These 

projects would also cause an initial increase in soil organic matter in the form of residual woody debris from tree 

harvesting activities that improves surface roughness and improves nutrient cycling. As grasses and forbs 

increase in numbers, fine root material would contribute to soil organic matter accumulation, improve soil 

aggregate stability and soil porosity, and protect soil surfaces from erosion by wind and rain. Reduction of tree 

canopy and fuel loads would reduce the threat of high severity wildfire that could remove plant and litter cover, 

consume seed bank, sterilize soils, and create erosion and flooding hazards. Decreased interception of 

precipitation (rain and snow) would result in increased surface runoff following vegetation treatments. 

Project objectives are typically designed to improve forest health by thinning overstocked stands and reducing the 

potential for high severity wildfire. These activities usually require the use of logging machinery with potential to 

disturb soils. Overall, forest thinning improves tree vigor, increases the diversity, distribution, and amount of 

herbaceous understory vegetation (including effective vegetative ground cover), and reduces the risk of 

uncharacteristic wildfire. Effects on soil productivity and stability are common to all harvest activities, but vary 

by silvicultural treatments, fuel treatments, and acres treated. Effects are generally related to roads, skid trails, log 

landings and fuels treatments resulting in varying degrees of soil displacement, compaction, and soil loss due to 

short-term reduction or complete removal of vegetative ground cover. Adequate vegetative ground cover is the 

primary component that protects the soil from accelerated erosion. 

It is assumed that between harvest and fuel reduction treatment activities, every acre in each proposed treatment 

unit would be affected. Therefore, the total acreage is assumed to be at risk for some level of soil disturbance. 

The risk of accelerated erosion from soil disturbance is expected to last until vegetative ground cover is sufficient 

to protect soil surfaces, which typically occurs within 3 to 5 years after fuel reduction treatments are completed. 

It is important that the reader understand that not all soil disturbance is detrimental. For example, a low severity 

prescribed fire disturbs soils by partially consuming and redistributing the surface organic fraction. This changes 

short term carbon-nitrogen ratios and increases available short term nutrient supplies, resulting in increased 

understory response which in turn provides improved protection of soils from erosion by wind and rain. 

By identifying and implementing site-specific BMPs and SWCPs prior to and during project implementation, 

adverse effects to soils and watershed resources are minimized and are generally short term (3 to 5 years). Best 

Management Practices are designed to maintain soil productivity and surface water quality by minimizing soil 

loss and associated sediment delivery to water bodies. 

Soil Stability and Erosion Processes. Gullies and headcuts are a primary source of sedimentation. They 

channelize and accelerate sediment-laden water, resulting in soil movement to downslope locations or into 

drainages. Areas which are sensitive to gully erosion are long, narrow alluvial plains, alluvial fans, and low lying 

areas with moderate slopes and deep, fine-textured soils. Gullies are typically the result of historical management 

practices and are now in varying degrees of recovery. Poorly located roads proposed for obliteration are, in some 

cases acting as gullies, channelizing runoff into ephemeral drainages. As management practices have improved 

and watershed conditions have changed, some gullies are reaching more stable conditions through aggradation 

and widening, creating more favorable floodplains and gentle gradients. This adjustment process involves erosion 

of banks and head cuts in order to reach a point of equilibrium. Once this point is reached, erosion decreases, 

vegetation begins to grow where gully sidewalls have a gentler angle of repose, and gullies stabilize. The effect 

of gully stabilization is reduced loss of soil productivity and downstream sedimentation. 

Soil stability would be improved over approximately 15,000 acres through increases in surface roughness from 

additional woody debris at the soil surface. Slash would enhance the effective ground cover and thereby reduce 

soil particle detachment by raindrop impact. Enhanced ground cover from the addition of slash, and over the 

longer term from increased understory vegetation, particularly grasses and forbs would improve microhabitat 

conditions (i.e., shade, moisture, and available nutrients). These improvements would occur on most TES map 

units within the project area. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

156 Chapter 3. Affected Environment and Environmental Consequences

Nutrient Cycling. Nutrient cycling would improve over time on approximately 15,000 acres due to the addition 

of small and large woody material. The project would leave at least 5-7 tons per acre of CWD in the activity 

units. In addition, up to 1-3 tons per acre of fine fuels would be left as needles, twigs, small limbs, and other small 

woody material. The addition of CWD and other fine fuels would have a beneficial effect to long-term soil 

productivity. The effectiveness of woody debris retention has been proven to reduce and control adverse impacts 

to soil resources and water quality (Ice 2004, Rashin 1994, Seyedbagheri 1996, USDA Forest Service 2004b). 

Soil Hydrology. Surveys of the project area indicate that the current existing percentage of landings, skid trails, 

and roads is approximately 5 to 10 percent of the proposed activity areas. As previously noted, several miles of 

roads proposed for obliteration are compacted, rutted, and are channelizing surface runoff and are not exhibiting 

substantial recovery. In order to mitigate any additional compaction and displacement of soils, temporary roads, 

skid trails, and landings would be stabilized using BMPs and SWCPs, which may include ripping or 

decompacting and seeding to alleviate reductions in porosity and infiltration capacity. Therefore, it is not expected 

that the percentage of compacted areas would increase substantially (i.e., beyond an additional 1 to 2 percent over 

the current condition). 

Areas of water repellency, which form as a result of the prescribed fire use, are expected to recover within 3 to 5 

years as natural processes such as freeze-thaw, wetting and drying, natural revegetation, root elongation, and 

chemical weathering occur. 

Watershed Response. The magnitude of change in water yield resulting from vegetation treatments and 

prescribed burning is most strongly related to the amount of precipitation and intensity of the treatments. 

The hydrologic response of watersheds in the project area to proposed activities would depend on the summed 

effect of the changes in evaporation, transpiration, soil moisture storage, and snowpack accumulation and melt 

processes. This includes the degree to which vegetation treatments influence net precipitation that reaches soil 

surfaces through reduced canopy interception, changes to soil moisture evaporation rates, and changes to the 

amount of transpiration and soil water depletion. Changes to streamflow would depend on whether precipitation 

or snowmelt exceeds both evapotranspiration demand, soil moisture holding capacity, and groundwater recharge 

rates. 

Changes in evapotranspiration following vegetation treatments would be the result of reduced soil moisture 

depletion during the growing season and decreased winter snowfall interception. Precipitation accumulates on 

Bill Williams Mountain over the winter as snowpack, with melting and sublimation occurring during warm phases 

throughout the winter. Much of the winter precipitation is intercepted by tree canopies. Some of this moisture 

evaporates or sublimates without contributing to soil moisture, while some is blown off of intercepting vegetation 

or simply falls off, thus reaching soil surfaces. 

When the remaining snowpack begins to melt in spring, melt water first recharges the soil by replacing the water 

that was depleted during the previous growing season. Once soil moisture storage capacity is at its maximum, 

remaining melt water is available to become stream flow. On north facing slopes, some of the snowpack remains 

almost continuously from December to April. While the evaporation rate is lower than south facing slopes, the 

relatively large surface area of snow permits a substantial amount of evaporative loss to occur. In contrast, on 

south facing slopes, intercepted snow quickly leaves the less dense forest canopy thus allowing less interception 

loss. For the first one to three years following vegetation treatments, a slight increase in stormwater runoff is 

expected since understory vegetation of grasses, forbs and shrubs would not have reached maximum ground cover 

levels, snowpack interception would be reduced, and there would be fewer trees to create evapotranspirational 

demand for soil moisture during the growing season. 

Recreational Activities. Recreational activities within the proposed project area include: hiking, viewing 

wildlife, hunting, dispersed car-camping, backpack camping, orienteering, horseback riding, photography, 

picnicking, taking scenic drives, ORV/ATV use, bicycling, shooting, and gathering in family or social groups. 

The project area is part of the Arizona Game and Fish Department’s Game Management Unit 10, and is popular 

for turkey, elk, mule deer, javelina, and pronghorn hunting. Other common uses within the project area include 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 157

firewood cutting, Christmas tree cutting, collecting boughs and cones, gathering antlers, and collecting food and 

medicinal resources such as berries, nuts, mushrooms, and medicinal plants. Of these, ORV/ATV use, dispersed 

camping, firewood collection and Christmas tree cutting have the greatest potential to result in adverse cumulative 

effects to soils through compaction, puddling, and displacement. These conditions would occur in areas where 

such activities take place. Wet weather, cross country travel restrictions and designated routes for fuelwood and 

Christmas trees cutting would minimize these adverse impacts. Popular recreational trails within the project area 

include Bill Williams Trail, Bixler Trail, and Clover Springs Trail. 

Livestock Grazing. Cumulative effects from livestock grazing include minor, generally localized soil 

compaction, puddling, and erosion from livestock trailing and in areas where animals congregate such as stock 

tanks and areas where mineral supplements are placed. Individual wildlife and livestock trails were noted in the 

proposed treatment areas, but these trails make up a small percentage of the landscape and proposed treatment 

areas. Livestock grazing is not expected to increase the area of soils characterized as unsatisfactory within the 

project area.

Invasive and Noxious Weeds. The cumulative effect of the increased risk of spread on noxious weeds on soil 

productivity can only be described in general terms because of the large number of unknown variables. Areas 

where soil disturbance includes compaction, displacement, erosion, and excessive heating are at the greatest risk 

of invasion by noxious weeds. These include spur roads used for fuelwood gathering and Christmas tree cutting, 

and pile burning areas. Monitoring of these areas for the presence of invasive and noxious weeds and treating 

observed populations in a timely manner would mitigate these adverse effects. To minimize cumulative adverse 

effects if invasive and noxious weeds, observed infestations would be managed in accordance with the Final 

Environmental Impact Statement for Integrated Treatment of Noxious or Invasive Weeds on the Coconino, 

Kaibab, and Prescott National Forests within Coconino, Gila, Mojave, and Yavapai Counties, Arizona. 

Fire Effects. In low burn severity areas, effects are mainly light ground char where the litter is scorched, charred, 

or partially consumed. The litter layer, or duff is largely intact, although it may be charred on the surface. Woody 

debris accumulations are partially scorched, charred, or consumed. Mineral soil properties are not adversely 

affected. In fact, low severity fire releases nutrients stored in surface organic matter and live vegetation. These 

nutrients facilitate rapid reestablishment of vegetative ground cover since root to shoot ratios are improved for 

grasses and forbs that survive fire, resulting in protection of soils from accelerated soil erosion soon after fire has 

occurred. Evidence of sheet and rill erosion as a result of low severity fire is minor. In forested areas, much of 

the tree overstory is green with some scorch at the base of the trees and in the lower branches following low 

severity fire. Most trees survive; however, pockets of seedlings, saplings, and mature trees can be killed or 

consumed where moderate to high severity fires occur. While most of the shrubs, forbs and grasses are affected 

under low severity fire conditions, in most cases, much of this vegetation survives. Areas identified as low burn 

severity may also contain large unburned areas, resulting in a mosaic of burned and unburned sites across the 

landscape.

Summary of Cumulative Watershed Effects

When combined with projects and activities listed in Table 3-40, cumulative watershed effects from 

implementation of the modified proposed action would contribute to an improved soils and watershed condition 

and restoration of the ecological interrelationships of soils, vegetation, and watersheds in the cumulative effects 

analysis area. Water impoundments and other infrastructure that depend on stable soils and watershed conditions 

would be better protected from potential adverse effects of high severity wildfire.

Alternative 3

Cumulative effects of Alternative 3 would be similar to the Modified Proposed Action. There would be no 

removal of trees greater than 9 inches DBH in MSO PACs and pine/oak habitat where slopes exceed 40 percent. 

Approximately 472 acres would therefore not receive full restoration treatments. Utilizing helicopters would 

facilitate removal of some trees; however, diameter limits would still prevent full restoration of portions of MSO 

PACs and pine/oak habitat on steeper slopes. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

158 Chapter 3. Affected Environment and Environmental Consequences

While adverse cumulative effects to soils and watersheds from proposed restoration activities would be reduced 

slightly as compared to the Modified Proposed Action this reduction is minimal. If helicopter yarding is used to 

complete vegetation treatments in these areas instead, soil disturbance and potential adverse effects to water 

quality would be minimized. 

Other fuels reduction and forest restoration activities are either completed, underway, or proposed within and 

surrounding the Bill Williams Mountain Restoration Project area. The effectiveness of such treatments would be 

offset by the marginal effectiveness of this alternative to achieve desired soils and watershed conditions since 

forest restoration would not be fully achieved. 

Alternative 4 

Cumulative effects of Alternative 4 to soils and watershed resources would be similar to the Modified Proposed 

Action and Alternative 3, with the exception that there would be no helicopter use under this alternative, limiting 

acres to be treated to 11,150, or 4,050 acres fewer than the Modified Proposed Action. Approximately 26 percent 

of the area proposed for treatment under the Proposed Action would therefore not receive forest restoration 

treatments. Additionally, as under Alternative 3, there would be no removal of trees greater than 9 inches DBH in 

MSO PACs and pine/oak habitat where slopes exceed 40 percent.

While short term adverse cumulative effects to soils and watershed resources would be reduced substantially 

under Alternative 4, it is through reduced acreage receiving forest restoration treatments that would protect and 

restore long term soils and watershed function. If these areas are not treated to reduce tree density and fuel loads 

under this alternative, the risk of high severity wildfire would remain on approximately 26 percent of the project 

area. In the absence of forest restoration treatments there is elevated potential for long term cumulative adverse 

effects to soils and watershed resources if an uncharacteristic, high severity wildfire were to occur within the Bill 

Williams Mountain Restoration Project area. Given the size, intensity, and locations (steep, mountainous terrain) 

of recent wildfires throughout the Southwest, the potential for an uncharacteristic, high severity wildfire to occur 

exists.

3.5.4 Climate Change

While it is currently not possible to discern climate change effects of the Modified Proposed Action or other 

Action Alternatives, given the lack of effects that can be meaningfully evaluated under current science and 

modeling, one would expect an initial, short-term increase in atmospheric CO2 and other greenhouse gases from 

the proposed treatments through burning of hydrocarbons to conduct mechanical vegetation treatments, rapid 

oxidation of vegetation and woody debris during prescribed burning, and increased decomposition of woody 

debris. However, long-term effects would be positive as the ground cover of grasses and forbs increases. Woody 

debris would provide long term nutrient sources and contribute to surface roughness, decreasing potential erosion. 

Nutrients released in ash during prescribed burning and through decomposition of residual woody debris from 

forest thinning would also improve soil quality. As previously noted the increase in ground cover of grasses, 

forbs, and shrubs, which have higher fine root turnover rates than large woody plants would result in greater soil 

organic matter content over time. Soils within the project area would therefore sequester more carbon dioxide 

(CO2) over the long term. 

The U.S. Environmental Protection Agency (EPA) has asserted that scientists know with virtual certainty that 

human activities are changing the composition of the Earth’s atmosphere. It is also documented that 

“greenhouse” gases, including CO2, methane (CH4), nitrous oxide (N2O), and hydro fluorocarbons have been 

increasing (EPA, 2010). The atmospheric increase of these gases is largely the result of human activities such as 

the burning of fossil fuels. Greenhouse gases absorb infrared energy that would otherwise be reflected from the 

earth. As this infrared energy is absorbed, the air surrounding the earth is heated (CARB 2007).

The Southwestern Region of the Forest Service recently released “Southwestern Region Climate Change - Trends 

and Forest Planning: A guide for addressing climate change in forest planning on southwestern National Forests 

and Grasslands. The following information is summarized from excerpts of this publication: 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 159

In the Southwest, climate modelers agree there is a drying trend that would continue well into the latter part of 

21st century (IPCC 2007; Seager et al. 2007). Climate modelers predict increased precipitation, but believe that 

the overall balance between precipitation and evaporation would still likely result in an overall decrease in 

available moisture. Regional drying and warming trends have occurred twice during the 20th century (1930s Dust 

Bowl, and the 1950s Southwest Drought). Current drought conditions “may very well become the new 

climatology of the American Southwest within a time frame of years to decades”. According to recent model 

results, the slight warming trend observed during the last 100 years in the Southwest may continue into the next 

century, with the greatest warming to occur during winter. Climate models predict temperatures to rise 

approximately 5 to 8 degrees Fahrenheit by the end of the century (IPCC 2007). This trend would likely increase 

demand on the region’s already limited water supplies, as well as increase energy demand, alter fire regimes and 

ecosystems, create risks for human health, and affect agriculture (Sprigg et al. 2000). 

Average ambient air temperatures are rising, and it is possible that continued warming will increase the 

temperature difference between the Southwest and the tropical Pacific Ocean, enhancing the strength of westerly 

winds that carry moist air from the tropics into the Southwest region during the monsoon season. This scenario 

may increase the monsoon’s intensity, or its duration, or both, in which case floods would occur with greater 

frequency (Guido 2008). While the region is generally expected to dry, it is possible that extreme weather 

patterns leading to more frequent destructive flooding would occur. Along with monsoons of higher intensity, 

hurricanes and other tropical depressions are projected to become more intense overall. Arizona typically receives 

10 percent or more of the annual precipitation from storms that begin as tropical depressions in the Pacific Ocean. 

In fact, some of the largest floods in the Southwest have occurred when remnant tropical storms intersect frontal 

storms from the north or northwest (Guido 2008). Most global climate models are not yet accurate enough to 

apply to land management at the ecoregional or National Forest scale. This limits regional and forest-specific 

analysis of the potential effects of climate change. 

Due to the spatial and temporal limitations of climate models, as stated above, site-specific analysis of climate 

change at the Forest level with regard to implementing fuels reduction treatments remains impractical. Several 

unknown factors further limit discussion and analysis of climate change at the Forest level. These include: lack of 

data on emissions from prescribed fire and wildfires, lack of data on emissions from logging machinery and traffic 

increases due to transportation of logs to processing facilities, limited data on emissions from machinery used to 

construct, maintain, or obliterate roads, and limited knowledge of the contributions of surrounding areas to current 

and future climate impacts at the Forest level necessary to analyze cumulative effects. Impacts to climate change 

from implementation of the proposed project are therefore discussed in a qualitative manner.

Projected future climate change could affect Arizona in a variety of ways. Public health and safety could be 

compromised due to an increase in extreme temperatures and severe weather events. Agriculture would be 

vulnerable to altered temperature and rainfall patterns, increasing plant stress and susceptibility to insects and 

diseases. Forest ecosystems could face increased occurrences of high severity wildfires and may also be more 

susceptible to insects and diseases. Snowpack could decrease and snowmelt may occur earlier. 

While the future of climate change and its effects across the Southwest remains uncertain, it is certain that climate 

variability will continue to occur throughout the region. Forest management activities should strive to promote 

ecosystem resilience and resistance to impacts of climate change. Forest management activities should focus on 

maintenance and restoration of native ecosystems, thereby reducing the vulnerability of these ecosystems to 

variations in climate patterns. Ecological diversity remains an integral component in native ecosystems. Projects 

should promote connected landscapes and endeavor to restore significantly altered biological communities, thus 

restoring their resilience to changes in climate. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

160 Chapter 3. Affected Environment and Environmental Consequences

3.6 Transportation 

3.6.1 Affected Environment

The Bill Williams project area encompasses approximately 15,200 acres of national forest land system land 

immediately southwest of the City of Williams. The project area is bounded by Interstate 40 and Old Route 66 on 

the north, county highway 73, (Perkinsville Road) on the east, forest road 122 on the south and forest road 108 on 

the west. There are approximately 88 miles of Forest Service system roads, non-Forest Service jurisdiction roads, 

and unauthorized roads within the project area (Table 3-41).

Table 3-41. Approximate Miles of Existing Roads within the Project Area

Road Miles

Forest Service System Roads 58

Maintenance Level 1 (ML-1) Roads 19

Maintenance Level 2 (ML-2) Roads 31

Maintenance Level 3 (ML-3) Roads 8 

Maintenance Level 4 (ML-4) Roads 0 

Non-Forest Service Jurisdiction 16

Previously Decommissioned and unauthorized roads 15

Total 89

Forest Service roads are classified by Maintenance Level (ML) on a 1 to 5 scale. ML-1 roads are closed roads 

that receive little to no maintenance; are planned/allowed to re-vegetate naturally; are not open to motor vehicle 

use, but may be open and suitable for non-motorized uses. ML-2 roads are maintained to allow for use by high 

clearance vehicles such as pick-ups and logging trucks. ML-3 roads are maintained to accommodate passenger 

cars. ML-4 and 5 are maintained for a higher level of passenger comfort. Forest Service road 108 is a ML-3 road 

while all of the other existing roads in the project area are maintenance level 1 or 2 roads. 

Portions of the project area have limited roaded access or are accessed by poorly located roads. Table 3-42 lists 

the many miles of roads within the project area that are poorly located and lack adequate transportation planning 

and engineering design. They are often found in drainage bottoms or on ridge tops, have steep grades in excess of 

15% and run parallel to the slope. They are often below the grade of the surrounding area and are deeply rutted as 

a result of poor drainage. Many of these roads are already decommissioned or are user created roads. However 

some of them are current National Forest System roads.

Much of the current road system was not located or designed properly to serve as a sustainable transportation 

system that facilitates land management and resource protection. 

Table 3-42. Approximate miles of roads that are poorly located and proposed for obliteration

Road

Alternative 1 

No Action Alternative 2

Alternatives 3 

and 4

Forest Service System Roads 0 8 11

Maintenance Level 1 (ML-1) Roads 0 4 6 

Maintenance Level 2 (ML-2) Roads 0 4 5 

Previously Decommissioned and Unauthorized 

Roads

0 15 13

Total 0 23 24
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 161

3.6.2 Environmental Effects

The transportation system that would be required to accomplish the objectives of the action alternatives has been 

closely analyzed and planned through field reconnaissance and extensive map analysis. The main goals of the 

transportation system are to minimize impacts to the environment while safely and efficiently accomplishing the 

goals of the action alternatives. The direct and indirect effects of the road systems on the various forest resources 

are addressed in the individual resource specialist reports and sections of the EIS. A comparison of road mileages 

by category and alternative is shown in Table 3-43. 

Road obliteration in this project is defined as deconstructing roadways so that they are no longer passable to 

vehicles, do not concentrate water flows and their former road surfaces are returned to a more natural state. This 

may be accomplished by a combination of actions that can include ripping and seeding the road surface, installing 

cross drains, recontouring, scattering slash or boulders on the former road surface and installing earthen berms.

Table 3-43. Comparison of Road Mileages by Alternative

Alternative 1 

No Action

Alternative 2

Modified 

Proposed 

Action Alternative 3 Alternative 4

Miles of new road construction

(Permanent)

0 15 22 0 

Miles of temporary roads 

constructed and obliterated after 

use

0 16 16 38

Miles of existing roads obliterated 0 23 24 24

Miles of road converted to trail 0 3 3 3 

Post Implementation Road Miles

Miles of closed roads (Maintenance 

Level 1) 

19 15 13 13

Miles of maintenance level 2 roads

Administrative Use Only

2 18 25 3 

Miles of maintenance level 2 roads

Open to Public

29 24 23 23

Miles of maintenance level 3 roads

Open to Public 

8 8 8 8 

Miles of maintenance level 4 roads 

Open to Public

0 0 0 0 

Effects Common to All Action Alternatives

Changes to Travel Management. Under all action alternatives the following roads status would change. 

111B- Currently an open ML-2 road, however it has a Forest Service locked gate approximately 0.3 miles from its 

junction with county road 73. Past this point it has numerous trees across it and much of it is not passable. A 

portion of 111B is accessible from the 111 road. In all action alternatives, all but the first 0.3 miles of the 111B 

from its junction with county road 73 would be restricted to administrative use only. 

122S- Currently an open ML-2 road, however it is physically closed with boulders near it’s junction with the 122 

road, effectively closing nearly its entire length. In all action alternatives 122S after the physical closure would be 

decommission and obliterated.

9221AD- Currently an open an ML-2 road, however the road is barely visible and not drivable. In all action 

alternatives it would be decommissioned and obliterated. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

162 Chapter 3. Affected Environment and Environmental Consequences

Existing Road Reconstruction and Relocation. Much of the existing road system that would be used for hauling 

on the project requires reconstruction. This may include but is not limited to, widening the roadbed, installing 

culverts and drainage features, ditching, mobile crushing of large rock in the road surface, importing and placing 

gravel for road surfacing and improving road alignment. Under all action alternatives, approximately four miles of 

existing road would be relocated up to several hundred feet from their current location. This would be done to 

eliminate overly steep grades that do not properly drain water from the road surface and are a continuing source of 

erosion. Relocation would also be done to eliminate road segments that are below the grade of the surrounding 

area and are channeling water down the road surface.

3.6.3 Transportation System Economics

Construction cost is broken out by construction phases such as clearing, excavation, etc. Under Alternatives 2 and 

3, temporary roads would only be constructed on slopes less than 20% side slope, roads on side slopes over 20% 

were all permanent roads. Under alternative 4 all roads, both over and under 20% side slope would be temporary 

roads. Roads over 20% require more excavation and require placement of a number of corrugated metal pipes 

(CMPs). This increases total road cost per mile. Obliterating roads with CMPs adds additional cost per mile of 

road because all CMPs must be removed. Costs per mile of road for different types of road are shown in Table 3-

45 and estimated road costs for the alternatives are shown in Table 3-44. Road costs were calculated using the 

interregional road construction cost guide for Regions 2, 3 and 4 (USDA 2010). 

Table 3-44. Road Cost/Mile by Construction Phase and Road Type

Construction 

Phase

New 

Construction 

Permanent 

Road

New Construction 

Temporary Road 

Over 20% side slope 

with Obliteration

New Construction 

Temporary Road 

Under 20% side 

slope with 

Obliteration

Road Obliteration 

Existing Roads

Clearing $6703 $6,703 $6,703 N/A

Excavation $2,250 $2,250 $0 N/A

Drain Dips $600 $600 $0 N/A

CMPs $1,432 $1,432 $0 N/A

Finishing $544 $544 $544 N/A

Seeding $1,513 $1,513 $1,513 $1,513

Mobilization $957 $957 $957 $957

Obliteration $0 $1,056 $1,056 $1,056

Remove CMPs 0 $704 0 0 

Total $/ Mile $13,999.00 $15,759.00 $10,773.00 $3,526.00
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 163

Table 3-45. Road Cost by Alternative

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Miles of New Permanent Road 0 15 22 0 

Total Cost for New Permanent 

Roads

$0 $209,985 $307,978 $0

Miles of Road Relocation and 

Associated Obliteration of Old 

Location

0 4 4 4 

Total Cost for Road 

Relocation and Associated 

Obliteration of Old Location

$0 $70,100 $70,100 $70,100

Miles of Temporary Road 

Under 20% side slope

$0 16 16 16

Total Cost for Temporary 

Road Construction and 

Obliteration Under 20% side 

slope

$0 $172,368 $172,368 172,368

Miles of Temporary Road 

Over 20% side slope

0 0 0 22

Total Cost for Temporary 

Road Construction and 

Obliteration Over 20% side 

slope

$0 $0 $0 $346,698

Miles of Road Obliteration 

Existing Road

0 23 24 24

Total Cost Road Obliteration 

Existing Road

$0 $81,098 $84,624 $84,624

Total Alternative Road Cost $0 $533,551 $635,070 $673,790

Alternative 1 – No Action

Direct and Indirect Effects

Under Alternative 1 the project would not be implemented. No harvesting would take place, no new or temporary 

road construction would occur. None of the poorly located, existing roads would be obliterated. There would be 

no costs incurred with this alternative and no changes would be made to the existing transportation system in the 

project area. 

Cumulative Effects

Because there are no direct or indirect effects, there would be no cumulative environmental effect under this 

alternative 1.

Alternative 2 – Modified Proposed Action

Direct and Indirect Effects

Under Alternative 2, approximately 15 miles of maintenance level 2 roads and approx. 16 miles of temporary 

roads would be constructed. All temporary roads would be obliterated after use and all new roads constructed 

would only be open to administrative use. Post implementation of the project, approximately 32 miles of ML 2 – 

4 roads would be left open for motor vehicle use and approximately 18 miles of ML 2-4 road would be only open 

to administrative use. 15 miles of ML1 road would be closed to all motor vehicle use. Twenty three miles of 

existing roads that are poorly located and causing erosion would be obliterated following implementation of the 

project.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

164 Chapter 3. Affected Environment and Environmental Consequences

By re-designing the transportation system through the construction of new and temporary roads and road 

relocation, Alternative 2 would improve access around the base of Bill Williams Mountain and adequately 

facilitate treatment of the entire project area. Alternative 2 would retain all of the newly constructed system roads 

after implementation of the project because of the investment that would be required to build them and in order to 

provide future access. However, it would reduce maintenance needs in the project area by eliminating poorly 

located roads. 

Estimated cost for constructing 15 miles of ML-2 roads, constructing 16 miles of temporary roads, relocating 4 

miles of existing road and obliterating 23 miles of roads under Alternative 2 is $533,551.00. 

Alternative 3

Direct and Indirect Effects

Under Alternative 3 approximately 22 miles of maintenance level 2 roads and approximately 16 miles of 

temporary road would be constructed. All temporary roads would be obliterated after use and all new permanent 

roads constructed would only be open to administrative use. Twenty-four miles of existing roads that are poorly 

located and causing erosion would be obliterated. Post implementation of the project, 31 miles of ML 2-4 road 

would be left open for motor vehicle use and approximately 25 miles of ML 2-4 road would be only open to 

administrative use. Thirteen miles of ML 1 road would be closed to all motor vehicle use. 

By re-designing the transportation system through the construction of new and temporary roads and road 

relocation, Alternative 3 would improve access around the base of Bill Williams Mountain and adequately 

facilitate treatment of the entire project area. Alternative 3 would retain all of the newly constructed system roads 

after implementation of the project because of the investment that would be required to build them and to provide 

future access. However, it would reduce maintenance needs in the project area by eliminating poorly located 

roads. 

Estimated cost for constructing 22 miles of ML-2 roads, constructing 16 miles of temporary roads, relocating 4 

miles of existing road and obliterating 24 miles of road under alternative 3 is $635,070.00. 

Alternative 4

Direct and Indirect Effects

Under Alternative 4, no new permanent roads would be constructed and treatment of the project area would be 

facilitated by the construction of a temporary road system; approximately 38 miles of temporary road would be 

constructed. All temporary roads would be obliterated after use. Twenty-four miles of existing roads that are 

poorly located and causing erosion would be obliterated. Post implementation of the project, approximately 31 

miles of ML 2 – 4 roads would be left open for motor vehicle use and approximately 3 miles of ML 2-4 roads 

would be open only to administrative use. Sixteen miles of ML-1 road would be closed to all motor vehicle use.

Alternative 4, like all other action alternatives, reduces maintenance needs in the project area by eliminating 

poorly located roads. It facilitates treatment of the project area by constructing only temporary roads. Roads that 

would be permanent under Alternative 3 would be temporary under Alternative 4. Alternative 4 builds 38 miles of 

temporary road, relocates 4 miles of existing road and obliterates 24 miles of existing road for a total cost of $ 

$673,790. 

Cumulative Effects for All of the Action Alternatives

The area for this cumulative effects analysis is the Williams Ranger District. The time frame for this analysis 

begins 2011 when the Williams District Travel Management decision was made. This starting point was selected 

because the travel management decision designated the official open road system, establishing a new baseline. 

The timeframe extends to ten years from now because that is what is reasonably foreseeable. The only other 

actions that would affect the Williams District transportation system within this analysis is the South Zone TMR 

(travel management rule) Revision Project. Although there is no decision for the South Zone TMR project at this 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 165

point, it proposes to close about four miles of currently open road and open 16 miles of new roads, twelve of 

which are existing roads and four miles are user created roads that would be added to the open road system. 

Implementation of any of the action alternatives would result in closing four miles of roads within the analysis 

area. The proposed action, when added to the past, present, and foreseeable projects would result in a net addition 

of eight new miles of open road. The cumulative effect of the action alternatives would result in a more 

sustainable permanent road system that would provide access for the Williams Ranger District.

3.7 Wildlife

See the Wildlife Specialist’s Report for a description of the legal framework, direction from Forest Service 

Manuals, evaluation criteria for analysis, and a detailed biological evaluation and assessment of all affected 

species. 

3.7.1 Wildlife of Highest Conservation Concern

The wildlife of highest conservation concern includes threatened, endangered, and sensitive (TES) species. If a 

TES species or its habitat occurs within the project’s action area, it is analyzed for this project (Table 3-46). See 

USDA (2014a) for a forest-level report on TES species to consider in Biological Evaluations. Effects of 

Alternatives were analyzed for only those species that are known to occupy the project area or have suitable 

habitat within the project area. See Table 3-46 for TES species considered and/or analyzed in this analysis, along 

with acres of habitat in the project area for each species. See Figure 3-44 and Figure 3-45 for a depiction of 

habitat for Mexican spotted owls and northern goshawks within the project area, respectively.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

166 Chapter 3. Affected Environment and Environmental Consequences

Table 3-46. List of wildlife species of conservation concern considered in this analysis

Species Status

Suitable 

Habitat 

Present

Suitable Habitat 

Known to Be 

Occupied Description of Habitat within Project Area

Approximate Acres of Affected 

Habitat in Project Area

Mexican spotted owl

(Strix occidentalis lucida)

Threatened Yes Yes Mixed-conifer and pine-oak forest. 7,123 (see MSO section for 

details)

Bald eagle

(Haliaeetus 

leucocephalus) 

Protected under 

Bald and Golden 

Eagle Protection 

Act; Sensitive

Yes Yes Generalist; all habitats. 15,202 (Entire project area)

Northern goshawk 

(Accipiter gentilis)

Sensitive Yes Yes Ponderosa pine, 

woodlands.

mixed-conifer forest, and 15,068 (See goshawk 

details)

section for 

American peregrine 

falcon

(Falco peregrinus 

anatum)

Sensitive Yes No Grasslands and other open landscapes, with 

cliffs present for nest sites.

64

Navajo Mogollon vole

(Microtus mogollonensis 

navaho)

Proposed Sensitive Yes No Meadows and grassy openings in 

ponderosa pine and mixed-conifer forests.

Meadows and openings 

(unquantified) within 12,462 

acres.

Spotted bat

(Euderma maculatum)

Sensitive Yes No Ponderosa pine forest, pinyon-juniper forest, 

and other habitat below mixed-conifer forest.

13,284

Allen’s lappet-browed bat

(Idionycteris phylliotis)

Sensitive Yes No Generalist; all habitats. 15,202 (Entire project area)

Pale Townsend’s bigeared bat

(Corynorhinus townsendii 

pallescens)

Sensitive Yes No Generalist; all habitats. 15,202 (Entire project area)

California condor

(Gymnogyps 

californianus)

Endangered No No N/A (requires open landscapes with canyon 

habitat for nesting).

0 

Black-footed ferret

(Mustela nigripes) 

Endangered No No N/A (requires grasslands with prairie dog 

town or complexes of >200 acres in size. 

Complex consists of 2+ neighboring towns 

within 4.3 miles of each other).

0

Northern leopard frog

(Rana pipiens)

Sensitive No No N/A (requires 

streams).

perennial wetlands or 0

Burrowing owl

(western) (Athena 

cumicularia hypugaea)

Sensitive No No N/A (requires grasslands 

present).

with burrows 0

Western red bat

(Lasiurus blossevillii)

Sensitive No No N/A (requires deciduous riparian habitat). 0 

Note: Habitat acreage calculations are based on the Silvicultural estimates of stand acres classified by cover type. One may assume that all acres of habitat listed in the last column on this table 

would be affected by the thinning and burning activities proposed under the different Action Alternatives.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 167

Figure 3-44. Mexican spotted owl habitat within the Project Area
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

168 Chapter 3. Affected Environment and Environmental Consequences

3.7.1.1 Mexican Spotted Owl

Existing Conditions

Table 3-46 lists the MSO habitat within the Bill Williams Mountain Restoration Project Area.

Population. The Bill Williams PAC is the only PAC within the project area. One MSO (a male) was detected in 

the core area on May 21, 2014. Nesting or roosting owls were not found in follow-up visits. A great-horned owl 

hooted in response to surveyor’s hoots in July 2014. Historic detections along with an evaluation of habitat 

allowed wildlife biologists to designate the 103 acre core area.

Except for areas of Bill Williams Mountain that occur on slopes >40%, the project area overlaps with the project 

areas of previous projects (City and Twin Vegetation Management Projects) and these areas have already been 

surveyed to established protocols (Wildlife Specialists Report). Kaibab National Forest wildlife biologists 

conducted surveys in 2008-2011, 2013, and 2014 within the Bill Williams PAC and project area. These were done 

according to formal recovery plan protocol. Several other types of owl and nightjar species were detected during 

these surveys in the project area. No MSOs were detected.

Existing Conditions General to All MSO Habitat

Fire-return intervals in ponderosa pine (including pine-oak) and dry mixed conifer forest range from 2-10 years 

and 5-25 years, respectively. However, much of the pine and dry mixed conifer forest has not burned in decades 

within the project area due to fire suppression activities. The ponderosa pine and dry mixed conifer forests within 

the project area are therefore far different from their pre-settlement condition, uncharacteristically dense, and at 

considerable risk of stand-replacing wildfire and insect/disease epidemics. Approximately 60% of the project 

area, including 80% of Protected Habitat and 70% of Recovery Habitat, is at risk of active crown fire, which 

would lead to long term loss of all forests in these areas. 

By definition, the 2012 Recovery Plan provides the best available science and recommendations for the 

conservation of Mexican spotted owls. The project was developed with the guidance of the 2012 revision of the 

Recovery Plan; especially the desired conditions for nesting/roosting recovery habitat (see MSO Recovery Plan 

Revised Edition, Table C.2 and C.3, FWS 2012). 

Existing Conditions in the Protected Activity Center, 103 acre Core area, and Recovery Nest/Roost 

Habitat

The entirety of the Bill Williams PAC occurs within the project boundary. The PAC consists of mixed conifer, 

ponderosa pine, and other forest and woodland types (primarily oak woodlands). Most of the 103 acre nest/roost 

core area is situated on a side slope, with the exception of a knife ridge on the south side. This includes a steep 

upslope drainage with heavily vegetated (mixed conifer) on a north slope. The PAC and recovery habitat within 

the project area is botanically diverse, contains several seasonal streams and springs, has rough topography, and 

contains many large patches of pre-settlement trees.

Due to decades of fire exclusion, the PAC and recovery habitat in the project area (Figure 3-44) is 

uncharacteristically dense. Without fire, the stands have high tree densities and inter-tree competition has reduced 

the health of trees. Areas with high tree density are common throughout the PAC and nest/roost recovery habitat. 

Uncharacteristic high tree densities have led to recent epidemics of fir engravers (Scolytus ventralis) that killed 

many large white fir trees (Abies concolor) within these areas.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 169

Table 3-47. MSO habitat within the Bill Williams Mountain Restoration Project Area

MSO Habitat Acres in Project Area

Designated Critical habitat 6,100

Protected Activity Centers PAC (outside of core area) 915

Core Area 103

Nest/roost Replacement Recovery habitat Mixed 

Conifer

1,207

Nest/roost Replacement Recovery habitat Pine-Oak 549

Recovery habitat (Pine-Oak) 4,349 (781 acres outside of UGM-13 EMU)

Due to decades of fire exclusion, the PAC and recovery habitat in the project area (Figure 3-44) is 

uncharacteristically dense. Without fire, the stands have high tree densities and inter-tree competition has reduced 

the health of trees. Areas with high tree density are common throughout the PAC and nest/roost recovery habitat. 

Uncharacteristic high tree densities have led to recent epidemics of fir engravers (Scolytus ventralis) that killed 

many large white fir trees (Abies concolor) within these areas.

Existing Conditions in Recovery Foraging Habitat

Recovery foraging habitat for the MSO is managed for a variety of purposes, including reducing fire hazard to 

PACs, providing foraging habitat, and providing for future nesting and roosting habitat. For the Bill Williams 

Mountain Restoration Project, MSO recovery foraging habitat is ponderosa pine-oak forest outside of recovery 

nest/roost habitat. All mixed conifer outside of the PAC is managed for nest/roost recovery habitat for the MSO. 

The pine-oak recovery foraging habitat within the project area is dominated by small to mid-sized trees (<18” 

DBH), has open to moderately closed canopies, is relatively even-aged, has very little topography, and exhibits 

low vegetative productivity. Uncharacteristically dense stands in these areas have led to epidemics of bark beetles 

and increased severity of dwarf mistletoe (Arceuthobium vaginatum), causing unhealthy forest conditions, 

including high mortality of trees, stunted growth of young trees, and extreme fire hazard to this habitat type in the 

Bill Williams Mountain Restoration Project Area.

Desired Conditions in MSO Habitat

Table 3-47 summarizes the desired condition by MSO habitat type for treatment in the PAC, Recovery Nest/Roost 

Habitat, and Recovery Foraging Habitat. The silviculture prescriptions would use these desired conditions and 

mitigation measures to ensure that the project implementation would follow the strategy established by the interdisciplinary team throughout the project’s planning process. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

170 Chapter 3. Affected Environment and Environmental Consequences

Table 3-48. Habitat/Vegetation Type and the Desired Condition of these types on the Bill Williams Mountain 

Restoration Project Area

Habitat Type General Description of Desired Conditions

MSO PAC in Presettlement patches

(247 acres)

Desired Conditions are for uneven aged forest characteristics. A Diversity of 

age/size tree classes would be maintained within these areas. Groups of all 

ages occur throughout the area. They are comprised of a diversity of seral 

stages, with many groups dominated by trees >18” DBH. Groups dominated by 

large trees have interlocking crowns, high canopy, complex understory cover, 

and a relatively continuous canopy. Those dominated by smaller trees develop 

interlocking crowns and high canopy cover over time. Canopy cover within 

groups average 60%. Basal area averages 80 ft.2 (including forested and nonforested areas) with group-level basal areas ranging from 60-160 ft.2

. Openings 

in patches range from 1-2 acres.

MSO PAC areas 

outside of presettlement patches

(771 acres)

Desired conditions for the matrix around the pre-settlement patches and small 

tree groups have lower basal areas than in patches. This promotes more 

diverse horizontal structure in the PAC and reduces the probability of standreplacing wildfire on Bill Williams Mountain. 

MSO Core Area

(103 acres)

Desired condition is for habitat heterogeneity (horizontal and vertical) with 

species diversity represented. A diverse composition of native herbaceous and 

shrub species is desired. Small openings 1/10 to 1 acre are desired. A diversity 

of tree sizes is desired with the goal of having trees > 16” DBH contributing > 50 

% BA. Basal area has a minimum of 120 ft2. Desired condition is to retain key 

owl habitat elements (large trees, snags, large hardwoods, etc.). Desired 

condition for fire in the core area is for cool season, low severity effects.

Mixed Conifer MSO 

Nest/Roost 

Replacement 

Recovery Habitat

(1,207 acres)

Desired condition is for multiple age classes of trees and to maintain species 

diversity. Prescriptions would strive to retain trees18 inches and greater. Basal 

area has a minimum of 120 ft2

. Canopy cover within groups is >60%. 

Pine Oak MSO 

Nest/Roost 

Replacement 

Recovery Habitat

(549 acres)

Desired condition is for uneven aged management. Basal areas are a minimum 

of 110 ft2.Canopy cover within groups is >60%. Prescriptions would strive to 

retain trees 18 inches and greater.

Pine Oak MSO 

Recovery Habitat

(4,349 acres)

Desired condition is more open than existing, with uneven aged management. 

Shade cover is greater than 40 % and trees greater than or equal to 24 inches 

DBH are retained. Average BA depends on pre-settlement conditions to guide 

prescriptions. 

Note: The basal area averages and ranges were developed by USDA Forest Service (FS) and United States Fish and Wildlife Service 

(USFWS) personnel in November 2011. The project is designed to enhance the key habitat components of MSO habitat while increasing 

forest sustainability.

Pre-Settlement Patches. The FS and USFWS worked together to identify 281 acres of pre-settlement patches 

(i.e., dense forest patches historically dominated by old, large diameter trees that persist today) that are greater 

than two acres in size (see Figure 3-45). These patches are to be maintained and managed to provide nest and 

roost habitat for the conservation of the MSO. The patches are delineated within or adjacent to the MSO PAC. 

This section outlines details regarding treatments within and around these patches. This section also provides 

further explanation which remains consistent with the action alternative, desired conditions, analysis, mitigation 

measures, and other components of the Bill Williams Mountain Restoration Project. 

The district biologist geo-referenced 1949 aerial photographs of Bill Williams Mountain and used these photos, in 

combination with 2010 ortho photos, to delineate patches of pre-settlement trees that were greater than 2 acres in 

size. The 1949 aerial photographs provided geospatial data that illustrated where large, contiguous patches of big, 

old trees historically occurred on the landscape.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 171

The forest confirmed that delineations based on 1949 aerial photos and 2010 ortho photos included the best 

patches of nesting and roosting habitat for MSO by overlaying other geospatial data. These data displayed 

northern aspects, the presence of drainages, and information on general tree density and density of trees >18” 

DBH.

The fire ecologist, silviculturist, and biologist met with staff from the USFWS and Arizona Game and Fish 

Department (AZGFD) to revise the patch delineations as necessary. The USFWS and AZGFD agreed with the 

patch delineations. The input and ideas from the USFWS and AZGFD are reflected in the map shown in Figure 

3-45. 

Figure 3-45. Priority Pre-settlement patches (281 acres) for MSO conservation
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

172 Chapter 3. Affected Environment and Environmental Consequences

Analysis of Effects to the MSO

The proposed Bill Williams Mountain Restoration project implements management that helps protect MSO 

habitat and ensures the maintenance of this habitat. Treatment within the PAC and recovery habitat would follow 

the Forest Plan which follows recommendations for treatment from the MSO Recovery Plan (2012). Each type of 

treatment/activity was analyzed for effects to the MSO below with MSO critical habitat in the section that 

follows. Table 3-49 shows a comparison of treatment methods by action alternative in the MSO habitat. The 

types of treatments/activities with the potential to affect the MSO and MSO critical habitat included in this 

analysis are: 

• Thinning Analysis, Including Strategic Fuel Breaks

• Road Construction, Maintenance, and Ground Disturbance from Thinning

• Other Effects of Disturbance 

• Effects from Prescribed Fire 

Table 3-49. Comparison of Treatment Method by Action Alternative in Acres of MSO Habitat

Alternative in MSO Habitat Type Conventional

Steep Slope 

Mechanical Helicopter

No 

Mechanical

Alternative 2. PAC 177 393 333 12

Alternative 2. MC N/R Recovery 204 703 265 35

Alternative 2. P-O N/R Recovery 155 347 47 0 

Alternative 2. P-O F Recovery 4,181 80 88 0 

Alternative 3. PAC 177 0 738 0 

Alternative 3. MC N/R Recovery 100 0 1,107 0 

Alternative 3. P-O N/R Recovery 218 0 331 0 

Alternative 3. P-O F Recovery 4,261 0 88 0 

Alternative 4. PAC 177 0 0 0 

Alternative 4. MC N/R Recovery 31 0 0 0 

Alternative 4. P-O N/R Recovery 164 0 0 0 

Alternative 4. P-O F Recovery 4,261 0 0 0 

Note: Acreages were calculated using ARC GIS data and are approximate estimates. For all alternatives thinning and burning in the MSO 

PAC would occur outside of the breeding season (March 1-August 31) to avoid disturbing nesting or roosting owls.

Alternative 1 – No Action 

Under alternative 1 habitat conditions for MSO may remain unchanged in the short-term, notwithstanding the 

effects of natural processes. However, alternative 1 would degrade habitat for owls in the long term. By not 

using mechanical treatments and prescribed fire to restore unnaturally dense forests, the no-action alternative 

would hinder restoration and maintenance of habitat for the species. For example, the evenness of trees among 

the three largest size classes in the PAC, as well as the percent of trees in these size classes, would be less under 

the no-action alternative than any of alternatives 2 and 3, even though alternatives 2 and 3 would maintain or 

increase the number of trees >18” DBH/acre.

Unnaturally dense forests increase the probability of stand-replacing wildfire and epidemics of insects and 

disease. Alternative 1 would perpetuate and compound this risk. These uncharacteristically severe disturbances 

would degrade or destroy the mature forests, trees >18” DBH, and snags on which this species relies. Under the 

no-action alternative, approximately 90% of the mixed conifer forest and 100% of the ponderosa pine (including 

pine-oak) forest in the project area would remain highly departed from its historical fire regime. The probability 

of active crown fire would only increase (currently at approximately 70% in Recovery Habitat and 80% in 

Protected Habitat) under the no-action alternative.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 173

For the MSO effects analysis, alternative 1 perpetuates the high probability of an active crown fire that would 

degrade most, if not all, MSO habitat associated with the project area. This could lead to conditions similar to the 

Pumpkin Fire of 2000, where an entire PAC was consumed by stand-replacing wildfire. No habitat treatments 

would occur under alternative 1. Therefore, alternative 1 would have No Effect (Direct, Indirect, or Cumulative) 

to MSO. While this is the only alternative that results in a no effect determination for the MSO, it does not meet 

many of the objectives of the project, including reducing the risk of high intensity stand-replacing wildfire to 

MSO habitat.

Alternative 2 − Modified Proposed Action

MSO Habitat Treatments. Table 3-50 shows how implementation in MSO habitat would create a diversity of 

patch sizes. A minimum patch size for the project is 2.5 acres. Larger patches were delineated using historic 

photos. These patches are scattered throughout the PAC and the core area. Patches dominated by pre-settlement 

trees would maintain old growth characteristics. Vertical diversity would be enhanced through the silvicultural 

prescription. All size classes of trees would be managed for. A substantial amount of vertical diversity of smaller 

trees would occur within canopy openings and under residual trees. Canopy openings for regeneration would be 

small (i.e., they are created by removing a single, mature tree).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

174 Chapter 3. Affected Environment and Environmental Consequences

Table 3-50. FS Veg. Model Run Tables Showing; Existing and After-Treatment Effects from the Modified Proposed Action on Key Habitat Components for the 

MSO (Protected Habitat and Mixed Conifer Nest/Roost Replacement Recovery Habitat)

Year BA

%BA by Size 

Class

(12-18” DBH)

%BA by Size 

Class

(18” DBH) TPA 18"+ Snags 18"+ Snags 12"+ Logs12"+ % Shade

Protected Habitat 915 Acres (excludes core area

Existing + SD 

(Range)

163 + 44

(70 -247) 

32% + 15

(8-58)

26% + 15

(0-53)

15 + 11

(0-39)

3.6 + 2.6

(0-10.9)

17.8 + 11.5

(0.08-45.24)

26 + 45

(0-106)

72 + 7.6

(51-83)

After first year + 

SD 

(Range) 

131 + 45

(29-203)

33% + 19

(7-90)

33% + 19

(0-67)

16 + 10

(0-39)

3.4 + 2.4

(0-10)

15.8 + 10

(0.46-39.61)

12 + 19

(0-70)

67 + 11

(28-82)

2033 118 34% 41% 18 2.3 4.9 22 64

2053 148 25% 50% 27 1.3 2.9 24 70

Mixed Conifer Nest/Roost Replacement Recovery Habitat 1,207 Acres

Existing + SD 

(Range)

149 + 43

(66-199)

26% + 19

(5-57)

20% + 11

(0-43

10 + 06

(0-51)

2.6 + 1.5

(.15-4.42)

11.9 + 5.3

(1.85-17.19)

14 + 06

(0-19)

70 + 09

(50-88)

After first year + 

SD 

(Range)

123 + 47

(55-199)

27% + 21

(06-58)

25% + 17

(0-62)

10 + 12

(0-51)

2.4 + 1.3

(0.12-4.16)

10.9 + 4.7

(1.55-15.53)

6 + 03

(0-9)

65 + 10

(45-78)

2033 77 29% 45% 13 2.6 6.1 17 53

2053 98 21% 51% 18 1.5 2.9 20 59
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 175

Table 3-51. FS Veg. Model Run Tables Showing; Existing and After-Treatment Effects from the Modified Proposed Action on Key Habitat Components for the

MSO (Pine-Oak Nest/Roost Replacement Recovery Habitat and Pine-Oak Recovery Habitat)

Year BA Oak BA

%BA by 

Size Class

(12-18” 

DBH)

%BA by 

Size Class

(18” DBH) TPA 18"+ Snags 18"+ Snags 12"+ Logs12"+ % Shade

Pine-Oak Nest/Roost Replacement Recovery Habitat 549 Acres

Existing + SD 

(Range)

144 + 85

(86-218)

14 + 12

(0-32)

28% + 12

(18-56)

15% + 17

(0-54)

9 + 14

(0-51)

2.0 + 1.05

(0-2.68)

8.4 + 4.1

(0.28-11.34)

6 + 23

(0-69)

69 + 13

(56-88)

After first year + SD 

(Range)

112 + 40

(81-155)

14 + 12

(0-32)

20% + 15

(15-54)

30% + 21

(0-72)

9 + 12

(0-43)

1.9 + 1.03

(0-2.72)

8.1 + 3.7

(0.28-10.33)

3 + 10.3

(0-30)

63 + 08

(55-78)

2033 100 18 31% 29% 13 1.1 5.4 9 60

2053 121 22 52% 24% 21 1.0 4.1 11 65

Pine-Oak Recovery Habitat 4,349 Acres

14 + 13

(0-39)

36% + 15

(5-62)

17% + 13

(0-54)

8 + 06

(0-26)

0.5 + 0.76

(0-4.05)

2.9 + 2.03

(0.03-10.89)

13 + 18

(0-72)

65 + 09

(24-86)

14 + 13

(0-39)

37% + 17

(3-54)

26% + 17

(0-72)

7 + 5.7

(0-43)

0.5 + 0.73

(0-3.94)

2.8 + 1.96

(0-10.33)

6 + 7.9

(0-31.16)

54 + 9.34

(25-88)

12 34% 45% 12 0.7 3.5 7 52

17 27% 53% 17 0.9 2.6 9 57
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

176 Chapter 3. Affected Environment and Environmental Consequences

A diversity of age/size classes would be maintained within these patches. The diversity of tree species would be 

maintained in each stand. Oaks would not be cut. A diversity of herbaceous cover would be enhanced by the 

diversity of forest structure induced by patches and openings. Areas outside of the patches would contain more 

open space than patches providing for a diversity of understory cover. Patches dominated by pre-settlement trees 

will be thinned from below to reduce ladder fuels, and create canopy gaps (approximately 1/10 acre in size) where 

existing canopy gaps can be enhanced. 

Mitigation measures to conserve pre-settlement and 24”+ DBH trees would drive prescriptions to mimic forest 

‘gap dynamics’. Gap dynamics are the change in space and time in the pattern, frequency, size, and successional 

processes of forest canopy gaps caused by the fall or death of one or more canopy trees, which creates a canopy 

gap. The fall or death of one or more canopy trees causes a new cohort of trees to recruit into a patch. Gaps will 

be formed in areas that lack pre-settlement and 24”+ DBH trees and contain surpluses of trees < 18” DBH. Trees 

up to 24” DBH (mainly 18” DBH and below) would be removed to mimic gaps for regeneration recruitment. To 

create variability and vertical structure, higher amounts of young (<5” DBH), intermediate (5-9” DBH), and 

suppressed trees would be retained in areas of lower fire hazard. Examples of such areas include moist drainages 

or depressions. The silvicultural prescriptions would meet the minimum canopy cover within stands (40% in 

pine-oak and 60% in mixed conifer). The silvicultural prescriptions would be designed to promote a diversity of 

tree sizes with goal of having trees ≥16” DBH contributing ≥50% of the stand BA.

The initial proposed treatments consist of thinning followed by prescribed broadcast burning. Trees from 1 inch 

to 24 inches DBH would be thinned with the majority of the trees removed being < 12 inches DBH on 10,691 

acres (in MSO recovery habitat and critical habitat). Trees from 1 inch to 18 inches DBH would be thinned with 

the majority of the trees removed being < 12 inches DBH on 2,671 acres (in MSO protected and nest/roost 

replacement recovery habitat). All yellow pines would be retained, along with Gambel oak and aspen. Thinning 

would occur over a range of size classes, leading to an uneven-aged condition. After thinning, slash would be 

machine and rough piled and burned, or lopped and scattered and burned depending on concentrations. 

Maintenance burning would occur at intervals of 3 to 15 years for up to 40 years to maintain the desired fuels 

profile. 

Proposed Treatments in MSO Habitat

Conventional Thinning (hand thinning or mechanical equipment). The modified proposed action proposes 

ground based conventional thinning on up to 11,110 acres in the project area. Conventional thinning would 

remove 310,800 tons of timber volume in the total project area. All yellow pines would be retained, along with 

Gambel oak and aspen. Thinning would occur over a range of size classes, leading to an uneven-aged condition. 

The proposed action includes 177 acres in the MSO PAC to be thinned using conventional treatment methods. In 

nest/roost replacement recovery habitat 204 acres of mixed conifer and 155 acres of pine-oak are proposed for 

conventional treatment methods. Trees from 1 inch to 18 inches DBH would be thinned with the majority of the 

trees removed being < 12 inches DBH on 530 acres. In pine-oak MSO recovery habitat trees from 1 inch to 24 

inches DBH would be thinned with the majority of the trees removed being < 12 inches DBH on 4,181 acres 

using conventional methods. 

Steep Slope Mechanical. The modified proposed action includes 2,400 acres designated for alternative steep 

slope ground-based thinning using new technology (steep slope harvester/forwarder) to remove material. Steep

Slope ground based thinning would remove 43,200 tons of timber in the total project area. All yellow pines 

would be retained, along with Gambel oak and aspen. Thinning would occur over a range of size classes, leading 

to an uneven-aged condition. In the PAC, 393 acres would be thinned using this method of treatment. In 

nest/roost replacement recovery habitat 703 acres of mixed conifer and 347 acres of pine-oak are proposed for 

steep slope mechanical treatment. In protected and nest/roost replacement recovery habitat trees from 1 inch to 18 

inches DBH would be thinned with the majority of the trees removed being < 12 inches DBH on 1,443 acres. In 

pine-oak MSO recovery habitat trees from 1 inch to 24 inches DBH would be thinned with the majority of the 

trees removed being < 12 inches DBH on 80 acres with this method. Technology proposed in the modified 

proposed action allows for snag conservation. Most snags can be retained using this method, with the only snags 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 177

removed being those that pose an immediate safety risk for operators or snags that cannot be avoided in the 

forwarder route. 

Helicopters to Remove Materials. The modified proposed action includes the use of helicopters to remove 

material from 1,060 acres. Helicopters would be used to remove approximately 19,080 tons of timber in the total 

project area. Alternative 3 proposes up to 4,050 acres where helicopters would be used to remove material. All 

yellow pines would be retained, along with Gambel oak and aspen. Thinning would occur over a range of size 

classes, leading to an uneven-aged condition. Helicopters to remove material would require that all hazard trees 

be removed from the entire area/unit where this activity occurs to provide for safety of the personnel on the 

ground outside of protected (closed cab) machinery. Within the proposed units where helicopters would remove 

material, some snags may be removed for safety reasons, and other snags would be retained. Using helicopters to 

remove material would result in the removal of snags in the MSO PAC (333 acres), mixed conifer nest/roost 

replacement recovery habitat (265 acres), pine-oak nest/roost replacement recovery habitat (32 acres), and pineoak recovery habitat (88 acres).

In protected and nest/roost replacement recovery habitat trees from 1 inch to 18 inches DBH would be thinned 

with the majority of the trees removed being < 12 inches DBH on 630 acres. In pine-oak MSO recovery habitat 

trees from 1 inch to 24 inches DBH would be thinned with the majority of the trees removed being < 12 inches 

DBH on 88 acres with this method. The forest will use patch cuts to avoid effects to snags in some areas. Areas 

of high volumes of snags could be deferred from treatment when operator safety is at risk. The silvicultural report 

for this project has quantitative FS Veg model estimates of snag densities and large logs over time. The desire is 

to maintain key habitat elements for the MSO where possible, while still treating the area to minimize the risk of 

stand-replacing wildfire. 

No Mechanized Equipment. Hand thinning in the PAC and within 1⁄4 mile of the PAC boundary would occur 

outside of the breeding season (March 1-August 31) to mitigate effects to the MSO. These areas were selected for 

this treatment because they are sparsely vegetated (with mostly PJ and small oaks), on ridge tops, and often 

contain cliffs and rock outcrops. Very few of the key habitat components for the MSO occur in these areas. Prey 

habitat does occur here and it is likely that owls hunt in these areas. Thinning would occur over a range of size 

classes, leading to an uneven-aged condition. Thinning to reduce fuel loading without the use of mechanized 

equipment (hand thinning with chain-saws) is proposed under the modified proposed action in 12 acres of the 

PAC, 35 acres of mixed conifer nest/roost replacement recovery habitat, and none in pine-oak nest/roost recovery 

habitat). In protected and nest/roost replacement recovery habitat trees from 1 inch to 18 inches DBH would be 

thinned with the majority of the trees removed being < 12 inches DBH on 47 acres. 

103 Acre Nest/Roost Core Area. There would be no thinning in the 103 acre nest/roost core area, and the area 

would be prescribed burned. By treating the area around the core area, and using prescribed fire as a treatment 

tool, fire management would only implement prescribed fire in the core area if the prescription can meet low 

intensity fire behavior and low severity fire effects using cool season burns.

Fuel Breaks. Approximately 2,500 acres of fuel breaks could remove some snags and large trees. While snags 

and large trees would be conserved where possible, some of these habitat attributes could be removed. This 

analysis used the maximum width of land that could be treated to create a fireline (600 ft.), or 73 acres of land 

would reduce surface, ladder, and canopy fuels for every one mile of fireline. Approximately 359 acres in the 

PAC and 1,222 acres in MSO recovery habitat would be treated for fuel breaks. Fuel break treatments would 

reduce surface, ladder, and canopy fuels up to 300 feet along both sides of the control lines. These acres would 

receive treatments and fuels would be thinned with hand-felling techniques. Large trees, >18 inches DBH in the 

PAC and nest/roost replacement recovery habitat and >24 inches DBH in other MSO recovery habitat would, will 

not be targeted, and would be conserved wherever possible. Large snags could be removed in these areas to 

accomplish fuel breaks. 

Road Construction, Transportation, and Maintenance. Construction of new roads (16 miles) would occur on 

0.2 miles (1.6 acres) of MSO nest/roost replacement recovery habitat, and 7.5 miles (60 acres) of MSO pine-oak 

recovery habitat. This analysis assumes that the average width of land cleared to create a roadbed is one chain (66 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

178 Chapter 3. Affected Environment and Environmental Consequences

ft.), or 8 acres of land would be denuded of trees for every one mile of road. Temporary road construction (0.1 

miles [0.8 acre] of protected habitat and 5 miles (40 acres) in MSO pine-oak recovery habitat) could occur. These 

roads would be obliterated after use. 

Effects from Thinning Including Strategic Fuel Breaks. Table 3-50 and Table 3-51shows the removal of trees 

from the protected habitat would reduce BA from 163 to as low as 131 following treatment. In nest/roost 

replacement recovery habitat BA would be reduced from 149 to as low as 123 in mixed conifer (165 to 125 in 

pine-oak nest/roost replacement recovery habitat) following treatment. In pine-oak recovery habitat BA would be 

reduced from 121 to as low as 78 following treatment (Appendix A). While the entire project area would not be 

treated at one time, the removal of large amounts of material in a short period of time would cause short term 

changes to the overall habitat condition through patch size alteration, changes to horizontal and vertical diversity 

within patches, changes in tree species diversity (though no oaks would be cut for this project), changes to the 

composition of herbaceous and shrub species from the effects of mechanized equipment, changes to opening sizes 

from alteration from mechanized equipment, and reduction of canopy cover from 100% in much of the project 

area to at least 40% in pine-oak and 60% in mixed conifer habitat. 

Effects to the MSO from thinning include changing the owl’s habitat structure; snags, downed logs, woody debris, 

multi-storied canopies, and dense canopy cover. The proposed thinning would also change the structure of MSO 

prey species’ habitat, affecting the abundance and composition of prey species in the short term. The proposed 

treatments may increase the diversity of vegetative conditions, which in turn would provide for a diverse prey 

base. Empirical models of factors that influence availability of Mexican spotted owls five common prey species 

indicate that microhabitat manipulation can influence abundance of the Mexican vole, followed by the long-tailed 

vole, Mexican wood rat, deer mouse and lastly the brush mouse (Ward 2001). Ward (2001) found that the total 

available biomass (kg) of mice and voles provided the strongest correlation with reproductive output. Model 

results indicated that abundance (g/ha) of the two vole species could be influenced by manipulating grass-forb 

height, whereas abundance of Mexican wood rats, the preferred prey, might be influenced by promoting shrub 

diversity and increasing large log cover.

By treating MSO habitat with fuels reduction treatments and prescribed fire, wildfire-induced mortality of key 

habitat components in recovery habitat would be reduced for the next several decades. In treated areas, there 

would be a short term increase in fire hazard in areas where slash needs to be cured before burning. This time 

period would last from 1 to 2 years. However, treatments would decrease fire hazard for several decades after 

burning is complete. 

Structure of nest/roost habitat could change as a result of treatment through loss of snags and some large trees that 

may have to be removed for strategic fuel break integrity. Wherever possible, trees greater than 18 inches in the 

PAC and nest/roost replacement recovery habitat and greater than 24 inches in other MSO recovery habitat would 

be retained. Areas with high volumes of snags would be avoided, if possible, during lay out of the fuel break line. 

Prey species habitat could change as a result of treatment in the short term, due to alteration from mechanized 

equipment (reduction in amounts of woody debris). 

Fireline preparation activities would focus on removing ladder fuels and reducing small understory trees that may 

increase passive crown fire behavior. The majority of trees to be removed are pole sized trees (1”-6” dbh). 

Fireline preparation activities may remove up to 75% of these pole size trees. Post fireline prep tree density 

values may range from 35-100 pole size trees per acre.

Overall, canopy closure would be maintained because trees >18” are not being removed unless they compromise 

firefighter safety. Based on on-site observations with the fuels specialist very few large trees will need to be 

removed and current values per acre are not expected to change significantly. Additionally, snags would be 

protected unless the snag poses a risk to firefighter safety and new snags may be created post prescribed fire 

implementation to offset any snags that may be removed during fireline preparation activities. 

It is expected that greater than 50 percent of the large logs present prior to fireline prep would be retained. A 

range of plant species and ground layer plant cover are important for maintaining MSO prey species. Little 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 179

change in ground layer plant species richness and cover in MSO habitat areas is expected during the 

implementation of fireline preparation activities. Slight decreases in plant cover and slight increases in species 

richness may occur within the first one to two years following pre-burn preparation, but these changes are 

unlikely to persist past the short term.

There is a potential for owls to relocate because of disturbance during treatment activities, though thinning in the 

PAC and within 1⁄4 mile buffer of the PAC would occur outside of the breeding season (March 1-August 31) to 

minimize effects to the MSO. Understory thinning in the project area followed by prescribed fire operations, will 

reduce surface fuel loads and basal areas. Canopy base heights will be increased, and large diameter trees will 

become more resistant to fire. Growth of fire resistant tree species such as pine and aspen would be promoted. 

Effects of Road Construction, Maintenance, and Ground Disturbance from Thinning. Compaction, rutting, 

and exposure of bare mineral soil can cause ground disturbance effects and the loss of vegetation. Landings, road 

construction, road obliteration, and other harvest activities could adversely affect the prey base on a short term 

basis by impacting individuals of prey species due to disturbance of prey species’ habitat. The following excerpt 

by the Kaibab National Forest’s Soil Scientist specialist report estimates the percent of disturbance by harvesting 

type in Arizona ponderosa pine forest on slopes less than 40 percent: 

Mechanical thinning of the ponderosa pine forests of Arizona has been occurring since the 1980s mainly through 

whole tree harvesting on slopes less than 40%. Typical equipment used for such harvesting includes rubber-tired 

feller bunchers and rubber-tired skidders with tracked dozers used for piling of slash. The amount of disturbance 

as a percentage of a typical harvest unit (i.e., area included in a timber sale) impacted by compaction, rutting, 

and/or exposure of bare mineral soil from this type of harvesting has been estimated to be roughly 8% associated 

with feller-buncher and skidding operations, 3% associated with machine piling of slash, 3% associated with 

landings, and 3% associated with temporary roads (MacDonald, 2013). Using helicopters to remove material 

would mostly avoid ground disturbance from heavy machinery on steep slopes (greater than 60%), and thus 

would generally prevent compaction, rutting, and/or exposer of bare mineral soil on steep slopes in the project 

area. Helicopter operations would require the use of landings where trees are processed and bundled for transport. 

On slopes greater than 40%, the modified proposed action would thin up to 2,400 acres using steep slope 

mechanized equipment. 

Of the 4,717 acres of ground based conventional method in MSO habitat, approximately 177 acres are protected 

habitat and 4,540 are recovery habitat. Roughly 660 acres (14 percent) could be impacted by compaction, rutting, 

and/or exposure of bare mineral soil. All harvest methods would require temporary roads which would result in 

additional acres that would be impacted by compaction and exposure of bare mineral soil. New roads, temporary 

roads, and roads to obliterate in MSO habitat are shown in Figure 3-44. 

Of the 1,523 acres proposed to be treated with steep slope mechanized equipment in MSO habitat, approximately 

393 acres are protected, and 1,130 acres are recovery habitat. Roughly 109 acres (14 percent) could be impacted 

by compaction, rutting, and/or exposure of bare mineral soil. 

No temporary roads would be constructed in the MSO nest core, reducing the potential for adverse effects to 

nesting owls. Temporary roads, landings and skid trails would be needed in protected and recovery habitat in 

order to accomplish thinning treatments; however all would be rehabilitated after harvesting (Soils Specialist 

Report). There would be 0 miles of temporary roads in protected habitat and 7.5 miles in recovery habitat, of 

which 0.2 miles is nest/roost replacement recovery habitat. The construction of temporary roads would remove 

important habitat components such as large trees, snags, and downed wood (assuming a 14-foot wide road) in 

61.6 acres in recovery habitat. 

Ground disturbance associated with landings, road decommissioning, temporary roads, and ground based harvest 

activities would be short term and temporary in nature, and although roads, landings and corridors might displace 

prey they would not limit their numbers in MSO recovery habitat. All ground disturbances would be rehabilitated 

after implementation (Soils Specialist Report). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

180 Chapter 3. Affected Environment and Environmental Consequences

Other Effects of Disturbance. In general, human activities have been documented to cause disturbance to raptors 

and in many instances can cause nest abandonment or changes in home range (Anderson et. al. 1990). Delaney 

and Grubb (2004) determined that spotted owls appear to be capable of hearing sounds from road maintenance 

equipment to distances of at least 400 meters (0.25 miles). Chainsaw operation caused most owls to flush from 

their perches when chainsaws were operated <60 meters (197 ft.) from roosting MSOs. Owl response decreased 

with increasing distance to noise source for chainsaw operation (Grubb 1999). Noise disturbance could be caused 

by project implementation activities including helicopters to remove material, thinning and burning, road 

construction, road maintenance, hauling of logs, and road rehabilitation in and adjacent to MSO habitat. No 

mechanical treatments would occur within the nest core. All treatment methods (thinning and burning) would 

occur outside of the MSO breeding season (March 1 – August 31) in the PAC and within a 1⁄4 mile buffer around 

the PAC.

Disturbance to the MSO from noise could be caused by project implementation activities in and adjacent to MSO 

habitat. Treatment within the PAC outside of the breeding season would not likely impact nesting success. 

Activities would occur during daylight hours when owls are typically roosting within the core area which would 

be protected from noise by geography. Since disturbance from thinning activities is spatially and temporally 

separated from breeding owls, the impacts from this activity are expected to be minimal. However, noise 

associated with hauling could disturb nesting owls and may occur in the project area. 

The MSO habitat within the project area has been surveyed according to approved protocols. Therefore, effects 

from proposed treatments to adult and young owls outside of the PAC are not expected. 

Nesting owls could be disturbed by noise from haul routes and trucks could potentially strike hunting owls, 

causing injury or death. The majority of the hauling activity would occur during day time hours when owls are 

not active; however there could be occasions when trucks are operating at times when owls would be hunting in 

the area. Main haul routes within 1⁄4 mile of the PAC boundary have been identified and include Forest Service 

Roads (FS) FS45 (Bixler Saddle Road), FS111 (Bill Williams Mountain Road) and a temporary road by the ski 

area on the eastern edge of the PAC.

The Bixler saddle road passes within a quarter-mile of the MSO core area, increasing the potential for vehiclerelated disturbance to nesting owls and collisions. Hauling of lumber within the project area may occur within 1/4 

mile of the core area and PAC boundary during the breeding season The Bixler Saddle Road is adjacent to the 

PAC and core area. To mitigate harassment to the MSO and to stay within the “amount of take statement” from 

the Biological Opinion for the proposed revised Kaibab National Forest Land and Resource Management Plan 

(LRMP), this route will only be used as a haul route for up to 3 consecutive seasons. If the material from the 

Bixler Basin area cannot be removed in three seasons consecutively, then seasonal restrictions will apply, limiting 

hauling to outside of the MSO breeding season. No hauling would occur within 1⁄4 mile of the PAC during the 

breeding season. 

Alternative 2 would treat 470 acres, which roughly correlates to a maximum of 431 truckloads of logs that would 

potentially be hauled adjacent to the nest core. There would be an estimated 95 acres/87 truckloads that could 

haul on FS111, and 215 acres/198 truckloads could haul over the temporary road by the ski area. This disturbance 

would occur consistently (i.e. greater than twice per hour) for an extended period of time (more than one hour) 

and could influence reproductive success if owls are nesting in these locations. 

Based on a normal operating season of April 15 – November 30 (150-210 days) assuming mechanical treatments 

accomplish eight acres per day; it could potentially take from 5-10 years to complete implementation in the 

project area. This is a conservative estimate; implementation could take less time to complete depending on 

weather, the contract procured, etc. However, most of the implementation will not occur in or near the PAC. 

Effects from Prescribed Fire. During broadcast burning activities, torching may occur within treatment areas. 

This is expected to create small openings of less than an acre in size; however a change in the stand structure from 

this type of event would likely not be detectable. Torching would mimic gap processes that occur under natural 

conditions (e.g. historic wildfire, windfall, and historic insect and disease outbreaks). Broadcast burning would 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 181

decrease coarse woody debris in all protected and recovery habitat treatments; however, levels would range from 

8 to 19 tons/acre in mixed conifer and pine-oak habitats and would exceed Forest Plan requirements (Fuels 

Specialist Report). Effects of reducing woody debris due to broadcast burning would decrease prey base 

abundance on a short term basis for approximately one year (Jenness 2000). Herbaceous vegetation typically 

responds favorably to prescribed fire, and an increase in forage for small mammals is expected to follow 

treatment. This would induce a corresponding increase in the small mammal prey base (Jenness 2000).

By treating MSO habitat with fuels reduction treatments and prescribed fire, risk of wildfire-induced mortality of 

key habitat components in protected and recovery habitat would be reduced for the next several decades. In 

treated areas, there would be a short term increase in fire hazard where slash needs to be cured before burning. 

This time period would last from 1 to 2 years. However, treatments would ultimately decrease fire hazard for 

several decades after burning is complete.

Smoke from burning may temporarily disturb MSOs. Rx burns would be managed to minimize the accumulation 

of smoke in the PAC during the breeding season. Impacts from smoke in the short term would be reduced by 

coordination, timing, and type of burning with wind direction, topography, time of year, and distance to the PAC 

considered. Burning would not occur in the nest core from March 1 to August 30, and burning would be 

restricted during the breeding season in areas that may create smoke impacts to the PAC and core area. Smokerelated effects from prescribed fire operations are not expected to be significant.

From burning there would be indirect effects from the modification of vegetation. Ground disturbance from 

treatment activities could adversely affect the prey base on a short term basis by impacting individuals of prey 

species due to disturbance of prey species’ habitat and harm from fire. Over the long term, improved understory 

vegetation, improved plant species richness, and increased diversity of vegetative structural stages would increase 

prey species.

Alternative 3

Alternative 3 differs from Alternative 2 in that:

• Approximately 2,400 acres of steep slope mechanical treatment would be accomplished using helicopters 

to remove the material.

• Thinning in the MSO PAC would be restricted to 9 inches and below. 

Thinning Analysis. Adverse effects to the MSO from Alternative 3 are greater than in Alternative 2. The reason 

is that differences exist between alternatives in how acres would be treated. Steep slope mechanical and 

mechanical equipment techniques for removing material are not part of Alternative 3. Instead, helicopters would 

be used to remove materials on these 2,400 acres.

Conventional Thinning. Effects to the MSO from conventional thinning are similar to alternative 2, except that 

trees greater than 9” DBH would not be cut in protected habitat. 

Helicopters to Remove Materials. Alternative 3 proposes using helicopters to remove material from a total of 

3,980 acres in the project area. Thinning in the PAC would occur outside of the breeding season (March 1-August 

31) to mitigate effects to the MSO. As most snags would be removed for the acres where this method is used to 

remove material, adverse effects to the MSO could occur under this alternative. Helicopters to remove material 

would require that all hazard trees be removed from the entire area/unit where this activity occurs to provide for 

safety of the personnel on the ground outside of protected (closed cab) machinery. Within the proposed units 

where helicopters would remove material, some snags may be removed for safety reasons, and other snags would 

be retained. Using helicopters to remove material would include the removal of snags in the MSO PAC (738 

acres), mixed conifer nest/roost replacement recovery habitat (1,107 acres), pine-oak nest/roost replacement 

recovery habitat (331 acres), and pine-oak recovery habitat (88 acres) could cause direct or indirect effects to 

MSO by loss/altercation of habitat, disturbing dispersing owls, or affecting their prey base. 

100 Acre Nest/Roost Core Area. Analysis is the same as in alternative 2.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

182 Chapter 3. Affected Environment and Environmental Consequences

Fuel Breaks. Analysis is the same as in alternative 2.

Road Construction and Maintenance Analysis. Effects from roads to the MSO are greater in Alternative 3, than 

in Alternative 2 because there is no steep slope mechanical option in alternative 3. Miles of new roads 

constructed are greater in Alternative 3 (22 miles; 7 more than in Alternative 2). Road construction would cause 

short-term degradation of habitat, including an incidental loss (i.e., a loss that is not the purpose of, but may result 

due to the nature of the activity) of trees >18” DBH, which serve as an important habitat component for nesting, 

roosting, and foraging MSOs. Approximately 11 miles of new roads would be constructed in MSO recovery 

habitat under Alternative 3 (0.5 miles in mixed conifer nest/roost replacement recovery habitat, 0.2 miles in pineoak recovery habitat, and 10.3 miles in pine-oak recovery habitat). Alternative 3 would involve construction of 

approximately 6.5 miles of temporary roads (obliterated after treatments are completed) in MSO recovery habitat 

(0.2 miles in mixed conifer nest/roost replacement recovery habitat, 0.2 miles in pine-oak nest/roost recovery 

habitat, and 6.1 miles in pine-oak recovery habitat).

As with Alternative 2, road construction in MSO recovery habitat under Alternative 3 has the potential to alter 

habitat characteristics and directly or indirectly affect MSO (see alternative 2 analysis).

Obliterating existing, poorly placed roads (24 miles) would reduce sedimentation and improve watersheds, which 

may benefit the habitat of MSO prey and increase their populations. Road obliteration would restore more native 

habitat and reduce recreational disturbance by humans. 

Prescribed Burning Analysis. This analysis is the same as alternative 2, except that 490 acres less would be 

prescribed burned under Alternative 3. For steep slopes, alternative 3 is expected to create fewer openings than 

alternative 2, increasing the risk of active crown fire for alternative 3 relative to alternative 2. Effects of 

prescribed burning on the MSO are the same as in Alternative 2.

Alternative 4

The main differences between Alternative 4 and the other action alternatives include:

• No helicopter logging. 

• No thinning on slopes greater than 40%. 

• No new road construction. 

• Thinning in the MSO PAC will be restricted to 9 inches and below. 

Thinning Analysis. Alternative 4 does not include helicopter logging or thinning on slopes greater than 40% from 

the proposed project. The steepest topography on Bill Williams Mountain would not be thinned, but could be 

burned under this alternative. Desired conditions may be hardest to achieve under this alternative due to high tree 

mortality as a result of increased fuel loading and steep topography. Mechanical thinning would be implemented 

on less than 40% slopes using; conventional, steep conventional; and mixed conventional methods (methods; 01, 

02 and 06; 11,126 acres).

In the MSO PAC, 177 acres would be thinned using conventional treatment methods. Trees greater than 9” DBH 

would not be cut in protected habitat. Thinning in the PAC would occur outside of the breeding season (March 1-

August 31) to mitigate effects to the MSO. In mixed conifer nest/roost replacement recovery habitat, 31 acres are 

proposed for conventional treatment methods. In pine-oak nest/roost replacement recovery habitat 164 acres are 

proposed to be thinned using conventional treatment methods. In pine-oak recovery habitat 4,261 acres are 

proposed using conventional treatment methods. Effects to the MSO from conventional thinning are the same as 

in alternative 3.

Fuel loading is potentially increased with this alternative, with canopy base heights increased and canopy bulk 

densities lowered. The habitat and watersheds have a high potential of high intensity stand-replacing wildfire and 

potential increase in mortality during prescribed fire due to fuel densities. Rare plant species are at increased risk 

due to potential for high fire severity. Implementing prescribed fire on the steep slopes of Bill Williams Mountain 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 183

is most difficult under this alternative because prescribed burning without thinning first could result in standreplacing fire conditions that would not allow fire managers to obtain the desired objectives. Effects to the MSO 

from thinning are less than in Alternatives 2 and 3. However, without thinning treatments in MSO habitat the risk 

of losing this habitat in the long-term to high intensity stand-replacing wildfire is increased.

100 Acre Nest/Roost Core Area. Prescribed burning would occur in the core area under Alternative 4. Effects to 

the MSO are the same as in alternatives 2 and 3.

Fuel Breaks. Analysis is the same as in alternative 2.

Road Construction and Maintenance Analysis. Alternative 4 would not involve the construction of new, 

Maintenance-Level 2 roads and would entail construction of approximately 38 miles of temporary roads. Road 

related habitat degradation is greatest under this alternative, compared to Alternatives 2-3 as alternative 4 includes 

the most miles of road construction. Road construction would cause short-term degradation of habitat, including 

an incidental loss (i.e., a loss that is not the purpose of, but may result due to the nature of the activity) of trees 

>18” DBH, which serve as an important habitat component for nesting, roosting, and foraging MSOs. Alternative 

4 would involve construction of approximately 17.4 miles of temporary roads (obliterated after treatments are 

completed) in MSO recovery habitat (0.4 miles in mixed conifer Nest/Roost Recovery Habitat, 0.2 miles in pineoak Nest/Roost Recovery Habitat, and 16.8 miles in pine-oak Foraging Recovery Habitat).

As with Alternative 2 and 3, temporary road construction in MSO Recovery Habitat under Alternative 4 has the 

potential to alter habitat characteristics and directly or indirectly affect MSOs.

Prescribed Burning Analysis. Alternative 4 is expected to create fewer openings from thinning than Alternatives 

2-3, increasing the risk of active crown fire. Effects to the MSO from burning treatments are increased from 

Alternative 2.

Analysis of Effects to Critical Habitat

MSO critical habitat elements were designated in the Federal Register 2004. All mixed conifer and pine-oak 

within Critical Habitat Units are designated as critical habitat. Primary constituent elements (PCEs) of MSO 

critical habitat are mixed conifer, pine-oak, and riparian forest types which contain the following: high basal area 

of large diameter trees; moderate to high canopy closure; wide range of tree sizes suggestive of uneven-age 

stands; multi-layered canopy with large overstory trees of various species; high snag basal area; high volumes of 

fallen trees and other debris; high plant species richness, including hardwoods; adequate levels of plant cover to 

maintain fruits, seeds, and regeneration to provide for the needs of Mexican spotted owl prey species. 

An analysis of Mexican spotted owl habitat has been completed within the 15,200 acre Bill Williams Mountain 

Restoration project area. Within the Bill Williams Mountain Restoration project boundary, 6,100 acres are 

designated MSO critical habitat within the UGM-13 critical habitat unit (Figure 3-44).

The primary constituent elements related to forest structure have the following attributes:

• A range of tree species, including mixed conifer, pine-oak, and riparian forest types, composed of 

different sizes reflecting different ages of trees, 30 percent to 45 percent of which are large trees with a 

trunk diameter of 12 inches or more when measured at 4.5 feet from the ground; 

• A shade canopy created by the tree branches covering 40 percent or more of the ground; and 

• Large dead trees (snags) with a trunk diameter of at least 12 inches when measured 4.5 feet from the 

ground. 

Primary constituent elements related to maintenance of adequate prey species have the following attributes:

• High volumes of fallen trees and other woody debris; 

• A wide range of tree and plant species, including hardwoods; and 

• Adequate levels of residual plant cover to maintain fruits, seeds, and allow plant regeneration. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

184 Chapter 3. Affected Environment and Environmental Consequences

Each type of treatment proposed can be analyzed for effects on MSO critical habitat. The types of treatments with 

the potential to affect MSO critical habitat included for this analysis are:

• Thinning Analysis

• Road Construction and Maintenance 

• Prescribed Fire

Alternative 1 – No Action

Alternative 1 perpetuates the high probability of an active crown fire that would degrade most of, or the entire, 

MSO critical habitat associated with the project area. This could lead to conditions similar to the Pumpkin Fire of 

2000, where an entire PAC was consumed by stand-replacing wildfire. No habitat treatments would occur under 

this alternative. Therefore, this alternative would not have adverse effects (Direct, Indirect, or Cumulative) to 

MSO critical habitat. While this alternative results in a no effect determination for MSO critical habitat, it does 

not meet all of the objectives of the project, including reducing the risk of high intensity stand-replacing wildfire 

in MSO habitat.

Effects to Primary Constituent Elements of MSO Critical Habitat from Alternative 1-No Action. 

Forest Structure

• The range of tree species would not improve under Alternative 1 in the short-term, and it would remain 

unchanged until active crown fire ignites in the area, which would cause a loss of most trees.

• Shade would not fall below 40% in the short-term. However, stand-replacing wildfire may cause a 

complete loss of shade canopy across most MSO Habitat in the long term.

• The number of snags would remain near current conditions in the short-term. A high number of snags 

would be created under Alternative 1 in the long term, as wildfire would likely cause high mortality in the 

project area.

Prey Species

• Fallen trees and woody debris would remain near current levels in the short-term. Many fallen trees and 

woody debris and would be created after stand-replacing wildfire.

• Oaks would remain suppressed in the short-term. Oaks would decrease over the long term, as they would 

be lost to active crown fire, and may regenerate robustly following a burn given their shade-intolerance.

• Herbaceous plant cover would remain suppressed in the short-term. Herbaceous plant cover (important 

for maintaining prey base of small mammals) would decrease, as soil erosion after uncharacteristic fire 

would inhibit growth of the understory (see Pumpkin PAC on Kendrick Mountain for example). 

Alternative 2 - Modified Proposed Action

Thinning Analysis. There are 6,100 acres of critical habitat associated with the Bill Williams Mountain 

Restoration Project area. Of these acres under this alternative, 2,378 would be thinned using Conventional 

methods, 2,376 would be thinned using Steep Slope Mechanical treatment, 969 acres would use helicopters to 

remove material, and 397 acres with hand thinning. The initial proposed treatments consist of thinning followed 

by prescribed broadcast burning. Trees from 1 inch to 24 inches DBH would be thinned with the majority of the 

trees removed being < 12 inches DBH on 3,429 acres (in critical habitat and MSO recovery habitat that overlaps 

with UGM-13). Trees from 1 inch to 18 inches DBH would be thinned with the majority of the trees removed 

being < 12 inches DBH on 2,671 acres (in MSO protected and nest/roost replacement recovery habitat that 

overlaps with UGM-13). 

In units where thinning would be implemented, mandatory conservation measures call for the protection of large 

oaks, large conifers, large snags, and large woody debris at recommended levels found in the Kaibab Forest and

2012 MSO Recovery Plans. In units where thinning would be implemented, mandatory conservation measures 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 185

call for the protection of large Gambel oaks, large conifers, large snags, and large woody debris at recommended 

levels found in the Kaibab Forest and MSO Recovery Plans. Mandatory conservation measures call for a canopy 

cover that maintains 40 percent or more ground shading in MSO critical habitat in areas where this PCE is 

available. The retention of large Gambel oaks, conifers, and snags will also provide a future source of woody 

debris and fallen trees. 

Thinning under the modified proposed action and the interrelated and interdependent action associated with these 

prescriptions would not change the range of tree and plant species present in MSO critical habitat. The project 

area would continue to maintain adequate levels of residual plant cover to maintain fruits, seeds and low plant 

regeneration necessary to maintain a prey base for MSOs. The thinning of trees with equipment may result in a 

short-term decrease of residual plant cover in this area. Plant cover is expected to increase in the first growing 

season after the implementation of this thinning. 

Effects to Primary Constituent Elements of MSO Critical Habitat from Thinning Under Alternative 2. 

Forest Structure

• Botanical biodiversity would improve Alternative 2. Restoration of structural diversity would create 

openings: retain large, uneven-aged patches dominated by trees > 18” DBH; and retain pre-settlement 

trees (30 percent to 45 percent of which are large trees with a trunk diameter of 12 inches or more when 

measured at 4.5 feet from the ground). If present, management would retain >30% of mixed-conifer and 

pine-oak stands with trees >12 DBH. If not present, the prescription would be designed to meet the 

desired condition.

• Canopy cover would not fall below 40% under this alternative. Even though Alternative 2 involves 

restoration to pre-settlement conditions across the ponderosa pine forests of the project area, desired 

conditions in MSO habitat would ensure that canopy cover would be maintained above 40% across the 

project area in critical habitat.

• Reducing inter-tree competition would increase the growth of trees >18” DBH, which would cause an 

increase in future snags. Prescribed fire would result in the creation and consumption of snags. Project 

implementation of Alternative 2 would increase the long term sustainability of the forest within the 

project area, thereby better securing the long term development of snags. However, helicopters used to 

remove material operations under Alternative 2 would cause a loss of existing snags on approximately 

969 acres of critical habitat. Construction of 2,500 acres of strategic fuels treatments would remove some 

trees and snags. This could have an adverse effect to MSO critical habitat.

Prey Species

• Helicopters to remove material would require that all hazard trees be removed from the entire area/unit 

where this activity occurs to provide for safety of the personnel on the ground outside of protected (closed 

cab) machinery. Within the proposed units where helicopters would remove material, some snags may be 

removed for safety reasons, and other snags would be retained. Removal of 969 acres of snags using 

helicopters would adversely affect prey species the MSO depends upon. Construction of 2,500 acres of 

strategic fuels treatments would remove some trees and snags. Thinning and burning treatments would 

increase the abundance and growth of oaks by reducing competition for sunlight, nutrients, and water. 

Prescribed fire may consume some oaks.

• Range of plant and tree species is expected to remain the same under the modified proposed action. 

• Herbaceous plant cover (important for maintaining prey base of small mammals) may decrease within the 

first year after consumption by prescribed fire. However, fire would return nutrients to the soil and 

stimulate higher growth thereafter (Griffis et al. 2001).

Road Construction and Maintenance Analysis. Alternative 2 has the least effect to MSO Critical Habitat from 

roads of any of the action alternatives. Construction of 15 miles of new roads would cause sedimentation and 

watershed degradation which may degrade MSO Critical Habitat along 7.7 miles of roads. The indirect or direct 

effects of temporary road construction (16 miles total with 5 miles in MSO Critical Habitat) could occur in the 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

186 Chapter 3. Affected Environment and Environmental Consequences

short-term, as roads would be obliterated after use. The effects of new road construction would be more 

pronounced, as it may take many years before roads re-vegetate on their own. However, best management 

practices would minimize soil erosion and watershed degradation from newly constructed, Maintenance-Level 2 

roads (open for administrative use only) after implementation (e.g., culvert removal to restore natural water 

flows). 

Road construction under Alternative 2 has the potential to alter habitat characteristics and directly or indirectly 

affect MSO Critical Habitat.

Obliterating 23 miles of existing, poorly placed roads would reduce sedimentation and improve watersheds, 

which may benefit the habitat of MSO prey and increase their populations. Road obliteration would restore more 

native habitat and reduce recreational disturbance by humans. 

Effects to Primary Constituent Elements of MSO Critical Habitat from Roads under Alternative 2. 

Forest Structure

• Range of tree species would not change under Alternative 2 as a result of road construction. 

• Shade would not fall below 40% under this Alternative. Even though Alternative 2 involves restoration to 

pre-settlement conditions across the ponderosa pine forests of the project area, desired conditions in MSO 

habitat would ensure that shade would be maintained above 40% across the project area in critical habitat.

• A small number of snags could be removed for road construction in critical habitat under Alternative 2. 

Snags would only be removed if they pose a risk to operators. Whenever possible large snags would be 

maintained.

Prey Species

• Removal of a small number of snags for road construction could affect prey species the MSO depends 

upon. Road construction could cause the removal of a small number of these habitat attributes. 

• Range of tree and plant species in MSO critical habitat would not change as a result of road construction 

under the modified proposed action. 

• Herbaceous plant cover (important for maintaining prey base of small mammals) may decrease slightly as 

a result of road construction. 

Prescribed Burning Analysis. Prescribed burning prescriptions would reduce the level of small-to-medium sized 

fuels that are more likely to ignite and can cause higher intensity fires under dry conditions. The burn prescription 

would allow for a low intensity burn that would create a mosaic of burned and unburned areas. The prescription 

would be designed to maintain a surface fire. The wetter north facing slope habitats are expected to have flame 

lengths averaging no more than one foot. The prescription calls for a backing fire to reduce fire intensity within 

the project area. Mandatory conservation measures call for the protection of large Gambel oaks, large conifers 

large snags, and large woody debris in MSO habitat at recommended levels. 

Tree mortality from burning associated with the Bill Williams Mountain Restoration Project is expected to be 

minimal for larger trees, with most mortality occurring in younger trees. No significant change in the existing 

shade canopy is expected to occur from the low intensity burn proposed. Shade canopy created by the tree 

branches covering 40% or more of the ground would remain in MSO Critical Habitat areas where this is currently 

available. Despite these precautions, a few snags are likely to be consumed during prescribed burning; however, 

some new snags would be created as well due to the burn. 

There would be no conversion or loss of vegetation types due to project implementation. A cool season burn in 

critical habitat may result in a short-term decrease of residual plant cover. An increase in plant cover is expected 

the following spring and during the breeding season. Over time residual plant cover is expected to increase, fruits 

and seeds would be maintained or increased, and plant regeneration would be promoted. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 187

Prescribed burning may cause a short-term reduction in herbaceous plant cover, but would not reduce cover below 

a level that is adequate to maintain fruits, seeds and low plant regeneration necessary to maintain a prey base for 

MSO. Prescribed burning under this proposed prescription associated with this project would improve MSO prey 

species habitat in the long term.

Effects to Primary Constituent Elements of MSO Critical Habitat from Prescribed Burning under 

Alternative 2. 

Forest Structure

• Prescribed burning under the proposed prescription and the interrelated and independent action associated 

with this prescription would not change the overall structure of MSO habitat in the project area. The 

resulting mosaic of burned areas and thinning is expected to help reduce the risk of stand-replacing 

wildfire, and to help reduce fuel loading in ponderosa pine habitat. No change in the range of tree species 

is expected to occur in MSO habitat in the project area.

• Shade would be maintained above 40% across the project area in critical habitat under this alternative. 

• Within areas that meet the definition of critical habitat, burning under the modified proposed action and 

the interrelated and interdependent action associated with the prescription would not change the levels of 

residual plant cover needed to maintain fruits, seeds and low plant regeneration. Herbaceous plant cover 

(important for maintaining prey base of small mammals) may decrease after the first year after 

consumption by prescribed fire. However, fire would return nutrients to the soil and stimulate higher 

growth thereafter (Griffis et al. 2001). Prescribed burning under the proposed prescription and the 

interrelated and independent action associated with this prescription would not change the overall density 

of large snags in the project area.

Prey Species

• Prescribed fire would result in the consumption and creation of fallen trees and woody debris. 

• The prescription in MSO habitat only allows for a low intensity burn that would maintain the vegetation 

diversity, including hardwoods in the project area. Following thinning and prescribed burning, the 

existing wide range of trees that include mixed conifer, ponderosa pine, piñon and juniper, and Gambel 

oak hardwoods would remain as would the wide array of existing vascular and non-vascular plant species. 

Burning treatments would increase the growth and abundance of oaks by reducing competition for 

sunlight, nutrients, and water. Prescribed fire may consume some oaks.

• Prescribed burning would provide for long term conditions suitable for increased herbaceous plant growth 

by removing a thick layer of dead plant debris within treated areas. The mosaic effect created by burned 

and unburned areas is also expected to increase herbaceous plant species diversity and in turn, assist in the 

production and maintenance of the MSO prey base. 

Alternative 3

Thinning Analysis. There are 6,342 acres of critical habitat associated with the Bill Williams Mountain 

Restoration Project area. Of these acres 3,267 would be thinned through conventional methods and 3,075 acres 

would be thinned using helicopters to remove material. In units where thinning would be implemented, 

mandatory conservation measures call for the protection of large Gambel oaks, large conifers, large snags, and 

large woody debris at recommended levels found in the Kaibab Forest Plan and 2012 MSO Recovery Plan. 

Mandatory conservation measures call for a canopy cover that maintains 40 percent or more ground shading in 

MSO Critical Habitat in areas where this PCE is available.

Effects to Primary Constituent Elements of MSO Critical Habitat from Alternative 3.

Forest Structure
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

188 Chapter 3. Affected Environment and Environmental Consequences

• Range of tree species would improve Alternative 3. Restoration of structural diversity would create 

openings: retain large, uneven-aged patches dominated by trees > 18” DBH; and retain pre-settlement 

trees (30 percent to 45 percent of which are large trees with a trunk diameter of 12 inches or more when 

measured at 4.5 feet from the ground). If present management would retain >30% of mixed conifer and 

pine-oak stands with trees >12” DBH. If not present the prescription would be designed to meet the 

desired condition. 

• Reducing inter-tree competition would increase the growth of trees >18” DBH, which would cause an 

increase in future snags. Prescribed fire would result in the creation and consumption of snags. Project 

implementation of Alternative 3 would increase the long term sustainability of the Forest within the 

project area, thereby better securing the long term development of snags. Helicopters to remove material 

would require that all hazard trees be removed from the entire area/unit where this activity occurs to 

provide for safety of the personnel on the ground outside of protected (closed cab) machinery. Within the 

proposed units where helicopters would remove material, some snags may be removed for safety reasons, 

and other snags would be retained. However, helicopter logging operations under Alternative 3 would 

cause a loss of existing and recruitment snags for 3,759 acres. These acres could have most of the snags 

removed. Construction of 2,500 acres of strategic fuels treatments would remove some trees and snags. 

This could have an adverse effect to MSO critical habitat.

Prey Species

• Removal of 3,759 acres of snags using helicopters would adversely affect prey species the MSO depends 

upon. Construction of 2,500 acres of strategic fuels treatments would remove some trees and snags. This 

could have an adverse effect to MSO critical habitat.

• Thinning and burning treatments would increase the abundance and growth of oaks by reducing 

competition for sunlight, nutrients, and water. 

• Herbaceous plant cover (important for maintaining prey base of small mammals) may decrease within the 

first year after consumption by prescribed fire. However, fire would return nutrients to the soil and 

stimulate higher growth thereafter (Griffis et al. 2001).

Road Construction and Maintenance Analysis. Effects from roads to MSO Critical Habitat are greater in 

Alternative 3, than in Alternative 2. There are seven more miles of new roads constructed in Alternative 3 for a 

total of 22 miles. Road construction would cause short-term degradation of habitat, including an incidental loss 

(i.e., a loss that is not the purpose of, but may result due to the nature of the activity) of trees >18” DBH, which 

serve as an important habitat component for nesting, roosting, and foraging MSOs. Approximately 11 miles of 

new roads would be constructed in MSO Critical Habitat under Alternative 3. Alternative 3 would involve 

construction of approximately 6.5 miles of temporary roads (obliterated after treatments are completed) in MSO 

Critical Habitat.

As with Alternative 2, road construction under Alternative 3 has the potential to alter habitat characteristics and 

directly or indirectly affect MSO Critical Habitat.

Obliterating existing, poorly placed roads (24 miles) would reduce sedimentation and improve watersheds, which 

may benefit the habitat of MSO prey and increase their populations. Road obliteration would restore more native 

habitat and reduce recreational disturbance by humans. 

Prescribed Burning Analysis. Effects from prescribed burning to MSO Critical Habitat from Alternative 3 are 

the same as Alternative 2. Also see thinning analysis Effects to Primary Constituent Elements of MSO Critical 

Habitat from Alternative 3 above, as burning is incorporated into Prey Species PCE analysis. 

Alternative 4

Thinning Analysis. Alternative 4 proposes to conventionally thin 2,240 acres with 40% or less slope in MSO 

critical habitat in the project area. Construction of 2,500 acres of strategic fuels treatments would remove some 

trees and snags. Effects from thinning to PCEs of MSO critical habitat in Alternative 4 are less than in 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 189

Alternatives 2 and 3 with the range of trees and forest structure in MSO habitat remaining largely unchanged 

under Alternative 4 from the existing condition. For operator safety, conventional thinning could cause the loss of 

some snags in critical habitat. This could have an adverse effect to MSO critical habitat. Though effects are less 

than in Alternatives 2 and 3, alteration of habitat following treatment under Alternative 4 could cause short-term 

adverse effects to MSO critical habitat. 

Road Construction and Maintenance Analysis. Alternative 4 would not involve the construction of new 

permanent roads and would entail construction of approximately 38 miles of temporary roads. Road related 

habitat degradation is greatest under this alternative, compared to Alternatives 2-3. Road construction would 

cause short-term degradation of habitat, including an incidental loss (i.e., a loss that is not the purpose of, but may 

result due to the nature of the activity) of trees >18” DBH, which serve as an important habitat component for 

nesting, roosting, and foraging MSOs. Alternative 4 would involve construction of approximately 17.4 miles of 

temporary roads (obliterated after treatments are completed) in MSO Critical Habitat. 

As with Alternatives 2 and 3, temporary road construction under Alternative 4 has the potential to alter habitat 

characteristics and directly or indirectly affect MSO Critical Habitat. 

Prescribed Burning Analysis. Effects from prescribed burning to MSO Critical Habitat from Alternative 4 are 

greater than Alternative 2 because many fire-killed snags would collapse. Also, an especially high number of 

snags would be created under Alternative 4, as burning without first mechanically thinning would cause fireinduced mortality of many trees. 

Direct and Indirect Effects Summary to the Species and Habitat

One Protected Activity Center, MSO recovery habitat, and designated MSO Critical Habitat occur in the project 

area. Implementation of thinning, road construction, and burning could have direct and indirect effects to the 

MSO and MSO Critical Habitat. Prescribed burning has been suggested as an effective tool to restore habitat to 

natural conditions with minimal short-term impact on resident owls (Bond et al. 2002). It is recommended that 

treatment areas outside of PACs that contain primary constituent elements for MSO Critical Habitat be evaluated 

for MSO occupancy prior to implementation. If MSOs are located in these areas, the South Zone of the Kaibab 

National Forest will contact USFWS to designate a new PAC (or redraw the existing PAC boundary), and amend 

or modify the silvicultural prescription and implementation timeline to mitigate adverse effects to the MSO and 

MSO Critical Habitat.

Cumulative Effects

The cumulative effects boundary for MSO is the action area, defined as the project area and a one-half mile buffer 

around the project. Activity effects over one-half mile from the project boundary diminish to very low levels and 

would not impact owls within the project (i.e. noise disturbance, smoke accumulations) and therefore would not 

combine with effects from other projects. The time period analyzed for cumulative wildlife effects includes a 51 

year time period (2004 to 2055). The main effects to owls from this project are related to the adverse effect of 

noise disturbance from implementation and the beneficial effect of improved habitat conditions. All project 

implementation is expected to be completed by 2025, with maintenance burning continuing through 2055, and the 

desired forest structure in MSO habitat would develop within this period. Reviews of all projects (past, present 

and reasonably foreseeable) that have the potential to impact owls during implementation follow in Table 3-52, 

Table 3-53, Table 3-54, and Table 3-55. 

Table 3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably 

foreseeable projects considered in the wildlife cumulative effects analysis for this project. Table 3-56 provides a 

partial listing of actions considered in the cumulative effects analysis for this project.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

190 Chapter 3. Affected Environment and Environmental Consequences

Table 3-52. Past projects in the Project Cumulative Effects Analysis Area

Project

Year NEPA 

completed Activities Status 

Williams High Risk Project 2005 Non-commercial thinning Completed

Clover High Fuels Reduction Project 2005 Non-commercial thinning Completed

Table 3-53. Current projects in the Project Cumulative Effects Analysis Area

Project

Year NEPA 

completed Activities Status 

City 2005 Veg. Mgt.: TS, TSI, & BB; includes some 

temporary roads and dozer lines

Currently being 

implemented

Twin 2005 TSI & Fuel reduction; includes some 

temporary roads and dozer lines

Ongoing – Approx. 

40% implemented

Bill Williams Cap 2009 Fuel reduction / Hazard Tree removal on 6 

ac.

DN signed – 

implementation 2010

Williams Ranger 

District Travel 

Management 

Project 

2010 Prohibit cross-country travel (except as 

designated on MVUM); close 380 miles of 

system roads to motor vehicle use.

Implemented in July 

2011 with 

publication of 

MVUM. 

Hat Allotment 

Grazing 

Management

2010 Authorizes grazing Ongoing

EIS for Treatment 

of Noxious or 

Invasive Weeds

2004 Treatment of Noxious or Invasive Weeds Ongoing

Dogtown Project Timber Sale; Prescribed burning; Noncommercial thinningPending Sales; 

Ongoing burning

Table 3-54. Reasonably foreseeable projects in the Project Cumulative Effects Analysis Area

Project

Estimated 

Year NEPA 

Completed Activities Status 

McCracken (WRD) 2010

Reconsulted 

with USFW 

in 2014

Thinning (15,200 ac), Burning (17,000 ac), 

Grassland Restoration

PA released in 

2008; Decision 

issued in June, 2012

Four Forest 

Restoration 

Initiative (Multiple 

Projects) 

Multiple Restoration of Ponderosa Pine ecosystem 

(thinning, burning)

Planning team and 

collaborative group 

are completing the 

Final EIS.

South Zone Travel 

Management 

Revision Project

2015 Revision to Travel Management Plan for 

South Zone of the Kaibab National Forest, 

including adding camping corridors and 

spur roads.

Public Scoping 

Packet Released in 

2014. Analysis 

initiated.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 191

Table 3-55. List of actions considered in the cumulative effects analysis for this project

List of actions considered in the cumulative effects analysis for this project

Activities such as vegetation management, fuels management, livestock grazing, recreational activities, and other 

management activities (e.g. noxious weeds treatments) have occurred in the past, are occurring, and are reasonably 

foreseeable actions on the Williams Ranger District. These activities could occur on private lands as well. 

Firewood cutting has occurred in the past and would likely continue in the foreseeable future on the District and private 

lands within watersheds that include the project area. 

Private landowners may harvest timber on their lands for lumber, fuelwood, or to reduce fire hazards. 

Urban development and interface growth would likely continue on private lands. 

Road construction, maintenance and right-of-way clearing can be expected to continue on non-National Forest System 

land. 

Road maintenance, reconstruction, or decommissioning may occur with future vegetation management projects on National 

Forest System land. 

Recreation activities are expected to continue to increase on the Forest. Future recreation projects may be developed. 

There is a multi-million dollar electronics site on the top of Bill Williams Mountain that includes communications 

infrastructure for the Department of Public Safety, USDA Forest Service, Arizona State Land Department, Burlington 

Northern Santa Fe railroad and several other governmental and private enterprises. Several special use permits exist and 

continue to be requested for the communications site such as cell tower extensions, new outbuildings, etc.

The north side of the mountain is home to a small ski and recreation area (Elk Ridge Ski and Outdoor Recreation Area) 

which operates periodically throughout the year with downhill skiing in the winter and tubing in the summer.

Review with the Forest Service Fuels Specialist concluded that smoke from broadcast and pile burning around the 

project would have similar short-term (3-5 days) and low intensity (drift smoke) effects of smoke to individual 

MSO. Burning inside PACs would occur outside the breeding season for all projects. Burning outside of PACs 

during the breeding season would be conducted in a manner that minimizes smoke impacts to MSO. However, it 

is anticipated that burning activities on portions of this project could occur simultaneously with burning activities 

on other fuels reduction projects. While there are numerous burning operations planned in areas adjacent to the 

project area, ADEQ standards limit the total amount of burning allowed in the airshed at a given time. Thus, 

smoke impacts to PACs are limited and expected to be the same as those analyzed in the effects section for this 

project and there would be no cumulative smoke impacts.

Vegetation treatments proposed for the Four Forest Restoration Initiative (4FRI) are expected to occur within the 

action area. Restoration of springs is proposed within the analysis area from the 4FRI and from Forest Plan 

Revision. Recovery nest roost habitat was identified in ponderosa pine as part of the analysis and nest roost 

recovery stands are located within the project area boundary. Any impacts to MSO would be mitigated by 

coordinating with 4FRI and in the McCracken project to limit entry into the PACs. Other ongoing implementation 

of fuels reduction projects such as City, Twin, Bill Williams Cap and Dogtown are designed to minimize impacts 

to owls and mitigation of disturbance from implementation has been incorporated into the project design for all of 

these projects, therefore cumulative effects from activities are expected to create minimal disturbance.

Decreases would occur in coarse woody debris, logs, and snags in the ponderosa pine for all of the above fuels 

reduction projects and would combine with the Bill Williams project to move toward desired conditions. Burn 

prescriptions and ignition techniques should limit overall losses of logs and snags. Burned snags would fall and 

provide logs, and trees killed by fire would become snags. The longevity of fire-killed snags is less than that of 

snags formed from other processes. However, maintenance burning from this and the other projects in the area 

(such as: 4FRI, McCracken, Twin, City, Bill Williams Cap, and Dogtown) should provide pulses of snags and logs 

through time. Less coarse woody debris is expected to be present as a result of prescribed burning. 

Thinning and burning should increase tree growth rates and self-pruning of the lower tree branches through time 

should gradually replenish course woody debris. Improving growing conditions should decrease density-related 

mortality of larger and older trees. Improving recruitment into the larger size classes would improve MSO habitat 

and the ability to provide large snags that remain on the landscape longer than smaller diameter or fire-created 

snags. This, when combined with the effects of other past present and foreseeably future activities in the area, 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

192 Chapter 3. Affected Environment and Environmental Consequences

would result in a net cumulative effect of short term reduction in key habitat components to the MSO, with long 

term beneficial effects through conservation of habitat and promotion of large trees, snags, woody debris, and 

diversity of understory and canopy. 

Cumulative effects from other projects such as the McCracken Forest Restoration project, which is adjacent with 

this project, would combine with effects from ground disturbance and noise disturbance to MSO and their habitat 

in the action area. Continued use of user-created trails in the area may disturb roosting or nesting owls. New roads 

or trails would not be designated for public motorized or recreational use as part of the Bill Williams Restoration 

project, and all temporary roads would be obliterated after implementation. This when combined with the effects 

of other past present and foreseeably future activities in the area would not result in a net cumulative effect of 

disturbance to the MSO or MSO critical habitat.

There are additive effects of reduction of understory vegetation by livestock grazing in, and adjacent to the project 

area. Livestock grazing would combine with short-term loss of understory vegetation from prescribed fire and 

logging operations. Allotments in and around the project area are managed on deferred rotational and deferred rest 

rotation grazing systems designed to allow forage a chance to recover from livestock grazing, reducing the 

potential for cumulative impacts. Prescribed burning would be coordinated with grazing schedules to minimize 

impacts to vegetation. This when combined with the effects of other past present and foreseeably future activities 

in the area would result in a net cumulative effect of short term reduction in key habitat components to the MSO 

(temporary reduction in understory and prey habitat), with long term beneficial effects through conservation of 

habitat and promotion of diversity of the understory and habitat characteristics for small mammals.

The net effect of the proposed action when combined with other past, present and foreseeable vegetation projects 

would contribute to resistant and resilient ecosystems, promoting landscape connectivity, and reducing the risk of 

uncharacteristic fire. Risks associated with dense forest conditions from the combined effects would be reduced 

and forest resiliency large scale disturbance under drier and warmer conditions would be improved by 

implementing the treatments proposed under all action alternatives. Individual tree growth would improve, 

resulting in larger average tree sizes. Species requiring habitat elements associated with closed canopy forest 

conditions or old or large tree, snag, and log structure would be more sustainable as forest resiliency is improved. 

Determination of Effect to the Species and Habitat

As documented in the analysis section, the level of effect from the implementation of the different phases of this 

proposal and the associated interrelated and interdependent actions could exceed a level that is insignificant and 

discountable; therefore, a determination of “May Affect, Likely to Adversely Affect” is made for the Mexican 

spotted owl. For the same reason, a determination of “May Affect, Likely to Adversely Affect” is made for 

Mexican spotted owl designated critical habitat.

3.7.1.2 Northern Goshawk

Existing Conditions

The northern goshawk in the Southwest primarily inhabits ponderosa pine and to a lesser extent, mixed conifer, 

forests. Nest areas typically occur on cooler, moister aspects and in drainages. Nesting goshawks prefer forests in 

later successional stages, often dominated by pre-settlement trees. Post-fledging family areas (PFAs) have 

patches of dense trees, developed herbaceous or shrubby understories, snags, downed logs, and small openings 

which provide protective cover and habitat for prey. Goshawks generally prefer stands of intermediate to high 

canopy cover for nesting and more open areas for foraging. Although juniper or pinyon-juniper woodlands are 

not heavily used by northern goshawks, some foraging may occur in these habitat types, especially in transition 

areas between ponderosa pine and pinyon-juniper habitats. Nesting habitat preference tends to increase with 

canopy cover, although many goshawks in Arizona nest in more open habitat. Small forest openings provide 

travel corridors, provide habitat for open-country prey, and encourage the dispersal of fledglings. Northern 

goshawks prey upon birds and mammals (Reynolds et al. 1992; BNA Online 2012). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 193

PFAs and nest areas within the project area are composed of ponderosa pine forest. Table 3-56 describes the 

goshawk habitat within the project area. Landscapes outside of goshawk post-fledging family areas (LOGPFA), 

habitat in mix conifer, and pine-oak habitat are managed for the MSO.

Two PFAs occur within the project boundary (Figure 3-46). Nest areas, alternate nest areas, and PFAs were 

delineated using historic nest locations and evaluations of best available habitat. PFAs outside the project 

boundary are too distant to be affected by noise or smoke disturbance. All potential nesting and foraging habitat 

in the project area and 0.5 miles beyond the boundary was surveyed for northern goshawks in 2011 according to 

protocol as directed in the Forest Plan (USDA 1988). No new PFAs were discovered during that survey period, 

although one adult goshawk was seen flying overhead in the vicinity of the southwestern PFA. 

Table 3-56. Acres of different goshawk habitat within the project area

Total Goshawk Habitat 15,068

Goshawk PFAs (excluding nest) 965

Goshawk Nest Stands 695

LOGPFAs (Ponderosa Pine Stands) 8,902

LOGPFAs (Mixed Conifer Stands) 1,973

LOGPFAs (Other) 2,533
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

194 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-46. Northern Goshawk PFAs with the Project Area

Northern goshawk habitat consists of late-seral ponderosa pine forest. The forest-wide habitat trend for late-seral 

ponderosa pine forest has declined as a result of timber management practices from the 1960s to the early 1990s. 

These practices favored cutting pre-settlement trees and altered late-seral ponderosa pine forests across the forest. 

Current forest management practices emphasize ecosystem restoration and maintenance. Recent projects, 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 195

including this project, do not allow cutting pre-settlement trees unless they pose a risk to safety or must be 

removed to create roads, etc. The age-class distribution of ponderosa pine across the Forest and project area is 

generally dominated by mid-seral stages, with some loss of old-growth and older trees, and some early-seral stage 

habitat created by wildfire. Snag densities, including the density of large snags, are increasing in ponderosa pine 

forests in the region of the project (Ganey and Vojta 2007). The Forest-wide population trend for northern 

goshawks is thought to be declining (see USDA 2010 for details). Monitoring and surveys are ongoing on the 

forest, including the project area. 

Direct and Indirect Effects

Alternative 1 − No-Action

Alternative 1 would not affect northern goshawks. Habitat conditions for the species would not change, 

notwithstanding the effects of natural processes. However, the No Action Alternative could degrade the habitat 

for goshawks in the long term; by not using mechanical treatments and prescribed fire to restore unnaturally dense 

forests, the No Action Alternative could hinder restoration of habitat for the species. Goshawk habitat would 

remain at high risk of active crown fire.

Alternatives 2−4 

Alternatives 2-4 would benefit goshawks by moving ponderosa pine forest, mixed conifer forest, and woodlands 

toward pre-settlement conditions in which the species adapted and evolved, while still conserving existing nest 

areas and PFAs regardless of historic conditions in these areas. Thinning treatments to restore unnaturally dense 

forests to historic conditions have been demonstrated to improve goshawk habitat (BNA Online 2012), so the 

mechanical treatments and prescribed fire under Alternatives 2-4 would benefit the species. Fuels-reduction 

treatments would develop a mosaic of uneven-aged forest across the landscape. Alternatives 2-4 would conserve 

groups of larger trees (typically 18” DBH or greater).

By thinning unnaturally dense forests, Alternatives 2-4 would reduce competition among trees, thereby promoting 

the growth of larger trees. Growth of trees >18” DBH would be greatest under Alternative 2, intermediate under 

Alternative 3, and least under Alternative 4, as these alternatives have (in said order) progressively less flexibility 

in reducing competition around trees >18” DBH. Thinning and prescribed fire would reduce the probability of 

stand-replacing wildfire in forests, thereby conserving the mature forest, trees >18” DBH, and snags on which this 

species relies. Reductions in fire hazard to goshawk habitat are greatest under Alternative 2, intermediate under 

Alternative 3, and least under Alternative 4, as these alternatives have (in said order) progressively less 

mechanical treatment. More open habitat around PFAs and nest areas under Alternative 2 would reduce fire 

hazard to PFAs and nest areas, in comparison to Alternatives 3-4. 

As Alternative 2 would most improve tree growth while still conserving nest areas and PFAs at high densities, it 

would most benefit the production of large live trees, recruitment of snags, and recruitment of down logs (habitat 

attributes important to goshawks and their prey). Groups of trees would occur in areas where historical evidences 

exist or where best group/clump structure exists at time of implementation. Snags and down logs would be 

conserved per Forest Plan direction. Woody debris would be conserved over the long term, although all of the 

Action Alternatives would cause a short-term reduction in woody debris below forest plan direction. The only 

exception is that mixed conifer landscapes outside PFAs would increase in woody debris, even the short term, due 

to the high number of trees consumed by high-severity fire. A diverse age and size class and interlocking crowns 

would occur in clumps. 

Smoke from broadcast and pile-burning may disturb goshawks, including nesting individuals. Smoke 

accumulation during times when goshawks are incubating eggs and tending nestlings and fledglings could cause 

adults to leave the area. Smoke tends to settle into low-lying areas, including drainages which goshawks inhabit. 

Due to prevailing winds from the southwest, smoke generally affects goshawks to the northeast of burning 

activities. Smoke may have short-term (3-5 days) effects. Smoke accumulation may cause goshawks to flush 

from nest areas or change their foraging behavior. This could cause goshawks to expend more energy or become 

more vulnerable to predators. However, fuels specialists would avoid burning all goshawk PFAs in the project 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

196 Chapter 3. Affected Environment and Environmental Consequences

area at once, which would reduce the overall effect by providing refugia for the species. Impacts from smoke are 

reduced by the coordination of timing and type of burning with wind direction, topography, and time of year. 

Prescribed fire and mechanical treatment of hazardous fuels may result in a loss of snags; however, mitigation 

measures include fire-lining snags 18” DBH and greater prior to broadcast burning. Throughout the project, 

torching may occur within treatment areas during broadcast burning activities. Torching would mimic gapproducing processes that occur under natural conditions. Alternatives 2-4 may result in a slight short-term 

decrease in snags followed by an increase over the long term. Alternative 4 (and Alternatives 2 and 3, if 

prescribed fire is used without first mechanically treating areas) would result in a higher loss of snags, as dense 

stand conditions would lead to more loss of forest and snags to torching. Noise from mechanical treatments 

would not likely directly affect nesting goshawks, as no thinning would occur within active PFAs during the 

breeding season.

Woody debris and snags provide habitat for small mammals and other prey. Indirect effects of reducing woody 

debris due to broadcast burning would decrease the abundance of prey on a short-term basis for approximately 

one year. However, herbaceous vegetation typically responds favorably to broadcast burning, and an increase in 

forage for small mammals is expected in years without drought (Jenness 2000). Model results indicated that the 

abundance of small mammals increases with the height of herbaceous growth, the diversity of shrubby vegetation, 

and the amount of downed logs (Ward 2001). Under Alternatives 2-4, prescribed fire would stimulate grass-forb 

growth and result in both a consumption and creation of downed logs.

As Alternatives 2-4 would entail identical treatments within goshawk PFAs and nest areas, they would have the 

same effect on snags, woody debris, and down logs. Snags would increase over time. The Action Alternatives 

would increase snag conservation in nest areas and PFAs in comparison to the No Action Alternative. There 

would be an initial decrease in down logs and woody debris (due to consumption by prescribed fire), but there 

would be a long-term increase. Down logs and woody debris would still be conserved, although there would be a 

short-term reduction in levels of woody debris. 

In landscapes outside PFAs in pine forest, Alternative 2 would most conserve snags. Alternative 4 could cause a 

short-term spike in snags in mixed conifer forest outside PFAs, and it could create and retain the most snags over 

time. Most mixed conifer forest occurs on steep slopes that would not receive mechanical treatment before 

prescribed fire. Therefore, many trees could die from prescribed fire, causing a flush of snag creation, followed 

by many snags falling and turning into down logs. 

Road obliterations (and for Alternatives 2 and 3, conversion of road to trail) would restore more native habitat and 

reduce disturbance by humans. They would improve the condition of the soil and watersheds in the species’ 

habitat. These activities would not occur within active PFAs during the breeding season and therefore would 

negligibly affect the species. Construction of roads would clear trees and snags across approximately 304-312 

acres. Construction of fireline could remove up to approximately 2,500 acres of snags and ladder fuels. 

Alternative 4 would have less road-related impacts than Alternatives 2-3, as no new Roads or trails would be 

constructed under this Alternative. Alternatives 2-3 would result in 0.7 miles (6 acres) of temporary road 

construction and 5.1 miles (4 acres) of new road construction within goshawk PFAs and nest areas. Alternative 4 

would result in 5.8 miles (5 acres) of temporary road construction within goshawk PFAs and nest areas but no 

new road construction in PFAs or nest areas. All other road construction (see description of alternatives) would 

occur in landscapes outside PFAs.

In general, Alternatives 2-4 would reduce the acreage of mid to late seral forest by removing some patches of late 

seral, post-settlement trees. Alternatives 3-4 would cause less of a decline than Alternative 2, as more postsettlement patches would be retained under these alternatives. Pre-settlement trees would be conserved wherever 

possible under all action alternatives. PFAs and nest areas would remain dense under all Action Alternatives, with 

moderate to high canopy cover, and many large trees per acre. Desired conditions for these areas would promote 

sustainability of habitat and populations of this species. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 197

Under Alternative 4, even though many fewer snags >18” DBH would be cut, the lack of mechanical treatments 

on many areas with steep slopes would still lead to consumption of many snags by fire (high fuel loadings would 

lead to greater torching of tree groups and snags).

Loss of snags, whether from cutting under Alternatives 2-3 or severe fire under Alternative 4, would degrade the 

quality of habitat for the species, as snags serve as an important habitat component for many prey species. 

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 51 years beginning with the first date (2004) from past projects in the area, were considered. Table 

3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably foreseeable 

projects considered in the wildlife cumulative effects analysis for this project. A partial list of actions considered 

in the cumulative effects analysis for this project is included in Table 3-56. 

The cumulative effects of the No Action Alternative would be to increase the number of acres of National Forest 

System lands that are vulnerable to severe fire effects, as dense forest conditions would continue to place goshawk 

habitat and adjacent habitat at risk of stand-replacing fire. The fire hazard would increase over time as vegetation 

would continue to grow, fuel continue to accumulate, and the impacts of climate change continue, thus continuing 

to have negative effects to northern goshawk.

From alternatives 2-4 there are additional indirect effects from vegetation modification activities occurring in 

other projects (such as: 4 FRI, McCracken, Dogtown), including hazard tree removal for power lines and 

highways, as well as tree removal for development of state and private lands. Grazing can temporarily reduce 

vegetative cover. The Hat grazing allotment in the project area is managed on deferred rotational and deferred rest 

rotation grazing systems designed to allow forage a chance to recover from livestock grazing, reducing the 

potential for cumulative impacts. Generally, projects are designed to move toward the desired conditions for 

northern goshawks as identified in the Forest Plan. Cumulatively, these projects and activities may impact 

northern goshawks but are not likely to cause a trend toward listing or loss of viability. 

Determination of Effects

Alternatives 2-4 may adversely impact northern goshawks in the short term but could cause a long-term beneficial 

impact. Alternatives 2-4 would not cause a trend toward listing or loss of viability of the species. More habitat 

would be protected and restored for the species under Alternative 2 than under Alternatives 3-4, as there would be 

less fire hazard and more flexibility to promote the growth of the largest trees that this species uses for nesting and 

which serve as recruitment snags and down logs on which prey species rely. Alternative 4 would have less roadrelated impacts than Alternatives 2-3. 

3.7.1.3 Bald Eagle

Existing Conditions

The bald eagle was removed from the list of threatened and endangered species in 2007 (FWS 2007). Eagles are 

currently protected under the Bald and Golden Eagle Protection Act and are a Forest Service sensitive species. 

Bald eagles have recently nested at Whitehorse Lake, approximately 10 miles east of the project area. Wintering 

eagles on the Kaibab have been recorded in the fall (usually late October-early November), and leave in early to 

mid-April. 

Roosting: Small or moderately sized groups (usually 2-50) of bald eagles roost at night in clumps of large trees in 

locations such as drainages and hillsides (Grubb and Kennedy 1982, Dargan 1991). Eagles typically roost in 

ponderosa pine stands that vary in size (1-43 acres), often occur on north or northeast-facing slopes, and are close 

to daytime foraging areas (Dargan 1991). Roost trees are large (averaging 28” DBH) live or dead ponderosa pine 

trees that occur in groups (Dargan 1991). 
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198 Chapter 3. Affected Environment and Environmental Consequences

Foraging: Eagles forage widely and opportunistically on carrion, waterfowl, fish, and terrestrial vertebrates. 

Eagles will use any open water that supports waterfowl. No large water bodies occur within the project area, so 

foraging eagles within the project area most likely target carrion and terrestrial vertebrates for food. Eagles likely 

forage from snags and dead-topped trees within and at the fringes of the project area. 

Direct and Indirect Effects for the No-Action Alternative (Alternative 1)

The No-Action Alternative would not affect bald eagles. Habitat conditions for the species would not change, 

notwithstanding the effects of natural processes. However, the No Action Alternative would perpetuate overly 

dense forest conditions in fire-dependent ecosystems. Such conditions increase the potential for high-severity 

wildfire in and around eagle habitat. This may reduce the amount of trees >18” DBH, snags, and other important 

habitat attributes for bald eagles.

Direct and Indirect Effects for Alternatives 2-4 

Alternatives 2-4 would benefit eagles by moving ponderosa pine forest, mixed conifer forest, woodlands, and 

grasslands toward pre-settlement conditions to which the species adapted and evolved. Mechanical treatments 

and prescribed fire under Alternatives 2-4 would benefit the species by restoring more open areas for foraging and 

by reducing fire hazard to trees >18” DBH, snags, and the general habitat of eagles. Fuels-reduction treatments 

would develop a mosaic of uneven-aged forest across the landscape. Alternatives 2-4 would conserve groups of 

larger trees (typically 18” DBH or greater).

By thinning unnaturally dense forests, Alternatives 2-4 would reduce competition among trees, thereby promoting 

the growth of larger trees. Growth of trees >18” DBH would be greatest under Alternative 2, intermediate under 

Alternative 3, and least under Alternative 4, as these alternatives have (in said order) progressively less flexibility 

in reducing competition around trees >18” DBH. Thinning and prescribed fire would reduce the probability of 

stand-replacing wildfire in forests, thereby conserving the mature forest, trees >18” DBH, and snags on which this 

species relies. Reductions in fire hazard to eagle habitat are greatest under Alternative 2, intermediate under 

Alternative 3, and least under Alternative 4, as these alternatives have (in said order) progressively more 

mechanical treatment.

Openings important to foraging eagles would be scattered throughout ponderosa pine and woodland habitat with 

progressively more openings as an eagle moves from nest areas to PFAs to foraging areas. Snags, downed logs, 

and woody debris would be conserved per forest plan direction. A diverse age and size class and interlocking 

crowns would occur in clumps. These conditions would benefit eagles by sustaining foraging perches and habitat 

for prey. 

Smoke from prescribed fire and noise from mechanical treatments may disturb the species. These disturbances 

may cause the species to abandon areas and become more vulnerable to predators. Impacts from smoke are 

reduced by the coordination of timing and type of burning with wind direction, topography, and time of year. 

Prescribed fire and mechanical treatment of hazardous fuels may result in a loss of snags; however, mitigation 

measures include fire-lining snags 18” DBH and greater prior to broadcast burning. Throughout the project, 

torching may occur within treatment areas during broadcast burning activities. Torching would mimic gapproducing processes that occur under natural conditions. Broadcast burning may decrease woody debris by up to 

approximately 50% of existing volume, and decrease the number of snags by 20% (Randall-Parker and Miller 

2000). Alternatives 2-4 may result in a slight short-term decrease in snags followed by an increase over the long 

term. Alternative 4 (and Alternatives 2 and 3, if prescribed fire is used without first mechanically treating areas) 

would result in a higher loss of snags, as dense stand conditions would lead to more loss of forest and snags to 

torching. 

Woody debris and snags provide habitat for small mammals and other prey. Indirect effects of reducing woody 

debris due to broadcast burning would decrease the abundance of prey on a short-term basis for approximately 

one year. However, herbaceous vegetation typically responds favorably to broadcast burning, and an increase in 

forage for small mammals is expected in years without drought (Jenness 2000). Model results indicated that the 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 199

abundance of small mammals increases with the height of herbaceous growth, the diversity of shrubby vegetation,

and the amount of downed logs (Ward 2001). Under Alternatives 2-4, prescribed fire would stimulate grass-forb 

growth and result in both a consumption and creation of downed logs.

Road decommissions (and for alternatives 2-3, conversion of road to trail) would restore more native habitat and 

reduce disturbance by humans. They would improve the condition of the soil and watersheds in the species’ 

habitat. Construction of new and temporary roads could clear trees and snags across approximately 304-312 

acres. Construction of fireline could remove up to approximately 2,500 acres of snags and ladder fuels. 

Alternative 4 would have less road-related impacts than Alternatives 2-3, as no new roads or trails would be 

constructed under this Alternative. 

Under Alternative 4, even though many fewer snags >18” DBH would be cut, the lack of mechanical treatments 

on many areas with steep slopes would still lead to consumption of many snags by fire (high fuel loadings would 

lead to greater torching of tree groups and snags).

Loss of snags whether from cutting under alternatives 2-3 or severe fire under alternative 4, would degrade the 

quality of habitat for the species, as the species uses large snags for roosting, and snags serve as an important 

habitat component for many prey species.

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 40 years beginning with implementation of the project were considered. Effects for a period of 51 

years beginning with the first date (2004) from past projects in the area were considered Table 3-53, Table 3-54, 

and Table 3-55. Table 3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and 

reasonably foreseeable projects considered in the wildlife cumulative effects analysis for this project. .

The No Action Alternative would maintain the current fire risk to bald eagle habitat and adjacent forest lands. 

The cumulative effects of the No Action Alternative would be to increase the number of acres of National Forest 

System lands that are vulnerable to severe fire effects, as dense forest conditions would continue to place bald 

eagle habitat and adjacent habitat at risk of stand-replacing fire. The fire hazard would increase over time as 

vegetation would continue to grow and fuel would continue to accumulate. Forests would continue to be 

susceptible to the effects of climate change including vulnerability to insects, disease, and high severity fire, thus 

continuing to have a negative effect to potential bald eagle habitat.

From alternatives 2-4 there is no effect to nesting eagles as there are no nesting eagles present within the project 

area; however, there may be possible short-term disturbance to potential roosting habitat with long term benefits. 

Short term disturbance to foraging bald eagles would occur during thinning and broadcast burning activities and 

may cause eagles to forage in nearby areas for the duration of the activity. These short-term impacts added to 

similar impacts from past, present, and reasonable foreseeable projects (including 4FRI, McCracken, City, twin, 

and Dogtown Projects) were considered. Implementation of other fuels reduction project activities could occur 

simultaneously; however, it is not anticipated to combine to cause a negative effect. Vegetation treatments in 

adjacent projects would also improve tree vigor and growth, and vegetative structural stage diversity, thus 

promoting the growth of larger trees and habitat components for eagles as well as the forest’s resiliency to climate 

change. Other cumulative effects include hazard tree removal for power lines, communication sites and 

highways, which have reduced the number of snags and large trees for perching along potential winter foraging 

areas in the project area; however it is not anticipated to combine to cause a negative effect. 

Determination of Effects

Alternatives 2-4 could affect individuals but would not cause a trend toward federal listing or loss of viability. 

More habitat would be restored for the species under Alternative 2 than under Alternatives 3-4, as there would be 

more flexibility to promote the growth of the largest trees that this species uses for roosting and foraging and 

which serve as recruitment snags and down logs on which prey species rely. Furthermore, Alternative 2 would 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

200 Chapter 3. Affected Environment and Environmental Consequences

restore more open areas that are important to foraging eagles. Alternative 4 would have less road-related impacts 

than Alternatives 2-3. Unintentional take of eagles would not occur under any of the Alternatives. 

3.7.1.4 American Peregrine Falcon

Existing Conditions 

The FWS removed the peregrine falcon from the Federal List of Endangered and Threatened Wildlife in 1999 

(FWS 1999). However, the species remains a Forest Service Sensitive species (USDA 1988). Peregrine falcons 

require rock cliffs for nesting and expansive foraging areas. Suitable nesting sites on rock cliffs have a mean 

height of 200-300 ft. The species occurs statewide as a migrant, transient, and/or wintering individual (Corman 

and Wise-Gervais 2005; BNA Online 2012). The subspecies anatum permanently resides on the Kaibab National 

Forest and breeds on isolated cliff ledges. It is only known to currently or historically nest at three locations on 

the Williams Ranger District.

Peregrine falcons historically nested on Bill Williams Mountain but have not been detected nesting in the area in 

several years. The locations of this nest area overlaps with the Bill Williams PAC. Prey species include bats, 

mammals, and birds; however, peregrine falcons mainly predate wetland birds in riparian areas, meadows, 

parklands, croplands, mountain valleys, and lakes within a 10-20 mile radius of the nest area. The species’ 

breeding season occurs from March 1st to August 31st (Corman and Wise-Gervais 2005; BNA Online 2012). 

Direct and Indirect for the No-Action Alternative (Alternative 1)

The No Action Alternative would not affect the peregrine. Habitat conditions for falcons would not change, 

notwithstanding the effects of natural processes. However, by not removing conifers which have encroached 

upon grasslands, meadows, and savannas, the No Action Alternative would prevent the conservation of foraging 

habitat for falcons. 

Direct and Indirect for Alternatives 2-4 

Alternatives 2-4 would treat around areas where Peregrine Falcons have been observed to nest in the past. As this 

is a cliff-nesting species and as the area around historic or potential nest sites are primarily rock, the Action 

Alternatives would not affect the nesting habitat of the species. However, mechanical treatments and prescribed 

fire would restore grasslands, meadows, and savannas toward pre-settlement conditions to which the species 

adapted and evolved and would therefore benefit the species. Alternative 2 would better restore more grasslands, 

meadows, and savannas than Alternatives 3-4, as more openings would be created. 

The ecosystems within the project area have all adapted and evolved to periodic fire (USDA 2012), and it is 

reasonable to assume that the species within these ecosystems have also adapted and evolved to this disturbance. 

Herbaceous vegetation would increase in abundance and diversity with prescribed fire. This would cause an 

increase in the population of terrestrial prey, which would benefit peregrine falcons. Herbaceous growth and 

related benefits would be higher under Alternative 2 than Alternatives 3-4, as canopies would be more open across 

the project area, which would in turn promote higher herbaceous growth. 

Noise from mechanical treatment of hazardous fuels may disturb falcons. However, timing restrictions around 

active nests would prevent noise disturbance from affecting reproductive success. Smoke from prescribed fire 

may disturb the species. These disturbances may cause the species to abandon areas and become more vulnerable 

to predators. Impacts from smoke are reduced by the coordination of timing and type of burning with wind 

direction, topography, and time of year. 

Road decommissions (and for Alternatives 2-3, conversion of road to trail) would restore more native habitat and 

reduce disturbance by humans. They would improve the condition of the soil and watersheds in the species’ 

habitat. Construction of roads would clear trees and snags across approximately 304-312 acres. Construction of 

fireline would clear up to approximately 2,500 acres of snags and ladder fuels. Firelines, temporary roads, new 

permanent roads, and trail would cause soil erosion and sedimentation of waterways, which may reduce the 

habitat (and ultimately, populations) of falcon prey. This may, in turn, affect fitness of the species. New 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 201

permanent road construction would have more impact on habitat of falcons’ prey, as these roads would not be 

obliterated. Alternative 4 would have less road-related impacts than Alternatives 2-3, as no new permanent roads 

or trails would be constructed under this Alternative. 

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 40 years beginning with implementation of the project were considered. Effects for a period of 51 

years beginning with the first date (2004) from past projects in the area, were considered Table 3-52, Table 3-53, 

Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably foreseeable projects considered in

the wildlife cumulative effects analysis for this project.

The No Action Alternative would maintain the current fire risk to peregrine falcon habitat and adjacent forest 

lands. The cumulative effects of the No Action Alternative would be to increase the number of acres of National 

Forest System lands that are vulnerable to severe fire effects, as dense forest conditions would continue to place 

peregrine falcon habitat and adjacent habitat at risk of stand-replacing fire. The fire hazard would increase over

time as vegetation would continue to grow, fuel would continue to accumulate, and the impacts of climate change 

would continue to affect forest health, thus continuing to have negative effects to peregrine falcon. 

Under Alternatives 2-4, there would be an additive effect from activities that modify vegetation (including 4FRI, 

McCracken, City, twin, and Dogtown Projects). Other projects where thinning occurs could affect the prey base 

on a short-term basis by impacting individuals of prey species due to disturbance of prey species’ habitat and 

harm from fire. However, projects would be implemented at different times and different locations, thus 

disturbances to the prey base would be minimized. An additional cumulative effect includes unmanaged climbing 

in areas where peregrine falcons are known to nest. In the last ten years, rock climbing has doubled, which could 

result in peregrine nesting success. Cumulatively, these projects and activities may impact peregrine falcons but 

are not likely to cause a trend toward listing or loss of viability.

Determination of Effects 

Alternatives 2-4 may impact individuals but would not cause a trend toward federal listing or loss of viability for 

the species. More habitat would be restored for prey species under Alternative 2 than under Alternatives 3-4, as 

there would be more flexibility to restore openings that existed in pre-settlement times. Alternative 4 would have 

less road-related impacts on prey species than Alternatives 2-3, as no new permanent roads would be constructed 

under this Alternative. 

3.7.1.5 Navajo Mogollon Vole

Existing Conditions

The Navajo Mogollon vole is found north of the Mogollon Rim, in open areas associated with ponderosa pine and 

other coniferous forests (meadows, riparian areas, and forested areas with low tree densities). Navajo Mogollon 

voles rely on grasses and other herbaceous vegetation for food and cover (Hoffmeister 1986). The species has not 

been detected in the project area but is likely to occur. Meadow openings within ponderosa pine and mixedconifer forest serve as suitable habitat in the project area, and conifers have encroached upon areas that were 

historically meadows.

Direct and Indirect Effects for the No-Action Alternative (Alternative 1)

The No Action Alternative would not affect the Navajo Mogollon Vole. Habitat conditions for these species 

would not change, notwithstanding the effects of natural processes. However, the No Action Alternative could 

degrade the habitat for voles in the long term. By not removing conifers which have encroached upon grasslands, 

meadows, and savannas, the No Action Alternative could hinder restoration of habitat for voles. 
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202 Chapter 3. Affected Environment and Environmental Consequences

Direct and Indirect Effects for Alternative 2-4 

Alternatives 2-4 would benefit voles by restoring grasslands, meadows, and savannas toward conditions to which 

the species adapted and evolved. In comparison to Alternatives 3-4, Alternative 2 would restore more habitat of 

voles, as without a 9” diameter cap in MSO Protected Habitat and with the ability to restore much of the 

ponderosa pine forest to pre-settlement conditions, Alternative 2 has the most flexibility to restore the grasslands 

and savannas important to this species. Prescribed fire is likely to have negligible effects on the creation and 

consumption of down logs in the habitat of these species, as fire does not have much residence time in grasslands, 

meadows, and savannas. Prescribed fire may cause direct mortality of the species, although this is unlikely, as the 

species are able to escape into burrows and other refugia.

Road obliteration and conversion of road to trail would restore more native habitat and reduce disturbance by 

humans. Construction of fire lines and temporary (and for Alternatives 2-3, Maintenance-Level 1) roads would 

cause degradation of habitat through soil erosion and sedimentation of waterways. Construction of roads would 

clear trees and snags across approximately 304-312 acres. Construction of fireline would clear up to 

approximately 2,500 acres of snags and ladder fuels. This would cause loss of habitat where roads pass through 

grasslands, meadows or other areas used by these species. New roads, unlike temporary roads, would not be 

obliterated after implementation and would therefore have longer-term effects on habitat.

Unlike Alternatives 2-3, which involve construction of 22-23 miles of new roads, Alternative 4 does not involve 

construction of any new permanent roads. This alternative would therefore have the least road-related 

degradation of habitat for the species. Mechanical treatment of hazardous fuels, prescribed fire, road 

construction, road decommissioning, and trail construction may reduce the habitat of voles in the short term or 

cause direct mortality, but such effects would not cause a trend toward listing or loss of viability.

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 51 years beginning with the first date (2004) from past projects in the area, were considered in 

Table 3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably 

foreseeable projects considered in the wildlife cumulative effects analysis for this project.

The No Action Alternative would maintain the current fire risk to vole habitat and adjacent forest lands. The 

cumulative effects of the No Action Alternative would be to increase the number of acres of National Forest 

System lands that are vulnerable to severe fire effects, as dense forest conditions would continue to place vole 

habitat and adjacent habitat at risk of stand-replacing fire. Climate change would continue to contribute to this 

risk. The fire hazard would increase over time as vegetation would continue to grow and fuel would continue to 

accumulate, continuing to have a negative effect on Navajo Mogollon vole.

In alternatives 2-4 Recreation (e.g., hiking, biking, and camping) and road travel pose an adverse effect to voles 

due to soil and vegetation disturbance and soil compaction. This would combine with projects such as the 

McCracken, City, Twin, and Dogtown Project’s proposed actions to reduce vole habitat. Recreational activities 

would continue to occur in the project area, resulting in decreased habitat for voles; however, forest management 

practices that promote herbaceous growth could lead to increased vole populations. There are additive effects of 

reduction of understory vegetation by livestock grazing in the Hat grazing allotment. Livestock grazing would 

combine with short-term loss of understory vegetation from burning and harvest activities. The allotment is 

managed on a deferred rotational and rest rotational grazing system designed to allow forage a chance to recover 

from livestock grazing, reducing the potential for cumulative effects. Development of private and state land has 

the greatest potential impact to vole habitat. Cumulatively, these projects and activities may impact the Navajo 

Mogollon vole but are not likely to cause a trend toward listing or loss of viability.

Determination of Effects 

The No Action Alternative would have no impact to the Navajo Mogollon vole. No action could perpetuate the 

process of forest and woodland encroachment of the open-land habitat which these species inhabit.
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Chapter 3. Affected Environment and Environmental Consequences 203

Alternatives 2-4 may affect individuals but would not cause a trend toward listing or loss of viability for the 

species. More habitat would be restored for this species under Alternative 2 than under Alternatives 3-4, as there 

would be more flexibility to restore openings that existed in pre-settlement times. Alternative 4 would have less 

road-related impacts than Alternatives 2-3, as no new permanent roads would be constructed under this 

alternative.

3.7.1.6 Spotted Bat, Allen’s Lappet-Browed Bat, and Pale Townsend’s Big-Eared Bat

Existing Conditions

Spotted Bat. The species inhabits a variety of ecosystems, including desert, open ponderosa pine forest, pinyonjuniper woodland, canyon bottoms, riparian areas, and rangelands. Spotted bats roost in caves and cracks in cliffs 

and canyons. The species appears to breed from May-August, and it primarily consumes moths (NatureServe 

2012). 

Allen’s Lappet-Browed Bat. Allen’s lappet-browed bats occur throughout all but the southwestern portion of 

Arizona. They use a variety of habitats, including ponderosa pine, pinyon-juniper, riparian areas, Mexican 

woodland, white fir forests, and Mohave desert scrub. The species associates with streams and ponds, which it 

uses for feeding and/or drinking. Allen’s lappet-browed bats roost in snags, caves, abandoned mine shafts, rocky 

areas, large snags, and cliffs (Hoffmeister 1986; Hinman and Snow 2003; Solvesky 2008). The reproductive 

biology of this species remains poorly know, but the species is thought to breed from May-August (Hinman and 

Snow 2003). These bats primarily predate small moths, but they eat other insects as well. Population trends 

remain poorly known. In fact, the species may have only expanded its range into Arizona during the twentieth 

century (Hoffmeister 1986). The species occurs on the Williams and Tusayan Ranger Districts and is likely to 

occur within the project area.

Pale Townsend’s Big-Eared Bat. The pale Townsend’s big-eared bat occurs throughout the western U.S and 

south into Mexico (Hoffmeister 1986; Hinman and Snow 2003). The species occurs from approximately 500-

7,500 ft., but most records occur above 3,000 ft. In summer, the species roosts in caves and mines at a variety of 

elevations and in variety of ecosystems, including desert scrub, oak woodland, pine-oak forest, pinyon-juniper 

forest, and mixed conifer forest. In winter, the species hibernates in cold caves, lava tubes, and mines in the 

uplands and mountains. These bats primarily predate small moths, but they eat other insects as well. They may 

forage up to five miles from the roost site. Breeding occurs from April-August. Population trends remain 

unclear; however, populations have declined or vanished in some maternity roosts (Hinman and Snow 2003). The 

species has been detected on the Williams and Tusayan Ranger Districts and is likely to occur within the project 

area.

Direct and Indirect Effects for the No-Action Alternative (Alternative 1)

The No Action Alternative would not affect the Spotted, Allen’s lappet-browed, or pale Townsend’s big-eared bats 

(henceforth collectively referred to as “bats”). Habitat conditions for these species would not change, 

notwithstanding the effects of natural processes. However, the No Action Alternative could degrade the habitat 

for bats in the long term. By not using mechanical treatments and prescribed fire to restore unnaturally dense 

ponderosa pine, mixed conifer, and pinyon-juniper forests, the No Action Alternative could hinder restoration of 

habitat for bats. The density of small-diameter trees would continue to increase under the No Action Alternative 

and existing high probabilities of fire hazard would persist. This could also exacerbate competition among trees, 

slow their growth into larger diameter classes, and thereby limit the development of larger trees (18”+ DBH) that 

Allen’s lappet-browed bats use for roosting. 

Direct and Indirect Effects for Alternatives 2-4 

Alternatives 2-4 would benefit bats by moving ponderosa pine, mixed conifer, and woodland habitat toward presettlement conditions to which the species adapted and evolved. Prescribed fire and mechanical treatment of 

hazardous fuels may result in a loss of snags; however, mitigation measures include fire-lining snags 18” DBH 

and greater prior to broadcast burning. Prescribed fire may cause direct mortality of young bats that have not 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

204 Chapter 3. Affected Environment and Environmental Consequences

developed into a mobile state. Alternatives 2-4 may result in a slight short-term decrease in snags followed by an 

increase over the long term. Smoke may disturb the species, but effects should be negligible due to the use of best 

management practices that include aiming for high lift and dispersion of smoke. This short term loss of snags 

would not affect the overall distribution of bats on the Forest. Mechanical treatments followed by prescribed fire 

would restore the native understory plant biomass and diversity of forests (Laughlin et al. 2008; Kane et al. 2010). 

This would create more foraging opportunities for moths and other prey, increase populations of prey, and 

ultimately improve the fitness of bats.

Helicopters to remove material would require that all hazard trees be removed from the entire area/unit where this 

activity occurs to provide for safety of the personnel on the ground outside of protected (closed cab) machinery. 

Within the proposed units where helicopters would remove material, some snags may be removed for safety 

reasons, and other snags would be retained. Helicopters to remove materials under Alternative 2 would cause a 

loss of snags on up to approximately 1060 acres of habitat used by nesting and roosting Allen’s lappet browed 

bats. Under Alternative 3 the effects would be greater because helicopters to remove materials could remove up 

to 3,980 acres of snags.

Road obliteration (and for Alternatives 2-3, conversion of road to trail) would restore more native habitat and 

reduce disturbance by humans. They would improve the condition of the soil and watersheds in the species’ 

habitat. Construction of roads could clear trees and snags across approximately 304-312 acres. Construction of 

fireline could remove to approximately 2,500 acres of snags and ladder fuels. New road construction would have 

more impact on the habitat of bats and their prey, as these roads would not be obliterated. Alternative 4 would 

have less road-related impacts than Alternatives 2-3, as no new permanent roads or trails would be constructed 

under this Alternative.

Mechanical treatment of hazardous fuels, prescribed fire, road construction, and trail construction may 

temporarily disturb bats, cause a loss of snags and trees >18” DBH important to these species, degrade habitat for 

the species and its prey, or cause direct mortality, but such effects would not cause a trend toward listing or loss of 

viability. 

Mitigation measures/Forest Plan desired conditions would ensure retention of at least 3 snags >18” DBH per acre 

in mixed conifer forest. They would also retain at least 2 snags >18” DBH per acre in ponderosa pine forest (this 

includes pine-oak forest).

Under Alternative 4, even though many fewer snags >18” DBH would be cut, the lack of mechanical treatments 

on many areas with steep slopes could still lead to consumption of many snags by fire (high fuel loadings would 

lead to greater torching of tree groups and snags). 

Loss of snags, be it from cutting under Alternatives 2-3 or the potential of severe fire under Alternative 4, would 

degrade the quality of habitat for the species, as the species uses large snags for breeding and roosting habitat. 

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 51 years beginning with the first date (2004) from past projects in the area, were considered. Table 

3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably foreseeable 

projects considered in the wildlife cumulative effects analysis for this project. 

Alternative 1 would maintain the current fire risk to bat habitat and adjacent forest lands. The cumulative effects 

of the No Action Alternative would be to increase the number of acres of National Forest System lands that are 

vulnerable to severe fire effects, as dense forest conditions and the effects of climate change would continue to 

place bat habitat and adjacent habitat at risk of stand-replacing fire. The fire hazard would increase over time as 

vegetation would continue to grow and fuel would continue to accumulate, continuing to have a negative effect to 

Spotted Bats, Allen’s lappet-browed and Pale Townsend’s big-eared bats.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 205

Ungulate grazing within the project area reduces understory vegetation, which reduces plant availability to adult 

insects, a primary food source. The Hat grazing allotment in project area is managed on deferred rotational and 

deferred rest rotation grazing systems designed to allow forage a chance to recover from livestock grazing, 

reducing the potential for cumulative impacts. Other projects that may add to the loss of snags include 4FRI, 

McCracken, City, twin, and Dogtown, power line maintenance, and removal of hazard trees along roads and trails. 

Cumulatively, these projects and activities may impact Spotted Bats, Allen’s lappet-browed bats or Pale 

Townsend’s big-eared bats, but are not likely to cause a trend toward listing or loss of viability. 

Determination of Effects 

Alternative 1 would not impact these bat species. However, no action would perpetuate the high fuel loadings and 

fire hazard in the project area and would eventually lead to stand-replacing fire in the habitat of these species.

Alternatives 2-4 may adversely impact Spotted Bat, pale Townsend’s big-eared, and Allen’s Lappet-browed bats 

in the short term but would cause a long-term beneficial impact. Alternatives 2-4 would not cause a trend toward 

listing or loss of viability. More habitat would be restored for these species under Alternative 2 than under 

Alternatives 3-4, as there would be more flexibility to promote the growth of the largest trees. Alternative 4 

would have less road-related and thinning impacts than Alternatives 2-3. 

3.7.1.7 Management Indicator Species

There are four MIS species found within the analysis area. Grace’s warbler is an indicator for ponderosa pine 

mature clumps within stands. The western bluebird is an indicator for understory development within openings in 

ponderosa pine forest. The ruby-crown kinglet is an indicator for mature overstory in frequent fire mixed conifer. 

The pronghorn is an indicator of grasslands. 

Management Indicator Species Current Population and Habitat Trends 

In the following analyses, for the three bird MIS, both density and occupancy estimates were used as 

complimentary lines of evidence for evaluating habitat and population trends. Density estimates are presented for 

data collected since 2005. The forest switched sampling design methodology in 2010 to support occupancy 

estimation, a robust analytical tool for assessing presence/absence of difficult to detect, cryptic and or wideranging species. Occupancy data, when analyzed with environmental covariates (e.g. plant composition, structure 

etc.) can also provide meaningful information on habitat use at both local and landscape scales. Data for both 

density and occupancy estimates are presented where available. In some instances, where sample size was limited, 

data provide a meaningful baseline, which will support future analyses. Occupancy data are further correlated 

with habitat quality to provide more meaningful insight on existing and potential habitat trends. 

Grace’s Warbler

In Stacier and Guzy (2002), they cite a study across pine and pine-oak forests of northern Arizona (Kaibab 

National Forest, north rim of Grand Canyon, Camp Navajo, and three districts of Coconino National Forest) that 

the Grace’s warbler is the fifth-most common bird species. In this study, the Grace’s warbler was present in 22 of 

23 stands. Ranges of habitat measurements: canopy cover 20–64% ponderosa pine and 2–14% Gamble’s oak; 

basal area 12–36 m2/ha pine and 1–6 m2/ha oak; herbaceous cover 10–71%. Density of pines in 5 size classes: 

26–2,067 stems/ha for trees 2.5–12.5 cm (<1 to 5”); 47–496 stems/ha for trees 12.6–30.4 cm (5 to 12”); 22–136 

stems/ha for trees 12.7–45.6 cm (5 to 18”); 4–46 stems/ha for trees 45.7–60.9 cm (18 to 24”); 1–30 stems/ha for 

trees >61 cm (>24”). In another study in Coconino Co., Grace’s warbler was found to be common on 

silviculturally thinned and control plots, averages were: 90 and 92% ponderosa pine; 10 and 8% oak or juniper. 

The Grace’s warbler foraging niche is in ponderosa-pine forest where it feeds mostly in tall pines, picking insects 

from finer foliage, perching on needles and twigs. In mature pines, foraging height typically ranges from 17–27 m 

(55 to 89’) (Stacier and Guzy 2002). 

The main concern for this species across it range is habitat alteration and fragmentation. Present-day ponderosapine forests differ greatly from presettlement forests because of logging, fuelwood harvest, fire suppression, 

grazing, and urban development. Size-class distributions are now skewed to smaller trees, with a more closed 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

206 Chapter 3. Affected Environment and Environmental Consequences

canopy, higher levels of disease, depleted understories, and high susceptibility to crown fires (Stacier and Guzy 

2002). On the Kaibab National Forest, this is seen more on the Williams and Tusayan Ranger District than on the 

North Kaibab Ranger District. Previously, park-like forests with clumps of large trees and grassy openings were 

maintained by low-intensity ground fires every 1–12 yr, limiting dense growth of young pines. It is likely then 

that Grace’s warbler who relies on large trees is less common in ponderosa-pine forests now than they were 

historically. Information suggests that pine forests that more closely mimic naturally open parklands with stands 

of large, mature trees, will eventually benefit this species. Previous research suggests that some manipulation of 

dense, nonvirgin stands may be beneficial. In northern Arizona, Grace’s warbler was most abundant in a 

silviculturally thinned forest (236 trees/ha of mixed-age and heterogeneous vertical and horizontal structure) than 

in unthinned, dense forest (646 trees/ha but similar foliage volume); greater levels of thinning (to 181 trees/ha), 

however, resulted in lower abundance (Stacier and Guzy 2002). 

Current Habitat and Population Tend on the Kaibab National Forest. Grace’s warbler is an indicator for 

ponderosa pine mature clumps within stands. On the Forest there is approximately 515,148 acres of ponderosa 

pine cover type and the potential natural vegetation type (PNVT) for ponderosa pine covers 541,000 acres (KNF 

2009 and 2010). The main difference between cover type and PNVT is that cover type reflects what is currently 

found on the forest while PNVT reflects what was on the Forest historically, depending on soil type, historic fire 

regime, and natural disturbance. Occupancy model results for the Grace’s warbler show that 245,417acres are of 

high quality and 132,161 acres are of moderate quality, for a total of 377,578 acres within ponderosa pine based 

on occupancy potential. There is 10,554 acres of ponderosa pine in the project area. This is approximately 2 % of 

the PNVT on the forest. Since the PNVTs are based on historical locations of ponderosa pine in the past, there 

would not change the amount of acreage within the ponderosa pine PNVT for any of the alternatives. The analysis 

will focus on if there would be improvement in the quality of the habitat. 

The ponderosa pine forest on the KNF is highly departed from reference condition (KNF CER 2009). This trend 

would continue under existing management. The amount and arrangement of forest developmental stages, and 

increased tree density/canopy cover are the primary characteristics that are departed. Only 19% of the PNVT is 

currently in the reference condition. The reference condition is defined as mature to old forest with various-sized 

patches of young regenerating forest. With the current rate of treatment within ponderosa pine forest, the current 

habitat trend would be considered stable; however there would not be progression towards the habitat reference 

condition. 

The forest has conducted bird surveys on the forest since 2005 with surveys being contracted out to Rocky 

Mountain Bird Observatory (RMBO) since 2007. The RMBO incorporated data collected by the forest in 2005 

and 2006 with the data from their surveys done since 2007 (Table 3-57). Currently, density estimate tables and 

graphs (Table 3-58, and Figure 3-47) on the RMBO website reflect data up to 2008. This website was checked 

again in January 2013 and the data had not been updated for any of the species. The 2009 and 2010 reports show a 

density of 36.79 and 25.26 respectively (Birek et al. 2010, White et al. 2011). With the 2010 survey data the 

RMBO was able to do estimated proportion of transects (Psi) occupied by species. A Psi estimate equal to 1 

indicates the species was detected on all transects surveyed. In total, 45 transects were surveyed on the KNF in 

2010. The Grace’s warbler had a Psi of .425, with the species found on 19 transects (White et al. 2011). 

Population trends based on forest monitoring appear to be stable within ponderosa pine habitats.

Table 3-57. Count of Grace’s Warbler by year on KNF (RMBO website)

Species 2005 2006 2007 2008 2009 2010

Total 

Year

Grace’s Warbler 128 155 135 220 488 473 1599
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Chapter 3. Affected Environment and Environmental Consequences 207

Table 3-58. Grace’s Warbler Density Estimates (RMBO Website)

Habitat Years D %CV LCL UCL n 

MC 2005 36.78 49 15.72 86.10 10 

MC 2006 4.93 39 2.65 9.20 18 

MC 2007 14.76 61 5.59 38.97 13 

MC 2008 24.14 41 12.39 47.03 50 

PP 2005 34.21 23 23.19 50.48 97 

PP 2006 25.24 23 17.14 37.18 76 

PP 2007 24.84 23 16.99 36.32 114 

PP 2008 24.76 24 16.79 36.51 147 

Figure 3-47. Grace’s Warbler Density Estimates (Rocky Mountain Bird Observatory Website)

Trends in occupancy for Grace’s warbler indicate an initial decrease in occupancy from 2006 to 2007 followed by 

an increase in subsequent years. As more bird surveys are done this may help influence the model results 

(Dickson et al. 2011). Results for Grace’s warbler indicate a strong relationship with habitat variables. 

Modeling results for Grace’s warbler indicate that basal area and canopy cover were strong positive predictors of 

occupancy for that species. Northeastern orientation, while not a “strong” predictor, did appear to negatively 

affect occupancy and indicated an affinity for more xeric habitat conditions. These results are consistent with 

other studies that have generally found Grace’s warbler in xeric pine or pine-oak dominate habitats with a 

diversity of tree size classes (Stacier & Guzy 2002). 

Annual estimates of occupancy for Grace’s Warbler were highest in 2006, lowest in 2007, and appeared to 

increase slightly between 2008 and 2009. Similarly, this species displayed annual increases in colonization while 

local extinction rates were similar across years. Multi-season occupancy models indicated increasing (although 

variable) trends for Grace’s warbler (Dickson et al. 2011). 

In summary the current forest-wide habitat and population trend for the Grace’s warbler is stable.
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208 Chapter 3. Affected Environment and Environmental Consequences

Direct and Indirect Effects for the No-Action Alternative (Alternative 1)

The No-Action Alternative would not affect Grace’s warblers. Habitat conditions for the species would not 

change, notwithstanding the effects of natural processes. However, the No Action Alternative could degrade the 

habitat for warblers in the long term; by not using mechanical treatments and prescribed fire to restore unnaturally 

dense forests, the No Action Alternative could hinder restoration of habitat for the species.

Direct and Indirect Effects for Alternatives 2-4 

Pre-settlement trees would be conserved wherever possible under all Action Alternatives. PFAs and nest areas 

would remain dense under all Action Alternatives, and MSO pine-oak Restricted Habitat would only be partially 

restored toward pre-settlement times, as more trees/evidence would be left in areas of high vegetative 

productivity. Such measures provide a balance between reduction of fire hazard (Table 3-48 and Table 3-49) and 

sustainability of the habitat and populations of this MIS. 

Alternatives 2-4 would benefit Grace’s warblers by moving ponderosa pine forest toward pre-settlement 

conditions to which the species adapted and evolved. Fuels-reduction treatments would develop a mosaic of 

uneven-aged forest across the landscape. Alternatives 2-4 would conserve groups of larger trees (typically 18” 

DBH or greater). By thinning unnaturally dense forests, Alternatives 2-4 would reduce competition among trees, 

thereby promoting the growth of larger trees to the benefit of turkeys, warblers, and nuthatches. Growth of large 

trees would be greatest under Alternative 2, intermediate under Alternative 3, and least under Alternative 4, as 

these alternatives have (in said order) progressively less flexibility in reducing competition around trees >18” 

DBH. Thinning and prescribed fire would reduce the probability of stand-replacing wildfire in forests, thereby 

conserving the mature forest, trees >18” DBH, and snags on which this species relies. Reductions in fire hazard 

to habitat are greatest under Alternative 2, intermediate under Alternative 3, and least under Alternative 4, as these 

alternatives have (in said order) progressively more mechanical treatment.

Treatments described in Alternatives 2-4 would move the project area from one dominated by young to mid-aged 

forest, toward an uneven-aged distribution with much more representation by mature and old forest. As 

Alternative 2 would most improve tree growth, it would most benefit the production of large live trees and 

recruitment of snags, which are an important habitat component for this MIS.

Alternatives 2-4 would manage for uneven aged conditions to sustain a mosaic of vegetation densities (overstory 

and understory), age classes, and species composition well-distributed across the landscape and provide for 

reserve trees, snags, and down woody debris. Within one year and twenty years after treatment, analyses 

indicated that Alternatives 2-4 would manage canopy cover toward above 50% after treatment in both nest areas 

and PFAs in ponderosa pine forest. Openings would be scattered throughout ponderosa pine forest with 

progressively more openings as one moves from nest areas to PFAs to foraging areas. Openings would not be 

greater than 2 acres in PFAs and 4 acres in foraging areas. Groups of trees would occur in areas where historical 

evidences exist or where best group/clump structure exists at time of implementation. Snags, downed logs, and 

woody debris would be conserved per forest plan direction. A diverse age and size class and interlocking crowns 

would occur in clumps.

Mitigation measures to conserve large oaks, pre-settlement trees, and some large, mistletoe-infected trees would 

benefit the species by conserving the trees most important to nesting, roosting, and foraging. 

Prescribed fire may cause direct mortality of warblers, but this is unlikely, as prescribed fire would occur as lowor moderate- intensity surface fire in ponderosa pine forest (see Fuels Specialist’s Report). Due to prevailing 

winds from the southwest, smoke generally affects goshawks to the northeast of burning activities. Smoke 

accumulation may cause birds to flush from nest areas or change their foraging behavior. This could cause them 

to expend more energy or become more vulnerable to predators. However, impacts from smoke are reduced by 

the coordination of timing and type of burning with wind direction, topography, and time of year. 

Prescribed fire and mechanical treatment of hazardous fuels may result in a loss of snags; however, mitigation 

measures include fire-lining snags 18” DBH and greater prior to broadcast burning. Throughout the project, 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 209

torching may occur within treatment areas during broadcast burning activities. Torching would mimic gapproducing processes that occur under natural conditions. Broadcast burning may decrease woody debris by up to 

approximately 50% of existing volume, and decrease the number of snags by 20% (Randall-Parker and Miller 

2000). Alternatives 2-4 may result in a slight short-term decrease in snags followed by an increase over the long 

term. Alternative 4 (and Alternatives 2 and 3, if prescribed fire is used without first mechanically treating areas) 

would result in a higher loss of snags, as dense stand conditions would lead to more loss of forest and snags to 

torching. Noise from mechanical treatments may affect nesting birds and cause a short-term reduction in 

reproductive success. Under Alternatives 2-4, prescribed fire would stimulate grass-forb growth, with Alternative 

2 supporting more growth than Alternatives 3-4. 

Road obliteration (and for Alternatives 2-3, conversion of road to trail) would restore more native habitat and 

reduce disturbance by humans. They would improve the condition of the soil and watersheds in the species’ 

habitat. Construction of new and temporary roads would clear trees and snags across approximately 304-312 

acres. Construction of fireline would clear up to approximately 2,500 acres of snags and ladder fuels. Fire lines, 

temporary roads, New roads, and trail would cause noise-related disturbance and soil erosion and sedimentation 

of waterways, which may reduce the reproductive success and habitat (and ultimately, populations) of birds. 

Road construction would have more impact on habitat of birds, as these roads would not be obliterated. 

Alternative 4 would have less road-related impacts than Alternatives 2-3, as no new permanent roads or trails 

would be constructed under this Alternative. 

There is 10,554 acres of ponderosa pine in the project area. This is approximately 2% of this habitat type on the 

forest. Mechanical treatment of hazardous fuels, prescribed fire, temporary road construction, road 

decommissions, road closures, and trail construction may temporarily disturb birds, cause a loss of snags and trees 

>18” DBH important to this species, or cause direct mortality, but such effects are too small to alter the quality of 

Forest-wide habitat or population trends for the species. 

The project would ensure retention of at least 3 snags >18” DBH per acre in mixed conifer forest, and would also 

retain at least 2 snags >18” DBH per acre in ponderosa pine forest (this includes pine-oak forest). Helicopters to 

remove material would require that all hazard trees be removed from the entire area/unit where this activity occurs 

to provide for safety of the personnel on the ground outside of protected (closed cab) machinery. Within the 

proposed units where helicopters would remove material, some snags may be removed for safety reasons, and 

other snags would be retained. Under Alternatives 2 and 3, helicopter operations would result in the removal of 

many snags >18” DBH.

Under Alternative 4, even though many fewer snags >18” DBH would be cut, the lack of mechanical treatments 

on many areas with steep slopes would still lead to consumption of many snags by fire (high fuel loadings would 

lead to greater torching of tree groups and snags).

Loss of snags whether from cutting under Alternatives 2-3 or the potential of severe fire under Alternative 4, 

would degrade the quality of habitat for the species, as snags serve as nesting and roosting habitat, as well as an 

important habitat component for many prey species.

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 51 years beginning with the first date (2004) from past projects in the area, were considered. Table 

3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably foreseeable 

projects considered in the wildlife cumulative effects analysis for this project.

The cumulative effects of the No Action Alternative would be to increase the number of acres of National Forest 

System lands that are vulnerable to severe fire effects, as dense forest conditions would continue to place warbler 

habitat and adjacent habitat at risk of stand-replacing fire. The fire hazard would increase over time as vegetation 

would continue to grow, fuel continue to accumulate, and the impacts of climate change continue, thus continuing 

to have negative effects to Grace’s Warblers.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

210 Chapter 3. Affected Environment and Environmental Consequences

From alternatives 2-4 there are additional indirect effects from vegetation modification activities occurring in 

other projects (such as: 4FRI, McCracken, City, twin, and Dogtown Projects), including hazard tree removal for 

power lines and highways, as well as tree removal for development of state and private lands. Grazing can 

temporarily reduce vegetative cover. The Hat grazing allotment in the project area is managed on deferred 

rotational and deferred rest rotation grazing systems designed to allow forage a chance to recover from livestock 

grazing, reducing the potential for cumulative impacts. Generally, projects are designed to move toward the 

desired conditions in closed ponderosa pine for Grace’s Warblers as identified in the Forest Plan. Cumulatively, 

these projects and activities will increase habitat and the population trend for Grace’s Warblers.

Determination of Effect

The no action alternative would not affect the population trend or quality of habitat for Grace’s Warblers. It could 

perpetuate the high fuel loadings and fire hazard in the project area and could eventually lead to stand-replacing 

fire in the habitat of the species.

Alternatives 2-4 would not cause a change in Forest-wide habitat quality or alter the population trend for the 

species. More habitat would be restored and protected for this species under Alternative 2 than under Alternatives 

3-4, as there would be less fire hazard and more flexibility to promote the growth of the largest trees and the 

herbaceous understory that this species relies on for nesting, roosting, and foraging. Alternative 4 would have less 

road-related impacts than Alternatives 2-3. 

Western Bluebird 

Western bluebirds are typically found in open, park like forests, edge habitats, burned areas, and where moderate 

amounts of logging have occurred, provided a sufficient number of larger trees and snags remain to provide nest 

sites and perches. The species does not favor large, open meadows. Clear-cutting, snag removal, fire suppression, 

and any changes in land use that cause open forest and edge habitat to be diminished adversely affect western 

bluebird populations (Guinan et al. 2008). 

In much of western bluebird range, the species is commonly associated with ponderosa pine forests and has a 

preference for open overstory; abundant in moderately disturbed areas, including moderately logged forests, and 

burned areas, where sufficient nest sites and foraging perches are available. In northern Arizona, breeding 

densities were greatest in a moderately thinned study plot of ponderosa pine forest with a tree density of 181 

trees/ha, canopy volume of 6,526 m3/ha and a mean tree height of 11.5 m. In mixed fir-pine forest of the White 

Mountains. Arizona, western bluebirds bred only in treated areas with a tree density 167.7 trees/ha and were 

absent from the control area that had 626.2 trees/ha (Guinan et al. 2008). 

Western bluebirds may benefit from some thinning of forests. In Guinan et al. (2008), they cite that moderate 

logging increased density of breeding western bluebirds in northern Arizona from 8 pairs/40 ha to 31 pairs/40 ha 

on a thinned plot (225 trees/ha) and 35 pairs/40 ha on an open plot (69 trees/ha.. In that study, the restoration of 

ponderosa pine forests by thinning of dense stands, followed by controlled burns and reseeding, increased nest 

and fledgling success, and decreased predation. The effects of fire and salvage logging in burned forests however 

are unclear. In some areas, there is a higher abundance of birds in areas of low snag density, but with more nests 

in areas of medium to high snag density. In other areas, there are more nests in areas of low – medium snag 

density than in areas with higher snag density (Guinan et al. 2008). 

Long-term measures proposed to develop and provide habitat for the western bluebird include the following: 

Controlled and natural burning can be used to prevent dense forest growth and overgrowth of open areas; 

retention of snags, and preservation of older, large, and partially dead trees. Silvicultural practices that retain 

snags leave sufficient numbers of mature trees to ensure adequate snag recruitment for the future, and retain 

smaller saplings and scattered shrubs for cover and foraging perches will provide suitable habitat in managed 

forests. Recommendations developed from research on habitat restoration treatments and nesting success 

includes: increasing herbaceous ground cover; reduction of ponderosa pine density to ≤ 270 stems/ha (no lower 

threshold established, but suggested to range from 57 to 150 stems/ha); retain Gambel oak trees and snags where 

present (Guinan et al. 2008). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 211

Recommendations for fire-management include: mimicking of natural fire regimens (size, timing, frequency, and 

severity), allowing for stand replacement burns where historic; consideration of effects of burn geometry (size, 

heterogeneity in terms of burn severity, and burn-to-edge ratio) in management policies (Guinan et al. 2008). 

Current Habitat and Population Trend 

The western bluebird, a ground foraging species, which depends largely on the understory for, capture of 

invertebrate prey is an indicator for understory development within openings in mature ponderosa pine forest. On 

the Forest there is approximately 515,148 acres of ponderosa pine and the PNVT for ponderosa pine covers 

541,000 acres (KNF 2009 and 2010). Occupancy model results for the western bluebird show that 417,111 acres 

within the ponderosa pine are high quality habitat while 64,315 acres are of moderate habitat quality, for a total of 

481,426 acres with potential occupancy. There is 10,554 acres of ponderosa pine in the project area. This is 

approximately 2 % of the PNVT on the forest. Since the PNVTs are based on historical locations of ponderosa 

pine in the past, there would not change the amount of acreage within the ponderosa pine PNVT for any of the 

alternatives. The analysis will focus on if there would be improvement in the quality of the habitat. 

Vegetation models created for the forest plan revision process suggest that the ponderosa pine forest on the KNF 

is highly departed from reference condition. Under current management, these forests will remain highly departed 

from reference conditions. The amount and arrangement of the developmental stages, and increased tree 

density/canopy cover are the primary characteristics that are departed. Only 19% of the PNVT is currently in the 

historic condition. Historic condition is defined as mature to old forest with various-sized patches of young 

regenerating forest (KNF 2009 and 2010). While the Forest is out of reference condition, the current rate of 

treatment within ponderosa pine should keep the habitat condition at a stable trend. However, it would not move 

the habitat toward reference condition. 

The Forest has conducted bird surveys across all three of its ranger districts since 2005, with surveys contracted 

out to Rocky Mountain Bird Observatory (RMBO) since 2007(Table 3-59). Currently, the RMBO website only 

reflects data through 2008 on their density estimates table and graphs (Table 3-60 and Figure 3-48). The 2009 

report showed a density of 33.59 (Birek et al. 2010). The 2010 report (White et al. 2011) showed the western 

bluebird had a .626 Psi and had the 5th highest occupancy rate out of 62 species that occupancy could be 

estimated for. Due to a change in sample design methodology, the density number for 2010 is not comparable to 

the previous data. There was a reduction of transects within the ponderosa pine habitat. Population trends based 

on forest monitoring appeared to be stable. 

Table 3-59. Count of Western Bluebird by year (Rocky Mountain Bird Observatory Website)

Species 2005 2006 2007 2008 2009 2010

Total 

Year

Western Bluebird 44 83 87 151 414 284 1,063

Table 3-60. Western Bluebird Density Estimates (Rocky Mountain Bird Observatory Website)

Habitat Year D %CV LCL UCL n 

PP 2005 28.08 27 17.66 44.66 38 

PP 2006 32.56 20 23.05 45.99 47 

PP 2007 31.14 19 22.60 42.91 64 

PP 2008 34.95 19 25.28 48.33 96 

D = Density (birds/km2) %CV = Percent Coefficient of Variation

LCL = Lower Confidence Limit

UCL = Upper Confidence Limit n = Number of detections used to estimate
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

212 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-48. Western Bluebird Density Estimates (Rocky Mountain Bird Observatory 

Website)

D = Density (birds/km2); Red – PP

Trends in occupancy for the western bluebird indicated an initial decrease in occupancy from 2006 to 2007 

followed by an increase in subsequent years. Western bluebird occupancy were positively associated with both 

basal area and those locations with canopy cover <30%. This is consistent with the species’ preference for more 

open, park-like forested settings. The presence of ponderosa pine habitat was a strong predictor for western 

bluebird (Dickson et al. 2011). Western Bluebird occupancy was also fairly steady throughout the analysis period, 

with the exception of decline in 2007 and subsequent increase in 2008. 

In summary, the current Forest-wide habitat and population trend for the western bluebird is stable. 

Direct and Indirect Effects for the No-Action Alternative (Alternative 1)

The No Action Alternative would not affect the forest wide trend for the species or degrade the quality of the 

habitat for western bluebirds. Habitat conditions for the species would not change, notwithstanding the effects of 

natural processes. However, the No Action Alternative could degrade the habitat for bluebirds in the long term; 

by not using mechanical treatments and prescribed fire to restore unnaturally dense forests, the No Action 

Alternative could hinder restoration of habitat for the species. 

Direct and Indirect Effects for Alternatives 2-4 

Alternatives 2-4 would benefit bluebirds by moving ponderosa pine forest toward pre-settlement conditions to 

which the species adapted and evolved. Fuels-reduction treatments would develop a mosaic of uneven-aged 

forest across the landscape. Alternatives 2-4 would conserve groups of larger trees (typically 18” DBH or 

greater). By thinning unnaturally dense forests, Alternatives 2-4 would reduce competition among trees, thereby 

promoting the growth of larger trees. Forest thinning would also promote the growth of grasses and forbs, to the 

benefit of bluebirds. Growth of large trees would be greatest under Alternative 2, intermediate under Alternative 

3, and least under Alternative 4, as these alternatives have (in said order) progressively less flexibility in reducing 

competition around trees >18” DBH. Thinning and prescribed fire would reduce the probability of standreplacing wildfire in forests. Reductions in fire hazard to habitat are greatest under Alternative 2, intermediate 

under Alternative 3, and least under Alternative 4, as these alternatives have (in said order) progressively more 

mechanical treatment.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 213

Treatments described in Alternatives 2-4 would move the project area from one dominated by young to mid-aged

forest toward an uneven-aged distribution with much more representation by mature and old forest. From the 

action alternatives alternative 2 would most improve tree growth while providing for openings in the forest, it 

would most benefit Western bluebirds, as it would restore overgrown forests to more open condition, with trees 

distributed in groups or clumps with openings in between. 

Prescribed fire may cause direct mortality of bluebirds, but this is unlikely, as prescribed fire would occur as lowor moderate- intensity surface fire in ponderosa pine forest (see Fuels Specialist’s Report). Smoke accumulation 

may cause birds to flush from nest areas or change their foraging behavior. This could cause them to expend 

more energy or become more vulnerable to predators. However, impacts from smoke are reduced by the 

coordination of timing and type of burning with wind direction, topography, and time of year. 

Prescribed fire and mechanical treatment of hazardous fuels may result in a loss of snags; however, mitigation 

measures include fire-lining snags 18” DBH and greater prior to broadcast burning. Throughout the project, 

torching may occur within treatment areas during broadcast burning activities. Torching would mimic gapproducing processes that occur under natural conditions. Broadcast burning may decrease woody debris by up to 

approximately 50% of existing volume, and decrease the number of snags by 20% (Randall-Parker and Miller 

2000). Alternatives 2-4 may result in a slight short-term decrease in snags (providing more openings in the forest 

canopy) followed by an increase over the long term. Alternative 4 (and Alternatives 2 and 3, if prescribed fire is 

used without first mechanically treating areas) would result in a higher loss of snags, as dense stand conditions 

would lead to more loss of forest and snags to torching. Noise from mechanical treatments may affect nesting 

birds and cause a short-term reduction in reproductive success. Under Alternatives 2-4, prescribed fire would 

stimulate grass-forb growth, with Alternative 2 supporting more growth than Alternatives 3-4. 

Road obliteration (and for Alternatives 2-3, conversion of road to trail) would restore more native habitat and 

reduce disturbance by humans. They would improve the condition of the soil and watersheds in the species’ 

habitat. Construction of roads could remove trees and snags across approximately 304-312 acres. Construction 

of fireline could clear up to approximately 2,500 acres of snags and ladder fuels. These selective tree removals 

would create openings in the ponderosa pine forest that could be beneficial for a species that uses open pine 

habitat. New permanent road construction would have more impact on habitat of birds, as these roads would not 

be obliterated. Alternative 4 would have less road-related impacts than Alternatives 2-3, as no new permanent 

roads or trails would be constructed under this alternative. 

The project would ensure retention of at least 3 snags >18” DBH per acre in mixed conifer forest, and would also 

retain at least 2 snags >18” DBH per acre in ponderosa pine forest (this includes pine-oak forest). Helicopters to 

remove material would require that all hazard trees be removed from the entire area/unit where this activity occurs 

to provide for safety of the personnel on the ground outside of protected (closed cab) machinery. Within the 

proposed units where helicopters would remove material, some snags may be removed for safety reasons, and 

other snags would be retained. Under Alternatives 2 and 3, helicopter operations would result in the removal of 

many snags >18” DBH.

Mechanical treatment of hazardous fuels, prescribed fire, temporary road construction, road decommissions, road 

closures, and trail construction may temporarily disturb birds, cause a loss of snags and trees >18” DBH important 

to this species, or cause direct mortality, but such effects are too small to alter Forest-wide habitat or population 

trends for the species. 

Under Alternative 4, even though many fewer snags >18” DBH would be cut, the lack of mechanical treatments 

on many areas with steep slopes would still lead to consumption of many snags by fire (high fuel loadings would 

lead to greater torching of tree groups and snags).

Loss of snags, whether from cutting under Alternatives 2-3 or severe fire under Alternative 4, could create large 

openings in the forest that could be beneficial for the species providing stand altering fire can be avoided. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

214 Chapter 3. Affected Environment and Environmental Consequences

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 51 years beginning with the first date (2004) from past projects in the area, were considered. Table 

3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably foreseeable 

projects considered in the wildlife cumulative effects analysis for this project.

The cumulative effects of alternative 1 would be to increase the number of acres of National Forest System lands 

that are vulnerable to severe fire effects, as dense forest conditions would continue to place bluebird habitat and 

adjacent habitat at risk of stand-replacing fire. The fire hazard would increase over time as vegetation would 

continue to grow, fuel continue to accumulate, and the impacts of climate change continue, thus continuing to 

have negative effects to Western Bluebirds.

From alternatives 2-4 there are additional indirect effects from vegetation modification activities occurring in 

other projects (such as: 4FRI, McCracken, City, twin, and Dogtown Projects), including hazard tree removal for 

power lines and highways, as well as tree removal for development of state and private lands. Grazing can 

temporarily reduce vegetative cover. The Hat grazing allotment in the project area is managed on deferred 

rotational and deferred rest rotation grazing systems designed to allow forage a chance to recover from livestock 

grazing, reducing the potential for cumulative impacts. Generally, projects are designed to move toward the 

desired conditions for Western Bluebirds as identified in the Forest Plan. Cumulatively, these projects and 

activities will increase habitat and population trends for this species. 

Determination of Effect

The No Action Alternative would not adversely impact the species. No action would perpetuate the high fuel 

loadings and fire hazard in the project area and could eventually lead to stand-replacing fire in the habitat of the 

species.

Alternatives 2-4 could cause a long-term beneficial impact. Alternatives 2-4 would not cause a change Forestwide habitat or population trend for the species. More habitat would be restored for this species under Alternative 

2 than under Alternatives 3-4, as there would be less fire hazard and more flexibility to promote the growth of the 

largest trees and the herbaceous understory that the species rely on for nesting, roosting, and foraging. The action 

alternatives would largely restore the project area to the more open ponderosa pine habitat condition that this 

species is an indicator for. Alternative 4 would have less road-related impacts than Alternatives 2-3. 

Ruby-crowned Kinglet

During the breeding season, ruby-crowned kinglets typically forage and nest in dense foliage high in the conifer 

forest treetops. In Arizona, they reach their highest densities in mixed-conifer forests. Breeding ruby-crowned 

kinglets are most abundant and widespread on the Kaibab Plateau and in the White Mountains. They are also 

found regularly in the San Francisco Mountains, Sitgreaves and Bill Williams' mountains (Corman and WiseGervais 2005). This species breeds in dry, open coniferous and mixed forests at high elevations. 

While this species is not a mixed-conifer obligate (Swanson et al. 2008), it does appear to be strongly associated 

with this habitat type. Predicting the effects of future forest management action on this species will require 

information at fine scales as management actions are more likely to impact existing forest structure for the species 

at that level.

Current Habitat and Population Trend

The ruby-crowned kinglet is an indicator for mature overstory in frequent fire mixed conifer. On the Forest there 

is approximately 39,130 acres of mixed conifer cover type and the PNVT for mixed conifer covers 127,900 acres 

(KNF 2009 and 2010). These numbers also include mesic mixed-conifer, which is too difficult to differentiate 

based on the sampling and modeling methods used for forest planning. However, the majority of the acreage in 

the mixed conifer PNVT is classified as frequent fire mixed-conifer (~107,000; KNF 2008b) and for this analysis 

the whole PNVT will be treated as frequent fire mixed conifer. This is consistent with analyses in the Vegetation 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 215

and Fire Specialist Report (KNF 2013a). Since there is a wide difference between the cover type and PNVT, the 

occupancy mapping done by Williamson and Dickson (2011) for the PNVT appears to provide better estimates for 

the amount of habitat that could potentially be available for the species. The occupancy modeling results for the 

ruby-crowned kinglet show that 17,112 acres within the mixed-conifer are of high quality habitat while 2,997 

acres are moderate quality. There is 1.973 acres of mixed conifer in the project area. This is approximately 1.5 % 

of the PNVT on the forest. Since the PNVTs are based on historical locations of mixed conifer in the past, there 

would not change the amount of acreage within the mixed conifer PNVT for any of the alternatives. The analysis 

will focus on if there would be improvement in the quality of the habitat. 

The majority of the mixed conifer cover type and PNVT occurs at high elevations on the North Kaibab Ranger 

District with a small amount (~14,200 acres) on the Williams Ranger District. This PNVT is younger and denser 

than during the reference period. About 5% of the area exists in a mature uneven-age state and only 23% of the 

area is comprised of uneven aged groups. Recent management has focused on moving towards reference 

conditions. The prescriptions have primarily thinned small trees around or under older trees. In some cases, group 

selection cuts have removed patches of large trees to promote regeneration within larger uneven-aged areas. 

Wildland fires within this PNVT are suppressed (KNF 2009 and 2010). While the Forest is out of reference 

condition, the current rate of treatment within the mixed conifer stands should keep the current habitat trend stable 

however; it would not move the habitat toward reference conditions over a large portion of the forest. 

The Forest has collected data on the ruby-crowned kinglet since 2005 (Table 3-61). Currently the RMBO website 

only includes data up to 2008 on their density estimate tables and graphs (Table 3-62 and Figure 3-49). The 2009 

reports show a density of 102.23 (Birek et al. 2010). In 2010 surveys were based on a new sample design and the 

amount of surveys within mixed conifer stands was greatly reduced. As a result there were not enough rubycrowned kinglets found to conduct a density estimate, with only 47 birds found. However, an estimated proportion 

of transects occupied for the 2010 surveys for the ruby-crowned kinglet was completed with a .113 Psi, being 

found on 5 transects (White et al. 2011). Their greatest population density, 74 birds/40 ha, was recorded in 

unlogged, mixed conifers in Arizona (Swanson et al. 2008). Trends based on forest monitoring from 2005-2009 

suggest this species appears to be increasing (but is variable) at this time. 

Table 3-61. Count of Ruby-crowned kinglet by year on KNF (RMBO website)

Species 2005 2006 2007 2008 2009 2010

Total 

Year

Ruby-crowned 

kinglet

41 173 66 217 301 53 851 

Table 3-62. Ruby-crowned Kinglet Density Estimates (RMBO Website)

Habitat Year D %CV LCL UCL n

MC 2005 45.47 34 24.64 83.90 17

MC 2006 19.13 22 13.44 27.24 96

MC 2007 46.22 21 32.08 66.61 56

MC 2008 66.69 18 49.39 90.04 189

D = Density (birds/km2) %

CV = Percent Coefficient of Variation

LCL = Lower Confidence Limit

UCL = Upper Confidence Limit

n = Number of detections used to estimate D
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

216 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-49. Ruby-crown Kinglet Density Estimates (Rocky Mountain Bird Observatory 

Website)

Variation in vegetation type was the strongest predictor of ruby-crowned kinglet occupancy; however, the 

magnitude of the parameter estimate for the mixed-conifer habitat type is likely to be a stronger contributor to the 

development of spatial models. This species appears to be strongly associated with the mixed-conifer habitat type. 

Model results show a strong association between the ruby-crowned kinglet and selected habitat variables.

Occupancy trends were not presented for the ruby-crowned kinglet due to the sharp change in detectability from 

2006 to 2007 and insufficient sample sizes to estimate colonization and local extinction for those first two years of 

surveys.

In summary, the current Forest-wide habitat trend for the ruby-crowned kinglet is stable. While the Forest 

monitoring data seems to imply an increasing population trend, the occupancy modeling could not determine a 

trend in support of the density data. To be conservative, the Forest-wide population trend is considered stable at 

this time.

Direct and Indirect Effects for the No-Action Alternative (Alternative 1)

The No Action Alternative would not affect ruby-crowned kinglets. Habitat conditions for the species would not 

change, notwithstanding the effects of natural processes. However, the No Action Alternative could degrade the 

habitat for ruby-crowned kinglets in the long term. 

Abnormally dense conditions have led to outbreaks of fir engravers, which in turn have caused widespread 

mortality of large conifers in the specie’s habitat. This has resulted in an increase in nesting habitat but a decrease 

in food resources for the species. The probability of stand-replacing wildfire in the mixed conifer forest of the 

project area is very high due to the extreme abundance of live and dead fuels. If an uncontrollable wildfire were 

to occur under severe conditions of humidity, fuel moistures, and winds, then stand-replacing wildfire would 

cause most if not all habitat of the species to be lost for at least several decades.

By not using mechanical treatments and prescribed fire to restore unnaturally dense forest, the No Action 

Alternative would hinder restoration of habitat for ruby-crowned kinglets. Furthermore, no action would increase 

the probability of further outbreaks of fir engravers as well as the probability stand-replacing wildfire causing 

long-term loss of habitat. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 217

Direct and Indirect Effects for Alternatives 2-4 

Alternatives 2-4 would benefit the long-term sustainability of late-seral mixed conifer forest, as well as the habitat 

for this management indicator species. They would reduce the probability of stand-replacing wildfire or 

outbreaks of insects/disease in mixed conifer forest. However, Alternative 4, with its limited potential for 

thinning on steep slopes, would provide less benefit toward the long-term sustainability of late-seral mixed 

conifer forest, and it would not have as much of an effect on reducing the probability of stand-replacing fire 

(Table 3-48 and Table 3-49). Under all Action Alternatives, pre-settlement trees would be conserved. Desired 

conditions, mitigations measures (see EIS), and design criteria specific to the conservation of MSOs ensure the 

sustainability of MSO and ruby-crowned kinglet habitat. 

Alternatives 2-4 would benefit the species by reducing fuels in the mixed conifer forest of the project area and 

thereby reducing the probability of stand-replacing wildfire in the specie’s habitat. Under Alternatives 2-4, 

thinning and prescribed fire would improve structural/age-class diversity across the project area and therefore 

benefit the species by ensuring long-term sustainability of the habitat.

Although the Action Alternatives would benefit the species in the long term by allowing for more sustainable 

habitat, a reduction in canopy cover would decrease the amount of interlocking crowns, infection levels of 

mistletoe, and number of late seral trees important to the species. This in turn may decrease fitness of the species, 

but it would bring fitness more in line with pre-settlement levels. As most of the species’ habitat overlaps with the 

Protected Habitat of MSOs, the project area would continue to provide substantial amounts of closed-canopy, late 

seral mixed conifer forest with many trees >18” DBH, snags, and other important habitat components for rubycrowned kinglets. 

If mechanical treatments are implemented before prescribed fire in the mixed conifer forest on steep slopes, then 

Alternative 2 would reduce fire hazard to snags, groups of trees >18” DBH, and other important habitat 

components more than Alternative 3, and Alternative 3 would reduce fire hazard more than Alternative 4. If 

mechanical treatments do not occur on steep slopes (i.e., only fireline and prescribed fire is implemented) under 

Alternatives 2-3, then Alternatives 2-4 would have identical effects on ruby-crowned kinglets, with a substantially 

higher probability of large patches of trees being replaced to torching than if areas were first mechanically treated 

(Table 3-48 and Table 3-49). 

Loss of mistletoe-infected trees would cause a loss of nesting microhabitat for the species. Although many 

mistletoe-infected trees would be removed, a mitigation measure specific to conservation of important wildlife 

trees would conserve this naturally occurring attribute of the ecosystem. Mitigations include conservation of presettlement trees wherever possible (including those with mistletoe infection), and conserving large, mistletoeinfected trees that occur within groups of pre-settlement trees that are infected with mistletoe already.

Smoke from prescribed fire and noise from mechanical treatments may disturb the species. These disturbances 

may cause the species to abandon areas and become more vulnerable to predation. Impacts from smoke are 

reduced by the coordination of timing and type of burning with wind direction, topography, and time of year. 

Prescribed fire and mechanical treatment of hazardous fuels may result in a loss of snags. Broadcast burning may 

decrease the number of snags by 20% (Randall-Parker and Miller 2000). Alternatives 2-4 may result in a slight 

short-term decrease in snags followed by an increase over the long term. Throughout the project area, torching 

may occur within treatment areas during broadcast burning activities. Torching would mimic gap-producing 

processes that occur under natural conditions. Alternative 4 (and Alternatives 2 and 3, if prescribed fire is used 

without first mechanically treating areas) would result in a higher loss of snags, as dense stand conditions would 

lead to more loss of forest and snags to torching. Under Alternatives 2-4, prescribed fire would stimulate grassforb growth. 

Road obliteration (and for Alternatives 2-3, conversion of road to trail) would restore more native habitat and 

reduce disturbance by humans. They would improve the condition of the soil and watersheds in the species’ 

habitat. Construction roads would clear trees and snags across approximately 304-312 acres. Construction of 

fireline would clear up to approximately 2,500 acres of snags and ladder fuels. Fire lines, roads, and trail would 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

218 Chapter 3. Affected Environment and Environmental Consequences

cause soil erosion and sedimentation of waterways, which may reduce the habitat of the species. New permanent 

road construction would have more impact on habitat, as these roads would not be obliterated. Alternative 4 

would have less road-related impacts than Alternatives 2-3, as no new permanent roads or trails would be 

constructed under this alternative. 

Mechanical treatment of hazardous fuels, prescribed fire, temporary road construction, road decommissions, road 

closures, and trail construction may temporarily disturb ruby-crowned kinglets, cause a loss of snags and trees 

>18” DBH important to these species, or cause direct mortality, but such effects are too small to alter Forest-wide

habitat or the population trend for the species. 

The project would ensure retention of at least 3 snags >18” DBH per acre in mixed conifer forest, and would also 

retain at least 2 snags >18” DBH per acre in ponderosa pine forest (this includes pine-oak forest). Helicopters to 

remove material would require that all hazard trees be removed from the entire area/unit where this activity occurs 

to provide for safety of the personnel on the ground outside of protected (closed cab) machinery. Within the 

proposed units where helicopters would remove material, some snags may be removed for safety reasons, and 

other snags would be retained. Under Alternatives 2 and 3, helicopter operations would result in the removal of 

many snags >18” DBH.

Under Alternative 4, even though many fewer snags >18” DBH would be cut, the lack of mechanical treatments 

on many areas with steep slopes would still lead to consumption of many snags by fire (high fuel loadings would 

lead to greater torching of tree groups and snags).

Loss of snags whether from cutting under Alternatives 2-3 or high intensity stand-replacing wildfire under 

Alternative 4, could degrade the quality of habitat for the species. 

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 51 years beginning with the first date (2004) from past projects in the area, were considered. Table 

3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably foreseeable 

projects considered in the wildlife cumulative effects analysis for this project.

The cumulative effects of alternative 1would be to increase the number of acres of National Forest System lands 

that are vulnerable to severe fire effects, as dense forest conditions would continue to place kinglet habitat and 

adjacent habitat at risk of stand-replacing fire. The fire hazard would increase over time as vegetation would 

continue to grow, fuel continue to accumulate, and the impacts of climate change continue, thus continuing to 

have negative effects to Ruby-crowned Kinglets.

From alternatives 2-4 there are additional indirect effects from vegetation modification activities occurring in 

other projects (such as: 4FRI, McCracken, City, twin, and Dogtown Projects), including hazard tree removal for 

power lines and highways, as well as tree removal for development of state and private lands. Grazing can 

temporarily reduce vegetative cover. The Hat grazing allotment in the project area is managed on deferred 

rotational and deferred rest rotation grazing systems designed to allow forage a chance to recover from livestock 

grazing, reducing the potential for cumulative impacts. Generally, projects are designed to move toward the 

desired conditions for ruby-crowned kinglets.as identified in the Forest Plan. Cumulatively, these projects and 

activities will not increase habitat and the population trend for ruby-crowned kinglets, but may increase the trend 

locally in this limited vegetation type on the Williams District of the Kaibab National Forest.

Determination of Effect

The No Action Alternative would not impact the species trend or degrade the quality of the habitat for the species. 

The No Action Alternative would perpetuate the existing high probability of a wildfire occurring under severe 

conditions of fire weather and fuel moistures. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 219

Alternatives 2-4 would not cause a change Forest-wide habitat or population trend for the species. As the mixed 

conifer forests in the project area exhibit uncharacteristically high fuel loadings, the probability of unintentionally 

torching large patches of trees (including large snags and pre-settlement trees) would be high in these areas if they 

did not first receive mechanical treatments. Alternatives 2-4 would allow prescribed fire to occur in kinglet habitat 

when conditions of weather and fuel moistures are most favorable, so loss of important habitat components would 

be much less than if a wildfire were to occur under extreme conditions of weather and fuel moistures. The action 

alternatives would improve habitat quality for kinglets as it would assist in moving the limited amount of habitat 

on the district closer to reference condition. 

Alternative 2 would best conserve kinglet habitat, as this Alternative would achieve the greatest balance of 

conserving large trees, canopy cover, and other attributes important to ruby-crowned kinglets while most reducing 

the probability of active crown fire in kinglet habitat. Alternative 3 would have an intermediate effect on reducing 

fire hazard, and it would have the greatest effect on promoting individual kinglet habitat attributes of importance. 

Alternative 4 would do little to reduce fire hazard (Table 3-48 and Table 3-49) and it would result in the greatest 

loss of important habitat attributes of the Action Alternatives. However, Alternative 4 would have less roadrelated impacts on kinglet habitat than Alternatives 2-3. 

None of the Action Alternatives’ effects are enough to change forest-wide habitat or population trends for the 

ruby-crowned kinglet.

Pronghorn 

Pronghorn antelope are an indicator of grasslands. Causes of decline in pronghorn herds across Arizona are 

numerous, but generally consistent. Paramount to the persistence of any wildlife species is presence of quality 

habitat. Continued urban sprawl and associated highway construction has fragmented and damaged quality 

pronghorn habitat (the latter continues to cause direct mortality via collision with vehicles and barriers for 

movement). Grasslands on the forest have been reduced in size by invasion of conifers, juniper, and shrub species 

resulting from decades of fire suppression. Past livestock grazing and historic fencing practices have reduced 

habitat quality and created barriers to pronghorn movement and migration routes. Finally, persistent drought and 

predation has impacted pronghorn populations to varying degrees statewide. The combination of these factors has 

led to a reduction in habitat availability and quality, a substantial decline in fawn recruitment, and a correlated 

increase in efficiency of pronghorn predators (AZGFD 2011). 

• The Statewide Pronghorn Management Plan (AZGFD 2011) discusses many of the issues for pronghorn 

populations. The following are the issues that could result from forest management activities. Pronghorn 

traverse fences by passing under, rather than over the fence; woven wire or fences with bottom wires 

below 20 inches act as barriers to pronghorn movements. Fences become more impervious barriers to 

pronghorn movement when they are placed near high-traffic roads. 

• Isolated populations become increasingly vulnerable to extirpation as population size decreases. 

(population fragmentation) 

• Fawning cover is generally provided by herbaceous vegetation that is >11 inches in height, with little 

shrub cover. 

• Pronghorn generally occupy open grassland or shrub-steppe habitats. Encroachment of shrubs or trees 

have reduced suitability of habitat, resulted in habitat abandonment, and isolated herds from historic 

interchange. 

• Pronghorn rely on forbs as the predominant food item, although shrubs may be important seasonally. 

Optimal vegetative composition should be short (<25 inches tall) shrubs (10-35% ground cover) and forb 

and grass (30-50% ground cover), emphasizing a diversity of forb species. Nutritional considerations of 

digestibility, quality, and nutrient levels are also important. 

Current Habitat and Population Trend

During Forest Plan Revision the grassland PNVT included all grasslands including montane/subalpine grassland, 

a habitat type that is not suitable for pronghorn. As such, montane/subalpine grasslands will not be included as 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

220 Chapter 3. Affected Environment and Environmental Consequences

part of the habitat trend analysis. Figure 3-50 shows the grasslands that provide habitat for the pronghorn. Within 

the PNVTs there is approximately 112,250 acres of grassland habitat for the pronghorn. Not all of these acres 

provide habitat for the pronghorn at this time. Currently, Forest-wide pronghorn habitat appears to be stable (KNF 

2014). There are only 64 acres of grassland in the project area. This is approximately 0 % of the PNVT on the 

forest. Since the PNVTs are based on historical locations of grasslands in the past, there would not change the 

amount of acreage within the grassland PNVT for any of the alternatives. The analysis will focus on if there 

would be improvement in the quality of the habitat. 

Figure 3-50. Pronghorn habitat on the Kaibab National Forest
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 221

The best model is estimated by changing mortality rates of the starting population so that the predicted malefemale ratios from the models for each year match those that are based on surveys. The AGFD Region 2 office 

provides the following summary (Table 3-63) for the units overseen by their region. The 3-year trends are for 

2011-2013 and 10-year for 2004-2013. 

Table 3-63. Trends in Pronghorn Populations based on AGFD data (McCall 2014)

Unit 3-Year 10-Year

7 Stable Stable

8 Increasing Increasing

9 Increasing Increasing

10 Stable Increasing

Beside the above listed GMUs, pronghorn are also found in 12A on the forest. All of these game units have a 

portion of the unit on the forest. Pronghorn numbers on GMU 12A appear to be sustaining an increasing trend. 

An assessment of the overall forest contribution to the pronghorn population trend suggests the forest wide 

population trend appears to be stable at this time (Keckler and Foster 2013). In summary, the current forest wide 

habitat and population trend for the pronghorn is stable. 

Direct and Indirect Effects for the No-Action Alternative (Alternative 1)

The No Action Alternative would not affect pronghorn antelope. Habitat conditions for these species would not 

change, notwithstanding the effects of natural processes. However, the No Action Alternative could degrade the 

habitat for antelope in the long term. By not removing conifers which have encroached upon grasslands, 

meadows, and savannas, the No Action Alternative could hinder restoration of habitat. This could result in an 

adverse effect on pronghorn. 

Direct and Indirect Effects for Alternatives 2-4 

Alternatives 2-4 would benefit the species by restoring grasslands, meadows, and savannas. Alternative 2 would 

remove encroaching conifers from grasslands, meadows, and savannas more than Alternatives 3-4, as more areas 

would be restored to pre-settlement conditions. This would restore herbaceous growth (that serves as protective 

cover and food for pronghorn) and therefore increase the species’ fitness.

Road decommissions, road closures, and conversion of road to trail would not affect the species trend or quality of 

habitat for pronghorn. 

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 51 years beginning with the first date (2004) from past projects in the area, were considered. Table 

3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably foreseeable 

projects considered in the wildlife cumulative effects analysis for this project.

The cumulative effects of the No Action Alternative would be to increase the number of acres of National Forest 

System lands that are vulnerable to severe fire effects, as dense forest conditions would continue to place 

pronghorn habitat and adjacent habitat at risk of stand-replacing fire. The fire hazard would increase over time as 

vegetation would continue to grow, fuel continue to accumulate, and the impacts of climate change continue, thus 

continuing to have negative effects to pronghorn. 

From alternatives 2-4 there are additional indirect effects from vegetation modification activities occurring in 

other projects ( such as; 4FRI, McCracken, City, twin, and Dogtown Projects), including hazard tree removal for 

power lines and highways, as well as tree removal for development of state and private lands. Grazing can 

temporarily reduce vegetative cover. The Hat grazing allotment in the project area is managed on deferred 

rotational and deferred rest rotation grazing systems designed to allow forage a chance to recover from livestock 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

222 Chapter 3. Affected Environment and Environmental Consequences

grazing, reducing the potential for cumulative impacts. Generally, projects are designed to move toward the 

desired conditions for pronghorn.as identified in the Forest Plan. Cumulatively, these projects and activities will 

increase habitat and the population trend for pronghorn.

Determination of Effect

Alternative 1 would not impact the species trend or quality of habitat. No action, however, could perpetuate the 

process of forest and woodland encroachment of the grasslands, meadows, and savannas which this species 

inhabits. 

Alternatives 2-4 may impact pronghorn antelope in the short term but would cause a long-term beneficial impact. 

Alternatives 2-4 would keep Forest-wide habitat or population trends for pronghorn antelope as stable to 

increasing. More habitat would be restored for the species under Alternative 2 than under Alternatives 3-4, as 

there would be more flexibility to restore grasslands, meadows, and forest openings that existed in pre-settlement 

times. Alternative 4 would have less road-related impacts than Alternatives 2-3, as no new permanent roads 

would be constructed under this Alternative. 

Migratory Birds

Existing Conditions

Executive Order 13186 (January 10, 2001) requires federal agencies to consider management impacts to 

migratory birds. In this analysis, we considered: 

1. Important Bird Areas and Important Wintering Areas that have been identified or recognized. Note: No 

such areas have been identified or recognized in the project area or within 0.5 miles of the project area. 

2. Birds of Conservation Concern in Bird Conservation Regions 16, 33, and 34 (designated by the U.S. Fish 

and Wildlife Service) that occur on the Kaibab National Forest. The effects of the action alternatives on 

those species that occur or have habitat in the project area or within 0.5 miles of the project area was 

analyzed (Table 3-64), as noise or smoke could potentially affect species within this action area.

3. Birds identified as priority species in the Arizona Partners in Flight Bird Conservation Plan (APIF; Latta, 

et al. 1999) that occur on the Kaibab National Forest. The effects of the alternatives on those species that 

occur or have habitat in the project area or within 0.5 miles of the project area was analyzed (Table 3-64).

o Arizona Partners in Flight lists priority species of conservation concern that both occur or have 

habitat in the project area and that I already considered or analyzed in previous sections of this report 

will not be discussed further. These include Mexican spotted owl, northern goshawk, burrowing owl, 

peregrine falcon, red-naped sapsucker, and juniper titmouse. 

Table 3-64. List of migratory birds of conservation concern that occur on the Kaibab National Forest, with notes on 

whether they occur or have habitat within the project area

Species* Habitat

Seasonal 

Occurrence

Suitable 

Habitat 

Present 

and/or 

Occupied

Bald eagle a variety of ecosystems, esp. 

wetlands

Winter Yes

Northern goshawk mixed conifer and pine year-round Yes

Common black-hawk Riparian summer/ rare No

Swainson's hawk Grassland Summer Yes

Ferruginous hawk Grassland migrant/winter Yes

Peregrine falcon usually near cliffs and open areas year-round Yes
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 223

Species* Habitat

Seasonal 

Occurrence

Suitable 

Habitat 

Present 

and/or 

Occupied

Flammulated owl Pine Summer Yes

Mexican spotted owl mixed conifer and pine-oak year-round Yes

Burrowing owl grasslands with burrowing animals Summer No

Lewis's woodpecker open pine year-round Yes

Three-toed woodpecker spruce-fir and mixed conifer year-round Yes

Red-naped sapsucker mixed conifer and aspen Summer Yes

Olive-sided flycatcher mixed conifer and pine Summer Yes

Gray flycatcher pinyon/juniper summer/migrant Yes

Cordilleran flycatcher Pine Summer Yes

Gray vireo pinyon/juniper Summer Yes

Pinyon jay pinyon/juniper year-round Yes

Purple martin Pine Summer Yes

Juniper titmouse pinyon/juniper year-round Yes

Golden-crowned kinglet spruce-fir year-round No

Swainson's thrush spruce-fir Migrant No

Bendire's thrasher open brushy areas summer/ rare No

Sprague's pipit short grass prairie winter/migrant/ rare No

Olive warbler open conifer summer/ rare Yes

Lucy's warbler low elevation riparian Summer No

Yellow warbler low elevation riparian and woodland summer/ rare No

Black-throated gray 

warbler

pinyon/juniper and dry oak woodlands Summer Yes

Grace's warbler tall pines Summer Yes

Red-faced warbler pine, pine-oak, fir Summer Yes

Canyon towhee open brushy areas year-round/ rare No

Yellow-breasted chat low elevation riparian Summer No

Black-chinned sparrow grasslands; scrub summer/ rare Yes

Lark bunting Grasslands winter/migrant/ rare Yes

Grasshopper sparrow grasslands; scrub mostly migrant/ rare Yes

Chestnut-collared 

longspur

grasslands; dry, open areas mostly migrant / rare Yes

Pine grosbeak spruce-fir Rare No

*The Southwestern Regional Office of the Forest Service recommends that all projects are developed in consideration of effects to the 

following: (1) Species of Concern listed by Arizona Partners in Flight; (2) U.S. Fish and Wildlife Service’s List of Birds of Conservation 

Concern; (3) Important Bird Areas (IBAs); and (3) Effects to important over-wintering areas. The following is an attempt to disclose the 

impacts, if any, of this project. This analysis considers these species and their habitats. Names are standardized according to the American 

Ornithological Union.

Birds of Mixed Conifer and Ponderosa Pine Forests. Three-toed woodpecker, olive-sided flycatcher, red-faced 

warbler and Virginia’s warbler inhabit mixed conifer forests. Flammulated owl, Lewis’s woodpecker, Cordilleran 

flycatcher, greater pewee, purple martin, Grace’s warbler, red-faced warbler, and olive warbler occur in ponderosa 

pine forests.

Flammulated owl, three-toed woodpecker, Lewis’s woodpecker, and purple martin are cavity-nesting birds and 

therefore rely on snags and trees >18” DBH. Three-toed woodpeckers associate with areas of insect infestation, 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

224 Chapter 3. Affected Environment and Environmental Consequences

including areas burned by high-severity wildfire. Lewis’ woodpeckers favor open forests, including open 

ponderosa pine forest and logged or burned pine forest. Flammulated owls rely on a variety of microhabitats, 

including dense thickets, clearings, and groups of large, old trees. The subspecies of Purple Martin occurs on the 

Kaibab National Forest and inhabits a diversity of ponderosa pine forests. They forage and drink at rivers, lakes, 

ponds, and earthen stock tanks, often far from nesting area (Corman and Wise-Gervais 2005). National population 

trends for both woodpeckers and purple martins indicate a decline; flammulated owls appear to be common but 

trends are unknown (BNA Online 2012). 

Olive-sided flycatchers inhabit forest openings and park-like coniferous forests with large snags and live trees. 

Abundance increases with thinning and fire. The species is declining throughout its range. Virginia’s warblers 

breed in pinyon-juniper woodlands and mixed conifer forests in the region of the Mogollon Rim; the species 

appears to locally prefer moist, pine-oak-locust habitat with a mesic maple component. Prescribed fire may cause 

a reduction in nesting microhabitat for Virginia’s Warblers. Population trends for the species remain unknown, 

but I have detected the species within the mixed conifer drainages of the project area. Red-faced warblers occur 

in high, deep, shady, cool canyons and other steeply sloping drainages, especially those with mixed conifer forest 

in the uplands. This ground-nesting species may be sensitive to logging appears to be expanding its range 

northward, but population trends remain unknown Band-tailed pigeons occur in montane mixed conifer and pineoak forests, and national trends show a decline (BNA Online 2012). 

Cordilleran flycatchers associate with cool, shaded areas along water courses. Population trends remain 

unknown. Greater pewees inhabit open, mature, pine-oak forest (BNA Online 2012). Grace’s warbler depends 

on extensive, park-like, mature stands of yellow pine. Previous research indicates that the species reacts 

favorably to moderate levels of mechanical thinning and low-severity fire in pine forests that have grown 

unnaturally thick from fire exclusion and historic timber management practices (BNA Online 2012). Olive 

warblers inhabit open pine forests and nests at the end of branches in the canopy. Population trends remain 

unknown for cordilleran flycatcher, greater pewee, grace’s warbler, and olive warbler.

Birds of Pinyon-Juniper Woodlands. Pinyon jay, gray vireo, gray flycatcher, and black-throated gray warbler 

inhabit pinyon-juniper woodlands. Pinyon jays heavily rely on the seeds of pinyon pines. Reproductive success 

of this winter-breeding species positively correlates with the abundance of pine-seed crops from the previous 

autumn. Pinyon jay populations are declining, and the species is listed as globally threatened by the International 

Union for the Conservation of Nature. Gray vireos associate with shorter and less dense pinyon-juniper 

woodlands. Population trend remains unknown. 

Above the Mogollon Rim, Gray flycatchers inhabit pinyon-juniper woodlands with big sagebrush and mountain 

mahogany. Range wide, the population appears to be increasing. Black-throated gray warblers prefer pinyonjuniper woodlands, especially those with higher densities of mature pinyon pine. Population trends remain 

unknown. 

Birds of Grasslands. Ferruginous Hawk, Swainson’s hawk, grasshopper sparrow, lark bunting, black-chinned 

sparrow, and chestnut-collared longspur occur in grasslands, and all species exhibit declining population trends. 

Ferruginous Hawk occurs in the winter, but populations appear to be transient. See above for a description of the 

ecology of loggerhead shrike. Swainson’s hawks inhabit grasslands and grassland-like croplands. They use tall 

trees or shrubs for nesting. The species is declining throughout much of its range, including Arizona (Corman and 

Wise-Gervais 2005; BNA Online 2012). Grasshopper sparrows may occur as rare transients/migrants on the 

Kaibab National Forest in grasslands. There is very little grassland bird habitat within the project area; most 

grasslands, meadows, and savannas within the project area have been invaded by conifers.

Birds of Moist, Cool Ecosystems. MacGillivray’s warbler, red-faced warbler, and Virginia’s warbler inhabit 

forests of the project area, and they probably inhabit the ephemeral drainages of Bill Williams Mountain. See 

above for a description of the ecology of red-faced and Virginia’s warblers. MacGillivray’s warblers occur in 

mountain drainages, springs, and slopes above 5,800 ft. They nest and forage in shrubby thickets and other early 

seral habitat. The species does not occur widely throughout Arizona has become extirpated from historical 

locations along the Mogollon Rim (Corman and Wise-Gervais 2005; BNA Online 2012). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 225

Direct and Indirect Effects for the No Action Alternative (Alternative 1)

The No Action Alternative would not affect migratory birds of conservation concern (henceforth referred to as 

“birds”). Habitat conditions for birds would not change, notwithstanding the effects of natural processes. 

However, the No Action Alternative would degrade the habitat for birds in the long term; by not using mechanical 

treatments and prescribed fire to restore unnaturally dense forests, woodlands, meadows, and grasslands, the No 

Action Alternative would hinder restoration of habitat for birds. Furthermore, unnaturally dense forests increase 

the probability of stand-replacing wildfire. Such fire would degrade or destroy the mature forests and trees >18” 

DBH and snags on which many birds rely. The No Action Alternative could perpetuate the high probability of 

active crown fire in the pinyon-juniper habitat of the pinyon jay, a globally threatened species (see Table 3-48 and 

Table 3-49). The No Action Alternative would not result in any unintentional take from management activities. 

Direct and Indirect Effects for Alternatives 2-4 

Treatments would benefit this diversity of species. Under Alternatives 2-4, thinning and prescribed fire would 

improve forest and woodland habitat for birds in the long term. These treatments would develop a mosaic of 

uneven-aged forest and woodland across the landscape, including habitat for a variety of birds. Prescribed fire 

would restore grasslands and meadows. Alternatives 2-4 would conserve groups of larger trees (typically 18” 

DBH or greater), especially important to cavity nesters and raptors. Alternative 2 would do the most to restore 

grassland meadow habitat, as much of the treatments in ponderosa pine forests would restore ecosystems to presettlement times, thereby restoring pine savannas. By thinning unnaturally dense forests, Alternatives 2-4 would 

reduce competition among trees, thereby promoting the growth of larger trees. Furthermore, thinning and 

prescribed fire would reduce the probability of stand-replacing wildfire in forests, thereby conserving the mature 

forest and trees >18” DBH and snags on which many birds rely. Species that rely on montane forest and 

drainages would most benefit from Alternatives 2 or 3, as treatments would reduce fire hazard while still 

conserving canopy cover, trees >18” DBH, snags, and other important habitat attributes. 

Under Alternatives 2-4, unintentional take may occur. When prescribed burning occurs during the spring and 

early summer, there could be some take of migratory birds from smoke impacting breeding birds and potentially 

impacting nesting success. Unintentional take could occur if nests are burned during implementation. All action 

alternatives may cause unintentional take from loss of eggs or nestlings to prescribed fire. Unintentional take may 

occur for all species but bald eagle, Swainson’s Hawk, Ferruginous Hawk, Peregrine Falcon, and Lark Bunting. 

These exceptions exist because these species do not breed in the area or they nest on cliffs or high in trees within 

grasslands and the probability of fire entering or causing smoke-related asphyxiation in these fine, flashy fuels is 

so low that it is negligible.

Prescribed fire and mechanical treatment of hazardous fuels may result in a loss of snags and loss of eggs or 

nestlings for cavity-nesting species. Alternative 2 may result in a slight short-term decrease in snags followed by 

an increase over the long term. This short-term loss of snags would not affect the overall distribution of birds on 

the Forest.

Construction of roads could clear trees and snags across approximately 304-312 acres. Construction of fireline 

could clear up to approximately 2,500 acres of snags and ladder fuels. Temporary roads and trail would cause soil 

erosion and sedimentation of waterways, which may reduce the habitat of birds and their prey. This may, in turn, 

affect fitness. Alternative 4 would have less road-related impacts than Alternatives 2-3, as no new permanent 

roads or trails would be constructed under this Alternative. 

Alternatives 2-4 would decrease the chance of stand-replacing wildfire in the pinyon-juniper habitat of birds of 

forests and woodlands, with Alternative 2 causing the greatest reduction in fire hazard (Table 3-48 and Table 3-

49).

Cordilleran flycatcher, purple martin, and all owl and woodpecker species exclusively nest in cavities, and 

virtually all cavities occur in snags. All other migratory birds of concern use snags as roosting or foraging habitat. 

Many snags in the project area would be felled under Alternatives 2-4. Mitigation measures would ensure 

retention of at least 3 snags >18” DBH per acre in mixed conifer forest and all forested habitats within the Bill 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

226 Chapter 3. Affected Environment and Environmental Consequences

Williams PAC. They would also retain at least 2 snags >18” DBH per acre in ponderosa pine forest (this includes 

pine-oak forest).

The project would ensure retention of at least 3 snags >18” DBH per acre in mixed conifer forest, and would also 

retain at least 2 snags >18” DBH per acre in ponderosa pine forest (this includes pine-oak forest). Helicopters to 

remove material would require that all hazard trees be removed from the entire area/unit where this activity occurs 

to provide for safety of the personnel on the ground outside of protected (closed cab) machinery. Within the 

proposed units where helicopters would remove material, some snags may be removed for safety reasons, and 

other snags would be retained. Under Alternatives 2 and 3, helicopter operations would result in the removal of 

many snags >18” DBH.

Under Alternative 4, even though many fewer snags >18” DBH would be cut, the lack of mechanical treatments 

on many areas with steep slopes would still lead to consumption of many snags by fire (high fuel loadings would 

lead to greater torching of tree groups and snags).

Loss of snags, be it from cutting under Alternatives 2-3 or the potential of severe fire under Alternative 4, may 

cause unintentional take of the aforementioned cavity-nesting species. 

Cumulative Effects

The cumulative effects boundary is the action area, defined as the project area and a one-half mile buffer. Effects 

for a period of 51 years beginning with the first date (2004) from past projects in the area, were considered. Table 

3-52, Table 3-53, Table 3-54, and Table 3-55 provide a summary of past, present, and reasonably foreseeable 

projects considered in the wildlife cumulative effects analysis for this project.

The cumulative effects of the No Action Alternative would be to increase the number of acres of National Forest 

System lands that are vulnerable to severe fire effects, as dense forest conditions would continue to place 

migratory bird habitat and adjacent habitat at risk of stand-replacing fire. The fire hazard would increase over 

time as vegetation would continue to grow, fuel continue to accumulate, and the impacts of climate change 

continue, thus continuing to have negative effects to migratory birds. 

From alternatives 2-4 there are additional indirect effects from vegetation modification activities occurring in 

other projects. Ongoing recreational activities may result in disturbance of migratory birds. Removal of hazard 

trees for power lines, trails and roads would reduce snags and reduce habitat for snag dependent species. Present 

and future forest health project activities have common objectives to improve current conditions by improving 

soil conditions, reducing competition of trees, managing for return of the large tree components and providing 

snags, logs and coarse woody debris in sufficient quantity to provide for raptor species. 

Grazing can temporarily reduce vegetative cover. The Hat grazing allotment in the project area is managed on 

deferred rotational and deferred rest rotation grazing systems designed to allow forage a chance to recover from 

livestock grazing, reducing the potential for cumulative impacts. Generally, projects are designed to move toward 

the desired conditions for migratory birds as identified in the Forest Plan. 

Under alternatives 2-4, treatments would provide protection from stand-replacing crown fires to high species rich 

habitats. The amount of impacts from vegetation treatments that would occur to migratory birds from 

implementation of alternative 2-4 when added to past, present and reasonably foreseeable future actions is not 

likely to occur to an extent that there would be a measureable negative effect on migratory bird populations. 

Cumulatively, these projects and activities may increase the trend for migratory birds and their habitats.

Determination of Effect

Alternative 1 would not adversely impact these species. No action would perpetuate the process of encroachment 

of and increasing fire hazard in the grasslands, meadows, savannas, woodlands, and forests on which these 

species rely, which may ultimately cause stand-replacing fire and mortality of nesting birds. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 227

Alternatives 2-4 would not cause a trend toward listing or loss of viability, or change community trends for birds. 

In general, more habitat would be restored for birds under Alternative 2 than under Alternatives 3-4, as there 

would be more flexibility to restore grasslands, meadows, woodlands, and forests to their pre-settlement 

conditions. Alternative 4 would have less road-related impacts than Alternatives 2-3, as no Maintenance-Level 1 

Roads would be constructed. Unintentional take may occur for all species but bald eagle, Swainson’s hawk, 

Ferruginous Hawk, Peregrine Falcon, and Lark Bunting. These exceptions exist because these species do not 

breed in the area or they nest on cliffs or high in trees within grasslands and the probability of fire entering or 

causing smoke-related asphyxiation in these fine, flashy fuels is so low that it is negligible. Although 

unintentional take may occur to some migratory bird species, the widespread distribution of these species over 

hundreds of thousands of acres (BNA Online 2012) precludes such take from causing a measurable effect to the 

populations of the species. 

Rare and Narrow Endemic Species for the Kaibab NF

The forest plan provides desired conditions and guideline for the protection of rare and endemic species on the 

forest. Table 3-65 shows which terrestrial species are considered rare and endemic on the forest and if they are 

located within the Bill Williams analysis area. For species not located within the analysis area, no further 

documentation is required within this document.

Table 3-65. Forest Planning Species classified as having Restricted Distributions or Narrow Endemic species

Species Rare

Narrow 

Endemic

Found in 

the 

Analysis 

Area Comment

California condor X No Only recorded on the Tusayan district

Apache trout X No Only found on North Kaibab ranger 

district

Arizona black rattlesnake X Yes Additional analysis

Utah Mountain kingsnake X No Only found on North Kaibab ranger 

district

Persephone’s darner X No Riparian habitat required – not 

affected by project activities

Kaibab fairy shrimp X No Only found on North Kaibab ranger 

district

Kaibab variable tiger beetle X No Only found on North Kaibab ranger 

district

Kaibab Indra swallowtail X No No habitat within the analysis area

House Rock Valley chiseltoothed kangaroo ratX No Only found on North Kaibab ranger 

district

Kaibab least chipmunk X No Only found on North Kaibab ranger 

district

Kaibab tree squirrel X No Only found on North Kaibab ranger 

district

Kaibab northern pocket 

gopher

X No Only found on North Kaibab ranger 

district

The Arizona black rattlesnake is usually found in mesic habitats but also dry rocky slopes and rock slides. 

Volcanic rock outcrops and talus slopes appear to provide hibernacula at higher elevations between 2130-3000 

meters (6988-9842 feet). The species is also strongly associated with downed woody debris, and this association 

may be more important than tree species associations (Bergamini et al. 2014).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

228 Chapter 3. Affected Environment and Environmental Consequences

Affected Environment

Forest Plan Compliance – Rare and Narrow Endemic Species. The forest plan directs the protection of rare 

and narrow endemic species. For the Bill Williams project this includes the Arizona black rattlesnake. Mitigations 

were developed for the Arizona black rattlesnake for the 4FRI project that will provide the project design to 

protect and provide for the species were it is likely to occur. This project will also incorporate these measures. 

The forest will review task orders to determine if existing den sites or potential habitat for den sites are within the 

task order area to determine which mitigations should be implemented. The project could affect individual snakes 

due to activities as running over snakes by accident with vehicles associated with the project or temporary 

disturbance of prey species due to thinning or burning activities. However, overall there would not be a 

measurable negative effect to the population add to mitigation measures section of chapter 2.

3.8 Invasive Species 

3.8.1 Affected Environment’s Existing Condition

The scope of this analysis focuses on invasive plant species within a 1-mile buffer of the proposed project 

perimeter. A 1-mile buffer was used because of the potential for currently established invasive species outside of 

the projected treatment boundary to move within the project boundary. Table 3-66 lists the invasive plant species 

that have been found within a one mile buffer of the Bill Williams project perimeter.

Table 3-66. Invasive plant species documented within a 1-mile buffer of the project area

Common Name Scientific Name Invasive Noxious

bull thistle Cirsium vulgare X x 

Cheatgrass Bromus tectorum X x 

common mullein Verbascum thapsus X 

Dalmatian toadflax Linaria dalmatica X x 

diffuse knapweed Centaurea diffusa X x 

field bindweed Convolvulus arvensis X 

Mexican fireweed Kochia scoparia X 

redstem stork’s bill Erodium cicutarium X 

Russian knapweed Acroptilon repens. X x 

Russian olive Elaeagnus angustifolia X x 

Siberian elm Ulmus pumila X x 

yellow salsify Tragopogon dubius X 

yellow sweetclover Melilotus officinalis X 

Following are species descriptions for those that have been documented within a 1-mile buffer of the project 

boundary (see Figure 3-51).

Bull thistle is a stout biennial thistle with purple flowers from Eurasia that commonly invades disturbed sites that 

include slash piles, log decks, burned areas, and roadsides. Regeneration occurs solely from short-lived seed. Bull 

thistle is widespread across the ponderosa pine vegetation type on Williams Ranger District where it can 

successfully establish. 

Cheatgrass is an erect cool season annual grass that was introduced from Europe. Cheatgrass is a prolific seed 

producer that can quickly establish and persist following disturbances that increase resource availability (e.g., 

fire). The presence of cheatgrass can increase fire frequency, creating a positive feedback loop that can result in 

cheatgrass monocultures. Relatively small cheatgrass populations are likely to be widespread across the Williams 

Ranger District.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 229

Common mullein can be biennial, perennial or, rarely, an annual with a deep tap root that is native to Europe and 

Asia. In its first year it produces a low vegetative rosette up to 60 cm in diameter which overwinters and is 

followed in the succeeding growing season by a stout flowering stem 5-18 cm tall. An individual may produce 

100,000-180,000 seeds, and seeds may remain viable for up to 100 years. Common mullein is likely to be 

widespread across the Williams Ranger District where appreciable disturbance has occurred.

Dalmatian toadflax is an ornamental, perennial introduced from the Mediterranean Region. It can grow up to 3 

feet tall, and reproduces from both seed and vegetative reproduction from buds on creeping roots. One plant can 

produce up to 500,000 seeds, as well as lateral roots that can produce new individuals up to 10 feet from the 

parent plant. Dalmatian toadflax may crowd out native plants and reduce forage on rangelands. Dalmatian 

toadflax has been documented in several areas of the Williams Ranger District, but is most prominent following 

disturbances in ponderosa pine. 

Diffuse knapweed is an annual or short-lived perennial from the Mediterranean region, growing 1-2 feet tall. 

Knapweeds are members of the sunflower family, with a single strong taproot. It reproduces by seed, and seeds 

can remain viable to 12 years. Dead plants break off at ground level and tumble via wind, spreading seed as they 

move. It produces chemical compounds that inhibit other species (even other knapweeds) from growing around it. 

Diffuse knapweed populations are limited on the Williams Ranger District

Field Bindweed is a perennial vine arising from deep, persistent spreading roots. It reproduces by rhizomes and 

seeds. Field bindweed intertwines and topples native species. It is one of the most serious weeds of agricultural 

fields on temperature regions of the world. Field bindweed is common on the eastern portion of the Williams 

Ranger District where appreciable disturbance has occurred. 

Mexican fireweed is an annual in the Chenopodium family. The plant reproduces by seed, and a single plant can 

produce up to 50,000 seeds annually under favorable conditions. Because of its low water requirements, Mexican 

fireweed can grow in warm, dry environments. It can spread long distances very rapidly, outcompeting and 

displacing natives along the way. Mexican fireweed populations are limited across the Williams Ranger District, 

and occur mostly in areas that have received appreciable disturbance

Redstem stork’s bill is an annual or biennial native to Europe or Asia, and is now common around the world. It is 

grown for forage, and is usually only considered a serious problem when it crowds out more valuable crops. 

Redstem stork’s bill populations are limited across the Williams Ranger District, and occur mostly in areas that 

have received appreciable disturbance.

Russian knapweed is a creeping, herbaceous perennial native to southern Ukraine, southeast Russia, Iran, 

Kazakhstan and Mongolia that reproduces from seed and vegetative root buds. Shoots, or stems, are erect, 18 to 

36 inches tall, with many branches. It emerges in early spring, bolts in May to June (elevation dependent) and 

flowers through the summer into fall. It produces seeds sparingly, approximately 50 to 500 per shoot. Seeds are 

viable for two to three years in soil. Its primary method of reproduction is from vegetative propagation, with seed 

of secondary importance. The weed forms dense, single species stands over time due to competition and 

allelopathy. Russian knapweed populations are limited on the Williams Ranger District. 

Russian olive is a woody species forming large shrubs to medium-sized trees. Until recently, this species was 

promoted for windbreaks and erosion control. It has been planted extensively in areas throughout northern 

Arizona and can invade riparian areas where it eventually replaces native tree species. Russian olive individuals 

are limited on the Williams Ranger District.

Siberian Elm is widely grown in many areas of northern Arizona as a shade tree. However, it is not appropriate in 

wildland settings where it can out-compete native tree species in riparian zones and other sensitive areas. The 

trees reproduce through winged seeds that can be transported long distances on the wind or by vehicles to new 

locations. The abundant production of seed will make this species difficult to control under favorable growing 

conditions. Siberian Elm individuals are limited on the Williams Ranger District.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

230 Chapter 3. Affected Environment and Environmental Consequences

Yellow salsify grows as an annual or occasionally biennial forb, reaching a height of typically 20-60cm. It is 

regarded as invasive in most states of the USA. Yellow salsify populations are limited on the Williams Ranger 

District.

Figure 3-51. Invasive plants within a 1-mile buffer of the project areas
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 231

Yellow sweetclover is an erect annual or biennial that grows from strong taproots; often forming colonies. It 

reproduces by seeds that are drought tolerant and cold hardy. It can outcompete native species by overtopping and 

shading. Yellow sweetclover populations are widespread on the Williams Ranger District.

Of these species, cheatgrass has the potential to be one of the most problematic following the proposed treatment. 

Cheatgrass is an opportunistic species that is very successful at maximizing available moisture and nutrients from 

the upper layer of soil, and it is capable of growing in years of drought and in poor soil conditions. Cheatgrass’ 

ability to sequester resources prior to later emerging species, high seed production, and low resource requirements 

allows this species to become dominant following disturbances. Cheatgrass plants produce many seeds, depending 

on the environment and the spacing and size of the plants. Individual plants growing in high densities may 

produce about 25 seeds each, while a large, open-grown plant can produce about 400 seeds (Zouhar 2003). The 

design of the seed allows it to be easily transported via clothing, animals, and vehicles. 

Other species of concern include non-native thistles, knapweeds, and Dalmatian toadflax. These species will be 

monitored and treated when possible prior to project initiation and monitored for the duration of the project and 

beyond. 

3.8.2 Environmental Consequences

Effects Common to All Alternatives

The Williams Ranger District will continue its invasive species program, which includes inventory, treatment, and 

monitoring of invasive plant species, with those populations having the most significant ecological impact and 

those having the greatest chance of successful control being the highest priority. Implementation of Best 

Management Practices described in the Soils and Watershed section above (Design Features, Best Management 

Practices, and Mitigation Measures) in the Final Environmental Impact Statement for Integrated Treatment of 

Noxious or Invasive Weeds on the Coconino, Kaibab, and Prescott National Forests within Coconino, Gila, 

Mojave, and Yavapai Counties, Arizona (2004) would assist in the protection of habitat quality from non-native 

invasive plants within the project area.

Alternative 1 – No Action

In the absence of severe wildfire, invasive species would continue to be introduced and spread at the current rate. 

However, with no action taken there is an inevitable risk of severe wildfire on Bill Williams Mountain (see Fire 

and Fuels Specialist Report for details). Hunter et al. (2006) found that severe wildfire had a greater impact on the 

establishment of non-native species than did fuels treatments, and noted several other studies in which severe 

wildfires resulted in increased establishment of non-native species (e.g., Crawford et al. 2001; Griffis et al. 2001). 

Crawford et al. (2001) reported higher cover of cheatgrass on severely burned sites when compared to less 

severely burned sites in ponderosa pine forests in Arizona.

Anecdotal evidence from relatively recent fires occurring on the Williams Ranger District (e.g., 2000 Pumpkin 

Fire, 2004 Trick Fire, 2009 Cross Fire, 2009 Wildhorse Fire, 2010 Eagle Rock Fire) that had isolated patches of 

high burn severity is also consistent with these studies. Comparable results have also been found on the North 

Kaibab Ranger District (Kaibab National Forest) from the 1996 Bridger Knoll Fire (Dustin Burger, pers. comm.). 

Frequency data collected in 2003 in both pinyon-juniper and ponderosa pine forests found multiple high severity 

areas that were noted for having cheatgrass as the dominant species. In contrast, low burn severity areas had 

cheatgrass present, but at a lower frequency. The low burn severity areas also had a higher frequency of native 

species relative to high burn severity areas. Results from Hunter et al. (2006) also suggest that the occurrence of 

large and severe wildfires may be one of the more important mechanisms for continued spread of non-native 

species in semi-arid forests in the west.

Effects Common to All Action Alternatives

Although mechanistic explanations for such are commonly inconsistent (e.g., Davis et al. 2001, Lonsdale et al. 

1999), invasion ecology theory often suggests that there is an increased probability of invasive species 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

232 Chapter 3. Affected Environment and Environmental Consequences

recruitment and for the spread of existing infestations with increased disturbance. Without early detection and 

treatment, invasive species have the ability emerge and proliferate into disturbed areas, potentially outcompeting 

native understory species and redirecting a plant community’s successional trajectory. Further, there is an 

increased threat of introducing new species via equipment and personnel that enter a project area. New and 

expanded invasions can be expected with all action alternatives. Invasive species monitoring and treatments will 

address invasive species issues for all action alternatives. Assuming that successful control of invasive plants 

occurs during project activities, all action alternatives can result in improved ground cover and vigor for native 

understory species (Moore et al. 2006, Abella 2004). The proposed treatments may also result in increased species 

richness and functional group diversity which can reduce how invasive a site is (Elton 1958, Davis et al. 2001). 

All action alternatives further reduce the potential for severe wildfire, where the risk of invasions is considerably 

higher. 

Alternative 2 – Modified Proposed Action

Alternative 2 would result in the greatest reduction of tree densities of all action alternatives, thus having the 

greatest impact on species abundance, and potentially species richness, of understory plant communities at the 

project scale. Alternative 2 would also result in the greatest reduction in the risk of severe wildfire compared to all 

other alternatives, which would provide the greatest safeguard against the undesirable effects that are associated 

with such. The combination of the ground disturbing activities associated with timber harvesting and enhanced 

resource availability following treatments will likely result in Alternative 2 having the highest probability of 

short-term invasions relative to the other Action Alternatives. Because Alternative 2 has the highest probability of 

reducing the risk of severe wildfire, it may have the lowest probability of long-term invasions relative to other 

alternatives. 

Mechanical Treatments. While the effects of the thinning treatments would be positive with the implementation 

of the mitigation measures described above, the operational effects of the various logging methods vary. The 

operational effects of helicopter and ground based logging are not likely to have long-term adverse effects due to 

the limited level of disturbance associated with such. The effects of ground based and helicopter logging would 

likely result in short-term invasions by non-native plant species. 

Strategic Fuels Treatments. Strategic Fuels Treatments would occur under Alternative 2 using ground based 

logging methods and hand felling. These treatments would be consistent with the mitigation measures described 

above. The effects of ground based logging operations are described above. 

Transportation and Trails. Alternative 2 includes the construction of 15 miles of new roads, 16 miles of 

temporary roads, and 1 mile of new trail. Although the direct loss of plant species habitat may be not be 

significant at this scale, roads and trails act as dispersal corridors for invasive species. Invasive species can 

negatively affect natives through direct competition that results in degraded habitat quality. Implementation of 

Best Management Practices described in the Soils and Watershed section above (Design Features, Best 

Management Practices, and Mitigation Measures) in the Final Environmental Impact Statement for Integrated 

Treatment of Noxious or Invasive Weeds on the Coconino, Kaibab, and Prescott National Forests within 

Coconino, Gila, Mojave, and Yavapai Counties, Arizona (2004) would assist in the protection of habitat quality 

from non-native invasives within the project area. Alternative 2 also includes 28 miles of road obliteration, which 

would improve understory conditions by limiting invasive species dispersal rates. 

Alternative 3

Alternative 3 would remove fewer trees than Alternative 2 due to diameter caps that restrict the size of trees that 

can be removed. Alternative 3 would have a less improved understory response at the project scale when 

compared to Alternative 2 due to the diameter cap; therefore would be less resistant to invasions. Alternative 3 

would result in less of a reduction in the risk of severe wildfire compared to Alternative 2, which would provide 

less of a safeguard against the undesirable effects that are associated with such. Because Alternative 3 has a lower 

probability of reducing the risk of severe wildfire when compared to Alternative 2, it may be more susceptible to 

long-term invasions should a severe wildfire occur.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 233

The effects of the mechanical treatments, ground based and helicopter logging operations, strategic fuels 

treatments, and transportation and trails are described in detail above under Alternative 2. 

Alternative 4

Alternative 4 would remove the fewest number of trees of all Action Alternatives due to diameter caps that restrict 

the size of trees that can be removed and the exclusion of helicopter logging. Alternative 4 would have a less 

improved understory response at the project scale when compared to Alternatives 2 and 3 due to the diameter cap; 

therefore would be less resistant to invasions. Excluding helicopter logging would result in 4,087 untreated acres 

within the project area. Areas proposed for these treatments are generally the steepest areas within the project 

area, thus the most susceptible to crown fires. Alternative 4 would result in the lowest level of disturbance at the 

project scale, thus would result in the lowest probability of short-term invasions of all action alternatives. Because 

Alternative 4 would result in the highest probability of severe wildfire of all action alternatives, it has the highest 

probability of long-term invasions of all action alternatives.

The effects of the mechanical treatments, steep slope and ground based logging operations, strategic fuels 

treatments, and transportation and trails are described in detail above under Alternative 2. Items not addressed 

under Alternative 2 are discussed below. 

Mechanical Treatments. The exclusion of helicopter logging would result in less disturbance, in turn resulting in 

a lower risk of future invasions in these areas in the absence of severe wildfire. Excluding these areas will result 

in increased risk of severe wildfire, in turn increasing the risk of long-term invasions in the project area. 

Transportation and Trails. Alternative 4 excludes the construction of 23 miles of new road construction in 

exchange for 38 miles of temporary roads. Excluding permanent roads would limit long-term invasive species 

expansion. Temporary roads may result in short-term invasions. 

Cumulative Effects

Grazing. The project area falls within the Hat Grazing Allotment (See Rangeland Ecology and Management 

Specialist Report for detail). The proposed vegetation treatments would be managed in coordination with grazing 

management so that grazing within the project area is deferred or avoided during implementation, and a recovery 

period will follow for treated pastures if needed. Allowing treated pastures to fully recover prior to livestock reentry will promote the establishment of a diverse native understory, thus reducing the invasibility of the treated 

area (Elton 1958).

Livestock grazing before or after burning can influence invasive species establishment, persistence, and spread, 

but the interaction of grazing with invasive species and fire is poorly understood (Zouhar et al. 2008). However, 

the dispersal of invasive species propagule while stressing more palatable native species deserves consideration. 

Several studies have shown that heavy livestock use can lead to increases in aggressive invasive species 

establishment (Zouhar et al. 2008). 

There have also been studies that indicate that well managed grazing with low stocking rates can be comparable to 

grazing rest. On a seven year study performed in north central Arizona during drought conditions, Loeser et al. 

(2006) compared exotic species colonization on plots experiencing high impact grazing, moderate intensity, and 

livestock removal. Their study noted that high impact grazing resulted in a considerable increase in exotic 

species, especially cheatgrass, while moderate grazing and complete livestock removal plots experienced very 

similar results of only small increases in exotic species. 

Currently the Hat Allotment is stocked appropriately for their annual forage production. Given that an anticipated 

effect of the treatment will increase understory growth, re-entry of livestock to areas treated after recovery should 

not have an adverse effect to continued understory species response. Combining sufficient understory recovery 

and planned aggressive weed monitoring and treatment, there is no anticipated effects of increases in non-native 

species once grazing pressure resumes. Adaptive management will be implemented to address the interaction of 

invasive plant and grazing (USDA 2009). Best Management Practices will be implemented within the project 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

234 Chapter 3. Affected Environment and Environmental Consequences

area, with those populations posing the greatest ecological threat and/or having the greatest likelihood of 

successful control being the highest priority for treatment to mitigate the treat of invasive species.

Fuels and Timber Management Activities. (Spring Valley, Pine-Aire, Beacon, Williams, Clover, City, Twin, Bill 

Williams Cap, Elk, Lee, Wright Hill, Horse Pine, Frenchy, Moose, Government 2, Dog Town, McCracken, 4FRI, 

KA, Irishman, Pomeroy, Community Tank) 

Fuels and Timber Management Activities often result in recruitment of invasive plant species that can degrade 

habitat for native plant species. If neighboring fuels and timber management projects are currently invaded by 

invasive plants, the risk of invasion within the Bill Williams Mountain Restoration Project is likely increased due 

to high propagule pressure. Currently, known invasive plant populations within these project areas are being 

treated, and will continue to be treated until control is achieved. The mitigation measures described above are 

designed to limit invasions within the Bill Williams Mountains Restoration Project boundary. Best Management 

Practices will be implemented within the project area, with those populations posing the greatest ecological threat 

and/or having the greatest likelihood of successful control being the highest priority for treatment to mitigate the 

treat of invasive species.

Williams RD Travel Management Project. The cumulative effects of the action alternatives and Williams RD 

Travel Management Project are expected to have positive effects on invasive plant species management due to 

reductions in dispersal rates associated with fewer roads.

Recreation. Recreational activities often accelerate seed dispersal rates of invasive plants. This can be especially 

problematic in recently disturbed areas, such as areas where fuels and timber management activities have 

occurred. Best Management Practices will be implemented within the project area, with those populations posing 

the greatest ecological threat and/or having the greatest likelihood of successful control being the highest priority 

for treatment to mitigate the treat of invasive species. 

Climate. Global climate change models project warmer, more arid conditions in the southwestern United States 

(Seager et al. 2007). However, the impact of global climate change on species’ distributions is mostly uncertain 

(Thuiller et al. 2007). Climate change may result in more frequent and severe droughts, as well as more highintensity wildfires. Drought and high-intensity wildfire may result in plant community conversions, habitat loss, 

and the loss of species viability. Restoration treatments that result in improvements to the understory plant 

community health may increase understory resistance and resilience to invasive plant invasions. 

3.9 Rare Plants 

3.9.1 Affected Environment

The Bill Williams Mountain Restoration Project area contains several cover types that range from Douglas fir and 

aspen at the upper range of elevations to grasslands at the lower range of elevations. There is a lack of data 

documenting the understory plant community component in the project area which makes it difficult to provide a 

site specific assessment of its existing condition as it pertains to rare plant species. However, we can make some 

assumptions based on studies conducted in northern Arizona forests. Laughlin et al. (2011) found that ponderosa 

pine basal area increased from an average of 4m2/ha in the early 1900s to 29 m2/ha in 2007, which resulted in a 

decline of understory plant foliar cover by 21%, species richness by 2 species/m2, and declines in functional 

richness.

Bakker and Moore (2007) found that species density declined by 34%, herbaceous plant density by 37%, shrub 

cover by 69%, total herbaceous cover by 59%, graminoid cover by 39%, and forb cover by 82% between 1941 

and 2004, and that these changes were negatively correlated with overstory vegetation. Arnold (1950) noted a 

25% reduction in grass density in ponderosa pine stands near Flagstaff, Arizona between 1912 and 1947 due to 

establishment and growth of ponderosa pine trees. Covington and Moore (1994) projected similar trends using a 

simulation model that showed herbage production (lbs./ac) may have declined approximately 84 % in an 

untreated ponderosa pine forest between 1907 and 1947. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 235

Repeat photography conducted within the Bill Williams Mountain Restoration Project area in 2011 and for the 

Hat Grazing Allotment Environmental Assessment in 2009 (USDA 2009), which is partially included within the 

Bill Williams Mountain Restoration Project boundary, indicates that both ponderosa pine and juniper species have 

increased within the project area. Therefore, it is appropriate to assume that the trends described above continue 

today in areas where tree encroachment and canopy closure continues to occur in northern Arizona forests. In 

addition, it is also appropriate to assume that understory plant species, including rare plant species, are more 

competitively stressed than they were under pre-settlement conditions, and are likely declining due to their 

inability to rapidly adapt to an altered environment (Laughlin et al. 2011). 

Direct and Indirect Effects

A review was conducted to determine if threatened, endangered, potential, and sensitive species and the rare and 

endemic plants occur or habitat exist within or near the project area. The following references were used: 

USFWS list of Threatened, Endangered, Proposed, Candidate, and Conservation Agreement species occurring in 

Coconino and/or Yavapai Counties; Arizona Game and Fish Department Heritage Data Management System; 

USDA Forest Service Region 3 Rare Species List; Arizona Rare Plant Field Guide; and Southwest Environmental 

Information Network. 

The search of known locations of rare plant species was conducted using spatial data from Arizona Game and 

Fish Department Heritage Data Management System, USDA Forest Service Rare Plants Occurrences database 

(NRIS), and Southwest Environmental Information Network. Arizona bugbane (Actaea arizonica; Forest Service 

Sensitive Species, and Flagstaff beardtongue (Penstemon nudiflorus; Forest Service Sensitive Species) are known 

to occur within the project boundary. Potential habitat may exist for Mt. Dellenbaugh sandwort (Arenaria 

aberrans; Forest Service Sensitive Species), Rusby’s milkvetch (Astragalus rusbyi; Forest Service Sensitive 

Species), Arizona Leather flower (Clematis hirsutissima var. hirsutissima), Rock fleabane (Erigeron saxatilis), and 

Arizona Phlox (Phlox amabilis). 

Regional Forester’s Sensitive Species

Effects Common to Alternatives 2, 3, and 4

Plant communities in the western United States have been dramatically altered by fire exclusion, overgrazing by 

livestock, and selective timber harvesting; all of which have combined to form highly dense and unhealthy 

forests. Increased ponderosa pine density has resulted in a significant loss of the herbaceous understory due to 

alterations in resource allocation within the stand, which can adversely affect both structural and functional 

properties of the forest understory (Laughlin et al. 2011, Stoddard et al. 2011). Ecological restoration can be 

applied to convert high-density ponderosa pine forests to an open canopy structure similar to that found at the 

time of Euro-American settlement (Moore et al. 2006), potentially reestablishing understory properties to near 

pre-settlement conditions (Stoddard et al. 2011). 

Forest thinning and prescribed burning are often proposed and implemented to reverse the undesirable changes in 

ponderosa pine forests in Arizona (Abella 2004). Forest thinning and prescribed burning can make resources (e.g., 

light, nutrients, and water) more readily available for understory plant species, and can aid in the restoration of 

ecosystem function and processes. Increasing resource availability can result in increased understory species 

abundance, vigor, and productivity, and potentially species richness (Griffis et al. 2001, Abella 2004, Moore et al. 

2006, Laughlin et al. 2008, Stoddard 2011). The proposed restoration treatments would provide structural 

diversity to promote suitable habitat for a host of understory species with differing resource requirements (e.g., 

shade-tolerant vs. shade-intolerant), and would have the potential to increase the abundance of rare plant species. 

Alternatives 2, 3 and 4 reduce tree densities and woody debris through mechanical and burning treatments 

throughout the project area. These treatments would have various impacts on plants in this report described in the 

above paragraph. However, these impacts would be less than a high intensity wildfire and the associated 

flooding/erosion if these alternatives were not implemented.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

236 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-52. Arizona Bugbane (Actaea arizonica) in the Project area

Arizona bugbane requires deep shade from forest or riparian overstory. Arizona bugbane occurs in mesic habitats, 

typically along the bottoms and lower slopes of steep, narrow canyons, where the dense overstory often includes a 

combination of coniferous and deciduous tree species. Important overstory species include Douglas fir 

(Pseudotsuga menziesii), white fir (Abies concolor), big tooth maple (Acer saccharum ssp. grandidentatum), 

Arizona alder (Alnus oblongifolia) and red osier dogwood (Cornus stolonifera).

This special combination of environmental features that contribute to Arizona bugbane habitat also supports a 

high diversity of other species of plants and animals (USFWS, 1998). It is confined to various tributaries of Oak 

Creek Canyon, and West Clear Creek on the Coconino National Forest and the slopes of Bill Williams Mountain 

on the Kaibab National Forest, and in Workman Creek and Cold Springs Canyon in the Sierra Ancha Mountains 

(Tonto National Forest), (Arizona Game and Fish Department, 2012). 

Arizona Bugbane (Actaea arizonica) 

Arizona bugbane (Figure 3-52) is an endemic species known only from northern and central Arizona that was first 

collected on the slopes of Bill Williams Mountain on the Kaibab National Forest in 1883. In 1993, a petition for 

listing Arizona bugbane as a Threatened or Endangered species was published in the Federal Register (58 Federal 

Register 51144; September 30 1993) and the species was assigned Category 1 Status, indicating there was enough 

information to support listing under the Act. The US Fish and Wildlife Service and Arizona Rare Plant Recovery 

Team determined that the implementation of a Conservation Strategy by the Forest Service with a Memorandum 

of Understanding (MOU) was sufficient to preclude the listing of Arizona Bugbane. 

As a result, the forests prepared the Arizona Bugbane Conservation Assessment and Strategy for Coconino and 

Kaibab National Forests in 1995. This document was accepted and approved by the District Rangers and Forest 

Supervisors for Coconino and Kaibab National Forests. The Conservation Strategy included a monitoring 

schedule for known populations. The Strategy is under revision with estimated completion by September 30, 

2015. 
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Chapter 3. Affected Environment and Environmental Consequences 237

Existing condition for Arizona Bugbane

Arizona bugbane is a sensitive species on the Kaibab National Forest, and management area has been set aside for 

it on Bill Williams Mountain. The Arizona Bugbane Botanical Area is comprised of 490 acres on the northwest 

slope of Bill Williams Mountain. Management direction in the Kaibab National Forest Plan for this species 

includes managing hiking to maintain ecological integrity in the area, exclusion of grazing in the area, managing 

fire suppression in the area to prevent damage to the population, trail maintenance and mineral withdrawal. 

The Arizona Bugbane Conservation Assessment and Strategy (1995) contains direction on several management 

concerns including degradation of the integrity of the ecosystem, which focuses on preservation of the shaded 

habitat needed for the species, grazing impacts, recreation impacts, mining, pesticide use and natural threats 

including certain plant diseases. Mining and pesticide use have generally not been threats.

Arizona bugbane occupies mesic canyons in the Oak Creek Canyon, West Fork of Oak Creek and its tributaries 

and West Clear Creek. In 2014, approximately 117 acres containing Arizona bugbane (West Fork of Oak Creek) 

were affected by the Slide Fire (Figure 3-53). Most of the populations experienced low to moderate severity fire. 

Only a minor portion was affected by high severity. 

Prescribed fire may provide opportunities for Arizona bugbane habitat enhancement (Phillips and Popowski 

1995). The current knowledge of fire effects on Arizona bugbane are based largely on observations on a local 

wildfire, the Fry Fire in 2003. The fire covered 180 acres of upland and canyon habitats in Fry Canyon and was of 

mixed severity. The initial effects of the fire to Arizona bugbane were loss the above ground portions of individual 

plants. On a visit in 2004, Arizona bugbane plants were growing along the fire line near the canyon bottom. A 

variety of plant sizes and ages were present, ranging from adults with mature fruits to seedlings. An adult plant 

with fruits and blackened soil at the base is shown in Figure 3-53. 

The Arizona bugbane populations were monitored again in 2005 and 2010, and no adverse effects from the fire 

were noted. A related species Actaea rubra has been studied in the Northwestern U. S. (Crane 1990). In that 

species, the tops of plants are removed by fire and then plants regenerate from thick underground caudices, but 

seedlings did not appear for several years post-fire. A separate population occurring on the Coconino National 

Forest has also remained stable since a watershed-scale fire occurring in the 1970’s (B. Phillips, pers. comm.). 

Pyke et al. (2010) state that rhizominous cryptophytes, such as Arizona bugbane, are generally protected from 

fires because their buds are below the soil surface and insulated from lethal temperatures. Pyke et al. (2010) also 

state that plants with perennating buds or organs near the surface (<10 cm under thick woody debris) may be 

susceptible to high-intensity fires with slow rates of spread, implying that those with perennating buds >10 cm are 

less susceptible to high-intensity fires.
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238 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-53. Arizona Bugbane sprouting in July 2014 in an area burned by 2014 Slide Fire

Fire can also consume surface litter where Arizona bugbane exists allowing for its seeds to reach mineral soil. 

Soil-seed contact may facilitate germination and recruitment of new Arizona bugbane individuals, as was evident 

at the Fry Fire population (B. Phillips, pers. comm.). Fire can also increase net nitrogen (N) mineralization, 

making N more readily available for plant uptake (Kaye and Hart 1998). Improved nutrient cycling following 

restoration treatments can increase production in remaining vegetation, resulting in enhanced plant community 

health. 

In 1982 the Arizona Bugbane population was mapped by US Forest Service personnel on Bill Williams Mountain. 

The population was found in four distinct bubbles, in a very small area (approximately 6.5 acres). A Level 1 

survey transect was established in 1988 and shows the population steadily increased up until the 2005 visit, with a 

slight decline since 2005 until 2013, while the number of fruiting stems has continued to increase. 

On September 9, 2013 Glenn Rink, Beverly Hansen, and Barbara Phillips surveyed the Bill Williams Bugbane 

population and conducted a Level 1 survey to obtain a current population estimate prior to thinning and burning 

treatments in this project (Figure 3-52). The survey resulted in 72 plants, 197 stalks, and 74 fruiting stalks in the 

monitoring plot. The upper most plants here are tucked under some rocks in the middle of the gully. They only 

found two other small batches of plants between this highest plant and the trail crossing just upstream of the upper 

end of the monitoring transect. They searched above this point to the fourth trail crossing of the gully and found 

Actaea rubra, but no Actaea. 

They found the lowermost Arizona bugbane plant below the area where the Bill Williams Mountain Trail is close 

to the gully (Figure 3-52). They also found plants as much as 14 meters above the main gully. The highest point 

found was on the big side gully to the west. This area above the gully was also occupied in the 1982 map of the 

bugbane population. The population is very dense on the south side of this gully and reaches its uppermost limit.
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Chapter 3. Affected Environment and Environmental Consequences 239

On April 18, 2014 district biologists visited the bugbane population on Bill Williams Mountain and used a GPS 

unit to record the population distribution on the mountain. Results were very similar to 2013, with an apparent 

slight increase in overall area where the plant is distributed. Figure 3-53 below shows the points taken by Rink et 

al. in 2013 and by the Wildlife Biologist in 2014. Observations of the population indicate that in areas where the 

aspen canopy has died or been reduced the bugbane is the main understory plant in the drainage bottom. In shaded 

areas the bugbane is present, and competing with locust and other understory species. 

Arizona bugbane Level 2 surveys were done in on Bill Williams Mountain in 1988, 1998, 2003, 2004, 2011, and 

2012. No other bugbane observations have been observed outside the Arizona Bugbane Botanical Area in any of 

these surveys. Data from these visits is limited to observations about increasing New Mexico Locust plants within 

the bugbane population in 2000 and a more open canopy condition was observed in 2003 compared to 2000. 

Additional surveys on Kendrick (2004 and 2014) and Sitgreaves Mountains (2004) have also been done with no 

bugbane observations. 

3.9.2 Direct and Indirect Effects

The most substantial effect to this species from management actions is effects to the shady, mesic microclimate 

needed for its survival and reproduction. Upland treatments should not compromise the shady moist canyon 

ecotone needed for Arizona bugbane. 

Alternatives 2-4 

Mechanical Treatments. Mechanical treatments in the Botanical Area may provide opportunities for habitat 

enhancement. For tall bugbane (Cimicfuga elata), Kaye and Kirkland (1999) hypothesized that hardwood trees 

play an important role in forest dynamics. The deciduous trees where Arizona bugbane is established are leafless 

in the spring allowing direct sunlight to reach the forest floor. Direct sunlight can heat the top layers of the soil, 

which may contribute to stimulated growth and enhance germination and establishment. In the summer, leaves on 

deciduous trees provide shade to maintain moisture and cooler temperatures. Since shade-tolerant coniferous trees 

have the potential to rise above the deciduous tree associates of Arizona bugbane and outcompete them in the 

absence of prescribed or natural fire, low intensity thinning of coniferous trees in the Botanical Area may promote 

the health and sustainability of Arizona bugbane’s deciduous tree associates.

Coniferous and deciduous trees that are part of the upper canopy and contribute to this unique habitat, as well as 

deciduous trees/shrubs greater than 5 inches in diameter, would be left on site to promote and maintain the deep 

shading that facilitates this microenvironment (i.e., reduced temperature, increased moisture, and seasonal light) 

for which Arizona bugbane is thought to be dependent. Further, improving tree health through density reductions 

may also result in long-term resistance to disturbance (e.g., insect outbreaks, drought), thus enhancing the longterm sustainability of the microenvironment. Interestingly, Kaye (1994) found that tall bugbane populations in 

clear cuts and thinned stands were taller and produced more flowers than that in uncut forests or second growth 

(>70 years). While this isn’t meant to advocate heavy thinning within the Botanical Area on Bill Williams 

Mountain, it does provide insight into treatment tolerance of Arizona bugbane. 

Helicopters to remove material and conventional thinning techniques are being proposed within the Arizona 

Bugbane Botanical Area under Alternative 2. While the effects of the thinning treatments in the Botanical Area 

would be positive with the implementation of the mitigation measures described above, the operational effects of 

the each logging method vary. Within the Botanical Area, helicopter logging (382 acres, 78% of the Botanical 

Area) would result in the least amount of disturbance, followed by ground based logging (108 acres, 22% of the 

Botanical Area) respectively.

Potential effects include loss of shade from reduction of tree canopies near the canyon edges and changes to the 

moist microclimate near the population. 

The proposed helicopter and ground based logging operations are not likely to adversely affect Arizona bugbane 

because of the limited level of disturbance associated with such, and the implementation of the mitigation 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

240 Chapter 3. Affected Environment and Environmental Consequences

measures that have been designed to protect the critical habitat components that provide the unique 

microenvironment for Arizona bugbane. 

An indirect effect of management actions within the potential habitat of Arizona bugbane includes an increased 

risk of invasion from noxious or invasive weeds. These effects would be mitigated by incorporating the Best 

Management Practices. Incorporation of the Best Management Practices would mitigate the effects of increased 

disturbance from management activities, and help to control the spread and introduction of weeds within the 

habitat of Arizona bugbane. 

Strategic Fuels Treatments. Strategic fuels treatments may occur in the Botanical Area. However, these 

treatments would be similar in effect as those described above under Mechanical Treatments, and are not likely to 

adversely affect Arizona bugbane because of the implementation of mitigation measures that have been designed 

to protect the critical habitat components for Arizona bugbane. 

Prescribed Fire. The Slide Fire began on May 20, 2014 and burned over 20,000 acres. It burned through several 

known locations of Arizona bugbane in the West Fork of Oak Creek and its associated tributaries. We have not 

been able to observe the effects to the plants and habitat due to safety concerns but data from fire severity and 

vegetation analyses indicate that most of the canyon itself burned at low to moderate severity. The effects of 

factors such as erosion, flooding and landslides in the future are not known. On a field visit on July 2, 2014, we 

observed Arizona bugbane plants sprouting in the edge of the fire in a low to moderate severity of the fire. More 

monitoring will be needed to determine the effects on Arizona bugbane. 

Prescribed burning may occur in or near the population of Arizona bugbane on Bill Williams Mountain. The area 

containing Arizona bugbane that will be subjected to burning treatments will be the same for all action 

alternatives. Short-term effects of burning include deaths of individual plants. Long-term effects include the loss 

of shade from tree mortality. This will be mitigated by burning at intensities in all entries low enough to limit 

mortality to trees. 

Given the projected climatic conditions (Seager et al. 2007) and current wildfire trends in the southwest United 

States (e.g., Shultz Fire of 2010, Wallow Fire of 2011), the risk of high-intensity wildfire within the Botanical 

Area can be considered very high. Following high-intensity wildfire, there is potential for the permanent loss of 

Arizona bugbane on Bill Williams Mountain due to sedimentation and erosion within the drainage where it exists, 

as well as the permanent loss of its habitat. Sedimentation and erosion may also occur following prescribed fire, 

but the extent would be significantly less than that from a high-intensity wildfire.

Prescribed fire (i.e., low to moderate fire intensity) can provide opportunities for Arizona bugbane habitat 

enhancement, and is not likely to adversely affect Arizona bugbane because of the implementation of the 

mitigation measures that have been designed to protect the critical habitat components that provide the unique 

microenvironment for Arizona bugbane. 

Transportation and Trails. No new roads or trails are proposed within the botanical area.

3.9.3 Cumulative Effects

The boundary of this discussion is the range of Arizona bugbane within the Kaibab National Forest. The time 

limit for this analysis begins in 1993, when monitoring for Arizona bugbane began on the Coconino and Kaibab 

National Forests. The following past actions have affected the abundance of Arizona bugbane and have 

established baseline current condition for Arizona bugbane. Some impacts observed include grazing, recreation, 

wildfire and natural disturbances such as flooding, drought, tornados and mortality in overstory trees. Grazing 

impacts were addressed in the Conservation Strategy (1995) and include fencing and monitoring in certain 

populations. This has led to a reduction in these conflicts. 
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Chapter 3. Affected Environment and Environmental Consequences 241

Ongoing and Future Foreseeable Actions for Arizona Bugbane

These management actions are ongoing within the habitat of Arizona bugbane. Some items in the cumulative 

effects document also apply.

Grazing by livestock and wildlife still occurs in or near some populations. Livestock grazing is a management 

action that can be addressed and mitigated by Forest Service actions, while wildlife grazing is not under the 

control of forest. However, no livestock grazing occurs within the Arizona Bugbane Botanical Area. 

Recreation impacts include hiking and trampling by humans. Hikers trample plants and degrade habitat by leaving 

established trails and establishing social trails within suitable habitat. No such use as been observed within the 

Arizona Bugbane Botanical Area. However, trail maintenance is necessary to keep the trail confined to the trail 

prism but mitigates the effects of trampling to non-significant levels.

At this time, there is less concern for the immediate bugbane population than there is for the health of the forest 

surrounding and supporting the population. Uncharacteristic high-intensity wildfire resulting from the 

accumulation of fuels currently threatens the habitat of Arizona bugbane in the Arizona Bugbane Botanical Area. 

Low levels of successful regeneration of aspen and the loss of large old-growth conifers have also resulted in 

habitat degradation. 

Climate change could affect the distribution of vegetation in general by affecting biotic and abiotic factors and by 

increasing the extent and severity of disturbances (USDA Forest Service 2010). Rare and sensitive species may be 

especially vulnerable because they often need specific habitat components such as specialized soil types that are 

not widely available. This could negatively affect their abilities to migrate to suitable areas as environmental 

conditions change. Water availability may decrease in some areas while temperatures generally increase. Alpine 

habitats may disappear entirely as elevational vegetation shifts occur (USDA Forest Service, 2010).

Future plant distributions in general may be governed by several factors including human influences, abilities of 

plants to disperse, and the presence of suitable habitat components including such factors as suitable soil types 

(McKenney et al, 2007). Large changes in ecosystem structure and species composition of plant communities are 

expected due to increasing temperatures and altered precipitation cycles (USDA Forest Service, 2010). Species 

have responded to climate change throughout their evolutionary history, but not at rates seen in recent climate 

change (Root et al, 2003). Phenology shifts in vegetation communities in large regions have been noted. These 

include shifts in the beginning, ending and length of growing seasons in temperate regions of the northern 

hemisphere. The results have been earlier emergence and blooming of flowering plants, extended end of season 

and longer growing seasons. 

Changes in growing season may affect climate by affecting surface radiation, temperature, hydrology and carbon 

cycling (Jeong et al, 2011). Trophic mismatches have been documented for several species (Parmesan, 2006) 

leading to disruption on symbiotic relationships and plant/animal interactions. In a review of many studies on 

climate change, Root et al, 2003 determined that “the balance of evidence for these studies strongly suggests that 

a significant impact to global warming is already discernible in animal and plant populations”.

Climate change coupled with other factors such as habitat loss could lead to extirpations and increased risks of 

extinction. Species generally respond to rapid climate change at differential rates. These differential movements 

may lead to loss of connectedness and loss of communities (Root et al, 2003). While the actions of this project 

will not mitigate widespread climate change, actions will help our local vegetative communities be more resilient, 

restore natural fire regimes, and reduce the risk of habitat loss due to uncontrolled wildfire. 

Determination of Effects for Arizona Bugbane

The Bill Williams Mountain Restoration Project may impact individuals of Arizona bugbane (Actaea arizonica) 

but is not likely to result in a trend toward federal listing or loss of viability. 

The following plants are from the Regional Forester’s Sensitive Species list and are found within the project area 

or habitat for this species exists in the project area.
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242 Chapter 3. Affected Environment and Environmental Consequences

Rusby Milkvetch (Astragalus rusbyi) 

Rusby milkvetch is a narrow endemic found on basaltic soils northwest and west of Flagstaff, Arizona. It is found 

in openings or meadows in ponderosa pine forests or at the edges of thickets and aspen groves, on dry basaltic 

soils; at elevations ranging from 7,000 to 8,000 feet. Known populations exist on the Williams Ranger District. 

Limiting factors or threats to the plant include: extremely narrow range, grazing, highway maintenance. 

Existing condition for Rusby milkvetch. Occurrences have also been recorded on the Kaibab National Forest in 

Frenchy Project Area (2003) and on the adjacent Camp Navajo (Springer, 2009). There are numerous occurrences 

of Rusby milkvetch in the Hart Prairie (2010) and Wing Mountain (2012) projects on the Coconino National 

Forest. Coconino Rural Environmental Corps (CREC) (2011) detected numerous locations of this plant in the A-1 

Mountain area of the Coconino. It is unknown if there is Rusby milkvetch in the project area below 8,000’. 

Arizona leather flower (Clematis hirsutissima var. hirsutissima) 

Habitat includes rocky hillsides in open to dense ponderosa pine with slopes from 12% to 40%, with aspects 

generally from 320o to 40o from 7,000 to 8,500 feet. It is generally found in limestone soils but a few populations 

occur on basalt soils. Known populations on North Kaibab Ranger District but potential habitat exists on the rest 

of the Kaibab National Forest. Limiting factors or threats are: logging, recreation, and land development. 

The inclusion of Arizona leather flower on the Region 3 sensitive plant list has an unusual history. The plant was 

formerly included on the Region 3 Sensitive Species List as Clematis hirsutissima var. arizonica, but was 

removed 1999 when taxonomists determined that the variety was not a valid taxon. Arizona leather flower was 

added back to the Region 3 sensitive species list as variety hirsutissima in 2007 that includes locally occurring 

plants formerly designated as var. arizonica. 

Existing condition for Arizona leather flower. Populations of Arizona leather flower occur in Northern Arizona 

near Lower Lake Mary, in Skunk Canyon and in Fay Canyon. Arizona leather flower also occurs on the Tusayan 

Ranger District of the Kaibab National Forest, near Ten X Tank (KNF). Other populations occur on Harold Ranch 

Road in east Flagstaff (private land), in Mountainaire (private land), Fort Valley and near Hoe Tank on the 

Mogollon Rim Ranger District, which is outside the current project area but within ponderosa pine habitat.

Juvenile plants benefit from high amounts of leaf litter. The litter provides a source of humidity around seedlings. 

However, heavy accumulation of litter can be detrimental to seedling survival and vegetative reproduction in 

adults. Intermediate amounts (approximately 50%) of light and shade were the most beneficial conditions for 

Arizona leather flower. Higher levels of light increased photosynthesis in adult plants, but resulted in lower 

reproductive success, and increased risk of desiccation. Low levels of light resulted in decreased photosynthesis, 

fewer stems per plant and lower seed production (Maschinski et al, 1997). It is unknown if there is Arizona leather 

flower in the project area.

Flagstaff beardtongue (Penstemon nudiflorus) 

Flagstaff beardtongue grows in dry pine forests, pine/oak, pine/oak/ juniper and pinyon juniper forests. It occurs 

on dry slopes, in openings and along edges of openings and in forested areas from 5,035-7,375’. Documented 

locations for Flagstaff beardtongue include Anderson Mesa, near Lake Mary, Luke Mountain, Mormon Lake, 

Stoneman Lake, along the Schnebly Hill Road, along Oak Creek on the Coconino NF and in the Volunteer 

Canyon area, Sycamore Canyon, Bill Williams Mountain, and near the City of Williams in the Kaibab National 

Forest. In recent years, numerous locations have been found in proposed fuels reduction projects such as Upper 

Beaver Creek Watershed Fuels Reduction Project (2010)) and in the Rocky Park Fuels Reduction Project (2001). 

It has been observed in several locations including the Wild Steer Mesa area along Forest Road 108 near the Hat 

Ranch area on the Kaibab NF. Limiting factors and threats to the plants include: its rarity, grazing, and fire.

Existing condition for Flagstaff beardtongue. It is unknown if there is Flagstaff beardtongue in the project area. 
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Chapter 3. Affected Environment and Environmental Consequences 243

Arizona phlox (Phlox amabilis) 

Arizona phlox is endemic to central and northern Arizona. It occurs in open, exposed limestone or basalt rocky 

slopes within pinyon-juniper and ponderosa pine, gambel oak communities where it grows on limestone and 

basalt soils 5,500-7200’. The population trends and history of Arizona phlox are unknown (Arizona Game and 

Fish Heritage Database Abstract, 2005). Limiting factors and threats to the plant include: grazing and fire. 

Existing condition for Arizona phlox. Arizona phlox was added to the Region 3 sensitive species list in 2013. 

Therefore, the forests have not conducted specific surveys for it in the past. The occurrences discussed in this 

section were derived from SEINet, an on-line database of collections and observations from several herbaria. It is 

unknown if there is Arizona phlox in the project area. 

Ro

Rock/Cliff Fleabane (Erigeron saxatilis) 

ck/cliff fleabane is an endemic species that occurs only in northern and central Arizona where it inhabits sheer 

canyon walls, moist north-facing slopes, steep solid rock and bedrock outcrops from 4,400 to 8,350’. Coconino 

sandstone seems to be preferred. Habitat may exist on cliff faces of Williams Ranger District. Limiting factors and 

threats for the plant include: rarity and recreation.

Existing Condition for rock fleabane. The habitat for this species is steep cliffs and bedrock boulders. It is 

unlikely that there would be enough fuel accumulated to merit thinning or allow fire to enter the areas where this 

species grows. Therefore, the management actions proposed in this analysis are not likely to affect individuals or 

habitat of cliff fleabane. It is unknown if there is cliff/rock fleabane in the project area. 

Mt. Dellenbaugh sandwort (Arenaria aberrans) 

Mt. Dellenbaugh sandwort is poorly understood, and is one of twenty species in the genus Arenaria that occurs 

throughout the US. The species aberrans only occurs in Arizona. It occurs in rocky habitats of ridges and canyon 

rims, mainly in oak and pine forests but also found in pinyon and junipers. It ranges from 5,500-9,000’ on south, 

north and northeast facing aspects. It grows on basaltic soil in Yavapai County, and sandy soil in north Coconino 

County. No known sites on Forest, but may occur on the Forest’s rocky ridges and canyon rims. There are no 

known limiting factors/threats besides being a rare plant.

Existing Condition for Mt. Dellenbaugh sandwort. There are no known populations of Mt. Dellenbaugh 

sandwort within or near the project area boundary, but suitable habitat may exist. 

Alternatives 2-4 

Direct and Indirect Effects for Sensitive Species 

Direct effects from the action alternatives would include loss of individual plants or population groups through 

management actions. Factors contributing to these effects would include disturbance from management actions 

such as activities associated with tree removal, prescribed burning, road reconstruction, maintenance and 

decommissioning, temporary road construction and obliteration.

Mechanical Treatments. Mechanical treatments would provide structural diversity to promote suitable habitat for 

a host of understory species with differing resource requirements (e.g., shade-tolerant vs. shade-intolerant), and 

may increase the abundance of rare plant species. Although little is known about the ecology of the rare plant 

species specific to this project, it is thought that Mt. Dellenbaugh sandwort and Rusby’s milkvetch prefer forest 

openings; therefore it would be expected that reductions in tree densities would favor these species. Laughlin et 

al. (2008) showed that Rusby’s milkvetch increased in frequency following thinning treatments. Given that 

mechanical treatments would provide structural diversity at the project scale, treatments may increase Flagstaff 

beardtongue abundance and distribution at the project scale. 

Thinning could increase the amount of sunlight and could increase photosynthesis for some populations of 

Arizona leather flower and Flagstaff Beardtongue. Changes in the amount of sunlight available for plants could 

have positive or negative effects to sensitive species depending on the amount of change produced by 
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244 Chapter 3. Affected Environment and Environmental Consequences

management actions. High levels of light may lead to increased vegetative growth, but lower reproduction and 

seedling survival (Maschinski et al, 1997). These effects will be mitigated by retaining shade around Arizona 

leather flower populations. Surveys to locate plants will be necessary, as will such measures as avoidance 

containing Arizona leather flower (see mitigation measure and design features12 and 17). 

The overall effects of mechanical treatments on rare plant species would be positive with the implementation of 

the mitigations described above. Helicopters to remove material would result in the least amount of disturbance, 

followed by ground based conventional thinning methods. With the implementation of the mitigation measures, 

the operational effects of helicopter and ground based logging are not likely to have long-term negative effects on 

rare plant species due to the limited level of disturbance associated with such.

Mechanical treatments may affect sensitive plant species individuals, but is not likely to contribute to a trend 

toward federal listing or a loss of species viability because of their relatively limited occurrence or absence within 

the project area and the implementation of the stated mitigation measures.

Strategic Fuels Treatments. Strategic Fuels Treatments would occur under Alternative 2 using ground based 

logging methods and hand felling. These treatments would be consistent with the mitigation measures described 

above; therefore the treatments are not expected to negatively affect rare plant species viability. The effects of 

ground based logging operations are described above.

Strategic fuels may affect sensitive plant species individuals, but is not likely to contribute to a trend toward 

federal listing or a loss of species viability because of their relatively limited occurrence or absence within the 

project area and the implementation of the stated mitigation measures.

Prescribed Fire. Given that these species evolved in a fire-adapted ecosystem, it is unlikely that prescribed fire of 

low to moderate intensities would negatively affect species viability. Both Flagstaff beardtongue and Rusby’s 

milkvetch have shown positive responses to fire (USDA 2007, Laughlin et al. 2008). Laughlin et al. (2008) 

showed that Rusby’s milkvetch showed an increase in frequency following prescribed fire. 

Burning could reduce the amount of litter present in populations of Arizona leather flower. The presence of litter 

is important for Arizona leather flower. Deep litter may negatively affect the plants, but removal of all litter from 

the site would have adverse effects on juvenile plants, which need some litter to retain moisture around them. 

These effects would be mitigated by burning under conditions that would reduce the litter layer without removing 

it entirely (see mitigation measures and design features #17).

Short-term effects of burning include mortality of individual plants. Long-term effects include the loss of shade 

from tree mortality or reduction in the amount of litter that would be detrimental to juvenile plants. This would be 

mitigated by managing burning at intensities in all entries low enough to limit mortality to trees and preserve a 

light layer of litter. The knowledge of fire effects on Arizona leather flower are based largely on observations on a 

local prescribed fire within the Bald Mesa Project on the Mogollon Rim Ranger District of the Coconino NF 

(2005) where mitigations such as raking and not igniting directly within the plant groups were used. These 

mitigations were sufficient to preserve adult plants and conserve the habitat needed for juvenile plants.

No data were found in published research specifically related to the effects of fire on Arizona leather flower. 

Plants in the genus Clematis regenerate through underground rhizomes as well as through seeds, including 

Arizona leather flower (Pringle 1997). The insulating properties of soil would protect Arizona leather flower 

plants and would allow them to survive low intensity fire through protection of below ground structures (Pyke et 

al, 2010). Higher severity fires with long residence time would lead to lethal temperatures in underground 

structures, causing mortality to individuals and populations. The effects of burning on Arizona phlox are 

undocumented (Baker, 2010).

In a study on the short-term effects of burning in savannas, a perennial tap-rooted phlox; Phlox pilosa showed 

delayed flowering in response to early season burning (Pavlovic et al., 2011) but it is unknown if Arizona phlox 

would exhibit a similar response. Another perennial, tap-rooted species (Phlox hoodii) is an early seral species but 
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Chapter 3. Affected Environment and Environmental Consequences 245

abundance may be reduced in the early post fire community (Gucker, 2006). Based on these data, there may be 

some initial reductions in the abundance of Arizona phlox in the units scheduled for burning but long term 

negative effects are not anticipated.

Prescribed fire has the potential to expand the current abundance and distribution of rare plant species by 

enhancing structural (e.g., variable shading) and functional (e.g., nutrient flow) ecosystem properties. Further, it is 

not reasonable to expect infinite fire exclusion on Bill Williams Mountain. This area will experience fire at some 

point in time, and prescribed fire would provide the greatest opportunity to protect rare plant species habitat when 

compared to a high-intensity wildfire.

Prescribed fire may affect sensitive species individuals, but is not likely to contribute to a trend toward federal 

listing or a loss of species viability because of their relatively limited occurrence or absence within the project 

area and the implementation of the stated mitigation measures. 

Transportation and Trails. Road construction and trails may cause habitat loss for rare plant species. However, 

the land area that would be converted to roads and trails is minimal, and would not result in significant habitat 

loss for any particular species or threaten species viability. The design criteria for roads and trails would minimize 

negative impacts to rare plant species (see above mitigations). Roads and trails also provide opportunities for the 

establishment and spread of invasive plants. However, invasive plant mitigations would protect rare plant 

populations from the adverse effects associated with invasions (see Invasive Weeds Specialist Report for 

mitigation measures).

Direct and indirect effects of temporary road construction, road maintenance, road reconstruction or 

decommissioning include destruction of individual plants, localized disturbance of suitable habitat and the 

potential introduction of noxious or invasive weeds. These effects would be mitigated by surveying the areas 

where activities would occur as well as nearby areas that may be disturbed and avoiding existing plant 

populations when found. 

Road construction and trails may affect sensitive plant species individuals, but is not likely to contribute to a trend 

toward federal listing or a loss of species viability because of their relatively limited occurrence or absence within 

the project area, and the implementation of the stated mitigation measures.

Determination of Effects for Alternatives 1-4 for Sensitive Species

Alternative 1, No Action. The No Action Alternative would not affect sensitive plant species. 

Alternatives 2-4. Direct and indirect effects include the alteration of habitat, which would be more long term. 

These effects would be mitigated by following the mitigation measures for sensitive plants mentioned above.

An indirect effect of management actions within the potential habitat of Arizona leather flower includes an 

increased risk of invasion from noxious or invasive weeds. These effects would be mitigated by incorporating the 

Best Management Practices described in Appendix B of Final Environmental Impact Statement for the Integrated 

Treatment of Noxious or Invasive Weeds, Coconino, Kaibab and Prescott National Forests (2005). Incorporation 

of the Best Management Practices would mitigate the effects of increased disturbance from management 

activities, and help to control the spread and introduction of weeds within the habitat of Rusby milkvetch. 

The action alternatives may affect individuals but will not cause a trend toward federal listing or loss of viability 

for these species because of the implementation of the mitigation measures that have been designed to protect the 

important habitat components that provide the unique microenvironment for plant species of conservation 

concern. Because the action alternatives provide the greatest opportunity for plant species of conservation concern 

habitat enhancement, these alternatives would not contribute to trends toward federal listing and a loss of species 

and population viability.
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246 Chapter 3. Affected Environment and Environmental Consequences

Cumulative Effects

The time limit for this discussion includes past actions since Rusby’s milkvetch was added to the Regional 

Forester’s list in 1999. Many past actions such as grazing, fire suppression, wildfires, timber activities and 

recreation have occurred within the range of Rusby’s milkvetch and have contributed to the current existing 

condition. Additionally, because of its unique appearance, the Arizona leather flower is occasionally collected and 

removed from the Forest for use as a landscaping plant. 

Ongoing and Future Foreseeable Actions for Sensitive Species. Management actions are ongoing within the 

habitat of these sensitive species. Some items in the cumulative effects document (Appendix D of FEIS) also 

apply. 

The Kaibab National Forest implemented the Travel Management Rule in 2012. The cumulative effects to this and 

other species are the reduction in the numbers of motorized routes and the elimination of cross-country travel. 

Negative effects from motorized vehicles such as crushing of plants, damage to potential habitat such damage to 

soils, fragmentation of habitat and introduction of noxious or invasive weeds into the habitats and/or populations 

have been reduced. These reductions would be from the elimination of cross-country travel and through the 

reduction of road density. These actions, combined with such actions as road obliteration and decommissioning in 

this project would reduce the impacts of vehicle traffic in the habitat of sensitive plant species.

The project includes new trail construction. This trail could affect sensitive plant species through impacts to 

individuals, but the project would also mitigate the effects to the species. 

Other actions such as grazing and wildfires would continue to occur in the range of these sensitive species and 

continue to affect it. None of these actions would lead to a trend toward federal listing. Refer to the cumulative 

effects document on file for further discussion on these and other actions in the project area. 

Climate change could affect the distribution of vegetation in general by affecting biotic and abiotic factors and by 

increasing the extent and severity of disturbances (USDA Forest Service 2010). Rare and sensitive species may be 

especially vulnerable because they often need specific habitat components such as specialized soil types that are 

not widely available. This could negatively affect their abilities to migrate to suitable areas as environmental 

conditions change. 

Water availability may decrease in some areas while temperatures generally increase. Alpine habitats may 

disappear entirely as elevational vegetation shifts occur (USDA Forest Service, 2010). Future plant distributions 

in general may be governed by several factors including human influences, abilities of plants to disperse, and the 

presence of suitable habitat components including such factors as suitable soil types (McKenney et al, 2007). 

Large changes in ecosystem structure and species composition of plant communities are expected due to 

increasing temperatures and altered precipitation cycles (USDA Forest Service, 2010).

Species have responded to climate change throughout their evolutionary history, but not at rates seen in recent 

climate change (Root et al, 2003). Phenology shifts in vegetation communities in large regions have been noted. 

These include shifts in the beginning, ending and length of growing seasons in temperate regions of the northern 

hemisphere. The results have been earlier emergence and blooming of flowering plants, extended end of season 

and longer growing seasons. Changes in growing season may affect climate by affecting surface radiation, 

temperature, hydrology and carbon cycling (Jeong et al, 2011). Trophic mismatches have been documented for 

several species (Parmesan, 2006) leading to disruption of symbiotic relationships and plant/animal interactions. In 

a review of many studies on climate change, Root et al, 2003 determined that “the balance of evidence for these 

studies strongly suggests that a significant impact to global warming is already discernible in animal and plant 

populations”. 

Climate change coupled with other factors such as habitat loss could lead to extirpations and increased risks of 

extinction. Species generally respond to rapid climate change at differential rates. These differential movements 

may lead to loss of connectedness and loss of communities (Root et al, 2003). While the actions of this project 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 247

would not mitigate widespread climate change, actions would help our local vegetative communities be more 

resilient, restore natural fire regimes and reduce the risk of habitat loss due to uncontrolled wildfire. 

Determination of Effects for Sensitive Species

The Bill Williams Mountain Restoration project may impact individuals of Rusby milkvetch Astragalus rusbyi, 

Arizona leather flower Clematis hirsutissima, Flagstaff beardtongue Penstemon nudiflorus, Arizona phlox 

amabilis, Cliff fleabane Erigeron saxatilis, and Mt Dellenbaugh sandwort Arenaria aberrans but is not likely to 

result in a trend toward federal listing or loss of viability.

Rare and Endemic Plants

The following plants are from the Rare and Endemic Species list and are found within the project area or habitat 

for this species exists within the project area.

Note: this section was added to the analysis after the completion of the DEIS. The forest plan provides direction 

for management of rare and endemic species.

Existing Condition

To determine whether the species was in any of the areas to be treated in the current analysis area, we used the 

rare and endemic plant lists in the forest planning documents above, and then searched the Southwest 

Environmental Information Network (SEINet) database for locations by county using Yavapai and Coconino 

counties for the basis of our search. Counties were used because there is not a method for searching by forest in 

the database. If the species was present in the county, data were exported to GIS and intersected with the latest 

treatment layer for the 4FRI analysis. Known occurrences and brief narratives for each species are included 

below. 

MacDougall’s bluebells (Mertensia macdougalii) 

MacDougall’s bluebells is endemic to Arizona where it grows in montane willow riparian forest and ponderosa 

pine. It grows in a variety of substrates, including sandstone cobble, clay loam, sand and duff. It occurs at 

elevations between 6,000 and 9,000 feet. Known sites on the Kaibab National Forest include Bill Williams 

Mountain and on the south and north rims of Grand Canyon. Limiting factors and threats to this plant include: its 

rarity, an important potential threat includes exposure to high intensity fires resulting from an interruption of 

natural fire regimes. Other potential threats include disturbance of soils due to vegetation treatments, grazing and 

recreation, and competition from invasive species. Loss of habitat due to development is a significant threat.

Existing Condition for MacDougall’s bluebells. There are known populations of MacDougall’s bluebells within 

the project area boundary. 

Black Dropseed (Sporobolus interruptus) 

Black dropseed is endemic to central Arizona where it grows on rocky slopes and in dry meadows of open 

ponderosa pine and oak-pine forests and pinyon-juniper woodlands at 5,000 to 7,500 feet in volcanic-derived 

soils. This species tends to be abundant in its narrow range. It is known on Tusayan and Williams Districts of the 

Kaibab National Forest and throughout the Coconino National Forest. Limiting factors and threats include: its 

rarity, uncharacteristic fire, non-native plants, tree harvesting, grazing, and recreation. 

Existing Condition for black dropseed. There are known populations of black dropseed within the project area 

boundary. 

Alternative 1, No Action

The No Action Alternative would not affect sensitive plant species. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

248 Chapter 3. Affected Environment and Environmental Consequences

Alternatives 2-4 

This analysis addresses all action alternatives. Treatments in any specific unit containing these rare and endemic 

species may vary by alternative but the general effects of management actions are the same for all alternatives.

Direct and Indirect Effects for rare and endemic species

Direct effects from the action alternatives would include loss of individual plants or population groups through 

management actions. Factors contributing to these effects would include disturbance from management actions 

such as activities associated with tree removal, prescribed burning, road reconstruction, maintenance and 

decommissioning, temporary road construction and obliteration. 

Mechanical Treatments. Mechanical treatments would provide structural diversity to promote suitable habitat for 

a host of understory species with differing resource requirements (e.g., shade-tolerant vs. shade-intolerant), and 

may increase the abundance of rare plant species. Although little is known about the ecology of the rare plant 

species specific to this project, it is thought that MacDougall’s bluebells and black dropseed prefer forest openings 

or areas where tree canopies are not dense; therefore it would be expected that reductions in tree densities would 

favor these species. Given that mechanical treatments would provide structural diversity at the project scale, 

treatments may increase both species abundance and distribution at the project scale.

Thinning could increase the amount of sunlight and could increase photosynthesis for some populations of 

MacDougall’s bluebells and black dropseed. Changes in the amount of sunlight available for plants could have 

positive or negative effects to sensitive species depending on the amount of change produced by management 

actions. High levels of light may lead to increased vegetative growth, but lower reproduction and seedling 

survival (Maschinski et al, 1997). 

The overall effects of mechanical treatments on rare plant species would be positive with the implementation of 

the mitigations described above. Helicopters to remove material would result in the least amount of disturbance, 

followed by ground based conventional thinning methods. With the implementation of the mitigation measures, 

the operational effects of helicopter and ground based logging are not likely to have long-term negative effects on 

rare plant species due to the limited level of disturbance associated with such.

Mechanical treatments would have no measureable negative impact to the population of MacDougall’s bluebells 

Mertensia macdougalii or black dropseed Sporobolus interrupt. It may affect individuals of plants but not affect 

the population and would improve the population of these plants by opening up the tree canopy and reducing the 

potential for high severity fire.

Strategic Fuels Treatments. Strategic Fuels Treatments would occur under Alternative 2 using ground based 

logging methods and hand felling. These treatments would be consistent with the mitigation measures described 

above; therefore the treatments are not expected to negatively affect rare plant species viability. The effects of 

ground based logging operations are described above. 

Strategic fuels would have no measureable negative impact to the population of MacDougall’s bluebells 

Mertensia macdougalii or black dropseed Sporobolus interrupt. It may affect individuals of plants but not affect 

the population and would improve the population of these plants by opening up the tree canopy and reducing the 

potential for high severity fire.

Prescribed Fire. Given that these species evolved in a fire-adapted ecosystem, it is unlikely that prescribed fire of 

low to moderate intensities would negatively affect species viability. Fire effects are unknown for MacDougall’s 

bluebells but the species is likely to respond similarly to those for Flagstaff beardtongue and Rusby’s milkvetch. 

Both these plants have shown positive responses to fire (USDA 2007, Laughlin et al. 2008). Laughlin et al. (2008) 

showed that Rusby’s milkvetch showed an increase in frequency following prescribed fire. Black dropseed like 

most all grasses would be affected positively by fire. 

Short-term effects of burning include mortality of individual plants. Long-term effects include the loss of shade 

from tree mortality or reduction in the amount of litter that would be detrimental to juvenile plants. This would be 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 249

mitigated by managing burning at intensities in all entries low enough to limit mortality to trees and preserve a 

light layer of litter. 

Prescribed fire has the potential to expand the current abundance and distribution of rare plant species by 

enhancing structural (e.g., variable shading) and functional (e.g., nutrient flow) ecosystem properties. Further, it is 

not reasonable to expect infinite fire exclusion on Bill Williams Mountain. This area will experience fire at some

point in time, and prescribed fire would provide the greatest opportunity to protect rare plant species habitat when 

compared to a high-intensity wildfire.

Prescribed fire would have no measureable negative impact to the population of MacDougall’s bluebells 

Mertensia macdougalii or black dropseed Sporobolus interrupt. It may affect individuals of plants but not affect 

the population and would improve the population of these plants by opening up the tree canopy and reducing the 

potential for high severity fire.

Transportation and Trails. Road construction and trails may cause habitat loss for rare plant species. However, 

the land area that would be converted to roads and trails is minimal, and would not result in significant habitat 

loss for any particular species or threaten species viability. The design criteria for roads and trails would minimize 

negative impacts to rare plant species (see above mitigations). Roads and trails also provide opportunities for the 

establishment and spread of invasive plants. However, invasive plant mitigations would protect rare plant 

populations from the adverse effects associated with invasions.

Direct and indirect effects of temporary road construction, road maintenance, road reconstruction or 

decommissioning include destruction of individual plants, localized disturbance of suitable habitat and the 

potential introduction of noxious or invasive weeds. These effects would be mitigated by surveying the areas 

where activities would occur as well as nearby areas that may be disturbed and avoiding existing plant 

populations when found. 

Road construction and trails may affect individuals of rare or endemic plant species, but it will have no 

measurable negative impact on the population because of their limited occurrences within the project area, and the 

implementation of mitigation measures listed above that are designed to protect known and newly discovered 

populations. 

Determination of Effects for Alternatives 1-4 for rare and endemic species

Alternative 1, No Action. The No Action Alternative would not affect rare and endemic species. 

Alternatives 2-4. Indirect effects include the alteration of habitat, which would be more long term. These effects 

would be mitigated by following the mitigation measures for rare plants mentioned above. 

An indirect effect of management actions within the potential habitat of MacDougall’s bluebells or black dropseed 

includes an increased risk of invasion from noxious or invasive weeds. These effects would be mitigated by 

incorporating the Best Management Practices described in Appendix B of Final Environmental Impact Statement 

for the Integrated Treatment of Noxious or Invasive Weeds, Coconino, Kaibab and Prescott National Forests 

(2005). Incorporation of the Best Management Practices would mitigate the effects of increased disturbance from 

management activities, and help to control the spread and introduction of weeds within the habitat of these plants. 

The action alternatives may affect individuals of rare or endemic plant species, but they would have no 

measurable negative impact on the population because of their limited occurrences within the project area, and the 

implementation of mitigation measures listed above that are designed to protect known and newly discovered 

populations. Because the action alternatives provide the greatest opportunity for plant species of conservation 

concern habitat enhancement, these alternatives would not contribute to a loss of population viability for these 

species.
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250 Chapter 3. Affected Environment and Environmental Consequences

3.9.4 Cumulative Effects

Ongoing and Future Foreseeable Actions for Rare and Endemic Species

Management actions are ongoing within the habitat of these rare and endemic species. Some items in the 

cumulative effects document also apply.

The Kaibab National Forest implemented the Travel Management Rule in 2012. The cumulative effects to this and 

other species are the reduction in the numbers of motorized routes and the elimination of cross-country travel. 

Negative effects from motorized vehicles such as crushing of plants, damage to potential habitat such damage to 

soils, fragmentation of habitat and introduction of noxious or invasive weeds into the habitats and/or populations 

have been reduced. These reductions would be from the elimination of cross-country travel and through the 

reduction of road density. These actions, combined with such actions as road obliteration and decommissioning in 

this project would reduce the impacts of vehicle traffic in the habitat of these plants.

The project includes new trail construction, and could affect sensitive plant species through impacts to 

individuals, but the project may also mitigate the effects to the species. 

Climate change could affect the distribution of vegetation in general by affecting biotic and abiotic factors and by 

increasing the extent and severity of disturbances (USDA Forest Service 2010). Rare and sensitive species may be 

especially vulnerable because they often need specific habitat components such as specialized soil types that are 

not widely available. This could negatively affect their abilities to migrate to suitable areas as environmental 

conditions change. Water availability may decrease in some areas while temperatures generally increase. Alpine 

habitats may disappear entirely as elevational vegetation shifts occur (USDA Forest Service, 2010). Future plant 

distributions in general may be governed by several factors including human influences, abilities of plants to 

disperse, and the presence of suitable habitat components including such factors as suitable soil types (McKenney 

et al, 2007). 

Large changes in ecosystem structure and species composition of plant communities are expected due to 

increasing temperatures and altered precipitation cycles (USDA Forest Service, 2010). Species have responded to 

climate change throughout their evolutionary history, but not at rates seen in recent climate change (Root et al, 

2003). Phenology shifts in vegetation communities in large regions have been noted. These include shifts in the 

beginning, ending and length of growing seasons in temperate regions of the northern hemisphere. The results 

have been earlier emergence and blooming of flowering plants, extended end of season and longer growing 

seasons.

Changes in growing season may affect climate by affecting surface radiation, temperature, hydrology and carbon 

cycling (Jeong et al, 2011). Trophic mismatches have been documented for several species (Parmesan, 2006) 

leading to disruption on symbiotic relationships and plant/animal interactions. In a review of many studies on 

climate change, Root et al, 2003 determined that “the balance of evidence for these studies strongly suggests that 

a significant impact to global warming is already discernible in animal and plant populations”. Climate change 

coupled with other factors such as habitat loss could lead to extirpations and increased risks of extinction. Species 

generally respond to rapid climate change at differential rates. These differential movements may lead to loss of 

connectedness and loss of communities (Root et al, 2003). While the actions of this project will not mitigate 

widespread climate change, actions will provide more resiliency to our local vegetative communities, restore 

natural fire regimes and reduce the risk of habitat loss due to uncontrolled wildfire.

Determination of Effects for rare and endemic species

The Bill Williams Mountain Restoration project may affect individuals of rare or endemic plant species, but it 

would have no measurable negative impact on the population because of their limited occurrences within the 

project area, and/or the implementation of mitigation measures listed above that are designed to protect known 

and newly discovered populations. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 251

3.10 Rangeland Resources 

3.10.1 Affected Environment 

The scope of this analysis focuses on the understory plant communities that occur within the proposed project 

perimeter, as well as the effect that the project may have on grazing activities within the proposed project 

perimeter. 

Understory Plant Community

Plant communities in the western United States have been dramatically altered by fire exclusion, overgrazing by 

livestock, and selective timber harvesting; all of which have combined to form highly dense and unhealthy 

forests. Increases in density in ponderosa pine forests have resulted in a significant loss of the herbaceous 

understory (understory, hereafter) due to alterations in resource allocation within the stand, which can adversely 

affect both structural and functional properties of a forest. Ecological restoration can be applied to convert highdensity ponderosa pine forests to an open canopy structure similar to that found at the time of Euro-American 

settlement (Moore et al. 2006), and reestablish historical structural and functional ecosystem properties. Forest 

thinning and prescribed burning are often proposed and implemented to reverse the undesirable changes in 

ponderosa pine forests of Arizona (Abella 2004). 

Forest thinning and prescribed burning can make resources (e.g., light, nutrients, water) more readily available for 

understory plant species by reducing overstory competition and enhancing nutrient cycling. Increasing resource 

availability can provide the herbaceous component of a plant community the opportunity to capitalize, which can 

result in increased species abundance, vigor, and productivity; and potentially enhance species diversity. Diverse 

and abundant understory plant communities provide soil stability, enhanced habitat and forage for wildlife, forage 

for livestock, and increases resistance against non-native plant invasions. 

The Bill Williams Mountain Restoration Project area contains several cover types that range from Douglas fir and 

aspen at the upper range of elevations to grasslands at the lower range of elevations. Because of the lack of data 

documenting the understory plant community component in the project area, it is difficult to provide a site 

specific assessment of its existing condition. However, we can make some assumptions based on studies 

conducted in northern Arizona forests. 

Laughlin et al. (2011) found that ponderosa pine basal area increased from an average of 4m2/ha in the early 

1900s to 29 m2/ha in 2007, which resulted in a decline of understory plant foliar cover by 21%, species richness 

by 2 species/m2, and declines in functional richness. Bakker and Moore (2007) found that species density 

declined by 34%, herbaceous plant density by 37%, shrub cover by 69%, total herbaceous cover by 59%, 

graminoid cover by 39%, and forb cover by 82% between 1941 and 2004, and that these changes were negatively 

correlated with overstory vegetation. Arnold (1950) noted a 25% reduction in grass density in ponderosa pine 

stands near Flagstaff, Arizona between 1912 and 1947 due to establishment and growth of ponderosa pine trees. 

Covington and Moore (1994) projected similar trends using a simulation model that showed herbage production 

(lbs./ac) may have declined approximately 84 % in an untreated ponderosa pine forest between 1907 and 1947. 

Repeat photography that was conducted in 2011 specific to the Bill Williams Mountain Restoration Project and 

for the Hat Grazing Allotment Environmental Assessment (USDA 2009), which is partially included within the 

Bill Williams Mountain Restoration Project boundary, indicates that both ponderosa pine and juniper species have 

increased within the project area. Therefore, it is appropriate to assume that the trends described above continue 

today in areas where tree encroachment and canopy closure continues to occur in northern Arizona forests, and 

that understory species are more competitively stressed than they were under pre-settlement conditions and are 

likely declining due to their inability to rapidly adapt to an altered environment (Laughlin et al. 2011). 

Grazing Management

Figure 3-54 shows 9,444 acres (approximately 9 percent of the allotment) of the project area are within the 

105,049 acre Hat Grazing Allotment which allows grazing by up to 4,160 ewes from May 1-October 31 and 140 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

252 Chapter 3. Affected Environment and Environmental Consequences

rams from June 1-July 15 that run in a minimum of two bands rotating throughout the allotment. The grazing 

management system incorporates seasonal deferment, with an emphasis on spring deferment from May 1 to June 

15, which minimizes the number of areas used during this time period to promote cool season plant development. 

As with the loss of much of the understory, forage species are also on the decline as a result of management 

activities. Because of past overgrazing, increasing tree densities, and unfavorable climatic conditions, livestock 

numbers have been cut significantly on the Hat Allotment from approximately 21,000 animal unit months in 1945 

to the current figure of approximately 5,000 animal unit months. Although increasing livestock numbers is not an 

anticipated result of the restoration treatments associated with this project due to climatic uncertainty, we can 

expect improved forage conditions for both livestock and wildlife in addition to improved watershed stability. 

Figure 3-54. The Hat Grazing Allotment and the Project Boundary
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Chapter 3. Affected Environment and Environmental Consequences 253

3.10.2 Direct and Indirect Effects

Alternative 1 – No Action

Current management would result in a continuance of understory plant community habitat degradation. Trees 

would continue to increase in both density and size which would lead to more intense competition for understory 

plant species. More intense competition would result in lower levels of species abundance, productivity, and 

vigor, and potentially reductions in species richness. Competition in ponderosa pine forests can also result in 

understory plant community conversions that are dominated by shade- and stress-tolerant species (Laughlin et al. 

2011). In addition, there is an extreme risk of uncharacteristic wildfire within the project area under the No Action 

Alternative. Severe wildfire in the project area may result in unprecedented levels of habitat loss for understory 

plant communities, and perhaps complete conversions of habitat types. Further, areas burned at high-severity may 

experience some level of reduction in site productivity, especially those with slope related erosion hazards 

(Bormann et al. 2008). Such losses can result in habitat loss for rare plant species, as well as their associates. 

Severe wildfire may also result in extensive non-native plant invasions that would further reduce the habitat 

quality for rare plant species.

At the present time, the grazing allotments are appropriately stocked for the average annual forage production. 

However, the understory plant community within the project area would continue to decline as competition 

becomes increasingly more intense due to the canopy closure. Grazing management would be in accordance with 

Allotment Management Plans until resources become limited to the point that available forage is reduced to a 

level where higher forage utilization occurs, at which time livestock numbers would be reduced.

Effects Common to All Action Alternatives

All Action Alternatives considered may ultimately result in similar understory plant responses. Ecological 

restoration can be applied to convert high-density ponderosa pine forests to an open canopy structure similar to 

that found at the time of Euro-American settlement (Moore et al. 2006), potentially reestablishing understory 

properties to near pre-settlement conditions (Stoddard et al. 2011). Forest thinning and prescribed burning are 

often proposed and implemented to reverse the undesirable changes in ponderosa pine forests in Arizona (Abella 

2004). Forest thinning and prescribed burning can make resources (e.g., light, nutrients, and water) more readily 

available for understory plant species. Increasing resource availability can provide the herbaceous component of a 

plant community the opportunity to capitalize, which can result in increased species abundance, vigor, and 

productivity, and potentially enhance species richness (Griffis et al. 2001, Abella 2004, Moore et al. 2006, 

Laughlin et al. 2008, Stoddard 2011). The proposed restoration treatments would provide structural diversity to 

promote suitable habitat for a host of understory species with differing resource requirements (e.g., shade-tolerant 

vs. shade-intolerant), and would have potential increase the abundance of rare plant species. 

Comparisons in anticipated forage production increases for each management action is difficult to estimate, as 

specific forage production may be influenced by factors including soil type and condition, slope, moisture, and 

available propagules. It is appropriate to assume that tree removal and prescribed burning would improve both 

forage quantity and quality. 

Soil disturbances associated with these projects may recruit/expand invasive plant species populations that 

degrade understory habitat quality. Livestock grazing after burning can influence invasive species establishment, 

persistence, and spread, but this interaction is poorly understood (Zouhar et al. 2008). The dispersal of invasive 

species propagules while stressing more palatable native species deserves consideration. Burned areas are usually 

rested from grazing until native plants have successfully established, thus no adverse effects are expected from 

grazing following prescribed burning. Once livestock are allowed to graze the burned area, the Forest Service 

monitors their effects and applies adaptive management when warranted. Best management practices and 

mitigation measures are implemented at project sites to reduce the introduction and spread of weed species.
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254 Chapter 3. Affected Environment and Environmental Consequences

Alternative 2 – Modified Proposed Action

Alternative 2 would remove the highest number trees of all Action Alternatives, and would likely result in the 

greatest understory improvement (i.e., enhanced abundance, vigor, productivity). More importantly, Alternative 2 

would result in the greatest reduction in the risk of severe wildfire, which would provide the greatest safeguard 

against the undesirable effects that are associated with such. Severe wildfires on Bill Williams Mountain may 

result in irreversible effects to understory plant communities due to the erosion hazard on steeper slopes that may 

result in the loss of site productivity.

Mechanical Treatments. Ground-based logging operations would have minimal temporary impacts to the 

understory plant community with the implementation of Best Management Practices. 

Helicopter logging operations would have minimal temporary impacts to the understory plant community with the 

implementation of Best Management Practices.

Strategic Fuels Treatments. Strategic Fuels Treatments would consist of heavy thinning in areas identified by 

Fuels Specialists. These treatments would improve the understory plant community with the implementation of 

Best Management Practices while reducing the risk of large-scale severe wildfire.

Transportation and Trails. Alternative 2 includes the construction of 15 miles of new roads, 16 miles of 

temporary roads, and 1 mile of new trail. Although the direct loss of plant species habitat may be not be 

significant at this scale, roads and trails act as dispersal corridors for non-native invasive species. Invasive species 

can negatively affect the native understory through direct competition and degraded habitat quality. 

Implementation of Best Management Practices described in the Soils and Watershed section above (Design 

Features, Best Management Practices, and Mitigation Measures) in the Final Environmental Impact Statement for 

Integrated Treatment of Noxious or Invasive Weeds on the Coconino, Kaibab, and Prescott National Forests 

within Coconino, Gila, Mojave, and Yavapai Counties, Arizona (2004) would assist in the protection of habitat 

quality from non-native invasives within the project area. Alternative 2 also includes 28 miles of road obliteration, 

which would improve understory conditions by limiting invasive species expansion and restoring roadbeds to 

native vegetation.

Alternative 3

Alternative 3 would remove fewer trees than Alternatives 2 due to diameter caps that restrict the size of trees that 

can be removed. Alternative 3 would limit harvested trees to less than 16”. This Alternative may have a similar or 

a slightly less improved understory response when compared to Alternative 2. Alternative 3 would result in less of 

a reduction in the risk of severe wildfire compared to Alternative 2, which would provide less of a safeguard 

against the undesirable effects that are associated with such. Severe wildfires on Bill Williams Mountain may 

result in irreversible effects to understory plant communities due to the erosion hazard on steeper slopes that may 

result in the loss of site productivity.

The effects of mechanical treatments, strategic fuels treatments, and transportation and trails are similar to 

Alternative 2; therefore not described in detail.

Alternative 4

Alternative 4 would remove the fewest number of trees of all Action Alternatives due to diameter caps that restrict 

the size of trees that can be removed and the exclusion of helicopter logging. Similar to Alternative 3, Alternative 

4 would limit harvested trees to less than 16”. Alternative 4 would likely result in the least improved (i.e., 

enhanced abundance, vigor, productivity) understory of all Action Alternatives. Understory plant communities in 

areas identified helicopter logging would continue to degrade as tree densities and size increase. Alternative 4 

would reduce the risk of severe wildfire the least when compared to all other Action Alternatives, which would 

provide the lowest level of safeguard against the undesirable effects that associated with such. Severe wildfires on 

Bill Williams Mountain may result in irreversible effects to understory plant communities due to the erosion 

hazard on steeper slopes that may result in the loss of site productivity. 
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Chapter 3. Affected Environment and Environmental Consequences 255

Mechanical Treatments. Ground-based logging operations would have minimal temporary impacts to the 

understory plant community with the implementation of Best Management Practices.

The exclusion of helicopter logging operations may also restrict the establishment of non-native species to 

accessible terrain. Understory plant communities in untreated areas would continue to decline due to increasing 

tree densities and size. Untreated areas would also be at high risk for severe wildfire that would likely result in 

undesirable effects to site understory potential where erosion hazards are high. Understory habitat type 

conversions may occur following severe erosion. 

Strategic Fuels Treatments. Strategic Fuels Treatments would consist of heavy thinning in areas identified by 

Fuels Specialists. These treatments would improve the understory plant community with the implementation of 

Best Management Practices while reducing the risk of large-scale severe wildfire.

Transportation and Trails. Alternative 4 excludes the construction of 23 miles of new roads, which would 

reduce invasive species expansion. The effects of temporary roads and road obliteration are similar for all Action 

Alternatives. 

3.10.3 Cumulative Effects

Range (No Action Alternative). The cumulative effects boundary is the Hat Allotment and the timeframe is 10 

years into the future, which is the life of a Term Grazing Permit before it is renewed. Cumulatively, there would 

be no disruption in livestock grazing within the Hat Allotment as there would not be any prescribed fire activities 

and thinning. Within the No Action Alternative, risk of uncharacteristic, high intensity wildfire that could result 

in damage to rangelands would exist due to no vegetation treatments. 

Based on the management, it is predicted that the physiological growth requirements of the forage plants would 

not be favored within the project area. Therefore, areas on the allotment could potentially decrease in desirable 

forage plant densities and plant residues. Additionally, there would be a decrease in plant species composition 

and vigor of forage plants. Livestock distribution within the five pastures would not improve, thus adhering to a 

more moderate to heavy utilization level. 

The No Action Alternative is tiered to not moving towards and/or meeting specific desired conditions and is in 

alignment with the Kaibab National Forest Plan. The lack of treatments would not provide benefits needed to a 

variety of resources including forest health conditions, grassland conditions, watershed conditions, water quality, 

and wildlife habitats. Potential long-term negative impacts to rangeland resources and/or allotment management 

activities may occur.

Range (Common to All Action Alternatives). The cumulative effects boundary is the Hat Allotment and the 

timeframe is 10 years into the future, which is the life of a term grazing permit before it is renewed. 

Cumulatively, prescribed burning would disrupt livestock grazing in the North / South Snyder, North Coleman, 

Sevier, Dutch Kid, and Hells Burn Trap Pastures within the Hat Allotment during and following prescribed fire 

activities. Livestock would not be able to graze in the treatment area during the burn, and sufficient forage 

regeneration would need to occur prior to restoring grazing to the project area. Coordination of pasture rotation 

schedules will be required to ensure that the permittee is not negatively impacted or lose grazing opportunities. 

Range infrastructure may be impacted by prescribed burning activities; however design criteria to pretreat range 

developments will be included in this project, thus minimizing effects. Access to transportation routes within the 

two pastures may be limited during both thinning and burning activities; however this effect will be short-lived 

once implementation is completed. Proposed vegetation treatments are intended to reduce the risk of 

uncharacteristic, high intensity wildfire that could result in damage to rangelands.

Based on the management, it is predicted that the physiological growth requirements of the forage plants would 

be favored within the project area. Therefore, areas on the allotment will increase in desirable forage plant 

densities and plant residues. Additionally, there would be an increase in plant species composition and improved 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

256 Chapter 3. Affected Environment and Environmental Consequences

vigor of forage plants. This would then improve livestock distribution within the five pastures, thus adhering to a 

more conservative utilization level. 

The action alternatives are tiered to moving towards and/or meeting specific desired conditions and are in 

alignment with the Kaibab National Forest Plan. The implementation of these treatments will provide benefits to 

a variety of resources including forest health conditions, grassland conditions, watershed conditions, water 

quality, and wildlife habitats. Based on field observations and observed effects to rangeland resources from 

previous prescribed fires on the Kaibab National Forest, implementation of any action alternative and any current 

and future projects within the Hat Allotment would not result in long-term negative impacts to rangeland 

resources and/or allotment management activities.

Invasive Plant Species (No Action Alternative). The cumulative effects boundary is the Hat Allotment and the 

timeframe is 10 years into the future, which is the life of a term grazing permit before it is renewed. 

Cumulatively, there would be no timber management activities and prescribed burning to remove portions of the 

overstory, understory, and/or litter cover. Understory plant communities that are abundant and diverse can 

increase the community’s resistance to non-native plant invasion (Elton 1958). Without reducing fuels and tree 

canopy cover will increase the threat of catastrophic wildfires that often times provide optimal conditions for 

weeds to establish. Inventory, treatments, and monitoring, as well as Best Management Practices, will continue to 

be implemented throughout the Kaibab National Forest. Populations posing the greatest ecological threat and/or 

having the greatest likelihood of successful control will continue to be the highest priority for treatment. 

Invasive Plant Species (All Action Alternatives). The cumulative effects boundary is the Hat Allotment and the 

timeframe is 10 years into the future, which is the life of a term grazing permit before it is renewed. 

Cumulatively, timber management activities and prescribed burning remove portions of the overstory, understory, 

and/or litter cover, with the objective of maintaining or improving forest health and improve the herbaceous 

understory. Understory plant communities that are abundant and diverse can increase the community’s resistance 

to non-native plant invasion (Elton 1958). Reducing fuels and tree canopy cover can also reduce the threat of 

catastrophic wildfires that often times provide optimal conditions for weeds to establish. Weeds could be spread 

by heavy equipment, vehicles, and personnel associated with these activities. Any action alternative, current, and 

any future projects within the Hat Allotment, may result in the recruitment/expansion of invasive plant species 

populations. Inventory, treatments, and monitoring, as well as Best Management Practices, will be implemented 

within any project area, with those populations posing the greatest ecological threat and/or having the greatest 

likelihood of successful control being the highest priority for treatment. 

Recreation. Recreational activities often accelerate seed dispersal rates of non-native invasive plants which can 

negatively affect habitat quality of understory plant communities. Inventory, treatments, and monitoring, as well 

as Best Management Practices, would be implemented within the project area, with those populations posing the 

greatest ecological threat and/or having the greatest likelihood of successful control being the highest priority for 

treatment to mitigate the treat of invasive species.

Climate. Global climate change models project warmer, more arid conditions in the southwestern United States 

(Seager et al. 2007). However, the impact of global climate change on species’ distributions is mostly uncertain 

(Thuiller et al. 2007). Climate change may result in more frequent and severe droughts, as well as more highintensity wildfires. Drought and high-intensity wildfire may result in forage species mortality, habitat loss, and the 

loss of species viability. Improving understory plant communities may increase forage species ability to resist 

drought due to a well-developed root system, resulting in the persistence of a native understory. 

3.11 Recreation Resources 

3.11.1 Existing Condition

Information on current recreation use levels and preferences is derived from public contacts, field observations, 

and surveys of visitors, local tourism businesses, and residents. Although exact figures are not known, recreation 

use in the project area is estimated by recreation managers to have high use. The National Visitor Use Monitoring 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 257

Survey conducted on the forest in 2010 indicates that there are 757,000 visitors to the Kaibab National Forest 

yearly. The National Visitor Use Monitoring (NVUM, 2005 and 2010) and visitor survey conducted in 2000-2002 

by Northern Arizona University (NAU- Boussard, 2002) indicate area visitors come from the local area, the 

surrounding region (Arizona, Colorado River, Las Vegas) and from across the nation and abroad. While local 

residents are consistent users of the project area, and have immediate access to the national forest, the project area 

receives a significant amount of recreational visitors from the lower-elevation, densely populated Phoenix Valley 

urban communities and Colorado River communities. There is also a fairly significant amount of recreation use 

in the project area by visitors from across the US and abroad, as Williams is part of the “Grand Circle” Colorado 

Plateau region, and adjacent to the Grand Canyon, which brings 4-5 million visitors to the region annually. 

Known as “The Gateway to the Grand Canyon,” Williams has a long history as a tourism destination, and tourism 

as an industry has received increasing emphasis in the past decades.

Within the project area there are several recreation sites, which include the Bill Williams, Benham, Bixler, Clover 

Spring Loop, City Link, and Buckskinner Trails. Immediately adjacent to the project area are some of the most 

heavily visited developed recreation sites on the Williams Ranger District. Sites found adjacent to this planning 

area include Dogtown Lake Recreation Complex, Overland Trail, Stage Station Loop Mountain Bike Trail, and 

Historic Route 66 Devil Dog Mountain Bike Loop. Privately operated recreation facility under special use permit 

on National Forest System lands within the project area is the Elk Ridge Ski Area. Buck Skinner Park is the 

municipally owned and operated recreation facility within the project area. A number of private recreation-based 

businesses are also located adjacent to the area (Young Life Lost Canyon Organizational Camp, the Grand 

Canyon Railway, and several RV parks, motels, etc.)

As recreation use increases, the types of recreation activities visitors engage in are likewise increasing and 

diversifying. The types of recreation activities visitors pursue in the project area are varied and occur in mostly 

dispersed settings in all seasons. These activities include camping, picnicking, hiking, mountain biking, boating, 

fishing, hunting, horseback riding, riding ATVs and motorcycles, driving, viewing wildlife and scenery, viewing 

historic features (such as Route 66), family gatherings, cross-country skiing, snowshoeing, sledding, and snowplay. General relaxing and escaping the heat of lower-elevations is one significant reason visitors mention for 

traveling to this area.

National Forest visitors are diverse in their preferences for recreational settings, experiences, and activities, and 

for the reasons mentioned above, as well as changing demographics, are becoming increasingly diverse. In order 

to provide a diversity of settings and opportunities the Forest Service uses the Recreation Opportunity Spectrum 

(ROS) as a management tool to inventory and describe recreation setting objectives for the National Forest 

System lands. Forest Plan ROS mapping was completed for the Kaibab National Forest south zone in 2004. The 

Bill Williams Project area encompasses four ROS classes: Rural on the far north end of the project area; Roaded 

Natural forms a ring around the project area on the lower slopes of Bill Williams Mountain; Semi-primitive 

Motorized encompasses the middle slopes on the south and west side of Bill Williams; and Semi-primitive 

Nonmotorized occurs on the highest slopes of the mountain. Forest plan direction states that ROS classes are to 

be considered in the design of project activities and ROS classes maintained or enhanced. Table 3-67 shows the 

total ROS acres for the Bill Williams project area.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

258 Chapter 3. Affected Environment and Environmental Consequences

Table 3-67. Recreation Opportunity Spectrum Classification for the Project Area

ROS Class

Approximate 

acres to be 

treated in 

Project 

Boundary General Setting Description (Desired Condition)

Rural (R) 391 Landscapes may be highly modified but managed to maintain general scenic 

attractiveness, and may include culturally modified and extensively developed 

recreation sites. Rural settings are highly modified and managed; there is generally a 

natural appearing backdrop.

Roaded Natural 

(RN)

7,376 Landscapes are carefully managed to maintain or enhance recreation and scenic 

values, sites and features, to be natural appearing, with changes designed to appear 

in harmony with natural setting. May contain highly developed recreation sites and 

travel routes.

Semi-Primitive 

Motorized

(SPM) 

4,672 Maintain predominately undeveloped landscapes and scenic vistas and limited 

recreation developments. Recreation uses are non-motorized.

Semi-Primitive 

Non-motorized 

(SPNM) 

2,698 SPNM 

The Scenic Integrity or "intactness" of national forest lands is the means by which proposed alterations to the land 

are evaluated. Scenic Integrity is produced from the combined inventory of scenic attractiveness, viewing distance 

from the observer, and concern level of forest visitors. Scenic Integrity Objectives (SIO) are established for the 

forest and can be applied at the forest, management area or project area (Forest Service 2010). SIOs range from 

Very High, meaning the landscape character is unaltered, to Very Low, meaning the landscape character is highly 

altered. Intermediate levels include High (landscape character appears unaltered), Moderate (landscape character 

is slightly altered), and Low (landscape character is moderately altered). Another basic premise of the SMS is 

landscape character, which gives a geographic area its visual and cultural image. It consists of a combination of 

physical, biological and cultural attributes that make each landscape identifiable and unique. Landscape character 

embodies distinct landscape attributes that exist throughout an area (Forest Service 2000). Table 3-68 compares 

the Visual Management System rankings and terminology with the Scenery Management System.

Table 3-68. Scenic integrity, visual quality objective, and perception crosswalk (USDA FS 1995, 2-4)

Scenic 

Integrity 

Rating by 

Number

Scenic Integrity 

(both Existing and 

Objective)

Visual Quality 

Objective The Forest’s Scenic Integrity as people perceive it 

1 Very High Preservation Unaltered; landscape character is intact

2 High Retention Appears unaltered; deviations to landscape character are 

not evident

3 Moderate Partial Retention Slightly altered; deviations are subordinate to landscape 

character being viewed

4 Low Modification Moderately altered; deviations begin to dominate the 

valued landscape character being viewed

5 Very Low Maximum Modification Appears heavily altered; deviations may strongly dominate 

the valued landscape character. 

Unacceptably Low Unacceptable 

Modification

Appears extremely altered; this level is only used to 

inventory existing scenic integrity. It is never an objective 

on National Forest System lands

3.11.2 Desired Condition

A spectrum of high-quality outdoor recreation settings and opportunities will be available in the Bill Williams 

Project area; Roaded Natural ROS areas with high scenic and recreational values and where use is high; and 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 259

Semi-Primitive settings occur where use is lower and the setting is more natural-appearing. Recreation facilities 

and trails will continue to be provided and maintained, and options for development of future facilities in response 

to public demand or need are analyzed and implemented if they meet Forest and ecosystem objectives.

The National Forest System lands surrounding Bill Williams Mountain will continue to provide high quality 

recreation opportunities and settings that compliment and support the City of Williams’ tourism industry, and 

contribute to local residents’ quality of life. Management activities on National Forest System lands are 

consistent with recreation setting objectives.

The desired scenic character for the Bill Williams project area would display a much more open and diverse forest 

canopy and vegetative mosaic. This would include representation of all age groups and size classes, especially 

large, old coniferous and deciduous trees. Trees would be arranged in groups with inter-tree space as well as 

openings around the groups. There would be a greater representation of aspen and meadows. The presence of 

tightly grouped intermediate-sized trees would be greatly reduced. Trees that have encroached into meadows and 

over-shaded aspen groves or large oak trees are thinned or removed, opening up these areas. Small and moderate 

sized irregularly shaped openings/grass-forb meadows would be more frequent, bounded by trees of all ages, 

including full-crowned, old, mature conifers and deciduous species (aspen, oak), accented by volcanic rock forms. 

The more open forest will provide improve views to attractive understory vegetation, wildlife, volcanic rock 

forms, snow features, seasonal color changes and more distant views outward from the forest canopy. Lastly, reintroduction of wildfire evidence into the scenery is desired, primarily within finely-scaled and irregularly-shaped, 

low- and moderate-intensity burn patterns that are consistent with historic conditions. 

3.11.3 Direct and Indirect Effects Analysis

Alternative 1 – No Action

Under this alternative, forested lands in the Bill Williams Project area would not receive treatments to improve 

ecosystem health and sustainability, improve the vegetative age classes, species and structure; move stand 

condition towards pre-settlement fire regimes, nor reduce the risk of stand-replacing fires.

Under the no action alternative there would be few immediate direct or indirect effects on the existing recreational 

setting or facilities. Since no direct management actions would occur, the existing recreational setting would not 

change. However, the Bixler Trail would continue to be underutilized as access was limited under the 2011 

decision for Travel Management. Hikers would have to hike up the closed Forest Road 45 to the existing trailhead 

in order to access the trail. Stand densities would remain unnaturally high, although most visitors are not aware of 

the unnatural condition of the forest, and their experience and perception of forest conditions would continue to 

be largely positive. However, due to unnaturally high stand densities and fuel loadings, there would continue to 

be the potential for disturbance processes to affect the landscape negatively, such as insect outbreaks, diseases, 

and wildfires. 

Of great concern to maintaining high recreation values is a high potential for large, stand-replacing wildfires to 

occur in the project area. If a large stand-replacing wildfire swept through the area, it could seriously damage or 

completely destroy recreational settings in the Bill Williams project area along with many of the recreation sites 

that fall within the Bill Williams Mountain watershed (including, but not limited to Dogtown Lake and 

Campground, Santa Fe Reservoir, City Reservoir, Buckskinner Park, Cataract Lake Day Use and Fishing Site). 

The quality of life of local residents and other national forest visitors who value forest recreation opportunities 

and facilities would be negatively affected for decades after a stand-replacing wildfire on the mountain. Tourism 

could also be negatively affected if visitors decide not to visit the Williams area due to the negative effects a large 

wildfire could have on recreation resources.

Alternative 2 – Modified Proposed Action

Under the modified proposed action approximately 15,200 acres in project area would be treated by a variety of 

mechanical treatments and prescribed fire in order to improve ecosystem health and sustainability; improve the 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

260 Chapter 3. Affected Environment and Environmental Consequences

vegetative age classes distribution, species and structure; move stand condition towards pre-settlement fire 

regimes; and reduce the risk of stand-replacing fires.

Under this alternative, it is expected that there would be some short-term direct and indirect effects to the 

recreation and visual settings. Table 3-69 shows the acres for alternative 2 by recreation opportunity spectrum 

and treatment methods directly affecting the SPM and the SPNM ROS character for the mountain, is the 

percentage of land that will fall under treatment during project implementation. This alternative would treat 95% 

of the SPM and 100% of the SPNM ROS classification area. The direction for the SPM and SPNM ROS areas on 

the mountain is that up to 25% of an individual area may be mechanically treated at one time. Also directly 

affecting the SPNM ROS classification is the determination that approximately 2/3 of a mile of re-opened 

maintenance level 1 (ML-1) roads will be required for the project. The road would be closed to continued use and 

restored to original conditions when the project is completed. 

Direct effects to recreation settings of mechanical treatments would be short-term, temporary change in ROS 

setting quality, which would persist until activity slash is treated and the treated area recovers to an “undisturbed” 

appearance. The effects of low and even some moderate-intensity fires on outdoor recreation settings are not to 

be considered to be negative; rather fire is recognized as an integral part of the forest landscape and setting.

Direct effects of mechanical treatments and prescribed burning are the potential for short-term displacement of 

recreationists during implementation (campers would need to be moved out, trail users would not be able to use 

certain trails during implementation, etc.), or visitor satisfaction (seeing activities slash, smoky conditions while 

people are visiting the area). Also, there is the potential for those recreationists seeking a specific setting, 

especially non-motorized experience, would not be able to achieve that on Bill Williams Mountain, even in the 

SPNM ROS classified area. Mitigation measures have been designed to ensure that the direct effects of the 

project activities are short term and important recreation and visual values are protected long term.

This alternative better provides for the long-term protection of recreation settings and facilities by improving 

stand conditions and reducing fuel loading. Improving forest manager’s ability to maintain healthy, green forests 

and reduce the risk of high-intensity stand-replacing wildfires in the project area would have a positive effect on 

the ability to protect and maintain high quality recreation setting long into the future. 

The construction of a new Bixler trailhead and the 0.5 mile of new trail construction would allow better access to 

existing trail. The 0.25 acre trailhead would be constructed with crushed native material and would allow for safer 

parking than the existing condition of parking along FSR 108 and hiking up the closed FSR45 to access the 

existing trailhead and trail. The conversion of one mile of FSR 45 from a poorly located closed road into a nonmotorized trail will provide better access to the existing portion of trail while reducing current erosion issues. 

Overall scenic integrity on Bill Williams Mountain would be lowered during project implementation. There would 

be evidence of new linear corridors as roads are constructed, trail work is completed, and mechanical treatments 

and prescribed burning are implemented. 

Interim measures would be used during implementation activities whereby the 11,131 acres in SIO 2 (high) will 

drop to SIO 3 (moderate) until project completion and for 5 to 10 years following. This will ensure adequate time 

for closed and decommissioned roads to naturalize, evidence of logging activities to recover, trailside vegetation 

to re-establish and initial prescribed fire activities to soften.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 261

Table 3-69. Acres for Alternative 2 by Recreation Opportunity Spectrum and Treatments

Treatment 

Methods Rural Acres

Roaded Natural

Acres

Semi-Primitive 

Motorized Acres

Semi-Primitive 

Non-Motorized

Acres

No Proposed 

Treatment

891 1,425 234 0 

Conventional 323 6,191 4,052 478

Helicopter 8 483 105 466

MSO core 0 0 24 80

No Mechanized 

Equipment

0 76 88 316

Steep Slope 

Mechanical 

0 626 403 1,358

Total Acres 1,282 8,801 4,906 2,698

Alternative 3

Under alternative 3, it is expected that there would be some short-term direct and indirect effects to the recreation 

and visual settings. Table 3-70 shows the acres for alternative 3 by recreation opportunity spectrum and 

treatment. Directly affecting the SPM and the SPNM ROS character for the mountain, is the percentage of land 

that will fall under treatment during project implementation. This alternative would treat 95% of the SPM and 

100% of the SPNM ROS classification area. The common direction for the SPM and SPNM ROS areas on the 

mountain is that up to 25% of an individual area may be mechanically treated at one time. Also directly affecting 

the SPNM ROS classification is the determination that approximately 2/3 of a mile of re-opened maintenance 

level 1 (ML-1) roads will be required for the project. The road will be closed to continued use and restored to 

original conditions when the project is completed. 

Direct effects to recreation and visual settings of mechanical treatments would be short-term, temporary change in 

ROS setting quality, which would persist until activity slash is treated and the treated area recovers to an 

“undisturbed” appearance. The effects of low and even some moderate-intensity fires on outdoor recreation 

settings are not to be considered to be negative; rather fire is recognized as an integral part of the forest landscape 

and setting. 

Direct effects of mechanical treatments and prescribed burning are the potential for short-term displacement of 

recreationists during implementation (campers would need to be moved out, trail users would not be able to use 

certain trails during implementation, etc.), or visitor satisfaction (seeing activities slash, smoky conditions while 

people are visiting the area). Also, there is the potential for those recreationists seeking a specific setting, 

especially non-motorized experience, would not be able to achieve that on Bill Williams Mountain, even in the 

SPNM ROS classified area. Mitigation measures have been designed to ensure that the direct effects of the 

project activities are short term and important recreation values are protected long term. 

This alternative better provides for the long-term protection of recreation settings and facilities by improving 

stand conditions and reducing fuel loading. Improving forest manager’s ability to maintain healthy, green forests 

and reduce the risk of high-intensity stand-replacing wildfires in the project area would have a positive effect on 

the ability to protect and maintain high quality recreation setting long into the future. The extension of the Bixler 

Trail will allow recreationists easier access to the existing trail while allowing the poorly located closed road to 

revegetate.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

262 Chapter 3. Affected Environment and Environmental Consequences

Table 3-70. Acres for Alternative 3 by Recreation Opportunity Spectrum and Treatments

Treatment 

Methods Rural Acres

Roaded Natural

Acres

Semi-Primitive 

Motorized Acres

Semi-Primitive 

Non-Motorized

Acres

No Proposed 

Treatment

892 1,402 234 0 

Adverse 

Forwarder

0 23 0 45

Conventional 323 5,170 3,057 192

Helicopter 7 1,171 599 2,094

MSO Core burn 

Only

0 0 24 80

Mixed 

Conventional

0 676 620 106

Steep Slope 

Conventional

59 336 374 182

Total Acres 1,281 8,778 4,908 2,699

Alternative 4 

Under Alternative 4, 11,095 acres in the Bill Williams Project area would be treated by a variety of mechanical 

treatments and prescribed fire in order to improve ecosystem health and sustainability; improve the vegetative age 

classes distribution, species and structure; move stand condition towards pre-settlement fire regimes; and reduce 

the risk of stand-replacing fires.

Under alternative 4, it is expected that there will be some short-term direct and indirect effects to the recreation 

setting. Table 3-71 shows the acres for alternative 4 by recreation opportunity spectrum and treatment. Directly 

affecting the SPM character for the mountain is the percentage of land that will fall under treatment during project 

implementation. This alternative will treat 83% if the SPM classification area. The direction for the SPM ROS 

areas on the mountain is that up to 25% of an individual area may be mechanically treated at one time. It is 

expected that the assigned ROS classification will be recovered within two years after project implementation for 

this ROS class.

Direct effects to recreation settings of mechanical treatments would be short-term, temporary change in ROS 

setting quality, which would persist until activity slash is treated and the treated area recovers to an “undisturbed” 

appearance. The effects of low and even some moderate-intensity fires on outdoor recreation settings are not to 

be considered to be negative; rather fire is recognized as an integral part of the forest landscape and setting.

Direct effects of mechanical treatments and prescribed burning are the potential for short-term displacement of 

recreationists during implementation (campers may need to be moved out, trail users may not be able to use 

certain trails during implementation, etc.), or visitor satisfaction (seeing activities slash, smoky conditions while 

people are visiting the area). Also, there is the potential for those recreationists seeking a specific setting, 

especially non-motorized experience, would not be able to achieve that on Bill Williams Mountain, even in the 

SPNM ROS classified area. Mitigation measures have been designed to ensure that the direct effects of the 

project activities are short term and important recreation values are protected long term.

This alternative better provides for the long-term protection of recreation settings and facilities by improving 

stand conditions and reducing fuel loading. Improving forest manager’s ability to maintain healthy, green forests 

and reduce the risk of high-intensity stand-replacing wildfires in the project area would have a positive effect on 

the ability to protect and maintain high quality recreation settings long into the future. 

Alternative 4 would result in fewer acres showing effects to scenic integrity from mechanical thinning than either 

action alternative (2 or 3). Interim measures will be used during implementation activities whereby the 13,401 

acres in SIO 2 (high) will drop to SIO 3 (moderate) until project completion and for 5 to 10 years following. This 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 263

will ensure adequate time for closed and decommissioned roads to naturalize, evidence of logging activities to 

recover, trailside vegetation to re-establish and initial prescribed fire activities to soften.

Table 3-71. Acres for Alternative 4 by Recreation Opportunity Spectrum and Treatments

Treatment 

Methods Rural Acres

Roaded Natural

Acres

Semi-Primitive 

Motorized Acres

Semi-Primitive 

Non-Motorized

Acres

No Treatment 899 2,597 856 2,218

Conventional 323 5,170 3,056 192

Mixed 

Conventional

 0 676 620 106

Steep Slope 

Conventional

59 337 374 182

Total Acres 1,282 8,779 4,906 2,698

3.11.4 Cumulative Effects

The cumulative effects analysis extends 20 years from the first phases of implementation of the Bill Williams 

Project. Twenty years was chosen because large complex projects can take 10, or more years to complete 

treatments. Once activities are completed in a treatment unit it takes approximately one to three years for treated 

area to recover until they are generally unnoticeable to the average forest visitor (one to two years of drying to 

dispose of slash after thinning projects, plus up to one more year for the visual effects of mechanical fire line 

preparation and prescribed burning to recover). Fuels reduction and stand improvement treatment including 

thinning, non-commercial and commercial tree harvesting, fuelwood sales, and prescribed burning will occur over 

time and in phases within the different project areas; thus different project areas will be in varying stages of 

treatment or recovery over the 20-year time period across the cumulative effects analysis area. The effects of 

mechanical treatments are addressed in this analysis; recurring maintenance burning is typically low intensity and 

usually recovers within one year of implementation and thus is considered to have minimal effects on recreation 

resources.

The area chosen for the cumulative effects analysis of this project is bounded by the northern Williams Ranger 

District boundary to the north, west to the forest boundary in Bellemont, Arizona; east to the forest boundary near 

Ash Fork, Arizona; and south to the forest boundary (the border with the north end of the Prescott National 

Forest). This area was chosen because the project area is the view-shed (areas of particular scenic or historic 

value that are readily visible from public areas such as from public roadways or communities of Bill Williams 

Mountain which is a popular recreation area for locals and out-of-town visitors and recreationists. 

Recently implemented and current ongoing vegetation management projects in this analysis area include: Clover 

High, Williams High Risk, Dogtown Fuels, and the Twin Burn. Potential future vegetation management projects 

include McCracken Project and the Four Forest Restoration Initiative. There is little information known about 

these projects at this time to predict the extent of the potential impact from these projects. With the increased 

emphasis for reducing hazardous fuels in the urban interface it is estimated that at least 10-15% of the area of the 

cumulative effects analysis area could either be in the physical state of being mechanically treated, awaiting final 

slash treatment and prescribed burning, or in a post treatments recovery phase over the next 20 years. 

Alternative 1 – No Action. Recreation user displacement, noise and dust are effects from past, present, and 

reasonably foreseeable projects that have affected the recreation resources on the district. Past experience has 

shown that these effects are usually short in duration and generally localized to the project area. When combined 

with the direct and indirect effects of implementing Alternative 1, the cumulative effects on recreation resources 

are minimal, as most recreationists do not recognize the unnatural state of the forest and have generally positive 

experiences in the pursuit of their recreational activities. In this alternative the threat to the mountain, of a wildfire 

and the potential for the mountain to experience a high intensity stand-replacing wildfire would remain 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

264 Chapter 3. Affected Environment and Environmental Consequences

unchanged. Under the no action alternative recreationists would not be displaced by project activities in the Bill 

Williams Project area, but could be potentially displaced by increased fire danger in the Bill Williams Watershed, 

closures of the watershed, and by fire activity on the mountain. 

Alternative 2 – Modified Proposed Action. The cumulative effects of the modified proposed action when 

combined with past, present, and reasonably foreseeable future actions, would be to greatly increase the total 

number of acres being treated or recovering from treatment by approximately 5 – 7 %, throughout the cumulative 

effects analysis area, as described. It is difficult to determine exactly how much mechanical treatment will be 

accomplished in the cumulative effects analysis area in any given year. If the assumption is made that all of the 

projects initial treatments will be completed in 5 - 20 years, the annual mechanical vegetation treatment acreages 

could range from 1,520 to 3,040 and from 5,000 to 10,000 acres burned each year. This would leave an 

approximate range of 17,296 – 26,336 acres treated and in a physical state of recovery from mechanical treatment 

and final slash treatments, throughout the cumulative effects analysis area, at any one time.

The potential for displacement of recreationists during the project implementation is increased over the 

cumulative effects area, although the exact numbers cannot be determined. In this alternative the greatest 

potential of displacement would be of those recreationists choosing to recreate in the SPNM setting, where there 

would be the greatest amount of disturbance during implementation inside of the SPNM area.

There are mitigation measures for the project that will minimize the impact to the recreation setting in particular 

areas, such as along important recreation roads, protecting the historic and recreational trails, and reducing the 

impact to the setting from treatment slash. However, outside of those areas the vegetation treatments in progress, 

or recently completed, will be evident for up to 5 years, having a short-term negative effect on recreation setting. 

These treatment areas will be scattered across the landscape and in varying stages of recovery from year to year. 

There will be some short term negative effects to recreation settings, especially with regards to the percentage of 

the settings for SPM and SPNM in recovery from treatment. The long-term effects of reducing fuels and 

improved stand conditions are considered to be very beneficial; the improvements will provide for better longterm protection of forest health from potentially large and damaging stand-replacing wildfires, or from 

widespread damaging insect kill. Healthy forests are critical to providing high quality and highly desirable 

recreation settings and opportunities. The Bill Williams project would improve the cumulative effectiveness and 

overall ability to protect recreational resources in the long term across the cumulative effects analysis area.

Alternative 3. Same as Alternative 2.

Alternative 4. The cumulative effects of this alternative when combined with past, present, and reasonably 

foreseeable future actions, would be to greatly increase the total number of acres being treated or recovering from 

treatment by approximately 3 – 7 %, throughout the cumulative effects analysis area, as described. It is difficult 

to determine exactly how much mechanical treatment will be accomplished in the cumulative effects analysis area 

in any given year. If the assumption is made that all of the projects initial treatments will be completed in 5 - 20 

years, the annual mechanical vegetation treatment acreages could range from 1,520 to 3,040 and from 5,000 to 

10,000 acres burned each year. This would leave an approximate range of 17,296 – 26,336 acres treated and in a 

physical state of recovery from mechanical treatment and final slash treatments, throughout the cumulative effects

analysis area, at any one time.

The potential for displacement of recreationists during the project implementation is increased over the 

cumulative effects area, although the exact numbers cannot be determined. 

There are mitigation measures for the project that will minimize the impact to the recreation setting in particular 

areas, such as along important recreation roads, protecting the historic and recreational trails, and reducing the 

impact to the setting from treatment slash. However, outside of those areas the vegetation treatments in progress, 

or recently completed, will be evident for up to 5 years, having a short-term negative effect on recreation setting. 

These treatment areas will be scattered across the landscape and in varying stages of recovery from year to year. 

There will be some short term negative effects to recreation settings, especially with regards to the percentage of 

the settings for SPM and SPNM in recovery from treatment.
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Chapter 3. Affected Environment and Environmental Consequences 265

The long-term effects of reducing fuels and improved stand conditions are considered to be very beneficial; the 

improvements will provide for better long-term protection of forest health from potentially large and damaging 

stand-replacing wildfires, or from widespread damaging insect kill. Healthy forests are critical to providing high 

quality and highly desirable recreation settings and opportunities, the Bill Williams project would improve the 

cumulative effectiveness and overall ability to protect recreational resources in the long term across the 

cumulative effects analysis area.

3.12 Scenic Resources 

3.12.1 Affected Environment

The Bill Williams Project will thin vegetation and use prescribed fire to improve the health and sustainability of 

the forested conditions on and surrounding Bill Williams Mountain. There will be related road construction 

activities, and a trailhead and trail will be relocated.

Plant communities throughout the project area have changed significantly from their historic condition due to fire 

suppression, historic logging and other management activities. Historic vegetation components of quaking aspen 

and meadows have declined across the landscape because of fire suppression and conifer encroachment. The 

regeneration of aspen in the project area is poor due to dense forest conditions and browsing pressure on aspen 

saplings. Springs and seeps have reduced function due to drought, lack of fire and closed forest canopies. The 

Kaibab National Forest has identified the needed road system for public and administrative motorized travel and 

roads and routes that should be decommissioned due to resource concerns. 

The scope of this analysis focuses on scenery management within the approximately 18,000 acres Bill Williams 

Mountain project area. 

This section documents the analysis of effects of proposed Bill Williams Project vegetation treatments on scenic 

resources located in the area. 

Recreation and scenic resource are closely related resources, as high quality scenery is often very important to 

providing high quality recreation settings. This close relationship is reflected in Spectrum and Scenery 

Management System direction and mapping. Both of these cultural and social resources are extremely important 

to the City of William’s tourism industry and on the local resident’s quality of life. 

3.12.2 Introduction 

Viewing scenery is one of the most sought after recreation activities on the KNF (Forest Service 2012). Scenic 

quality within the project area is particularly important to those who enjoy the views from the City of Williams, 

Interstate 40, Highway 89A, adjacent Forest Roads, developed recreation sites and trails (USDA 2007). Scenery 

also contributes indirectly to local quality of life, tourism and economic vitality, and the KNF’s scenic heritage.

The project will help achieve the desired conditions for scenery as defined in the forest plan (Forest Service 

2010): Protect and enhance the scenic and aesthetic values of the Kaibab National Forest.

3.12.3 Project Level Scenic Inventory

Sense of Place

Bill Williams Mountain serves as a backdrop to Williams, Arizona, and is the dominant element in forming the 

city’s sense of place nestled at the base of the mountain on the north side. Bill Williams Mountain (BWM) has 

served as a local landmark from prehistory through the present. It has been a resource for humans through time 

providing water, forest products, forage for livestock, habitat that supports game and wildlife, and as a part of 

people’s lives and culture. The mountain is a reminder of seasonal change, as well as viewing pleasure. The BWM 

is highly visible from major highways in the surrounding area including Interstate 40, US Highway 89, and State 

Highway 64, as well as the Burlington Northern Santa Fe railroad which includes Amtrak passenger train service. 
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266 Chapter 3. Affected Environment and Environmental Consequences

Thousands of people travelling through the area view the attractive picture of the small town in the mountainous 

setting. Those traveling on the Grand Canyon Railroad from the Grand Canyon National Park to Williams also 

have a distinct view of the mountain. As such, Bill Williams Mountain is a part of the community’s image and 

sense of place.

Bill Williams Mountain’s forested character and role as a backyard forest is recognized and documented in the 

2007 KNF Recreation Niche (Forest Service):

“Settings, Special Places, and Values: ... the Forest steps up through extensive forests of ...ponderosa pine to forests 

of fir and spruce...The Kaibab National Forest is the traditional home of Native people and continues to play an 

important role in their lives. It is a backyard forest with generations of family connections and provides 

commodities and tourism’s economic benefits for local businesses... Providing respite from the valley heat, the 

Forest is also a destination for those seeking a summer oasis to relax, and enjoy activities such as hiking, birdwatching, fishing and sightseeing. 

Oasis - Provide opportunity to escape the heat in the desert valleys. Higher elevation; includes the sky islands - Bill 

Williams Mountain, Sitgreaves Mountain, and the Kaibab Plateau, dominated by ponderosa pine forest and scenic 

meadows and prairies.”

Figure 3-55. Finger Rock formation on Bill Williams Mountain
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Chapter 3. Affected Environment and Environmental Consequences 267

Existing Landscape Character

The following is the existing landscape character description from the Kaibab NF ROS/SMS Guidebook (Forest 

Service 2004). “The Bill Williams Project is located within the Flagstaff Character Type, a fairly un-dissected 

plateau with extensive lava flows and volcanic cones, drained by dry washes with a few natural and created 

reservoirs. Coniferous forest, primarily montane conifer, is the predominate vegetation. Mountain meadow 

grassland, aspen, plains grassland, and pinyon-juniper woodland are common to parts of the area. Stringers of 

riparian deciduous forest and woodland are common along watercourses.” 

Site Specific Characteristics

Landform: Bill Williams Mountain is the highest point on the KNF at an elevation of 9,256 feet above sea level. It 

is part of the San Francisco volcanic field (USGS 2001). Bill Williams Mountain is made of a cluster of lava 

domes. Lava domes are formed from viscous lava that piles up into dome-shaped mounds. Other dome-cluster 

mountains in the San Francisco volcanic field include Sitgreaves Mountain and Kendrick Mountain (Forest 

Service 2011). The volcanic origins of the mountain result in rocky outcrops and formations. Finger Rock as 

depicted below in Figure 3-56 is found on the south side of Bill Williams Mountain. Many of the smaller outcrops 

and rocky terrain are not visible through the thick vegetative cover. Large rock formations are dominant features 

in the foreground and middle ground of the mid and upper regions of BWM. 

The landform has received minor modifications as forest roads have been built, trails constructed, utility corridors 

cleared, and structures erected. These structural features are noticeable and detract somewhat from the scenic 

integrity of the mountain. 

Waterform

Seeps, springs and ephemeral drainages are minor attributes of the landscape character. They contribute to the 

valued image of the landscape, but are less noticeable. Springs and seeps on the mountain provide isolated green 

oases where plant and animal life and activity occur. Many different plant species can be found in these places and 

they provide brief climatic relief and contrast to the surrounding coniferous forest. Springs are special for viewing 

wildflowers and moisture loving plants, butterflies, moths, bees and other insects, as well as birds and other 

wildlife. Springs have provided water for human occupants and visitors over time. In addition, a number of 

ephemeral drainages provide seasonal flowing water, a rare commodity on the KNF.

Vegetation: The overstory vegetation is the most dominant scenic attribute in the project area. The mountain has 

coniferous cover in most places. In the foothills of Bill Williams Mountain ponderosa pine trees prevail. 

Secondary components include white fir, Gambel oak, and alligator juniper. At upper elevations, the vegetation 

changes to mixed conifer where components of Douglas fir and white fir increase and are mixed with scattered 

aspen and ponderosa pine. On the west side of the mountain, there is a pinyon-juniper unit included in the project 

area. Species include alligator juniper, scattered ponderosa pine, Gambel oak, Utah juniper, and pinyon pine. 

Understory vegetation is currently a minor attribute. It includes small trees and shrubs such as choke cherry, 

maple, mountain mahogany and cliff rose, currant and wild rose, grasses such as Arizona fescue and mountain 

muhly, and forbs. In the pinyon-juniper forest types, the understory component changes to include different shrub, 

grass and forb species.

Aspen is an important visual component on the mountain, both for the contrasting color, scale and texture that 

stands provide and for the seasonal color change that attract viewers to the area. Gambel oak is also an important 

hardwood visual component. Oak trees provide a contrast in color, texture and scale. Aspen and oak are minor 

attributes that contribute to the valued image.

Natural meadows, grasslands, open savannahs and forest openings within the project are notable visual 

components because of the contrast in color, texture, shape and scale they provide. Openings are minor attributes.

Scenic Identity
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268 Chapter 3. Affected Environment and Environmental Consequences

The project area’s dominant scenic identity is its largely continuous, conifer forest and openings overlaying the 

moderate to steeply sloping volcanic landforms. The project area is viewed at all distances from inventoried 

sensitive roadways in and around the project area. The major positive scenery attribute of the project area is its 

coniferous forest vegetation, primarily composed of ponderosa pine, mixed conifer stands with meadows and 

openings. Pinyon and juniper occur at lower elevations. Aspen, oak trees, and other mixed hardwoods are 

interspersed (see Figure 3-56 and Figure 3-57). Patterns of this vegetative mosaic are moderate to fine-scaled, 

with many irregular openings. Openings less than 5 acres in size are difficult to distinguish due to dense 

vegetation, yet some openings over 25 acres are distinguishable. Other scenery attributes include volcanic rocks 

and outcrops of all sizes. Seasonal changes including reliable winter snowfall accents the scenery as do wildlife 

sightings of birds and mammals. Research shows that such diversity of scenery attributes supports a positive 

viewing experience for people traveling through or recreating within the project area, and supports the quality of 

life for local residents and visitors (Ryan 2005).

Figure 3-56. Bill Williams Mountain in a background view from downtown Williams, AZ
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Chapter 3. Affected Environment and Environmental Consequences 269

Figure 3-57. Foreground mixed conifer on top of Bill Williams Mountain, and looking to background at Williams, AZ

Ecosystem Context

Vegetation is the dominant scenery attribute of the project area. Landform is a minor scenic attribute. Both offer 

significant opportunities for scenery. The steep slopes of the mountain make it a dramatic landscape feature. 

Rocky outcrops and formations contribute to the unique identity of the mountain, and contribute to the complexity 

of planning management activities that may occur there.

Reference conditions are those vegetative conditions that existed on this forest at a point of time prior to EuroAmerican settlement of the area. As explained in the Existing and Desired Conditions Report (Forest Service 

2011) The analysis uses the year 1870 as a reference point because it is just prior to Euro-American settlement of 

the area and it is a point in time where past tree stocking can still be estimated by looking at pre-settlement 

evidence that still exists on the site (old trees, stumps, fallen trees, stump holes). 

Research in Northern Arizona show the average ponderosa pine basal area historically was about 40 square feet 

per acre (sf/ac). The current average basal area of ponderosa pine in the project area is 121 sf/acre which is almost 

three times historic conditions (FEIS Section 3.2 Silviculture). The basal area of mixed conifer, pinyon and 

juniper vegetation types have also increased. The ponderosa pine and mixed conifer types on the project area are 

at high risk of declining forest health due to dense conditions and competition for sunlight and nutrients, as well 

as susceptibility to high intensity wildfire (see Appendix A Scenic Stability Analysis). In addition, the understory 

of these types is declining since its health is dependent upon forest stand openness. The understory is also at high 

risk due to these same ecological stressors.

Of the minor scenery attributes, aspen is at high risk due to conifer encroachment, lack of fires typical of the 

historic fire regime, and browsing by ungulates. As noted in Section 3-2 (see Silviculture Section), the aspen 

cover type within the project area have been encroached and suppressed by conifer species resulting in a decline 

to the population (Fairweather et al 2008). 

Due to the spatial arrangement of high density trees and fuels, the slopes of Bill Williams Mountain currently pose 

a high risk of stand replacement crown fire. Over 80% of the project area could carry crown fires and about 17% 

could carry surface fire (see BWMR DEIS Section 3-4 Fires and Fuels). Closed tree canopies with understory tree 

regeneration create “ladder fuels” to carry surface fires into the overstory. The ponderosa pine type and mixed 
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270 Chapter 3. Affected Environment and Environmental Consequences

conifer forest within the project area is at a high risk for stand-replacing wildfires while the risk for the woodland 

types in the project area ranges from moderate to high. Stands on the slopes of the mountain are at high to 

extreme risk for crown fire.

The dense vegetation and risk of fire has departed from the natural historic range of variability in terms of fire 

history and vegetation condition. The project area’s Scenic Character is in need of widespread restoration, 

primarily through extensive reduction of forest canopy density, and restoration of the historic fire cycle, to recreate historic ecologically diverse and resilient conditions that can best sustain desired scenery conditions.

Trends for these impaired vegetation conditions result in a continuing decline in forest health, and scenery 

attributes. Over time, the excessively dense conifer stands have and will increasingly experience competition for 

available light, water and nutrients, become more stagnant and subject to increased insect and disease risks, and 

gradually die or likely be consumed by wildfire. These conditions would further increase the risk of large and 

intense wildfires that would inevitably eliminate many vegetation scenery attributes within large portions of the 

project area. It is likely that large scale burn patterns will be inconsistent with the more historic patterns created 

by natural wildfire cycles. Refer to the Silviculture and Fire and Fuels analyses for more specifics on vegetation 

trends (Sections 3.2 and 3.3).

Cultural Context

The project area is highly visible and viewed by large numbers of people from important heavily used travel 

corridors, including Interstate 40, Highway 64, County Rd 73 (a.k.a. Perkinsville Rd, or South Rd), Forest Road 

(FR) 108 (a.k.a. Bill Williams Mountain Loop Rd.), FR 122 (a.k.a. Twin Springs Rd.) and secondary travel-ways 

through the forest. Beyond the project area, private landowners and campers at Dogtown Lake Campground view 

the planning area and the surrounding landscapes from the campground, backyards and porches. The landscapes 

they view on a daily basis is likely very important to their quality of life. Also of import are the “special areas” in 

the project area, which hold high value and meaning for visitors and local residents (spiritual, aesthetic, nostalgic, 

or other). Bill Williams Mountain, Elk Ridge Ski Area, Buckskinner Park, Bill Williams Mountain Loop Rd, 

Twin Springs Rd., and Vista Point were all identified specifically as “special places” by respondents of the 2000-

2001 South Kaibab Visitor Survey (Forest Service). Most respondents to the survey also said they prefer an 

undisturbed natural area with no evidence of humans. 

In the 2010 National Visitor Use Monitoring survey (Forest Service 2012), visitor satisfaction was measured. In 

the comparison of importance and level of satisfaction for condition of the environment and scenery, visitors 

reported the KNF was at or above the highest rating in these areas. The importance of the surrounding forested 

environment and attractive scenery are repeated themes mentioned in the Williams Strategic Plan for Economic 

Development (December 1994). The benefits of high-quality scenery are numerous despite the fact that a dollar 

value is seldom assigned to it, except in regard to real estate appraisals and overall tourism revenue to the town.

Desired Conditions

The desired Scenic Character for the project area would display a much more open and diverse forest canopy and 

vegetative mosaic. This would include representation of all age groups and size classes, especially large, old 

coniferous and deciduous trees. Trees would be arranged in groups with inter-tree space as well as openings 

around the groups. There would be a greater representation of aspen and meadows. The presence of tightly 

grouped intermediate-sized trees would be greatly reduced. Trees that have encroached into meadows and overshaded aspen groves or large oak trees are thinned or removed, opening up these areas. Small and moderate sized 

irregularly shaped openings/grass-forb meadows would be more frequent, bounded by trees of all ages, including 

full-crowned, old, mature conifers and deciduous species (aspen, oak), accented by volcanic rock forms. The more 

open forest would provide improved views of attractive understory vegetation, wildlife, volcanic rock forms, 

snow features, seasonal color changes and more distant views outward from the forest canopy. In some areas 

wildlife species require different habitat conditions, and these would be accommodated. See the Wildlife Section 

3.7 for specific information. Lastly, re-introduction of wildfire evidence into the scenery is desired, primarily 

within finely-scaled and irregularly-shaped, low- and moderate-intensity burn patterns that are consistent with 

historic conditions. 
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Chapter 3. Affected Environment and Environmental Consequences 271

These scenery attributes described above would be distributed through time and space to offer increased 

attractiveness in terms of vegetative forms, colors, canopy texture and immediate foreground spatial variety, while 

improving the overall Scenic Character. These conditions shall be strategically arranged to increase the ecological 

resilience and stability of vegetation scenery attributes which are central to Bill Williams Mountain’s historic 

Scenic Character, image, and identity.

The Desired Scenic Character for the project includes two elements: (1) the desired Scenic Character described 

above, and (2) variations to that character as necessary to meet project objectives for wildlife habitat, heritage 

resources, fuels reduction, forest health and resiliency. These essential elements as a whole form the fully 

integrated, holistic Desired Scenic Character of the project, and would offer greater ecological resilience and long 

term stability of the Desired Scenic Character.

The photo found in Figure 3-58 doesn’t have the benefit of a historic comparison, but helps to illustrate the 

pinyon-juniper vegetation type found on the west side of BWM. There are more interspaces between trees, there 

is a bunchier understory component, and bare ground is visible (versus being covered with pine needles and duff 

at higher elevations).

Figure 3-58. Photo of the western slopes of Bill Williams Mountain

Among the many potential scenery attributes that are under-represented are large, old trees, diverse age groups 

and mature forest structures (especially aspen and pines as individual trees and groups), and meadows with 

shrubs, grasses and forbs. Many meadow areas have decreased in size and are being encroached upon by conifers, 

and/or are obscured from view by dense coniferous vegetation in ponderosa pine, mixed conifer and pinyonjuniper types. Inter-tree spaces so evident in the 1910 photos have mostly disappeared. Aspen stands are old and 

in some cases decadent and reproduction has been hampered by fire suppression and ungulate browsing. Some 

aspen stands are encroached by conifers. Oak thickets are often overtopped or crowded by young conifers.
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272 Chapter 3. Affected Environment and Environmental Consequences

The dense conifer vegetation obscures visibility to even nearby volcanic rock forms and outcrops, and the 

understory is often sparse and lacks diversity. Many “view windows” outward to adjacent areas of the KNF and to 

landforms are obscured by vegetation. In addition, human constructed features including buildings, recreation 

sites, roads, trails and utility corridors, as well as management activities such as logging, right-of-way clearing 

and fire suppression have interrupted and diminished scenic vegetation attributes in some places within the project 

area. The sum of these occurrences has resulted in forest canopy that is excessively dense and uniform, or, 

fragmented in patterns and shapes inconsistent with the historic, vegetative mosaic.

As noted in the Kaibab NF ROS-SMS Guidebook (Forest Service 2004), historic and more recent human 

disturbances have resulted in changes to the ecosystem: “The area is dominated by ponderosa pine type forest, 

which, although largely natural-appearing, has experienced significant changes since European settlement. Above 

8,000 feet on Bill Williams Mountain there is mixed conifer, a combination of Douglas fire, white fir and blue 

spruce. Intensive livestock grazing, forestry practices such as railroad logging and fire suppression have all 

contributed to the changes in forest structure and ecosystem processes. The historic condition of scattered groups 

of yellow pines with abundant grassy understory and a few denser groups of black jack pines has changed to more 

dense thickets of sapling and pole sized stands of pines. The existing forest is less diverse and more prone to 

uncharacteristic change than historically, since the previous disturbance regime of frequent, low-intensity fires 

have been replaced by a regime of stand-replacing, high-intensity fires”.

Some springs, such as Clover Spring, were piped to provide community water sources. Bill Williams Mountain is 

critical to the City of Williams watershed. Williams is dependent upon a number of constructed reservoirs that 

collect seasonal runoff, as well as groundwater wells that provide water for the community. No constructed 

reservoirs are included in the project area, but they are at risk from ecological stressors that could alter the 

conditions in the project. 

Existing roads in the area also offer opportunities for ecosystem improvement. Many of the high clearance and 

closed roads (Maintenance Level 2 and 1) run straight up and down slopes, and a few go up drainages. County 

Road 73 and designated forest roads create linear features through the landscape. The roads and the recreation 

developments also provide viewing platforms into the project area as well as from the mountain into the 

surrounding landscape. 

Hikers, mountain bikers and horseback riders use the trails that climb into the foothills at the base of, and climb 

up Bill Williams Mountain. Trails include Benham Trail, Clover Springs Trail, Bixler Saddle, and City Link. 

These provide linear features through the landscape, but are at a smaller scale, and can be more easily designed to 

work with topographic features. 

Many recreationists enjoy camping along FR 122 and 108. In order to get off the forest roads, campers typically 

drive off the shoulder and have created a network of short routes to areas where they park and set up camp. 

Motorized travel management implemented in 2012 designates some of these short routes as roads open to public 

travel (and camping). These linear roads and cleared areas contrast with the characteristic landscape. 

Elk Ridge Ski Area attracts winter enthusiasts and also provides some summer activities. It includes a series of 

cleared ski runs, a tow rope and ski lift, as well as a ski lodge and associated buildings. The linear, cleared runs 

and constructed features contrast with the forested landscape.

As noted in the purpose and need of the Bill Williams Mountain Restoration Project, the health and sustainability 

of forested conditions and hazardous fuels are currently outside of desired conditions identified in the Kaibab 

Forest Plan. The proposed project would result in better forest plan compliance as well as improved watershed 

conditions contributing to the City of Williams water supply. This will meet Forest Plan direction for scenery 

which is to “Protect and enhance the scenic and aesthetic values of the Kaibab National Forest.” In order to reduce 

risks and enhance scenic values, the Forest Plan also encourages management activities “Where existing 

conditions do not meet mapped ROS or Scenic Integrity Objectives (SIOs), design and implement projects to 

move the area toward desired conditions” (Forest Service 2010). Reduction of risk to the scenic attributes will 

help to meet Forest Plan direction as well as ensuring that the valued scenery will be available into the future.
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Chapter 3. Affected Environment and Environmental Consequences 273

3.12.4 Direct, Indirect, and Cumulative Effects

Alternative 1

If the modified proposed action were not implemented, the project area would continue to be mostly naturalappearing for several years. Important scenery attributes such as open and diverse overstory vegetation and 

healthy understory would continue to have overly dense growing conditions and views into and out from the 

forest would be blocked by trees. Grasslands and mixed hardwoods would continue to be overtopped and 

encroached upon by conifers. The large, old tree character that historically contributed to the attractiveness of the 

area would be limited. Historic fire regimes would not be re-established, limiting nutrient recycling and allowing 

the density of forest fuels to increase. Declining aspen would become more and more decadent and could at some 

time disappear altogether from the project area.

At some point, overstocked vegetative conditions may be attacked by insects or disease, or experience an 

uncharacteristically large and intense wildfire that would burn much of the vegetation that is the primary scenic 

attribute. While some insect and disease activity occurs every day, the overly dense conditions combined with 

extreme weather events characteristic of climate change could allow these to escalate and become wide spread. 

Large, high intensity fires have become more common with increasing tree density and lack of a regular fire 

regime. Large scale events such as these would be outside the range of historic variability.

In the event of an uncharacteristic high severity wildfire such as the Schultz Fire, the existing landscape character 

would be suddenly altered with little opportunity to slow or control the change. The SIO’s in the project area 

would have to be remapped and uncharacteristic high severity, large-scale wildfire would redefine and reshape the 

existing landscape character for decades if not centuries. The appearance and character of the area would shift 

from densely forested to patchy and open. The overstory component and green canopy would be absent or 

drastically reduced, depending on the severity of the fire. For a few decades, the landscape would be dominated 

by blackened, dead standing trees; if allowed to come down on their own, the trees would likely fall in a dense, 

jack-straw pattern. Although short term, smoke from high intensity wildfire would cause scenic quality to be 

diminished and if thick enough, would obscure views to scenic attributes. 

In the short term following high intensity fire, emergency fire suppression actions such as fire lines and 

emergency post-fire rehabilitation treatments could result in unnatural scars on the landscape. With rehabilitation 

and other mitigation measures, the immediate impacts of the suppression and emergency treatments should not be 

evident to the casual forest visitor within 2 to 3 years of completion, although effects from the fire itself would 

remain visible much longer. For two to three growing seasons, the blackened, exposed ground surfaces would be 

highly visible due to lack of vegetation. Sedimentation and erosion would increase, raveling soils that would take 

a long time to revegetate.

Eventually these areas would be covered with spotty vegetation and invasive weeds until native material became 

established. Within 5 years, the effects of the fire would begin to be viewed in a somewhat more positive light as 

the shrubby understory, seedlings and saplings became more abundant. There is some risk that a vegetation type 

change could occur especially if there is wide spread drought, and/or if trends toward higher temperatures, and 

less annual precipitation continue. These changes would be visible throughout the project area in the foreground 

of Forest roads and trails, and as middle ground and background views from communities within the project area, 

and developed recreation sites.

Initial public reaction to a large-scale fire tends to be negative, as many people do not consider extensive, 

blackened landscapes to be natural or beneficial (Ryan 2005). These effects are often perceived by local residents 

as devastating to their community and way of life; non-local forest visitors may regard the effects of a 

uncharacteristic fire as interesting and something “to be seen” but also as a degradation of the scenic quality.

Indirect effects of high intensity wildfire include short term and temporary smoke that would affect nearby 

subdivisions, the City of Williams, and in large, high acreage blazes, could affect the City of Flagstaff, Sedona 

and Verde Valley, Grand Canyon and residents of the Navajo Nation. Effects would include smoky conditions and 
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274 Chapter 3. Affected Environment and Environmental Consequences

decreased visibility, and would last until the fire was contained and declared as “out”. Other indirect effects of 

high intensity wildfire could include damage to the Bill Williams watershed (see section 3.4 of the BWMRP 

DEIS) with subsequent effects to local reservoirs, the City of Williams water system, and the scenic character of 

locally important recreation sites such as Cataract Lake, Kaibab Lake and Dogtown Lake, as well as hiking trails, 

wildlife viewing opportunities and others. 

Under this alternative there would be no opportunities to enhance and improve scenic resources or achieve the 

desired condition because there would be no thinning or other treatments. It would maintain the existing 

landscape character in the short term, but in the long term the existing landscape character would decline. 

This alternative would not meet the project’s desired conditions or forest plan direction. It would not move the 

project area toward scenic stability. Over time, scenic stability would decrease and move to very low. No action 

would result in continuation of current risks to scenic attributes and it is reasonable to assume that these risks 

increase each year and could be exacerbated by climate change. The No Action alternative would not meet longterm scenic integrity objectives since these are dependent upon improving the condition of scenic attributes so 

that they are more resilient to ecological stressors.

Since there is no change in existing condition with this alternative, there are no direct, indirect or cumulative 

effects.

Alternative 2

Preparation of sale areas may have slight effects to scenery from marking trees and project boundaries. These will 

be mitigated by using butt marks on the side facing sensitive travel corridors (bole marks will be facing away 

from sensitive road corridors).

There would be light to extensive effects on scenic quality during and immediately following mechanical 

treatments.

• Hand thinning usually has little or no short term effects on scenery. Trees are cut down, then cut into 

segments that can be treated. Effects may include slash from limbing and topping trees. Project 

mitigations require slash to be treated.

• Conventional or steep slope logging typically has moderate short term effects to scenery. During 

implementation, in most cases whole trees are cut and moved to a “landing” near a haul road. At the 

landing, the limbs and tops are removed, and the clean logs are decked to be loaded and hauled away. 

After vegetation has been thinned, the slash remains. Effects of logging operations typically include 

trampling of vegetation where equipment is operating, creation of linear skid trails where vegetation is 

trampled or completely removed exposing bare soil, creation of linear log landings where vegetation has 

been trampled or removed and bare soil is exposed, and piles of cull logs not suitable for commercial 

uses. After logs or useable material is removed, slash would be treated as per mitigation measures. This 

may include: bulldozers pushing slash into large piles (10-20 foot wide piles, often 10 feet tall) which can 

trample vegetation and cause bare soil to be exposed, hand piling, chipping, crushing, and lopping and 

scattering. Following log removal, activity slash must be treated. Methods may include bunching and 

piling slash mechanically which can trample vegetation and cause bare soil to be exposed, hand piling, 

chipping, crushing, and lopping and scattering. 

• Helicopter systems transport logs or trees to central log decks. Helicopter logging typically has moderate 

to extensive effects on scenery. Trees would be cut and limbed. Logs would have cables attached, then 

would be lifted up and transported away from the cutting area to central locations (log decks) where the 

logs are detached from the cables. Equipment such as grapplers is used at the log decks to stack logs and 

load them into trucks for transport. Effects include scraping and loss of limbs on existing trees as a result 

of adjacent trees being felled or transported, creation of large, cleared landings where logs are decked and 

equipment can be accommodated (moved and turned) and helicopters can be landed.
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Chapter 3. Affected Environment and Environmental Consequences 275

• Following log removal, activity slash must be treated which may include bunching and piling 

mechanically which can trample vegetation and cause bare soil to be exposed, hand piling, chipping, 

crushing, and lopping and scattering. The effects of slash treatment are short term depending on how slash 

is treated. Chipping has the least effects because the chips will begin to grey out and become less 

noticeable in one to two years. Hand piling creates noticeable piles, but after these are burned, there is a 

shorter recovery time than with mechanical piling. Lop and scatter results in untreated slash since it is 

allowed to remain in an area until it is burned. Ryan (2005) found this is not as acceptable as when slash 

is treated either by chipping or piling. 

Road Construction would have moderate to extensive effects on scenic quality during and immediately following 

restoration treatments.

• Construction of approximately 15 miles of new roads to provide access for ground-based logging systems 

will have extensive short term effects on scenery. The new roads would add new, unnatural linear features 

into the landscape. Trees would be removed, soil exposed, and roadbeds constructed including minimal 

drainage features. Some of the new roads would be closed following restoration treatments. The status of 

the new roads that would be closed would change to intermittent. Mitigation measures would be used to 

close entrance points and Best Management Practices for watershed would ensure drainage is adequate 

and the roads would be allowed to naturalize. Mitigation measures and best management practices will be 

used to rehabilitate the road beds. The new roads would naturalize in 5 to 10 years and become less 

noticeable to the casual observer.

• Construction of approximately 16 miles of temporary roads would result in extensive short term effects 

on scenery. Effects are similar to new road construction noted above, although the temporary roads would 

be obliterated after use. Mitigation measures would be used to close entrance points and Best 

Management Practices for watershed would ensure drainage is re-established and the roads can 

rehabilitate. The temporary roads would begin to recover and should be mostly recovered and less 

noticeable to the casual observer in 5 to 10 years. 

• Road obliteration of 23 miles of roads would entail obliteration whereby road surfaces would be ripped 

and seeded or mulched, inside ditches would be filled, road prisms out sloped, culverts and fill materials 

removed, stream crossings re-contoured, unstable side cast or cutslopes removed or stabilized, and 

entrances blocked to prevent future access (see Soils/Watershed Section 3.5). These would have moderate 

short term effects to scenery. Mitigation measures would help return these roads to a more stable status. 

The obliterated roads would begin to recover after treatment and would be mostly recovered and less 

noticeable to the casual observer in 5 to 10 years.

Strategic fuels treatments would have low effects on scenic quality immediately after treatment. 

• Strategic fuels treatments would enhance fire control lines enabling prescribed fire to be safely 

implemented. They include hand thinning or use of machinery equipped with cutting or grinding heads 

300 feet on either side of control lines. Slash is treated within the cleared area, and this becomes the 

staging area for implementing prescribed burning blocks. Effects include short term introduction of linear 

features throughout the area. Upon completion of prescribed burning it is expected that the linear features 

will not be as noticeable because the density of trees on either side of the treatment areas would be 

thinned and/or burned reducing the number of trees. 

Fuels reduction and reintroduction of fire would have moderate effects on scenic quality immediately after 

treatment, and low effects after repeat burning.

• Prescribed fire would be used on approximately 15,200 acres of the project area within all treatment 

areas. It may be used in conjunction with mechanical treatments or singly. The objective of prescribed 

burning is to reduce fuel loading, raise crown base heights and reduce live tree density. Repeat or 

maintenance burning would help maintain these objectives. Depending on fire severity, effects would 

include: charred soil and vegetation immediately following burning; charred bark up to 10 feet from the 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

276 Chapter 3. Affected Environment and Environmental Consequences

ground; needle and leaf scorch typically less than 20 feet from the ground; and, loss of understory trees, 

trees with old scars or trees with large accumulations of dead fuels at their base.

• In areas of moderate to high severity, openings may be created as a result of more extensive tree mortality. 

The presence of charred surface vegetation and red or black trees would present a contrast to the 

otherwise green surroundings. These contrasts would soften and become less noticeable within two or 

three growing seasons after project completion as the understory component (i.e., grass, aspen and oak 

seedlings, etc.) moved in, as singed but not dead trees recovered and greened up, and as dead standing 

trees fell down. Effects may last longer and be more pronounced in areas of moderate to high fire severity, 

but these areas would be localized and limited. Repeat burning would temporarily blacken the forest floor, 

some charred bark, and scorch or burning of some understory trees and shrubs. These effects typically 

soften after one year, and are less noticeable to the casual observer after 2 to 3 years.

• Effects from pile burning would be primarily limited to the immediate dead and live fuels of the slash 

pile, although some scorching and mortality of residual trees would be expected. Following burning, the 

bare areas are susceptible to invasive species. Mitigation measures for invasive species will monitor and 

treat infested areas. The areas are expected to revegetate within 1 to 3 years following burning. 

• Smoke from pile burning and prescribed burning creates short term and temporary effects on scenic 

quality. During implementation, smoke would obscure views of the mountain. Effects to residents and 

visitors to the Williams area may be dissatisfaction that their views are obstructed, and scenic features are 

obscured. Very smoky conditions typically occur during the first entry of prescribed burning due to heavy 

fuel loadings. There can be lingering smoke for two weeks to a month after burning as stumps, large logs 

and roots smolder. Smoke from repeat burns should be less than the initial prescribed burns, since there 

would be less fuel to be consumed. 

There may be indirect effects of smoke as well since it drifts and is pushed by air currents. Nearby developed 

recreation sites, houses and subdivisions, and the community of Williams may experience reduced visibility and 

smoky conditions. Dispersed campers and other recreationists may experience reduced visibility and smoky 

conditions in some places near the project area.

Trails work in this project would have low to moderate effects on scenic quality.

• Activities would include construction of a new parking area and trailhead for Bixler Trail, conversion of a 

portion of FR 45 to a non-motorized trail, and constructing about 1 mile of new trail. Effects would 

include removal of vegetation and construction of new features including the parking lot and installation 

of trailhead signing, placement of barriers, and creation of new trail segments (new linear features). 

Mitigations would include the use of rustic materials (boulders, logs, local surfacing materials) or 

materials that will blend in with the surrounding landscape. The new trail section will be most visible 

immediately after construction when there is the greatest contrast between the bare soil and surrounding 

vegetation. These effects will soften as trailside vegetation is re-established. Conversion of FR 45 to trail 

will reduce the impact of the road since it will be narrowed to a trail. Slash, rocks, and logs will be used to 

obscure the non-trail road width, and over time vegetation will be re-established.

Aspen treatments would have moderate effects on scenic quality.

• Aspen treatments to stimulate new sprouting require fencing to protect the areas from ungulate browsing 

following treatments. Aspen outside of MSO habitat would have invading conifers removed. The project 

includes treatment of aspen and fencing. Fence materials proposed include wire and jack-strawing of 

trees. All would introduce unnatural linear features into the landscape that would not be natural appearing. 

Since these are isolated areas scattered around the project area, introduction of linear features would have 

low effects. Wire and metal posts can be shiny and the color can contrast with the natural surroundings. 

Mitigation measures will be used to introduce the fewest contrasting elements where wire fencing is used 

and effort would be made to locate the site of the fencing where it is least noticeable. Wire fencing would 

have low effects and would meet the SIO.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 277

• Jack-strawing has been used to a limited extent on neighboring forests in order to protect aspen 

restoration projects from ungulate browsing. It involves cutting and stacking high numbers of cut trees in 

an irregular manner to form a wide, tall barrier surrounding the aspen stand. While natural materials 

would be used to create the jack straw, the shape and form created at this scale would not normally be 

found in the characteristic landscape. It would not be completely unnatural however, as it would be 

similar to large scale blow down events that may be caused by weather related events. Placement of jack 

straw treatment would not meet the requirements for foregrounds of high concern level roads in high SIO 

areas. Even if these sites were allowed to drop one SIO level, they would still not meet the basic 

definition of moderate SIO that “noticeable deviations must remain visually subordinate to the landscape 

character being viewed” (Forest Service 2000). 

• Beyond the foreground 300 feet, jack-straw piling may be suitable, and would be mitigated by carefully 

locating these barriers. These area would drop to moderate SIO until the jackstraw barrier begins to 

deteriorate or is burned in follow up prescribe burn activities. Once the aspen are large enough to 

withstand ungulate browsing, and the jackstraw barriers begin to decay, they are not as noticeable; these 

areas will improve to the mapped SIO. The timeline for use of the jack straw piling may exceed the 

projected recovery for the rest of the project area. There may be a need to drop to moderate SIO in jackstraw piled aspen treatments until the trees are large enough to withstand browsing, this could be 15 to 20 

years.

Scenic Integrity Objectives. The scenic integrity objectives for the BWMR project are shown in Figure 3-59. 

Seventy-six percent of the project is in high SIO. 

Overall scenic integrity on Bill Williams Mountain will be lowered during project implementation. There will be 

evidence of new linear corridors as roads are constructed, trail work is completed, and mechanical treatments and 

prescribed burning are implemented. Table 3-72 presents the Scenic Integrity Objectives (SIO) by treatment 

method. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

278 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-59. Forest Plan scenic integrity objectives
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 279

Table 3-72. Scenic integrity objectives for the proposed treatment methods

Treatment 

Methods

High

(Appears Unaltered)*

Moderate

(Appears Slightly Altered)*

No Proposed 

Treatment

0 282

Conventional 8,124 2,981

Helicopter 836 226

MSO core 103 0 

No Mechanized 

Equipment 337 143

Steep Slope 

Mechanical 

1,731

657

Total Acres 11,131 4,289

Interim measures will be used during implementation activities whereby the 11,131 acres in SIO 2 (high) will 

drop to SIO 3 (moderate) until project completion and for 5 to 10 years following. This will ensure adequate time 

for closed and decommissioned roads to naturalize, evidence of logging activities to recover, trailside vegetation 

to re-establish and initial prescribed fire activities to soften.

Aspen treatments are the exception to the timeline for meeting SIO for the BWMR project. In areas where jack 

straw piling is used, these features must stay in place until the trees can withstand browsing. It is estimated that 

where aspen is treated and jack straw piles are used, these areas will not meet desired SIO for 15 to 20 years after 

treatment.

Similarly, the presence of skid trails, landings, and piled or scattered slash would result in a moderate reduction of 

the scenic integrity for the duration of the project. The effects in these areas would not be long-term since skid 

trails would be rehabilitated and activity generated slash would be mitigated in foreground areas, and treated 

throughout the project area. The ground disturbance resulting from using machines to pile slash would be 

noticeable for up to 1 year after project completion, depending on how quickly the areas were rehabilitated and 

vegetation regenerated.

Areas receiving strategic fuels treatments will follow the interim measures and timeline as described above. 

Figure 3-60 shows an example of this type of treatment near Elk Ridge Ski Area just outside of Williams, AZ.

The modified proposed action would improve scenic stability on 15,200 acres within the project, reduce tree 

density, improve age class diversity and would make progress toward structure of woody vegetation. The risk of 

high intensity wildfire would be reduced and fire would be reintroduced into the ecosystem helping to maintain 

the lower tree density. There would be some progress toward having large, old trees well represented, although the 

project area is deficit in this area, and it will take many decades to develop large, old trees to meet this attribute. 

Aspen would be retained as an important scenic attribute, although it will take a couple of decades for stands to 

regain their health. Understory vegetation is expected to improve through use of thinning and prescribed burning. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

280 Chapter 3. Affected Environment and Environmental Consequences

Figure 3-60. Example of strategic fuels treatment near Elk Ridge Ski Area (prior to burning)

The motorized transportation system would be well designed, and some of the new road construction would be 

closed after project implementation and allowed to naturalize. Mixed hardwoods would be retained and their 

health improved as a result of thinning activities. Pinyon-juniper and juniper woodland would receive minor 

treatments since they are at low risk and do not require intensive treatments to meet the purpose and need of the 

project. Similarly, the trailhead and parking lot construction and trail conversion and construction are at low risk 

and will meet project objectives. The proposed treatments in the modified proposed action would meet the Forest 

Plan requirements for scenic integrity in the long term.

Cumulative Effects

The cumulative effects analysis area is the entire Williams Ranger District, Kaibab NF. The timeline for analysis 

is 20 years, 10 years in the past and 10 year into the future. The following is a partial listing of actions considered 

in the cumulative effects analysis for this project:

• Activities such as vegetation management, fuels management, livestock grazing, recreational activities, 

and other management activities (e.g. noxious weeds treatments) have occurred in the past, are occurring, 

and are reasonably foreseeable actions on the district. These activities could occur on private lands as 

well.

• Firewood cutting has occurred in the past and would likely continue in the foreseeable future on the 

district and private lands.

• Private landowners may harvest timber on their lands for lumber or to reduce fire hazards.

• Urban development and interface growth will continue on private lands. 

• Road construction, road maintenance and right-of-way brushing can be expected to continue on nonNational Forest System land. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 281

• Road maintenance, reconstruction, or decommissioning may occur with future vegetation management 

projects.

• Recreation activities are expected to continue to increase on the Forest. Future recreation projects may be 

developed. 

Past and present activities that created the current conditions include grazing, the evolving forest management 

practices related to timber harvest and fire suppression, drought, disease and insect infestations, developed and 

dispersed recreational use and associated developments, and private land in-holdings. The effects associated with 

this project combined with effects from past, present, and reasonably foreseeable future actions would not have a 

measurable cumulative effect on the scenic resources.

Past, present and future vegetation management activities and fuels management activities would have similar 

direct and indirect effects on scenic integrity objectives as found in this project and dotted across the Williams 

Ranger District. Cumulatively, it is expected there would be minor fluctuations in scenic quality as projects are 

implemented and recover. Overall, the result of vegetation and fuels activities is to stabilize scenic attributes and 

assure their presence into the future.

Livestock grazing has minor cumulative effects on scenic integrity. Construction of fencing or other 

improvements may decrease scenic integrity in small, localized areas that would be distributed across the district.

Urban development and interface growth will continue on private lands as the population of Arizona continues to 

grow, but Williams, AZ has not grown as fast as cities near the Phoenix metro area or Tucson. These will have 

slight effects on scenic integrity but are limited to private land parcels in the area.

Recreation activities and developments have remained fairly stable on the district according to the National 

Visitor Use Monitoring surveys (Forest Service 2012). The effects of these activities, especially those related to 

motorized cross country travel are expected to decline. Travel Management has been implemented which 

prohibits motorized cross country travel and restricts travel to the designated open system of roads, trails and 

areas. Dispersed camping will continue to be a popular activity, but is restricted by Travel Management as well. 

Recreation opportunities will continue to be offered and it is expected that recreation use will grow slowly with 

minimal effects to scenic integrity.

Road construction and maintenance on forest and non-forest lands will continue. Travel Management reduced the 

number of roads open to motorized travel on forest lands. It is anticipated that there will be very little new road 

construction in the future. The cumulative effects of the existing road system and maintenance activities will have 

minor additional effects to scenic integrity. Decommissioning of roads will improve landscape character and 

scenic integrity.

Overall, the cumulative effects of this project and those analyzed will result in some improvement to the scenic 

integrity on the district.

Alternative 3

Preparation of sale areas may have slight effects to scenery from marking trees and project boundaries. These will 

be mitigated by using butt marks on the side facing sensitive travel corridors.

Mechanical Treatments. There would be light to extensive effects on scenic quality during and immediately 

following mechanical treatments.

• Hand thinning usually has little or no short term effects on scenery. Trees are cut down, and then cut into 

segments that can be treated. Effects may include slash from limbing and topping trees. Project 

mitigations require slash to be treated.

• Conventional logging typically has moderate short-term effects to scenery; these would be the same as 

with Alternative 2. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

282 Chapter 3. Affected Environment and Environmental Consequences

• Helicopter systems transport logs or trees to central log decks. Helicopter logging typically has moderate 

to extensive effects on scenery; these would be the same as with Alternative 2.

Road Construction would have moderate to extensive effects on scenic quality during and immediately following 

restoration treatments. The effects are the same as for Alternative 2, the modified proposed action.

Strategic fuels treatments would have low effects on scenic quality immediately after treatment. The effects would 

be the same as for Alternative 2, the modified proposed action. 

Fuels reduction and reintroduction of fire would have moderate effects on scenic quality immediately after 

treatment, and low effects after repeat burning.

Prescribed fire would be used on approximately 14,710 acres of the project areas within Operability Zones 1-7 

except within the Arizona Bugbane Botanical Area. It may be used in conjunction with mechanical treatments or 

singly. The objective of prescribed burning is to reduce fuel loading, raise crown base heights and reduce live tree 

density. Repeat or maintenance burning would help maintain these objectives. Effects would be the same as for 

Alternative 2, the modified proposed action, but about 4 percent less of the area would show fire effects.

Trails work in this project would have low to moderate effects on scenic quality. The effects would be the same as 

for Alternative 2, the modified proposed action. 

Aspen treatments would have moderate effects on scenic quality and the effects would be the same as for 

Alternative 2, the modified proposed action. 

Scenic Integrity Objectives. Overall scenic integrity on Bill Williams Mountain will be lowered during project 

implementation. There will be evidence of new linear corridors as roads are constructed, trail work is completed, 

and mechanical treatments and prescribed burning are implemented. Table 3-73 presents the Scenic Integrity 

Objectives (SIO) by Operability Zone for Alternative 3.

Table 3-73. Scenic Integrity Objectives by Operability Zone for Alternative 3

Operability Zone SIO 2 Acres SIO 3 Acres

Conventional-01 6,870 1,873

Steep Conventional-02 651 299

Adverse Forwarder-03 68 0 

Excaline with Forwarder Swing 

Skid-04

0 0 

Skyline Yarding-05 0 0 

Mixed Conventional-06 620 783

Helicopter-07 2,925 1,023

Total Acres* 11,134 3,978

Interim measures will be used during implementation activities whereby the 11,134 acres in SIO 2 (high) will 

drop to SIO 3 (moderate) until project completion and for 5 to 10 years following. This will ensure adequate time 

for closed and decommissioned roads to naturalize, evidence of logging activities to recover, trailside vegetation 

to re-establish and initial prescribed fire activities to soften.

Aspen treatments are the exception to the timeline for meeting SIO for the BWMR project. In areas where jack 

straw piling is used, these features must stay in place until the trees can withstand browsing. It is estimated that 

where aspen is treated and jack straw piles are used, these areas will not meet desired SIO for 15 to 20 years after 

treatment.

Effects for scenic integrity objectives are the same as for Alternative 2.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 283

Effects for scenic stability are the same as for Alternative 2.

Cumulative Effects

The cumulative effects are the same as Alternative 2.

Alternative 4

Preparation of sale areas may have slight effects to scenery from marking trees and project boundaries. These will 

be mitigated by using butt marks on the side facing sensitive travel corridors.

Mechanical Treatments. There would be light to extensive effects on scenic quality during and immediately 

following mechanical treatments. 

• Hand thinning usually has little or no short term effects on scenery. Trees are cut down, then cut into 

segments that can be treated. Effects may include slash from limbing and topping trees. Project 

mitigations require slash to be treated.

• Conventional logging typically has moderate short short-term effects to scenery. During implementation, 

in most cases, whole trees are cut and moved to a “landing” near a haul road. At the landing, the limbs 

and tops are removed, and the clean logs are decked to be loaded and hauled away. After vegetation has 

been thinned, the slash is piled using bulldozers. Effects typically include trampling of vegetation where 

equipment is operating, creation of linear skid trails where vegetation is trampled or completely removed 

exposing bare soil, creation of linear log landings where vegetation has been removed and bare soil is 

exposed, and piles of cull logs not suitable for commercial uses. After logs or useable material is 

removed, slash would be treated as per mitigation measures. This may include bulldozers pushing slash 

into large piles (10-20 foot wide piles, often 10 feet tall) which can trample vegetation and cause bare soil 

to be exposed, hand piling, chipping, crushing, and lopping and scattering. 

Road Construction would have moderate to extensive effects on scenic quality during and immediately following 

restoration treatments.

• Construction of approximately 38 miles of temporary roads would result in extensive short term effects 

on scenery. Effects are similar to new road construction noted above, although the temporary roads would 

be obliterated after use. Mitigation measures would be used to close entrance points and Best 

Management Practices for watershed would ensure drainage is re-established and the roads can 

rehabilitate. The temporary roads would begin to recover and should be mostly recovered and less 

noticeable to the casual observer in 5 to 10 years.

• Road obliteration of 28 miles of roads would entail obliteration whereby road surfaces would be ripped 

and seeded or mulched, inside ditches would be filled, road prisms out sloped, culverts and fill materials 

removed, stream crossings re-contoured, unstable side cast or cutslopes removed or stabilized, and 

entrances blocked to prevent future access (see Soils/Watershed Section 3.5). These would have moderate 

short short-term effects to scenery. Mitigation measures would help return these roads to a more stable 

status. The obliterated roads would begin to recover after treatment and would be mostly recovered and 

less noticeable to the casual observer in 5 to 10 years.

Strategic fuels treatments would have low effects on scenic quality immediately after treatment. 

• Strategic fuels treatments would enhance fire control lines enabling prescribed fire to be safely 

implemented. They include hand thinning or use of machinery equipped with cutting or grinding heads on 

300 feet either side of control lines. Slash is treated within the cleared area, and this becomes the staging 

area for implementing prescribed burning blocks. Effects include short short-term introduction of linear 

features throughout the area. Upon completion of prescribed burning it is expected that the linear features 

will not be as noticeable because the density of trees on either side of the treatment areas would be 

thinned and/or burned reducing the number of trees. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

284 Chapter 3. Affected Environment and Environmental Consequences

Fuels reduction and reintroduction of fire would have moderate effects on scenic quality immediately after 

treatment, and low effects after repeat burning.

• Prescribed fire would be used on approximately 14,710 acres of the project area except in the Arizona 

Bugbane Botanical Area. It may be used in conjunction with mechanical treatments or singly. The 

objective of prescribed burning is to reduce fuel loading, raise crown base heights and reduce live tree 

density. Repeat or maintenance burning would help maintain these objectives. Effects are the same as for 

Alternative 2, but about 4% less area would be burned. 

Aspen treatments would have moderate effects on scenic quality.

• Aspen treatments to stimulate new sprouting require fencing to protect the areas from ungulate browsing 

following treatments. Aspen outside of MSO habitat would have invading conifers removed. The project 

includes treatment of aspen and fencing. Fence materials proposed include wire and jack-strawing of 

trees. Effects would be the same as Alternatives 2 and 3.

Scenic Integrity Objectives. Overall scenic integrity on Bill Williams Mountain will be lowered during project 

implementation. There will be evidence of new linear corridors as roads are constructed, trail work is completed, 

and mechanical treatments and prescribed burning are implemented. Table 3-74 presents the Scenic Integrity 

Objectives (SIO) by Operability Zone. 

Table 3-74. Scenic integrity objectives by operability zone for Alternative 41

Treatment Methods

High

(Appears Unaltered)

Moderate

(Appears Slightly Altered)

No Treatment 5,288 1,282

Conventional 6,868 1,872

Mixed Conventional 620 783

Steep Slope Conventional 625 328

Total Acres 13,401 4,289 

1 Acres are approximate. 

Alternative 4 would result in fewer acres showing effects to scenic integrity from mechanical thinning than either 

action alternative (2 or 3). Interim measures will be used during implementation activities whereby the 8,113 

acres in SIO 2 (high) will drop to SIO 3 (moderate) until project completion and for 5 to 10 years following. This 

will ensure adequate time for closed and decommissioned roads to naturalize, evidence of logging activities to 

recover, trailside vegetation to re-establish and initial prescribed fire activities to soften.

Aspen treatments are the exception to the timeline for meeting SIO for the BWMR project. In areas where jack 

straw piling is used, these features must stay in place until the trees can withstand browsing. It is estimated that 

where aspen is treated and jack straw piles are used, these areas will not meet desired SIO for 15 to 20 years after 

treatment.

The presence of skid trails, landings, and piled or scattered slash would result in a moderate reduction of the 

scenic integrity for the duration of the project. The effects in these areas would not be long-term since skid trails 

would be rehabilitated and activity generated slash would be mitigated in foreground areas, and treated 

throughout the project area. The ground disturbance resulting from using machines to pile slash would be 

noticeable for up to 1 year after project completion, depending on how quickly the areas were rehabilitated and 

vegetation regenerated.

Scenic Stability. Alternative 4 would improve scenic stability on 15,200 acres within the project but not to the 

extent that Alternatives 2 and 3 would. This alternative would make less progress in reducing tree density and 

improving age class diversity and would require mechanical treatment sooner than the other action alternatives. It 

would make progress toward structure of woody vegetation since logging would be prohibited on slopes steeper 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 285

than 40%. The risk of high intensity wildfire would be reduced and fire would be reintroduced into the ecosystem 

helping to maintain the lower tree density, but in 4% less of the area. There would be less progress toward having 

large, old trees well represented, although the project area is deficit in this area, and it will take many decades to 

meet this attribute. Similarly, aspen will be retained as an important scenic attribute, although it will take a couple 

of decades for stands to regain their health.

Understory vegetation is expected to improve somewhat, although since less of the area would be thinned, fewer 

openings would be created. There is also a chance that it there will be more trees killed and more large openings 

created from prescribed burning since less area will be thinned. The motorized transportation system will use 

more temporary roads and will continue to use the poorly placed existing road system. Temporary roads and those 

identified for obliteration will naturalize. Mixed hardwoods would be retained but there would be little 

improvement in their health since less area would be thinned. Pinyon-juniper and juniper woodland would receive 

minor treatments since they are at low risk and do not require intensive treatments to meet the purpose and need 

of the project. Similarly, the trailhead and parking lot construction and trail conversion and construction are at low 

risk and will meet project objectives.

Cumulative Effects

The cumulative effects are the same as Alternatives 2.

3.13 Cultural and Tribal Resources 

3.13.1 Cultural Resources and Heritage Desired Future Conditions

Under the previous Kaibab National Forest Plan the focus of the Heritage Program was to protect and preserve 

cultural resources in accordance with the National Historic Preservation Act of 1966 as amended. Under the 2014 

Forest Plan, the Kaibab National Forest Heritage Program desired conditions and standards were expanded to 

specifically include the management of Traditional Cultural Properties and also to include the following:

• Cultural resources, including known traditional cultural properties, are preserved, protected, or restored. 

• Historic artifacts are preserved in situ or, when necessary, curated following current standards.

• All historic properties are evaluated for their eligibility to the National Register and properties that are 

appropriate are listed to the National Register of Historic Places.

• Cultural resource findings will be synthesized and shared with the scientific community and public 

through formal presentations, publications, and educational venues. 

• Public understanding about the cultural resources and historic preservation issues contribute to their 

protection. 

• The Kaibab NF historic documents, including photographs, maps, journals, and Forest Service program 

management records, are available to the public for research and interpretation.

• Traditional practitioners have access to TCPs for ceremonial use and privacy to conduct ceremonies.

• TCPs are preserved protected, or restored for their cultural importance and generally free of impacts from 

other uses. 

• The significant visual qualities of TCPs are preserved consistent with the TCP eligibility determination.

• Traditional use of TCPs by the associated cultural groups is accommodated. 

• Confidential and/or sensitive information regarding TCPs is protected.

3.13.2 Affected Environment

Kaibab National Forest archaeologists developed a sampling design for this project (Woodard 2012) based on 

guidelines in Appendix J of the First Amended Programmatic Agreement between the Arizona, Texas, New 

Mexico, and Oklahoma State Historic Preservation Officers, and the Advisory Council on Historic Preservation 

(Programmatic Agreement, USDA 2010) and the 4FRI Heritage Resource Strategy (Gifford 2011). Based on low 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

286 Chapter 3. Affected Environment and Environmental Consequences

site density and the unlikelihood of cultural resources occurring on slopes greater than 40%, the Arizona SHPO 

concurred with Kaibab National Forest archaeologists on 12/8/2012 that a sample survey was more than adequate 

since previous inventory already exceeded the recommended 25 to 50% survey requirement outline in the 

aforementioned Four Forest Restoration Initiative (4FRI) Heritage Resource Strategy and 4FRI NHPA 

Compliance Report (Gifford 2011). 

In response to the planned activities archaeologists surveyed an additional 1069 acres bringing the total amount of 

survey to 8659 acres or 66% of the project area. Archaeologists identified five isolated occurrences and 18 new 

sites. Of these 13 are eligible for inclusion on the National Register, four remain unevaluated, and one is 

recommended as ineligible at this time. The total number of sites from new and previous survey is 117 of which 

65 are eligible for inclusion to the National Register, 45 have not been evaluated at this time and will be treated as 

eligible, 6 are not eligible, and one is currently being recommended as ineligible.

The most common archaeological site types are prehistoric structures with 1 to 2 rooms. Other site types 

documented included pit houses, rock shelters, food gathering and processing centers, lithic scatters, and 

agricultural features. Historic sites are associated with Route 66, the Bill Williams Lookout Tower and the historic 

Civilian Conservation Corps built Clover Ranger Station and Bill Williams Trail.

TCP National Register Integrity and Tribal Concerns

The entire project encompasses the Bill Williams Mountain Traditional Cultural Property (TCP) that is eligible to 

the National Register of Historic Places for its importance to five of the Kaibab’s consulting tribes. Although the 

mountain is overgrown with trees and shrubs, the integrity of the TCP currently remains intact as tribes still have 

an integral relationship to the mountain for the collection of plant resources and ceremonial use.

Although the proposed treatment of the mountain will significantly alter the mountain visually, a stand replacing 

fire would have lasting and devastating effects to traditional use of the mountain and its culturally important plant 

resources. The tribes agree with the Forest Service’s assessment that current conditions in the project area pose 

long-term risks to the mountain and also to cultural and traditional resources. The tribes support the purpose and 

need of the project and have indicated that the proposed project activities will not impact integrity of relationship 

and condition related to the TCP. Through government-to-government consultation (see Section 4.1), the 

Havasupai Tribe, Hopi Tribe, Hualapai Tribe, Navajo Nation, and Yavapai-Prescott Indian Tribe have supported 

the purpose and need of the Bill Williams Restoration and helped develop mitigation measures listed in Section 

2.4.5 to ensure no adverse effects to the TCP. 

The Kaibab National Forest has been consulting with tribes on the management of Bill Williams Mountain for 

over 20 years. During that time, tribal representatives have stated a number of general concerns related to 

management of the mountain. These concerns are summarized as follows: 

• Concerns with impacts to the visual quality of Bill Williams Mountain, 

• Concerns with commercial development of the mountain, 

• Disruption of ceremonial activities related to the mountain and ensuring access for those activities, 

• Impacts to important medicinal plants and other traditional use resources, 

• Protection of specific ceremonial sites, 

• Protection of ancestral sites/archaeological sites, 

• Overall forest health on the mountain, 

• Impacts to the integrity of the Bill Williams Mountain traditional cultural property,

• Monitoring of important plant resources

• Impacts to threatened and endangered species.

Consultation specific to the project (see Section 4.1) has resulted in three additional concerns regarding 

management of the mountain: 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 287

• Concerns with impacts to the watershed, particularly to Cataract Creek, Havasu Creek and the village of 

Supai, AZ, 

• A desire for direct monitoring of the project by Tribes, and 

• Access to timber and thinning slash for traditional use and fuelwood.

3.13.3 Direct and Indirect Effects

Alternative 1 – No Action

Under the no action alternative, project managers would not implement prescribed burns or mechanical vegetation 

treatments that involve felling, killing or removing trees in the 15,200-acre project area. If activities associated 

with the Bill Williams project were not implemented, mitigation measures to address cultural resources and TCP 

issues and concerns would no longer be necessary.

Direct Effects. The continued deposition of fuels in the area would increase the likelihood of a high intensity 

uncharacteristic wild fire on Bill Williams Mountain. It is likely that the Bill Williams Mountain Traditional 

Cultural Property, its scenic integrity, plants collected by tribes and used for ceremonial purposes, many of the 

prehistoric sites and especially the few historic sites with combustible features would suffer adverse effects from 

intense fire behavior. 

Indirect Effects. Under this alternative, fuels would continue to accumulate on and around cultural resource sites 

increasing the likelihood of a devastating fire on Bill Williams Mountain. The revised Kaibab National Forest 

Plan (2014) makes note of this issue, “In recent years, most adverse impacts to heritage resources are caused by 

high-intensity, stand-replacing wildfire and increased erosion associated with such fires.”

Due to the steepness of the slopes of Bill Williams Mountain above known cultural resources, those sites that 

survived an uncharacteristic fire would then be exposed to the threat of severe erosion and flooding. Post fire 

flooding and erosion have been shown to have adverse effects on archaeological sites, especially when a fire 

occurs on steep slopes. A nearby example of the effects of unforeseen erosion is the 2000 Pumpkin Fire on 

Kendrick Mountain (Weintraub et al. 2002). These same effects would also adversely affect the Bill Williams 

Traditional Cultural Property by affecting the collection of plants used for medicinal and ceremonial purposes, 

and would have a long-term and devastating effect on the scenic integrity of Bill Williams Mountain.

Cumulative Effects. Under the No Action Alternative, hazardous fuels would continue to accumulate in the 

project area, cumulatively leaving cultural and tribal resources at risk to the effects of stand-replacing fires.

Alternative 2 – Modified Proposed Action

Under the modified proposed action alternative, project managers would implement prescribed burns and 

mechanical vegetative treatments on up to 15,200 acres. Project managers could use mechanical timber harvesting 

and piling, pre-commercial thinning, roundwood, sawtimber thinning, and hand piling, fuelwood sales, helicopter 

logging, crushing and prescribed burns to achieve forest health and sustainability and reduce the risk of 

uncharacteristically intense stand-replacing wild fire. These actions would require ground disturbing equipment 

and fire to move across the land. In addition, Alternative 2 includes the construction of 15 miles of new roads and 

16 miles of temporary roads that would be obliterated after use. Another 28 miles of poorly located roads would 

also be obliterated. Finally, a new 1 mile section of trail and trailhead parking lot area would be built along Forest 

Road 122. 

Direct Effects. Under Alternative 2, 65 cultural resource sites and one TCP are eligible for the National Register 

of Historic Places and another 45 are unevaluated for the Register that could be affected by the project’s activities. 

Reducing the amount of dead and down woody debris, ladder fuels, and unnaturally high tree density would 

greatly reduce the risk of effects to cultural resource sites from stand replacing wildfire. However, the activities 

associated with treatments including skidding, crushing, road construction and obliteration under this alternative 

could potentially affect cultural resource sites adversely. Heavy machinery used to build roads and skid trees 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

288 Chapter 3. Affected Environment and Environmental Consequences

across sites can result in impacts that include rutting, erosion, dislocation or breakage of artifacts and features, and 

the general destruction of sites and site stratigraphy. Prescribed burning also has the potential to affect fire 

sensitive sites by directly igniting those with flammable materials such as those constructed with wood. These 

potential effects are addressed through site avoidance strategies and implementing the site protection mitigation 

measures outlined in Section 2.4.5 of this report and agreed to in the cultural resources consultation with the State 

Historic Preservation Office (Woodard 2012) that will result in no adverse effects to cultural resources.

As noted above, the area has low site density, and surveys focused on areas around springs, where sites were most 

likely to occur. There may be undiscovered sites that would be exposed to the effects stated above. However, 

Kaibab timber marking crews are well-versed in identifying cultural resources, often helping archaeologists paint 

site boundaries. Prior to each sale, archaeologists discuss what types of sites might be encountered in both 

surveyed and unsurveyed areas.

Direct effects to the TCP are similar; logging will open the forest canopy and alter its scenic integrity, potentially 

impact plants collected for ceremonial and medicinal use, and potentially disrupt ceremonies. See Section 3.9 for 

details how the project’s activities can affect rare plants that are on the Mountain. With regards to the Mountain’s 

scenic integrity, the effects are discussed at length in Section 3.12. As a result of close coordination with 

consulting tribes, Tribal staff has designed mitigation measures (see Section 2.4.5) to ensure the long term 

traditional and ceremonial use of the mountain. 

Indirect Effects. Initial reduction of heavy fuels may lead to an increase in site visibility, public visitation, and 

possible vandalism. Those issues are reduced through management actions that include project specific as well as 

long term monitoring. Initial entry prescribed burns are periodically revisited and burned to reduce natural fuel 

accumulation and archaeological site monitoring is part of that process. Possible road decommissioning can also 

assist in limiting access to some archaeological sites thus reducing post-burn visibility and visitation at those sites. 

It also reduces the threat of the public interfering with traditional Native American uses of the Traditional Cultural 

Property. 

Alternative 3

Alternative 3 differs only very slightly from the modified proposed action. It includes helicopter activities on the 

steep slopes of Bill Williams Mountain. It also removes prescribed fire from 490 acres due to the Arizona 

Bugbane Botanic Area and creates 22 miles of new roads, constructs 16 miles of temporary roads that would be 

obliterated after use, and would obliterate 24 miles of poorly located roads. Direct and indirect effects to cultural 

resources and the TCP are the same as those in Alternative 2.

Alternative 4

Alternative 4 differs from Alternative 3 as it does not include helicopter activities on the steep slopes of Bill 

Williams Mountain. This also removes the logging of 70 acres near the top of the mountain. There would be no 

new road construction under this alternative; however, the main difference is that it includes 38 miles of 

temporary road construction that would be obliterated after use, and the obliteration of 24 miles of poorly located 

roads. The Bixler Saddle Trail would not be constructed. 

The number of cultural resources within the area of potential direct and indirect effects is the same as those in 

Alternative 2; however, because the steep slopes of Bill Williams Mountain would not be treated, the TCP and 

most cultural resources would be vulnerable to the effects of post fire flooding and erosion below those steep 

slopes. 

3.13.4 Cumulative Effects 

It is the goal of the Bill Williams Restoration project to reduce the risk of stand-replacing wildfire on the 

mountain. This in turn reduces the likelihood of adverse effects from a stand-replacing wildfire to cultural 

resources, the Bill Williams Mountain Traditional Cultural Property, its scenic integrity, and plants important to 

and collected by Native American cultures. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 289

Over the past 25 years, due to the steepness of its terrain, few projects have been implemented on Bill Williams 

Mountain. The main project that has occurred in the area is the Twin Prescribed Burn that has been ongoing over 

the past 10 years to reduce hazardous fuels on the slopes of Bill Williams Mountain. This project will continue 

into the foreseeable future. The Bill Williams Cap project which was implemented in 2011 and 2012 was a fuels 

reduction project that thinned and piled dense trees around the communication towers at the top of the mountain 

with no adverse effect to the Traditional Cultural Property. 

Over the next 10 years the area surrounding Bill Williams Mountain is proposed for treatments under the Four 

Forest Restoration Initiative which also has the goal of reducing the risk of stand-replacing wildfire and 

improving forest health on the slopes below the Bill Williams Restoration project area. Surrounding the Bill 

Williams project are the McCracken and City Vegetation treatment areas, projects also slated to improve forest 

health over the next 10 years.

The recently implemented Travel Management Rule (2010) has limited the areas where the public can drive off 

road, thus reducing road densities and the adverse effects that can occur from erosion to cultural resources, the 

Bill Williams Mountain Traditional Cultural Property, its scenic integrity, and the cultural values of plants 

important to and collected by Native American cultures. As the Travel Management Rule greatly reduced the 

number of roads the public could drive on, it also reduced the threat of the public accessing cultural resources. It 

also reduces the threat of the public interfering with traditional Native American uses of the Traditional Cultural 

Property. 

Cumulatively cultural and tribal resources may be affected by the Bill Williams Mountain Restoration, when the 

effects of the action alternatives are added to the effects of the past, present and future projects. However, since all 

projects go through the Section 106 consultation process with both the Arizona State Historic Preservation Office 

and concerned Tribes, effects are minimized and therefore the cumulatively the effects would not be adverse.

3.14 Implementation Economics

3.14.1 Introduction, Methodology, and Analysis Process

This report evaluates and discloses the project implementation economics for four alternatives proposed for the 

Bill Williams Restoration Project. 

Implementation of the Bill Williams Mountain project would require several types of activities. Costs to 

undertake these activities have been estimated using a variety of methods. The activities that have been analyzed 

for and the methodology that was used to estimate their costs are: 

Net Timber Value

Net timber value is the value of the timber to be harvested as it stands on the stump; it is also referred to as 

stumpage value. This is the monetary amount that a contractor would be willing to pay the government for the 

timber or the amount that the contractor would need to be paid in order to harvest and haul the timber from the 

site. The analysis in this document does not consider the cost of road construction, road obliteration or any Forest 

Service costs as part of the net timber value calculations.

In May of 2012, the Forest Service awarded the Four Forest Restoration Initiative (4-FRI) stewardship contract. 

This contract specifies a product value for each geographic working circle within the 4-FRI contract area. 4-FRI 

will be the major market for timber produced from the Williams Ranger District until at least 2021, which will be 

the end of the current contract period. The value of timber in the working circle that the Bill Williams Mountain 

Restoration Project is located within, is a positive $3.50/green ton for logs greater than 5 inches on the small end 

(i.e. the contractor pays the government for the timber) The material that is smaller than this, including limbs and 

tops, has a negative value of $3.50/green ton (i.e. the government pays the contractor $3.50/green ton to remove 

this material from the site).
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

290 Chapter 3. Affected Environment and Environmental Consequences

This EIS assumes that these product values indicate the current market value for timber cut on the Bill Williams 

Mountain Restoration Project for ground based harvesting. However due to the steep and unroaded terrain on 

much of the Bill Williams Mountain Restoration Project, more expensive logging systems capable of working on 

these steep slopes, such as steep slope harvester/forwarder and helicopter are under consideration. These systems 

would have a higher logging cost than conventional ground based logging. 

Conventional ground based logging has the lowest logging cost per ton of any logging system. In order to account 

for the cost of these higher priced systems and the effect they have on net timber value, logging cost was 

calculated for all systems and net timber value was adjusted to reflect the increased cost of these more expensive 

logging systems. For example if a ground based logging cost is calculated to be $25/ton and has a product value 

of $3/ton and a helicopter logging system has a cost of $90/ton, then this increased cost would be subtracted from 

the ground based product value of $3/ton to show the net timber value of the timber harvested with a helicopter 

system. This calculation would be: $3/ton (product value of a ground based system) minus $65/ton (increased 

cost of a helicopter system) equals, a negative $62/ton product value for the timber harvested with a helicopter 

system.

Total stem volume of all trees were used in logging cost calculations.

It is estimated that of the standing stem volume in the project area, 80 percent is sawlog size with a value to the 

government of $3.50/ton, and 20 percent is smaller than this with a value to the government of negative $3.50/ton. 

This yields a composite value of approximately $2/ton for stem material logged. It is also estimated that limbs 

comprise a tonnage equal to 20% of the total stem weight of trees that will be cut. These limbs will be brought in 

from the harvest units attached to boles during logging. Under the 4-FRI contract as an example for the value of 

stumpage this material has a negative value of $3.50/ton. Logging costs were estimated using the Forest Service’s 

log cost program (USDA FS, version 13.1) and in some cases adjusted for special circumstances. 

Cultural Resource Survey Cost

Prior to project implementation, within logging units, archaeologists must mark known cultural resource sites for 

protection. In addition, archaeologists will survey all proposed road construction and/or roads to be obliterated, 

they will mark sites for protection from road construction and/or obliteration activities, and write a clearance 

report to assure no adverse effects to cultural resources. These costs were provided by the Williams District 

archaeologist, based on past experienced costs.

Sale Preparation Cost

Sale preparation costs are all costs associated with locating harvest units, timber marking and timber cruising. 

These costs were provided by the Williams District timber management officer based on past experienced costs. 

Sale Administration Cost

This is the cost to supervise the logging done by a contractor and to administer the contract. These costs were 

estimated by the Williams District timber management office based on past experienced costs.

Road Engineering Cost

This is the cost to design and engineer the roads required to implement the project. It was estimated by using 

costs per mile found in the inter-regional road cost guide.

Road Construction/Obliteration Cost- This is the estimated cost for a contractor to actually build required roads 

and obliterate other roads that are not needed or are temporary roads. It was estimated using the costs provided in 

the inter-regional cost guide.

Road Construction/Obliteration Administration Cost

This is the cost to supervise the work of constructing and obliterating roads and to administer the contract with a 

contractor. It was estimated by the Coconino-Kaibab zone forest engineer. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 291

Strategic Fuel Break Construction Cost

This is the cost to construct strategic fuel breaks on Bill Williams Mountain. They would also be used as control 

lines for proposed prescribed burning. It was estimated by the Williams District assistant fire management officer 

(fuels) based on past experienced costs.

Prescribed Burning Cost

This is the cost to carry out prescribed burning excluding the cost of constructing fuel breaks. It was estimated by 

the Williams District assistant fire management officer (fuels) based on past experienced costs.

3.14.2 Affected Environment

The Kaibab National Forest currently operates and funds programs for vegetation management, forest products, 

cultural resources, engineering, and fuels management, among others. Funding for these programs come from 

annual Congressional appropriations to the USDA Forest Service, and then is further allocated to the USFS 

Southwest Region and Kaibab National Forest. Funding levels in recent years have been generally flat to 

declining, although trends are somewhat variable between the various National Forest program areas. Receipts 

resulting from National Forest timber sale contracts are deposited in the federal treasury. As an alternative to 

timber sales, the Forest Service currently has Stewardship Contracting authority, which provides a legal 

mechanism for exchanging the value of goods (such as forest products) for service work (such as pre-commercial 

thinning). When the value of goods such as merchantable timber in a given stewardship contract is less than the 

cost of the service work in that project, agency appropriated federal funding can be available through an 

Integrated Resource Service Contract (IRSC). IRSCs allow for the Forest Service to pay a contractor to carry out 

work on National Forest lands when the value of the goods does not cover the cost of the service work, which can 

include logging costs. 

3.14.3 Environmental Effects

Alternative 1- No Action

Direct and Indirect Effects.

Net Timber Value: No logging would be done under this alternative and no cost incurred or timber value 

generated.

Cultural Resource Survey Cost: No heritage survey would be done under this alternative and no cost incurred. 

Sale Preparation Cost: No sale preparation would be done under this alternative and no cost incurred. 

Sale Administration Cost: No sale administration done would be under this alternative and no administrative 

cost incurred.

Road Engineering Cost: No road engineering would be done under this alternative and no cost incurred. 

Road Construction: No road construction would be done under this alternative and no cost incurred. 

Road Obliteration Cost: No road obliteration would be done under this alternative and no cost incurred. 

Road Construction/Obliteration Administration Cost: No road construction or obliteration would be done 

under this alternative and no administrative cost incurred.

Strategic Fuel Break Construction Cost: No strategic fuel breaks would be constructed under this alternative 

and no cost incurred. 

Prescribed Burning Cost: No prescribed burning would be done under this alternative and no cost incurred. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

292 Chapter 3. Affected Environment and Environmental Consequences

Cumulative Effects. Cumulative effects do not apply to costs; costs are not effects. There would be no 

cumulative environmental effect under this alternative.

Alternative 2- Modified Proposed Action

Direct and Indirect Effects. 

Net Timber Value

Net timber value under this alternative is a negative $1,674,174. Logging cost calculations for Alternative 2 are 

shown in Table 3-75. 

Table 3-75. Logging cost summary Alternative 2

Logging 

System

Stump to 

Truck Cost 

($/Ton)

Volume/ac

(Tons) Acres

Total

Volume

(Tons)

Timber 

Value 

($/Ton)

Net Timber 

Value by 

Logging 

System ($)

Ground-based 

Mechanical

25 28 11,100 310,800 2 621,600

Steep Slope 

Ground-based

30 18 2,400 43,200 (3) (129,600)

Helicopter 120 18 1,060 19,080 (93) (1,774,440)

Total Stem 

Wood

14,560 373,080 (1,282,440)

Non-stem 

Biomass

111,924 (3.50) (391,734)

Total 485,004 (1,674,174)

Cultural Resource Survey Cost

Marking cultural resource sites: 160 hours @ $31/hour = $4,960 

Surveying new road locations for cultural resources: 752 acres of road @ $30/acre = $22,560 

Total Cultural Resource Survey Cost = $27,520 

Sale Preparation Cost 

13,500 acres of ground based sale preparation @ $102/acre = $1,377,000 

1,060 acres of helicopter sale preparation @ $143/acre = $151,580 

Total sale preparation cost = $1,528,580 

Sale Administration Cost

14,560 acres of timber sale to administer @ $136/acre = $1,980,160 

Total Sale Administration Cost = $2,067,200 

Road Engineering Cost 

15 miles of new permanent road @ $3,500/mile = $52,500 

16 miles of temporary road @ $500/mile = $8,000 

Total Road Engineering Cost = $60,500 

Road Construction/Obliteration Cost 

New permanent road construction, 15 miles @ $13,999/mile = $209,985 

New temporary road construction and obliteration, 16 miles @ $10,773 = $172,368 

Existing road obliteration, 23 miles @ $3,526/mile = $81,098 

Total road construction and obliteration cost = $463,451 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 293

Road Construction/Obliteration Administration Cost 

31 miles of construction, permanent and temporary @ $960/mile = $29,760 

39 miles of obliteration, existing and new temporary @ $480/ mile = $18,720 

Total Road Administration Cost = $48,480 

Strategic Fuel Break Construction Cost

2,500 acres of strategic fuel breaks would be constructed with an estimated cost of $700/acre 

Total cost = $1,750,000 

Prescribed Burning Cost 

11,150 acres of slopes under 30% @ $100/acre =$1,115,000 

4,050 acres of slopes over 30% @ $250/acre = $1,012,500 

Total prescribed Burn cost = $2,127,500 

Cumulative Effects. Cumulative effects do not apply to costs; costs are not effects. There would be no 

cumulative environmental effect under this alternative.

Alternative 3

Direct and Indirect Effects. 

Net Timber Value 

Net timber value under this alternative is a negative $15,186,877. Logging cost calculations for Alternative 3 are 

shown in Table 3-76. 

Table 3-76. Logging cost summary Alternative 3

Logging 

System

Stump to 

Truck Cost 

($/Ton)

Volume/ac

(Tons) Acres

Total

Volume

(Tons)

Timber 

Value 

($/Ton)

Net Timber 

Value by 

Logging 

System ($)

Ground-based 

Mechanical

25 25 11,099 277,475 2 554,950

Cut to length 33 14 68 952 (6) (5,712)

Helicopter 1,467 3 3,713 11,139 (1,440) (16,040,160)

Total Stem 

Wood

14,880 289,566 (15,490,922)

Non-stem 

Biomass

86,870 (3.50) (304,045)

Total 376,436 (15,186,877)

Cultural Resource Survey Cost

Marking cultural resource sites: 160 hours @ $31/hour = $4,960 

Surveying new road locations for cultural resources: 921 acres of road @ $30/acre = $27,630 

Total Cultural Resource Survey Cost = $32,590 

Sale Preparation Cost 

11,167 acres of ground based sale preparation @ $102/acre = $1,139,034 

3,713 acres helicopter sale preparation @ $143/acre = $530,959 

Total sale preparation cost = $1,669,993 

Sale Administration Cost
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

294 Chapter 3. Affected Environment and Environmental Consequences

14,880 acres of timber sale to administer @ $136/acre = $2,023,680 

Total Sale Administration Cost = $2,023,680 

Road Engineering Cost 

22 miles of new permanent road @ $3,500/mile = $77,000 

16 miles of temporary road @ $500/mile = $8,000 

Total Road Engineering Cost = $85,000 

Road Construction/Obliteration Cost 

New permanent road construction, 22 miles @ $13,999/mile = $307,978 

New temporary road construction and obliteration, 16 miles @ $10,773 = $172,368 

Existing road obliteration, 24 miles @ $3,526 = $84,624 

Total road construction and obliteration cost = $564,970 

Road Construction/Obliteration Administration Cost 

38 miles of construction, permanent and temporary @$960/mile = $36,480 

40 miles of obliteration, existing and new temporary @ $480/ mile = $19,200 

Total Road Administration Cost = $55,680 

Strategic Fuel Break Construction Cost

2,500 acres of strategic fuel breaks would be constructed with an estimated cost of $700/acre

Total cost = $1,750,000 

Prescribed Burning Cost 

11,150 acres of slopes under 30% @ $100/acre =$1,115,000 

3,560 acres of slopes over 30% @ $350/acre = $1,246,000 

Total prescribed Burn cost = $2,361,000 

Cumulative Effects. Cumulative effects do not apply to costs; costs are not effects. There would be no 

cumulative environmental effect under this alternative.

Alternative 4

Direct and Indirect Effects. 

Net Timber Value 

Net timber value under this alternative is a positive $263,599. Logging cost calculations for Alternative 4 are 

shown in Table 3-77. 

Table 3-77. Logging cost summary Alternative 4

Logging 

System

Stump to 

Truck Cost 

($/Ton)

Volume/ac

(Tons) Acres

Total

Volume

(Tons)

Timber 

Value 

($/Ton)

Net Timber 

Value by 

Logging 

System ($)

Ground-based 

Mechanical

25 25 11,099 277,475 2 554,950

Total Stem 

Wood 

277,475 554,950

Non-stem 

Biomass

83,243 (3.50) (291,351)

Total 360,718 263,599
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 295

Heritage Survey Cost

Marking cultural resource sites: 160 hours @ $31/hour = $4,960 

Surveying new road locations for cultural resources: 897 acres of road @$30/acre = $26,910 

Total Cultural Resource Survey Cost = $31,870 

Sale Preparation Cost 

11,099 acres of ground based sale preparation @ $102/acre = $1,132,098 

Total Sale Preparation Cost = $1,132,098 

Sale Administration Cost

11,099 acres of timber sale to administer @ $136/acre = $1,509,464 

Total Sale Administration Cost = $ 1,509,464 

Road Engineering Cost 

38 miles of temporary road @ $500/mil = $19,000 

Total Road Engineering Cost = $19,000 

Road Construction/Obliteration Cost 

New temporary road construction and obliteration, 38 miles = $519,066 

Existing road obliteration, 24 miles = $84,624 

Total road construction and obliteration cost = $603,690 

Road Construction/Obliteration Administration Cost 

38 miles of construction, temporary @$960/mile = $36,480 

42 miles of obliteration, existing and new temporary @ $480/ mile = $20,160 

Total Road Administration Cost = $56,640 

Strategic Fuel Break Construction Cost

2,500 acres of strategic fuel breaks would be constructed with an estimated cost of $700/acre

Total cost = $1,750,000 

Prescribed Burning Cost 

11,150 acres of slopes under 30% @ $100/acre = $1,115,000 

3,560 acres of slopes over 30% @ $350/acre = $1,246,000 

Total prescribed burn cost = $2,361,000 

Cumulative Effects. Cumulative effects do not apply to costs; costs are not effects. There would be no 

cumulative environmental effect under this alternative.

Alternative Comparison 

A comparison of costs to implement this project is shown in Table 3-78. All costs are subtracted from net timber 

value to arrive at a total cost to implement the project. Alternatives 2 and 3 show a negative net timber value, 

while alternative 4 shows a positive net timber value. All of the action alternatives analyzed require funding to 

implement.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

296 Chapter 3. Affected Environment and Environmental Consequences

Table 3-78. Estimated Implementation Costs by Alternative

Alternative 1 Alternative 2 Alternative 3 Alternative 4

Net Timber Value 0 (1,674,174) (15,186,877) 263,599

Cultural Resource Survey 

Cost

0 22,560 32,590 31,870

Sale Preparation Cost 0 1,528,580 1,669,993 1,132,098

Sale Administration Cost 0 1,980,160 2,023,680 1,509,464

Road Engineering Cost 0 60,500 85,000 19,000

Road 

Construction/Obliteration 

Cost

0 463,451 564,970 603,690

Road 

Construction/Obliteration 

Administration Cost 

0 48,480 55,680 56,640

Strategic Fuel Break 

Construction Cost

0 1,750,000 1,750,000 1,750,000

Prescribed Burning Cost 0 2,127,500 2,361,000 2,361,000

Cost of Implementation (not 

including net timber value)

0 7,981,231 8,542,913 7,463,762

Net Timber Value 0 (1,674,174) (15,186,877) 263,599

Costs of Implementation 

(not including net timber 

value)

0 7,981,231 8,542,913 7,463,762

Total Implementation Cost: 

Net Timber Value minus 

Cost of Implementation 

0 9,655,405 23,729790 7,200,163

3.15 Socio Economics 

3.15.1 Affected Environment

The City of Williams is the closest incorporated community to the Bill Williams Restoration Project area. In fact, 

the city limits extends to the top of Bill Williams Mountain. There are many private landowners and residents that 

live within and adjacent to the project area. Many of these residents live next to forest conditions classified by the 

Forest Service as high fire risk due to high tree densities and unnaturally high fuel loads. Fuelwood cutters, 

hunters, grazing permittees, and recreationists use the project area. The principal economic activities in this area 

of Coconino County occur with federal, state, and local governments, retail trade, and the service sector. The trade 

and service sectors are oriented toward tourism. Commercial timber cutting and livestock grazing are enterprises 

that represent minor components of the economic environment. 

The communication site on top of Bill Williams Mountain provides important communications to all of northern 

Arizona. This multi-million dollar site provides communications for a number of local, county, state and federal 

entities. A disruption in services could jeopardize public safety for several months. A dollar value was not 

estimated, but the disruption in services could cost tens of thousands of dollars for the building and tower owners, 

which includes the Federal Government building and tower. The situation immediately following a fire that 

destroyed or severely damaged the communication site would be chaotic to say the least. 

Bill Williams Mountain is the primary watershed for the City of Williams and provides a major water source for 

residents. A high-intensity fire could result in reservoirs filling with sediment which would render the water 

system that depends on surface water useless for a year or more. Water would probably have to be trucked or 

brought in by rail cars to sustain the local residents. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 297

Costs for implementing the project that remain fairly constant for the action alternatives include cultural resource 

surveys, sale preparation, sale administration, road engineering, road construction and obliteration, strategic fuel 

break construction and prescribed burning. 

The cost that would vary would be the net value for the timber. Net timber value is the value of the timber to be 

harvested as it stands on the stump; it is also referred to as stumpage value. This is the monetary amount that a 

contractor would be willing to pay the government for the timber or the amount that the contractor would need to 

be paid in order to harvest and haul the timber from the site. Recent timber sales harvested by ground based 

logging methods on the Williams District have generated a positive value of approximately $3/CCF, (i.e. the 

contractor pays the Forest Service for the timber). 

Different types of logging systems have different costs associated with them. Ground based logging generally has 

the lowest cost per CCF harvested when compared to other logging systems such as steep slope or helicopter. 

Logging costs for other harvest methods were calculated and the cost difference between that cost and the cost for 

ground based logging was used to adjust net timber values up or down. The cost of all logging systems were 

estimated by using the USDA Forest Service’s log cost program, (version 11.0). 

3.15.2 Direct and Indirect Effects

Not all benefits and costs to society can be quantified. Revenues from forest products such as sawtimber have 

been assigned dollar values based on current markets and are quantifiable. Other resources such as watershed 

health, riparian health, wildlife abundance and diversity, long-term habitat improvement, social benefits, and 

scenic resources cannot easily be assigned dollar values. Under any of the action alternatives, this proposed 

project would have a sustained economic impact rather than a changing economic impact. 

Alternative 1 - No Action

Under this alternative, management and recreational activities in the area would continue, i.e., fuelwood 

gathering, hunting, and grazing. The risk of high-intensity stand-replacing wildfires would remain high, as well as 

the risk of the consequences that go along with such an event, including the loss of recreational settings and 

opportunities, loss of visual/scenery aesthetic values, loss of wildlife habitat, and the potential loss of public and 

private property. There would be no new economic benefits (i.e., new jobs, income, or tax revenue) associated 

with the no-action alternative. 

Under the no-action alternative, there would be no thinning or prescribed burning. The project area would remain 

at risk for a high-intensity stand-replacing fire. High-intensity stand-replacing wildfires can incur high costs 

associated with suppression, post fire rehabilitation, and reforestation. Post-fire rehabilitation, including 

emergency soil stabilization and replanting, have high per-acre costs. Stand-replacing wildfires also cause losses 

to Forest resources, which can have economic effects in the form of reduced tourism dollars and loss of 

commercial wood products. For comparison, the Shultz Fire on the San Francisco Peaks north of Flagstaff, 

Arizona was approximately 15,000 acres in size, roughly the same size of our project area. 

Suppression costs for the Schultz Fire were approximately $10 million. The USDA Forest Service spent about 

$4.1 million on Burned Area Emergency Response (BAER) costs, with another $1 million to rehabilitate roads. 

And the Forest Service spent another $500,000 to complete the rehabilitation in the past two years. Coconino 

County spent $4-5 million to control sediment and erosion and has received a grant for an additional $8 million 

for flood control. The total expenditures to date are between $25-30 million. These figures do not include money 

spent by the utility companies and homeowner losses due to the flooding (Personal Communication with Mike 

Elson, Flagstaff District Ranger (May 2012). A similar fire on Bill Williams Mountain would be devastating to the 

City of Williams and the local economy for many years. 

Alternative 2 – Modified Proposed Action

Under Alternative 2, there would be some short-term (one to ten years in any one area) effects on the social 

environment while commercial sales and follow-up activities are under way. These primarily include: a modest 
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298 Chapter 3. Affected Environment and Environmental Consequences

increase in fire hazard until harvest-generated slash is cleaned up; minor noise and human disturbance to wildlife 

during timber sale operations; some noise disturbance to adjacent private land residents; light log truck traffic on 

haul routes; and potential decrease in the quality of recreational experiences due to noise and the presence of 

equipment. There would be economic benefits (i.e., new jobs, income, or tax revenue) associated with these 

alternatives. The estimated cost for implementing this alternative is approximately $9.7 million. These costs 

include the net timber value minus the cost of implementation. This alternative would reduce hazardous fuels and 

fire risk more than the other action alternatives and would result in the least potential loss of other resources 

(DEIS, Section 3.13). 

Alternative 3

Alternative 3 differs from the Modified Proposed Action in that less hazardous fuels would be removed from the 

project area. There would be no reference condition thinning around the base of the mountain, but there could be 

an increase in the helicopter logging acres. This reduction in timber removed around the base of the mountain and 

the increase in helicopter use increases the total implementation costs to approximately $23.7 million (DEIS, 

Section 3.13). 

Alternative 4

Alternative 4 is considered the “least mechanical” of the action alternatives. There would be no helicopter 

logging, and no new road construction. Only temporary roads would be built and then obliterated under this 

alternative. There would be no reference condition thinning around the base of the mountain, as in Alternative 3. 

The reduction in the logging and road building activities decreases the total implementation costs to 

approximately $7.2 million (DEIS, Section 3.13). 

3.15.3 Cumulative Effects

Alternative 1 – No Action. Implementing Alternative 1 would have no cumulative effect on the social and 

economic environment of the Williams Ranger District as there would be no changes in current management and 

recreational activities in the project area. The risks associated with taking no action within this project area would 

remain high until new vegetation management projects designed to reduce fuel loading and tree densities are 

implemented in this area.

Alternatives 2, 3, and 4. When combined with the direct and indirect effects of past, present and reasonably 

foreseeable activities in the project area, implementation of either action alternative would have some minor 

short-term adverse impacts on the social environment. However, implementation of any action alternative in 

conjunction with past, present and reasonably foreseeable vegetation management projects would help the Forest 

reduce fuel loading and the risk of high-intensity fires. This would also help maintain or boost the timber industry 

in the state and in turn help generate jobs and tax revenues for local economies. 

3.16 Lands and Minerals 

3.16.1 Affected Environment

The scope of this analysis focuses on the Lands resource located on the steep portion (over 40% slope) of the 

mountain, specifically, the Bill Williams Mountain Communication Site on top of Bill Williams Mountain and the 

electrical transmission and fiber optic lines that support the communication site on the east side of the project 

boundary. Since much of Bill Williams Mountain was withdrawn from minerals entry in 1963 (Public Land Order 

3147 dated 7/30/1963), there are no minerals resources affected by this project. 

The top of Bill Williams Mountain has been used as a fire lookout and communication site since the 1950’s and 

serves as a critical link in the communication and distribution networks of a wide variety of public safety, 

industrial and commercial users, as well as residents of Williams and Northern Arizona. Current development 

includes 11 buildings and 14 towers. Each of these facilities have a backup power source that include batteries 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 299

(both wet and gel cell), and hydrogen, propane or diesel powered generators. Some of these facilities are multipleuse, meaning they can house tenants, and some are single use.

The building and tower owners include Niles Radio, Verizon Wireless, SBA Communications, the Burlington 

Northern and Santa Fe Railway, KTVK-TV, Century Link/Qwest Corporation, Arizona Public Service, Arizona 

Department of Public Safety and the United States Government building that houses the Forest Service, the 

Federal Aviation Administration, U. S. Customs and Border Protection and the Federal Bureau of Investigation. 

The current replacement value of each building and tower combination is estimated to be approximately $1.5 

million dollars, which does not take into account the purchase of the lease site or the potential temporary 

disruption of service. This dollar figure only represents replacement value of the building and tower. 

The use and occupancy of the non-Forest Service owned facilities are authorized by 30-year communications use 

leases issued by the Kaibab National Forest. Ownership and maintenance responsibility for the structures belong 

to the lessee, but the Kaibab National Forest manages and maintains responsibility for the land and surrounding 

vegetation.

There is an overhead 12.5kV electrical power line owned by Arizona Public Service and a fiber optic phone line 

owned by Century Link/Qwest Corporation located within the same 20-foot wide right-of-way on the east side of 

the mountain serving the communication site as an ancillary improvement. Both of the electrical and fiber optic 

lines are very fire and heat sensitive.

The most relavant past activity that has affected the existing condition is the Bill Williams Cap Project, which was 

a fuels reduction project implemented on 6 acres in 2010. The Cap Project resulted in fuels reduction on all 

species up to 9” diameter and several large trees over 9” diameter also were removed that impinged on the 

communication facilities. This was a move in the right direction, however, trees would need to be thinned and/or 

grouped together upwards of one mile radius from the mountaintop to really reduce the wildfire threat from 

below. 

3.16.2 Existing Condition

The existing condition for the communication site on top of the mountain can best be described as heavy fuel 

loadings due to dense stand conditions and a very high potential for damage or complete destruction from 

uncharacteristic wildfire from below (DEIS, Appendix E). Part of the communication site is located within a 

Mexican Spotted Owl (MSO) Protected Activity Center, which has some of the highest basal areas on the 

mountain. There is much dead and downed fuels and continuous tree crowns which could lead to devastating 

crown fires. The Cap project helped to thin some of the trees surrounding the communication site, but large trees 

are still interfering with communications by restricting beam paths. 

The electrical and fiber optic lines on the east side of the project area have a 20-foot right-of-way that has been 

cleared by APS, however, these lines are susceptible to smoke and heat from burning. There have been some 

thinning and prescribed burning projects on slopes less than 40% in this area (City and Twin), but there is still a 

threat from wildfire. 

3.16.3 Direct, Indirect, and Cumulative Effects

Alternative 1 –No Action

The direct and indirect effects of implementing Alternative 1 are a continuation of the risk of uncharacteristic 

wildfire because of the high fuel loadings and dense stand conditions that exist under current conditions. There is 

a high probability that an uncontrolled wildfire will burn to the top of the mountain and damage or destroy one or 

more of the facilities at the communication site at the top. There is also a high probability that a wildfire will 

damage or destroy the electrical power and fiber optic lines on the east side of the mountain. If fuels are not 

reduced under a controlled manner, the risk of damage to the communication site and electrical and fiber optic 

lines increases over time.
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300 Chapter 3. Affected Environment and Environmental Consequences

When combined with the past, present, and reasonably foreseeable future actions in the area, the cumulative 

effects of implementing Alternative 1 are an increase in risk of damage or destruction to the communication site, 

as there would be no reduction to the fuel load on the mountain. There is also an increase in the risk of damage, 

or destruction, to the supporting power and fiber optic lines on the east side of the project area because fuel 

loading and dense stand conditions will increase over time on the steep (over 40%) part of the project area. 

Alternative 2 –Modified Proposed Action

The direct and indirect effects of implementing Alternative 2 are a greatly reduced threat to the communication 

site and electrical and fiber optic lines. This alternative reduces the largest amount of fuels on the steep part of the 

mountain which directly reduces the chance of a uncharacteristic wildfire that could damage or destroy the 

facilities on the mountaintop. The reintroduction of fire into the ecosystem as maintenance burning will continue 

to reduce fuel buildup leading up to the communication site and the power and fiber optic lines on the east side of 

the project area.

When combined with the past, present, and reasonably foreseeable future actions in the area, the cumulative 

effects of implementing Alternative 2 are a reduction of the risk of damage, or destruction, of the communication 

site from uncharacteristic wildfire. This is due to the stands on the steep slopes of the mountain being thinned and 

the reintroduction of smaller intensity, more frequent fires into the ecosystem. The smaller and more frequent 

fires would continue to reduce the risk of destruction of the communication site, by a large wildfire, over the next 

twenty years.

Alternative 3

The direct and indirect effects of implementing Alternative 3 are the same as Alternative 2 because the only real 

change is in the logging systems used to reduce fuel loading.

The cumulative effects of implementing Alternative 3 are the same as Alternative 2.

Alternative 4

The direct and indirect effects of implementing Alternative 4 are less likely to reduce fuel loading to an acceptable 

level because mechanized equipment will not be used, so a substantial amount of fuel will remain in place. The 

risk to the communication site and power and fiber optic lines will be less than Alternative 1, but greater than 

Alternatives 2 and 3. 

When combined with the past, present, and reasonably foreseeable future actions in the area, the cumulative 

effects of implementing Alternative 4 are a reduction in fuel loading and risk to the communication site, to a lesser 

degree than Alternatives 2 and 3, because there will still be high fuel loadings and a high risk to the 

communication site and associated support facilities.

3.17 Other Disclosures 

3.17.1 Environmental Justice

On February 11, 1994, President Clinton issued Executive Order 12898, "Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations." This Executive Order was 

designed to focus the attention of federal agencies on the human health and environmental conditions in minority 

and low-income communities. It requires federal agencies to adopt strategies to address environmental justice 

concerns within the context of existing laws, including NEPA. The goal of Environmental Justice Analysis is not 

to shift risks among populations, but to identify potential disproportionately high and adverse effects, and to 

identify alternatives that may mitigate these impacts.

One way that this is achieved is by providing an opportunity for minority and low-income populations to 

participate in planning, analysis, and decision making. Individual tribal members may use the project area for the 

personal collection of traditional or medicinal plants. Low-income groups may use the area for the collection of 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 301

fuel wood. None of the alternatives would have disproportionate adverse effects on these uses or to low income 

and minority populations in the area. No concerns or issues related to Environmental Justice were raised during 

project scoping. Additionally, the American Indian Tribes listed in Chapter 4 were consulted regarding this 

proposal and potential effects were analyzed.

Alternative 1 – No Action

The no action alternative does not reduce the risk of high-intensity, stand-replacing wildfire. Although all 

communities, wealthy and poor, suffer direct economic consequences when there are large wildfires, normal 

commercial activity can be disrupted. Many of the low-income jobs in the area are connected to tourism. Even a 

temporary loss of work can overwhelm low-income individuals and families. Fires can also reduce the availability 

of native plants and building supplies that sustain many traditional and indigenous communities. 

A

Alternative 2, 3 and 4

ny of the action alternatives would reduce fuel loading and the risk of high-intensity fires. Even though there 

could be direct economic consequences associated with fires, the disruption to normal commercial activity would 

be less than the no action alternative. 

Direct, Indirect and Cumulative Effects. All action alternatives would reduce the risk of high-intensity standreplacing wildfires, which would better protect the area resources and the communities that they serve.

3.17.2 Short-term Uses and Long-term Productivity

NEPA requires consideration of “the relationship between short-term uses of man’s environment and the 

maintenance and enhancement of long-term productivity” (40 CFR 1502.16). As declared by the Congress, this 

includes using all practicable means and measures, including financial and technical assistance, in a manner 

calculated to foster and promote the general welfare, to create and maintain conditions under which man and 

nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and 

future generations of Americans (NEPA Section 101). 

The proposed project was developed to promote forest diversity on Bill Williams Mountain while reducing the 

risk of high intensity fire so the area will be ecologically sustainable and contribute to social and economic 

stability of the surrounding area. The biggest risks to Bill Williams Mountain are the effects associated with 

uncharacteristic stand-replacing fire (discussed in the “Fire and Fuels Management” section of this chapter) and 

resulting soil losses (discussed in the “Soil and Watershed” section of this chapter), degradation of the watershed 

for the City of Williams, reduced wood production (discussed in the “Silviculture” section of this chapter), loss of 

wildlife habitat (discussed in the “Wildlife” section of this chapter) and the potential interruption of important 

communications (discussed in the “Lands and Minerals” section of this chapter). There are differences in 

alternatives that would result in more or less modification of stand structure and fuel loading which correlates to 

ecosystem diversity and the risk of fire. 

3.17.3 Unavoidable Adverse Effects

Under Alternative 2 only, approximately 8,900 acres of ponderosa pine forest surrounding the base of Bill 

Williams Mountain would have reduced stand densities similar to pre-settlement reference conditions. Alternative 

2 also would result in the largest reduction in large trees initially, but then remaining trees would grow faster due 

to increased sunlight, nutrients and water (DEIS, Section 2.5). 

Alternatives 3 and 4 move less than half of the project area to the historic fire regime range. Alternative 2 would 

result in more than half the area available for direct attack tactics and Alternative 3 and 4 would result in less than 

half the area available for direct attack tactics (DEIS, Sections 2.5 and 3.3). 

All of the action alternatives would result in a short term increase in particulate matter from burning. There would 

also be short term increases in soil disturbance, erosion potential and soil compaction (DEIS, Sections 2.5 and 

3.4). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

302 Chapter 3. Affected Environment and Environmental Consequences

The action alternatives would result in short term reduction of Mexican Spotted Owl habitat, but Alternative 2 

moves toward the most sustainable conditions. Under Alternatives 2-4, the area moves from the most to least 

protection of nest area and PFA’s from active crown fires (DEIS, Sections 2.5 and 3.6). 

The action alternatives would also result in a temporary reduction in forest visitors, and short term effects to 

scenery management due to the mechanical treatments (DEIS, Sections 2.5, 3.10 and 3.11). 

Alternative 4 would result in the most increase in risk to cultural resource sites from flooding and erosion 

following high intensity fires (DEIS, Sections 2.5 and 3.12). 

Alternative 2 would result in the greatest short term potential increase in weeds.

3.17.4 Irreversible and Irretrievable Commitments of Resources

An irreversible commitment of a resource is one that cannot be regained, such as the extinction of a species. An 

irretrievable commitment is one where the value of the resource is lost for a period of time, such as the loss of soil 

productivity. Based on analysis found in chapter 3 of the FEIS, alternative 2 will have the following irreversible 

commitment of soils resources.

• Permanent road construction would commit areas incorporated into road prisms to non-productive status 

for the forseeable future (i.e., at least 50 years). Based on a traveled way width of 14 feet and a clearing 

width of 6 feet on each side of the traveled way for ditches and fill slopes, approximately 48 acres of land 

would be removed from timber and forage production under alternative 2. 

• The proposed Bixler Trailhead and parking area would be approximately 0.25 acres in size and 

constructed in TES map unit 537. This portion of TES map unit 537 would therefore be removed from 

productivity for the foreseeable future (i.e., 50 years). The parking area would consist of native fill 

material and would be constructed using appropriate best management practices and soil and water 

conservation practices to minimize adverse impacts to surface water.

A likely result of Alternative 1—is a high intensity stand-replacing wildfire. The effects of such a fire as described 

in chapter 3 would result in long-term changes to the landscape that would be both irreversible and irretrievable 

Post-fire effects that require decades of recovery would be irretrievable in the short term and potentially the long 

term. For example, topsoil which is critical to healthy surface vegetation would take centuries to recover. The loss 

of old growth and old trees would be irretrievable as it would require decades and centuries to recover. When 

considered with climate change, it is unknown exactly what the ecological trajectory would be for the replacement 

of old growth and old trees. 

3.17.5 Cumulative Effects

Cumulative effects for each resource area are addressed in their respective sections of Chapter 3. There are interrelationships of cumulative effects between the Silviculture, Fire and Fuels Management Soils and Watershed, and 

the Wildlife sections. 

3.17.6 Other Required Disclosures

NEPA at 40 CFR 1502.25(a) directs “to the fullest extent possible, agencies shall prepare draft environmental 

impact statements concurrently with and integrated with other environmental review laws and executive orders.”

• Fish and Wildlife Service under the Fish and Wildlife Coordination Act for causing water to be 

impounded or diverted; 

o This project will not result in water becoming impounded or diverted so consultation is not required 

under the Fish and Wildlife Coordination Act. 

• National Historic Preservation Act for causing ground disturbing actions in historical places; 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 3. Affected Environment and Environmental Consequences 303

o Consultation with the Arizona State Historic Preservation Office has occurred and concurrence on the 

project has been reached.

• U.S. Fish and Wildlife Service and the National Marine Fisheries Service in accordance with the ESA 

implementing regulations for projects with threatened or endangered species; 

o Consultation, coordination and discussions with the U.S. Fish and Wildlife Service have been 

ongoing since this project began in the Fall 2010. An informal brainstorming session was held in 

Flagstaff, AZ in mid-January 2011 to discuss and seek input about the project design. A formal 

comment letter was received on May 23, 2011 on the proposed action and a meeting was held in our 

office on June 23, 2011 to discuss their comments. A meeting was held in our office on July 13, 2011 

to continue the coordination and development of the project and alternatives. There was a field trip to 

the project area to discuss Pine Oak Target/Threshold habitat and the Arizona Bugbane population on 

June 23, 2011 and August 23, 2011. Another meeting was held in our office on October 11, 2011 to 

discuss desired conditions and recommendations for MSO habitat. 

• Any applicable Arizona State and Coconino County laws affected by the alternatives;

o There are no Arizona State or Coconino County laws affected by this project. 

Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 4. Consultation and Coordination 305

Chapter 4. Consultation and Coordination

4.1 Preparers and Contributors 

The USDA Forest Service consulted the following individuals, Federal, State, and local agencies, tribes and nonUSDA Forest Service persons during the development of this environmental assessment. 

4.1.1 ID Team Members

Katherine Sánchez Meador ID Team Leader, NEPA Specialist

Marcos Roybal NEPA and GIS Specialist; ID Team Leader

Richard Gonzalez Silviculturist

Justin Schofer Wildlife Biologist/ Botany Specialist

Mike Uebel Fuels Specialist

Christopher MacDonald Soils and Hydrology 

Bob Rich Logging Specialist, Regional Office

Danelle Harrison District Ranger

Deirdre McLaughlin Lands and Minerals Specialist 

Jesarey Barela Rangeland Specialist

Lisa Jones Recreation Forester

Neil Weintraub Archaeologist 

Mike Lyndon Assistant Forest Archaeologist/Forest Tribal Liaison

Micah Grondin Timber Staff

Holly Krake Fire Information Officer

Ed Monin Assistant Forest Engineer

4.1.2 Federal, State, and Local Agencies

U. S. Fish and Wildlife Service 

Arizona Game and Fish Department 

City of Williams

Arizona Department of Transportation

Grand Canyon National Park 

4.1.3 Tribes 

Havasupai Tribe

Hopi Tribe

Hualapai Tribe

Navajo Nation

Kaibab Band of Paiute Indians 

Yavapai-Prescott Indian Tribe

Pueblo of Zuni

4.1.4 Others

Ponderosa Fire Advisory Council (PFAC) 

Wildland Fire Advisory Council (WFAC) 

Coconino County Board of Supervisors 

Grand Canyon Trust

Bill Williams Mountain Communication Site Improvement Association 

Northern Arizona University

Ecological Restoration Institute (ERI)
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

306 Chapter 4. Consultation and Coordination

4.2 List of Agencies, Organizations and Persons to Whom Copies of 

the DEIS, SDEIS, and FEIS Were Sent 

This environmental impact statement has been distributed to individuals who specifically requested a copy of the 

document [(for FEIS only) and those who submitted substantive comments on the DEIS or SDEIS]. In addition, 

copies of the SDEIS 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 Bill Williams Mountain 

Restoration Project.

United States Fish and Wildlife Service

Arizona State Game and Fish Department

City of Williams

Havasupai Tribe

Hopi Tribe

Hualapai Tribe

Kaibab Band of Paiute Indians 

Navajo Nation

Yavapai-Prescott Indian Tribe

Pueblo of Zuni

4.3 Tribal Consultation Summary 

Government-to-government consultation with tribes is guided by a variety of existing laws, regulations, and 

policies, including the National Environmental Policy Act (NEPA), the Archaeological Resources Protection Act 

(ARPA), the National Historic Preservation Act (NHPA), the American Indian Religious Freedom Act (AIRFA), 

the Native American Graves Protection and Repatriation Act (NAGPRA), the National Forest Management Act 

(NFMA) of 1976, the Religious Freedom Restoration Act (RFRA), Executive Order 13007-Indian Sacred Sites, 

Executive Order 13175-Consultation and Coordination with Indian Tribal Governments, and Executive Order 

12898- Environmental Justice. The Kaibab National Forest has entered into Memoranda of Understanding with 

the Havasupai Tribe, the Hualapai Tribe, the Hopi Tribe, and the Kaibab Band of Paiute Indians to establish a 

standard process for consultation with each tribe. 

Area tribes have strong cultural ties to lands now managed by the Kaibab National Forest and maintain valuable 

traditional knowledge about the sustainable management of those lands. Tribal members regularly come to the 

Kaibab National Forest to gather resources for traditional uses and to visit ancestral and sacred sites. Due to the 

cultural and historic importance of Bill Williams Mountain to numerous tribes, the Kaibab National Forest has 

conducted extensive tribal consultation and scoping of tribal communities throughout the environmental analysis 

process. 

Tribal consultation for this project was conducted at the government-to-government level according to established 

Memoranda of Understanding and existing laws and regulations. Additionally, the Forest scoped tribal 

communities that utilize the forest. The Kaibab initiated consultation with tribes in the earliest stages of analysis, 

and incorporated tribal comments into the development of the Alternatives. A summary of tribal consultation 

regarding the project is included in Table 4-1. 

Table 4-1. Summary of tribal consultation on the Bill Williams Restoration Project

Tribe Location What occurred

9/14/10 Havasupai

Hopi

Hualapai

Flagstaff, AZ At 4th Annual Intertribal Meeting, District Ranger Martie 

Schramm briefed tribal representatives on project and invited 

early participation from tribes in environmental analysis

11/03/10 Havasupai

Hopi

Hualapai

Kaibab Band of Paiute

Navajo

Letter District Ranger Martie Schramm sent a letter to tribes with 

notification of the project and invitation for early involvement in 

planning process.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 4. Consultation and Coordination 307

Tribe Location What occurred

Yavapai-Prescott

Pueblo of Zuni

12/02/10 Havasupai

Hopi

Hualapai

Kaibab Band of Paiute

Navajo

Yavapai-Prescott 

Pueblo of Zuni and 

seven Navajo Chapters

Letter Forest Supervisor Mike Williams sent a letter to tribes inviting 

them to participate in the early planning process.

2/15/11 Yavapai-Prescott Prescott Forest officials met with the Tribe and provided tribal 

representative with a list of known plants for circulation within 

the tribe. Yavapai-Prescott is supportive of reducing threats of 

uncharacteristic fire on mountain.

2/16/11 Hualapai Tribe Peach Springs Forest officials met with the Tribe and provided tribal 

representatives with a list of known plants for circulation within 

the tribe. Hualapai Tribe would be interested in conducting 

plant surveys in the project area.

2/23/11 Pueblo of Zuni Zuni, NM Forest officials met with the Tribe. Pueblo of Zuni expressed 

interest in project and requested field visit to project area. 

Pueblo of Zuni request common names for plants in project 

area.

2/24/11 Navajo Nation Window Rock Forest representatives met with the Navajo Nation. Navajo 

Nation supports a project to restore the mountain and voiced 

concerns about potential impacts from additional road 

construction. Navajo Nation requests a field trip to project area 

and additional information on watershed impacts. Navajo 

Nation generally supports reducing fuels on Bill Williams Mt and 

other TCPs to prevent uncharacteristic wildfire. 

3/7/11 Havasupai Tribe Flagstaff Forest representatives met with the Tribe regarding other 

issues. Forest representatives notified the Tribe of project.

4/21/11 Havasupai

Hopi

Hualapai

Kaibab Band of Paiute

Navajo

Yavapai-Prescott 

Pueblo of Zuni

NA Forest emailed Notice of Intent and invitation to public meeting. 

Forest invited tribes to conduct field visits of project area.

7/21/11 Hopi Tribe Project Area Williams District Ranger Martie Schramm and other Forest staff 

conducted a site visit to the project area with cultural advisors 

from the Hopi Tribe. Hopi voiced support for the project and 

stated it would protect the mountain and resources from future 

wildfire.

11/1/11 Havasupai Tribe Project Area Williams District Ranger Martie Schramm and other Forest staff 

conducted a site visit to the project area with the Havasupai 

Tribe. Havasupai representatives supported the project and 

requested specific mitigation measures as outlined below.

1/26/12 Navajo Nation Flagstaff, AZ Forest officials met with Navajo Nation to discuss the range of 

Alternatives and the proposal for new roads in the Preferred 

Alternative. Navajo Nation supports the Preferred Alternative. 

Navajo Nation requests mitigation measure to GPS plants with 

traditional significance during implementation. 

6/14/2012 Hopi Tribe Prescott, AZ The Hopi Cultural Preservation Office and Kaibab staff copresented at the Arizona Historic Preservation Office on the 

project, and collaborative management of the Mountain by the 

Forest and Tribe.

9/09/2012 Hopi Tribe Kykotsmovi, 

AZ 

The Forest Supervisor and staff provided an update on the 

DEIS. Hopi Tribe supports these types of projects.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

308 Chapter 4. Consultation and Coordination

Tribe Location What occurred

9/20/2012 Navajo Nation Window Rock, 

AZ 

The Forest Supervisor and staff provided an update on the 

DEIS. Navajo supports the Preferred Alternative and identified 

culturally important plants in the project area. 

9/20/2012 Pueblo of Zuni Zuni, NM The Forest Supervisor and staff provided an update on the 

DEIS. Zuni is interested in the results of plant surveys 

conducted by Hualapai Tribe and requests a future field visit. 

9/21/2012 Hualapai Tribe Project Area Hualapai staff, elders and youth visited the project area to 

assist with plant survey work. Kaibab staff presented 

information on the project.

10/04/2012 Havasupai Tribe Supai, AZ The Forest Supervisor and staff provided an update on the 

DEIS. Havasupai reaffirmed historic and cultural connection to 

the mountain and requested future updates. 

11/08/2013 Havasupai

Hopi

Hualapai

Kaibab Band of Paiute

Navajo

Yavapai-Prescott 

Pueblo of Zuni

Email The Forest emailed the Supplemental DEIS to tribal contacts.

11/15/2013 Havasupai

Hopi

Hualapai

Kaibab Band of Paiute

Navajo

Yavapai-Prescott 

Pueblo of Zuni and 

seven Navajo Chapters

Letter The Forest sent a letter with information about the

Supplemental DEIS.

12/04/2013 Navajo Nation Letter The Navajo Nation sent a letter to the Forest reaffirming the 

historic and cultural significance of the project area and ongoing 

interest in the project. 

12/12/2013 Hualapai Tribe Peach 

Springs, AZ

The Acting Williams District Ranger provided updates on the 

DEIS. Hualapai Tribe provided updates on the cultural plant 

surveys. Hualapai is interested in more partnership work on the 

project.

01/15/2014 Hopi Tribe Kykotsmovi, 

AZ 

The Williams District Ranger provided updates. Hopi Tribe has 

no issues with the project. Hopi Tribe has a need for timbers in 

project area for traditional uses.

4.3.1 Tribal Concerns with the Bill Williams Restoration Project

The Kaibab National Forest has been consulting with tribes on the management of Bill Williams Mountain for 

over 20 years. During that time, tribal representatives have stated a number of general concerns related to 

management of the mountain. These concerns are summarized as follows. 

1. Concerns with impacts to the visual quality of Bill Williams Mountain, 2) Concerns with commercial 

development of the mountain, 3) Disruption of ceremonial activities related to the mountain and ensuring 

access for those activities, 4) Impacts to important medicinal plants and other traditional use resources, 5) 

Protection of specific ceremonial sites, 6) Protection of ancestral sites/archaeological sites, 7) Overall forest 

health on the mountain, 8) Impacts to the integrity of the Bill Williams Mountain traditional cultural property, 

9) Monitoring of important plant resources, 10) Impacts to threatened and endangered species. 

Consultation on the project has resulted in three additional concerns regarding management of the mountain: 

11) Concerns with impacts to the watershed, particularly to Cataract Creek, Havasu Creek and the village of 

Supai, AZ, 12) A desire for direct monitoring of the project by Tribes, 13) Access to timber and thinning slash 

for traditional use and fuelwood. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Chapter 4. Consultation and Coordination 309

Mitigation Measures to Address Tribal Concerns. Mitigation measures and monitoring measures for Tribal 

Concerns are listed in Sections 2.4.5 of this document. Taken together, the proposed mitigation measures address 

all of the above issues that are within the scope of the analysis.

The Forest will continue to work with tribes to identify traditionally important plant species and populations that 

occur within the project area, and facilitate the sustainable collection of these resources for traditional and cultural 

purposes. Monitoring of known collection sites will occur within the project area during implementation. Newly 

documented populations will be recorded and mapped for consideration as collection sites. 

The Navajo Nation has recommended that the Forest select the Alternative that allows the least amount of road 

construction in the project area, while allowing for the successful implementation of restoration treatments across 

the mountain. Over the course of several consultation meetings, Navajo Nation has stated support for the 

Preferred Alternative. Based on consultations with the above tribes, all tribes support the Purpose and Need for 

the project. No Tribe has recommended Alternative 1- the No Action Alternative. Indeed, every consulted tribe 

agrees with the assessment that current conditions in the project area present an unacceptable, long-term risk to 

cultural, natural, and traditional resources in the project area.

While Alternatives 2, 3 and 4 propose active thinning treatments on the mountain, tribes have stated that these 

activities will result in a long-term beneficial effect to the Bill Williams Mountain Traditional Cultural Property. 

Provided the above mitigation measures are followed, implementation of Alternatives 2-4 is not expected to 

impact traditional tribal values or use areas associated with the project area. 

Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Glossary 311

Glossary

Cover type ~ This term refers to the most represented species within a stand. There can be multiple species 

within a cover type.

Crowns ~ Tree crowns are generally from the lowest live limb to the top of the tree. Crowns consist of 

leaves/needles and limbs.

Crown Closure ~ This is the interaction of trees as they start to compete for resources within a stand. As trees 

start to grow closer together, growing space and crown space become limited; this is when you get crown closure. 

Density ~ This term refers to the density of trees generally measured in Trees per Acre and Stand Basal Area. 

Managers use other forms of forest/stand tree density measures to determine stand condition based on forest 

dynamics. 

Encroachment ~ This is the movement of any living organism to an area where it has been previously excluded 

or had low populations that inhibits growth to another living organism. Encroachment can encourage higher 

stress levels and higher risk of fire within a stand.

Fire Severity ~ Fire severity generally indicates the degree of environmental change caused by fire or is the effect 

of a fire on ecosystem properties, usually described by the degree of soil heating or mortality of vegetation.

Fuel loadings ~ Accumulation of dead and down woody material is generally what this term is referring to but 

fuel loading can also means live trees. 

Ladder fuels ~ Under certain conditions, fire that is burning on the forest floor can climb upward using ladder 

fuels. These consist of smaller trees positioned under larger trees.

Mixed-severity fire ~ This type of fire exhibits a wide range of effects on the dominant vegetation. Some areas of 

a mixed-severity fire exhibit low fire severity, having experienced little damage to the overstory vegetation; other 

areas exhibit moderate fire severity, having experienced considerable overstory mortality but not complete 

replacement; and yet other areas exhibit high severity, having experienced complete overstory mortality.

Mortality ~ Because trees within the forest grow as a group or in stands, mortality refers to multiple trees dying 

due to an impact of competition for sunlight, water and nutrients, stress, or insects and diseases.

Obliteration ~ Deconstructing roadways so that they are no longer passable to vehicles, do not concentrate water 

flows and their former road surfaces are returned to a more natural state.

Overstory competition ~ This term refers to the competition for resources such as sunlight, water and nutrients 

between the trees that are representing the overstory tree composition or canopy. 

Pre-settlement evidence ~ This is evidence that is left behind to describe the forest structure and composition on 

a particular stand. Evidence includes but is not limited to, stumps, stump holes, snags, trees with fire scares and 

old living trees. Pre-settlement evidence provides a snapshot in time of the condition within the natural range of 

variability of trees generally alive prior to 1870. 

Recruitment ~ This term refers to regeneration within the forest successfully avoiding mortality to become part 

of the stand. The forest can regenerate a lot of trees, but only a certain amount will survive to be recruited into the 

stand.

Restoration ~ There are many definitions of restoration. Typically restoration restores functions within the forest 

such as snags, logs, fire etc. Other types of restoration focus on structure and arrangement of trees within the 

natural range of variability.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

312 Glossary

Snags ~ Dead and standing trees that provide wildlife habitat and vertical dead fuel structure to a stand. 

Stands ~ A stand is a delineation of a small portion of the landscape that is similar in cover type, structure, and 

overstory connectivity. Stands can range from approximately 150 acres to 1 acre in size. 

Stand-replacing wildfires ~ This term refers to a type of fire that drastically changes the overstory arrangement 

of trees. Generally these fires kill all of the overstory and are replaced by tree regeneration in the future. 

Stand Density Index ~ Any index that expresses relative stand density based on a comparison of measured stand 

values with some standard condition. 

Slash ~ Dead and down material that is created naturally or mechanically.

Surface Fire ~ Fire that burns loose debris on the surface, which includes dead branches, leaves, and low 

vegetation.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

References Cited 313

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Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Index 325

Index

Affected environment

Air resources ..................................................... 101 

Cultural and tribal resources ............................. 285 

Fire and fuels ...................................................... 87 

Invasive species ................................................ 228 

Lands and minerals ........................................... 298 

Management indicator species ....... 53, 96, 97, 205 

Migratory birds ................................................. 222 

Rangeland resources ......................................... 251 

Rare and endemic plants ................................... 234 

Recreation resources ......................................... 256 

Regional Forester’s sensitive plant species ...... 235 

Scenic resources ............................................... 265 

Silviculture ......................................................... 58 

Socioeconomics ................................................ 296 

Soils and watershed .......................................... 108 

Transportation .................................................. 160 

Wildlife of highest conservation concern ......... 165 

Air quality ..................................................... 102, 103 

Alternatives considered but eliminated from detailed 

study ................................................................... 42 

Alternatives considered in detail ............................ 26 

Alternative 1 (description of) ............................. 26 

Alternative 2 (description of) ............................. 26 

Alternative 3 (description of) ............................. 28 

Alternative 4 (description of) ............................. 30 

Arizona bugbane .. 7, 9, 11, 34, 35, 41, 55, 66, 76, 79, 

80, 82, 86, 94, 105, 146, 148, 235, 236, 237, 238, 

239, 240, 241, 288, 303 

Botanical Area ... 11, 28, 34, 36, 41, 66, 70, 71, 94, 

105, 146, 148, 151, 237, 239, 241, 282, 284 

Buffer zone ............................................. 11, 35, 36 

Best management practices, soils and watershed . 129 

Bill Williams Mountain communication site . 1, 2, 43, 

55, 151, 191, 199, 296, 298, 299, 300, 301, 305 

Changes between DEIS and FEIS ............................ 9 

City of Williams municipal watershed .... 1, 2, 3, 106, 

123, 153, 272, 296, 301 

Climate change ...... 86, 158, 159, 197, 199, 201, 204, 

209, 214, 218, 221, 226, 234, 241, 246, 250, 256, 

273, 274, 302 

Comparison of alternatives – key features ............. 44 

Comparison of alternatives – summary of effects on 

resources ............................................................. 46 

Cultural resources .. 7, 36, 54, 86, 285, 286, 287, 288, 

289, 290, 291, 292, 293, 295, 297, 302 

Cumulative effects

Air resources ..................................................... 103 

Cultural and tribal resources ............................. 288 

Fire and fuels .................................................... 101 

Invasive species ................................................ 233 

Lands and minerals ...........................................299 

Management indicator species ........ 53, 96, 97, 205 

Migratory birds .................................................222 

Rangeland resources .........................................255 

Rare and endemic plants ...................................247 

Recreation resources .........................................263 

Regional Forester’s sensitive plant species ......235 

Scenic resources ...............................................273 

Silviculture..........................................................84 

Socioeconomics ................................................298 

Soils and watershed ..........................................151 

Transportation ...................................................164 

Wildlife of highest conservation concern .........165 

Direct and indirect effects

Air resources .....................................................102 

Cultural and tribal resources .............................287 

Fire and fuels ......................................................88 

Invasive species ................................................231 

Lands and minerals ...........................................299 

Management indicator species ........ 53, 96, 97, 205 

Migratory birds .................................................222 

Rangeland resources .........................................253 

Rare and endemic plants ...................................247 

Recreation resources .........................................259 

Regional Forester’s sensitive plant species ......235 

Scenic resources ...............................................273 

Silviculture..........................................................65 

Socioeconomics ................................................297 

Soils and watershed ..........................................127 

Transportation ...................................................161 

Wildlife of highest conservation concern .........165 

Economics ............................................................289 

Cultural resource survey cost... 290, 291, 292, 293, 

295, 296 

Net timber value ...... 289, 290, 291, 292, 293, 294, 

295, 296, 297, 298 

Prescribed burning cost .... 291, 293, 294, 295, 296 

Road construction/obliteration administration cost

 .............................. 290, 291, 293, 294, 295, 296 

Road construction/obliteration cost . 290, 292, 294, 

295, 296 

Road engineering cost ..... 290, 291, 292, 294, 295, 

296 

Sale administration cost ... 290, 291, 292, 293, 294, 

295, 296 

Sale preparation cost . 290, 291, 292, 293, 295, 296 

Strategic fuel break construction cost ......291, 293, 

294, 295, 296 

Environmental justice ...........................................300 

Fire

High severity .. 51, 82, 83, 132, 147, 155, 157, 158, 

159, 273 

Prescribed 3, 27, 29, 30, 31, 33, 44, 47, 48, 50, 52, 

69, 81, 93, 94, 101, 102, 103, 105, 106, 107, 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

326 Index

129, 132, 133, 134, 135, 136, 142, 143, 144, 

145, 146, 148, 151, 153, 155, 156, 159, 172, 

177, 178, 179, 181, 182, 185, 187, 188, 192, 

195, 196, 198, 199, 200, 202, 203, 204, 208, 

209, 212, 213, 216, 217, 218, 219, 224, 225, 

237, 240, 244, 245, 248, 249, 255, 256, 259, 

260, 262, 263, 265, 275, 279, 282, 283, 284, 

288 

Uncharacteristic ... 1, 47, 54, 55, 97, 155, 184, 192, 

247, 253, 273, 287, 299, 300, 307 

Forest health ..................................................... 46, 76 

Forest Plan

Project consistency with ................. 4, 86, 228, 272 

Revision ................................................................ 4 

Harvest systems ...................................................... 20 

Cable logging 5, 7, 9, 26, 36, 44, 45, 48, 49, 50, 51 

Conventional ground based . 21, 27, 176, 181, 182, 

184, 187, 188, 239, 244, 248, 281, 283, 290 

Helicopter yarding ... 3, 8, 9, 24, 29, 30, 36, 38, 44, 

47, 48, 49, 51, 73, 137, 138, 146, 147, 158, 182, 

188, 232, 233, 239, 254, 255, 274, 282, 287, 

290, 298 

Steep slope ground based ...... 24, 25, 26, 137, 172, 

176, 179, 181, 182, 184, 261, 262, 263, 279, 

284 

Hauling (log) ..... 32, 48, 49, 120, 147, 162, 180, 274, 

283, 289, 297, 298 

Historic range of variability ................ 47, 65, 66, 270 

Irreversible and irretrievable commitments of 

resources ........................................................... 302 

Issues, non-significant .............................................. 5 

Issues, significant ................................................. 6, 7 

Management indicator species (MIS) 53, 96, 97, 205, 

217 

Mexican spotted owl.. 3, 5, 6, 7, 9, 10, 26, 28, 32, 33, 

40, 51, 52, 66, 70, 71, 76, 77, 79, 80, 82, 83, 94, 

98, 106, 107, 146, 147, 157, 158, 165, 166, 167, 

168, 169, 170, 171, 172, 173, 174, 175, 176, 177, 

178, 179, 180, 181, 182, 183, 184, 185, 186, 187, 

188, 189, 191, 192,193, 202, 208, 217, 222, 223, 

261, 262, 276, 279, 284, 299, 302, 303 

Nest core ........................................... 179, 180, 181 

Protected activity center (PAC) ..... 5, 7, 28, 32, 33, 

51, 52, 66, 70, 82, 94, 98, 107, 146, 147, 157, 

158, 168, 169, 170, 172, 173, 176, 177, 178, 

179, 180, 181, 182, 184, 189, 191, 200, 226, 

299 

Recovery Plan .... 7, 32, 33, 94, 106, 168, 172, 184, 

187 

Mitigation and monitoring ...................................... 32 

Mitigation .. 1, 4, 5, 6, 7, 12, 27, 29, 31, 32, 33, 34, 

35, 36, 37, 39, 43, 44, 69, 70, 73, 82, 85, 87, 

101, 117, 128, 129, 136, 146, 169, 170, 176, 

191, 196, 198, 203, 204, 208, 213, 217, 225, 

228, 231, 232, 234, 239, 240, 244, 245, 248, 

249, 250, 253, 254, 260, 261,262, 264, 273, 

274, 275, 276, 283, 286, 287, 288, 307, 309 

Monitoring . 4, 32, 35, 39, 40, 41, 44, 86, 126, 135, 

157, 195, 206, 211, 215, 216, 231, 232, 233, 

236, 238, 240, 256, 270, 281, 286, 287, 288, 

308, 309 

Northern goshawk .. 10, 14, 15, 16, 33, 40, 52, 66, 82, 

98, 165, 166, 192, 193, 194, 195, 196, 197, 208, 

222 

Post-fledgling family areas .. 10, 14, 15, 16, 33, 40, 

52, 98, 192, 193, 194, 195, 196, 198, 208, 302 

Old growth .................... 6, 7, 46, 57, 81, 82, 173, 302 

Other required disclosures ....................................302 

Preparers and contributors ....................................305 

Pre-settlement conditions....... 53, 168, 170, 185, 186, 

195, 198, 200, 202, 203, 208, 212, 221, 227, 235, 

251, 253 

Pre-settlement patches .... 11, 12, 13, 32, 34, 170, 171 

Pre-settlement trees .... 6, 12, 13, 33, 43, 82, 168, 170, 

173, 176, 185, 188, 192, 194, 196, 208, 217, 219 

Public involvement ...................................................4 

Purpose and need for action ......................................3 

Rare and narrow endemic species ..... 34, 53, 227, 228 

Recreation Opportunity Spectrum ... 37, 53, 257, 258, 

260, 261, 262, 263 

Roads 

Decommissioning ...... 38, 130, 136, 141, 142, 150, 

151, 160, 161, 179, 191, 199, 200, 202, 209, 

213, 218, 221, 243, 245, 246, 248, 249, 250, 

260, 263, 265, 279, 281, 282, 284, 288 

Existing .. 28, 37, 38, 142, 152, 160, 161, 162, 163, 

164, 165, 272, 281, 285, 292, 294, 295 

New construction ....... 6, 7, 37, 147, 152, 161, 182, 

186, 196, 204, 233, 275, 280, 281, 283, 288, 

298 

Obliteration .... 3, 28, 30, 31, 38, 39, 41, 45, 49, 54, 

132, 133, 136, 137, 141, 142, 147, 150, 152, 

153, 155, 156, 159, 160, 161, 162, 163, 164, 

178, 179, 182, 183, 186, 188, 189, 192, 201, 

202, 204, 209, 213, 217, 232, 243, 246, 248, 

250, 254, 255, 275, 283, 285, 287, 288, 289, 

290, 291, 292, 293, 294, 295, 297, 298, 311 

Temporary construction ..... 6, 33, 38, 45, 163, 178, 

183, 185, 189, 196, 209, 213, 218, 243, 245, 

248, 249, 288, 292, 294, 295 

Scenery Management System ................. 37, 258, 265 

Scenic integrity .. 37, 54, 55, 258, 260, 262, 267, 272, 

274, 277, 278, 279, 280, 281, 282, 284, 287, 288, 

289 

Short-term uses and long-term productivity .........301 

Silvicultural prescriptions ...... 9, 83, 84, 96, 155, 166, 

173, 176, 177, 189, 210 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Index 327

Smoke 27, 30, 31, 101, 102, 103, 104, 107, 181, 189, 

191, 193, 195, 198, 200, 204, 208, 213, 217, 222, 

225, 227, 273, 276, 299 

Traditional cultural property ...... 1, 55, 285, 286, 287, 

288, 289, 307, 308, 309 

Traditional use .................. 1, 285, 286, 287, 306, 308 

Tribal consultation ................................................ 306 

Unavoidable adverse effects ................................. 301 

Vegetative structural stage (VSS).. 44, 57, 58, 59, 62, 

63, 66, 67, 68, 69, 70, 71, 72, 73, 74, 82, 181, 199

Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 329

Appendices

Introduction 

These appendices contain material that supports the Final Environmental Impact Statement (FEIS) for the Bill 

Williams Mountain Restoration Project. This includes maps related to all project alternatives; responses to 

comments received on the Draft Environmental Impact Statement (DEIS) and Supplemental Draft Environmental 

Impact Statement (SDEIS); a list of comments received during the scoping phase of the project and identification 

of associated issues; a list of past, present, and reasonably foreseeable future actions that were considered in the 

cumulative effects analysis for the project; and a description of silvicultural treatments in pre-settlement patches 

of forest in Mexican spotted owl protected habitat and the Arizona Bugbane Botanical Area. Information from 

some appendices that were included in the DEIS was incorporated into the FEIS and is thus not repeated here. 

Table 1 provides a crosswalk of appendices in the DEIS and SDEIS and how that information is included in this 

document. 

Table 1. Crosswalk between appendices in DEIS, SDEIS, and FEIS

FEIS DEIS SDEIS

Appendix A: Maps Appendix A: Maps Incorporated by reference

Appendix B: Response to 

Comments N/A N/A

Soils and Watershed Best 

Management Practices 

information included in Table 

3-21 of the FEIS

Appendix B: Soil and 

Watershed Best Management 

Practices

Incorporated by reference 

Appendix C: Issue Processing 

Report

Appendix C: Issue Processing 

Report Incorporated by reference 

Appendix D: Past, Present, 

and Reasonably Foreseeable 

Future Actions

Appendix D: Past, Present, 

and Reasonably Foreseeable 

Future Actions

Incorporated by reference 

Appendix E: Silvicultural 

Treatments in Pre-Settlement 

Patches of Forest in MSO 

Protected Habitat and the 

Arizona Bugbane Botanical 

Area

N/A

Appendix F: Silvicultural 

Treatments in Pre-Settlement 

Patches of Forest in MSO 

Protected Habitat and the 

Arizona Bugbane Botanical 

Area

Existing and desired 

conditions information 

incorporated into FEIS and 

specialist reports; desired 

conditions and other Forest 

Plan guidance included in 

forest plan consistency check 

(located in project record)

Appendix E Incorporated by reference 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

330 Appendices

Appendix A: Project Maps

The following maps are cited in the body of the Final Environmental Impact Statement (FEIS). Table A-1 

provides a crosswalk between the maps included in the Draft Environmental Impact Statement (DEIS) and the 

maps that are now found in the FEIS. In order to better display the information related to the project, the maps 

were updated between the DEIS and FEIS. For example, the DEIS displayed the proposed operations and 

transportation system for Alternative 2 in two separate maps (maps 1 and 3). These two maps are now combined 

into one map (map 1) in the FEIS for the modified proposed action to better display the relationship between the 

proposed treatments and road system. Additionally, the map order was changed in the FEIS to group maps with 

the same themes together (e.g. proposed treatments/road systems) to make it easier to compare similar maps 

across alternatives.

If you have special needs for size and color to view the details of these maps, please contact the Williams Ranger 

District of the Kaibab National Forest, (928) 635-5600. 

Table A-1. Crosswalk between maps in the final and draft environmental impact statements

FEIS DEIS

Map 

Number Map Name

Map 

Number Map Name

1 Modified Alt. 2 Treatment Areas 

and Road System 

1 Alt. 2 Operations

3 Alt. 2 Transportation System

2 Alt. 3 Treatment Areas and Road 

System

7 Alt. 3 Operations 

8 Alt. 3 Transportation System

3 Alt. 4 Treatment Areas and Road 

System

10 Alt. 4 Operations

11 Alt. 4 Transportation System

4 All Alts Fuels Treatment Locations 2 All Alts Fuels Treatment Locations

5 Modified Alt. 2 Road Obliteration

4 All Alts Road Obliteration

6 Alts 3 & 4 Road Obliteration

7 Modified Alt. 2 Post-Treatment 

Transportation System 5 Alt. 2 Post-Treatment Transportation System

8 Alt. 3 Post-Treatment 

Transportation System 9 Alt. 3 Post-Treatment Transportation System

9 Alt. 4 Post-Treatment 

Transportation System 12 Alt. 4 Post-Treatment Transportation System

10 Existing Transportation System 6 Existing Transportation System

11 Existing Fuels Mgmt Projects in 

Project Area 13 Existing Fuels Mgmt Projects in Project Area
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 331

Map 1. Alternative 2 (modified proposed action) treatment map and road system
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

332 Appendices

 

Map 2. Alternative 3 treatment map and road system
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 333

 Map 3. Alternative 4 treatment map and road system 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

334 Appendices

 Map 4. Potential strategic fuels treatment locations, all alternatives 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 335

Map 5. Alternative 2 roads to obliterate
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

336 Appendices

Map 6. Alternatives 3 and 4 roads to obliterate
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 337

Map 7. Alternative 2 post-treatment transportation system
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

338 Appendices

Map 8. Alternative 3 post-treatment transportation system 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 339

Map 9. Alternative 4 post-treatment transportation system 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

340 Appendices

Map 10. Existing transportation system in the Bill Williams Mountain Restoration Project area
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 341

Map 11. Existing fuels management projects within the Bill Williams Mountain Restoration Project boundary
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

342 Appendices

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Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 343

Appendix B: Response to Comments, Draft Environmental 

Impact Statement and Supplemental Draft Environmental 

Impact Statement

The comment period for the Bill Williams Mountain Restoration Project Draft Environmental Impact Statement 

(DEIS) ran from July 14, 2012 through August 27, 2012. The comment period for the Supplemental Draft 

Environmental Impact Statement (SDEIS) ran from November 9, 2013 through December 23, 2013. Fourteen 

comment letters were submitted in response to the DEIS, and seven comment letters were submitted in response 

to the SDEIS. Additionally, a comment letter from the U.S. Fish and Wildlife Service was received on October 

15, 2012, which was after the end of the DEIS comment period. Although the letter was received outside the 

official comment period, it was reviewed by the interdisciplinary team and useful information was incorporated 

into the Final Environmental Impact Statement (FEIS). Specific comments are excerpted from the comment 

letters and included in this appendix, numbered, and responded to by the interdisciplinary team. The full comment 

letters are available in the project record.

Planning for this project began under the 1988 Land and Resource Management Plan for the Kaibab National 

Forest. A revised Land and Resource Management Plan was adopted in February 2014. Many comments 

submitted in response to this project addressed standards, guidelines, and other components of the 1988 Forest 

Plan. Because the revised Forest Plan is now in effect, only the standards, guidelines, desired conditions, and 

other components of the revised Plan apply to this project 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

344 Appendices

Response to Comments: Draft Environmental Impact Statement 

Comment Letter 1: Dick Artley

Comment 1-1 

If the EIS for the Bill Williams Mountain Restoration Project does not analyze a Dr. Cohen alternative in detail it 

will be necessary to inform the public in your area about Dr. Cohen’s fire risk reduction methods myself. 

Response to Comment 1-1 

The Purpose and Need for the Bill Williams Mountain Restoration Project are to reduce the risk for high intensity 

stand replacing wildfire, improve the health and sustainability of forested conditions on the National Forest land 

on and surrounding Bill Williams Mountain by reducing hazardous fuels, and moving vegetative conditions in the 

project area toward the desired conditions. This work would be done to directly and indirectly improve the 

condition of watersheds that contribute to the City of Williams water supply. This is a federal land management 

project, and the Kaibab National Forest does not have the authority to prescribe what is done on private lands. 

The views expressed by Dr. Cohen are directly related to protection of homes from the effects of wildland fires. 

The Kaibab National Forest actively participates with local citizens and fire departments on the Williams Fire 

Advisory Council to educate and assist private local landowners to reduce fuel and fire risk on their property. 

Comment 1-2 

Please notify this member of the public when the ROD and final EIS are first posted online. 

Response to Comment 1-2 

Mr. Artley will be notified when the Final Environmental Impact Statement (FEIS) is completed and the Record 

of Decision (ROD) is available.

Comment 1-3 

Incredibly, when I access the Kaibab NF WEB site and click on “Bill Williams Mountain Restoration Project” 

which is in the “Under Analysis” looking for the DEIS I get: “No documents are available for this project.” I’m 

lucky I received the electronic version of the 345 page DEIS from one of your employees. You have at least one 

employee who cares about the public land

Response to Comment 1-3 

The FEIS and ROD will be made available on the Kaibab National Forest website.

Comment Letter 2: Todd G. Geiler

Comment 2-1 

The Bill Williams Restoration Project is not needed, it is mandatory. The Forest Service has allowed its forest 

management policies to be held hostage by the radical fringe ten percent. As a member of the silent majority, I 

applaud your efforts with this Project. We realize the need for responsible application of fire to achieve these 

goals. Likewise, there will need to be responsible logging and yes; we expect to see logging trucks during the 

duration of this project. Those of us who have lived in and around Williams remember the current district office 

site was once where the Saginaw Timber Company had its mill. Ironic isn’t it we are having this discussion given 

where the Rangers off now sits? The end point we request will take both the Forest Service and the private sector 

acting in together. Bill Williams Mountain does not need to look like Escudilla Mountain on the ApacheSitgreaves Forest. Our mountain will however if this project becomes a Forest Service public relations show 

instead of a sound timer management project. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 345

Response to Comment 2-1 

Thank you for your support for the Bill Williams Mountain Restoration Project. 

Comment Letter 3: Larry Smart

Comment 3-1 

I would like to see the project move forward in the restoration of Bill Williams. 

Response to Comment 3-1 

We appreciate your support for the Bill Williams Mountain Restoration Project.

Comment Letter 4: Mark Worden

Comment 4-1 

I agree with selected thinning of the forest but fervently believe in protecting the ancient trees (trees 20 inches and 

above) and the ancient part of Bill Williams Mountain. 

Response to Comment 4-1 

Mr. Worden defines ancient trees as trees greater than 20 inches and above and explains how the USDA Forest 

Service should protect these trees on Bill Williams Mountain. Tables 3-5 and 3-6 in the Final Environmental 

Impact Statement (FEIS) show a decrease of 1-8 trees/acre >18” diameter at breast height (DBH) 40 years after 

implementation, depending on the action alternative. However, no action is very likely to lead to stand-replacing 

fire and the loss of many more trees/acre >18” DBH than any of the action alternatives.

Pre-settlement trees would be retained in this project (see mitigation measures in chapter one of the FEIS). Some 

pre-settlement trees may be incidentally taken due to harvesting operability, burning operations, and for human 

health and safety. Much of the forest in the project area consists of pre-settlement trees where little active 

management besides fire suppression has occurred. However, due to fire exclusion over many decades, much of 

the structure, function, and processes of the forest have changed from conditions prior to Euro-American 

settlement (and the advent of fire exclusion). Ponderosa pine, dry mixed-conifer, and other forest and woodland 

ecosystems on the mountain, even in those areas that were never commercially harvested, have grown abnormally 

dense with trees due to fire exclusion and other causes (see cumulative effects analyses in wildlife section of 

FEIS). This has caused the probability of high intensity stand-replacing wildfire to drastically increase such as the 

severe fire events that occurred on Kendrick Mountain in 2000 and on the San Francisco Peaks in 2010. 

In turn, this condition poses a threat to forest and ecosystem health (e.g., in terms of probability of loss to standreplacing fire, uncharacteristic outbreaks of insects and disease). It also compromises the habitat for many 

wildlife and plant species of conservation concern (e.g., Mexican spotted owl, northern goshawk, Allen’s lappetbrowed bat, Arizona bugbane). It is necessary to thin and burn the project area to restore the structure, function, 

and processes of the ecosystems on and around the mountain and to conserve patches of forest that are dominated 

by pre-settlement trees. Patches of forest that are dominated by pre-settlement trees were identified using aerial 

photos from 1949, and these areas would be conserved although limited treatments may be used). See the 

wildlife, botany, silviculture, fire, and other natural resource related sections of the FEIS for details.

Comment 4-2 

They are a valuable resource on the mountain especially the Corkbark Fir “Abies lasiocarpa” (which is 

specifically native to the sub alpine range of the San Francisco Peaks Range).

Response to Comment 4-2 

There is no corkbark fir (Abies lasiocarpa var. arizonica) on Bill Williams Mountain. However, white fir (Abies 

concolor) occurs commonly. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

346 Appendices

Comment 4-3 

I would highly recommend a “sky islands designation” for that part of the mountain that includes these ancient 

trees (at least the saddle of Bill Williams Mountain where they are most abundant). 

Response to Comment 4-3 

This comment is outside the scope of this project because cork bark fir is not found on Bill Williams Mountain.

Comment 4-4 

I believe it is extremely in the best interest of the Forest Service and the citizens of our country to save some of 

the Ancient Forest up there. (Much of it is a unique, one of a kind eco-system.)

Please, consider all of these points when considering just how much of the mountain you are thinning. 

Please use a rational “balanced plan” before thinning the entire mountain and be aware that it is in the best interest 

of forest health, the wildlife and the entire mountains eco-system to preserve much of the old growth as possible.

Response to Comment 4-4 

See response to 4-1. 

Comment Letter 5: EPA

Comment 5-1 

We recognize the challenge the Forest Service faces by implementing a management plan that will rely heavily on 

prescribed burns and wildfire to achieve restoration objectives. Though the planning area has good air quality, and 

meets all federal ambient air quality standards, the fine particulate matter generated during wildland fire can 

present a human health risk. Re recommend that the Forest Service implement BMPs and work with the 

interagency Smoke Management Group to reduce emissions from prescribed burns and wildfires to the greatest 

possible extent. 

Response to Comment 5-1 

Smoke management is of the greatest importance to the Kaibab National Forest (KNF) prescribed fire program. 

The fire and fuels specialist report analyses particulate matter 2.5 production for the project. By law, the KNF 

submits (yearly) and is permitted by the Arizona Department of Environmental Quality (ADEQ) to proceed with a 

project that will create smoke emissions. Also, before each burn day, permission must be given by ADEQ to 

implement that specific project. A part of the permission granting process is the requirement that the State 

approved Emission Reduction Techniques are used to mitigate smoke. The KNF works closely with the ADEQ 

and will comply with these requirements. The public is notified ahead of time regarding prescribed burning and 

the district has a list of people sensitive to smoke they contact prior to implementing prescribed burns. 

Comment 5-2 

One aspect of the project that gives us pause is the planned use of cable logging within the Arizona Bugbane 

Botanical Area. The DEIS states that the disturbance associated with cable logging within the Botanical Area 

could disrupt the microclimate and may adversely affect the Arizona bugbane population (p. 243). Additionally, 

the DEIS states that the anticipated disruption of the microclimate, coupled with projected future warming of the 

planning area, could contribute to a trend toward federal listing of the species (p. 244). We recommend that the 

Forest Service refrain from the use of cable logging within the Botanical Area unless mitigation measures could 

be developed that would ensure long-term protection of the Arizona bugbane population. 

Response to Comment 5-2 

Cable logging is no longer included in any of the alternatives in this project. The areas proposed for cable logging 

will be treated with steep slope equipment or with helicopters. In particular, the 54 acres in the Arizona Bugbane 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 347

Botanical Area that were planned for cable logging have been changed to helicopter logging in Alternative 2- 

modified proposed action. Implementation of the mitigation measures in conjunction with helicopter logging is 

not likely to adversely affect the unique micro-climate where Arizona bugbane currently exists, and meets the 

overall objectives of providing for the long-term conservation of Arizona bugbane and its habitat. 

Comment Letter 6: Stroud (via mail)

Comment 6-1 

We are asking that the currently locked forest service gate, the fence line along the west side of FS Rd. 111B from 

Benham Trail Road to our property corner, and no motorized access to FS Rd. 111B (except for KNF personnel) 

that runs parallel along our southern property line be maintained. Additionally, we request the KNF place “No 

Camping Beyond This Point” signs 50 feet from our southeast residential property line on FS Rd. 111B in order to 

create a reasonable buffer between campers, motorized vehicles and our property. There is little or no monetary 

cost associated with these requests and is in keeping with the Project objectives and statements made on the KNF 

website as to the special nature and preservation of the Kaibab National Forest.

Response to Comment 6-1 

Forest Road 111B will be very important for the Bill Williams Mountain Restoration project when thinning 

operations are implemented. Implementation would be phased in over several years, and the road would be 

maintained to USDA Forest Service standards during the time it would be used. Under all action alternatives 

111B road from its junction with road 111 to the current locked gate adjacent to private property will be open to 

only Forest Service administrative use. The portion of the road 111B from its junction with county road 73 to the 

private property boundary to the north will remain open to public use. Project design includes limitations on 

times logging trucks are running near private residences.

Following completion of project work in that area, the Kaibab National Forest would evaluate the need to keep 

the road open to the public. Adding signage in this area for no camping is outside the scope of this project and 

can be addressed by visiting with district staff.

Comment Letter 7: James Benham

Comment 7-1 

I sent the following letter to you last year concerning the Bill Williams Restoration project. I am assuming the 

issues I raised in the letter have been adequately addressed. Please keep me informed. Thanks.

Response to Comment 7-1 

Thank you for your comments letters. The comment letter dated May 10, 2011 was incorporated into the Draft 

Environmental Impact Statement (DEIS) as letter #3 of Appendix C, and is addressed in the issue processing 

section found in Appendix C of the Final Environmental Impact Statement (FEIS). 

Comment 7-2 

Some years ago (probably late 2005) there was a prescribed burn on Forest Service land north and west of my 

property. Since then I have noticed increased runoff and initially very dirty water containing lots of partially 

burned pine needles, among other things, flowing through my property. Am I correct in concluding that after a 

prescribed burn, more water runs off the land and therefore less soaks into the ground and is not available for the 

remaining trees and vegetation?

Response to Comment 7-2 

The commenter is correct in concluding that there is typically an initial hydrologic response of increased storm 

water runoff following prescribed fire, which can occur as both channel and sheet flow. The severity of this 

response is dependent on a variety of factors including burn intensity, surface soil textures, slope gradient, soil 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

348 Appendices

anisotropy (i.e., differences in soil properties when measured along different axes), residual unburned vegetative 

cover, and the level of fire-induced soil hydrophobicity following prescribed burning. Under low burn severity, 

changes in runoff volume are typically minimal since burn patterns usually result in a mosaic of burned areas 

intermingled with unburned areas. The project is being proposed to avoid the severe effects that are associated 

with higher severity wildfires such as the potential of increased surface runoff and entrain soil particles and other 

debris (gravel, rock, and forest litter).

Although runoff potential increases following prescribed fire, there is typically sufficient soil moisture for 

remaining vegetation to thrive, particularly due to reduced vegetative competition and associated plant water 

demand. Best Management Practices (BMPs) have been developed to minimize adverse effects on soils and 

watershed resources from use of prescribed fire. These include BMP Numbers 2, 3, 4, and 25. The potential 

responses of soils and watersheds to prescribed burning have been analyzed in the soils and watershed specialist’s 

report and the FEIS as follows:

Table B-1. Locations in Soils and Watershed Specialist Report and FEIS where effects of prescribed burning are 

analyzed

Soils and Watershed 

Specialist Report Page No.

FEIS Page No.

1 133 

60 134

67 135 

68 136 

69 142 

70 143 

77 144 

78 145

80 146

81 148 

82 151 

157 

Comment 7-3 

If you do a prescribed burn on the Mountain, will you be prepared for all the debris that will eventually flow 

down, including dirt and rocks? In other words, are you concerned about erosion and will you take steps to 

prevent it? Can the water treatment plant in Williams remove the debris and burned smell in the runoff? 

Response to Comment 7-3 

Please refer to response to comment 7-2 for details of analyses of soils and watershed response to use of 

prescribed fire on Bill Williams Mountain. There is certainly concern regarding potential erosion and sediment 

delivery rates resulting from prescribed burning. As noted in response to comment 7-2, BMPs were developed to 

minimize adverse effects on soils and watershed resources from use of prescribed fire. These practices have been 

shown to minimize or mitigate adverse effects on soils and watershed resources from prescribed burning.

Comment 7-4 

There are many spots on the mountain that support unique plants. One that I know about is past the one mile 

marker on the Benham Trail. There is a stretch of several hundred feet of ferns. We have nicknamed it Ferndell. I 

would hope this area would not be subject to a prescribed burn. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 349

Response to Comment 7-4 

The proposed action would allow for the entire project area to receive prescribed fire treatments. In general, micro 

climates where ferns are in abundance are usually cool, moist sites during times when prescribed fires are likely. 

This type of environment is conducive to low intensity fire behavior which relates to low mortality in plants and 

are considered in the project.

Comment 7-5 

Lastly, have you considered what will happen to the water quality of my well as a result of the proposed project? 

Many years ago some action caused the sediment load to increase greatly. Maybe it was when mining companies 

were looking for claims in the area. Anyway, it clogged my water filter within a day or two. I assume any 

disturbance on the land above my well is likely to cause additional dirt in my well water, but it would be nice to 

minimize it.

Response to Comment 7-5 

The effects of fuels reduction treatments and prescribed burning were analyzed in the soils and watershed 

specialist report for the project. Analyses indicate there is an increased risk of erosion and sediment delivery to 

downslope locations. Best Management Practices developed for this project (Table 1, page 11 in soils and 

watershed specialist report) are expected to be sufficient to prevent delivery of sediment and other contaminants 

to private water wells.

It is known that minor aquifers in the general vicinity of Bill Williams Mountain are commonly thin and 

discontinuous (Montgomery et al. 1988). Most wells drilled to these perched aquifers fail after a pumping period 

ranging from several days to several years due to well sedimentation which is outside the scope of the project.

Comment Letter 8: Debra Noel

Comment 8-1 

First, I want to thank you for the long, difficult, and complex work taken on by the Kaibab NF staff. It is not 

always an easy task to educate the public on the complexities of ecosystem restoration. 

Response to Comment 8-1 

We appreciate your support of the Kaibab National Forest’s efforts to work with the local communities 

regarding the Bill Williams Mountain Restoration Project.

Comment 8-2 

Second, I support the intent, mission, and preferred treatment alternative no. 2, as I believe it will address the 

main focus of the project, which is to decrease the potential of catastrophic crown fire in the Bill Williams 

watershed, and also increase the health of the watershed, and most of the species living therein. The only area in 

which I have some concern is the (1) use of cable logging/mechanical treatment in the Arizona Bugbane Protected 

Area, and the (2) use of controlled burn in the same area. Although not listed as endangered, this is such a unique 

plant, and in that the type specimen was collected on Bill Williams Mountain, I hope that the highest level of 

protection will be implemented in maintaining the health of the population on Bill Williams Mountain. From my 

experience working with noxious invasive plant species on the forest, as a seasonal employee during the years of 

2002 & 2003, I know that any kind of disturbance can initiate the introduction of invasives, and that depending on 

the species, can be extremely difficult to eradicate. Because of these concerns, I would like to see some 

implementation of proposed alternative #3 or #4 in addressing the protection of the Arizona Bugbane Protect 

Area. I was not clear as to whether or not mitigation(s) would accommodate this action. 

Response to Comment 8-2 

The modified proposed action allows for prescribed fire within the Arizona bugbane botanical area. Mitigation 

measures for Arizona bugbane are identified in Chapter 2, Section 2.4.5.1of the Final Environmental Impact 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

350 Appendices

Statement (FEIS) that relate to the Arizona bugbane as well as noxious weeds. Extensive planning and discussions 

have taken place and are documented in the project record regarding the importance of the Arizona Bugbane 

population and botanical area. 

The Kaibab National Forest is committed to conserving the long-term viability of Arizona bugbane and its unique 

habitat. The mitigation measures are designed to reduce the risk of high intensity wildfires while maintaining the 

habitat components that provide Arizona bugbane its unique micro-environment. The buffer zones incorporated 

into the design of this project will limit the level of management that occurs in the Arizona Bugbane botanical 

area. For example, timber management activities will not occur within the “Inner Buffer Zone” to protect the 

immediate habitat, and the surrounding “Limited Treatment Buffer Zone” will be limited to ladder fuel reductions 

that will protect the overstory that provides shade for this environment. 

The project no longer includes cable logging in any of the alternatives. The cable logging that was proposed in 

the DEIS for the Arizona Bugbane botanical area has been changed, and these acres are now designated for 

helicopter logging. Implementation of the mitigation measures in conjunction with helicopter logging is not likely 

to adversely affect the unique micro-climate where Arizona bugbane currently exists, and meets the overall 

objectives of providing for the long-term conservation of Arizona bugbane and its habitat. 

Proactively reintroducing fire as a natural process through prescribed burning in the botanical area will reduce the 

risk of high intensity wildfire, ultimately resulting in the long-term conservation of Arizona bugbane and its 

habitat. A No-Action approach to burning in the botanical area would not reduce the risk of high intensity fire, and 

may result in fire conditions similar to other wildfires the region has experienced in recent times (e.g., 2010 

Schultz Fire). The fire effects of a high intensity wildfire on Bill Williams Mountain could be detrimental to 

Arizona bugbane and its habitat.

The Williams Ranger District will continue its invasive species program by implementing items listed in 

Appendix B of the FEIS for Integrated Treatment of Noxious or Invasive Weeds. This includes inventory, 

treatment, and monitoring of invasive plant species across the entire district.

Comment Letter 9: David Farley

Comment 9-1 

Please refer to DEIS Appendix Map 3 - Alternative 2 Transportation System Map. Our proposal for change 

concerns FS Road 111B that exists now and is shared by APS to service the power lines that parallel this road. At 

the north end of this road Alternative 2 proposes a left turn (west) through a FS locked gate and continue in a 

westerly direction. This west road is adjacent to about 1300 ft. on the south side of the Stroud property and within 

200 ft. of their home. Before it turns west, FS Road 111B abuts our property and is about 300 ft. from our home. 

The west part of FS Road 111B, past the FS locked gate, has not been used in the 12 years since we have been 

there and can only be recognized as a road for the first few hundred feet. It will take some serious work to make it 

usable by heavy equipment. The disruption to adjacent home owners during treatment by road and logging 

equipment will be intense and unnecessary. We propose moving the westerly access road to a point midway 

between the Benham Trailhead Rd. and the north end of FS Road 111B where you can still head west through FS 

land and meet up with the existing roadbed somewhere past the Stroud property. The only necessary addition 

would be the creation of a new gate at this point or move the existing gate south along the fence. This would 

create a buffer, consistent with DEIS literature, between Project activity and private property. Please reference 

page 18, 2.3.1 Mitigation, which states that “The Forest Service employs several measures to reduce or prevent 

negative impacts to the environment in the planning and implementation of management activities”. And again 

page 24 under Recreation Resources paragraph 39 bullet 4 which establishes a 300 ft. buffer zone between private 

homes with concern for handpiling slash. Certainly the road grading and logging activity would fall under this 

philosophy of a buffer zone mitigating the impact of heavy equipment activity on private home owners. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 351

Response to Comment 9-1 

Due to resource concerns related to erosion the lower portion of Forest Service Road 111B would be relocated to 

the south to improve drainage. Following completion of project work in that area, the Kaibab National Forest 

would evaluate the need to keep the road open to the public. 

Comment 9-2 

Furthermore, we feel that the westerly road should be marked for obliteration after treatment is completed. This 

opinion comes from two years of monitoring, cleaning and caring for the camping areas next to FS Road 111B. 

The disregard for the forest that some dispersed campers exhibit is alarming. The 300 ft. buffer enforced by the FS 

with simply a “no camping beyond this point” sign would also lessen the impact of noise, trash, illegal ATV 

activity, etc. on private property owners at the north end of FS Road 111B. Inviting dispersed camping further into 

the Bill Williams watershed area is frightening. The violations we have witnessed by campers on FS Road 111B 

have convinced us that there will be a human caused fire there. It is only a matter of time. There are plenty of 

beautiful camping spots on the east side of Perkinsville Rd. leaving the paved road as a defensible fire line to 

protect the Bill Williams watershed.

Response to Comment 9-2 

Mr. Farley was contacted in order to clarify if he meant the road should be closed or obliterated. He meant closed. 

Under all alternatives 111B road from its junction with road 111 to the current locked gate adjacent to private 

property will be open to only Forest Service administrative use. The portion of the road 111B from its junction 

with county road 73 to the private property boundary to the north will remain open to public use. A short portion 

of the 111B road would be relocated to the south for resource concerns and to improve drainage. The old section 

the 111b road would be obliterated. 

Camping is not a part of this project and is outside the scope of this project and can be discussed with district 

staff.

Comment Letter 10: Sierra Club

Comment 10-1 

The National Environmental Policy Act (NEPA) and the regulations promulgated to implement the act (42 U.S.C. 

§ 4321, et seq., 40 CFR § 1500.1, et seq.) mandate that USDA-Forest Service assess and evaluate the 

environmental impacts of this project and that reasonable alternatives be considered (42 consider cumulative 

impacts as well as direct and indirect impacts of the proposal (40 CFR ~ 1508.7). 

Response to Comment 10-1 

Per all regulations direct, indirect, and cumulative effects are described in chapter three of the Final 

Environmental Impact Statement (FEIS).

Comment 10-2 

We support the first proposed amendment to re-designate the land suitability classification within certain 

areas to allow restoration treatments, and request that the long-term desired conditions be “achieved through 

strict-sense restoration and maintenance burning” rather than managed for timber production. A focus on 

restoration and return of natural processes will serve the public well both in the short and long term whereas 

a focus on timber production will likely result in more of the same challenges we are currently seeing in our 

national forests.

Response to Comment 10-2 

As of 2014, the Kaibab National Forest has a revised forest plan. The decision for this project will be signed 

under the revised plan. Proposed actions associated with this project are consistent with the revised forest plan 

and amendments are no longer needed.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

352 Appendices

Comment 10-3 

Recent research has found that many local forests experienced historically high stocking and stand- replacing fire 

(Jenkins et al. 2011, Margolis et al. 2011), and that fire, even without tree thinning, can drive forests to meet 

restoration-oriented objectives (Fulé et al. 2004, Stevens-Rumann et al. 2011). We ask that the amendments 

associated with Mexican Spotted Owl (NSO) and northern goshawk be dropped as they are not necessary to 

achieve the Kaibab National Forest’s objectives.

Response to Comment 10-3 

The Kaibab National Forest has a revised forest plan. The decision for this project will be signed under the 

revised plan. Proposed actions associated with this project are consistent with the revised forest plan and 

amendments are no longer needed. Originally, in the Draft Environmental Impact Statement (DEIS) alternative 3 

and 4 responded to this issue. They did not include any site specific forest plan amendments. 

In the FEIS, Chapter 1, Section 1.3-Purpose and Need for Action describes the purpose and need identified by the 

Kaibab National Forest (KNF). Bullets 2, 3 and 5 identify the need for the proposed action related to this 

comment. The cited literature in the comment provided information about possible fire regimes and fire-incurred 

tree mortality. It is agreed upon that fire can be used as a thinning tool and fire can produce tree mortality. In this 

project, fire as the only tool for stand density reduction is not preferable. 

Due to the current high fuel loadings, tree stocking levels and topography associated with Bill Williams 

Mountain, it would compromise firefighter and public safety to allow for fire to reach intensities required to meet 

the desired condition. Furthermore, fires of this intensity are difficult to control, promoting the exact issue fire 

managers hope to diminish regarding protecting the surrounding communities, communication sites, wildlife 

habitat and watershed. This type of forest thinning is also not desirable. The project identifies the retaining of 

large, older aged trees for forest health and wildlife habitat. This is increasingly difficult with fire as the only 

treatment, as many ladder fuels that would otherwise be mechanically thinned would pose a threat to the retention 

of large, older trees. 

For nesting and roosting habitats, Mexican spotted owls (MSOs) and northern goshawks require dense patches of 

forest dominated by trees greater than 18” diameter at breast height (DBH). In order for these species to have 

sustained habitat into the future, forest patches of various age- and size- classes are necessary to replace existing, 

dense forest dominated by trees >18” DBH; if all MSO habitat in the project area is managed for an even-aged 

condition (as would be the case if only thin-from-below treatments were conducted, per the commenter’s 

suggestion), then replacement habitat would not develop by the time that existing habitat is lost to insects, disease, 

fire, or other processes that consume old forests. Note that pre-settlement trees would be conserved throughout 

the project area (see mitigation measures in chapter two of the FEIS), so managers would not manage for a 

diversity of age- and size- classes by removing pre-settlement trees.

Comment 10-4 

Reducing canopy cover beyond unknown thresholds can damage MSO populations on the KNF. According to a 

report prepared for the Four Forests Restoration Initiative (4FRI), median canopy cover for MSOs foraging and 

roosting in mixed conifer forests is greater than 60 percent. Note, “75% of stands used for roosting had canopy 

cover >60%.” (Ganey et al. 2011, fig. 3). Further: 

“Current data indicate that owls within the UGM RU are most common in mixed-conifer and ponderosa 

pine–Gambel oak stands with high basal area and canopy cover. These stands frequently have a prominent 

hardwood component and numerous large trees and snags. Most are uneven-aged, with variable age-and 

size-classes of trees and snags and considerable volumes of down logs. These are not the kinds of stand 

structures that forest managers typically try to create in restoration activities in ponderosa pine and 

mixed-conifer forests that evolved with relatively frequent fire (for example, Cooper 1960, Dieterich 

1983, Covington and Moore 1994, Fulé and others 1997, 2002, 2003, 2004, 2009, Cocke and others 2005, 

Kaufmann and others 2007; see also Beier and Maschinski 2003). The conditions typical of owl nesting 

and roosting habitat therefore are frequently viewed as “unsustainable” and unnatural in these 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 353

systems (Johnson 1994). How then did Mexican spotted owls, which apparently occurred historically 

in these forest types (for example, Ligon 1926, Steele 1927, Bailey 1928, Huey 1930), come tospecialize 

on these types of forest stands (for example, Hutto and others 2008)? Were such stands (or perhaps 

patches smaller than stands) present historically in these landscapes, for example in fire refugia (Camp and 

others 1997) such as north-facing slopes or rocky canyon slopes? If so, is there a minimum size to suitable 

patches for nesting and/or roosting owls? Or were spotted owls able to exist and persist in stands with 

lower basal area, canopy cover, and fuel loads?... The problem is that we do not know where potential 

thresholds may lie, or how far we can reduce stand conditions before those stands no longer provide 

habitat for spotted owls.” (Ganey et al. 2011 and references within, pp. 81-82, bold emphasis added) 

In light of the fact that thresholds for MSO-occupied stand density have not been determined, the KNF should not 

risk destroying the habitat for this threatened species. Instead, KNF should strategically thin from below in ways 

that eliminate the need to treat the entire landscape. Using a combination of hand thinning from below and 

prescribed burning along drier gradients in the mixed conifer, outside of PACs, KNF can break up fuel continuity 

and therefore reduce the potential for large patches of high-severity fire that could cause significant runoff and 

soil erosion events 

Response to Comment 10-4 

See responses to comments 4-1, 4-4, and 10-3. 

Desired conditions for MSO protected habitat that include canopy cover were developed by working with the U.S. 

Fish and Wildlife Service (USFWS) and using the best available science as found in the 2012 Recovery Plan (see 

Appendices E and F for details). Thin-from-below and individual tree selections are the silvicultural treatment 

methods to be used in the best MSO nesting/roosting habitat in the project area (see appendices). However, it is 

necessary to thin more heavily around nesting/roosting habitat in order to protect these areas from stand-replacing 

wildfire and uncharacteristic outbreaks of insects and disease. 

Furthermore, not all habitat in the area should be managed for nesting/roosting habitat: Not all habitat occurs in 

locations that are or ever were suitable for nesting and roosting (e.g., some areas in protected habitat on dry, 

south-facing slopes or ridges), and land management must strike a balance between conserving patches of 

nesting/roosting habitat (consisting of fire-prone, dense stands) and protecting these nesting/roosting patches from 

active crown fire by creating openings around these patches (e.g., in areas that are drier and had few trees/acre in 

pre-settlement times).

Mitigation measures and desired conditions would ensure conservation of both protected and restricted habitat. 

Heavier and lighter mechanical treatments would be placed according to the ecology of the landscape (e.g., using 

aspect, ridgetops vs. drainages, and other geographic features to inform where forest should be left denser vs. 

more open). See the wildlife specialist’s report, mitigation measures, desired conditions, and references based on 

the best available science.

Eliminating prescribed fire treatments from protected activity centers (PACs) is extremely difficult in this project 

due to topography as well as other factors. In order to accomplish this, managers would need to fragment the 

vegetative structure around the PAC in order to keep fire from moving into it. This would not meet desired 

conditions. This would also become a safety concern for firefighters by requiring additional exposure to 

firefighters during implementation. Firefighter and public safety must be strongly considered within the design of 

the project.

Comment 10-5 

Amendment 3 Allowing a deviation from Forest Plan standards and guidelines in ponderosa pine stands 

outside of goshawk Post Fledgling Family Area’s (PFA’s) and nest areas 

We also object to the need to thin areas to below 40 percent in areas that can affect northern goshawks. While we 

object to several aspects of the current Management Recommendations for Northern Goshawks (MRNG) and how 

they have been applied on the ground, the Forest Service has a requirement to ensure the viability of this species 

and should be equally concerned with other canopy-dependent species. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

354 Appendices

The Forest Service has not demonstrated that MRNG guidelines, as they are being implemented, are benefitting 

northern goshawks, their prey, or other canopy dependent species (i.e., Beier et al. 2008, 2012; Kalies et al. 2009; 

Dodd et al. 2006; UDSA 2005; AGFD 2003). The Forest Service should not aim to create a forest that is even 

more open than specified by MRNG unless it can ecologically and scientifically justify that it will not harm forest 

health or the viability of goshawks.

Response to Comment 10-5 

See response to comment 10-17. 

Alternatives 3 and 4 were designed to analyze the effects of conventional management of landscapes outside of 

goshawk PFAs. Alternative 2 would reduce canopy cover below 40% only in ponderosa pine forest outside of 

goshawk post-fledgling family areas (PFAs) and nest areas and outside of MSO Protected Habitat or 

Target/Threshold Habitat. Note that pre-settlement trees would be retained in these areas. Approximately 1-2 

trees per pre-settlement evidence (e.g., live or dead pre-settlement tree, stump hole) would be conserved after 

mechanical treatments, with a diversity of size classes being represented. This would restore these areas to 

approximate the conditions that existed prior to Euro-American settlement. Northern goshawks adapted and 

evolved to thrive on the landscape in those conditions. 

Dozens of northern goshawk territories occur on the Williams Ranger District, and hundreds occur across the 

National Forest System Lands, National Park Lands, and other protected lands of northern Arizona, allowing for 

viable genetic and demographic diversity. With this in mind, along with the fact that all nest areas and PFAs are 

conserved to retain densely forested conditions (even those that had many fewer trees/acre in pre-settlement 

times), it stands that the species will continue to thrive on the landscape, even if some ponderosa pine forest 

outside of the two nest areas and PFAs in the project area are restored to pre-settlement conditions. 

The Kaibab National Forest has a revised forest plan. The decision for this project will be signed under the 

revised plan. Proposed actions associated with this project are consistent with the revised forest plan and 

amendments are no longer needed. Although historic timber management resulted in a loss of goshawk nesting 

habitat in the past, the forest plan, and this project, ensures the conservation of the species by conserving any nest 

areas and PFAs, even in forest that was much less dense in pre-settlement times. Restoring pine forests that 

surround nest areas and PFAs would remove these pine forests from the timber base. Goshawks use a variety of 

habitat for foraging. The generalist species needs dense forest dominated by large trees for nesting and for the 

protection of juveniles, but it does not require such forest everywhere in its extensive range. See the wildlife 

specialist’s report, mitigation measures, and desired conditions in the EIS for more details, including references 

based on the best available science.

Comment 10-6 

Amendment 4 Allowing Forest managers to exceed fire planning objectives for the Arizona Bugbane 

Botanic Area. 

The Arizona bugbane is found in very small patches on Bill Williams Mountain. Rather than burning with a large 

fire, KNF should strategically thin from below in a careful manner to limit the fire risk to the Botanic Area. KNF 

should continue to exercise extreme caution with fire in and around the Botanic Area, rather than enlarge the size 

of permitted fires there.

Response to Comment 10-6 

See response to comment 8-2. 

The modified proposed action allows for prescribed fire within the Arizona Bugbane botanical area. Mitigation 

measures are identified in Chapter 2, Section 2.4.5.1. Extensive planning and discussions have taken place and 

are documented in the project record regarding the importance of the Arizona Bugbane population and botanical 

area.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 355

Mechanical treatment within the botanical area would help facilitate prescribed burning. These measures will help 

assist in meeting burn objectives as well as the future fire risk to the Arizona Bugbane population. The mitigation 

measures for the botanical area would require a thin from below strategy in areas that directly contribute to 

Arizona bugbane habitat with the objective of minimizing the risk of high intensity wildfires. 

The Kaibab National Forest has a revised forest plan. The decision for this project will be signed under the 

revised plan. Proposed actions associated with this project are consistent with the revised forest plan and 

amendments are no longer needed. Originally, direction in the old forest plan from 1988 required that the 

maximum annual accomplishment for prescribed burning be limited to 0.1 acres/year in the botanical area, which 

would have prohibited all prescribed burning within this area due to logistics and fire fighter safety. Further, the 

1988 forest plan did not allow for the restoration of fire as a natural process within the botanical area, which is a 

recommendation in the Arizona Bugbane Conservation Assessment and Strategy (1995), due to these prescribed 

fire limitations. 

Continuing this approach would not reduce the threat of high intensity wildfire within the botanical area, and 

jeopardizes Arizona bugbane and its habitat on Bill Williams Mountain. The modified proposed action includes 

the option to prescribe burn the entire AZ bugbane botanical area reducing the risk of high intensity fire, 

reintroducing fire as a natural process, and ultimately promoting the long-term conservation of this unique habitat 

and its biological associates. 

Comment 10-7 

Alternative 4 Comes Closest to meeting Project Purpose and Need 

Alternative 4 comes closest to meeting the purpose and need for this project for several reasons. First, its focus on 

using fire to manage a large part of the area is a more sustainable and ecologically defensible action. Likewise, the 

focus on utilizing fire helps to greatly reduce the cost compared to the other alternatives. Alternative 2 will cost 

$17.1 million; Alternative 3 will cost $56.2 million; and Alternative 4 will cost the least, at $7.1 million (DEIS 

Table 2, p. 44). 

KNF should select an alternative that it can actually afford to implement. If an unaffordable alternative is chosen, 

KNF is effectively misrepresenting the impacts of it in the DEIS and ensuring that the actions and effects will 

differ from what it is predicting. The agency must analyze effects of what it will actually implement. The cost of 

using natural processes and implementing a prescribed fire regime will be less costly than logging and will better 

meet ecological objectives. Cable logging adds a huge wasteful expense and a significant negative ecological cost 

as it removes large swaths of trees without protecting the desirable trees that lie in the paths of the cables. The 

inability to selectively remove trees in the paths of the cables, and the vertical swaths of bare ground that will be 

open to erosion, are ecologically undesirable. 

We make specific suggestions for improvement of Alternative 4 below. Also, we critique the Forest Service 

analysis that determines Alternative 2 to be the best option in the section below titled, “Analysis of Direct and 

Indirect Effects is Flawed.”

Response to Comment 10-7 

The cost of implementing alternative 2 pales in perspective to the cost of a large and catastrophic wildfire, cost of 

wildfire suppression, cost of a Burned Area Emergency Response (BAER) and economic effects on our local 

communities. For example, chapter three includes information in the socio economics section regarding the 

Schultz Fire which burned in 2010 on the neighboring Coconino National forest cost approx. $10 million for 

suppression, $4.1 million for BAER work, and $1.5 million on long-term rehab (roads, trails, hazard trees, rec 

sites, planting, etc.). The actual costs are even higher when the investments in the Environmental Assessment for 

the sediment reduction project and all the public meetings are included. There is also the cost to the affected 

community of approx. $130 million which includes Coconino County expenses, Arizona Department of 

Transportation (ADOT), utilities, insurance, lost economic activity, decline in home values, etc.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

356 Appendices

Alternative 2 would be expensive to implement, and we expect the project will have to be implemented in phases 

over the course of several years or more. Alternative 2 is more expensive than Alternative 4. However, 

Alternative 2 has some important advantages. Mechanical thinning provides an added level of effectiveness in 

reducing risk of stand replacing fire by reducing ladder fuels and crown bulk density compared to only using 

prescribed fire. The mechanical treatments also have the advantage of “widening” the burning prescription 

window or parameters in the mixed conifer forest type which are also implementation feasibility issues in 

Alternative 4. Prescribed fire in mixed conifer typically has a very narrow prescription window; it either won’t 

burn very well because conditions are too moist or it burns too hot and is difficult to control, with relatively little 

prescription space between the two ends of the window. As a result Alternative 4 presents more risk, and could 

take much longer to implement due to the narrow prescription window. 

Cable logging is no longer included in any of the alternatives in the project. Alternative steep slope thinning 

techniques address this comment. The cost to implement the modified proposed action is much less than the 

original proposed action. 

Comment 10-8 

Roads 

The DEIS claims that Alternative 4 will add no new roads. However, on page 18 it is noted that approximately 38 

miles of temporary roads will be constructed and obliterated after use. Temporary roads remove surface 

vegetation and can destabilize soils, causing erosion and inviting non-native weed establishment. An analysis of 

this should be included. 

Alternatives 2 and 3 include “the construction of a new and more sustainable road system that would also provide 

access for the fuel treatments” (DEIS, p. iv), without adding to the total road mileage on Bill Williams Mountain 

because of the obliteration of poorly located roads in drainage bottoms. If the new road system would truly be an 

improvement and reduce sedimentation and erosion, then it should be considered in Alternative 4. A major 

purpose of this project is to “directly and indirectly improve the watershed conditions contributing to the City of 

Williams water supply” (DEIS Purpose and Need for Action, p. 3), and if the new road configuration would help 

with that, it should be done. The road costs are similar across the alternatives (DEIS, Table 3.5-5). The road 

system should be improved to reduce long-term negative effects on the watershed. Temporary roads should not 

replace road improvements. All roads should be re-seeded after obliteration, and scarified if necessary. This is an 

important step to speed up the restoration process, help exclude non-native plants, and limit erosion. 

Response to Comment 10-8 

The modified proposed action reduces the miles of new roads from 23 to 15 miles. 

The environmental effects of the 38 miles of temporary road called for in Alternative 4 have already been 

analyzed. The construction of a “new and more sustainable road system” referred to as part of alternative 2 refers 

to the construction of new permanent system roads and the obliteration of 23 miles of poorly located and eroding 

existing roads. Under alternative 4 there is no construction of new “permanent” roads. Obliteration of 24 miles of 

existing road is included in alternatives 3 and 4. Since one of the intents of Alternative 4 was to have an 

alternative with no new permanent road constructed, we cannot add new permanent roads to this alternative. 

Under all alternatives, temporary roads would be closed, stabilized and either seeded or allowed to re-vegetate 

naturally to reduce potential long term impacts to the watershed.

The effects of temporary road construction under Alternative 4 are analyzed and disclosed in the soils and 

watershed specialist report, including predicted soil erosion and sediment delivery rates. Alternative 4 was 

developed in response to a request for an alternative that included no new construction of permanent roads. As a 

result, temporary road construction and use was analyzed under Alternative 4. Best Management Practices 

(BMPs) numbers 10 and 28 in Table 1, and those discussed on page 75, lines 44-46, and page 94, lines 26-29 of 

the Soils and Watershed Specialist Report are designed to mitigate adverse impacts to soils and watersheds 

resulting from temporary road construction, use and obliteration. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 357

Comment 10-9 

Strategic Fuels Treatments 

Strategic Fuels Treatments “designed specifically to enhance control lines would be implemented to enable land 

managers to achieve resource objectives with prescribed fire while serving to protect important resources. 

Treatments would reduce surface, ladder, and canopy fuels (i.e. fuel loading) up to 300 feet along both sides of 

control lines. ... Approximately 2,500 acres would receive non-commercial treatments and fuels would most 

likely be thinned by hand-felling techniques or, where practical, machinery equipped with cutting or grinding 

heads. These treatments represent the minimum acreage needed to prepare stands on steeper slopes for prescribed 

burning and would be combined with mechanical treatments where possible.” (DEIS, pp. 12-13) 

The Strategic Fuels treatments should be considered in the context of restoring natural fire to the forest. Rather 

than creating artificial linear swaths, the Forest Service should focus on utilizing the natural features of the land, 

including the vegetative features for fuel breaks. This means using the existing heterogeneity and creating 

additional vertical breaks where necessary. Overall, however, this should be minimized in order to reintroduce 

natural fires. (Allen et al. 2002, Weatherspoon and Skinner 1996). Wide, relatively straight clearings running 

perpendicular to slopes proposed can cause soil loss and habitat fragmentation and if the goal is to continue fire 

exclusion, then the treatments will be counterproductive. 

The Forest Service has a responsibility to ensure the viability of northern goshawk and other canopy dependent 

species. Areas cleared for these treatments must be considered in the cumulative impacts analysis regarding the 

amount of forest openings and VSS 1 and 2 areas. 

Response to Comment 10-9 

Strategic fuels treatments would enhance control lines for prescribed burning and would be used when and where 

necessary to prevent fire from moving out of areas prepared for fuels treatments. Strategic fuels treatments are not 

artificial linear swaths. They were designed to prepare stands on steeper slopes for prescribed burning. Allowing 

fire to play a natural role in the future in this project area has been considered and is referenced in the desired 

condition (Section 3.3.1) as well as the Cumulative Effects (3.3.3) of the fire and fuels specialist report (starting 

on FEIS page 87). Elements that fire managers would consider are discussed in Appendix C of the Fire and Fuels 

specialist report.

These treatments will only be placed where necessary for fire control and limited to the extent necessary for 

control. Natural features (such as rock outcroppings, rock screes) as well as existing man-made features (trails, 

roads) will be used to the greatest extent practical to create fire lines to help eliminate linear swaths. Placement of 

these treatments will also take into consideration areas that can take advantage of existing vegetation changes and 

topography. 

It is clear in the FEIS that the goal is not to continue fire exclusion, but to reintroduce fire to Bill Williams 

Mountain in a manner which is more readily controlled and minimizes adverse effects on soils and watershed 

resources. The effects on soils and watershed resources from proposed strategic fuels breaks were analyzed in the 

Soils and Watershed Specialists Report and the FEIS as follows (Table B-2): 

Table B-2. Locations in Soils and Watershed Specialist Report and FEIS where effects of proposed fuel breaks are 

analyzed

Soils and Watershed 

Specialist Report Page No.

FEIS Page No.

61 142

73 143

83 151

84
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

358 Appendices

Strategic fuels treatments would result in removal of the woody vegetation and woody debris that contributes to 

soil stability and nutrient availability. However, these treatments would also reduce soil burn severity by 

removing materials that contribute to smoldering fire conditions resulting in soil hydrophobicity and increased 

storm water runoff and erosion. Long term soil conditions would be improved as strategic fuels treatment areas 

naturally revegetate with grasses, forbs and shrubs following use of prescribed fire. 

The objectives of the strategic fuel treatments would be to facilitate holding of low intensity prescribed fires 

within burning units. Treatments would reduce ladder fuels and maintain the integrity of the canopy; therefore 

they would not result in creating more vegetative structural stage (VSS) 1 and 2 areas. These treatments would 

not result in a linear swath of all trees being cut, would have a natural appearance, and best management practices 

would ensure soil conservation (see map 4 in appendix A). They would be placed in areas to minimize 

fragmentation of habitat for species of conservation concern (e.g., Mexican spotted owl nesting and roosting 

habitat). 

The USDA Forest Service does have a responsibility to ensure the viability of northern goshawks and other 

canopy-dependent species. However, strategic fuel treatments are part of the action alternatives and the direct, 

indirect and cumulative effects of the alternatives on these species were analyzed in accordance with 40 CFR. 

See the wildlife specialist’s report and chapter 3 for analyses and determinations of effects of the action 

alternatives on species of concern.

Comment 10-10

Canopy Cover Should be Measured at the Stand Level 

Canopy cover and VSS class should be measured at the stand level, not group level. Measuring VSS class and 

canopy cover at the group level threatens to leave too little cover across the landscape to ensure viability of 

canopy dependent species. If structural stages and the associated canopy densities are only measured at the group 

or tree level, then species with contiguous canopy requirements will lose habitat. Measuring canopy only at the 

group scale allows the Forest Service to succeed in meeting guidelines on paper while failing to achieve 

guidelines on the ground. This should be addressed in the Final EIS. 

Response to Comment 10-10

Within goshawk habitat, the Kaibab National Forest Land Management Plan 2014 (forest plan) states that Canopy 

cover guidelines apply only to mid-aged to old forest structural stages (VSS 4, VSS 5, and VSS 6) and not to 

grass/forb/shrub to young forest structural stages (VSS 1, VSS 2, and VSS 3) p. 29. It also gives desired percent 

distribution of VSS (forest plan, pages 29 through 30). The plan does not specify at what spatial scale VSS and 

canopy cover is measured, and therefore no forest plan amendment is needed.

The analysis for this project measures VSS at the group scale (Methodology and Analysis Process section of the 

silviculture specialist report in the project record). Group scale data is then interpreted at the stand and Ecosystem 

Management Area (EMA) level. The 2014 forest plan (pg. 30) states “Project design should manage for 

replacement structural stages to assure continuous representation of old growth over time.” In addition (pg. 17) 

“tree groups are made up of clumps of various age classes and size classes that typically occur in areas less than 1 

acre, but may be larger such as on north facing slopes”. At the midscale, interspaces with native grasses, forb, and 

shrub vegetation are variably shaped and typically range from 10-70%.” The direction in the current forest plan is 

consistent with how VSS was measured under the old forest plan. 

The Bill Williams proposed treatments would move towards uneven-aged conditions. These treatments break the 

stands into different aged groups over time in order to eventually reach a regulated uneven-aged condition. This 

approach supports using VSS at the group level to analyze whether we are meeting desired distributions which 

also represents the stand and EMA level. The Bill Williams alternatives also attempt to meet the desired 

distribution of group VSS (based on group scale VSS designations) at both the stand scale and at the EMA scale. 

How well each alternative meets these distributions is analyzed in the direct and indirect effects section 3.2.2 of 

the FEIS.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 359

At the midscale under the revised forest plan, “interspaces with native grasses, forb, and shrub vegetation are 

variably shaped and typically range from 10-70%.” When canopy covers are being met at the group level for VSS 

4, 5, and 6 and the desired distribution of these structural stages are being met at the group level, this would imply 

that the desired conditions, canopy covers for VSS 4, 5, and 6, are also being met at the stand and EMA scales. 

The FEIS analyzes how well each alternative meets VSS distribution and canopy cover in the direct and indirect 

effects section of section 3.2.2 of the FEIS. The FEIS analyzes various habitat structures at the group scale, stand 

scale, and the EMA scale (see direct and indirect effects section of section 3.2.2). Table 3.2.2-18 of the dEIS 

outlines which alternative met each evaluation criteria for canopy cover and VSS distribution. 

The revised forest plan direction is consistent with how canopy cover was measured under the old forest plan.

Comment 10-11

Large Tree Retention 

There is a generally recognized need to retain larger trees and protect old growth in southwestern ponderosa pine 

forest restoration. Some proponents of large tree retention have suggested that a 16” diameter at breast height 

(dbh) cap is both ecologically and socio-politically warranted given the scarcity of mature and old growth forest 

cover in the region; the need to quickly re-establish lost mature and old forest structure; the necessity of retaining 

trees larger than 16” dbh to recruit new trees into regionally- underrepresented VSS 5, 6 and “old growth” 

structural stages; and the regional rarity of trees larger than 16” (approximately 96 percent of ponderosa pine trees 

in northern Arizona and New Mexico are smaller than 16-inch dbh). 

These diameter caps have been proposed as a means to (1) prevent large-tree logging for production- oriented, 

uneven-aged silvicultural goals, (2) discourage large-tree logging to pay for small-tree thinning or other activities, 

(3) favor small-diameter-specific industries over large-tree-dependent ones, (4) avoid population-level effects to 

imperiled species and wildlife that are associated with larger live and dead trees and denser canopy, (5) mitigate 

unforeseen large tree mortality during and following restoration treatments, (6) mitigate unknown rates of future 

large tree mortality resulting from re-establishing natural fire regimes and future climates, (7) mitigate underestimates of historical tree densities owing to evidence undercounting and loss to fire, logging, and decay, (8) 

accommodate differing reference scales, choices of reference attributes, restoration objectives, and desired 

degrees of precision or rates of change, (9) mitigate uncertainty about future national forest policy, timber, and 

wildlife habitat management, and (10) facilitate a restoration approach that reduces immediate crown fire threat 

while incrementally moving the forest toward its natural range of variability through a combination of thinning 

and natural fire. 

Research suggests that removal of smaller trees is more effective in reducing the likelihood of active crown fires 

than removal of larger trees (e.g., Scott 1998, Graham et al. 1999, Arno and Fiedler 2005, Hunter et al. 2007). 

Large tree removal is not necessary or beneficial to fire hazard reduction or ecological restoration (Allen et al. 

2002) and fire can often achieve restoration goals without removing any trees (Fulé et al. 2004, Stevens-Rumann 

et al. 2012). 

However, ponderosa pine forests historically contained a percentage of trees that were saplings, poles, and 

blackjack sized trees. To account for this, a diversity of tree sizes should be retained both within tree groups as 

well as across the restoration treatment area. Removing all of the smaller trees would result in oversimplification 

of the forest’s structure and distribution of trees by age class. Still, large trees should not be cut to make room 

for regeneration.

Response to Comment 10-11

As explained in the DEIS on page 27, “An alternative was considered but eliminated from detailed study that 

would conserve trees larger than 16 inches diameter ...” The DEIS (pp. 27-28) explains why this alternative was 

eliminated from detailed study. 

Table 3.2-17 of the DEIS illustrates the alternatives compared to large tree retention effectiveness for the short 

term, mid-term and long term. Depending on the action alternative large trees are also protected through time by 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

360 Appendices

a decreased fire and bark beetle risk. Alternative 1 maintains an increasing bark beetle and fire risk to large trees. 

Please refer to comment 10-26 for modeling assumptions with disturbances. 

The average diameters in VSS 5 and 6 provide an ecological tie to diameter numbers” (DEIS pg. 80). The large 

tree retention analysis shows the effect of the treatments which include developing regeneration areas. Managing 

for large trees across the landscape in the desired condition is met for all alternatives. Under Alternative 1, fire 

risk remains high and is a continuing threat to retention of large trees. 

The 2014 forest plan has provisions for protecting large, old trees (p. 30): “Project design and treatment 

prescriptions should generally not remove: Large, old ponderosa pine trees with reddish-yellow, wide platy bark, 

flattened tops, with moderate to full crowns and large drooping or gnarled limbs (e.g. Thomson’s age class 4, 

Dunning’s tree class 5 and/or Keen’s Tree Class 4, A & B [appendix C]). See forest plan consistency check 

verifying project design and mitigation measures. These and other measures to limit cutting of large and/or old 

trees are found in chapter two of the FEIS. 

Comment 10-12

Monitoring 

Monitoring should continue after the project, to evaluate ecological effects of this project that might not emerge 

for years after completion. There is no monitoring of northern goshawk in the plan; Mexican spotted owl is the 

only wildlife monitored. Monitoring should include evaluation of the persistence of sensitive species including 

northern goshawk, Mexican spotted owl, and Arizona bugbane; invasion of non-native plants; and development of 

forest structure including snags, coarse woody debris, and tree growth. 

Response to Comment 10-12

Monitoring of northern goshawk nest areas and PFAs has been clarified in the monitoring section of the FEIS. 

The wildlife monitoring section of the FEIS states that monitoring would be done for trees >18” DBH (combined 

with existing stand data, that would allow for monitoring of tree growth), snags, and other features of concern. 

The rare plants, noxious weeds, and Bill Williams Botanical Area monitoring sections address the commenter’s 

other concerns.

Monitoring recommendations for effects on soils and watershed have been addressed in the soils and watershed 

specialist report on page 99, lines 21-42 and page 100, lines 1-10. Monitoring for the presence of invasive or 

noxious weeds has been addressed in the FEIS on page 157. Monitoring recommendations for soils and watershed 

resources are included in the soils and watershed specialist report and chapter two of the FEIS:

“Known locations of rare plant populations, including Arizona bugbane, within the project area will be monitored 

throughout project implementation and thereafter to ensure their protection and viability” (Pg. 40, FEIS). 

The Williams Ranger District will continue its invasive species management program, which includes inventory, 

treatment, and monitoring of invasive plant species across the entire district in the following phases: Phase 1 – 

During Timber Harvest Activities; Phase 2 – Timber Sale Closure; Phase 3 – Broadcast and Pile Burning; Phase 4 

– Effectiveness Monitoring; and Phase 5 – Follow Up. 

Comment 10-13

Mistletoe Treatments 

Because the purpose of the Bill Williams Mountain Restoration Project is “to improve the health and 

sustainability of forested conditions on and surrounding Bill Williams Mountain”, and not to improve timber 

production, mistletoe treatments are unwarranted and counterproductive. Research repeatedly shows that 

mistletoe is an important component of healthy forest habitats, and large trees with mistletoe brooms provide 

essential food and occupancy needs to wildlife. Worldwide, species in 97 vertebrate families consume mistletoe 

and species in 50 vertebrate families use mistletoe for nesting; therefore mistletoe can be considered a keystone 

species in forest ecosystems (Watson 2001). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 361

Mistletoe brooms provide essential wildlife nesting, foraging, caching, resting, and roosting habitat for sites for 

Abert squirrel, porcupine, and passerine birds; managers should retain some broomed trees as wildlife habitat. 

(Parks et al. 1999, Mathiasen et al. 2004). Bird species richness in southwestern ponderosa pine forest positively 

correlates with level of dwarf mistletoe, and no bird species appear to have a negative correlation with dwarf 

mistletoe (Bennetts et al. 1996). Mistletoe provides a consistent food-based moisture source for squirrels 

(Pederson et al. 1987). Deer use was significantly higher in tree clusters with dwarf mistletoe in the Wet Beaver 

Creek watershed (Clary and Larson 1971). Mistletoes provide a climatically stable food resource for avian 

frugivores, even when other tree-based foods are unavailable due to drought. Plants that rely on birds to disperse 

seeds benefit from mistletoe, which correlates with bird presence through a range of climatic conditions (van 

Ommeren and Whitham 2002). Red squirrels rely on specific types of mistletoe brooms for nesting in mixedconifer forests in northern Arizona and New Mexico (Hedwall et al. 2006). Mistletoe provides inclement weather 

protection to porcupines in Douglas-fir (Smith 1975) and pine-juniper forests (Hoffer 1967). Number of branches 

within a mistletoe broom and tree height correlate with probability of Abert squirrel caching, foraging, and 

nesting. Taller trees with mistletoe are most important. 

Forest managers should keep trees > 18 m and with brooms having > 7 branches (Garnett et al. 2006). Since fire 

causes more scorch and there is higher fire mortality in medium scorch classes with mistletoe, if these areas will 

have prescribed burning in the future, mistletoe populations will be kept in check without intervention 

(Harrington et al. 1990).

Response to Comment 10-13

It is not an objective to eliminate mistletoe from the landscape in any of the action alternatives. It is recognized in 

the silvicultural and wildlife sections of the FEIS that mistletoe is an important component of forest ecosystems. 

Mitigation measures for the project include conservation of pre-settlement trees (regardless of mistletoe infection) 

and additional post-settlement trees in groups to promote the abundance of VSS 5 and 6 groups across the 

landscape. This will ensure conservation of most mistletoe-infected trees >18 m and with brooms having > 7 

branches, as such trees are typically pre-settlement or greater than 18” DBH (VSS 5 and 6 trees). Uneven aged 

silvicultural management within a landscape of high intensity and severity of mistletoe has proven to be 

impossible on the Williams Ranger District. The infected areas eventually break down and become susceptible to 

stand replacing fires and beetle mortality. As described in the Silviculture section of the FEIS this action prompts 

a new cohort of trees to represent the stand in an even aged stand dynamic.

Comment 10-14

Aspen Treatments 

Aspen historically resprouted after fires and ground clearing disturbances, acting as one of the first trees to 

stabilize soils and create conditions appropriate for conifer regeneration. Today, a major cause of the aspen 

decline and failure to regenerate within the project area is elk grazing (USDA 2001, Bailey and Whitham 2002). 

The Forest Service wishes to perform aspen treatments. The root of the problem is not being addressed. The 

Forest Service should support efforts to make sure the elk population is at a more sustainable level – that means 

supporting restoration of the predator prey relationship and ending the manipulation of habitat that encourages 

“growing” elk like a crop. KNF should refrain from allowing the installation of additional artificial waters and 

any artificial water features should be kept away from aspen stands.

Response to Comment 10-14

There are no artificial water developments proposed as part of this project. However, the project does attempt to 

develop new aspen regeneration and does address elk browsing by protecting newly developing aspen sprouts 

from elk and deer browsing with fencing and jack-strawing of activity slash. Elk population management in 

Arizona is the responsibility of the Arizona Game and Fish Department.

Comment 10-15

Bark Beetles 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

362 Appendices

A mitigation measure for bark beetles is to avoid non-commercial thinning that creates excess slash between 

January 1 and July 1, especially around private property (DEIS, p. 19). This should not just apply to noncommercial treatments; it should apply to all treatments, and in all parts of the project area.

Response to Comment 10-15

In general, non-commercial thinning operations would focus on felling small diameter material, less than 12” 

DBH. Timing restriction for non-commercial thinning operations is necessary because the material would be left 

on site and treated at a later date. This is due to the latent time activity slash is left in the forest that causes 

concerns with bark beetles outbreaks unless there are timing restrictions. The purpose of the timing restrictions 

for bark beetles in non-commercial slash is to prevent two bark beetle ‘hatches or flights’, in fresh slash, before 

the proceeding winter. The second flight, in fresh slash, is the most aggressive to the residual forest and these 

beetles before winter would prey on trees not necessarily stressed. These are the reasons for a timing restriction 

for non-commercial thinning.

Timing restrictions for commercial thinning regarding bark beetle activity is un-necessary for multiple reasons. 

The primary reason is due to the increased tree and stand vigor within a stand harvested commercially. In general, 

achieving desired condition and increasing tree vigor in most stands is more effective under commercial harvest. 

This prevents smaller diameter slash that may be retained longer on site (less than 5” in diameter), which dries 

more quickly, to likely support multiple generations of bark beetles. 

Timber sale contracts also impose restrictions of how long a cut tree bole can stay on site. Piles of limbs and tops 

will be located in landings and openings large enough so burning will not harm the residual stand. This would 

allow piles to dry out fast enough to inhibit bark beetle populations from increasing. 

One benefit of piles created from timber harvest is that they are easy to burn and consume a lot of slash at once. 

This is good to capture beetles that may be overwintering in piles get consumed in the burning process, lowering 

the numbers for the following year’s spring flight. The piling objective isn’t to capture beetles but this association 

after timber harvest activity could reduce the probability of an outbreak.

Comment 10-16

Range 

A mitigation measure for range is to rest pastures for at least one growing season prior to and following burning. 

In reality, some pastures may require rest for several years post burning in order to allow native plants to 

regenerate to the best potential, and to reduce non-native weeds and soil erosion. Likewise, the Forest Service 

should evaluate whether livestock grazing is suitable for these areas.

Response to Comment 10-16

Post-fire grazing deferment varies based on site specific conditions. Soil stability and plant health will be assessed 

prior to the authorization of grazing in burned areas (Pg. 34, FEIS). Range managers will work closely with the 

grazing permittee prior to and following any prescribed burning to ensure that areas are either ready to burn or are 

ready to be grazed again.

Monitoring and assessment of rangeland conditions provide the qualitative and quantitative information necessary 

to support decisions on livestock use and stocking rates. These data are supplemented with information gathered 

during soils and watershed condition assessment and monitoring such as those outlined in the soils and watershed 

specialist report. The purpose and need for authorization or reauthorization of livestock grazing is determined in 

separate environmental analyses and are therefore beyond the scope of this analysis.

Grazing suitability is evaluated in the development of the revised forest plan, and is beyond the scope of the Bill 

Williams Project. The Hat Allotment underwent an environmental analysis in 2010 in which the decision 

excluded livestock grazing from the steeper slopes of Bill Williams Mountain (approximately 2,500 acres). The 

analysis also disclosed the grazing capacity for the allotment, which includes the pastures surrounding Bill 

Williams Mountain. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 363

Comment 10-17

Savannah Restoration 

This issue was discussed in the Four Forests Restoration Initiative process and was very controversial. No 

consensus, scientific or otherwise, was reached. The Forest Service should take a conservative approach relative 

to any treatments.

Response to Comment 10-17

Treatments to restore savannahs under Alternative 2 were indeed designed using a conservative approach. 

Desired conditions within the ponderosa pine cover type outside of goshawk PFAs and nest areas and outside of 

Mexican spotted owl (MSO) Protected Habitat or Target/Threshold Habitat, are as follows: “Tree density, spatial 

orientation, and species distribution of trees in the ponderosa pine cover type will be maintained in a state that is 

close to vegetative reference conditions.” These are the only areas that would be impacted by savannah 

restoration treatments. They lie outside of important nesting and roosting habitat for MSOs and goshawks (areas 

that would be managed for more densely forested conditions and not in line with vegetative reference conditions). 

This approach results in a mosaic of treatments across the landscape and places savannah restoration treatments in 

areas where there is the lowest risk for unintended adverse effects on wildlife or other resources. Furthermore, 

this balanced approach to savannah restoration treatments would benefit other declining wildlife species of 

concern (e.g., pronghorn; see wildlife section of EIS for details). 

Minimizing the loss of pre-settlement trees, conserving trees >24” DBH, promoting large hardwoods, and 

retaining snags are examples of mitigation measures (FEIS Section 2.4.5.1) that ensure the conservation of 

important habitat components in savannah restoration treatments. Vegetative reference conditions would inform 

savannah restoration. In this project area, reference conditions indicate that more groups of trees >18”DBH were 

on the landscape than exist today (DEIS, pg. 77). Therefore, silvicultural and prescribed fire prescriptions would 

strive to restore more trees >18” DBH on the landscape. Also see response to comment 10-21. 

Comment 10-18

Rare Plants 

A mitigation measure for rare plants states, “where possible road construction will avoid known plant 

populations” (DEIS, p. 19). Are they so abundant that roads can’t avoid all known populations of rare plants? 

Also, the DEIS states that relative to mitigation measures, “Rare plant surveys and surveys for Native American 

medicinal and ceremonial plants, such as Porter's licorice-root (syn. osha root, Ligusticum porteri), within the 

project area will occur where suitable habitat exists. The extent and scale of these surveys will be dependent upon 

funding.” (DEIS, p. 19) Work should be postponed if the cost of vegetation surveys can’t be paid for. When 

discussing a potentially $56 million project (DEIS Table 2, p. 44), it is unreasonable that the Forest Service would 

not invest in protecting natural and cultural resources such as rare and ethnobotanically important rare plants. If 

thinning is to be done commercially, it should be factored into the cost of commercial work, paid to the Forest 

Service with the cost of trees removed.

Response to Comment 10-18

The Kaibab National Forest has partnered with the Hualapai Tribe to conduct rare plant surveys and surveys for 

Native American medicinal and ceremonial plants within the project area. The Hualapai Tribe has already 

initiated fieldwork for these surveys, and fieldwork will continue at least through 2014. 

The approximate length and location of proposed roads are illustrated in Appendix A. There are no known 

occurrences where a proposed road intersects a rare plant population. If rare plant populations are discovered 

during implementation they will be avoided. However, if an action is essential to project implementation and will 

not likely contribute to a trend toward federal listing or a loss of species viability, then the action may be 

permitted. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

364 Appendices

Comment 10-19

Prescribed Burning as a Management Action 

An alternative was eliminated from detailed study that would employ prescribed burning only. A reason given for 

its elimination was:

“Additionally, this alternative would not meet the purpose and need for action because it would not provide 

for forest products, and would not effectively meet the need to reduce stand densities. As Kaufmann et al. 

(2005) demonstrates, the best way to restore forested stands that are denser than historical times is through 

mechanical thinning.” (DEIS, p. 26) 

There are two problems with this statement. First, production of forest products is not in the Purpose and Need 

section. Also, the Forest Service doesn’t explain how prescribed burning would not reduce stand densities. Fire 

can often achieve restoration goals without removing any trees (Fulé et al. 2004, Stevens- Rumann et al. 2012). 

Response to Comment 10-19

Section 1.3 under Purpose and Need for Action of the FEIS, bullet 10 states...to provide forest products, such as 

firewood, for people...

Current conditions in much of the Bill Williams Mountain Restoration Project area have dense stands of trees with 

interlocked crowns, an abundance of ladder fuels and heavy surface fuel loadings. These conditions are conducive 

to extreme fire behavior and high severity fire effects due to both surface and crown fire potential at levels of 

intensity that produce mortality within many aspects of the environment. The project area also has a very complex 

topography system, an element that can exacerbate fire potential. An example of these conditions can be seen in 

the FEIS on page 89, Figure 3-30. This figure shows the modeled effects of a wildfire under the current 

conditions. 

Although prescribed fire is conducted within specific weather parameters, the surface fuel loadings, ladder fuels 

and interlocked crowns in congruence with the steep topography and multiple landscape changes (aspect, fuel 

moistures, dead to live vegetation ratio, etc.) make for the prediction of the amount and spatial configuration of 

tree mortality difficult to predict. It is possible that fire managers would not be able to control fire or find 

windows of opportunity to conduct implementation of a prescribed burn due to so many dynamic constraints. This 

could lead to not meeting the desired condition. Prescribed fire could reduce stand densities, but it is very hard to 

predict or control the level, amount and spatial scale of the mortality. This could be very detrimental to wildlife 

habitat including the MSO and PAC as well as affect the watershed condition, soil integrity, private lands and 

communication sites as well as foster an unsafe environment for firefighters and the public.

Prescribed fire treatments that are not preceded by treatments to reduce stand densities (i.e., mechanical or nonmechanical thinning) have increased potential to adversely affect soils and watersheds through higher burn 

severities that then increase soil hydrophobicity and erosion, reducing soil productivity and degrading surface 

water quality. It is likely that the use of prescribed fire only in some areas on Bill Williams Mountain would 

reduce stand densities, but this would be to the detriment of soils and watershed health if higher burn severities 

increase soil erosion and sediment delivery to stream courses.

Comment 10-20

Campfire Restrictions 

In addition to the proposed action, the Forest Service can decrease the chances of unplanned wildfires by 

instituting a seasonal campfire restriction during northern Arizona’s annual dry season. KNF doesn’t make a case 

for not including a campfire ban as a part of an alternative. By banning campfires on the same dates each year, the 

costs associated with educating the public and patrolling would be decreased from the current situation, where 

campfire bans occur at irregular intervals based on localized conditions. Public safety would be increased, and 

since unplanned ignitions would be reduced, firefighters safety and ecological health would be improved also. 

KNF makes a strong case for why fire in this area could risk important private, and public assets, including 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 365

communications towers and the City of Williams’ water supply. Therefore, the Bill Williams Mountain project 

area is a prime example of a land parcel that could benefit from seasonal campfire restrictions.

Response to Comment 10-20

The Kaibab National Forest is continuously working to improve fire management decision processes, relative to 

fire conditions and campfire restrictions/closures. The forest works closely with our interagency fire partners 

(State, County, Tribal, local fire districts, and other Federal agencies) to monitor specific criteria when 

considering the appropriate time and locations to enter campfire restrictions. These factors include such things as 

previous weather patterns, current weather, fire potential outlook, number of active fire starts and their causes, 

firefighting resource availability, and social, political, and economic impacts to communities. Simply 

implementing fire restrictions does not stop campfires. During fire restrictions Forest Service law enforcement 

officers often issue many citations for illegal campfires.

Comment 10-21

Table 3.2-6 – How do these “seral stages” compare to the VSS classes referred to elsewhere in the document? 

How does maintaining 50 percent of ponderosa pine in early seral stage and 50 percent in mid to late seral stage 

meet the guidelines for northern goshawk requiring 60 percent of forest to be in VSS classes 4-6? The Forest 

Service must be clear and consistent in describing what it intends to do, and what the predicted outcome of its 

actions will be. Using VSS data to determine canopy or forest structure at the group or individual tree level could 

present a false picture of stand conditions and associated canopy. “Vegetation structural stage (VSS) is a method 

of describing the growth stages of a stand of living trees. It is based on tree size (DBH) and total canopy cover” 

(Appendix 5, MRNG). VSS is “a generalized description of forest growth and aging stages based on the majority 

of the trees in the specific diameter distribution of the stand” (Glossary of Terms, MRNG). The Forest Service is 

obligated to meet goshawk guidelines for VSS classes, and if they have other ways to measure canopy cover or 

seral stage, they need to show that using those categories of land cover won’t impede their chance to meet 

goshawk guidelines.

Response to Comment 10-21

The Sierra Club asked how Table 3.2-6 in the DEIS was compared to VSS classification. Table 3.2-6 was 

described in the DEIS “to show, with generalized assumptions, on how alternative 2 will represent a pine savanna 

condition with grassy openings surrounding tree groups compared to all the alternatives. Assumptions are based 

on aerial imagery of the project area and previous treatments” (pg. 54, DEIS). This comparison was needed to 

demonstrate the difference between alternative 2 and the other alternatives.

The Kaibab National Forest has a revised forest plan. The decision for this project will be signed under the 

revised plan. Proposed actions associated with this project are consistent with the revised forest plan and 

amendments are no longer needed. Alternative 2 originally included a site-specific forest plan amendment to “redesignate the land suitability classification within the project area to allow restoration treatments to move 

vegetative conditions toward the reference condition” (pg. 3, DEIS). Based on table 3.2-6 of the DEIS, the 

assumption for the ponderosa pine in the project area under alternative 2 would have approximately 50% of the 

forested area to remain in an early seral stage. This means that the 50% of the remaining area is forested area in 

alternative 2 and will be managed for various VSS classes. The percentages are assumptions and approximations 

which would average across the project area but each stand would have different densities based on their 

reference conditions and habitat requirements.

The other alternatives, for ponderosa pine, as shown in table 3.2-6 are consistent with the forest plan VSS desired 

conditions. 20% of an early seral stage for ponderosa pine, categorized in table 3.2-6, in alternative 3 and 4 

represent 10% for VSS 1 and 10% for VSS 2. Aerial imagery was used to estimate 5% for the no action 

alternative in ponderosa pine. In response to comments, and to be consistent with the revised forest plan, 

“interspace and canopy cover” will be used to demonstrate openness.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

366 Appendices

Comment 10-22

Why is piñon-juniper going to move from 20 percent to 75 percent early seral stage? What is the need for treating 

piñon-juniper forests? Where is the science justifying fire risk and/or ecological benefit of thinning piñon-juniper 

forests?

Response to Comment 10-22

The assumptions of Table 3.2-6 (Table 3-2 in the FEIS) are outlined in the response to comment 10-21 and on 

pages 65-66 of the FEIS. Based on aerial imagery, on the ground assessments and desired conditions, it was 

assumed these changes are present across the project area in the pinyon juniper cover type. “Woodlands will be 

maintained at stocking levels that are much closer to reference conditions”. Primary objectives within this cover 

type would be an un-even aged forest condition, sustaining a mosaic of vegetation densities, and age classes and 

species composition.

The objectives are consistent with the 2014 forest plan direction, “Pinyon-juniper communities occur as a shifting 

mosaic interspersed with openings across the landscape. The configuration of vegetation and openings provides 

foraging and browsing opportunities for wildlife, and enough sighting distance and hiding cover for pronghorn to 

escape predators...Old growth occurs throughout the landscape, generally in small areas as individual 

components, or as clumps. The location of old growth shifts on the landscape over time as a result of succession 

and disturbance (tree growth and mortality)...At the mid-scale and above, canopy cover is at least 10 percent with 

a mix of young and mature groups and clumps of trees”(Forest Plan Page 31). 

The Bill Williams project objectives would maintain resiliency to future disturbances within the project area. 

Chapter 3, Section 3.3 of the DEIS discusses fire regime of the pinyon juniper forest inside the project area as 

well as the current and desired condition class (pages 95 and 96). 

Comment 10-23

How will aspen move from 5 percent to 50 percent early seral stage after a treatment year? What is the benefit of 

removing older aspen when aspen is already limited and declining?

Response to Comment 10-23

There would be no prescribed aspen removal on the Bill William Mountain Restoration Project. Outlined 

assumptions of Table 3.2-6 (Table 3-2 in the FEIS) are explained in comment 10-21 and on pages 65-66 of the 

FEIS. On the ground assessments and aerial imagery show that these aspen stands are dominated with conifer 

species and overstory aspen trees are outcompeted for resources promoting population decline. This vegetation 

state is described in the Bill Williams FEIS current conditions in chapter three. The changes in Table 3.2-6 (Table 

3-2 in the FEIS) would be due to the removal of conifers to help increase the vigor of aspens in aspen stands 

described in the desired conditions in the FEIS. 

Comment 10-24

Fig 3.2-11: Alternatives 2 and 4 end up with levels of VSS 1 and 2 within ranges specified by Forest Plan. 

Alternative 2 “would exceed the grass/forb/shrub percentage across the ponderosa pine type, it is deemed 

acceptable because the entire grass/forb/shrub stage isn’t intended for regeneration areas” (DEIS, p. 56). This is, 

in fact, not acceptable. The Forest Service has a legal obligation to keep a certain percentage of the landscape in 

other VSS classes to meet Forest Plan guidelines, and cannot remove those to create more VSS 1 and 2.

Response to Comment 10-24

The VSS analysis only represents the forested areas within the project. In the case of alternative 2, the forested 

area is approximately 50% (Table 3.2-6, DEIS; Table 3-2 in the FEIS) of what the forested area is for alternative 3 

and 4. Alternatives 3 and 4 were developed to be compliant with the forest plan. The Kaibab National Forest has 

a revised forest plan. The decision for this project will be signed under the revised plan. Proposed actions 

associated with this project are consistent with the revised forest plan and amendments are no longer needed. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 367

VSS classification was a tool used in analysis to determine separate age classes and uneven-aged forest. This was 

determined to be appropriate due to the desire to manage and sustain uneven aged forest conditions in the revised 

forest plan. VSS was used in project design to manage for replacement structural stages which assures continuous 

representation of old growth over time. The use of VSS as a descriptor does not violate the revised forest plan 

desired conditions, standards and guidelines. In response to comments, and to be consistent with the revised forest 

plan, “interspace and canopy cover” will be used to demonstrate openness.

Refer also to comment 10-21.

Comment 10-25

Modeling only included one case of future burning (R. Gonzalez, personal communication). Future burning will 

reset seral stages. Since the text associated with the graph indicates that the modeled levels of VSS 1 and 2 are 

low “due to larger yellow pines, larger trees and reserve trees among areas designated for regeneration”, and 

“future non-modeled events can increase grass/forb/shrub to seedling/sapling stages from burning and future 

tending events (White 1985). It is likely grass/forb/shrub and seedling/sapling stages would increase within the 

project area under action alternatives (White 1985, Rietveld 1978). VSS 1 and 2 are underrepresented due to the 

averaging of multiple sizes with grass/forb/shrub to seedling/sapling stages with larger trees, based on basal area 

of tree sizes, in a group.” (DEIS, p. 56) Isn’t it possible that Alternative 2 would increase area of VSS 1 and 2 

beyond Forest Plan guidelines? Since we can’t predict that these areas will in fact regenerate, and if so, when, 

why create a condition that fails to meet Forest Plan guidelines?

Response to Comment 10-25

Modeling of one burning event is acceptable and realistic due to the burning objectives. It is not an objective to 

thin overstory trees with fire. Thinning overstory trees with fire has proven to fuels managers to be risky to fire 

fighter safety and achieving desired conditions. The only time that seral stages would be ‘reset’ with fire is in a 

case of overstory mortality from burning; this is not an objective in the Bill Williams Mountain Restoration 

Project. Burning prescriptions were designed to reduce fuels to specified levels acceptable in the forest plan and 

to achieve incidental thinning of small diameter under-story trees susceptible to mortality by pre-heating and 

scorch. 

Alternative 2 will not increase VSS 1 and 2 beyond what’s needed for uneven aged condition, specified by the 

forest plan. In the case of alternative 2, the forested area is approximately 50% (Table 3-2, FEIS) of what the 

forested area is for alternative 3 and 4. 

The 50% of an area at an early seral stage, due to the land re-designation, is not intended to be VSS 1 and 2. The 

intent of these openings around groups of trees is based on restoration treatments and some areas will be very 

open, and some will be dense since they would be based on historic reference conditions. The distribution of tree 

groups is still followed as directed by the forest plan. 

VSS 1 is the grass/forb/shrub phase intended to move into VSS 2, the seedling/sapling phase and has a density to 

meet VSS 6. The 50% of area with the early seral stage in table 3-2 does not have this same density. Interspaces 

between groups would be maintained with fire. Calling these early seral stage areas VSS 1 would be equivalent to 

calling them a prairie, maintained to have no trees, which is not intended using the VSS classification system 

classifying forested areas.

In response to comments, and to be consistent with the revised forest plan, “interspace and canopy cover” is be 

used to demonstrate openness. 

Comment 10-26

Figure 3.2-12 – Alternative 1 (no action) best meets desired percentage of VSS 3 in “Landscapes Outside 

Goshawk PFAs” (LOGPFAs) at Stand Level; effects of other actions are hard to differentiate. Alternative 4 best 

meets desired percentage of stand in VSS 3 at tree group and EMA level. It looks like all error bars overlap at 

Stand Level except for the no action alternative (which best approximates desired outcome); at tree group and 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

368 Appendices

EMA level, alternatives 1 (no action) and 2 have overlapping error bars in 40 years, while alternative 3 and 4 

overlap and best approximate the desired outcome. Therefore, at the stand level, only Alternative 1 achieves 

objectives, and it best meets objectives for VSS 3 at other scales.

Response to Comment 10-26

Vegetative Structural Stage (VSS) classification is a tool used in the analysis to determine separate age classes for 

an uneven-aged forest. The use of VSS was determined to be appropriate due to the desire to manage and sustain 

uneven aged forest conditions in the revised forest plan. VSS is a generalized description of forest growth and 

aging stages based on the majority of the trees in the specific diameter distribution of a group of trees. VSS was 

used in project analysis to manage for replacement structural stages which assures continuous representation of 

regeneration and old growth over time. The use of VSS as a guide or an analysis tool does not violate the revised 

forest plan desired conditions, standards and guidelines. 

There are a couple of factors taken into consideration when determining if modeled results meet or don’t meet the 

desired conditions though time. This has to do with modeling assumptions. The modeling for the Bill Williams 

project assumes disturbances such as catastrophic fire and bark beetle attacks are static. These types of 

unforeseeable events are not modeled in FVS due to the uncertainty of intensity, severity and location. Modeling 

future disturbance is difficult due to changing of condition and unpredictability. Depending on the intensity and 

severity of fire, insects or diseases; the associated mortality would contribute to changes in structural diversity and 

sustainability” (pg. 60, FEIS). This is why managers rely on ‘risk’ modeling. 

Figure 3.2-31 of the DEIS shows that under the no action alternative, the area is at an extreme risk for back beetle 

epidemics based on risk modeling. . This is primarily resulting from an even aged forest dominated by VSS 3 and 

VSS 4. So even though Alternative 1 modeling could be interpreted as ‘best’ meeting VSS 3, consideration of risk 

adds another element to the interpretation of the results. Alternative 1 is not ‘best’ at meeting the desired 

condition because of the lack of forest resiliency from natural disturbances such as catastrophic wildfires and the 

intense bark beetle risk. The condition modeled used a static scenario to show trends to forest structure and 

conditions. It is unlikely in Alternative 1 that forests could ‘fend off’ stand replacement wildfires and bark beetle 

epidemics. Therefore the modeled outcome was not sustainable overtime.

However, the action alternatives best meet the desired conditions for stand level VSS 3 directly after treatment. 

The analysis shows how “action alternatives for VSS 3 (young forest) trend to forest plan guidelines directly after 

treatment where no action directly after treatment remains above 10 percent of the desired condition” (pg. 56, 

DEIS).

The modeling results for the action alternatives in Figure 3.2-12 do show a decline below desired conditions after 

treatment date but the modeling assumed this was acceptable in order to maintain the integrity of all desired 

conditions. Since the management of VSS is a balance of forest structural stages, based on a percentage (totaling 

100%), future vegetative cutting treatments of higher VSS classes would move VSS 3 stand level averages toward 

desired condition. This strategy moves the forest condition toward the desired distribution of VSS more quickly. 

The risk assumption (described above) in the modeling was not applied to the no action alternative. Refer to 

comment 10-28 for a response on error bars. 

Comment 10-27

The text is describing Figure 3.2-12 is wrong. It says, “Through time at the tree group and EMA level, all 

alternatives returned to desired condition, with alternative 2 being closest to 20%.” (p. 56). Actually, Alternative 2 

is higher than 20%, and indistinguishable from Alternative 1. Alternative 4 is closest to 20%, and moves toward 

desired conditions most quickly of the action alternatives.

Response to Comment 10-27

For alternative 2, Figure 3.2-12 demonstrates how VSS 3 at the group and EMA level would be within 5% (+/-) of 

the desired condition through the whole simulation. No other alternative remains as close to the desired 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 369

conditions as alternative 2. The no action alternative does not meet the desired conditions based on the modeling 

assumption regarding risk outlined in comment 10-26. 

Comment 10-28

Fig. 3.2-13 – Again, for VSS 4, at both scales, all error bars except Alternative 1 (no action) overlap by 2053 

timepoint. Therefore, there is no difference between the outcome of the alternatives. 

Response to Comment 10-28

The discussion explaining the differences between alternatives (FEIS pp 93-95) is discussing effects based on 

assumptions outlined in comment 10-26. 

The Forest Service forest vegetation simulator (FVS) was used to model attributes for the Bill Williams Mountain 

Restoration Project vegetation analysis. This program uses computer modeling based on equations to assess 

forest inventory data, which was taken through forest service common stand exam (CSE) procedures, to depict 

stand conditions at the time of inventory, evaluate it through time and projected with treatments. Data results 

from FVS were evaluated and displayed in graphs in order to evaluate the alternatives based on evaluation 

criteria. Error bars were provided to display their statistical significance to each other.

When the graph lines, with error bars, are expressed in a relationship between two or more variables, they often 

rely on equations to properly configure their values. If the data values are not statistically significant to each 

other, error bars can show how far the entered value is from the true or correct value (i.e. if there are more data 

contributing to the equation the error bars become smaller). The interpretation of FVS data in the analysis, not 

taking into the consideration of error bar overlap, provides the ability to evaluate criteria against other alternatives 

but ultimately to the desired condition. Evaluation of the desired condition in relation to each alternative is more 

meaningful. 

A summary of these results is displayed in Table 3.2-18 of the DEIS. This table displays how well an alternative 

met the desired condition, not which alternative ranked better over another. This is especially important when 

managing for a desired distribution of VSS. VSS is the evaluation criterion we use to display the desired 

condition for forest vegetation. To manage for desired conditions based on VSS requires balance of all classes 

amongst the population being evaluated. It is extremely difficult to achieve balanced VSS classes in every 

scenario. That is why balance is interpreted and evaluated at multiple levels to determine if an alternative 

ultimately meets the desired condition. In response to this comment and to reduce confusion table 3.2.18 was 

removed from the EIS. 

VSS classification is an analysis tool used to determine separate age classes and amount of uneven-aged forest, 

and was determined to be appropriate due to the desire to manage and sustain uneven aged forest conditions in the 

forest plan. VSS was used in project design to manage for replacement structural stages, which assures continuous 

representation of old growth over time. The use of VSS does not violate the revised forest plan desired 

conditions, standards and guidelines. 

Comment 10-29

Fig. 3.2-14 – Again, for VSS 5, at Stand Level scale, all error bars except Alternative 1 (no action) overlap by 

2053 timepoint. At tree group level, all error bars except no action alternative overlap until the 2053 timescale, 

when Alternative 2 begins to leave less VSS 5 on the landscape than the all other alternatives except Alternative 1.

Response to Comment 10-29

See response to comment 10-28. 

Comment 10-30

Fig. 3.2-15 – At 2053 timepoint, Alternatives 3 and 4 most closely match Forest Plan guidelines, with error bars 

overlapping. At tree group and EMA level, all error bars overlap at 2053 timepoint except Alternative 1, and less 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

370 Appendices

than half of VSS 6 target is reached. To increase chances of reaching VSS 6 targets in the near term, VSS 4 and 5 

classes should be protected to the greatest extent possible.

Response to Comment 10-30

The difference among the alternatives is found on FEIS pp 93-95. The differences are based on assumptions 

outlined in response 10-26. Implementing alternative 2 reaches the desired conditions quicker than alternatives 3 

and 4. Alternative 2 also remains the closest to the desired condition for 30 years into the simulation. The 

modeling resulted in too much VSS 6, but this was deemed acceptable based on the modeling assumptions 

outlined in comment 10-26. See comment 10-26 for explanation of how VSS is based on age and how average 

tree size is used as a guide. VSS 6 also contributes to the amount of large trees and reflects the maintenance of 

pre-settlement trees. See comment 10-28 regarding error bars. 

Comment 10-31

VSS 5 - Alternative 2 does not move toward desired conditions more quickly than other alternatives when we 

consider that overlapping error bars mean effects cannot be distinguished. It does not build up any more of an 

excess of VSS 5 than other alternatives (in fact, at tree group and EMA level, it is less). It is unclear why this 

translates to “future increases in VSS 6”. Over time, Alternative 4 can be considered as best meeting the 

objectives of the plan because its error bars often end up overlappingwith target conditions, and it leaves more 

surplus VSS 5 at tree group/EMA level to eventually grow into underrepresented VSS 6. At Stand Level, there is 

no difference in error bars of VSS 5 remaining at any time step. Alternative 2 does not move “the best toward the 

desired condition directly and through time” because, again, the error bars overlap with other alternatives: at 

Stand level, Alternatives 3 and 4 end up closest to target conditions when error bars finally separate at 2053 time 

step; none of the alternatives rises above 10% at tree group and EMA level, and all end up at same place in 2053. 

The Forest Service has arbitrarily and incorrectly interpreted the results of VSS class modeling over time.

Response to Comment 10-31

The FEIS states “Alternatives 3 and 4 directly meet the VSS 5 desired condition the best.” (pg. 69). The 

evaluation of VSS in the FEIS does not only rely on the ending result at the end of simulation. Direct effects after 

treatment, from treatment year and after treatment year, factored with how well the values modeled through each 

year were other evaluations used to determine how well each alternative modeled against each other. See 

comment 10-28 for a response regarding error bars. 

Comment 10-32

Figure 3.2-16 – Again, the Forest Service arbitrarily interprets this result. At only one time step, 2023, do the 

proposed alternatives differ significantly from the no action alternative (Alternative 1) in the percent of VSS 1 and 

2 on the landscape. There is nothing presented in the DEIS to support the statements, “Alternative 1 would 

maintain even aged conditions across the PFA limiting the amount of grass/forb/shrub and seedling/sapling stages 

needed to meet the desired conditions. Under alternative 1, grass/forb/shrub and seedling/sapling stages would 

only increase from overstory mortality events triggered from insects and diseases or stand replacing fires. 

Alternative 2, 3 and 4 best meet the desired conditions for grass/forb/shrub and seedling/sapling stages in PFAs.” 

(DEIS, p. 59) 

Response to Comment 10-32

The current conditions in the project include a high density of similar aged trees in the project area. This impedes 

the development of grasses, forbs, and shrubs in the forest understory. Some stands also have a large number of 

fairly even-aged trees, which is hindering the regeneration and development of younger trees in the understory”. 

Figure 3-2 of the FEIS displays the current condition of VSS for the ponderosa pine goshawk habitat in the 

project area. Figure 3-2 clearly shows that the amount of “VSS 3 and 4 are approximately twice the desired 

condition. Limited forest structure diversity leads to uncertain forest sustainability (Binkley et al. 2007)” (pg. 58, 

FEIS). See comment 10-28 and 10-26. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 371

Comment 10-33

Figure 3.2-17 – It appears that the no action alternative is the only alternative that moves toward the desired 

condition for VSS 3 over time. The treatments move the level of VSS 3 below the target level, and it is unclear 

how “Future thinning treatments can move the stand level VSS toward the desired condition.” 

Response to Comment 10-33

See comment 10-26 for explanation of how VSS is based on age and how average tree size is used as a guide. 

VSS is an evaluation criterion in the FEIS to display the desired condition of forest vegetation. VSS is based on a 

percentage, totaling to 100%. To manage for desired conditions based on VSS requires balance of all classes 

amongst the population being evaluated. That is why balance is interpreted and evaluated at multiple scales. 

Thinning to achieve VSS desired conditions is based on treating over-represented VSS classes. If natural 

processes, such as fire and insects, do not maintain desired conditions through time, future thinning can maintain 

the VSS balance in future cutting cycles. Lack of modeling for future disturbance events is discussed in comment 

10-26. 

VSS classification was a tool used in analysis to determine separate age classes and uneven-aged forest. This was 

determined to be appropriate due to the desire to manage and sustain uneven aged forest conditions in the revised 

forest plan. VSS was used in project design to manage for replacement structural stages which assures continuous 

representation of old growth over time. The use of VSS does not violate the revised forest plan desired 

conditions, standards and guidelines. 

Comment 10-34

Figure 3.2-20 – The prediction that excess VSS 4 will cause PFA Alternative 2,3, and 4 to decrease the level of 

VSS 6 over time does not make sense when VSS 5 should be growing into VSS 6. The Nest Alternative 2, 3, and 

4, which causes a similar (though slightly decreased) increase in VSS 4, achieves the desired condition, as does no 

action (Nest Alternative 1). The techniques that are most likely to achieve desired conditions should be employed. 

Response to Comment 10-34

See comment 10-33 for VSS clarification. Figure 3.2-1, of the DEIS, clearly demonstrates how there is an excess 

of almost twice of the desired condition for VSS 4 in ponderosa pine PFA in almost the whole scenario for all the 

alternatives. Due to this, “Post-fledgling family areas will include the nest sites” (pg. 29, 1988 forest plan), 

desired conditions in VSS 4 remain above threshold due to conserving the desired conditions for goshawk nest 

areas. According to analysis, VSS 4 starts to increase. This means VSS 3 are moving to VSS 4 class. The 

desired VSS distribution could be maintained with thinning, but won’t due to maintaining desired nest stand 

conditions. Areas outside of goshawk nest stands and within the PFA would maintain desired conditions though 

the action alternatives.

VSS classification was a tool used in analysis to determine separate age classes and uneven-aged forest. This was 

determined to be appropriate due to the desire to manage and sustain uneven aged forest conditions in the revised 

forest plan. VSS was used in project design to manage for replacement structural stages which assures continuous 

representation of old growth over time. The use of VSS does not violate the revised forest plan desired 

conditions, standards and guidelines.

Comment 10-35

Is VSS being identified as an age class or a size class? It is confusing how removing a maturing class of trees 

would lead to an increase in the development of a more mature class? The use of VSS classes to substitute for age 

classes is confusing. VSS seems to be a measure of average diameters at breast height (dbh). Yet, VSS class is 

treated as a measure of age class, and age is not simply a measure of size. Old growth stands have a suite of 

characteristics that arise over time, and are a product of natural history such as fire, soil development, understory 

plant and fungal colonization, lichen growth, etc. It should be a goal of the Forest Service to reduce interference 

with processes that create healthy old growth. Thinning a forest is a disturbance that can reset forest development 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

372 Appendices

to an earlier state. It can compact soils, introduce non-native plant species, and remove some of the forest’s 

biodiversity. The Forest Service should be clear about how it will create old growth, and how it will meet the VSS 

requirements of its Forest Plan guidelines. They are really two separate things. Some of the forest should be left 

intact to truly promote an old growth ecosystem in the future. 

Response to Comment 10-35

See comment 10-26 for explanation of how VSS is based on age and how average tree size is used as a guide. 

VSS is successional stages for mixed-species forest ecosystems. VSS has associated diameter classes due to 

being calculated as groups, not individual trees. Old growth desired conditions are displayed in the 1988 forest 

plan pages 32 to 34. The DEIS explains how “the most common reason that the forest areas do not fully meet old 

growth characteristics is because very few areas meet the minimum number of trees that are of the specified age 

or greater. Mitigation measures are in place for the project area to maintain and protect pre-settlement trees” (pg. 

76 DEIS). The FEIS provides an updated discussion on old growth in the context of the revised Forest Plan (pp. 

108-109). 

Page 77 of the DEIS explains how old growth would be managed for the Bill Williams project across multiple 

scales. Areas of de facto old growth allocations include MSO protected habitat, MSO threshold, MSO PAC, 

Goshawk nest, and Arizona bugbane botanical area. To manage at a smaller scale outside of de facto old growth 

allocated stands, VSS 6 was calculated into the analysis. Due to the project design which would conserve and 

value VSS 6, groups of 24” diameter trees and above, to a desired density across the landscape through time, it 

was appropriate and necessary to allocate this smaller scale as old growth across the landscape. VSS 6 groups 

would represent the characteristic in 1988 forest plan table 15. Old growth at all scales would be managed to the 

standards and guidelines in the revised forest plan. 

VSS classification was a tool used in analysis to determine separate age classes and uneven-aged forest. This was 

determined to be appropriate due to the desire to manage and sustain uneven aged forest conditions in the revised 

forest plan. VSS was used in project design to manage for replacement structural stages which assures continuous 

representation of old growth over time. The use of VSS does not violate the revised forest plan desired 

conditions, standards and guidelines. 

Comment 10-36

Figure 3.2-21 – The Nest Alternative 2,3, and 4 does not dip below the desired percentage of VSS 4 Canopy 

cover, and the results after 2033 are indistinguishable from the other alternatives. Again, Alternative 4 should be 

the technique employed. For VSS 5, all alternatives show statistically similar results.

Response to Comment 10-36

Refer to comment 10-28 for a response on error bars and analysis. To manage for desired conditions based on 

VSS requires balance of all classes amongst the population being evaluated. That is why balance is interpreted 

and evaluated at multiple scales Analysis of canopy cover is consistent with the revised forest plan.

Comment 10-37

Fig 3.2-22 – It is confusing why this graph is not comparing nest and PFA alternatives like the previous ones. It 

analyzes LOGPFA. However, here we see that Alternative 4 reaches the desired condition for VSS 6 by 2023, 

while others take another 10-20 years. It is not true that “Alternative 4... did not increase at the rate of Alternative 

1.” (DEIS, p. 62) It achieved the goal 20 years before Alternative 1. 

Response to Comment 10-37

Figure 3.2-22 analyzes VSS 6 canopy cover for LOGPFA and not PFA canopy cover. Figure 3.2-23 analyzes 

canopy cover for VSS 4, 5 and 6 in PFAs. To manage for desired conditions based on VSS requires balance of all 

classes amongst the population being evaluated. That is why balance is interpreted and evaluated at multiple 

scales. PFAs include nest stands. Canopy cover of PFA includes nest stands. Refer to comment 10-28 about 

error bars and analysis. The analysis of canopy cover in the FEIS is consistent with the revised forest plan. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 373

Comment 10-38

Figure 3.2-23 – If conditions approximate target conditions now or will in a year with no action for VSS 4, it is 

unclear why action should be taken in these areas, especially since the outcomes areindistinguishable as soon as 

the forest rebounds to the target condition. For VSS 5 and 5 PFA, the action delays achievement of desired 

condition for 20 to 30 years. For VSS 5 and 6 nests, the proposed action delays the achievement of desired 

condition for almost 20 years and then becomes indistinguishable from untreated areas. How is it beneficial to 

temporarily remove this necessary part of goshawk habitat for a period of 20 to 30 years? The DEIS fails to make 

the case for why this is necessary. How is it beneficial to spend money and labor to move forests further from 

desired conditions, only to have effects be indistinguishable from no action once desired conditions are reachieved?

Response to Comment 10-38

It is necessary for action to be taken in these areas to meet a variety of desired conditions Other purposes for 

treatment in areas managed for habitat are to reduce the severity to the residual stand for a fire event. The 

objective and desired condition remains consistent with the revised forest plan. These areas are being managed 

for the goshawk habitat described in the desired conditions of the FEIS. For goshawk nest and PFA, analysis in 

figure 3.2-23 shows that canopy cover is below desired thresholds and treatments would not bring treatment 

below these desired thresholds directly after the cutting treatment. The effects are distinguishable and logical for 

an action when taking into consideration multiple desired condition evaluation criteria, bark beetle risk, fire risk 

and a landscape treatment approach. More importantly, when reintroducing fire, which is a natural disturbance, to 

these areas that have unnatural fuel loadings, the chance for torching and crowning is reduced with thinning 

treatment. The desired condition remains the same and is met through the action alternatives through time. 

Comment 10-39

If VSS 1 can be accidentally classified as other age classes (p. 56 and 65), does that mean that other VSS classes 

are over-estimated? What is the range of error, and which classes are most likely to be over-estimated?

Response to Comment 10-39

Large VSS classes are not over represented because VSS is based on a group of trees. Areas that would represent 

regeneration areas (VSS 1 & 2) would have an over story component. This would be designated as VSS 1 or 2, 

representing 20% of each stand, to have a higher classification of VSS. FVS is not a spatial model. “Because 

VSS is area based, the creation of areas for VSS 1 and 2 will be established upon implementation” (pg. 56 and 64, 

DEIS and associated discussion on pp. 66 and 71, FEIS). Regeneration areas greater than 1 acre in size would 

have 3 to 5 reserve trees. Most areas for VSS 1 and 2 would be less than one acre in size. Other areas designated 

on the ground will incorporate reserve trees. This does not change the VSS classification. 

See comment 10-26 for explanation of how VSS is based on age and how average tree size is used as a guide. 

VSS classification was a tool used in analysis to determine separate age classes and uneven-aged forest. This was 

determined to be appropriate due to the desire to manage and sustain uneven aged forest conditions in the revised 

forest plan. VSS was used in project design to manage for replacement structural stages which assures continuous 

representation of old growth over time. The use of VSS does not violate the revised Kaibab Forest plan desired 

conditions, standards and guidelines. 

Comment 10-40

Figure 3.2-33 – Dwarf Mistletoe infection rates are lowest in Alternative 4 at 2023, and indistinguishable between 

Alternatives 3 and 4 at other times. Alternative 2 is indistinguishable from no action and higher than Alternatives 

3 and 4. A similar trend for Dwarf Mistletoe Rating is shown in Figure 3.2 -34. 

Response to Comment 10-40

Thank you for your comment. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

374 Appendices

Comment Letter 11: Arizona Game and Fish Department

Comment 11-1 

We agree that the Bill Williams Mountain project area is in need of treatment to reduce the risk of stand-replacing 

fire, to protect the town of Williams and facilities within the project area from fire damage, and to move 

conditions toward the Forest's Desired Conditions (DCs) for these forest types. However, the DEIS raises 

concerns for the Department about how the stated "Forest Restoration" goal of this project will be met. We 

recommend clarification and continued communication with the Department to ensure this project achieves 

meaningful restoration.

Response to Comment 11-1 

Thank you for your general support of this project. The Forest Service has been, and continues to be, committed 

to communication with the Arizona Game and Fish Department (AGFD) and other stakeholders in the 

development of this project. Regarding the need for clarification on restoration, the desired conditions are 

included in each specialist report and explain which vegetative types would be restored to reference conditions. 

Comment 11-2 

The latest version of the Desired Conditions for mixed conifer are very helpful in clarifying the intended habitat 

characteristics within that forest type. This section is particularly important because neither the Purpose and Need 

nor the Proposed Action specify treatment strategies for varying vegetation types. The DCs for remaining 

vegetation types, however, do not adequately describe the approach that will be taken to achieve wildlife habitat 

restoration objectives in those types. The Department is very interested in working with the Forest to develop 

more spatially defined treatment approaches to ensure heterogeneity is achieved at fine and coarse scales. We 

recommend field visits and the development of a treatment map. This could be an intermediate step in support of 

the Forest's implementation plan and treatment prescriptions. We believe that many of the following concerns can

be addressed through such a planning process: 

Response to Comment 11-2 

Thank you for your support of the desired conditions in mixed conifer forest. Although the AGFD states that the 

desired conditions for the remaining vegetation types do not adequately describe the approach that would be taken 

to achieve wildlife habitat restoration objectives, they do not specify what would constitute an adequate 

description. The project benefits to wildlife habitat are explained in chapter 3. 

The Desired Conditions for all vegetation types specifically provide for habitat heterogeneity and diversity. Since 

AGFD submitted this comment, the Kaibab National Forest has worked with the AGFD and U.S. Fish and 

Wildlife Service (USFWS) to collaboratively write more spatially defined treatment approaches in a document 

that specifies treatment methods in Mexican spotted owl (MSO) nesting/roosting patches and suitable habitat for 

Arizona bugbane and collaboratively created a map that spatially depicts said patches and habitat.

Comment 11-3 

We would like the Forest to consider options for balancing fuels reduction with habitat restoration. For example, 

there may be options to treat savannah and juniper habitat toward more open conditions while allowing for some 

closed canopy conditions in the various forest types. 

Response to Comment 11-3 

The Bill Williams Mountain Restoration Project is not specifically a wildlife habitat restoration project. There 

will be indirect benefits to wildlife from vegetation treatments. Also see response to comment 10-17. 

Comment 11-4 

Descriptions of forest types are inconsistent throughout the document, making it difficult to envision the layout of 

type-specific treatments in the project area. The differences in terminology also raise the questions: Will dry 
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Appendices 375

mixed conifer be treated as separate from wet mixed conifer? Will pine-oak only be treated as a unique forest type 

within MSO PACs?

Response to Comment 11-4 

Dry mixed conifer forest would be treated differently from wet mixed conifer forest. Wet mixed conifer forest 

generally occurs within areas of mixed conifer forest on northern, eastern, and northeastern aspects, drainages, 

and other areas of high vegetative productivity. Dry mixed conifer forest generally occurs within areas of mixed 

conifer forest on southern, western, and southwestern aspects, dry ridge tops, and other areas of low productivity. 

See the desired conditions for mixed conifer forest within the Bill Williams protected activity center (PAC) and 

mixed conifer forest on steep slopes. Only 176 acres of mixed conifer forest occur on slopes less than 40%, of 

which over 25% are conserved as Target/Threshold Habitat. Those areas that are not conserved as target/threshold 

habitat (which would be conserved at very dense levels; see desired conditions for this habitat type) are 

considered dry mixed conifer forest. 

Pine-oak forest would be treated as a unique forest type in all protected and restricted MSO habitat, not just in the 

PAC and other protected habitat. See Desired Conditions for ponderosa pine forest outside of goshawk postfledgling family areas (PFAs) and nest areas and outside of MSO steep-sloped (>40%) Protected Habitat and 

Target/Threshold Habitat: “Some of these areas included pine-oak Restricted Habitat; mitigations measures have 

been created to ensure conservation of these areas (see section 2.4.5.1).” Also see Desired Conditions for pineoak forest within MSO Target/Threshold Habitat (which constitutes part of Restricted Habitat).

The analysis is broken up into cover types (Current condition of Final Environmental Impact Statement (FEIS)) 

and habitats (goshawk, MSO and old growth). Wet mixed conifer is not broken out in the analysis. However, “wet 

mix conifer (historically infrequent fire) forest type can be found in isolated areas on the north facing slope and 

major drainages on Bill Williams Mountain” (pg. 62, FEIS). Areas would retain pre-settlement trees and 

reference conditions would determine species composition. Stands are delineated based on species composition 

and topography. The isolated areas on the north facing slope and major drainages on Bill Williams Mountain that 

were historically wet mixed conifer exist in small inclusions but are identifiable by the ample amount of evidence 

of pre-settlement white fir. A majority of these areas were identified as patches in MSO protected habitat and 

Bugbane habitat which would be managed at higher densities. 

Comment 11-5 

The Wildlife Specialist Report acknowledges likely impacts to Abert's squirrel (an MIS) habitat in the ponderosa 

pine type. We agree and accept that a significant amount of winter core habitat for this species will be lost if the 

Proposed Action is implemented. The Department recognizes the Abert's squirrel as a proxy for other closed 

canopy-dependent species whose habitat needs are not as well understood. While the implementation guidance for 

squirrel habitat may help to alleviate impacts to this species, we would advocate a more comprehensive effort to 

provide for the full range of historic variability, including closed canopy conditions. 

Response to Comment 11-5 

Desired conditions and mitigation measures ensure a comprehensive effort to provide for the full range of historic 

variability in the habitat of Abert’s squirrel. Examples include conserving high or moderate tree densities in 

northern goshawk nest areas, northern goshawk post-fledging family areas, MSO pine-oak Target/Threshold 

Habitat, and MSO pine-oak habitat in areas of high vegetative productivity; minimizing loss of pre-settlement 

trees (regardless of mistletoe infection); conserving trees greater than 24” diameter at breast height (DBH) in 

MSO habitat; using irregular spacing of tree groups; and conserving vegetative structural stage (VSS) 5 and 6 

groups and post-settlement trees infected with mistletoe where necessary. See mitigation measures in the FEIS 

and the desired conditions in the wildlife specialist’s report. 

Comment 11-6 

The Department is concerned with the potential for soil erosion due to cable logging methods. It seems that 

planned cable logging treatments, which create vertical strips of soil disturbance, overlap with highly erosive 
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376 Appendices

soils. Given the novelty of this approach in Northern Arizona's forests, we would hope to see an adaptive 

approach employed. Treatments could be done over several years in discrete locations, allowing for posttreatment assessments. If unexpected damage is discovered after the first treatment, methods could be adjusted 

and areas with significant damage could be rehabilitated. In addition, we request that specific mitigation measures 

be articulated for cable logging. These may include:

• Maximizing suspension to minimize dragging along the soil surface 

• Placing slash in the cable corridors prior to logging 

• Avoiding "blind leads" 

• Attaching logs at the butt end to improve control 

• Assessing cable corridors post-treatment, rehabilitating if necessary

Response to Comment 11-6 

In response to comments, cable logging is no longer being considered for this project. 

Comment 11-7 

Where roads are to be "closed" after treatment, please elaborate on the level of rehabilitation that the Forest will 

ensure. According to the DEIS, most are to remain functional roads that are closed to the public. Is there a 

foreseeable need for these roads to remain after the timber sale is completed? As it is written, the DEIS implies 

that the Forest will allow the roads to "revegetate naturally" because they will no longer be used as roads. If 

permanent closure is the intent, we recommend reseeding or covering the road with debris to prevent unnecessary 

erosion and runoff.

Response to Comment 11-7 

The modified proposed action reduced miles of roads proposed in response to comments. Most of the newly 

constructed roads would be closed following implementation and allowed to re-vegetate naturally; additionally, 

drainage features such as culverts will be removed to minimize the long term maintenance investment of retaining 

these roads. Where natural revegetation is inadequate, or revegetation potential is low, best management practices 

(BMPs) would be implemented to minimize soil erosion from road surfaces. These BMPs are discussed in Table 1 

of the soils and watershed specialist report.

Comment 11-8 

It is not clear to us what fuel breaks will actually look like if implemented as mapped. Please clarify the types of 

materials to be removed, intensity of fuels removal, and the spatial extent of these breaks.

Response to Comment 11-8 

Control lines used for prescribed fire implementation will be used within the project area (referred to as Strategic 

Fuels Treatments (SFTs) in the FEIS). The intent of these treatments is to aid in fire control during prescribed fire 

operations, both in fire control as well as provide greater sight distance to observe fire outside of the control line 

for quick detection. To do this, ladder fuels may be removed (up to 300 feet of the line) to lessen the chance of fire 

moving into the overstory. Some surface fuels may be moved away from the control treatments. Fuels will be 

scattered away from the line, removed from the sight or piled and burned. The fuels treatments will only be placed 

where necessary for fire control and limited to the extent necessary for control.

Natural features (such as rock outcroppings, rock screes) as well as existing man-made features (trails, roads) will 

be used to the greatest extent practical to create fire lines. Linear swaths will not be the intent of the SFTs and 

feathering is often used to blend these treatments into the surrounding landscape. Placement of these lines will 

also take in consideration areas that can take advantage of existing vegetation changes, topography and avoid 

existing key features. For example, habitat fragmentation is considered undesirable and therefore special 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 377

considerations would be taken where a strategic fuels treatment would take place or to what degree within that 

feature as to not adversely affect the integrity of the area.

Comment 11-9 

MSO habitat

Pg 173 - The statement that data indicate MSO " ... virtually never uses pine-oak forest on the Williams Ranger 

District. .. " raises question as to whether the study and survey methods that generated the data were designed to 

capture habitat use. We expect that pine-oak is an important habitat component for foraging and other activities. 

Pine-oak is considered an important habitat type for the Recovery Unit and must be considered according for 

potential future use.

According to the Forest Plan, MSO guidance takes precedence over goshawk guidelines where habitat overlaps. 

Throughout the DEIS, the Forest explains that goshawk nest area guidelines will be used to design MSO 

Restricted Habitat treatments. This is inconsistent with Forest Plan and MSO Recovery Plan guidance.

Response to Comment 11-9 

Survey methods are outlined by the USFWS and are incorporated into the revised forest plan (see wildlife 

specialist’s report). MSO conservation does indeed take precedence over conservation of species that are not 

federally threatened or endangered, but only where there is a conflict in the simultaneous conservation of the two, 

and no such conflict exists in the project area. See effects analysis for MSOs in wildlife section of EIS for 

rationale. The Forest Service consulted with the USFWS on effects of this project to federally protected species, 

and the agency has been actively working with the USFWS in the development of this project. See desired 

condition for MSO habitat types in Pine-oak in the FEIS.

Comment 11-10

Noxious weeds

The mitigation measure on Pg 25 describes a monitoring approach. Will pre-treatment surveys be done to inform 

the need for control? What does "control weeds as necessary" mean?

Cheatgrass is recognized in the document as a priority concern for weeds in the project area. Will there be specific 

mitigation measures and/or an adaptive approach beyond the guidance referenced in the 3-forest EIS for 

Integrated Treatment of Noxious Weeds? New scientific information produced by NAU's School of Forestry may 

provide guidance. 

Response to Comment 11-10

The extent of known populations of noxious weeds is illustrated in Figure 3-51 of the FEIS, and described on 

Pages 228-231 of the FEIS. The Williams Ranger District will continue its invasive species program, which 

includes inventory, treatment, and monitoring of invasive plant species across the entire district. An adaptive 

approach will be incorporated into this project, in that as new populations are discovered, they will be assessed 

and controlled as necessary. “Controlled as necessary” means treating those populations having the most 

significant ecological impact and the greatest chance of successful control.

Guidance used for noxious weeds management will come from Appendix B of the FEIS for integrated treatment 

of noxious or invasive weeds. As new and applicable research is developed it will be taken into consideration. 

Comment 11-11

Minor corrections:

• The figures on Pg 2 appear to be reversed. 

• At the top of Pg 50, the term "uneven" appears to have been used in place of"even". 

• The last paragraph on Pg 177 states that the alternatives "would not occur in 'pure' pine forest, 

not pine-oak or mixed conifer forest." Please clarify where they would be done. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

378 Appendices

Response to Comment 11-11

The images on page two of the DEIS will be put in the correct order in the FEIS. 

Regarding second bullet in comment, the correction is not needed. Research has shown under these conditions, 

over the long term, forest may move into uneven aged conditions. 

Regarding the third bullet in comment: Thank you for pointing out this typographical error; the “not” which the 

commenter underlined is now deleted from this sentence.

Comment Letter 12: Center for Biological Diversity

Comment 12-1 

The latest report of the Kaibab National Forest on management indicator species habitat and population trends 

(USDA 2010) states that the source population of northern goshawk on the Kaibab Plateau is in decline, and the 

species is “at risk of extirpation or extinction in Arizona.” The Forest Service must ensure that the project will not 

adversely affect goshawk or contribute to a trend toward listing under the Endangered Species Act. 

Response to Comment 12-1 

See the wildlife and silvicultural specialist’s reports for analysis of effects of the alternatives, along with 

determinations of effects of each alternative, on the northern goshawk. Desired conditions specific to northern 

goshawk nest areas and post-fledgling family areas (PFAs), along with various mitigation measures (e.g., 

conservation of pre-settlement trees, trees >24” diameter at breast height (DBH), vegetative structural stage (VSS) 

5 and 6 post-settlement trees infected with mistletoe) ensure the conservation of this species within the project 

area.

Comment 12-2 

The amended Kaibab Forest Plan incorporates the Management Recommendations for the Northern Goshawk in 

the Southwestern United States (Reynolds et al. 1992), which quantifies structural attributes of habitat for 

northern goshawk and 14 of the hawk’s prey species. To date, two environmental impact statements on forest 

planning in the Southwestern Region have based action alternatives and decisions on those recommendations 

(USDA 1996, 2006). In doing so, the Forest Service established a habitat-proxy relationship of ponderosa forest 

structure and viability of northern goshawk, and applied a proxy-on-proxy assumption to its analysis of 

population viability for 14 vertebrate prey species.

Response to Comment 12-2 

The Forest Service produced two environmental impact statements to update forest plans to incorporate northern 

goshawk conservation (as mentioned by the commenter), and these environmental impact statements analyzed 

effects of forest plans on species viability.

Under Threatened, Endangered and sensitive species Desired Conditions (pg. 51) the revised Kaibab Forest Plan 

states:

• Goshawk nest areas are multi-aged forests dominated by large trees with interlocking crowns and are 

generally denser than the surrounding forest. 

Also under Guidelines (pgs 51-52) the revised forest plan states:

• Project activities and special uses should be designed and implemented to maintain refugia and critical 

life cycle needs of Forest Service (FS) sensitive species.

The Kaibab National Forest maintains strong partnerships between the State, other federal agencies, academia, 

and nongovernment organizations to provide for threatened, endangered, and sensitive (TES) species. Emphasis 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 379

is placed on the protection and replacement of key habitats that contain threatened, endangered, or sensitive 

species of plants and animals.

Goshawk is a FS sensitive species, and is no longer a management indicator species (MIS) for the Kaibab 

National Forest under the revised forest plan. In the old forest plan it was an indicator for late-seral Ponderosa 

Pine Forest. The comment is based on the Draft Environmental Impact Statement (DEIS) using the MIS list for 

the old forest plan since the revised forest plan had not been signed yet. The Final Environmental Impact 

Statement (FEIS) only used the MIS list that is associated with the revised forest plan. This analysis has not 

assumed a habitat proxy relationship of ponderosa forest structure and population viability for the goshawk and its 

prey species. Desired conditions and guidelines from the revised forest plan are incorporated into the alternatives. 

The revised forest plan places responsibility on forest managers to maintain refugia and critical life cycle needs of 

FS sensitive species. The modified proposed action does this for the goshawk. The determination in the wildlife 

specialist report for the modified proposed action states: 

• Alternatives 2-4 may adversely impact northern goshawks in the short term but could cause a long-term 

beneficial impact. Alternatives 2-4 would not cause a trend toward listing or loss of viability of the 

species. More habitat would be protected and restored for the species under Alternative 2 than under 

Alternatives 3-4, as there would be less fire hazard and more flexibility to promote the growth of the 

largest trees that this species uses for nesting and which serve as recruitment snags and down logs on 

which prey species rely. Alternative 4 would have less road-related impacts than Alternatives 2-3. 

Comment 12-3 

The Arizona Game and Fish Department repeatedly has expressed concern to the Forest Service that application 

of canopy cover guidelines derived from the Management Recommendations (Reynolds et al. 1992) at small 

clump- and group-scales (generally <1 acre) instead of at larger forest stand scales has the potential to 

significantly reduce the amount of forest cover within areas subject to vegetation treatment, with detrimental 

consequences to goshawk and its prey. For example, assuming a residual canopy cover of 50 percent within tree

groups (< 1 acre) after vegetation treatment, and if such groups occupy 50 percent of a stand (>2 acres), canopy 

cover at the stand scale will be 25 percent. To prevent this outcome in site specific projects, which clearly would 

harm goshawk and its prey, the Management Recommendations (Reynolds et al. 1992) and the amended forest 

plans incorporating them, including the Kaibab Forest Plan, require maintenance of canopy cover at stand scales 

in goshawk nesting and fledging habitat. 

The Kaibab National Forest developed a white paper entitled Implementation and Interpretation of Management 

Recommendations for the Northern Goshawk, Version 3.0 (“I&I”– USDA 2009) that calls for assessment of forest 

treatment effects to goshawk habitat at small clump- and group-scales, and not at the larger scale of a forest stand. 

This interpretation of guidelines for goshawk habitat in the amended forest plan shifts requirements for 

maintenance of canopy cover and vegetative structural stages from the stand scale to smaller scales. Its use in the 

current project requires an amendment to the forest plan.

Independent of the scale of application, continued implementation the Management Recommendations (Reynolds 

et al. 1992) is scientifically controversial as a means of insuring population viability for goshawk and prey 

species. The Coconino Forest Biologist wrote to her colleagues that a study of influences of ponderosa pine forest 

structure on northern goshawk reproduction conducted by Beier and others (2008) “sort of rocks the world for the 

1996 goshawk guidelines.”Beier and others (2008) detected a negative correlation of goshawk breeding 

productivity with territories that were treated by logging consistent with the Management Recommendations 

(Reynolds et al. 1992) and the amended forest plans. That finding agrees with observations of Silver and others 

(unpublished), who found evidence of the same phenomenon in the Kaibab National Forest, and stated, 

“Goshawks are known to be adapted to hunt in, and to prefer closed forests... [L]ogging continues to negatively 

impact goshawk reproduction, regardless of the guidelines.”

The proposed action would amend the Forest Plan to allow reduction of canopy cover in ponderosa pine forest 

located outside of goshawk nest areas and post-fledging areas below 40 percent. DEIS at 4. The Forest Service 
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380 Appendices

never explains what “restoration objectives” drive the need for a plan amendment nor does it explain how Forest 

Plan guidelines for canopy retention in forage areas preclude accomplishment of the purpose and need. 

Response to Comment 12-3 

Response to Comment 12-3a (first two paragraphs of comment 12-3)

See response to comment 10-10. Also, the Arizona Game and Fish Department (AGFD) letter to which the 

commenter refers is outdated and does not pertain to this project. AGFD has been involved in the development of 

this project and has not expressed the concerns cited in this outdated letter. 

Response to Comment 12-3b (third paragraph of the comment 12-3)

The interdisciplinary team (IDT) used the best available science in the development of this project, including 

aspects that pertain to conservation of northern goshawks and their habitat. In Keckler’s white paper (USDA 

2012), there is a discussion of the research of Reynolds et al. and Beier et al. and how it pertains to forest 

restoration projects on the Kaibab National Forest.

Response to Comment 12-3c (last paragraph of the comment 12-3) 

Hazardous fuels reduction, improving watershed conditions, and moving vegetative conditions in the project area 

toward the desired conditions drive the purpose and need of this project (see Section 1.3). The fire/fuels and 

soil/watersheds sections of the FEIS demonstrate that Alternative 2 would result in more improved watershed 

conditions and better reduce hazardous fuels than the other alternatives. Alternative 2 better accomplishes the 

purpose and need of the project that pertains to watershed conditions and fuels reduction. 

In terms of moving vegetative conditions in the project area toward the desired conditions, Alternative 2 best 

meets this purpose and need. Desired conditions within the ponderosa pine cover type outside of goshawk PFAs 

and nest areas and outside of Mexican spotted owl (MSO) Protected Habitat or Target/Threshold Habitat, are as 

follows: “Tree density, spatial orientation, and species distribution of trees in the ponderosa pine cover type will 

be maintained in a state that is close to vegetative reference conditions.” Pre-settlement evidence is a major factor 

in determining reference conditions. Much of the project area was historically pine savannah, with canopy cover 

below 40%. Therefore, Alternative 2 better accomplishes the purpose and need of the project that pertains to 

moving vegetative conditions in the project area toward the desired conditions.

The Desired Conditions for Threatened, Endangered, and Sensitive Species (page 51) in the 2014 forest plan state: 

• “Threatened, endangered, and sensitive species have quality habitat, stable or increasing populations, and 

are at low risk for extirpation. 

• Goshawk nest areas are multi-aged forests dominated by large trees with interlocking crowns and are 

generally denser than the surrounding forest. 

Guidelines for Threatened, Endangered, and Sensitive Species 

• Project activities and special uses occurring within federally listed species habitat should integrate habitat 

management objectives and species protection measures from approved recovery plans. 

• Project activities and special uses should be designed and implemented to maintain refugia and critical 

life cycle needs of Forest Service Sensitive Species. 

• Activities occurring near areas used by bald eagles should follow recommendations identified in the 

National Bald Eagle Management Guidelines and Arizona Conservation Assessment and Strategy for the 

Bald Eagle. 

• A minimum of six goshawk nest areas (known and replacement) should be located per territory. Nest and 

replacement nest areas should generally be located in drainages, at the base of slopes, and on northerly 

(NW to NE) aspects. Nest areas should generally be 25 to 30 acres in size. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 381

• Goshawk PFAs (post-fledging family areas) of approximately 420 acres in size should be designated 

surrounding the nest sites. 

• Potentially disturbing project-related activities should be minimized in occupied goshawk nest areas 

during nesting season of March 1 through September 30.

The Kaibab National Forest maintains strong partnerships between the State, other federal agencies, academia, 

and nongovernment organizations to provide for TES species. Emphasis is placed on the protection and 

replacement of key habitats that contain threatened, endangered, and/or sensitive species of plants and animals. 

The Kaibab National Forest works with the U.S. Fish and Wildlife Service (USFWS) and other partners to 

develop conservation measures (e.g. public education to reduce human impacts) to prevent listing and to aid to in 

the recovery and delisting of federally listed species. For 10(j) species, such as the California condor, this applies 

inside and outside the designated experimental range.

Comment 12-5 

Mexican spotted owl

The project area overlaps habitat of threatened Mexican spotted owl. Logging, road construction and prescribed 

firing activities may affect spotted owl critical habitat. The DEIS states that all alternatives, including no-action, 

“may affect, and [are] likely to adversely affect” the owl and its critical habitat. DEIS at 191. That statement 

assumes that “The No-Action Alternative would perpetuate the unnaturally dense conditions in the coniferous 

forests of the project area. It would exacerbate the reduction in habitat caused by historic land management 

practices, recreation, illegal fuelwood harvest, and hazard-tree removal.” Id. at 190-191. “The No-Action 

Alternative may therefore have an adverse effect on Mexican spotted owls.” Id. At 191. 

The DEIS errs in stating that no-action will adversely affect Mexican spotted owls. Adverse effects associated 

with Alternative 1 in the DEIS actually result from historic land management and ongoing recreation, fuelwood 

harvest and hazard tree removal, not from failure to implement the proposed action. The Forest Service never 

articulates any practical way that implementation of the Bill Williams Project will cause those other activities to 

cease or how it will mitigate or eliminate those ongoing adverse effects. In fact, no-action is the only alternative 

that will avoid adverse effects to spotted owl and critical habitat.

The DEIS further states that “None of the Alternatives’ effects are impactful enough to change Forest-wide habitat 

or population trends for MSOs or to cause a trend toward loss of viability.” Id. at 191. However, “The Forest-wide 

population trend for MSOs is declining,” so project implementation will maintain the trend of decline. Id. at 173. 

The Forest Service only considers the direct impact of this proposed action on Forest-wide habitat and population 

trends and does not state effects of other past, ongoing or foreseeable actions. It references an unspecified 

“appendix in EIS” for a list of other actions considered, but provides no detailed information about effects to owl. 

Id. at 190. Lack of information about habitat and population trends is a significant issue regarding other 

management indicator species, as well, because the DEIS only contains a summary table with no supporting data. 

See id. at 218-219 (Table 3.6-16). 

Response to Comment 12-4 

Response to Comment 12-4a (first two paragraphs of comment 12-4)

Determinations of effects must take into account short-term and long-term adverse effects.

The South Zone Wildlife Biologist determined that the No Action Alternative would have no effect to the MSO 

and MSO Critical Habitat. This determination and analysis is in the FEIS.

Response to Comment 12-4b (last paragraph of comment 12-4)

Although the forest-wide population trend for MSOs is declining and the action alternatives would adversely 

affect the species and it’s Critical Habitat in the short term, none of the alternatives’ effects are impactful enough 

to change forest-wide habitat or population trends for MSOs or cause a trend toward loss of viability. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

382 Appendices

Furthermore, all of the action alternatives would be better for the conservation of MSOs and other wildlife over 

the long term than the no-action alternative (see effects analyses in the Biological Evaluation and wildlife 

specialist’s report for details).

Regarding forest-wide population trends for MSOs and loss of viability – One MSO (a male) was detected in the 

nest core area on May 21, 2014. Follow up visits failed to find nesting or roosting owls. A great-horned owl 

hooted in response to surveyor’s hoots in July 2014. If the species were to re-occupy the PAC, none of the action 

alternatives would cause a change in Forest-wide population trends or cause a trend toward loss of viability, as 

mitigation measures, desired conditions, and collaborative design of treatments with the USFWS would conserve 

existing nesting and roosting habitat of the species. 

The local wildlife biologist determined that the action alternatives would adversely affect the MSO and its Critical 

Habitat, as some important habitat components to the species (e.g., trees and snags >18” DBH) may be consumed 

by high-severity fire in some portions of the Protected Habitat in the project area. However, this does not mean 

that all nesting and roosting habitat for the species would be consumed by fire or that the PAC would be rendered 

uninhabitable for the species; if that were the case, which it is not, then it would be reasonable to determine that 

the Action Alternatives change Forest-wide habitat or population trends for MSOs or cause a trend toward loss of 

viability.

Regarding forest-wide habitat trends for MSOs – fire modeling indicates that much of the Protected Habitat 

would not experience stand-replacing fire under the action alternatives, and as mentioned above, desired 

conditions, mitigation measures, and collaborative design of treatments for the project with the MSO recovery 

team leader ensure that the existing nesting/roosting habitat would be conserved for the species at levels sufficient 

enough to provide for occupancy of the PAC in the future. Desired conditions are included in the wildlife 

specialist’s report and include a description of mechanical treatments in nesting/roosting patches for MSOs, and a 

map that depicts nesting/roosting patches to be conserved across Bill Williams Mountain. Also, see mitigation 

measures in the FEIS.

The wildlife specialist’s report and the FEIS consider direct, indirect, and cumulative effects of the action 

alternatives. Appendix D was included in the FEIS and lists past, present, and reasonably foreseeable projects 

that were considered in the cumulative effects analysis for all wildlife species analyzed, in addition to the other 

factors listed in bulleted statements under the Cumulative Effects section for each species. The individual projects 

that are listed in Appendix D pertain to timber harvesting, forest thinning, prescribed fire, livestock grazing, and 

travel management. Although specific names of each project in Appendix D are not listed in the cumulative 

effects section, a reference to the appendix is found in the cumulative effects section, and the effects of these 

projects are broadly analyzed in the cumulative effects sections for all species analyzed for this project.

There is ample information about habitat and population trends for all management indicator species, and it may 

be found in the wildlife specialist’s report. It was incorporated into the FEIS by reference and remains 

incorporated by reference in the FEIS.

Comment 12-5 

On May 23, 2011, the Center commented in response to the Notice of Intent for this project that the Forest Service 

never complied with terms and conditions of the June 10, 2005 biological opinion and incidental take statement of 

the U.S. Fish and Wildlife Service (“FWS”) regarding implementation of the Kaibab Forest Plan. Specifically, the 

Forest Service admitted to the FWS in an October 2008 “Annual Report” that it failed to monitor spotted owl 

populations as required and likely exceeded allowable incidental take.4 Protected Activity Centers (“PAC”) were 

monitored for owl occupancy but not reproduction. According to the Forest Service, personnel and funding levels 

never were adequate to meet the monitoring requirements set out in Term and Condition 3.1 of the June 10, 2005 

incidental take statement.

On April 17, 2009, the Forest Service requested re-initiation of formal consultation on effects of implementing the 

Kaibab Forest Plan on Mexican spotted owl and its critical habitat. According to that letter, “[i]t has now become 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 383

apparent that the Forest Service will likely soon exceed the amount of take issued for at least one species, the 

Mexican spotted owl.” More, “it has become apparent that the Forest Service is unable to fully implement and 

comply with the monitoring requirements associated with the Reasonable and Prudent Measures for several 

species (including MSO) in the [biological opinion].” The FWS accepted the Forest Service’s request and 

reinitiated formal consultation on the Forest Plan and issued a new biological opinion and incidental take 

statement on March 30, 2012. 

The March 30, 2012 biological opinion and incidental take statement eliminates the requirement of prior take 

statement to monitor Mexican spotted owl populations throughout the range of the species, and replaced it with a 

much more modest requirement to monitor and report take (defined as PAC management) rather than population 

activities and trends. Compliance with new terms and conditions in the March 30, 2012 take statement does not 

assure that the Forest Service’s independent obligation the Kaibab Forest Plan to monitor spotted owl populations 

will be met.

The March 30, 2012 incidental take statement anticipates, “Harassment of owls associated with no more than one 

PAC per year due to a single or short-term disturbance,” and “Harm and/or harassment of owls associated with 

one PAC due to long-term or chronic disturbance, or habitat degradation or loss over the life of the [Forest Plan]” 

(USDI 2012: 29). “Smoke from broadcast and pile-burning may disturb MSOs.” DEIS at 177. “Approximately 

11.7 miles (94 acres) of new, Maintenance-Level 1 roads would be constructed in MSO habitat under Alternative 

2, with approximately 0.2 miles (1.6 acres) on the northwestern edge of the Bill Williams PAC...” Id. at 178. 

“Alternative 2 would involve construction of approximately 6.8 miles (54 acres) of temporary roads [...] in MSO 

habitat, with approximately 0.1 miles (0.8 acres) in the PAC...” Id. The project will incur the total amount of 

incidental take authorized by the FWS for implementation of the Kaibab Forest Plan. The Four Forest Restoration 

Initiative Proposed Action also includes logging and prescribed fire treatments on 36,674 acres of PAC. 

Response to Comment 12-5 

When the 1988 forest plan was in effect, the Kaibab National Forest complied with the forest plan’s obligation to 

monitor spotted owl populations. The only standard pertaining to monitoring in the 1988 forest plan was 

“Monitor changes in owl populations and habitat.” The Forest monitors MSO populations and habitat by 

surveying known PACs and inventorying project areas before authorizing environmental analyses.

The only portion of the revised forest plan that speaks toward monitoring population activities and trends is a 

guideline. It occurs under the section on MSO conservation, within the “Range-Wide” portion of subsection F 

(“Monitoring”): 

“Assist the recovery team and recovery unit working group to establish sampling units consisting of 19 to 39 

square mile quadrats randomly allocated to habitat strata. Quadrats should be defined based on ecological 

boundaries such as ridge lines and watersheds. Quadrat boundaries should not traverse owl territories. Twenty 

percent of the quadrats will be replaced each year at random. Using the sample quadrats, monitor the number of 

territorial individuals and pairs per quadrat; reproduction; apparent survival; recruitment; and age structure. Track 

population density both per quadrat and habitat stratum.” 

This guideline specifically states that the forest is to “assist the recovery team and recovery unit working group.” 

If the Forest is directed by the recovery team or recovery unit working group to provide assistance, then it will 

indeed assist said team or group, and it will therefore comply with the direction quoted immediately above. 

See Comment response to 12-3c for revised forest plan language. 

“Monitoring and evaluation should be collaboratively planned and coordinated with involvement from each 

national forest, USFWS Ecological Services Field Office, USFWS Regional Office, USFS Regional Office, 

Rocky Mountain Research Station, recovery team, and recovery unit working groups.” 

The re-issued, 2012 biological opinion by the USFWS (which was written based on collaborative planning and 

coordination with the USFWS Regional Office, USFS Regional Office, and other parties) on the Kaibab Forest 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

384 Appendices

Plan sets forth the latest collaboratively planned and coordinated monitoring requirements. The Forest is actively 

implementing the terms, conditions, and reasonable and prudent measures of this Biological Opinion. Thus, the 

Forest is complying with the forest plan’s obligation to monitor spotted owl populations. 

The Kaibab National Forest hosts six other PACs in addition to the Bill Williams Mountain PAC. Two occur on 

Kendrick Mountain (one of which was virtually completely denuded by the 2000 Pumpkin Wildfire), one on 

Sitgraves Mountain, and two in Sycamore Canyon one in Hell’s Canyon (Bear Tank #2 PAC) designated in 2013. 

None of these other PACs have been or are anticipated to require an incidental take statement as the result of any 

past, present, or foreseeable projects, including the Four Forest Restoration Initiative. Therefore, there is no 

foreseeable possibility of incidental take in these six other PACs. The Forest Service is consulting with the 

USFWS to receive a biological opinion on this project. The Forest Service biologist for this project determined 

that the project may adversely affect MSOs. As such, an incidental take statement may result. However, USFWS 

is responsible for determining whether or not incidental take would occur. The consultation will determine if 

incidental take would result from this project. The Forest remains in line with the March 30, 2012 incidental take 

statement to which the commenter refers.

Comment 12-6 

Cumulative effects

The project area has experienced potentially significant cumulative impacts from past and ongoing management. 

In particular, livestock grazing in the Hat Allotment is an important factor influencing forest health and fire 

regimes. Grazing is a major factor in the alteration of historic fire regimes and a substantial contributor to fire 

hazard (Arnold 1950, Cooper 1960, Madany and West 1983, Mitchell and Freeman 1993, Rummell 1951, Savage 

and Swetnam 1994). The Center is concerned about potentially significant cumulative effects to soil, plant 

communities, fire regimes and wildlife forage that may result from active range management in combination with 

proposed treatments. Livestock grazing, logging, prescribed fire, off-road vehicle use, and other practices that 

disturb soils can spread noxious weeds. Livestock act as vectors for seed travel, disturb soil, and reduce the 

competitive and reproductive capacities of native species. Exotic weeds can displace native species, in part, 

because native grasses are not adapted to frequent and close grazing (Mack and Thompson 1982, Belsky and 

Blumenthal 1997). 

Noxious weed spread is a reasonably foreseeable and potentially significant forest-wide cumulative impact of the 

proposed action. Treatments similar to the proposed action have left forest restoration sites overrun with 

cheatgrass (Bromus tectorum) (McGlone et al. 2009). Although it is not extensive in the planning area today, 

cheatgrass invasion has important longterm implications for native plant communities in fire-adapted ecosystems 

and wildlife associated with grassland habitats, including management indicator species like pronghorn antelope. 

Melgoza and others (1990) studied cheat grass soil resource acquisition after fire and noted its competitive 

success owing to its ability suppress the water uptake and productivity of native species for extended periods of 

time. They further showed that cheat grass dominance is enhanced by its high tolerance to grazing. Its annual lifeform coupled with the abilities to germinate readily over a wide range of moisture and temperature conditions, to 

quickly establish an extensive root system, and to grow early in the spring contribute to its successful 

colonization. In addition, Melgoza and others (1990) showed that cheat grass successfully competes with the 

native species that survive fire, despite these plants being well-established adult individuals able to reach deeper 

levels in the soil. This competitive ability of cheat grass contributes to its dominance when lands experience 

synergistic disturbances from grazing and fire.

Response to Comment 12-6 

Grazing actions are beyond the scope of this project. Livestock grazing on the Hat Allotment was analyzed in the 

2010 Hat Allotment EA. Range managers will continue to work with the grazing permittee to identify areas to be 

grazed or rested and time periods. 

Noxious weeds will be addressed using the Integrated Pest Management (IPM) approach which was addressed in 

the 2006 Final Environmental Impact Statement for Integrated Treatment of Noxious or Invasive Weeds.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 385

Cheatgrass is a concern of the Bill Williams project, and can achieve competitive dominance in some ecosystems. 

However, it is not appropriate to compare invasion potential in degraded sagebrush ecosystems of the Great Basin 

(i.e., Melgoza et al. 1990) to that of Bill Williams Mountain, which occurs in an entirely different climatic and 

vegetation zone. The Williams Ranger District has conducted several thinning and burning projects on sites 

similar to those on the Bill Williams Mountain Restoration Project, none of which resulted in cheatgrass 

dominated plant communities. In McGlone et al. (2009), they explicitly state that ‘‘no proactive measures were 

taken to eradicate or contain cheatgrass prior to or immediately following treatment. The presence of non-natives 

prior to the generation of restoration-associated disturbances suggested that these areas were at risk for invasion.’’

Currently cheatgrass is relatively isolated within the project area, and Best Management Practices (i.e., ‘‘proactive 

measures’’) will be implemented to minimize the introduction of new populations and the expansion of current 

populations. McGlone et al. (2009) proposes recommendations similar to the Bill Williams Project mitigation 

measures that will be implemented to address post-treatment cheatgrass invasion.

The influence of past actions, including grazing and logging, on fire regimes and existing conditions are discussed 

in chapter three of the EIS. Cumulative effects in the rangeland resources section of chapter three addresses 

interaction of grazing and proposed activities. Existing conditions and the need for change section addresses past 

grazing, logging, among other activities on existing conditions. The cumulative effects of livestock grazing, fuels 

(i.e., fire), and invasive species are discussed in detail in the Invasive Plants Specialist Report, and on Pages 233-234 of 

the FEIS.

Comment 12-7 

Please contact me with any questions regarding this letter, and keep me apprised of all developments in analysis 

and decision making regarding the Bill Williams Project.

Response to Comment 12-7 

The Kaibab National Forest will provide copies of the FEIS and Record of Decision (ROD) to the Center for 

Biological Diversity upon completion. 

Comment Letter 13: Marlin

Comment 13-1 

http://williamsnews.com/main.asp?SectionID=1&SubsectionID=1&ArticleID=12695 

Response to Comment 13-1 

The link in this comment is to a comment section in the Williams News that has comments to the article regarding 

the availability of the Draft Environmental Impact Statement (DEIS) to the public. None of these comments 

result in standing or are addressed as they are in response to a newspaper article.

Comment Letter 14: Stroud (received at a public meeting)

Comment 14-1 

My husband and I own property with a home and barn just off Perkinsville Rd near the Benham Trail exit. The 

southeast corner of our land is at the north end of FS 111B where the locked Forest Service gate is. On the 

proposed operations map, logging activities/vehicles/movement will occur along the entire 1300 feet of the south 

side of our property. What will be done to mitigate noise and dust, concerns that will occur as logging operations 

occur? Also, what hours of operation will the activities involve? Will activities along our property line (our home 

and barn are both within 150 feet of this property line) be conducted during normal business hours MondayFriday, 0800-1700 hours or will they occur at all hours night and day and on weekends? Will there be a project 

representative designated to work with property owners impacted by operations associated with the project? There 

should be to ensure good communication and cooperation. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

386 Appendices

Response to Comment 14-1 

Throughout the contract process (from on-the-ground layout and marking activities through sale award and 

implementation) Forest Service staff is available to work with adjacent property owners and others to ensure 

cooperation and coordination of project activities. While timber sale or stewardship operations are active, 

designated agency representatives are assigned to monitor operations, ensure contract compliance and address 

issues that may arise. These individuals will also serve as points of contact for questions or concerns with project 

operations. 

In general, site specific requirements for dust abatement measures are considered during the preparation phase of 

a timber sale (or stewardship) contract. Cutting unit design, proximity to private property and other resources, 

extent/intensity of use, anticipated seasonality of operations, availability of water sources and economic 

practicality all factor in to whether or not dust abatement requirements are appropriate for a given sale. The most 

common form of dust abatement is the watering of roads used for hauling timber products out of the project area. 

The consideration for dust abatement measures will be included in the implementation plan associated with this 

project.

Mitigating the noise associated with commercial (chainsaws, heavy equipment, log trucks) and non-commercial 

(chainsaw) treatments is difficult, if not impossible, to accomplish. Most logging operations look to maximize 

daily production by operating from dawn to dusk, and occasionally at night. Defining the operational period to 

specified hours in a day could be included in a timber sale or stewardship contract; however, these limitations can 

result in significant impacts to project economics and implementation timeframes. These types of considerations 

for operations around private property will be included in the implementation plan associated with this project and 

will be considered by sale preparation, recreation and lands specialists. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 387

Response to Comments: Supplemental Draft Environmental Impact 

Statement 

Comment Letter 1: Dick Artley 

Comment 1-1 

The July 2012 Bill Williams Mountain Restoration Project DEIS has 359 pages. I will expect to see the Bill 

Williams Mountain Restoration Project SDEIS to be of similar size.

Response to Comment 1-1 

In regard to supplements the regulations at 40 CFR 1502.9(c) state: 

“(c) Agencies: 

(1) Shall prepare supplements to either draft or final environmental impact statements if: 

(i) The agency makes substantial changes in the proposed action that are relevant to 

environmental concerns; or 

(ii) There are significant new circumstances or information relevant to environmental 

 concerns and bearing on the proposed action or its impacts. 

(2) May also prepare supplements when the agency determines that the purposes of the Act will be 

furthered by doing so. 

(3) Shall adopt procedures for introducing a supplement into its formal administrative record, if such a 

record exists. 

(4) Shall prepare, circulate, and file a supplement to a statement in the same fashion (exclusive of 

scoping) as a draft and final statement unless alternative procedures are approved by the Council.”

The Code of Federal Regulations does not specify a length for National Environmental Policy Act (NEPA) 

analyses. Furthermore, CFR1502.1 states “Agencies shall focus on significant environmental issues and 

alternatives and shall reduce paperwork and the accumulation of extraneous background data. Statements shall be 

concise, clear, and to the point, and shall be supported by evidence that the agency has made the necessary 

environmental analyses.” 

The supplement updated the sections of the Draft Environmental Impact Statement (DEIS) affected by new 

information. It was not necessary to repeat other material from the DEIS. The length of the supplement is 

supported by 40 CFR 1502.1. 

Comment Letter 2: Jean Public

Comment 2-1 

NO ACTION IS WHAT SHOULD HAPPEN HERE. THERE SEEM TO BE TOO MANY EXEMPTIONS TO 

WHAT YUO ARE SEEKING TO DO SO THAT NONE OF THEM SHUOLD BE CONSIDERED. IN 

ADDITION, THE PRESCRIBED BURNING YOU ARE PROPOSING WILL KILL AND INJURE MANY 

ELDERLY RESIDENTS WITH THE FINE PARTICULATE SOOT YOU ARE RELEASING. SUCH SOOT 

WHICH IS MICROSCOPIC CAUSES PNEUMONIA, ALLERGIES, ASTHMA, LUNG CANCER, HEART 

ATTACKS AND STROKES. IT IS PARTICULARLY HARMFUL TO BABIES AND ELDERLY WHO LIVE IN 

THIS AREA. THERE IS NO REASON TO ALLOW THIS PRESCRIBED BURNING WHICH SEEMS TO BE 

DONE SO THAT THE FS WORKERS MAKE ADDITIONAL PAY. THIS COMMENT IS FOR THE PUBLIC 

RECORD.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

388 Appendices

Response to Comment 2-1 

Recent trends in the Southwest Region indicate that the absence of treatments to reduce the potential for 

uncharacteristic fire behavior has resulted in high severity wildfires in the Southwest as exemplified by the 

Wallow, Whitewater-Baldy, Tres Lagunas, Schultz, Horseshoe 2, and Rodeo-Chediski wildfires, among others. 

These wildfires have released uncharacteristically large amounts of particulate matter, harmful gasses, and other 

aerosols in smoke, which can adversely affect human health.

The Bill Williams project proposes to use prescribed fire in a manner that would minimize the release of harmful 

constituents in smoke by burning in a manner that reduces fire intensity in comparison to high severity wildfires 

and reduces acreages affected by fire within a given watershed by burning specific areas. These treatments have 

been shown to effectively mitigate wildfire behavior and associated amounts of smoke and detrimental effects on 

watersheds and downstream resources, including developed areas. 

Prescribed burning is included in the alternatives as a measure to reintroduce fire to a fire adaptive ecosystem, 

bringing them closer to a historic range, and to increase resiliency of the forest to wildfires by removing some of 

the surface fuels and heightening crown base heights. Smoke from prescribed fires is regulated by the Arizona 

Department of Environmental Quality. The Department requires a yearly burn plan registration and daily burn 

requests and accomplishments that specifically identify smoke movement, location, amount and emission 

reduction techniques to minimize smoke impacts. Public notices are issued in advance to notify people who are 

sensitive to smoke prior to burning operations. 

Comment Letter 3: Erica Prather

Comment 3-1 

However, one area of concern is the clarification of the cable logging taking place on 480 acres of protected forest 

land. I strongly feel that this works against the very premise of the restoration project. Taylor McKinnon with the 

Center for Biological Diversity states that, ““This new plan provides a blueprint for bureaucratic discretion, not 

owl recovery. It relies on monitoring that the Forest Service and Fish and Wildlife Service routinely refuse to do 

to justify logging and weaker protections in owl habitat. This plan gives the Forest Service’s old-guard foresters 

the logging latitude they’ve been seeking for years, and it does so at the owl’s expense — and at the expense of 

the majority of Americans who want our wildlife preserved instead of pillaged.” 

While McKinnon was referencing the 2012 DEIS, the approval of cable logging on 480 acres is inconsistent with 

the overall goals of the conservation of both the Kaibab National Forest and the owl recovery project. The owl 

recovery project was yet another amendment which I wholeheartedly support, as the continuation of gathering 

information regarding the Mexican Spotted Owl is crucial, whose current species status is that of 'threatened.' As 

stated in the current supplemental statement, the “Mexican spotted owl is threatened primarily by habitat 

degradation and loss of old growth nesting habitats through stand-replacing wildland fire.” Habitat degradation 

would also fit into the proposal of 480 acres of cable logging.

Response to Comment 3-1 

Cable logging was removed from the project in response to comments received for the project.

The effects on the Mexican spotted owl (MSO) have been analyzed in the Biological Assessment (BA) by Forest 

Service wildlife biologists and the U.S. Fish and Wildlife Service (USFWS) concurred with the analysis. The 

USFWS will determine if a call of “take” is warranted as a result of the restoration and wildfire abatement 

implementation actions. 

Comment 3-2 

While there appears to be evidence that Mexican Spotted Owls have a difficult time nesting in burn areas, this 

does not justify burning forest as a preventative measure. Removal of snags for the safety of conservation workers 

seems unnecessary. The supplement goes to great lengths to provide specific measurements regarding number of 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 389

logs, snags, woody debris, and so on in the ponderosa pine forest. This also seems counterintuitive to the 

preservation of the area as a whole. Australia's Department of Sustainability and Environment has conducted 

multiple, in depth studies on the effects of 'bushwhacking' and, among other negative impacts, states that, 

“Walking on the track edges and cutting corners on steep ‘zigzag’ tracks, increase damage, erosion and visual 

scarring...Avoid sensitive vegetation. Ferns, mosses and other sensitive vegetation are easily destroyed by 

trampling.” With such heavy foot traffic for snag removal, it would be nearly impossible to sustain a zero-impact 

ideology.

Response to Comment 3-2 

The objectives of the Bill Williams project do not include preservation, but are instead focused on restoration. 

Specific measures regarding the number of logs, snags, and amount of woody debris retained after treatments 

provide a quantitative approach for assessing the success of restoration treatments. 

The second part of this comment references a zero-impact ideology, reference from Forest Notes, Bushwhacking 

Code. The Bill Williams Mountain Restoration Project is not based on a zero-impact ideology, so this reference 

would not apply to this project. As required under 40 CFR 1502.1 and 40 CFR 1502.9, an Environmental Impact 

Statement (EIS) and Supplemental EIS have been prepared in order to disclose significant environmental impacts 

to the public and the decision maker and to analyze reasonable alternatives that would avoid or minimize adverse 

impacts or enhance the quality of the human environment. 

The supplemental Draft Environmental Impact Statement (DEIS) provides additional information on snag 

removal and describes the mitigations that would be applied to remove as few snags as possible while still 

restoring historic conditions.

The safety of workers in the field is an important consideration. There is an Occupational Safety and Health 

Administration (OSHA) regulation to remove danger trees for up to 2 tree lengths before work starts in an area. 

Snags are considered danger trees due to deterioration of the stem and root system. Thus, all snags in the area 

where helicopter logging takes place would be felled. Pertinent OSHA regulations are listed below.

1910.266 (c): "Danger tree." A standing tree that presents a hazard to employees due to conditions such as, but not 

limited to, deterioration or physical damage to the root system, trunk, stem or limbs, and the direction and lean of 

the tree.

1910.266(h) (1) (vi): Each danger tree shall be felled, removed or avoided. Each danger tree, including lodged 

trees and snags, shall be felled or removed using mechanical or other techniques that minimize employee

exposure before work is commenced in the area of the danger tree. If the danger tree is not felled or removed, it 

shall be marked and no work shall be conducted within two tree lengths of the danger tree unless the employer 

demonstrates that a shorter distance will not create a hazard for an employee.

Comment 3-3 

Perhaps the most unsustainable practice mentioned is the removal of trees for the purpose of paving roads and 

machinary [sic] access. If roads are introduced to an area whose intent and purpose is the preservation of wildlife 

and the Mexican Spotted Owl, it seems illogical to install roads and introduce machinary [sic] into the setting. The 

supplement states that there should be a deviation from the current forest plan to “save all trees >24 inches DBH” 

within MSO restricted habitat” in lieu of creating temporary roads.

In a study published in the British Colombia Journal of Ecosystems and Management, Patrick Daigle states that, 

“Environmental effects of roads include spatial and temporal dimensions and biotic and abiotic components. 

Effects can be local (along a road segment) or extensive (related to a large road network).In addition to direct loss 

of habitat and ecosystems caused by the footprint of resource roads, another spatial aspect is the “road-effect 

zone”3 that can radiate out from the sides of the road and/or extend downstream where effects on aquatic 

conditions may be located a distance from the source. The road-effect zone also changes light conditions and 

disturbs soils and thus creates conditions suitable for invasive plants. Spatial effects of roads vary because species 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

390 Appendices

habitat requirements and ecosystem characteristics are diverse. For example, less mobile wildlife species tend to 

have smaller habitats whereas wide-ranging mammal and bird requirements tend to be spread across macroenvironments.” 

Response to Comment 3-3 

The Bill Williams Mountain Restoration Project does not propose paving any roads. There is currently an 

unsustainable road network in the project area and necessary access to implement restoration treatments is 

inadequate. As described in the soils and watershed specialist’s report, several existing roads exist in drainages are 

in a state of disrepair. These roads are eroding and delivering sediment to watercourses.

The proposed project would eliminate poorly located and unsustainable roads and install roads in appropriate 

locations that would minimize adverse effects on soils and watershed conditions. The majority of roads would be 

native surface, i.e. the material in the ground the road is built on. A limited number of roads would likely be 

surfaced with imported material such as cinder or crushed rock. 

As part of the purpose and need for the project to improve the motorized transportation system to provide for a 

more sustainable road system and poorly located roads would be relocated or obliterated. Roads are also 

necessary in order to provide access to the area for timber removal. This requires that some large trees be 

removed. Cleared right of way for the majority of permanent roads in the project area would be approximately 

30’-40’ in width. Temporary roads would be somewhat less in width. 

Roads can deliver sediment to streams, especially if they are not properly designed and if adequate drainage 

structures such as drain dips are not present. All roads proposed for this project would be designed with adequate 

drainage in order to minimize sediment delivery to streams. Nearly all of the new temporary roads proposed 

would be closed following use and revegetated. This greatly reduces the potential for erosion and sediment 

delivery. Roads can also act as a vector for the spread of noxious weeds. Revegetation of the road surface and 

closing roads to traffic after use will reduce this impact.

Effects from all activities associated with road construction and obliteration roads were analyzed for this project 

(Final Environmental Impact Statement (FEIS), section 3.6 pgs. 160-165). The BA also analyses the effects of 

roads on threatened and endangered wildlife and the wildlife specialist report analyzes the effects from roads on 

non-listed wildlife species. The BC Journal of Ecosystems and Management article does not provide any 

additional information that has not already been considered within the analysis. 

In response to comments, the number of roads under the modified proposed action was reduced to 15 miles of 

new roads and 16 miles of temporary roads that would be obliterated after treatment. Twenty-three miles of 

poorly located roads causing resource damage would be obliterated.

Comment 3-4 

A road would clearly be a hindrance to any conservation based work, and would not be in line with the goals of 

the overall project. Another addition to the supplement not in line with the goals of the project is the “treatment in 

the MSO 100 no treatment area” ammendment [sic]. While thinning of underbrush that could be a fire hazard may 

seem necessary, burning by method of “low intensity fire” presents yet another unncessary [sic] complication to 

the cause. Wildlife dispersal, the possibility of an uncontrolled burn, and the question of necessity are just a few 

reasons I do not support this amendment. 

Response to Comment 3-4 

As part of the purpose and need for the project to improve the motorized transportation system to provide for a 

more sustainable road system poorly located roads would be relocated or obliterated. As described in the 

response to comment 3-3, several existing roads in the project area are eroding and delivering sediment to 

watercourses. The proposed project would eliminate these historic, poorly located and unsustainable roads and 

install roads in appropriate locations that would minimize adverse effects on soils and watershed conditions. An 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 391

improved and more sustainable road network is therefore not a hindrance to proposed restoration treatments as it 

would provide the necessary access for current and future management of Bill Williams Mountain.

Use of prescribed fire in MSO nest core areas is consistent with the 2014 forest plan and the revised MSO 

Recovery Plan. Under the 2012 revised MSO recovery plan, the management recommendation for treating nest 

core areas is prescribed fire. Treatment in the 103-acre nest core area and the effects on the Mexican spotted owl 

MSO and its critical habitat are addressed in the BA. Under the modified proposed action the 103 acre MSO nest 

core area the only treatment would be prescribed burning. Prescribed burning in the nest core is proposed to help 

reduce surface fuel loadings, which would moderate fire behavior during a wildfire. Choosing specific burn 

windows to target low intensity fire will assist in meeting this objective but not affect a large portion of the 

overstory with fire kill. Prescribed fire will also assist in raising the crown base heights of the trees (overstory), 

making it more fire resilient by changing the crown to surface distance so that a surface fire would need to 

produce greater flame lengths to transition to a crown fire.

Excluding prescribed fire from the nest core would take either substantial control lines to be constructed around it 

or eliminating a large area from prescribed fire. Neither option would meet the purpose and need of the project. 

Constructing fireline capable of keeping fire out of the nest core would require removal of all vegetation for 

several hundred feet, which would not only fragment habitat, but would also be a safety concern to workers. 

Eliminating prescribed fire on a large section of the mountain does nothing towards protecting the featured habitat 

or surrounding wildland urban interface areas.

Comment Letter 4: EPA

Comment 4-1 

We continue to strongly support the restoration goals for this Project. We appreciate the clarification 

provided, in the SDEIS, of the silvicultural treatments proposed in the pre-settlement patches in the Mexican 

spotted owl 'protected habitat and the Arizona bugbane botanical area in the Bill Williams Mountain project 

area. Though we support the decision to conduct thin-from-below treatments to maintain the integrity of the 

overstory, we continue to recommend that the Forest Service refrain from the use of cable logging within the 

Botanical Area unless mitigation measures could be developed that would ensure long-term protection of the 

Arizona bugbane population. 

Response to Comment 4-1 

In response to comments cable logging is no longer included in this project. There would be no cable logging in 

the Arizona bugbane botanical area. The area originally proposed for cable logging has been changed to the use 

of steep slope equipment or the use of helicopters to remove material.

Comment Letter 5: USFWS

Comment 5-1 

The Department of the Interior has reviewed the U.S. Forest Service (USFS) Supplemental Draft Environmental 

Impact Statement (SDEIS) for the Bill Williams Mountain Restoration Project (Project) in Coconino County, 

Arizona. We provided comments on August 27, 2012, and believe these comments are still applicable. 

Response to Comment 5-1 

Thank you for your current and previous comments to the Supplemental Draft Environmental Impact Statement 

(SDEIS) and Draft Environmental Impact Statement (DEIS), respectively. A comment letter from the Department 

of the Interior Fish and Wildlife Service was received on October 15, 2012 which was after the end of the notice 

and comment period (July 14, 2012 through August 27, 2012). Even though the letter was received outside the 

official notice and comment period for the DEIS the letter was reviewed by the interdisciplinary team and useful 

information was incorporated into the Final Environmental Impact Statement (FEIS). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

392 Appendices

Comment 5-2 

Our main comments regarding the SDEIS are that it lacks clarity in how Mexican spotted owl habitat and the Bill 

Williams Protected Activity Center will be treated through this project.

Response to Comment 5-2 

The Biological Assessment (BA) clarified how Mexican spotted owl (MSO) habitat and the protected activity 

center (PAC) will be treated, and this information is incorporated into the FEIS. 

Comment 5-3 

Although we understand the purpose and need for this project to reduce fuel loading and fire risk in and around 

the project area, it is not clear how the project will comply with the Mexican Spotted Owl Recovery Plan, First 

Revision (Recovery Plan), as the SDEIS states. We have also worked with the USFS to identify pre-settlement 

polygons within owl habitat, and will continue to work together to more specifically design treatments within 

these areas.

Response to Comment 5-3 

The BA clarified how the modified proposed action is in compliance with the 2012 revised MSO recovery plan. 

As part of compliance with the 2012 MSO recovery plan the only treatment proposed in the 103 acre MSO nest 

core area is prescribed burning. Thinning in the nest core is not part of any of the action alternatives. On May 5, 

2015, the Biological Opinion for this project was received and notes on page 32 “The Kaibab national Forest’s 

intent is to integrate the best available recovery habitat management objectives where possible into forest 

restoration and/or fuels reduction projects with the overall goal to protect owl PACs from high-severity wildland 

fire and to conduct actions to improve forest sustainability (e.g., thinning and prescribed burning).” 

Comment 5-4 

In accordance with the Arizona Bugbane Candidate Conservation Agreement, we recommend the USFS include 

an evaluation of effects to this species in their biological assessment. The Coconino National Forest is also 

planning fuels treatments within the habitat for this species, and we recommend further coordination to establish 

consistent post-treatment monitoring within these habitat areas.

Response to Comment 5-4 

Bugbane was not addressed in the BA because it is not a federally listed species. However, since it is a Forest 

Service sensitive species it was included within the Biological Evaluation completed for this project. District 

personnel worked with the local U.S. Fish and Wildlife Service (USFWS) field office both in the field and during 

meetings to develop mitigations for the Arizona Bugbane. An analysis for bugbane was completed and is part of 

the project record and FEIS. An updated conservation assessment and agreement for Arizona Bugbane is 

currently being developed with the USFWS and the Forest Service. The Bill Williams Mountain Restoration 

Project does follow the 2014 forest plan direction which was incorporated into the new conservation assessment 

for Arizona Bugbane. Specific forest plan desired conditions for the Arizona Bugbane Botanical Area includes: 

Desired Conditions for the Arizona Bugbane Botanical Area

• Arizona bugbane has a sustainable population and is at low risk for extirpation. 

Comment 5-5 

In addition, interagency consultation under the Endangered Species Act will be required, and we recommend the 

USFS to meet with our staff to discuss the consultation process and information needed. We look forward to 

working with the USFS as they further refine this project.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 393

Response to Comment 5-5 

The interdisciplinary team has involved, and will continue to involve, the USFWS in the planning process. 

Informal consultation occurred between the Forest Service and USFWS during the development of the project and 

USFWS was involved throughout the analysis of the Bill Williams project. After the development of the BA, the 

forest went into formal consultation with the USFWS. On May 5, 2015, the Biological Opinion for this project 

was sent to the forest. The USFWS will be involved during implementation of the project as well.

Comment Letter 6: Center for Biological Diversity and Wild Earth Guardians

Comment 6-1 

The proposed action would mechanically disturb an occupied nest core area of threatened Mexican spotted owl, 

remove nesting-quality protected habitat, and build new roads in suitable recovery habitat at one of the only 

locations where the species occurs in the Kaibab National Forest. It is not consistent with recommendations of the 

2012 Mexican Spotted Owl Recovery Plan, First Revision (USDI 2012a). Moreover, the project shirks protective 

standards and guidelines in the Kaibab forest plan, and is likely to adversely affect spotted owl and its critical 

habitat, harm and/or harass individual birds causing incidental take, and undermine recovery. 

Response to Comment 6-1 

Bill Williams Mountain is one of seven protected activity centers (PACs) designated on the South Zone of the 

Kaibab NF. The Biological Assessment (BA) analyzed the effects on Mexican spotted owl (MSO) and MSO 

critical habitat for the project. The Kaibab National Forest has a revised forest plan. The decision for this project 

will be signed under the revised plan. Proposed actions associated with this project are consistent with the revised 

forest plan and amendments are no longer needed. The analysis of the project in the BA concluded that the 

project will have a short term adverse effect to the MSO and its critical habitat. The forest conducted formal 

consultation with U.S. Fish and Wildlife Service (USFWS) and received a biological opinion on May 5, 2015. 

The forest received a harassment take for the Bill Williams PAC. However, the biological opinion states the 

following: 

Page 28: “The Bill Williams Restoration Project includes measures to protect the Mexican spotted owl and its 

habitat by deferring management activities in the nest core area and the PAC during the breeding season, planning 

for low severity fire effects in the PAC, and attempting to avoid breeding season disturbance to Mexican spotted 

owls from most project activities. However, the project has the potential to negatively affect the Mexican spotted 

owl and its habitat. There will likely be short-term disturbance to breeding owls and some loss of key habitat 

components (large trees, snags, and logs), although we also expect benefits to the owl through habitat 

enhancement over the long-term and reduced fire risk.” 

Page 32: “Over the long-term, these actions should increase the sustainability and resiliency of Mexican spotted 

owl habitat (particularly through fuels management and forest restoration actions). Therefore, implementation of 

the proposed Bill Williams Mountain Restoration Project is not expected to further diminish the conservation 

contribution of critical habitat to the recovery of the Mexican spotted owl.” 

Page 33: Mexican spotted owl and critical habitat

After reviewing the current status of the Mexican spotted owl and its critical habitat, the environmental baseline 

for the action area, the effects of the proposed action and the cumulative effects, it is our biological opinion that 

implementation of the proposed Bill Williams Mountain Restoration Project will not jeopardize the continued 

existence of the Mexican spotted owl, and will not destroy or adversely modify its designated critical habitat. We 

base our conclusion on the following: 

1. The Bill Williams Mountain Restoration Project will strive to implement the Recovery Plan (USDI FWS 

2012) and manage for Mexican spotted owl recovery on the Kaibab National Forest. 
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394 Appendices

2. Desired conditions and guidelines in the Bill Williams Mountain Restoration Project recognize the need to 

reduce the potential for landscape level, stand-replacing fire in forests that the Mexican spotted owl 

occupies. These efforts to improve forest condition and sustainability should reduce the risk of high 

severity fire across large areas and subsequently, reduce the loss of owl habitat.

3. Based on the discussion provided in the Effects on Mexican Spotted Owl Critical Habitat section above, 

Upper Gila Mountain (UGM)-13 Critical Habitat Unit (CHU) affected by the project will continue to 

serve the function and conservation role of critical habitat for the Mexican spotted owl.

The conclusions of the Biological Opinion (BO) are based on full implementation of the project as summarized in 

the “Description of the Proposed Action” section in the FEIS including the standards and guidelines that apply to 

the action and serve as conservation measures that were incorporated into the project design

For consistency with the Kaibab Forest plan a consistency check was performed by the interdisciplinary team 

(IDT). The Kaibab National Forest has a revised forest plan. The decision for this project will be signed under 

the revised plan. Proposed actions associated with this project are consistent with the revised forest plan and 

amendments are no longer needed. The consistency check document is available in the project record.

Comment 6-2 

A forest plan amendment introduced in the supplemental analysis would allow logging and prescribed fire in the 

nest core area of the Bill Williams Protected Activity Center (“PAC”). See SDEIS at 3. The 2012 DEIS also 

includes a plan amendment to allow logging trees greater than 9-inches diameter within the PAC. Id. 2. 

Combined, the two proposed amendments to the forest plan would eliminate standards and guidelines that protect 

occupied Mexican spotted owl nesting and roosting habitat from destruction and/or adverse modification by 

logging operations. 

Response to Comment 6-2 

The guidelines of no treatments in core areas and no thinning of trees over 9 inches in the PAC was not carried 

forward in the revised forest plan. In addition, the 2012 revised Mexican Spotted Owl Recovery Plan also did not 

retain these recommendations. The Bill Williams Restoration Project is consistent with the revised forest plan and 

recovery plan. Mitigation measures have been established in the Bill Williams Mountain Restoration Project to 

minimize effects on MSO (see chapter two of the Final Environmental Impact Statement (FEIS)). The only 

treatment proposed in the 103 acre MSO nest core area is prescribed burning. Thinning in the nest core is no 

longer part of any of the action alternatives. The forest worked with USFWS on identifying mixed conifer and 

pine-oak stands that are or have potential for becoming MSO nest/roost habitat both within and outside of the 

PAC. USFWS was also part of the discussion on what potential management options to either protect or develop 

key habitat features within these nest/roost habitat stands. 

Comment 6-3 

Although the Forest Service maintains, “Any prescriptions that may occur within the PAC Core would be 

restricted to thinning the understory and mid-story while still retaining substantial vertical diversity within the 

Core,” it nevertheless fails to specify any restriction on the size or number of trees to be cut within protected 

habitat. 2012 DEIS at 19. The proposed action would take Mexican spotted owl (USDI 2012b: 29) (defining 

“incidental take” as “harm and/or harassment of owls associated with one PAC due to long-term or chronic 

disturbance, or habitat degradation or loss over the life of the project”); also see id. (“We expect that actions that 

could result in this type of harm or harassment would be very rare under the existing LRMP due to the protective 

standards and guidelines and other conservation measures included in the forest plan for the MSO”) (emphasis 

supplied).

Response to Comment 6-3 

The potential of thinning within the nest core was not carried forward into the FEIS. A detailed account of 

prescriptions that will occur in MSO habitat was included in the BA. Seventeen prescriptions describe the effects 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 395

of the modified proposed action to the MSO and MSO critical habitat. Each description documents: if the area 

currently meets revised MSO recovery plan nest/roost recovery minimum requirements, the habitat type, the 

desired basal area that the prescription will accomplish, forest structure, spaces, patch density, and diversity of 

tree sizes. The exact number of trees and snags removed is not possible to calculate until we are actually on the 

ground implementing the restoration project. In protected habitat outside of the nest core and in nest/roost 

replacement recovery habitat, trees ranging from 1 to 18 inches diameter at breast height (DBH) will be thinned 

with the majority of the trees removed being less than 12 inches DBH. In other recovery habitat (outside of 

nest/roost replacement habitat) trees from 1 inch to 24 inches DBH will be thinned with the majority of the trees 

removed being less than 12 inches DBH. 

Note: It may be necessary to remove trees larger than 18 and 24 inches when operator safety or desired conditions 

dictate removal. These instances will be rare, and are only mentioned because not removing any of these trees 

may cause risk of human safety or could deviate from the desired conditions. 

Comment 6-4 

The Forest Service admits that the proposed action would destroy protected habitat of Mexican spotted owl in at 

least two ways. First, it would completely remove all trees from approximately 72 acres of PAC within cable 

logging corridors:

[C]able-logging operations (i.e., “cable-logging” and “exca-lining” as described in the EIS) would cause a 

loss of all snags and trees (including snags >18” DBH, trees greater than >24” DBH, and pre-settlement 

trees) across 15% of approximately 480 acres of Protected Habitat (mostly mixed conifer forest). Cablelogging operations would entail cutting all vegetation in corridors of approximately 15’ in width, spaced 

approximately every 100’. Approximately 15%, or 72 acres, of Protected Habitat treated with cable-logging 

operations would therefore be denuded under Alternative 2. Much of this area contains extremely large 

(>24” DBH) pre-settlement trees and snags (JJD, personal observation).

2012 DEIS at 178-179; compare SDEIS at 6 (disclosing only five acres of PAC to be denuded of trees in cable 

logging corridors under Alternative 2). Second, new road construction would destroy another 8.2 acres protected 

habitat: 

Road construction would cause an incidental loss of trees >18” DBH. This analysis assumes that the 

average width of land cleared to create a roadbed is one chain (66 ft.), so approximately eight acres of land 

would be denuded of trees for every one mile of road. Approximately 11.7 miles (94 acres) of new, 

Maintenance-Level 1 roads would be constructed in MSO habitat under Alternative 2, with approximately 

0.2 miles (1.6 acres) on the northwestern edge of the Bill Williams PAC, approximately 0.5 miles (4 acres) 

in Protected Habitat outside the PAC, and the remainder in Restricted Habitat. Approximately 11 miles (88 

acres) of new, Maintenance-Level 1 roads would be constructed in MSO habitat under Alternative 3, with 

approximately 0.2 miles (2 acres) on the northwestern edge of the Bill Williams PAC and the remainder in 

Restricted Habitat. Alternative 2 would involve construction of approximately 6.8 miles (54 acres) of 

temporary roads (obliterated after treatments are completed) in MSO habitat, with approximately 0.1 miles 

(0.8 acres) in the PAC and 0.2 miles (1.6 acres) in Protected Habitat outside the PAC under Alternative 2 

and the remainder in Restricted Habitat. Alternative 2 [sic] would involve construction of approximately 

6.5 miles (52 acres) of temporary roads in MSO habitat, all in Restricted Habitat. Alternative 4 would not 

involve the construction of new, Maintenance-Level 1 roads; however, it would entail construction of 

approximately 17.5 miles (140 acres) of temporary roads in MSO habitat, with approximately 0.2 miles 

(1.6 acres) on the northwestern edge of the Bill Williams PAC and the remainder in Restricted Habitat.

2012 DEIS at 178. New permanent road construction would destroy nesting and roosting opportunities for 

Mexican spotted owl on 5.6 acres, and temporary road construction would remove trees on an additional 2.6 acres 

of protected habitat. In all, the proposed action would destroy approximately 80 acres of existing suitable 

protected habitat. The revised Recovery Plan for Mexican spotted owl recommends against such activity: “New 

road or trail construction is not recommended in PACs” (USDI 2012a: 274, 261). The FWS qualifies its 

recommendation, stating: “New road construction should be avoided whenever possible, and temporary road and 

skid trail construction should be designed to minimize impacts on soil integrity and natural recovery processes. 

All new and temporary roads and skid trails should be decommissioned and obliterated after use” (USDI 2012a: 
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396 Appendices

264). However, new road construction may adversely affect primary constituent elements of Mexican spotted owl 

critical habitat, and this is a significant issue for analysis. New roads may destroy large trees and coarse woody 

structure, permanently impair soil productivity and alter plant communities, even if their use is temporary. Loss of 

large tree and coarse wood constituent elements is irreparable.

Further, the FWS documented incidences when Mexican spotted owls were killed by motor vehicles on unpaved 

roads (USDI 2012a: 29, 229). In addition, “[R]oads and trails through PACs may fragment habitat continuity, alter 

natural movement patterns, and increase disturbance to resident owls. Roads in nest/roost, forested, and riparian 

recovery habitat may also result in loss of habitat components (e.g., large logs, large snags, hardwoods) as people 

access these areas for fuelwood cutting, and in sensitive riparian areas, roads and trail can inhibit hydrological 

processes that affect proper functioning ecological conditions” (USDI 2012a: 45). In other words, new roads 

introduce the possibility of chronic harassment outside the scope of the initially permitted incidental take. Noise 

associated with road maintenance in PACs may harass Mexican spotted owls and decrease their reproductive 

success (USDI 2012a: 234-235). 

Response to Comment 6-4 

The project no longer includes cable logging in the action alternatives. In addition no new roads and only 0.1 

miles of temporary road construction will occur within the protected habitat (PAC). The 0.1 mile of temporary 

road will not remove any nesting/roosting MSO habitat. In response to comments the mileage in the modified 

proposed action was reduced to 15 miles on new road construction, 16 miles of temporary roads to be obliterated 

after treatment, and obliteration of 23 miles of poorly placed (in terms of resource damage) roads. Roads and the 

effects on the MSO and critical habitat were included in the BA, which USFWS consulted on. There is mitigation 

that states that speeds will be restricted to 15 miles per hour or less along haul routes within 0.25 mile of the PAC. 

The biological opinion (page 25) notes, that this mitigation combined with the comparatively low number of 

ground haul trips associated with the project and near the PAC, will make owl-vehicle collisions unlikely to occur. 

Comment 6-5 

The analysis is silent regarding the timeframe required to recover other elements of critical habitat, such as 

effective ground cover and food sources for seed-eating prey species, after temporary roads are decommissioned 

or obliterated. “New road construction should be avoided whenever possible, and temporary road and skid trail 

construction should be designed to minimize impacts on soil integrity and natural recovery processes. All new and 

temporary roads and skid trails should be decommissioned and obliterated after use” (USDI 2012a: 264). 

Response to Comment 6-5 

Roads were analyzed in the FEIS (section 3.6 “Transportation” pgs. 160-165). The effects of the project area 

roads were analyzed for effects on MSO and MSO critical habitat in the BA. Roads are a necessary tool for 

removing material in order to meet the purpose and need of the project. Mitigation measures displayed in chapter 

two would be used to minimize effects from roads and road construction on soils, hydrology, MSO and MSO 

critical habitat. 

The FEIS (page 156) states “For the first one to three years following vegetation treatments, a slight increase in 

stormwater runoff is expected since understory vegetation of grasses, forbs and shrubs will not have reached 

maximum ground cover levels, snowpack interception would be reduced, and there would be fewer trees to create 

evapotranspiration demand for soil moisture during the growing season.” 

In response to comments roads construction activities in the modified proposed action were reduced to 15 miles 

on new road construction, 16 miles of temporary roads to be obliterated after treatment, and obliteration of 23 

miles of poorly placed roads. Recovery after obliteration is covered in the best management practice (BMP)#28: 

After use all temporary roads will be ripped to a shallow depth (<6”), seeded using the seed mix specified in BMP 

# 10, drained through installation of necessary water diversion structures and covered with slash from landings. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 397

Comment 6-6 

Furthermore, the original Mexican Spotted Owl Recovery Plan (USDI 1995) stated that uneven-aged forest 

management may adversely affect the availability of large trees in suitable nesting and roosting habitat:

We have not been able to assess the effects of classic uneven-aged management on Mexican spotted owl 

habitat because we were unable to acquire data for most areas where uneven-aged management is practiced 

on a large scale. However, based upon our understanding of the application of uneven-aged systems, stand 

density is often kept at a fairly low level, seldom exceeding 18 m2/ha (80 ft2/acre) of basal area. These low 

residual stand densities allow for regeneration and growth of ponderosa pine. Unevenaged systems, 

whether they retain individual trees or groups of trees, allow for the development of multiple canopy levels, 

a key component of Mexican spotted owl habitat. However, Ganey and Dick (1995) demonstrate clearly 

that owl habitat typically also includes significant numbers of large trees. These large trees may not be 

retained where uneven-aged management is applied in this fashion.

In summary, uneven-aged management has some promise for providing stands exhibiting characteristics of 

spotted owl habitat. As currently practiced, however, uneven-aged management results in large acreages of 

low-density stands, numerous road openings, and the eventual eradication of large diameter stems. 

Although neither the short- or the long-term effects of these applications on spotted owls are known, this 

type of application may not be the best option for producing spotted owl habitat.

USDI (1995: 71). The project would retain just 60-160 square feet per acre (ft2/ac) of basal area (“BA”) in 

Mexican spotted owl critical habitat. See 2012 DEIS Appendix E at 13 (tree “groups” in critical habitat “will 

range from 60-160 ft2 in basal area”). “Desired conditions” for mixed conifer and pine-oak forest include 

“openings” of up to two acres featuring “very few, if any, trees.” Id. 11 and 13. That condition is not consistent 

with the “minimum” desired condition of 120 ft2/ac basal area in mixed conifer recovery habitat (USDI 2012a:

278 (Table C.3)). 

Response to Comment 6-6 

This project is following the 2012 Revised MSO Recovery plan. The commenter is referring to the obsolete 1995 

recovery plan. The 2012 revised MSO recovery plan, followed by the 2014 revised forest plan allows the Kaibab 

National Forest to adopt and implement management recommendations based on the best available science found 

in the recovery plan. Therefore, the term and condition that they cite does not apply to the 2014 revised forest plan 

and the plan is not in violation of the National Forest Management Act (NFMA). 

Uneven aged management provides a range of conditions that allow us to promote the Primary Constituent 

Elements (PCEs) of critical habitat and desired conditions of MSO key habitat types. Effects of 

treatments/actions on Critical habitat for the MSO are analyzed in the BA. The effects determination for MSO 

critical habitat is May Affect, Likely to Adversely Affect. This is due to permanent and temporary road 

construction, and the removal of snags as a safety precaution in areas of helicopter logging. Critical PCEs does 

not contain a basal area requirement, but instead has a 40% shade cover requirement. Where the project area 

current meets the 40% shade cover, this PCE will be retained. The two-acre openings are consistent with the 2012 

MSO recovery plan recommendations and critical habitat PCEs. 

The comment is also in error in saying that desired conditions for critical habitat and mixed conifer nest/roost 

recovery habitat (basal area of 120 square feet per acre) are the same. They are not. The recommended 120 

square feet per acre basal area in the recovery plan is only areas that contain or is being toward nesting and 

roosting habitat. It is not used for other recovery habitat. Critical habitat is defined as all mixed conifer or pineoak stands as defined in the 2004 recovery plan as MSO habitat (USDI 2004). This includes stands that are 

considered foraging habitat which have a lower basal area. 

Comment 6-7 

Monitoring in the proposed action is controversial because the Forest Service admitted in an October 2008 Annual 

Report to the U.S. Fish and Wildlife Service (“FWS”), and in litigation, that it lacked funding and personnel to 

conduct required monitoring of Mexican spotted owl habitat and populations to ensure that its actions would not 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

398 Appendices

jeopardize the continued existence of the species nor adversely modify critical habitat. In October 2008, the Forest 

Service provided its Annual Report to the FWS for the period of June 10, 2005, through June 10, 2007, regarding 

the Programmatic Biological Opinion on the Land and Resource Management Plans for the 11 National Forests 

in the Forest Service Southwestern Region. In it, the Forest Service acknowledged that it failed to comply with the 

monitoring requirements set forth in the biological opinion’s terms and conditions, and/or likely exceeded the 

allowable incidental take for a number of listed species, including Mexican spotted owl. The Forest Service 

typically monitored only 20-25% of PAC during 2005-07. Moreover, the agency monitored that sample of PAC 

for owl occupancy but not reproduction. The Forest Service stated in the Annual Report that personnel and 

funding levels were inadequate to meet the monitoring requirements set out in Term and Condition 3.1 of the 

biological opinion. As a result, in many cases, monitoring has not been accomplished. The Forest Service has 

failed to “monitor changes in owl populations and habitat needed for delisting,” as required by the Kaibab forest 

plan, in violation of NFMA.

The proposed action, under the heading, “Monitoring,” states, 

Mexican Spotted Owls 

1. Survey suitable MSO nesting/roosting habitat in the project area prior to implementation, either during 

the year of implementation or one year prior to implementation.

2. Conduct pre- and post-treatment microhabitat monitoring in MSO Protected and Restricted Habitat. 

Dependent on available resources, post-treatment monitoring will occur 1-2 years after the first thinning or 

burning treatments within Protected Habitat; post-treatment monitoring should not be withheld until the 

entire project area has been treated. Attributes to monitor include units/acre and/or basal area of oaks and 

other hardwoods greater than or equal to 10 inches drc, trees 12-18 inches dbh), trees greater than or equal 

to 18 inches dbh, down logs greater than or equal to12 inches midpoint diameter, and snags greater than or 

equal to 18 inches dbh.

2012 DEIS at 25. The efficacy of proposed treatments in promoting the conservation and recovery of Mexican 

spotted owl is uncertain (USDI 1995, USDI 2012b). The Forest Service is required by NEPA to disclose scientific 

controversy and uncertainty regarding effects of the project to Mexican spotted owl and its critical habitat. The 

complete monitoring plan, including study design and analysis protocols, should be made available for public 

review and comment before a decision is made to implement the project. The Center has specific questions 

regarding the monitoring plan, including but not limited to: (1) criteria for selection of PAC as paired treatment 

and control sites; (2) criteria for selection of measurable indicators of change; (3) sampling design power analysis 

and expected observational error rates; (4) sampling procedures including monitoring cycle...

Response to Comment 6-7 

The 2008 monitoring requirements referred to by the commenter is not required under the September 10, 2013 

Biological Opinion for the Kaibab National Forest Land and Resource Management Plan (USDI 2013). Therefore, 

the term and condition that they cite does not apply to the 2014 revised forest plan and the plan is not in violation 

of NFMA. However, the Southwestern Regional Office is working with USFWS to develop an occupancy model 

and survey design that will provide population data and trend for the recovery of the species as proposed in the 

revised recovery plan. 

The Bill Williams PAC has been surveyed every year since 1992 (except for 2012). Formal surveys will continue 

into the future every year in this area. Monitoring is part of the FEIS, Section 2.4.5.1 “Monitoring”. The 

monitoring required from the terms and conditions of the May 5, 2015 Biological Opinion for this project has 

been included within the monitoring plan. This project will not have a paired monitoring and it is not required for 

this project. In discussion with USFWS, that study is being done with the Four-Forest Restoration Initiative 

(4FRI) project which is at a scale that is more likely to provide needed sample size to scientifically answer 

questions on the impact to MSO from restoration treatments. 

Monitoring for MSO
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 399

This is monitoring required under Forest Plan BO and what is in the draft BO (reads the same). We are not doing 

the type of monitoring they are requesting. Paired study. This is being done with 4FRI. Monitor the impacts of 

incidental take resulting from implementation of the proposed action and report these finding to the USFWS. 

Incidental take monitoring shall include information such as when or if the project was implemented, whether the 

project was implemented as proposed and analyzed in the site-specific BO, breeding season(s) over which the 

project occurred, relevant owl survey information, and any other pertinent information about the project’s effects 

on the species.

The commenter did not disclose what scientific controversy that has not been analyzed in the SDEIS, so it is not 

possible to address that concern. There is some uncertainty of effects on the MSO from restoration activities. 

However, the forest has worked with the USFWS to develop manage activities within MSO habitats. In addition 

formal consultation with the USFWS has resulted in only a harassment take to the owl. The BO (USDI 2015) has 

notes that the project should result in long term benefits to the MSO (see response to comment 6-1) 

Comment 6-8 

(5) confidence levels to be applied in data analysis and reporting; (6) timeframe for evaluation of results; and (7) 

triggers for management adaptation using new information. In addition, the Forest Service should study, develop 

and describe an action alternative that:

• Avoids road construction in PAC.

• Applies spatial modeling of different treatment intensities and configurations in Mexican spotted owl 

habitat, as demonstrated by Prather and others (2008). 

Response to Comment 6-8 

In response to comments no new road construction in the PAC would occur under any action alternative. 

Improving the motorized transportation system for the Bill Williams Project area is part of the purpose and need 

of this project. It is integral to achieving other aspects of the purpose and need including forest restoration, 

reduction of the risk of catastrophic wildfire and removal of wood products. The silviculturist and wildlife 

biologist used FVS modeling to ascertain the effects of treatment on key MSO habitat variables. This analysis is 

found in the BA, the silviculturist specialist reports, and the FEIS. 

Comment 6-9 

The modeling work of Prather and others (2008) is particularly relevant to this analysis because it is: (1) specific 

to the project area; (2) consistent with the purpose and need of the project; (3) representative of the best available 

science; and (4) offers a meaningful basis for comparison of the intensity of environmental impacts that may 

result to significant factors including federally listed species and critical habitat. “[E]ven without application of 

treatments that would seriously affect MSO habitat, managers could achieve approximately 60% of the fuels 

reduction that would be achieved if there were no restrictions on treatments. With reasonable tradeoffs considered 

in planning, such as largely treating in lower suitability owl habitat, this figure would rise to over 80%” (Prather 

et al. 2008: 148). “When conservation and restoration planning is scaled-up from a stand to landscape scale, many 

apparent conflicts disappear as management actions are spatially partitioned and prioritized” (Prather et al. 2008: 

149). 

Response to Comment 6-9 

Most road construction has been removed from the PAC with only 0.1 mile of temporary road included. The 0.8 

acres of effected acres from the construction of the temporary road is not within mixed conifer or pine-oak 

habitat. 

The Prather et al. (2008) analysis cited by the commenter included the entire Upper Gila Mountains MSO 

Recovery Unit (811,000 acres) of which this project is located. However, the study was focused specifically on 

Ponderosa Pine forest habitat type. The Bill Williams Mountain Restoration Project area d includes ponderosa 
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400 Appendices

pine and mixed conifer habitat types. The article supports treatment in MSO habitat stating, “Arguments that 

treatments within owl habitat are generally unnecessary are short-sighted. Treatments within MSO habitat could 

result in considerable benefits, both for communities and MSO habitat, albeit potentially more costly and difficult 

to implement than treatments outside of MSO habitat, (p. 148)” 

Following the exact recommendations from Prather et al. are difficult because of the smaller scale of this project 

and the different habitat types, and are inconsistent with the objectives and purpose and need of this project. 

Further Prather et al. indicate that treatments in MSO habitat are largely beneficial to the species, overall, in lieu 

of short term negative effects. Further the authors say, “In some cases not only do the needs of individual 

imperiled species conflict with one another, but restoration and management goals for the ecosystem do not 

coincide with species-specific management objectives.”pg 147.

The authors go on to say, “In some cases carefully designed thinning and burning treatments may actually 

enhance habitat quality for Mexican spotted owls, while aggressive treating of adjacent, forest stands can reduce 

fire hazard across the landscape, thus better protecting both human communities and owl habitat...”although 

aggressive thinning may reduce owl habitat quality at a specific location, when examined from a landscape 

perspective, well-placed thinning and prescribed fire can enhance overall owl habitat quality, both through 

improving the quality of the marginal stands and reducing the likelihood of large losses of habitat from standreplacing fire.” Pg 148. 

Our proposed activities/treatments are supported by Prather, et al.

Comment 6-10

Plan amendments

The Forest Service characterizes the forest plan amendments in this project as “one-time, project specific” 

changes to management direction for threatened Mexican spotted owl and sensitive northern goshawk. SDEIS at 

2-3. In fact, the agency simultaneously proposes the same or similar plan amendments in concurrent projects on 

the Kaibab and Coconino national forests. Their cumulative effect is to render meaningless existing forest plans 

and invalidate biological opinions and associated incidental take statements on implementation of forest plans. 

Independent of this project, all of the action alternatives in the Four Forest Restoration Initiative Draft 

Environmental Impact Statement (“4FRI DEIS”) amend standards and guidelines of the Kaibab and Coconino 

forest plans, respectively, for Mexican spotted owl. In particular, they: (1) permit mechanical removal of trees up 

to 18-inches diameter 18 PAC totaling 7,353 acres; (2) allow prescribed fire in 56 PAC nest core areas comprising 

5,600 acres; (3) modify PAC habitat in excess of 10 percent in each recovery unit; (4) forego designation of an 

equal number of untreated PAC as monitoring controls; (5) shun monitoring of owl populations and habitat; (6) 

shirk designation of “target” or “threshold” (i.e., nesting and roosting) habitat; and (7) retain as little as 110 

ft2/acre basal area on 6,321 acres of recovery habitat. See 4FRI DEIS at 549-561 (Alternative C – Amendment 3 

to Kaibab forest plan); 500-518 (Alternative C – Amendment 1 to Coconino forest plan). Remarkably, the Forest 

Service maintains that those forest plan amendments are “a specific, onetime variance” from the standards and 

guidelines, and “the language proposed does not apply to any other forest project.” Id. at 500. 

In addition to the 4FRI, the proposed action for the Mahan-Landmark Project in the Coconino National Forest 

includes a forest plan amendment that would allow logging trees up to 16-inches diameter in PAC. Moreover, the 

proposed action for the Flagstaff Watershed Protection Project would amend the Coconino forest plan to: (1) 

allow logging and burning in spotted owl nest cores; (2) repeal the 9-inch diameter limit on mechanical logging in 

PAC; (3) delete timing restrictions on PAC treatments; (4) ignore the 24-inch diameter limit on logging in 

Restricted Habitat; and (5) disregard monitoring of spotted owl populations and habitat. 

Proposed amendments to forest plans in all of these concurrent and foreseeable land management actions are 

similar or identical, affecting the same national forests, yet the Forest Service states in duplicative language that 

each is “one-time,” “specific,” or does “not apply to any other forest project.” The Forest Service is required to 

take a hard look at the cumulative effect of plan amendments on threatened species and critical habitat.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 401

Response to Comment 6-10

The Kaibab National Forest has a revised forest plan. The decision for this project will be signed under the 

revised plan. Proposed actions associated with this project are consistent with the revised forest plan and 

amendments are no longer needed. Thinning in the MSO nest core is no longer included in this project.

Comment 6-11

Northern goshawk

The latest report of the Kaibab National Forest on management indicator species habitat and population trends 

(USDA 2010) states that the source population of northern goshawk on the Kaibab Plateau is in decline, and the 

species is “at risk of extirpation or extinction in Arizona.” The Forest Service must ensure that the project will not 

adversely affect goshawk or contribute to a trend toward listing under the Endangered Species Act. 

The amended Kaibab forest plan incorporates the Management Recommendations for the Northern Goshawk in 

the Southwestern United States (Reynolds et al. 1992), which quantifies structural attributes of habitat for 

northern goshawk and 14 of the hawk’s prey species. To date, two environmental impact statements on forest 

planning in the Southwestern Region have based action alternatives and decisions on those recommendations 

(USDA 1996, 2006). In doing so, the Forest Service established a habitat-proxy relationship of ponderosa forest 

structure and viability of northern goshawk, and applied a proxy-on-proxy assumption to its analysis of 

population viability for 14 vertebrate prey species. 

Application of canopy cover guidelines derived from the Management Recommendations (Reynolds et al. 1992) 

at small clump- and group-scales (generally <1 acre) instead of at larger forest stand scales has the potential to 

significantly reduce the amount of forest cover within areas subject to vegetation treatment, with detrimental 

consequences to goshawk and its prey. For example, assuming a residual canopy cover of 50 percent within tree 

groups (<1 acre) after vegetation treatment, and if such groups occupy 50 percent of a stand (>2 acres), canopy 

cover at the stand scale will be 25 percent (Table 1). To prevent this outcome in site-specific projects, which 

clearly would harm goshawk and its prey, the Management Recommendations (Reynolds et al. 1992) and the 

amended forest plans incorporating them, including the Kaibab forest plan, require maintenance of canopy cover 

at stand scales in goshawk nesting and fledging habitat. This schematic demonstrates that the proposed action may 

fall short of canopy cover requirements established by the amended forest plan even within post-fledging and nest 

areas, and may significantly impact sensitive species at an intensity that exceeds what was analyzed and disclosed 

prior analysis (USDA 1995, 2006). 

Response to Comment 6-11

The northern goshawk is on the Regional Forester’s list of sensitive species and we must analyze the effects of 

project activities on goshawks and their habitat. These effects are analyzed in the wildlife specialist report. The 

analysis concluded that the modified proposed action may impact individuals but is not likely to cause a trend 

toward federal listing or affect the viability of the species. 

The commenter discussion about the forest plan based on the previous forest plan and not the revised forest plan 

that was signed in 2014 (USDA 2014). While Reynolds et al. (1992) is not incorporated directly into the revised 

forest plan, the revised forest plan is based off the concepts of GTR 310 (Reynolds et al. 2013). GTR 310 has 

incorporates the concepts of Reynolds et al. (1992) within its development. Desired conditions for ponderosa 

pine and mixed conifer cover types (pages 17-23) guides the development stands from fine scale to landscape 

scale. There is not canopy cover requirement within the revised forest plan. All alternatives within the FEIS is in 

compliance with the revised forest plan. 

Comment 6-12

Finally, the Forest Service is proposing virtually identical forest plan amendments in every project-level analysis 

throughout the Southwestern Region. It should account for the cumulative effect of its coordinated, but piecemeal, 

effort to unravel current management direction for northern goshawk habitat. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

402 Appendices

Table 1. Prescription intensities and canopy cover percentages measured at stand and group scales

Response to Comment 6-12

This project would not cause a federal trend for listing for the northern goshawk. 

The Kaibab National Forest has a revised forest plan. The decision for this project will be signed under the 

revised plan. Proposed actions associated with this project are consistent with the revised forest plan and 

amendments are no longer needed.

Comment 6-13

Old growth

There is a need to conserve existing old growth structure and to hasten its development in the project area. Old 

growth differs from other forest structure because it comprises the preferred habitat of many endangered, 

threatened and sensitive wildlife species, and supplies a host of ecological services including soil retention and 

carbon storage (Kaufmann et al. 1992, Luyssaert et al. 2008). Logging significantly reduces long-term recruitment 

of coarse wood and old growth habitat (e.g., Quigley et al. 1996, Spies 2004, van Mantgem et al. 2009). Most of 

the former old growth in the ponderosa pine and mixed conifer formations of the Southwestern Region were 

destroyed by logging (Covington and Moore 1994). 

The analysis should disclose the spatial extent of old growth meeting forest plan criteria at each of the prescribed 

scales, and the extent of old growth meeting the definition supplied by Reynolds and others (2013: 47-48). This 

information should be clearly displayed in a manner that is easily understood by public. Removal of old growth 

structure may be a cumulatively significant environmental impact.

Response to Comment 6-13

The revised Kaibab National Forest plan (USDA 2014) defines old growth by the following: 

“Old growth in southwestern forested ecosystems is different than the traditional definition based on 

northwestern infrequent fire forests. Due to large differences among Southwest forest types and natural 

disturbances, old growth forests vary extensively in tree size, age classes, presence and abundance of 

structural elements, stability, and presence of understory (Helms 1998). Old growth refers to specific 

habitat components that occur in forests and woodlands—old trees, dead trees (snags), downed wood 

(coarse woody debris), and structure diversity (Franklin and Spies 1989, Helms 1998, Kaufmann et al. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 403

2007). These important habitat features may occur in small areas, with only a few components, or over 

larger areas as stands or forests where old growth is concentrated (Kaufmann et al. 2007). In the Southwest, 

old growth is considered “transitional” (Oliver and Larson 1996), given that the location of old growth 

shifts on the landscape over time as a result of succession and disturbance (tree growth and mortality). 

Some species, notably certain plants, require “old forest” communities that may or may not have old 

growth components but have escaped significant disturbance for lengths of time necessary to provide the 

suitable stability and environment”

In Southwestern frequent-fire forests, old growth is naturally fragmented, and occurs as tree groups, clumps, 

individual trees, and occasional patches in an uneven-aged forest landscape. Research has demonstrated an 

inverse relationship between fire frequency and old-growth contiguity. In the ponderosa pine and frequent-fire 

ecosystems of Kaibab National Forest, local research has shown that old growth did not occur in large contiguous 

areas, but rather as fine-scale components of the uneven-aged system (Reynolds et al. 2013). There is no scientific 

basis to support managing for contiguous old-growth conditions at larger scales for these vegetation types on the 

Kaibab National Forest. 

Project activities provide for a range of old-growth conditions and function over time at the fine, mid, and 

landscape scales as defined in the desired conditions in the revised forest plan (pp. 17-23). Spatial shifting or 

transition of old growth on the landscape over time would remain consistent with historic conditions meeting the 

purpose and need to improve the diversity of age classes and structure of woody vegetation. While alternative 2 

allows for the removal of large, mature, and old trees, the vegetation analysis demonstrates that result in a net gain 

of large trees over time, and more than any other alternative. Therefore, alternative 2 would not result in an 

irreversible or irretrievable commitment of resources. Moreover, managing for restored forest conditions, which is 

part of the purpose and need, that are similar to natural conditions will restore resiliency and the evolutionary 

environment of these forests, providing the best opportunity for these forests to persist and adapt to future 

climates (Reynolds et al. 2013). 

Old growth throughout the landscape would shift over time as a result of succession and disturbance in ponderosa 

pine and frequent-fire mixed conifer, where a high degree of age-class interspersion (fragmentation) is natural, 

and therefore desired. For mesic mixed conifer, the project at the landscape scale will maintain old growth over 

large areas as stands and forests. The project provides habitat for goshawk nest areas, which are typically welldefined tree groups that meet the definition of old growth. The project also provides larger areas managed for 

MSO recovery nest/roost habitat, MSO PAC and Arizona bugbane, which would be dominated by old growth 

patches and tree groups. 

Mitigation measures are in place for the project area to maintain and protect pre-settlement trees, the old trees that 

lived during the time period where natural functions such as frequent fire events persisted naturally under historic 

fuel loadings. The placement of these old trees across the landscape helps define existing old growth on the 

ground. The project manages for old growth and old-growth components for all forest and woodland vegetation 

types, which the proposed activities maintain or make progress toward. 

Additionally, the project follows revised forest plan guidelines (plan page 30) to generally not remove structural 

components associated with old growth including large old ponderosa pine trees with reddish-yellow wide platey 

bark, mature trees with large dwarf mistletoe-induced witches’ brooms, large snags, partial snags, and trees 

(greater than 18 inches DBH) with broken tops, cavities, sloughing bark, and lightning scars. In addition, the 

project “should generally retain at least historic frequencies of trees by species across broad age and diameter 

classes at the mid-scale. As such, the largest and oldest trees are usually retained”.

Comment 6-14

Large trees

The Old Growth Protection and Large Tree Retention Strategy (“strategy”) collaboratively developed by public 

stakeholders for implementation in the Four Forest Restoration Initiative is an “agreement-based outcome and 

product” recognizing that “translation of such agreement greatly enhances chances for success, and reduces the 

risk of conflict.” It defines the “social license” for ecological restoration requested by the Regional Forester. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

404 Appendices

More, on July 2, 2013, the Forest Supervisor of the Apache Sitgreaves National Forests committed to implement 

the strategy in the Rim Lakes Project. It is a reasonable alternative for this project. 

The strategy describes precautionary exception criteria for removal of large young trees in explicitly defined 

ecological settings. It must not be interpreted as blanket license to remove large trees in each of the listed settings. 

The strategy provides for removal of large trees (>16-inches diameter) to address site-specific needs for 

maintenance or restoration of uneven-aged ponderosa pine forest. It is specific in “identifying circumstances, 

ecological objectives and selection criteria for instances in which large post-settlement trees may be cut to meet 

restoration objectives,” and it proposes a procedure for “collaborative discussion and planning that we hope will 

bolster restoration efforts by increasing confidence and knowledge-sharing, maximizing agreement and 

minimizing disagreement” regarding the uniquely complex and challenging “exception category” of “Heavily 

Stocked Stands with High Basal Area Generated by a Preponderance of Large Young Trees.” The strategy 

acknowledges, “In stands where pre-settlement evidences, restoration objectives, community protection, or other 

ecological objectives indicate much lower tree density and [basal area] would be desirable, large post-settlement 

pines may need to be removed to achieve post-treatment conditions consistent with a desired restoration 

trajectory,” and it outlines ecological objectives that inform large tree removal in those site-specific contexts.

The ecological objectives of the strategy are consistent with the stated purpose and need for this project. For 

example, to promote forest “openness,” the strategy provides: “Large (>16” dbh) post-settlement ponderosa pine 

trees may be removed to restore the unique biophysical attributes of within stand openings according to these 

criteria,” including “(2) Where desired openings are tentatively identified as _0.05 acre[]” (emphasis supplied). 

An action alternative based on the strategy would realize the desired condition of more extensive openings in the 

project area, but may do so differently from the proposed action. A comparison of alternatives would afford the 

decision-maker and the public a basis to understand effects on forest vegetation (uneven-aged structure) and 

wildlife habitat (canopy cover) resulting from the forest plan amendments contained in the proposed action. 

Response to Comment 6-14

The full analysis for large tree retention is disclosed in the FEIS pp. 82-83. The analysis discloses the effects, by 

alternative on large trees within the project area. The ecological tie to vegetative structural stage (VSS) 4-6 and 

old growth habitat are reflected in the analysis. Old Growth analysis promotes the purpose and need to improve 

the diversity of age classes and structure of woody vegetation. The Large Tree Retention Strategy (LTRS) for the 

Four Forest Restoration Initiative is out of the scope of this project due to the difference in setting and conditions. 

The purpose and need and the desired conditions for this project are specific to the steep slope conditions, 

increased potential of catastrophic wildfires, and protection of the watershed southwest of Williams, Arizona. The 

LTRS, as written by the 4FRI stakeholders, would not meet the purpose and need for the project due to the 16” 

inch diameter limit.

Comment 6-15

Road construction 

All of the action alternatives include significant new road construction and reconstruction. Those activities may 

affect soils and water quality, a significant issue for analysis. Roads and ground-based logging activities may 

cause significant losses of soil productivity (Gucinski et al. 2001: 21) (“Losses of productivity associated with 

road-caused, accelerated erosion are site specific and variable in extent, but they are commonly reported for all 

steep-slope landscapes”). New roads can permanently impair soil productivity even if their use is temporary 

(Trombulak and Frissell 2000). 

Road-related soil erosion is a chronic source of sediment production that can limit water quality (Gucinski et al. 

2001). The distance that sediment travels is an important factor in determining how much eroded soil is delivered 

to a water body. Soil loss and erosion occurring closer to a stream have greater potential to deliver sediment and 

lead to water quality impairment than erosion triggered farther away from streams. For this reason, road-stream 

crossings have high potential to adversely impact water quality (Endicott 2008). In addition, road construction and 

fuel treatments may combine to increase overland water flow and runoff by removing vegetation and altering 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 405

physical and chemical properties of soil, which can permanently alter watershed function (Elliot 2010, Robichaud 

et al. 2010). This has implications for the purpose and need to protect municipal water supplies from socially 

undesirable effects of flooding and erosion. 

The extent and location road construction and its effects to soil erosion, runoff channelization and suspended 

sediment loads merit a hard look in the analysis. The Forest Service should study, develop and describe an action 

alternative that foregoes road building on steep slopes and sensitive soils where it may increase erosion or impair 

productivity. Such an alternative would provide the decision-maker and the public with a meaningful basis on

which to compare environmental effects. Project design features may fail to mitigate significant cumulative 

effects (Endicott 2008: 93) (noting lack of science to validate effectiveness of many best management practices 

related to forest roads). New roads directly remove and cumulatively fragment wildlife habitat, and they indirectly 

contribute to biological invasions of noxious weeds (Gucinski et al. 2001). Significant cumulative effects of road 

construction are foreseeable in other projects on the Williams Ranger District.

Response to Comment 6-15

The effects on soils (by terrestrial ecosystem survey (TES) map unit, slope classes and associated acreages), 

including predictions of sediment delivery to stream courses from construction of permanent and temporary roads 

was analyzed and disclosed in the soil and watershed specialist’s report, pages 75-77, and Tables 19 and 20. This 

information was incorporated into the FEIS tables 3-25 and 3-26. Table 3-42 provides the approximate mileage of 

poorly located roads that would be obliterated.

Rarea roads were analyzed for effects on soils in the FEIS. A road network is needed to meet the poads were 

analyzed in the FEIS (section 3.6 “Transportation” pages 160-165). The effects of the project urpose and need of 

the project, which is to improve the motorized transportation system to provide for a more sustainable road 

system where poorly located roads are relocated or obliterated. Mitigation measures (chapter two of the FEIS) 

would minimize effects from roads and road construction, on soils and hydrology. The commenter states that in 

regard to roads and impacts on watershed function, “This has implications for the purpose and need to protect 

municipal water supplies from socially undesirable effects of flooding and erosion”. This concern is specifically 

addressed in the purpose and need statement for the project: The effects of the proposed actions and the no action 

alternative were analyzed in the soils and hydrology specialist reports associated with the project record and the 

FEIS. The no action alternative would likely result in the socially undesirable effects listed by the commenter. 

The commenter also states that “The Forest Service should develop and describe an action alternative that forgoes 

road building on steep slopes and sensitive soils where it may increase erosion or impair productivity.” This is 

captured in alternative 1, no action. Without a road network to access treatment areas and remove material, the 

project could not meet the objectives of restoration and fire risk abatement.

The transportation specialist report for the Bill Williams Mountain Restoration Project has more detail about the 

proposed road construction. Under Alternatives 2 and 3, temporary roads would only be constructed on slopes less 

than 20% side slope; roads on side slopes over 20% were all permanent roads. Under alternative 4 all roads, both 

over and under 20% side slopes would be temporary roads. 

Effects of roads on TES species were analyzed in the BA, and summarized in the FEIS. In response to comments, 

road actions/treatments in the modified proposed action were reduced to 15 miles of new roads, 16 miles of 

temporary roads to be obliterated after use, and obliteration of 23 miles of poorly located roads, ,currently causing 

resource damage.

Comment Letter 7: Sierra Club 

Comment 7-1 

In our comments on the July 2012 Bill Williams Project DEIS, we pointed out a number of apparent mistakes in 

the way that the Kaibab National Forest (“KNF”) interpreted its own statistical analysis (See letter dated August 

27, 2012, “Analysis of Direct and Indirect Effects is Flawed”, pp. 9-12). According to the Forest Service’s 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

406 Appendices

statistics, the Proposed Action was not the best way to achieve the project’s Purpose and Need; in fact, Alternative 

4 is projected to bring the project area into desired ranges for VSS 1, 2, and 3; Alternatives 3 and 4 both end up 

closer to target VSS conditions by 2053 than the Proposed Alternative. Alternative 4 reaches the desired condition 

for VSS 6, 10-20 years earlier than other Alternatives. Alternative 4 also better approaches the Forest Service’s 

objectives regarding dwarf mistletoe. Alternative 4 proposes techniques that more closely simulate natural and 

historical fire processes, requires no Forest Plan amendments, and has a lower cost than other alternatives. 

Alternative 4 does not include a proposal to improve poorly located roads, but road improvement could easily be 

added to improve Alternative 4 even more. In our letter dated August 27, 2012, we suggest some other ways to 

improve Alternative 4.

Response to Comment 7-1 

The need’s purpose and need of the project has several goals;, primary goal is to restore forest conditions and 

reduce the risk of catastrophic wildfire. Alternative 4 only treats steep slopes on Bill Williams Mountain with 

prescribed fire. The fuels specialist report demonstrated that Alternative 4 would result in a decrease in crown fire 

(as compared to alternative 2) but would also result in a greater area of continuous crown fire, especially on the 

slopes of Bill Williams Mountain by mimicking historical forest conditions while alternative 3 & 4 will maintain 

forest conditions at higher densities. Uneven-aged forest conditions would be achieved in alternative 2 but would 

not be achieved in the mixed conifer for alternative 3 and 4. All the action alternatives meet the objective of 

mistletoe management. Alterative 2 does not primarily focus on mistletoe removal to meet the desired condition 

while tree removal in alternative 3 & 4 would be based on mistletoe infection. However alternative 2 would focus 

some mistletoe reduction within individual groups. Bark beetle hazard risk would be lowered to manageable 

levels for all action alternatives. Effectiveness for bark beetle hazard risk would be most effective for alternative 

2, less effective for alternative 3 and least effective for action alternative 4 due to the no thinning on steep slopes. 

Vegetative Structural Stage (VSS) classification was a tool used in the analysis to determine separate age classes 

and uneven-aged forest. The use of VSS in the analysis was appropriate due to the desire to manage and sustain 

uneven aged forest conditions as described in the revised forest plan. The VSS was used in project design to 

manage for replacement structural stages which assures continuous representation of old growth over time. The 

use of VSS does not violate the revised Kaibab Forest plan desired conditions, standards and guidelines.

Comment 7-2 

The Supplemental DEIS exclusively analyzes the Proposed Alternative, without performing consistency checks 

among the other alternatives and the 2012 MSO Recovery Plan or the current and revised Forest Plans. According 

to page i of the Supplemental DEIS, “Alternatives 3 and 4 are modifications of the preferred alternative,” but 

Alternative 2 proposes cable and helicopter logging, and Alternative 4 has neither of these techniques; Alternative 

2 requires site specific Forest Plan Amendments and Alternatives 3 and 4 do not require site specific Forest Plan 

amendments. By only considering Alternative 2 in the Supplemental DEIS, the Forest Service seems to have 

made a decision to continue pursuing an alternative that it knows is not the best possible (or least expensive) way 

to achieve its Purpose and Need, and neglects to adequately consider its other alternatives. Has the Forest Service 

made a decision based on incomplete analyses, before the DEIS process is complete?

Response to Comment 7-2 

The Forest Service did analyze all of the alternatives and these are incorporated into the DEIS and Final 

Environmental Impact Statement (FEIS). The supplemental Draft Environmental Impact Statement (DEIS) 

focused on alternative 2 because the clarifications were related to amendments, snags, cable logging, and treating 

in the Mexican spotted owl (MSO) nest core. Alternative 2 is the preferred alternative because it will help achieve 

the purpose and needs of the project. Alternative 2 has been modified in response to comments, and is now the 

modified proposed action (see chapter two of the FEIS). 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 407

Comment 7-3 

The Forest Plan amendments proposed in the DEIS and Supplemental DEIS are unnecessary, considering that 

Alternative 4 does not require any amendments and better achieves the Purpose and Need.

Response to Comment 7-3 

All alternatives, including Alternative 4, have been analyzed in full (see FEIS).

The Kaibab National Forest has a revised forest plan. The decision for this project will be signed under the 

revised plan. Proposed actions associated with this project are consistent with the revised forest plan and 

amendments are no longer needed.

Comment 7-4 

The Supplemental DEIS still fails to analyze the effects of 38 miles of temporary roads on the project area. That is 

a significant omission. 

Response to Comment 7-4 

The FEIS and the transportation specialist report for the project analyzed the effects of 38 miles of road 

treatments/activities (FEIS Section 3.6). The effects on soils (by terrestrial ecosystem survey (TES) map unit, 

slope classes and associated acreages), including predictions of sediment delivery to stream courses from 

construction of permanent and temporary roads were analyzed and disclosed in the soil and watershed specialist’s 

report, pages 75-77, and Tables 19 and 20. This information was incorporated into the FEIS tables 3-25 and 3-26. 

Table 3-42 provides the approximate mileage of poorly located roads that would be obliterated. 

Effects of roads to TES species were analyzed in the Biological Assessment (BA), and included in the FEIS. In 

response to comments, roads in the modified proposed action were reduced to 15 miles of new roads, 16 miles of 

temporary roads to be obliterated after use, and 23 miles of poorly located roads to be obliterated.

.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

408 Appendices

Appendix C: Issue Processing Report

The following report was developed to document the interdisciplinary team’s consideration of scoping comments, 

and was included as Appendix C in the DEIS. It documents how the Forest Service identified significant and nonsignificant issues and why non-significant issues were eliminated from detailed study. Significant issues were 

carried forward and are addressed in the Environmental Impact Statement (EIS) (Section 1.8).

Issues serve to highlight effects or unintended consequences that may occur from the proposed action and 

alternatives, giving opportunities during the analysis to reduce adverse effects and compare trade-offs for the 

decision-maker and public to understand (FSH 1909.15, 12.4). An issue is not an activity in itself; instead, it is the 

projected effects of the activity that creates the issue.

The Forest Service reviewed all comments received in regards to scoping of the Proposed Action. A Notice of 

Intent was published in the Federal Register on Thursday, April 21, 2011. The NOI asked for public comment on 

the proposal by May 23, 2011. In addition, the Forest invited public comment and participation through listing of 

the project in the Schedule of Proposed Actions (SOPA); posting the scoping packet online 

(http://fs.usda.gov/goto/kaibab/projects); and mailing letters to potentially interested persons, tribal governments, 

and State and other Federal agencies. A scoping meeting was also hosted at the Williams Ranger District on 

Wednesday May 11, 2011 to discuss the proposed action and accept comments. 

Each comment received was considered and evaluated to determine whether the issue was significant or nonsignificant. Significant issues were defined as those directly or indirectly caused by implementing the proposed 

action. Non-significant issues were identified as those: 1) outside the scope of the proposed action; 2) already 

decided by law, regulation, Forest Plan, or other higher level decision; 3) irrelevant to the decision to be made; or 

4) conjectural and not supported by scientific or factual evidence. Some comments/issues were also considered 

non- significant because they would be addressed through routine analyses and/or processes.

Once comments were received (email, letter, phone call record, comment form, etc.), they were assigned a 

comment number. The first number represents the document number (based on the order in which it was 

received) and the second number represents the individual comment/issue within that letter that required 

consideration (ex. issue number 3-4 was the sixth comment/issue the FS responded to within the third letter 

received). Table C-1 displays which comment letter received which number. The full text of these letters is 

available in the project record. Each issue is summarized below and in bold text is the determination that was 

made regarding whether the issue was significant or non-significant and how it was resolved.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 409

Table C-1. Crosswalk between letter number and comment letter source

Letter 

Number

Comment Letter Source

1 Steve Pierce, State Senator

2 The Hopi Tribe

3 James Benham

4 Questions received during public meeting

5 WildEarth Guardians

6 Susan Brown

7 Laura Duncan

8 Robynn Eckel

9 James Jensen

10 Kali Kaliche

11 Kali Kaliche

12 Kali Kaliche

13 David Mills

14 Dick Artley

15 Public Works/Water Department City of Williams

16 U.S. Fish and Wildlife Service

17 Center for Biological Diversity

18 Arizona Game and Fish Department

19 Sierra Club

20 Arizona Department of Transportation

1-1 I support the project and any efforts to improve forest health.

Non-Significant Issue – This comment is supportive of the project.

2-1 Please continue to consult with the Hopi Tribe on this project.

Non-Significant Issue – The Kaibab National Forest routinely consults with the Hopi Tribe and will 

continue to do so with this project. Documentation of our consultation efforts will be presented in Chapter 

4 of the EIS.

3-1 Removing most of the dead trees, both standing and fallen, will greatly reduce the fire danger. 

Non-Significant Issue – The purpose and need for the project recognizes the need to reduce fuel buildup 

and reduce the risk for intense stand-replacing wildland fires. The proposed action was developed to meet 

the purpose and need.

3-2 Prescribed burning will increase debris flow and increase surface erosion. The water treatment plant will not 

be able to remove debris and burned smell in the runoff. 

Significant Issue – The effects from prescribed burning will be analyzed and discussed in the EIS. 

Implementation of Soil and Watershed Best Management Practices (BMPs) will reduce the likelihood of 

erosion problems.

3-3 Prescribed burning will affect unique plants such as the ferns about one mile up the Benham Trail.

Non-Significant Issue – The effects from prescribed burning on rare plants will be analyzed and discussed 

in the EIS. Ferns are not a Threatened and Endangered Species (TES); Forest Service Sensitive Species; 

nor a Management Indicator Species (MIS).

3-4 The project will increase sediment loads which will impact the water quality of my well.

Non-Significant Issue – The effects from prescribed burning will be analyzed and discussed in the EIS. 

Implementation of Soil and Watershed Best Management Practices (BMPs) will reduce the likelihood of 

erosion problems.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

410 Appendices

4-1 There may be changes to the chemistry of the local water supply.

Non-Significant Issue – The effects to water quality will be analyzed and discussed in the EIS.

4-2 This burning portion of this project cannot be completed safely. 

Non-Significant Issue – While safety is very important and there are inherent risks when conducting 

prescribed burning efforts, the Forest believes it can successfully implement the prescribed burning safely. 

Safety considerations will also be addressed in any prescribed burn plan that will be developed for this 

project.

4-3 This project will cost too much money. 

Non-Significant Issue – The EIS will discuss the economic impacts of the proposed action and alternatives 

analyzed in detail. Implementation of the project will be dependent on available funding and market 

conditions which are outside the scope of the project.

4-4 Do mechanical thinning for the first treatment, then burn. 

Non-Significant Issue – The proposed action includes strategic fuel treatments which will be implemented 

prior to any prescribed burning. Implementation of the mechanical treatments will be dependent on 

available funding and market conditions which are outside the scope of the project.

4-5 There should be a campfire ban around the base of the mountain at least until this project is completed.

Non-Significant Issue – The decision to implement a campfire ban in the project area is outside the scope of 

this project. While a campfire ban can reduce the risk for an intense stand-replacing wildland fire, it in no 

other way would meet the purpose and need for action nor would it assist the Forest in meeting or moving 

towards the desired conditions for the area.

4-6 Free use firewood areas should be identified. 

Non-Significant Issue – Firewood collection is already a part of the proposed action (Post- mechanical 

Treatments). The permitting of forest products is outside the scope of the proposed action.

4-7 The project may hurt mixed conifer and wildlife areas.

Non-Significant Issue – The effects to mixed confer stands and wildlife areas will be disclosed in the EIS.

4-8 The project needs to be completed asap.

Non-Significant Issue – Implementation of the project would begin in 2012 and would occur as funding 

and/or favorable conditions allow.

4-9 Any effort to leave pre-settlement and old growth trees? 

Significant Issue - A mitigation measure has been developed to retain pre-settlement and old growth trees 

where possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting 

activities to occur. 

4-10 Where will you get the funding to complete the project? 

Non-Significant Issue – Funding for the project is dependent on Congress and is an issue outside the scope 

of the project.

4-11 Is it going to be easy to sell the timber?

Non-Significant Issue – The selling of the timber is dealt with as a part of implementation of the project 

and an economic analysis will be done as part of the EIS.

4-12 What are you doing about aspen restoration? 

Non-Significant Issue – The treatment of Aspen is addressed in the project proposal. 

4-13 Concerned that fuel loading is getting worse up there.

Non-Significant Issue – The Purpose and Need for Action identifies the need for reduced fuel loadings.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 411

4-14 You should start the project in Zone 1 now instead of waiting for approval of whole project. 

Non-Significant Issue – Implementation of the project would begin in 2012 and would occur as funding 

and/or favorable conditions allow.

4-15 Are there going to be diameter caps on timber removed?

Significant Issue - A mitigation measure has been developed to retain pre-settlement and old growth trees 

where possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting 

activities to occur. 

4-16 Prescribed burning will result in increased ash filling Benham tanks.

Significant Issue – The effects from prescribed burning will be analyzed and discussed in the EIS. 

Implementation of Soil and Watershed Best Management Practices (BMPs) will reduce the likelihood of 

erosion problems.

4-17 Vertical arrangement of Strategic fire lines around blocks may result in erosion problems. 

Significant Issue – The effects of the strategic fuel treatments will be analyzed and discussed in the EIS. 

Implementation of Soil and Watershed Best Management Practices (BMPs) will reduce the likelihood of 

erosion problems.

4-18 Are we removing riparian or wetland vegetation during project?

There are no riparian areas or wetland vegetation in the project area and implementation of the project 

will follow Forest Plan guidance and BMPs.

4-19 Map #5 needs to be corrected to show consistent road lengths that will be open or closed after project. 

Non-Significant Issue – The maps will be updated as the planning process continues.

5-1 The purpose and need can be met without the 3 site-specific FP amendments.

Significant Issue – This issue suggests an alternative with no Forest Plan amendments.

5-2 Prescribed burning can be used to a greater degree with less vegetation manipulation.

Significant Issue – This issue suggests an alternative with limited mechanical treatments or a burn only 

alternative. 

5-3 There should be a 16” diameter cap on the cutting of ponderosa pine.

Non-Significant Issue – The agencies experience and interpretation of the best available science does not 

support the claim that we can adequately meet the purpose and need for action with a 16” diameter cap. 

However, a mitigation measure has been developed to retain pre-settlement and old growth trees where 

possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting activities 

to occur. The effects to pre-settlement and old growth trees will be analyzed and discussed in the EIS.

5-4 Our preferred management approach (see the Citizen’s Alternative) should be used.

Non-Significant Issue – The suggested alternative was considered in whole and in part and did not present 

any issues other than those already considered in this report. An alternative was considered but eliminated 

from detailed study to reflect the suggested alternative.

5-5 There should be no temporary or new road construction to protect the watershed. Hand crews can be used in 

areas with no road access.

Significant Issue – Implementation of Soil and Watershed Best Management Practices (BMPs) would 

reduce the potential for impacts from road construction to the watershed.

5-6 There should be an action alternative that does not include site-specific FP amendments.

Significant Issue – This issue suggests an alternative with no Forest Plan amendments.

5-21 There should be an action alternative that would place a 16” diameter cap on ponderosa pine. 

Non-Significant Issue – The agencies experience and interpretation of the best available science does not 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

412 Appendices

support the claim that we can adequately meet the purpose and need for action with a 16” diameter cap. 

However, a mitigation measure has been developed to retain pre-settlement and old growth trees where 

possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting activities 

to occur. The effects to pre-settlement and old growth trees will be analyzed and discussed in the EIS.

5-7 The EIS must consider a statistically-valid risk of catastrophic fire as well as the required maintenance 

schedule and costs to keep that risk low against the impacts from logging on other resources. 

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-8 You must account for cumulative effects of fuels treatments over time.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-9 You must realize that with climate change, it may be impossible to stop uncharacteristic wildfire and spending 

money on expensive management actions may be futile.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-10 It is a false assumption to think the no-action alternative will result in crown fires.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-11 Cutting large trees to reduce fuels is contrary to fuels reduction or forest restoration objectives. 

Non-Significant Issue – The agencies experience and interpretation of the best available science does not 

support the claim that we can adequately meet the purpose and need for action without cutting large trees. 

A mitigation measure has been developed to retain pre-settlement and old growth trees where possible. 

Some pre-settlement and old growth trees may be incidentally taken to allow harvesting activities to occur. 

The effects to pre-settlement and old growth trees will be analyzed and discussed in the EIS.

5-12 There is lack of empirical evidence supporting mechanical fuels reduction treatments will reduce the severity 

of wildfire and the FS is required by NEPA to disclose and discuss this “responsible opposing view.” 

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-13 All large trees should be retained because a 16” diameter cap will achieve crown fire hazard prevention.

Non-Significant Issue – The agencies experience and interpretation of the best available science does not 

support the claim that we can adequately meet the purpose and need for action with a 16” diameter cap. 

However, a mitigation measure has been developed to retain pre-settlement and old growth trees where 

possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting activities 

to occur. The effects to pre-settlement and old growth trees will be analyzed and discussed in the EIS.

5-14 Failure to discuss the findings of Odion et al. 2004 and Perry et al. 2004 regarding crown fire is a violation 

of NEPA.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-15 The FS must consider the cost-effectiveness of the treatments, in particular, mechanical treatment versus 

prescribed fire.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-16 The FS must consider in detail the impacts on forestlands from grazing activities.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-17 The FS must fully disclose the cumulative effects of livestock grazing, timber harvest, fuel break 

construction, thinning, prescribed fire, and road developments on water quality, forest health, wildlife habitat, 

noxious weeds, cultural resources, and other resources.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-18 The FS must provide documentation that it is in compliance with NEPA regulations including the 

requirement that the Service analyze the cumulative effects on this and other projects on various terrestrial and 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 413

aquatic wildlife species and various plant species.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-19 NFMA requires the FS to analyze impacts to Forest Plan Management Indicator Species as found in the 

LMP.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

5-20 The FS cannot sign the ROD until after the USFWS has completed the new consultation on the Forest Plans 

and their effect on the MSO.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS. 

Consultation with the USFWS will be conducted in accordance with the Endangered Species Act.

5-21 WildEarth Guardians requests the FS consider their Citizen’s Alternative described in their comment letter 

pages 9-16. 

Non-Significant Issue – The suggested alternative was considered in whole and in part and did not present 

any issues other than those already considered in this report. An alternative was considered but eliminated 

from detailed study to reflect the suggested alternative.

6-1 Keep in mind that the use of prescribed fire may result in an increase in ash into the water treatment plant for 

the City of Williams. How will this increase affect the water supply?

Significant Issue – The effects from prescribed burning will be analyzed and discussed in the EIS. 

Implementation of Soil and Watershed Best Management Practices (BMPs) will reduce the likelihood of 

erosion problems.

7-1 Propose a campfire ban in project area with the boundary being FR 108 at least until the project is 

implemented and completed.

Non-Significant Issue – The decision to implement a campfire ban in the project area is outside the scope of 

this project. While a campfire ban can reduce the risk for an intense stand-replacing wildland fire, it in no 

other way would meet the purpose and need for action nor would it assist the Forest in meeting or moving 

towards the desired conditions for the area.

8-1 Leave some of the mountain as wild as you can for recreation.

Non-Significant Issue – The management of the project area is defined in and guided by the Forest Plan. 

The effects to recreation resources will be analyzed and discussed in the EIS.

8-2 Open the area up to free use permits for the removal of forest products prior to implementation. 

Non-Significant Issue – Firewood collection is already a part of the proposed action (Post- mechanical 

Treatments). The permitting of forest products is outside the scope of the proposed action.

9-1 Thin to pre-settlement conditions starting with Zones 1 and 2 and along South Perkinsville and FR 40 first.

Non-Significant Issue – Implementation of the project would begin in 2012 and would occur as funding 

and/or favorable conditions allow.

9-2 Use mechanical thinning first before fire treatments for better control.

Non-Significant Issue – The proposed action includes strategic fuel treatments which will be implemented 

prior to any prescribed burning. Implementation of the mechanical treatments will be dependent on 

available funding and market conditions which are outside the scope of the project.

9-3 Open the project area up to firewood cutters. 

Non-Significant Issue – Firewood collection is already a part of the proposed action (Post- mechanical 

Treatments). The permitting of forest products is outside the scope of the proposed action.

10-1 Be careful with treatments on the slopes and ravines to prevent runoff and erosion. 

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

414 Appendices

Implementation of Soil and Watershed Best Management Practices (BMPs) will reduce the likelihood of 

erosion problems.

10-2 Habitat areas for MSO, goshawks and peregrine falcons will need to be treated very carefully.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

10-3 Keep a night patrol on prescribed burns for safety reasons.

Non-Significant Issue – While safety is very important and there are inherent risks when conducting 

prescribed burning efforts, the Forest believes it can successfully implement the prescribed burning safely. 

Safety considerations will also be addressed in any prescribed burn plan that will be developed for this 

project.

10-4 Provide firewood opportunities for local use and sales. 

Non-Significant Issue – Firewood collection is already a part of the proposed action (Post- mechanical 

Treatments). The permitting of forest products is outside the scope of the proposed action.

11-1 Wildlife areas will need to get the necessary attention particularly habitat for bobcats, goshawks, peregrine 

falcons and MSO.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

12-1 The decades long downsizing of the FS is the underlying problem in making the mountain able to survive 

fire. This political agenda is harmful to our public lands. 

Non-Significant Issue – Politics and the agencies administration of human resources is outside the scope of 

the project.

13-1 Protect goshawk and MSO habitat.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

13-2 Maintain recreational opportunities.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

13-3 Protect T&E plants.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS 

and is to some degree already required/resolved by existing laws and regulations. 

13-4 I am concerned about an increase in invasive weeds.

Non-Significant Issue – This issue will be resolved by implementation of Forest Plan Standards and 

Guidelines as well as Best Management Practices.

13-5 I am concerned about smoke impacts to residents.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS. 

Implementation of prescribed burning efforts will be approved by the Arizona Department of 

Environmental Quality (ADEQ) and will include public notices of the prescribed burning efforts.

13-6 Protect cultural resources.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS. 

Mitigation measures have been developed to protect cultural resources.

13-7 The project should restore and maintain healthy aspen groves. 

Non-Significant Issue – The treatment of Aspen is addressed in the project proposal.

13-8 The project should provide opportunities for fuelwood utilization, both commercial and personal use. 

Non-Significant Issue – Firewood collection is already a part of the proposed action (Post- mechanical 

Treatments). The permitting of forest products is outside the scope of the proposed action.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 415

13-9 Minimize expansion of unmaintained roads. 

Non-Significant Issue – A part of the purpose and need for action includes improving the motorized 

transportation system to provide for a more sustainable road system where poorly located roads are 

relocated or obliterated.

13-10 The project should protect and promote the growth of Native American medicinal and ceremonial plants. 

Significant Issue – A mitigation measures will be developed to protect and promote the growth of Native 

American medicinal and ceremonial plants in consultation with the Tribes.

13-11 Treatments in the lower elevation ponderosa pine should aggressively thin and burn stands with the 

objective of returning to reference conditions. 

Non-Significant Issue – This issue is already a part of the purpose and need for action.

13-12 Maximum utilization of wood products is desirable.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

13-13 The greatest challenge is to maintain mixed conifer stands while reducing the potential for stand replacing 

fire.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

13-14 Care will be required to balance hazard fuel reduction with other values and aesthetics.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

14-1 Temporary roads constructed on slopes have the potential to create more sediment per mile during 

precipitation events than system roads. Please do not construct any temporary roads for this project. 

Significant Issue – Implementation of Soil and Watershed Best Management Practices (BMPs) would 

reduce the potential for impacts from road construction to the watershed.

14-2 Proposed roads will affect wildlife. Reduce all impacts from road construction. 

Significant Issue – The issue suggests an alternative with no new road construction. Implementation of Soil 

and Watershed Best Management Practices (BMPs) would reduce the potential for impacts from road 

construction to the watershed.

14-3 Science indicates that timber harvest activities cause resource damage.

Non-Significant Issue – As part of the Environmental Impact Statement we will discuss the impacts of the 

harvest activities proposed and the responsible official will consider those impacts when making their 

decision.

14-4 If noxious weed treatment is planned, do not use herbicides containing glyphosate. 

Non-Significant Issue – This issue will be resolved implementation of the “Design Features, Best 

Management Practices, and Mitigation Measures” identified in the “Final Environmental Impact 

Statement for Integrated Treatment of Noxious or Invasive Weeds on the Coconino, Kaibab, and Prescott 

National Forests within Coconino, Gila, Mojave, and Yavapai Counties, Arizona” (2004). 

15-1 If the mountain is control burned, the run-off is known to affect the water quality in the surrounding lakes 

and the City’s ability to properly treat this water. Please conduct a study on the effects of control burning on water 

quality. 

Significant Issue – The effects from prescribed burning will be analyzed and discussed in the EIS. 

Implementation of Soil and Watershed Best Management Practices (BMPs) will reduce the likelihood of 

erosion problems.

16-1 A strategic treatment design must be incorporated into the project to retain and maintain structural integrity 

of forest habitat, such as key placements of fewer target treatments along with a prescribed burning plan to 

achieve restoration goals.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

416 Appendices

Non-Significant Issue – Prescribed burning and treatment areas are designed and strategically located to 

retain and maintain structural integrity of forested habitats. 

16-2 Consider previous treatments in the project area and vicinity to determine thinning treatment areas.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives and 

cumulative effects in the EIS.

16-3 We recommend including recommendations developed from the recent Forest Health Focus effort.

Non-Significant Issue – The Bill Williams Mtn area was identified in the Forest Health Focus effort as 

priority area for treatment. 

16-4 The DEIS should disclose if an MSO PAC exists in the project area and the effects of the project to the PAC. 

We recommend that the project enhances and protects MSO habitat within a PAC as recommended in the MSO 

Recovery Plan.

Significant Issue – The EIS will disclose the effects and affected environment for Mexican Spotted Owls, 

however this comment suggests an alternative that would not amend the Forest Plan.

16-5 A portion of the project area cover type is pine-oak. We recommend working with the FWS to identify MSO 

pine-oak habitat to ensure treatments will benefit the MSO and restore the area.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

16-6 The MSO Recovery Plan identifies mixed conifer cover type and also refers to Douglas-fir and white fir 

cover types. To assist the FS in identifying MSO habitat and potential treatments, we recommend describing the 

project area in terms of mixed conifer cover type as defined in the MSO Recovery Plan.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

16-7 We recommend including MSO protected and restricted habitat as a discussion to avoid confusion in the 

desired condition section.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

16-8 Desired Condition section also confounds MSO guidelines and northern goshawk guidelines. Northern 

goshawk guidelines are also presented as desired conditions for mixed conifer (particularly within MSO protected 

and target/threshold habitat) with no reference to guidelines described in the MSO Recovery Plan. We encourage 

the USFS to refer to the MSO Recovery Plan management recommendations (Volume I/Part III; pp.82-96), and 

primary constituent elements found in the final rule designating MSO critical habitat (August 31, 2004; 69 FR 

53232).

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

16-9 We recommend the USFS follow the management guideline recommendations for each category of MSO 

habitat (PAC, protected steep slope, target/threshold, and restricted) and critical habitat as described in the MSO 

Recovery Plan and the final rule designating critical habitat.

Significant Issue – The EIS will disclose the effects and affected environment for Mexican Spotted Owls, 

however this comment suggests an alternative that would not amend the Forest Plan. Following the 

guidelines for conservation of critical habitat requires 40% shade.

16-10 In the scoping document, the section on desired conditions for ponderosa pine and mixed conifer cover 

types suggests the desired conditions are driven by management guidelines for the northern goshawk. However, in 

areas where the guidelines conflict with MSO Recovery Plan recommendations in MSO habitat (pine-oak and 

mixed conifer), we encourage the MSO Recovery Plan recommendations take precedence.

Non-Significant Issue – This issue is already decided by the Forest Plan; MSO guidelines supersede 

goshawk guidelines in areas of overlap. 

16-11 A desired condition for both ponderosa pine and mixed conifer cover types states large trees of all species 

will be developed throughout the cover type. The pine-oak and mixed conifer cover types likely contain many 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 417

large trees, a key habitat component of MSO habitat and a primary constituent element of MSO critical habitat. 

We recommend the proposed action be designed to maintain this key habitat component and primary constituent 

element.

Significant Issue - A mitigation measure has been developed to retain pre-settlement and old growth trees 

where possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting 

activities to occur. 

16-12 A desired condition for both ponderosa pine and mixed conifer cover types states fuel loading will average 

5 to 7 tons per acre in northern goshawk habitat in those cover types. We recommend the Restoration Project be 

designed to retain a sufficient amount of large logs and other dead and down material compatible with MSO needs 

and primary constituent elements of MSO critical habitat, while meeting forest restoration objectives. We also 

recommend the USFS refer to Brown et al. (2003) and Graham et al. (2004) regarding the amount of coarse 

woody debris needed to maintain soil health in ponderosa and mixed conifer forests in northern Arizona. 

Significant Issue - A mitigation measure has been developed to retain large down logs and woody debris 

where possible. Where possible we will avoid direct ignition of large down logs and woody debris in the 

project area to meet desired conditions.

16-13 The scoping document states sites with dwarf mistletoe left unmanaged in the area cannot be maintained in 

a sustainable, uneven-aged condition. We understand there is a need to manage dwarf mistletoe as part of forest 

restoration objectives, and we recommend including an objective to support uneven-aged management in dwarf 

mistletoe-infected stands.

Non-Significant Issue – The proposed action will do uneven-aged management in infected sites. Sometimes 

in highly infected sites it may be necessary to do even-aged treatments.

16-14 The Arizona bugbane is a sensitive species for which a conservation strategy and agreement was developed. 

Additional measures may be needed to protect this species during implementation of the Restoration Project. We 

encourage the USFS to implement the terms of the conservation strategy and agreement as part of the proposed 

action. 

Non-Significant Issue – This issue is already decided by the Forest Plan.

16-15 The State of Arizona and various American Indian Tribes maintain lists of sensitive species that may not be 

protected by Federal law. We recommend you contact the Arizona Game and Fish Department (AGFD) and any 

affected tribe to determine if sensitive species may occur in the action area. We encourage the USFS to invite the 

AGFD and any affected tribe to participate in the review of your proposed action. 

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS. 

The proposed action was scoped to the AGFD and Tribal consultation on the proposed action is ongoing.

16-16 Maintain mixed conifer habitat and avoid removing important components (white fir, Douglas-fir, and other 

mixed conifer tree species).

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS. 

Mixed conifer stands will be maintained under the proposed action.

16-17 Maintain pre-settlement/old-growth trees.

Significant Issue - A mitigation measure has been developed to retain pre-settlement and old growth trees 

where possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting 

activities to occur. 

16-18 Maintain pine-oak habitat within MSO PACs.

Significant Issue – The EIS will disclose the effects and affected environment for Mexican Spotted Owls, 

however this comment suggests an alternative that would not amend the Forest Plan.

16-19 Maintain mixed conifer stands containing aspen as mixed conifer habitat described in the MSO Recovery 

Plan.
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418 Appendices

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS. 

Mixed conifer stands will be maintained under the proposed action.

17-1 The Center requests that the Forest Service study, develop, and describe an alternative that would meet the 

purpose and need for action while conserving trees larger than 16-inches diameter at breast height (“dbh”) outside 

of a well-defined wildland-urban interface (“WUI”) zone comprising one-quarter (1⁄4) mile distance from 

established residential and other community infrastructure. 

Non-Significant Issue – The agencies experience and interpretation of the best available science does not 

support the claim that we can adequately meet the purpose and need for action with a 16” diameter cap. A 

mitigation measure has been developed to retain pre-settlement and old growth trees where possible. Some 

pre-settlement and old growth trees may be incidentally taken to allow harvesting activities to occur. The 

effects to pre-settlement and old growth trees will be analyzed and discussed in the EIS.

17-2 Large tree removal should be a significant issue in the forthcoming environmental impact statement to 

account for potentially significant impacts to forest vegetation, old growth recruitment, and wildlife habitat. See 

40 C.F.R. § 1508.27. 

Significant Issue - A mitigation measure has been developed to retain pre-settlement and old growth trees 

where possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting 

activities to occur. 

17-3 Fuel treatments should be designed with spatial patterns of fire spread in mind. The agency’s science and 

experience show that fuel management can be unnecessary and counterproductive if it is not spatially arranged to 

take advantage of site-specific topography and weather patterns (Finney 2001). Moreover, Peterson and Johnson 

(2007) posed questions regarding the efficacy of different fuel treatment options at various spatial scales that 

should be addressed in the project analysis.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

17-4 To the degree that the project also may increase the effectiveness of fire suppression, the analysis must 

consider effects on the environment resulting from connected and cumulative fire suppression activities (Backer et 

al. 2004).

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

17-5 Many forest animals are threatened by large scale fires and habitat degradation associated with silvicultural 

management in dwarf mistletoe stands.

Significant Issue - A mitigation measure has been developed to retain some dwarf mistletoe as a natural 

component in stands.

17-6 The Forest Service must ensure that the project will not adversely affect goshawk or contribute to a trend 

toward listing under the Endangered Species Act.

Non-Significant Issue – This issue will be resolved by implementation of Forest Plan Standards and 

Guidelines and will also be resolved through analysis of the alternatives in the EIS.

17-7 The Kaibab National Forest developed a white paper entitled Implementation and Interpretation of 

Management Recommendations for the Northern Goshawk, Version 3.0 (“I&I” – USDA 2009) that calls for 

assessment of forest treatment effects to goshawk habitat at small clump- and group-scales, and not at the larger 

scale of a forest stand. This interpretation of guidelines for goshawk habitat in the amended forest plan shifts 

requirements for maintenance of canopy cover and vegetative structural stages from the stand scale to smaller 

scales. Its use in the current project requires an amendment to the forest plan.

Non-Significant Issue – The group can be addressed at multiple scales (e.g. site, landscapes, etc.).

17-8 The Center encourages the Forest Service to avoid creating forest openings larger than two (2) acres in the 

project. At a 2005 meeting with Forest Service biologists, Dr. Reynolds stated: “Do not create openings 4 acres in 

size unless there is an overriding management need, keep openings small.” [4] Please refer to comments above for 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 419

reasons why mistletoe treatments may not justify openings larger than forest plan guidelines allow. 

Non-Significant Issue – The Proposed action would keep openings to less than 4 acres.

17-9 Smoke accumulation from prescribed burning may flush owls from nests, causing incidental take. Therefore, 

the Forest Service is required to complete formal consultation with the U.S. Fish and Wildlife Service (“FWS”) 

culminating in a biological opinion and incidental take statement to secure exemption of the proposed action from 

the Endangered Species Act’s (“ESA”) prohibition of take of listed species.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS. 

Consultation with the USFWS will be conducted in accordance with the Endangered Species Act.

17-10 Despite its admission of ongoing monitoring deficiencies, potential exceedance of incidental take, and noncompliance with the mandatory terms and conditions of the 2005 biological opinion, the Forest Service continues 

to approve site-specific projects that may affect Mexican spotted owl. The Forest Service is violating the 

mandatory terms and conditions set forth in the 2005 biological opinion concerning the implementation of the 

Forest Plans in the Southwest Region, including mandatory monitoring requirements for the Mexican spotted owl, 

in violation of the ESA. 16 U.S.C. §1536(b)(4)(C)(iv); 50 C.F.R. §§ 402.14(i)(1)(iv), and 402.14(i)(3). Due to 

these monitoring failures, the Forest Service is also failing to insure that it has not exceeded the incidental take 

allowances for these species. Therefore, the agency should withhold approval of actions that may affect Mexican 

spotted owl pending reconsultation to insure that the proposed action will not irretrievably commit owls or their 

habitat. 

Non-Significant Issue – This issue is outside the scope of the project. Consultation with the USFWS will be 

conducted in accordance with the Endangered Species Act.

17-11 The FS must disclose cumulative effects within the project area including timber sales, crown fires, past 

changes in forest structure, invasive plant populations, overall fire management goals for the project area, and the 

location of the project area in relation to important wildlife habitat. 

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives and 

cumulative effects in the EIS.

17-12 If active grazing allotments overlap the planning area then we would be very concerned about potentially 

significant cumulative effects to soil, plant communities, fire regimes and wildlife forage that may result from 

active range management in combination with proposed treatments. 

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives and 

cumulative effects in the EIS.

17-13 Treatments similar to the proposed action have left forest restoration sites overrun with cheatgrass (Bromus 

tectorum) (McGlone et al. 2009).

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS 

and will be resolved by implementation of the “Design Features, Best Management Practices, and 

Mitigation Measures” identified in the “Final Environmental Impact Statement for Integrated Treatment 

of Noxious or Invasive Weeds on the Coconino, Kaibab, and Prescott National Forests within Coconino, 

Gila, Mojave, and Yavapai Counties, Arizona” (2004). 

18-1 If fuels reduction is the main objective, a more strategic design and placement of evidence-based restoration 

treatments could more effectively protect values at risk, thereby reducing the need to treat the entire project area.

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS.

18-2 The Department does not think cable logging can be accomplished in an ecologically sound manner. We do 

not support the harvest of old growth trees if that is necessary for cable logging. 

Significant Issue – This issue suggests an alternative with no cable logging systems.

18-3 The Department does not like the linear fuels control line arrangement as proposed.

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

420 Appendices

18-4 The Department requests the FS to include a thorough description for old growth throughout the planning 

document. We recommend expanding the definition to include the essential structural features of old growth. 

Non-Significant Issue – An analysis of old growth will be in the EIS.

18-5 Be careful and strategic in the treatments of the relatively rare habitat types of Gambel oak and aspen. 

Non-Significant Issue – The treatment of Gambel oak and aspen are addressed in the project proposal.

18-6 Ladder fuels should not be eliminated across large areas of the landscape as they are an important component 

of structural heterogeneity which is important to wildlife.

Non-Significant Issue – The proposed action does not include the elimination of all ladder fuels.

18-7 We encourage the FS to manage toward habitat diversity that includes greater variability in forest/meadow 

patch size, vertical heterogeneity, tree density, basal area and successional stage with an emphasis on old growth 

retention. 

Non-Significant Issue – The proposed action does manage for diversity including through tree groups with 

dispersed openings and uneven-aged management. 

18-8 We ask the FS to consider a wider range of BA within the desired conditions as 10-50 BA will not support 

many closed canopy animal species.

Significant Issue – This issue suggests an alternative with no Forest Plan amendments.

18-9 We ask that the FS place more emphasis on ensuring a mosaic of all successional stages, now and in the 

future, throughout a landscape comprised of all known habitat types. Please refer to our draft “Desired Ponderosa 

Pine Forest Conditions for Wildlife in the Southwest”.

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS.

18-10 There is little information on the historic reference condition of mixed conifer. The Department 

recommends a smaller scale experimental approach to treatment in mixed conifer. 

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS.

18-11 The Department is concerned about the similarity between wet and dry mixed conifer frequent fire DFC’s. 

We don’t want the FS to convert dry mixed conifer into PIPO when it’s actually an important and distinct 

Potential Natural Vegetation Type.

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS. The 

proposed action does not include the conversion of cover types.

18-12 The dry mixed conifer type needs to be defined and mapped. 

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS.

18-13 If the FS is going to continue with the dry mixed conifer concept, the Department recommends addressing 

the importance of retaining transitional, ecotonal habitats between ponderosa pine and mixed conifer for wildlife. 

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS.

19-1 While the Sierra Club supports making wood derived from thinning treatments available to residents for 

personal use, we do not support large scale commercial extraction of timber from our National Forests. Please 

consider altering the Specific Need statement from “To provide forest products, such as firewood, for people 

living in Williams and the surrounding area, in order to meet their needs for forest and wood products, while 

protecting these resources for future generations” to “...in order to meet their personal use needs...” Also add to 

the “need for” list, Preventing erosion and soil loss that could further impair watersheds, Protecting rare, 

threatened and endangered species, and Protecting and enhancing wildlife habitat.

Non-Significant Issue – The purpose and need for action is appropriately scaled for the project based on 

management direction contained within the Forest Plan (which allows commercial timber harvest). The 

suggested needs are things that are also guided by management direction in the Forest Plan and Forest 

Service Handbooks and Manuals.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 421

19-2 We encourage the Forest Service to focus this project on restoration of natural processes, such as fire, and 

restoring forest resiliency to help address the impacts of climate change and the historic impacts of fire 

suppression, logging, and livestock grazing. 

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS.

19-3 The Sierra Club supports the use of fire to restore ecosystems, and finds this alternative preferable to 

mechanical treatments on steep slopes where mechanical treatment could lead to erosional problems and 

dangerous conditions. Helicopter treatments on 3,468 acres is not defensible and is an unnecessary expense for 

the KNF, a safety hazard, and a significant disturbance to wildlife and nearby residents. 

Significant Issue – This issue suggests a burn only alternative and an alternative that does not utilize 

helicopter logging.

19-4 The Arizona Bugbane botanical area boundary should be respected. Treatments should protect the boundary, 

but mechanical treatment should not occur within the area because machines move across the ground too quickly 

for operators to observe details of vegetation composition. Skid trails in this area could also invite non-native 

invasive species.

Significant Issue – Mitigation measures have been developed to prevent and control the spread of nonnative invasive species within the project area. This issue suggests an alternative that does not include 

mechanical treatments (except for hand-felling techniques) in the AZ bugbane botanical area.

19-5 The Strategic Fuels treatments should be considered in the context of restoring natural fire to the forest. 

Rather than creating artificial linear swaths, the Forest Service should focus on utilizing the natural features of the 

land, including the vegetative features for fuel breaks. This means using the using the existing heterogeneity and 

creating additional vertical breaks where necessary. This should be minimized in order to reintroduce natural fires. 

(Allen et al. 2002, Weatherspoon and Skinner 1996). The wide, relatively straight clearings running perpendicular 

to slopes proposed can cause soil loss and habitat fragmentation and if the goal is to continue fire exclusion, then 

the treatments will be counterproductive.

Significant Issue – Implementation of Soil and Watershed Best Management Practices (BMPs) would 

reduce the likelihood of erosion problems from construction of strategic fuels treatments.

19-6 The Forest Service should consider implementing fuel reduction first in areas where limited resource 

investment may be able to create more fire resilient stand conditions. This may include sites with little 

encroachment of small trees and open stands dominated by large conifers or hardwoods. Targeting initial work in 

these areas will maximize the area to be treated with available funds and personnel, and thereby provide the 

greatest opportunity to quickly reduce fuels and restore ecosystem function at larger spatial scales.

Non-Significant Issue – The proposed action includes strategic fuel treatments which will be implemented 

prior to any prescribed burning. Implementation of the project would begin in 2012 and would occur as 

funding and/or favorable conditions allow.

19-7 Larger, fire resistant trees should be left uncut.

Significant Issue - A mitigation measure has been developed to retain pre-settlement and old growth trees 

where possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting 

activities to occur. 

19-8 We agree with comments submitted by the Center for Biological Diversity and ask that the Forest Service 

develop and evaluate an alternative that would meet the purpose and need for action while conserving any 

presettlement and large trees outside of a well-defined wildland-urban interface - approximately 1⁄4 mile from 

established community infrastructure. 

Significant Issue - A mitigation measure has been developed to retain pre-settlement and old growth trees 

where possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting 

activities to occur. 

19-9 If there is riparian vegetation, wetland emergent vegetation, wetland or aquatic habitats in the treatment area, 

thinning activities should leave a buffer zone around these places that is sufficient to anchor soils and capture ash 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

422 Appendices

that may flow downhill after prescribed or naturally-occurring fires. This will protect water quality. Mechanical 

equipment should not be allowed to pass through these fragile, important habitats. 

Non-Significant Issue – There are no riparian areas or wetland vegetation in the project area and 

implementation of the project will follow Forest Plan guidance and BMPs.

19-10 White fir germinates well in bare mineral soils, so burning will contribute to a new generation of white fir 

saplings. Frequent fire will be required to regularly re-treat and suppress white fir.

Non-Significant Issue – Maintenance burning is included in the proposed action.

19-11 Seeding the understory after treatments may help to inhibit non-native invasive species, and to shade white 

pine seeds, to prevent germination. 

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS 

and will be resolved by implementation of the “Design Features, Best Management Practices, and 

Mitigation Measures” identified in the “Final Environmental Impact Statement for Integrated Treatment 

of Noxious or Invasive Weeds on the Coconino, Kaibab, and Prescott National Forests within Coconino, 

Gila, Mojave, and Yavapai Counties, Arizona” (2004). 

19-12 Keeping livestock grazing out of areas where white pine is undesirable might also be helpful, since a dense, 

healthy understory will suppress woody species germination. 

Non-Significant Issue – The management of livestock grazing is outside the scope of this project.

19-13 Mechanical treatment near the base of the mountain only, and treatment exclusively with fire higher up on 

the mountain, is desirable.

Significant Issue – This issue suggests an alternative with limited mechanical treatments or a burn only 

alternative. 

19-14 Presettlement and any and all old growth trees should not be cut. Large trees should not be cut to make 

room for regeneration. Conservation of large trees in fuel treatments is critical to restoration of fire- adapted forest 

ecosystems (Brown et al. 2004, DellaSala et al. 2004).

Significant Issue - A mitigation measure has been developed to retain pre-settlement and old growth trees 

where possible. Some pre-settlement and old growth trees may be incidentally taken to allow harvesting 

activities to occur. 

19-15 Some shrubs should be left in the understory to provide forage, cover, and nesting sites for wildlife.

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS.

19-16 Some pockets of very high density forest should be left intact. 

Non-Significant Issue – This issue will be resolved through routine analysis of alternatives in the EIS.

19-17 Understory seeding with a native seed mix should follow treatment, to suppress non-native invasive 

species, many of which increase fire risk on the landscape.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS 

and will be resolved by implementation of the “Design Features, Best Management Practices, and 

Mitigation Measures” identified in the “Final Environmental Impact Statement for Integrated Treatment 

of Noxious or Invasive Weeds on the Coconino, Kaibab, and Prescott National Forests within Coconino, 

Gila, Mojave, and Yavapai Counties, Arizona” (2004). 

19-18 Impacts of livestock grazing should be considered as well. Livestock grazing contributes to the long term 

and degradation of grasslands contributes to the encroachment of noxious and invasive weeds as well as woody 

vegetation.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives and 

cumulative effects in the EIS.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 423

19-19 Spread of noxious weeds is a reasonably foreseeable and potentially significant forest-wide cumulative 

impact of the proposed action.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives and 

cumulative effects in the EIS and will be resolved by implementation of the “Design Features, Best 

Management Practices, and Mitigation Measures” identified in the “Final Environmental Impact 

Statement for Integrated Treatment of Noxious or Invasive Weeds on the Coconino, Kaibab, and Prescott 

National Forests within Coconino, Gila, Mojave, and Yavapai Counties, Arizona” (2004). 

19-20 Insects, diseases, and mistletoe are naturally part of the system (p.17). Once needles fall from dead trees, 

active crown fire risk in those stands may be reduced (Fleming et al. 2002, Romme et al. 2006, Jenkins et al. 

2007). It is unclear what treatments are being proposed to deal with insects, disease, and mistletoe. Since snags 

and witches’ brooms provide important habitat values, and mistletoe provides a drought-resistant food source for 

wildlife, the best treatment of these areas may be to burn them but not mechanical treatment.

Significant Issue - A mitigation measure has been developed to retain some dwarf mistletoe as a natural 

component in stands. This issue also suggests a burn only alternative. 

19-21 Because of concerns about failure to monitor and inadequate monitoring and the potential for this project to 

result in an exceedance of incidental take relative to this species, we ask that the Forest Service refrain from 

actions that would affect the owls until the Forest Service has consulted with the U.S. Fish and Wildlife Service to 

ensure that this project would not result in significant harm to the owls and their habitat and exceedance of 

incidental take.

Non-Significant Issue – This issue is outside the scope of the project. Consultation with the USFWS will be 

conducted in accordance with the Endangered Species Act.

19-22 The Sierra Club cannot support a one-time deviation from Forest Plan guidelines for Mexican spotted owls 

at this time. Please be explicit about the activities the KNF is seeking to undertake in these areas, how they 

deviate from current guidelines, why they are necessary, and how much habitat would be affected by the 

amendment.

Significant Issue – This issue suggests an alternative that does not amend the Forest Plan to deviate from 

Mexican Spotted Owl guidelines.

19-23 The Scoping Document is not specific about what deviations from these guidelines are needed, but the 

Sierra Club asks that the Forest Service consider the study by Beier and others (2008) that detected a negative 

correlation of goshawk breeding productivity with territories that were treated by logging consistent with the 

MNRG (Reynolds et al. 1992) and the amended forest plans and that populations of the northern goshawk are in 

decline across the forest. Please be explicit about the activities the KNF is seeking to undertake in these areas, 

how they deviate from current guidelines, why they are necessary, and how much habitat would be affected by the 

amendment.

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives in the EIS.

20-1 ADOT is concerned with the potential impacts with the existing forest road (947?) that parallels the 

Interstate 40 ROW with respect to potential higher year round use and any improvements, such as widening, 

increased drainage discharge to ADOT existing drainage structures, right-of-way fencing and smoke impacts to I40. 

Non-Significant Issue – This issue will be resolved through routine analysis of the alternatives and 

cumulative effects in the EIS.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

424 Appendices

Appendix D: Past, Present, and Reasonably Foreseeable 

Future Actions

The following is a list of past, present, and reasonably foreseeable future actions in and around the South Zone 

(SZ) of the Kaibab National Forest considered in the cumulative effects analysis for this project: 

• Activities such as vegetation management, fuels management, livestock grazing, recreational activities, 

and other management activities (e.g. noxious weeds treatments) have occurred in the past, are occurring, 

and are reasonably foreseeable actions on the SZ. These activities could occur on adjacent lands under 

private and other jurisdictions as well.

• Firewood cutting has occurred in the past and will likely continue in the foreseeable future on the SZ and 

private lands. 

• Private landowners may harvest timber on their lands for lumber or to reduce fire hazards.

• Urban development and interface growth will continue on private lands. 

• Management of Camp Navajo, Grand Canyon National Park, and currently designated wildernesses (e.g. 

Sycamore Canyon Wilderness, Kendrick Mountain Wilderness) will continue.

• Road construction, road maintenance, and right-of-way brushing are expected to continue on nonNational Forest System land. 

• Road construction, reconstruction, and decommissioning are expected to continue to move towards Forest 

Plan desired conditions.

• Road realignment, reconstruction, or decommissioning may occur with future vegetation management 

projects.

• Recreation activities are expected to continue to increase on the Forest. Future recreation projects may be 

developed. 

• Mining and quarrying activities have occurred historically and are expected to continue to occur on the 

SZ.

• Adjacent National Forest System lands have been and will continue to be managed to meet the multipleuse goals and objectives established in their Forest Plans.

The following is a list of projects considered in the cumulative effects analysis for this project:

Table D-1. Past projects and activities

Project District Year NEPA 

completed Activities Status

Bill Williams Cap Williams 2009 Fuel reduction/ hazard tree 

removal on six acres Completed 

Pineaire Williams 2004 Timber sale (TS); non-commercial 

thinning; broadcast burning (BB) Completed 

Clover High Fuels 

Reduction Project Williams 2002 Non-commercial thinning Completed 

Williams High Risk 

Project Williams 2001 Non-commercial thinning Completed 

Scott Tusayan 1998 

Timber stand improvement (TSI); 

vegetation management; 

prescribed (Rx) burning; road 

obliteration; road closures; some 

new road construction

Completed 

Beacon Williams 1997 vegetation management; TS; TSI; 

BB Completed 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 425

Table D-2. Present projects and activities

Project District Year NEPA 

completed Activities Status

Four Forest 

Restoration 

Initiative (4FRI)

Multiple 

forests Multiple Restoration of ponderosa pine ecosystem (thinning, burning ROD signed in 2015 

Watts Vegetation 

Management 

Project

Tusayan 2014 Thinning; Rx burning; fuelwood 

gathering; road closure 

DM signed in 2014; 

implementation to begin 

soon

McCracken Williams 2012 Commercial/non-commercial 

thinning; Rx burning

Currently being 

implemented

Russell Vegetation 

Management 

Project

Tusayan 2011 

Non-commercial thinning; slash 

piling/burning; BB; cross-country 

fuelwood collection

Currently being 

implemented

Tusayan Ranger 

District Travel 

Management 

Implementation

Tusayan 2011 

Prohibit cross-country travel (except 

as allowed under 36 CFR 212.51); 

designate open road system

Implemented in 2011; 

ongoing 

Williams Ranger 

District Travel 

Management 

Implementation

Williams 2010 

Prohibit cross-country travel (except 

as allowed under 36 CFR 212.51); 

designate open road system

Implemented in 2011; 

ongoing 

Airport Hazardous 

Fuels Reduction 

Project

Tusayan 2009 

Hazardous fuels reduction; 

noncommercial mechanical thinning; 

Rx burning

Currently being 

implemented

Community Tank Williams 2009 Grassland restoration; Rx burning; 

road obliteration Final sale in progress

City Williams 2005 

vegetation management; TS, TSI, 

and BB; includes some temporary 

roads and dozer lines

Currently being 

implemented

Twin Williams 2005 

TSI and fuels reduction; includes 

some temporary roads and dozer 

lines

Ongoing 

EIS for Treatment 

of Noxious or 

Invasive Weeds

Multiple 

forests 2004 Treatment of noxious or invasive weeds Ongoing 

Spring Valley Williams 1999 TS; non-commercial thinning Final sale in progress

Grazing allotment 

management

Williams/ 

Tusayan Various Authorizes grazing and related activities Ongoing 

Special uses 

authorizations

Williams/ 

Tusayan Various Continuation of recreation/ lands/ minerals special use activities Ongoing 

Fuelwood 

gathering 

Williams/ 

Tusayan Various

Continuation of Forest fuelwood 

collection (commercial and personal 

use) program as approved annually 

and under specific projects

Ongoing 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

426 Appendices

Table D-3. Foreseeable future projects and activities

Project District

Estimated 

year NEPA 

completed

Activities Status

Bill Williams 

Mountain 

Restoration 

Project 

Williams 2015 

Thinning; Rx burning; temporary 

and new road construction; road 

obliteration

Environmental analysis 

nearing completion 

South Zone 

Grassland 

Restoration 

Project

Williams/ 

Tusayan

FY 2015 or 

2016 

Restoration of historical grassland 

areas outside of the 4FRI planning 

area (thinning, burning)

Developing proposed 

action
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 427

Appendix E: Silvicultural Treatments in Pre-Settlement 

Patches of Forest in MSO Protected Habitat and the 

Arizona Bugbane Botanical Area

This appendix is being added to the EIS to clarify silvicultural treatments proposed in pre-settlement patches in 

Mexican spotted owl protected habitat and the Arizona bugbane botanical area in the Bill Williams Mountain 

project area.

The United State Forest Service (USFS) and United States Fish and Wildlife Service (USFWS) worked together 

to identify pre-settlement patches (i.e., dense forest patches historically dominated by old, large diameter trees 

that persist today; see the map at the end of this appendix) that are greater than two acres in size. These patches 

are to be maintained and managed to provide nest and roost habitat for the conservation of the Mexican Spotted 

Owl (MSO) and maintaining canopy closure for Arizona bugbane. The patches are delineated both within and 

outside of the MSO Protected Activity Center. This section outlines details regarding treatments within and 

around these patches. It provides further explanation that remains consistent with the action alternatives, desired 

conditions, analysis, mitigation measures, and other components of the Bill Williams Mountain Restoration 

Project.

Methods for Delineating Pre-Settlement Patches 

The District biologist geo-referenced 1949 aerial photographs of Bill Williams Mountain and used these photos, 

in combination with 2010 ortho photos, to delineate patches of pre-settlement trees that were greater than 2 acres 

in size. The 1949 aerial photographs provided geospatial data that illustrated where large, contiguous patches of 

big, old trees historically occurred on the landscape.

The Forest confirmed that delineations based on 1949 aerial photos and 2010 ortho photos included the best 

patches of nesting and roosting habitat for MSOs by overlaying other geospatial data. These data displayed 

northern aspects, the presence of drainages, and information on general tree density and density of trees >18” 

DBH.

The fire ecologist, silviculturist, and biologist met with staff from the USFWS and Arizona Game and Fish 

Department (AZGFD) to revise the patch delineations as necessary. The USFWS and AZGFD agreed with the 

patch delineations. The input of the USFWS and AZGFD are reflected in the map (figure F-1) and the description 

of silvicultural treatments within this appendix.

Treatments in MSO Protected Habitat 

Desired conditions for Protected Habitat – including areas outside pre-settlement patches – are described in 

Appendix E of the DEIS. Protected Habitat will have an average basal area of 80 ft2

 per acre (including forested 

and non-forested areas). As pre-settlement patches and smaller tree groups will be managed for higher basal 

areas, the matrix around these patches and groups will be managed for lower basal areas. Lower basal areas in the 

matrix will promote more diverse horizontal structure and reduce the probability of stand-replacing wildfire in 

pre-settlement patches and groups. There will be scattered individual and small groups of small to large trees 

between delineated patches. Pre-settlement patches will range from 60-160 ft2 per acre basal area. Presettlement patches that are managed for higher basal would be dominated by trees >18” DBH. Patches managed 

for lower basal areas will be comprised of smaller size classes of trees (generally <18” DBH) to allow for growth 

into closed-canopy mature groups. Fewer tree patches will occur in areas that were historically open (generally 

with less than 10 trees/acre in pre-settlement times). Trees > 18” DBH will represent the majority of the basal 

area in Protected Habitat – both in and outside of pre-settlement patches.
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

428 Appendices

The two silvicultural treatment types within pre-settlement patches will be single (a.k.a., individual) tree selection 

or thin-from-below treatments. In general, pre-settlement patches dominated by large trees will be managed with 

thin-from-below treatments. Patches that are mixed-age will present more opportunities for single tree selection.

Individual stands may have a high density of trees 18-24” DBH and be deficient in vertical diversity and diversity 

of tree size classes. These are desired components of nesting/roosting habitat (Table C.2 of the 2012 Recovery 

Plan; FWS 2012). In some stands post-settlement trees up to 24” DBH could be removed to help create desired 

vertical diversity as described in the recovery plan. Pre-settlement trees and trees >24” DBH would be retained in 

MSO habitat except where they are incidentally taken due to harvesting operability needs or unforeseen 

circumstances related to safety.

Patches dominated by pre-settlement trees would be thinned from below to reduce ladder fuels, and create canopy 

gaps (approximately 1/10 acre in size) where existing canopy gaps can be enhanced. Mitigation measures to 

conserve pre-settlement and 24”+ DBH trees will drive prescriptions to mimic forest ‘gap dynamics’. Gap 

dynamics are the change in space and time in the pattern, frequency, size, and successional processes of forest 

canopy gaps caused by the fall or death of one or more canopy trees, which creates a canopy gap. The fall or 

death of one or more canopy trees is where the new cohort of trees recruits into a patch. In general, gaps would 

be formed in areas that lack pre-settlement and 24”+ DBH trees and contain surpluses of trees < 18” DBH. Trees 

up to 24” DBH (mainly 18” DBH and below) would be removed to mimic gaps for regeneration recruitment. To 

create variability and vertical structure, higher amounts of young (<5” DBH), intermediate (5-9” DBH), and 

suppressed trees will be retained in areas of lower fire hazard. Examples of such areas include moist drainages or 

depressions. 

Single tree selection would be used in pre-settlement patches where the forested area is not dominated by presettlement trees. It will strive to maintain all size classes of trees. This means that a substantial amount of 

vertical diversity of smaller trees will occur within canopy openings and under residual trees. Canopy openings 

for regeneration are very small (i.e, they are created by removing a single, mature tree). These mature, postsettlement trees would be up to 24” DBH but would mainly be 18”DBH and below. The different age classes of 

trees would be intermixed and close enough to each other that individual tree groups would not be readily 

apparent. A diversity of age/size classes would be maintained within these patches. This treatment focuses on 

sustaining a dominant component of mature and pre-settlement trees across the landscape into the future.

Treatments in the Arizona Bugbane Botanical Area

Treatments in pre-settlement patches for the conservation of Arizona bugbane will maintain the integrity of the 

overstory canopy. The USFWS and USFS agreed to delineate an inner buffer, limited treatment buffer, and 

additional pre-settlement patches within the Botanical Area that serve as suitable habitat (see page 20 of the DEIS 

for an explanation of buffer zones). Thin-from-below treatments will be conducted in these areas to maintain the 

integrity of the overstory. Incidental suppressed, young, and intermediate trees may be removed to promote gap 

dynamics. Some suppressed, young, and intermediate trees will be retained in areas that do not increase the risk 

of torching and crowning under the initial prescribed fire event. 
Bill Williams Mountain Restoration Project Final Environmental Impact Statement

Appendices 429

Figure E-1. Pre-settlement patches for MSO and bugbane conservation