United States Department of Agriculture

Santa Fe National Forest 

Geothermal Leasing

Final Environmental Impact Statement

Forest Service Santa Fe Coyote, Cuba, Espanola October 2017 

National Forest Jemez Ranger Districts MB-R3-10-24
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Santa Fe National Forest

Final Environmental Impact Statement

Sandoval and Rio Arriba Counties, New Mexico

Lead Agency: USDA Forest Service

Cooperating Agencies: Bureau of Land Management 

National Park Service 

Responsible Official: James Melonas 

11 Forest Lane, Santa Fe, New Mexico 87508 

For information, contact: Larry Gore 

04B County Road 11, Cuba, New Mexico 

(575) 289-3264 x2149 

Abstract: In accordance with the Energy Policy Act of 2005 (Public Law 109-58, August 8, 2005), 

Secretarial Order 3285A1 (amended February 22, 2010), and the Forest Service obligations under Section 

225 of the Energy Policy Act, the Forest Service is required to facilitate the development and production 

of geothermal energy. This final environmental impact statement (EIS) documents the National 

Environmental Policy Act analysis for determining which lands would be available for geothermal leasing 

in the project area and under what stipulations. The final EIS analyzes four alternatives in detail: 

Alternative 1 (No Action), Alternative 2 (the Proposed Action), Alternative 3 (No Leasing), and 

Alternative 4 (Development Alternative). The proposed action would amend the 1987 Santa Fe National 

Forest Plan. This final EIS tiers to and incorporates by reference those elements of the 2008 Geothermal 

Programmatic Environmental Impact Statement that are appropriate for such use, such as resource impact 

analysis, stipulations, leasing procedures, and best management practices. 

This project is subject to the Predecisional Administrative Review Process (Objection Process), in 

accordance with 36 Code of Federal Regulations (CFR), Part 218, Subparts A and B for the proposed 

project and 36 CFR, Part 219, Subparts A and B for the Forest Plan Amendment. The final EIS and draft 

record of decision are available online at https://www.fs.usda.gov/project/?project=46886. These 

documents are also available for review at the Santa Fe National Forest Supervisor’s Office: 11 Forest 

Lane, Santa Fe, NM 87508. 
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Summary 

Santa Fe National Forest Geothermal Leasing EIS i 

Summary

The Santa Fe National Forest (SFNF) proposes to identify lands in the project area administered 

by the Forest Service as closed to geothermal leasing under either nondiscretionary or 

discretionary authorities or open to geothermal leasing, subject to stipulations. The project area 

encompasses 194,910 acres in the Coyote, Cuba, Espanola, and Jemez Ranger Districts, of which 

168,650 acres are National Forest System (NFS) lands. 

This action is needed to allow the Forest Service to satisfy its statutory and policy mandates in 

responding to requests for the environmentally responsible development of energy resources and 

to respond to other policy directives calling for clean and renewable energy.

In 2008, the US Department of the Interior, Bureau of Land Management (BLM) recommended 

and the Assistant Secretary of Land and Minerals Management approved the Record of Decision 

(ROD) associated with the Programmatic Environmental Impact Statement (PEIS) for 

Geothermal Leasing in the Western United States. This led to a decision to amend BLM resource 

area management plans and provided certain National Forests with analysis to make decisions on 

existing lease applications. Decisions in the 2008 Geothermal ROD identified those lands that are 

legally open or closed to consideration for geothermal leasing on affected NFS lands; it provided 

stipulations, best management practices (BMPs), and procedures for geothermal leasing and 

development. The Forest Service has determined that additional site-specific environmental 

analysis is needed to supplement the 2008 Geothermal PEIS. This is so the Forest Service can 

make a decision about providing concurrence and consent to the BLM to lease lands in the SFNF

for developing geothermal resources.

The appendices in this final EIS are as follows:

• Appendix A, Management Areas and Prescriptions from Forest Plan, provides a summary of 

standards and guidelines specific to managements areas in the project area.

• Appendix B, Geothermal Leasing Stipulations by Alternative, describes stipulations for each 

alternative. 

• Appendix C, Best Management Practices and Mitigation Measures, is a list of BMPs. 

• Appendix D, Summary of Statutes and Regulations Governing Geothermal Leasing and 

Development on National Forest System Lands, describes the relevant statutes and 

regulations that pertain to this project. 

• Changes made since release of the DEIS are summarized in Appendix E, Changes Made 

Since the Draft Environmental Impact Statement. 

• Public comments and responses to the DEIS are presented in Appendix F, Summary of 

Public Comments. 

The Proposed Action

Under Alternative 2, the Proposed Action, the SFNF would amend the Forest Plan to implement 

discretionary and nondiscretionary leasing closures for geothermal resources. Approximately 

32,000 acres would be closed (by law, regulations, or other authority) to geothermal leasing in the 

project area. Approximately 136,650 acres of NFS lands in the project area would be allocated as 

open to geothermal leasing. This would be subject to existing laws, regulations, formal orders, 

and stipulations attached to the lease form, and the terms and conditions of the standard lease 
Summary 

ii Santa Fe National Forest Geothermal Leasing EIS

form. Controlled surface use (CSU), no surface occupancy (NSO), and timing limitation (TL)

stipulations would be implemented. 

Public Involvement 

The formal public scoping comment period, as required by the National Environmental Policy 

Act (NEPA; 40 CFR, Subpart 1501.7), began on May 13, 2015, and ended on June 26, 2015. 

Scoping included the following:

• Notice of Intent (NOI) published in the Federal Register on May 13, 2015 

• Media outreach, including press releases and the project website, http://www.fs.usda.gov/

projects/santafe/landmanagement/projects

• Scoping letter mailed to those on the project mailing list, including federal, state, and local 

agencies, Native American tribes, special interest groups, and landowners

• Public scoping meetings 

Results of the public scoping are discussed in detail in the scoping report posted on the project 

website.

Alternatives Considered 

Following the close of the public scoping period on June 26, 2015, the SFNF began developing 

alternatives. Based on public input, the interdisciplinary team’s analysis of the current 

management situation and resource data and on the defined purpose and need for the project, the 

Forest Service developed four alternatives. 

Under Alternative 1, the No Action Alternative, the SFNF would not amend the Forest Plan and 

would not make an availability determination for geothermal leasing on lands in the project area. 

It would continue processing geothermal lease applications and nominations but would evaluate 

them on a case-by-case basis under separate NEPA analyses, in accordance with the Forest Plan 

and existing laws and regulations. This alternative does not meet the purpose and need.

Under Alternative 2, the proposed action, the SFNF would amend the Forest Plan and land in the 

project area administered by the Forest Service would be identified as being closed to geothermal 

leasing under either nondiscretionary or discretionary authorities or open to geothermal leasing 

with possible moderate constraints (TL and CSU stipulations) to major constraints (NSO 

stipulations). 

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. The SFNF 

developed this alternative in response to comments received from the public and tribes during 

scoping. Although this alternative is contrary to program direction and mandates to make mineral

and energy resources available, it is supportable, due to resource concerns and the level of 

protection needed. Alternative 3 may prevent geothermal development on private land in and 

adjoining the project area due to drainage of federal resource issues.

Under Alternative 4, the SFNF would amend the Forest Plan and land in the project area 

administered by the Forest Service would be closed to geothermal leasing under either nondiscretionary or discretionary authorities, or would be open to geothermal leasing, with possible 

moderate constraints (TLs and CSU stipulations) to major constraints (NSO stipulations). There 
Summary 

Santa Fe National Forest Geothermal Leasing EIS iii

would be fewer areas identified as closed to geothermal leasing, and the stipulations would be 

less restrictive, compared with Alternative 2. 

Decision to be Made 

The SFNF supervisor is the Forest Service responsible official. Based on the environmental 

analysis and supporting documents in the project record, the forest supervisor will decide whether 

the proposed action should be implemented as proposed, modified by another action alternative, 

or not implemented at all. This decision is subject to the pre-decision administrative review 

process (objection process) under 36 CFR, Part 218, Subparts A and B. The Forest supervisor will 

also decide whether to amend the 1987 Forest Plan concurrently with the decision on geothermal 

leasing. The forest plan amendment decision is subject to the pre-decisional administrative review 

process (objection process) under 36 CFR, Part 219, Subparts A and B. 

Major Conclusions 

Under Alternative 1, geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA 

analyses, in accordance with the Forest Plan and existing laws and regulations. The Jemez 

National Recreation Area would remain closed to geothermal leasing; however, no other 

geothermal-specific leasing closures or stipulations would be implemented to protect resource or 

resource uses in the project area outside of the Jemez National Recreation Area. 

Potential indirect impacts from future geothermal leasing are as follows:

• Increased risk of seismic activity and ground subsidence

• Soil disturbance, compaction, and erosion 

• Changes in groundwater flow paths, pressurization, and temperature 

• Increased sediment and turbidity in surface water

• Vegetation removal

• Fish and wildlife habitat alteration and noise disturbance

• Increased short-term fugitive dust and vehicle emissions

• Disturbance to livestock and livestock grazing operations 

• Reduced livestock grazing forage

• Disturbance to landscapes and locations associated with religious beliefs or cultural uses

• Temporary and long-term job creation

Alternative 1 would not meet the purpose and need of the project. This is because it would not 

identify reasonable and necessary conditions to protect surface and subsurface resources.

Indirect impacts under Alternative 2, the Proposed Action, would generally be similar to those 

under Alternative 1; however, discretionary closures and stipulations could reduce or mitigate 

impacts on some resource or resource uses. For example, soil disturbance, compaction, and 

erosion would occur, but soil stipulations would reduce erosion in areas with severe erosion 

hazards and steep slopes. Stipulations for streams and rivers would limit sediment transport and 

turbidity. 

Fish and wildlife could be impacted through habitat alteration, removal, reduction, or 

fragmentation; however, implementation of stipulations would protect seasonally important 
Summary 

iv Santa Fe National Forest Geothermal Leasing EIS

wildlife habitat. Also, impacts would not lead to a substantial population change or trend toward 

federal listing for any species. Stipulations and closures for traditional cultural properties and 

Native American sacred sites, as identified though consultation, may reduce impacts, compared 

with Alternative 1; nevertheless, tribes consider the disturbance of the land or use of geothermal 

resources as an adverse impact that could not be avoided or minimized. The risk of seismic 

activity and ground subsidence would still occur under the proposed action. 

Under Alternative 3, all Forest Service lands in the project area would be closed to geothermal 

leasing, and there would be no direct or indirect impacts. 

Indirect Impacts under Alternative 4 would be similar to those described under Alternative 2, the 

Proposed Action. However, because fewer discretionary closures and stipulations would be 

implemented, the intensity or severity of impacts could be greater in certain areas. For example, 

soil erosion and runoff would be more likely to occur, and riparian areas would be more likely to 

experience disturbance or habitat alteration impacts. 
Contents

Santa Fe National Forest Geothermal Leasing EIS v 

Contents 

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

The Proposed Action .................................................................................................................... i

Public Involvement ...................................................................................................................... ii

Alternatives Considered .............................................................................................................. ii

Decision to be Made ................................................................................................................... iii

Major Conclusions...................................................................................................................... iii

Acronym or Abbreviation ............................................................................................................... ix

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

1.1 Introduction ................................................................................................................. 1-1

1.2 Purpose and Need for Action ...................................................................................... 1-2

1.3 Description of the Project Area and Decision Area .................................................... 1-3

1.4 Background for Geothermal Resources ....................................................................... 1-3

1.5 Leasing and Development Process of Geothermal Resources on National 

Forest System Lands ................................................................................................... 1-7

1.6 New Mexico Geothermal Potential ............................................................................. 1-9

1.7 Relationship to Forest Service Plans, Policies, and Programs .................................. 1-13

1.8 Scope of Analysis ...................................................................................................... 1-16

1.9 Decision Framework ................................................................................................. 1-16

1.10 Public Involvement and Scoping ............................................................................... 1-17

1.11 Tribal Coordination ................................................................................................... 1-18

1.12 Coordination with Other Federal and State Agencies ............................................... 1-19

1.13 Issues ......................................................................................................................... 1-19

1.14 Proposed Action ........................................................................................................ 1-22

1.15 Forest Plan Amendments ........................................................................................... 1-23

Chapter 2. Alternatives, Including the Proposed Action .............................................................. 2-1

2.1 Introduction ................................................................................................................. 2-1

2.2 Stipulations, Best Management Practices, and Procedures ......................................... 2-1

2.3 Alternatives Considered in Detail ............................................................................... 2-5

2.4 Alternatives Considered but Eliminated from Detailed Study .................................. 2-12

2.5 Reasonably Foreseeable Development Scenario ....................................................... 2-13

2.6 Comparison of Alternatives ....................................................................................... 2-15

Chapter 3. Affected Environment and Environmental Consequences .......................................... 3-1

3.1 Introduction ................................................................................................................. 3-1

3.2 Methods and Assumptions Common to the Analysis of Impacts ................................ 3-1

3.3 Cumulative Actions for Cumulative Impacts Analysis ............................................... 3-3

3.4 Land Use, Recreation, and Special Designations ........................................................ 3-6

3.5 Geologic Resources ................................................................................................... 3-17

3.6 Energy and Mineral Resources .................................................................................. 3-27

3.7 Paleontological Resources ......................................................................................... 3-32

3.8 Soil Resources ........................................................................................................... 3-37

3.9 Water Resources ........................................................................................................ 3-41

3.10 Air Quality and Air Quality-Related Values ............................................................. 3-60

3.11 Vegetation ................................................................................................................. 3-77

3.12 Fish and Wildlife ....................................................................................................... 3-86

3.13 Threatened and Endangered Species and Special Status Species .............................. 3-98

3.14 Livestock Grazing ................................................................................................... 3-122

3.15 Cultural Resources .................................................................................................. 3-127

3.16 Tribal Interests and Traditional Cultural Resources ................................................ 3-134
Contents

vi Santa Fe National Forest Geothermal Leasing EIS

3.17 Visual Resources ..................................................................................................... 3-141

3.18 Social Interests, Economics and Environmental Justice ......................................... 3-152

3.19 Health and Safety .................................................................................................... 3-167

3.20 Noise ....................................................................................................................... 3-169

3.21 Transportation and Access ...................................................................................... 3-172

3.22 Climate Change ....................................................................................................... 3-177

3.23 Short-Term Uses and Long-Term Productivity ....................................................... 3-185

3.24 Unavoidable Adverse Impacts ................................................................................ 3-186

3.25 Irreversible and Irretrievable Commitments of Resources ...................................... 3-186

Chapter 4. Consultation and Coordination ................................................................................... 4-1

4.1 Preparers and Contributors .......................................................................................... 4-1

4.2 List of Agencies, Organizations and Persons Who Were Sent Copies of 

the DEIS ...................................................................................................................... 4-4

Chapter 5. Glossary ...................................................................................................................... 5-1

Chapter 6. References ................................................................................................................... 6-1

Chapter 7. Index............................................................................................................................ 7-1

List of Tables

Table 1-1. Amendment Language by Alternative for the Geothermal EIS ................................ 1-23

Table 2-1. Summary of Acres Open and Closed to Geothermal Leasing, by Alternative ............ 2-6

Table 2-2. Summary of Surface Disturbance from Exploration Activities................................. 2-13

Table 2-3. Summary of Surface Disturbance from Drilling and Utilization .............................. 2-14

Table 2-4. Comparison of Alternatives ....................................................................................... 2-15

Table 3-1. Reasonably Foreseeable Future Actions ..................................................................... 3-4

Table 3-2. Geologic Units in Decision Area ............................................................................... 3-18

Table 3-3. PRRAS Classification for Project Area ..................................................................... 3-33

Table 3-4. Soil Characteristics of the Project Area..................................................................... 3-37

Table 3-5. Watershed Erodibility Index ..................................................................................... 3-48

Table 3-6. Summary of Common Impacts on Water Resources by Geothermal 

Development Phase ............................................................................................................ 3-56

Table 3-7. National and New Mexico Ambient Air Quality Standards ...................................... 3-61

Table 3-8. Air Quality Monitoring Values in Rio Arriba and Sandoval Counties, 

New Mexico ........................................................................................................................ 3-65

Table 3-9. Summary of Annual Emissions for Rio Arriba and Sandoval Counties, 

2011 (Tons) ......................................................................................................................... 3-66

Table 3-10. Summary of Geothermal Exploration Activities and Surface Disturbance ............. 3-71

Table 3-11. Geothermal Exploration Well Drilling Emissions .................................................. 3-72

Table 3-12. Summary of Geothermal Development Drilling and Surface Disturbance ............. 3-73

Table 3-13. Geothermal Development Drilling Emissions......................................................... 3-74

Table 3-14. Major Vegetation Communities in the Project Area ............................................... 3-78

Table 3-15. Climate Vulnerability Rankings by Watershed ....................................................... 3-81

Table 3-16. Southwestern Region Regional Forester’s MIS on the SFNF ................................. 3-86

Table 3-17. Federally Listed and Region 3 Regional Forester’s Sensitive Species on 

the SFNF ............................................................................................................................. 3-99

Table 3-18. Northern Goshawk Post-Fledgling Family Areas in the Project Area .................. 3-105

Table 3-19. Livestock Grazing Allotments in the Santa Fe National Forest 

Geothermal Decision Area................................................................................................ 3-123

Table 3-20. Livestock Grazing Allotments in the Jemez National Recreation Area ................ 3-126

Table 3-21. Scenic Integrity ..................................................................................................... 3-142

Table 3-22. Examples of Lux Measurements on a Given Surface............................................ 3-144
Contents

Santa Fe National Forest Geothermal Leasing EIS vii

Table 3-23. Stipulations and Closures within a 1- and 2-mile Buffer of NPS Lands 

for Action Alternatives ..................................................................................................... 3-151

Table 3-24. Viewshed Acres from the Caldera Rim and Redondo Peak by Action 

Alternative......................................................................................................................... 3-151

Table 3-25. Population by County, State, and Country ............................................................ 3-153

Table 3-26. Housing Units by County, State, and Country ...................................................... 3-154

Table 3-27. Housing Vacancy Status 2010 ............................................................................... 3-154

Table 3-28. Median Home Values and Median Gross Rent 2014 ............................................ 3-154

Table 3-29. Santa Fe Geothermal Leasing Study Area - Property Tax Assessed 

Values and Obligations ..................................................................................................... 3-155

Table 3-30. Santa Fe Geothermal Leasing Study Area - Average Yearly Unadjusted 

Unemployment Rate by County from 2010-2015 ............................................................. 3-156

Table 3-31. Median Household Income .................................................................................... 3-156

Table 3-32. Per Capita Income ................................................................................................. 3-156

Table 3-33. Populations in Poverty 2014 .................................................................................. 3-158

Table 3-34. Study Populations by Race/Ethnicity 2014 ........................................................... 3-159

Table 3-35. Economic Impacts of Geothermal Electricity Generation ..................................... 3-164

Table 3-36. Observed and Calculated Noise Levels for Geothermal Power Plants, 

Production Wells, and Drill Rigs ...................................................................................... 3-171

Table 3-37. Average Temperatures and Precipitation in the Project Area (1981–2010) .......... 3-177

Table 3-38. Geothermal Development Exploration Well Carbon Dioxide Emissions ............. 3-181

Table 3-39. Geothermal Development Well Drilling Carbon Dioxide Emissions ................... 3-182

Table 3-40. Comparison of Geothermal and Fossil Fuel Carbon Dioxide Emissions .............. 3-183

List of Figures

Figure 1-1. Geothermal Leasing Project Surface Administration ................................................. 1-4

Figure 1-2. Uses of Geothermal Energy (from 2008 PEIS; BLM and Forest Service 2008) ....... 1-5

Figure 1-3. Geothermal Leasing and Development Process ....................................................... 1-10

Figure 1-4. Geothermal Potential Areas ..................................................................................... 1-12

Figure 3-1. Geology .................................................................................................................... 3-21

Figure 3-2. Watersheds ............................................................................................................... 3-43

Figure 3-3. Grazing Allotments ................................................................................................ 3-124

Figure 3-4. Scenic Integrity ...................................................................................................... 3-143

Figure 3-5. Redondo Peak and Caldera Rim Viewsheds .......................................................... 3-145

Appendix B Figures 

Figure 2-1. Alternative 2 – The Proposed Action Closed to Leasing 

Figure 2-2. Alternative 2 – The Proposed Action Available for Leasing Subject to 

No Surface Occupancy

Figure 2-3. Alternative 2 – The Proposed Action Available for Leasing Subject to 

 Controlled Surface Use 

Figure 2-4. Alternative 2 – The Proposed Action Available for Leasing Subject to 

Timing Limitations

Figure 2-5. Alternative 4 – The Development Alternative Closed to Leasing

Figure 2-6. Alternative 4 – The Development Alternative Available for Leasing Subject to 

No Surface Occupancy

Figure 2-7. Alternative 4 – The Development Alternative Available for Leasing Subject to 

 Controlled Surface Use 
Contents

viii Santa Fe National Forest Geothermal Leasing EIS

Figure 2-8. Alternative 4 – The Development Alternative Available for Leasing Subject to 

Timing Limitations

Figure 2-9. Alternative 3 – The No Leasing Alternative Closed to Leasing

List of Appendices

Appendix A. Management Areas and Prescriptions from Forest Plan

Appendix B. Stipulations and Closures by Alternative 

Appendix C. Best Management Practices and Mitigation Measures

Appendix D. Summary of Statutes and Regulations Governing Geothermal Leasing and 

Development on National Forest System Lands 

Appendix E. Changes Made Since the Draft Environmental Impact Statement

Appendix F. Summary of Public Comments 
Contents

Santa Fe National Forest Geothermal Leasing EIS ix

Acronym or Abbreviation Full Term

μg/m3 micrograms per cubic meter

AADT annual average daily traffic

ACEC Area of Critical Environmental Concern 

AMZ aquatic management zone

AQRV air quality related value 

AUM animal unit month 

BLM United States Department of the Interior, Bureau of Land Management

BLS Bureau of Labor Statistics 

BMP best management practice

°C degree Celsius

CAA Clean Air Act

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations

CWA Clean Water Act

CO2 carbon dioxide 

CO2e carbon dioxide equivalent 

COA condition of approval 

CRMP Cultural Resource Management Plan 

CSU controlled surface use

CWE cumulative watershed effects

dBA a-weighted decibel

DEIS draft environmental impact statement

DOE United States Department of Energy

EIA Energy Information Administration

EIS environmental impact statement

EPA United States Environmental Protection Agency 

ESA Endangered Species Act of 1973 

°F degree Fahrenheit

FEIS final environmental impact statement

FLPMA Federal Land Policy and Management Act of 1976 

Forest Plan Santa Fe National Forest Plan 

FSH Forest Service Handbook 

GHG greenhouse gas 

GIS geographic information system 

IPCC Intergovernmental Panel on Climate Change 

IRA inventoried roadless area

JNRA Jemez National Recreation Area

KGRA known geothermal resource area 

LANL Los Alamos National Laboratory 

MBTA Migratory Bird Treaty Act

MIS management indicator species

MOU memorandum of understanding 

MSO Mexican spotted owl 
Contents

x Santa Fe National Forest Geothermal Leasing EIS

MW megawatt 

NAAQS National Ambient Air Quality Standards

NEPA National Environmental Policy Act

NFS National Forest System 

NHD National Hydrography Dataset

NHPA National Historic Preservation Act

NMDGF New Mexico Department of Game and Fish

NMDOT New Mexico Department of Transportation

NMED New Mexico Environment Department 

NMED-DWB Drinking Water Bureau of the New Mexico Environmental Department 

NMOSE New Mexico Office of the State Engineer

NMWQCC New Mexico Water Quality Control Commission

NOI notice of intent 

NORM naturally occurring radioactive materials

NPS United States Department of the Interior, National Park Service

NRA National Recreation Area

NRCS Natural Resources Conservation Service

NRHP National Register of Historic Places

NSO no surface occupancy 

PAC protected activity center

PEIS programmatic environmental impact statement

PFA post-fledging area

PM2.5 particulate matter with an aerodynamic diameter of 2.5 microns or less

PM10 particulate matter with an aerodynamic diameter of 10 microns or less

ppb parts per billion

ppm parts per million 

PRRAS Paleontological Resources Rapid Assessment System

PSD prevention of significant deterioration 

RFDS reasonably foreseeable development scenario

RGCT Rio Grande cutthroat trout

ROD record of decision 

ROI region of interest

ROS Recreation Opportunity Spectrum 

ROW right-of-way

SHPO State Historic Preservation Office

SFNF Santa Fe National Forest

TCP traditional cultural property

TL timing limitation

TMDL total maximum daily load

USC United States Code

USDA United States Department of Agriculture

USFWS United States Fish and Wildlife Service

USGS United States Geological Survey

VCNP Valles Caldera National Preserve

WEG wind erodibility group 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-1

Chapter 1. Purpose of and Need for Action

1.1 Introduction

In 2008, the US Department of the Interior, Bureau of Land Management (BLM) recommended 

and the Assistant Secretary of Land and Minerals Management approved the Record of Decision

(ROD) associated with the Programmatic Environmental Impact Statement (PEIS) for 

Geothermal Leasing in the Western United States. This led to a decision to amend BLM resource 

area management plans and provided analysis to allow certain National Forests to make 

decisions on existing lease applications. 

Decisions in the 2008 Geothermal ROD identified those lands that are legally open or closed to 

consideration for geothermal leasing on affected National Forest System (NFS) lands; it 

provided stipulations, best management practices (BMPs), and procedures for geothermal leasing 

and development. The Forest Service has determined that additional site-specific environmental 

analysis is needed to supplement the 2008 Geothermal PEIS. This is so the Forest Service can 

make a decision about providing concurrence and consent to the BLM to lease lands in the Santa 

Fe National Forest (SFNF) for developing geothermal resources. The regulations governing the 

relationship between the BLM and Forest Service (43 Code of Federal Regulations [CFR],

Subpart 3201.10[a][2]) use the term “concurrence.” Throughout this document “concurrence” 

and “consent” are used interchangeably. 

The 2008 Geothermal PEIS and ROD was prepared in accordance with the planning 

requirements of the Federal Land Policy and Management Act of 1976, as amended (FLPMA) 

and its implementing regulations at 43 CFR, Part 1600, as well as with the National 

Environmental Policy Act (NEPA) and its implementing regulations at 40 CFR, Parts 1500 

through 1508.

The Forest Service’s proposed action is to determine which lands in the SFNF on the Coyote, 

Cuba, Espanola, and Jemez Ranger Districts would be available for geothermal leasing and 

under what stipulations. This proposed action would amend the 1987 Santa Fe National Forest 

Plan.

The Forest Service has prepared this environmental impact statement (EIS) in compliance with 

NEPA and other relevant federal and state laws and regulations. This EIS identifies the direct, 

indirect, and cumulative environmental impacts that would result from the proposed action and 

alternatives. 

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

found in the project planning record located at the SFNF.

This chapter details the purpose and need for the proposed action, the action’s objective, the 

planning and decision areas. It also provides the following:

 Provides a brief background on geothermal resources and the leasing and development 

process

 Details the relationship of the proposed action to existing policies and plans

 Outlines the scope of the analysis for the proposed action, the decisions to be made after 

analysis, and issues to be addressed based on internal and external scoping
Chapter 1. Purpose of and Need for Action

1-2 Santa Fe National Forest Geothermal Leasing EIS

Secretarial Order 3285A1, amended February 22, 2010, establishes the development of 

environmentally responsible renewable energy as a United States Department of Interior priority. 

The US Department of Agriculture, Forest Service (Forest Service) has obligations under Section 

225 of the Energy Policy Act to facilitate the development and production of geothermal energy.

The State of New Mexico, through the Renewable Portfolio Standard, has mandated that 

investor-owned utilities procure renewable energy and renewable energy certificates from New 

Mexico renewable generation facilities. In 2007 legislative changes to the Renewable Energy Act 

(SB418, signed by Governor Bill Richardson) mandated that investor-owned utilities must have 

in their portfolio as a percentage of total retail sales to New Mexico customers, renewable energy 

of no less than 15 percent by 2015 and 20 percent by 2020. 

Geothermal resources, along with oil and gas, fall under the Forest Service Leasable Minerals 

Program. The Geothermal Steam Act of 1970 gives the Secretary of the Interior authority to 

issue geothermal leases on NFS lands and regulates subsurface geothermal activities through the 

BLM (BLM; 30 United States Code [USC] 1002, Section 3).

In response to lease nominations and inquiries from industry, the BLM has requested the 

concurrence of the Forest Service to lease NFS lands in the SFNF for future geothermal 

exploration, development, and production (see Section 1.5, Leasing and Development Process of 

Geothermal Resources on NFS Lands, for more information about the leasing process). The 

BLM may only lease nominated NFS lands with Forest Service concurrence (43 CFR, Subpart 

3201.10[a][2]). Before providing concurrence to the BLM for leasing, the Forest Service is 

responsible for conducting a NEPA analysis for leasing, for developing appropriate terms and 

conditions under which leases may be issued, and for ensuring decisions are consistent with the

SFNF Plan. 

1.2 Purpose and Need for Action

The purpose of the action is to refine the analysis available in the PEIS in order to determine if 

certain lands in the SFNF may be made available for geothermal leasing and, if so, to provide 

consent to leasing of lands and to identify reasonable and necessary conditions to protect

resources. 

The need for the action is twofold: (1) to allow the Forest Service to satisfy its respective 

statutory and policy mandates in responding to requests for the environmentally responsible 

development of energy resources and (2) to respond to other policy directives calling for clean 

and renewable energy.

Specifically, the United States Geological Survey (USGS) has identified approximately 194,000 

acres of SFNF lands with significant geothermal potential; the BLM has received expressions of 

interest in leasing approximately 46,000 acres of this land for geothermal energy production. 

This action is needed because the SFNF Plan, as amended (Forest Service 1987) does not 

allocate areas as open or closed to geothermal leasing, does not have adequate stipulations or 

BMPs to apply to geothermal leases to protect sensitive resources, and does not assess the 

reasonably foreseeable development scenario (RFDS), as required in the 2008 PEIS. 

While the current expressed interest in geothermal leasing does not constitute all 194,000 acres, 

the entire area plus an additional approximately 900 acres for power transmission will be 

considered in the analysis in the event that the SFNF needs to address future interest. By 

incorporating all lands identified as containing significant geothermal potential under one EIS, 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-3

the SFNF can address future nominations and applications and provide consent or non-consent in 

a timely manner. 

1.3 Description of the Project Area and Decision Area

The project area encompasses approximately 194,910 acres, as follows:

 Approximately 26,212 acres are privately owned

 Approximately 48 acres are owned by state or other government entities

 Approximately 168,650 acres are NFS lands (lands on the Coyote, Cuba, Espanola, and 

Jemez Ranger Districts of the SFNF [Figure 1-1, Geothermal Leasing Project Surface 

Administration]). These lands comprise the decision area for the project; non-federal lands 

are not included in this decision.

The project area is in Sandoval and Rio Arriba Counties, New Mexico. The SFNF defined spatial 

boundaries for five units in the project area, for the purpose of future planning and characterizing 

existing conditions. These units, on lands managed by the SFNF, are listed below:

 Lease Interest Unit (39,200 acres)

 North Unit (48,200 acres)

 Middle Unit (10,800 acres)

 Jemez National Recreation Area (JNRA) Unit (39,200 acres)

 South Unit (34,400 acres)

1.4 Background for Geothermal Resources

As described in the 2008 PEIS, the term geothermal comes from the Greek words gé, meaning 

earth, and thermé, meaning heat, as geothermal energy is derived from the natural heat of the 

earth. Geothermal resources are typically underground reservoirs of hot water or steam created 

by heat from the earth, but geothermal resources also include subsurface areas of dry hot rock. In 

cases where the reservoir is dry hot rock, the energy is captured by injecting cool water from the 

surface, which is then heated by the hot rock and extracted as fluid or steam. 

Geothermal steam and hot water can naturally reach the earth’s surface in the form of hot 

springs, geysers, mud pots, or steam vents. Geothermal reservoirs of hot water are also found at 

various depths beneath the Earth’s surface. In the United States, geothermal resources are most 

ubiquitous in the western states, Alaska, and Hawaii (Tester et al. 2006; NREL 2015a). 

Geothermal resources can be accessed by wells and used to provide heat directly. This is called 

the direct use of geothermal energy. The heat energy can also be used to commercially generate 

electricity, a process called indirect use. As shown in Figure 1-2, Uses of Geothermal Energy, 

there are a wide range of uses for geothermal resources.

1.4.1 Direct Use

Humans have been using geothermal resources in the form of hot springs for thousands of years, 

and direct heat use is one of the most versatile forms of geothermal energy use (Dickson and 

Fanelli 2003, p. 16). Today, geothermal reservoirs with waters of 68 degrees Fahrenheit (oF) to 

302oF (20 degrees Celsius [oC] to 150oC) temperature water provide numerous opportunities for 

direct use. Direct use means using geothermal resources for commercial, residential, agricultural, 
Chapter 1. Purpose of and Need for Action 1-4 Santa Fe National Forest Geothermal Leasing EIS Figure 1-1
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-5

Figure 1-2. Uses of Geothermal Energy (from 2008 PEIS; BLM and Forest Service 2008)
Chapter 1. Purpose of and Need for Action

1-6 Santa Fe National Forest Geothermal Leasing EIS

or public facilities or for energy needs other than the commercial production of electricity (43 

CFR, Subpart 3200.1). The direct use of geothermal energy includes heating pools and spas, 

greenhouses and aquaculture facilities, and melting snow, and drying agricultural products. 

Direct use also has industrial applications and can be used for ground-source heat pumps (Lund 

and Boyd 2015). 

Direct uses in the United States have been growing at about 7 percent per year. The largest 

applications of direct heat uses in the United States are ground-source heat pumps, accounting 

for 88 percent of the annual energy use for all geothermal direct uses (Lund and Boyd 2015).

1.4.2 Commercial Electrical Generation

Commercial electrical generation from geothermal resources is also called indirect use. Electrical 

generation uses geothermally heated fluid to turn a turbine connected to a generator. As 

discussed below, the fluid may be the naturally occurring steam or water in the geothermal 

reservoir or another fluid that has the geothermal heat transferred through a heat exchange 

system.

Geothermal energy has been a small but consistent source of electricity in the United States since 

1971, providing 0.4 percent of total generation in 2013 (EIA 2015a). As of 2013, there were 64 

operating conventional geothermal power plants in the United States, accounting for nearly 

2,700 megawatts (MW) of total capacity (EIA 2015a).

Geothermal power plants can be small (generating 300 kilowatts), medium (generating 10 to 50 

MW), and large (generating 50 MW and higher; Nemzer et al. 2007). Generation capacity is 

guided by the number of turbines in a plant. To extract thermal energy economically, one must

drill to depths where temperatures are sufficiently high to justify investment in the heat-mining 

project. For commercial electricity generation, this generally means drilling to rock temperatures 

in excess of 300oF (149oC) (Tester et al. 2006). However, new technologies have proven that 

lower-temperature water (below 300oF [149oC]) can also be used for electrical generation 

(Aneke et al. 2011; BLM and Forest Service 2008; DOE 2015).

The following three types of geothermal power plant systems are commonly used to generate 

electricity, depending on temperature, depth, and quality of the water and steam in the area 

(NREL 2015b):

 Flash steam

 Binary-cycle

 Dry stream power plants

These plants can also be hybridized by including elements of the different technologies at a 

single location. In all three methods, the remaining geothermal fluid is injected back into the 

ground to replenish the reservoir and recycle the residual hot water. Geothermal power plant

systems are described in detail in the 2008 Geothermal PEIS (BLM and Forest Service 2008).
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-7

1.5 Leasing and Development Process of Geothermal 

Resources on National Forest System Lands

1.5.1 Federal Geothermal Leasing Laws and Regulations

A federal geothermal lease grants “the exclusive right to drill for, extract, produce, remove, 

utilize, sell, and dispose of all the geothermal resources” in the lands described within the lease 

form. According to 43 CFR, Subpart 3200.1, geothermal steam and associated geothermal 

resources are defined as follows:

 All products of geothermal processes, including indigenous steam, hot water, and brines

 Steam and other gases, hot water, and hot brines resulting from water, gas, or other fluids 

artificially introduced into geothermal formations

 Other associated energy found in geothermal formations

 Any byproducts

The BLM has the delegated authority to issue geothermal leases on federal lands. It is the policy 

of the federal government, consistent with Section 2 of the Mining and Mineral Policy Act of 

1970 and Sections 102(a)(7), (8), and (12) of the FLPMA (43 USC, Section 1701 et seq.), to 

encourage the development of mineral resources, including geothermal resources, on federal 

lands. The Geothermal Steam Act of 1970 (30 USC, Section 1001 et seq.), which was amended 

and supplemented by the Energy Policy Act of 2005, provides statutory guidance for geothermal 

leasing by the BLM. Federal geothermal development regulations (43 CFR, Parts 3000, 3200, 

and 3280—Geothermal Resource Leasing and Geothermal Resources Unit Agreements) were 

made effective June 1, 2007 (72 Federal Register 24358, May 2, 2007), as a result of a directive 

provided in the Energy Policy Act of 2005. These statutes and regulations delineate lands that are 

available and unavailable for leasing.

See Appendix D, Summary of Statutes and Regulations Governing Geothermal Leasing and 

Development on National Forest System Lands, for additional laws and regulations related to 

geothermal leasing.

1.5.2 Leasing and Development Process, Rights, and Limitations

The BLM grants access to geothermal resources through a formalized leasing process based on 

the end use. For direct uses, an applicant can apply noncompetitively for a lease; for indirect use, 

such as commercial electrical generation, the BLM awards leases through a competitive bidding 

process. Historically, certain lands were designated as known geothermal resource areas

(KGRAs). All lands designated within KGRAs were leased through a competitive bidding 

process. Before the passage of the Energy Policy Act of 2005, lands outside of known 

geothermal resource areas could be leased noncompetitively. Section 222 of the Energy Policy 

Act of 2005 modified the Geothermal Steam Act of 1970 to allow only competitive lease sales 

for all federal geothermal resources and their associated lands; however, there were the following 

exceptions:

 Parcels of land that did not receive bids in a competitive sale

 Lands available exclusively for direct use

 Lands with a mining claim and a current approved plan of operations
Chapter 1. Purpose of and Need for Action

1-8 Santa Fe National Forest Geothermal Leasing EIS

 Lands for which a lease application was pending on August 8, 2005, if the applicant so 

chooses

Lease areas are nominated by the public for a lease sale, whereas the public is defined as

follows: 

 A US citizen at least 18 years old

 An association of US citizens, including a partnership

 A corporation organized under the laws of the United States

 Any state or the District of Columbia

 A domestic government unit

When the BLM receives a nomination, it is adjudicated and configured into lease parcels by the 

respective BLM state office. Lease parcels are then forwarded to the appropriate Forest Service

office, where the appropriate environmental analysis and review is conducted. Environmental 

analysis and review yields a consent or non-consent decision for geothermal leasing. With the 

Forest Service’s consent, and once lease parcels are configured, the BLM is responsible for 

conducting geothermal lease sales and issuing competitive and noncompetitive leases. 

The BLM holds a competitive lease sale at least once every two years for lands available for 

leasing in a state that has nominations pending. Although the BLM cannot issue a lease without the 

consent of the Forest Service, it can add any additional terms, conditions, or stipulations that it 

deems necessary and appropriate. Also, the BLM must make an independent decision on whether 

to issue the lease after reviewing the decision and documentation presented by the Forest Service. 

The four stages of geothermal resource development within a lease area are exploration, drilling 

operations, utilization, and reclamation and abandonment. Each stage requires a permit from the 

BLM and is described in detail in Chapter 2 of the 2008 Geothermal PEIS (BLM and Forest 

Service 2008). Leasing geothermal resources from the BLM vests with the lessee a nonexclusive 

right to future exploration (non-production) and an exclusive right to produce and use the 

geothermal resources in the lease area. This is subject to existing laws, regulations, and formal 

orders. The lease is also subject to the terms, conditions, and stipulations in or attached to the 

lease form or included as conditions of approval to permits. 

Lease issuance alone does not authorize any ground-disturbing activities to explore for or develop 

geothermal resources without site-specific approval for the intended operation. Such approval 

could include additional environmental reviews and permits. Also at each stage, the BLM can issue 

site-specific conditions of approval (COAs) to protect resource values. For both exploration and 

production or utilization operations on leased lands, the BLM determines if the permit application 

should be approved. It coordinates NEPA review with the Forest Service, which may propose 

permit conditions of approval involving surface issues. The level of environmental analysis to be 

required under NEPA for subsequent individual exploration, development, and production permits 

is determined at the BLM field office and Forest Service unit level. 

A lease is issued for a primary term of 10 years and may be extended for two five-year periods. 

The BLM will extend the primary term for five years under one of the following circumstances:

 The lessee has satisfied the minimum work requirement or made a payment to the BLM 

equivalent to the required work; in such a case, the total of the payment and the value of the 

work performed must equal $40 per acre (43 CFR, Subparts 3207.10 and 3207.11).
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-9

 The lessee submits documentation to the BLM that geothermal resources are produced or 

used in commercial quantities (43 CFR, Subparts 3207.10 and 3207.11).

Once commercial production is established, the lease may receive a production extension of up 

to 35 years and a renewal period of up to 55 years. The lease must continue to produce to remain 

in effect. The BLM may grant a suspension of operations and production on a lease when 

justified by the operator (43 CFR, Part 3207). A diagram outlining the leasing and development 

process, including what stages provide opportunities for public involvement, is shown in Figure 

1-3, Geothermal Leasing and Development Process.

Geothermal exploration and production on federal land conducted through leases is subject to 

lease terms and stipulations and must also comply with all applicable federal and state laws 

pertaining to various considerations for tribal interests, sanitation, air quality, solid waste, scenic 

values, roads, water quality, wildlife, safety, cultural resources, and reclamation.

New Mexico classifies geothermal resources as mineral if the fluid produced has a temperature 

greater than 250°F and as water if the fluid produced has a temperature less than or equal to 

250°F. If the fluid produced is considered mineral, the resource is under the primary jurisdiction 

of the New Mexico Department of Energy, Minerals, and Natural Resources. This agency 

coordinates with the US Environmental Protection Agency (EPA), Region 6, which has authority 

over wastewater discharge to surface waters in the state. Both of these agencies, in addition to 

the New Mexico Environment Department (NMED), have regulatory authority over geothermal

discharge permits.

Geothermal fluid less than 250°F is considered water and is under the primary responsibility of 

the New Mexico Office of the State Engineer (NMOSE) for drilling and permitting. The EPA 

also has authority over wastewater discharge to surface waters in the state for fluids less than 

250°F. State permitting is beyond the scope of this project.

1.6 New Mexico Geothermal Potential

At the broad level, the 2008 PEIS (BLM and Forest Service 2008) estimated the potential for 

geothermal energy. However, since that time, changes in technology and more specific studies 

were conducted so that these areas may be more closely designated. In order to assess where 

geothermal development could occur, the SFNF conducted a detailed review of literature 

pertaining to existing geothermal potential studies on lands covering the SFNF.

The USGS (USGS 2010) reviewed geographic information system (GIS) data for lands with 

highly favorable geothermal development potential. This study analyzed 12 models that correlate 

different geological and geophysical factors to the known presence of moderate (90 to 150°C) to 

high (greater than 150°C) temperature geothermal systems (Williams and DeAngelo 2008; 

Williams et al. 2008; Williams et al. 2009). The SFNF also evaluated the location of KGRAs that

the USGS identified as containing geothermal resources (Forest Service 1977). Although

KGRAs no longer guide the geothermal leasing process, they do show areas of potential 

geothermal resources. Additionally, the SFNF evaluated data published in a US Department of 

Energy (DOE) commissioned study: Opportunities for Near-Term Geothermal Development on 

Public Lands in the Western United States (DOE and BLM 2003). Based on the information 

contained in these studies, the SFNF identified lands most likely to receive geothermal lease 

nominations and applications. This area was defined as the project area for the EIS.
1-10 Santa Fe National Forest Geothermal Leasing EIS Chapter 1. Purpose of and Need for Action Figure 1-3
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-11

1.6.1 Resource Geography

New Mexico contains abundant geothermal resources throughout a large temperature gradients. 

Temperature gradients refer to the rate of increasing temperature with respect to increasing depth. 

High temperature gradients can indicate the location and depth of potential underground geothermal 

reservoirs capable of supporting commercial uses. Resources suitable for most development are 

concentrated in the west and north-central regions of the state, with high temperature gradients 

ranging from 1.6°F to 2.5°F per 100 feet of depth (BLM and Forest Service 2008).

Within the project area, highly favorable geothermal resources are concentrated on lands next to 

the Valles Caldera National Preserve (VCNP), as shown on Figure 1-4, Geothermal Potential 

Areas (USGS 2010). KGRAs cover most lands in the project area south of Highway 96. 

Similarly, most lands identified as having geothermal development potential in the project area

in the 2003 US DOE study are south of Highway 96 (DOE and BLM 2003).

1.6.2 Utilization

New Mexico’s first utility-scale geothermal power plant was completed at the Lightning Dock 

geothermal field in Hidalgo County in 2013, producing 4 MW of electricity (Geothermal Energy 

Association 2014). No other utility-scale production plants are in operation in New Mexico. 

Direct use applications of geothermal in New Mexico include greenhouses, heat pumps, and 

aquaculture operations.

1.6.3 Past Geothermal Exploration near Project Area

The project area and adjacent lands contain a geothermal system was previously investigated as a 

source of geothermal energy. Beginning in the early 1960s, exploratory geothermal drilling was 

conducted in the Sulphur Springs area, in what is now part of the VCNP. The potential of the 

geothermal system was confirmed in 1970 with the drilling of a discovery well (Baca 4) in the 

Redondo Creek area, southeast of Sulphur Springs. In 1971, Union Oil Company leased 

approximately 100,000 acres of private land, known as Baca Location No. 1, and began an active 

drilling program. In 1978, the DOE, Public Service Company of New Mexico, and Union Oil 

Company entered into a cooperative agreement to develop a 50-MW demonstration power plant

at the Baca 4 site; however, in 1982, the participants in the demonstration power plant project 

signed an agreement of non-viability. This terminated the Baca project, due to technical 

difficulties encountered in drilling the steam supply wells. Scarcity and unpredictability of 

production zones, low permeability, and difficulties drilling were identified as the reasons for the 

unsuccessful outcome. In total, Union Oil Company drilled over 20 holes (referred to as Baca 

wells) before terminating the project (Trainer et al. 2000; Molloy 1982). 

1.6.4 Technical Capabilities

New Mexico universities, national laboratories, state agencies, local working groups, and private 

companies contribute technical capabilities to the local and national geothermal communities. 

Research conducted through Sandia National Laboratories has investigated drilling concepts and 

new technology and processes, including tools to make geothermal energy drilling more cost 

efficient. The concept of hot dry rock1geothermal technology originated at Los Alamos National 

 

1 Hot dry rock technology refers to the formation of a fully engineered geothermal reservoir in hot, crystalline 

rock by the application of hydro-shearing techniques and the subsequent circulation of water through that 

engineered reservoir to mine the thermal energy from the hot rock (Duchane and Brown 1995).
Figure 1-4 Chapter 1. Purpose of and Need for Action 1-12 Santa Fe National Forest Geothermal Leasing EIS
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-13

Laboratory (LANL) in the early 1970s (Brown 2009, Brown et al. 2012). Numerous research and 

collaboration studies from the University of New Mexico have contributed to the understanding 

of geothermal and hydrothermal conditions in the state, including SFNF lands. New Mexico 

State University at Las Cruces has conducted geothermal research that resulted in the 

development of a geothermal space-heating system that at one point heated up to 30 campus 

buildings, such as dorms and athletic facilities (BLM and Forest Service 2008).

1.6.5 Electrical Power Generation and Capacity

In the near term, geothermal development in New Mexico is likely for small-scale power (BLM 

and Forest Service 2008). The USGS report titled Assessment of Moderate- and High-Temperature 

Geothermal Resources of the United States estimates a mean probability 170 MW of electrical 

power generation for identified geothermal resources on all lands in New Mexico during the next 

30 years; it predicts a total low-high range of between 53 MW and 343 MW (Williams et al. 2008).

Lopez et al. (2012) investigated technical potential for hydrothermal and enhanced geothermal 

systems by state, given system performance, topographic limitations, environmental, and landuse constraints to estimate the upper boundary of development potential. In New Mexico, total 

estimated technical potential for hydrothermal is 2 gigawatts, and enhanced geothermal systems 

is 180 gigawatts (Lopez et al. 2012).

1.7 Relationship to Forest Service Plans, Policies, and 

Programs

1.7.1 Santa Fe National Forest Plan

The SFNF operates under the direction of the Santa Fe National Forest Plan, as amended (Forest 

Service 1987). The 1987 Forest Plan does not allocate lands as available or unavailable to 

geothermal leasing. 

Goals and forest-wide standards and guidelines relevant to fluid mineral leasing and 

development (i.e., lands and minerals) are summarized below. Standards and guidelines specific 

to management areas in the project area are found in Appendix A, Management Areas and 

Prescriptions from Forest Plan. This list is not comprehensive but instead includes only 

management that is relevant to geothermal leasing. In 2015, the SFNF began the process of 

revising the Forest Plan. The results of this EIS will amend the 1987 Forest Plan.

1.7.1.1 Goals—Minerals

 Support sound energy and minerals exploration and development, where appropriate. 

Administer the mineral laws and regulations to minimize adverse surface resource impacts.

1.7.1.2 Goals—Lands

 Minimize the number of electronic sites and utility corridors by allowing only those that are 

most appropriately located on Forest lands. Use existing corridors, whenever possible from a 

need and resource management standpoint. 

1.7.1.3 Forest-Wide Standards and Guidelines—Minerals 

 G01—Review with the BLM existing withdrawals to ensure compliance with FLPMA. 

Consider release for exploration and development while adequately protecting surface 
Chapter 1. Purpose of and Need for Action

1-14 Santa Fe National Forest Geothermal Leasing EIS

resources. (Note: Forest Service Manual 2561.25 provides direction on managing 

groundwater resources in addition to surface resources).

 G04—Respond in a timely manner to oil and gas, geothermal, and other mineral lease 

applications. Response will normally be within 30 days of receipt of application, but 

extensive public involvement or environmental analysis needs may require more time. Such 

needs will be fully coordinated with the BLM. 

 G05—Control surface uses in mineral operations through plans of operation and permits that 

provide for the following:

 Meeting visual quality objectives

 Preserving water quality

 Protecting watershed values

 Reclaiming the surface to original or characteristic contours or adapting it to serve 

further surface resource uses

 Revegetating or reforesting the surface with appropriate plant species to attain soil 

stability

 Protecting cultural resources

 Protecting threatened and endangered species and other wildlife habitats

 G06—Ensure mineral areas are restored to repair resource damage and remove public safety 

hazards, as needed. Reclamation will be managed for progressive development and 

rehabilitation. Operating plans, including appropriate bonding, will be the means for 

accomplishing this. Backlog work will be programmed and accomplished as opportunities 

arise and funding is made available.

1.7.1.4 Forest-Wide Standards and Guidelines—Lands and Utility Corridors

 Provide for joint use in corridors and combine uses to the extent possible in light of technical 

and environmental constraints. All requests for utility corridors will require a comprehensive 

NEPA environmental analysis. Each management area has been evaluated as to suitability 

for corridor location. The suitability classifications are as follows:

 Exclusion area—No utility corridors are allowed.

 Avoidance area—Utility corridors are not consistent with management area emphasis 

and may require extensive mitigation measures.

 Unclassified area—Utility corridors are permitted after normal environmental analysis.

1.7.2 Memorandum of Understanding Between Forest Service and 

BLM: Implementation of Section 225 of the Energy Policy Act 

of 2005 Regarding Geothermal Leasing and Permitting

In 2006, the BLM and Forest Service signed a Memorandum of Understanding (MOU) to 

facilitate interagency coordination between the Forest Service and BLM, and establish policies 

and procedures to implement Section 225 of the Energy Policy Act of 2005, Public Law 109-58. 

Section 225 requires the coordination of geothermal leasing and permitting on public lands and 

NFS lands between the Secretary of the Interior and Secretary of Agriculture.

The MOU establishes that the Forest Service will take the lead for completing pre-lease NEPA

documents and is responsible for providing the official Forest Service consent or non-consent to 

leasing on NFS lands. The Forest Service and BLM will also identify, through the analysis, 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-15

reasonable and justifiable stipulations needed to protect or minimize impacts on specific 

resources or land uses. 

1.7.3 Programmatic Environmental Impact Statement for 

Geothermal Leasing Exploration and Development

The BLM and Forest Service prepared the 2008 Geothermal PEIS to assess the environmental 

impacts from developing and implementing the geothermal program. It facilitated

environmentally responsible utility-scale geothermal energy development in the following 

Western states: Alaska, Arizona, California, Colorado, Idaho, Montana, New Mexico, Nevada, 

Oregon, Utah, Washington, and Wyoming. Additionally, the 2008 Geothermal PEIS allocated 

NFS lands as open or closed to being considered for geothermal leasing. It also adopted 

stipulations and BMPs and explained the procedures for geothermal leasing and development 

(BLM and Forest Service 2008).

The Forest Service determinations resulting from the 2008 Geothermal PEIS and ROD are as 

follows:

 Identified those NFS lands legally open or closed to leasing

 Developed an RFDS for a potential for 12,210 MW of electrical generating capacity from 

244 power plants in the 12 western states by 2025, plus additional direct uses of geothermal 

resources

 Included stipulations, BMPs, and procedures for geothermal leasing and development

 Recognized that, before making a leasing decision on lands near a National Park Service

(NPS) unit, the BLM or other surface management agency must determine if there would be 

any impacts on thermal or hydrological features in the unit, in accordance with the 

Geothermal Steam Act Amendments (30 USC, Section 1026)

The 2008 Geothermal PEIS noted that designating lands for geothermal leasing potential and 

amending a land use plan, in and of itself, does not cause any direct impacts, as defined by the 

Council on Environmental Quality (CEQ) regulations (40 CFR, Subpart 1508.8[a]). However, it 

is reasonable to foresee that on-the-ground impacts would occur if the BLM were to issue 

geothermal leases but that the impacts would not occur until the future. Therefore, the 2008 

Geothermal PEIS addressed both direct and indirect impacts based on the foreseeable on-theground actions, including exploration, drilling, and utilization.

In Volume I, these impacts were not analyzed site specifically but generically and 

programmatically for the 2008 Geothermal PEIS project area, based on the RFDS. The 2008 

Geothermal PEIS analyzed the broad impacts associated with allocation of geothermal resources

for leasing. It also analyzed the adoption of stipulations and BMPs, based on the assumptions 

presented in the RFDS, in assessing the likely impacts from development following leasing in 

the project area. 

Volume II of the PEIS provided lease-specific analysis to decision-makers to aid them in 

deciding on whether to issue or deny 19 geothermal lease applications that were pending as of 

January 1, 2005. Pending lease applications did not include lands on the SFNF, and no sitespecific analysis for issues associated with on-the-ground actions of geothermal exploration, 

drilling, utilization, or reclamation and abandonment was conducted. Additionally, the 2008 

Geothermal PEIS did not result in a consent determination on NFS lands. Before conducting 

lease sales, the Forest Service must provide the BLM with a consent determination (including 
Chapter 1. Purpose of and Need for Action

1-16 Santa Fe National Forest Geothermal Leasing EIS

terms and conditions or stipulations). As such, this document alone is insufficient to proceed 

with geothermal lease sales and issuance of competitive and noncompetitive leases. The 2008 

Programmatic EIS provides the basis for consent decisions covered in this EIS. 

1.8 Scope of Analysis

The 2008 Geothermal PEIS included an analysis of the potential effects of utility-scale 

geothermal energy development on public lands. That analysis was designed to provide 

environmental consequences, in accordance with NEPA, to support the decision, which 

identified lands legally open to leasing. The SFNF Geothermal Leasing EIS is a separate analysis 

process, with the following purposes:

 Determines if lands in the project area are available for the BLM to lease and, if so, under 

what stipulations for protection of surface resources

 Describes the RFDS for the project area

 Examines the existing environmental setting

 Describes the potential direct, indirect, and cumulative impacts on the human and natural 

environment associated with implementing a range of alternatives

Because the planning and decision area for the SFNF Geothermal Leasing EIS is in the study 

area covered by the 2008 Geothermal PEIS analysis, this EIS will “tier” to the PEIS. Tiering 

refers to the coverage of general matters in a broader EIS; subsequent narrower EISs or 

environmental assessments, such as this one, incorporate by reference the general discussions 

and concentrate solely on the issues specific to the EIS or environmental assessment 

subsequently prepared (40 CFR, Subpart 1508.28). Tiering typically results in a more efficient 

environmental analysis process for future development proposals. The determination of the 

necessary level of additional NEPA analysis is made on a case-by-case basis at the time a project 

is proposed. 

This EIS will tier to those elements of the 2008 Geothermal PEIS that are appropriate for such 

use (e.g., resource impact analysis, stipulations, leasing procedures, and BMPs). Because the 

SFNF Geothermal Leasing EIS presents different site-specific issues than those addressed in the 

2008 Geothermal PEIS, the analysis for this EIS has been refined and may include other 

protective provisions specific to the project area.

The scope of this analysis does not evaluate surface-disturbing geothermal exploration or 

development proposals. Subsequent site-specific projects would require future environmental 

analysis, which could tier to this EIS and the 2008 Geothermal PEIS. The appropriate level of 

environmental analysis would be determined by the authorizing officer. 

1.9 Decision Framework

Given the purpose and need, the deciding official reviews the proposed action, the other 

alternatives, and the environmental consequences in order to make the following decisions:

 What lands would be made available for leasing through a consent determination and any 

stipulations that would be included in future leases the BLM may issue

 What lands would not be available for leasing 

This decision would not authorize lease sale or development of parcels. 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-17

1.10 Public Involvement and Scoping

The formal public scoping comment period, as required by NEPA (40 CFR, Subpart 1501.7), 

began on May 13, 2015, and ended on June 26, 2015. Scoping included the following:

 Notice of intent (NOI) published in the Federal Register on May 13, 2015;

 Media outreach, including press releases and project website 

(http://www.fs.usda.gov/project/?project=46886)

 Scoping letter mailing to those on the project mailing list, including federal, state, and local 

agencies, Native American tribes, special interest groups, and landowners

 Public scoping meetings

The NOI published was entitled Santa Fe National Forest; New Mexico; Geothermal Leasing. It

noted that comments concerning the scope of the analysis must be received by June 12, 2015 (on 

June 8, 2015, the SFNF issued a news release indicating the scoping period was extended to June 

26). The NOI also provided an overview of the proposed action, purpose and need for the 

project, and instructions for submitting comments.

The SFNF issued a press release on May 13, 2015, announcing its intent to prepare an EIS. The 

press release included a link to the NOI, which was published that day. On May 26, 2015, the 

SFNF issued a second press release that included dates, times, and locations for the two 

scheduled public scoping meetings, as well as information on how written comments could be 

submitted. On June 8, 2015, a third press release was issued indicating the SFNF had extended 

the deadline for public comments on the scope of the environmental analysis from June 12 to 

June 26, 2015, to give the public more time to submit comments on the proposed project.

On May 22, 2015, the SFNF e-mailed a scoping letter and scoping document to federal, state, 

and local agencies, special interest groups, landowners, and other interested individuals. Hard 

copies of the scoping letter were also mailed to individuals with no e-mail address on file. The

scoping letter provided a brief overview of the project and included dates and locations of the 

two public meetings and instructions for submitting written comments. The scoping document 

provided a more detailed description of the project: leasing background information, purpose and 

need for action, decision to be made, preliminary issues, scoping process, analysis process, and 

figures showing the project area and proposed closures.

Public scoping meetings were held on June 1, in Cuba, New Mexico and on June 2 in Santa Fe. 

Forest Service staff were available at the meetings to answer questions from attendees, who were 

encouraged to submit written comments so that their concerns could be accurately conveyed and 

formally addressed in the EIS. Comment forms were available at the meetings for attendees to 

fill out and either submit at the meeting or mail in later. 

Results of the public scoping are discussed in detail in the scoping report posted on the project 

website.

The Notice of Availability for the DEIS was published in the Federal Register on July 8, 2016 

(81 Federal Register 44608, July 8, 2016). The opportunity for providing comments to establish 

eligibility to object under 36 CFR, Subpart 219.52, was originally scheduled to end August 22, 

2016, 45 days following the Notice of Availability. The comment period was extended to

October 28, 2016, and a Federal Register amended notice was published on July 29, 2016 (81 

Federal Register 49982, July 29, 2016). 
Chapter 1. Purpose of and Need for Action

1-18 Santa Fe National Forest Geothermal Leasing EIS

The SFNF received comments by mail, fax, and e-mail and at public meetings. It recognizes that 

commenters invested considerable time and effort to submit comments on the DEIS; as such, it 

developed a comment analysis method to ensure that all comments were considered, as directed 

by NEPA regulations. 

The SFNF developed a systematic process for responding to comments to ensure that all were 

tracked and considered. On receipt, each comment letter was assigned an identification number 

and logged into a tracking database. This allowed the SFNF to organize, categorize, and respond 

to comments, which were coded by appropriate categories, based on the content of the comment. 

Similar comments were grouped under a topic heading. The SFNF then drafted a statement 

summarizing the issues contained in each group of comments. The responses were crafted to 

respond to the comments and to note whether a change to the EIS was warranted. (See 

Appendix F, Summary of Public Comments.)

1.11 Tribal Coordination

The Forest Service consults on a government-to-government basis with Native American tribes. 

Consultation and coordination with Native American tribal governments are ongoing. 

Federal agencies must consult with Native American tribes to identify traditional cultural 

properties (TCPs), sacred sites, and properties of religious or cultural significance. The SFNF 

sent letters to tribal leaders and Tribal Historic Preservation Officers, describing the scope of the 

project and inviting them to participate as consulting parties, under the Section 106 consultation 

process. 

The SFNF invited the following federally recognized tribes in the region to consult on the EIS: 

Pueblo of Acoma; Pueblo of Isleta; Kewa Pueblo (Pueblo of Santa Domingo); Pueblo of Nambé; 

Pueblo of Cochiti; Pueblo of Jemez; Pueblo of Laguna; Ohkay Owingeh; Pueblo of Picuris; 

Pueblo de San Ildefonso; Pueblo of Santa Clara; Pueblo of Pojoaque; Pueblo of San Felipe; 

Pueblo of Santa Ana; Pueblo of Taos; Pueblo of Tesuque; Pueblo of Zia; Pueblo of Zuni; Jicarilla 

Apache Nation; Ojo Encino Navajo Chapter House; Pueblo Pintado Navajo Chapter House; 

Canoncito Navajo Chapter House; Ramah Navajo Chapter House; Counselor Navajo Chapter 

House; Crownpoint Navajo Chapter House; Torreon Navajo Chapter House; Whitehorse Lake 

Navajo Chapter House; Mescalero Apache Tribe; The Hopi Tribe; The Navajo Nation; Southern 

Ute Tribe; Ute Mountain Ute Tribe.

The SFNF began consultation before the formal scoping period by mailing a briefing paper to 

tribes on October 14, 2014, which provided an overview of the project, and its status. 

Additionally, meetings were held with tribes in October, 2014, to present information related to 

the project and answer questions. The SFNF held meetings with the following tribes: Pueblo of 

Jemez; Pueblo of Zia; Pueblo of Cochiti; Pueblo of Santa Domingo; Pueblo de San Ildefonso; 

Ohkay Owingeh; Pueblo of Santa Clara; Jicarilla Apache Nation; Counselor Navajo Chapter 

House; and Torreon Navajo Chapter House. 

Tribal scoping letters were sent to the list of tribes, describing the project, date, and times of the 

public meetings and requesting consultation. The SFNF requested information on issues or 

concerns with the project and historic properties in the project area under Section 106 of the 

National Historic Preservation Act (NHPA). The agency held meetings with the San Felipe and 

Santa Clara Pueblo in July and September 2015, and it has continued to honor its obligation to 

consult on a government-to-government basis.
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-19

In support of this final EIS and Southwest Jemez Mountains Landscape Restoration Project, the

SFNF is also conducting an ethnographic overview and assessing traditional and current land 

uses by Native American and other communities. The SFNF is working with descendants of 

Native Americans and Hispanic land grant recipients, who had occupied portions of the Jemez 

Mountains and adjacent areas prehistorically and historically and maintained traditional cultural 

resources and practices associated with those resources.

1.12 Coordination with Other Federal and State Agencies 

The BLM and NPS served as cooperating agencies during preparation of the EIS. Subsections 

1501.6 and 1508.5 of 40 CFR of the CEQ regulations address cooperating agencies, which are 

federal agencies other than a lead agency; they have jurisdiction by law or special expertise with 

respect to any environmental impact involved in a proposal or reasonable alternative. As 

cooperating agencies, the BLM and NPS participated in the scoping process, reviewed and 

provided comments on the specialist reports, reviewed the DEIS before its public release, and 

reviewed draft responses to comments received during the comment period. 

1.13 Issues 

The Forest Service separated the issues into two groups: significant and non-significant. 

Significant issues were defined as those directly or indirectly caused by implementing the 

proposed action. Non-significant issues were identified as the following:

 Those outside the scope of the proposed action

 Those already decided by law, regulation, Forest Plan, or other higher level decision

 Those irrelevant to the decision to be made

 Those conjectural and not supported by scientific or factual evidence

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 reasons regarding 

their categorization as such can be found in the project record.

As for significant issues, the Forest Service identified the following issues during scoping:

1.13.1 Timing and Scope of the Proposal

 Issue—Is the timing and scope of the proposal appropriate, considering the size of the 

project area relative to expression of interest area and the ongoing Forest Plan revision 

process?

 Issue—Considering previous geothermal exploration in the region, how viable is commercial 

geothermal development in the project area?

 Issue—Are there other agencies besides the BLM and NPS that should serve as cooperating 

agencies on this project?

1.13.2 Land Use, Recreation, and Special Designations (Including 

Inventoried Roadless Areas)

 Issue—How would geothermal leasing impact inventoried roadless areas (IRAs) and 

sensitive resources in IRAs?
Chapter 1. Purpose of and Need for Action

1-20 Santa Fe National Forest Geothermal Leasing EIS

 Issue—How would geothermal leasing impact adjacent wilderness areas, lands with 

wilderness characteristics, IRAs, and Areas of Critical Environmental Concern (ACECs) or 

other special designations?

 Issue—How would geothermal leasing affect recreation in the project area? How would 

geothermal leasing affect the JNRA and other nearby recreation areas managed by other 

federal or state agencies?

1.13.3 Geologic Resources

 Issue—What are the impacts on geologic resources from geothermal developments? Could 

there be increased risk for induced seismicity or other geologic hazards as a result of 

geothermal leasing? If so, what are the indirect effects of geologic hazards, considering the 

proximity of the Abiquiu Dam and LANL?

 Issue—Is baseline seismic monitoring or additional fault mapping required to determine the 

risks of induced seismicity or other geologic hazards associated with geothermal exploration

or development?

1.13.4 Water Resources and Quality

 Issue—How would geothermal leasing affect surface and subsurface water quantity? Would 

geothermal leasing change or reduce water allocations for other uses? What are the shortand long-term effects on the regional aquifer?

 Issue—How would geothermal leasing affect water quality, and what size buffers are 

necessary to protect surface waters? How might these effects differ, depending on the type of 

geothermal system?

 Issue—How would geothermal leasing affect the Abiquiu Reservoir and Dam and the New 

Mexico Department of Game and Fish (NMDGF) Habitat Stamp Program water projects?

1.13.5 Air Quality and Air Quality-Related Values

 Issue—How would gases and emissions from geothermal leasing be monitored and 

controlled, and how would residual waste accumulations from air emission management be 

disposed of?

 What are the effects of odors from geothermal leasing, and how would these affect receptors 

in the project area?

1.13.6 Vegetation

 Issue—How would vegetation loss from geothermal leasing affect soil erosion?

 Issue—How would noxious and invasive weeds be managed in geothermal leasing areas?

1.13.7 Wildlife

 Issue—What are the short- and long-term effects of geothermal leasing on cold water

fisheries, wildlife corridors, critical wildlife habitat areas, fish hatcheries, and other 

important or sensitive fish and wildlife habitats in the project area?

1.13.8 Threatened and Endangered Species and Special Status 

Species

 Issue—What are the effects of geothermal leasing on the Mexican spotted owl (MSO), 

Jemez Mountain salamander, New Mexico meadow jumping mouse, Jemez woodland snail, 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-21

Rio Grande cutthroat trout (RGCT), and other threatened and endangered or special status 

species in the project area? What stipulations and mitigation measures are necessary to 

protect these species?

 Issue—Would geothermal leasing displace other resource uses on the forest, such as 

recreation and livestock grazing, into or near threatened and endangered species or special 

status species’ habitats?

1.13.9 Livestock Grazing

 Issue—How would geothermal leasing affect grazing allotments and grazing forage?

1.13.10 Cultural Resources

 Issue—How would cultural resources be affected by geothermal leasing, and how would 

these effects be managed?

1.13.11 Tribal Interests and Traditional Cultural Properties

 Issue—How would TCPs and other tribal interests be affected by geothermal leasing, 

including those in confidential locations, and how would those effects be managed? What 

are the direct, indirect, and cumulative impacts of other resource impacts on tribal interests?

1.13.12 Visual Resources

 Issue—What are the visual impacts associated with geothermal leasing, including 

construction of transmission lines and water vapor from geothermal plants?

1.13.13 Social Interests, Economics, and Environmental Justice

 Issue—How would geothermal leasing affect tourism, local businesses, property values, and 

community services?

 Issue—Would geothermal leasing result in disproportionate impacts on communities, tribes, 

or other populations?

1.13.14 Health and Safety

 Issue—What are the health and safety risks of geothermal leasing? How would geothermal 

leasing affect drinking water, considering the regional geology?

1.13.15 Noise

 Issue—What are the impacts of increased noise in the project area?

1.13.16 Transportation and Access

 Issue—How would increased traffic affect residents, visitors, and other forest users? What 

would be the impacts on road conditions and adjacent buildings as a result of increased 

traffic?

 Issue—How would geothermal leasing affect public access to the SFNF?

1.13.17 Climate Change

 Issue—How would the SFNF address climate change and greenhouse gas (GHG) emissions 

from geothermal leasing?
Chapter 1. Purpose of and Need for Action

1-22 Santa Fe National Forest Geothermal Leasing EIS

 Issue—Would geothermal leasing affect regional weather conditions?

1.13.18 Fire2

 Issue—What stipulations and mitigation measures are necessary to reduce the risk of 

wildfire associated with geothermal energy transmission, and how would geothermal leasing

affect the risk of wildfire?

1.13.19 National Park Service Values3

 Issue—How would geothermal leasing affect the natural, cultural, and sensory resource 

values of the Bandelier National Monument and VCNP, including geothermal resources, and 

what stipulations and mitigation measures are necessary to protect these values?

1.14 Proposed Action

The Forest Service’s proposed action is to determine which lands in the SFNF on the Coyote, 

Cuba, Espanola, and Jemez Ranger Districts would be available for geothermal leasing and 

under what stipulations. This would be implemented by amending the SFNF Forest Plan.

Under the proposed action, certain lands in the project area are excluded from geothermal 

leasing on the basis of existing laws, regulations (43 CFR, Subpart 3201.11), and executive 

orders. Non-discretionary closures are for the JNRA (28,900 acres).

In addition to non-discretionary closures, the Forest Service has the administrative authority to 

issue discretionary closures to protect special resource values. The following areas are proposed 

Forest Service discretionary closures for geothermal leasing:

 Administrative site withdrawals

 Seven Springs (7 acres)

 Encino (184 acres)

 Encino Point (120 acres)

 Cerro Pelado Lookout (160 acres)

About 29,321 acres of NFS lands would be closed by law, regulations, or other authority to 

geothermal leasing in the project area. This represents about 17 percent of the NFS lands in the 

project area. 

All other lands in the project area would be allocated as open to leasing, subject to existing laws, 

regulations, formal orders, stipulations attached to the lease form, and terms and conditions of 

the standard lease form.

No surface occupancy (NSO), controlled surface use (CSU), and timing limitation (TL)

stipulations would be implemented on lands allocated as open to leasing, in accordance with the 

 

2

Issues specific to fire are discussed under Section 3.11, Vegetation, and Section 3.19, Health and Safety.

3

Issues specific to National Park Service values are discussed under Section 3.17, Visual Resources; 

Section 3.20, Noise; Section 3.15, Cultural Resources; Section 3.16, Tribal Interests and Traditional 

Cultural Resources; Section 3.11, Vegetation; Section 3.12, Fish and Wildlife; and Section 3.13, 

Threatened and Endangered Species and Special Status Species. 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-23

guidance provided in the Geothermal PEIS. These allocations are described in detail in 

Chapter 2. 

The lessee and the appropriate federal agency would monitor lease stipulations, conditions of 

approval, and the general operation of geothermal developments to ensure their continued 

effectiveness through all phases of development. Using adaptive management strategies, where 

mitigation measures are determined to be ineffective at meeting the desired resource conditions, 

the BLM and Forest Service would take steps to determine the cause and would require the 

operator to take corrective action. This information would also be used to inform future 

geothermal leasing and development.

1.15 Forest Plan Amendments

The proposed action (Alternative 2) and all action alternatives (Alternatives 3 and 4) each would 

include amendments to the Santa Fe National Forest Plan that would incorporate the geothermal 

leasing restrictions, as the mechanism to implement discretionary and nondiscretionary leasing 

closures in the project area (see Table 1-1, Amendment Language by Alternative for the 

Geothermal EIS). Forest plan amendments are needed to achieve the purpose and need and to 

assure consistency with the forest plan. The forest plan would be amended using the 2012 

Planning Rule (36 CFR 219.13).

Table 1-1. Amendment Language by Alternative for the Geothermal EIS

Forest Plan 

Location 

and Plan 

Component 

Type

Alternative 2 – Proposed 

Action

Alternative 3 – No 

Leasing Alternative

Alternative 4 –

Development Alternative

Forest-wide 

Standard 

(Minerals 

section)

Lands within the Geothermal 

Analysis Area in the Coyote, 

Cuba, Espanola and Jemez 

Ranger Districts (Appendix B 

Figure 2-1) that are closed to 

geothermal leasing include:

 All hot springs, including a 

1-mile protection zone 

around each.

 Administrative sites: Seven 

Springs (7 acres), Encino 

(184 acres), Encino Point 

(120 acres), Cerro Pelado 

Lookout (160 acres).

 The Jemez National 

Recreation Area within the 

Geothermal Analysis Area 

(28,900 acres)

Geothermal leasing outside of 

the Geothermal Analysis Area 

must undergo site-specific 

environmental analysis to 

determine if leases can be 

authorized and what sitespecific stipulations may be 

required.

Lands within the 168,650 

acres of Geothermal 

Analysis Area in the 

Coyote, Cuba, Espanola, 

and Jemez Ranger 

Districts ((Appendix B 

Figure 2-9)) are closed to 

geothermal leasing. 

Geothermal leasing 

outside of the 

Geothermal Analysis 

Area must undergo sitespecific environmental 

analysis to determine if 

leases can be authorized 

and what site-specific 

stipulations may be 

required.

The Jemez National 

Recreation Area within the 

Geothermal Analysis Area 

(28,900 acres) is closed to 

geothermal leasing 

(Appendix B Figure 2-5). 

Geothermal leasing 

outside of the Geothermal 

Analysis Area must 

undergo site-specific 

environmental analysis to 

determine if leases can be 

authorized and what sitespecific stipulations may 

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

1-24 Santa Fe National Forest Geothermal Leasing EIS

Table 1-1. Amendment Language by Alternative for the Geothermal EIS

Forest Plan 

Location 

and Plan 

Component 

Type

Alternative 2 – Proposed 

Action

Alternative 3 – No 

Leasing Alternative

Alternative 4 –

Development Alternative

Forest-wide 

Guideline 

(Minerals 

section)

No surface occupancy for 

geothermal leasing should be 

allowed in the following areas 

(Appendix B Figure 2-2):

• Designated or proposed 

critical habitat for species 

listed under the 

Endangered Species Act

or listed or proposed 

species without designated 

habitat, if it would 

adversely modify the 

habitat.

• Areas with important 

cultural or archeological 

resources, which may 

include, but not be limited 

to:

♦ Traditional cultural 

properties (TCPs) and 

Native American 

sacred sites, as 

identified through 

consultation

♦ Properties listed on or 

eligible for listing on 

the National Register 

of Historic Places

(NRHP), including 

National Landmarks 

and National Register 

Districts and Sites

♦ Additional lands 

outside the designated 

boundaries, to the 

extent necessary to 

protect values where 

the setting and 

integrity are critical to 

their designation or 

eligibility

♦ Areas that qualify for 

cultural resource 

protection, based on 

Forest Plan criteria 

(e.g., Management 

Area I, P, Q, R, S).

• Water bodies, perennial 

and intermittent rivers and 

streams; wetlands, springs, 

playas (NHD mapping); 

500-foot-wide riparian

No surface occupancy for 

geothermal leasing should 

be allowed in the following 

areas (Appendix B Figure 

2-6):

• All hot springs, 

including a 1-mile 

protection zone 

around each.

• Designated or 

proposed critical 

habitat for species 

listed under the 

Endangered Species 

Act or listed or 

proposed species

without designated 

habitat, if it would 

adversely modify the 

habitat.

• Areas with important 

cultural or 

archeological 

resources, which may 

include, but not be 

limited to:

• Traditional cultural 

properties (TCPs) 

and Native American 

sacred sites, as 

identified through 

consultation

• Properties listed on or 

eligible for listing on 

the National Register 

of Historic Places

(NRHP), including 

National Landmarks 

and National Register 

Districts and Sites

• Additional lands 

outside the 

designated 

boundaries, to the 

extent necessary to 

protect values where 

the setting and 

integrity are critical to 

their designation or 

eligibility

• Areas that qualify for 

cultural resource 
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-25

Table 1-1. Amendment Language by Alternative for the Geothermal EIS

Forest Plan 

Location 

and Plan 

Component 

Type

Alternative 2 – Proposed 

Action

Alternative 3 – No 

Leasing Alternative

Alternative 4 –

Development Alternative

protection zones; 100-year 

floodplains.

 A 50-foot zone (measured 

horizontally from the outer 

edge of the ditch) around 

acequias with water rights 

recognized by the New 

Mexico Office of the State 

Engineer (NMOSE).

 Water sources recognized 

by the Drinking Water 

Bureau of the New Mexico 

Environmental Department 

and NMOSE. These 

include drinking water 

sources, wells, springs, 

and a 1-mile protection 

zone around them.

 Slopes in excess of 40 

percent.

 Soils with severe erosion 

potential.

 Developed recreation 

facilities, special-use 

permit recreation sites, and 

areas with significant 

recreational use with which 

geothermal development is 

deemed incompatible (e.g., 

San Antonio Creek 

Recreation Area, Seven 

Springs Recreation Area, 

Paliza Recreation Area).

 Areas with Scenery 

Management System 

integrity levels of very high.

 Inventoried Roadless 

Areas.

protection, based on 

Forest Plan criteria 

(e.g., Management 

Area I, P, Q, R, S).

 Water bodies, 

perennial rivers and 

streams; wetlands, 

springs, playas (NHD 

mapping); 500-footwide riparian 

protection zones; 

100-year floodplains. 

 A 50-foot zone 

(measured 

horizontally from the 

outer edge of the 

ditch) around 

acequias with water 

rights recognized by 

the New Mexico 

Office of the State 

Engineer (NMOSE).

 Drinking water 

sources recognized 

by the Drinking Water 

Bureau of the New 

Mexico 

Environmental 

Department and 

NMOSE and a 1-mile 

protection zone 

around them.

 Hot springs and a 

one-mile protection 

zone around them

 Slopes in excess of 

40 percent.

 Developed recreation 

facilities, special-use 

permit recreation 

sites, and areas with 

significant 

recreational use with 

which geothermal 

development is 

deemed incompatible 

(e.g., San Antonio 

Creek Recreation 

Area, Seven Springs 

Recreation Area, 

Paliza Recreation 

Area, Seven Springs 

Administrative Site, 
Chapter 1. Purpose of and Need for Action

1-26 Santa Fe National Forest Geothermal Leasing EIS

Table 1-1. Amendment Language by Alternative for the Geothermal EIS

Forest Plan 

Location 

and Plan 

Component 

Type

Alternative 2 – Proposed 

Action

Alternative 3 – No 

Leasing Alternative

Alternative 4 –

Development Alternative

Encino Administrative 

Site, Encino Point 

Administrative Site, 

Cerro Pelado Lookout 

Administrative Site).

 Inventoried Roadless 

Areas.

Forest-wide 

Guideline 

(Minerals 

section)

Controlled surface use 

stipulations that could require 

future geothermal leasing 

activities or development be 

modified or relocated from the 

proposed location if necessary 

to protect resources should 

apply in the following areas and 

site conditions (Appendix B 

Figure 2-3):

 Slopes between 30 and 40 

percent.

 Important dispersed 

motorized and 

nonmotorized recreation 

areas.

 Areas with Scenery 

Management System 

integrity levels of high.

Controlled surface use 

stipulations that could 

require future geothermal 

leasing activities or 

development be modified 

or relocated from the 

proposed location if 

necessary to protect 

resources should apply in 

the following areas and 

site conditions (Appendix 

B Figure 2-7):

 Intermittent streams 

listed in the NHD and 

ephemeral drainages 

delineated by sitespecific mapping.

 New Mexico Office of 

the State Engineer 

(NMOSE) recognized 

springs and permitted 

wells.

 Slopes between 30 

and 40 percent.

 Soils with severe 

erosion potential.

 Important dispersed 

motorized and 

nonmotorized 

recreation areas.

 Areas with Scenery 

Management System 

integrity levels of very 

high and high.

Forest-wide 

Guideline 

(Minerals 

section)

Timing limitation stipulations for 

drilling and construction related 

to geothermal leasing should 

be prohibited in (Appendix B 

Figure 2-4):

 Mexican spotted owl 

designated protected 

activity centers between 

March 1 and August 31.

 Northern goshawk 

designated post-fledging 

Timing limitation 

stipulations for drilling and 

construction related to 

geothermal leasing should 

be prohibited in (Appendix 

B Figure 2-8):

 Mexican spotted owl 

designated protected 

activity centers 

between March 1 and 

August 31.
Chapter 1. Purpose of and Need for Action

Santa Fe National Forest Geothermal Leasing EIS 1-27

Table 1-1. Amendment Language by Alternative for the Geothermal EIS

Forest Plan 

Location 

and Plan 

Component 

Type

Alternative 2 – Proposed 

Action

Alternative 3 – No 

Leasing Alternative

Alternative 4 –

Development Alternative

areas between March 1 

and September 30.

 Peregrine falcon eyrie 

nesting areas between 

March 1 and August 15.

 Elk calving areas between 

June 1 and July 31.

 Northern goshawk 

designated postfledging areas 

between March 1 and 

September 30.

 Peregrine falcon eyrie 

nesting areas 

between March 1 and 

August 15.

 Elk calving areas 

between June 1 and 

July 31.

Forest-wide 

Guideline 

(Minerals 

section)

Geothermal lessees should not 

be allowed to perform any 

vegetation clearing within 

migratory bird nesting areas 

between May 15 and July 31.

Geothermal lessees 

should not be allowed to 

perform any vegetation 

clearing within migratory 

bird nesting areas 

between May 15 and July 

31.
Chapter 1. Purpose of and Need for Action

1-28 Santa Fe National Forest Geothermal Leasing EIS

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Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-1

Chapter 2. Alternatives, Including the Proposed 

Action

2.1 Introduction

This chapter provides the details of the proposed action, the alternatives to the proposed action, a

discussion of alternatives considered but eliminated from detailed analysis, and an overview of 

the RFDS for geothermal resources in the SFNF. Also in this section is a comparison of the 

alternatives, sharply defining the differences between each alternative and providing a clear basis 

for choice among options by the decision-maker and the public.

After the public scoping period closed on June 26, 2015, the SFNF began developing 

alternatives. Based on public input, the interdisciplinary team’s analysis of the current 

management situation and resource data, and the defined purpose and need for the project, the 

Forest Service developed four alternatives, including a no action alternative. Each of the 

alternatives denotes whether the SFNF would consent to leasing land in the decision area and 

which lease stipulations would apply. Differences between alternatives are expressed by whether 

the SFNF would consent to leasing land and the degree of stipulation constraints applied to those 

areas. 

2.1.1 Lands Available for Geothermal Leasing

The geothermal leasing regulations (43 CFR, Part 3201) describe the types of lands available and 

unavailable for geothermal leasing. The BLM may issue geothermal leases on Forest Service lands 

that are available for leasing in the land use planning process. Exceptions to this are identified as 

lands closed to geothermal leasing; this denotes an area that is not available for geothermal leasing, 

exploration, or development for nondiscretionary or discretionary reasons. The 2008 Geothermal 

PEIS identified certain classifications of lands as excluded from geothermal leasing, based on a 

nondiscretionary or discretionary basis. Nondiscretionary closures would be for lands that are 

excluded based on existing laws, regulations (43 CFR, Subpart 3201.11), and executive orders. For

both the action and no action alternatives, nondiscretionary closed lands or lands where consent 

would not be granted for leasing are approximately 28,900 acres of NFS lands in the JNRA (of the 

32,900 total acres—including non-NFS lands—in the JNRA). 

2.2 Stipulations, Best Management Practices, and 

Procedures

This section describes the types of constraints that would be applied as appropriate to any new 

leases for lands that are available for geothermal leasing. The SFNF developed stipulations, 

BMPs, and procedures based on the 2008 Geothermal PEIS and through the assessment process 

for this EIS. These stipulations were selected for inclusion based on a comprehensive review of 

the SFNF Forest Plan, program guidance, geothermal development activities, published data on 

geothermal development impacts, industry standards, and best professional judgment. Other 

reports on fluid mineral leasing and development (e.g., oil and gas) were consulted because of 

the similarity of most of the activities and impacts, such as from exploration, drilling, and site 

development. Where the agency determines that particular stipulations may be inappropriate for 

a planning area, the procedures for waivers, exceptions, and modifications would be followed.
Chapter 2. Alternatives, Including the Proposed Action

2-2 Santa Fe National Forest Geothermal Leasing EIS

A detailed description of stipulations by alternative is provided in Appendix B, Stipulations and 

Closures by Alternative. A list of BMPs is provided in Appendix C, Best Management Practices 

and Mitigation Measures. 

2.2.1 Lease Stipulations

Lease stipulations are major or moderate constraints applied to a new geothermal lease. A lease 

stipulation is a condition of lease issuance that provides a level of protection for other resource 

values or land uses by restricting lease operations during certain times or at certain locations or 

by mitigating unacceptable impacts, to an extent greater than standard lease terms or conditions. 

A stipulation is an enforceable term of the lease contract; it supersedes any inconsistent 

provisions of the standard lease form and is attached to and made a part of the lease. Lease 

stipulations further implement the Forest Service’s and BLM’s regulatory authority to protect 

resources or resource values.

Stipulations provided in this EIS would serve as the minimal level of protection and would be 

adopted into the Forest Plan when the ROD is signed. It may be necessary to add, delete, or 

modify lease stipulations in the Forest Plan. This would happen as a result of pre-lease issuance 

parcel reviews, statewide lease stipulation consistency reviews, plan amendments, changed 

circumstances on the ground, or changed resource protection priorities. This is accomplished and 

documented either through the plan maintenance process (for minor changes consistent with an 

approved plan) or the plan amendment process (for changes resulting in modification of terms, 

conditions, or decisions in an approved plan).

More than one stipulation may apply to a parcel of land. For example, a parcel may have an NSO

stipulation to protect a property listed on the National Register of Historic Places (NRHP), a

CSU stipulation to protect a recreation area, and a TL for big game winter range.

2.2.2 Lease Exceptions, Waivers, and Modifications

To ensure leasing decisions remain appropriate in light of continually changing circumstances 

and new information, the Forest Service and BLM develop and apply lease stipulation 

exceptions, waivers, and modification criteria. An exception, waiver, or modification (defined 

below) may not be approved unless the BLM Authorized Officer determines that the factors 

leading to the stipulation’s inclusion in the lease have changed sufficiently to make the 

protection provided by the stipulation no longer justified, or the proposed operations would not 

cause unacceptable impacts (43 CFR, Subpart 3101.1-4).

 An exception is a one-time exemption for a particular site within the leasehold and is

determined on a case-by-case basis; the stipulation continues to apply to all other sites within 

the leasehold. An exception is a limited type of waiver.

 A waiver is a permanent exemption from a lease stipulation. The stipulation no longer 

applies anywhere within the leasehold. 

 A modification is a change to the provisions of a lease stipulation, either temporarily or for 

the term of the lease. Depending on the specific modification, the stipulation may or may not 

apply to all sites within the leasehold to which the restrictive criteria are applied.

Requests from the operator should contain, at a minimum, a plan with the following information:

 Related on-site or off-site mitigation efforts, to adequately protect affected resources

 Data collection and monitoring efforts
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-3

 Time frames for beginning and completing the proposed project

The BLM Authorized Officer will require the operator to submit a written request for an 

exception, waiver, or modification and information demonstrating one of the following:

 The factors leading to the inclusion of the stipulation in the lease have changed sufficiently 

to make the protection provided by the lease stipulation no longer justified.

 The proposed operation would not cause unacceptable impacts. 

The SFNF must analyze and document how the exception, waiver, or modification conforms

with the Forest Plan. It must identify the plan decision (including goals, objectives, or desired 

outcomes) supported by the proposed exception, waiver, or modification. If existing NEPA

analysis does not support the exception, waiver, or modification, the Forest Service must conduct 

the appropriate environmental review and NEPA analysis. If the proposed exception, waiver, or 

modification is not in conformance with the Forest Plan or that document does not disclose the 

conditions under which such proposed change would be allowed, the Forest Service must either 

amend the plan or deny the request for exception, waiver, or modification.

During the review process, the BLM Authorized Officer will coordinate with other state or 

federal agencies, as appropriate, and will document the outcome. For example, it may be 

appropriate to coordinate the review of wildlife exceptions, waivers, and modifications with 

NMDGF staff; review and recommendations will be documented, along with any necessary 

mitigation, and provided to the BLM Authorized Officer for approval or disapproval. The 

applicant will then be provided with a written notification of the decision.

Public notification (30-day public review), if required, should both identify the modified lease 

terms and describe the affected lands on a map. When public notification is required, the 

following procedures may apply:

 Approval of an exception, waiver, or modification at the same time the grounddisturbing activity is approved—A notice describing the modified lease terms, when 

required, may be posted for 30 days in the SFNF offices, on the SFNF website, or in a local 

paper as a legal notice or incorporated into a newspaper article. Or the notice may be included 

as part of the NEPA document’s public review, if the document is offered for review.

 Approval of an exception, waiver, or modification after the ground-disturbing activity 

is approved—Public notice, if required, may take the form of a 30-day posting on the SFNF 

website, a legal notice or article in the newspaper, or a notice and associated public review 

conducted as part of the NEPA analysis process.

2.2.3 No Surface Occupancy Lease Stipulation

NSO stipulations are considered a major constraint, because they do not allow for surface 

development. For example, a lessee of an NSO area must develop any surface infrastructure 

outside the NSO area. The lessee would need to use advanced technology, such as directional 

drilling, to access the geothermal resource under the NSO area. An NSO is appropriate when the 

standard terms and conditions, CSU stipulations, TLs, and BMPs for permit approval are 

determined to be insufficient to achieve the resource protection objectives.
Chapter 2. Alternatives, Including the Proposed Action

2-4 Santa Fe National Forest Geothermal Leasing EIS

2.2.4 Timing Limitations and Controlled Surface Use Lease 

Stipulations

Where standard lease terms and permit-level decisions are deemed insufficient to protect 

sensitive resources but where an NSO is deemed overly restrictive, the Forest Service would 

apply seasonal or TL or CSU stipulations to leases.

In general, TLs are used to protect resources that are sensitive to disturbance during certain 

periods. Such stipulations are generally applicable to specific areas, seasons, and resources. They 

are commonly applied to wildlife activities and habitat, such as winter range for deer and elk, 

nesting habitat for raptors and migratory birds, and wildlife breeding areas. The SFNF 

Authorized Officer would apply TLs as appropriate for the specific lease areas. 

A CSU allows the Forest Service to require that any future activity or development be modified 

or relocated from the proposed location if necessary to protect resources. The project applicant 

would be required to submit a plan to meet the resource management objectives through special 

design, construction, operation, mitigation, or reclamation measures or relocation. Unless the 

plan is approved, surface occupancy would not be allowed in the CSU stipulation area.

2.2.5 Best Management Practices

In addition to lease stipulations, during any subsequent exploration, drilling, utilization, or 

reclamation and abandonment of geothermal resources, the SFNF may require project-specific 

mitigation measures to permits. A list of BMPs, provided in Appendix C, was developed based 

on the following:

 Programmatic EIS for Geothermal Leasing in the Western United States (BLM and Forest 

Service 2008)

 Forest Service National Best Management Practices for Water Quality Management on 

National Forest System Lands 

 Forest Service Handbook ([FSH]; Southwestern Region) FSH 2509.22 – Soil and Water 

Conservation Handbook

 Santa Fe National Forest Plan, as amended (Forest Service 1987)

The BMPs detailed in Appendix C would be incorporated as appropriate into the permit 

application or would be included in the approved use authorization by the BLM as COAs. When 

implementing the BMPs, the BLM and Forest Service would work with an affected lessee early 

in the process to explain how BMPs may fit into its development proposals and how BMPs can 

be implemented with the least economic impact on the lessee. 

The BLM and Forest Service would discuss potential resource impacts with the lessee and would 

seek the operator’s recommended solutions. The BLM and Forest Service would also encourage the 

lessee to incorporate necessary and effective BMPs into its project proposals, as determined to be 

appropriate during site-specific, project-level environmental analysis. BMPs not incorporated into 

the lessee’s permit applications may be considered and evaluated through the environmental review 

process and incorporated into the use authorization as COAs or right-of-way (ROW) stipulations.

2.2.6 Monitoring

The lessee and the appropriate federal agency would monitor such measures as lease stipulations 

and COAs, as well as the general operation of geothermal developments. This would be done to 
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-5

ensure the continued effectiveness of the stipulations and COAs through all phases of 

development, as described in the 2008 Geothermal PEIS (BLM and Forest Service 2008). Using 

adaptive management strategies, where mitigation measures are determined to be ineffective at 

meeting the desired resource conditions, the BLM and SFNF would determine the cause and 

would require the operator to take corrective action. The two agencies would also use this 

information to inform future geothermal leasing and development.

2.2.7 Procedures Prior to Leasing

Pre-lease procedures would follow guidance identified in the 2008 Geothermal PEIS (BLM and 

Forest Service 2008). The stipulations listed above would also be used to help achieve resource 

protection, in accordance with laws and regulations. 

The SFNF would provide a consent determination (including terms and conditions or 

stipulations) to the BLM prior to any parcels on NFS lands being offered for lease sale. 

2.3 Alternatives Considered in Detail

After the public scoping period closed, on June 26, 2015, the SFNF began developing alternatives.

The Forest Service developed four alternatives, including the No Action Alternative. This was

based on public input, the interdisciplinary team’s analysis of the current management situation 

and resource data, and the defined purpose and need for the project. Much of the GIS data used in 

developing the alternatives is based on remote sensing, and has not been field verified. 

A summary of lands closed and available to leasing for the action alternatives is provided in 

Table 2-1. For figures showing the locations of closures and stipulations, see Appendix B, 

Stipulations and Closures by Alternative.

2.3.1 Alternative 1—No Action

2.3.1.1 No Action 

NEPA regulations require an agency conducting an EIS to “include the alternative of no action” 

(40 CFR, Subpart 1502.14). Under the no action alternative, the present course of management,

based on the current forest plan, would continue. The Forest Plan would not be amended.

Under the no action alternative, the SFNF would not make an availability determination for 

geothermal leasing on lands in the project area. Geothermal lease applications and nominations 

would continue to be processed; however, they would be evaluated on a case-by-case basis under 

separate NEPA analyses, in accordance with the Forest Plan and existing laws and regulations. 

The JNRA (approximately 28,900 acres) would remain closed to geothermal leasing. This 

alternative does not meet the purpose and need. 

2.3.2 Alternative 2—The Proposed Action

Under the proposed action, the Forest Plan would be amended. Land in the project area 

administered by the Forest Service would be identified as being closed to geothermal leasing,

under either nondiscretionary or discretionary authorities, or would be identified as open to 

geothermal leasing, with possible moderate constraints (TLs and CSU stipulations) or major 

constraints (NSO stipulations). 
Chapter 2. Alternatives, Including the Proposed Action

2-6 Santa Fe National Forest Geothermal Leasing EIS

Table 2-1. Summary of Acres Open and Closed to Geothermal Leasing, by Alternative1, 2, 3

Allocation Alternative

Alternative 2

Acres/percent of 

decision area

Alternative 3

Acres/percent of 

decision area

Alternative 4

Acres/percent of 

decision area

Closed to geothermal 

leasing

32,000

19

168,600

100

28,900

17

Open to geothermal 

leasing, subject to NSO

stipulations

132,900

79

0

0

122,500

73

Open to geothermal 

leasing, subject to CSU

stipulations

80,300

48

0

0

122,600

73

Open to geothermal 

leasing, subject to TLs

39,500

23

0

0

42,200

25

Open to geothermal 

leasing, subject to 

standard lease terms 

and conditions

1,400

1

0

0

3,800

2

Available for surface 

occupancy4

3,700

2

(largest parcel = 300 

acres)

0

0

17,200

10

(largest parcel = 1,900 

acres)

Source: Forest Service GIS 2015

1 NSO, CSU, and TLs do not overlap areas closed to leasing.

2 Multiple NSO, CSU, and TLs overlap each other; and all would apply. Exceptions, modifications, or waivers may be 

applied to some stipulations.

3 Acres identified as closed or open to geothermal leasing, subject to stipulations, are not provided for in Alternative 1, 

as the SFNF would not make an availability determination for geothermal leasing under this alternative.

4

Lands that are neither closed to leasing nor subject to NSO stipulations are considered available for surface 

occupancy.

2.3.2.1 Lands Closed to Leasing

The Forest Service has determined that certain lands in the project area are excluded from 

geothermal leasing on the basis of existing laws, regulations (see 43 CFR, Subpart 3201.11), and 

executive orders. This would be the case for NFS lands in the JNRA; approximately 28,900 acres.

1

In addition to making nondiscretionary closures, the Forest Service has the administrative 

authority to issue discretionary closures to protect special resource values. 

The following areas are proposed Forest Service discretionary closures for geothermal leasing:

2

 

1 Wilderness areas and the segment of the East Fork of the Jemez River designated as wild under the Wild 

and Scenic Rivers Act were listed in the alternatives presented during the public scoping period. They are 

deleted because there are no wilderness areas within the project area, and the Wild segment of the East 

Fork of the Jemez River is within the JNRA.

2 This list originally included National Historic Trails, but there are no designated National Historic Trails 

in the project area, the Jemez Mountain National Scenic Byway, Jemez Historic Site National Landmark, 

and Monument Canyon Research Natural Area, all of which are in the JNRA.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-7

 Hot springs and a 1-mile radius protection zone around them

 Administrative site withdrawals3

 Seven Springs (7 acres)

 Encino (184 acres)

 Encino Point (120 acres)

 Cerro Pelado Lookout (160 acres)

Approximately 32,000 acres of Forest Service lands would be closed (by law, regulations, or 

other authority) to geothermal leasing within the project area. 

2.3.2.2 Lands Available for Leasing

Under the proposed action approximately 136,650 acres of the Forest Service lands in the project

area would be available for geothermal leasing. This would be subject to existing laws,

regulations, formal orders, and stipulations attached to the lease form and its terms and 

conditions.

No Surface Occupancy

NSO stipulations would apply to the following:4

 Designated or proposed critical habitat for listed species under the Endangered Species Act

(ESA) of 1973 (as amended) if it would adversely modify the habitat. For listed or proposed 

species without designated habitat, NSO would be implemented to the extent necessary to 

avoid jeopardy.

 Areas with important cultural and archaeological resources, such as

 Traditional cultural properties and Native American sacred sites, as identified through 

consultation5

 Properties listed on or eligible for listing on the NRHP, including National Landmarks 

and National Register Districts and Sites

 

3 This list originally included La Cueva, Sulphur Flat, and Las Conchas, all of which are in the JNRA.

4 NSO stipulations were originally proposed for the segments of the East Fork of the Jemez River

designated as Scenic or Recreational; however, these segments are within the JNRA, which is closed to 

geothermal leasing. In addition, NSO stipulations were originally proposed for segments of rivers 

determined to be potentially eligible for status under the Wild and Scenic Rivers Act which have not been 

listed, but there are none within this category at present. Natural Geothermal Features were inadvertently 

listed as NSO; however, they are classified as not available for leasing.

5 Whether there are TCPs in an area is determined during the identification stage of the Section 106 

process of the NHPA. Because this has not yet occurred, no TCPs have been formally identified in the 

Geothermal EIS project area; however, any action requiring further identification, evaluation, or effects 

determination and resolution associated with Section 106 could result in the identification of a TCP at that 

time. Designation of a TCP may not mandate specific management, such as an NSO determination; 

nevertheless, that management may be applied, if it is determined that a TCP may be adversely affected by 

a project. This would be the case if an NSO were stipulated as a mitigation, in addition to other 

stipulations that may be agreed to in consultation between federal agencies, the State Historic Preservation 

Officer (SHPO), the Advisory Council, and consulting parties. All leasing stipulations must be applied 

before a lease is issued, so a TCP designated before leasing would trigger the NSO stipulation. If a TCP 

were designated after the lease is issued and lease development activities could adversely affect the 

qualities that make the TCP eligible for the National Register, then BMPs (“stipulations,” as used in the 

NHPA) to protect those qualities would be required.
Chapter 2. Alternatives, Including the Proposed Action

2-8 Santa Fe National Forest Geothermal Leasing EIS

 Additional lands outside the designated boundaries, to the extent necessary to protect 

values where the setting and integrity are critical to their designation or eligibility

 Areas that qualify for cultural resource protection, based on Forest Plan criteria

 Water bodies; perennial and intermittent rivers and streams;

6 wetlands, springs, and playas 

(mapped in the USGS National Hydrography Dataset [NHD]); riparian areas; 100-year 

floodplains surrounding some features are protected by a 500-foot-wide protection zone. 

 Acequias7are not included in the NHD and will need to be delineated on-site. Acequias with 

water rights recognized by the NMOSE would be protected by a protection zone of 50 feet, 

measured horizontally from the outer edge of the ditch.

 Water sources recognized by the Drinking Water Bureau of the New Mexico Environmental 

Department (NMED-DWB) and NMOSE. These include drinking water sources, wells, 

springs, and a 1-mile protection zone around them.

 Slopes in excess of 40 percent. 

 Soils with severe erosion potential.

 Developed recreation facilities, special-use permit recreation sites, and areas with significant 

recreational use with which geothermal development is deemed incompatible8

 San Antonio Creek Recreation Area

 Seven Springs Recreation Area

 Paliza Recreation Area

 Forest Service lands with a Scenery Management System integrity level of very high.

 Inventoried roadless areas.

Approximately 132,900 acres of Forest Service lands would be available to leasing under 

Alternative 2, subject to NSO stipulations. 

Controlled Surface Use

CSU stipulations would apply to the following areas and site conditions:

 Protection of slopes between 30 and 40 percent—This stipulation would be applied to 

minimize the potential for soil erosion on these slopes.

9

 Protection of important dispersed recreational areas—This stipulation would be applied to 

minimize the potential for adverse impacts on recreational values, both motorized and 

nonmotorized, and the natural settings associated with the recreation.

 Protection of viewsheds with a Scenery Management System integrity level of high.

Under Alternative 2, approximately 80,300 acres of Forest Service lands would be available to 

leasing, subject to CSU stipulations. Of these lands, approximately 78,200 acres are also subject 

to NSO stipulations. 

 

6

Perennial and intermittent rivers and streams were added to this listing for clarity. Ephemeral streams 

were removed, and acequias were moved to their own NSO stipulation.

7 Man-made ditches to bring irrigation water from the highlands to privately owned agricultural lands. A 

new NSO stipulation was created to address acequias.

8 This list originally included Jemez Falls, East Jemez, Horseshoe Springs, Las Conchas, Jemez Canyon, 

Redondo, San Antonio Creek, Battleship Rock, La Cueva, Laughing Water, and Sulphur Flat Summer 

Home Area, all of which are in the JNRA.

9 This CSU stipulation was added, because it had been inadvertently left off the original list.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-9

Timing Limitation Stipulations

TLs would apply to the following areas:

10

 Mexican spotted owl designated protected activity centers (PACs)—Drilling and 

construction would be prohibited between March 1 and August 31.

 Northern goshawk designated post-fledging areas (PFAs)—Drilling and construction would 

be prohibited between March 1 and September 30.

 Peregrine falcon eyrie nesting areas—Drilling and construction would be prohibited between 

March 1 and August 15.

 Elk Calving Areas—Drilling and construction would be prohibited between June 1 and July 

31.11

Approximately 39,500 acres would be available to leasing under Alternative 2, subject to TL

stipulations. Of these lands, approximately 23,800 acres are also subject to CSU stipulations, and 

approximately 39,400 acres are also subject to NSO stipulations.

Standard Lease Terms and Conditions

Under Alternative 2, approximately 1,400 acres would be open to leasing, subject to standard 

lease terms and conditions; that is, they would not be subject to closures or NSO, CSU, or TL

stipulations, as described above. 

Notice to Lessee

The notice to lessee of no vegetation clearing between May 15 and July 31 would be applied in 

migratory bird nesting areas.

2.3.3 Alternative 3—No Leasing

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. This 

alternative was developed in response to comments received from the public and tribes during 

scoping. Alternative 3 is contrary to program direction and mandate to make mineral and energy 

resources available, but it is supportable due to resource concerns and level of protection needed.

This alternative may prevent geothermal development on private land in and adjoining the 

project area due to federal resource drainage issues.

2.3.3.1 Lands Closed to Leasing

Under Alternative 3, 194,900 acres would be closed to leasing, including nondiscretionary closed 

lands in the JNRA.

2.3.3.2 Lands Available for Leasing

There would be no lands available for leasing in the project area under Alternative 3.

 

10 This list originally included deer and elk winter range, but that was removed because none is identified 

in the project area. Migratory bird nesting areas were removed from the TLs and will be included as a 

notice to lessee.

11 No deer fawning areas were identified, so that designation was removed.
Chapter 2. Alternatives, Including the Proposed Action

2-10 Santa Fe National Forest Geothermal Leasing EIS

2.3.4 Alternative 4—Development Alternative

Developed to complete the range of alternatives, Alternative 4 incorporates the BLM’s 

information on the RFDS of geothermal resources; therefore, it focuses on the Leasing Interest 

Unit (i.e., Pending Lease Unit) and the Northern Unit. The Forest Plan would be amended.

2.3.4.1 Lands Closed to Leasing

The Forest Service has determined that certain lands in the project area are excluded from 

geothermal leasing on the basis of existing laws, regulations (43 CFR, Subpart 3201.11), and 

executive orders. These non-discretionary closures include approximately 28,900 acres in the 

JNRA. There would be no discretionary closures under Alternative 4. In total, 28,900 acres 

would be closed to geothermal leasing.

2.3.4.2 Lands Available for Leasing

Under the proposed action, approximately 139,800 acres of Forest Service lands in the project

area would be available for geothermal leasing. This would be subject to existing laws,

regulations, formal orders, and stipulations attached to the lease form and to the terms and 

conditions of the standard lease form.

No Surface Occupancy

NSO stipulations would apply to the following:

 Hot springs, and a 1-mile protection zone around them.

 Designated or proposed critical habitat for listed species under the ESA of 1973 (as 

amended) if it would adversely modify the habitat. For listed or proposed species without 

designated habitat, NSO would be implemented to the extent necessary to avoid jeopardy.

 Areas with important cultural and archaeological resources, such as

 Traditional cultural properties and Native American sacred sites, as identified through 

consultation

 Properties listed on or eligible for listing on the NRHP, including National Landmarks 

and National Register Districts and Sites

 Additional lands outside the designated boundaries, to the extent necessary to protect 

values where the setting and integrity are critical to their designation or eligibility

 Areas that qualify for cultural resource protection, based on Forest Plan criteria

 Water bodies; perennial rivers and streams; riparian areas, wetlands, and playas; 100-year 

floodplains; and a 500-foot-wide protection zone around them

 Acequias, which are not included in the NHD and will need to be delineated on-site;

acequias with NMOSE-recognized water rights would have a protection zone of 50 feet, 

measured horizontally from the outer edge of the ditch

 Drinking water sources recognized by NMED-DWB and a 1-mile protection zone around them

 Developed recreation facilities, special-use permit recreation sites, areas with significant 

recreation where geothermal development is deemed incompatible, and the following 

administrative sites

 San Antonio Creek Recreational Area

 Seven Springs Recreation Area

 Paliza Recreation Area

 Seven Springs Administrative Site
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-11

 Encino Administrative Site

 Encino Point Administrative Site

 Cerro Pelado Lookout Administrative Site

 Inventoried roadless areas

 Slopes in excess of 40 percent

Approximately 122,500 acres of Forest Service lands would be available to leasing under 

Alternative 4, subject to NSO stipulations.

Controlled Surface Use

CSU stipulations would apply to the following areas and site conditions:

 Intermittent streams listed in the NHD and ephemeral drainages delineated by site-specific 

mapping

 NMOSE-recognized springs and all NMOSE-permitted wells

 Protection of slopes between 30 and 40 percent; this stipulation would be applied to 

minimize the potential for soil erosion on these slopes

 Soils with severe erosion potential

 Protection of important dispersed recreational areas; this stipulation would be applied to 

minimize the potential for adverse impacts on recreational values, both motorized and 

nonmotorized, and the natural settings associated with the recreation

 Viewsheds with a Scenery Management System integrity level of very high and high

Approximately 122,600 acres of Forest Service lands would be available for leasing under 

Alternative 4, subject to CSU stipulations. Of these lands, approximately 78,200 acres are 

subject to NSO stipulations.

Timing Limitations

TLs would apply as appropriate to the following areas:

 Mexican spotted owl designated PACs—Drilling and construction would be prohibited 

between March 1 and August 31.

 Northern goshawk designated post-fledging areas—Drilling and construction would be

prohibited between March 1 and September 30.

 Peregrine falcon eyrie nesting areas—Drilling and construction would be prohibited between 

March 1 and August 15.

 Elk calving areas—Drilling and construction would be prohibited between June 1 and July 31.

Approximately 42,200 acres of Forest Service lands would be available to leasing under 

Alternative 4, subject to TL stipulations. Of these lands, approximately 36,900 acres are also 

subject to CSU stipulations, and approximately 41,800 acres are also subject to NSO

stipulations.

Standard Lease Terms and Conditions

Under Alternative 4, approximately 3,800 acres would be open to leasing, subject to standard 

lease terms and conditions; that is, they would not be subject to closures or NSO, CSU, or TL

stipulations, as described above. 
Chapter 2. Alternatives, Including the Proposed Action

2-12 Santa Fe National Forest Geothermal Leasing EIS

Notice to Lessee

The notice to lessee of no vegetation clearing between May 15 and July 31 would be applied in 

migratory bird nesting areas.

2.4 Alternatives Considered but Eliminated from Detailed 

Study

NEPA requires federal agencies to rigorously explore and objectively evaluate all reasonable 

alternatives and to briefly discuss the reasons for eliminating any that were not developed in 

detail (40 CFR, Subpart 1502.14). Through their comments on the proposed action, the public 

suggested alternative methods for achieving the purpose and need. Some of these alternatives 

may have been outside the scope of identifying lands as being open or closed to leasing, were 

duplicative of the alternatives considered in detail, or were determined to be components that 

would cause unnecessary environmental harm. These suggested alternatives were considered but 

dismissed from detailed consideration for the reasons summarized below.

2.4.1 Reduced Project Area

Under a reduced project area alternative, the SFNF would evaluate future geothermal leasing

only in the 46,000 acres where the BLM has received expressions of interest in leasing. This 

alternative was considered but eliminated from detailed analysis because it fails to address the

potential for future lease nominations on other lands with significant geothermal potential on the 

SFNF. In these areas, geothermal lease applications and nominations would be evaluated on a 

case-by-case basis under separate NEPA analyses. This could yield delays and inefficient 

consideration of future project planning.

2.4.2 Enlarged Project Area

Under an enlarged project area alternative, the SFNF would evaluate future geothermal leasing

on additional lands within the SFNF (beyond the currently defined project area boundary of 

194,000 acres). This would include lands east of the project area boundary. This alternative was 

considered but eliminated from detailed analysis due to limited geothermal potential and existing 

constraints on geothermal development potential.

2.4.3 Alternative with Stipulations and No Exceptions, Waivers, or 

Modifications

Under this alternative, geothermal stipulations would be applied, as described under the 

proposed action alternative; however, no lease exceptions, waivers, or modifications would be 

granted. This alternative was considered but eliminated from detailed analysis because some 

stipulations are based on resources that are not permanent, fixed geographic points, or polygons 

and may change over time. For example, an NSO stipulation would be applied to designated 

critical habitat for species listed under the ESA, and a TL stipulation would be applied to elk

calving areas. Species may become delisted over time, or elk calving areas may change, based on 

forage availability. Non-consent for resources that are dynamic, such as those examples provided 

above, would not allow for adaptive management when circumstances change.

2.4.4 Compensatory Off-Site Mitigation

Under this alternative, the Forest Service would require compensatory off-site mitigation for 

unavoidable impacts that may result from geothermal leasing. This alternative was considered 
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-13

but eliminated from detailed analysis because the extent and level of detail regarding adverse or 

unavoidable impacts for specific geothermal land use authorizations is unknown at this time.

2.4.5 Wilderness Protection

Under the wilderness protection alternative, the SFNF would apply the stipulations described 

under the proposed action; however, IRAs and lands meeting wilderness planning criteria (FSH 

1909.12, Land Management Planning Handbook, Chapter 70 – Wilderness Evaluation), would 

be closed to leasing. This alternative was considered but eliminated from detailed analysis 

because evaluating lands with wilderness characteristics is beyond the scope of this project.

2.5 Reasonably Foreseeable Development Scenario

In 2015, the BLM prepared an RFDS for the SFNF geothermal leasing project (BLM 2015) for 

the time frame of 2016 through 2031. The RFDS is a best professional estimate of what may 

occur if lands in the project area were leased. It is based on the assumption that all potentially 

productive areas can be open under standard lease terms and conditions, except those areas 

designated as closed to leasing by law, regulation, or executive order. It is not intended to be a 

maximum development scenario; however, it is biased toward the higher end of expected 

development. The RFDS for geothermal resource use involves three sequential phases: (1) 

exploration, (2) development drilling and utilization, and (3) final plugging and reclamation.

Utilization and final plugging and reclamation may continue beyond the RFDS time frame.

Activities and acres of surface disturbance associated with each phase are summarized below. 

2.5.1 Exploration

As described in detail within the RFDS, activities associated with exploration are geochemical 

surveys, geologic mapping, geophysical surveys, exploration drilling, and temperature-gradient 

drilling. Table 2-2, below, provides a description of expected disturbance in the project area

from the exploration phase of geothermal development. 

Table 2-2. Summary of Surface Disturbance from Exploration Activities

Activity Amount Expected Over 

Life of Plan

Amount of Disturbance 

per Unit (Acres)

Disturbance over Project 

Area for Life of Plan (15 

Years) (Acres)

Temperaturegradient wells1215 0.25 3.75

Slim wells13, 0.2 

wells per lease

5 2.8 14

Exploration roads 10 miles of road widened 

by 8 feet

N/A 9.7

Total 27.45

Source: BLM 2015

 

12 Temperature-gradient wells enable the investigation of temperatures at shallow depths in and around a 

geothermal system. Initial well diameters are typically 8 to 10 inches (BLM 2015). 

13 Slim wells are 3 to 6 inches in diameter and are used to recover core, take water samples, and measure 

thermal and fluid flow properties (BLM 2015).
Chapter 2. Alternatives, Including the Proposed Action

2-14 Santa Fe National Forest Geothermal Leasing EIS

2.5.2 Development Drilling and Utilization

Drilling and utilization involves full-diameter well drilling, power plant construction, power 

plant utilization, and repairs and maintenance. Table 2-3, below, provides a description of the 

expected disturbance in the project area from the development drilling and utilization phase of 

geothermal energy use.

Table 2-3. Summary of Surface Disturbance from Drilling and Utilization

Activity Amount Expected 

over Life of Plan

Amount of 

Disturbance (Acres)

Disturbance over Project 

Area for Life of Plan (15 

Years) (Acres)

Production and/or 

injection wells

30 5 per well 150

Transmission lines A maximum of 14 

miles, at a width of 

200 feet

N/A 339 

Pipelines A maximum of 7 

miles per plant, with 

a width of 25 feet

21.2 per plant 106

Roads 10 miles of road 

widened 2 feet

N/A 2.42

Power plant and 

ancillary facilities

5 power plants 10 per power plant 50

Total 647.42

Source: BLM 2015

2.5.3 Plugging and Final Reclamation

The final stage of geothermal operations is abandonment when exploration is unsuccessful or 

after production ceases. Certain facilities may be abandoned before all operations are ready for 

closure, and interim reclamation, such as revegetating the shoulders and ditches of access roads,

may occur immediately following construction. The RFDS expects that 40 percent of the well 

pad area would be subject to interim reclamation. The physical footprint of the well pads would 

not undergo interim reclamation; however, interim reclamation would occur in the area 

surrounding the well pads.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-15

2.6 Comparison of Alternatives

This section provides a summary of the effects of implementing each alternative. Information in the table is focused on activities and effects where 

different levels of effects or outputs can be distinguished quantitatively or qualitatively among alternatives. 

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Land use, recreation, and 

special designations 

The JNRA (approximately 

28,900 acres) would remain 

closed to geothermal leasing.

No direct impacts would occur 

in this area. Geothermal 

leasing and development 

could increase truck traffic. 

Changes in flows for natural 

hot springs could conflict with 

existing recreation

management direction in the 

JNRA; however, the potential 

of these indirect impacts is 

low, because the JNRA would 

remain closed to geothermal 

leasing.

Geothermal lease 

applications and nominations 

would continue to be 

processed; however, they 

would be evaluated on a 

case-by-case basis under 

separate NEPA analyses, in 

accordance with the Forest 

Plan and existing laws and 

regulations. 

Impacts would be minimized 

by implementing CSUs, 

NSOs, and TLs. These would 

be designed to protect 

existing land uses, recreation

areas, and special 

designation areas. Compared 

with the Alternative 1, 

Alternative 2 provides specific 

guidance to ensure an SFNFwide approach is adopted and 

that land use, recreation, and 

special designation areas are 

considered across all users of 

the SFNF. Impacts on

recreational use of hot and 

warm springs would be the 

same as those described 

under Alternative 1.

There would be no direct or 

indirect impacts on land use 

on 168,600 acres of the SFNF 

project area.

Of the alternatives that 

include geothermal leasing, 

Alternative 4 would have 

fewer closed acres, fewer 

acres under NSO, more acres 

under CSU, fewer TLs, fewer 

stipulations, and more 

waivers and modifications. 

Because of the greater 

access to SFNF lands and 

fewer restrictions, Alternative 

4 would have a greater impact 

on the broad spectrum of land 

uses, recreation areas, and 

special designation areas on 

the SFNF. Impacts on

recreational use of hot and 

warm springs would be the 

same as those described 

under Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

2-16 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Geologic resources The SFNF would process 

leases on a case-by-case 

basis. Geothermal 

development projected under 

this alternative could slightly 

increase the likelihood of 

seismic activity in and around 

the project area, particularly if 

enhanced geothermal systems

are used. This would require 

further analysis, if proposed as

part of a geothermal 

development project. 

Geothermal development may 

also slightly increase the risk 

of subsidence in the project 

area. Impacts on volcanic 

activity or release of 

radioactive material are not 

expected to result from the 

projected geothermal 

development.

Impacts would be the same 

as those described under 

Alternative 1. 

There would be no direct or 

indirect impacts on geologic 

resources in the project area.

Impacts would be the same 

as those under Alternative 1.

Energy and mineral resources Impacts on energy and mineral 

resources would be evaluated 

on a case-by-case basis under 

separate NEPA analyses. 

While additional roads and 

transmission lines could 

encourage additional energy 

and mineral development, 

other limitations associated 

with those resources would still 

prevent their development.

Impacts would be the same 

as those described under 

Alternative 1. 

All Forest Service lands in the 

project area would be closed 

to geothermal leasing. There 

would be no construction of 

transmission lines or 

development of roads 

specifically for geothermal 

energy development. There 

would be no impacts on nongeothermal energy and 

mineral resources. 

Impacts would be the same 

as those described under 

Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-17

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Paleontological resources Geothermal lease stipulations 

and closures would not be 

specifically implemented on 

paleontological resources 

outside of the JNRA; 

however, all geothermal lease 

applications and nominations 

would be subject to the 

standards and guidelines 

outlined in the Forest Plan 

and subsequent 

environmental analysis. 

Surface disturbance related to 

geothermal development

could impact an unknown 

quantity of fossils that may 

occur on or underneath the 

surface in areas containing 

paleontologically sensitive 

geologic units.

Impacts would be similar to 

those described under 

Alternative 1. Closures and 

stipulations would not be 

specifically implemented for 

paleontological resources; 

however, closures and 

stipulations for other resources 

would incidentally protect 

geologic units with likely fossil 

occurrences. The potential for 

geothermal development to 

impact sensitive geologic units 

is low, considering geothermal 

leasing closures, stipulations, 

and BMPs.

There would be no direct or 

indirect impacts on

paleontological resources 

under Alternative 3. 

Impacts under Alternative 4 

on paleontological resources 

would be similar to those 

described under Alternative 2; 

however, fewer acres in areas 

with likely fossil occurrence 

would be subject to NSO

stipulations and closures, and 

more acres would be subject 

to CSU stipulations. The 

potential for geothermal 

development to impact 

sensitive geologic units is low, 

considering geothermal 

leasing closures, stipulations, 

and BMPs.

Soil resources Impacts would be assessed 

on a case-by-case basis. 

Geothermal development

could result in physical 

disturbance, compaction, 

changes to erosion patterns, 

and loss of soil productivity. 

Impacts could result from the 

development of roads and 

facilities and geothermal 

projects, including 

construction and operation.

Impacts from geothermal 

exploration and development 

would be similar to those 

described under Alternative 1; 

however, they would be 

restricted in location by 

administrative withdrawals

and stipulations.

NSO stipulations would limit 

erosion on soils with severe 

erosion hazards and steep 

slopes, but they would 

exclude potential impacts 

from powerline and road 

construction and road use. 

There would be no direct 

impacts on soils under 

Alternative 3. However, there 

would be indirect impacts on 

soil resources because the 

project area would be closed 

to geothermal leasing for the 

foreseeable future. Over time, 

there would be less soil 

disturbance than expected 

under the current Forest Plan.

Impacts from geothermal 

exploration and development 

would be similar to those 

described under Alternative 2; 

however, they would have 

more potential for impacts on 

slopes between 30 and 40 

percent and in areas with 

moderately high to high runoff 

potential, due to a reduction in 

stipulations.
Chapter 2. Alternatives, Including the Proposed Action

2-18 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Water resources Impacts would be assessed 

on a case-by-case basis. 

Geothermal development

could result in contamination, 

altered groundwater flow 

paths or pressurization, and 

changes in water 

temperature. 

Exploration, development, 

and operation could result in 

increased sediment and 

turbidity in surface water and

contamination of surface 

water or groundwater by 

accidental release of 

chemicals or waste. Water 

and geothermal fluids may be 

lost when reinjected into the 

formation or through 

accidental spills or releases.

Impacts from geothermal 

exploration and development 

would be similar to those 

described under Alternative 1; 

however, they would be 

restricted in location by 

administrative withdrawals

and stipulations.

NSO stipulations would 

reduce the potential for direct 

impacts on many hydrologic 

features. They would also 

limit erosion on soils with 

severe erosion hazard and 

steep slopes. This would 

reduce the potential for 

sedimentation into streams 

but would exclude potential 

impacts from road and 

powerline construction, and 

road use. Water and 

geothermal fluids may be lost 

when reinjected into the 

formation or through 

accidental spills or releases.

There would be no impacts on 

watersheds or groundwater

resources under Alternative 3.

However, there would be 

indirect impacts on water 

resources. Because the 

project area would be closed 

to geothermal leasing for the 

foreseeable future, over time, 

there would be less surface 

disturbance than expected 

under the current Forest Plan, 

and less potential for changes 

to surface or subsurface 

water resources.

Impacts under Alternative 4 

would be similar to those 

described under Alternative 2. 

However, there would be no 

discretionary closures under 

Alternative 4, and there would 

be reduced protection of 

specific areas from 

implementing less restrictive 

lease stipulations. Water and 

geothermal fluids may be lost 

when reinjected into the 

formation or through 

accidental spills or releases.

Air quality and air qualityrelated valuesThere would be temporary 

and short-term impacts on air 

quality during exploration, 

development, and utilization 

from fugitive dust and 

equipment and vehicle 

exhaust. Impacts would be 

minimized through BMPs

applied at the permit level. 

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of emissions would be 

the same.

The constraints in areas open 

to leasing may alter the 

locations where geothermal 

development would occur. 

There would be no 

geothermal development;

therefore, no direct or indirect 

effects on air quality or air 

quality related values 

(AQRVs) would occur.

Direct and indirect impacts on 

air quality and AQRVs would 

be the same as described for 

Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-19

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Impacts from hydrogen sulfide 

release, if present in the 

geothermal resource, would 

be avoided with blowout 

prevention equipment and 

through monitoring and 

abatement, if required by 

NMED during air permitting.

Long-term emissions from 

operating the binary-cycle 

plants would be low because 

they are closed-loop systems 

that are designed to not emit 

pollutants. Because the plants 

would be air cooled, they 

would not emit steam plumes 

and, therefore, would not 

affect visibility in Class I 

areas. The plants would not 

emit hydrogen sulfide, if 

present in the resource, 

during normal operations; 

therefore, operations would 

not emit nuisance odors.

All activities must comply with 

the Clean Air Act (CAA) and 

applicable state air quality

regulations.

More areas would be 

constrained than under 

Alternative 1, so activities 

under Alternative 2 could 

occur within a smaller area. 

Because geothermal plants 

would be spaced by 1 mile or 

more, the overall direct and 

indirect impacts would be the 

same as under Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

2-20 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Vegetation The JNRA would remain 

closed to geothermal leasing. 

No direct impacts on

vegetation would occur in this 

area. Elsewhere, geothermal 

lease applications and 

nominations would continue 

to be processed; however, 

they would be evaluated on a 

case-by-case basis under 

separate NEPA analyses, in 

accordance with the Forest 

Plan and existing laws and 

regulations. Direct impacts 

(vegetation removal and 

vegetation communities

alteration) and indirect 

impacts (introduction or 

spread of invasive species) 

may occur. Up to 765 acres 

may be disturbed in 

vegetation communities by 

developing well pads, 

roadways, transmission 

corridors, and other 

geothermal facilities. There 

would be an increased risk of 

wildland fire from geothermal 

development. Potential 

sources of ignition would be 

vehicles, electrical lines, and 

people smoking.

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of disturbance would be 

the same. Compared to 

Alternative 1, an additional 

3,100 acres would be closed 

to geothermal leasing. 

Impacts would be minimized 

by implementing CSUs, 

NSOs, and TLs. These would 

be designed to protect 

vulnerable and important 

vegetation communities. Up 

to 765 acres may be 

disturbed in vegetation 

communities by developing 

well pads, roadways, 

transmission corridors, and 

other geothermal facilities.

The risk of wildfire would be 

the same as that described 

under Alternative 1. 

There would be no 

geothermal development;

therefore, no direct or indirect 

effects on vegetation would 

occur.

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of disturbance would be 

the same. Impacts would be 

similar to Alternative 2, except 

that fewer acres would be 

closed to geothermal leasing

and fewer acres would be 

subject to NSO stipulations. 

Intermittent streams and

slopes with severe erosion 

potential would be subject to 

CSU stipulations. Impacts on

riparian vegetation 

communities may be more 

severe than under Alternative 

2, because there would be 

less restrictive geothermal 

leasing stipulations in these 

areas, compared with 

Alternative 2. The risk of 

wildfire would be the same as 

that described under 

Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-21

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Fish and wildlife The JNRA would remain 

closed to geothermal leasing, 

and no direct impacts on fish 

and wildlife would occur in 

this area. Elsewhere,

geothermal lease applications 

and nominations would 

continue to be processed; 

however, they would be 

evaluated on a case-by-case 

basis under separate NEPA

analyses, in accordance with 

the Forest Plan and existing 

laws and regulations. 

Geothermal leasing 

stipulations and closures 

specific to fish and wildlife 

would not be implemented 

under this alternative; 

however, any geothermal 

lease applications and 

nominations would be subject 

to standards and guidelines 

outlined in the forest plan and 

environmental analysis.

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of disturbance would be 

the same. 

Impacts on fisheries and 

aquatic biota could occur from 

erosion and sedimentation 

into rivers and streams; 

however, geothermal leasing

stipulations on steep slopes 

and erosive soils would 

mitigate these effects, and 

impacts are unlikely to result 

in a substantial population 

change.

Impacts on wildlife could 

occur though habitat 

alteration, removal, reduction, 

or fragmentation. 

Implementing TLs would limit 

impacts on seasonally 

important wildlife habitat. 

Impacts would not lead to a 

substantial population change 

for any wildlife species.

There would be no 

geothermal development;

therefore, no direct or indirect 

effects on fish and wildlife

would occur.

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts from the overall 

levels of disturbance would be 

the same.

Direct and indirect impacts on 

fish and wildlife would be 

similar to those described 

under Alternative 2; however, 

there would be a greater 

likelihood of increased 

sedimentation flowing into 

perennial streams, which 

reduce the quality of habitat 

for sediment intolerant aquatic 

species.

Threatened and endangered 

species and special status 

species

The JNRA would remain 

closed to geothermal leasing, 

and no direct impacts on

threatened or endangered 

species or special status 

species would occur in this 

area. Elsewhere, geothermal 

lease applications and 

The RFDS would be the same 

as described under Alternative 

1; therefore, impacts from the 

overall levels of disturbance 

would be the same. 

Alternative 2 would not result 

in adverse impacts on

threatened or endangered 

There would be no 

geothermal development;

therefore, no direct or indirect 

effects on threatened and 

endangered species and 

special status species would 

occur.

The RFDS would be the same 

as described under 

Alternative 1; therefore, 

impacts related to the overall 

levels of disturbance would be 

the same. Impacts would be 

similar to Alternative 2; 

however, the potential 
Chapter 2. Alternatives, Including the Proposed Action

2-22 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

nominations would continue 

to be processed; however, 

they would be evaluated on a 

case-by-case basis under 

separate NEPA analyses, in 

accordance with the Forest 

Plan and existing laws and 

regulations. The types of 

effects could include habitat 

disturbance or alteration, 

noise disturbance, injury or 

mortality, exposure to 

contaminants, and 

interference with behavioral 

activities. All actions must 

comply with the ESA.

species, and would not lead 

to a trend toward federal 

listing of non-federally listed 

special status species. All 

actions must comply with the 

ESA.

disturbance on intermittent 

streams could lead to 

increased sedimentation 

flowing into perennial streams 

and could have an impact on 

species that are sediment 

intolerant, such as Rio 

Grande sucker, Rio Grande 

chub, RGCT, and other cold 

water fish species. All actions 

must comply with the ESA.

Livestock grazing The JNRA would remain 

closed to geothermal leasing.

Within those 28,900 acres,

there would be no disturbance 

to livestock or livestock 

management. Impacts 

identified in the 2008 

geothermal PEIS could occur 

on allotments outside of the 

JNRA on a case-by-case

basis.

In addition to portions of 

allotments closed to 

geothermal development that 

fall within the JNRA, 

Alternative 2 closes other 

areas based on special 

circumstances, and impacts 

would be less than under 

Alternative 1. Indirect impacts 

on grazing allotments outside 

of the JNRA and other closure 

areas would be a reduction in 

forage, a possible reduction in 

animal unit months (AUMs), 

and harassment of livestock.

There would be no direct or 

indirect impacts on livestock 

or livestock operations from 

geothermal leasing.

Indirect impacts would be the 

same as those described for 

Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-23

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Cultural resources Because there would be sitespecific analysis, potential 

impacts on cultural resources 

and their settings could be 

avoided or reduced, but there 

would be no additional 

established stipulations for 

surface use that may 

incidentally reduce impact 

potential on cultural 

resources. Current closures to 

leasing in the JNRA would 

continue.

The potential for impacts on 

cultural resources would be 

reduced by additional 

closures and stipulations. 

Stipulations for other surface 

uses may also incidentally 

reduce the impact potential on 

cultural resources. 

NSO stipulations would be 

implemented for areas with 

important cultural resources 

and their settings, including 

archaeological resources, 

TCPs, sacred sites, and 

NRHP-eligible and listed 

properties. There are 1,567 

known sites that would be 

included in land with NSO 

stipulations under this 

alternative. 

Implementing discretionary 

closures to geothermal 

leasing on all lands in the 

project area not already 

closed to leasing would result 

in no leasing and no 

subsequent development.

There would be no impacts on 

cultural resources and their 

settings.

The potential for impacts on 

cultural resources would be 

reduced by stipulations, but 

there would be no new 

closures. Stipulations for 

other surface uses may also 

incidentally reduce the impact 

potential on cultural 

resources. 

NSO stipulations would be 

implemented for areas with 

important cultural resources 

and their settings, including 

archaeological resources, 

TCPs, sacred sites, and 

NRHP-eligible and listed 

properties. There are 1,522 

known sites that would be 

included in land with NSO 

stipulations under this 

alternative. 

Tribal interests and traditional 

cultural resources

Potential direct and indirect 

impacts from subsequent 

geothermal development

could disturb landscapes and 

locations associated with 

religious beliefs or cultural 

uses. 

Because there would be sitespecific analysis and 

consultation, potential impacts 

could be avoided or reduced, 

but there would be no 

additional established 

stipulations for surface use 

There would be new closures 

and NSO stipulations for 

TCPs and Native American 

sacred sites, as identified 

through consultation and sitespecific consideration of 

impacts on tribal interests and 

traditional cultural resources 

and uses and their settings for 

each phase of geothermal 

development.

The potential for impact from 

subsequent geothermal 

development would be 

The SFNF would amend the 

forest plan to implement 

discretionary closures to 

geothermal leasing on all 

lands in the project area not 

already closed to leasing. 

Because there would be no 

leasing and no subsequent 

development, no new impacts 

are anticipated.

There would be NSO

stipulations for TCPs and 

Native American sacred sites, 

as identified through 

consultation and site-specific 

consideration of impacts and 

consultation for each phase of 

geothermal development. 

The potential for impact from 

subsequent geothermal 

development would be 

reduced; however, tribes may 

consider the disturbance of 

the land or use of geothermal 
Chapter 2. Alternatives, Including the Proposed Action

2-24 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

that may incidentally reduce 

impact potential on tribal 

interests and traditional 

cultural resources and uses.

Tribes may consider the 

disturbance of the land or use 

of geothermal resources as 

an adverse impact that could 

not be avoided or minimized. 

reduced; however, tribes may 

consider the disturbance of 

the land or use of geothermal 

resources as an adverse 

impact that could not be 

avoided or minimized. 

Additional habitat and visual 

protections may incidentally 

reduce the impact potential on 

traditional cultural resources

and resource uses, cultural 

landscapes, and their 

settings.

resources as an adverse 

impact that could not be 

avoided or minimized.

Additional habitat and visual 

protections may incidentally 

reduce the impact potential on 

traditional cultural resources

and resource uses, cultural 

landscapes, and their 

settings.

Visual resources The JNRA would remain 

closed to geothermal leasing. 

Visual resources would be 

protected in this area.

Elsewhere, visual resources 

could be impacted because of 

the lack of stipulations. The 

visual variety of the landscape 

in areas with very high or high 

scenic integrity would make 

hiding geothermal 

development activities easier 

than in areas with moderate, 

low, or very low scenic 

integrity. However, areas with 

existing development may be 

able to absorb new 

development without much 

change in the overall 

landscape.

The JNRA would remain 

closed to geothermal leasing,

and an additional 10,400 

acres would also be closed; 

impacts would be the same 

as under Alternative 1 but 

over a larger area. In areas 

restricted by NSO

stipulations, visual resources

would be preserved in the 

same way that areas closed 

to leasing would be protected. 

Areas restricted by CSU

stipulations would see 

reduced impacts on visual 

resources. These landscapes 

generally have diverse 

topography, colors, and 

vegetation, which can be 

used to screen development 

from casual observers. 

Finally, areas not subject to 

NSO or CSU stipulations 

There would be no leasing, so 

no impacts on visual 

resources from geothermal 

exploration or development.

Impacts would be similar to 

Alternative 2, except that 

fewer acres would be closed 

to geothermal leasing and 

fewer acres would be subject 

to NSO stipulations. 

Therefore, more acres would 

be subject to possible impacts 

on visual resources. CSU

stipulations on most of the 

area not closed to leasing 

would offer some protection, 

but any development could

impact visual resources. More 

acres would be open to 

leasing not subject to NSO or 

CSU stipulations than under 

Alternative 2. Impacts would 

be the same but would occur 

over a larger area. 
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-25

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

have the greatest risk of 

impacts. These areas have 

either moderate or low scenic 

integrity. 

Social interests, economics, 

and environmental justice

Impacts would occur on a 

case-by-case basis but would 

include temporary and longterm job creation, new federal 

royalty payments and taxable 

incomes, and retained 

recreation and tourism 

revenues in the long term. 

There is also the potential for 

localized impacts on quality of 

life from traffic, noise, and 

dust during construction.

Due to the lack of site-specific 

plans for geothermal 

development, specific location 

and intensity of impacts from 

development on 

environmental justice

populations in the project area 

cannot be determined at this 

time.

Some pueblo representatives 

believe that any level of 

geothermal development in 

the planning area would result 

in impacts on resources with 

cultural and spiritual value; 

this could not be mitigated 

and would therefore represent 

disproportionate, adverse 

impacts.

Overall impacts are the same 

as Alternative 1, but economic 

impacts could be less 

regionally dispersed due to 

NSO, CSU, and TL

stipulations.

There would be no lands 

available for leasing in the 

project area and no impacts 

on socioeconomics or 

environmental justice from 

geothermal development.

Overall impacts are the same 

as Alternative 1, but economic 

impacts could be less 

regionally dispersed due to 

NSO, CSU, and TL

stipulations.
Chapter 2. Alternatives, Including the Proposed Action

2-26 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

Health and safety Impacts would continue to 

occur on a case-by-case 

basis, and measures to 

minimize impacts on health 

and safety would be 

considered in separate NEPA

analyses. There would be a 

risk of human-caused fire from 

geothermal development.

However, because power line 

rights-of-way would be cleared 

of trees, the risk of wildfire 

associated with trees causing 

downed power lines would be 

minor.

The nature and character of 

impacts would be similar to 

those described for Common 

Impacts Associated with 

Geothermal Development. 

BMPs included in approved 

use authorizations would 

protect public health and 

safety by minimizing risks to 

workers and the public. The 

risk of wildfire associated with 

downed power lines would be 

the same as under Alternative 

1.

There would be no lands 

available for leasing in the 

project area and no impacts 

on health and safety from 

geothermal activities.

Impacts would be the same 

as those described under 

Alternative 2, because the 

same level of disturbance, the 

same number of wells, and 

the same number of power 

plants are expected.

Noise Impacts would continue to 

occur on a case-by-case 

basis, and measures to 

minimize noise impacts would 

be considered in separate 

NEPA analyses.

Due to the highly rural and 

unpopulated nature of lands in 

the project area, it is unlikely 

that any sensitive receptors 

would experience noise levels 

approaching the 65 Aweighted decibels (dBA) limit 

specified in BLM regulations.

There would be no lands 

available for leasing in the 

project area and no noise 

impacts from geothermal 

activities.

Impacts would be the same 

as those described under 

Alternative 2, because the 

same level of disturbance, the 

same number of wells, and 

the same number of power 

plants are expected.

Transportation and access Geothermal lease applications 

and nominations would 

continue to be processed; 

however, they would be 

evaluated on a case-by-case 

basis under separate NEPA

analyses, in accordance with 

the Forest Plan and existing 

laws and regulations.

Alternative 2 would result in 

greater limitations for siting 

geothermal infrastructure. This 

could result in more 

concentrated areas of 

development, resulting in 

fewer impacts on 

transportation and access 

within an NSO boundary, but a 

potentially higher 

concentration of visual and 

noise impacts for travelers in 

areas outside of an NSO 

There would be no direct or 

indirect impacts on the 

transportation network or 

access over the 168,600 

acres of the SFNF project 

area.

Of the alternatives that 

include geothermal leasing, 

Alternative 4 would have 

fewer closed acres, fewer 

acres under NSO, more acres 

under CSU, fewer TLs, fewer 

stipulations, and more 

waivers and modifications. 

Because of the greater 

access to SFNF lands and 

fewer overall restrictions, 

Alternative 4 may have a 

greater impact on 
Chapter 2. Alternatives, Including the Proposed Action

Santa Fe National Forest Geothermal Leasing EIS 2-27

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

boundary. It may also 

concentrate traffic issues, 

although any future action 

would have to comply with the 

Forest Plan and be studied 

under a site-specific NEPA

analysis.

transportation and access on 

the SFNF.

Climate change There would be no direct 

impacts. Indirect impacts are 

from GHG emissions during 

all project phases from the 

following: fuels combustion by 

equipment and vehicles, the

release of carbon dioxide in 

the geothermal resource, and 

the removal of vegetation and 

disturbance of soils on 760 

total acres. BMPs that reduce 

equipment and vehicle 

exhaust emissions to 

minimize impacts on air 

quality would also reduce 

GHG emissions.

GHGs emissions from plant 

operation are from commute 

traffic, maintenance traffic, 

truck deliveries, and potential 

releases of carbon dioxide 

during well maintenance. 

GHG emissions would be 

below the 25,000 metric tons 

per year reporting limit under 

the Greenhouse Gas 

Monitoring Rule. Geothermal 

power plant development 

could have an indirect 

Impacts would be the same 

as those described for 

Alternative 1.

There would be no 

geothermal development and 

no emissions of GHGs. If 

there is no geothermal power 

plant development, there 

could be an indirect negative 

impact on climate change if 

power from conventional 

fossil fuel sources of 

electricity were developed in 

place of geothermal 

development.

Impacts would be the same 

as those described for 

Alternative 1.
Chapter 2. Alternatives, Including the Proposed Action

2-28 Santa Fe National Forest Geothermal Leasing EIS

Table 2-4. Comparison of Alternatives

Resource or Use Alternative 1 Alternative 2 Alternative 3 Alternative 4

beneficial impact if power 

produced by the geothermal 

plant were to displace 

electricity generated by 

conventional fossil fuel 

sources of electricity.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-1

Chapter 3. Affected Environment and 

Environmental Consequences

3.1 Introduction

This chapter describes the affected environment and environmental consequences for resources 

and resource uses. The affected environment discussion includes a description of the biological, 

physical, and socioeconomic characteristics, including human uses, that could be affected by any 

future actions. Information from broad-scale assessments was used to help set the context for the 

project area. The information and direction for NFS lands has been further broken down into 

fine-scale assessments and information, where possible.

The environmental consequences discussion analyzes direct, indirect, and cumulative impacts 

expected to occur by implementing any future actions (including any decisions to lease or 

develop geothermal resources) that may be taken, consistent with the four alternatives: 

Alternative 1, the No Action Alternative; Alternative 2, the Proposed Action; Alternative 3, No 

Leasing; and Alternative 4, the Development Alternative. The scope of the analysis is 

commensurate with the detail of the alternatives and the availability of data. Current conditions 

of the project area, as described under the affected environment sections, provide the baseline for 

assessing impacts. 

The effects of the forest plan amendments are the same as the effects of identifying which lands 

are closed to geothermal leasing under either nondiscretionary or discretionary authorities or 

open to geothermal leasing, subject to stipulations. This is because the plan amendment itself is 

the mechanism to implement these discretionary and nondiscretionary leasing closures. This 

effects analysis is documented in this chapter. The amendments may create significant 

environmental effects and thus required the preparation of an EIS (36 CFR, Subpart 

219.13(b)(3), as amended January 2017).

3.2 Methods and Assumptions Common to the Analysis of 

Impacts

Consenting to issue a geothermal lease has no direct impact on the environment; however, it is a 

commitment of the resource for potential future exploration, drilling operations and development, 

utilization, and reclamation and abandonment, which are subject to environmental review and 

permits. Therefore, this EIS analyzes the potential impacts of the various stages that may follow a 

leasing decision, along with the potential cumulative impacts throughout the entire project area.

The method for the following impact assessment conforms to the guidance found in the 

following sections of the CEQ regulations for implementing NEPA: 

 40 CFR, Subpart 1502.24 (Methodology and Scientific Accuracy)

 40 CFR, Subpart 1508.7 (Cumulative Impact)

 40 CFR, Subpart 1508.8 (Impacts)

CEQ regulations require that agencies “rigorously explore and objectively evaluate” the impact 

of all alternatives.
Chapter 3. Affected Environment and Environmental Consequences

3-2 Santa Fe National Forest Geothermal Leasing EIS

The alternatives described in Chapter 2 do not propose developing a geothermal resource. For 

this reason, the analysis relies on the RFDS, which projects future geothermal leasing and 

development on NFS lands in the SFNF geothermal leasing project area from 2016 through 2031 

(15 years) based on best professional judgment. The RFDS is based on the assumption that all 

potentially productive areas can be open under standard lease terms and conditions, except those 

designated as closed to leasing by law, regulation, or executive order. Therefore, it does not 

consider any allocations (e.g., NSO, CSU, or TL stipulations) prescribed under any of the 

alternatives when projecting future geothermal leasing and development. The RFDS is not 

intended to be a “maximum-development” scenario; however, it is biased toward the higher end 

of expected development. 

It is important to note that the magnitude and extent of impacts on any resource or resource use 

will vary, depending on the amount of land apportioned for each lease. A lease can range in size 

from 640 acres up to 5,120 acres.

A consent to lease lands, in and of itself, does not cause any direct impacts, as defined by the 

CEQ regulations, which state that such impacts “are caused by the action and occur at the same 

time and place” (40 CFR, Subpart 1508.8[a]). Before any ground disturbance or other future 

actions that would occur consistent with implementing the plan, further decision-making would 

be required. This decision-making must take place before any future actions. It would take into 

consideration a wide variety of factors, including policy initiatives about timing of actions, 

whether any applications are submitted, whether funding is available, and compliance with other 

authorities and policies.

The regulations governing geothermal leasing and development provide for several decision 

stages before any ground-disturbing activities take place and may include further compliance 

with applicable authorities during these decision stages. Prior to ground disturbance, additional 

site-specific analysis would be required as described in Chapter 1. Under this regulatory 

scheme, the BLM receives and approves an application for a permit to drill or other authorization 

with specific information about a particular project. Until then, the impacts of actual 

development that might follow lease issuance are speculative. This is because so much is 

unknown as to location, scope, scale, and timing of that development. At each decision stage, the 

BLM retains the authority to approve, deny, or approve subject to conditions any permit, based 

on compliance with applicable authorities and policies. Therefore, the analysis of the impacts of 

development in this EIS reflects a more general, programmatic approach.

Any future development of geothermal resources would result in impacts. It is reasonable, 

therefore, to foresee what on-the-ground impacts would occur if the Forest Service were to 

consent to leasing and the BLM were to issue geothermal leases. However, those impacts would 

not occur until some point in the future and following several decision stages. Because of this, 

the following analysis focuses primarily on both direct and indirect impacts of future 

development of geothermal resources. It is based on the foreseeable on-the ground actions, 

taking into consideration the stipulations, BMPs, and procedures outlined in the 2008 

Geothermal PEIS. These impacts cannot be analyzed site specifically, but they can be analyzed 

in general terms for the leasing area, based on the RFDS outlined in Chapter 2. 

The following assumptions from the RFDS (Section 2.5) were applied for the analysis in 

Chapter 3:

 A total of 25 leases would be issued during the 15-year RFDS time frame.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-3

 Five 25-megawatt binary power plants would be developed on leases in the project area, 

with separations of a mile or more between plants.

 The total acres of surface disturbance associated with geothermal exploration is anticipated 

to be 27.

 The total acres of surface disturbance associated with development drilling and utilization is 

647. This includes disturbance associated with developing wells, transmission lines, 

pipelines, roads, power plants, and ancillary facilities.

 Based on existing temperature gradient data, binary cycle power plants are most likely to be 

constructed in the project area. These plants operate at lower temperatures than flash steam 

plants or dry steam plants. Therefore, this analysis does not analyze the potential impacts of 

flash steam or dry steam geothermal power plants. 

In addition, this analysis assumes the capacity of the SFNF is sufficient to implement any of the 

alternatives. 

3.3 Cumulative Actions for Cumulative Impacts Analysis

The CEQ regulations state that the cumulative impact analysis should include the anticipated 

impacts on the environment resulting from “the incremental impact of [an] action when added to 

other past, present, and reasonably foreseeable future actions, regardless of what agency (federal 

or non-federal) or person undertakes such other actions. Cumulative impacts can result from 

individually minor but collectively significant actions taking place over time” (40 CFR, Subpart

1508.7).

Sections 3.3.1 through 3.3.4 describe the processes for assessing cumulative impacts, the time 

frame of the cumulative projects, and reasonably foreseeable future actions for the cumulative 

impact assessment. Each resource or resource use section includes a cumulative impact 

assessment.

3.3.1 Process for Assessing Cumulative Impacts

The cumulative impact analysis for each resource or resource use builds on the analyses of the 

direct and indirect impacts of anticipated future actions to be taken, consistent with the project 

alternatives. In addition, the cumulative impact analysis considers other past, present, and 

reasonably foreseeable future actions and their impacts on natural resources, ecosystems, and 

human uses in the project area.

3.3.2 Regions of Influence

To determine which other actions should be included in a cumulative impacts analysis, the 

region of influence for each resource must first be defined. These regions should not be limited 

to only the geographic areas of resources addressed by the project, but they should also take into 

account the distances that cumulative impacts may travel and the regional characteristics of the 

affected resources.

Because this EIS addresses the consent to lease NFS lands at a programmatic level, the region of 

influence for each resource evaluated by the cumulative impacts analysis is the project area, 

unless otherwise noted.
Chapter 3. Affected Environment and Environmental Consequences

3-4 Santa Fe National Forest Geothermal Leasing EIS

3.3.3 Time Frame of the Cumulative Projects

The time frame of the cumulative impact analysis incorporates the sum of the impacts of 

anticipated future actions consistent with implementing an alternative, in combination with other 

past, present, and future actions. This is because impacts may accumulate or develop over time. 

The future actions described in this analysis are those that are “reasonably foreseeable”; that is, 

they are ongoing (and will continue into the future), are funded for future implementation, or are 

included in firm near-term plans. The reasonably foreseeable time frame for future actions 

evaluated in this cumulative analysis is 20 years from the consent to geothermal leasing. While it 

is difficult to project reasonably foreseeable future actions (or trends) beyond a 20-year time 

frame, the impacts identified in the cumulative impacts analysis will likely continue beyond the 

20-year horizon.

3.3.4 Reasonably Foreseeable Future Actions

Reasonably foreseeable future actions are projects, activities, or trends that could impact human 

and environmental receptors in the defined regions of influence (Section 3.3.2) and in the 

defined time frames (Section 3.3.3). 

Table 3-1. Reasonably Foreseeable Future Actions

Project Name General Location Project Description

Vegetation Management

Southwest Jemez 

Mountains Landscape 

Restoration Project

Middle Jemez River

Watershed

Ecological restoration of up to 110,000 acres in 

the greater Southwest Jemez Mountains over 

10 years.

Supplement to the Final 

EIS for Invasive Plant 

Control Project EIS

Carson National Forest 

and SFNF

Updates information contained in the Forest 

Service’s final EIS for the Invasive Plant Control 

Project, published September 2005.

Cerro Pelon Timber Stand 

and Wildlife Habitat 

Improvement Project

SFNF, Espanola Ranger 

District

Thinning in a stand of pinyon-juniper of 165 

acres to improve the health and fire resilience of 

the stand. This should result in increased pinyon 

nut production for birds and other wildlife. This 

project has been postponed.

Water Resources

Pueblo of Jemez Red 

Rocks Dam Repair

Pueblo of Jemez The project area is on the east side of New 

Mexico State Highway 4 (NM 4), in an unnamed 

ephemeral stream channel and arroyo. This 

arroyo flows west into the Jemez River, which is 

less than 0.4 mile downstream. During the 

federal disaster declared by the president and 

designated as Federal Emergency Management 

Agency (FEMA) Number 4152-DR-NM, a major 

storm and subsequent high water flows eroded 

the containment berm at Red Rocks Dam. This

caused a breach and failure of the stormwater 

detention facility. This facility provides flood 

protection for downstream road and irrigation 

infrastructure at the Pueblo of Jemez. As such, 

the purpose of the proposed project is to repair 

the stormwater detention facility and protect 

downstream infrastructure.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-5

Table 3-1. Reasonably Foreseeable Future Actions

Project Name General Location Project Description

Pueblo of Jemez Owl 

Springs Bridge Sediment 

Removal Project

Pueblo of Jemez The Natural Resources Department of Jemez 

Pueblo is proposing to use a track hoe for 

removing the sedimentation; it will be operated 

from the banks of the Jemez River.

Valle Seco Wetland

Restoration Project

Valles Caldera The proposal is to restore severely eroded 

emergent wetlands in the watershed of Sulphur 

Creek in the VCNP, Jemez Springs. The project 

will construct 54 rock and earthen structures 

along five headwater tributaries (19,580 feet) 

and 3,600 feet of the main channel. The project 

proponent will build 25 plug and pond 

structures, sod dams, one-rock dams, a worm 

ditch, and contour swales.

Abiquiu Land Grant 

Waterline Replacement 

Project

SFNF, Espanola Ranger 

District

In 1967, the Merced de Abiquiu (Land Grant) 

installed a water collection gallery and water line 

on NFS lands in order to provide water for 

livestock. This facility is at the end of its life, and 

the proposal is to replace it.

McKinney County Dam SFNF, Jemez Ranger 

District

Remove McKinney Dam and replace it with a 

fish barrier. This project is on hold.

Energy and Mineral Resources

Valles Caldera: 

Nomination under the 

Geothermal Steam Act

VCNP The NPS is in the process of listing the Valles 

Caldera as a significant geothermal feature 

under the Geothermal Steam Act of 1970 (30 

USC, Section 1019). If it were determined by the 

BLM, in consultation with the NPS, that 

geothermal operations were reasonably likely to

result in a significant adverse impact on such a 

feature, then the BLM would decline to issue the 

lease. The BLM or Forest Service, in 

consultation with the NPS, would include 

stipulations to protect any significant thermal 

features of a National Park System unit that 

could be adversely affected by geothermal 

development. These stipulations would be 

added, if necessary, if the lease or permit were

issued, extended, renewed, or modified (43 

CFR, Subpart 3201.10[b]).

South Pit Pumice Mine 

Expansion

SFNF, Jemez Ranger 

District

Approval of a 10-year-plan of operations for a 

pumice mine of approximately 48 acres next to 

a recently reclaimed 9-acre pumice mine.

Duran 2010 Pumice Mine South of Cerro del Pino, 

Jemez Ranger District, 

SFNF

Develop an open-pit pumice mine south of 

Cerro del Pino.

Threatened, Endangered, and Special Status Species

New Mexico Meadow 

Jumping Mouse Critical 

Habitat Protection Project 

(EA)

Jemez Ranger District, 

SFNF

Protection and improvement of habitat 

conditions for the New Mexico Meadow Jumping 

Mouse.
Chapter 3. Affected Environment and Environmental Consequences

3-6 Santa Fe National Forest Geothermal Leasing EIS

Table 3-1. Reasonably Foreseeable Future Actions

Project Name General Location Project Description

Planning

SFNF Land Management 

Plan Revision EIS: 

Inventory and Evaluation 

Steps of the Wilderness 

Recommendation Process

SFNF The SFNF is revising its land and resource 

management plan. These plans describe the 

strategic direction for management of forest 

resources for 10 to 15 years. The plans are 

adaptive and amendable as conditions change 

over time. As part of the land and resource 

management plan revision process, the SFNF is 

conducting a wilderness inventory and 

evaluation to determine if there are any lands 

suitable or unsuitable to recommend to 

Congress for inclusion in the National 

Wilderness Preservation System. 

Source: Forest Service GIS 2015

3.4 Land Use, Recreation, and Special Designations

3.4.1 Affected Environment

This section focuses on the current management and use in project area for the SFNF. 

Three resource classes are described and analyzed below: land use, recreation, and special 

designations. National Scenic and Historic Trails are covered as a subsection under special 

designations.

3.4.1.1 Land Use

The National Forest Management Act of 1976 requires the Secretary of Agriculture to assess 

NFS lands, to develop a management program based on multiple-use and sustained-yield 

principles, and to implement a resource management plan for each unit of the NFS. The primary 

statutes that authorize the disposal of renewable resources on NFS lands are the Organic 

Administration Act, Multiple-Use Sustained-Yield Act, and the Bankhead-Jones Farm Tenant 

Act. 

The SFNF operates under the direction of the Forest Plan (Forest Service 1987). In accordance 

with the Geothermal Steam Act of 1970 (30 USC, Section 1019), the BLM administers 

geothermal leasing on NFS lands. It does this with the concurrence of the Forest Service, which 

is mandated by national policies to administer lands under the concept of multiple uses, while 

protecting the long-term health of the land. 

Land Use Authorizations

Land use authorizations include various agreements to use Forest Service land, such as ROW

grants, road use agreements, and associated temporary use permits. Land use authorizations are 

issued for a variety of purposes, both short term and long term. Short-term uses include 

agricultural leases and other uses involving minimal land improvements or disturbances. Longterm uses include ROW grants for power lines, highways, roads, pipelines, fiber-optic cables, 

communication sites, electric power generation sites, and irrigation canals or acequias.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-7

Rights-of-way and Utility Corridors

A ROW grant is an authorization to use a specific piece of public land for a certain project, such 

as roads, pipelines, transmission lines, and fiber-optic lines. The grant authorizes rights and 

privileges for a specific use of the land for a specific period of time. Generally, a Forest Service

ROW is granted for the life of the project and remains in impact unless terminated by mutual 

agreement or one agency giving the other 90 days prior written notice. 

Special Use Permits and FLPMA Leases

A lease is an authorization to possess and use public land for a fixed period. A lease is issued 

when there is going to be substantial construction, development, and improvement, and there is 

an investment of large amounts of capital that would be amortized over time. Special use permits 

are authorized when uses of public lands would be short term and involve little or no land 

improvement, construction, or investment. Special use permits and leases are subject to process 

and monitoring fees and a fair-market rental value.

Withdrawals

A land withdrawal is a real estate management tool to implement resource management planning 

prescriptions or to transfer administrative jurisdiction from one federal agency to another. A 

withdrawal creates a title encumbrance on the land, thereby restricting an agency’s ability to 

manage its lands under multiple use management principles. The restrictions generally segregate 

the lands from some or all of the public land laws and some or all of the mining and mineral 

leasing laws for a specific period, generally 20 years for post-FLPMA withdrawals. Withdrawn 

land can be closed to mining, mineral leasing, or mineral material disposal.

SFNF Project Area: Land Use

The SFNF project area covers approximately 194,900 acres and is in the northwest-central 

portion of New Mexico, including Rio Arriba and Sandoval Counties. Property adjacent to the

project area is as follows:

 Lands administered by the Taos Field Office of the BLM, LANL, and DOE

 Bandelier National Monument and VCNP administered by the NPS

 State and municipal lands

 Pueblo of Jemez lands administered by the Pueblo and Bureau of Indian Affairs

 Private lands

There are no major population centers in the project area. Nearby towns are Jemez Springs, 

Jemez Pueblo, Ponderosa, Canon, Los Alamos, Coyote, Youngsville, and other small towns and 

villages. Ranger Districts on the SFNF are Coyote, Cuba, Espanola, Jemez, and Pecos/Las 

Vegas, although the project area does not include the Pecos/Las Vegas Ranger District. 

The SFNF manages lands for multiple uses, including recreation, grazing, wildlife habitat, 

fisheries, watersheds, and heritage resource protection and interpretation. Lands surrounding the 

SFNF are undeveloped areas (open grasslands and low-, mid-, and high-elevation forest 

ecosystems), dispersed residential developments, small towns, villages, and pueblos, a national 

research center (LANL), ski areas, reservoirs, and agricultural areas, including both ranches and 

small irrigated farms. 
Chapter 3. Affected Environment and Environmental Consequences

3-8 Santa Fe National Forest Geothermal Leasing EIS

Existing ROWs on the SFNF are those for transmission lines, water lines, fiber-optic cables, 

communication facilities, roads and highways, pipelines, and other infrastructure that support 

local, regional, and national interests. 

3.4.1.2 Recreation

Recreation planning on NFS lands is an integral part of land and resource management planning, 

as required by the Forest and Rangeland Renewable Resources Planning Act of 1974, as 

amended by the National Forest Management Act of 1976, and described in 36 CFR, Part 219, 

and Forest Service Manual 1920. 

Recreation opportunities in the project area range from dispersed uses, such as hiking, natural 

hot or warm spring use, and wildlife viewing, to developed recreation, such as that for 

campgrounds and interpretive sites. Recreation is an important component of the multiple use 

management practices of the SFNF. Surveys cited in the PEIS (2008) demonstrate that recreation 

on Forest Service lands is increasing annually (BLM and Forest Service 2008). Steady 

population growth continues to increase the recreation demand on undeveloped public lands as 

visitors and nearby residents seek a diversity of recreation.

The Recreation Opportunity Spectrum (ROS) is both a classification system and a prescriptive 

tool for recreation planning, management, and research (Clark and Stankey 1979). The Forest 

Service uses ROS to illustrate the recreation setting by describing a combination of the physical, 

biological, social, and managerial conditions that give value to a place. 

The ROS embodies six land classes, as follows, along with the number of acres in the project 

area on lands managed by the SFNF (Forest Service GIS 2015): 

 Primitive—0 acres

 Semi-primitive non-motorized—9,415 acres

 Semi-primitive motorized—85,973 acres

 Roaded natural—74,309 acres

 Rural—398 acres

 Urban—0 acres

Each setting provides experiences that range from a sense of isolation and closeness to nature (at 

the primitive end of the spectrum) to social experiences in highly structured environments (at the 

urban end of the spectrum). 

The SFNF includes a diversity of landscapes, offering visitors a variety of recreation settings and 

opportunities. Providing these outdoor recreation opportunities is a primary goal identified in the 

Forest Service’s Strategic Plan for Fiscal Years 2015 to 2020 (Forest Service 2015a). In the plan, 

the Forest Service has identified the following key aspects for managing recreation resources on 

system lands:

 Maintain recreation settings, hiking trails, and other sustainable recreation opportunities on 

National Forests and Grasslands for public use

 Improve recreation facility accessibility

 Help meet public needs and expectations for outdoor recreation on National Forests and 

Grasslands through public and private partnerships
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-9

 Improve our communication of outdoor recreation information about the National Forests 

and Grasslands on the Internet, social media, and other outlets to reach more people, serve 

them better, and receive their feedback

 Encourage community planning for sustainable tourism and recreation, providing private 

landowners with economic incentives to maintain open space

 Use tools such as the ROS and the Scenery Management System to help identify, prioritize, 

protect, and enhance open spaces

 Maintain water of sufficient quantity and quality to sustain aquatic life and support terrestrial 

habitats, domestic uses, recreation opportunities, and scenic character

 Develop sustainable recreation settings and opportunities along with programs that 

complement national, state, and community tourism strategies

In addition to planning documents, the aspects of the regulatory framework for recreation are 

provided in the 2008 Geothermal PEIS (BLM and Forest Service 2008). Since publication of the 

2008 PEIS, the SFNF completed updates to its Forest Plan (Forest Service 1987), including 

identifying management areas for recreation, providing management rules for special designations 

areas, and restricting motor vehicles to the route network displayed on motor vehicle use maps.

SFNF Recreation Areas

The VCNP, formerly the Baca Ranch, is a unit of the National Park System and is surrounded by, 

but not included in, the project area. Bandelier National Monument, also administered by the 

NPS, is east of the project area, near LANL, on the Pajarito Plateau.

An estimated 591,000 to 676,000 people visited the Jemez Ranger District in 2012. Holiday 

weekend visitation can increase dramatically. For example, on Memorial Day weekend in 2003, 

visitation was 163 percent above the average weekday (MRCOG 2006). Most SFNF recreation 

users from the Albuquerque area travel on NM 4. Almost all of the Jemez Ranger District 

developed recreation sites are found along NM 4 and NM 126. The notable exception is Paliza 

Family and Group campgrounds, which are located off Forest Road 10 (Forest Service 2015b).

Recreation use is generally light to moderate throughout the broader project area, except along 

major routes, such as NM 4, and around campgrounds, hot springs, rivers, and population 

centers, such as Jemez Springs, where peak-season visitation during the summer can be high. In 

April and May there is a dramatic increase in day-use hikers. Trailhead parking is full during 

weekends and mostly full during the weekdays. Forest roads are opened to the public in midApril and visitors begin to use the dispersed camping areas. Forest Road 144 provides a desired 

area for dispersed camping. By early May the developed sites are open to the public and are busy 

throughout the summer. Campgrounds and dispersed camping areas continue to be used during 

the fall big game hunting seasons. As winter approaches the most developed sites are winterized 

and closed. Forest roads typically close in early January and are used as cross-country ski and 

snowmobile trails (Forest Service 2015b).

There are 1,089 miles of motorized routes that crisscross the SFNF project area (Forest Service

GIS 2015). The Travel Management Rule (36 CFR, Part 212) establishes requirements for 

National Forest transportation systems. It also describes the requirements for designating roads, 

trails, and areas for motor vehicle use on a motor vehicle use map.
Chapter 3. Affected Environment and Environmental Consequences

3-10 Santa Fe National Forest Geothermal Leasing EIS

In addition, there are many designated recreation areas on the SFNF, such as the San Antonio, 

Jemez Falls, Jemez Canyon, Laughing Water, Redondo, Las Conchas, Horseshoe Springs, and 

Paliza, which total to over 5,000 acres (Forest Service GIS 2015). 

Within the project area, there are six campgrounds (all on the Jemez Ranger District) and four 

picnic sites (three on the Jemez Ranger District and one on the Coyote Ranger District; Forest 

Service GIS 2015). Primitive camping is allowed throughout, unless otherwise posted and not 

within 100 feet of a riparian area.

NMDGF Hunt Units 5B, 6A, 6B, 51A, and 51B are partially or entirely in the project area. 

Permitted hunting is through the NMDGF, although an additional habitat stamp is required to hunt 

on federal lands. Typical hunted species are mule deer, elk, turkey, and other small game animals.

Streams in the project area provide recreation fishing opportunities, primarily for nonnative 

rainbow and brown trout. Popular fishing streams are the Jemez River, East Fork Jemez River, San 

Antonio Creek, and the Rio Cebolla. There also are fisheries for native Rio Grande cutthroat trout

in the headwaters of the Rio Cebolla, Cañones Creek, and Chihuahuenos Creek. 

3.4.1.3 Special Designations

The following section describes special management designations on the project area, including 

IRAs, National Recreation Areas (NRAs), National Historic and Scenic Trails, Wilderness Areas, 

and Wild and Scenic Rivers. These areas have been designated to protect unique characteristics 

and contain resources that have been identified as scientifically, educationally, or recreationally 

important. Special area designations on NFS lands can be established by Congress or 

Presidential Proclamation or administratively by the US Department of Agriculture (USDA). The 

Forest Service has the authority to adopt many, but not all, special management designations 

through Forest Plan amendments or revisions, such as the management designations detailed in 

the SFNF Plan (Forest Service 1987).

Inventoried Roadless Areas

IRAs are a Forest Service administrative designation representing some of the nation’s most 

highly valued expanses of open space.

There are seven IRAs in the SFNF project area covering approximately 15,800 acres. IRAs can 

be characterized by nine values or features, which are described below. The 2001 Roadless Rule 

(36 CFR, Subpart 294.43) places restrictions on resource extraction and road 

construction/reconstruction in IRAs.

The 2001 Roadless Rule lists the following nine values or features that often characterize IRAs:

 High-quality or undisturbed soil, water, and air

 Sources of public drinking water

 Diversity of plant and animal communities

 Habitat for threatened, endangered, proposed, candidate, and sensitive species and for those 

species that depend on large, undisturbed areas

 Primitive, semi-primitive non-motorized, and semi-primitive motorized recreation 

opportunities

 Reference landscapes

 Natural-appearing landscapes with high scenic quality

 TCPs and sacred sites
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-11

 Other locally identified unique characteristics

Seven IRAs are distributed in the northern and southern portions of the project area. Youngsville 

(6,000 acres), Pueblo Mesa (1,100 acres), Canones Creek (3,900 acres), and Polvadera (1,200 

acres) are all in this northern area; Virgin Canyon (600 acres), Peralta Ridge (800 acres), and 

Alamo Canyon (2,200 acres) are in the far south (Forest Service 2016a). 

National Recreation Areas

The Forest Service establishes NRAs primarily to protect important recreation, scenic, scientific, 

and natural values for the enjoyment of current and future generations. The highlighted activities 

center on water- and land-based pursuits associated with the natural environment.

The JNRA is in the project area. It was established in 1993 and consists of over 28,000 acres,

managed by the Jemez Ranger District, and abuts portions of the VCNP. The SFNF administers 

the lands to promote the area for fishing, camping, rock climbing, hunting and hiking. Mining in 

this NRA is prohibited, except on preexisting claims, and the JNRA Act withdrew the area from 

geothermal leasing and development. The JNRA (Public Law 103-104, Stat. 1025) requires the 

SFNF to protect, conserve, and restore natural resource values in the JNRA. 

National Historic, Scenic, and Recreational Trails

The National Trails System is made up of National Scenic Trails, National Historic Trails, and 

National Recreation Trails. National Scenic Trails and National Historic Trails are congressional 

designations given to protected areas in the United States that contain trails and surrounding 

areas of particular natural beauty and historic significance. National Recreational Trails are 

designated based on applications from diverse partnerships, and include more than 1,200 trails 

on federal, state, local, and privately owned land throughout the country. National Trails are 

officially established under the authorities of the National Trails System Act (16 USC, 

Subsection 1241-51). 

National Scenic Trails are 100 miles or longer, continuous, primarily non-motorized routes of 

outstanding recreation opportunity. National Historic Trails commemorate historic and 

prehistoric routes of travel that are of significance to the entire nation. National Historic Trails 

have as their purpose the identification and protection of the historic route and its historic 

remnants and artifacts for public use and enjoyment (NPS 2006a). They must meet three criteria 

listed in Section 5(b)(11) of the National Trails System Act:

 They must follow actual documented route of historic use

 They must be of national significance

 They must possess significant potential for public recreation and interpretation

Within the SFNF, there is one federally designated National Scenic Trail: the Continental Divide 

Trail. It runs along the Continental Divide of North America and crosses the SFNF for a total of 

25.7 miles on the Cuba and Coyote Ranger Districts1, but not within the project area (Forest 

Service 2016b). There are no National Historic Trails within the project area; however, the Old 

Spanish National Historic Trail is located north of the project area. The Canones Creek National 

 

1 Mathew Chavez and Anne Bishop, Forest Service, personal communication with Holly Prohaska, 

EMPSi. March 2, 2016.
Chapter 3. Affected Environment and Environmental Consequences

3-12 Santa Fe National Forest Geothermal Leasing EIS

Recreational Trail is the only National Recreational Trail in the project area, extending 6.2 miles 

from the Cerro Pavo trailhead through Canones Canyon near Coyote.

National Scenic Byways 

The National Scenic Byways Program (23 USC 162) was authorized in 1991 and is administered 

by the Federal Highway Administration. The Federal Highway Administration designates 

National Scenic Byways when roads have outstanding scenic, historic, cultural, natural, 

recreational, and archaeological qualities. The National Scenic Byways Program funding 

supports projects that manage and protect these intrinsic qualities, interpret these qualities for 

visitors, and improve visitor facilities along byways. The National Scenic Byway in the project 

area is the Jemez Mountain Trail National Scenic Byway. It is approximately 65 miles long, 21.8 

miles of which fall within the project area. It provides scenic opportunities for viewing 

geological formations, ancient Native American ruins, Jemez Pueblo, and an area rich in historic 

logging, mining, and ranching (Forest Service GIS 2015). The portion of the Jemez Mountain 

Trail National Scenic Byway within the project area is within the JNRA.

Wilderness Areas 

The National Wilderness Preservation System was created to ensure the preservation and 

protection of natural conditions in areas designated as wilderness. On the SFNF, there are of four 

wilderness areas (Pecos, San Pedro Parks, Chama River Canyon, and Dome). None of these are 

in the project area. 

Wild and Scenic Rivers

Congress established the National Wild and Scenic Rivers System to effectively manage special 

river segments. Rivers, or segments of rivers, must be free flowing and possess at least one 

outstandingly remarkable value, such as scenic, recreational, geologic, fish, wildlife, historic, 

cultural, or other features. The outstandingly remarkable values of eligible rivers must be 

protected until superseded by Congress. Within the National Wild and Scenic Rivers System, 

three classifications define the general character of designated rivers: wild, scenic, or 

recreational. Classifications reflect levels of development and natural conditions along a stretch 

of river. These classifications are used to help develop management goals for the river.

The SFNF has three Wild and Scenic Rivers: The Rio Chama, Pecos, and the East Fork of the 

Jemez River. All 9 miles of the East Fork Jemez River in the project area are in the JNRA (Forest 

Service GIS 2015).

3.4.2 Environmental Consequences

3.4.2.1 Scoping Comments on Land Use, Recreation, and Special 

Designations

The following issues specific to land use, recreation, and special designations were identified 

during the public scoping period:

 How would geothermal leasing impact IRAs and their sensitive resources?

 How would geothermal leasing impact adjacent wilderness areas, lands with wilderness 

characteristics, IRAs, and ACECs or other special designations?

 How would geothermal leasing affect recreation in the project area? How would geothermal 

leasing affect the JNRA and other nearby recreation areas managed by other federal or state 

agencies?
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-13

3.4.2.2 How Resource Impacts Were Evaluated

Methods

Land status baseline information, recreation data, and special designation areas in Section 3.4

were reviewed for an understanding of SFNF management practices, designations, and land use 

in the project area. The SFNF GIS data (Forest Service GIS 2015) were overlain with the actions 

found under each alternative in Chapter 2. Conclusions were drawn based on an understanding 

that these types of actions may affect NFS lands and adjacent landowners.

Indicators

The following indicators have been identified in order to evaluate potential impacts on land use, 

recreation, and special designation areas:

 Conflict with management goals and objectives set forth by the Forest Service to sustain the 

health, productivity, and diversity of federal lands

 Result in proposed uses that are incompatible with existing or adjacent land uses

 Result in a change of recreation access

 Conflict with existing recreation uses of the area

 Diminish existing recreation experiences and opportunities by altering the recreation setting

 Conflict with management goals and objectives set forth by the Forest Service in order to 

categorize, protect, and manage special designation areas

 Conflict with conservation goals for the area

 Result in proposed land uses that are incompatible with adjacent special designation areas

Assumptions

This analysis assumes the following: 

 The SFNF’s consent or denial of NFS lands for geothermal leasing and its issuance of 

geothermal leases would not impact land use and access. Existing ROWs and 

communication sites would be managed to protect valid existing rights. However, impacts 

could result from future construction and operation of geothermal energy projects in the 

project area, based on future leases.

 Congressionally designated wilderness areas would be closed to leasing. 

 Current land use could change once site-specific geothermal operations begin. Under travel 

management, new roads created for a specific project would probably not be open to 

recreational use.

 Demand for recreation opportunities would increase over time.

3.4.2.3 Common Impacts Associated with Geothermal Development

Due to the inability to predict the location, scope, scale, and timing of future development, the 

following impact analysis provides a general description of common impacts on land use from 

geothermal development. The information presented in the Common Impacts on Land Use with 

Geothermal Development section of the 2008 Geothermal PEIS is incorporated by reference and 

summarized here (BLM and Forest Service 2008). Chapter 2 summarizes the alternativespecific data.
Chapter 3. Affected Environment and Environmental Consequences

3-14 Santa Fe National Forest Geothermal Leasing EIS

Lands converted to geothermal use during the drilling and utilization phases (well pad, power 

plant, pipeline, and transmission line construction and uses) could result in long-term indirect 

impacts on other uses, such as grazing, recreation, hunting, and mining, because geothermal use 

could displace these activities and uses. Short-term (lasting only the duration of the actual 

activity) impacts could include maneuvering construction and maintenance equipment and 

vehicles associated with the drilling and utilization activities. Further, reclamation and 

abandonment would likely return the landscape to its pre-construction condition, and the 

previous uses and activities could resume.

The development of geothermal resources could also alter the physical, social, and operational 

character of the recreation setting, thereby changing an individual’s experiences. All phases of 

development, including surveying, drilling, utilization, operation, and maintenance, could restrict 

recreation areas, temporarily reducing the amount of land available for recreation and accessible 

trails. This could displace some recreationists and could limit recreation. Recreationists could 

experience an increase in noise, vibration, and dust. Additionally, exploration could shift the 

ROS setting. Under travel management, new roads created for a specific project would probably 

not be open to recreational use. However, this would also alter the experience for people seeking 

a more remote experience in those same areas. 

Increased traffic from reclamation and abandonment could affect timely public access, as 

described above. All disturbed lands would be reclaimed, in accordance with Forest Service

standards, restoring recreation opportunities to predevelopment levels; after this, recreation 

activities could resume. 

3.4.2.4 Impacts Under Alternative 1—No Action

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. The JNRA would 

remain closed to geothermal leasing, and no direct impacts would occur in this area. 

Geothermal leasing and development could require road improvements and lead to increased

truck traffic through the SFNF associated with the development and other uses. Industrial uses, 

more traffic, and noise could diminish the overall recreation experience on the SFNF. In 

addition, geothermal leasing and development could reduce upward vertical hydraulic gradients, 

and groundwater flow paths, as described in Section 3.9.2. This could alter the natural, 

recreational hot springs in the JNRA. Reduced flows could conflict with recreation management 

direction for hot and warm springs in the Jemez National Recreation Area Management Plan. 

This includes direction to “restore and maintain or enhance natural resource conditions” in hot 

and warm spring areas (Forest Service 1987); however, because the JNRA would remain closed 

to geothermal leasing, the risk of indirect impacts on recreational hot springs is low.

Geothermal lease stipulations and closures would not be specifically implemented on recreation 

areas or special designations outside of the JNRA; however, any geothermal lease applications 

and nominations would be subject to the standards and guidelines outlined in the Forest Plan and 

subsequent environmental analysis.

3.4.2.5 Impacts Under Alternative 2—Proposed Action

Relevant stipulations detailed in Chapter 2 and designed to protect existing land uses are CSU

stipulations in and around popular recreation areas, TLs to benefit wildlife, and NSOs to ensure 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-15

sensitive and special designation areas are protected. These measures are expected to effectively 

avoid or minimize direct and indirect impacts identified in Section 3.4.2.3 on land uses, 

recreation and special designation areas by identifying conflicts early in the process and 

requiring specific measures to maintain public uses and values. Implementing lease stipulations 

under Alternative 2 would minimize impacts. Impacts on recreational use of hot and warm 

springs would be the same as those described under Alternative 1. 

More trucks, possible road improvements, and more people could diminish the overall recreation 

experience on the SFNF. Further, traffic noise may disrupt the experience of people staying in 

campgrounds and picnic areas along NM 4 and NM 126. Evening and night traffic from trucks 

and project equipment would be light, but traffic noise from evening and night travel could 

indirectly impact campers’ experience. Daytime traffic may have fewer impacts because many 

campers are elsewhere during the day, in contrast to users of picnic areas that are open only 

during the daytime. 

Special designations in the project area, including the Wild and Scenic segment of the East Fork 

of the Jemez River, the JNRA, Canones Creek National Recreation Trail, and the seven IRAs, 

are either closed to leasing or are subject to NSO under Alternative 2. No direct impacts would 

occur in these areas. The Jemez Mountain Trail National Scenic Byway, 21.8 miles of which fall 

within the project area, could experience minor, temporary impacts from congestion resulting 

from large, long-wheelbase construction vehicle traffic during geothermal exploration and 

development phases; however, most lands accessible from the Jemez Mountain Trail National 

Scenic Byway are withdrawn from leasing (that is, most of the land is in the JNRA) or are

covered by NSO stipulations. Geothermal development north of the scenic byway, in the Middle 

Unit, could increase use of the byway; however, alternate access routes in this area could be 

used, such as Forest Road 367 or Forest Road 144, which would minimize these impacts. 

Overall, this alternative would result in greater limitations for the siting of geothermal 

infrastructure, compared to Alternative 1, which could result in more concentrated areas of 

development. Recreation experiences and opportunities may be diminished by increased visual 

and noise impacts. These impacts would occur in areas not subject to leasing closures or NSO 

stipulations.

Compared with Alternative 1, Alternative 2 provides specific guidance to ensure that a National 

Forest-wide approach is adopted and that land use issues are considered across all users of the 

SFNF.

3.4.2.6 Impacts Under Alternative 3—No Leasing

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. Under the no 

lease alternative, there would be no direct or indirect impacts on land use, recreation, or special 

designations in the project area.

3.4.2.7 Impacts Under Alternative 4—Development 

Relevant stipulations and closures detailed in Chapter 2 would be designed to protect special 

designation areas, such as IRAs, the JNRA, Scenic Trails, recreation areas, and land uses. 

Impacts would be similar to those described under Alternative 2. However, because of the 

greater access to SFNF lands and fewer overall restrictions, Alternative 4 may have greater 

indirect impacts—such as noise, fugitive dust, and visual intrusions—on special designation 

areas, recreation opportunities, and land uses on the SFNF. Impacts on recreational use of hot 

and warm springs would be the same as those described under Alternative 1.
Chapter 3. Affected Environment and Environmental Consequences

3-16 Santa Fe National Forest Geothermal Leasing EIS

The JNRA is closed to leasing under Alternative 4. However, there could be impacts on other 

types of recreation areas, including remote portions of the SFNF and areas currently valued for 

solitude and low-density visitation. More trucks, possible road improvements, and more people 

could reduce the overall recreation experience on the SFNF, compared to Alternative 3. Traffic 

noise may disrupt the experience of people staying in campgrounds and picnic areas along NM 4 

and NM 126. Evening and night traffic from trucks and project equipment would be light, but 

traffic noise from evening and night travel could indirectly impact campers’ experience. Daytime 

traffic may have fewer impacts because many campers are elsewhere during the day, in contrast 

to users of picnic areas that are open only during the daytime. 

Other special designations in the project area, including the wild and scenic segment of the East 

Fork of the River, Canones Creek National Recreation Trail, and the seven IRAs are either 

closed to leasing or subject to NSO under Alternative 4. No direct impacts would occur in these 

areas. The Jemez Mountain Trail National Scenic Byway, 21.8 miles of which fall within the 

project area, could include minor, temporary impacts from congestion, resulting from large, 

long-wheelbase construction vehicle traffic during geothermal exploration and development.

3.4.2.8 Cumulative Impacts, Land Use, Recreation, and Special Designations

Consent to the issuance of a geothermal lease has no direct impact on the environment (40 CFR, 

Subpart 1508.8[a]); however, it is a commitment of the resource for potential future exploration, 

drilling operations and development, utilization, and reclamation and abandonment. These would 

be subject to environmental review under NEPA and project-specific permitting from the BLM 

and the SFNF. However, any future development of geothermal resources, if or when it does take 

place, may result in impacts, whether deemed significant or not. It is reasonable, therefore, to 

foresee that on-the-ground impacts on land use, recreation, and special designation areas may 

occur if the Forest Service consents to leasing and the BLM issues geothermal leases. Those 

impacts would not occur, however, until some point in the future, following several decision 

stages. 

Past and present activities that have had cumulative impacts on land uses, recreation, and special 

designation areas are wildfire, mining, ranching, timber cutting, road building, off-road vehicle 

riding, and dispersed camping, including in sensitive riparian areas, such as along the wild and 

scenic portion of the East Fork of the Jemez River near Las Conchas. 

Reasonably foreseeable future actions are the proposed South Pit Pumice Mine Expansion, the 

Duran 2010 Pumice Mine, the inventory and evaluation steps of the wilderness recommendation 

process, and the VCNP designation as a significant geothermal feature under the Geothermal 

Steam Act of 1970 (30 USC, Section 1019). The two pumice mines are on the Jemez Ranger 

District and could have a cumulative impact on recreation and land uses. Specifically, they could 

have indirect impacts related to noise, traffic, fugitive dust, and visual intrusions. Further, if the 

NPS successfully nominates the VCNP as a significant thermal feature under the Geothermal 

Steam Act, areas next to the caldera, or those with hydrological connections, may not be leased; 

this could reduce potential indirect impacts on land uses, recreation, and special designations. 

Under the inventory and evaluation steps of the wilderness recommendation process, the current 

conditions of the land are taken into consideration. Because the inventory and evaluation process 

has not yet been completed, it is unknown if any lands that may be made available for leasing 

under Alternatives 2 or 4 would also be recommended for wilderness designation. However, 

while unlikely, it is possible that after further site-specific review the Forest Service could 

consent to leasing and the BLM could issue leases in areas that are later recommended for 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-17

inclusion in the National Wilderness Preservation System. Any preexisting leases would not be 

revoked, if areas were ultimately designated as wilderness. As such, geothermal exploration and 

development could be incompatible with existing land uses or those on adjacent lands, 

depending on the outcome of the inventory and evaluation steps of the wilderness 

recommendation process. 

Other reasonably foreseeable actions could include potential fire management activities, timber 

sales, mineral leases, and transmission lines 

Incremental cumulative impacts are not anticipated under Alternative 3, because the project area 

would be closed to geothermal leasing. Under Alternatives 2 and 4, there would be incremental 

cumulative impacts on recreation, including noise, fugitive dust, increased traffic, and visual 

intrusions that may diminish recreation experiences. However, special designation areas would 

not be affected, due to NSO stipulations. Further, any ground disturbance or other future actions 

that would occur under Alternatives 2 and 4 would require further decision-making under NEPA. 

This would involve a wide variety of factors; examples are policy initiatives about timing of 

actions, whether any applications are submitted or any funding is available, and compliance with 

other authorities and policies. The use of TLs, CSUs, and NSOs should minimize conflicts with 

land use, recreation, and special designation areas, as should individual analyses under NEPA 

that would determine project-specific direct, indirect, and cumulative impacts. Alternative 1 

would also follow this action-specific NEPA process. 

3.5 Geologic Resources

3.5.1 Affected Environment

3.5.1.1 Geologic Setting

The project area is in the Jemez Mountain region of northern New Mexico, to the west of the Rio 

Grande Valley. It sits at the southern margin of the Rocky Mountain ecoregion on the west side 

of the Rio Grande Rift Zone. The Jemez Mountains are part of the Jemez Lineament, which is a 

chain of volcanic centers extending from Arizona to Colorado. The Rio Grande Rift is a feature 

where the crustal plate is separating that stretches from the Colorado Rockies to Mexico. The 

project area lies above the intersection of the Jemez Lineament and the Rio Grande Rift. A 

dormant super-volcano beneath the project area has erupted numerous times due to tectonic 

movements (Muldavin and Tonne 2003). The last eruption occurred 40,000 to 50,000 years ago. 

The Valles Caldera crater was created by a massive eruption 1.25 million years ago, and is now a 

13-mile-wide crater-shaped landscape. It contains a former 89,000-acre ranch that is now the 

VCNP, bordered on three sides by the project area (Forest Service 2016c).

The Jemez Mountains and Valles Caldera are composed of Quaternary Period alluvial and 

landslide deposits, welded Bandelier tuff, Tertiary basalt, basaltic-andesite, or rhyolite and 

breccias, which originated from volcanic activity in the region 13 million years ago. These rocks 

overlie Tertiary, Mesozoic, and Paleozoic sedimentary rocks, which in turn overlie Precambrian 

granitic basement rock. More specifically, the Paleozoic Madera limestone underlies the 

redstones, siltstones, and shale of the Abo Formation, with the Mesozoic Chinle formation and 

the Tertiary Santa Fe Group and Abiquiu tuff superseding. The more permeable layers of 

volcanic tuff allow for groundwater to occur in perched aquifers above the relatively 

impermeable Abo Formation (Forest Service 2016c).
Chapter 3. Affected Environment and Environmental Consequences

3-18 Santa Fe National Forest Geothermal Leasing EIS

The rocks are down-faulted to the east into the Rio Grande Rift. Unconsolidated Tertiary 

sediments of the Santa Fe Formation thicken eastward toward the axis of the rift. The Jemez 

Mountains volcanics occur at the intersection of the rift with the northeast-trending Jemez 

Lineament, a line of Miocene to Quaternary volcanic fields extending across the northwest 

portion of New Mexico (Aldrich and Laughlin 1984; Shevenell et al. 1987).

The Chama River cuts through the southeastern Colorado Plateau and southern Rocky 

Mountains, which consists of high mesas dissected by tributaries of the Rio Chama and its main 

stem. Rock units exposed in the lower reach of the river are the Ojo Caliente sandstone, Abiquiu 

tuff, and Lobato basalt (Wells 2009).

Downstream of the Abiquiu Reservoir, to the confluence of the Rio Chama with the Rio Grande,

and following the Rio Grande downstream to its confluence with the Jemez River, the valley 

floors also consist of Tertiary Period partly compacted sands and gravels of the Santa Fe group

or Quaternary Period alluvium. The Santa Fe Group consists of alluvial fans, river channel 

deposits, and interbedded volcanic rocks. Several of the mesas are capped by Triassic Period 

basaltic to andesitic lava flows (NRCS 2011a).

The project area is characterized by 21 unique geologic units, as shown in Table 3-2, below. 

Bandelier Tuff (56,400 acres) is the most dominant unit in the decision area.

Table 3-2. Geologic Units in Decision Area

Unit Name Acres in Project Area

Quaternary

Alluvium 1,700 

Bandelier Tuff 56,400 

Landslide deposits and colluvium 2,000 

Piedmont alluvial deposits 900 

Older rhyolite lavas and early volcaniclastic sedimentary fill deposits 600 

Ring-fracture Valles Rhyolite lava domes 13,000 

Quaternary and Tertiary

Upper Santa Fe Group 100

Tertiary

Basalt and andesite lava flows (Miocene) 3,200 

Silicic to intermediate volcanic rocks 23,700 

Intermediate to silicic volcanic rocks 20,600 

Paleogene sedimentary units 2,000 

Lower Santa Fe Group 12,100

Cretaceous

Dakota Sandstone 3,300

Mancos Shale 1,000

Jurassic

Morrison Formation 9,200

Triassic

Chinle Group 7,700
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-19

Table 3-2. Geologic Units in Decision Area

Unit Name Acres in Project Area

Paleozoic

Abo Formation 5,200

Cutler Formation 4,200

Madera Formation 3,900

San Andres Limestone and Glorieta Sandstone 700

Yeso Formation 600

Source: New Mexico Bureau of Geology and Mineral Resources GIS 2003

The distribution of geologic units, along with faults and volcanic vents, are shown in Figure 3-1, 

Geology. Faults in the project area include both concealed (i.e., covered by another unit) and 

exposed (i.e., visible at the surface) types. Major fault zones in the region include the Jemez fault 

zone, Cañada de Cochiti fault zone, and Pajarito fault zone (Heiken et al. 1990); these are 

described in greater detail below. 

The Jemez Fault Zone

The northeast striking Jemez fault zone is in the southern region of the project area. This fault 

zone offsets Pennsylvanian-Permian rocks and Bandelier Tuff. Several fault splays north of the 

Jemez fault zone strike northeast, parallel to the strike of the main fault (Kelley et al. 2003). An 

estimated 25 to 50 percent of discharge from the Valles caldera hydrothermal outflow plume is 

confined to this fault zone (Goff et al. 1988).

Pajarito Fault Zone

The Pajarito fault zone occurs east of the project area. It is a north-northeast trending series of en 

echelon2faults along the eastern flank of the Jemez Mountains. This is the active boundary fault 

along the western edge of the Española Basin of the Rio Grande rift. The main fault scarp 

exhibits up to 300-foot displacement in the Bandelier Tuff unit and skirts much of the western 

side of LANL (Dransfield and Gardner 1985).

Cañada de Cochiti Fault Zone

The Cañada de Cochiti fault zone lies west of the Pajarito fault zone at the southern end of the 

project area. Displacements of the Pleistocene Bandelier Tuff are as much as 330 feet (Smith and 

Lynch 2007). 

3.5.1.2 Geologic Hazards

Seismic Activity

The project area lies above several faults. There were 54 earthquakes in the vicinity of the SFNF 

between 1962 and 2014, with the largest having a magnitude 3.5. The probability of an 

earthquake exceeding magnitude 5.0 in the project area in the next 20 years ranges from 3 

percent to 15 percent (USGS 1999). A magnitude 5.0 earthquake may damage poorly constructed 

structures but have little to no damage on well-constructed structures. 

 

2 Closely spaced, parallel or subparallel, overlapping or step-like, minor structural features, which lie 

oblique to the overall structural trend.
Chapter 3. Affected Environment and Environmental Consequences

3-20 Santa Fe National Forest Geothermal Leasing EIS

Earthquakes of high magnitude and intensity have the potential to damage dams. The largest dam 

in the vicinity of the project area is the Abiquiu Dam, in Rio Arriba County. The Rio Arriba 

County Hazard Mitigation Plan (Rio Arriba County Office of Emergency Management 2014) 

describes the probability of the Abiquiu Dam failing to be “rare”. Small earthquakes are 

expected to continue to occur in the vicinity of the project area (Forest Service 2015c). 

Seismic activity can be caused by human activity in areas with certain types of faults and a 

critical state of stress in the rocks. Changes in pore pressure, or stress, on a fault may occur when 

fluids are injected into or extracted from a well. This change may lead to movement along that 

fault, resulting in a seismic event. Increased seismicity in the central United States in recent 

years has been linked to injection of wastewater or other fluids in high volumes over an extended 

period in deep disposal wells (Petersen et al. 2015). Geothermal development has been 

associated with induced seismicity but only in cases of enhanced geothermal systems (i.e., 

injecting and withdrawing fluids from rock formations to enhance rock permeability and recover 

heat from the rock; Majer et al. 2012). The seismic events believed to have resulted from this 

activity have almost all been of relatively small magnitude. Most of these events are rarely felt 

by the time the seismic energy reaches the surface (Majer et al. 2007). 

The USGS is working to create a seismic hazard model that incorporates induced seismicity into 

predictions of probability of future seismic events. A 2014 report prepared by the USGS states 

that forecasting the seismic hazard from induced seismicity is fundamentally different from 

forecasting the seismic hazard for natural seismic activity. This is due to the economic and policy 

factors that affect where fluid extraction and injection occurs. The report concludes that the rates 

of induced earthquakes are inherently variable and non-stationary and therefore are extremely 

difficult to predict on a multi-year basis (Petersen et al. 2015). As a result, the risk of induced 

seismicity in the project area cannot be accurately predicted at this time.

The USGS has identified 17 areas in the central and eastern United States that contained 

seismicity suspected to have been induced by fluid injection or removal. These areas are called 

induced seismicity zones. New Mexico contains two such zones—the Raton Basin near the New 

Mexico-Colorado border and Dagger Draw in southeastern New Mexico. While earthquakes 

recorded in these zones could be natural, the USGS believes they may be induced seismicity. 

This is because the earthquakes are all located near deep fluid injection wells or other industrial 

activities capable of inducing earthquakes (Petersen et al. 2015). Neither of the induced 

seismicity zones in New Mexico are in or near the project area.

Volcanic Activity

There is a long history of volcanic activity in northern New Mexico, including the SFNF 

(Schwab et al. 2008). All of the volcanoes on or near the SFNF are considered extinct, except for 

those in the Valles Caldera. As discussed in Geologic Setting, above, the project area surrounds 

three sides of the Valles Caldera and sits above a dormant super-volcano. The volcano has not 

erupted in the past 40,000 to 50,000 years. However, new magma has been detected in the 

volcanic deposits beneath the project area, suggesting that “the Jemez Mountains volcanics field 

may be entering a new phase of activity” (Dunbar 2010). Those studying the area conclude that 

the volcanic features beneath the project area are likely to erupt again but that the next eruption 

may not occur for thousands, or even tens of thousands, of years (Dunbar 2010). In its New 

Mexico State Hazard Mitigation Plan (2013), the New Mexico Department of Homeland 

Security and Emergency Management estimated the probability of a volcanic eruption anywhere 

in New Mexico to be extremely low. Studies of magma bodies in New Mexico indicate that 
Figure 3-1 Santa Fe National Forest Geothermal Leasing EIS 3-21 Chapter 3. Affected Environment and Environmental Consequences
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Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-23

magma deposits may occur as little as 2.5 miles below the earth’s surface; however, most of the 

deposits are believed to occur between 3.7 and 11.8 miles below the surface (Sanford 1983; 

Fialko and Simons 2001). 

Naturally Occurring Radioactive Material

Some geologic formations, including the Mancos Formation in northwestern New Mexico, 

contain low levels of radioactive materials, such as uranium and thorium, and their decay 

elements, radium 226 and radium 228 (USGS 1999). These elements emit the same levels of 

radiation that humans are generally exposed to on a daily basis (BLM 2014). These naturally 

occurring radioactive materials (NORM) can be brought to the surface during drilling operations 

that remove fluids from the radioactive formation (Sumi 2008). 

Pipes and other equipment that handle large volumes of water flowing out of formations over the 

long term can become coated with scale deposits that contain radium (USGS 1999). Radiation 

levels on these pipes may increase above background levels over time to a level that can be 

dangerous to those who handle the equipment (USGS 1999). However, the radiation is weak 

enough that it cannot penetrate dense materials, such as the steel used in pipes and tanks, to 

contaminate the surrounding environment (BLM 2014).

3.5.2 Environmental Consequences

3.5.2.1 Scoping Comments on Resource

The following issues specific to geologic resources were identified during the public scoping 

period:

 What are the impacts on geologic resources from geothermal developments? Could there be 

increased risk for induced seismicity or other geologic hazards as a result of geothermal 

leasing? If so, what are the indirect impacts of geologic hazards, considering the proximity 

of the Abiquiu Dam and LANL?

 Is baseline seismic monitoring or additional fault mapping required to determine the risk of 

induced seismicity or other geologic hazards associated with geothermal exploration or 

development?

3.5.2.2 How Resource Impacts Were Evaluated

Method

The potential impacts of geothermal development were evaluated by assessing the impacts that 

anticipated future actions under the alternatives would have on the geologic resources of the 

project area. 

Indicators

The following indicators have been identified in order to evaluate potential impacts on geology 

and seismicity: 

 Changes in seismic activity, including both natural and induced seismicity

 Changes in volcanic activity

 Release of NORM into the environment

 Ground subsidence
Chapter 3. Affected Environment and Environmental Consequences

3-24 Santa Fe National Forest Geothermal Leasing EIS

Assumption

This analysis assumes that further environmental analysis would be completed before enhanced 

geothermal systems are authorized in the project area.

3.5.2.3 Common Impacts Associated with Geothermal Development

The information presented in the Common Impacts on Geology Resources and Seismic Setting 

Associated with Geothermal Development section of the 2008 Geothermal PEIS is incorporated 

by reference and summarized here. 

Although the concerns identified above in the Indicators are discussed here and in the 2008 

Geothermal PEIS, due to the inability to predict future types of development, the timing, and 

locations, the potential for these impacts to occur can only be fully evaluated once a site-specific 

proposal is submitted. Any subsequent, site-specific projects that might occur in the project area 

would undergo NEPA review, during which geotechnical investigations may be conducted, if 

deemed necessary. 

Seismic risk could increase if geothermal resource development includes high pressure 

reinjection along any faults intersected by the injection well. However, the risk is reduced where 

geothermal fluid withdrawn from the resources is used and then reinjected into the system for a 

near zero net change.

While the project area has had historic volcanic activity and has the potential for future volcanic 

activity, geothermal development in the project area is not expected to affect the risk of this 

activity. As discussed under Section 3.5.1, studies of magma bodies in New Mexico indicate that 

magma deposits may occur between 2.5 and 11.8 miles below the earth’s surface, though most 

deposits occur at least 3.7 miles below the surface (Sanford 1983; Fialko and Simons 2001). The 

deepest geothermal wells are drilled to approximately 2.2 miles below the surface, and most are 

shallower than that (Finger and Blankenship 2010; Brown 2009 [Fenton Hill]). Therefore, the 

potential for a geothermal well to encounter a magma deposit is low.

NORM can be released from subsurface formations during drilling as drill cuttings and during 

withdrawal of groundwater associated with geothermal development. Radioactivity associated 

with NORM cannot penetrate the well casings, so the potential for long-term exposure to the 

environment is low. Drill cuttings can be tested to determine whether they present a hazard and, 

if so, removed to a licensed disposal site.

Subsidence can occur where groundwater is pumped from underground aquifers at a rate 

exceeding the rate at which it is replenished. When water is withdrawn, sediments may compact, 

because the water may be partially responsible for bearing the weight of overlying sediments. 

Unconsolidated alluvial or basin-fill aquifer systems comprised of aquifers and aquitards3are 

generally the most susceptible to subsidence (Galloway and Burbey 2011). The underlying Rio 

Grande aquifer system is one such unconsolidated sand basin-fill system. However, in the project 

area, no land subsidence has been recorded (Rio Arriba County Office of Emergency 

Management 2014; Sandoval County 2013). Most geothermal development techniques include 

reinjecting the geothermal fluid after the heat is used and maintaining static pressure of the 

geothermal reservoir; therefore, the potential for subsidence during these activities is low.

 

3 A geologic formation or stratum that lies next to an aquifer and that allows only a small amount of liquid 

to pass.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-25

Pumped groundwater used to supply hydraulic stimulation and makeup water (as described in 

Section 3.9) would not be reinjected; however, the applicant would be required to obtain water 

rights, and the source and location of makeup water is unknown. Once proponents submit plans 

of exploration and development, project-specific information, studies, and modeling would help 

to better understand the risk of subsidence in the project area due to groundwater pumping for 

stimulation and makeup water.

Enhanced Geothermal Systems 

The process of stimulating production and injection wells by injecting water under pressure, and 

often at a much cooler temperature than the receiving rock, results in the expansion of existing 

fractures and sometimes the creation of new fractures through the movements of masses of rock 

at depth. This fracturing method is commonly referred to as hydro-shearing or shearing. These 

movements result in seismic activity. Since the seismic activity is created by the reservoir 

stimulation, it is distinguished from natural seismicity by the term induced seismicity. Whether 

or not the induced seismicity can be felt at the surface depends on the depth of the reservoir, the 

degree to which the rock masses are shifted from the stimulation, and the nature of the overlying 

geology and its ability to transfer the shock waves to the surface. 

Typically, natural fractures vary in length on a scale of 1 to 10 meters. Seismic energy radiated 

during the shearing process depends on the length of the fracture or the stress release from the 

constraining natural forces. Most of the observed data from existing enhanced geothermal 

systems projects suggest that the higher energy radiated from the shearing is caused by a high 

stress release from relatively small joint lengths (Michelet et al. 2004). This would suggest that if 

there were some perceived seismicity on the surface, the frequency content would be too high to 

generate any seismic risk, but minor events may still raise concern among local inhabitants. As 

part of the NEPA process for any specific enhanced geothermal systems proposal, mitigation 

measures, such as seismic monitoring requirements, would be developed to address the potential 

for seismic-related risks.

Protocols 

The International Energy Agency developed a peer-reviewed and accepted protocol for

addressing induced seismicity during geothermal projects, and the DOE has adopted it (Majer et 

al. 2012). Such protocols may be made a requirement of any enhanced geothermal systems

project. The protocol calls for the following steps to be taken for a site-specific project:

 Perform a preliminary screening evaluation

 Implement an outreach and communication program

 Review and select criteria for ground vibration and noise

 Establish seismic monitoring

 Quantify the hazard from natural and induced seismic events

 Characterize the risk of induced seismic events

 Develop risk-based mitigation plan

Induced Seismicity Hazards Risk Analysis 

If desired by the operator or required by the Forest Service, an independent consultant can be 

contracted to prepare an induced seismicity and seismic risk hazards analysis. Such analyses 

identify and quantify the risk associated with induced seismicity and can focus its content on 

potential impacts on nearest communities and homeowners.
Chapter 3. Affected Environment and Environmental Consequences

3-26 Santa Fe National Forest Geothermal Leasing EIS

Prediction of Event Number and Magnitude 

Recent advances have been made in predicting the number and magnitude of induced seismicity 

that can be expected during hydro-shearing operations. If desired by the operator or required by 

the Forest Service, mechanisms of induced seismicity can be quantified and a “seismogenic 

index” can be developed for a specific area. Such an index would characterize the potential 

number of induced seismicity events greater than a particular magnitude as a function of the 

injected volume. Changes to injection rates and total fluid volumes can be used during 

operations to manage seismic impacts. The maximum allowable magnitude is determined by the 

induced seismicity and seismic hazard risk analysis. Evaluation of the seismogenic index will 

allow project geologists to place initial bounds on the hydro-shearing operational and mitigation 

limits for a given project. 

Control Rate of Injection and Bleeding Reservoir Pressure after Injection 

Mitigation measures can be implemented if induced seismic events approach defined limits. The 

primary mitigation method may be reducing the rate of water injection to a level where an 

induced seismicity rate and magnitude are within an acceptable range. A secondary method can 

be to backflow the well to reduce reservoir pressure. 

The utilization phase of enhanced geothermal systems projects could produce micro-seismic 

events. Seismic data collection arrays may be set up before any well stimulation so that induced 

seismicity can be monitored in real time. This monitoring allows supervising geologists to track 

where the reservoir is opening up and allows operations to be modified, as needed. The ongoing 

monitoring of micro-seismicity with multi-station sensor arrays would allow regulators to 

continuously review the project and halt or modify operations if the risk to properties is 

considered to be too great.

3.5.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. 

Projected geothermal development under Alternative 1 may increase the impacts on geologic 

resources, described under Common Impacts Associated with Geothermal Development. As 

noted under Common Impacts Associated with Geothermal Development, these impacts of 

increased seismic risk, volcanic activity, release of NORM, and subsidence are all low. While the 

risk of increased seismicity cannot be quantified at this stage, development using enhanced 

geothermal systems would not be authorized without further analysis of the risks of induced 

seismicity associated with a proposed project.

Earthquakes can result in indirect impacts, including building damage; disruption of 

communications, electrical power supplies, gas, sewer, and water lines; fires, dam failures, 

landslides, and released hazardous materials (New Mexico Department of Homeland Security 

and Emergency Management 2013). These impacts depend on the magnitude4and intensity.5 The 

increased risk of induced seismicity would increase the potential for indirect impacts from 

 

4 A fixed property of an earthquake source, estimated from seismograms, proportional to the logarithm of 

the total energy released.

5 The strength of ground motion at a specific location.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-27

earthquakes; however, the likelihood of these impacts would be evaluated at the exploration and 

development stage. 

Impacts on structures or facilities at LANL are highly unlikely, because the fault zone beneath 

LANL (the Pajarito fault zone) lies east of the Jemez and Cañada de Cochiti fault zones, which 

are the primary fault zones that overlap the project area.

3.5.2.5 Impacts Under Alternative 2

Impacts under Alternative 2 on geologic resources would be the similar as those described under 

Alternative 1. BMPs identified in Appendix C include monitoring during all phases of 

development and adaptive management strategies developed at the project level. These measures 

would reduce the risk of geologic hazard impacts.

3.5.2.6 Impacts Under Alternative 3

Under Alternative 3, the entire project area would be closed to geothermal leasing. Therefore, the 

impacts described under Common Impacts Associated with Geothermal Development would not 

occur.

3.5.2.7 Impacts Under Alternative 4

Impacts under Alternative 4 on geologic resources would be the same as those described under 

Alternative 2.

3.5.2.8 Cumulative Impacts

Cumulative impacts on geologic resources from geothermal exploration, drilling, and 

development are expected to be minor. BMPs identified in Appendix C—such as geotechnical 

investigations and monitoring, and mitigation of impacts from future drilling activities—would 

be implemented. Any impacts from development that might occur would be minimal and largely 

limited to the project site. Seismic events related to geothermal reservoir injection could 

cumulatively contribute to seismic events triggered by multiple operations; however, the risk of 

seismic events triggered by specific geothermal development activities cannot be assessed at this 

time.

3.6 Energy and Mineral Resources

3.6.1 Affected Environment

In this section, energy and mineral resources are discussed, along with their association with 

geothermal resources. This section addresses the Forest Service’s general regulatory framework 

for energy and mineral resource development, regulations particular to the project area, energy 

resources and activity in New Mexico and the project area, and mineral resources and activity in 

New Mexico and the project area.

Wind, solar, biomass, and geothermal energy are considered renewable energy resources. The 

Forest Service manages these activities (except geothermal) under 36 CFR, Part 251, Subpart B. 

These resources all have different factors influencing the feasibility of their development. 

However, some issues are common to all, including distance to existing power transmission 

facilities and compatibility with existing federal land use.
Chapter 3. Affected Environment and Environmental Consequences

3-28 Santa Fe National Forest Geothermal Leasing EIS

On federal lands, mineral resources are governed by the General Mining Law of 1872, as 

amended; those portions of the FLPMA that affect the General Mining Law; the Mineral Leasing 

Act of 1920; the Surface Resources Act of 1955; and the Mining and Minerals Policy Act of 

1970. Oil and gas leasing is guided by the Energy Policy Act of 2005, and geothermal leasing is 

guided by the Geothermal Steam Act of 1970 (30 USC 1004), as amended by the Energy Policy 

Act of 2005.

The Forest Service manages oil and gas operations on NFS lands under 36 CFR, Part 228, 

Subpart E. Mineral leasing operations are guided by Forest Service Manual 2820; mineral 

prospecting, including geophysical activities, is guided by Forest Service Manual 2860. 

Locatable minerals and surface management regulations fall under 36 CFR, Part 228, Subpart A, 

and Forest Service Manual 2810. Mineral materials are regulated under 36 CFR, Part 228, 

Subpart C, and Forest Service Manual 2850. Within the SFNF, the right to occupy and use 

surface lands as reasonably necessary to carry on prospecting and mining is guided by 16 USC, 

Subsection 482(j). 

A portion of the project area overlaps the JNRA. Subject to valid existing rights, lands in the 

recreation area are withdrawn from locatable mineral entry under the General Mining Law of 

1872 and the Mineral Leasing Act of 1920, 16 USC, Subsection 460jjj-2(b). Locatable mineral 

development is similarly prohibited within 0.25 mile of the high-water mark on either side of the 

East Fork of the Wild and Scenic Jemez River. As a result, nearly one-quarter of the project area 

is withdrawn from mineral leasing.

3.6.1.1 Energy Resources in New Mexico

New Mexico is an energy exporter, producing 2.4 times as much energy as it consumes (New 

Mexico Energy, Minerals & Natural Resources Annual Report 2015). In 2014, New Mexico 

exported 13 million megawatt hours of electricity (EIA 2014). Coal, crude oil, natural gas, 

uranium, hydroelectric, solar, wind, and geothermal resources are all being developed in the 

state.

The state ranks sixth nationally in crude oil production, seventh in dry natural gas production, 

twelfth in coal production, 38th in electricity production. It is home to over a quarter of proven 

US coal-bed methane reserves, second only to Colorado. These resources are produced largely 

on federal lands, but approximately 25 percent is produced on state lands, with fractional 

amounts produced on private and tribal lands (EIA 2015b).

Electric utilities must meet the State’s renewable portfolio standard by including a State policydetermined proportion of renewable energies in their total generating capacity. Investor-owned 

utilities must have no less than 20 percent of their generation come from renewable energies by 

2020, while rural electrical cooperatives, like the Central New Mexico Electric Cooperative,

must have no less than 10 percent by 2020. In 2007, the New Mexico Public Regulation 

Commission issued an order requiring renewable generation used to meet the standard to include 

no less than 30 percent wind, 20 percent solar, 5 percent other renewable technologies, and 1.5

percent distributed generation (New Mexico Public Regulation Commission 2016).

Historically, coal and natural gas have been the major fuel sources for electrical generation in 

New Mexico. Since 1990, these fuels have accounted for over 90 percent of the state’s 

generation. Wind and solar accounted for 7 percent of that capacity, while hydro-electric and 

petroleum combined contributed less than 0.5 percent. In 2013, geothermal energy sources 

generated 0.0002 percent (or 69 megawatt hours) in the state (EIA 2016).
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-29

From 1870 to 1890, the US Army Corps of Engineers surveyed much of New Mexico and 

identified the following as geothermal waters: the San Ysidro Spring, Ojo Caliente, Ponce de 

Leon Warm Springs, San Antonio Hot Springs, San Antonio Warm Springs, Jemez Hot Springs, 

Montezuma Hot Springs, Apache Tejo Warm Springs, Faywood Hot Springs, and the Mimbres 

Hot Springs (Summers 1976).

In the mid-1960s, the State of New Mexico took on its own effort to inventory geothermal waters 

in the state. It identified sources in Gila River Basin, Rio Grande Basin, Pecos River Basin, 

Tularosa Basin, and San Juan River Basin, to varying extents (Summers 1976).

In the early 1980s, the New Mexico Energy and Minerals Department funded two projects to use 

geothermal energy, both outside of the project area. The first, at Carrie Tingley Hospital, used 

geothermal waters to heat a pool used for physical therapy treatments. The second used 

geothermal water as a low-temperature space heating system at a senior citizens’ center (Lund 

and Witcher 2002).

3.6.1.2 Energy Resources in the Santa Fe National Forest Project Area

The project area is in the Albuquerque-Santa Fe Rift province identified in the USGS National 

Oil and Gas Assessment (Molenaar 1995). There has been no oil or gas production in the project 

area, and none is expected during the next 20 years. There are no active or pending coal leases in 

the project area, and coal resources have not been identified there (Hoffman 1996). 

As discussed in Chapter 1, Purpose of and Need for Action, the project area contains the lands 

identified by SFNF as most likely to receive geothermal lease nominations and applications, 

based on the favorability of its geothermal resources (see Figure 1-4, Geothermal Potential 

Areas). However, no geothermal development has occurred in the project area to date, largely 

due to the lack of transmission lines there.

The RFDS prepared by SFNF (BLM 2015) projects development of 15 temperature gradient 

wells and 5 slim wells over the expected life of the plan. Development of five 25-MW binary 

power plants containing six wells each is also predicted. (See the SFNF’s RFDS [BLM 2015] for 

detailed explanation of the different types of geothermal wells.)

There are no active or pending proposals for wind energy in the project area, and there is little 

potential for wind energy development. There is no known potential for hydroelectric power in 

the project area.

3.6.1.3 Mineral Resources in New Mexico

The earliest mining in the region started around 1870 with the production of sheet mica (Bingler 

1968). This mineral is now used primarily in the electronic industry due to its unique electrical, 

insulating, and mechanical properties (Dolley 2008). As demand for sheet mica declined, a 

market for electrical mica grew through World War II. Since then, most of the mica mined in 

New Mexico has been processed for scrap mica (Dolley 2008). In the early twentieth century, 

mineral production was primarily for sand and gravel. However, some commercial development 

occurred for gold, silver, copper, lead, zinc, molybdenum, fluorite, and crushed and ornamental 

stones (Bingler 1968).

3.6.1.4 Mineral Resources in the SFNF Project Area

For many centuries, local populations in the SFNF used clay for ceramics and stones for 

buildings. Turquoise was commercially developed and transported from the area. High-grade 
Chapter 3. Affected Environment and Environmental Consequences

3-30 Santa Fe National Forest Geothermal Leasing EIS

copper deposits were also mined by the Spanish and Indians (Gillio 1979; Bingler 1968). Some 

lead was also mined for bullets.

There are no active mineral operations in the project area. The SFNF is offering portions of the 

project area for pumice mining through a competitive sale. Pumice deposits are common in and 

around the project area, due to ancient volcanic eruptions (Schwab et al. 2008).

While other minerals exist in the project area, known occurrences are too small and low grade to 

be economically mined and transported to processing plants. Therefore, development of other 

minerals in the project area is not expected during the life of the Forest Plan.

3.6.2 Environmental Consequences

3.6.2.1 Scoping Comments on Resource

There were no issues specific to energy and mineral resources identified during the public 

scoping period. 

3.6.2.2 How Resource Impacts Were Evaluated

Method

Impacts of energy and minerals were evaluated by examining whether leasing areas for 

geothermal resources would have the potential to impact mining, oil and gas leasing, and 

electricity generation or transmission or the subsequent development of those resources.

Indicators

The potential impacts of geothermal development were evaluated by assessing the impacts that 

anticipated future actions consistent with implementation of the alternatives described in 

Chapter 2 would have on energy and mineral resources. Geothermal leasing would have no 

direct impacts on energy and mineral resources. Impacts would occur from subsequent 

development. Potential impacts on energy and mineral resources could occur if reasonably 

foreseeable future actions were to have any of the following impacts: 

 Result in the construction of transmission lines that would affect the feasibility of other 

energy development along the transmission corridor

 Develop roads that would encourage other energy and mineral exploration in otherwise 

undeveloped areas

 Occupy portions of the project area in a manner that precludes extraction of other minerals 

or development of energy infrastructure

Assumptions

This analysis assumes the following: 

 If the prescription for an administrative designation, as described in the applicable land use 

plans, allows for geothermal leasing, then these areas could remain open to geothermal 

leasing, at the discretion of the Forest Supervisor. 

3.6.2.3 Common Impacts Associated with Geothermal Development 

Improving existing roads and constructing new roads for geothermal resource exploration, 

production, operation and reclamation and abandonment of geothermal resources would have a 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-31

negligible to minor impact on the exploration for other energy and mineral resources in the 

immediate area. The degree of impact would depend on the existing limits to access in the area 

and the distance of the roads to the other mineral resources. Introducing new transmission lines 

would encourage developing other energy resources along the transmission line. Mineral 

resource developments would be encouraged due to the new availability of power for their 

operations. These impacts would be reduced with increased distance from mineral resources to 

the power plant, roads, and transmission lines. 

Drilling operations would hinder the development of other energy or mineral resources on the 

same land; however, after reclamation and abandonment of geothermal operations, developers of 

other energy sources could use the property. Any other ongoing operations in the area that use 

these facilities would have to take over maintenance of shared facilities, such as roads and

transmission lines, or they would also be reclaimed.

The extent of these impacts in the project area would be limited due to the small amount of current 

and expected energy and mineral development in the project area. While additional roads and 

transmission lines would encourage additional energy and mineral development, other limitations 

associated with those resources in the project area may still prevent their development.

3.6.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations.

The Forest Plan calls for sound energy and minerals exploration and development administered 

“to minimize adverse surface resource impacts.” It directs Forest supervisors to respond to 

geothermal lease applications in a timely manner; however, the availability of roads and utility 

corridors is subject to certain restrictions. For example, reconstruction and rehabilitation of 

existing roads is emphasized over new road construction. Roads constructed for mineral 

activities would be built and maintained by the permittee to minimum standards for the intended 

use. Similarly, utility corridors are prohibited in some management areas while placement in 

others would require extensive mitigation measures.

Under Alternative 1, the RFDS prepared by the SFNF (BLM 2015) predicts that fifteen 

temperature gradient wells, five slim wells, and five 25-MW binary power plants (with six wells 

each) would be developed in the project area over the life of the plan. Developing these facilities

could increase accessibility to otherwise undeveloped areas and result in the construction of 

transmission lines. However, there would be a negligible impact on other non-geothermal 

mineral and energy resources, due to the low amount of projected development.

3.6.2.5 Impacts Under Alternative 2

Under Alternative 2, the SFNF would manage approximately 17 percent of the project area as 

closed to geothermal leasing. Another 79 percent would be open, subject to NSOs, 48 percent 

would be open subject to CSUs, and 23 percent would be open subject to TLs.

6 Approximately 1 

percent of the project area would be open to geothermal leasing, subject to standard stipulations. 

 

6 The percentages add up to greater than 100 percent because some stipulations overlap.
Chapter 3. Affected Environment and Environmental Consequences

3-32 Santa Fe National Forest Geothermal Leasing EIS

In accordance with the RFDS (BLM 2015), the amount of expected geothermal development

would be the same as Alternative 1. Therefore, the impacts of that development on other energy 

and minerals resources would be the same as those described under Alternative 1.

3.6.2.6 Impacts Under Alternative 3

Under Alternative 3, the entire project area would be closed to geothermal leasing. Therefore, the 

impacts described under Common Impacts Associated with Geothermal Development would not 

occur. There would continue to be a reliance on other forms of energy production and electrical 

generation in the region, the majority of which come from fossil fuels.

3.6.2.7 Impacts Under Alternative 4

Under Alternative 4, the SFNF would manage approximately 17 percent of the project area as 

closed to geothermal leasing. Another 73 percent would be open subject to NSOs, 73 percent 

would be open subject to CSUs, and 25 percent would be open subject to TLs. Approximately 2 

percent of the project area would be open to geothermal leasing, subject to standard stipulations.

In accordance with the RFDS (BLM 2015), the amount of expected geothermal development

would be the same as Alternative 1. Therefore, the impacts of that development on other energy 

and minerals resources would be the same as those described under Alternative 1.

3.6.2.8 Cumulative Impacts

Geothermal development in the project area could change the electricity generation mix in New 

Mexico by increasing the proportion of geothermal energy used to provide electricity and 

decreasing the proportion associated with other energy sources. This would occur only where 

geothermal resources are developed to produce electricity, and not where they are developed for 

direct use. Under Alternatives 1, 2, and 4, the development of five 25-MW geothermal power 

plants in the project area would add up to 1.1 million megawatt hours per year of geothermalproduced electricity to New Mexico’s energy mix. The additional geothermal electricity 

generated would make up less than 1 percent of the total electricity produced in New Mexico; 

however, it would contribute to the state’s renewable energy standard mandate, calling for 5 

percent of an investor-owned utility’s electrical generation to come from renewable energies 

other than wind, solar, and distributed generation (EIA 2015b [Supply and Disposition of 

Electricity]; New Mexico Administrative Code 17.9.572). 

Alternatively, Alternative 3, at a minimum, would maintain reliance on other forms of energy 

production and electrical generation – the majority of which are generated by burning fossil fuels 

like coal and natural gas.

3.7 Paleontological Resources

3.7.1 Affected Environment

Paleontological resources, or fossils, are the remains, imprints, or traces of once living organisms 

preserved in rocks, sediments, and caves. These include mineralized, partially mineralized, or 

unmineralized bones and teeth, soft tissues, shells, wood, leaf impressions, footprints, burrows, 

and microscopic remains. The fossil record is the only evidence that life on earth has existed for 

more than 3.6 billion years. Fossils are considered nonrenewable resources because the 

organisms they represent no longer exist (BLM and Forest Service 2008). 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-33

Fossils are managed for scientific, educational, and recreational values, such as collecting 

invertebrate fossils and petrified wood for a hobby, and to protect these resources from any 

impacts. Primary regulations governing the protection and conservation of paleontological 

resources on federally administered lands includes the Antiquities Act of 1906 and the 

Paleontological Resource Preservation Act (Sections 6301-6312 of the Omnibus Public Lands 

Act of 2009, 16 USC, Section 470[aaa]). The Antiquities Act protects both historic and 

prehistoric resources on federal lands, and the Paleontological Resource Preservation Act 

provides specific protections for paleontological resources, mandating the management and 

preservation of those resources on public lands, using scientific principles and expertise. In 

addition, FLPMA (Public Law 94-579) requires that public lands be managed in a manner that 

protects the “quality of scientific” and other values, and NEPA requires protections for 

“important historic, cultural and natural aspects of our national heritage.” 

The SFNF issued nine reconnaissance/collecting permits for paleontological resources between 

1997 and 2014. Seasonal interns researched, documented, and published paleontological work on 

northern New Mexico NFS lands in 2004. They identified 1,335 fossil localities in Rio Arriba, 

Sandoval, Santa Fe, Los Alamos, San Miguel, and Mora Counties. Of these sites, 240 are within 

the SFNF boundary or within a 2-mile buffer around the SFNF. The site data were used to 

determine the formations’ potential for vertebrate fossil occurrence (Forest Service 2015c). 

As required by Forest Service Manual 2882.6, the SFNF classified its NFS lands for fossil potential 

using the Paleontological Resources Rapid Assessment System (PRRAS), the results of the 2004 

project, and more recent work. SFNF is using this information and PRRAS rankings to manage 

activities on NFS lands with the potential to disturb or degrade the scientific value of the 

paleontological resources. The PRRAS classification has the following categories: fossil occurrence 

likely (2), fossil occurrence likelihood unknown (1), and fossil occurrence unlikely (0). The project 

area includes geologic units classified as PRRAS 2, 1, and 0, as shown below (Table 3-3).

Table 3-3. PRRAS Classification for Project Area

PRRAS 

Classification Geologic Units Acreage

Fossil occurrence 

likely (2)

Abo Formation, alluvium, Chinle Group, Cutler 

Formation, Dakota sandstone, Lower and Middle Santa 

Fe Group, Madera Formation, Mancos shale, Morrison 

Formation, piedmont alluvial deposits, San Andres 

limestone, Glorieta sandstone, Santa Fe Group, 

Paleogene sedimentary units, and Yeso Formation

68,800

Fossil occurrence 

likelihood 

unknown (1)

Landslide deposits and colluvium, basaltic volcanics, 

and Bandelier tuff

69,300

Fossil occurrence

unlikely (0)

Neogene basalt and andesite flows, Neogene volcanic 

rocks, silicic volcanic rocks, silicic to intermediate 

volcanic rocks, and Valles rhyolite

56,700

Sources: Forest Service 2015c; Forest Service GIS 2015

The project area includes 68,830 acres with geologic units classified as PRRAS 2 (likely fossil 

occurrence) (Forest Service 2015c). These geologic units mostly range in age from the Jurassic 

Era to the Early Pleistocene. Of particular importance are the deposits of Early Paleocene 

mammals that are extremely well preserved in these units. These deposits represent an excellent 

record of the rapid mammalian diversification, following the extinction of the dinosaurs at the 

end of the Cretaceous (BLM and Forest Service 2008). By the late Eocene, all the modern orders 
Chapter 3. Affected Environment and Environmental Consequences

3-34 Santa Fe National Forest Geothermal Leasing EIS

of mammals had evolved and were represented by species that were ancestral to the modern 

forms known today. As climates cooled, the tropical and subtropical forests of the Paleocene and 

early Eocene gave way to more open woodlands; continued global cooling and drying led to the 

evolution of grassland ecosystems during the Miocene. General adaptive strategies for 

mammalian groups at this time included an increase in body size, the ability to digest grasses, 

and a trend toward a greater emphasis on running. 

Decades of scientific investigation have recovered various fossil remains from these geologic 

units, including early reptiles, eohippus (the first horse), camelids, rhinoceroses, gomphotheres 

(ancestors of modern elephants), oreodonts, dogbears, large cats that could be considered sabertoothed, and many other extinct orders, families, and genera (Kues and Lucas 1979; SFNF 

2015). 

3.7.2 Environmental Consequences

3.7.2.1 Scoping Comments on Resource

There were no issues specific to paleontological resources identified during the public scoping 

period.

3.7.2.2 How Resource Impacts Were Evaluated

Method

The PRRAS classification, described above in Table 3-3, describes the potential for 

paleontological resources within a given geological unit and the potential sensitivity that should 

be considered in project planning; however, it does not mean that paleontological resources are 

actually present within those specific units. 

The analysis area for paleontological resources is the project area. The potential impacts of 

geothermal development were evaluated by assessing the impacts that anticipated future actions 

under the alternatives would have on the paleontological resources.

Indicators

Potential impacts on paleontological resources could occur if anticipated actions consistent with 

implementing the alternatives described in Chapter 2 were to involve the following:

 Surface disturbance, such as building roads or preparing drill sites or plant sites, that could 

directly impact paleontological resources

 Surface disturbance that could expose geologic units with potentially important 

paleontological resources, leading to impacts from vandalism or unsupervised and 

unpermitted fossil collection

 Surface disturbance that could cause indirect impacts from increased erosion of important 

fossil resources

General indicators were evaluated, along with those considered in the Geothermal PEIS (BLM 

and Forest Service 2008).
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-35

Assumptions

This analysis assumes that leasing land for potential geothermal development does not involve 

ground-disturbing activities or any type of construction, so there would be no direct impact on 

paleontological resources. Any impacts would result from activities pursued after leasing.

3.7.2.3 Common Impacts Associated with Geothermal Development

The Geothermal PEIS (BLM and Forest Service 2008) provides a general description of 

common impacts on paleontological resources from geothermal resource development, although 

it is not possible to predict specific future development scenarios, including types of 

development, timing, and location. 

Impacts on nonrenewable surface or subsurface paleontological resources, particularly those 

involving PRRAS 2 classifications (fossil occurrence likely), could result from destruction by 

breakage and crushing during surface-disturbing actions. Surface disturbance related to 

geothermal development has the potential to impact an unknown quantity of fossils that may 

occur on or underneath the surface in areas containing paleontologically sensitive geologic units 

classified as PRRAS 2 (fossil occurrence likely). 

Without mitigation, these fossils, as well as the paleontological data they could provide if 

properly salvaged and documented, could be destroyed, rendering them permanently 

unavailable. Impacts can typically be mitigated to below a level of significance by implementing 

CSU or NSO stipulations, such as avoiding or minimizing work in areas with PRRAS 2

classifications (fossil occurrence likely). Mitigation also results in the salvage of fossils that may 

never have been unearthed as the result of natural processes. With mitigation, these newly 

exposed fossils become available for scientific research, education, display, and preservation into 

perpetuity at a public museum. 

Impacts also result from the continuing implementation of management decisions and associated 

activities. For paleontological resources, impacts most commonly occur as the result of 

management actions that increase the accessibility of public lands, increasing the potential for 

loss of paleontological resources by vandalism or unsupervised and unpermitted collecting 

(poaching). These impacts are difficult to mitigate to below the level of significance, but they 

can be greatly reduced by increasing public awareness about the scientific importance of 

paleontological resources through education, community partnerships, and interpretive displays 

and by informing the public about penalties for unlawfully destroying or collecting these 

resources. 

3.7.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analyses, in accordance with the Forest Plan (Forest Service 1987) and existing laws and 

regulations. There would be no impacts on paleontological resources in the JNRA.

Geothermal lease stipulations and closures would not be specifically implemented on 

paleontological resources outside of the JNRA; however, any geothermal lease applications and 

nominations would be subject to the standards and guidelines outlined in the Forest Plan and 

subsequent environmental analysis. The types of impacts that could occur would be the same as 

those described under Common Impacts Associated with Geothermal Development.
Chapter 3. Affected Environment and Environmental Consequences

3-36 Santa Fe National Forest Geothermal Leasing EIS

3.7.2.5 Impacts Under Alternative 2

Impacts under Alternative 2 on paleontological resources would be similar to those described 

under Alternative 1. However, additional lands would be identified as closed to leasing or subject 

to NSO, CSU, and TL stipulations. Closures and stipulations would not be specifically 

implemented for paleontological resources; however, closures and stipulations for other 

resources would also protect geologic units with likely fossil occurrences. In PRRAS 2, 8,400 

acres would be closed to geothermal leasing, 39,400 acres would be subject to NSO stipulations, 

and 25,700 acres would be subject to CSU stipulations (Forest Service GIS 2015). 

In accordance with BMPs identified in Appendix C, if paleontological resources are present at a 

site, or areas with a high potential to contain paleontological material have been identified, a 

paleontological resource management plan would be developed. The potential is low for 

geothermal development to impact sensitive geologic units (those classified PRRAS 2 [fossil 

occurrence likely]), considering geothermal leasing closures, stipulations, and BMPs. 

3.7.2.6 Impacts Under Alternative 3

Under Alternative 3, the entire project area would be closed to geothermal leasing. Therefore, the 

impacts on paleontological resources described under Common Impacts Associated with 

Geothermal Development would not occur.

3.7.2.7 Impacts Under Alternative 4

Impacts under Alternative 4 on paleontological resources would be similar to those described 

under Alternative 2; however, fewer acres of PRRAS would be subject to NSO stipulations and 

closures, and more acres would be subject to CSU stipulations. In PRRAS 2, 7,800 acres would 

be closed to geothermal leasing, 35,900 acres would be subject to NSO stipulations, and 35,800 

acres would be subject to CSU stipulations. The potential is low for geothermal development to 

impact sensitive geologic units (those classified PRRAS 2 [fossil occurrence likely]), 

considering geothermal leasing closures, stipulations, and BMPs.

3.7.2.8 Cumulative Impacts

Consenting to issue a geothermal lease has no direct impact on the environment (40 CFR, 

Subpart 1508.8[a]); however, it is a commitment of the resource for potential future exploration, 

drilling operations and development, utilization, and reclamation and abandonment. These would 

be subject to environmental review under NEPA and project-specific permitting from the BLM 

and the SFNF. However, any potential future development of geothermal resources may result in 

impacts, whether deemed significant or not. It is reasonable, therefore, to foresee that cumulative 

impacts on sensitive geologic units (those classified PRRAS 2 [fossil occurrence likely]) could 

occur if the Forest Service were to consent to leasing and the BLM were to issue geothermal 

leases under Alternatives 1, 2, and 4. Those impacts would not occur, however, until some point 

in the future, following further decision-making under NEPA. Moreover, the use of CSU or NSO

stipulations would likely minimize or avoid impacts on paleontological resources. 

Alternative 3 would have no cumulative impacts on paleontological resources.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-37

3.8 Soil Resources

3.8.1 Affected Environment

The soils of the project area are primarily characterized by those typical of the region. The 

primary soil classifications in the project area are inceptisols, alfisols, entisols, and mossisols. 

Specific soil types and distributions by unit can be found in the Soils and Water Specialist Report 

(Forest Service 2016c). 

3.8.1.1 Soil Erosion

The soil erosion hazard is a measure of the susceptibility of the soil to erode when its surface is 

exposed to water. A rating of severe indicates that predicted potential soil loss rates have a high 

probability of reducing site productivity due to erosion. Table 3-4, below, summarizes the area 

of severe erosion hazard by unit. The project area includes 107,775 acres of severe erosion

hazard, making up 55 percent of the entire project area. Over 82 percent of the area in the Lease 

Interest Unit and Middle Unit is rated as severe. Locations of areas with severe soil erosion 

hazard are depicted in the Soils and Water Specialist Report (Forest Service 2016c).

Table 3-4. Soil Characteristics of the Project Area

Unit

JNRA

Unit

Lease 

Interest 

Unit

Middle 

Unit

North 

Unit

South 

Unit Totals

Area of Severe Erosion Hazard per Unit in Project Area

Area of severe erosion hazard 

in unit (acres)

18,880 32,561 11,528 29,460 15,346 107,775

Percent of unit with severe 

erosion hazard

48 83 82 43 45 55

Percent of Each Wind Erodibility Group per Unit in the Project Area

WEG 1 0 0 0 0 1 0

WEG 2 0 0 0 23 0 8

WEG 3 0 0 0 14 0 5

WEG 4L 12 29 33 5 12 14

WEG 5 21 12 61 10 6 16

WEG 7 35 59 0 42 65 45

WEG 8 33 0 6 7 15 12

Percent of Each Hydrologic Soil Group per Unit in the Project Area

A: Low runoff potential/high

infiltration rate

0 0 0 0 0 0

B: Moderately low runoff 

potential

68 21 67 56 45 50

C: Moderately high runoff 

potential

0 41 0 19 0 15

D: High runoff potential/very 

slow infiltration rate

32 38 33 25 55 35

Sources: Forest Service 2016c
Chapter 3. Affected Environment and Environmental Consequences

3-38 Santa Fe National Forest Geothermal Leasing EIS

3.8.1.2 Wind Erodibility

The wind erodibility group (WEG) is a Natural Resources Conservation Service (NRCS) 

designation for a grouping of soils that have similar properties affecting their susceptibility to 

wind erosion. The ranking ranges from 1 to 8, with 1 being the most susceptible to wind erosion. 

Data group 1 is fine sand, sand, and coarse sand. A data group of WEG 8 would indicate soils 

that are not susceptible to wind erosion due to rock and pararock7fragments at the surface. Table 

3-4, Soil Characteristics of the Project Area, summarizes the percent of land in each WEG by 

project area unit. 

The soils of the project area are not particularly susceptible to wind erosion, with the exception 

being some of the soils in the North Unit. Across the project area, 73 percent is covered by soils 

that are categorized as WEG 5 or higher, with large tracts of land (57 percent of the project area) 

categorized as WEG 7 or 8. Locations of WEG designations are depicted in the Soils and Water 

Specialist Report (Forest Service 2016c).

3.8.1.3 Soil Runoff Potential

A hydrologic soil group is soils that have similar runoff potential under similar storm and cover 

conditions. The classification reflects the soil’s runoff potential from rainfall. The rankings range 

from A to D, with A being the lowest runoff potential and highest infiltration rates and D having the 

highest runoff potential and lowest infiltration rates. Table 3-4, Soil Characteristics of the Project 

Area, summarizes the percent of area covered by each hydrologic soil group by project unit. 

The soils in the project area tend to have a moderate to high runoff potential. Seventy-nine 

percent of the Lease Interest Unit area has either a moderately high or high runoff potential. The 

locations of hydrologic soil group designation in the project area are depicted in the Soils and 

Water Specialist Report (Forest Service 2016c).

3.8.1.4 Shrink/Swell Potential

Shrink/swell potential is the relative change in volume to be expected with changes in moisture 

content. The change in volume can exert enough force on a building or structures to cause 

structural damage to buildings, other structures, and roads. Most of the project area has a low 

shrink/swell potential, but the Lease Interest Unit has a few larger areas of moderate shrink/swell 

potential. Shrink/swell potential is further described in the Soils and Water Specialist Report 

(Forest Service 2016c).

3.8.2 Environmental Consequences

3.8.2.1 Scoping Comments on Resource

There were no issues specific to soil resources identified during the public scoping period. 

3.8.2.2 How Resource Impacts Were Evaluated

Method

Available soils data for the project area was analyzed to determine the susceptibility of the soils 

to erosion and potential transport by surface flow. The analysis also examines areas of expansive 

soils where construction may be difficult. 

 

7

Soft rock fragments
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-39

The soil erosion hazard data are from the Terrestrial Ecological Unit Inventory, which classifies 

ecological types and maps terrestrial ecological units to a consistent standard throughout NFS 

lands (Forest Service 2005). 

The WEG is soils that have similar properties affecting their resistance to soil blowing. These 

data were adopted from the NRCS.

The Digital General Soil Map of the United States, or STATSGO2, is a broad-based inventory of 

soils and non-soil areas that occur in a repeatable pattern on the landscape and that can be 

mapped at the scale of 1:250,000 in the continental United States. The United States General Soil 

Map is composed of general soil association units and is maintained and distributed as a spatial 

and tabular dataset from the NRCS. This level of soils data was used for the existing condition of 

soils in the project area. 

Indicators

The consent or denial of NFS lands for geothermal leasing and the issuance of geothermal leases 

would not directly impact soils. However, indirect impacts would result from future construction 

and operation of geothermal energy projects in the project area, based on future leases. Indicators 

of impacts of the proposed action and alternatives are as follows:

 Susceptibility of soils in the project area to water erosion, as measured by the soil erosion 

hazard

 Susceptibility of soils in the project area to wind erosion, as measured by the WEG

 Potential for runoff and sediment transport in the project area, as measured by the hydrologic 

soil condition

 Area of expansive soils (shrink/swell potential)

Assumptions

 The potential impacts of the alternatives were evaluated on the basis of extent of area that 

would be open for exploration and development and the general presence of easily eroded 

soils.

3.8.2.3 Common Impacts Associated with Geothermal Development

A detailed description of geothermal development operations relative to soil resources is in the 

2008 Geothermal PEIS (BLM and Forest Service 2008) and is summarized in this section. 

Common impacts on soil resources from geothermal development are physical disturbance (such 

as movement or removal), compaction, and changes to erosion patterns. 

Impacts on soils could include direct disturbance due to development of roads and facilities 

associated with exploration and development of geothermal production sites. Development could 

lead to erosion and sedimentation of soils. There would be some loss of soil productivity. 

Exposed soil surfaces would be vulnerable to the impacts of wind and surface water runoff 

during construction and operations.

Surface water erosion could remove some soils from the disturbed sites, potentially carrying 

them into streams and other water resources. In addition, some areas may be subject to 

deposition of wind-blown material outside the footprint of construction areas or the loss of soil 

due to wind erosion. 
Chapter 3. Affected Environment and Environmental Consequences

3-40 Santa Fe National Forest Geothermal Leasing EIS

Soils would be directly impacted by grading activities during construction. The degree of risk of 

erosion and transport due to water and wind depends on the eventual location of disturbances, 

such as roads and facilities.

There would be a long-term commitment of soil resources in areas that are converted to non-soil 

surfaces (such as geothermal structures and ancillary facilities) and therefore removed from 

productive use. This loss may be temporary, as in disturbance surrounding sites or along edges of 

roads, or long term, due to construction of impermeable surfaces, such as drilling pads and 

power plants. The loss is not permanent, because all surfaces would be reclaimed if exploration 

is unsuccessful or after production ceases. 

3.8.2.4 Impacts Under Alternative 1—No Action

Alternative 1 would have the same general impacts on soil resources associated with the RFDS

as described under Common Impacts Associated with Geothermal Development, above. Although 

the SFNF would not make an availability determination for geothermal leasing in the project 

area, geothermal lease applications and nominations would continue to be processed on a caseby-case basis under separate NEPA analysis, in accordance with the Forest Plan (Forest Service

1987) and existing laws and regulations. 

Geothermal leasing stipulations and closures would not be specifically implemented related to 

soil resources; however, any future geothermal lease applications and nominations would be 

subject to standards and guidelines outlined in the Forest Plan and environmental analysis. 

3.8.2.5 Impacts Under Alternative 2—Proposed Action

Under Alternative 2, impacts from anticipated geothermal exploration and development would 

generally be the same as those described under Alternative 1; however, the location of potential 

sites would be restricted by administrative withdrawals and stipulations. Approximately 32,000 

acres, or 17 percent of the NFS lands in the project area, would be closed to geothermal leasing; 

approximately 136,650 acres would be allocated as open to geothermal leasing, subject to 

existing laws, regulations, formal orders, and stipulations.

Implementing NSO stipulations on soils with severe erosion hazard would limit the amount of 

potential erosion from soil disturbance. Preventing facility development on slopes in excess of 

40 percent would further limit both erosion and sediment transport potential. This would 

minimize the potential impacts, particularly in areas that do not have a severe erosion hazard 

(and therefore are subject to NSO) but do have a high runoff potential. However, roads and 

powerlines could still likely cross areas of severe erosion hazard and potentially areas of steep 

slopes; therefore, there would still be a risk of erosion and transport due to road construction, 

reconstruction, use, eventual reclamation, and powerline construction. In all units, BMPs

identified in Appendix C could be implemented to minimize any potential impacts.

3.8.2.6 Impacts Under Alternative 3

There would be no direct impacts on soils under Alternative 3. No surface areas would be 

disturbed by geothermal developments. However, there would be indirect impacts on soil 

resources. Because the area would be closed to leasing for the foreseeable future, over time, 

there would be less soil disturbance than expected under the implementation of the current Forest 

Plan.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-41

3.8.2.7 Impacts Under Alternative 4

Impacts on soils would be similar to those described under Alternative 2. However, allowing 

surface occupancy on areas of severe erosion hazard by implementing only CSU stipulations on 

these soils would increase the risk of erosion and sediment transport in areas disturbed for 

exploration and development of geothermal sites under Alternative 4. This would be a particular 

concern on steeper slopes of between 30 and 40 percent and areas with moderately high to high 

runoff potential. Implementing BMPs identified in Appendix C to minimize and contain any 

erosion could reduce the impacts on soil productivity.

3.8.2.8 Cumulative Impacts

Cumulative impacts for soil resources are analyzed at the sixth-level watersheds that overlap or 

encompass the project area. Past, present, and reasonably foreseeable future actions are 

discussed in Section 3.3.4. 

Water resource repair and replacement projects—the Pueblo of Jemez Red Rocks Dam Repair, 

the Abiquiu Land Grant Waterline Replacement, and the McKinney County Dam—will initially 

directly impact soil resources through digging and removing soil resources. These surfacedisturbing activities could cause additional erosion and sedimentation into waterways. Mineral 

development projects—the South Pit Pumice Mine Expansion and the Duran 2010 Pumice 

Mine—would involve significant soil disturbance for expansion and operation. These activities 

could increase erosion and reduce soil productivity.

Restoration projects, such as the Southwest Jemez Mountains Restoration Project, Pueblo of 

Jemez Owl Springs Bridge Sediment Removal Project, and Valle Seco Wetland Restoration 

Project, would maintain or improve soil conditions in their respective project areas by removing 

sedimentation and reducing erosion.

Sedimentation and erosion would likely occur from geothermal development, combined with 

natural processes, such as fires in project area watersheds. The intensity of the combined impacts 

of fires and geothermal development will depend on the size and severity of the fire, as well as 

local soil conditions.

There would be the fewest cumulative impacts under Alternative 3, due to the restriction of 

leasing in the entire project area. Cumulative impacts over the remaining alternatives would be 

similar, due to the RFDS; however, Alternatives 1 and 4 would likely have the greatest intensity, 

due to a lack of or reduction of restrictive stipulations on geothermal development. 

3.9 Water Resources

3.9.1 Affected Environment

3.9.1.1 Watersheds and Surface Water

The project area lies in the Rio Grande River Basin. The Rio Grande flows from its headwaters 

in southern Colorado through New Mexico to the border with Mexico, where it turns eastward 

and marks the border between Mexico and Texas before emptying into the Gulf of Mexico.

Tectonic rifting has defined the route of the Rio Grande through New Mexico over millions of 

years and has resulted in intense volcanism in the basin. Valles Caldera, surrounded by the 
Chapter 3. Affected Environment and Environmental Consequences

3-42 Santa Fe National Forest Geothermal Leasing EIS

project area boundary on three sides, is one of the world’s largest and youngest calderas. Magma 

underlying the caldera is the source of the geothermal heat in the region.

The project area includes parts of three fourth-level watersheds8of the Rio Grande system: 

Jemez River, Rio Chama, and Rio-Grande-Santa Fe. The three four-level watersheds are further 

defined as sixth-level watersheds. Parts of 22 nested sixth-level sub-watersheds are included in 

the project area. Figure 3-2 shows a map of the sixth-level watersheds within the project area 

(Watershed Boundary Dataset GIS 2016).

Some of the sixth-level watersheds overlap the project area to a very minimal extent. However, 

should activities in these overlapped areas be proposed, the activities could affect watershed 

conditions, both in the project area and in the larger watershed that extends outside of the project 

area. Therefore, the watershed analysis takes into account all sixth-level watersheds that overlap 

part of the project area. Fourth and sixth-level watersheds and their relation to the project area 

are shown in the Soils and Water Specialist Report (Forest Service 2016c).

Surface water flows in the Rio Grande Basin originate primarily in the high mountain elevations 

as snow melt during the spring and as monsoonal rainfall during the late summer. Typically, the 

river reaches its highest discharge between April and June, with its peak levels in May. Natural 

flows also show variation from year to year due to drought and climate variability (New Mexico 

Office of the State Engineer 2006). The northern extent of the leasing area, north of the VCNP is 

part of the Upper Rio Grande Basin and includes the Rio Chama watershed. The Jemez 

Watershed is in the southern part of the leasing area and includes the Jemez River, the only 

perennial tributary to the Middle Rio Grande Basin.

The annual flow of the Rio Grande is quite variable. One-third of the approximately 1.1 million 

acre-feet (long-term average) of native Rio Grande surface water that leaves the Upper Rio 

Grande comes from Colorado, one-third comes from the Sangre de Cristo Mountains, and 

another third comes from the Rio Chama watershed. Water storage on the Upper Rio Grande 

includes waters stored in reservoirs on the Rio Chama, including storage of San Juan Chama 

Project water. The reservoirs are Heron, El Vado, and Abiquiu (New Mexico Office of the State

Engineer 2006). The Abiquiu Reservoir is just north of the project area. 

The project area is in the Jemez Mountains, where warm springs originating from subsurface 

geothermal activity have long been used for bathing and therapy. The Jemez Mountains are 

relatively wet in comparison to the dryer and lower surrounding country. Part of this 

precipitation, in the form of rain or snow melt, runs off or is lost to evapotranspiration, but the 

rest infiltrates and is stored as groundwater. The water supports a dense forest in the high 

country. The Valles Caldera, surrounded by the project area on three sides, is a defining terrain 

unit. The Jemez River drains the caldera on the west and then flows south through the project 

area. The Rio Chama drains the caldera on the north.

 

8 The United States is divided and subdivided into successively smaller hydrologic units. The fourth-level 

of classification is the cataloging unit. It is a geographic area representing part or all of a surface drainage 

basin, a combination of drainage basins, or district hydrologic features. The fourth-level watersheds are 

further divided into fifth and sixth levels, where the sixth-level watershed is the smallest subdivision, 

normally encompassing between 10,000 and 40,000 acres. Each hydrologic unit is assigned a name 

corresponding to its principal hydrologic feature or to a cultural or political feature in the unit. 
Figure 3-2 Santa Fe National Forest Geothermal Leasing EIS 3-43 Chapter 3. Affected Environment and Environmental Consequences
Chapter 3. Affected Environment and Environmental Consequences

3-44 Santa Fe National Forest Geothermal Leasing EIS

Jemez River Watershed

The Jemez Watershed is a fourth-level watershed that covers 44 percent of the project area, 

primarily in the southwest and south-central portions, and along the east edge of the VCNP. All 

of the Middle Unit, the southernmost spur of the Leasing Unit, and approximately the western 

two-thirds of the JNRA Unit and the South Unit are in this watershed. The surface waters 

draining the Valles Caldera are collected by this watershed’s streams, including the Jemez River

and San Antonio Creek. 

There are six hot springs located in this watershed. There are also two drinking water sources, 

one in the JNRA Unit and the other in the southern end of the South Unit.

Ongoing processes and existing conditions in the Jemez Watershed include high sediment 

erosion and water runoff as the result of forest fires. In addition, the lowering of valleys by river 

incision is a continuing process. Many valleys are flanked by terraces. Rivers respond by 

aggrading during climates that promote large sediment yield and large, stable discharges, and 

incising during climates that produce flash flows and reduce the sediment supply (NRCS 2011c).

There are 10 sixth-level watersheds in the Jemez fourth-level watershed that are partially within 

the project area, as follows: 

 Cañon de la Canada

 Church Canyon-Jemez River

 East Fork Jemez River

 Headwaters Rio Cebolla

 Headwaters San Antonio Creek

 Outlet Rio Cebolla

 Outlet San Antonio Creek

 Sulphur Creek

 Vallecita Creek

 Virgin Canyon

Rio Chama Watershed

The Rio Chama Watershed is a fourth-level watershed that covers approximately 49 percent of 

the project area, including all of the North Unit and most of the northern portion of the Proposed 

Leasing Unit. Waters draining the north-facing sides of the Valles Caldera and the northern 

Nacimiento Mountains, as well as adjacent mountains and valleys, are channeled to the Rio 

Chama and the Abiquiu Reservoir. Eventually these waters lead to the Rio Grande, north of the 

project area. There are three drinking water wells along the northern edge of the project area in 

this watershed. There are no natural thermal features in the portion of this watershed that covers 

the project area.

The western boundary of the larger Rio Chama Watershed is formed by the Continental Divide 

and the northeastern edge of the Jemez Mountains. In the east, the watershed is hemmed in by 

the Tusas Mountains and Black Mesa. The Rio Chama headwaters drain the southern San Juan 

Mountains, and the river ends at its confluence with the Rio Grande, near Espanola, New 

Mexico. The upland areas of the drainage basin are significant contributors to Rio Chama flows, 

resulting in snowmelt-dominated hydrology. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-45

Mean annual precipitation in the basin ranges from 9 to 53 inches, with values dependent on 

elevation (NRCS 2011a). Ongoing processes and existing conditions in the Rio Chama

Watershed include high sedimentation rates caused by landslides in the Mancos shale and high 

sediment erosion and water runoff as the result of forest fires. In addition, the lowering of valleys 

by river incision is a continuing process. 

There are seven sixth-level watersheds of the larger Rio Chama Watershed that occupy portions 

of the project area, as follows:

 Cañones Creek

 Cañones Creek-Abiquiu Reservoir

 Coyote Creek

 Headwaters Rio Puerco

 Outlet Rio Puerco

 Poleo Creek

 Polvadero Creek

Many of these sub-watersheds have impairments, due to bank instability and lack of a healthy 

riparian zone. These impairments have resulted in excess sediment and higher stream 

temperatures (Levine et al. 2015). 

The greatest land use in the Rio Chama Watershed by area is rangeland. Impairments are typical 

of streams impacted by improper grazing management, which can cause a loss of riparian

vegetation, increase habitat and seed source for invasive species that compete with native 

species, and degrade banks, leading to erosion and sedimentation.

Rio Grande-Santa Fe Watershed

The Rio Grande-Santa Fe Watershed is a fourth-level watershed that covers just 7 percent of the 

project area. It is in the southeastern extent, on the eastern side of the JNRA Unit, and the eastern 

side and southern edge of the South Unit. Waters drain into this watershed from the southeastfacing slopes of the Valles Caldera, joining several streams and canyons leading to the Cochiti 

Reservoir and eventually the Rio Grande. This watershed contains the headwaters of Capulin 

Creek, which is one of only two perennial steams in Bandelier National Monument. There are no 

drinking water wells or hot springs in the portion of this watershed that is in the project area.

Outside of the project area, portions of the Rio Grande-Santa Fe Watershed extend into 

Bernalillo, Los Alamos, San Miguel, Sandoval, and Santa Fe Counties. Elevations range from 

5,000 to 13,153 feet and precipitation ranges from 9 to 43 inches annually, depending on 

elevation.

The hydrologic unit begins at Otowi, west of Pojoaque, New Mexico, in the Upper Rio Grande

Valley. Farther downstream, the river enters Cochiti Lake, which marks the northern boundary of 

the Middle Rio Grande Valley. The hydrologic unit continues downstream to the confluence with 

the Jemez River. 

Ongoing processes and existing conditions in the Rio-Grande Santa Fe Watershed are high 

sediment erosion and water runoff as the result of forest fires. In addition, the lowering of valleys 

by river incision is a continuing process. This can be exacerbated by mining sand and gravel 

from the river channels.
Chapter 3. Affected Environment and Environmental Consequences

3-46 Santa Fe National Forest Geothermal Leasing EIS

There are five sixth-level watersheds in the Rio Grande-Santa Fe watershed in the project area, 

as follows: 

 Alamo Canyon-Rio Grande

 Capulin Canyon-Rio Grande

 Headwaters Borrego Canyon

 Peralta Canyon

 Rio Chiquito

100-Year Floodplains

One hundred-year floodplains in the project area are delineated in accordance with the Federal 

Emergency Management Act and are shown in the Soils and Water Specialist Report (Forest 

Service 2016c). Most of the delineated areas are in the JNRA Unit, along the Jemez River, 

including the Cañon de San Diego, and extending slightly into San Antonio and Sulphur Creeks. 

There is also a small section of the East Fork of the Jemez River that crosses into the JNRA Unit 

that is delineated as a 100-year floodplain. There is also a 100-year floodplain in the portion of 

the Middle Unit that is crossed by the Rio Cebolla. The delineation of this floodplain extends 

into the southwestern corner of the Lease Interest Unit. There are also several small sections of 

tributaries to the Rio Puerco, along the northern edge of the North Unit, that include 100-year 

floodplains.

Beneficial Uses

The basic authority for water quality management in New Mexico is provided through the State 

Water Quality Act. It establishes the New Mexico Water Quality Control Commission 

(NMWQCC), which is the state water pollution control agency for purposes of the federal Clean 

Water Act (CWA). New Mexico’s water quality standards define water quality goals by 

designating uses for rivers, streams, lakes, and other surface waters. The waters are classified by 

the uses for which they are presently suitable or intended to become suitable. The standards set 

criteria to protect these uses and establish anti-degradation provisions to preserve water quality. 

The standards are adopted by the NMWQCC, then approved by the EPA under the federal CWA. 

The New Mexico Environment Department (NMED) is responsible for implementing the federal 

CWA in New Mexico and ensuring that surface waters meet their designated beneficial uses and 

New Mexico state water quality standards. The beneficial uses of the sixth-level project area 

watersheds are presented in the Soils and Water Specialist Report (Forest Service 2016c). All of 

the watersheds have the beneficial use of livestock watering/wildlife habitat. 

Clean Water Act, Section 303(d), Impaired Surface Waters and Total Maximum Daily 

Loads

Under the CWA, Section 303(d), states, territories, and federally recognized tribes that have 

obtained treatment in a similar manner as states are required to develop lists of impaired waters. 

These are waters that are too polluted or otherwise degraded to meet the water quality standards 

set by the states, territories, or tribes. The law requires that these jurisdictions establish priority 

rankings for waters on the lists and develop a Total Maximum Daily Load (TMDL) for these 

waters (see the Soils and Water Specialist Report [Forest Service 2016c]). TMDL is a calculation 

of the maximum amount of a pollutant that a water body can receive and still safely meet water 

quality standards. The NMWQCC is the issuing agency of water quality standards for interstate 

and intrastate waters in New Mexico.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-47

In the Jemez Watershed there is one body of water, the 23.81-acre Fenton Lake, with a maximum 

volume estimated at 264 acre-feet, that is listed as impaired as of the 2010 to 2012 listing cycle. 

Fifteen reaches of the Jemez Watershed are in the sixth-level watersheds that overlap the project 

area and are listed as Section 303(d) impaired surface water. Natural conditions contribute to 

high aluminum concentrations throughout the Jemez Watershed, and impacts on aquatic life are 

unclear. Many sixth-level watersheds in the Jemez Watershed have aluminum listings, but no 

TMDLs have been identified yet. 

In the Rio Chama Watershed there are seven reaches in the sixth-level watersheds that overlap 

the project area and are listed as Section 303(d) impaired surface waters. 

The Rio Grande-Santa Fe Watershed contains one reach in the sixth-level watersheds that 

overlap the project area and is listed as a Section 303(d) impaired surface water. 

The Soils and Water Specialist Report identifies specific reaches that have been listed as Section 

303(d) impaired surface waters.

Watershed Condition Class

The watershed condition framework is a comprehensive approach for restoring priority 

watersheds on national forests and grasslands (Forest Service 2011). It also provides a consistent 

way to evaluate watershed conditions at both the national and forest levels. Further explanation 

of this metric can be found in the Soils and Water Specialist Report (Forest Service 2016c).

The Forest Service completed an assessment of all sixth-level Watersheds on National Forests in 

2011. It rated the condition of each watershed as properly functioning, functioning at risk, or 

functionally impaired. The watersheds were also given ratings for twelve condition indicators.

None of the sixth-level watersheds in the analysis are considered to be properly functioning. Two 

of the watersheds, Headwaters Rio Cebolla and Outlet San Antonio Creek, are functionally 

impaired. Both are sub-watersheds of the fourth-level Jemez Watershed and together cover most 

of the Middle Unit.

Throughout all of the sixth-level watersheds, the categories that are consistently of concern are 

riparian and wetland vegetation, roads and trails, soil condition, and fire impacts. None of the 

watersheds scored “good” in these categories. For both roads and trails and soil condition, only 

two watersheds scored “fair”: Cañones Creek-Abiquiu Reservoir for soil condition and Outlet 

Rio Puerco for road and trails. All the other watersheds were classified as “poor” for these 

categories. 

These categories are indicators of the following concerns:

 Riparian and wetland vegetation—Vegetation condition

 Roads and trails—Open road density, road maintenance, proximity to wear, and mass 

wasting

 Soil Conditions—Soil productivity, soil erosion, and soil contamination

 Fire impacts—Fire condition class or wildfire impacts

Watershed Erodibility Index and Road Density

The watershed erodibility index is an indicator of the vulnerability of a watershed to erosion and 

sedimentation from disturbances determined by evaluating the risk of both erosion and transport 
Chapter 3. Affected Environment and Environmental Consequences

3-48 Santa Fe National Forest Geothermal Leasing EIS

to streams. This index weights the area in each watershed covered by each erodibility-transport 

risk (slight, moderate, severe, or very severe). This provides an overall watershed index number 

that allows watersheds to be compared to each other and illustrates relative risk across the 

watershed. The index ranges from 1 to 4, with 1 indicating the entire watershed has only a slight 

erodibility-transport risk, and 4 indicating that the entire watershed would have a very severe 

erodibility-transport risk. More information on the method for creating this index number can be 

found in the Soil and Water Specialist Report (Forest Service 2016c). The watershed erodibility 

index rating across all of the sixth-level watersheds that overlap portions of the project area 

ranges from 1.2 to 1.9, with an average of 1.5 (see Table 3-5, below).

Table 3-5. Watershed Erodibility Index

Watershed Name Percent of Watershed

in Project Area

Road Density (Miles of 

Road per Square Mile)

Watershed Erodibility 

Index Rating

Fourth-Level Watershed: Jemez 

Cañon de la Cañada 72.1 5.6 1.2

Church Canyon-Jemez 

River

77.6 6.1 1.3

East Fork Jemez River 15.1 3.9 1.6

Headwaters Rio Cebolla 70.1 10.5 1.3

Headwaters San 

Antonio Creek

1.6 5.5 1.5

Outlet Rio Cebolla 16.3 6.5 1.3

Outlet San Antonio 

Creek

69.5 7.1 1.6

Sulphur Creek 11.0 3.0 1.9

Vallecita Creek 50.0 6.1 1.3

Virgin Creek 22.1 5.0 1.3

Fourth-Level Watershed: Rio Chama

Cañones Creek 82.0 12.3 1.5

Cañones Creek-Abiquiu 

Reservoir

21.1 2.5 1.2

Coyote Creek 99.6 6.8 1.6

Headwaters Rio Puerco 21.1 5.7 1.8

Outlet Rio Puerco 47.5 3.3 1.4

Poleo Creek 1.3 7.9 1.7

Polvadero Creek 21.2 5.1 1.7

Fourth-Level Watershed: Rio Grande-Santa Fe 

Alamo Canyon-Rio 

Grande

6.0 2.9 1.5

Capulin Canyon-Rio 

Grande

2.1 2.0 1.3

Headwaters Borrego 

Canyon

0.9 3.1 1.2

Peralta Canyon 9.1 1.4 1.5

Rio Chiquito 28.8 5.3 1.5

Source: Forest Service 2016c
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-49

Problems with road density and poor maintenance can also manifest in soil erosion by resulting 

in deficiency of drainage, modification of water runoff, and excessive loading of slopes resulting 

in mass movement such as landslides. Additionally, roads can convert subsurface runoff to 

surface runoff and then route the surface runoff to stream channels, increasing peak flows (Ice 

1985; Swanson et al. 1987). Roads can also divert stream channels to adjacent channels through 

surface runoff, increasing discharge and peak flow to the receiving channel and decreasing 

discharge and peak flows to the diverted channel. Therefore, watersheds with higher road 

densities have a higher risk of sedimentation of stream channels when there are disturbances in 

the watershed. The average road density for all sixth-level watersheds that overlap the project 

area is 5.3 miles of road per square mile.

3.9.1.2 Groundwater

The Rio Grande Aquifer System

The groundwater in the project area is in the Rio Grande aquifer system, which is the principal 

aquifer in a 70,000-square-mile area of southern Colorado, central New Mexico, and western 

Texas. The Rio Grande Aquifer is an unconsolidated sand and gravel system, consisting of a 

network of hydraulically interconnected aquifers in basin-fill deposits along the Rio Grande 

Valley and nearby valleys. Although some volcanic rocks (like those that make up the majority 

of the bedrock in the project area), solution-altered carbonate rocks, or extensively fractured 

beds can yield water in specific areas, the bedrock underlying the Rio Grande Valley and aquifer 

is relatively impermeable. However, the bedrock in the surrounding mountains is somewhat 

permeable and acts to collect precipitation for recharge.

Recharge to the Rio Grande aquifer system primarily comes from precipitation in the 

mountainous areas that surround the basins. Runoff from snowmelt or rainfall spreads across 

permeable alluvial fans and percolates downward into the aquifer. If the volume of runoff is 

large or becomes part of a perennial stream, groundwater recharge can be distributed over a 

much longer reach of stream channel. 

Runoff produces most mountain-front recharge to the aquifer system and water from the bedrock 

aquifers is discharged into the basin fill where the mountains front the Rio Grande Valley (Goff 

2002). In some mountainous areas, such as the project area, thick and extensive layers of 

volcanic rocks are sufficiently permeable to enable large volumes of water to flow through the 

rocks and directly recharge the basin-fill aquifers. Precipitation falling in the valleys does not 

contribute to aquifer recharge, because most of it is lost to evaporation and transpiration.

Project Area Hydrogeology

The project area lies in the Jemez Mountains in north-central New Mexico. The most dominant 

feature of the Jemez Mountains is the large central caldera, or area of collapse, known as the 

Valles Caldera. It contains a geothermal system that is a classic, liquid-dominated reservoir, 

overlain by a low-pressure vapor cap and recharged by local water derived from precipitation or 

condensation (Goff et al. 1985; Trainer et al. 2000). The Valles geothermal system is in the 

central and western parts of the Valles Caldera but does not extend under the entire caldera 

(Hulen and Nielson 1986; Wilt and Vender Harr 1986). 

The caldera contains both thermal and non-thermal groundwater. Like the local surface water

drainage patterns, groundwater flows radially outward from the rim of the caldera. The most 

extensive and productive aquifer in the region underlies the Pajarito Plateau on the east side of 

the mountain mass. On the west side, thermal and non-thermal waters discharge from the caldera 
Chapter 3. Affected Environment and Environmental Consequences

3-50 Santa Fe National Forest Geothermal Leasing EIS

to the southwest, down Cañon de San Diego, which follows the trace of the Jemez Fault Zone. 

The principal geothermal reservoir, or aquifer, in the region is under the central and western parts 

of the caldera (Trainer et al. 2000).

Non-thermal water in Valles Caldera occurs in diverse perched aquifers and deeper valley-fill 

aquifers. The non-thermal groundwater is derived from precipitation or condensation (Vuataz 

and Goff 1986). Discharge of non-thermal water from Valles Caldera takes several paths, some 

of which are not well understood. Some of the non-thermal groundwater discharges from 

springs, particularly from higher, smaller perched aquifers. Water from the more extensive 

valley-fill aquifers discharges as spring flow and seepage to the principal streams. Some deeper 

discharge from the valley-fill aquifers recharges the underlying geothermal reservoir by slow 

leakage through relatively impermeable rocks and along fractures and faults (Faust et al. 1984, in 

Trainer et al. 2000; Vuataz and Goff 1986, in Trainer et al. 2000). The water that recharges the 

geothermal reservoir moves downward from the aquifers in the caldera fill to depths of 6,500 

feet or more, reaching temperatures of approximately 330 degrees Celsius (°C). This now heated 

geothermal water then rises convectively to depths of 2,000 feet or less and mixes with other 

groundwater as it flows away from the geothermal reservoir. 

The principal reservoir of geothermal fluids is at depth under the central and western parts of the 

caldera. The heated water of the geothermal system flows out the caldera to the west and 

southwest under the Jemez Plateau and along the Jemez Fault Zone. This geothermal water 

mixes with other groundwater as it flows along the fault zone, and some of this mixed or 

derivative water issues as hot springs in Cañon de San Diego (Trainer 1974). Outflowing mineral 

water appears to be limited to the western and southwestern parts of the Jemez Mountains. 

The geothermal system at Valles Caldera is subdivided into the Redondo, Sulphur Springs, and 

Jemez Springs geothermal areas, based on the distribution of springs and fumaroles,9past 

geothermal exploration projects, and scientific drilling programs. Surface discharges at Redondo 

and Sulphur Springs are fed by upwelling fluids from chemically distinct, isolated reservoirs 

beneath the caldera floor (OpenEI 2016). Free gas issues at Sulphur Springs and from smaller 

springs and fumaroles in the resurgent dome of the caldera (Goff et al. 1988). The Jemez Springs 

system lies outside the caldera walls, to the southwest in Cañon de San Diego. Hydrothermal 

features outside Valles Caldera are restricted largely to this canyon; geothermal waters reach the 

springs primarily by structurally controlled lateral outflow and by more minor flow through 

Paleozoic strata. 

Subsurface escape of reservoir fluid from near and beneath Valles Caldera has formed a 

discharge plume of reservoir water, mixed with dilute groundwater, which extends down Cañon 

de San Diego (Trainer 1974; Goff et al. 1988). The Jemez Fault Zone transports a relatively large 

portion of this flow. Soda Dam and Jemez Springs are derivatives of geothermal outflow from 

the reservoir. Near the Pueblo of Jemez, subsurface mineral water merges with the regional 

aquifer in fill deposits of the Albuquerque Basin (Trainer 1974). Free gas also emerges from 

several thermal features along the Jemez fault zone, southwest of the caldera.

Natural Hot Springs

Hot springs are found both inside and outside of the Valles Caldera, a result of deep groundwater

circulating over the very hot rocks of the magma chamber that underlies the caldera (New 

 

9 An opening in or near a volcano that emits hot sulfurous gases
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-51

Mexico Natural History 2015). Numerous natural mineral hot springs are located throughout the 

Jemez valley. Some are on public land, others are on private land and are open to the public for a 

fee. All of these features are found in the Jemez Watershed and are associated with the collapsed 

caldera. The five natural hot or warm springs in the project area are Jemez, Soda Dam, San 

Antonio, Spence, and McCauley. An additional hot spring, Sulphur Spring, is just outside of the 

project area boundaries, in the Valles Caldera. More information on the individual hot springs 

can be found in the Soils and Water Specialist Report (Forest Service 2016c).

Non-Thermal Groundwater Sources

Little information is available on groundwater hydrology in the region. However, groundwater is 

critically important because most of the region’s residents depend on it for their domestic water 

supplies, and periodic shortages occur. Aquifer characteristics in much of the region severely 

limit groundwater availability. 

Groundwater beneath the Rio Chama Watershed

Groundwater in the Mancos shale, an aquiclude,10 has a low yield, and usually is fair to poor 

quality for livestock or crops. Groundwater in the igneous rocks and volcanics is usually along 

fracture zones that are hard to intercept with water wells (NRCS 2011a). 

The Rio Chama watershed consists of three different geologic provinces, each containing distinct 

aquifer systems. The Española Basin province, in the southern part of the watershed and 

overlapping the project area, consists of Tertiary Period sediments, primarily the Santa Fe Group. 

These deposits are moderately permeable, contain large amounts of sand and gravel, transmit a 

fair amount of water, and have a relatively large recharge potential, meaning that the 

groundwater is easily renewed by percolating surface water. Española Basin aquifers usually 

yield relatively ample supplies of good quality water (New Mexico Office of the State Engineer 

2006). 

Shallow alluvial aquifers are found throughout the watershed, in all three geologic provinces, 

and many wells in the region draw water from these aquifers. Alluvial aquifers, composed 

largely of gravel and sand, can be a good source of water if the deposits are deep and extensive. 

However, in the Rio Chama region, the alluvial deposits are shallow and generally not extensive. 

Wells drawing water from these aquifers often run short of water in dry years. 

Additional groundwater production may be possible on a limited scale in certain areas. However, 

in the Rio Chama watershed as a whole, there do not appear to be significant untapped 

groundwater sources that could replace any large fraction of surface water use or provide major 

new water supplies in or outside of the region.

Groundwater beneath the Jemez Watershed

The bedrock geology in the western portion of the watershed is characterized by Precambrian 

metamorphic and Permian sedimentary rocks, while the central and eastern portions of the 

watershed are composed of volcanic rocks associated with the Valles Caldera. Groundwater

occurs in bedrock and in surficial deposits overlying it. Groundwater in the igneous rocks and 

volcanics is usually along fracture zones that are hard to intercept with water wells. Groundwater 

quality ranges from fair to poor for livestock or crops (NRCS 2011c).

 

10 A subsurface rock, soil, or sediment unit that does not yield useful quantities of water
Chapter 3. Affected Environment and Environmental Consequences

3-52 Santa Fe National Forest Geothermal Leasing EIS

Groundwater beneath the Rio Grande-Santa Fe Watershed

The most significant aquifer in the Rio Grande-Santa Fe Watershed is the Santa Fe Group, 

particularly its lower member, the Tesuque Formation. The upper member, the Ancha, is 

typically more conductive than the Tesuque but occurs above the water table in much of the Rio 

Grande-Santa Fe Watershed (NRCS 2011b). Deeper groundwater is nearly continuous in the 

Tesuque Formation throughout the watershed area, to depths of 2,000 feet or greater in some 

areas. This deep groundwater dates from the Ice Age and is recharged little if at all by presentday rainfall and snowmelt. 

Precipitation in the high mountains and flow in the Santa Fe River and its tributary arroyos seeps 

into and recharges shallow groundwater, which, in some areas, may be continuous with deeper 

groundwater (NRCS 2011b). Volcanics often serve as a “floor” or channel to concentrate 

percolating groundwater and cause it to emerge as spring flow. 

Groundwater Conditions at LANL

At its closest point, LANL is just over 2 miles east of the southern boundary of the project area. 

It is situated on a thick zone of mainly unsaturated rock and sediments. Groundwater below 

LANL occurs in three modes: perched alluvial groundwater in canyon bottoms; discontinuous 

zones of intermediate-depth perched groundwater; and the regional aquifer beneath the Pajarito 

Plateau (LANL 2005). The depth of the perched-intermediate groundwater ranges from 120 to 

750 feet, and the regional aquifer is found at 600 to 1,200 feet below the ground surface (LANL 

2015). Groundwater in the regional aquifer generally flows east or southeast, at a rate of 

approximately 30 feet per year. The Sierra de los Valles provides most of the recharge to 

groundwater beneath the Pajarito Plateau. 

Contaminants from historical laboratory operations are present in perched-intermediate 

groundwater zones and in the regional aquifer below LANL. These contaminants are associated 

with past liquid effluent releases from outfalls (the discharge point of a liquid waste stream into 

the environment; LANL 2015). The results of groundwater characterization and monitoring from 

the 2015 LANL Annual Site Environmental Report (LANL 2015) indicate that two substances 

have notable areas of groundwater contamination at LANL: hexahydro-1,3,5-trinitro-1,3,5-

triazine beneath Cañon de Valle and Hexavalent chromium beneath Sandia and Mortandad 

Canyons. The water supply wells in this area, which are owned and operated by Los Alamos 

County, meet all federal and state drinking water standards (LANL 2015).

3.9.2 Environmental Consequences

3.9.2.1 Scoping Comments on Resource

The following issues specific to water resources were identified during the public scoping 

period:

 How would geothermal leasing affect surface and subsurface water quantity? Would 

geothermal leasing change or reduce water allocations for other uses? What are the shortand long-term impacts on the regional aquifer?

 How would geothermal leasing affect water quality, and what size buffers are necessary to 

protect surface waters? How might these impacts differ, depending on the type of geothermal 

system?

 How would geothermal leasing affect the Abiquiu Reservoir and Dam and the NMDGF 

Habitat Stamp Program water projects?
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-53

3.9.2.2 How Resource Impacts Were Evaluated

Method

This section analyzes water resource data for the project area to determine the current conditions 

of watersheds and their susceptibility to impacts from erosion. Water quality, flow pattern, water 

temperature, and groundwater supply impacts are discussed.

The surface water layers were taken from the NHD Stream and Water Body GIS layers. This 

dataset represents the drainage network, with such features as rivers, streams, canals, lakes, 

ponds, coastlines, dams, and stream gages. This dataset has a scale of 1:24,000. These data are 

designed to be used in general mapping and in analyzing surface water systems.

The watershed boundaries were delineated by the NRCS Geospatial Data Gateway. Both fourthand sixth-level watershed boundaries from this dataset are used. The watershed erodibility index 

analysis uses the Kw factor from the State Soil Geographic spatial database and land slope 

derived from USGS 30-meter digital elevation models. The Watershed Condition Class 

Framework is from the Forest Service GIS Layer. The 100-year floodplains are from the Federal 

Emergency Management Act GIS layer. The well data is from the NMOSE Enterprise GIS. 

The NMOSE Enterprise GIS offers an open data site, which is set up for agency transparency for 

allowing the public and other agencies access to downloadable data from the NMOSE. The point 

of diversions layer includes well locations, surface declarations, and surface permits. These data 

were extracted from the NMOSE Water Administration Technical Engineering Resource System 

database. These data are current as of March 2016, have varying degrees of accuracy, and have 

not been validated. 

Indicators

Indicators of the impacts of the proposed action and alternatives are as follows:

 Erosion and sedimentation that could alter or impair perennial or intermittent streams; the 

analysis includes a combined erosion and transport potential for each watershed in the 

project area, as measured by the soil erosion water factor (Kw) and slope to form the 

watershed erodibility index

 Possible impacts on beneficial uses and sensitive watersheds as measured by combining 

factors including the watershed erodibility index, watershed condition class, impaired 

streams, density of roads and beneficial uses

 Potential for contamination of fresh surface water or groundwater supplies, as indicated by 

risk of leaks and spills

 Possibility for depletion of groundwater supplies or interferences with groundwater recharge, 

such that the local groundwater table would be lowered to a level that would not support 

existing land uses

 Potential for groundwater “mounding” due to injection that does not result in groundwater 

being returned to the aquifer that it was extracted from

 Potential for changes to natural thermal features

 Potential for changes in flow from springs and in surface water drainages

 Potential for changes in groundwater or surface water temperatures

 Potential for changes in groundwater or surface water quality

 Potential for changes in source water and vegetation at wetland areas
Chapter 3. Affected Environment and Environmental Consequences

3-54 Santa Fe National Forest Geothermal Leasing EIS

 Possible flash flooding impacts on proposed facilities, as indicated by location of 100-year 

floodplains

Assumptions

This analysis assumes the following: 

 Leasing land does not involve ground-disturbing activities or any type of construction, so 

there would be no direct impact on water resources. Impacts would result from activities 

pursued after leasing.

 BMPs, such as those identified in Appendix C, would be applied, as applicable, at the BLM 

permitting level to minimize impacts on water resources from geothermal exploration, 

drilling, utilization, and reclamation and abandonment.

 It is the responsibility of the applicant to obtain water rights.

3.9.2.3 Common Impacts Associated with Geothermal Development

The following impact analysis provides a general description of common impacts on water 

resources from geothermal development, as well as specific impacts based on the RFDS. 

Because the RFDS is the same under all alternatives, except the No Leasing Alternative 

(Alternative 3), general impacts under those alternatives would be the same. 

The information presented in the Common Impacts on Water Resources and Quality Associated 

with Geothermal Development section of the 2008 Geothermal PEIS is incorporated by

reference and summarized here. As described in the 2008 Geothermal PEIS, common impacts 

from geothermal development could include water contamination, lowered groundwater tables, 

and changes in water temperature. 

Impacts on water quantity are directly related to water use. Water would be used during all 

phases of geothermal resource development: exploration, drilling, utilization, and reclamation 

and abandonment. Water use is required for drilling wells, constructing infrastructure, 

stimulating injection wells, operating the power plant, and dust control. Water would not be used 

for cooling because the air temperature is sufficiently low to allow for air cooling of water to be 

reinjected. The applicant would be responsible for obtaining water rights in accordance with 

state and federal regulations. Fresh water used in the drilling operations would be trucked in or 

would come from local springs and wells at depths less than 1,000 feet (BLM 2015). Water is 

used during the well construction as drilling fluids, and for cementing the casing in place. Well 

depth, total number of wells, volume of the borehole, and the physical and chemical properties of 

the formation would affect water volume requirements during drilling operations. 

For enhanced geothermal systems, water is also required for stimulating the reservoir11. 

Stimulation volume is dependent on the desired water volume flow rate (Clark et al. 2011). The 

vast majority of water use would occur during the operations phase. Although extracted water 

would be reinjected after use, water may be lost to the geologic formation. To maintain pressure 

and operation, water that is lost must be made up from alternative water sources. Water 

consumption (i.e., water that is withdrawn from a resource such as a river, lake, or nongeothermal aquifer that is not returned to that resource) varies between 0.29 and 0.72 gallons per 

kilowatt-hour for enhanced geothermal scenarios (Clark et al. 2011). 

 

11 Stimulation opens existing spaces within the formation and enables or enhances the circulation of fluids.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-55

Groundwater extraction for hydraulic stimulation and makeup water can result in a cone of 

depression (DOE 2016), where water is being removed faster than the aquifer’s permeability 

allows it to be replenished. As such, extraction may change the rate or direction of flow in and 

near the well.

Potential impacts on surface water quality due to ground disturbance during road, powerline, and 

facility development could occur from erosion and subsequent transport of eroded materials into 

surface waters in areas where vegetation has been removed and soils disturbed. This could 

increase suspended sediment and turbidity in surface water following periods of runoff. These 

types of impacts would occur during all phases of geothermal resource development. There 

could also be impacts on sensitive riparian zones due to road construction and any activities that 

are proposed near stream courses. This would be of particular concern in areas of highly erodible 

soils, near impaired stream reaches, or in sensitive watersheds.

Potential short-term impacts on water quality could also occur from accidental releases of 

chemical compounds, such as fuels, solvents for removing buildup on pipes, and working fluids 

required for drilling and operation activities, or wastewater, which could contaminate surface 

water or shallow groundwater or both. Impacts from accidental releases of wastewater, such as 

stormwater or sanitation water, could include increased concentrations of nitrate, phosphate, total 

dissolved solids, and fecal coliform in shallow groundwater or surface water. These types of 

impacts would occur during all phases of geothermal resource development. 

The risk of occurrence of spills, or impacts if a spill occurs, would be reduced by incorporating 

in the development plan BMPs and environmental protection measures. Extracted geothermal 

fluids containing high concentrations of dissolved constituents and leaking into the shallow 

aquifer could contaminate freshwater supplies through faulty reinjection practices, geothermal 

well casing failure, and uncontrolled discharge of waste geothermal fluids. Protecting 

groundwater from contamination by geothermal fluids is facilitated by the use of multiple casing 

strings, whose depths are specified partly on the basis of the depths of groundwater aquifers. In 

addition, redundant blow-out prevention equipment is used. 

Impacts would vary relative to the area that is disturbed and location of the disturbance in 

relation to permeable soils and local aquifers.

Binary power plant systems would return most of the extracted groundwater to the geothermal 

source aquifer through injection wells. During pumping, some groundwater flow paths in the 

deeper aquifers could be modified due to reductions in temperature of reinjected waters, which 

reduces pressure in the deeper geothermal system and could therefore change flow paths. 

Upward vertical hydraulic gradients could be reduced due to this depressurization, altering flow 

paths. It is also possible that the reinjection site would not return the geothermal fluid to the 

exact hydraulic connection that it was withdrawn from, and water may be lost to the formation. 

This could also locally alter pressurization in the system and flow paths. These types of impacts 

would occur during the drilling and utilization phases of geothermal resource development. 

Implementing monitoring plans would track changes occurring from the pumping. 

Flows at non-thermal springs and seeps are not likely to be affected by geothermal groundwater

development. Most of these springs are recharged by shallow groundwater with short flow paths, 

which is recharged primarily from precipitation, irrigation, and runoff. For most of the project 

area, geothermal fluids would be extracted at much greater depths than the shallow aquifer and 

would be reinjected once the heat is extracted. However, there are numerous faults extending 

from the caldera, and where there is an interconnection between deeper groundwater and faults, 
Chapter 3. Affected Environment and Environmental Consequences

3-56 Santa Fe National Forest Geothermal Leasing EIS

pumping during drilling and utilization could change flow paths. There also could be some slight 

changes in flow paths from pressure differences due to small differences in the extraction and 

reinjection zones. 

Deeper groundwater is nearly continuous in the Tesuque Formation throughout the Santa Fe-Rio 

Grande Watershed area, to depths of 2,000 feet or greater in some areas. This deep groundwater 

dates from the Ice Age, approximately 10,000 years ago, and is recharged little if at all by 

present-day rainfall and snowmelt. Should geothermal drilling and utilization occur in this area, 

there could be more risk of changes to flow paths, and mixing of geothermal fluids with other 

groundwater. However, as geothermal waters are reinjected, any changes in groundwater level 

would be minor and would result from changes in flow paths, rather than reductions in 

groundwater quantity. 

Where there is interconnected flow to springs and seeps in thermal areas, this could alter the 

mixing of weather-related non-thermal waters with the deeper geothermal waters and alter flow 

paths to hot springs. Additionally, temperatures could be lowered if interconnected flow from 

deeper zones is reduced by returning the cooled geothermal water to the reservoir. 

A summary of common impacts on water resources by geothermal development phase is 

summarized in Table 3-6, below.

Table 3-6. Summary of Common Impacts on Water Resources by Geothermal Development Phase

Exploration Drilling 

Operations Utilization

Reclamation 

and 

Abandonment

Impact

Water use for drilling wells, constructing 

infrastructure, stimulating injection wells, 

operating the power plant, and controlling 

dust

X X X X

Water use for stimulating the reservoir 

during enhanced geothermal system

operations

X

Increased turbidity and suspended 

sediment in surface water resources, due to 

erosion and transport of eroded materials 

where ground disturbance occurs

X X X X

Accidental releases of chemical compounds 

or wastewater, which could contaminate 

surface water or shallow groundwater

X X X X

Changes in groundwater flow paths, 

reduced upward vertical hydraulic gradients, 

loss of water to the formation, geothermal 

fluid temperature reduction

X X

Mixing of geothermal fluids with 

groundwater sources

X X
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-57

3.9.2.4 Impacts Under Alternative 1

Alternative 1 would have the same general impacts on water resources associated with the RFDS

described under Common Impacts Associated with Geothermal Development, above. Although 

the SFNF would not make an availability determination for geothermal leasing in the project 

area, geothermal lease applications and nominations would continue to be processed on a caseby-case basis under separate NEPA analysis, in accordance with the Forest Plan (Forest Service

1987) and existing laws and regulations. 

Geothermal leasing stipulations and closures would not be specifically implemented related to 

watershed, surface water, or groundwater resources; however, any future geothermal lease 

applications and nominations would be subject to standards and guidelines outlined in the Forest 

Plan and environmental analysis. 

It has been established that there is a geothermal plume that extends from the caldera southwest 

to Jemez Springs and Soda Dam. The delineation of that plume is not exact. Most of it likely 

runs through the JNRA Unit, which is not available for leasing. However, the plume may also 

extend into the Middle Unit and South Unit, west of the edge of the caldera. Any pumping, 

including outside of the geothermal system, could affect pressurization, temperature, and 

possible flow paths.

The hot springs in Valles Caldera and southwest of the caldera in San Diego Canyon could be 

impacted by extracting and reinjecting geothermal waters from these systems. Both flow rates 

and water quality could be impacted. Extracting groundwater could have short-term impacts in 

reducing shallow groundwater levels and altering pressures of geothermal sources and fractures. 

Because the applicant would be required to obtain water rights, and the source of makeup water 

is unknown, the amount of water consumption occurring within the project area is unknown.

It is unknown if water for hydraulic stimulation and makeup would be extracted near LANL;

however, LANL has an extensive groundwater monitoring network and implements measures to 

control contaminant migration (LANL 2015). Once plans of exploration and developed are 

submitted, project-specific information, studies, and modeling would help to better understand 

the groundwater system and the potential site-specific impacts of LANL contaminant 

mobilization.

3.9.2.5 Impacts Under Alternative 2

Under Alternative 2, indirect impacts from anticipated geothermal exploration and development 

would generally be the same as those described under Alternative 1, although the location of 

potential sites would be restricted by administrative withdrawals and stipulations. Approximately 

32,000 acres, or 17 percent of the NFS lands in the project area, would be closed to geothermal 

leasing, while approximately 136,650 acres in the project area would be allocated as open to 

geothermal leasing, subject to existing laws, regulations, formal orders, and stipulations. 

NSO stipulations for drinking water sources, points of surface water diversions, developed 

springs and wells, rivers, streams, wetlands, springs, playas, riparian areas, 100-year floodplains, 

and other water bodies would reduce the potential for direct impacts on these resources from 

erosion caused by development and contamination from accidental spills. Implementing a 1-mile 

no leasing protection zone around hot springs should reduce the potential for direct pumping of 

geothermal fluids around these features. However, in this fractured and interconnected system, 
Chapter 3. Affected Environment and Environmental Consequences

3-58 Santa Fe National Forest Geothermal Leasing EIS

pumping some distance from the hot springs could change temperature and chemical 

composition and flow rates. 

NSO stipulations on slopes greater than 40 percent and soils with severe erosion potential, as 

well as CSU stipulations for slopes between 30 and 40 percent, would reduce the potential for 

direct impacts on water resources connected with these sites from erosion caused by 

development and contamination from accidental spills. However, road and power line 

development could still impact all of these areas, as described under Common Impacts 

Associated with Geothermal Development. 

Because the applicant would be required to obtain water rights, and the source of makeup water 

is unknown, the amount of water consumption occurring within the project area is unknown. 

However, BMPs—such as evaluating the consumptive use of water in the operation and its effect 

on water dependent ecosystems, and identifying areas of groundwater discharge and recharge 

and their potential relationship with surface water bodies—could be applied into the permit 

application or included as approved use authorizations by the BLM as COAs. These measures 

would reduce the likelihood of lowering the groundwater table to a level that would not support 

existing land uses.

It is unknown if water for hydraulic stimulation and makeup would be extracted near LANL;

however, LANL has an extensive groundwater monitoring network and implements measures to 

control contaminant migration (LANL 2015). Once plans of exploration and developed are 

submitted, project-specific information, studies, and modeling would help to better understand 

the groundwater system and the potential site-specific impacts of LANL contaminant 

mobilization.

There would be no indirect impacts on surface water in the VCNP or Bandelier National 

Monument. This is because surface water drainage from the caldera generally flows into the 

project area. While headwaters to perennial streams in the South Unit of Bandelier National 

Monument occur in the South Unit of the project area, no impacts on these headwaters are 

anticipated. This is because NSO stipulations would apply to 33,200 acres in the South Unit (or 

97 percent of the South Unit), including 500 feet from the outer edge of perennial and 

intermittent rivers and streams.

3.9.2.6 Impacts Under Alternative 3

There would be no direct impacts on watersheds or groundwater resources under Alternative 3. 

No surface areas would be disturbed by geothermal developments; however, there would be 

indirect impacts on water resources. Because the area would be closed to leasing for the 

foreseeable future, over time, there would be less potential impacts on surface or subsurface 

water resources than expected under implementation of the current Forest Plan.

3.9.2.7 Impacts Under Alternative 4

Impacts from Alternative 4 would be similar to those described under Alternative 2. However, 

there would be no discretionary closures under Alternative 4, and there would be reduced 

protection of specific areas from implementing less restrictive lease stipulations. 

Although there would be no discretionary closures, approximately 17 percent of the NFS lands 

in the project area would still be closed to geothermal leasing. NSO would still be stipulated for 

slopes in excess of 40 percent, and slopes between 30 and 40 percent would still be subject to 

CSU. However, implementing CSU rather than NSO stipulations on areas with severe erosion 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-59

hazard would increase the risk of erosion in areas disturbed by exploration and development of 

geothermal sites. This would increase sedimentation and turbidity into streams and rivers, 

particularly near steeper slopes between 30 and 40 percent and areas with moderately high to 

high runoff potential. 

Runoff from development on steep slopes in areas of severe erosion hazard would be a concern 

for watersheds and water quality if runoff were to reach streams and impact water quality. BMPs

identified in Appendix C could be implemented to minimize and contain erosion.

CSU rather than NSO stipulations in intermittent streams (the NSO still applies to perennial 

streams) would increase the risk of erosion and transport to water sources. This would be the 

case particularly in areas of severe erosion hazard and where the runoff potential is moderate to 

high. Implementing an additional CSU stipulation for ephemeral drainages would reduce the risk 

of erosion and sediment transport in these areas. BMPs identified in Appendix C could be 

implemented to help reduce impacts on these stream reaches. 

Impacts from road development and water use under Alternative 4 would be the same as those

described under Alternative 2.

Under Alternative 4, NSO stipulations apply to natural hot springs, and a 1-mile buffer around 

them. NSO stipulations would protect these resources from accidental spills or leaks from the 

pumping site and would increase the difficulty of accessing geothermal waters close to the hot 

springs. However, this stipulation does not prevent withdrawals from waters near the hot springs

using advanced technology. A lessee of a NSO area must develop any surface infrastructure 

outside the NSO area and would need to use advanced technology, such as directional drilling, to 

access the geothermal resource under the NSO area; nevertheless, those resources could still be 

accessed. Therefore, this alternative is more likely to impact natural hot springs, potentially 

affecting temperatures and flow rates. BMPs identified in Appendix C include a monitoring 

plan, which could be implemented to identify impacts on these resources.

As with Alternative 2, the applicant would be required to obtain water rights, and the source of 

makeup water is unknown; therefore, the amount of water consumed in the project area is 

unknown. It is unknown if water for hydraulic stimulation and makeup would be extracted near 

LANL; however, LANL has an extensive groundwater monitoring network and implements 

measures to control contaminant migration (LANL 2015). Once plans of exploration and 

developed are submitted, project-specific information, studies, and modeling would help to 

better understand the groundwater system and the potential site-specific impacts of LANL 

contaminant mobilization.

There would be no indirect impacts on surface water in the VCNP or Bandelier National 

Monument because surface water drainage from the caldera generally flows into the project area. 

While headwaters to perennial streams in the South Unit of Bandelier National Monument occur 

in the South Unit of the project area, no impacts on these headwaters are anticipated. This is 

because NSO stipulations would apply to 33,200 acres in the South Unit (or 97 percent of the 

South Unit).

3.9.2.8 Cumulative Impacts

Cumulative impacts for water resources are analyzed at the level of the sixth-level watersheds. 

Past, present, and reasonably foreseeable future actions are discussed in Section 3.3.4.
Chapter 3. Affected Environment and Environmental Consequences

3-60 Santa Fe National Forest Geothermal Leasing EIS

Water resource repair and replacement projects—the Pueblo of Jemez Red Rocks Dam Repair, 

the Abiquiu Land Grant Waterline Replacement, and the McKinney County Dam—in 

combination with Alternatives 1, 2, and 4, would likely initially directly impact water resources 

through increased erosion and sedimentation into waterways. However, long-term impacts would 

be improved protection from flooding and erosion and reduced potential for loss of water 

resources through leakage.

Restoration projects, such as the Southwest Jemez Mountains Restoration Project, Pueblo of 

Jemez Owl Springs Bridge Sediment Removal Project, and Valle Seco Wetland Restoration 

Project, would maintain or improve water resource conditions in their respective project areas by 

removing sedimentation and reducing erosion, or by maintaining streambank stability.

Under Alternatives 1, 2, or 4, sedimentation and erosion would likely occur from geothermal 

development. Natural processes, such as fire, could accelerate or amplify the impacts of 

sedimentation and erosion. The magnitude and intensity of these impacts would depend on the 

size and severity of the fire, as well as local soil conditions. Water quality impacts from 

accidental spills related to geothermal development are possible and could be combined with 

impacts from sediment transport and erosion or other accidental spills outside of the project area 

that travel downstream through the sixth-level watersheds. 

Although extracted water would be reinjected after use, water may be lost to the geologic 

formation. To maintain pressure and operation, water that is lost must be made up from 

alternative water sources, which may contribute to the cumulative demand for water resources in 

the fourth-level watersheds under Alternatives 1, 2, and 4. Climate change scenarios predict that 

annual runoff in the Southwest will decrease by as much as 20 percent (Furniss et al. 2010); this

could further increase water demand under these alternatives. In addition, timing and rates of 

groundwater recharge may shift under future climate scenarios, in response to changing patterns 

of precipitation and runoff (Furniss et al. 2010). 

While the source of makeup water is unknown, BMPs identified in Appendix C—such as 

evaluating the consumptive use of water in the operation and its effect on water dependent 

ecosystems, and identifying areas of groundwater discharge and recharge and their potential 

relationship with surface water bodies—could be applied into the permit application or included 

as approved use authorizations by the BLM as COAs. These measures would reduce the 

likelihood of lowering the groundwater table to a level that would not support existing land uses.

3.10 Air Quality and Air Quality-Related Values

3.10.1 Affected Environment

Ambient air quality is affected by the type and amount of air pollutants emitted into the 

atmosphere, the size and topography of the air basin, prevailing meteorological conditions, and 

the conversion of air pollutants and other species by a complex series of chemical and 

photochemical reactions in the atmosphere. The levels of air pollutants are generally expressed 

in terms of concentration, either in units of parts per million (ppm), parts per billion (ppb), or 

micrograms per cubic meter (μg/m).
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-61

3.10.1.1 Regulatory Framework

Clean Air Act

The CAA (42 USC, Sections 7401-7642), as amended, is the primary authority for regulating 

and protecting air quality in the United States. The EPA has the primary responsibility for 

regulating atmospheric emissions. This includes six nationally regulated air pollutants, known as 

criteria pollutants, that are believed to be key indicators of air quality: carbon monoxide, 

nitrogen dioxide, ozone, sulfur dioxide, lead, and two categories of particulate matter (particulate 

matter with an aerodynamic diameter of 10 microns or less [PM10] and particulate matter with an 

aerodynamic diameter of 2.5 microns or less [PM2.5]). 

Under the authority of the CAA, the EPA has set time-averaged national ambient air quality

standards (NAAQS) for these criteria pollutants. The two-tiered standards may be primary or 

secondary. Primary standards set limits to protect public health, including the health of sensitive 

populations, such as asthmatics, children, and the elderly. Secondary standards set limits to 

protect public welfare, including protection against decreased visibility and damage to animals, 

crops, vegetation, and buildings. Averaging periods vary by pollutant, based on the potential 

health and welfare impacts of each pollutant. States may set their own ambient air quality 

standards, but they must be at least as stringent as the national standards. National and state 

ambient air quality standards are shown in Table 3-7, below.

Table 3-7. National and New Mexico Ambient Air Quality Standards

Pollutant Averaging 

Time

National Standards New 

Mexico

Primary Secondary Standard Form

Ozone 8-hour 0.070 

ppm1

Same as 

primary

Annual 4th-highest daily 

maximum 8-hour 

concentration, averaged 

over 3 years

—

Carbon 

monoxide

8-hour 9 ppm — Not to be exceeded more 

than once per year

8.7 ppm

1-hour 35 ppm — 13.1 ppm

Nitrogen 

dioxide

Annual 

(arithmetic 

mean)

0.053 

ppm

Same as 

primary

Annual mean 0.05 ppm

24-hour — — — 0.10 ppm

1-hour 100 ppb — 98th percentile, averaged 

over 3 years

—

Sulfur dioxide Annual mean — — — 0.02 ppm

24-hour — — — 0.10 ppm

3-hour — 0.5 ppm Not to be exceeded more 

than once per year

—

1-hour 75 ppb2 — 99th percentile of 1-hour 

daily maximum 

concentrations, averaged 

over 3 years

—

PM10 24-hour 150 

μg/m3

Same as 

primary

Not to be exceeded more 

than once per year on 

average over 3 years

—
Chapter 3. Affected Environment and Environmental Consequences

3-62 Santa Fe National Forest Geothermal Leasing EIS

Table 3-7. National and New Mexico Ambient Air Quality Standards

Pollutant Averaging 

Time

National Standards New 

Mexico

Primary Secondary Standard Form

PM2.5 Annual 

(arithmetic 

mean)

15 μg/m3Same as 

primary

Annual mean, averaged 

over 3 years

—

24-hour 35 μg/m3Same as 

primary

98th percentile, averaged 

over 3 years

—

Lead3 Rolling 3-month 

average

0.15 

μg/m3

Same as 

primary

Not to be exceeded —

Total 

suspended 

particulates

Annual 

(geometric 

mean)

— — — 60 μg/m3

30-day average — — — 90 μg/m3

7-day — — — 110 μg/m3

24-hour — — — 150 μg/m3

Total reduced 

sulfur

0.5-hour — — — 0.003 ppm

Hydrogen 

sulfide

1-hour 

(statewide)

— — — 0.010 ppm

0.5-hour (within 

5 miles of

municipalities 

greater than 

20,000 people)

— — — 0.003 ppm

Sources: EPA 2016a; New Mexico Commission of Public Records 2002

1

Final rule signed October 1, 2015, and effective December 28, 2015. The 2008 ozone standards additionally remain in 

impact in some areas. Revocation of the 2008 ozone standards and transitioning to the 2015 standards will be 

addressed in the implementation rule for the current standards.

2

Final rule signed June 2, 2010. The 1971 annual and 24-hour sulfur dioxide standards (0.03 ppm annual and 0.14 ppm 

24-hour) were revoked in that same rule making. However, these standards remain in impact until 1 year after an area is 

designated for the 2010 standard. One exception is in areas designated nonattainment for the 1971 standards; here, the 

1971 standards remain in impact until implementation plans to attain or maintain the 2010 standard are approved.

3

Final rule signed October 15, 2008. The 1978 lead standard (1.5 μg/m3) remains in impact until 1 year after an area is 

designated for the 2008 standard. The one exception is in areas designated nonattainment for the 1978 standard; here,

the 1978 standard remains in impact until implementation plans to attain or maintain the 2008 standard are approved.

Hazardous Air Pollutants

Congress amended the CAA in 1990 to address a large number of air pollutants that are known to 

cause or may reasonably be anticipated to cause impacts on human health or the environment. 

Congress initially identified 188 specific pollutants and chemical groups as hazardous air 

pollutants and has modified the list over time. 

The CAA requires control measures for hazardous air pollutants. The EPA issues national 

emissions standards for hazardous air pollutants to limit the release of specified hazardous air 

pollutants from specific industrial sectors. These standards are technology based, meaning that 

they represent the maximum achievable control technology that is economically feasible for an 

industrial sector. The CAA defines a major source for hazardous air pollutants to be one that 

emits 10 tons per year of any single hazardous air pollutant or 25 tons per year of any 

combination of hazardous air pollutants. Under state regulations, a construction or operating 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-63

permit may be required for any major source, though some exceptions apply. In New Mexico, 

these regulations are Sections 20.2.70 and 20.2.73 of the New Mexico Administrative Code. 

Clean Air Act Conformity Requirements

Section 176(c) of the CAA requires that federal actions conform to the appropriate state 

implementation plan. This is a plan developed at the state level that provides for the 

implementation, maintenance, and enforcement of NAAQS and is enforceable by the EPA. The 

EPA has promulgated rules establishing conformity analysis procedures for transportation-related 

actions and for other general federal agency actions (40 CFR, Parts 6, 51, and 93). 

The EPA general conformity rule requires preparation of a formal conformity determination 

document for federal agency actions that are undertaken, approved, or funded in federal 

nonattainment or maintenance areas, when the total net change in direct and indirect emissions 

of nonattainment pollutants (or their precursors) exceeds specified thresholds. Because the SFNF 

Ranger Districts in the project area are not in a nonattainment or maintenance area, the proposed 

action is exempt from the CAA general conformity rule (discussed further under Air Quality

Conditions, below).

Prevention of Significant Deterioration

In addition to the NAAQS, the Prevention of Significant Deterioration (PSD) regulations set 

forth a permit process that applies to new major sources or major modifications of existing 

sources for pollutants. It is applicable where the emission source is inside an attainment or 

unclassifiable area, as defined by the NAAQS. Furthermore, the PSD program requires the use 

of best available control technologies and provides for an air quality impact analysis and public 

involvement. The purpose of the PSD program is to protect public health and welfare. It also 

preserves, protects, and enhances the air quality of national parks and wilderness areas, national 

monuments, seashores, and other areas of recreation, scenic, or historic value.

The PSD regulations prevent areas that are in attainment of the NAAQS from being polluted up 

to the level of the standards. The CAA directs the EPA to classify areas of the United States as 

Class I, II, or III. Class I areas are national parks and wilderness areas of a certain size that 

existed before 1977 or additional areas that have since been designated by federal regulation. 

The PSD regulations place limits on the total increase in ambient pollution levels above 

established baseline levels for sulfur dioxide, nitrogen dioxide, and PM10 that are allowed in 

these areas. Class II areas are the remaining areas in the United States (outside of nonattainment 

and maintenance areas). No Class III areas have been designated.

The SFNF is not a PSD Class I area. There are four Class I areas within 62 miles of the SFNF 

boundary: Bandelier Wilderness, Pecos Wilderness, San Pedro Parks Wilderness, and Wheeler 

Peak Wilderness. 

The PSD regulations require operators of major sources or major modification of sources to 

obtain permits for attainment pollutants. Geothermal plants are not a rule-listed emissions 

source; therefore, the PSD trigger levels are 250 tons per year for each criteria pollutant emitted 

during individual plant operations.

Regional Haze Rule

On July 1, 1999, the EPA issued regional haze rules to comply with the requirements of the 

CAA. Under 40 CFR, Subpart 51.308, the rule requires the State of New Mexico to develop state 

implementation plans. The plans must include visibility progress goals for each of the nine Class 
Chapter 3. Affected Environment and Environmental Consequences

3-64 Santa Fe National Forest Geothermal Leasing EIS

I areas in New Mexico, as well as provisions requiring continuing consultation between the state 

and federal land managers to address and coordinate implementation of visibility protection 

programs. Under 40 CFR, Subpart 51.309, the rule also provides an optional approach to New 

Mexico and eight other western states to incorporate emission-reduction strategies issued by the 

Grand Canyon Visibility Transport Commission. These are designed primarily to improve 

visibility in 16 Class I areas on the Colorado Plateau, including the San Pedro Parks Wilderness 

Area (Forest Service 2015d). New Mexico has been implementing an approved state 

implementation plan since 2006. The goal of the regional haze rule is, by 2064, to return 

visibility in Class I areas to visibility conditions before man-made impacts.

State Law

In New Mexico, the Environmental Improvement Board is the state air pollution control agency 

(except in Bernalillo County), and air quality programs are administered under the authority of 

the NMED. Air quality is regulated under the New Mexico Air Quality Control Act (Sections 74-

2-1 to 74-2-17, New Mexico Statutes, Annotated 1978) and the New Mexico Ambient Air 

Quality Standards and Air Quality Control Regulations. 

The state ambient air quality standards are described in Table 3-7. One of the state-regulated 

pollutants, hydrogen sulfide, is a naturally occurring byproduct of oil, gas, and geothermal 

development in some areas. It is a colorless flammable gas with a rotten egg smell. It is both an 

irritant and a chemical asphyxiant, with impacts on both oxygen utilization and the central 

nervous system. Its health impacts can vary, depending on the level and duration of exposure. 

While there is no NAAQS for hydrogen sulfide, and it is not regulated as a hazardous air 

pollutant under the CAA, a number of states, including New Mexico, have set standards for 

hydrogen sulfide at the state level. No information was found on whether hydrogen sulfide is 

present, or at what levels, in geothermal fluids in the project area.

3.10.1.2 Air Quality Conditions

The CAA requires each state to identify areas that have ambient air quality in violation of federal 

standards using monitoring data collected through state monitoring networks, as follows:

 Areas that violate air quality standards are designated as nonattainment for the relevant 

criteria air pollutants.

 Areas that comply with air quality standards are designated as attainment for the relevant 

criteria air pollutants.

 Areas that have been re-designated from nonattainment to attainment are considered 

maintenance areas.

 Areas of uncertain status are generally designated as unclassifiable but are treated as 

attainment areas for regulatory purposes. 

The project area is in attainment or unclassified for all NAAQS (EPA 2016b). The only 

nonattainment and maintenance areas are in southwestern New Mexico, over 200 miles south of 

the project area. Given the distance between these nonattainment and maintenance areas and the 

weather patterns in New Mexico, the proposed action would have no potential to affect air quality

in these areas; thus, these areas would have no potential to affect air quality in the project area.

The NMED, Air Quality Bureau, is responsible for operating a network of air monitoring stations 

in most of New Mexico. Table 3-8, below, shows the locations, the pollutants monitored, and the 

last 3 years of monitoring data for each station in Rio Arriba and Sandoval Counties. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-65

Table 3-8. Air Quality Monitoring Values in Rio Arriba and Sandoval Counties, New Mexico

Pollutant Averaging 

Time 2012 2013 2014 3-Year Average NAAQS

Percent 

of 

NAAQS

Coyote Ranger District (21 New Mexico 96, Coyote, NM 87012; Rio Arriba County)1

Ozone (ppm) 8-hour N/A20.066 ppm 0.065 ppm N/A20.070 ppm N/C3

Highway Department Yard Near Bernalillo (E Avenida Bernalillo, Bernalillo, NM; Sandoval County)4

Ozone (ppm) 8-hour 0.062 ppm 0.067 ppm 0.062 ppm 0.064 ppm 0.070 ppm 91

Bernalillo City Hall (829 S Camino Del Pueblo, Bernalillo, NM 87004; Sandoval County)5

PM10 (μg/m3) 24-hour 23 μg/m325 μg/m321 μg/m323 μg/m3150 μg/m315

Source: EPA 2016c

1Approximately 2 miles northwest of the project area boundary

2Not available

3Not calculated since there are not 3 consecutive years of data

4Approximately 25 miles south of the project area boundary

5Approximately 30 miles south of the project area boundary

As shown in Table 3-8, ambient air concentrations of monitored pollutants are below the 

NAAQS for stations with 3 consecutive years of data. However, monitored levels of ozone are 

nearing the NAAQS. These ozone levels generally are attributed to oil and gas operations and 

power plants, including the San Juan Generating Station and the Four Corners Power Plant, in 

the region (Four Corners Air Quality Task Force 2007).

Actions to address emissions from oil and gas operations and fossil fuel-fired power plant 

operations have included the following:

 In October 2012, the EPA promulgated New Source Performance Standards under 40 CFR, 

Part 60, Subpart OOOO, that requires air pollution controls for volatile organic compounds 

at natural gas production wells and other facilities associated with the oil and gas industry.

 In 2013, the NMED, the Public Service Company of New Mexico, and the EPA agreed to 

meet the requirements of the federal regional haze rule by closing two units at the San Juan 

Generating Station by the end of 2017. 

 In December 2013, three coal-fired generators were closed at the Four Corners Power Plant 

as part of a plan to meet the requirements of the federal regional haze rule. The remaining 

two coal-fired generators will have selective catalytic reduction technology installed by 

2018. These changes satisfy the EPA’s best available retrofit technology requirements.

It is uncertain whether the Four Corners area will be redesignated as an ozone nonattainment 

area over the 15-year life of the RFDS (2016 to 2031), or if the SFNF will be included in the 

nonattainment boundary if redesignation occurs. While federal, state, local, and tribal 

jurisdictions continue to seek ways to reduce emissions from the oil and gas sector and 

electricity generating plants through voluntary and regulatory mechanisms, sources of ozoneprecursor emissions from these industrial sectors continue to be proposed west of the project 

area. 

Existing Emissions

The EPA prepares a national emissions inventory every 3 years to provide a comprehensive and 

detailed estimate of emissions from all air emission sources in the United States. Emissions in 
Chapter 3. Affected Environment and Environmental Consequences

3-66 Santa Fe National Forest Geothermal Leasing EIS

the inventory are presented by county. The inventories are based on emission estimates and 

model inputs provided by state, local, and tribal air agencies for sources in their jurisdictions, 

supplemented by data developed by the EPA.

Table 3-9, below, summarizes the mobile and stationary source emissions in Rio Arriba and 

Sandoval Counties in 2011, the most recent inventory year available (EPA 2013). This baseline 

emissions summary is a conservative overestimate of project area emissions. This is because it 

includes emissions from all of Rio Arriba and Sandoval Counties, and the project area 

encompasses only approximately 3 percent of those counties together. However, the baseline 

emissions summary provides a scale against which to compare projected emissions from 

geothermal exploration, development, and production under the proposed action.

Table 3-9. Summary of Annual Emissions for Rio Arriba and Sandoval Counties, 2011 (Tons)

Source Category 

County

Volatile 

Organic 

Compounds

Carbon 

Monoxide

Nitrogen 

Oxides

Sulfur 

Dioxide PM10 PM2.5

Agricultural

Rio Arriba — — — — 34 7

Sandoval — — — — 36 7

Subtotal — — — — 70 14

Bulk Gasoline Terminals and Gas Stations

Rio Arriba 303 — — — — —

Sandoval 591 — — — — —

Subtotal 894 — — — — —

Commercial Cooking

Rio Arriba 1 3 — — 7 7

Sandoval 4 11 — — 29 26

Subtotal 5 14 — — 36 33

Dust

Rio Arriba — — — — 32,819 308

Sandoval — — — — 38,616 3,949

Subtotal — — — — 71,435 4,257

Fuel Combustion

Rio Arriba 811 2,542 1,811 13 109 106

Sandoval 214 1,296 416 75 209 180

Subtotal 1,025 3,838 2,227 88 318 286

Industrial Processes

Rio Arriba 15,498 12,411 9,016 4 124 109

Sandoval 525 338 300 0 35 9

Subtotal 16,020 12,749 9,316 4 159 118

Miscellaneous Nonindustrial 

Rio Arriba 19 0 0 0 0 0

Sandoval 36 0 0 0 0 0

Subtotal 55 0 0 0 0 0

Mobile Sources

Rio Arriba 920 6,608 1,108 6 62 49

Sandoval 1,513 15,487 3,397 16 169 129

Subtotal 2,433 22,095 4,505 22 231 178
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-67

Table 3-9. Summary of Annual Emissions for Rio Arriba and Sandoval Counties, 2011 (Tons)

Source Category 

County

Volatile 

Organic 

Compounds

Carbon 

Monoxide

Nitrogen 

Oxides

Sulfur 

Dioxide PM10 PM2.5

Solvents

Rio Arriba 295 — — — — —

Sandoval 929 — — — — —

Subtotal 1,224 — — — — —

Waste Disposal

Rio Arriba 30 366 14 1 67 57

Sandoval 3 4 1 1 11 7

Subtotal 33 370 15 2 78 64

Total source 

emissions

21,689 39,066 16,063 116 72,327 4,950

Total source 

emissions (without 

fugitive dust)

21,689 39,066 16,063 116 892 693

Source: EPA 2013

3.10.1.3 Air Quality-Related Values

AQRVs are resources that may be affected by a change in air quality, including visibility, aquatic 

and terrestrial impacts of wet and dry pollutant deposition, and terrestrial impacts of ozone. The 

only AQRV discussed in this report is visibility, which is the primary AQRV concern in the 

project area and the AQRV with the most potential to be impacted by the proposed action.

In 1985, the EPA initiated a network of monitoring stations to measure impacts on visibility in 

Class I areas. These are known as the Interagency Monitoring for the Protection of Visual 

Environments monitors and exist in some, but not all, Class I areas. There are monitors at three 

of the four Class I areas within 62 miles of the project area; however, one of the monitors 

represents conditions at both the Pecos Wilderness and Wheeler Peak Wilderness. 

The visibility trends for the Interagency Monitoring for the Protection of Visual Environments 

monitors in Bandelier Wilderness, Pecos Wilderness/Wheeler Peak Wilderness, and San Pedro 

Parks Wilderness are shown in the Air Technical Report (Forest Service 2016d). In most cases, 

visibility trends have been flat or improving. Implementation of best available retrofit 

technology strategies, as required under the federal Regional Haze Rule, may result in further 

improvements. The peak in the Bandelier Wilderness 20 percent worst days line is likely due to 

the occurrence of large wildfires in 2000.

3.10.2 Environmental Consequences

3.10.2.1 Scoping Comments on Resource

The following issues specific to air quality and AQRVs were identified during the public scoping 

period:

 How would gases and emissions from geothermal leasing be monitored and controlled, and 

how would residual waste accumulations from air emission management be disposed of?
Chapter 3. Affected Environment and Environmental Consequences

3-68 Santa Fe National Forest Geothermal Leasing EIS

 What are the impacts of odors from geothermal leasing, and how would these affect 

receptors in the project area?

3.10.2.2 How Resource Impacts Were Evaluated

Method

The method for air quality impact analysis is incorporated by reference from the 2008 

Geothermal PEIS (BLM and Forest Service 2008). There would be no direct impacts on air 

quality and AQRVs from leasing actions. However, it is reasonable to foresee that on-the-ground 

impacts would occur if the Forest Service were to consent to leasing and the BLM were to issue 

geothermal leases. 

The potential impacts of geothermal development on air quality and AQRVs were evaluated by 

examining the typical air emissions associated with the various stages of geothermal 

development. The emissions from potential geothermal well development were compared against 

the PSD construction permit threshold. There are no federally designated nonattainment areas in 

the project area, so CAA conformity guidelines do not apply.

Indicators

The indicators of impacts on air quality are as follows:

 Emissions in tons per year for regulated pollutants

 Comparison to PSD permitting thresholds

 Amount and time frame of steam and water vapor emitted from potential project operations

Assumptions

 BMPs, such as those identified in Appendix C, would be applied, as applicable, at the BLM 

permitting level to minimize impacts on air quality from exploration, drilling operations, 

utilization, and reclamation and abandonment.

 State air permitting requirements would depend on the timing, scope, and size of sitespecific geothermal exploration, development, and utilization proposals and would be 

determined during project-level analysis prior to approval.

 Based on existing temperature gradient data, binary cycle power plants (which operate at 

lower temperatures than flash steam or dry steam plants) are the most likely technology that 

would be developed in the project area. Therefore, this analysis does not assess the potential 

impacts of flash steam or dry steam geothermal power plants. Binary plants are closed-loop 

systems and do not emit air pollutants during their operation. For this reason, only emissions 

from exploration and development are evaluated. 

 Binary plants would use air cooling rather than wet cooling.

 Five 25-megawatt binary power plants would be developed on leases in the project area. 

 Total surface disturbance associated with geothermal exploration would be 27 acres.

 Total surface disturbance associated with development drilling and utilization would be 647

acres, including disturbance associated with developing wells, transmission lines, pipelines, 

roads, power plants, and ancillary facilities.

Geothermal leasing would have no direct impacts on air quality and AQRVs; any impacts would 

occur from subsequent development activities.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-69

3.10.2.3 Common Impacts Associated with Geothermal Development

This section addresses the general air quality and AQRV impacts associated with each phase of 

geothermal development. The common impacts associated with exploration, drilling, utilization, 

and reclamation and abandonment presented in the 2008 Geothermal Programmatic EIS (BLM 

and Forest Service 2008; Section 4.8.3, Common Impacts on Air Quality and Atmospheric 

Values Associated with Geothermal Development) are summarized below. 

Some activities resulting in air quality emissions are common to all phases of a geothermal 

project life cycle, while others are specific to certain phases. Table 4-1 in the Geothermal 

Programmatic EIS (BLM and Forest Service 2008) summarizes the activities and the criteria 

pollutants of concern related to those activities and are incorporated here by reference.

General Geothermal-Related Air Quality Impacts Associated with Each Phase of 

Geothermal Development

Exploration

Air quality and AQRV impacts associated with exploration are short term and are generally 

limited to the release of fugitive dust from surface disturbance and emissions from vehicles and 

construction and drilling equipment. Initial exploration activities, such as surveying and 

sampling, would have minimal impacts on air quality and AQRVs. These impacts would be from 

accessing exploration sites in areas without roads and from disturbing small land areas while 

placing surveying equipment. Secondary exploration activities, specifically site clearing, 

exploration well pad development, and drilling temperature gradient wells and slim wells, would 

have more intensive fugitive dust and exhaust-related emissions and would last longer. The total 

time for exploration activities typically ranges from 1 to 5 years.

Drilling Operations

Air emissions during the drilling operations phase of a geothermal project are fugitive dust and 

emissions from combustion engines. The following specific activities during the drilling 

operations phase would result in emissions of fugitive dust and exhaust from combustion 

engines:

 Driving vehicles, such as worker vehicles, watering trucks, and materials delivery trucks, on 

access roads

 Removing vegetation cover 

 Constructing roads and well pads

 Drilling production and injection wells

 Constructing fluid sump pits

As successful wells are drilled, geothermal fluids venting to the atmosphere are an additional 

source of air pollutant emissions. Well venting introduces the potential release of hydrogen 

sulfide, carbon dioxide, mercury, arsenic, and boron when these compounds are present in the 

geothermal resource. Hydrogen sulfide is generally the primary pollutant of concern if present in 

the geothermal resource. The NMED may require a project proponent to establish an air 

monitoring program for hydrogen sulfide emissions. 

Utilization

Constructing a geothermal power plant and its associated infrastructure—roads, pipelines, and 

transmission lines—during the onset of the utilization phase would create fugitive dust and 
Chapter 3. Affected Environment and Environmental Consequences

3-70 Santa Fe National Forest Geothermal Leasing EIS

exhaust from combustion engines. Fugitive dust and exhaust from combustion engines during 

operations in the utilization phase would be generally limited to worker and maintenance vehicle 

traffic.

A binary cycle geothermal power plant does not emit air pollutants, except from well venting 

during maintenance or leaks in the heat exchangers, which could result in the release of volatile 

organic compounds. The working fluid in the binary power plants would be condensed through 

air cooling, which does not produce steam plumes. 

Reclamation and Abandonment

Air quality and AQRV impacts during reclamation and abandonment would be limited to 

emissions from vehicles, trucks, and construction equipment and to fugitive dust from the 

movement of vehicles and reclamation of disturbed areas. Depending on the flow and 

temperature of the geothermal fluids or steam at the well heads at the time of abandonment, well 

capping could release the range of pollutants listed above under General Impacts by Geothermal 

Development Phase—Drilling Operations.

Emissions by Geothermal Development Phase for the Reasonably Foreseeable 

Development Scenario

This section describes the air pollutant emissions from each stage of geothermal exploration and 

development, as described in the RFDS, which also describes the phases as exploration, 

development drilling and utilization, and final plugging and reclamation. Because the RFDS is 

the same under all alternatives except Alternative 3, emissions under each of the other 

alternatives would be the same. 

Exploration

Exploration would have temporary impacts on air quality and AQRVs from construction and 

drilling. Sources of temporary and localized fugitive dust emissions are the following:

 Surface disturbance for temperature gradient wells, slim wells, and exploration roads

 Travel on unpaved roads and surfaces by commute vehicles, delivery trucks, water trucks, 

and tractor trailers

 Travel on paved roads by commute vehicles, delivery trucks, water trucks, and tractor 

trailers

Sources of temporary exhaust-related criteria pollutant emissions are the following:

 Gas- and diesel-powered construction equipment for exploration road development

 Drill rigs and auxiliary equipment to develop temperature gradient wells and slim wells

 Tractor trailers to bring in and move out construction and drilling equipment

 Water trucks for dust suppression during road construction and to bring in water for mixing 

drilling fluids during well development

 Delivery trucks for supplies

 Commute vehicles for road construction and drill rig personnel 

Diesel-fired equipment and trucks would also emit small quantities of diesel particulate matter, 

acetaldehyde, benzene, and formaldehyde. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-71

Temperature gradient wells do not typically come in contact with the geothermal resource; 

therefore, no release of naturally occurring non-condensable gases, such as carbon dioxide or 

hydrogen sulfide, or trace amounts of boron, mercury, or arsenic would occur. Slim wells do 

encounter the geothermal resource and thus have the potential to release these gases; blowoutprevention equipment and monitoring devices for hydrogen sulfide may be required for slim well 

development and would be determined at the project-level planning stage.

Under the RFDS, the geothermal exploration time frame is 1 to 5 years of the 15-year RFDS 

time frame. Table 3-10, below, summarizes the number and type of wells and the area of surface 

disturbance associated with exploration under the RFDS.

Table 3-10. Summary of Geothermal Exploration Activities and Surface Disturbance

Activity

Amount Expected over 

15-Year RFDS Time 

Frame (2016 to 2031)

Amount of 

Disturbance 

(Acres)

Disturbance over Project 

Area over 15-Year RFDS

Time Frame (Acres)

Temperature gradient wells 15 wells 0.25 3.75

Slim wells 5 wells 2.80 14.00

Exploration roads 10 miles of road widened 

by 8 feet

N/A 9.7

Total 27.45

Source: BLM 2015

Table 3-11, below, depicts potential emissions for exploration associated with geothermal 

exploration drilling, based on the parameters described in Table 3-10, above. Emissions are 

presented to develop a single exploration well and include the following categories:

 Emissions from on-road vehicles and trucks 

 Fugitive dust from vehicle travel on unpaved roadways

 Fugitive dust from vehicle travel on paved roadways

 Emissions from drill rigs and auxiliary equipment 

Emissions from developing a single well are multiplied by the total number of wells to estimate 

the total well drilling emissions that would be associated with the RFDS.

In addition to the drilling-related emissions shown in Table 3-11, the following construction 

activities would produce emissions:

 Construction equipment not used for road development

 Fugitive dust during road development

The primary pollutants of concern relative to construction emissions are fugitive dust from 

surface disturbance, wind erosion, and travel on unpaved surfaces and criteria pollutant, 

primarily nitrogen oxide, emissions from the operation of diesel-fired construction equipment,

and heavy truck traffic. Because emissions from construction would be temporary and localized 

and would occur intermittently over 1 to 5 years, construction-related emissions from road 

development have not been quantified for this analysis.
Chapter 3. Affected Environment and Environmental Consequences

3-72 Santa Fe National Forest Geothermal Leasing EIS

Table 3-11. Geothermal Exploration Well Drilling Emissions

Activity1 Carbon 

Monoxide

Nitrogen 

Oxides

Volatile 

Organic 

Compounds

Sulfur 

Oxides PM10 PM2.5

On-road vehicle exhaust (tons 

per well)

0.0281 0.0279 0.0042 0.0001 0.0015 0.0012

Unpaved road dust2(tons per well) - - - - 0.6855 0.0685

Paved road dust (tons per well) - - - - 0.0260 0.0033

Drill rig and auxiliary equipment 

(tons per well)

0.1484 0.5419 0.0417 0.0157 0.0339 0.0329

Total (tons per well) 0.1484 0.5419 0.0417 0.0157 0.7469 0.1059

Total3(tons per RFDS [20 

wells])

3.53 11.40 0.92 0.32 14.94 2.12

Source: Forest Service GIS 2015

1Assumptions for equipment use, vehicle miles traveled, and drilling times and durations, along with emission 

spreadsheet tables, are provided in the Air Quality Technical Report (Forest Service 2016d).

2Assumes dust control using watering and speed limits; dust could be further controlled with chemical dust suppressants 

or by covering roads with aggregate.

3Emissions from vehicle travel (on-road exhaust and paved and unpaved road dust) would likely be less under the full 

RFDS, as drill rig equipment and other construction equipment would likely be moved from well site to well site, resulting 

in fewer miles traveled than calculated for a single well development. 

BMPs, such as those identified in Appendix C, would be applied at the permit level to minimize 

impacts on air quality and AQRVs from construction and surface disturbance. These include 

measures to mitigate equipment exhaust emissions and measures to control fugitive dust. BMPs 

would be incorporated into the permit application or may be included in the approved use 

authorization as conditions of approval. 

Development Drilling and Utilization

Development drilling and utilization would have temporary impacts on air quality and AQRVs

from construction and drilling. Sources of temporary and localized fugitive dust emissions would 

be the following:

 Surface disturbance for well pads, transmission lines, pipelines, roads, and power plant 

construction

 Travel on unpaved roads and surfaces by commute vehicles, delivery trucks, water trucks, 

and tractor trailers

 Travel on paved surfaces by commute vehicles, delivery trucks, water trucks, and tractor 

trailers

Sources of temporary exhaust-related criteria pollutant emissions would be the following:

 Gas- and diesel-powered construction equipment for well pad, transmission line, pipeline, 

road, and power plant construction

 Drill rigs and auxiliary equipment to develop production and injection wells

 Tractor trailers to bring in and move out construction and drilling equipment and materials to 

construct the power plants

 Water trucks for dust suppression during road construction and to bring in water for mixing 

drilling fluids during well development
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-73

 Delivery trucks for supplies

 Commute vehicles for construction and drill rig personnel 

As described under Exploration, above, diesel-fired equipment and trucks would also emit small 

quantities of diesel particulate matter, acetaldehyde, benzene, and formaldehyde. 

In addition to diesel equipment and vehicle emissions, well drilling has the potential to release 

non-condensable gases, such as carbon dioxide, hydrogen sulfide, methane, and ammonia, as 

well as trace amounts of mercury, boron, and arsenic when these compounds are contained in the 

geothermal resource. The amount and ratio of these constituents varies by geothermal resource, 

with carbon dioxide generally comprising over 95 percent of the non-condensable gases. Noncondensable gases would be emitted during flow testing, but this would be temporary, lasting 

until the well is shut in or connected to the pipeline.

While the exact characterization of the geothermal resource that would be developed is not yet 

known, there is potential for hydrogen sulfide to be present in the resource. Hydrogen sulfide is the 

non-condensable gas of greatest concern because it can pose a threat to human health at high 

concentrations (BLM and Forest Service 2008). It also can result in nuisance odor conditions, even 

at levels below the state standard for hydrogen sulfide. Hydrogen sulfide releases are of greatest 

concern in the event of a well blowout. Blowout prevention equipment may be required for well 

development, so large releases of hydrogen sulfide during well development would be unlikely. 

Some minor releases of hydrogen sulfide could occur during well drilling and flow testing. 

The NMED may require that monitoring devices be installed and operated during drilling and 

testing and that a hydrogen sulfide abatement plan be developed. Any necessary mitigation 

measures and BMPs would be determined during project-specific NEPA analysis and NMED air 

permitting at the project-level stage. Such measures as monitoring and abatement would ensure 

that hydrogen sulfide emissions would not result in unsafe levels and would prevent potential 

nuisance odors if hydrogen sulfide is present in the geothermal resource.

Under the RFDS, the development drilling and utilization time frame is 2 to 10 years of the 15-

year RFDS time frame. Table 3-12, below, summarizes the number of wells and the area of 

surface disturbance associated with development drilling under the RFDS.

Table 3-12. Summary of Geothermal Development Drilling and Surface Disturbance 

Component

Amount Expected over 

the 15-Year RFDS Time 

Frame (2016 to 2031)

Amount of 

Disturbance (Acres)

Disturbance in the Project 

Area over 15-Year RFDS

Time Frame (Acres)

Wells 30 wells 5.0 acres per well 150.00

Transmission lines Maximum of 14 miles at a 

width of 200 feet

N/A 339.00 

Pipelines Maximum of 7 miles per 

power plant with a width of 

25 feet

21.2 acres per power 

plant

106.00

Roads 10 miles of road widened 

by 2 feet

N/A 2.42

Power plants and 

ancillary facilities

5 power plants 10.0 acres per power 

plant

50.00

Total 647.42

Source: BLM 2015
Chapter 3. Affected Environment and Environmental Consequences

3-74 Santa Fe National Forest Geothermal Leasing EIS

Production well development requires much larger drill rigs and auxiliary equipment and longer 

drilling times than exploration well development. As such, emissions from development drilling 

operations are much greater than from exploration well operations. For comparison purposes, on a 

per-well basis, emissions from development drilling operations would not exceed Pre-Construction 

and New Source Review permit rates of 25 tons per year of criteria pollutants, or PSD construction 

permit limits for major stationary sources of 250 tons per year of any regulated pollutant. However, 

production well development associated with a single proposed geothermal power plant (six wells) 

could exceed the Pre-Construction and New Source Review permit rate. Development of the 30 

wells together would not exceed the PSD construction permit limit of 250 tons per year for any 

regulated pollutant. The RFDS indicates that exhaust emission and dust would be controlled to 

meet applicable air quality standards for the duration of the drilling operation.

In addition to the development drilling-related emissions shown in Table 3-13, the following 

construction activities would produce air pollutant emissions:

 Non-road construction equipment emissions for well pad, transmission line, pipeline, road, 

and power plant construction

 On-road vehicle equipment emissions from material and equipment deliveries, water trucks, 

concrete trucks, and construction personnel commute vehicles

 Fugitive dust emissions from well pad, transmission line, pipeline, road, and power plant 

development

Table 3-13. Geothermal Development Drilling Emissions

Activity1 Carbon 

Monoxide

Nitrogen 

Oxides

Volatile 

Organic 

Compounds

Sulfur 

Oxides PM10 PM2.5

On-road vehicle exhaust 

(tons per well)

0.0959 0.0765 0.0139 0.0004 0.0047 0.0036

Unpaved road dust2(tons 

per well)

- - - - 2.96 0.30

Paved road dust (tons per 

well)

- - - - 0.1091 0.0138

Drill rig and auxiliary 

equipment1(tons per well)

1.85 7.15 0.52 0.15 0.38 0.36

Total (tons per well) 1.85 7.15 0.52 0.15 3.4538 0.6774

Total3(tons per 6 wells) 11.68 43.36 3.20 0.90 20.72 4.06

Total (tons per RFDS [30 

wells])

58.38 216.80 16.02 4.51 103.61 20.32

Source: Forest Service GIS 2015

1Assumptions for equipment use, vehicle miles traveled, and drilling times and durations, along with emission 

spreadsheet tables, are provided in the Air Quality Technical Report (Forest Service 2016d).

2Assumes dust control using watering and speed limits; dust could be further controlled with chemical dust suppressants 

or by covering roads with aggregate.

3Emissions from vehicle travel (on-road exhaust and paved and unpaved road dust) would likely be less under the full 

RFDS. This is because drill rig equipment and other construction equipment would likely be moved from well site to well 

site, resulting in fewer miles traveled than calculated for a single well development. In addition, commute-related 

emissions may be less if on-site worker camps were developed for drill rig personnel.

As described under Exploration, above, the primary pollutants of concern relative to construction 

emissions are fugitive dust from surface disturbance, wind erosion, travel on unpaved surfaces, 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-75

and criteria pollutant emissions, primarily nitrogen oxide, from the operation of diesel-fired 

construction equipment and heavy truck traffic. Because emissions from construction would be 

temporary and would occur over 2 to 10 years, construction-related emissions from these 

activities have not been quantified for this analysis.

Construction for development and utilization would occur at a scale requiring air permits from 

NMED, as well as implementation of measures to mitigate fugitive dust emissions and 

equipment exhaust emissions. BMPs, such as those identified in Appendix C, would be applied, 

as needed, at the BLM permitting level to minimize impacts on air quality from construction and 

surface disturbance. BMPs would be incorporated into the permit application or may be included 

in the approved use authorization as conditions of approval.

Under the RFDS, five 25-MW geothermal binary cycle power plants would operate for 30 to 50 

years. Operating a binary cycle geothermal power plant does not emit air pollutants, except from 

well venting during maintenance or from leaks in the heat exchangers, which could result in the 

release of volatile organic compounds.

Binary cycle power plants operate on water at temperatures of approximately 225oF to 360oF. 

Binary cycle plants use the heat from the hot water to boil a working fluid, usually an organic 

compound with a low boiling point. The working fluid is vaporized in a heat exchanger and is 

used to turn a turbine. The water is then injected back into the ground to be reheated. Under 

normal operations, binary power plants operate in a closed environment, where the geothermal 

fluid and the working fluid do not contact the atmosphere. The working fluid is a substance with 

a low boiling point, typically a butane or pentane hydrocarbon. 

Because the power plant would be a closed system with the working fluid rarely exposed to the 

atmosphere, little impact on air quality is expected from the operation of the power plant. During 

maintenance or if there are leaks in the system, there may be emissions of nitrogen, carbon 

dioxide, and oxygen from the working fluid. Mitigation measures, such as those identified in 

Appendix C, may be applied at the permit level to monitor for emissions from plant operations.

In addition, the RFDS indicates that because of the cool air temperatures and the scarcity of 

water in the project area, the binary plants would likely be air cooled instead of water cooled. 

Air-cooled plants do not produce steam plumes; therefore, plant operations would not affect 

visibility in any of the four Class I areas within 62 miles of the project area. Operation of a 

binary power plant would likely have emissions below the level that constitutes a major source 

of new emissions in the federal PSD program.

The RFDS estimates that each plant would employ 9 shift workers and up to 12 additional 

workers per day. Emissions would be limited primarily to vehicle and maintenance equipment, 

including vehicle commute traffic, delivery traffic, and on-site maintenance truck and equipment 

use. These emissions would be low. 

Reclamation and Abandonment

Air quality and AQRV impacts during reclamation and abandonment would include emissions 

from vehicles, construction equipment, and truck traffic, from dismantling the power plant and 

other unnecessary infrastructure, and fugitive dust from the movement of vehicles and 

reclamation of disturbed areas. Depending on the flow and temperature of the geothermal fluids 

or steam at the well heads at the time of abandonment, well capping could result in the potential 

release of the range of pollutants listed under Development Drilling and Utilization, above. 

Because reclamation and abandonment would occur 30 to 50 years in the future, no emissions 
Chapter 3. Affected Environment and Environmental Consequences

3-76 Santa Fe National Forest Geothermal Leasing EIS

have been calculated for this action. However, these activities would be subject to NEPA analysis 

and BLM permitting, at which time mitigation measures and BMPs would be determined to

minimize or mitigate impacts on air quality.

3.10.2.4 Impacts Under Alternative 1

Alternative 1 would have the same impacts on air quality as described under Emissions by 

Geothermal Development Phase for the RFDS, above. Well drilling emissions, as quantified in 

Table 3-11 and Table 3-13, would emit criteria air pollutants, hazardous air pollutants, and 

GHGs in the project area. Exploration drilling emissions for all 20 wells would be far below the 

PSD permitting threshold of 250 tons per year (presented for comparison purposes only). These 

emissions would also be less than 1 percent of county emission levels described in Table 3-9 for 

all criteria pollutants.

Development drilling would produce a greater level of emissions. Emissions to develop and 

complete all 30 wells would still be below the PSD permitting threshold of 250 tons per year. 

These emissions would also be less than 1 percent of county emission levels described in Table 

3-9 for volatile organic compounds, carbon monoxide, PM10, and PM2.5 (when fugitive dust is 

included), 1.35 percent of county emissions for nitrogen oxides, and 4.05 percent of county 

emissions for sulfur dioxide. Thus, development drilling would contribute to county emissions 

but not to a substantial degree, relative to overall emissions. Drilling emissions would be a 

temporary and short-term source of emissions.

Construction activities would emit similar pollutants, as described for drilling. However, they 

would be at lower levels for exploration and at similar or lower levels for development and 

utilization, given the amount of surface disturbance described in Table 3-12 and the diesel-fired

heavy construction equipment that would be necessary to construct the power plants and 

associated infrastructure. As described under Emissions by Geothermal Development Phase for 

the Reasonably Foreseeable Development Scenario, construction would be temporary and would 

occur over a 1- to five-year exploration time frame and a 2- to 10-year development time frame.

Both drilling and construction emissions would be minimized or mitigated through BMPs

applied at the permit level to minimize impacts on air quality from well drilling, facility and 

infrastructure construction, and surface disturbance. BMPs would be incorporated into the permit 

applications or may be included in the approved use authorizations as conditions of approval. 

BMPs identified in Appendix C include measures to mitigate equipment exhaust emissions and 

control fugitive dust. State air permitting would impose additional limits on allowable emissions 

from future development activities. The permits required and the conditions imposed in these 

permits would be determined during project-specific permitting processes.

Long-term emissions from operating the binary cycle geothermal power plants would be low. 

Binary cycle power plants are closed-loop systems and generally do not emit pollutants under 

normal operating conditions. Because the plants would be air cooled, they would not emit steam 

plumes and, therefore, would not affect visibility in the four Class I areas within 62 miles of the 

project area. They also would not emit hydrogen sulfide; therefore, plant operations would not 

cause nuisance odor conditions.

3.10.2.5 Impacts Under Alternative 2

The RFDS under Alternative 2 would be the same as described under Alternative 1; therefore, 

impacts related to the overall levels of emissions would be the same. Impacts on AQRVs would 

also be the same. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-77

While the moderate to major constraints in areas open to geothermal leasing would not affect the 

overall level of emissions that would result from geothermal development in the project area, it 

may alter the locations where geothermal development would occur. More areas would be 

constrained under Alternative 2 than under Alternative 1; therefore, geothermal exploration and 

development under Alternative 2 could occur in a smaller area in the project area than under 

Alternative 1. As the RFDS indicates that geothermal plants would be spaced by 1 mile or more, 

the overall direct and indirect impacts would be the same as described under Alternative 1.

3.10.2.6 Impacts Under Alternative 3

Under Alternative 3, there would be no geothermal development; therefore, no direct or indirect 

impacts on air quality or AQRVs would occur.

3.10.2.7 Impacts Under Alternative 4

Direct and indirect impacts on air quality and AQRVs under Alternative 4 would be the same as 

described for Alternative 1.

3.10.2.8 Cumulative Impacts

Cumulative air quality impacts occur when multiple projects affect the same geographic area at 

the same time, or when sequential projects extend the duration of air quality impacts on a given 

area over a longer period. Air quality monitoring data trends can predict future air quality 

conditions in the cumulative impacts area. Past and present actions in the project area have 

affected air quality such that monitored levels of ozone are nearing the NAAQS. Ozone levels 

generally are attributed to oil and gas operations and power plants, including the San Juan 

Generating Station and the Four Corners Power Plant, in the region (Four Corners Air Quality 

Task Force 2007).

Past and present actions on SFNF lands that have affected air quality are those related to 

development, including timber harvest, road development, and mineral development. Reasonably 

foreseeable actions would also affect air quality, including pumice mine expansion and 

development and actions related to vegetation management. These actions would have temporary 

and intermittent air quality impacts from vehicle and equipment use and surface disturbance. 

The contribution of Alternatives 1, 2, and 4 to cumulative air pollutant emissions would be minor, 

and such impacts would be minimized by implementing BMPs identified in Appendix C. Air 

quality impacts from these alternatives would consist of temporary impacts during well exploration 

and development. As a result, the potential for cumulative impacts from this alternative would be 

short term and minimal, as binary cycle power plants are closed-loop systems and do not emit 

pollutants under normal operating conditions. Alternative 3 would not emit air pollutants; 

therefore, there would be no cumulative impacts associated with this alternative.

3.11 Vegetation

3.11.1 Affected Environment

3.11.1.1 Fire

The natural fire regime has been interrupted since the late 1800s. High numbers of sheep and 

cattle that grazed in the Jemez Mountains reduced the native grasses that carried surface fires. 

The Forest Service has suppressed wildfires, even those that would have benefited the landscape;
Chapter 3. Affected Environment and Environmental Consequences

3-78 Santa Fe National Forest Geothermal Leasing EIS

without fire to control their numbers, seedlings and saplings thrived. As a result, the forests in 

the project area are dominated by dense thickets of pole-sized trees, 5 to 16 inches in diameter. 

Understory plants and grasses, large, thick-barked pine trees, and old growth are lacking. The 

species composition has shifted, and ponderosa pine forests now resemble mixed conifer forests,

with more Douglas-fir, white fir, and limber pine (Forest Service 2015b). 

3.11.1.2 Vegetation Communities

There are twelve major vegetation communities in the 194,900-acre project area (Table 3-14, 

Major Vegetation Communities in the Project Area, and Figure 2 in the SFNF Geothermal 

Leasing EIS, Wildlife, Fisheries, and Plants Report [Forest Service 2016e]). 

The dominant vegetation communities are ponderosa pine (Pinus ponderosa), upper deciduous 

evergreen mix, and pinyon-juniper. The ponderosa pine forest vegetation community is 

dominated by ponderosa pine but includes other species, such as oak (Quercus spp.), juniper

(Juniperus spp.), and pinyon (Pinus edulis). Such species as aspen (Populus tremuloides), 

Douglas-fir (Pseudotsuga menziesii), white fir (Abies concolor), and blue spruce (Picea 

pungens) may also be present but occur infrequently as small groups or individual trees. This 

forest vegetation community typically occurs with an understory of grasses and forbs and 

sometimes includes shrubs. There are 65,200 acres of ponderosa pine forest, covering 

approximately 33 percent of the project area.

Table 3-14. Major Vegetation Communities in the Project Area

Vegetation Community Acres Percent of Project Area

Blue grama grassland 3,200 1.6

Perennial grass mix 7,400 3.8

Big sagebrush 4,100 2.1

Deciduous shrub mix 5,500 2.8

Aspen 4,900 2.5

Juniper 11,100 5.7

Pinyon/pinyon-juniper 20,800 10.7

Ponderosa pine 65,200 33.4

Spruce and fir 9,600 4.9

Upper deciduous evergreen mix 63,200 32.4

Sparsely vegetated Less than 100 0.0

Total 194,900 100.00

Source: Forest Service GIS 2015

Suitable mature ponderosa pine habitat is abundant in the project area; however, much of this 

forest type has become crowded and overstocked with relatively young trees. Open areas are

gradually filling in with trees. These systems have moved from open forests, dominated by 

groups and clumps of trees of different ages and sizes, to a dense, continuous blanket of evenaged (80- to 90-year-old), pole-sized (5- to 12-inch-diameter) trees. Tree densities in the 

southwest Jemez Mountains have increased 10-fold, from an average of 15 to 56 trees per acre to 

500 trees per acre (Forest Service 2010). There are fewer large (over 18-inch-diameter) trees, old

growth trees, snags, and down wood. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-79

Openings and understory plants are scarce. The common, open park-like characteristic of 

reference conditions for ponderosa pine forests (Swetnam and Baisan 1996) promoted greater 

faunal diversity and were better adapted to fire than the dense stands of today. Ponderosa pine 

forests in the project area are generally denser and more continuous than in pre-settlement 

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

would have occurred under the historic disturbance regime. The dense tree canopy also inhibits 

the growth of understory grasses, forbs, and shrubs. Instead, there is a carpet of pine needles.

The lack of fire disturbance has led to fuel loads that increase the risk of uncharacteristically 

severe wildfire and drought-related mortality. This means there is more competition for light, 

water, and nutrients. On average, the trees are now smaller and grow more slowly. There is a 

moderate risk of insect and disease outbreak, which is also a function of increased tree density.

The spruce/fir community occurs in high elevation areas in the project area. This community is 

dominated by blue spruce, Douglas-fir, and white fir. Mature and old growth spruce/fir forests on 

the SFNF provide valuable habitat for various special status wildlife species. There are 9,600 

acres of spruce/fir, covering approximately 5 percent of the project area.

Upper deciduous evergreen mix is present throughout the project area between the ponderosa 

pine and the spruce/fir vegetation communities. This community contains a mix of ponderosa 

pine, blue spruce, Douglas-fir, white fir, and aspen. The canopy cover for this community is 

composed of less than 75 percent deciduous trees (Brohman and Bryant 2005). There are 63,200 

acres of upper deciduous evergreen mix, covering approximately 32 percent of the project area.

Aspen-dominated stands are currently a minor part of New Mexico forests and forests in the 

project area, though they are considered important for providing diversity of wildlife habitat, 

forage, and watershed values in the conifer-dominated forests. There are approximately 4,900 

acres of aspen covering approximately 3 percent of the project area. Aspen forests are unusual 

because they reproduce primarily by suckering from the parent root system. Often a disturbance 

or dieback is necessary to stimulate stand regeneration.

The pinyon/pinyon-juniper cover type is collectively composed of the pinyon woodland, pinyonjuniper grassland, pinyon-juniper sagebrush, pinyon-juniper evergreen shrub, and pinyon-juniper 

persistent woodland communities. Two-needle pinyon pine (Pinus edulis) is common, as is oneseed (Juniperus monosperma), Utah (J. osteosperma), Rocky Mountain (J. scopulorum), and 

alligator (J. deppeana) juniper. Species composition and stand structure vary by location,

primarily due to precipitation, elevation, temperature, and soil type. There are 20,800 acres of 

pinyon-juniper habitat, comprising approximately 11 percent of the project area.

Most of the pinyon-juniper vegetation communities are younger and denser than they were 

historically because of changes in wildfire occurrence and past livestock and wildlife grazing. 

Greater tree density has increased competition for water and nutrients. This, in turn, has caused a 

reduction in understory plant cover and diversity, a loss of ground cover, and subsequent 

increases in soil erosion. Pinyon-juniper woodland supports a wider array of birds and mammals 

than ponderosa pine forest. Several species of birds are directly associated with pinyon-juniper 

habitats, including pinyon jays (Gymnorhinus cyanocephalus) and juniper titmice (Baeolophus 

ridgwayi). Woodlands provide key winter habitat for a range of species, including ungulates and 

raptors. 

The pinyon-juniper communities produce hard mast that supports high densities of small 

mammals, making these areas important for foraging carnivorous species, including black bear
Chapter 3. Affected Environment and Environmental Consequences

3-80 Santa Fe National Forest Geothermal Leasing EIS

(Ursus americanus), birds, and snakes. Many wildlife species select large trees for foraging and 

large snags for nesting. Current conditions slow the growth rates of trees, prolonging the time 

required to develop old and large trees. Slowed growth rates can also leave large and old trees 

more vulnerable to short- and long-term weather and climate trends (Kane and Kolb 2014). The 

delay in replacing this component of woodland habitat also delays future large-diameter snag 

recruitment.

Riparian areas occupy a small percent of the landscape of the project area; however, their 

importance far outweighs their representation on the landscape. Riparian areas provide valuable 

habitat for fish, wildlife, migratory birds, and special status species. Riparian areas are found as 

narrow bands of shrubs or trees lining stream banks, seeps, and springs. Often riparian areas are 

composed of a mosaic of multiple communities and are found throughout the project area. Riparian 

habitat in the project area occurs along the Jemez River, Redondo Creek, San Antonio Creek, Rio 

Cebolla, Coyote Creek, and other perennial and intermittent streams, seeps, and springs. Common 

species include alder (Alnus spp.), willow (Salix spp.), aspen, maple (Acer spp.), dogwood (Cornus

spp.), cottonwood (Populus spp.), and ash (Fraxinus spp.; Dreesen et al. 2002).

Nonnative and invasive plants (also known as noxious weeds) are aggressive and displace native 

plant species. The National Invasive Species Council defines invasive species as “those (species) 

that are not native to the ecosystem under consideration and that cause or are likely to cause 

economic or environmental harm or harm to human, animal, or plant health.” Noxious and 

invasive weeds that have the potential to occur in the project area are bull thistle (Cirsium 

vulgare), Canada thistle (C. canadensis), field bindweed (Convolvulus arvensis), nodding thistle 

(Carduus nutans), poison hemlock (Conium maculatum), cheatgrass (Bromus tectorum), oxeye 

daisy (Leucanthemum vulgare), spotted knapweed (Centaurea stoebe), dalmation toadflax 

(Linaria dalmatica), Russian olive (Elaeagnus angustifolia), saltcedar (Tamarix spp.), Siberian 

elm (Ulmus pumila), hoary cress (Cardaria draba), scotch thistle (Onopordum acanthium), and 

Russian knapweed (Rhaponticum repens; Forest Service 2013).

3.11.1.3 Climate Change Vulnerability Assessment

The Climate Change Vulnerability Assessment Project is a vegetation-based approach to 

predicting vulnerability on the SFNF. This assessment categorizes climate change vulnerability 

based on vegetation communities and the projected difference between pre-1990 climate 

envelopes and the projected climate conditions. Vulnerability in this context is considered the 

relative probability of vegetation type conversion, such as pine-dominated communities being 

converted to dominance by oak and interior chaparral species. Climate vulnerability categories 

are as follows: 

 Low vulnerability 

 Moderate vulnerability

 High vulnerability 

 Very high vulnerability

The climate vulnerability results for watersheds are shown in Table 3-15, representing a 

composite scoring of vulnerability for all lands, regardless of ownership. 

As shown in Table 3-15, 93 percent of lands in the project area are covered by watersheds that 

are ranked as moderate vulnerability, while approximately 7 percent of lands are covered by 

watersheds ranked as high vulnerability (Triepke 2015; Forest Service 2016c). 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-81

Table 3-15. Climate Vulnerability Rankings by Watershed

4

th Level Watershed Name Percent of Project Area 

Covered by Watershed Rank

Jemez Watershed 4th Level Watershed

Cañon de la Cañada 5.4 Moderate vulnerability

Church Canyon-Jemez River 9.3 Moderate vulnerability

East Fork Jemez River 3 Moderate vulnerability

Headwaters Rio Cebolla 8.2 Moderate vulnerability

Headwaters San Antonio Creek 0.3 Moderate vulnerability

Outlet Rio Cebolla 1.6 Moderate vulnerability

Outlet San Antonio Creek 5.3 Moderate vulnerability

Sulphur Creek 0.9 Moderate vulnerability

Vallecita Creek 8.3 Moderate vulnerability

Virgin Canyon 1.3 Moderate vulnerability

Rio Chama 4th Level Watershed

Cañones Creek 15.2 Moderate vulnerability

Cañones Creek-Abiquiu 

Reservoir

3.9 Moderate vulnerability

Coyote Creek 14.7 Moderate vulnerability

Headwaters Rio Puerco 3.8 Moderate vulnerability

Outlet Rio Puerco 8.9 Moderate vulnerability

Poleo Creek 0.2 Moderate vulnerability

Polvadera Creek 2.4 Moderate vulnerability

Santa Fe-Rio Grande 4th Level Watershed

Alamo Canyon-Rio Grande 1.2 High vulnerability

Capulin Canyon-Rio Grande 0.3 High vulnerability

Headwaters Borrego Canyon 0.1 Moderate vulnerability

Peralta Canyon 1.3 High vulnerability

Rio Chiquito 4.5 High vulnerability

Sources: Triepke 2015; Forest Service 2016c

3.11.2 Environmental Consequences

3.11.2.1 Scoping Comments on Resource

The following issues specific to vegetation were identified during the public scoping period:

 How would vegetation loss from geothermal leasing affect soil erosion?

 How would noxious and invasive weeds be managed in geothermal leasing areas?
Chapter 3. Affected Environment and Environmental Consequences

3-82 Santa Fe National Forest Geothermal Leasing EIS

3.11.2.2 How Resource Impacts Were Evaluated

Method

Leasing geothermal resources would not affect vegetation or important habitats and 

communities. These resources would be affected only by development of specific geothermal 

projects that occurred after the leasing action. Potential impacts of geothermal development were 

evaluated based on the typical disturbance of geothermal projects for the various stages of 

development and then were assessed based on projected intensity, as described in the RFDS

(BLM 2015). The types of vegetation and important habitats and communities that could be 

affected by geothermal development depend on the specific location of the proposed projects, 

which are unknown at this time. In general, the vegetation communities described in Section 

3.11 could be affected by geothermal development, as described below.

Indicators

Potential impacts on vegetation could occur if anticipated future actions, consistent with 

implementing the alternatives described in Chapter 2, were to result in the following:

 Affect a plant species, habitat, or natural community recognized for ecological, scientific, 

recreational, or commercial importance

 Affect a species, habitat, or natural community that is specifically recognized as biologically 

significant in local, state, or federal policies, statutes, or regulations

 Establish or increase noxious weed populations

 Destroy or extensively alter habitats or vegetation communities in such a way that would 

render them unfavorable to native species

 Conflict with Forest Service management strategies

Assumptions

This analysis assumes the following:

 NSO stipulations would generally prevent direct disturbance to vegetation by restricting 

surface-disturbing activities where they are applied, except when exceptions, waivers, or 

modifications are met.

 CSU stipulations could be used to avoid impacts on sensitive vegetation in certain areas.

 The degree of impact attributed to any one disturbance or series of disturbances would be 

influenced by several factors, including location in the watershed; the type, time, and degree 

of disturbance; existing vegetation; the amount, type, and timing of precipitation; and 

mitigating actions applied to the disturbance.

 The Forest Service would comply with its own weed control plans.

3.11.2.3 Common Impacts Associated with Geothermal Development

Common impacts on vegetation associated with geothermal development are described in the 

2008 Geothermal PEIS (BLM and Forest Service 2008) and are incorporated into this document 

by reference.

Regardless of the location of geothermal development projects, the nature of impacts from 

exploration and development on vegetation would be similar in all vegetation communities. 

Vegetation would be affected by direct destruction and removal, erosion, and fugitive dust. In 

addition, potential direct and indirect impacts could occur from exposure to such contaminants as 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-83

oil and fuel leaks from heavy equipment, accidental fire caused by on-site workers or heavy 

equipment, and the introduction of invasive species. However, BMPs identified in Appendix C

would minimize these risks.

The extent of the impacts is typically associated with the size of the area that is disturbed and the 

types of vegetation habitats and communities present. In general, localized impacts from 

geothermal development on the scale anticipated by the RFDS on vegetation communities that 

are common in the project area, such as ponderosa pine and upper deciduous evergreen mix 

forests, would be unlikely to change the composition or health of most vegetation communities.

3.11.2.4 Impacts Under Alternative 1

Fire

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations.

There would be a risk of wildland fire from geothermal development under Alternative 1. 

Equipment operations, increased vehicular and human traffic, and geothermal fluids extraction 

can increase the risk of fires. Vehicles, electrical lines, and smoking can all result in accidental 

fires. As stated in the RFDS, transmission lines would be required from the power plant to the 

main lines, and these lines would likely be aboveground. The mechanisms for which 

transmission lines can result in wildfires are broken conductors; poletop fires caused by failing 

apparatus; clashing conductors that create falling burning particles; failing transformers and 

other apparatus; and vegetation contact with power lines (Wischkaemper et al. 2014). However, 

because power line ROWs would be cleared of trees, the risk of wildfire from falling trees 

bringing down power lines would be minor. This is in contrast to smaller service lines associated 

with residences, where the ROW owner may not clear trees far enough from power lines to 

prevent them from falling on the lines.

High severity wildfires destroy vegetation and seed banks for native plants. In addition, fire can 

result in indirect impacts, such as helping establish and spread invasive species by increasing 

plant resource availability, reducing competition, or altering sediment transport of an affected 

watershed (USGS 2002; Brooks and Lusk 2008). Low severity wildfires are important 

ecologically and help maintain variable tree densities.

Vegetation Communities

Vegetation communities may be impacted by habitat alteration, removal, reduction, or 

fragmentation. Up to 674 acres may be disturbed in vegetation communities in the project area. 

The Forest Service has determined that the JNRA (approximately 28,900 acres) is excluded from 

geothermal leasing on the basis of existing laws, regulations (43 CFR, Subpart 3201.11), and 

executive orders. There would be no direct disturbance to vegetation within the JNRA under 

Alternative 1.

3.11.2.5 Impacts Under Alternative 2

Fire

The risk of wildland fire in the project area from geothermal development would be the same as 

that described under Alternative 1. 
Chapter 3. Affected Environment and Environmental Consequences

3-84 Santa Fe National Forest Geothermal Leasing EIS

Vegetation Communities

Under Alternative 2 approximately 32,000 acres would be closed to geothermal leasing, while 

approximately 136,650 acres of the NFS lands in the project area would be allocated as open to 

geothermal leasing, subject to existing laws, regulations, formal orders, and stipulations.

Vegetation communities may be impacted by habitat alteration, removal, reduction, or 

fragmentation. Up to 674 acres of disturbance may occur in vegetation communities in the 

project area; however, the location of disturbance is unknown. Vegetation at drilling pads, 

facilities, roadways, and transmission corridors may be affected. The magnitude of the 

disturbance would be a function of the level of preexisting disturbance and the size, scale, and 

phase of geothermal development. Impacts on wetland and riparian areas would be minimized by 

the leasing stipulations described in Chapter 2.

Fragmentation can facilitate the spread and introduction of invasive plant species. Roads and other 

corridors can facilitate the dispersal of invasive species by altering existing habitat conditions, 

stressing or removing native species, and allowing easier movement by wild or human vectors 

(Trombulak and Frissell 2000). Sensitive plants can be affected by invasive vegetation through 

competition for resources and available habitat. BMPs for noxious weeds include measures such as 

weed monitoring, education of personnel on weed identification, use of certified weed-free mulch, 

a controlled inspection and cleaning area for vehicles arriving from locations with known weed 

infestations, and developing a plan for control of noxious weeds and invasive species.

3.11.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area under Alternative 3; there would 

be no direct or indirect impacts on vegetation from geothermal activities.

3.11.2.7 Impacts Under Alternative 4

Fire

The risk of wildland fire in the project area from geothermal development would be the same as 

that described under Alternative 1.

Vegetation Communities

Under Alternative 4 approximately 28,900 acres would be closed to geothermal leasing, while 

approximately 139,800 acres of the NFS lands in the project area would be allocated as open to 

geothermal leasing, subject to existing laws, regulations, formal orders, and stipulations. Direct 

and indirect impacts on vegetation would be similar to those under Alternative 2. However, the 

intensity of disturbance could be more severe and certain areas may be more likely to be 

disturbed (specifically intermittent streams and viewsheds with a Scenery Management System 

integrity level of very high). Therefore, impacts on vegetation communities in these areas (direct 

vegetation removal, or indirect spread and establishment of noxious weeds) would be more 

likely.

3.11.2.8 Cumulative Impacts

The cumulative impacts analysis region of influence for vegetation is the three level 4 

watersheds that intersect the project area: the Rio Grande-Santa Fe, Rio Chama, and Jemez 

watersheds. Past, present, and reasonably foreseeable future actions within these watersheds are 

the Pueblo of Jemez Red Rocks Dam Repair, the Abiquiu Land Grant Waterline Replacement, 

and the McKinney County Dam; mineral development in the South Pit Pumice Mine Expansion 

and the Duran 2010 Pumice Mine; and habitat improvement projects, such as the Southwest 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-85

Jemez Mountains Restoration Project, the Cerro Pelon Timber Stand and Wildlife Habitat 

Improvement Project, the Pueblo of Jemez Owl Springs Bridge Sediment Removal Project, the 

New Mexico Meadow Jumping Mouse Critical Habitat Protection Project, and the Supplement 

to the Final EIS for Invasive Plant Control Project. 

Implementation of Alternatives 1, 2, or 4 would increase the number of acres of disturbance in 

the region of influence (i.e., the three level 4 watersheds) over the long term, when combined 

with other surface-disturbing projects. However, under Alternatives 2 and 4, NSO and CSU

stipulations would mitigate impacts on vegetation by restricting where development could occur. 

Habitat improvement projects could help to restore vegetation conditions within the cumulative 

impacts analysis area to a more fire-adapted ecosystem. 

As a result of exploration, drilling, and utilization disturbance, there is the potential for 

nonnative and invasive species to colonize and dominate sites. The facilitation of seed dispersal 

could result from construction equipment transporting invasive species from the construction 

areas to adjacent lands along access roads and main roads. However, BMPs identified in 

Appendix C (such as weed monitoring, education of personnel on weed identification, use of 

certified weed-free mulch, a controlled inspection and cleaning area for vehicles arriving from 

locations with known weed infestations, and weed control plans) and other weed control efforts 

on the Coyote, Cuba, Espanola, and Jemez Ranger Districts would reduce this risk. This impact 

could occur under Alternatives 1, 2, and 4.

Geothermal development within the project area could increase the risk of wildland fire in the 

project area, which could spread to adjacent land such as the Valles Caldera. Wildfires that 

spread beyond the project area could further impact vegetation communities affected by recent 

fires, such as the Thompson Ridge fire (2013), Las Conchas fire (2011), Tres Lagunas fire 

(2013), and South Fork fire (2010). The Las Conchas and Thompson Ridge fires burned much of 

the upper deciduous evergreen mix forest type on the Valles Caldera. Disturbance in this 

vegetation type could further alter or remove upper deciduous evergreen mix forest communities. 

However, of the 60,600 acres of upper deciduous-evergreen mix forest type in the decision area, 

the majority would be closed to geothermal leasing or NSO under Alternatives 2 and 4. Under 

Alternative 2, 400 acres would be open subject to standard lease terms and conditions, while 

1,500 acres would be open subject to standard lease terms and conditions under Alternative 4 

(Forest Service GIS 2015). BMPs would minimize the potential for a human-caused fire.

The impacts of geothermal leasing and development on vegetation could be exacerbated by 

climate change. Geothermal leasing and development and climate change may act as dual 

stressors for vegetation change; that is, it could alter structure, composition, or function. These 

impacts would be greatest on watersheds identified as high vulnerability (7 percent of the project 

area, in the JNRA and South Unit). 

Under Alternatives 2 and 4, NSO stipulations encompass 97 percent of the South Unit, and the 

JNRA is closed to leasing; therefore, cumulative impacts from climate change would be minimal 

in these areas. Under Alternative 3, there would be no cumulative impacts from geothermal 

leasing and development in high vulnerability areas. In the remainder of the project area, 

geothermal leasing and development under Alternatives 1, 2, and 4 could reduce resistance12 and 

 

12 The ability of an ecosystem to endure disturbance and maintain its characteristic structure, composition, 

and function. 
Chapter 3. Affected Environment and Environmental Consequences

3-86 Santa Fe National Forest Geothermal Leasing EIS

resilience13 of vegetation ecosystems, when combined with future climate regimes. Alternative 3 

would have no cumulative impacts on vegetation.

3.12 Fish and Wildlife

3.12.1 Affected Environment

This section discusses management indicator species (MIS) and migratory birds. The detailed 

description and analysis of MIS in the SFNF Geothermal Leasing EIS Fish, Wildlife, and Plant 

Report (Forest Service 2016e) is incorporated by reference and summarized here. In this 

analysis, these species are used as a proxy for all fish and wildlife in the project area. MIS are 

identified as representing a group of species having similar habitat requirements. MIS in the 

SFNF are shown below in Table 3-16.

Table 3-16. Southwestern Region Regional Forester’s MIS on the SFNF

Common 

Name Species Species Status1

Species or 

Habitat in 

the Project 

Area

Habitat 

Association

Acres in the 

Project 

Area

Acres in 

SFNF

Rocky 

Mountain 

bighorn 

sheep

Ovis 

canadensis 

canadensis 

MIS No Alpine meadow 0 7,900

Rocky 

Mountain elk

Cervus elaphus MIS Yes Mid-elevation 

grasslands 

(generally less 

than 9,000 

feet), meadows 

and forest

157,800 1,424,900

Merriam’s 

turkey

Meleagris 

gallopavo 

merriami

MIS Yes Mature 

ponderosa pine 

forest

59,400 633,700

Mourning 

dove

Zenaida 

macroura

MIS Yes Mid- and lowelevation 

grasslands, 

woodlands, and 

ponderosa pine

48,900 647,300

Hairy 

woodpecker

Pica villosa MIS Yes Mature forest 

and woodland

10,200 84,100

Pinyon jay Gymnorhinus 

cyanocephalus

MIS Yes Pinyon-juniper 

woodlands

12,600 250,100

Mexican 

spotted owl

(MSO)

Strix 

occidentalis 

lucida

T/MIS Yes Late-seral stage

mixed-conifer

72,500 667,600

Rio Grande

cutthroat 

trout (RGCT)

Oncorhynchus 

clarki virginalis

SS/MIS Yes Riparian and 

stream habitat; 

good water 

quality

23 miles 135 miles

 

13 The ability of an ecosystem, following disturbance, to regain its characteristic structure, composition, 

and function on a time span consistent with its successional patterns. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-87

Common 

Name Species Species Status1

Species or 

Habitat in 

the Project 

Area

Habitat 

Association

Acres in the 

Project 

Area

Acres in 

SFNF

Migratory 

birds

— — Yes All 194,900 1,558,500

Source: Forest Service GIS 2015, Forest Service 1987

1

T = Threatened under the ESA of 1973 

SS = Forest Service Region 3 Forester’s sensitive species

MIS = Forest Service Region 3 Forester’s MIS

3.12.1.1 Rocky Mountain Bighorn Sheep

Bighorn sheep serve as a management indicator for alpine meadow habitat. On the SFNF, Rocky 

Mountain bighorn sheep inhabit the highest alpine areas of the Sangre de Cristo Mountains in the 

Pecos Wilderness, outside the project area. Bighorn sheep were reintroduced into the Cochiti 

Canyon, approximately 10 miles southeast of the project area, and may use the project area as 

transition habitat. Habitat conditions in the Pecos Wilderness are generally fair to good, but the 

limiting factor is severe winter conditions, where quality and quantity of forage can fluctuate

significantly. The habitat trend for bighorn sheep on the SFNF is stable.

Species Status and Population Trend

In 2011 the number of bighorn sheep in the SFNF was 110 to 125 adults. The Rocky Mountain 

Bighorn Sheep population ranks as uncommon for the SFNF. This means that the estimated 

number of breeding females ranges between 100 and 1,000 individuals. The population trend for 

Rocky Mountain bighorn sheep is declining on the SFNF. There is no suitable or occupied 

habitat for bighorn sheep within the project area. 

3.12.1.2 Rocky Mountain Elk

Rocky Mountain elk are primarily grazers and inhabit most forest types with good forage and 

cover. However, they were selected to represent mid-elevation grasslands (generally less than 

9,000 feet), meadows, and forested areas, which are present in the project area (Amy and Cook 

2012). Overall, elk habitat is rated as stable. 

Species Status and Population Trend

The total number of elk on the SFNF is estimated at between 7,500 and 11,000 (Amy and Cook

2012). The Rocky Mountain elk population ranks as common for the SFNF. This means that the 

estimated number of breeding females ranges between 1,000 and 10,000. The population may 

fluctuate from year to year based on hunting pressure and a variety of environmental factors. The 

population trend for the Rocky Mountain elk is ranked as increasing on the SFNF. The objective, 

however, is to maintain the herd at about its current level. In recent years, the NMDGF has 

increased the number of elk hunting licenses, including late-season cow permits, in an attempt to 

maintain current elk populations.

3.12.1.3 Merriam’s Turkey

Merriam’s turkeys use a wide range of vegetation communities, but they were selected to serve 

as a management indicator of healthy, mature ponderosa pine habitat, which is present in the 

project area (Amy and Cook 2012). The estimated habitat trend for turkey is relatively stable,

based on disturbed acres providing additional feeding habitat and undisturbed areas declining in 

quality due to forest-encroachment issues. 
Chapter 3. Affected Environment and Environmental Consequences

3-88 Santa Fe National Forest Geothermal Leasing EIS

Species Status and Population Trend

Merriam’s turkey has the widest distribution and is known to reside on all the ranger districts on 

the SFNF. They are ranked as common on the SFNF, which means that the estimated number of 

breeding female birds ranges between 1,000 and 10,000. The NMDGF estimates between 35,000 

and 40,000 wild turkeys throughout the state. The population trend for Merriam’s turkey on the 

SFNF is rated as stable. This estimate is based on the amount of habitat available, breeding bird 

surveys, and professional opinion of local biologists. Statewide, population numbers are 

expected to increase. The NMDGF has not conducted hunter success surveys over the past few 

years and currently does not conduct population surveys for Merriam’s turkey (Amy and Cook 

2012).

3.12.1.4 Mourning Dove

Mourning dove serves as a management indicator of healthy mid- and low-elevation grasslands, 

woodlands, and ponderosa pine habitats, which are present in the project area (Amy and Cook 

2012). The habitat trend for the mourning dove is stable to increasing across the SFNF. Emphasis 

in healthy forest restoration should result in an upward trend.

Species Status and Population Trend

Mourning doves are common throughout the state. They are ranked as common on the SFNF,

meaning that the estimated number of breeding pairs ranges between 1,000 and 10,000. The 

mourning dove is listed as secure in New Mexico (NatureServe 2011a). The population trend for 

the mourning dove on the SFNF is stable, based on the statewide trend and breeding bird surveys 

on and next to the SFNF.

3.12.1.5 Hairy Woodpecker

Hairy woodpeckers serve as a management indicator for mature forest and woodland habitats—

ponderosa pine, mixed-conifer, spruce/fir, aspen, and oak woodland—which are present in the 

project area (Amy and Cook 2012). The SFNF supports adequate numbers of snags and downed

logs for hairy woodpecker habitat. 

Species Status and Population Trend

This species is widespread across the SFNF and can be found in any of the suitable habitat types.

The hairy woodpecker population is ranked as abundant on the SFNF. This means that the 

estimated number of breeding pairs ranges between 10,000 and 100,000. Breeding bird survey 

routes on or near the SFNF reported to the USGS between 1987 and 2010 indicate a stable to 

increasing trend for hairy woodpecker on the SFNF. The hairy woodpecker is listed as secure in 

New Mexico (NatureServe 2011b). The population trend for the hairy woodpecker on the SFNF 

is stable, based on the statewide trend and breeding bird surveys in and next to the SFNF.

3.12.1.6 Rio Grande Cutthroat Trout

RGCT serve as a management indicator of healthy riparian and stream habitat and good water 

quality. Since development of the Forest Plan (Forest Service 1987), stream habitat conditions 

for RGCT have varied from slightly declining to slightly improving. However, large catastrophic 

wildfires (e.g., Thompson Ridge fire [2013], Tres Laguna fire [2013], Las Conchas fire [2011], 

and South Fork fire [2010]) have severely impacted important RGCT streams in the SFNF, 

causing the habitat quality to decline.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-89

Species Status and Population Trend

RGCT is also a Forest Service Region 3 sensitive species and was a candidate for federal 

protection under the ESA, from 2008 to 2014; then it was removed from candidacy when it was 

determined that listing was not warranted (79 Federal Register 59140-59150, October 1, 2014; 

NMDGF 2014). The SFNF manages approximately 1,072 miles of perennial streams. 

Approximately 965 miles were thought to be historically occupied before nonnative trout were 

stocked, and all are considered potential habitat in the State-Wide Conservation Agreement.

RGCT currently live on 135 miles of perennial streams in the SFNF (NMDGF 2014). The 

population trend for RGCT on the SFNF is stable to declining.

3.12.1.7 Pinyon Jay

Pinyon jays can be found in a wide variety of vegetation communities, but they were selected to 

serve as a management indicator of healthy pinyon-juniper habitat. Their greatest threat is the 

continued loss of cone-producing pinyon due to drought and insect infestation. Because of this 

wide-scale loss of pinyon, the habitat trend for pinyon jay is ranked as declining on the SFNF.

Species Status and Population Trend

Survey results for routes on or near the SFNF reported to the USGS, between 1987 and 2010, 

indicate a stable population trend for pinyon jay on the SFNF, although the USGS data indicate a 

downward trend throughout New Mexico and the West (Amy and Cook 2012). NatureServe 

(2011c) lists the pinyon jay as vulnerable in New Mexico.

3.12.1.8 Mexican Spotted Owl

MSO serves as a management indicator for late seral stage mixed-conifer habitat. MSO are 

discussed in detail in Section 3.13, Threatened and Endangered Species and Special Status 

Species.

3.12.1.9 Migratory Birds

The Migratory Bird Treaty Act of 1918 (MBTA) implements a series of international treaties that 

provide for migratory bird protection. Under the MBTA, it is unlawful, except as permitted by 

regulations, “to pursue, take, or kill any migratory bird, or any part, nest or egg of any such bird” 

(16 USC, Section 703); however, the MBTA does not regulate habitat. The list of species 

protected by the MBTA was revised in March 2010 and includes almost all 1,007 bird species 

that are native to the United States. The Forest Service Southwestern Region currently analyzes 

the following impacts on migratory birds:

 Impacts on highest priority species listed by New Mexico Avian Conservation Partners 

 Impacts on United States Fish and Wildlife Service (USFWS) priority species in the 

Southern Rockies/Colorado Plateau bird conservation region 

 Impacts on Important Bird Areas

 Impacts on important overwintering areas

Highest Priority Species Listed by New Mexico Avian Conservation Partners

New Mexico Avian Conservation Partners considers eight risk factors in identifying conservation 

priority species: global abundance, New Mexico breeding abundance, global breeding 

distribution, New Mexico breeding distribution, threats to breeding in New Mexico, importance 

of New Mexico to breeding, global winter distribution, and threats on wintering grounds. Species 

with the highest risk factors are classified as “highest priority” for conservation action. This 
Chapter 3. Affected Environment and Environmental Consequences

3-90 Santa Fe National Forest Geothermal Leasing EIS

evaluation addresses general impacts on migratory birds and impacts on highest priority species 

for the main habitat types found in the project area (New Mexico Partners in Flight 2013). 

New Mexico Partners in Flight Bird Conservation Plan (New Mexico Partners in Flight 2013) 

lists priority species of concern by vegetation type. All highest priority species were reviewed for 

vegetation types found in the project area for spruce/fir, mixed-conifer, ponderosa pine, pinyonjuniper, montane riparian, wet meadows/montane grasslands, middle-elevation riparian, and 

cliffs and caves (New Mexico Partners in Flight 2013). These include aspen, juniper, pinyon, 

pinyon-juniper, ponderosa pine mix, spruce/fir, and upper deciduous evergreen forest.

USFWS Priority Species in the Southern Rockies/Colorado Plateau Bird Conservation 

Region

The following criteria are used to select species for consideration and inclusion on bird 

conservation region lists: 

 Begin with a list from appropriate bird conservation initiative

 Follow criteria for appropriate bird groups

 Add nonbreeding species, if they occur at significant relative density scores or have 

moderate or high threat levels in nonbreeding season, if not already included due to breeding 

population

 Consider subspecies and populations, where appropriate, and where information on their 

status is available

 Remove sport-hunted species and federally listed threatened or endangered populations 

(retaining non-listed populations with notation)

 Add recently ESA de-listed, candidate, or proposed species not already included

 In very limited circumstances, add or remove species and document the rationale when 

USFWS expertise, supplemental information, or local data indicate a much greater or lesser 

degree of concern than that reflected by bird conservation initiative scoring

There are 27 species of birds on the list for the Southern Rockies/Colorado Plateau bird 

conservation region.

Important Bird Areas

There are no designated Important Bird Areas in the project area; however, the 89,000-acre 

Valles Caldera/Jemez Mountains Important Bird Area is next to the project area. 

Overwintering Areas

Many important overwintering areas are large wetlands. Important overwintering areas 

recognized on the SFNF are Rio Chama, Rio Grande corridor, and Pecos Canyon. The project 

area is not recognized as an important overwintering area, because significant concentrations of 

birds do not occur there, nor do a unique or a high diversity of birds winter there.

3.12.2 Environmental Consequences

3.12.2.1 Scoping Comments on Resource

The following issue specific to fish and wildlife was identified during the public scoping period:
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-91

 What are the short- and long-term impacts of geothermal leasing on cold-water fisheries, 

wildlife corridors, critical wildlife habitat areas, fish hatcheries, and other important or 

sensitive fish and wildlife habitat in the project area?

3.12.2.2 How Resource Impacts Were Evaluated

Method

Leasing geothermal resources does not affect fish and wildlife. These resources would be 

affected only by subsequent development of specific geothermal projects. Potential impacts of 

geothermal development were evaluated based on the typical disturbance of geothermal projects 

for the various stages of development and then assessed based on projected intensity, as 

described in the RFDS. The types of fish and wildlife that could be affected by geothermal 

development depend on the specific location of the proposed project, the time of year, the project 

design, and its environmental setting. The analysis uses Forest Service MIS as a proxy for 

general impacts on non-sensitive fish and wildlife. Impacts on federally listed Forest Service 

sensitive species are discussed in Section 3.13. Since most fish and wildlife species rely to some 

extent on the vegetation in the project area, impacts on vegetation, as described in Section 3.11, 

would also likely impact fish and wildlife habitat.

Indicators

Indicators of impacts on fish and wildlife are as follows:

 Disturbance and changes in habitat, food supplies, cover, breeding sites, and other habitat 

components necessary for population maintenance used by any species to a degree that 

would lead to substantial population change

 Disturbance and change of seasonally important habitat (e.g., critical for overwintering or 

successful breeding) to a degree that would lead to substantial population change

 Interference with a species’ movement pattern that affects its ability to breed or overwinter 

successfully to a degree that would lead to substantial population change

Assumptions

This analysis assumes the following:

 NSO stipulations would prevent direct disturbance to habitats and species by restricting 

surface-disturbing activities where they are applied.

 TL stipulations would help to prevent direct disturbance to species during sensitive periods, 

such as during winter, when forage is sparse, and during breeding and birthing.

 Disturbance of a key or critical component of a species habitat would be detrimental, with 

the degree dependent on the importance of the habitat component to the maintenance of the 

population.

 Habitat conditions and quality are directly linked to the health, vigor, and cover of vegetation 

communities, as well as to soil conditions and water quality and quantity.

 Habitat disturbance from damaged vegetation, noise, human presence, and increased dust 

would often displace wildlife beyond the actual disturbance footprint, although some 

wildlife may adapt over time, depending on the nature of the disturbance and the species 

being impacted.
Chapter 3. Affected Environment and Environmental Consequences

3-92 Santa Fe National Forest Geothermal Leasing EIS

3.12.2.3 Common Impacts Associated with Geothermal Development

The information presented in the Common Impacts on Fish and Wildlife Associated with 

Geothermal Development section of the 2008 Geothermal PEIS (BLM and Forest Service 2008) 

is incorporated by reference here. Additional information specific to this EIS includes 

consideration of the particular fish and wildlife species in the project area per alternative below.

3.12.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. Impacts under 

Alternative 1 would be similar to those described in the 2008 Geothermal PEIS (BLM and Forest 

Service 2008), although specific impacts would be evaluated on a case-by case basis. 

Geothermal leasing stipulations and closures specific to fish and wildlife would not be 

implemented under this alternative; however, any geothermal lease applications and nominations 

would be subject to standards and guidelines outlined in the Forest Plan and environmental 

analysis. The Forest Service has determined that the JNRA (approximately 28,900 acres) is 

excluded from geothermal leasing on the basis of existing laws, regulations (see 43 CFR, 

Subpart 3201.11), and executive orders. There would be no direct impacts on wildlife in the 

JNRA under Alternative 1.

3.12.2.5 Impacts Under Alternative 2

Fisheries and Aquatic Biota

Impacts on fisheries from geothermal projects are directly linked to impacts on streams and 

aquatic habitat, in most cases. Impacts would result primarily from activities occurring near or in 

water bodies. NSO stipulations described in Chapter 2 would apply to water bodies, rivers and 

streams (perennial and intermittent), wetlands, springs, playas, riparian areas, 100-year 

floodplains, and a 500-foot-wide protection zone surrounding these features. Adjacent ground 

and streams would not be disturbed directly. The NSO stipulations would reduce or eliminate 

impacts associated with direct habitat disturbance, such as removal of streamside vegetation.

Indirect impacts on aquatic habitat could occur from groundwater withdrawal from geothermal 

activities. However, the amount of water to be used during geothermal development is not 

identified in the RFDS and is not known at this time. Changes in flows of surface waters due to 

geothermal pumping would be unlikely, because the extracted geothermal groundwater would be 

returned to the source aquifer via injection wells. Therefore, the volume of groundwater in the 

source aquifer would not be substantially reduced over the life of the project. 

Indirect impacts on aquatic habitat from groundwater withdrawal during geothermal activities 

are unknown at this time. In future projects the operator will be responsible for obtaining water 

rights, and the source of this water is not known at this time. Water depletions would be 

evaluated at a later stage, with USFWS consultation, once more information is known.

Stream flow rates are affected by the upland vegetation and adjacent terrain; therefore, 

geothermal development could alter stream flows and affect aquatic species and habitat. NSO

stipulations would apply to slopes in excess of 40 percent and soils with severe erosion potential. 

These stipulations would reduce the impacts on aquatic habitat from runoff and sedimentation of 

streams due to geothermal activity. Surface disturbance and use of heavy machinery and 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-93

equipment could result in erosion and sedimentation into cold water aquatic habitats; however, 

these impacts are unlikely to result in a substantial population change.

Wildlife

Wildlife species may be affected by habitat alteration, removal, reduction, or fragmentation. Up 

to 674 acres of disturbance may occur in wildlife habitat in the project area; however, the 

location of surface disturbance is unknown at this time. Habitat at drilling pads, facilities, 

roadways, and transmission corridors would be directly affected. The magnitude of the 

disturbance would be a function of the level of preexisting disturbance and the size, scale, and 

phase of geothermal development. Geothermal development would have the greatest impact on 

wildlife if it were to affect specialty habitats, such as riparian areas, wetlands, alpine talus, caves, 

or wintering and breeding areas. NSO stipulations would apply to several specialty habitats, such 

as riparian areas, wetlands, and slopes in excess of 40 percent, reducing the likelihood of direct 

or indirect impacts on wildlife in these areas. 

Fragmentation would affect wildlife by altering how wildlife species use the habitat. 

Fragmentation can separate wildlife populations into smaller populations, making them more 

vulnerable to predation, drought, and disease and limiting genetic diversity within breeding 

groups. Movement between habitat tracts is more difficult after fragmentation. Roads have been 

shown to impede the movements of invertebrates, reptiles, and small and large mammals 

(Jackson 2000). Habitat fragmentation can create increased edges for access by predators and 

invasive species and can facilitate access by hunters, reducing the density and diversity of 

wildlife species found in the original habitat (Andren 1994). 

Animals displaced by fragmentation would occupy nearby habitats, which could lead to an 

increase in competition for resources and result in decreased health and, potentially, death for 

individuals that are less fit. The impacts resulting from displacement after habitat removal and 

fragmentation depend on many factors, including the sensitivity of a species to edge and area 

impacts, the duration and rate of habitat loss and fragmentation, and the proximity of a chosen 

habitat to the disturbed area (Hagan et al. 1996). 

Wildlife would generally avoid areas next to disturbance resulting from geothermal 

development; therefore, the amount of habitat actually affected by disturbance and fragmentation 

extends beyond the habitat disturbed. The effective habitat loss (amount of habitat actually used 

by wildlife) due to new roadways was reported to be 2.5 to 3.5 times as great as actual habitat 

loss (Reed et al. 1996). During the exploration phase of development, approximately 10 miles of 

local road, with a width of 12 feet, would need to be widened to about 20 feet to accommodate 

larger truck traffic. Roads used during exploration would be widened an additional 2 feet during 

the development phase. Wildlife habitat fragmentation and disturbance impacts described above 

could occur along these roadways; however, the exact location and magnitude of impacts are 

unknown at this time.

Fragmentation can facilitate the spread and introduction of invasive plant species. Roads and 

other corridors can facilitate the dispersal of invasive species by altering existing habitat 

conditions, stressing or removing native species, and allowing easier movement by wild or 

human vectors (Trombulak and Frissell 2000). 

Wildlife can be affected by invasive vegetation. Invasive plant species may be unpalatable for 

native animal species, making it difficult for them to forage. This can alter the population 

structure of entire habitats. Invasive plants often disperse native vegetation, reducing the quality 
Chapter 3. Affected Environment and Environmental Consequences

3-94 Santa Fe National Forest Geothermal Leasing EIS

of the habitat for most wildlife. Birds are most directly affected by invasive plants, as their food 

source is often seeds from native grasses and shrubs. 

Noise from geothermal activities can have impacts on wildlife. Principal sources of noise from 

geothermal activities include trucks and the operation of drilling rigs and heavy machinery. On 

the basis of the types of equipment that would likely be used, such as drill rigs and graders, noise 

levels above 65 dBA would be present at distances of less than 400 feet from binary power 

plants. Noise levels from production wells would exceed the 65 dBA limit only at a distance of 

less than 69 feet. Most impacts associated with noise could occur if critical life cycle activities 

were disrupted, such as mating and nesting. Disturbance during mating, nesting, or rearing can 

cause wildlife to abandon mating and nesting activities and can strand young, leaving them 

susceptible to predation and starvation. However, implementing TLs, as described in Chapter 2, 

would limit noise disturbance nesting and breeding periods (March 1 to August 15) and would 

reduce the likelihood of impacts on seasonally important wildlife habitat.

The location and timing of geothermal activities (especially exploration and development) may 

affect the migratory and other behavioral activities of some species. Construction activities could 

affect local wildlife by disturbing normal behavior, such as foraging, mating, and nesting. 

Wildlife may cease foraging, mating, or nesting or may vacate active nest sites in areas where 

geothermal activities are occurring; some species may permanently abandon the disturbed areas 

and adjacent habitats. In addition, exploration and development may affect the movements of

some birds and mammals; for example, they may avoid a migratory route because of ongoing 

construction. 

Increased human activity also increases the potential for fires. Fire may affect wildlife through 

direct mortality, reduced habitat, or reduced habitat quality including reduced forage and cover. 

BMPs (such as development of a fire management strategy) would minimize the potential for a 

human-caused fire.

Rocky Mountain Bighorn Sheep 

Because all Rocky Mountain bighorn sheep habitat is in the Pecos Wilderness and Cochiti 

Canyon, and the proposed action would not impact alpine meadow habitat, there would be no 

impacts on Rocky Mountain bighorn sheep. 

Rocky Mountain Elk

Direct and indirect impacts on Rocky Mountain elk would be the same as the impacts described 

above for wildlife. Up to 674 acres of the approximately 1,424,900 acres of Rocky Mountain elk

habitat in the SFNF could be directly impacted by Alternative 2. Constructing access roads could 

result in indirect impacts on Rocky Mountain elk, including temporal and spatial habitat 

avoidance. These impacts could occur on approximately 14,320 acres of habitat surrounding 

roads during times that roads are utilized (Wisdom et al. 2004; Rowland et al. 2000). However, 

the exact amount of habitat directly or indirectly affected is unknown, because the location of 

surface-disturbing geothermal development is not known at this time. At most, expected surface 

disturbance would remove less than 0.05 percent of the available Rocky Mountain elk habitat in 

the SFNF, and, because population trends are stable, changes in vegetation would have 

negligible impacts on Rocky Mountain elk habitat and would not lead to a substantial population 

change. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-95

Merriam’s Turkey

Direct and indirect impacts on Merriam’s turkey would be the same as the impacts described 

above for wildlife. Up to 674 acres of the approximately 633,700 acres of Merriam’s turkey 

habitat in the SFNF could be directly impacted by Alternative 2. Indirectly, some habitat could 

be reduced in quality due to noise or other disturbance. However, the exact extent of habitat 

directly or indirectly affected is unknown, as the location of surface-disturbing geothermal 

development activities is not known at this time. At most, expected surface disturbance would 

remove less than 0.1 percent of the available Merriam’s turkey habitat on the SFNF. Because 

population trends are stable, changes in vegetation would have negligible impacts on Merriam’s 

turkey habitat and would not lead to a substantial population change.

Mourning Dove

Direct and indirect impacts on mourning dove would be the same as the impacts described above 

for wildlife. Up to 674 acres of the approximately 647,300 acres of mourning dove habitat in the 

SFNF could be directly impacted by Alternative 2. Indirectly some habitat would be reduced in 

quality due to noise or other disturbance. However, the exact amount of habitat directly or 

indirectly affected is unknown, as the location of surface-disturbing geothermal development

activities is not known at this time. At most, expected surface disturbance would remove less 

than 0.1 percent of the available mourning dove habitat on the SFNF. Because population trends 

are stable, changes in vegetation would have negligible impacts on mourning dove habitat and 

would not lead to a substantial population change.

Hairy Woodpecker

Direct and indirect impacts on hairy woodpecker would be the same as the impacts described 

above for wildlife. Up to 674 acres of the up to 84,100 acres of hairy woodpecker habitat in the 

SFNF could be directly impacted by Alternative 2. Indirectly, some habitat could be reduced in 

quality due to noise or other disturbance. However, the exact amount of habitat directly or 

indirectly affected is unknown, as the location of surface-disturbing geothermal development

activities is not known at this time. At most, expected surface disturbance would remove less 

than 0.8 percent of the available hairy woodpecker habitat on the SFNF. Because population 

trends are stable, changes in vegetation would have negligible impacts on hairy woodpecker 

habitat and would not lead to a substantial population change.

Rio Grande Cutthroat Trout

In most cases, impacts on RGCT and its habitat from geothermal projects are directly linked to 

impacts on riparian and wetland habitats. Sediment inputs may affect habitat suitability 

(particularly spawning habitat, which consists of clean gravel, with little or no fine sediment).

NSO stipulations would apply to water bodies, rivers and streams (perennial and intermittent), 

wetlands, springs, playas, riparian areas, 100-year floodplains, and a 500-foot-wide protection 

zone surrounding these features. Implementing these measures would protect and maintain 

streamside vegetation and bank stability in RGCT habitat. In addition, in combination with NSO 

stipulations for steep slopes and soils with severe erosion potential, the stipulations would reduce 

the likelihood of sedimentation into occupied RGCT streams. However, indirect impacts

associated with sedimentation could still occur.

Indirect impacts on RGCT habitat from groundwater withdrawal during geothermal activities are 

unknown at this time. In future projects the operator will be responsible for obtaining water 

rights, and the source of this water is not known at this time. Water depletions would be 

evaluated at a later stage once more information is known.
Chapter 3. Affected Environment and Environmental Consequences

3-96 Santa Fe National Forest Geothermal Leasing EIS

There would be no direct impacts on RGCT. Alternative 2 could indirectly impact RGCT habitat 

but would not reduce available habitat. The impacts on RGCT habitat would not lead to a 

substantial population change.

Pinyon Jay

Direct and indirect impacts on pinyon jay would be the same as the impacts described above for 

wildlife. Up to 674 acres of the approximately 250,100 acres of pinyon jay habitat in the SFNF 

could be directly impacted by Alternative 2. Indirectly, some habitat could be reduced in quality 

due to noise or other disturbance. However, the exact extent of habitat directly or indirectly 

affected is unknown, because the location of surface-disturbing geothermal development

activities is not known at this time. At most, expected surface disturbance would remove less 

than 0.3 percent of the available pinyon jay habitat on the SFNF. Because population trends are 

stable, changes in vegetation would have negligible impacts on pinyon jay habitat and would not 

lead to a substantial population change.

Mexican Spotted Owl

The types of direct and indirect impacts on MSO would be the similar as the impacts described 

above for wildlife. However, surface occupancy and use would be prohibited on designated 

habitat. In these areas, no direct impacts on MSO are anticipated. Indirectly, some habitat could 

be reduced in quality due to noise or other disturbance; however, the extent and magnitude of 

these impacts is unknown, as the locations of surface-disturbing geothermal development

activities is not known at this time. 

Direct and indirect impacts could also occur on potential MSO habitat not designated as critical 

habitat (late-seral stage mixed conifer vegetation, which constitutes 72,500 acres in the project 

area). These types of impacts could include direct removal, fragmentation, habitat avoidance, 

and noise disturbance. Implementing TLs from March 1 to August 31 would protect and limit 

disturbance from drilling and construction in PACs during the critical nesting and breeding 

period. At most, expected surface disturbance would remove less than 0.9 percent of late-seral 

stage mixed conifer habitat on the SFNF. Because population trends are stable on the SFNF, the 

changes in vegetation would have a negligible impact on MSO habitat and would not lead to a 

substantial population change.

Migratory Birds

Direct and indirect impacts on migratory birds would be the same as the impacts described above 

for wildlife. Up to 674 acres of the approximately 1,558,500 acres of migratory bird habitat in 

the SFNF could be impacted by Alternative 2. Expected surface disturbance would remove less 

than 0.04 percent of the available migratory bird habitat on the SFNF; therefore, changes in 

vegetation would have negligible impacts on migratory bird habitat.

3.12.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area under Alternative 3. There 

would be no direct or indirect impacts on fish and wildlife species from geothermal activities 

under this alternative.

3.12.2.7 Impacts Under Alternative 4

Under Alternative 4, approximately 28,900 acres would be closed to geothermal leasing, while 

approximately 139,800 acres of the NFS lands in the project area would be allocated as open to 

geothermal leasing, subject to existing laws, regulations, formal orders, and stipulations. As with 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-97

Alternative 2, 674 acres could be disturbed in the project area. Direct and indirect impacts on 

fish and wildlife would be similar to those described under Alternative 2; however, the level of 

intensity of disturbance could be more severe, specifically for fish and riparian species. This is 

because stipulations for water bodies and rivers or streams are less restrictive. The potential 

disturbance on intermittent streams could lead to increased sedimentation flowing into perennial 

streams and could reduce the quality of habitat for species that are sediment intolerant, such as 

RGCT and other cold water fish species. 

3.12.2.8 Cumulative Impacts

The cumulative impacts analysis region of influence for fish and wildlife is the three level 4 

watersheds that intersect the project area: the Rio Grande-Santa Fe, Rio Chama, and Jemez 

watersheds. Impacts on fish and wildlife do not end at the project area boundary but would 

encompass migration corridors, large home ranges, and cross boundary landscapes that extend 

beyond SFNF land. 

Past, present, and reasonably foreseeable future actions are discussed in Section 3.3.4. They are 

the following projects, which would increase the amount of disturbance in the cumulative 

impacts analysis area:

 Building hiking trails for the Continental Divide National Scenic Trail

 Pueblo of Jemez Red Rocks Dam Repair

 Abiquiu Land Grant Waterline Replacement

 McKinney Dam

 Mineral development, including the South Pit Pumice Mine Expansion and the Duran 2010 

Pumice Mine

Other projects that would likely restore habitat conditions in the cumulative impacts analysis 

area are as follows:

 Southwest Jemez Mountains Restoration Project

 Cerro Pelon Timber Stand and Wildlife Habitat Improvement Project

 Pueblo of Jemez Owl Springs Bridge Sediment Removal Project

 New Mexico Meadow Jumping Mouse Critical Habitat Projection Project

 Supplement to the Final EIS for Invasive Plant Control Project

The response of individual species to past, present, and reasonably foreseeable future actions 

would vary, depending on the life history and habitat needs of the species. However, in general, 

projects that increase the amount of disturbance could reduce habitat or cover where those 

projects occur. In addition, ongoing recreation use could result in wildlife habitat avoidance in 

some areas. 

Alternatives 1, 2, and 4 would increase the number of acres of disturbance in the cumulative 

impacts analysis area, when combined with other past, present, and reasonably foreseeable future 

actions. However, NSO, CSU, and TL stipulations under Alternatives 2 and 4 would limit 

impacts in seasonally important habitats (such as perennial and intermittent rivers and streams, 

and elk calving areas). TLs for special status raptors may also minimize risk to reproductive and 

post-fledgling success for other migratory birds nesting in those areas. 
Chapter 3. Affected Environment and Environmental Consequences

3-98 Santa Fe National Forest Geothermal Leasing EIS

Geothermal development activities, in combination with other surface-disturbing activities, may 

increase the potential for nonnative and invasive species to colonize and dominate sites, thus 

reducing the quality of habitat for some species. However, BMPs identified in Appendix C—

and other weed control efforts on the Coyote, Cuba, Espanola, and Jemez Ranger Districts—

would reduce or mitigate this impact.

Cumulative impacts on fish and aquatic habitats could include sediment influx in some areas as a 

result of geothermal development in combination with natural wildfire or flooding. However, 

stipulations for rivers, streams, and erosive soils under Alternatives 2 and 4 would restrict 

geothermal development in these areas and limit the amount of sedimentation entering 

waterways from geothermal specific activities.

Climate change may have cumulative impacts on fish and wildlife in the project area by altering 

habitat or habitat components. RGCT and other fish and aquatic biota are likely to be affected by 

climate change through increased water temperature, decreased streamflow, changed

hydrograph, and increased occurrences of extreme events, such as fire, drought, and floods 

(USFWS 2013a). These impacts, in combination with increased sediment inputs under 

Alternatives 1, 2, and 4, may reduce suitable habitat, especially spawning habitat.

For terrestrial wildlife, cumulative impacts from climate change are most likely to affect those 

species associated with and dependent on low resistance and low resilience ecological 

communities. Examples of these communities are spruce-fir forest and mixed conifer with aspen, 

both of which are modeled as low resistance communities on the SFNF (Triepke 2015). 

Over time, other MIS may experience cumulative impacts from climate change due to the 

following (Mawdsley et al. 2009):

 Shifts in the distribution of biological communities along elevational or latitudinal gradients

 Direct loss of habitat due to increased fire frequency

 Increased vegetation disease outbreaks and direct warming of habitats

 Effects on demographic rates, such as survival and reproduction

 Reductions in population size

 Changes in coevolved interactions, such as predator-prey relationships

 Increased abundance of or range expansion by species that are direct competitors

3.13 Threatened and Endangered Species and Special 

Status Species

3.13.1 Affected Environment

This section addresses only federally listed or proposed species and Forest Service sensitive 

species. No special status species surveys were conducted for this project.

Species listed as endangered under the ESA are those that are “in danger of extinction 

throughout all or a significant portion of its range” (16 USC, Subsection 1532[6]). A species 

listed as threatened under the ESA is considered “likely to become an endangered species within 

the foreseeable future throughout all or a significant portion of its range” (16 USC, Subsection 

1532[20]). Proposed species for ESA listing are those that were found to warrant listing as either 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-99

threatened or endangered and were officially proposed as such in a Federal Register notice after 

the completion of a status review and consideration of other protective conservation measures.

Forest Service sensitive species are defined in Forest Service Manual 2670.5 as “those plant and 

animal species identified by a Regional Forester for which population viability is a concern, as 

evidenced by 1) significant current or predicted downward trends in population numbers or 

density, or 2) significant current or predicted downward trends in habitat capability that would 

reduce a species’ existing distribution.” Table 3-17, below, shows threatened, endangered, or 

Forest Service sensitive species on the SFNF and whether each is known to occur in the project 

area.

Table 3-17. Federally Listed and Region 3 Regional Forester’s Sensitive Species on the SFNF

Common Name Taxon Species 

Status1

Known to Occur 

in the Project 

Area

Occurrence in 

SFNF2

Amphibians

Northern leopard frog Lithobates pipiens SS Yes D

Jemez Mountain 

salamander

Plethodon 

neomexicanus

E Yes D

Birds

Northern goshawk Accipiter gentilis SS Yes D

Boreal owl Aegolius funereus SS No D

Burrowing owl Athene cunicularia 

hypugaea

SS No ND

American peregrine 

falcon

Falco peregrinus 

anatum

SS Yes D

White-tailed 

ptarmigan

Lagopus leucura SS No D

Mexican spotted owl Strix occidentalis lucida T/MIS Yes D

Gray vireo Vireo vicinior SS Yes D

Fish

Rio Grande sucker Catostomus plebeius SS Yes D

Rio Grande chub Gila pandora SS Yes D

Rio Grande cutthroat 

trout (RGCT)

Oncorhynchus clarki 

virginalis

SS/MIS Yes D

Mammals

Pale Townsend’s 

big-eared bat

Corynorhinus townsendii 

pallescens

SS Yes D

Gunnison’s prairie 

dog

Cynomys gunnisoni SS Yes D

Spotted bat Euderma maculatum SS Yes D

American marten Martes americana 

origenes

SS No D

Goat Peak pika Ochotona princeps 

nigrescens

SS Yes3 D

American pika O. princeps saxatilis SS Yes D
Chapter 3. Affected Environment and Environmental Consequences

3-100 Santa Fe National Forest Geothermal Leasing EIS

Table 3-17. Federally Listed and Region 3 Regional Forester’s Sensitive Species on the SFNF

Common Name Taxon Species 

Status1

Known to Occur 

in the Project 

Area

Occurrence in 

SFNF2

Cinereus (masked) 

shrew

Sorex cinereus cinereus SS Yes D

Water shrew S. palustris navigator SS Yes4 D

Preble’s shrew S. preblei SS Yes D

New Mexico 

meadow jumping 

mouse

Zapus hudsonium luteus E Yes D

Clams

Lilljeborg’s pea-clam Pisidium lilljeborg SS No D

Plants

Tufted sand verbena Abronia bigelovii SS No S

Greene milkweed Asclepias uncialis 

uncialis

SS No D

Chaco milkvetch Astragalus micromerius SS No S

Pecos mariposa lily Calochortus gunnisonii 

var. perpulcher

SS No D

Yellow lady’s-slipper Cypripedium 

parviflorum pubescens

SS No D

Robust larkspur Delphinium robustum SS No ND

Heil’s alpine 

whitlowgrass

Draba heilii SS No D

Pecos fleabane Erigeron subglaber SS No D

Wood lily Lilium philadelphicum SS No D

Chama blazingstar Mentzelia conspicua SS No D

Santa Fe (Springer’s) 

blazingstar

Mentzelia springeri SS Yes S

Arizona willow Salix arizonica SS No D

Source: Forest Service GIS 2015, Biota Information System of New Mexico 2016, Forest Service 2014a

1E = Endangered under the ESA

T = Threatened under the ESA

SS = Forest Service Region 3 Forester’s sensitive species

MIS = Forest Service Region 3 Forester’s MIS

2D = Documented, reliable, recorded observation in appropriate habitat within the SFNF boundary 

S = Suspected, likely to occur based on habitat availability to support individuals/breeding pairs/groups within the SFNF

boundary

ND = Not documented or suspected within the SFNF boundary

Species known to occur in the project area are discussed in more detail below. Federally listed 

species observed there are the Jemez Mountain salamander, New Mexico meadow jumping 

mouse, and MSO. Forest Service sensitive species analyzed below are the Rio Grande sucker, 

Rio Grande chub, northern leopard frog, northern goshawk, American peregrine falcon, gray 

vireo, pale Townsend’s big-eared bat, spotted bat, Gunnison’s prairie dog, Goat Peak pika, 

American pika, cinereus (masked) shrew, water shrew, Preble’s shrew, woodlily, Santa Fe 

(Springer’s) blazingstar, and Arizona willow.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-101

3.13.1.1 Forest Service Species Excluded from Analysis and Rationale

A list of potential occurrence in the project area and within 0.5 mile of it was used for the species 

exclusion from analysis. Sensitive species that may be affected by the proposed action were

identified by evaluating the habitat needs of the listed species against the habitat in the project

area. Known occupancy or use by sensitive species was also considered.

The following Forest Service Region 3 sensitive species were excluded from further analysis in 

this report because the project area is outside the species’ range, there is lack of essential habitat 

in the project area, or the species is not known to occur in the project area.

During the impacts analysis for this report, the proposed action was determined to have no 

impact on the following species: boreal owl, burrowing owl, bald eagle, white-tailed ptarmigan, 

American marten, Lilljeborg’s pea-clam, tufted sand verbena, Greene milkweed, Chaco 

milkvetch, Pecos mariposa lily, robust larkspur, Pecos fleabane, and Chama blazing star. The 

rationale for this no impact determination is included in the SFNF Geothermal Leasing EIS Fish, 

Wildlife, and Plant Report (Forest Service 2016e).

3.13.1.2 Federally Listed Species

Jemez Mountain Salamander

This salamander can be found in moss-covered talus and under bark and beneath logs and rocks 

in and near mixed forests of spruce/fir and aspen (Biota Information System of New Mexico

2015). This species occurs underground except during periods of warm seasonal rains. In New 

Mexico, it is found from 6,990 to 11,270 feet in elevation. It lays its eggs underground. 

The Jemez Mountain salamander is restricted to the Jemez Mountains in Sandoval, Los Alamos, 

and Rio Arriba Counties. More than 90 percent of the recorded observations are on lands 

administered by the SFNF, with additional populations on Santa Clara Pueblo, in Bandelier 

National Monument, and in the VCNP. Habitat on the SFNF consists of spruce/fir and aspen 

between 6,990 and 11,270 feet in elevation. Critical habitat for the Jemez Mountain salamander 

covering 34,400 acres has been designated in the project area; the Forest Service has recorded

573 observations there (Forest Service GIS 2015). 

New Mexico Meadow Jumping Mouse

New Mexico meadow jumping mouse can be found on the ground surface in grassy or weedy 

meadows in the riparian, mixed-conifer, and spruce/fir vegetation communities. This species 

appears to use two specific riparian community types: persistent emergent herbaceous wetlands

(i.e., beaked sedge and reed canarygrass alliances) and scrub-shrub wetlands (i.e., riparian areas 

along perennial streams that are composed of willows and alders). This jumping mouse 

especially uses microhabitats of patches or stringers of tall dense sedges on moist soil, along the 

edge of permanent water (USFWS 2016). This species has been recorded on the SFNF, including 

three observations in the project area (Forest Service GIS 2015). 

Due to the low number of observations, it is uncertain how much potential habitat it occupies;

however, a study conducted in 2005/2006 found that neither the species nor its habitat was found 

at 73 percent of historical localities surveyed in the Jemez Mountains. The study found that the 

decline was attributed to loss of habitat, primarily as a result of livestock grazing (Frey and 

Malaney 2009). Approximately 800 acres of critical habitat for the New Mexico meadow 

jumping mouse has been designated in the project area, in the San Antonio Creek and Rio 

Cebolla areas.
Chapter 3. Affected Environment and Environmental Consequences

3-102 Santa Fe National Forest Geothermal Leasing EIS

Mexican Spotted Owl

The MSO is federally listed as threatened. It is found from parts of central Colorado and Utah, 

south through Arizona, New Mexico, and west Texas, then south again through northwestern 

Mexico to the Mexican state of Michoacán. It has the largest geographic range of the three 

spotted owl subspecies. Its range extends from the southern Rocky Mountains in Colorado and 

the Colorado Plateau in southern Utah, southward through Arizona and New Mexico and, 

discontinuously, through the Sierra Madre Occidental and Oriental to the mountains at the south 

end of the Mexican Plateau (USFWS 1993). Twenty-one years has passed since the first recovery 

plan, and total population size is not reliably known (USFWS 2012).

MSO is resident in the mountains of New Mexico, being most regular in the south. It can be

found in the San Juan, Jemez, Sangre de Cristo, Mount Taylor, Sandia, Manzano, San Francisco, 

Tularosa, Mogollon, San Mateo, Pinos Altos, Black, White, Sacramento, Guadalupe, and Animas 

Mountains (Hubbard 1978). The MSO is threatened by destruction and modification of habitat 

caused by timber harvest and fires. Fuel accumulation and forests overstocked with trees place 

MSO habitat at risk to stand-replacing fires. Lack of small-scale, low-intensity ground fires has 

increased this risk.

MSO has limited distribution across the SFNF. There are historical records from all Ranger 

Districts, mostly in the Jemez and Pecos/Las Vegas Ranger Districts, where it is found in very 

specific habitat types.

MSO is most common in mature and old-growth forests throughout much of its range. The most

highly sought habitat characteristics are high canopy closure, high stand density, a multi-layered

canopy, uneven-aged stands, numerous snags, and downed woody matter. Dominant and codominant trees in the main canopy are often 18-inch-diameter breast height or larger, with 18-

inch-diameter breast height or greater in the mature and old forest types, best expressed in oldgrowth mixed-conifer forests (usually more than 200 years old). These characteristics may also 

develop in younger stands that are unmanaged or minimally managed, especially when the 

stands contain remnant large trees or patches of large trees from earlier stands (USFWS 1993). 

MSO may be found in other vegetation communities, but on the SFNF, they are closely linked to 

the mixed-conifer and riparian vegetation types, which occur throughout the project area.

In addition to the forested areas, MSO in the Jemez Mountains also occupy canyon habitats, 

where they are cliff nesters. These canyon habitats range from those with a high degree of forest 

structure on at least one of the slopes above the canyon wall, to little or no tree cover present; 

however, typically mixed-conifer habitat is close by.

Since 1988, the SFNF has been surveying for MSO. As new areas were surveyed, the number of 

PACs also increased as owls were located. PACs are areas measuring 600 acres and are 

designated to conserve the core use areas of MSO. PACs are designed to protect the nest site, 

several roost sites, and the closest and highly used foraging sites (Ganey et al. 2014). The 

number of PACs identified in the SFNF has increased from 19 in 1989 to 50 in 2009; 14 PACs 

have been identified in the project area. Monitoring of existing PACs to determine occupancy 

has been sporadic; 17 MSO observations have been recorded in the project area (Forest Service

GIS 2015).
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-103

3.13.1.3 Fisheries

Rio Grande Sucker

Rio Grande suckers typically occur in middle elevation streams (6,600 to 8,600 feet) of small to 

large size (Sublette et al. 1990). On the SFNF, Rio Grande sucker are found in low gradient (less 

than 3.2 percent) stream reaches at elevations from 5,600 to 9,600 feet. Juveniles and adults both

prefer glides and pools with mean water column velocities of less than 8 inches per second; 

however, the velocities could be as high as 44 inches per second (Rees and Miller 2005). They 

favor low- to moderate-gradient riffles and pools below riffles in low-velocity stream reaches. 

They are usually found over gravel or cobble but can also be in backwater habitats (Calamusso et 

al. 2002). Rio Grande suckers prefer clear-water streams where periphyton14 food is common, 

and they are rarely found in waters with heavy loads of silt and organic detritus (Sublette et al. 

1990). In the project area, Rio Grande suckers are found in the Rio Cebolla, Rio Guadalupe, San 

Antonio Creek, East Fork of the Jemez River, and in the main stem Jemez River. The East Fork 

of the Jemez River, its main stem, and half of San Antonio Creek are in the JNRA.

Rio Grande Chub

Rio Grande chub spawn in riffle habitat in the spring and early summer, with peak spawning

occurring as water levels are declining from peak flow in the spring. Rio Grande chubs feed on 

mid-water insects, zooplankton, and small fish. They are generally found in streams less than 2 

percent gradient in low-velocity habitats, such as pools, runs, and glides, and are often associated 

with in-stream woody debris or aquatic vegetation (Rees et al. 2005). In the project area, Rio 

Grande chubs are found in the Rio Cebolla, Rio Guadalupe, and in the East Fork and main stem 

of the Jemez River, both of which are in the JNRA.

Rio Grande Cutthroat Trout

RGCT is a Forest Service Region 3 sensitive species. It was a candidate for federal protection 

under the ESA from 2008 to 2014, when it was removed from candidacy because listing was 

determined to be not warranted (79 Federal Register 59140-59150, October 1, 2014; NMDGF 

2014). 

RGCT is 1 of 14 subspecies of cutthroat trout native to the western United States (Behnke 2002).

It is found primarily in clear, cold mountain lakes and streams in Colorado and New Mexico,

within the Rio Grande Basin (Sublette et al. 1990). In New Mexico, RGCT exist in mountain 

streams, primarily in the Sangre de Cristo and Jemez Mountains in the Carson National Forest 

and SFNF. Isolated populations persist in southern New Mexico on the Gila National Forest in 

the Black Range (Sublette et al. 1990) and on the Mescalero Apache Indian Reservation in the 

Tularosa Basin. Conservation populations (those with 10 percent or less hybridization with

nonnative trout genes) of RGCT occupy approximately 10 percent of their historical habitat 

(Alves et al. 2008). In 2013, there were 127 conservation populations range-wide, with four

conservation populations in the project area, including Canones Creek, Medio Dia Creek, Rio 

Cebolla, and Rio Puerco (USFWS 2013a).

Streams capable of supporting RGCT are at elevations of 6,000 feet and higher. Historically 

(circa 1800), 43 percent of RGCT populations occupied streams 8,000 feet or less in elevation 

 

14 A complex mixture of algae, blue-green bacteria, microbes that live off nutrients they scavenge from 

living hosts or find in dead organic matter, and waste or debris that is attached to submerged surfaces in 

most aquatic ecosystems. 
Chapter 3. Affected Environment and Environmental Consequences

3-104 Santa Fe National Forest Geothermal Leasing EIS

(Alves et al. 2008). Currently, only approximately 1.6 percent of the populations are in streams 

with elevation less than 8,000 feet (Alves et al. 2008). Conservation populations are concentrated 

in streams with elevations from 9,000 to 10,000 feet. Because RGCT are now restricted to firstand second-order headwater streams that are narrow and small, compared to the larger third- and 

fourth-order streams they once occupied, the absolute loss of habitat is much greater than stream 

miles might indicate.

Quality of habitat conditions is generally less than moderate across the SFNF. In high-elevation 

locations where access is limited by topography and wilderness regulations, stream habitat 

quality is moderate to excellent. Where poor habitat and water quality conditions occur, the size 

of RGCT populations is affected. Decreased water quality can be attributed to, but is not limited 

to, soil compaction, road runoff, bank instability, and pollutant delivery from nonpoint sources. 

Poor habitat conditions can be attributed to, but are not limited to, a lack of in-stream large 

woody debris, sediment-filled pools, loss of undercut banks, depletion of beaver populations, 

lack of side channel development, and poor riparian health.

At the conclusion of 2010, the SFNF had surveyed over 299 miles of stream using the Forest 

Service Region 3 Stream Habitat Inventory protocol. An analysis of the habitat data collected 

between 2001 and 2005 shows that streams in the wilderness average 33 pieces of large wood 

per mile. In similar stream types outside of the wilderness, streams had only 11 pieces per mile, 

in many cases going several miles without one piece of wood. Other habitat indicators often 

below standard are as follows:

 Excessive sediment and fines in riffle habitat (greater than 20 percent)

 Stream widening that has led to high water temperatures

 Unstable stream banks

 Too few and small pools with low pool volume

 Lack of side channel development

Since development of the Forest Plan (Forest Service 1987), stream habitat conditions for RGCT

have varied from slightly declining to slightly improving. However, three large catastrophic 

wildfires have severely impacted six important RGCT streams in the SFNF between 2010 and 

2011, causing the habitat quality to decline. 

The SFNF manages approximately 1,072 miles of perennial stream. Approximately 965 miles 

were thought to be historically occupied before being stocked with nonnative trout, and all are 

considered potential habitat in the State-Wide Conservation Agreement. RGCT currently live on 

135 miles of perennial stream in the SFNF (NMDGF 2014). In the project area, RGCT are 

present in 23 miles of stream reaches, including Rio Cebolla, Rio Puerco, Medio Dia Creek, and

Canones Creek (Forest Service GIS 2015). All of these creeks are outside of the JNRA.

3.13.1.4 Wildlife

Northern Leopard Frog

This leopard frog ranges in a wide variety of habitats (springs, marshes, wet meadows, riparian

areas, vegetated irrigation canals, ponds, and reservoirs) but requires a high degree of vegetation

cover for concealment (NatureServe 2009a; Biota Information System of New Mexico 2006). In 

New Mexico, it is known from approximately 3,600 to 10,000 feet and breeds in ponds or lake 

edges with fairly dense aquatic emergent vegetation, from April to July and September to 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-105

October (Degenhardt et al. 1996). The leopard frog attaches its eggs to submerged vegetation 

well below the surface, in water 1.5 feet deep or more (NatureServe 2009a). 

Over-wintering habitats are larger lakes and streams that do not freeze completely during winter 

(NatureServe 2009a). Suitable habitat is present in the project area.

The northern leopard frog has been documented on the SFNF Cuba, Jemez, Española, and 

Pecos/Las Vegas Ranger Districts. The species is also suspected to be on the SFNF Coyote 

District. There are approximately 7,400 acres of potential habitat for northern leopard frog in the 

project area. This habitat was modeled using the SFNF riparian geospatial information below 

10,000 feet in elevation. A total of 28 observations have been recorded in the project area. Due to 

the low number of observations, it is uncertain how much potential habitat is currently occupied. 

In 2013, the species was reintroduced as tadpoles on the VCNP (outside of the project area) in 

two isolated pond locations. 

Northern Goshawk

Preferred habitat for the northern goshawk consists of coniferous forests, with a variety of

structural stages for nesting and foraging. Forest types occupied by the goshawk in the 

Southwest are ponderosa pine (74 percent), mixed species (23 percent), and spruce-fir (3 

percent; Reynolds et al. 1992). At the nest tree/stand level, nests typically occur in mature to oldgrowth forests, composed primarily of large trees with high canopy closure, near the bottom of 

moderate hill slopes, with sparse ground cover (Squires and Reynolds 1997; Squires and 

Kennedy 2006). Goshawks nested 2.5 times more often than expected in stands with 70 to 79 

percent canopy coverage and 5.8 times more often than expected in stands with 80 percent or 

greater canopy coverage (Squires and Reynolds 1997). The nest site is generally situated within 

0.25 mile of a stream or other water source (Squires and Reynolds 1997). 

Northern goshawks prey on small- to medium-size birds and mammals, from robins and 

chipmunks to grouse and rabbit (Reynolds et al. 1992). The best foraging habitat occurs in a 

mosaic of structural stages scattered across the landscape (Reynolds et al. 1992). In New 

Mexico, average home range size during the breeding season is 1,400 acres for females and 

5,200 acres for males (Squires and Reynolds 1997).

Suitable nesting and foraging habitat for northern goshawk is found in the ponderosa pine and 

spruce/fir vegetation communities in the project area. Post-fledgling family areas are 

surrounding a nest area that is defended by a goshawk pair. The project area contains 14 known 

post-fledgling family areas, covering a total of 7,900 acres (Table 3-18). Nineteen observations 

have been recorded in the project area.

Table 3-18. Northern Goshawk Post-Fledgling Family Areas in the Project Area

Post-Fledgling Family Area Name Year of Occupancy Acres

Barley 1992 500

Calaveras 1993 400

Cerro Pavo 1992 700

Cerro Pelado 1992 600

Cerro Pelon 1989 4,100

El Cajete 1991 600
Chapter 3. Affected Environment and Environmental Consequences

3-106 Santa Fe National Forest Geothermal Leasing EIS

Table 3-18. Northern Goshawk Post-Fledgling Family Areas in the Project Area

Post-Fledgling Family Area Name Year of Occupancy Acres

Horseshoe 1984 600

Las Conchas 1992 600

Monument 1991 600

Pony Canyon 1991 600

Redondo 1989 500

Rio Cebolla 1995 600

San Juan Canyon 1991 600

San Juan Mesa 1991 600

Source: Forest Service GIS 2015

Boreal Owl

The boreal owl occurs mainly above 9,500 feet in spruce/fir forests. Surveys through 1996 

showed this species to be resident in very small numbers in spruce/fir habitat in the Jemez 

Mountains. As of 1996 no boreal owls have been observed south of the Valles Caldera, but 

individuals have been observed in the Valles Caldera, next to the project area (Forest Service

2014a).

Approximately 9,600 acres of spruce/fir forest are present in the project area, some of which are 

above 9,500 feet in elevation. These forests may provide suitable habitat for the boreal owl in the 

project area, and this species may be present but not recorded by the Forest Service.

American Peregrine Falcon

There are approximately 237,600 acres of designated peregrine falcon suitable breeding habitat 

zones on the SFNF, 3,100 acres of which are in the project area. There are four designated 

suitable breeding habitat zones completely within the boundaries of the project area: R26, R29, 

R39, and R44. A peregrine falcon territory is an area surrounding a nest that is defended by a 

falcon pair. Statewide surveys conducted from 2008 to 2010 found that 84 percent of the 174 

peregrine falcon territories were occupied. Populations increased dramatically from 1980 to 

2007, then remained stable or declined slightly by 2010 (Biota Information System of New 

Mexico 2016). 

Suitable habitat for American peregrine falcon includes various open habitats, from grassland to

forested areas, in association with suitable nesting cliffs (NatureServe 2009b). In New Mexico, 

the breeding territories of peregrine falcon center on cliffs that are in wooded/forest habitats, 

next to large expanses of foraging areas (Biota Information System of New Mexico 2008). The 

falcon often nests on ledges or potholes on the face of rocky cliffs or crags (Biota Information 

System of New Mexico 2008). Ideal locations include undisturbed areas with a wide view, near 

water, and close to plentiful prey. Foraging habitats of woodlands, open grasslands, and water 

bodies are generally associated with the nesting territory (NatureServe 2009b). Suitable nesting 

and foraging habitat is in the project area. 

Prey consists almost entirely of birds, ranging in size from swallows to large shorebirds. In New 

Mexico, jay, woodpecker, swift, mourning dove (Zenaida macroura), and pigeon (Columbo 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-107

livia) are commonly taken as prey species (Biota Information System of New Mexico 2008). 

Falcons are known to forage over large areas, often 10 to 15 miles from the nest.

Gray Vireo

The gray vireo is a scrub-foraging inhabitant of some of the hottest, most arid regions of the

southwestern United States and adjacent parts of northwestern Mexico. The vireo is a shortdistant migrant, withdrawing from breeding habitat by August (early fall) and returning in late 

April to early May (NMDGF 2006). Breeding habitat in northern and northwestern parts of New 

Mexico is found at elevations from 5,500 to 7,200 feet, in broad-bottomed canyons (flat or 

gently sloped valleys), below or near ridgetop/rock outcrop/cliff head wall of canyon, or gently 

sloped bowls in pinyon-juniper woodlands (NatureServe 2006; NMDGF 2006). The vireo is 

most often associated with juniper, pinyon pine, or oak trees, with a wide variety of shrubs and 

grasses (NMDGF 2006, 2007). Habitat usually contains a mixture of open savannas and slightly 

more closed-canopy woodland areas (NatureServe 2006; NMDGF 2006). Trees in habitat areas 

are generally mature, ranging from 12 to 25 feet in height (NatureServe 2006).

Gray vireos are insectivorous, taking grasshopper, stinkbug (Eleodes spp.), treehopper, cricket, 

moth, damselfly, cicada, and caterpillar. The vireo is a thicket forager, taking most prey from 

leaves, twigs, branches, and trunks of small trees or twigs and branches of shrubby vegetation. 

Territory size varies in part with population density, ranging from 5 to 17 acres (NMDGF 2007).

The gray vireo is found throughout New Mexico west of the Great Plains, but with an extremely

patchy distribution often composed of small sites (NMDGF 2006, 2007a). Breeding Bird Survey 

data showed a significantly increasing trend for gray vireos range-wide during the 1980s and 

1990s; however, this may, in part, reflect increased ability by survey personnel to detect this 

easily overlooked species (New Mexico Partners in Flight 2007). Current range-wide Breeding

Bird Survey data still show an increasing trend, but there is insufficient sample size and data 

quality for a reliable estimate to be made. Breeding Bird Survey coverage of this species in New 

Mexico is minimal. The highly negative trend shown for New Mexico reflects a drop in 

detections on a small number of routes in the northwest part of the state. On the SFNF, the gray 

vireo is documented on the Jemez and Española Ranger Districts and is suspected on the Coyote, 

Cuba, and Pecos/Las Vegas Ranger Districts. Individuals and a pair of birds were detected during 

surveys on the SFNF in 2010.

There are approximately 192,600 acres of potential habitat for the gray vireo on the SFNF, 9,200

acres of which are in the project area. This habitat was modeled using pinyon-juniper vegetation 

communities between 5,500 and 7,200 feet in elevation. Due to a low number of observations, it 

is uncertain how much potential habitat it currently occupies.

Pale Townsend’s Big-Eared Bat

Although pale Townsend’s big-eared bat occurs in a wide variety of habitats, its distribution

tends to be geomorphically15 determined and is strongly correlated with the availability of caves 

or cave-like roosting habitat, such as old mines. Population concentrations occur in areas with

substantial surface exposures of cavity-forming rock, such as limestone, sandstone, gypsum, or

volcanic (Pierson et al. 1999). Individuals or small groups of three to five bats may roost during 

the day in hollow and creviced trees and snags for a limited time. 

 

15 Related to or resembling the earth’s surface
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3-108 Santa Fe National Forest Geothermal Leasing EIS

Populations appear to be quite sedentary, with marked animals (all females) not known to move 

more than a few miles from their birth roost. Studies suggest that movement in the nursery 

season, whether for foraging or shifting to an alternate roost, are confined to within 9.3 miles of 

the primary roost (Pierson and Rainey 1998). The most significant roosts are those with large 

congregations of bats, summer maternity roosts, and winter hibernacula (Pierson et al. 1999). 

These sites are highly sensitive to disturbance and human interference. 

Foraging occurs after dark in a variety of habitats, including open and forested areas. The bat 

forages in tree canopies and gleans insects from vegetation. It can forage up to 8 miles from day 

roosts but tends to forage within a few miles of colonial roosts (Pierson et al. 1999). Suitable 

roosting and foraging habitat is in the project area.

Threats are habitat loss, cave vandalism disturbance by cave explorers at maternity and

hibernation roosts (Pierson et al. 1999; Biota Information System of New Mexico 2006), and the 

spread of white-nose syndrome, which affects hibernating bats. Named for the white fungus that 

appears on the muzzle and other body parts of hibernating bats, white-nose syndrome is 

associated with extensive mortality of bats in eastern North America. First documented in New 

York in the winter of 2006/2007, white-nose syndrome has spread rapidly across the eastern 

United States and Canada, and the fungus associated with white-nose syndrome has been 

detected as far west as Oklahoma. White-nose syndrome has not been documented in New 

Mexico.

There are approximately 302,600 acres of potential habitat for the pale Townsend’s big-eared bat 

on the SFNF, 6,200 acres of which are in the project area. This habitat was modeled using 

information on geologic formations that are known for producing cave and rock crevice habitat. 

While mines provide artificial habitat for the pale Townsend’s big-eared bat, there is insufficient 

information on bat use of abandoned mines on the SFNF; therefore, mines were not used for this 

analysis. An individual was captured during studies in 1998 in the vicinity of the project area, 

indicating a low density in the Jemez Mountains (Bogan et al. 1998). It is uncertain how much 

potential habitat it currently occupies.

Spotted Bat

Spotted bats have been recorded in a variety of habitats, including riparian, pinyon-juniper, 

ponderosa pine, mixed-conifer, and spruce-fir forest. Most records are from forested areas. This 

bat occurs between 3,900 and 10,600 feet in New Mexico. It is suggested that it is a resident of 

the ponderosa pine area in June and July and moves to lower elevations in late summer and 

autumn. Those captured in the Jemez Mountains were netted over streams or water holes in 

ponderosa or mixed-coniferous forest (Bogan et al. 1998). They are cliff dwellers that roost in 

cracks and crevices in rock. The bat’s diet consists predominantly of moths but also includes 

katydids, grasshoppers, and flies (Biota Information System of New Mexico 2006; NMDGF 

2006). 

This species is fairly rare throughout its range, indicating that its scarcity in New Mexico may be 

due to biology rather than other impacts (NMDGF 2006). There are approximately 76,900 acres 

of potential habitat for the spotted bat on the SFNF, 7,500 acres of which are in the project area. 

Due to the species rarity and low number of observations, it is uncertain how much potential 

habitat it currently occupies. Suitable roosting and foraging habitat is in the project area.
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Santa Fe National Forest Geothermal Leasing EIS 3-109

Gunnison’s Prairie Dog

Gunnison’s prairie dog is found in grassland and shrub-steppe habitat, at elevations ranging from 

semi-desert to montane (NMDGF 2008). In New Mexico, Gunnison's prairie dog may occur 

from approximately 4,500 to 10,000 feet in elevation. The species is found in montane grassland, 

juniper savanna, plains-mesa grassland, Great Basin desert scrub, plains-mesa sand scrub, and 

desert grassland vegetation in New Mexico, as well as in urban and cultivated areas (NMDGF 

2008). A large complex of Gunnison’s prairie dog in the VCNP, next to the project area,

constitutes a focal area for the species. Approximately 8,000 acres of potentially suitable habitat 

is in the project area, and six incidental observations were recorded there. Due to a low number 

of observations, it is uncertain how much potential habitat it currently occupies.

American Marten

American marten prefers late successional stands of mesic, conifer-dominated forest. It occurs 

between 7,000 to 13,000 feet, mostly above 9,000 feet. Optimum habitat appears to be mature 

old-growth spruce/fir, with more than 30 percent canopy cover, abundant fallen logs and stumps, 

and lush shrub and forb vegetation to support prey species. These are mice, voles, insects, red 

squirrels, and snowshoe hare. It also feeds on carrion, birds, and bird eggs. It is sensitive to 

changes in habitat, including timber harvest, snag removal, and firewood collection. Martens den 

in tree cavities, logs, rock piles, and burrows (Forest Service 2014a).

American marten have been documented on the Espanola and Pecos/Las Vegas Ranger Districts 

and suspected on the Jemez District of the SFNF. There have been no recorded observations in 

the project area, but there have been sightings on the northwestern corner of the VCNP, next to 

the project area. American marten home ranges from these sightings would most likely overlap 

with the project area. Due to no recorded observations, it is uncertain how much potential habitat 

it currently occupies.

Goat Peak Pika

Goat Peak pika is confined to talus slides and boulder fields in alpine and subalpine areas. 

Optimal habitat for the pika is the talus/meadowland ecotone, with grass growing between the 

rock slabs. Temperature is a limiting factor for Goat Peak pika. The temperature within 

representative talus habitat ranges from -10 to 53°F, with temperatures 2 feet above the ground 

ranging from -13 to 72°F. Pikas cannot tolerate an ambient air temperature in their immediate 

environment of 82°F for more than 2 hours. 

In the Jemez Mountains, Goat Peak pikas have been observed on Goat, Santa Clara, and Pelado

Peaks, where they live in lava rocks as low as 9,000 feet (Biota Information System of New 

Mexico 2016). Goat Peak pikas occupy virtually every patch of appropriate talus in the Jemez 

Mountains. Specimens have been collected from Chicoma Mountain, Pajorito Mountain, Cerro 

Grande, Rabbit Mountain, the head of Frijoles Creek, Redondo Peak, and Cerros del Abrigo. 

Additional sightings have been made on Cerro Toledo and Shell Mountain (Biota Information 

System of New Mexico 2016). There are approximately 7,400 acres of potential habitat for the 

Goat Peak pika on the SFNF, 200 acres of which are in the project area. This habitat was 

modeled using alpine and subalpine communities above 9,000 feet in elevation. Goat Peak pikas 

have been recorded at Pelado Peak, Rabbit Mountain, and Frijoles Creek in the project area. 

American Pika

American pika is rather narrowly restricted to mountainous areas, where talus slopes provide 

suitable cover. In New Mexico, American pikas live from above the timberline, down into 
Chapter 3. Affected Environment and Environmental Consequences

3-110 Santa Fe National Forest Geothermal Leasing EIS

subalpine forest. Occasional exceptional animals are found living under piles of boards or 

timbers or in burrows (probably made by other mammals), but broken rock (including mine 

tailings) is the usual habitat. The rock must be sufficiently large that the spaces between provide 

corridors for movement; the slide must be of sufficiently recent origin that the spaces have not 

filled with debris from higher ground. In the best habitat, the talus is interspersed with meadow 

vegetation (Biota Information System of New Mexico 2016). 

In New Mexico, American pikas are confined to talus slides and boulder fields in alpine and 

subalpine areas. They are common in the alpine area of the Sangre de Cristo Range, descending 

as low as 11,000 feet. There are approximately 86,400 acres of potential habitat for the American 

pika on the SFNF, less than 100 acres of which are in the project area. One occurrence of 

American pika has been recorded in the project area.

Cinereus (Masked) Shrew

In New Mexico, this shrew is confined primarily to riparian habitats in subalpine coniferous

forest in the Sangre de Cristo, Jemez, and San Juan Mountains, usually above 9,500 feet. This 

species has been found along the banks of cold streams, in springy meadows, or under logs in the 

cold spruce woods.

There are approximately 268,500 acres of potential habitat for cinereus shrew on the SFNF, 

23,100 acres of which are in the project area. This habitat was modeled by including highelevation areas (above 9,000 feet in elevation), including ponderosa pine and white fir vegetation 

communities on the west side of the SFNF. Five observations have been recorded in the project 

area (Forest Service GIS 2015). Due to the large area modeled and the fact that more than 75 

percent of the observations fell within the modeled habitat, most of the modeled habitat is 

assumed to be sparsely occupied. 

Water Shrew

According to current records in New Mexico, water shrews are confined to the Sangre de Cristo,

San Juan, and Jemez Mountains. It occurs near permanent streams, seldom descending below 

8,000 feet in elevation. The water shrew can swim with great facility, diving under water to 

pursue aquatic organisms, and can run across the surface of the water for a short distance 

(Findley 1987). It eats large quantities of invertebrates daily, such as earthworms and spiders.

On the SFNF, the water shrew has been documented on all Ranger Districts. It is widespread in

the Jemez Mountains, although it is not common (Frey 2004). Known capture sites on the Jemez 

Ranger District are near Fenton Lake, Rio Cebolla, and San Antonio Creek. There are 

approximately 76,900 acres of potential habitat for water shrew on the SFNF, 7,500 acres of 

which are in the project area. It is uncertain how much potential habitat it currently occupies,

though approximately a third of the observations fell within the modeled habitat. Water shrews 

have been observed along San Antonio Creek in the project area. 

Preble’s Shrew

The species can be found near permanent or intermittent streams, in arid to semiarid shrub or

grasslands, and to a lesser extent in dense high-elevation coniferous forests. In general, its

habitats are confined to riparian or riparian-like (e.g., springs and seeps) conditions (Cornely et 

al. 1992). Little is known about its food sources, but it probably forages on small, soft-bodied 

invertebrates found in riparian areas. There are approximately 76,900 acres of potential habitat 

for Preble’s shrew on the SFNF, 7,500 acres of which are in the project area. Six incidental 
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Santa Fe National Forest Geothermal Leasing EIS 3-111

observations have been recorded there. Due to a low number of observations, how much

potential habitat it currently occupies is uncertain.

3.13.1.5 Plants

Yellow Lady’s Slipper

The yellow lady’s slipper is a perennial deciduous herb that grows as a single plant or in a 

colony. It grows in moderate shade to nearly full sun in fir, pine, and aspen forests from 6,000 to 

9,500 feet in elevation. It most often grows just above the banks of streams, usually 150 to 300 

feet from water. This species grows on mesic slopes up to 60 degrees, facing east to northeast, 

and covered with lush growth less than a foot tall (Forest Service 2014a). 

This species is known from San Miguel, Los Alamos, San Juan, and Santa Fe Counties (Forest 

Service 2014a). There is no modeled habitat for it in the project area, and there are no recorded 

observations there, but yellow lady’s slipper has been observed in the Valle Caldera National 

Preserve, next to the project area. Due to a low number of observations, it is uncertain how much 

potential habitat it currently occupies and if suitable habitat is in the project area.

Heil’s Alpine Whitlowgrass

Heil’s alpine whitlowgrass is a perennial herb found scattered in small populations in northern 

New Mexico. This species is found in alpine tundra growing in association with other low

growing, cushion-shaped alpine plants. This species occurs at elevations from 12,100 feet and 

higher. It is known from Rio Arriba and Mora Counties (NMRPTC 1999). It has not been 

recorded in the project area but has been recorded on the Bandelier National Monument next to 

the project area, and there may be suitable habitat in the project area. Due to a low number of 

observations, it is uncertain how much potential habitat it currently occupies.

Woodlily

The woodlily is a perennial herb found scattered in small populations in northern New Mexico. It

prefers wetter sites, in mixed conifer forests with a lush understory, often associated with large 

aspen, Douglas-fir, or ponderosa pine. Less frequently this species can be found along streams or 

in meadows (Forest Service 1990). It prefers soils that are rich and well drained. This species is 

known from San Miguel, Los Alamos, Sandoval, Otero, Rio Arriba, and Santa Fe Counties 

(Forest Service 2014a). It has not been recorded in the project area, but it contains approximately 

4,700 acres of potentially suitable habitat. Potentially suitable habitat both within the project area 

and surrounding areas has undergone significant reductions due to wildfires. Due to a low 

number of observations, it is uncertain how much potential habitat it currently occupies.

Santa Fe Blazingstar

Santa Fe blazingstar is a perennial herb, with numerous branches 1.0 to 1.5 feet long. Its yellow

flowers open in late afternoon in July through August. This species occurs in volcanic pumice 

and unconsolidated pyroclastic ash in pinyon-juniper woodland and lower montane coniferous 

forests, from 7,000 to 8,000 feet in elevation (NMRPTC 1999). This species is narrowly endemic 

to loose, volcanic substrate of the Jemez Mountains and is often seen where roads cut through 

pumice.

The Santa Fe blazingstar is known in Los Alamos, Sandoval, and Santa Fe Counties, New 

Mexico. Modeled habitat was taken from the SFNF’s Terrestrial Ecological Unit Inventory 

geospatial information for volcanic soils between 7,000 and 8,000 feet in elevation 
Chapter 3. Affected Environment and Environmental Consequences

3-112 Santa Fe National Forest Geothermal Leasing EIS

(approximately 15,500 acres of potential habitat on the SFNF, 5,600 acres of which are in the 

project area). The Santa Fe blazingstar has been documented in three locations in the project 

area, with a total of 0.49 acre of occupied habitat recorded. Due to a low number of observations, 

it is uncertain how much potential habitat it currently occupies.

Arizona Willow

Arizona willow is a perennial shrub forming a prostrate mat, large hedge, or thicket up to 9 feet 

tall. The plant’s flowers open in late May through June. This species occurs in sedge meadows 

and wet drainage ways in subalpine coniferous forests, from 10,000 to 11,200 feet in elevation 

(NMRPTC 1999). Habitat often occurs as a narrow, linear strip associated with perennial water 

in seeps, springs, stream sides, and wet meadows. This species is known from locations in New 

Mexico, Arizona, and Utah. Arizona willow is known in Rio Arriba, Taos, and Mora Counties, 

New Mexico. The Forest Service has not documented it in the project area, where there is

approximately 100 acres of potentially suitable habitat. Due to a low number of observations, it 

is uncertain how much potential habitat it currently occupies.

3.13.2 Environmental Consequences

3.13.2.1 Scoping Comments on Resource

The following issues specific to threatened and endangered species and special status species 

were identified during the public scoping period:

 What are the impacts of geothermal leasing on the MSO, Jemez Mountain salamander, New 

Mexico meadow jumping mouse, Jemez woodland snail, RGCT, and other threatened and 

endangered or special status species in the project area? What stipulations and mitigation 

measures are necessary to protect these species?

 Would geothermal leasing displace other resource uses on the forest, such as recreation and 

livestock grazing, into or near threatened and endangered species or special status species’ 

habitats?

3.13.2.2 How Resource Impacts Were Evaluated

Method

The method for determining special status species impact is incorporated by reference from the 

2008 Geothermal PEIS (BLM and Forest Service 2008). The analysis presented is largely 

qualitative, due to the lack of data or uncertainty in existing data on special status species in the 

project area. Since most special status species are associated with specific vegetation 

communities, the impacts on vegetation described in Section 3.11 would also likely impact 

special status species. In addition, many of the impacts on fish and wildlife associated with 

geothermal development described in Section 3.12 would also apply to special status species.

Indicators

Indicators of impacts on special status species are as follows:

 Change in acres of habitat potentially suitable for threatened and endangered and special 

status species

 Change in acres of habitat occupied by threatened and endangered and special status species

 Change in number of threatened and endangered and special status species populations
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Santa Fe National Forest Geothermal Leasing EIS 3-113

 Change in acres of rare plant associations

 Change in number of special status wildlife detections

Assumptions

This analysis assumes the following:

 NSO stipulations would minimize direct disturbance to habitats and species by restricting 

surface-disturbing activities where they are applied.

 TL stipulations would help to prevent direct disturbance to species during sensitive periods, 

such as winter, when forage is sparse, and during breeding and birthing.

 Disturbance of a key or critical component of a species habitat would be detrimental, with 

the degree dependent on the importance of the habitat component to the maintenance of the 

population.

 Impacts on special status species would be more significant than impacts on common species 

because population viability is already uncertain for special status species.

 The Forest Service would consult with the USFWS for any actions that could affect any 

federally listed endangered, threatened, or proposed species.

3.13.2.3 Common Impacts Associated with Geothermal Development

The information presented in the Common Impacts on Special Status Species Associated with 

Geothermal Development section of the 2008 Geothermal PEIS (BLM and Forest Service 2008) 

is incorporated by reference. Additional information specific to this EIS includes consideration 

of the particular special status species and habitats found in the project area.

Due to the inability to predict the location, scope, scale, and timing of future development, the 

impact analysis below provides a general description of common indirect impacts on threatened 

and endangered and special status species from geothermal resource development. Geothermal 

exploration, drilling operations, utilization, and reclamation and abandonment could affect 

threatened, endangered, and sensitive species in the same manner that vegetation, wildlife, and 

aquatic resources could be affected (see Section 3.12, Fish and Wildlife).

Special status species could be affected as a result of 

 Habitat disturbance

 Introduction of invasive vegetation

 Injury or mortality

 Erosion and runoff

 Fugitive dust

 Noise

 Exposure to contaminants

 Interference with behavioral activities

Which species may be at risk to construction-related impacts would depend on the project 

location and specific habitat at or near the site.

An important distinction about impacts on special status species is that those on small localized 

areas or those affecting only a few individuals can have impacts on special status species. Many 

special status species depend on unique habitats or have small remaining populations. Impacts 
Chapter 3. Affected Environment and Environmental Consequences

3-114 Santa Fe National Forest Geothermal Leasing EIS

that directly affect these unique habitats or individuals, even when small, can have significant 

impacts on special status species.

3.13.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analyses, in accordance with the Forest Plan and existing laws and regulations. 

Geothermal leasing stipulations and closures specific to threatened and endangered species or 

other special status species would not be implemented; however, any geothermal lease 

applications and nominations would be subject to standards and guidelines outlined in the Forest 

Plan and environmental analysis. The Forest Service has determined that the JNRA

(approximately 28,900 acres) is excluded from geothermal leasing on the basis of existing laws, 

regulations (see 43 CFR, Subpart 3201.11), and executive orders. There would be no direct 

disturbance to threatened, endangered, or sensitive species in the JNRA under Alternative 1.

Elsewhere, the types of impacts that could occur on threatened and endangered and special status 

species are those described under Common Impacts Associated with Geothermal Development. 

3.13.2.5 Impacts Under Alternative 2

Federally Listed Species

Jemez Mountain Salamander

Jemez Mountain salamander may be affected by habitat alteration, removal, reduction, or 

fragmentation. NSO stipulations would apply to any designated critical habitat for this species.

There are approximately 34,400 acres of critical habitat for Jemez Mountain salamander in the 

project area, and it may also be present outside of designated critical habitat in the aspen and 

spruce/fir vegetation communities. 

NSO stipulations would be in place outside of critical habitat as well, as outlined in Chapter 2. 

Under Alternative 2, NSO stipulations would apply to approximately 132,900 acres in the project 

area. Up to 674 acres of disturbance is anticipated in the RFDS in the project area; any

disturbance that occurs in Jemez Mountain salamander habitat outside of designated critical 

habitat would reduce the number of acres of suitable habitat available. Habitat at drilling pads, 

facilities, roadways, and transmission corridors would be affected. The magnitude of the 

disturbance would be a function of the level of preexisting disturbance and the size, scale, and 

phase of geothermal development. 

Fragmentation would affect Jemez Mountain salamander by altering how it uses the habitat. 

Fragmentation can separate populations into smaller populations, making them more vulnerable 

to predation, drought, and disease and limiting genetic diversity within breeding groups. 

Movement between habitat tracts is more difficult after fragmentation. Roads have been shown 

to impede the movements of invertebrates, reptiles, and small and large mammals (Jackson 

2000). Habitat fragmentation can create increased edges for access by predators and invasive 

species (Biota Information System of New Mexico 2015). 

Disturbance in occupied habitat could lead individuals to move into adjacent habitat that may be 

at or near carrying capacity. Increased concentrations in adjacent habitat could lead to an 
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Santa Fe National Forest Geothermal Leasing EIS 3-115

increase in the spread of diseases transmitted from humans, such as Batrachochytrium 

dendrobatidis, a fungal disease in northern New Mexico.

Direct injury and mortality could occur as a result of geothermal development associated with 

the RFDS. Equipment used for clearing vegetation, roadways, well pads, and facility sites and 

vehicles used during operation and closeout would affect wildlife, such as the Jemez Mountain 

salamander, which are not mobile enough to avoid construction operations. 

New Mexico Meadow Jumping Mouse

Impacts on New Mexico meadow jumping mouse from geothermal projects are directly linked to 

impacts on riparian and wetland habitats, in most cases. Impacts would result primarily from 

activities occurring near or in water bodies. 

NSO stipulations would apply to the following features, including a 500-foot-wide protection 

zone surrounding each feature: 

 Water bodies

 Rivers and streams (perennial and intermittent)

 Wetlands, springs, and playas

 Riparian areas 

 100-year floodplains

Disturbance of adjacent ground and direct stream disturbance would not occur. 

The NSO stipulations would reduce or eliminate impacts from ground disturbance, vegetation 

removal, road construction and excavation, the installation of structures and other facilities (e.g., 

transmission towers or pipelines), and water contaminants release. There would be no reduction 

in the acres of suitable habitat available for New Mexico meadow jumping mouse. NSO 

stipulations would apply to any designated critical habitat for New Mexico meadow jumping 

mouse. Approximately 800 acres of critical habitat have been designated in the San Antonio 

Creek and Rio Cebolla areas in the project area. Potential habitat occurs beyond designated 

critical habitat (such as along the upper Rio Cebolla); however, development in these areas 

would be restricted due to the riparian area stipulations. Direct and indirect impacts on New 

Mexico meadow jumping mouse would not occur as a result of Alternative 2.

Mexican Spotted Owl

MSO may be impacted by habitat alteration, removal, reduction, or fragmentation. NSO

stipulations would apply to any MSO-designated critical habitat. Approximately 12,998 acres of 

MSO critical habitat have been designated in the project area. Up to approximately 674 acres of 

disturbance is anticipated in the RFDS in the project area, and any disturbance that occurs in 

MSO habitat outside of designated critical habitat would reduce the number of acres of suitable 

habitat available. Habitat at drilling pads, facilities, roadways, and transmission corridors would 

be affected. The magnitude of the disturbance would be a function of the level of preexisting 

disturbance and the size, scale, and phase of geothermal development. 

Noise from geothermal activities can have impacts on MSO. Principal sources of noise from 

geothermal activities would be trucks, drilling rigs, and heavy machinery. The most impacts 

associated with noise could occur if critical life cycle activities (e.g., mating and nesting) were 

disrupted. Disturbance during mating, nesting, or rearing of young can cause MSO to abandon 

mating and nesting activities and can strand young, leaving them susceptible to predation and 
Chapter 3. Affected Environment and Environmental Consequences

3-116 Santa Fe National Forest Geothermal Leasing EIS

starvation. Other potential impacts from noise are increased flush frequency, alert responses (i.e., 

head movements), and reduced prey delivery rates (Delaney et al. 1999). 

The most significant noise sources would be binary power plants, productions wells, and drill 

rigs. Calculated noise levels at various distances from these sources are provided in Section 

3.20, Noise. 

The location and timing of geothermal activities (especially exploration and development) may 

affect the migratory and other behavioral activities of MSO. They may cease foraging, mating, or 

nesting or may vacate active nest sites in areas where geothermal activities are occurring; MSO 

may permanently abandon the disturbed areas and adjacent habitats. In addition, exploration and 

development may affect movements; for example, they may avoid a localized migratory route 

because of ongoing construction. However, drilling and construction would be prohibited 

between March 1 and August 31 in MSO-designated PACs. Implementing TLs in designated 

PACs would minimize impacts on MSO during critical nesting and breeding periods.

Fisheries and Aquatic Biota

Impacts on Rio Grande sucker, Rio Grande chub, RGCT, and northern leopard frog from 

geothermal projects are directly linked to impacts on riparian and wetland habitats, in most 

cases. Impacts would result primarily from activities near or in water bodies. The East Fork and 

main stem of the Jemez River and San Antonio Creek are in the JNRA, which is closed to 

geothermal development, so direct impacts from geothermal development in these streams would 

not occur. 

NSO stipulations would apply to the following features, including a 500-foot-wide protection 

zone surrounding each feature: 

 Water bodies

 Rivers and streams (perennial and intermittent)

 Wetlands, springs, and playas

 Riparian areas

 100-year floodplains

Disturbance of adjacent ground and direct stream disturbance would not occur. 

The NSO stipulations would reduce or eliminate impacts from ground disturbance, vegetation 

removal, road construction and excavation, the installation of structures and other facilities (e.g., 

transmission towers or pipelines), and water contaminants release. There would be no reduction 

in the acres of suitable habitat available for aquatic species. 

Indirect impacts on aquatic habitat from groundwater withdrawal during geothermal activities

are unknown at this time. In future projects the operator will be responsible for obtaining water 

rights, and the source of this water is not known at this time. Water depletions would be 

evaluated at a later stage, with USFWS consultation, once more information is known. 

Stream flow rates are affected by the upland vegetation and adjacent terrain; therefore, 

geothermal development could alter stream flows and affect aquatic species and habitat. NSO

stipulations would apply to slopes in excess of 40 percent and soils with severe erosion potential. 

These stipulations would reduce the impacts on aquatic habitat from runoff and sedimentation of 

streams due to geothermal activity.
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Santa Fe National Forest Geothermal Leasing EIS 3-117

Alternative 2 may impact individual Rio Grande sucker, Rio Grande chub, RGCT, and northern 

leopard frog; however, it is not likely to result in a trend toward federal listing of these species or 

loss of species viability.

Riparian Mammals

In most cases, impacts on water shrew and Preble’s shrew from geothermal projects are directly 

linked to impacts on riparian and wetland habitats. Impacts would result primarily from activities 

occurring near or in water bodies. The East Fork and main stem of the Jemez River and San 

Antonio Creek are in the JNRA, which is closed to geothermal development, so direct impacts

from geothermal development in these streams would not occur. 

NSO stipulations would apply to the following features, including a 500-foot-wide protection 

zone surrounding each feature: 

 Water bodies

 Rivers and streams (perennial and intermittent)

 Wetlands, springs, and playas

 Riparian areas

 100-year floodplains

Disturbance of adjacent ground and direct stream disturbance would not occur. 

The NSO stipulations would reduce or eliminate impacts from ground disturbance, vegetation 

removal, road construction and excavation, the installation of structures and other facilities (e.g., 

transmission towers or pipelines), and water contaminants release. There would be no reduction 

in the acres of suitable habitat available for riparian species. 

Alternative 2 may impact individual water shrew and Preble’s shrew, but it is not likely to result 

in a trend toward federal listing of these species or loss of species viability.

Raptors and Migratory Birds

Northern goshawk, boreal owl, American peregrine falcon, and gray vireo may be affected by 

habitat alteration, removal, reduction, or fragmentation. Up to 674 acres may be disturbed in

raptor and migratory bird habitat in the project area and may reduce the number of acres of 

suitable habitat available. Habitat at drilling pads, facilities, roadways, and transmission 

corridors would be affected. The magnitude of the disturbance would be a function of the level 

of preexisting disturbance and the size, scale, and phase of geothermal development. 

Geothermal development would have the greatest impact on raptors and migratory birds if it 

were to affect specialty habitats, such as riparian areas, wetlands, cliffs, tall trees, or nesting 

areas. NSO stipulations would apply to several specialty habitats, such as riparian areas and 

wetlands. 

The direct injury and mortality of raptors and migratory birds may occur as a result of 

geothermal development associated with the RFDS. Equipment used for clearing vegetation and 

roadways, well pads, and facility sites and vehicles used during operation and closeout would 

affect migratory birds nesting in the areas of proposed disturbance. Wildfire could remove acres 

of suitable habitat for raptors and migratory birds and could reduce the quality of remaining 

habitat.
Chapter 3. Affected Environment and Environmental Consequences

3-118 Santa Fe National Forest Geothermal Leasing EIS

Noise from geothermal activities can have impacts on raptors and migratory birds. The principal 

sources of noise are trucks, drilling rigs, and heavy machinery. The most impacts associated with 

noise could occur if critical life cycle activities were disrupted (e.g., mating and nesting). All 

birds could be disturbed by noise. Disturbance during mating, nesting, or rearing of young can 

cause birds to abandon mating and nesting activities and can strand young, leaving them 

susceptible to predation and starvation. 

However, TLs are proposed in northern goshawk post-fledgling areas, with drilling and

construction prohibited between March 1 and September 30, and in peregrine falcon nesting 

areas, with drilling and construction prohibited between March 1 and August 15. These measures 

would minimize risks to northern goshawk and peregrine falcon reproductive and post-fledgling 

success during the critical nesting and breeding period. 

Raptors and migratory birds could also be affected by light pollution. Increased illumination may 

extend diurnal16 or crepuscular17 behaviors into the nighttime environment by improving an 

animal’s ability to orient itself. However, constant artificial night lighting may also disorient or 

entrap birds accustomed to navigating in a dark environment, which may affect foraging, 

reproduction, communication, and other behaviors (Longcore and Rich 2004). The BMPs

identified in Appendix C include efficient facility light design, such that upward light scattering 

is minimized. These measures would minimize potential impacts on migratory birds associated 

with light pollution.

Alternative 2 may impact individual northern goshawk, boreal owl, American peregrine falcon, 

and gray vireo, but it is not likely to result in a trend toward federal listing or loss of species 

viability.

Bats

Pale Townsend’s big-eared bat and spotted bat may be affected by habitat alteration, removal, 

reduction, or fragmentation. Up to 674 acres may be disturbed in bat habitat in the project area, 

which may reduce the number of acres of suitable habitat available. Habitat at drilling pads, 

facilities, roadways, and transmission corridors would be affected. Geothermal development

would have the greatest impact on bats if it were to affect specialty habitats, such as riparian

areas, wetlands, rock outcrops, caves, and tree roosting areas. NSO stipulations would apply to 

several specialty habitats, such as riparian areas, wetlands, and slopes in excess of 40 percent 

(accounting for rock outcrops and cliffs). 

The direct injury and mortality of bats may occur as a result of geothermal development

associated with the RFDS. Bat mortalities could occur by colliding with vehicles or structures 

associated with geothermal development. Shining lights downward can reduce the risk of 

impacts on bat species; implementing such BMPs as installing shrouds, properly directing light 

to illuminate only necessary areas, and installing motion sensors to illuminate areas only when 

necessary, would minimize upward light scattering.

Noise from geothermal activities can have impacts on bats. The principal sources of noise would

be trucks, drilling rigs, and heavy machinery. The most impacts associated with noise could 

occur if critical life cycle activities were disrupted (e.g., mating and foraging). Bats use sound in 

order to forage, and increased noise can affect their ability to find food through echolocation. 

 

16 Appearing or being active during the day

17 Appearing or being active in twilight
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-119

On the basis of the types of equipment that would likely be used, such as drill rigs and graders, 

the noise levels associated with the equipment would be elevated to levels that could potentially 

disturb bat species, which are known to avoid areas of elevated noise while foraging (Schaub et 

al. 2008).

Alternative 2 may impact individual pale Townsend’s big-eared bat and spotted bat, but it is not 

likely to result in a trend toward federal listing or loss of species viability.

Small Mammals

Gunnison’s prairie dog, American marten, Goat Peak pika, American pika, and cinereus shrew 

may be affected by habitat alteration, removal, reduction, or fragmentation. Up to 674 acres may 

be disturbed within potential small mammal habitat in the project area and may reduce the 

number of acres of suitable habitat available. Habitat at drilling pads, facilities, roadways, and 

transmission corridors would be affected. Geothermal development would have the greatest 

impact on small mammals if it were to affect specialty habitats, such as riparian areas, wetlands, 

alpine talus, caves, or wintering and breeding areas. NSO stipulations would apply to several 

specialty habitats, such as riparian areas, wetlands, and slopes in excess of 40 percent. 

The direct injury and mortality of small mammals may occur as a result of geothermal 

development associated with the RFDS. Equipment used for clearing vegetation and roadways, 

well pads, and facility sites and vehicles used during operation and closeout would affect special 

status wildlife that are not mobile enough to avoid them. Of the small mammal species with 

habitat in the project area, Gunnison’s prairie dog and cinereus shrew would be most susceptible. 

American pika and Goat Peak pika have habitat in high elevation alpine talus, where geothermal 

development is unlikely.

Noise from geothermal activities can have impacts on small mammals. Principal sources of noise 

are trucks, drilling rigs, and heavy machinery. The most impacts associated with noise could 

occur if critical life cycle activities, such as mating, were disrupted. All small mammals could be 

disturbed by noise. Disturbance during mating or rearing of young can cause wildlife to abandon 

mating activities and can strand young, leaving them susceptible to predation and starvation. 

Alternative 2 may impact individual Gunnison’s prairie dog, American marten, Goat Peak pika, 

American pika, and cinereus shrew, but it is not likely to result in a trend toward federal listing

or loss of species viability.

Plants

Yellow lady’s slipper, Heil’s alpine whitlowgrass, woodlily, Santa Fe blazingstar, and Arizona 

willow may be impacted by habitat alteration, removal, reduction, or fragmentation. Up to 674

acres may be disturbed in potential sensitive plant habitat in the project area, and acres of 

suitable habitat available may be reduced. Habitat at drilling pads, facilities, roadways, and 

transmission corridors may be affected. The magnitude of the disturbance would be a function of 

the level of preexisting disturbance and the size, scale, and phase of geothermal development. 

Fragmentation can separate sensitive plant populations into smaller populations, making them 

more vulnerable to drought, surface disturbance, and disease. Fragmentation can facilitate the 

spread and introduction of invasive plant species. Roads and other corridors can facilitate the 

dispersal of invasive species by altering existing habitat conditions, stressing or removing native 

species, and allowing easier movement of wild or human vectors (Trombulak and Frissell 2000). 

Sensitive plants can be affected by invasive vegetation through competition for resources and 
Chapter 3. Affected Environment and Environmental Consequences

3-120 Santa Fe National Forest Geothermal Leasing EIS

available habitat. However, BMPs for noxious weeds identified in Appendix C, including 

development of a weed control plan and use of a controlled inspection and cleaning for 

construction equipment, would reduce the potential for noxious weed invasion. Wildfire could 

remove acres of suitable habitat for special status plants and could reduce the quality of 

remaining habitat.

The direct removal and mortality of sensitive plants would likely not occur as a result of 

geothermal development associated with the RFDS. Before geothermal activity begins, BMPs

such as clearance surveys could be incorporated as appropriate into permit applications, or 

included in the approved use authorizations. These measures would allow for detection and 

avoidance of sensitive plant populations prior to disturbance. 

Alternative 2 may impact individual yellow lady’s slipper, Heil’s alpine whitlowgrass, woodlily, 

Santa Fe blazingstar, and Arizona willow, but it is not likely to result in a trend toward federal 

listing or loss of species viability.

3.13.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area under Alternative 3. There 

would be no direct or indirect impacts on threatened, endangered, and sensitive species from 

geothermal activities under Alternative 3.

3.13.2.7 Impacts Under Alternative 4

Direct and indirect impacts on federally listed species, raptors and migratory birds, bats, small 

mammals, and plants would be the same as those described under Alternative 2; however, the 

level of intensity of disturbance could be more severe under Alternative 4 for fish, aquatic 

communities, and other species that use or depend on riparian environments. This is because the 

NSO stipulations under Alternative 2 are more restrictive for intermittent streams and soils with 

severe erosion potential.

Intermittent streams, along with a 500-foot protection zone, are subject to NSO stipulations 

under Alternative 2, compared to CSU stipulations under Alternative 4. The potential disturbance 

on intermittent streams could lead to increased sedimentation flowing into perennial streams and 

could have an impact on species that are sediment intolerant, such as Rio Grande sucker, Rio 

Grande chub, RGCT, and other cold water fish species. 

3.13.2.8 Cumulative Impacts

The cumulative impacts analysis region of influence for threatened and endangered species and 

special status species is the three level 4 watersheds that intersect the project area: the Rio 

Grande-Santa Fe, Rio Chama, and Jemez watersheds. Impacts on threatened, endangered, and 

sensitive species do not end at the project area boundary but would encompass migration 

corridors, large home ranges, and cross-boundary landscapes that extend beyond SFNF land.

Past, present, and reasonably foreseeable future actions are discussed in Section 3.3.4. The 

following projects would increase the amount of disturbance in the cumulative impacts analysis 

area:

 Pueblo of Jemez Red Rocks Dam Repair

 Abiquiu Land Grant Waterline Replacement

 McKinney County Dam
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-121

 Mineral development in the South Pit Pumice Mine Expansion and the Duran 2010 Pumice 

Mine

Projects that should improve habitat conditions in the cumulative impacts analysis area are as 

follows:

 Southwest Jemez Mountains Restoration Project,

 Cerro Pelon Timber Stand and Wildlife Habitat Improvement Project

 Pueblo of Jemez Owl Springs Bridge Sediment Removal Project

 New Mexico Meadow Jumping Mouse Critical Habitat Projection Project

 Supplement to the Final EIS for Invasive Plant Control Project

The response of individual species to past, present, and reasonably foreseeable future actions 

would vary, depending on the life history and habitat needs of the species. However, in general, 

projects that increase the amount of disturbance could reduce habitat or cover where those 

projects occur. 

Alternatives 1, 2, and 4 would increase the number of acres of disturbance in the cumulative 

impacts analysis area, when combined with other past, present, and reasonably foreseeable future 

actions. An expanded road network within the project area could increase fragmentation and 

reduce the habitat quality for special status species in the cumulative impact analysis area. 

However, NSO, CSU, and TL stipulations under Alternatives 2 and 4 would limit wildlife 

impacts in seasonally important habitats (such as goshawk PFAs, peregrine falcon eyrie nesting 

areas, and MSO PACs), designated or proposed critical habitats, and riparian areas. 

Geothermal leasing and development under Alternatives 1, 2, and 4 would contribute to 

cumulative noise impacts. For example, the number of acres of habitat occupied by some 

threatened and endangered and special status species could be reduced. This would be due to the 

existing noise sources, such as vehicle traffic along NM 4, in combination with reasonably 

foreseeable future actions, such as the Southwest Jemez Mountains Landscape Restoration 

Project, and geothermal exploration, drilling, and utilization; however, the magnitude of impacts 

depends on the species’ noise tolerance level. Under Alternatives 2 and 4, TLs for MSO PACs, 

northern goshawk PFAs, and peregrine falcon eyrie nesting areas would reduce the likelihood of 

flush responses and habitat avoidance during critical nesting and breeding periods. Cumulative 

noise impacts, including habitat avoidance, could still occur in areas not subject to TLs; 

however, the noise BMPs identified in Appendix C would minimize these types of impacts.

For fish and other aquatic special status species, stipulations for rivers, streams, and erosive soils 

under Alternatives 2 and 4 would restrict geothermal development in these areas, thereby 

maintaining acres of occupied and potentially suitable habitat. 

Geothermal development, combined with future surface-disturbing projects or wildfire, existing 

surface disturbances, and wildfires, could reduce the number of acres of potentially suitable 

habitat for special status wildlife and plants in the cumulative impacts analysis area; however, 

clearance surveys would be required in advance of surface-disturbing geothermal activities.

Climate change may have cumulative impacts on threatened and endangered and special status 

species in the project area. This would come about by altering habitat or habitat components. In 

particular, current and future effects from warmer climate conditions in the Jemez Mountains 

could reduce the amount of suitable salamander habitat, reduce the time period when the species 
Chapter 3. Affected Environment and Environmental Consequences

3-122 Santa Fe National Forest Geothermal Leasing EIS

can be active aboveground, and increase the moisture demands and subsequent physiological 

stress on salamanders (USFWS 2013b). 

Increased drought frequency associated with climate change is also likely to impact the New 

Mexico jumping mouse through reduced habitat. This is because of its dependence on permanent 

waterways and limited ability to disperse (Frey and Malaney 2009). Similar impacts may occur 

for other riparian mammals in the project area, such as water shrew and Preble’s shrew.

Climate change may impact MSO through such mechanisms as the following (USFWS 2012):

 Shifts in distribution in response to predicted warming in the southwest

 Changes in demography, including reduced reproductive output

 Changes in co-evolved interactions

 Direct loss of habitat from increased disturbance regimes, such as high severity fires and 

bark beetle outbreaks

Climate change may also impact the habitats of threatened and endangered special status raptors. 

For example, climate change may reduce the high-elevation habitats for boreal owls, particularly

as more frequent and larger fires are predicted (Stahlecker et al. 2014); however, no boreal owls 

are known to occur in the project area. Similarly, drier conditions from increased temperatures 

and evapotranspiration could increase susceptibility to fire and reduce the distribution and health 

of pinyon-juniper communities, which the grey vireo depends on (NMDGF 2007).

Climate change may affect bat communities through climate-related shifts in riparian habitat, 

potentially resulting in greater travel distances between roosts and foraging grounds (Friggens et 

al. 2013). Other special status species mammals, such as the goat peak pika and American pika,

are vulnerable to climate change, due to their sensitivity to high temperatures. Climate models 

anticipate the American pika will experience range contraction from increased temperatures and 

decreased precipitation (Galbreath et al. 2009).

The cumulative impacts of climate change on fisheries would be the same as those described 

under Section 3.12.2.8.

The impacts from climate change, when combined with the impacts under Alternatives 1, 2, and 

4, could reduce habitat availability over time for threatened and endangered and special status 

species. Alternative 3 would have no cumulative impacts on threatened, endangered, and 

sensitive species or their habitat.

3.14 Livestock Grazing

3.14.1 Affected Environment

The primary law governing grazing on NFS lands is the Public Rangelands Improvement Act of 

1978. The three enabling statutes that govern grazing on NFS lands are the Organic Administration 

Act, the Bankhead-Jones Farm Tenant Act, and the Multiple-Use Sustained-Yield Act.

The Forest Service primarily manages grazing and management on NFS lands under 36 CFR, 

Part 222, Forest Service Manual 2200 – Range Management, and Forest Service Handbook 2200 

– Range Management (Forest Service 2016f). Under this management, ranchers may obtain a 

grazing permit for an allotment of public or NFS land on which a specified number of livestock 

may graze. An allotment is an area of land designated and managed for livestock grazing. The 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-123

number of permitted livestock on a particular allotment on public land is determined by how 

many AUMs18 that land will support. Upper and special limits governing the total number of 

livestock for which a person is entitled to hold a grazing permit on NFS lands is determined by 

the Chief of the Forest Service (36 CFR, Part 222).

There are 17 grazing allotments on NFS lands in the SFNF Geothermal Decision Area (see Figure 

3-3). Table 3-19, below, outlines the active grazing allotments that occur in the SFNF Geothermal 

Decision Area, as well as the total acres and AUMs designated for each. 

Table 3-19. Livestock Grazing Allotments in the Santa Fe National Forest Geothermal Decision 

Area

Allotment Name Acres in the Decision 

Area1 AUMs

Alamo 5,100 332

Bland Canyon 100 15

Cebolla/San Antonio 19,700 1544

Chicoma 3,800 152

Coyote 19,900 2457

Del Norte 4,900 337

Jarosa 8,200 3022

Las Conchas 1,400 337

Mesa Del Medio 14,200 1085

Penas Negras 3,800 1387

Peralta 3,700 267

Polvadera 4,800 186

Recreation 3,500 0

San Diego 17,200 2522

Vallecitos 15,800 671

V-Double Slash 12,400 1908

Youngsville 30,300 5640

Sources19: Forest Service GIS 2015 

1Rounded to the nearest 100

 

18 The quantity of forage required by one mature cow and her calf (or the equivalent in sheep or horses) for 

1 month. 

19 Mathew Chavez and Anne Bishop, Forest Service, personal communication with Holly Prohaska, 

EMPSi. March 2, 2016.
Figure 3-3 3-124 Santa Fe National Forest Geothermal Leasing EIS Chapter 3. Affected Environment and Environmental Consequences
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-125

3.14.2 Environmental Consequences

3.14.2.1 Scoping Comments on Resource

The following issue specific to livestock grazing was identified during the public scoping period:

 How would geothermal leasing affect grazing allotments and grazing forage?

3.14.2.2 How Resource Impacts Were Evaluated

Method

The method used to determine potential impacts on livestock grazing included a review of 

available allotment information and GIS data for the geothermal decision area.

Indicators

Potential impacts on livestock grazing could occur if reasonably foreseeable future actions were 

to result in the following:

 Decrease acreages available to grazing

 Decrease AUM number or forage

 Cause harassment or death of livestock

3.14.2.3 Common Impacts Associated with Geothermal Development

Issuing a geothermal lease does not involve ground-disturbing activities or any type of 

construction, so there would be no direct impact on livestock grazing. Impacts would result from 

activities pursued after leasing. Due to the inability to predict the location, scope, scale, and 

timing of future development, the following impact analysis provides a general description of 

common impacts on livestock grazing from geothermal resource development. 

A detailed description of geothermal development operations relative to livestock grazing

resources are described in detail in the 2008 Geothermal PEIS; the phases of geothermal 

development, including exploration, drilling operations, utilization, and reclamation and 

abandonment, are also discussed in detailed in the PEIS. Indirect impacts on livestock grazing 

from the future phases of geothermal exploration or development would occur from ground 

disturbance on allotments in a lease area. Indirect impacts are temporary or permanent reduction 

in forage and AUMs, harassment of livestock, shifts in grazing distribution, or changes in season 

of use.

3.14.2.4 Impacts Under Alternative 1

Under Alternative 1, the JNRA (approximately 28,900 acres) is excluded from geothermal 

leasing on the basis of existing laws, regulations (43 CFR, Subpart 3201.11), and executive 

orders. Within those 28,900 acres there would be no disturbance to livestock or livestock 

management on the allotments in the JNRA from geothermal development (see Table 3-20, 

below). Indirect impacts identified above and in the 2008 geothermal PEIS could occur on 

allotments outside of the JNRA on a case-by-case basis.
Chapter 3. Affected Environment and Environmental Consequences

3-126 Santa Fe National Forest Geothermal Leasing EIS

Table 3-20. Livestock Grazing Allotments in the Jemez National Recreation Area

Allotment Name

Acres in the Jemez 

National Recreation 

Area

Percentage of 

Allotment

Cebolla San Antonio 1,600 8

Del Norte 3,300 67

Las Conchas 1,400 100

Peralta 2,100 57

Recreation 3,400 97

San Diego 7,500 44

Vallecitos 3,800 24

V-Double Slash 5,700 46

Total 28,900

Source: Forest Service GIS 2015

Based on the RFDS for the decision area and an estimated disturbance of 27 acres from 

exploration or 647 acres of development, there is potential for indirect impacts on grazing 

allotments outside of the JNRA and other closure areas. These impacts would be a reduction in 

forage, possible reductions in AUMs, and harassment of livestock. However, because the size 

and location of each geothermal project is not known, the disturbance of approximately 674

acres could be spread across all of the grazing allotments, minimizing overall impacts per 

allotment.

3.14.2.5 Impacts Under Alternative 2

In addition to portions of allotments closed to geothermal development that fall within the 

JNRA, Alternative 2 closes other areas based on special circumstances. As such, the Cebollo San 

Antonio allotment would have an additional 2,600 acres closed to geothermal development, the 

Vallecitos and V-Double Slash allotments would have an additional 100 acres closed to 

geothermal development, and the Youngsville would have 300 acres closed to geothermal 

development. The closures, along with the addition of NSO stipulations, would slightly decrease 

disturbance of livestock grazing and livestock forage over Alternative 1. 

3.14.2.6 Impacts Under Alternative 3

Under Alternative 3, all 194,900 acres of grazing allotments in the project area would be closed 

to leasing. Therefore, there would be no direct or indirect impacts on livestock or livestock 

operations from geothermal leasing and development.

3.14.2.7 Impacts Under Alternative 4

Indirect impacts under Alternative 4 would be the same as those described for Alternative 1; 

however, CSU stipulations may decrease harassment of livestock or disturbance of forage where 

these areas overlap. 

3.14.2.8 Cumulative Impacts

Cumulative impacts on livestock grazing would occur from the loss of forage for grazing, loss of 

AUM capacity, and the disruption of livestock grazing practices where geothermal development

and other projects create disturbance on grazing allotments in and next to the project area. Past, 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-127

present, and reasonably foreseeable future actions are discussed in Section 3.3.4 and include the 

following projects, which would increase the amount of disturbance in the project area:

 Abiquiu Land Grant Waterline Replacement

 McKinney County Dam

 Mineral development in the South Pit Pumice Mine Expansion and the Duran 2010 Pumice 

Mine

However, cumulative projects that would also promote healthy forage and clean water in the 

project area are as follows:

 Southwest Jemez Mountains Restoration Project

 Cerro Pelon Timber Stand and Wildlife Habitat Improvement Project

 New Mexico Meadow Jumping Mouse Critical Habitat Projection Project (while this project 

would promote clean water, forage would be protected for jumping mouse habitat and not 

available to livestock)

 Supplement to the Final EIS for Invasive Plant Control Project

3.15 Cultural Resources

Cultural resources are the present expressions of human culture and the physical remains of past 

activities, such as buildings, structures, districts, landscapes, archaeological sites, and objects. 

They can also include locations that can be significant in national, regional, or local history, 

architecture, archaeology, engineering, or culture. They include sacred sites and natural features 

significant to contemporary communities or peoples. Section 3.16 provides an additional 

discussion of ethnographic resources and the potential for impacts on these resources.

The Cultural Resource Specialist Report (PaleoWest 2016) is incorporated by reference. (See the 

report for a detailed cultural history of the project area and information on regulatory 

background, data sources, methods, assumptions, and data limitations.)

3.15.1 Affected Environment

NEPA requires a consideration of “important historic, cultural, and natural aspects of our natural 

heritage.” This includes the necessity of independent compliance with the applicable procedures 

and requirements of other federal and state laws, regulations, and executive orders. The principal 

federal law addressing cultural resources is the National Historic Preservation Act (NHPA) of 

1966, as amended (54 USC, Section 300101 et seq.) and its implementing regulations found at 

36 CFR, Part 800.3. These regulations, commonly referred to as the Section 106 process, 

describe the procedures for identifying and evaluating historic properties, for assessing the 

impacts of federal actions on historic properties, and for project proponents consulting with 

appropriate agencies to avoid, reduce, or minimize adverse effects. Historic properties are 

cultural resources that meet specific criteria for listing on the NRHP.

Among other mandates, Section 110a of the NHPA (54 USC, Sections 306101[a] and 306102) 

requires federal agencies to develop a program that ensures that historic properties under the 

jurisdiction or control of the agency are identified, evaluated, and nominated to the NRHP. It also 

requires that they be maintained in a way that considers the preservation of their historic, 

archaeological, architectural, and cultural values. Although leasing consent has no direct impact 

on cultural resources, it is a commitment of resources that may result in potential impacts in the 
Chapter 3. Affected Environment and Environmental Consequences

3-128 Santa Fe National Forest Geothermal Leasing EIS

future. Thus, in support of this EIS, the Forest Service has prepared a cultural resource specialist 

report examining the entire geothermal potential area, rather than simply considering reasonably 

foreseeable development or past lease interest areas. The goal of the report is to compile 

information on previously recorded cultural resources and cultural resource inventories in the 

project area. Cultural resource GIS data for sites and projects provided by the Forest Service is 

current and accurate as of fall 2015 (PaleoWest 2016).

3.15.1.1 Inventory

Archaeologists have surveyed approximately 102,002 acres, or 52 percent, of the project area, 

including all levels of pedestrian survey on SFNF, private, and state lands. Many previous 

surveys are overlapping, and therefore cultural resource surveys have covered 233,643 acres in 

965 survey projects. Most of the higher density of survey coverage is in the central and southern 

portion of the project area. Based on reported field methods, inventories are categorized as valid 

and complete (consistent with current Forest Service standards), less than complete, or unknown 

by the Forest Service. These assessments of survey validity are not absolute but are considered 

when determining cultural resource identification for specific undertakings. Valid and complete 

survey coverage is estimated at approximately 28 percent of the project area, or 54,558 acres.

The Forest Service has identified 1,962 cultural resource sites on the 102,002 surveyed acres in 

the project area. These consist of a wide variety of prehistoric and historic era resources. 

Human occupation of the Jemez Mountains spans from the earliest identified culture in the 

United States (Paleo-Indian) to the present. Most cultural resource sites identified in the project 

area are prehistoric (1,054, or 54 percent); 143 sites (7 percent) are historic; 368 sites (19 

percent) have both prehistoric and historic components; 388 sites (20 percent) are unknown; and 

the cultural affiliation of 9 sites (less than 1 percent) was not reported. Eight sites are linear, such 

as roads and trails. 

Contemporary pueblo, tribal, and Hispanic communities have traditional ties to ancestral sites, 

landscapes, and resources in the project area. These are not necessarily enumerated or recorded 

in these inventories, but they are of concern from a cultural resource management perspective. 

The Forest Service is responsible for considering the impacts of its actions on TCPs and 

traditional cultural practices. TCPs are considered historic properties under the NHPA. The All 

Pueblos Council of Governors (2015) adopted a resolution that expressed its support for 

designating the Jemez Mountains as a TCP. Section 3.16 provides additional discussion of 

ethnographic resources and the potential for impacts on these resources.

Prehistoric resources are field houses, agricultural terraces, grid gardens, pueblo villages, 

roomblocks, pithouses, rock art panels, rock shelters, rubble mounds/habitations, campsites, 

activity areas, hearths, hunting features, storage features, cairns, shrines, trails, lithic quarries, 

lithic and pottery scatters, and burials. Historic era resources are ranching and livestock sites, 

railroad and logging sites, cabins ruins, refuse scatters and roads, and erosion control features. 

More than half of the sites in the project area (1,152) are situated between 7,000 and 8,000 feet 

above mean sea level. One site occurs at an elevation of less than 6,000 feet, 201 sites are 

between 6,000 and 7,000 feet, 494 sites are between 8,000 and 9,000 feet, and 113 sites are at 

elevations over 9,000 feet. Only 11 sites have been located above 10,000 feet in elevation.

The GIS data included 405 site records where NRHP eligibility was reported. Eligibility 

recommendations of 1,557 sites were not reported and should be treated as “unevaluated.” Of the 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-129

sites with eligibility recommendations, 6 are listed on the NRHP, 288 are recommended as 

eligible for listing, 21 are ineligible for listing, and 90 are unevaluated (PaleoWest 2016).

Six properties in the project area are listed on the NRHP: one in the JNRA (LA56557 [Virgin 

Logging Camp #2]) and five in the southern part of the project area (LA303 [Sayshukua], LA475 

[Totaskwina], LA478 [Wabakwa], LA386, and LA5920). LA675, known as Gíusewa Pueblo 

(Jemez State Monument), is listed on the NRHP and is National Historic Landmark #12001007. 

Gíusewa is in the project area but is on land owned by the State of New Mexico. 

All of the above sites, aside from the logging camp (LA56557), were listed under a National 

Register Multiple Property nomination, Jemez Cultural Developments in North-Central New 

Mexico (NPS 1990).

3.15.2 Environmental Consequences

3.15.2.1 Scoping Comments on Resource

The following issues specific to cultural resources were identified during the public scoping 

period:

 How would cultural resources be affected by geothermal leasing? 

 How would these impacts be managed?

3.15.2.2 How Resource Impacts Were Evaluated

A consent to leasing and leasing decisions do not grant any rights or authorize any activities 

affecting cultural resources. The impact analysis focuses on the potential future actions and 

disturbance estimates, based on the RFDS, and the implementation of the alternatives described 

in Chapter 2. In all cases, before any ground disturbance or other future actions, further 

decision-making would be required, including cultural resource compliance.

Methods

PaleoWest (2016) reviewed cultural resource baseline information for an understanding of 

known resources and to determine the condition of the resources. Also, it considered all laws 

pertinent to determining the impacts on cultural resources and included them in criteria for 

determining impacts. Known resources and an informed estimation of site density in unsurveyed 

areas was overlain with the actions found under each alternative in Chapter 2. Conclusions were 

drawn, based on an understanding of how these types of actions may affect the known and 

potentially discoverable resources (PaleoWest 2016). 

Based on ongoing consultation with contemporary pueblo, tribal, and Hispanic representatives, 

the SFNF used a qualitative assessment of the potential for impacts on sites, landscapes, and 

other resources that may be important to those groups for traditional or religious uses (Forest 

Service 2016g). 

Indicators

Potential impacts on cultural resources could occur if anticipated future actions, consistent with 

implementing the alternatives described in Chapter 2, were to have any of the following 

impacts: 
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3-130 Santa Fe National Forest Geothermal Leasing EIS

 Conflict with Forest Service goals and objectives to inventory, protect, evaluate, nominate to 

the NRHP, interpret, and enhance cultural resources

 Result in uses that are incompatible or that interfere with maintaining cultural resources and 

their qualities or TCPs, practices, and uses

 Result in an adverse effect on historic properties under Section 106 of the NHPA

Impacts on cultural resources occur when there is damage or loss of cultural resources or their 

settings. Impacts on cultural resources are assessed by applying the NHPA criteria of adverse 

effect, as defined in the implementing regulations for Section 106 of the NHPA (36 CFR, Part 

800). 

An adverse effect is found when an action may alter the characteristics of a historic property that 

qualify it for inclusion on the NRHP, in a manner that would diminish the integrity of the 

property’s location, design, setting, workmanship, feeling, or association. Adverse effects may 

include reasonably foreseeable impacts caused by the action that may occur later in time, be 

farther removed in distance, or be cumulative (36 CFR, Subpart 800.5). 

Additionally, focused consultation with the affected group is required to assess impacts involving 

contemporary pueblo, tribal, or other traditional community’s cultural or religious practices, 

resources, or areas. Impact analysis would be informed by ongoing consultation with 

communities with interests in the SFNF and focused consultation for subsequent actions and 

decisions (Forest Service 2016g). Some pueblo representatives have indicated that any form of 

geothermal leasing anywhere in the project area would have a disproportionately high and 

adverse environmental effect on their communities. This effect could not be mitigated, because 

of the nature of those environmental justice impacts (see Appendix F, Summary of Public 

Comments).

For the purposes of this analysis, indicators for determining impacts on cultural resources are to 

ask if the action would have any of the following impacts:

 Cause physical destruction or damage to all or part of the property

 Alter a property in a manner that is not consistent with the Secretary of the Interior’s 

standards for the treatment of historic properties (36 CFR, Part 68) and applicable guidelines

 Remove the property from its historic location

 Change the character of the property’s use or physical features in its setting that contribute to 

its historic significance, such as isolating the property from its setting

 Introduce visual, atmospheric, or audible elements that diminish the integrity of the 

property’s significant historic features

 Neglect a property, which causes its deterioration, except where such neglect and 

deterioration are recognized qualities of a property of religious and cultural significance to 

an Indian tribe

 Disturb any human remains, including those interred outside of formal cemeteries

Under the NHPA, any of the above indicators would contribute to an adverse effect on a cultural 

resource if it were listed on or eligible for listing on the NRHP, or if it were an area of 

importance to Native American tribes, pueblos, or other traditional communities.

Impacts can be direct or indirect. In practice, a direct impact would be limited to the direct 

physical disturbance of a historic property, such as destroying the property for facility or access 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-131

construction. Indirect impacts would be visual or audible intrusion as a result of the project being 

built or the increased risk of looting as a result of better access and increased visitation to the 

area.

Impacts on cultural resources are typically considered permanent and any disturbance, 

particularly of archaeological sites, cannot be reversed. However, impacts on the historic 

landscape or the viewsheds of historic or other culturally significant areas can be temporary, if 

projects do not permanently impact associated resources and are removed at a future date.

Adverse effects may be resolved or reduced through avoidance and other measures that the 

applicant would implement, in coordination with the Forest Service and the BLM. 

Assumptions

This analysis assumes the following:

 Neither this programmatic geothermal leasing analysis nor the consent to lease specific 

parcels following the Forest Plan Amendment are considered to be undertakings that could

adversely affect historic properties under the NHPA; no further Section 106 review is 

required until authorization of surface-disturbing activities is proposed.

 There would be no direct impacts from any of the alternatives, because consent to leasing 

would not disturb the ground. Future geothermal development phases involving ground 

disturbance would be subject to additional analyses under NEPA and the NHPA, and any 

adverse effects from such actions would be identified at that time.

 Cultural resource protection and avoidance measures apply to all proposed federal or 

federally assisted undertakings by the Forest Service and to leases granted by the BLM. 

 Several decision stages would occur before any ground-disturbing activities and would 

include further compliance with applicable authorities. If leasing were approved, the Forest 

Service and the BLM would complete steps to meet cultural resource legal and procedural 

requirements before development begins, as outlined in the Section 106 process and the 

Region 3 Programmatic Agreement (Forest Service 2003). These include consultation with 

the New Mexico SHPO and Native American tribes, pueblos, or other traditional 

communities. Determination of effects and resolution of adverse effects must be completed 

before surface-disturbing activities are authorized.

 The number of sites that could be affected by actions correlates with the degree, nature, 

depth, and quantity of surface-disturbing activities in the project area and the cultural 

sensitivity of the area.

 The information on cultural resources in the project area is based on the results of industry 

and Forest Service inventory projects and depicts the relative potential for cultural resource 

sites. However, these data are geographically biased toward past project-oriented 

undertakings and cannot accurately predict where and how many resources may exist in 

unsurveyed areas. 

 Likewise, the presence and significance of sites, landscapes, and other resources that may be 

important to contemporary pueblo, tribal, and Hispanic groups for traditional or religious 

uses may not be readily identifiable outside of those communities; however, some pueblo 

representatives assert that entire project area and the Jemez Mountains are a living place of 

active worship that would be impacted by any geothermal resource development (see 

Appendix F, Summary of Public Comments).
Chapter 3. Affected Environment and Environmental Consequences

3-132 Santa Fe National Forest Geothermal Leasing EIS

 Cultural resource inventories, either federal undertakings or related programs, would result 

in the continued identification of cultural resources. The cultural resource data acquired 

through these inventories and evaluations would increase overall knowledge and 

understanding of the distribution of cultural resources in the region.

3.15.2.3 Common Impacts Associated with Geothermal Development

The nature and characteristics of the direct and indirect impacts on cultural resources from 

geothermal development would be the same as those described in the 2008 Geothermal PEIS

(BLM and Forest Service 2008, pp. 4-106 to 4-108). These are incorporated by reference and 

summarized here. The PEIS describes common impacts on cultural resources associated with 

exploration, drilling, utilization, reclamation, and abandonment. 

Any activities that would involve surface-disturbing activities would have direct and indirect 

impacts on cultural resources, including damaging, destroying, or displacing artifacts and 

features and building modern features out of character with a historic setting. Damaging, 

displacing, or destroying cultural resources could include removing artifacts from their 

situational context, breaking artifacts, or shifting, obliterating, or excavating features without 

appropriately recording them. 

Indirect impacts on cultural resources would include changing the character of a property’s use 

or physical features in its setting that contribute to its historic significance (such as isolating the 

property from its setting) and introducing visual, atmospheric, or audible elements that diminish 

the integrity of its historic features. The geothermal plants, well pads, and associated facilities 

would be modern features in a landscape that did not have them previously, thereby juxtaposing 

modern industrial features onto a historic landscape. Additionally, with the increased human 

presence of site workers during all phases of geothermal development, there is the risk of illicit 

collection of surface artifacts, resulting in a loss of scientific information.

The potential for undiscovered buried cultural resources and human remains exists, despite 

previous archaeological surveys and investigations. Surface-disturbing activities would directly 

impact undiscovered cultural resources and human remains by exposing buried material, 

resulting in inadvertent artifact destruction or loss of scientific context. Indirect impacts could 

result from the increased presence of site workers, leading to possible illicit collection of newly 

exposed materials.

Final reclamation of geothermal developments would eliminate the indirect viewshed or setting 

impacts for cultural resources. With reclamation, the natural and historic setting would be 

restored. Similar to impacts during earlier phases, the potential for undiscovered buried cultural 

materials or human remains continues to exist through reclamation and abandonment. 

Abandonment may expose buried materials, resulting in inadvertent artifact destruction or loss of 

scientific context; additionally, the increased presence of site employees may lead to illicit 

collection of exposed materials.

3.15.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. The level of anticipated geothermal leasing and development is 

assumed to be consistent with the RFDS. If geothermal lease applications and nominations are 

received, they would be processed and evaluated on a case-by-case basis under separate NEPA

and NHPA analyses, in accordance with the Forest Plan and existing laws and regulations. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-133

Potential direct and indirect impacts from subsequent geothermal development phases would be 

the same as those described for Common Impacts Associated with Geothermal Development.

Because there would be site-specific analysis, potential impacts on cultural resources and their 

settings could be avoided or reduced, but there would be no additional established stipulations 

for surface use that may incidentally reduce impact potential on cultural resources. The JNRA is 

excluded from geothermal leasing on the basis of existing laws, regulations, and executive 

orders. There would continue to be no leasing in the JNRA and thus no impacts on cultural 

resources from subsequent geothermal development phases. 

3.15.2.5 Impacts Under Alternative 2

Under Alternative 2, the SFNF would identify lands as being closed to geothermal leasing under 

either nondiscretionary or discretionary authorities, or open to geothermal leasing, with TL, 

CSU, and NSO stipulations. Compared with Alternative 1, Alternative 2 provides standard 

stipulations and consideration for resource protection and other uses for the project area for 

geothermal leasing, consistent with forest goals and objectives. There would still be site-specific 

consideration of impacts on cultural resources and their settings for each phase of geothermal 

development. 

Alternative 2 includes NSO stipulations for areas with important cultural resources and their 

settings, including archaeological resources, TCPs, sacred sites, and NRHP-eligible and listed 

properties. Because of this, the potential for impact on cultural resources from subsequent 

geothermal development would be reduced. Additional established stipulations for other surface 

uses may incidentally reduce the impact potential on cultural resources. There are 1,567 known 

sites that would be included in land with NSO stipulations under Alternative 2. 

3.15.2.6 Impacts Under Alternative 3

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. Because there 

would be no leasing and no subsequent development, there would be no impacts on cultural 

resources and their settings. 

3.15.2.7 Impacts Under Alternative 4

Under Alternative 4, the SFNF would not identify lands as being closed to geothermal leasing

under discretionary authorities. Lands would be identified as open to geothermal leasing with 

TL, CSU, and NSO stipulations. Compared with Alternative 1, Alternative 4 provides standard 

stipulations and consideration for resource protection and other uses for the project area for 

geothermal leasing, consistent with forest goals and objectives. There would still be site-specific 

consideration of impacts on cultural resources and their settings for each phase of geothermal 

development. 

Alternative 4 includes NSO stipulations for areas with important cultural resources and their 

settings, including archaeological resources, TCPs, sacred sites, NRHP-eligible and listed 

properties. Because of this, the potential for impacts on cultural resources from geothermal 

development would be reduced. Additional established stipulations for other surface uses may 

incidentally reduce the impact potential on cultural resources. There are 1,522 known sites that 

would be included in land with NSO stipulations under Alternative 4.
Chapter 3. Affected Environment and Environmental Consequences

3-134 Santa Fe National Forest Geothermal Leasing EIS

3.15.2.8 Cumulative Impacts

Cumulative impacts on cultural resource are analyzed at the landscape scale for the project area. 

Past, present, and reasonably foreseeable future actions are those that would increase surface 

disturbance in the project area, potentially affecting cultural resources. These are the following:

 Pueblo of Jemez Red Rocks Dam Repair

 Abiquiu Land Grant Waterline Replacement

 McKinney County Dam

 South Pit Pumice Mine Expansion

 Duran 2010 Pumice Mine

 Southwest Jemez Mountains Restoration Project

 Cerro Pelon Timber Stand and Wildlife Habitat Improvement Project

 Pueblo of Jemez Owl Springs Bridge Sediment Removal Project

 New Mexico Meadow Jumping Mouse Critical Habitat Protection Project

Those that are in the project area have now or will have cultural resource compliance actions 

through the Section 106 process and the Region 3 Programmatic Agreement. These would seek 

to avoid or reduce the potential for adverse effects on cultural resources. The full RFDS under 

Alternatives 1, 2, and 4 may impact cultural resources and their settings, but impacts would be 

reduced through the Section 106 process and the stipulations that would be implemented. The 

contributions to direct cumulative impacts would be minor, relative to the project area, although, 

depending on siting, the indirect impacts on setting and cultural landscapes may be moderate. 

There would be no contributions to cumulative impacts under Alternative 3.

3.16 Tribal Interests and Traditional Cultural Resources

Tribal interests include economic rights, such as Indian trust assets, and resource uses and access 

guaranteed by treaty, agreements, or legislation. Traditional cultural resources include areas of 

cultural importance to contemporary communities, such as sacred sites or resource gathering 

areas. 

As discussed in Section 3.15, Cultural Resources, places that are important in maintaining 

community traditions or culturally important activities can also be recognized as eligible for 

listing on the NRHP as TCPs. 

While most commonly considered in the context of Native American tribes and pueblos, there 

are traditional cultural resources associated with other ethnic or socially linked groups in the 

Jemez Mountains and project area, such as Hispanic land grants and communities. Although the 

SFNF does not have decision concurrence authority over leasing on Indian reservations, there are 

tribal and other traditional uses of Forest Service lands that could be impacted from subsequent 

phases of geothermal exploration, drilling operations, utilization, and reclamation and 

abandonment. Adjacent or nearby reservation land and land grants may also be impacted by 

these actions. When planning any proposed project or action, the agencies must ensure that all 

anticipated impacts on Indian lands, trust resources, and treaty rights are addressed in the 

planning, decision, and operational documents prepared for each project. Federal agencies must 

ensure that meaningful consultation and coordination are conducted on a government-togovernment basis with federally recognized tribes.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-135

The trust responsibility is the US government’s permanent legal obligation to exercise statutory 

and other legal authorities to protect tribal lands, assets, resources, and treaty rights, as well as a 

duty to carry out the mandates of federal law with respect to Native American tribes. Treaties are 

negotiated contracts made pursuant to the US Constitution and take precedence over any 

conflicting state laws because of the Constitution’s supremacy clause (Article 6, Clause 2). 

Other sources of defined reciprocal rights and obligations assumed by the federal government 

and Indian tribes are congressional and executive branch actions to acquire or repatriate Indian 

lands, establish reservations, provide federal recognition of tribes, and remove Indian peoples to 

reservations. 

Communities often view these rights and resource uses as interconnected with culture, tradition, 

and spiritual practice. Among many groups, land, water, geologic features, landscapes, and other 

seemingly inanimate objects are considered sacred. Examples of traditional cultural resources are

natural landscape features, ceremonial and worship places, plant gathering locations, traditional 

hunting and fishing locations, ancestral archaeological sites, artisan material locations, rock art,

and communal resources, such as community-maintained irrigation systems. 

While many traditional cultural resources are known, many locations or resources may be 

privileged information that is restricted to specific practitioners or clans. For tribes, maintaining 

confidentiality and customs regarding traditional knowledge may take precedence over 

identifying and evaluating these resources, unless they are in imminent danger of damage or 

destruction. 

3.16.1 Affected Environment

3.16.1.1 Overview

Native American occupation and use of the lands of the Jemez Mountains for thousands of years 

is well documented in the archaeological record and by oral traditions. Patterns of occupation 

and use changed through time, ranging from small, highly mobile bands following the seasons 

and resources to small and large permanent and semipermanent communities, defensive sites,

and agricultural fields (PaleoWest 2016). During the Spanish contact and early colonization 

period (1540-1610), the majority of puebloan villages were located near the junction of the Rio 

Grande and Rio Chama, along the Rio Grande, and along the Jemez River. Still, artifacts and 

faunal and botanical data clearly show that the mountains continued to be visited for hunting, 

gathering, raw material procurement, and field house-based high altitude farming. 

Spanish colonization of New Mexico brought the alien concept of landownership to the pueblo 

world that conflicted with native concepts of movement across the land, seasonal lowlandupland migrations, and religious associations with landscape and water features. 

From 1609 to 1680, the Spaniards developed New Mexico through a system of religious 

missions, military presidios, the feudal system of encomiendas, and agricultural land grants. In 

theory, the Spanish Crown issued patents or grants for lands to native communities, which 

colonial officials were then charged with protecting from adverse activities by Hispano settlers. 

The problem of settler encroachment on Indian fields, disenfranchisement of native lands, and 

abuse by colonists was a universal one under Spanish and later Mexican rule. Mexico honored 

the land grants already established by the Spanish Crown for both pueblo people and Hispanic 

settlers, but it also created a system for establishing new immigrant settlements of Europeans and 

Americans who would become Mexican citizens. Those outside influences and new trade 
Chapter 3. Affected Environment and Environmental Consequences

3-136 Santa Fe National Forest Geothermal Leasing EIS

through the Santa Fe Trail caused more American occupation of Mexican territory, leading to the 

US-Mexican War of 1846-1848.

The war ended with the Treaty of Guadalupe Hidalgo. The treaty also affirmed established land 

grants, but in practice it failed in most cases to protect them. Some land grants have been 

incorporated into the SFNF. There is a long subsequent history of congressional and Executive 

Branch actions and litigation regarding land grants, reservation boundaries, sovereignty, and 

tribal rights that continue to the present (Forest Service 2016g). 

3.16.1.2 Resources

The SFNF regularly consults on a government-to-government basis with federally recognized 

tribes and engages with communities on the impacts of their actions and programs. In support of 

this EIS and Southwest Jemez Mountains Landscape Restoration Project, the SFNF consulted 

with descendants of Native American and Hispanic land grant recipients, who had occupied 

portions of the Jemez Mountains and adjacent areas prehistorically and historically and 

maintained traditional cultural resources and practices associated with those resources. 

The Forest Service contracted an ethnographic overview and assessment of traditional and 

current land uses by Native American and other communities. The intent is to identify traditional 

uses across the Jemez Mountains at the landscape level, but not to single out specific locations or 

traditional cultural resources, unless their significance to landscape-scale planning is appropriate 

and necessary. A general review of this outreach and preliminary results is provided in a public 

summary (Forest Service 2016g).

The SFNF determined the following Native American communities could be directly affected by 

future projects either because they are adjacent to Forest lands or have long-term documented 

intensive use of the Jemez Mountains: Pueblo of Jemez, Pueblo of Zia, Kewa Pueblo (Pueblo of 

Santo Domingo), Pueblo of Santa Ana, Pueblo of Cochití, Ohkay Owingeh, Pueblo of Santa 

Clara, Pueblo de San Ildefonso, Pueblo of Nambé, Pueblo of Pojoaque, Pueblo of Tesuque, 

Pueblo of San Felipe, Jicarilla Apache Tribe, and the Navajo Nation. It is understood that many

other tribes have had associations with the Jemez Mountains, either through inter-tribal 

relationships or more sporadic occupation of lands or resource use. 

Land grants recognized as units of government include the Abiquiu Land Grant and the San 

Joaquin del Rio de Chama Grant. Land grants incorporated into the SFNF include the Polvadera 

Grant, Juan Jose Lobato Grant, Ojo de San Jose Grant, Cañon de San Diego Grant, and Baca 

Location No. 1 Grant. The ethnographic studies, interviews and consultation with these 

communities broadly identified traditional use areas, significant plant and animal resources, 

mineral resources, visual resources, and traditional community perspectives on direct and 

indirect impacts of geothermal leasing and landscape restoration on those resources. 

Ongoing consultation with representatives of the pueblos and tribes indicated that the Jemez 

Mountains are important as a sacred place, as a sacred landscape, or as a historic landscape. 

Within the Jemez Mountains are subregions (based primarily on topography) that were discussed 

regarding specific concerns. Many landforms and locations have defined place names and are 

described in the oral traditions of the pueblo and Hispanic people. Areas of concern relate to high 

peaks that may contain shrines and campsites near the shrines, trails for access and ceremonies 

that extend variously through the Jemez Mountains or within these sub-regions, high areas, such 

as alpine meadows for plant collecting, ancestral sites and cultural resources, and springs that 

provide water for ceremonies, consumption, and supply water for grazing allotments and farming
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-137

(Forest Service 2016g). General areas of concern as traditional use areas are known, but specific 

locations of traditional cultural resources, plant gathering areas, and other important locations are 

not revealed; however, some pueblo representatives assert that the entire project area and the 

Jemez Mountains are a living place of active worship that would be impacted by any geothermal 

resource development (see Appendix F, Summary of Public Comments).

Continued forest management practices were encouraged to attain healthy, stable forest 

environments, but practices should include sensitive consideration of the cultural heritage 

associations and traditional uses of the areas by those who were consulted and those who choose 

to not discuss their particular interests or resources. Communities fear that geothermal energy 

development will have devastating impacts on the area, including impacting the availability of 

water resources and the quality of water and effects on other resources that are important for

their heritage and ceremonies. 

In general, the representatives of the groups interviewed were not in favor of geothermal energy 

development, or they expressed concerns about the impacts on water quality and availability. 

Native American and Hispanic groups are also interested in recovering ownership of lands that 

were part of their original land base and, therefore, would be concerned about committing lands 

to other uses (Forest Service 2016g). Some pueblo representatives have indicated that any form 

of geothermal leasing anywhere in the project area would result in impacts that would cause a 

disproportionately high and adverse environmental effect on their communities. The 

representatives stated that this effect could not be mitigated, because of the nature of those 

environmental justice impacts (see Appendix F, Summary of Public Comments).

The All Pueblos Council of Governors adopted a resolution on August 10, 2015, unanimously

supporting closing the SFNF to energy and mineral exploration and development. The Council 

also requested that the Forest Service withhold any consent to the BLM for leasing of any of the 

SFNF for geothermal and other mineral or energy exploration, leasing, or development and 

expressed the Council’s support for the designation of the Jemez Mountains as a TCP. The 

resolution requests that meetings be held to inform and consult with pueblo leadership regarding 

this proposal (All Pueblo Council of Governors 2015).

3.16.2 Environmental Consequences

3.16.2.1 Scoping Comments on Resource

The following issues specific to tribal interests and traditional cultural resources were identified 

during the public scoping period:

 How would TCPs and tribal interests be affected by geothermal leasing, including those in 

confidential locations, and how would those impacts be managed? What are the direct, 

indirect, and cumulative impacts of other resource impacts on tribal interests?

Method

Consent to leasing and leasing decisions do not grant any rights or authorize any activities that 

would directly affect tribal interests and traditional cultural resources. However, issuing 

geothermal leases confers on the lessee a right to future exploration and development of 

geothermal resources in the lease area. Thus, it is a conditional commitment or granting of a 

right that may interfere with other uses or interests, such as land-into-trust applications by tribes 

or acquisition of ancestral land base or resources. 
Chapter 3. Affected Environment and Environmental Consequences

3-138 Santa Fe National Forest Geothermal Leasing EIS

The impact analysis focuses on the potential future actions and potential for direct impacts or 

disturbances, based on the RFDS and the implementation of the alternatives described in 

Chapter 2. In all cases, before any ground disturbance or other future actions, further decisionmaking would be required. Examples are NEPA, NHPA compliance, and meaningful 

consultation and coordination with affected communities, on a government-to-government basis,

with federally recognized tribes and pueblos.

As described above, the SFNF regularly consults with Native American groups and other 

traditional communities on its activities and is conducting a landscape-scale study of past and 

present uses of the Jemez Mountains in support of this EIS and other actions. This work for each 

of the tribal groups and land grants includes ethnographic archival research and interviews to 

define and provide a more holistic understanding of tribal interests and the range and variety of 

traditional cultural resources and uses of the Jemez Mountains. The identification is at an 

appropriate level for determining the impacts of leasing consent. Laws, regulations, and policies 

pertinent to determining impacts on tribal interests and resources were considered and included 

in the impact criteria. 

A qualitative assessment is used to assess the potential for impacts on sites, landscapes, and other 

resources that may be important to contemporary pueblo, tribal, and Hispanic groups for 

traditional or religious uses, based on ongoing consultation with these groups. Locally sensitive 

areas and resources may be known from previous consultation and resource identification efforts. 

However, affected groups may not wish to enter into direct consultation or may prefer not to 

discuss specific traditional use areas or sacred sites until development plans are proposed and 

there is a perception that interests or resources would be threatened.

Indicators

Impacts on tribal interests or traditional and heritage resources could occur if anticipated future 

actions consistent with implementing the alternatives were to result in the following:

 Conflict with land uses, management, and economic well-being of adjacent or nearby 

reservations, trust lands, restricted Indian allotments, and tribal-dependent Indian 

communities

 Conflict with the exercising of off-reservation treaty and reserved rights and agreements,

including grazing rights, hunting and fishing rights, gathering rights and interests, and water 

rights

 Conflict with federal trust responsibilities to tribes and pueblos regarding real property, 

physical assets, or intangible property rights

 Conflict with existing court decisions, laws, policies, executive orders, and agency 

agreements with tribes and land grant communities regarding land and resource use

 Result in proposed uses that are incompatible with maintaining and identifying cultural 

resources and their qualities

 Have an adverse effect on TCPs and cultural landscapes under Section 106 of the NHPA (36 

CFR, Part 800)

 Impact or restrict access to traditionally used hunting, fishing, and gathering areas and 

species

 Change or reduce access to traditionally used or culturally important water sources and hot 

springs

 Impact culturally important trails or trail systems
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-139

 Impact sacred sites or their settings, access, or use

Assumptions

This analysis assumes the following:

 Areas proposed for leasing would likely include lands and specific locations where there are 

tribal interests and traditional cultural resources that are not currently identified.

 The SFNF would continue to coordinate and consult with pueblo, tribal, and affected 

communities to identify issues and concerns during all phases of geothermal leasing and 

development and to avoid impacts on traditional cultural resources and tribal interests.

 Some Native American tribes or pueblos and land grant communities may be interested in 

recovering ownership of lands or specific resource locations that were part of their original 

land base and, therefore, would be concerned about committing lands to other uses.

 The Jemez Mountains and the project area in its entirety have been characterized as a sacred 

place, as a sacred landscape, or as a historic landscape. Disturbing the land for exploration, 

drilling operations, use of geothermal resources, and reclamation and abandonment may be 

considered an adverse impact that could not be avoided or minimized.

 There may be unidentified conflicts with existing rights or claims of ownership related to hot 

springs and water sources.

3.16.2.2 Common Impacts Associated with Geothermal Development

The nature and characteristics of the impacts on tribal interests and traditional cultural resources 

and uses associated with geothermal development would be the similar to those described in the 

2008 Geothermal PEIS (BLM and Forest Service 2008, pp. 4-114 to 4-117). These are

incorporated by reference and summarized here. 

The PEIS describes common impacts on tribal interests and traditional cultural resources and 

uses associated with exploration, drilling operations, utilization, and reclamation and 

abandonment.

Types of impacts that could occur from exploration, drilling operations, utilization, and 

reclamation and abandonment are direct disturbance of locations or landscapes associated with 

traditional beliefs, resource gathering areas, hunting and fishing areas, water sources, hot 

springs, ancestral sites, human remains, and trails. Other impacts could result from alterations of 

visual and aural aspects of the cultural landscape’s setting, both on the lease site and in adjacent 

areas; increased access and site workers, which could lead to increased incidents of vandalism

and unauthorized collection of ancestral sites; decreased tribal member access or interference 

with the exercise of rights or cultural uses and practices, such as resource gathering or hunting; 

and the potential for erosion, pollution, habitat loss, and less tangible changes to natural features 

and resources that tribal members may consider sacred. 

Pueblo representatives have asserted that geothermal resource drilling of any kind would 

diminish the integrity and traditional power and quality of various TCPs found throughout the 

entire project area. Furthermore, drilling would adversely affect traditional cultural practices and 

uses (see Appendix F, Summary of Public Comments).

Exploration, drilling operations, and utilization in or around hot spring sources may impact 

traditional resources and could impact other tribal interests. Impacts could include loss of access, 

interference with use, and changes to hot springs. Since the thermal water in these springs may 
Chapter 3. Affected Environment and Environmental Consequences

3-140 Santa Fe National Forest Geothermal Leasing EIS

be considered sacred, there is a potential for loss of sacred sites and the healing energy and 

power they provide to the tribal users who value them. 

While visual and aural settings and some habitats may be restored, some impacts on cultural uses

or sacred sites may be impossible to avoid, restore or mitigate.

3.16.2.3 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. The level of anticipated geothermal leasing and development is 

assumed to be consistent with the RFDS. If geothermal lease applications and nominations are 

received, they would be processed and evaluated on a case-by-case basis under separate NEPA

and NHPA analyses, in accordance with the Forest Plan and existing laws and regulations. 

Potential direct and indirect impacts from subsequent geothermal development phases would be 

the same as those described for common impacts associated with geothermal development.

Because there would be site-specific analysis and consultation, potential impacts could be 

avoided or reduced, but there would be no additional established stipulations for surface use that 

may incidentally reduce impact potential on tribal interests and traditional cultural resources and 

uses. 

Tribes may consider disturbance of the land or use of geothermal resources as an adverse impact

that could not be avoided or minimized. The JNRA is excluded from geothermal leasing on the 

basis of existing laws, regulations, and executive orders. There would continue to be no leasing 

in the JNRA and thus no impacts anticipated from subsequent geothermal development phases.

3.16.2.4 Impacts Under Alternative 2

Under Alternative 2, the SFNF would identify lands as being closed to geothermal leasing under 

either nondiscretionary or discretionary authorities or open to geothermal leasing with TLs and 

CSU stipulations and NSO stipulations. Compared with Alternative 1, Alternative 2 provides 

standard stipulations and consideration for resource protection and other uses for the project area 

for geothermal leasing, consistent with forest goals and objectives. There would be NSO 

stipulations for TCPs and Native American sacred sites, as identified through consultation. There 

would still be site-specific consideration of impacts on tribal interests and traditional cultural 

resources and uses and their settings for each phase of geothermal development. 

Because Alternative 2 includes NSO stipulations for areas with important cultural resources and 

their settings (archaeological resources, TCPs, sacred sites, and NRHP-eligible and listed 

properties), the potential for impact from subsequent geothermal development would be reduced.

Tribes may consider disturbance of the land or use of geothermal resources as an adverse that 

could not be avoided or minimized. Additional established stipulations for other surface uses 

(i.e., habitat and visual protections) may incidentally reduce the impact potential on traditional 

cultural resources, cultural landscapes, and their settings.

3.16.2.5 Impacts Under Alternative 3

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. Because there 

would be no leasing and no subsequent development, no new impacts are anticipated. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-141

3.16.2.6 Impacts Under Alternative 4

Under Alternative 4, the SFNF would not identify lands as being closed to geothermal leasing

under discretionary authorities. Lands would be identified as open to geothermal leasing with 

TLs and CSU stipulations and NSO stipulations. Compared with Alternative 1, Alternative 4 

provides standard stipulations and consideration for resource protection and other uses for the 

project area for geothermal leasing, consistent with forest goals and objectives. There would be 

NSO stipulations for TCPs and Native American sacred sites, as identified through consultation. 

There would still be site-specific consideration of impacts and consultation for each phase of 

geothermal development. 

Alternative 4 includes NSO stipulations for areas with important cultural resources and their 

settings, including archaeological resources, TCPs, sacred sites, NRHP-eligible and listed 

properties. Because of this, the potential for impact on cultural resources from subsequent 

geothermal development would be reduced. Tribes may consider disturbance of the land or use 

of geothermal resources as an adverse impact that could not be avoided or minimized. Additional 

established stipulations for other surface uses (i.e., habitat and visual protections) may 

incidentally reduce the impact potential on traditional cultural resources, cultural landscapes, and 

their settings. 

3.16.2.7 Cumulative Impacts

Cumulative impacts on tribal interests and traditional cultural resources and uses are analyzed at 

the landscape scale for the project area. Past, present, and reasonably foreseeable future actions 

include those that would increase surface disturbance in the project area, potentially affecting 

cultural resources. These include Pueblo of Jemez Red Rocks Dam Repair, the Abiquiu Land 

Grant Waterline Replacement, the McKinney County Dam, South Pit Pumice Mine Expansion, 

the Duran 2010 Pumice Mine, the Southwest Jemez Mountains Restoration Project, the Cerro 

Pelon Timber Stand and Wildlife Habitat Improvement Project, Pueblo of Jemez Owl Springs 

Bridge Sediment Removal Project, and the New Mexico Meadow Jumping Mouse Critical 

Habitat Protection Project. 

Each of these that is in the project area has or will have cultural resource compliance actions and 

site-specific consultation, which would seek to identify tribal interests and traditional cultural 

resources and avoid or reduce the potential for adverse impacts. Tribes may consider disturbance 

of the land or use of geothermal resources as an adverse impact that could not be avoided or 

minimized. The full RFDS under Alternatives 1, 2, and 4 may impact traditional cultural 

resources and their settings, but impacts would be reduced through the Section 106 process and 

the stipulations that would be implemented. The contributions to direct cumulative impacts 

would be minor to major, relative to the project area. This would depend on the perspective of 

consulting parties on the impacts on tribal interests and traditional cultural resources. There 

would be no contributions to cumulative impacts from Alternative 3.

3.17 Visual Resources

3.17.1 Affected Environment

The landscape in the decision area is characterized primarily by montane woodlands and 

meadows, but also includes canyons and rock outcrops in the southwest portion of the decision 

area near Jemez Springs and surrounding areas. Elevation ranges from about 6,300 feet to 10,000 

feet.
Chapter 3. Affected Environment and Environmental Consequences

3-142 Santa Fe National Forest Geothermal Leasing EIS

The Forest Service manages visual resources according to the Scenery Management System. The 

Scenery Management System is described in the IRAs report for this project (Forest Service 

2016a).

Table 3-21, below, and Figure 3-4, Scenic Integrity, shows the acres of lands in the decision 

area by each scenic integrity degree.

Table 3-21. Scenic Integrity

Scenic Integrity Acres

Very high 3,700

High 93,000

Moderate 67,800

Low 3,800

Very low 300

Source: Forest Service GIS 2015

3.17.1.1 Night Skies

The Forest Service does not manage lands specifically for preserving dark night skies. However, 

lands adjacent to the project area are managed by the NPS, and the NPS is mandated to preserve, 

to the greatest extent possible, the natural lightscapes of the parks, which are natural resources 

and values that exist in the absence of human-caused light (NPS 2006b). Therefore, the affected 

environment for night skies adjacent to the project area is discussed below in order to provide a 

comprehensive cumulative analysis.

The natural lightscape plays a role in natural resource processes and affects biological behavior, 

as well as being a feature that contributes to visitor experience. The VCNP’s high elevation, 

excellent air quality, low population density, and frequent cloud-free weather afford world-class 

viewing and enjoyment of naturally dark, star-filled skies. The unfettered view of the Milky Way, 

planets, meteors, and galaxies is increasingly becoming a major reason for many to visit the 

park. 

Although night sky measurements have not yet been made at VCNP, they have been made at a 

nearby Bandelier National Monument fire tower, located approximately 6 miles east of the 

project area boundary. Light is evaluated through Lux. Lux is the unit of light measurement 

taking area into consideration (i.e., light intensity). Table 3-22, Examples of Lux Measurements 

on a Given Surface, provides examples of lux pertaining to different origins of light illuminated 

on a surface. Measurements at the Bandelier National Monument fire tower in 2005 identified a 

maximum vertical illuminance of 1.11 millilux with an estimated artificial contribution of 0.44 

millilux. Measurements in 2006 identified a maximum vertical illuminance of 1.24 millilux with 

an estimated artificial contribution of 0.73 millilux (NPS 2005; 2006c). 

Dark sky conditions in the project area and the adjacent VCNP are likely to be similar to those 

recorded at the Bandelier National Monument fire tower. However, because factors that 

influence dark skies (e.g., distance populated areas, elevation, topography, and other sources of 

human-caused light), vary between the location of recorded measurements and the project area, 

overall maximum vertical illuminance and estimate artificial illuminance values may not be 

identical.
Figure 3-4 Santa Fe National Forest Geothermal Leasing EIS 3-143 Chapter 3. Affected Environment and Environmental Consequences
Chapter 3. Affected Environment and Environmental Consequences

3-144 Santa Fe National Forest Geothermal Leasing EIS

Table 3-22. Examples of Lux Measurements on a Given Surface

Illuminance Surfaces illuminated by:

0.0001 lux Moonless, overcast night sky (starlight)

0.0014 lux Venus at brightest

0.002 lux Moonless clear night sky with airglow

0.1 lux Quarter moon

0.27–1.0 lux Full moon on a clear night

3.4 lux Dark limit of civil twilight under a clear sky

Source: Schlyter 2006; Bunning and Ilse 1968

3.17.1.2 Adjacent Landscapes

Landscapes adjacent to the project area include undisturbed natural settings consisting of forest 

cover, volcanic landforms, and other geologic features. The VCNP is located adjacent to the 

project area, and important visitor use areas in the VCNP include the caldera rim and Redondo 

Peak. The viewshed from the caldera rim and Redondo Peak (for objects up to 35 meters in 

height) is shown in Figure 3-5, Redondo Peak and Caldera Rim Viewsheds. This viewshed 

covers approximately 119,300 acres (61 percent) in the project area, including lands not 

managed by the Forest Service.

3.17.2 Environmental Consequences

3.17.2.1 Scoping Comments on Resource

The following issues specific to visual resources were identified during the public scoping 

period:

 What are the visual impacts associated with geothermal leasing, including construction of 

transmission lines and water vapor from geothermal plants?

3.17.2.2 How Resource Impacts Were Evaluated

Method

The impact analysis for visual resources was based on review of existing baseline data for the 

project area as described under Section 3.17.1 and information gathered through scoping. To the 

extent practical, spatial data were used to compare environmental conditions with the 

alternatives. Various actions that might create changes to the basic landscape elements were 

considered in identifying potential impacts. The region of influence for direct and indirect 

impacts is the decision area.

Indicators

Potential impacts on visual resources could occur if reasonably foreseeable future actions were 

to:

 Have impacts on a scenic vista;

 Degrade the existing visual character or quality of the site and its surroundings;
Figure 3-5 Santa Fe National Forest Geothermal Leasing EIS 3-145 Chapter 3. Affected Environment and Environmental Consequences
Chapter 3. Affected Environment and Environmental Consequences

3-146 Santa Fe National Forest Geothermal Leasing EIS

 Create a new source of light or glare; or

 Be incompatible with the scenic integrity.

Assumptions

Receptors sensitive to disturbances of visual resources are varied and depend on the landscape’s 

visual resources; the project’s location; the view distance, angle, and duration; the location of 

travel routes; public areas of interest; the season; the topography; recreation activities; and the 

number of viewers. Because of this, it is important to note that site-specific impact assessment is 

needed to thoroughly assess impacts on visual resources from a particular project. Without 

precise information about a specific project, it is not possible to detail the visual impacts. 

However, by using the RFDS as a general description of expected geothermal resource

development activities, a generalized assessment of the possible impacts on visual resources can 

be made by describing the range of expected visual changes.

The assumptions for this analysis are:

 Other visual impact mitigation measures would likely be required at the project-specific 

phase of analysis and permitting; 

 Scenic resources will remain in demand on public lands;

 Any new surface-disturbing geothermal activities would be subject to further NEPA analysis, 

which would include an analysis to determine consistency with applicable visual resource

objectives.

 Geothermal infrastructure, such as transmission lines, power plants, and rig equipment, is 

not expected to exceed 115 feet (35 meters) in height. 

3.17.2.3 Common Impacts Associated with Geothermal Development

The common impacts associated with geothermal development are described in the Final 

Programmatic EIS for Geothermal Leasing in the Western United States (BLM and Forest 

Service 2008).

Additional impacts associated with light pollution and dark skies are discussed below. 

Light pollution, defined as stray unwanted light outside the range and timing of natural variation, 

is not only an ecological disrupter, but also may affect the natural scenery of the night. 

Light pollution has been documented over 200 miles from the light source (Chespesiuk 2009). 

The cumulative effect of multiple artificial light sources at varying distance brightens the sky 

background, drowning out stars and astronomical objects by contrast reduction, and increasing 

the luminance of the ground surface. Particularly dark night skies are most prone to a 

degradation of their scenic potential, showing a large reduction in the number of visible stars 

with a small amount of light pollution. Night skies already brightened by artificial light show a 

lessening degradation with each incremental increase in light pollution. Within this response 

function may be embedded thresholds whereupon certain species, ecological processes, or key 

scenic resources would be affected (Longcore and Rich 2004).

The degree of impact of artificial light is highly dependent on the distance and the type and 

brightness of the light fixture. Atmospheric characteristics such as humidity and particulates 

further influence the apparent effect of artificial light. Whether the light fixture is fully shielded 

is also important; fully shielded fixtures can greatly decrease the creation of both point and 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-147

diffuse source light pollution (Falchi et al. 2011). The perception of light pollution would vary 

from one location to another caused by differences in vegetation cover, sight lines and horizon 

visibility, and even the color of the ground. Atmosphere of greater clarity tends to amplify distant 

light sources and attenuate nearby light sources, while more humid and polluted air tends to 

amplify close light sources.

While there is a canopy layer of vegetation in most of the project area and adjacent NPS lands, 

subsequent geothermal development could increase the amount of artificial lighting and could 

increase the potential for skyglow into adjacent landscapes such as the VCNP. This is especially 

true for the horizon, the part of the sky in which lightscape impacts are first noted. Air quality

considerations can play a role in the context of lightscape impacts, because the presence of air 

pollution can increase light scattering. 

Distance is the most influential factor in determining skyglow, because the brightness of skyglow 

from a given light source decreases six times for every doubling of distance (point light sources 

decrease four times for every doubling of distance). The distance for lighting on a drill rig to 

diminish to the level equivalent to a clear moonless night with airglow on a surface—or 0.002 

lux—is approximately 10,000 feet, or 2 miles.

20

Light measurement data collected in April 2016 from a drilling rig near Big Thicket National 

Preserve, Texas, provided the basis for the extrapolation of collected data to define the distance 

of the affected environment. This survey data is representative of a typical drilling rig. Using this 

information, the strongest direction that light shone from the source was south with 1.3 lux at 

375 feet. Since this was the strongest light direction and the variability of the drill rig orientation 

can change on future well drilling projects, this direction was used to produce a radius that 

would show the largest distance light would travel from the source in any direction. The distance 

for lighting on a drill rig to diminish to the illumination of starlight and natural airglow on a 

clean moonless night (0.002 lux; Table 3-22), is approximately 10,000 feet, or 2 miles. This 

calculation assumes spatially isotropic illumination and light of sight conditions, with no 

scattering or reflection from aerosols, leaves, or other objects. This distance does not take 

anthropogenic and natural barriers, such as walls and vegetation, which would drastically reduce 

this distance.

21

3.17.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area, except for nondiscretionary closures (i.e., the JNRA). Geothermal 

lease applications and nominations would continue to be processed; however, they would be 

evaluated on a case-by-case basis under separate NEPA analysis, in accordance with the Forest 

Plan and existing laws and regulations. 

The JNRA would remain closed to geothermal leasing. Visual resources would be protected in 

this area.

In the remainder of the decision area, visual resources could be impacted from subsequent 

geothermal exploration and development. It is likely that some form of mitigation would be 

 

20 Randy Stanley, Natural Sounds and Night Skies Coordinator, NPS, letter to Forest Service regarding 

night skies. April 28, 2016.

21 Randy Stanley, Natural Sounds and Night Skies Coordinator, NPS, letter to Forest Service regarding 

night skies. April 28, 2016.
Chapter 3. Affected Environment and Environmental Consequences

3-148 Santa Fe National Forest Geothermal Leasing EIS

required in areas of very high or high scenic integrity. In addition, due to the generally greater 

visual variety of the landscape in these areas, some development can be more easily hidden from 

view of the casual observer. In moderate, low, and very low scenic integrity areas, new 

development may not be as easily hidden. However, areas with existing development may be 

able to absorb new development without much change in the overall landscape. 

Visual impacts could occur during each stage of geothermal resource development, as described 

below.

Exploration

Visual impacts would occur from the following:

 Vegetation damage or removal

 Drilling rigs, support equipment, and vehicles 

 Artificial lighting

Visual impacts from the approximately 27 acres of vegetation damage or removal would occur in 

areas where the surface is disturbed. Because exploration is limited in duration and relatively 

small in extent, visual impacts would generally be minor and short term. 

Drilling Operations and Utilization

Visual impacts would occur from the following: 

 Vegetation damage or removal 

 Construction 

 Alteration of natural landforms or contours

 New access roads

 Transmission lines

 Drilling rigs, support equipment, and vehicles

 Power plants

 Wells

 Well field equipment, such as pipeline infrastructure, and maintenance

 Artificial lighting

Visual impacts, including those from modifying the visual character of the landscape, would 

occur in areas in the estimated 647 acres of disturbed surface. Impacts from geothermal 

infrastructure, such as access roads, transmission lines, power plants, and well field equipment,

would be long term. 

Plugging and Final Reclamation

During the plugging the final reclamation phase, visual impacts would occur from activities 

involving reclamation and removal of surface structures and equipment; however, over time, 

regrading, recontouring, and reestablishing desirable vegetation would improve the visual 

character to more closely resemble pre-geothermal development conditions. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-149

3.17.2.5 Impacts Under Alternative 2

The JNRA would remain closed to geothermal leasing. An additional 10,400 acres would also be 

closed to geothermal leasing. Visual resources would be protected in these areas.

In addition to areas closed to leasing, 132,900 acres would be subject to NSO stipulations. This 

would preclude surface occupancy in these areas and visual resources would be preserved in the 

same way that areas closed to leasing would be protected. This includes all lands of very high 

scenic integrity.

The remaining 3,700 acres not either closed or subject to NSO stipulations are in the Lease 

Interest Unit and North Unit. High scenic integrity landscapes in this area would be subject to 

CSU stipulations. This stipulation would not prohibit development in the area, but development 

would need to take into consideration scenic values. The CSU stipulation would require that 

visual quality objectives be met within 5 years from project startup, reducing impacts on visual 

resources in the long term. While few existing modifications are in high scenic integrity 

landscapes, these landscapes generally have diverse topography, colors, and vegetation features 

that can be used to screen development from sight of the casual observer. 

Few areas (1,400 acres) are not subject to any stipulations. Where this occurs, the scenic 

integrity is either moderate or low. This means that the landscape character is slightly or 

moderately altered. Often these landscapes have less visual variety than areas with very high or 

high scenic integrity, making it more difficult to blend disturbances with the landscape, 

particularly where few are currently present. However, some level of disturbance that is 

noticeable to the casual observer is allowed in these areas.

The types of visual impacts at each stage of geothermal development would be the same as those 

described under Alternative 1. 

3.17.2.6 Impacts Under Alternative 3

Under Alternative 3, no leasing would be permitted. There would be no impacts associated with 

geothermal development and the characteristic landscape would be retained.

3.17.2.7 Impacts Under Alternative 4

The JNRA would remain closed to geothermal leasing. Visual resources would be protected in 

this area.

In addition to the JNRA, 122,500 acres would be subject to NSO stipulations. None of the NSO 

is specifically to protect visual resources. However, visual resources would be incidentally 

protected. The impacts would be the same as described under Alternative 2.

The remaining 17,200 acres not either closed or subject to NSO stipulations are in the Lease 

Interest Unit and North Unit. Very high and high scenic integrity landscapes in this area would 

be subject to CSU stipulations. Impacts would be the same as described under Alternative 2.

Few areas are not subject to any stipulations. Where this occurs, the scenic integrity is either 

moderate or low. Impacts would be the same as under Alternative 2, but over a slightly larger 

area as there would be more acres not subject to stipulations under this alternative.

The types of impacts at each stage of geothermal development would be the same as those 

described under Alternative 1. 
Chapter 3. Affected Environment and Environmental Consequences

3-150 Santa Fe National Forest Geothermal Leasing EIS

3.17.2.8 Cumulative Impacts

The region of influence for cumulative impacts is the viewshed of the decision area and adjacent 

landscapes.

Development of geothermal resources could result in cumulative impacts on visual resources

across the project area when combined with other projects. The heights, type, and color of 

drilling equipment and power plants, together with their placement with respect to local 

topography, are factors that would contribute to determining the extent of visual intrusion on the 

landscape. Also, the development of transmission lines to connect new electrical production 

facilities to the regional power grid could contribute to cumulative impacts. Stipulations for the 

protection of visual resources including areas with very high and high scenic integrity would 

minimize impacts on visual resources. 

Cumulative impacts on night skies and adjacent landscapes may occur. These impacts are 

described by alternative below.

Alternative 1

Night Skies

Under Alternative 1, geothermal exploration, drilling, and utilization as described in the RFDS

(BLM 2015) would result in new artificial light sources in the project area. These light sources

would likely increase the artificial contribution of skyglow in the project area, and potentially 

adjacent landscapes such as the VCNP, as described under Common Impacts Associated with 

Geothermal Development. The quantitative increase in artificial illuminance for adjacent 

lightscapes would ultimately depend on factors such as topography, the distance to VCNP, and 

vegetation cover. Wells within 2 miles of the VCNP boundary would be most likely to increase 

the artificial contribution of skyglow in the VCNP.

Adjacent Landscapes

Geothermal development under Alternative 1 may occur in the Redondo Peak and caldera rim 

viewsheds. Transmission lines and other geothermal infrastructure would likely be visible from 

portions of the VCNP. In general, visual impacts from well rigs would be short term, while 

visual impacts from powerplants, powerlines, and other utilization infrastructure would be long

term. Impacts on adjacent landscapes would be evaluated on a case-by-case basis. 

Alternative 2

Night Skies

Cumulative impacts on night skies would be similar to those described under Alternative 1. 

However, discretionary leasing closures and stipulations would limit areas of potential 

development near the VCNP boundary, as shown in Table 3-23, below.

Under Alternative 2, there would be no lands open to geothermal leasing, subject to standard 

lease terms and conditions, within a 2-mile buffer of NPS lands. Geothermal development could 

potentially occur within 2 miles of NPS lands, resulting in increased artificial lighting. However, 

implementing BMPs as described in Appendix C (such as topography and vegetation screening, 

and minimum lighting design) would reduce the likelihood of increasing skyglow in the project 

area and adjacent NPS lands. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-151

Table 3-23. Stipulations and Closures within a 1- and 2-mile Buffer of NPS Lands for Action 

Alternatives

Alternative 2 Alternative 3 Alternative 4

1 mile from NPS Lands

Decision Area Lands 23,700 23,700 23,700

Closed 9,500 23,700 8,300

NSO 14,200 0 13,800

CSU 8,900 0 13,700

TL 5,000 0 6,100

Open Subject to Standard 

Lease Terms and Conditions

0 0 100

2 miles from NPS Lands

Decision Area Lands 49,200 49,200 49,200

Closed 17,900 49,200 15,500

NSO 27,200 0 26,000

CSU 14,600 0 26,500

TL 9,300 0 11,600

Open Subject to Standard 

Lease Terms and Conditions

0 0 400

Source: Forest Service GIS 2015

Adjacent Landscapes

Geothermal development under Alternative 2 could potentially occur in the viewshed of the 

caldera rim and Redondo Peak. However, geothermal leasing closures and stipulations would 

restrict where development could occur, as shown in Table 3-24, below.

Table 3-24. Viewshed Acres from the Caldera Rim and Redondo Peak by Action Alternative1

Alternative 2 Alternative 3 Alternative 4

Decision Area Lands 111,300 111,300 111,300

Closed 28,800 111,300 25,900

NSO 80,000 0 73,200

CSU 48,000 0 74,000

TL 26,900 0 29,500

Open Subject to 

Standard Lease Terms 

and Conditions

1,100 0 3,100

Source: Forest Service GIS 2015; NPS GIS 2016

1Visibility of any objects up to 35 meters in height

Under Alternative 2, most decision area lands in the viewshed would be closed to leasing or NSO. 

Approximately 1,100 acres in the viewshed would be open to leasing, subject to standard lease 

terms and conditions. Geothermal developments such as wells, power plants, and powerlines may 

be visible from the caldera rim, Redondo Peak, and other landscapes adjacent to the project area, 
Chapter 3. Affected Environment and Environmental Consequences

3-152 Santa Fe National Forest Geothermal Leasing EIS

which may detract from the visual character of these areas. However, implementing BMPs

described in Appendix C would minimize the potential impacts on adjacent landscapes.

Alternative 3

There would be no cumulative impacts on visual resources under Alternative 3.

Alternative 4

Night Skies

Cumulative impacts on night skies would be similar to those described under Alternative 2. 

However, because there would be more acres open to leasing, subject to standard terms and 

conditions (approximately 400 acres) within a 2-mile buffer of NPS lands, there would be a 

greater potential for development near the NPS boundary and, therefore, a greater potential for 

increased skyglow in these areas. Because the location of geothermal developments is unknown, 

the magnitude of impacts is unknown. 

Adjacent Landscapes

Impacts on adjacent landscapes would be similar to those described under Alternative 2;

however, there would be an increased likelihood for development in this area and for viewing 

geothermal infrastructure from adjacent landscapes. This is because there would be more acres 

(approximately 3,100) open to leasing that would be subject to standard lease terms and 

conditions in the viewshed of Redondo Peak and the caldera rim.

3.18 Social Interests, Economics and Environmental Justice

3.18.1 Affected Environment

The construction and operation of geothermal power plants contributes to local, state, and 

national economies by creating jobs, generating property taxes, paying revenues, and making 

voluntary contributions to communities. The use of NFS lands in the project area for geothermal 

energy development affects the demographic characteristics and economies of the project area. 

Additionally, social structure and values in the project area shape the demand and opportunities 

created by NFS lands.

For these reasons, demographic, economic, and social data for the project area are presented in 

this section. Counties that fall within the project area were selected as the region of interest 

(ROI) for socioeconomic and environmental justice analysis because the impacts of leasing are 

likely to occur within this region. The ROI is Rio Arriba and Sandoval Counties. 

A summary of the population, housing, and low-income and minority populations for each county 

is provided, based primarily on data from US Census 2010 and 2014 population estimates, 

demographic and housing information from the US 2010 Census, and employment and industry 

information from the Bureau of Labor Statistics (BLS) and the Bureau of Economic Analysis.

3.18.1.1 Population

The project area is in Rio Arriba and Sandoval Counties. Rio Arriba is in north-central New 

Mexico, bordering Colorado to the north, Taos and Mora Counties to the east, Santa Fe, Los 

Alamos, and Sandoval Counties to the south, and San Juan County to the west. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-153

Rio Arriba County has a land area of 5,860.84 square miles and a population density of 6.9 persons 

per square mile, with a total population of 40,155 (US Census Bureau 2014). Population growth is 

expected to be slow for Rio Arriba County over the next 20 years. Estimates conclude that by 

2035, the county will have a population of approximately 47,000 people (Alcantara 2008). 

Sandoval County is directly south of Rio Arriba and is part of the Albuquerque metropolitan 

statistical area. Sandoval County borders Los Alamos and Santa Fe Counties to the east, 

Bernalillo County to the south, and Cibola, McKinley, and San Juan Counties to the west. 

Sandoval County has a land area of 3,710.65 square miles and a population density of 35.5 

persons per square mile, with a total population of 135,191 (US Census Bureau 2014). Unlike

Rio Arriba County, the Sandoval County population is projected to grow quickly and will exceed 

200,000 people by 2035; this will result in a 68 percent growth in population over the next 20 

years. New Mexico as a whole is also estimated to experience quick population growth, by 

nearly 70 percent between 2014 and 2035. This growth will be concentrated in and around the 

metropolitan centers of Albuquerque, Santa Fe, and Las Cruces (Alcantara 2008).

Table 3-25, below, describes population data for 2010 and 2014. Rio Arriba’s total population 

decreased by 1 percent between 2010 and 2014; Sandoval’s population increased by 

approximately 1 percent during the same period, narrowly outpacing average population growth 

in both New Mexico and the United States (US Census Bureau 2014). 

Table 3-25. Population by County, State, and Country

Location 2010 2014 2010-2014 Percent 

Change

United States 303,965,272 314,107,084 +1.03

New Mexico 2,013,122 2,080,085 +1.03

Rio Arriba County 40,195 40,155 -0.99

Sandoval County 124,263 135,191 +1.09

Source: US Census Bureau 2010, 2014

Note: American Community Survey estimates are based on data collected over 5 years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.

*Percent change rounded to the nearest hundredth. 

3.18.1.2 Housing

Table 3-26, below, provides data on the number of housing units for 2010 and 2014 for Rio 

Arriba and Sandoval Counties. The total housing supply for both counties grew between 2010 

and 2014. 

Table 3-27, below, shows the vacancy rate for Rio Arriba and Sandoval Counties as 23 percent 

and 10.8 percent. Vacancy rates can be indicators of rental property income, property values, 

unemployment rates, disposable income, and overall economic conditions in a region (US 

Census Bureau 2010). A significant portion of vacant housing in both counties is classified for 

seasonal or recreation use. 

In 2014, as shown in Table 3-28, below, the Rio Arriba County median home value was 

$140,900. This was below the New Mexico and national median home value. The median home 

value in Sandoval County was $175,800, well above the New Mexico median home value and 
Chapter 3. Affected Environment and Environmental Consequences

3-154 Santa Fe National Forest Geothermal Leasing EIS

Table 3-26. Housing Units by County, State, and Country

Location 2010 2014 2010-2014 Percent 

Change

United States 130,038,080 132,741,033 +1.02

New Mexico 887,890 907,233 +1.02

Rio Arriba County 19,385 19,601 +1.01

Sandoval County 50,314 53,289 +1.06

Source: US Census Bureau 2010, 2014

Note: American Community Survey estimates are based on data collected over 5 years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.

*Percent change rounded to the nearest hundredth.

Table 3-27. Housing Vacancy Status 2010

United States New Mexico Rio Arriba 

County Sandoval County

Vacancy rate 12.2% 14.8% 23.0% 10.8%

Vacant housing 

units

14,988,438 109,993 3,870 4,685

For rent 4,137,567 22,150 373 594

Rented, not 

occupied

206,825 1,303 38 51

For sale only 1,896,796 11,050 179 894

Sold, not occupied 421,032 2,143 45 170

For seasonal, 

recreational, or 

occasional use

4,649,298 36,612 1,709 1,532

For migratory 

workers

24,161 229 8 4

Other vacant 3,652,759 36,506 1,518 1,440

Source: US Census Bureau 2010

Table 3-28. Median Home Values and Median Gross Rent 2014

Location Median Home Value Median Gross Rent

United States $175,700 $920

New Mexico $159,300 $774

Rio Arriba County $140,900 $644

Sandoval County $175,800 $997

Source: US Census Bureau 2014

Note: American Community Survey estimates are based on data collected over 5 years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-155

nearly equivalent to the national median home value. Median gross rent for Rio Arriba County 

was $644, also below New Mexico and national median gross rent. Sandoval County median 

gross rent was $997, which was higher than the New Mexico and national median gross rents. 

Sandoval County is part of the Albuquerque metropolitan area, which accounts for its higher 

median home values and median gross rent.

Property taxes are a substantial source of revenue for Rio Arriba and Sandoval Counties. The 

weighted average property tax rate, or mill levy, is calculated by weighing tax rates in proportion 

to the taxable value of the tax district in which the rates appear. The property tax rate for Rio 

Arriba County in 2015 was $18.643 per $1,000 of net taxable value for residential property and 

$28.231 per $1,000 for nonresidential property. The property tax rate for Sandoval County in 

2015 was $33.241 per $1,000 of net taxable value for residential property and $36.194 per 

$1,000 for nonresidential property (NMDFA 2015). In comparison, the mean residential property 

tax rate for New Mexico was $29.751 per $1,000 of net taxable value and the mean 

nonresidential property tax rate for New Mexico was $31.252 per $1,000 of net taxable value 

(NMDFA 2015). Property tax obligations (revenue, assuming 100 percent collection) and 

assessed values are shown in Table 3-29, below.

Table 3-29. Santa Fe Geothermal Leasing Study Area - Property Tax Assessed Values and 

Obligations

Location

Residential Nonresidential

Total Assessed 

Value Tax Obligation Total Assessed Value Tax Obligation

Rio Arriba County

2014

2015

Percent change

$497,972,317

$503,272,606

1.01

$8,857,470

$9,382,526

1.06

$304,893,136

$289,642,902

-0.95

$7,943,607

$8,176,899

1.02

Sandoval County

2014

2015

Percent change

$2,427,832,009

$2,459,906,995

1.01

$79,541,120

$81,769,053

1.02

$751,460,176

$738,900,559

-0.98

$26,774,991

$26,743,586

-1.00

State of New Mexico

2014

2015

Percent change

$31,574,705,479

$32,283,583,025

1.02

$929,779,057

$960,480,174

1.03

$17,003,242,702

$17,454,632,250

1.02

$528,806,372

$545,494,747

1.03

Source: NMDFA 2014, 2015

3.18.1.3 Employment

Table 3-30, below, provides the average unadjusted unemployment rate for each year by county. 

Both Rio Arriba and Sandoval Counties saw an overall decrease in unemployment over this 

period, by 1.2 percent and 1.8 percent, following state and national trends (BLS 2015). 

Unemployment rates remained consistently higher than the New Mexico rate in Rio Arriba 

County and slightly above the state rate in Sandoval County over the period examined.

In December 2014, the labor force of Rio Arriba County consisted of 16,356 people; 14,995 were 

employed and 1,361 were unemployed (BLS 2015). Sandoval County had a labor force of 59,968 

people; 55,711 were employed and 4,257 were unemployed as of December 2014 (BLS 2015). 
Chapter 3. Affected Environment and Environmental Consequences

3-156 Santa Fe National Forest Geothermal Leasing EIS

Table 3-30. Santa Fe Geothermal Leasing Study Area - Average Yearly Unadjusted Unemployment 

Rate by County from 2010-2015

Percent Unemployed

Location 2010 2011 2012 2013 2014 2015

United States 9.6 9.0 8.1 7.4 6.2 5.3

New Mexico 8.1 7.6 7.1 6.9 6.5 6.5

Rio Arriba County 9.1 9.2 9.1 9.2 8.3 7.9

Sandoval County 8.4 8.1 7.8 7.5 7.1 6.6

Source: BLS 2015

3.18.1.4 Income

Table 3-31, below, shows median household incomes for years 2010 and 2014. The median 

household income for Rio Arriba County was $38,635 in 2014; this is a decrease in median 

household income by $2,802 from 2010 and falls below the New Mexico and United States 

median household incomes (US Census Bureau 2014). Sandoval County’s median household 

income decreased less significantly from 2010 to 2014; at $57,092 in 2014, it is above both the 

New Mexico and United States median household incomes (US Census Bureau 2014).

Table 3-31. Median Household Income

Location 2010 2014

United States $51,914 $53,482

New Mexico $43,820 $44,968

Rio Arriba County $41,437 $38,635

Sandoval County $57,158 $57,092

Source: US Census Bureau 2010, 2014

Note: American Community Survey estimates are based on data collected over 5 years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.

Table 3-32, below, shows average income across the total population for Rio Arriba and 

Sandoval Counties in 2010 and 2014. 

Table 3-32. Per Capita Income

Location 2010 2014

United States $27,334 $28,555

New Mexico $22,966 $23,948

Rio Arriba County $19,913 $19,483

Sandoval County $25,979 $26,916

Source: US Census Bureau 2010, 2014

Note: American Community Survey estimates are based on data collected over 5 years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-157

3.18.1.5 Key Economic Sectors Related to Forest Service Management

Tourism

Revenues and employment opportunities associated with travel and tourism are important 

sources of income in Rio Arriba and Sandoval Counties. Based on data from a 2014 National 

Forest Service Visitor Use and Monitoring report, the average total trip spending on a visit to the 

Santa Fe region of the SFNF was $230, while the median was $25 (Forest Service 2014b). 

Visitors planned overnight stays within 50 miles of the National Forest 21 percent of the time 

and stayed an average of 4.9 nights per trip within 50 miles of SFNF (Forest Service 2014b). In 

2009, an estimated 1,496,000 people visited the SFNF (Harris 2014). In 2014, the travel and 

tourism sector accounted for 11.7 percent of total employment in Rio Arriba County and 14.3 

percent in Sandoval County (Headwaters Institute 2016b). A significant majority of these 

employment opportunities come from the accommodations and food services industries. 

Mineral Development

For fiscal year 2014, neither Rio Arriba nor Sandoval County received any royalty payments 

from the federal government for geothermal leases on federal lands (Headwaters Institute 

2016a).

Grazing

Royalties from grazing leases on federal lands can be significant sources of revenue for local 

county governments. Rio Arriba County received $32,043 in federal lands payments from 

grazing districts in fiscal year 2014; Sandoval County received $46,641 in federal lands 

payments from grazing districts in the same year (Headwaters Institute 2016a). 

Community Services

Rio Arriba County has two sheriff’s office locations, one in Tierra Amarilla, the county seat, and 

one in Espanola. There are 18 fire districts in Rio Arriba County; it is serviced by 12 emergency 

management stations and a county public works office (Rio Arriba County 2016). Sandoval 

County is serviced by 8 fire districts and 20 fire stations, with nearly 300 volunteer and full-time 

firefighters (Sandoval County 2016). Its sheriff’s office is in Bernalillo. Both counties are also 

serviced by New Mexico state police districts (New Mexico State Police 2016). 

3.18.1.6 Environmental Justice

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations, requires that federal agencies identify and address 

any disproportionately high and adverse human health or environmental impacts of their 

programs, policies, and activities on minority, low-income populations and Native Americans. 

Guidance on environmental justice terminology developed by the President’s CEQ provides the 

following definitions:

 A low-income population is determined based on annual statistical poverty thresholds 

developed by the US Census Bureau. In 2014, the poverty level is based on a total income of 

$12,316 for an individual under age 65 and $24,418 for a family of four (DeNavas-Walt and 

Proctor 2015).

 A low-income community may include either a group of individuals living in geographic 

proximity to one another or dispersed individuals, such as migrant workers or Native 

Americans.
Chapter 3. Affected Environment and Environmental Consequences

3-158 Santa Fe National Forest Geothermal Leasing EIS

 Minorities are individuals who are members of the following population groups: American 

Indian, Alaska Native, Asian, Pacific Islander, Black, or Hispanic.

 A minority population area can be defined in multiple ways, according to CEQ regulations and 

EPA recommendations (EPA 2016d). A minority population is so defined if either the 

aggregate population of all minority groups combined exceeds 50 percent of the total 

population in the area (also referred to as the Fifty Percent Analysis), or if the percentage of the 

population in the area comprising all minority groups is meaningfully greater than the minority 

population percentage in the comparison population (Meaningfully Greater Analysis). For this 

analysis, meaningfully greater is defined as 10 percentage points or more above the 

comparison population. Like a low-income population, a minority population may include 

either individuals living in geographic proximity to one another or dispersed individuals.

 For the purpose of identifying a minority population or a low-income population 

concentration, the reference or comparison population used in this study is the state of New 

Mexico as a whole.

To analyze low-income and minority populations in the project area, US Census Bureau data for 

study area counties and census tracts overlapping the planning area was examined. Rio Arriba 

Census Tract 4, Rio Arriba Census Tract 5, Sandoval Census Tract 110, and Sandoval Census 

Tract 112 all overlap the project area. Data from census tracks are more representative of 

populations in the project area than data taken from Rio Arriba or Sandoval Counties as a whole. 

3.18.1.7 Low-Income Populations

Rio Arriba Census Tract 5, Sandoval Census Tract 110, and Sandoval Census Tract 112 all had 

percent of populations in poverty lower than that of the State of New Mexico comparison

population (see Table 3-33). Only Rio Arriba County and Rio Arriba Census Tract 4, with 22.5 

percent of individuals below the poverty level, had a percentage of the population in poverty 

greater than New Mexico (US Census Bureau 2014); however, these populations were within 

five percentage points of the comparison population of New Mexico and do not meet the 

Meaningful Greater Analysis assessment. Because of this, no low-income populations have been 

identified for environmental justice consideration in this planning process.

Table 3-33. Populations in Poverty 2014

Location

Percent of Individuals Whose Income 

in the Past 12 Months Was below the 

Poverty Level

Percent of Families Whose Income in 

the Past 12 Months Was below the 

Poverty Level

United States 15.6 11.5

New Mexico 20.9 16.1

Rio Arriba County 22.5 15.8

Rio Arriba County,

Census Tract 4

22.5 12.8

Rio Arriba County,

Census Tract 5

15.4 12.2

Sandoval County 14.7 10.7

Sandoval County,

Census Tract 110

19.2 14.4

Sandoval County,

Census Tract 112

14.2 12.1

Source: US Census Bureau 2014

Note: American Community Survey estimates are based on data collected over 5 years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-159

3.18.1.8 Minority Populations

As shown in Table 3-34, below, all study area populations were above 50 percent minority and 

therefore pass the Fifty Percent Analysis test for environmental justice consideration. Rio Arriba 

County, Rio Arriba Census Tracts 4 and 5, and Sandoval Census Tract 110 also had aggregate 

minority populations that were greater than the New Mexico aggregate minority population. 

Notably, Rio Arriba County, Rio Arriba Census Tract 4, and Sandoval Census Tract 110 were

well over 10 percentage points higher than the comparison population of the state. Minority 

populations were also identified in Sandoval Census Tract 112, with 57 percent of the population 

identifying as a minority, although this was less than the New Mexico aggregate minority 

population (US Census Bureau 2014). 

Table 3-34. Study Populations by Race/Ethnicity 2014

Population

Tract 

4, Rio 

Arriba 

County

Tract 5, 

Rio 

Arriba 

County

Tract 

110, 

Sandoval 

County

Tract 

112, 

Sandoval 

County

Rio 

Arriba 

County

Sandoval 

County

New 

Mexico

United 

States

Total 

population

4,504 3,548 1,859 2,676 40,155 135,191 2,080,085 314,107,084

Hispanic or 

Latino 

ethnicity of 

any race

77.5% 65.2% 32.7% 17.1% 71.4% 36.4% 47.0% 16.9%

White alone 21.6% 31.3% 25.4% 42.9% 13.1% 46.1% 39.6 % 62.8%

Black or 

African 

American 

alone

0.4% 0.3% 1.0% 0.0% 0.4% 2.0% 2.0% 12.6%

American 

Indian or 

Alaskan 

Native alone

1.5% 3.4% 36.5% 39.8% 14.0% 11.9% 9.2% 0.8%

Asian alone 0.0% 0.1% 0.7% 0.8% 0.5% 1.3% 1.4% 5.0%

Native 

Hawaiian 

and Other 

Pacific 

Islander 

alone

0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.2%

Some other 

race

11.9% 4.9% 9.8% 5.0% 0.1% 0.4% 11.1% 4.7%

Two or 

more races

0.2% 1.0% 4.0% 0.4% 0.5% 1.9% 3.1% 2.9%

Aggregate 

Minority 

population

78.4% 68.7% 74.6% 57.1% 86.9% 53.9% 60.4% 36.2%

Source: US Census Bureau 2014

Note: American Community Survey estimates are based on data collected over 5 years. They represent the average 

characteristics of populations between January 2010 and December 2014 and do not represent a single point in time.

Aggregate minority population is calculated by total population, minus those reporting as white of non-Hispanic.
Chapter 3. Affected Environment and Environmental Consequences

3-160 Santa Fe National Forest Geothermal Leasing EIS

3.18.1.9 Native Americans

As noted in Section 3.16, Tribal Interests and Traditional Cultural Resources, the following 

Native American communities have connections to planning area lands; as such, they could be

impacted by project activities:

 Pueblo of Jemez

 Pueblo of Zia

 Kewa Pueblo (Pueblo of Santo Domingo)

 Pueblo of Santa Ana

 Pueblo of Cochití

 Ohkay Owingeh

 Pueblo of Santa Clara

 Pueblo de San Ildefonso

 Pueblo of Nambé

 Pueblo of Pojoaque

 Pueblo of Tesuque

 Pueblo of San Felipe

 Jicarilla Apache Tribe

 Navajo Nation

Pueblo members represent a unique population that may be impacted by proposed activities

throughout the planning area, due to cultural and spiritual ties to planning area lands.

Furthermore, American Indian populations represent an important minority group in some 

specific geographic locations in the socioeconomic planning area, as demonstrated in Census 

Bureau data. In Sandoval Census Tract 110, 678 persons identify as American Indian alone, out

of a total population of 1,859 (approximately 36 percent of the population). In Sandoval Census 

Tract 112, 1,065 persons identify as American Indian alone, out of a total population of 2,676, 

which is approximately 40 percent of the population (US Census Bureau 2014). 

As identified in Table 3-34, Study Populations by Race/Ethnicity 2014, all populations in the 

area have more than 50 percent aggregate minority populations. Many also have populations that 

are 10 percentage points or more above the New Mexico comparison population. As a result, 

these populations qualify as minority populations under CEQ guidance. Furthermore, pueblo 

populations are recognized as a geographically dispersed minority group with common cultural 

ties that may be impacted by proposed project activities. The Forest Service will address

environmental justice populations in the project area in the EIS to mitigate any disproportionate 

environmental impacts on these populations, following guidelines set forth in Executive Order 

12898. 

3.18.2 Environmental Consequences

3.18.2.1 Scoping Comments on Resource

The following issues specific to social interests, economics, and environmental justice were 

identified during the public scoping period:

 How would geothermal leasing affect tourism, local businesses, property value, and 

community services? 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-161

 Would geothermal leasing result in disparate impacts on communities, tribes, or other 

populations?

3.18.2.2 How Resource Impacts Were Evaluated

Method

Impacts were analyzed in terms of the predicted increase in geothermal energy activities and the 

associated changes expected in employment, income, tax revenue, royalties, property value, 

public infrastructure needs, impacts on other land uses, and other socioeconomic factors. The 

location of such development could occur anywhere in the project area where consent to leasing 

has been granted. Components of geothermal plant construction and operation, including the 

number of temporary and permanent workers required, are partially determined by plant 

production potential.

The analysis of socioeconomic and environmental justice issues associated with the development 

of geothermal facilities considers impacts within the counties of the project area: Rio Arriba and 

Sandoval. 

Indicators

Impacts would result from the lease revenues and future construction and operation of 

geothermal energy projects in the project area, based on future leases. Consenting to geothermal 

leasing and issuing geothermal leases would not impact environmental justice. Potential impacts 

on socioeconomics and environmental justice could occur if reasonably foreseeable future 

actions were to result in any of the following:

 Impact other land uses that currently create revenue

 Change residential property value and property taxes collected

 Induce growth or otherwise change population concentrations and cause additional demands 

on housing or social services that could not be met by the local communities

 Cause a change in local or project area employment

 Have a disproportionately high and adverse impact on minority populations or a 

disproportionately high and adverse impact on low-income populations

Assumptions

 NSO stipulations would prevent direct disturbance to recreation, wildlife, visual resources, 

habitats, and species by restricting surface-disturbing activities where they are applied.

 Geothermal projects in the project area would be developed in accordance with the RFDS, 

suggesting a maximum of five geothermal plants of 25 MW each during the 15-year time 

frame, for a total of 125 MW. 

 Jobs and economic activity generated are based on RFDS MW estimates and economic 

impact estimates from the Geothermal Leasing PEIS (BLM and Forest Service 2008).

 Any new surface-disturbing geothermal activities would be subject to further NEPA analysis, 

which would include a site-specific analysis to determine consistency with applicable 

environmental justice guidelines.
Chapter 3. Affected Environment and Environmental Consequences

3-162 Santa Fe National Forest Geothermal Leasing EIS

3.18.2.3 Common Impacts Associated with Geothermal Development

The issuance of geothermal leases would impact socioeconomics through lease revenues, with 

50 percent of revenues going to the state, 25 percent going to the county, and the remainder 

going to the US Treasury (BLM and Forest Service 2008).

Impacts on area socioeconomics and environmental justice from developing the geothermal 

resource would vary, depending on the types, timing, and location of development. 

The largest impact on economics would result from employment and income directly and 

indirectly associated with geothermal electricity plant construction and operation. In addition, 

geothermal power plants may generate additional revenue streams for local government,

including property taxes and royalties. Information and impacts for these factors are discussed at 

length in the 2008 Geothermal PEIS (BLM and Forest Service 2008), and this information is 

incorporated by reference and summarized here.

Activities associated with exploration and drilling provide temporary jobs for the local 

community near geothermal resources, as well as expenditures for fuel, lodging, food, and other 

needs, providing stimulus to the local economy. 

The level of impact resulting from utilization phase activities (construction, operations, and 

maintenance) generally varies, depending on resource potential for the area. Based on the 2008 

Geothermal PEIS (BLM and Forest Service 2008), construction income is estimated to be 

roughly $4.5 million per 25-MW power plant and associated activities. In summary, construction 

of a 25-MW power plant and the associated transmission lines would require 935 person-months, 

or 77.5 person-years, with a variable number of employees required at any given time during 

construction. Operations and maintenance income is estimated to be $1.6 million annually for a 

25-MW plan. 

Generally, employment would provide positive impacts on the surrounding area in the form of 

opportunities and secondary impacts from money spent in the local economy. Additionally, 

geothermal resource development may provide an opportunity to broaden the economic base of 

the communities in and around the project area and would provide taxes and possible royalties to 

the county. 

Social impacts on local communities could occur from project exploration, drilling and 

utilization. Construction equipment and operation may change the social setting, due to increases 

in local traffic, noise, fugitive dust and emissions, altered visual setting, or conflict with existing 

land uses (see Sections 3.4.2, Land Use, Recreation, and Special Designations, 3.10.2, Air 

Quality and Air Quality Related Values, 3.17.2, Visual Resources, 3.20.2, Noise, and 3.21.2, 

Transportation and Access). In addition, potential impacts on water quality or quantity, including

those to existing hot springs, may impact adjacent communities (see Section 3.9.2, Water 

Resources). The potential for increased seismic risk may also impact local communities (see 

Section 3.5.2, Geological Resources). Implementation of BMPs would reduce the level of 

impacts.

As noted in Section 3.18.1, minority populations for environmental justice consideration have 

been identified in the planning area. There is a potential for impacts on these communities

because of development, as outlined above. The level and intensity of impacts would depend on 

the site-specific location and size of the proposed development.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-163

Pueblo representatives believe that any leasing and development of planning area lands for 

geothermal resources would impact habitat for wildlife species of cultural and ceremonial 

important. Such activities also would impact land related to traditional uses and religious beliefs

(see Section 3.16.2, Tribal Interests and Traditional Cultural Resources, for details). The

representatives stated that these impacts represent disproportionately high and adverse 

environmental impacts on pueblo communities that would be impossible to mitigate.

3.18.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. Excluded from 

leasing would be the 28,900-acre JNRA. The social and economic impacts from geothermal 

development, should a lease application be approved, are described here. 

Alternative 1 would result in impacts similar to those described in Section 3.18.2.3. The direct 

economic impacts from the construction and operation of the five 25-MW geothermal plants also 

include employment opportunities and federal royalties paid to the State of New Mexico and Rio 

Arriba and Sandoval Counties. Indirect impacts, such as increased economic activity and tax 

contributions, would also impact the area.

The creation of approximately 388 temporary construction jobs, only some of which would come 

from the local labor force, would have temporary impacts on the local economy (BLM and 

Forest Service 2008). The degree to which employment would be filled by area residents would 

depend on the level of skill required for particular jobs and the availability of qualified 

candidates, among other factors. While these jobs would be temporary, indirect impacts on local 

economies would be spending by these job holders on housing, goods, and services. 

A short-term increased demand for housing might also occur. Such an increase is not anticipated to 

create a significant burden on local housing or social services markets or induce a level of growth 

that the local communities do not have a capacity for. This is because the number of construction 

workers needed at any given time would vary throughout the completion of the project. 

Table 3-35, below, further details the direct economic impacts associated with geothermal 

electricity plant development. It is in accordance with expected development scenarios 

established in the RFDS (BLM 2015) and economic impacts from those scenarios from the 

Geothermal Programmatic EIS (BLM and Forest Service 2008).

Long-term employment projections from geothermal operations and maintenance could include 

up to 212 new jobs (BLM 2015). Geothermal projects employ people with a variety of skills and 

education levels in diverse careers, from geologists and hydrologists to plumbers, machinists, 

electricians, and structural engineers (Kagel 2006). Some of these jobs would employ members 

of the region’s current labor force, while some specialized positions may require hiring workers 

new to the region. 

As discussed under Section 3.18.2.3, short-term direct impacts for local area residents’ quality of 

life may occur as a result of project construction, due to increased traffic, noise, and dust from 

construction equipment. Impacts would be focused on those who live in the vicinity of 

development projects, and specific intensity and location of impacts would be variable,

depending on the location of wells and plants, which are currently unknown. Because there is 

low housing density in the project area, these impacts would occur only in localized areas. 
Chapter 3. Affected Environment and Environmental Consequences

3-164 Santa Fe National Forest Geothermal Leasing EIS

Table 3-35. Economic Impacts of Geothermal Electricity Generation

Estimated geothermal MW Five 25-MW geothermal plants = 125 MW 

Total temporary construction jobs1388

Construction income (million $)2$22.5 million

Operations and maintenance jobs (permanent, full-time jobs)3212

Annual operations and maintenance income4$8 million

Federal royalty estimate (30-year total)

5

$1.75 million

State royalty estimate (30-year total)5$3.5 million

County royalty estimate (30-year total)5$1.75 million

1 Assuming an average of 3.1 total construction jobs per MW (BLM and Forest Service 2008)

2 Assuming a rate of $4.5 million for a 25-MW power plant (BLM and Forest Service 2008)

3 Assuming a rate of 1.7 permanent full time jobs/MW, in accordance with the Reasonably Foreseeable Design (BLM 

2015)

4 Assuming a rate of $1.6 million annually for a 25-MW power plant, as discussed in BLM and Forest Service (2008)

5 With average electricity price of 6 cents/kilowatt hour and 95 percent capacity factor, following Kagel (2006)

In addition to direct impacts, indirect impacts on social interests and economics might occur as a 

result of geothermal development under Alternative 1. Property tax values of lands near or next 

to the geothermal power plant could be impacted by the perceived decrease in scenic value from 

the development. However, because geothermal plants are of small footprint and must be located 

near existing power lines, these affects would be minimal and short term. This is because much 

of the disturbed area would be reclaimed within a few years after the completion of construction.

Although some long-term employment opportunities may be created though geothermal 

development, the population, labor force, or employment sector of the region would not be 

greatly altered. The RFDS reports that 1.7 potential long-term jobs are created for every MW of 

a geothermal plant. Assuming geothermal development reaches its full potential of five 25-MW

plants in the project area, 212 long-term jobs could result from development. Assuming the 

maximum long-term employment rate, that each person who receives a job must relocate to the 

project region, and that each person has an average size family of three persons, the total 

maximum increase in population would equal 636 people. This unlikely potential impact would 

result in a negligible 1.5 percent maximum population increase to Rio Arriba County or a 

negligible 0.5 percent maximum population increase to Sandoval County.

Recreation and tourism revenues might be reduced, but this would be limited to the construction 

phase of geothermal development. Hiking, hunting, wildlife viewing, sport climbing, and 

camping are all popular recreation activities in the area. Currently developed recreation facilities, 

special-use permit recreation sites, and areas with significant recreation use deemed 

incompatible with geothermal development would be closed to geothermal leasing. This would 

minimize impacts on current recreation and tourism revenues. Due to these stipulations and the 

dispersed nature of the popular activities, there would be minimal long-term impacts on revenues 

that come from recreation and tourism in the project area.

As described in Section 3.18.2.3, any potential impacts on water quality or water quantity could 

indirectly impact local communities. As described under Section 3.9.2, where there is 

interconnected flow to springs and seeps in thermal areas, this could alter the mixing of weatherrelated non-thermal waters with the deeper geothermal waters and could alter flow paths to hot 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-165

springs. Such impacts could reduce revenue for commercial hot springs. However, because the 

entire JNRA is closed to geothermal leasing, the risk of indirect socioeconomic impacts is low. 

Alternative 1 is not site specific, and leasing would be approved on a case-by-case basis; 

therefore, uniform guidance, stipulations, closures, and consistent BMPs for leasing have not 

been identified under this alternative. This type of planning does not provide the best protections 

for natural resources, socioeconomics, or environmental justice populations. By designating 

specific areas as open or closed to leasing and imposing stipulations on direct and indirect landuse by geothermal development, impacts on natural resources, socioeconomics, and 

environmental justice populations can be minimized or negated.

Without site-specific plans for geothermal development, the specific location and intensity of 

impacts from development on environmental justice populations in the project area cannot be 

determined at this time; however, pueblo representatives believe that any level of geothermal 

development in the planning area would impact resources with cultural and spiritual value. These 

impacts could not be mitigated and, therefore, would represent disproportionate, adverse 

impacts. (See the discussion in Section 3.16.2, Tribal Interests and Traditional Cultural

Resources, for additional details.)

3.18.2.5 Impacts Under Alternative 2

The overall economic impacts of geothermal development under Alternative 2 are the same as 

Alternative 1, but certain restrictions to leasing would apply. Under this alternative, 29,321 acres 

would be closed by law, regulation, or authority to geothermal leasing. Also, under this 

alternative, 139,329 acres would be open to leasing, but 132,900 of them would be subject to 

NSO stipulations, 80,300 would be subject to CSU stipulations, and 39,500 would be subject to 

TL stipulations (Forest Service GIS 2015). 

The overall potential development of five 25-MW geothermal plants and the overall net 

economic impacts from such development would be the same as under Alternative 1, but 

Alternative 2 includes greater limitations for the siting of geothermal plants and infrastructure

than Alternative 1. Site limitations may cause net economic impacts to be more dispersed 

throughout the ROI than under Alternative 1. NSO, CSU, and TL stipulations would limit

potential development sites but would minimize the direct impacts on natural resources, such as 

wildlife, soil, and water. This reduced impact on natural resources indirectly impacts 

socioeconomics by improving the quality of life for residents of the surrounding project area and 

reducing impacts on recreation and other land uses that generate revenue for the local economy. 

The programmatic nature of this EIS does not allow for analyzing the specific location and 

intensity of impacts from development on environmental justice populations in the project area. 

Additional NEPA analysis would be required before any projects begin. Site-specific 

considerations for environmental justice populations would mitigate any disproportionately high 

and adverse impacts from geothermal development, in compliance with Executive Order 12898; 

however, pueblo representatives believe that any level of geothermal development in the 

planning area would impact resources with cultural and spiritual value. These impacts could not 

be mitigated and therefore represent disproportionate, adverse impacts. (See the discussion in 

Section 3.16.2, Tribal Interest and Traditional Cultural Resources, for additional details.)

3.18.2.6 Impacts Under Alternative 3

Under Alternative 3, no leasing would be permitted, and no new employment opportunities, 

federal royalty payments, or new taxable income would be generated. There would be no 
Chapter 3. Affected Environment and Environmental Consequences

3-166 Santa Fe National Forest Geothermal Leasing EIS

impacts associated with geothermal development, and the current social and economic profile of 

the surrounding area would be retained. No impacts would occur on environmental justice

populations.

3.18.2.7 Impacts Under Alternative 4

The overall economic impacts of geothermal development under Alternative 4 are the same as 

under Alternative 1, but certain restrictions to leasing would apply. Under this alternative, 28,900 

acres would be closed by law, regulation, or authority to geothermal leasing. Also, under this 

alternative, 139,329 acres would be open to leasing, but 122,500 of them would be subject to 

NSO stipulations, 122,600 would be subject to CSU stipulations, and 42,200 would be subject to 

TL stipulations (Forest Service GIS 2015). 

The overall potential development of five 25-MW geothermal plants and the overall net 

economic impacts from such development would be the same as under Alternative 1, but 

Alternative 4 includes greater limitations for the siting of geothermal plants and infrastructure

than Alternative 1. Site limitations may cause net economic impacts to be more dispersed 

throughout the ROI than under Alternative 1. NSO, CSU, and TL stipulations would limit

potential development sites but would minimize the direct impacts on natural resources, such as 

wildlife, soil, water, and air quality. This reduced impact on natural resources indirectly impacts 

socioeconomics by improving the quality of life for residents of the surrounding project area and 

reducing impacts on recreation and other land uses that generate revenue for the local economy. 

The programmatic nature of this EIS does not allow for analyzing the specific location and 

intensity of impacts from development on environmental justice populations. Additional NEPA

analysis would be required before any project begins. There would be site-specific 

considerations for environmental justice populations. This would mitigate any disproportionately 

high and adverse impacts from geothermal development, in compliance with Executive Order 

12898; however, pueblo representatives believe that any level of geothermal development in the 

planning area would impact resources with cultural and spiritual value. These impacts could not 

be mitigated and therefore represent disproportionate, adverse impacts. (See the discussion in 

Section 3.16.2, Tribal Interest and Traditional Cultural Resources, for additional details.)

3.18.2.8 Cumulative Impacts

Overall cumulative net impacts from geothermal development and other industrial projects also 

slated to occur in the ROI would generally result in increased economic activity in the region. 

Projects are the Pueblo of Jemez Red Rocks Dam Repair, the Pueblo of Jemez Owl Springs 

Bridge Sediment Removal, and the Abiquiu Land Grant Waterline Replacement. Impacts include 

the creation of jobs, increased royalties for local municipalities, increased tax revenue, and the 

securement of reliable utilities, such as clean potable water and electricity for the population. 

However, a cumulative increased demand for housing and social services from temporary 

construction employment, should these development projects overlap with geothermal 

development, could impact the local economy’s ability to provide such services. The level of 

impacts would depend on the exact timing of development projects and the level of employment 

needs, which cannot be determined at this time. 

Contribution to cumulative impacts would vary by Alternative. Following direct and indirect 

impacts discussed above, geothermal leasing under Alternatives 1, 2, and 4 would result in 

contributions to cumulative impacts, while no contributions to cumulative impacts would occur 

under Alternative 3 due to no geothermal leasing and development. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-167

Future climate scenarios suggest that increasing temperatures and competition for water supplies 

could reduce agriculture yields and displace jobs in some rural communities of the Southwest

(Garfin et al. 2014). None of the alternatives are anticipated to change these types of impacts.

Geothermal development projects when combined with other industrial projects could 

cumulatively impact environmental justice populations in the project area identified in Section 

3.18.1.6. Compliance with the environmental justice guidelines set forth in Executive Order 

12898 would be necessary to ensure no disproportionately high and adverse impacts affect these 

identified populations. 

3.19 Health and Safety

3.19.1 Affected Environment

The 2008 Geothermal PEIS describes health and safety concerns associated with geothermal 

energy development, as well as the regulatory framework around the health and safety of 

workers involved in such development. In the future, when NEPA analysis is conducted for 

specific geothermal exploration and development projects in the project area, site-specific health 

and safety risks would be documented. Existing health and safety risks in the project area relate 

to existing and ongoing mining and exploration, vegetation treatments, recreation, hunting, and 

transportation. In addition, there have been several major wildfires on the SFNF in recent years 

caused by trees or branches falling on small service lines.

3.19.2 Environmental Consequences

3.19.2.1 Scoping Comments on Resource

The issues specific to health and safety identified during the public scoping period are 

 What are the health and safety risks of geothermal leasing? How would geothermal leasing 

affect drinking water, considering the regional geology?

3.19.2.2 How Resource Impacts Were Evaluated

Method

The method for the public health and safety impact analysis is incorporated by reference from 

the health and safety section of the 2008 Geothermal PEIS (BLM and Forest Service 2008).

Indicators

Impact criteria for public health and safety are also incorporated by reference from the health 

and safety section of the 2008 Geothermal PEIS (BLM and Forest Service 2008). More 

specifically, the analysis discusses the potential for the exposure of construction workers, 

personnel, or the public to hazards related to the exploration, development, or operational phases 

of a geothermal project. 

Assumptions

This analysis assumes the following: 

 The risk of exposure to hazardous situations would be highest among geothermal project 

staff; the general public would have a lower risk of exposure due to the reduced likelihood of 

being on the project site during exploration, development, operations, and abandonment. 
Chapter 3. Affected Environment and Environmental Consequences

3-168 Santa Fe National Forest Geothermal Leasing EIS

 All construction workers and operational personnel would work according to Occupational 

Health and Safety Administration standards to prevent or minimize health and safety risks.

3.19.2.3 Common Impacts Associated with Geothermal Development

The nature and characteristics of the impacts on public health and safety associated with 

geothermal development as a result of the decisions common to all action alternatives would be 

the same as those described in the 2008 Geothermal PEIS (BLM and Forest Service 2008), 

which is incorporated by reference and summarized here. 

Due to the inability to predict the location, scope, scale, and timing of future development, what 

follows is a general description of common impacts on public health and safety from geothermal 

resource development. Potential impacts are as follows: 

 Exposure of individuals to geothermal steam during exploration and development drilling 

 Exposure of individuals to electrical fires or wildfires caused by project activities

 Exposure of individuals to electric shock from maintenance of transmission lines and 

substations

 Vehicular accidents due to increased traffic on local roads

 A variety of potential accidents inherent to exploration, development, operations, 

maintenance, and reclamation and abandonment, as listed in the Geothermal PEIS

 A variety of potential accidents inherent to industrial facilities

Potential public health and safety impacts would last for the duration of exploration, estimated at 

between 1 and 5 years for an individual project, development phase, estimated at 2 to 10 years 

for an individual project, and operations and maintenance phase, estimated at 10 to 30 years for 

an individual project.

Impacts from drilling activities on drinking water quality are discussed in Section 3.9, Water 

Resources.

3.19.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis and in accordance with the Forest Plan and existing laws and regulations. Impacts 

would be similar to those identified in Section 3.19.2.3, Common Impacts Associated with 

Geothermal Development, above. Measures to minimize impacts on health and safety would be 

considered in these separate NEPA analyses.

There would be a risk of human-caused fire from geothermal development. However, because 

power line rights-of-way would be cleared of trees, the risk of wildfire associated with trees 

causing downed power lines would be minor. This is in contrast to smaller service lines 

associated with residences, where the ROW owner may not clear trees at a sufficient distance to 

prevent them from falling on the line. 

3.19.2.5 Impacts Under Alternative 2

The nature and character of impacts under Alternative 2 would be similar to those described in 

Common Impacts Associated with Geothermal Development. Under this alternative, the 

recommended BMPs detailed in Appendix C would be incorporated as appropriate into the 
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Santa Fe National Forest Geothermal Leasing EIS 3-169

permit application by the lessee or would be included in the approved use authorization as 

conditions of approval. Depending on which BMPs are identified as necessary for each lease, 

operators may be required to implement actions that would protect public health and safety. For 

example, operators would be required to minimize air quality impacts, develop hazardous 

materials and waste management plans, establish safety zones, and develop fire management

strategies. These measures would effectively minimize impacts on health and safety from 

geothermal-related actions. 

Impacts from wildfire and power lines would be the same as described under Alternative 1.

3.19.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area and no impacts on health and 

safety from geothermal activities.

3.19.2.7 Impacts Under Alternative 4

Impacts would be the same as those described under Alternative 2, because the same level of 

disturbance, the same number of wells, and the same number of power plants are expected.

3.19.2.8 Cumulative Impacts

Health and safety risks associated with geothermal energy activities, in conjunction with other 

reasonably foreseeable projects across the project area, are expected to be negligible. This is 

because all project proponents would have to comply with state and federal requirements 

pertaining to worker safety and the use, storage, transport, and disposal of debris and hazardous 

materials and wastes. The potential for spills of hazardous waste, such as fuel and drilling muds, 

would be minimized by applying BMPs included in lease terms. Any spills would not be at a 

large enough scale to cumulatively affect human health and safety, either at the local level, when 

combined with other local projects, or across the project area, when combined with all other 

projects with similar individual impacts. There would be no cumulative impact on wildfire from 

downed power lines, because power line rights-of-way associated with geothermal development

would be maintained free of trees or other vegetation that could fall onto the line.

3.20 Noise

3.20.1 Affected Environment

The federal law that directly affects noise control is the Noise Control Act of 1972, as amended 

by the Quiet Communities Act of 1978 (42 USC, Sections 4901-4918). This act delegates to the 

states the authority to regulate environmental noise. It also directs government agencies to 

comply with local community noise statutes and regulations and to conduct their programs to 

promote an environment free of any noise that could jeopardize public health or welfare.

Geothermal developers on NFS lands are subject to BLM leasing regulations. These mandate that 

noise at one-half mile—or at the lease boundary, if closer—from a major geothermal operation 

shall not exceed 65 dBA (Federal Geothermal Resources Operational Order Number 4).

An understanding of current noise conditions in the project area is derived from a mix of noise 

measurements and modeled calculations. For example, geospatial models of the ambient sound 

level in the VCNP predict summer daytime median (L50) sound levels ranging from 
Chapter 3. Affected Environment and Environmental Consequences

3-170 Santa Fe National Forest Geothermal Leasing EIS

approximately 30 to 32 dBA22. Noise measurements were taken at the El Cajete Pumice Mine in 

the JNRA south of the VCNP; normal background noise levels were measured at less than 40 

dBA and up to 70 dBA, with a strong breeze in the surrounding pine forest. Vehicle noise on NM 

4 was measured at 50 to 60 dBA from a distance of approximately 200 feet. Because vehicle 

travel is less common at night, there will be less vehicle noise then. Noise levels at oil and gas 

wells operating in the SFNF have also been measured. Gas-fueled pump-jacks registered at 55 to 

60 dBA, at a distance of 20 feet from their spark arresters, and gas compressors registered at 55 

to 70 dBA, at a distance of approximately 80 feet.23

3.20.2 Environmental Consequences

3.20.2.1 Scoping Comments on Resource

The following issue specific to noise was identified during the public scoping period:

 What are the impacts of increased noise in the project area?

3.20.2.2 How Resource Impacts Were Evaluated

Method

The method for the noise impact analysis is incorporated by reference from the noise section of 

the 2008 Geothermal PEIS.

Indicators

Impact criteria for noise are incorporated by reference from the noise section of the 2008 

Geothermal PEIS. More specifically, the analysis discusses potential noise levels and compares 

them to those set by the Federal Geothermal Resources Operational Order Number 4. This 

mandates that noise levels must be 65 dBA or less at the geothermal lease boundary, or 0.5 mile 

from the source, whichever is greater.

Assumptions

This analysis assumes the following: 

 Future analysis for site-specific projects would identify the presence of sensitive noise 

receptors, such as residences or schools, in the vicinity of the proposed well drilling or 

geothermal plant activities. 

 Noise levels for the specific activities would be assessed to determine their compliance with 

applicable noise guidelines, and measures to reduce noise impacts would be identified, if 

necessary.

3.20.2.3 Common Impacts Associated with Geothermal Development

Noise levels measured at geothermal power plants and wells can provide insight into the type 

and severity of impacts expected in the project area. In support of an EIS for the proposed Casa 

 

22 Randy Stanley, Natural Sounds and Night Skies Coordinator, National Park Service, personal 

communication with Forest Service. April 28, 2016.

23 Larry Gore, Geologist, Forest Service, personal communication with Drew Vankat, EMPSi. February 

10, 2016.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-171

Diablo IV project near Bishop, California, Leiken (2011) measured average noise levels at the 

Galena-3 binary power plant near Reno, Nevada (Table 3-36). 

Table 3-36. Observed and Calculated Noise Levels for Geothermal Power Plants, Production 

Wells, and Drill Rigs

Distance Binary Power Plant Production Well Drill Rig

150 feet 71.5 dBA154.8 dBA269.1 dBA2

400 feet 64.5 dBA1 46.3 dBA260.6 dBA1

1,320 feet (0.25 mile) 54.0 dBA135.6 dBA150.2 dBA2

Sources: Leiken 2011; Sengpielaudio 2016

1 Observed or calculated average noise levels from Leiken 2011

2 Calculated noise levels from Sengpielaudio 2016

Doubling the distance from the source of a sound decreases sound levels by 6 dBA. Using this 

formula, estimated sound levels at different distances can be calculated. Based on field 

measurements and calculated estimates, noise levels from binary power plants would only 

exceed the limit of 65 dBA established in Federal Geothermal Resources Operational Order 

Number 4 at distances of less than 400 feet. Production wells would exceed this limit at 

distances of less than 69 feet, and drill rigs would exceed this limit at distances of less than 241 

feet. These distances are estimates, as vegetation, topography, and other site-specific factors 

could affect sound levels. Because power plants and rig operations often operate continuously, 

noise impacts would occur during the day and night time. 

Noise impacts could also occur during the exploration stage of development; however, these 

impacts would generally be less than noise levels generated during drilling operations and 

utilization.

During exploration, drilling, and utilization, vehicle use and construction equipment would 

increase noise levels. These noise sources would be mobile, and impacts would occur along 

access routes and at development sites. Noise emissions from heavy truck use is a function of 

volume, speed, and number of trucks. Vehicle noise is primarily a combination of that produced 

by the engine, exhaust, and tires (Federal Highway Administration 2011). Vehicles also would be

used during the reclamation and abandonment phase, but to a lesser extent. 

3.20.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. Measures to 

minimize noise related impacts (as identified above under Common Impacts Associated with 

Geothermal Development) would be considered in these separate NEPA analyses.

3.20.2.5 Impacts Under Alternative 2

Since leases are not issued on lands that also contain sensitive receptors, such as residences, 

schools, or hospitals, the maximum noise potentially experienced by such a receptor would be 65 

dBA. This indirect impact from subsequent development would occur only if the receptor is next 

to the lease boundary or within 400 feet of a power plant. Due to the highly rural and 
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3-172 Santa Fe National Forest Geothermal Leasing EIS

unpopulated nature of lands in the decision area, it is unlikely that any sensitive receptors would 

be this close to noise-emitting geothermal equipment or activities.

3.20.2.6 Impacts Under Alternative 3

There would be no lands available for leasing in the project area and no noise impacts from 

subsequent geothermal exploration and drilling.

3.20.2.7 Impacts Under Alternative 4

Impacts would be similar to those described under Alternative 2, because the same level of 

disturbance, the same number of wells, and the same number of power plants are expected.

3.20.2.8 Cumulative Impacts

The region of influence for noise is the project area and adjacent landscapes. Past, present, and 

reasonably foreseeable future noise-producing projects are pumice mine operation and expansion 

and mechanical vegetation treatments. Cumulative impacts on noise could occur if these 

activities were close to geothermal development activities and sensitive receptors. 

Geothermal development could potentially affect adjacent landscapes, including the VCNP,

under Alternatives 1, 2, and 4. As shown in Table 3-23, Stipulations and Closures within a 1- and 

2-mile Buffer of NPS Lands for Action Alternatives, under Alternative 2 there would be no lands 

open to geothermal leasing, subject to standard lease terms and conditions, within a 2-mile buffer 

of NPS lands. Under Alternative 4, approximately 400 acres would be open to leasing subject to 

standard lease terms and conditions within 2 miles of NPS lands. Under both alternatives, 

geothermal development could potentially occur within 2 miles of NPS lands, resulting in 

increased noise levels. There would be a greater potential for development near NPS lands under 

Alternative 4, as more acres would be open subject to standard lease terms and conditions near 

the VCNP boundary. However, implementing BMPs as described in Appendix C (such as sound 

control devices, adequate mufflers, and adequate equipment maintenance) would reduce these 

impacts from increased noise levels on NPS lands.

3.21 Transportation and Access

3.21.1 Affected Environment

A network of state highways and Forest Service roads serve the broader project area. Throughout 

the project area there are a range of single-lane and two-lane roads, with varying degrees of 

improvements and a broad range of users. The 2012 ROD for the SFNF Travel Management 

Plan EIS provides a comprehensive summary of travel management issues and decisions on the 

SFNF (Forest Service 2012).

Any operations related to the geothermal leases will require specific authorizations and will be 

exempt from the Travel Management Plan (36 CFR, Subpart 212.51[a][8]).Temporary roads are 

authorized by contract, special use permit, lease, or other written authorization; they are not NFS 

roads and are not included in any NFS transportation atlas. Temporary roads do not require an 

amendment to the travel management plan. 

3.21.1.1 State Highways

There are three main state highways in the project area: NM 4, NM 126, and NM 96. For NM 4 

the 2014 annual average daily traffic (AADT) was 3,198 vehicles (New Mexico Department of 
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Santa Fe National Forest Geothermal Leasing EIS 3-173

Transportation [NMDOT] 2014). For NM 126, the 2014 AADT was 2,700 vehicles (NMDOT 

2014), and for NM 96, the 2014 AADT was 1,238 vehicles (NMDOT 2014). These state 

highways are two-lane roads with narrow shoulders, and they traverse the forested and 

mountainous terrain typical of this part of northern New Mexico.

The Jemez Mountain Trail National Scenic Byway follows NM 4 for 21.8 miles in the project 

area (Forest Service GIS 2015). NM 4 is a popular 1-day loop drive, connecting Albuquerque 

with Los Alamos and Santa Fe, and is the main access to the developed campgrounds, picnic 

areas, and trailheads. NM 4 also travels directly through the Pueblo of Jemez and is often highly 

congested during the summer and fall, with tourists, recreation vehicles, and day visitors. NM 

126 is also in the project area, for a total of 6.2 miles (Forest Service GIS 2015). NM 126 

provides access to Fenton Lake and Cuba, located west of the project area. NM 96, along the 

northern project boundary for 10.4 miles, connects Abiquiu with Coyote, Gallina, Regina, and 

other towns and villages to the west of the project area (Forest Service GIS 2015). It is less 

popular with tourists.

3.21.1.2 SFNF Roads and Trails

The SFNF has implemented the Travel Management Rule that requires all National Forests and 

Grasslands to designate a system of roads, trails, and areas for motorized use and to prohibit 

motor vehicle use off the designated system. Any operations related to the geothermal leases will 

require specific authorizations, and will be exempt from the Travel Management Plan (36 CFR, 

Subpart 212.51[a][8]).

To address concerns about the impacts of unmanaged off-highway vehicles, the Forest Service

published final travel management regulations for motor vehicle use on National Forests and 

Grasslands on November 9, 2005. The Travel Management Rule “provides for a system of NFS

roads, NFS trails, and areas on NFS lands that are designated for motor vehicle use. After these 

roads, trails, and areas are designated, motor vehicle use, including the class of vehicle and time 

of year, not in accordance with these designations is prohibited.”

On the SFNF, complying with the Travel Management Rule means the following: 

 No cross-country motorized travel except in designated areas

 Identification of roads and trails that are open for motorized use

 Designation of the limited use of motor vehicles within a specified distance of certain 

designated routes and, such as within specified periods, solely for the purposes of dispersed 

camping or retrieval of a big game animal by an individual who has legally killed that 

animal

 A Forest Plan that reflects these management classifications and is consistent with the Travel 

Management Rule (Forest Service 2012)

The 2015 SFNF Motor Vehicle Use Maps provide a comprehensive overview of system roads 

and trails on the SFNF. These maps show which roads and trails are open to motor vehicle travel, 

what type of vehicle they are open to, and what season they are open. Within the project area, 

roads and trails are as follows (Forest Service GIS 2015):

 Miles of paved main roads—19

 Miles of dirt main roads—125
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3-174 Santa Fe National Forest Geothermal Leasing EIS

 Miles of dirt roads—908

 Miles of motorized trails—74

Forest Road 376 travels through the most used motor vehicle-dispersed recreation area on the

SFNF. An estimated 97,000 to 110,000 people travel on this road every year. Forest Road 10 is 

another highly used motor vehicle recreation corridor; 93,000 to 107,000 people travel through 

and recreate along this road every year. Forest Road 10 provides primary access to other 

dispersed recreation areas along Forest Roads 266, 270, and 269. The dispersed camping 

corridor along Forest Road 144 serves as an overflow area for the Forest Road 376 recreation 

area when it is full (Forest Service 2015b). Other Forest roads in the project area also experience 

high-volume visitation during the peak summer season.

3.21.2 Environmental Consequences

3.21.2.1 Scoping Comments on Resource

The following issues specific to transportation and access were identified during the public 

scoping period:

 How would increased traffic affect residents, visitors, and other Forest users?

 What would the impacts be on road conditions and adjacent buildings as a result of increased

traffic?

3.21.2.2 How Resource Impacts Were Evaluated

Method

Information from the National Visitor Use Monitoring surveys (NVUM 2013), the SFNF Travel 

Management EIS and ROD (Forest Service 2012), SFNF GIS (Forest Service GIS 2015), and 

traffic counts from the NMDOT (2014) were used to estimate the number of visitors to the area, 

the travel management issues on the Forest, areas of greatest use in the project area, and the 

overall issues that would be encountered under the analyzed alternatives. 

Indicators

Potential impacts on transportation and access could occur if reasonably foreseeable future 

actions were to have the following impacts:

 Change traffic patterns or volume

 Change access to public or private roads

Assumptions

This analysis assumes the following:

 Making land potentially available to geothermal leasing, as included under Alternatives 1, 2, 

and 4, would not impact transportation or access; however, impacts could occur if applicants 

propose exploration or production. These impacts would be considered in future site-specific 

analyses under NEPA.

 Potential future geothermal activities could improve motorized access, with a possible 

increase in traffic and congestion from large construction vehicles operating during 

exploration and development.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-175

3.21.2.3 Common Impacts Associated with Geothermal Development

Due to the inability to predict the location, scope, scale, and timing of future development, the

following impact analysis provides a general description of common impacts on transportation 

and access from geothermal development. The information presented in the Development section 

of the 2008 Geothermal PEIS may also be referenced (BLM and Forest Service 2008).

If the geothermal resources in the project area are explored or used, there could be impacts on 

traffic and access along the primary routes in the project area (NM 4, NM 96, and NM 126). This 

would be due to additional vehicles, such as large trucks, drilling rigs, cranes, construction 

trailers, or other long-wheelbase vehicles. 

Impacts could include increased congestion. This is because the use of these large vehicles with 

limited turning radii and potentially heavy loads that make acceleration difficult would likely 

slow other traffic in the steep, narrow roads with limited sight distance that are typical of the 

project area. These potential increases in congestion and traffic would mostly be temporary and 

limited to exploration and development, in contrast to the operational phase of geothermal 

development; this requires fewer large vehicles and would result in minor or negligible impacts 

on transportation or access. Such measures as traffic control plans, signage, and travel time 

restrictions in the road use authorization could help to mitigate the temporary impacts on traffic 

and access during exploration and development (see Appendix C). 

If the geothermal resources in the project area were explored or used, there could be impacts 

from the development of new roads or improvements to existing roads. The RFDS (BLM 2015) 

estimates that under the exploration phase, approximately 10 miles of current 12-foot-wide roads 

may be widened by up to 8 feet—for a total road width of 20 feet—to accommodate large drill 

rigs and tractor-trailers. These existing two-track roads vary in condition, but generally would 

require widening, along with grading and other minor improvements to accommodate seismic 

activities or exploratory drilling. Fewer vehicles and trips would be involved with exploratory 

activities, compared with development and utilization (BLM 2015).

During the development and utilization phases, the BLM (2015) estimates that the 10 miles of 

roads used during exploration may be widened by an additional 2 feet—for a total road width of 

22 feet. This is because access roads would have to be at a higher standard than for gradient-well 

drilling: the drill rig for a full-diameter well is transported to the site by tractor-trailer. The 

number of trips for both heavy and light vehicles would be significantly greater than under the 

exploration phase. Transporting the drill rig and ancillary equipment to the site may require 

approximately 15 to 20 trips by full-sized tractor-trailers; the same number would be required to 

demobilize the rig. The size of the material-supply trucks and water trucks would necessarily be 

larger than for a temperature-gradient well, and the number of trips would be proportionally 

greater, given the greater well depth. A full-diameter drilling operation typically has from 10 to 

15 people on-site at all times, with more coming and going periodically with equipment and 

supplies, which may increase traffic and congestion (BLM 2015).

In addition, there would be impacts from the construction of new temporary roads associated 

with development and utilization phases in the project area. The temporary roads would be 

adequate for exploration and development equipment and trucks to get from geothermal sites to a 

landing or main road and could be decommissioned after use. A temporary road is one that is 

authorized by contract, special use permit, lease, or other written authorization that is not an NFS

road and that is not included in an NFS transportation atlas. Any temporary roads would not 

require an amendment to the Travel Management Plan.
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3-176 Santa Fe National Forest Geothermal Leasing EIS

3.21.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. Impacts would be

similar to those identified under Common Impacts Associate with Geothermal Development, 

such as temporary increases in congestion and traffic limited to the use of large, long-wheelbase 

construction vehicles in the exploration and development phases. Under Alternative 1, there 

would be no amendment to the Travel Management Plan.

3.21.2.5 Impacts Under Alternative 2

Direct and indirect impacts would be the same as those described under Alternative 1. However, 

implementing closures and stipulations may limit the volume of traffic in those areas. TLs

imposed on drilling operations and construction would reduce the volume of traffic from March 

1 to September 30, compared to Alternative 1.

3.21.2.6 Impacts Under Alternative 3

Under Alternative 3, the SFNF would amend the Forest Plan to implement discretionary closures 

to geothermal leasing on all lands in the project area not already closed to leasing. There would 

be no direct or indirect impacts on transportation or access, compared to Alternative 1.

3.21.2.7 Impacts Under Alternative 4

Direct and indirect impacts would be the same as those described under Alternative 2.

3.21.2.8 Cumulative Impacts

Consenting to the issue a geothermal lease has no direct impact on the environment (40 CFR, 

Subpart 1508.8[a]); however, it is a commitment of the resource for potential future exploration, 

drilling operations and development, utilization, and reclamation and abandonment. These would 

be subject to environmental review under NEPA and project-specific permitting from the BLM 

and the SFNF. However, any future development of geothermal resources may result in impacts, 

whether significant or not. It is reasonable, therefore, to foresee that on-the-ground impacts on

transportation and access may occur if the Forest Service consents to leasing and the BLM issues 

geothermal leases. Those impacts would not occur, however, until some point in the future, 

following several decision stages. 

Past and present activities that have had cumulative impacts on transportation and access are 

mining, ranching, timber cutting, road building, road decommissioning, off-road vehicle riding, 

developing the LANL, and implementing the travel management plan. In addition, the 2014

transfer of Valles Caldera to a National Preserve under the management of the NPS has increased 

access, visitor days, and overall traffic on NM 4 and portions of the project area next to the 

caldera.

Reasonably foreseeable future actions are the proposed South Pit Pumice Mine Expansion, the 

Duran 2010 Pumice Mine, and the Valles Caldera nomination under the Geothermal Steam Act 

of 1970 (30 USC, Section 1019). The two pumice mines on the Jemez Ranger District could 

have a minor cumulative impact on transportation and access. Further, if the VCNP is designated 

as a significant thermal feature under the Geothermal Steam Act, development in areas near to 

the caldera, or those with hydrological connections, may not be leased; this would reduce

potential indirect impacts on transportation and access, such as increased congestion. Other 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-177

reasonably foreseeable actions could include potential fire management activities, timber sales, 

mineral leases, and transmission lines. 

Incremental cumulative impacts would not be anticipated under Alternative 3, because the 

project area would be closed to geothermal leasing. Under Alternatives 1, 2, and 4, incremental 

cumulative impacts on transportation and access would increase traffic and congestion. 

However, these would be temporary impacts associated with exploration and development. 

3.22 Climate Change

3.22.1 Affected Environment

Climate

Climate is defined as the generally prevailing weather conditions of a particular region 

throughout the year, averaged over a series of years. Climate is both a driving force and a 

limiting factor for biological, ecological, and hydrologic processes, as well as for resource 

management of public lands. 

The climate of the project area is generally mild. The summer and fall are characterized by warm 

daytime temperatures and cold nights. In the summer, the climate is abundant in sunshine, with 

large variations between daytime and nighttime temperatures. Peak precipitation occurs in late 

summer and early fall, when moisture from the Gulf of Mexico moves into the region. 

Table 3-37, below, shows monthly climate normal data from 1981 to 2010 for select towns 

within the buffer zones of the project area. Climate normals are three-decade averages of 

climatological variables produced by the National Oceanic and Atmospheric Administration, 

National Climatic Data Center, every 10 years. Monthly summary tables of these data, along 

with average annual snowfall, were obtained from the Western Regional Climate Center. 

Table 3-37. Average Temperatures and Precipitation in the Project Area (1981–2010)

Location

Average Maximum 

Temperature (°F)

Average Minimum 

Temperature (°F)

Average Precipitation 

(in inches)

Average 

Snow in 

Jan Jul Annual Jan Aug Annual June Aug Annual Inches

Los 

Alamos

39.6 81.1 60.4 18.6 53.3 36.3 1.56 3.42 19.03 53.2

Santa Fe 43.8 86.2 65.4 18.3 54.0 36.0 1.25 2.23 14.19 21.0

Source: WRCC 2014

Climate Change

Climate change is an identifiable change in climate over time due to natural processes and 

variability or as a result of human activity (IPCC 2014). 

According to the most recent assessment from the Intergovernmental Panel on Climate Change 

(IPCC), humans are the primary cause of climate change through emissions of GHGs. The earth 

has a natural greenhouse impact, wherein naturally occurring gases, such as water vapor, carbon 

dioxide, methane, and nitrous oxide, absorb and retain heat. Without the natural greenhouse 

impact, the earth would be approximately 60°F cooler. Climate change is caused in part by the 
Chapter 3. Affected Environment and Environmental Consequences

3-178 Santa Fe National Forest Geothermal Leasing EIS

increase in GHGs in the atmosphere beyond naturally occurring levels. Over time the amount of 

energy sent from the sun to the earth’s surface should be approximately the same as the amount 

of energy radiated back into space, leaving the temperature of the earth’s surface roughly 

constant. Increased levels of GHGs trap more heat in the atmosphere and result in average 

overall warming of temperatures over time.

From 1983 to 2012, the northern hemisphere experienced what is likely the warmest 30-year 

period in the last 1,400 years, and global temperatures have increased 1.53oF since 1880 (IPCC 

2014). A climate change vulnerability assessment for biodiversity in New Mexico identified the 

following climate trends (Enquist and Gori 2008):

 Mean annual temperatures have risen across New Mexico and the southwestern United 

States since the early twentieth century. Relative to a 1961 to 1990 baseline, both the 1991 to 

2005 and 2000 to 2005 periods show temperature increases in over 95 percent of the 

geographical area of New Mexico. The magnitude of warming varied across the state, with 

the greatest warming in northwestern, central, and southwestern New Mexico.

 In New Mexico, mean annual temperatures increased 0.6°F per decade, with a 1.8°F overall 

change since 1976, when averaged across the state’s eight climate divisions. Mean winter 

temperatures are most responsible for this rise, yet springtime temperatures have also risen.

 Precipitation changes vary across New Mexico, with 54 percent of the state tending toward 

wetter conditions, 41 percent toward drier conditions, and 5 percent showing no change 

during the 1991 to 2005 period, compared to 1961 to 1990 baseline conditions.

Climate change has potentially disruptive consequences for agriculture, water supply, 

transportation, coastal communities, the economy, energy, ecosystems, and national security. 

Observed climate change has impacted natural and human systems, regardless of its cause, 

underscoring the sensitivity of natural and human systems to changing climate (IPCC 2014). In 

New Mexico, climate change is likely to exacerbate the impacts of natural and altered 

disturbance regimes, including wildfire, insect outbreaks, flooding, and erosion, across all habitat 

types and may prompt abrupt ecological changes. This is particularly true in such ecosystems as 

grasslands, riparian areas, and forests, where the impacts of past management and land use 

change are substantial (Enquist and Gori 2008). Climate change scenarios predict that annual 

runoff in the Southwest will decrease by as much as 20 percent (Furniss et al. 2010). In addition, 

a reduction of Southwest mountain snowpack during February through May is anticipated, due to 

higher temperatures. Climate variations of temperature and precipitation over short periods 

(year-to-year and decade-to-decade) are expected to continue to be a prominent feature of the 

Southwest climate (Cayan et al. 2013).

Mid- to high-elevation forests and woodlands have experienced the highest levels of climate 

change effects since the late twentieth century, particularly in terms of mean temperature 

increases. The forests and woodlands in northwestern New Mexico have been subjected to 

consistently warmer and drier conditions. Elevated moisture stress in forests and woodlands of 

the southwestern United States has been shown to amplify the impacts of ecological disturbance 

regimes, such as insect outbreaks and fire, in addition to increasing the risk of large-scale forest 

diebacks. These disturbances are expected to increase under the warmer and drier conditions that 

most climate models predict for twenty-first century climate in the region (Enquist and Gori 

2008).
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-179

Greenhouse Gases

GHGs are compounds that contribute to climate change by trapping heat in the atmosphere. They

absorb infrared radiation and radiate a portion of that radiation back to the earth’s surface, thus 

trapping heat and warming the atmosphere. The most important naturally occurring GHG 

compounds are carbon dioxide (CO2), methane, nitrous oxide, ozone, and water vapor. CO2, 

methane, and nitrous oxide are produced naturally by the following processes:

 Respiration and other physiological processes of plants, animals, and microorganisms 

 Decomposition of organic matter

 Volcanic and geothermal activity

 Naturally occurring wildfires

 Natural chemical reactions in soil and water

Ozone is not released directly by natural sources but forms during complex chemical reactions in 

the atmosphere among organic compounds and nitrogen oxides in the presence of ultraviolet 

radiation. While water vapor is a strong GHG, its concentration in the atmosphere is primarily a 

result and not a cause of changes in surface and lower atmospheric temperature conditions. 

Although naturally present in the atmosphere, concentrations of CO2, methane, and nitrous oxide 

are also produced by industrial processes, transportation technology, urban development, 

agriculture, and other human activity. Globally, atmospheric CO2 concentrations have increased 

from an estimated 277 parts per million before 1750 to approximately 395 parts per million in 

2013 (Global Carbon Project 2014). 

In the United States, GHG emissions come mostly from energy use. Such emissions result from 

combustion of fossil fuels used for electricity generation, transportation, industry, heating, and 

other needs. In 2009, the electric power sector was the largest source, accounting for 40 percent 

of all energy-related CO2 emissions; the transportation sector was the second-largest source, at 

34 percent of total emissions (EIA 2011). 

The EPA estimated that national GHG emissions in 2014 (the most recent year for which

national data has been tabulated) totaled 6,873 million metric tons of carbon dioxide equivalents 

(CO2e; a measure that accounts for the global warming potential of the different GHGs; EPA 

2015). 

The most recently available comprehensive inventory of statewide GHG emissions for New 

Mexico occurred in 2007. It showed gross GHG emissions of 76.2 million metric tons of CO2e 

(NMED 2010). This state-wide inventory was 1.02 percent of total US emissions for that same 

year (7,480 million metric tons of CO2e). 

Large emitters are required to report their GHG emissions to the EPA annually. Reported sources 

in Rio Arriba County were nine petroleum and natural gas systems, which emitted 405,735 

metric tons of CO2e. Reported sources in Sandoval County include two landfills, a wallboard 

plant, and an electronics manufacturing facility that emitted 206,035 metric tons of CO2e (EPA 

2014).

3.22.2 Environmental Consequences

3.22.2.1 Scoping Comments on Resource

The following issues specific to climate change were identified during the public scoping period:
Chapter 3. Affected Environment and Environmental Consequences

3-180 Santa Fe National Forest Geothermal Leasing EIS

 How would the SFNF address climate change and GHG emissions from geothermal leasing?

 Would geothermal leasing affect regional weather conditions?

3.22.2.2 How Resource Impacts Were Evaluated

Method

The method for climate change compares estimated GHG emissions from well drilling, the 

primary source of temporary emissions from geothermal development, against national and state 

GHG emission levels and against the indicator described below. The analysis also compares 

GHG emissions associated with geothermal power production against GHG emissions from 

other sources of energy generation.

Indicators

On September 22, 2009, the EPA released final regulations for a Greenhouse Gas Monitoring 

Rule (see 74 Federal Register 56260). The reporting rule requires suppliers of fossil fuels or 

industrial GHGs, manufacturers of vehicles and engines, and facilities that emit 25,000 metric 

tons or more per year of GHG emissions to submit annual reports to the EPA. As there are no 

CAA significance thresholds for evaluating GHGs, this analysis compares likely GHG emissions 

from each alternative against the Greenhouse Gas Monitoring Rule.

Assumptions

The analysis makes the following assumption:

 BMPs, such as those identified in Appendix C, would be applied at the BLM permitting 

level to minimize impacts on air quality from exploration, drilling operations, utilization, and 

reclamation and abandonment. Minimization of equipment-related air quality impacts also

would minimize GHG emissions from this equipment.

 Based on existing temperature gradient data, binary cycle power plants (which operate at 

lower temperatures than flash steam plants or dry steam plants) are the most likely 

technology that would be developed in the project area. Therefore, this analysis does not 

assess the potential impacts of flash steam or dry steam geothermal power plants. Binary

plants are closed-loop systems and do not emit GHGs during their operation. For this reason, 

only GHG emissions from exploration and development are evaluated. 

 Binary plants would use air cooling rather than wet cooling.

 There is a correlation between global concentrations of GHGs and climate change. However, 

it is not currently possible to link projected GHG emissions associated with any particular 

activity to specific environmental impacts at a specific site or location.

3.22.2.3 Common Impacts Associated with Geothermal Development

The information on climate change presented in the Common Impacts on Air Quality and 

Atmospheric Values Associated with Geothermal Development section of the PEIS is 

incorporated here by reference (this section of the PEIS also addresses climate change and 

GHGs). Leasing would have no direct impacts related to climate change or emissions of GHGs.

Temporary emissions of CO2 and methane from equipment use would occur during all phases of 

geothermal development. Sources of these temporary GHG emissions are vehicles, truck traffic, 

and construction equipment required for exploration, well drilling, and power plant construction. 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-181

Exploration

Exploration would result in exhaust-related CO2 emissions and much smaller amounts of 

methane from vehicles and construction and drilling equipment. Sources of emissions are the 

following:

 Gas- and diesel-powered construction equipment for exploration road development

 Drill rigs and auxiliary equipment to develop temperature gradient wells and slim wells

 Tractor trailers to bring in and move out construction and drilling equipment

 Water trucks for dust suppression during road construction and to bring in water for mixing 

drilling fluids during well development

 Delivery trucks for supplies

 Commute vehicles for road construction and drill rig personnel

Table 3-38 provides estimated CO2 emissions from geothermal development under the RFDS. 

The time frame for geothermal exploration is 1 to 5 years.

Table 3-38. Geothermal Development Exploration Well Carbon Dioxide Emissions

Activity CO2 (tons) 1

On-road vehicle exhaust (tons per well) 10

Unpaved road dust (tons per well) 0

Paved road dust (tons/well) 0

Drill rig and auxiliary equipment (tons per well) 82

Total (tons per well) 92

Total2(tons per RFDS [20 wells]) 1,840

Source: Forest Service 2016d

1Assumptions for equipment use, vehicle miles traveled, and drilling times and durations, along with emission 

spreadsheet tables, are provided in the Air Quality Technical Report (Forest Service 2016d).

2Emissions from vehicle travel would likely be less under the full RFDS, as drill rig equipment and other 

construction equipment would likely be moved from well site to well site, resulting in fewer miles traveled than 

calculated for a single well development.

In addition to the drilling-related CO2 emissions shown in Table 3-38, on-road construction 

equipment for road development would produce CO2 emissions and much smaller amounts of 

methane. BMPs, such as those identified in Appendix C, would be applied at the permit level. 

Measures to mitigate equipment exhaust emissions, if applied, would also reduce CO2 emissions.

Temperature gradient wells do not typically encounter the geothermal resource; therefore, no 

release of naturally occurring non-condensable gases, comprised mostly of carbon dioxide, 

would occur. Slim wells do encounter the geothermal resource and thus have the potential to 

release CO2 during development.

Exploration would disturb approximately 27 acres, primarily for exploration road development. 

Removing vegetation and disturbing soil releases the soil organic carbon and the carbon stored in 

the vegetation. 
Chapter 3. Affected Environment and Environmental Consequences

3-182 Santa Fe National Forest Geothermal Leasing EIS

Development Drilling and Utilization

Development drilling and utilization would result in exhaust-related CO2 emissions and much 

smaller amounts of methane from vehicles and construction and drilling equipment. Sources of 

emissions are the following:

 Gas- and diesel-powered construction equipment for well pad, transmission line, pipeline, 

road, and power plant construction

 Drill rigs and auxiliary equipment to develop production and injection wells

 Tractor trailers to bring in and move out construction and drilling equipment and materials to 

construct the power plants

 Water trucks for dust suppression during road construction and to bring in water for mixing 

drilling fluids during well development

 Delivery trucks for supplies

 Commute vehicles for construction and drill rig personnel

Well drilling has the potential to release non-condensable gases, primarily CO2. Noncondensable gases would be emitted during flow testing and would last until the well is shut in 

or connected to the pipeline.

Table 3-39 depicts potential CO2 emissions associated with geothermal development. The time 

frame for geothermal exploration is 2 to 10 years.

Table 3-39. Geothermal Development Well Drilling Carbon Dioxide Emissions

Activity CO2 (tons) 1

On-road vehicle exhaust (tons per well) 38

Unpaved road dust (tons per well) 0

Paved road dust (tons per well) 0

Drill rig and auxiliary equipment (tons per well) 802

Total (tons per well) 840

Total (tons per 6 wells, or 1 power plant) 5,040

Total2(tons per RFDS [30 wells]) 25,200

Source: Forest Service 2016d

1Assumptions for equipment use, vehicle miles traveled, and drilling times and durations, along with emission 

spreadsheet tables, are provided in the Air Quality Technical Report.

2Emissions from vehicle travel would likely be less under the full RFDS, as drill rig equipment and other 

construction equipment would likely be moved from well site to well site, resulting in fewer miles traveled than 

calculated for a single well development.

In addition to the development drilling-related emissions shown in Table 3-39, the following 

construction activities would produce CO2 emissions and much smaller amounts of methane:

 Non-road construction equipment emissions for well pad, transmission line, pipeline, road, 

and power plant construction

 On-road vehicle equipment emissions from material and equipment deliveries, water trucks, 

concrete trucks, and construction personnel commute vehicles
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-183

As described under Exploration, BMPs, such as those identified in Appendix C, would be 

applied at the permit level. Measures to mitigate equipment exhaust emissions, if applied, would 

also reduce CO2 emissions.

In addition to equipment and vehicle emissions, well drilling has the potential to release noncondensable gases. The amount and ratio of the constituents in the geothermal resource varies by 

geology, with carbon dioxide generally comprising over 95 percent of the non-condensable 

gases. Emissions of non-condensable gases would occur during flow testing and would continue 

until the well is shut in or connected to the pipeline.

Development and utilization would disturb approximately 647 acres for well pads, transmission 

lines, pipelines, roads, and power plant facilities. Removing vegetation and disturbing soil 

releases the soil organic carbon and the carbon stored in the vegetation. 

Power Plant Operation

Under the RFDS, five 25-megawatt geothermal binary cycle power plants would operate for a 

period of 30 to 50 years. The RFDS estimates that each plant would employ 9 shift workers and 

up to 12 additional workers per day. CO2 emissions would be limited primarily to vehicle and 

maintenance equipment emissions, including vehicle commute traffic, delivery traffic, and onsite maintenance truck and equipment use.

Operating a closed binary cycle geothermal power plant does not emit CO2, except from well 

venting during maintenance and potentially if there are leaks. The plants would use air cooling 

and therefore would not emit steam into the environment. Development of the power plants 

would have an indirect impact on GHG emissions if the power produced by the plants were to 

displace electricity generated by conventional sources of electricity. Geothermal power 

production creates less CO2 per kilowatt-hour of electricity produced than burning fossil fuels. It 

would have a positive net impact on CO2 emissions if used in place of fossil fuel extraction. 

Compared to coal and natural gas, geothermal energy has a smaller carbon footprint and lower 

gaseous emissions (Matek 2013). 

Table 3-40, below, compares CO2 emissions for a composite of geothermal power plant

technology versus fossil fuel plants. As shown, geothermal plants emit significantly less CO2

(Bloomfield et al. 2003). Because the geothermal technology used in the project area would be 

air-cooled binary plants, no CO2 would be emitted from operation of the plants. 

Table 3-40. Comparison of Geothermal and Fossil Fuel Carbon Dioxide Emissions

Geothermal Coal Petroleum Natural Gas

Emissions (pounds of CO2 per kilowatt-hour) 0.2 2.095 1.969 1.321

Source: Bloomfield et al. 2003

3.22.2.4 Impacts Under Alternative 1

Under Alternative 1, the SFNF would not make an availability determination for geothermal 

leasing in the project area. Geothermal lease applications and nominations would continue to be 

processed; however, they would be evaluated on a case-by-case basis under separate NEPA

analysis, in accordance with the Forest Plan and existing laws and regulations. 

Alternative 1 would have no direct climate change impacts. 
Chapter 3. Affected Environment and Environmental Consequences

3-184 Santa Fe National Forest Geothermal Leasing EIS

Indirect impacts would include the production of GHG emissions during all phases of 

geothermal development, including construction and well drilling. GHGs would be produced 

through the combustion of fuels used by construction equipment and construction-related 

vehicles. GHGs would also be emitted during well drilling as the CO2 is released from the 

geothermal resource itself. Carbon would be released from the removal of vegetation and 

disturbance of soils on approximately 760 total acres. Any BMPs or measures designed to reduce 

equipment and vehicle exhaust emissions to minimize impacts on air quality would also reduce 

GHG emissions.

As shown under Common Impacts Associated with Geothermal Development, well drilling 

during exploration would emit an estimated 1,840 tons of CO2 under the RFDS (20 temperature 

gradient and slim wells), while well drilling under exploration would emit an estimated 25,200 

tons of CO2 under the RFDS (30 production wells). These emissions would occur over the life of 

the exploration phase (1 to 5 years) and development phase (2 to 10 years); thus these activities 

would emit less than the referenced 25,000 metric tons of GHG per year under the EPA’s GHG 

Monitoring Rule, which is used as an indicator in this analysis. They would also represent less 

than 1 percent of national and state emission levels.

GHG emissions associated with the operation of geothermal power plants would include 

commute traffic, maintenance traffic, and truck deliveries and potential releases of CO2 during 

maintenance. GHG emissions from each power plant would be expected to be well below the 

25,000 metric tons per year reporting limit under the Greenhouse Gas Monitoring Rule.

As described under Common Impacts Associated with Geothermal Development, geothermal 

power plant development could have an indirect impact, if power produced by the geothermal 

plant were to displace electricity generated by conventional fossil fuel sources of electricity and 

thus offset CO2 emissions that would otherwise be provided by fossil fuel-produced electricity. 

3.22.2.5 Impacts Under Alternative 2

Indirect impacts would be the same as those described for Alternative 1.

3.22.2.6 Impacts Under Alternative 3

Under Alternative 3, there would be no geothermal development and no emissions of GHGs. 

3.22.2.7 Impacts Under Alternative 4

Indirect impacts would be similar to those described for Alternative 1.

3.22.2.8 Cumulative Impacts

The cumulative impacts analysis region of influence for GHG emissions is northern New 

Mexico. Past and present actions and events in this analysis area have directly emitted GHGs and 

caused carbon to be released from soils and vegetation. Past and present actions and conditions 

that have contributed GHGs to the atmosphere are urban development (population increases 

spurring development), mineral development, energy production, fossil fuel burning (primarily 

transportation-related use), and wildfire. These sources will continue to emit GHGs in the future. 

Reasonably foreseeable future actions in the immediate project area from vegetation and water 

resources management, described in Section 3.3.4, would temporarily emit GHGs from vehicles

and equipment; surface disturbance also would release carbon during vegetation removal and 

soil disturbance.
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-185

Current scientific technology makes it difficult to link a specific action to a specific climate 

change-related impact. Emissions of GHGs from construction under Alternatives 1, 2, and 4 

would be small in the context of broader emissions. However, over the long term, these actions, 

in combination with other GHG-emitting actions, do contribute to total global emission levels. 

These, in turn, could contribute to future long-term, anticipated climate changes to a small

degree. Overall, the contribution of geothermal development under Alternatives 1, 2, and 4 

would be a very small portion of the total from other sources of a regional and global nature. In 

addition, GHG production would be temporary, because the plants would not emit GHGs. 

Therefore, GHG emissions under Alternatives 1, 2, and 4 would not be cumulatively significant. 

Alternatives 1, 2, and 4 would result in five 25-MW binary geothermal plants being brought 

online, which would have the potential to reduce GHG emissions from other sources of 

nonrenewable energy.

3.23 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, Subpart 1502.16). 

As declared by Congress, this includes using all practicable means and measures, such as 

financial and technical assistance, in a manner calculated to foster and promote the general 

welfare, to create and maintain conditions under which humans 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).

For this EIS, short term refers to the steps needed to develop a geothermal resource (exploration, 

drilling, testing, and construction). Long term refers primarily to the 15-year time frame 

described within the RFDS.

The exploration and testing phase of a geothermal project is designed to determine the nature 

and extent of the geothermal resource, including boundaries, controls on permeability, 

temperature distribution, and fluid flow paths. Generally, this phase lasts 1 to 5 years. Where 

such exploration proves unsuccessful, these lands would not be used for subsequent development 

and production; instead they would be restored as much as possible to their original condition on 

completion of exploration and testing.

If geothermal activities progress beyond the exploration and testing phase into the development 

and production phases, the lands could be affected to a greater extent. The short-term uses of the 

environment associated with anticipated future actions—exploration, drilling, land clearing, 

plant construction, operation, maintenance, and plugging and final reclamation, as detailed in the 

RFDS—consistent with implementation of Alternatives 1, 2, and 4, include impacts on the 

natural and human environment, as detailed in each resource section of this chapter. These shortterm impacts can be compared to the long-term productivity associated with long-term 

renewable energy production. Under Alternative 3, all lands in the project area would be closed 

to leasing, and there would be short-term uses or long-term productivity associated with 

geothermal development.

Over the long term, while geothermal plants are in production, low-cost and renewable energy

would be generated. Geothermal power production creates less CO2 per kilowatt-hour of 

electricity produced than burning fossil fuels. Compared to coal and natural gas, geothermal 

energy has a smaller carbon footprint and lower gaseous emissions (Matek 2013). Therefore, 

geothermal energy development would offset the use of irretrievable resources, such as coal and 

oil, which would reduce GHG emissions.
Chapter 3. Affected Environment and Environmental Consequences

3-186 Santa Fe National Forest Geothermal Leasing EIS

In addition, while in production, each plant would provide employment opportunities for citizens 

of surrounding communities, and energy sales would generate revenue for Rio Arriba and 

Sandoval Counties. 

3.24 Unavoidable Adverse Impacts

Consenting to geothermal leasing and the subsequent issuing of leases would not result in any 

unavoidable adverse impacts. These impacts would be assessed during the permitting process 

and on a site-specific basis. If geothermal leases were developed, adverse impacts would be 

expected. Because the RFDS anticipates development of leases under Alternatives 1, 2, and 4, 

the following impacts would be applicable to these alternatives:

 Long-term loss of vegetation, wildlife habitat, soil, and soil quality. The stipulations in the 

EIS would reduce these impacts as described under Section 3.8, Soil Resources, Section 

3.11, Vegetation, Section 3.12, Fish and Wildlife, and Section 3.13, Threatened and 

Endangered Species and Special Status Species.

 Short-term and intermittent noise impacts from construction and maintenance as described 

under Section 3.20, Noise.

 Possible loss of recreation opportunities from energy infrastructure, although new roads 

could provide access for additional recreation opportunities, as described under Section 3.4, 

Land Use, Recreation, and Special Designations.

 Long-term visual impacts from power plants and infrastructure. The degree to which visual 

impacts would occur would vary by alternative, as described in Section 3.17, Visual 

Resources.

There would be no unavoidable adverse impacts under Alternative 3, as all lands in the project 

area would be closed to geothermal leasing.

3.25 Irreversible and Irretrievable Commitments of 

Resources

This section describes the irreversible and irretrievable commitments of resources associated 

with implementing the alternatives. Resources irreversibly or irretrievably committed by a 

proposed action are those used on a long-term or permanent basis. Irreversible resource 

commitments occur when there is unavoidable destruction of natural resources that could limit 

the range of potential uses of that particular environment. Irreversible commitments apply 

primarily to nonrenewable resources, such as cultural resources, and also to those resources that 

are renewable only over long periods, such as soil productivity or forest health. Irretrievable 

resource commitments occur when an action causes the use or consumption of a resource that is 

neither renewable nor recoverable for future use. Irretrievable commitments apply to loss of 

production, harvest, or use of natural resources. These include the use of nonrenewable resources 

such as metal, fuel, and other natural or cultural resources considered irretrievable, in that they 

would be used for the proposed action when they could have been conserved or used for other 

purposes.

No irreversible commitments of resources would result from the Forest Service providing 

consent to geothermal leasing. In addition, stipulations outlined under the action alternatives 

would be applicable to future phases of leasing and development, and lessees would be required 

to complete a site-specific NEPA analysis outlining their proposed action and alternatives and the 

direct and indirect impacts associated with their proposed action, before any occupancy and 
Chapter 3. Affected Environment and Environmental Consequences

Santa Fe National Forest Geothermal Leasing EIS 3-187

surface disturbance. Nevertheless, anticipated future development actions that may follow 

leasing consistent with implementation of any of the alternatives discussed in Chapter 2 could 

result in a variety of irreversible and irretrievable commitments of resources, below.

3.25.1 Geologic Resources and Energy and Mineral Resources

The principal commitment of resources in implementing the proposed action would be the 

depletion of thermal energy and water from the geothermal reservoirs tapped for energy use. To 

minimize this impact, the hot water extracted from the geothermal reservoirs through production 

wells would be injected back into the reservoir for reheating and reuse. Over time, these 

resources (heat and water) could be depleted to the point that the power generating plant would 

no longer be economically productive.

3.25.2 Water Resources

Because of the large volume and long duration of geothermal fluid production, the production 

stage of resource development is likely to have the greatest potential for impact on hydrologic 

resources. These impacts could occur in terms of changes to the hydraulics of the geothermal and 

groundwater reservoirs and spent geothermal fluid disposal. The result could include a reduction 

in spring discharge rates and lowering of water levels in wells. Reinjecting spent geothermal 

fluids could also introduce low-quality fluids to groundwater pathways that discharge at springs 

or wells. This could also affect the quality of available water. Disposal of spent geothermal fluids 

on the surface could create large pools of low-quality water. Changes in spring flow and 

development of spent fluid-holding ponds could impact wetlands-supported ecosystems and 

habitats. As a result, hydrologic impacts associated with geothermal development could have 

secondary impacts in the plant and animal community supported by natural or created wetlands

3.25.3 Vegetation

Introduction of noxious weeds by construction and support vehicles into previously clean areas 

would be probable during all phases of geothermal development. The drilling and utilization 

phases would present the greatest opportunity for noxious weed introduction and proliferation. 

Once introduced, control or eradication of noxious weeds could be difficult.

3.25.4 Threatened and Endangered Species

Loss of any species is irretrievable. Protection of threatened, endangered, and special status 

species is governed by federal and state statute. To minimize the impacts on threatened, 

endangered, and special status species, lessees would be required to complete a site-specific 

NEPA analysis, outlining their proposed actions and alternatives, and the direct and indirect 

impacts of their proposed actions, on any threatened, endangered, and special status species 

before any occupancy and surface disturbance. Site-specific compliance with the ESA would 

occur at the time of development.

3.25.5 Visual Resources

Any changes in the characteristic landscape of the affected areas due to geothermal energy 

development could be visible for many years. Succession (change in habitat type over time, 

including the return of an area to its pre-development state after site reclamation/rehabilitation) 

in the project area is slow, due to generally low annual precipitation. Rehabilitation techniques 

could use nonindigenous plant species, thus changing the character of the area. The degree of 

contrast between a reclaimed project site and its untouched surroundings would vary by area, 

rehabilitation techniques, and the success of those techniques. All landscapes are unique in their 
Chapter 3. Affected Environment and Environmental Consequences

3-188 Santa Fe National Forest Geothermal Leasing EIS

own right, and any change or loss of scenic values is irretrievable. Those losses become more 

significant in areas of unique or outstanding scenic quality.

3.25.6 Hazardous Materials and Waste and Solid Waste

If handled improperly, hazardous materials and waste and solid waste have the potential to create 

irretrievable consequences. The hazardous materials used or generated during exploration, 

drilling, and utilization activities are petroleum, oils, lubricants, solvents, paints, herbicides, 

geothermal fluids, hydrogen sulfide contained in geothermal fluid or steam, and drilling muds. 

The use of hazardous materials during each stage of development is described in the 2008 

Geothermal Programmatic EIS (BLM and Forest Service 2008). The transportation, storage, use, 

and disposal of hazardous materials and waste and solid waste are governed by federal and state 

statutes. To minimize the impacts of hazardous materials and waste and solid waste, lessees 

would be required to complete site-specific NEPA analyses, outlining their proposed actions and 

alternatives and the direct and indirect impacts of hazardous materials and waste and solid waste 

associated with their proposed actions before any occupancy and surface disturbance.
Chapter 4. Consultation and Coordination

Santa Fe National Forest Geothermal Leasing EIS 4-1

Chapter 4. Consultation and Coordination

4.1 Preparers and Contributors

The Forest Service consulted the individuals, federal, state, and local agencies, tribes, and other 

organizations below during the development of this environmental impact statement.

4.1.1 Interdisciplinary Team Members

Santa Fe National Forest Interdisciplinary Team Members

Team Member Responsibility Education Years of Relevant 

Experience

Will Amy Wildlife Program Manager BS Natural Resource 

Sciences

17

Anne Baldwin Supervisory Archeologist BA Anthropology MA 

Cultural Anthropology

40

Christine Bishop Rangeland Program Manager BS Wildlife Biology

MS Rangeland Ecology

12

Michael Bremer Forest Archaeologist BA Anthropology MA 

Anthropology

40

Mathew Chavez Range Management 

Specialist

BS in Wildlife Science

BS in Range Science

6

Jennifer Cramer Social Interest, Economics, 

and Environmental Justice

BA Biology

PhD Plant Biology

6

Michael Frazier R/H/L/M/E Staff Officer BA Liberal Arts 

BS Forestry

44

Larry Gore Project Manager, Geologist BS Geology

MS Geology

26

Cliff Gibbons Safety and Occupational 

Health Specialist

BS Biology 17

Joshua Hall Air Quality Specialist MS Environmental 

Science 

MA Environmental 

Policy and Natural 

Resource Management

11

Lee Harrelson Forest Engineer BS Civil Engineering 31

Sandy Hurlocker NEPA Specialist BS Science Ed.

MS Journalism

25

Heidi Klingel Soils and Hydrology 

Specialist 

BS Earth Science

MS Geosciences

11

Julie Luetzelschwab Forest Resource Information 

Coordinator

BA, MA Environmental 

Geography

19

Steve Miranda Fire Management Specialist BS Rangeland 

Management

22

Cecil Rich Fish Biologist BS Biology

MS Fish Ecology

PhD Fisheries and 

Aquatic Science

20
Chapter 4. Consultation and Coordination

4-2 Santa Fe National Forest Geothermal Leasing EIS

EMPSi – Environmental Management and Planning Solutions, Inc. (Contractor)

Team Member Resource/Resource Program Education Years of 

Experience

David Batts Principal-in-Charge MS Natural Resource 

Planning

23

Kevin Rice Project Management, Biological 

Resources

BS Environmental 

Science

6 

Kevin Doyle Cultural Resources, Tribal 

Interests and Traditional Cultural 

Resources, QA

BA Sociology 31

Nick Parker Land Use, Recreation, Special 

Designations, and 

Transportation and Access

MA Archaeology

BA Earth Science and 

Cultural Geography

16 

Katie Patterson Geologic Resources JD Environmental Law 7 

Alex Finch Geologic Resources JD Natural Resources 

Law and Policy

4 

Melissa Estep Soil and Water Resources BS Industrial & Systems 

Engineering

4 

Laura Patten Air Quality, Climate Change MS Environmental Law 

and Policy

5

Amy Cordle Air Quality, Climate Change BS Civil Engineering 18 

Daniel Robinson Biological Resources BS Wildlife Ecology and 

Conservation

10 

Kate Krebs Visual Resources BA Environmental 

Studies, Spanish

10 

Drew Vankat Health and Safety, Noise, MS Environmental Policy 

and Planning

11 

Zoe Ghali Social Interests, Economics, and 

Environmental Justice

MS Integrative Physiology 

(Environmental 

Physiology)

8 

Sarah Crump Social Interests, Economics, and 

Environmental Justice

BA Environmental 

Studies, Political Science

3 

Holly Prohaska Livestock Grazing/QA MS Environmental 

Management

15 

Marcia Rickey GIS MS Biology, Conservation 

Biology Sequence

15 

Jacob Accola GIS BA Environmental Design 2 

Cooperating Agency Team Members and Other Contributors 

Team Member Resource/Resource Program Education Years of 

Experience

Linda Dansby Energy and Minerals 

Coordinator, Intermountain 

Region, NPS

BS Biology 38

Fraser Goff Geothermal Consultant to the 

NPS

BS Chemistry

PhD Earth Sciences

41
Chapter 4. Consultation and Coordination

Santa Fe National Forest Geothermal Leasing EIS 4-3

Cooperating Agency Team Members and Other Contributors 

Team Member Resource/Resource Program Education Years of 

Experience

Ross Klein Natural Resource Specialist –

Minerals, BLM

BS Renewable Natural 

Resources

MS Rangeland Ecology 

and Management

8

Sheila Mallory Deputy State Director, BLM BS Geology

MS Economic Geology

15

Mark Meyer Renewable Energy Visual 

Resource Specialist, Air 

Resources Division, NPS

BS Design Landscape 

Architecture 

MS Natural Science

34

Robert Parmenter Biological Scientist/Division 

Chief, Science and Resource 

Stewardship, Valles Caldera, 

NPS

BA Biology

MS Zoology

PhD Biology/Ecology

42

Mark Peyton Wildlife Biologist/Technician, 

Valles Caldera National 

Preserve, NPS

MS Forestry

MS Wildlife Science

12

Ana Steffen Archaeologist, Valles Caldera 

National Preserve, NPS

BA 

Anthropology/Archaeology

MS 

Anthropology/Archaeology

PhD 

Anthropology/Archaeology

25

Randy Stanley Natural Sounds & Night Skies 

Coordinator, Intermountain 

Region, NPS

BSE Acoustical 

Engineering

M.Eng Acoustics

18

Martina Suazo Plant Ecologist/Technician, 

Valles Caldera National 

Preserve, NPS

BS Biology 5

John Swigart Cartographer, Valles Caldera 

National Preserve, NPS

BA Anthropology

MA Anthropology

20

4.1.2 Federal, State, and Local Agencies

• Bureau of Land Management

• National Park Service

4.1.3 Tribes

• Canoncito Navajo Chapter House

• Counselor Navajo Chapter House

• Crownpoint Navajo Chapter House

• Ojo Encino Navajo Chapter House

• Ramah Navajo Chapter House

• Torreon Navajo Chapter House

• Whitehorse Lake Navajo Chapter House
Chapter 4. Consultation and Coordination

4-4 Santa Fe National Forest Geothermal Leasing EIS

• Jicarilla Apache Nation

• Mescalero Apache Tribe

• Ohkay Owingeh

• Kewa Pueblo (Pueblo of Santo Domingo)

• Pueblo of Acoma

• Pueblo of Cochiti

• Pueblo of Isleta

• Pueblo of Jemez

• Pueblo of Laguna

• Pueblo of Nambé

• Pueblo of Picuris

• Pueblo of Pojoaque

• Pueblo of San Felipe

• Pueblo de San Ildefonso

• Pueblo of Santa Ana

• Pueblo of Santa Clara

• Pueblo of Taos

• Pueblo of Tesuque

• Pueblo of Zia

• Pueblo of Zuni

• Pueblo Pintado Navajo Chapter House

• Southern Ute Tribe

• The Hopi Tribe

• The Navajo Nation

• Ute Mountain Ute Tribe

4.1.4 Others

• Los Alamos National Laboratory

4.2 List of Agencies, Organizations and Persons Who Were 

Sent Copies of the DEIS

4.2.1 Federal

• Advisory Council on Historic Preservation

• USDA, Animal and Plant Health Inspection Service

• USDA, Natural Resources Conservation Service

• USDA, National Agriculture Library

• National Oceanic and Atmospheric Administration

• US Army Corps of Engineers

• US Environmental Protection Agency 

• US Department of Energy
Chapter 4. Consultation and Coordination

Santa Fe National Forest Geothermal Leasing EIS 4-5

• Department of Interior, Office of Environmental Policy and Compliance

• Federal Aviation Administration

• US Department of Transportation, Federal Highway Administration

In addition, all individual, organizations, and agencies on the project mailing list received

notification of the availability of the DEIS.
Chapter 4. Consultation and Coordination

4-6 Santa Fe National Forest Geothermal Leasing EIS

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Chapter 5. Glossary

Santa Fe National Forest Geothermal Leasing EIS 5-1

Chapter 5. Glossary

Allotment: An area of land where one or more operators graze their livestock. It generally 

consists of public lands but may include parcels of private or state-owned lands. The number of 

livestock and period of use are stipulated for each allotment.

Animal unit month (AUM): The amount of forage necessary for the sustenance of one cow or 

its equivalent for a period of one month (approximately 800 pounds of air-dried material per 

AUM). A full AUM’s fee is charged for each month of grazing by adult animals if the grazing 

animal 1) is weaned, 2) is six months or older when entering public land, or 3) will become 12 

months old during the period of use. For fee purposes, an AUM is the amount of forage used by 

five weaned or adult sheep or goats or one cow, bull, steer, heifer, horse, or mule. The term AUM 

is commonly used in three ways: 1) stocking rate, as in X acres per AUM, 2) forage allocation, 

as in X AUMs in allotment A, and 3) utilization, as in X AUMs consumed from Unit B.

Assessment: The act of evaluating and interpreting data and information for a defined purpose.

Best management practices (BMPs): A suite of techniques that guide, or may be applied to, 

management actions to aid in achieving desired outcomes. 

Buffer: An area of specified width where certain activities may not occur. Buffers are usually 

defined around special sensitive resources, such as archaeological sites, or along each side of a 

stream, or near other features to be protected from human disturbance. 

Controlled surface use (CSU): The CSU stipulation is intended for application where standard 

lease terms and permit-level decisions are deemed insufficient to achieve the level of resource 

protection necessary to protect the public interest, but where an NSO is deemed overly 

restrictive. A CSU is not required if relocating a proposed facility or activity by up to 200 meters 

would be sufficient to protect the specified resources.

Condition of approval (COA): A site-specific and enforceable requirement included in an 

approved application for permit to drill or sundry notice that may limit or amend the specific 

actions proposed by the operator. Conditions of approval minimize, mitigate, or prevent impacts 

on resource values or other uses of public lands.

Direct use: Use of geothermal resources for commercial, residential, agricultural, or public 

facilities or for energy needs other than the commercial production of electricity.

Endangered species: As defined in the federal Endangered Species Act, any species that is in 

danger of extinction throughout all or a significant portion of its range. For terrestrial species, the 

US Fish and Wildlife Service determines endangered status.

Environmental impact statement (EIS): A written analysis of the impacts on the natural, 

social, and economic environment of a proposed project or resource management plan.

Erosion: The wearing away of the land surface by rain or irrigation water, wind, ice, or other 

natural or human agents that abrade, detach, and remove geologic parent material or soil from 

one point on the earth’s surface and deposit it elsewhere.
Chapter 5. Glossary

5-2 Santa Fe National Forest Geothermal Leasing EIS

Exception: A one-time exemption for a particular site in a leasehold. Exceptions are determined 

on a case-by-case basis, and the stipulation continues to apply to all other sites in the leasehold. 

An exception is a limited type of waiver.

Federal land: Land owned by the United States without reference to how the land was acquired 

or which federal agency administers it, including mineral and coal estates underlying private 

surface.

Geographic information system (GIS): A computer system capable of storing, analyzing, and 

displaying data and describing places on the earth’s surface.

Geothermal energy: Natural heat from within the earth, captured for production of electric 

power, space heating, or industrial steam.

Geothermal plant: A plant powered by a steam turbine. The turbine is driven either by steam 

produced from hot water or by natural steam that derives its energy from heat found in rocks or 

fluids at various depths beneath the surface of the earth. The energy is extracted by drilling or 

pumping.

Geothermal resource: All products of geothermal processes, embracing indigenous steam, hot 

water, and hot brines; steam and other gases; hot water and hot brines resulting from water, gas, 

or other fluids artificially introduced into geothermal formations; the heat of other associated 

energy found in geothermal formations; and any byproduct derived from them.

Hot dry rock: A type of geothermal technology that refers to the formation of a fully engineered 

geothermal reservoir in hot crystalline rock by the application of hydro-shearing and subsequent 

circulation of water through that engineered reservoir to mine the thermal energy from the hot 

rock.

Indirect use: Commercial electrical generation from geothermal resources.

Invertebrates: Animals without back bones.

Known geothermal resource area (KGRA): A region identified by the US Geological Survey 

as containing geothermal resources. New leasing regulations no longer use KGRAs as a basis for 

the leasing process.

Lease stipulation: A condition of lease issuance that provides a level of protection for other 

resource values or land uses by restricting lease operations during certain times or locations or to 

avoid unacceptable impacts, to an extent greater than standard lease terms or regulations. A 

stipulation is an enforceable term of the lease contract, supersedes any inconsistent provisions of 

the standard lease form, and is attached to and made a part of the lease. Lease stipulations further 

implement the Forest Service’s regulatory authority to protect resources or resource values. 

Lease stipulations are developed through the land use planning process.

Locatable mineral: A mineral subject to location under the 1872 Mining Laws. Examples of 

such minerals are gold, silver, copper, and lead, as compared to oil and natural gas, which are 

leasable minerals.

Modification: A change to the provisions of a lease stipulation, either temporarily or for the 

term of the lease. Depending on the specific modification, the stipulation may or may not apply 

to all sites within the leasehold to which the restrictive criteria are applied.
Chapter 5. Glossary

Santa Fe National Forest Geothermal Leasing EIS 5-3

National Environmental Policy Act (NEPA) of 1969: A law enacted on January 1, 1970, that 

established a national policy to maintain conditions under which humans and nature can exist in 

productive harmony and fulfill the social, economic, and other requirements of present and 

future generations of Americans. It established the Council on Environmental Quality for 

coordinating environmental matters at the federal level and to serve as the advisor to the 

president on such matters. The law made all federal actions and proposals that could have 

significant impact on the environment subject to review by federal, state, and local 

environmental authorities.

Native (indigenous) species: A species of plant or animal that naturally occurs in an area and 

that was not introduced by humans.

National Forest System lands: Forests and grasslands that the Forest Service manages. Includes 

both lands reserved from the federal estate and acquired lands. 

No surface occupancy (NSO): A fluid minerals leasing constraint that prohibits occupancy or 

disturbance on all or part of the lease surface to protect special values or uses. Lessees may 

exploit the fluid mineral resources under the leases restricted by this constraint through the use 

of directional drilling from sites outside the NSO area.

Open: Generally denotes that an area is available for a particular use or uses. Refers to specific 

program definitions found in law, regulations, or policy guidance for application to individual 

programs. For example, 43 CFR, Subpart 8340.0-5, defines the specific meaning of open as it 

relates to off-highway vehicle use.

Permitted use: The forage allocated by, or under the guidance of, an applicable land use plan for 

livestock grazing in an allotment under a permit or lease, expressed in AUMs (43 CFR, Subpart

4100.0-5).

Project area: Potential geothermal leasing areas on National Forest Service lands that were 

identified for the analysis to determine consent to leasing.

Renewable energy: Resources that constantly renew themselves or that are regarded as 

practically inexhaustible. Examples are solar, wind, geothermal, hydro, and wood. Although 

particular geothermal formations can be depleted, the natural heat in the earth is a virtually 

inexhaustible reserve of potential energy. Renewable resources also include some experimental 

or less developed sources, such as tidal power, sea currents, and ocean thermal gradients.

Right-of-way: An easement or permit that authorizes public land to be used for a specified 

purpose that generally requires a long narrow strip of land. Examples are roads, power lines, and 

pipelines.

Seismic exploration: This remains the most common way to locate subsurface resources. The 

process involves sending sound waves into the earth at one point and recording them at other

points after they have passed through different geological strata. There are two common methods 

used today. The first involves the detonation of small explosive charges; the other consists of a 

truck that drops a huge weight at various intervals. The data collected is used to show probable 

subsurface resource deposits.

Site visit: The entry of one person on a site or area to participate in recreation for an unspecified 

period.
Chapter 5. Glossary

5-4 Santa Fe National Forest Geothermal Leasing EIS

Special status species: Includes proposed species, listed species, and candidate species under 

the ESA and Forest Service sensitive species, as defined in Forest Service Manual 2670.5 as 

“those plant and animal species identified by a Regional Forester for which population viability 

is a concern, as evidenced by 1) significant current or predicted downward trends in population 

numbers or density, or 2) significant current or predicted downward trends in habitat capability 

that would reduce a species’ existing distribution”

Standard lease terms and conditions: Areas may be open to leasing with no specific 

management decisions; however, these areas are subject to lease terms and conditions, as defined 

on the lease form (Form 3100-11, Offer to Lease and Lease for Oil and Gas; and Form 3200-24, 

Offer to Lease and Lease for Geothermal Resources).

State implementation plan: A strategic document, prepared by a state or other authorized air 

quality regulatory agency and approved by the US Environmental Protection Agency, which 

thoroughly describes how requirements of the Clean Air Act will be implemented, including 

standards to be achieved, control measures to be applied, and enforcement actions in case of 

violation.

Stipulation: A condition of lease issuance that provides protection for other resource values or 

land uses by establishing authority for substantial delay or site changes or the denial of 

operations within the terms of the lease contract.

Stipulation standards: The physical and temporal conditions, resources, or resource values that 

must be present and met for application of a specific stipulation to a specific lease.

Tectonic: A field of study in geology concerned generally with the structure of the crust of the 

earth and particularly with the forces and movements that have operated in a region to create 

geomorphic features. 

Thermal resources: A subsurface heat source, heat-conducting rock formation, and air or water 

that circulates through the formation and may discharge at the surface such resource features as 

geysers, hot springs, mudpots, fumaroles, unique and rare mineral precipitates and formations, 

and hydrophilic biotic communities. 

Timing limitation (TL): This stipulation limits activity during a specified period of the year. A 

TL stipulation is intended for application where standard lease terms are deemed insufficient to 

achieve the level of resource protection necessary to protect the public interest, but where an 

NSO is deemed overly restrictive. The scope of the TL stipulation goes beyond grounddisturbing activities to encompass any source of protracted or high-intensity disturbance that 

could interfere with normal wildlife behavior and adversely affect habitat use. The limitation is 

applied annually for a specified period lasting more than 60 days. Under the proposed plan, TLs 

may also be applied to land uses and activities other than oil and gas development.

Transmission: The movement or transfer of electric energy over an interconnected group of 

lines and associated equipment between points of supply and points where it is transformed for 

delivery to consumers or is delivered to other electric systems. Transmission is considered to end 

when the energy is transformed for distribution to the consumer.

Threatened species: 1) Any species that is likely to become endangered within the foreseeable 

future throughout all or a significant portion of its range, and 2) as further defined by the 

Endangered Species Act of 1973.
Chapter 5. Glossary

Santa Fe National Forest Geothermal Leasing EIS 5-5

Tribal interests: Native American or Native Alaskan economic rights, such as Indian trust 

assets, resource uses and access guaranteed by treaty rights, and subsistence uses. 

Traditional cultural resources or properties: Areas of cultural importance to contemporary 

communities, such as sacred sites or resource gathering areas. 

Utility: A regulated entity that exhibits the characteristics of a natural monopoly. For the 

purposes of electric industry restructuring, it refers to a regulated, vertically integrated electric 

company. Transmission utility refers to the regulated owner or operator of the transmission 

system only. Distribution utility refers to the regulated owner or operator of the distribution 

system that serves retail customers.

Vertebrate: Animals with back bones, including fish, amphibians, reptiles, birds, and mammals.

Viewshed: The natural environment that is visible from one or more viewing points.

Waiver: A permanent exemption from a lease stipulation that no longer applies anywhere within 

the leasehold.

Watershed:

• First Level: The first level of classification divides the nation into 21 major geographic 

areas, or regions. These geographic areas contain either the drainage area of a major river, or 

the combined drainage areas of a series of rivers.

• Second Level: The second level of classification divides the 21 regions into 221 subregions. 

A subregion includes the area drained by a river system, a reach of a river and its tributaries 

in that reach, a closed basin(s), or a group of streams forming a coastal drainage area. 

• Third Level: The third level of classification subdivides may of the subregions into 

accounting units. These 378 hydrologic accounting units are nested within, or can be 

equivalent to the subregions.

• Fourth Level: The four level of classification is the cataloging unit. A cataloging unit is a 

geographic area representing part of or all of a surface drainage basin, a combination of 

drainage basins, or distinct hydrologic feature. These units subdivide the subregions and 

accounting units into smaller areas. There are 2,264 cataloging units in the Nation.

Watt: The electrical unit of power. The rate of energy transfer equivalent to 1 ampere flowing 

under a pressure of 1 volt at unity power factor.

Watt-hour: An electrical energy unit of measure equal to 1 watt of power supplied to, or taken 

from, an electric circuit steadily for 1 hour.

Wilderness area: An area of public land designated by an act of Congress to be protected in its 

natural condition according to the requirements of the Wilderness Act of 1964.
Chapter 5. Glossary

5-6 Santa Fe National Forest Geothermal Leasing EIS

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Chapter 6. References

Santa Fe National Forest Geothermal Leasing EIS 6-1

Chapter 6. References

Alcantara, Adelamar N. 2008. New Mexico County Population Projections July 1, 2005 to July 1, 

2035. University of New Mexico. Bureau of Business and Economic Research. July 

2008. Internet website: http://unmwest.unm.edu/common/docs/reports/B_Projections_

Summary_Narrative.pdf. 

Aldrich, M. J., Jr., and A. W. Laughlin. 1984. “A model for the tectonic development of the 

southeastern Colorado plateau boundary.” Journal of Geophysical Research

89(B12):10,207–10,218.

All Pueblo Council of Governors. 2015. Resolution Number APCG 2015-11, Close the Santa Fe

National Forest to Energy and Mineral Development and Support Designation of Jemez 

Mountains as a Traditional Cultural Property. Albuquerque, New Mexico. August 10, 

2015.

Alves, J. E., K. A. Patten, D. E. Brauch, and P. M. Jones. 2008. Range-wide status of Rio Grande

cutthroat trout (Oncorhynchus clarki virginalis): 2008. Unpublished report and Microsoft 

Access database. Internet website: http://www.wildlife.state.nm.us/download/

conservation/species/fish/reports-publications/2008-RGCT-Status-Assessment.pdf. 

Amy, W., and C. Cook. 2012. Santa Fe National Forest Management Indicator Species 

Assessment: February 2012 Update. Internet website: http://www.fs.usda.gov/Internet/

FSE_DOCUMENTS/stelprd3795730.pdf.

Andren, H. 1994. Effects of habitat fragmentation on birds and mammals in landscapes with 

different proportions of suitable habitat: A review. Oikos 71(3):355–366.

Aneke, M., B. Agnew, C. Underwood. 2011. “Performance analysis of the Chena binary 

geothermal power plant.” Applied Thermal Engineering 31:1825–1832.

Behnke, R. J. 2002. Trout and Salmon of North America. Illustrated by Joseph R. Tomelleri; 

foreword by Thomas McGuane. First edition. Free Press, New York City, New York. 

Bingler, Edward C. 1968. Bulletin 91: Geology and Mineral Resources of Rio Arriba County, 

New Mexico. State Bureau of Mines and Mineral Resources. New Mexico Institute of 

Mining and Technology. Socorro, New Mexico. Internet website: https://geoinfo

.nmt.edu/publications/monographs/bulletins/downloads/91/Bulletin091.pdf. 

Biota Information System of New Mexico. 2006. Species Booklet for Bald Eagle, White-tailed 

Ptarmigan, Northern Leopard Frog, Gray Vireo, Pale Townsend’s Big-Eared Bat, and 

Spotted Bat. Internet website: http://www.bison-m.org/simplespeciessearch.aspx. 

_____. 2008. Species Booklet for American Peregrine Falcon. Internet website: http://www.bisonm.org/simplespeciessearch.aspx. 

_____. 2015. Species Booklet for Jemez Mountains Salamander. Internet website: 

http://www.bison-m.org/booklet.aspx?id=020060.

_____. 2016. Species Booklet for Goat Peak Pika and American Pika. Internet website: 

http://www.bison-m.org/simplespeciessearch.aspx. 
Chapter 6. References

6-2 Santa Fe National Forest Geothermal Leasing EIS

BLM (US Department of the Interior, Bureau of Land Management) and Forest Service (US

Department of Agriculture, Forest Service). 2008. Programmatic Environmental Impact 

Statement for Geothermal Leasing in the Western United States. Internet website: 

http://www.blm.gov/wo/st/en/prog/energy/geothermal/geothermal_nationwide/

Documents/Final_PEIS.html.

BLM (US Department of the Interior, Bureau of Land Management). 2014. October 2014 

Competitive Oil and Gas Lease Sale Decision Record. Farmington Field Office, 

Farmington, New Mexico. 

_____. 2015. Reasonably Foreseeable Development Scenario: Santa Fe National Forest 

Geothermal Leasing EIS Project. Santa Fe National Forest, New Mexico. Unpublished 

report. BLM, New Mexico State Office, Santa Fe, New Mexico.

Bloomfield, K. Kit (INEEL), Joseph N. Moore (EGI), and Robert M. Neilson, Jr. (INEEL). 2003. 

CO2 “Emissions from geothermal energy facilities are insignificant compared to power 

plants burning fossil fuels.” Climate Change Research. Internet website: 

http://www.geothermal.org/PDFs/Articles/greenhousegases.pdf. 

BLS (US Bureau of Labor Statistics). 2015. US Department of Labor. Data Finder. Internet 

website: http://www.bls.gov/home.htm.

Bogan, M. A., T. J. O’Shea, E. W. Valdez, A. M. Ditto, and K. T. Castle. 1998. Continued Studies 

of Bat Species of Concern in the Jemez Mountains, New Mexico. LA-UR-98-5691. 

December 1998. Albuquerque, New Mexico.

Brohman, R., and L. Bryant (editors). 2005. Existing Vegetation Classification and Mapping 

Technical Guide. Gen. Tech. Rep. WO–67. USDA, Forest Service, Ecosystem 

Management Coordination Staff. Washington, DC.

Brooks, M., and M. Lusk. 2008. Fire Management and Invasive Plants: A Handbook. United 

States Fish and Wildlife Service, Arlington Virginia.

Brown, D. 2009. “Hot dry rock geothermal energy: Important lessons from Fenton Hill.” Paper 

presented at 34th Workshop on Geothermal Reservoir Engineering, Stanford University,

Palo Alto, California. February 9 to 11, 2009.

Brown, D. W., D. V. Duchane, G. Heiken, V. T. Hriscu. 2012. Mining the Earth’s Heat: Hot Dry 

Rock Geothermal Energy. Springer, New York, New York.

Bunning, E., and Moser, I. 1968. Interference of moonlight with the photoperiodic measurement 

of time by plants, and their adaptive reaction. Institute of Biology, University of 

Tubingen, Germany. December 2, 1968.

Calamusso, B., J. N. Rinne, P. R. Turner. 2002. “Distribution and abundance of the Rio Grande 

sucker in the Carson and Santa Fe National Forests, New Mexico.” The Southwestern 

Naturalist 47(2):182–286.

Cayan, D. M., M. Tyree, K. E. Kunkel, C. Castro, A. Gershunov, J. Barsugli, et al. 2013. “Future 

Climate: Projected Average” in Assessment of Climate Change in the Southwest United 

States: A Report Prepared for the National Climate Assessment. A report by the 

Southwest Climate Alliance. Washington, DC. 
Chapter 6. References

Santa Fe National Forest Geothermal Leasing EIS 6-3

Chespesiuk, R. 2009. “Missing the dark: Health effects of light pollution.” Environmental Health 

Perspectives 117(1):A20–A27.

Clark, R. N., and G. H. Stankey. 1979. The recreation opportunity spectrum: A framework for 

planning, management, and research, Gen. Tech. Rep. PNW-GTR-098. Portland, Oregon: 

USDA Forest Service, Pacific Northwest Research Station. Internet website: 

https://iucn.oscar.ncsu.edu/mediawiki/images/b/b4/Clark%281979%29.pdf. 

Clark, C. E., C. B. Harto, J. L. Sullivan, M. Q. Wang. 2011. Water Use in the Development and 

Operation of Geothermal Power Plants. Energy Systems Division, Argonne National 

Laboratory. Argonne, Illinois.

Cornely, J. E., L. N. Carraway, and B. J. Verts. 1992. “Sorex preblei.” Am. Soc. Mamm., 

Mammalian Species 416:1–3.

Degenhardt, W., C. Painter, and A. Price. 1996. Amphibians and Reptiles of New Mexico. 

University of New Mexico Press, Albuquerque.

Delaney, D. K., T. G. Grubb, P. Beier, L. L. Pater, and H. Reiser. 1999. “Effects of helicopter 

noise on Mexican spotted owls.” Journal of Wildlife Management 63:60–76.

DeNavas-Walt, Carmen, and Bernadette D. Proctor. 2015. US Census Bureau, Current Population 

Reports, P60-252, Income and Poverty in the United States: 2014. US Government 

Printing Office, Washington, DC.

Dickson, M. H., and M. Fanelli. 2003. Geothermal Energy: Utilization and Technology. UNESCO 

Renewable Energy Series. Paris, France.

DOE (Department of Energy). 2016. Geothermal Technical Working Paper No 4: Hydraulic 

Stimulation. Internet website: https://www1.eere.energy.gov/geothermal/pdfs/twp4_

hydraulic_stimulation-public_comments_final_draft.pdf.

_____. 2015. Geothermal Technology Breakthrough in Alaska: Harvesting Heat below Boiling 

Temperatures. Internet website: http://energy.gov/eere/success-stories/articles/geo

thermal-technology-breakthrough-alaska-harvesting-heat-below. 

DOE and BLM. 2003. Opportunities for Near-Term Geothermal Development on Public Lands in 

the Western United States. Produced for the US Department of Energy by the National 

Renewable Energy Laboratory, Golden, Colorado.

Dolley, Thomas P. 2008. USGS: 2008 Minerals Yearbook; Mica. United States Geological

Survey. Reston, Virginia.

Dransfield, B. J., and J. N. Gardner. 1985. Subsurface Geology of the Pajarito Plateau, Española 

Basin, New Mexico. Los Alamos National Laboratory, LA-10455-MS. Los Alamos, New 

Mexico.

Dreesen, D., J. Harrington, T. Subirge, P. Stewart, and G. Fenchel. 2002. Riparian Restoration in 

the Southwest – Species Selection, Propagation, Planting Methods, and Case Studies. 

USDA-NRCS New Mexico. Internet website: http://www.nrcs.usda.gov/Internet/

FSE_PLANTMATERIALS/publications/nmpmcsy03852.pdf. 
Chapter 6. References

6-4 Santa Fe National Forest Geothermal Leasing EIS

Duchane, D., and D. Brown. 1995. Hot Dry Rock Geothermal Energy Development in the USA. 

Los Alamos National laboratory, Los Alamos, New Mexico.

Dunbar, N. W. 2010. “The Jemez Mountains and the Valles Caldera.” In: The Geology of 

Northern New Mexico’s Parks, Monuments, and Public Lands (L. Greer Price, editor). 

New Mexico Bureau of Geology and Mineral Resources. Pp. 126–134.

EIA (US Energy Information Administration). 2011. Emissions of Greenhouse Gases in the 

United States in 2009. March 2011. Washington, DC.

_____. 2014. Supply and Disposition of Electricity. Internet website: http://www.eia.gov/

electricity/annual/html/epa_01_03.html. 

_____. 2015a. Geothermal resources used to produce renewable electricity in western states. 

Internet website: http://www.eia.gov/todayinenergy/detail.cfm?id=17871.

_____. 2015b. New Mexico: State Profile and Energy Estimates – Profile Analysis. Internet 

website: http://www.eia.gov/state/analysis.cfm?sid=NM.

_____. 2016. Table 5. Electric Power Industry Generation by Primary Energy Source, 1990-2014. 

Internet website: https://www.eia.gov/electricity/state/newmexico/. 

Enquist, Carolyn, and Dave Gori. 2008. “A climate change vulnerability assessment for 

biodiversity in New Mexico, part I: Implications of recent climate change on 

conservation priorities in New Mexico.” April 2008. Internet website: 

http://nmconservation.org/dl/NMClimateChange_report1_527.pdf. 

EPA (US Environmental Protection Agency). 2013. National Emissions Inventory. Internet 

website: www.epa.gov/ttn/chief/net/2011inventory.html. Version 1 released September 

30, 2013.

_____. 2014. 2014 Greenhouse Gas Emissions from Large Facilities, Rio Arriba and Sandoval 

Counties. Internet website: http://ghgdata.epa.gov/ghgp/main.do.

_____. 2015. Inventory of US Greenhouse Gas Emissions and Sinks: 1990-2-013. Internet 

website: http://www3.epa.gov/climatechange/ghgemissions/usinventoryreport

.html#fullreport.

_____. 2016a. National Ambient Air Quality Standards. Internet website: http://www.epa.gov/

air/criteria.html. 

_____. 2016b. The Green Book Nonattainment Areas for Criteria Pollutants. Internet website: 

http://www3.epa.gov/airquality/greenbook/. 

_____. 2016c. Air Data Monitor Values Report. Internet website: http://www3.epa.gov/

airdata/ad_rep_mon.html.

_____. 2016d. Promising Practices for Environmental Justice Methodologies in NEPA Reviews. 

Report of the Federal Interagency Working Group on Environmental Justice and NEPA 

Committee. Washington, DC.
Chapter 6. References

Santa Fe National Forest Geothermal Leasing EIS 6-5

Falchi, F., P. Cinzano, C. D. Elvidge, D. M. Keith, and A. Haim. 2011. Limiting the impact of 

light pollution on human health, environment and stellar visibility. Journal of 

Environmental Management (92): 2714–2722.

Faust, C. R., J. W. Mercer, S. D. Thomas, and W. P. Balleau. 1984. “Quantitative analysis of 

existing conditions and production strategies for the Baca geothermal system, New 

Mexico.” Water Resources Research 20(5):601–618.

Federal Highway Administration. 2011. Highway Traffic Noise: Analysis and Abatement 

Guidance. FWHA-HEP-10-025. Washington, DC.

Fialko, Yuri, and Mark Simons. 2001. “Evidence for ongoing inflation of the Socorro magma 

body, New Mexico, from interferometric synthetic aperture radar imaging.” Geophysical 

Research Letters 20:3549–3552. 

Findley, J. S. 1987. The Natural History of New Mexican Mammals. University of New Mexico 

Press, Albuquerque. 

Finger, John, and Doug Blankenship. 2010. Handbook of Best Practices for Geothermal Drilling. 

SAND2010-6048. Sandia National Laboratories, Albuquerque, New Mexico.

Forest Service (US Department of Agriculture, Forest Service). 1977. Final Environmental 

Impact Statement—Geothermal Leasing for the Santa Fe National Forest, US Forest 

Service, Southwestern Division, Albuquerque, New Mexico.

_____. 1987. Santa Fe National Forest Plan, as amended. Albuquerque, New Mexico.

_____. 1990. Conserving Endangered Species: A Commitment to the Future. Forest Service

Southwestern Region. Albuquerque, New Mexico.

_____. 2003. First Amended Programmatic Agreement Regarding Historic Property Protection 

and Responsibilities among New Mexico Historic Preservation Officer and Arizona 

Historic Preservation Officer and Texas and Oklahoma and the Advisory Council on 

Historic Preservation and the United States Department of Agriculture Forest Service 

Region 3. Southwestern Region, Albuquerque, New Mexico.

_____. 2005. Terrestrial Ecological Unit Inventory Technical Guide: Landscape and Land Unit 

Scales. General Technical Report WO-68. Washington, DC.

_____. 2010. Southwest Jemez Mountains Landscape Assessment Report. Santa Fe National 

Forest, Sandoval County, New Mexico. September 2010.

_____. 2011. Watershed Condition Framework, A Framework for Assessing and Tracking 

Changes to Watershed Condition. FS-977. Internet website: http://www.fs.fed.us/sites/

default/files/Watershed_Condition_Framework.pdf. 

_____. 2012. Record of Decision for Travel Management on the Santa Fe National Forest, Santa 

Fe, New Mexico.

_____. 2013. Nonnative and Invasive Plant Species Specialist Report for the Southwest Jemez 

Mountains Landscape Restoration Project. Santa Fe National Forest, Sandoval County, 

New Mexico. June 2013.
Chapter 6. References

6-6 Santa Fe National Forest Geothermal Leasing EIS

_____. 2014a. Biological Evaluation 1 of Sensitive Species, Southwest Jemez Mountains 

Restoration Project. USDA Forest Service, Santa Fe National Forest, Sandoval County, 

New Mexico.

_____. 2014b. National Visitor Use Monitoring. Internet website: http://apps.fs.usda.gov/

nfs/nrm/nvum/results/ReportCache/Rnd3_A03010_Master_Report.pdf.

_____. 2015a. Strategic Plan: Fiscal years 2015-2020. Internet website: http://www.fs.fed.us/

sites/default/files/strategic-plan%5B2%5D-6_17_15_revised.pdf. 

_____. 2015b. Final Environmental Impact Statement for the Southwest Jemez Mountains 

Landscape Restoration Project. Santa Fe National Forest, Sandoval County New Mexico. 

MB-R3-10-22. August 2015.

_____. 2015c. Santa Fe National Forest Plan Draft Assessment Report, Volume II. 

Socioeconomic Resources. Santa Fe National Forest, Santa Fe, New Mexico. 

_____. 2015d. Santa Fe National Forest Plan Draft Assessment Report. Volume I. Ecological 

Resources. Santa Fe National Forest, Santa Fe, New Mexico.

_____. 2016a. Santa Fe National Forest Geothermal Leasing EIS, Inventoried Roadless Areas

Report. Santa Fe, New Mexico. 

_____. 2016b. Continental Divide Trail. Internet website: http://www.fs.usda.gov/recmain/

santafe/recreation.

_____. 2016c. Santa Fe National Forest Geothermal Leasing EIS, Soils and Water Specialist 

Report. Santa Fe National Forest, Santa Fe, New Mexico.

_____. 2016d. Santa Fe National Forest Geothermal Leasing EIS, Air Technical Report. Prepared 

by Environmental Management and Planning Solutions, Inc. February 2016; revised June 

2016.

_____. 2016e. Santa Fe National Forest Geothermal Leasing EIS, Wildlife, Fisheries, and Rare 

Plants Report. Santa Fe, New Mexico.

_____. 2016f. Forest Service Handbooks. Internet website: http://www.fs.fed.us/dirindexhome/

dughtml/fsh_2000.html. 

_____. 2016g. Public Summary of the Ongoing Ethnographic Assessment of the Jemez 

Mountains for the Santa Fe National Forest, New Mexico. Prepared by EMPSi 

Environmental Management and Planning Solutions, Inc. Santa Fe, New Mexico.

Forest Service GIS. 2015. GIS data used to create proposed and developed alternatives, affected 

environment and environmental consequences. Santa Fe National Forest. Santa Fe, New 

Mexico. 

Four Corners Air Quality Task Force. 2007. Four Corners Air Quality Task Force Report of 

Mitigation Options. Internet website: www.nmenv.state.nm.us/aqb/4C/Docs/

4CAQTF_Report_FINAL_Introduction.pdf. 
Chapter 6. References

Santa Fe National Forest Geothermal Leasing EIS 6-7

Frey, J. 2004. “Taxonomy and distribution of the mammals of New Mexico: An annotated 

checklist.” Occasional Papers: Museum of Texas Tech University. No. 240:1–32. 

Publications of the Museum of Texas Tech University, Lubbock. July 2004.

Frey, J. K., and J. L. Malaney. 2009. “Decline of the meadow jumping mouse (Zapus hunsonius 

luteus) in two mountain ranges in New Mexico.” The Southwestern Naturalist 54(1):31–

44. 

Friggens, M. M., D. M. Finch, K. E. Bagne, S. L. Coe, and D. L. Hawksworth. Vulnerability of 

species to climate change in the Southwest: Terrestrial species of the Middle Rio Grande. 

Gen. Tech. Rep. RMRS-GTR-306. Fort Collins, Colorado. US Department of 

Agriculture, Forest Service, Rocky Mountain Research Station. 

Furniss, M. J., B. P. Staab, S. Hazelhurst, C. F. Clifton, K. B. Roby, B. L. Ilhardt, et al. 2010. 

Water, Climate Change, and Forests. Watershed Stewardship for a Changing Climate. 

Forest Service, Pacific Northwest Research Station, General Technical Report PNWGTR-812. Portland, Oregon. 

Galbreath, K. E., D. J. Hafner, and K. R. Zamudio. 2009. “When cold is better: Climate-driven 

elevation shifts yield complex patterns of diversification and demography in an alpine 

specialist (American pika, Ochotona princeps).” Evolution 63:2848–2863.

Galloway, D. L., and T. J. Burbey. 2011. “Review: Regional land subsidence accompanying 

groundwater extraction.” Hydrogeology Journal 19:1459–1486.

Ganey, J. L., J. P. Ward, J. S. Jenness, W. M. Block, S. H. Hedwall, R. S. Jonnes, D. L. Apprill, et 

al. 2014. “Use of protected activity centers by Mexican spotted owls in the Sacramento 

Mountains, New Mexico.” Journal of Raptor Research 48(3):210–218.

Garfin, G., G. Franco, H. Comrie, P. Gonzalez, T. Piechota, R. Smyth, et al. 2014. Ch. 20: 

Southwest. Climate Change Impacts in the United States: The Third National Climate 

Assessment (J. M. Melillo, Terese (T.C.) Richmond, and G. W. Yohe, editors). US Global 

Change Research Program. Pp. 462–486.

Geothermal Energy Association. 2014. 2014 Annual US and Global Geothermal Power 

Production Report. Washington, DC.

Gillio, David, A. 1979. Cultural Resource Report - Santa Fe National Forest Area: An Historical 

Perspective for Management. Forest Service. Southwestern Region. Albuquerque, New 

Mexico. Internet website: http://www.foresthistory.org/ASPNET/Publications/region/3/

santa_fe/cultres-30.pdf. 

Global Carbon Project. 2014. Carbon budget 2014: An annual update of the global carbon budget 

and trends. Internet website: http://www.globalcarbonproject.org/index.htm.

Goff, F. 2002. Geothermal Potential of Valles Caldera, New Mexico. Los Alamos National 

Laboratory. Los Alamos, New Mexico. GHC Bulletin December 2002.

Goff, F. E., J. N. Gardner, R. Vidale, and R. Charles. 1985. Geochemistry and isotopes of fluids 

from Sulphur Springs, Valles Caldera, New Mexico. Journal of Volcanology and 

Geothermal Research (23): 273–297.
Chapter 6. References

6-8 Santa Fe National Forest Geothermal Leasing EIS

Goff, F., L. Shevenell, J. N. Gardner, F. D. Vuataz, and C. O. Grigsby. 1988. “The hydrothermal 

outflow plume of the Valles Caldera, New Mexico, and a comparison with other outflow 

plumes.” Journal of Geophysical Research 93(B6):6041–6058.

Hagan, J. M., W. M. Vander Haegen, and P. S. McKinley. 1996. “The Early Development of 

Forest Fragmentation Impacts on Birds,” Conservation Biology 10(1):188–202.

Harris, Jeff. 2014. South West Jemez Mountains Landscape Restoration Project: Recreation 

Report. US Department of Agriculture. Forest Service. Jemez Ranger District. Santa Fe, 

New Mexico. February 28, 2014.

Headwaters Institute. 2016a. A Profile of Federal Land Payments. Economic Profile System 

(EPS). Bozeman, Montana. February 3, 2016.

_____. 2016b. A Profile of Industries that Include Travel and Tourism. Economic Profile System 

(EPS). Bozeman, Montana. February 3, 2016.

Heiken, G., F. Goff, J. N. Gardner, and W. S. Baldridge. 1990. “The Valles/Toledo Caldera 

Complex, Jemez Volcanic Field, New Mexico.” Annu. Rev. Earth Planet. Sci. 18:27–53. 

Hoffman, Gretchen K. 1996. Coal Resources of New Mexico. New Mexico Bureau of Mines and 

Mineral Resources. Volume 20. Socorro, New Mexico.

Hubbard, J. P. 1978. “Revised checklist of the birds of New Mexico.” New Mexico 

Ornithological Society Publication 6:5–6. Albuquerque, New Mexico.

Hulen, J. B., and D. L. Nielson. 1986. Hydrothermal alteration in the Baca geothermal system, 

Redondo Dome, Valles Caldera, New Mexico. Journal of Geophysical Research

91(B2):1867–1886.

Ice, G. G. 1985. Catalog of landslide inventories for the Northwest. Technical Bulletin 456. 

National Council of the Paper Industry for Air and Stream Improvement. New York, New 

York. 

IPCC (Intergovernmental Panel on Climate Change). 2014. Climate Change 2014: Synthesis 

Report. Contribution of Working Groups I, II and III to the Fifth Assessment Report of 

the Intergovernmental Panel on Climate Change (R. K. Pachauri and L. A. Meyer, 

editors). IPCC, Geneva, Switzerland.

Jackson, S. D. 2000. “Overview of transportation impacts on wildlife movement and 

populations.” In: Wildlife and Highways: Seeking Solutions to an Ecological and Socioeconomic Dilemma (T. A. Messmer and B. West, editors). The Wildlife Society. Pp. 7–20.

Kagel, Alyssa. 2006. A Handbook on the Externalities, Employment, and Economics of 

Geothermal Energy. Geothermal Energy Association. Internet website: http://www

.geoenergy.org/publications/reports/Socioeconomics%20Guide.pdf.

Kane, J. M., and T. E. Kolb. 2014. “Short- and long-term growth characteristics associated with 

tree mortality in southwestern mixed-conifer forests.” Canadian Journal of Forest 

Research 44(10):1227–1235.
Chapter 6. References

Santa Fe National Forest Geothermal Leasing EIS 6-9

Kelley, S. K., A. Kempter, F. Goff, M. Rampey, G. R. Osburn, and C. A. Ferguson. 2003. 

Geologic map of the Jemez Springs Quadrangle, Sandoval County, New Mexico. New 

Mexico Bureau of Geology and Mineral Resources Open-file Digital Geologic Map OFGM 073. Socorro, New Mexico. 

Kues, Barry, and Spencer G. Lucas. 1979. “Summary of the paleontology of the Santa Fe Group 

(Mio-Pliocene), north-central New Mexico.” In: Santa Fe Country (R. V. Ingersoll, L. A. 

Woodward, and H. L. James, editors). New Mexico Geological Society 30th Annual Fall 

Field Conference Guidebook. Internet website: https://nmgs.nmt.edu/publications/

guidebooks/downloads/30/30_p0237_p0241.pdf.

LANL (Los Alamos National Laboratory). 2005. Los Alamos National Laboratory’s 

Hydrogeologic Studies of the Pajarito Plateau: A Synthesis of Hydrogeologic Workplan 

Activities (1998-2004). LA-14263-MS. Los Alamos, New Mexico. 

______. 2015. Annual Site Environmental Report. LA-UR-16-26788. Los Alamos, New Mexico. 

Leiken, Ron. 2011. Noise Report Casa Diablo 4 Geothermal Development Project. For Ormat 

Nevada, Inc. Reno, Nevada. June 29, 2011.

Levine, R., A. Symonds, R. Morrison, M. Sims, and C. McConvill. 2015. Rio Chama Group 

Project. The Rio Chama Watershed: Present State, Current Management and Future 

Restoration Potential. Internet website: https://riverrestoration.wikispaces.com/

Rio+Chama+Group+Project. 

Longcore, T., and C. Rich. 2004. “Ecological light pollution.” Front Ecol. Environ. 2(4):191–

198.

Lopez, A., B. Roberts, D. Heimiller, N. Blair, and G. Porro. 2012. US Renewable Energy 

Technical Potentials: A GIS-Based Analysis. NREL/TP-6A20-51946. National 

Renewable Energy Laboratory, Golden, Colorado. 

Lund, J. W., and T. L. Boyd. 2015. “Direct utilization of geothermal energy 2015 worldwide 

review.” Proceedings World Geothermal Congress. Melbourne, Australia, April 19–25, 

2015.

Lund, John W., and James C. Witcher. 2002. “Truth or Consequences, New Mexico: A spa city.” 

GeoHeat Center Quarterly Bulletin 23(4):20-24. Oregon Institute of Technology, 

Klamath Falls, Oregon. Internet website: http://www.oit.edu/docs/default-source/geoheatcenter-documents/quarterly-bulletin/vol-23/23-4/23-4-art5.pdf?sfvrsn=4. 

Majer, Ernie, James Nelson, Ann Robertson-Tait, Jean Savy, and Ivan Wong. 2012. Protocol for 

Addressing Induced Seismicity Associated with Enhanced Geothermal Systems.

DOE/EE-0662. US Department of Energy, Energy Efficiency and Renewable Energy, 

Geothermal Technologies Program, Washington, DC.

Majer, Ernie, R. Baria, M. Stark, S. Oates, J. Bommer, B. Smith, and H. Asanuma. 2007. 

“Induced seismicity associated with enhanced geothermal systems.” Geothermics

36:185–222.Matek, Benjamin. 2013. Promoting Geothermal Energy: Air Emissions 

Comparison and Externality Analysis. Geothermal Energy Association. Washington, DC.
Chapter 6. References

6-10 Santa Fe National Forest Geothermal Leasing EIS

Mawdsley, J. R., R. O. O’Malley, and D. S. Ojima. 2009. “A review of climate-change adaption 

strategies for wildlife management and biodiversity conservation.” Conservation Biology

23(5):1080–1089.

Michelet, S., R. Baria, J. Baumgartner, A. Gérard, S. Oates, T. Hettkamp, and D. Teza. 2004.

“Seismic source parameter evaluation and its importance in the development of an

HDR/EGS system,” Procedures of the 29th Workshop on Geothermal Reservoir

Engineering, Stanford University, Palo Alto, California.

Molenaar, C. M. 1995. US Geological Survey, 1995 National Assessment of United States Oil 

and Gas Resources. Albuquerque-Santa Fe Rift Province (023).Internet website: 

https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&ved=0ahUKE

wjd7feyuuTLAhWGs4MKHRRJBQYQFggfMAA&url=http%3A%2F%2Fwebapp1.dlib.

indiana.edu%2Fvirtual_disk_library%2Findex.cgi%2F4265000%2FFID620%2FREGIO

N3%2FPROV23%2FPROV23.RTF&usg=AFQjCNHgmJ7Psa2nvgTlfKBMd_6uUOEWf

g&sig2=3AT_wruU1t9nmp5Nlsdb8A&bvm=bv.118353311,d.amc&cad=rja. 

Molloy, M. W. 1982. “Baca geothermal demonstration project – reservoir definition review.” US 

Department of Energy. Geothermal Resources Council, Transactions Vol. 6. Oakland, 

California.

MRCOG (Mid-Region Council of Governments). 2006. Jemez Valley Corridor Assessment. 

Albuquerque, New Mexico.

Muldavin, Esteban, and Phil Tonne. 2003. A Vegetation Survey and Preliminary Ecological 

Assessment of Valles Caldera National Preserve, New Mexico. University of New 

Mexico, Albuquerque.

NatureServe. 2006. NatureServe Explorer: Gray Vireo. Internet website: http://explorer.nature

serve.org/index.htm. 

_____. 2009a. NatureServe Explorer: Northern Leopard Frog. Internet website: http://explorer

.natureserve.org/index.htm.

_____. 2009b. NatureServe Explorer: American Peregrine Falcon. Internet website: http://expl

orer.natureserve.org/index.htm.

_____. 2011a. NatureServe Explorer: Mourning Dove. Internet website: http://explorer.nature

serve.org/index.htm. 

_____. 2011b. NatureServe Explorer: Pinyon Jay. Internet website: http://explorer.natureserve

.org/index.htm. 

Nemzer, Marilyn, Deborah Page, and Anna Carter. 2007. Energy for Keeps. Energy Education 

Group. Tiburon, California.

New Mexico Bureau of Geology and Mineral Resources GIS. 2003. Geologic map of New 

Mexico, used to display geology and faults. Socorro, New Mexico.

New Mexico Commission of Public Records. 2002. 20.2.3 NMAC—Ambient Air Quality

Standards. Effective October 31, 2002. Internet website: www.nmcpr.state.nm.us/nmac/

parts/title20/20.002.0003.htm.
Chapter 6. References

Santa Fe National Forest Geothermal Leasing EIS 6-11

New Mexico Department of Homeland Security and Emergency Management. 2013. Internet 

website: http://www.nmdhsem.org/uploads/files/NM%20HMP%20Final%209-30-13.pdf.

New Mexico Energy, Minerals and Natural Resources Department. 2015. Annual Report: New 

Mexico Energy, Minerals and Natural Resources Department. State of New Mexico. 

Internet website: http://www.emnrd.state.nm.us/ADMIN/documents/2015_EMNRD_

AnnualReport_web.pdf. 

New Mexico Natural History. 2015. Valles Caldera, Jemez Volcanic Field. Internet website: 

http://nmnaturalhistory.org/volcanoes/valles-caldera-jemez-volcanic-field. 

New Mexico Office of the State Engineer. 2006. Rio Chama Water Plan Executive Summary. 

Internet website: http://www.ose.state.nm.us/Planning/RWP/Regions/RioArriba/ExecSummary.pdf. 

New Mexico Partners in Flight. 2007. New Mexico Bird Conservation Plan Version 2.1. C. 

Rustay and S. Norris, compilers. Albuquerque, New Mexico. Internet website: 

http://www.nmpartnersinflight.org/. 

_____. 2013. Bird Conservation Plan, Appendix D. Internet website: http://www.nmpartners

inflight.org/bcp.html. 

New Mexico Public Regulation Commission. 2016. Utility—Renewable Energy. Internet website: 

http://www.nmprc.state.nm.us/utilities/renewable-energy.html. 2016.

New Mexico State Police. 2016. Internet website: http://www.nmsp.dps.state.nm.us/.

NMDFA (New Mexico Department of Finance and Administration). 2014. Property Tax Facts for 

Tax Year 2014. Local Government Division, Budget and Finance Bureau. Internet 

website: http://nmdfa.state.nm.us/uploads/FileLinks/ff1373ca37bb4c4f800f868687821

827/2014_property_tax_facts_pdf.

_____. 2015. Property Tax Facts for Tax Year 2015. Local Government Division, Budget and 

Finance Bureau. Internet website: http://nmdfa.state.nm.us/uploads/FileLinks/ff1373ca37

bb4c4f800f868687821827/Property_Tax_Facts_2015_1.pdf.

NMDGF (New Mexico Department of Game and Fish). 2006. Comprehensive Wildlife 

Conservation Strategy for New Mexico. New Mexico Department of Game and Fish, 

Santa Fe.

_____. 2007. Gray Vireo (Vireo vicinior) Recovery Plan. New Mexico Department of Game and 

Fish, Santa Fe, New Mexico.

_____. 2008. Conservation Plan for Gunnison’s Prairie Dog (Cynomys gunnisoni) in New 

Mexico. New Mexico Department of Game and Fish, Santa Fe, New Mexico. May 12, 

2008.

_____. 2014. Rio Grande Cutthroat Trout No Longer an Endangered Species Candidate. Internet 

website: http://www.wildlife.state.nm.us/rio-grande-cutthroat-trout-no-longer-anendangered-species-candidate/. 
Chapter 6. References

6-12 Santa Fe National Forest Geothermal Leasing EIS

NMDOT (New Mexico Department of Transportation). 2014. TIMS Road Segments by Posted 

Route/Point With AADT Information. Internet website: http://dot.state.nm.us/content/

dam/nmdot/Data_Management/NM_AADT_Listing.pdf.

NMED (New Mexico Environment Department). 2010. Inventory of New Mexico Greenhouse 

Gas Emissions: 2000-2007. Santa Fe, New Mexico. March 15, 2010.

NMRPTC (New Mexico Rare Plant Technical Council). 1999. New Mexico Rare Plant. 

Albuquerque, New Mexico Rare Plants Home Page. Internet website: http://www

.nmrareplants.unm.edu. 

NPS (National Park Service). 1990. Jemez Culture Developments in North-Central New Mexico, 

National Register of Historic Places Multiple Property Documentation Form. Jemez 

Mountains Research Center, April 19, 1990. Albuquerque, New Mexico.

_____. 2005. Night Sky Quality Monitoring Report, Bandelier, New Mexico. Internet website: 

http://www.sierranights.com/nightsky/reports/BAND051206.html. 

_____. 2006a. The National Trails System, Memorandum of Understanding 06-SU-11132424-

196. Internet website: http://www.fhwa.dot.gov/environment/recreational_trails/

overview/ntsmou2006.cfm. 

_____. 2006b. Management Policies. Washington, DC.

_____. 2006c. Night Sky Quality Monitoring Report, Bandelier, New Mexico. Internet website: 

http://www.sierranights.com/nightsky/reports/BAND060928.html.

NPS GIS. 2016. GIS data used to identify Redondo Peak and caldera rim viewsheds. Valles 

Caldera National Preserve. Jemez Springs, New Mexico.

NRCS (Natural Resources Conservation Service). 2011a. Rapid Watershed Assessment: Rio 

Chama Watershed. Internet website: http://www.nrcs.usda.gov/Internet/FSE_DOCU

MENTS/nrcs144p2_068016.pdf. 

_____. 2011b. Rapid Watershed Assessment: Rio Grande-Santa Fe Watershed. Internet website: 

http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs144p2_068017.pdf. 

_____. 2011c. Rapid Watershed Assessment: Jemez Watershed. Internet website: http://www

.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs144p2_066022.pdf.

NREL (National Renewable Energy Laboratory). 2015a. Geothermal Prospector. Internet website: 

http://www.nrel.gov/gis/tools_gt_prospector.html. 

_____. 2015b. Geothermal Electricity Production Basics. Internet website: http://www.nrel.gov/

learning/re_geo_elec_production.html. Content last updated July 25, 2014.

NVUM (National Visitor Use Monitoring Results). 2013. Data Collected FY 2008 to FY 2012.

Internet website: http://www.fs.fed.us/recreation/programs/nvum/2012%20National_

Summary_Report_061413.pdf. 

OpenEI. 2016. Geothermal Energy: Valles Caldera: Sulphur Springs Geothermal Area. Internet 

website: http://en.openei.org/wiki/Valles_Caldera_-Sulphur_Springs_Geothermal_Area. 
Chapter 6. References

Santa Fe National Forest Geothermal Leasing EIS 6-13

PaleoWest (PaleoWest Archaeology). 2016. Santa Fe National Forest Geothermal Leasing EIS, 

Cultural Resources Specialist Report. Prepared by PaleoWest Archaeology, for EMPSi 

Environmental Management and Planning Solutions Inc. January 2016. Farmington, New 

Mexico.

Petersen, Mark D., Charles S. Mueller, Morgan P. Moschetti, Susan M. Hoover, Justin L. 

Rubinstein, Andrea L. Llenos, Andrew J. Michael, et al. 2015. Incorporating Induced 

Seismicity in the 2014 United States National Seismic Hazard Model—Results of 2014 

Workshop and Sensitivity Studies. Open-File Report 2015–1070. US Geological Survey, 

Reston, Virginia. 

Pierson, E. D., and W. E. Rainey. 1998. Distribution, Status, and Management of Townsend’s 

Big-Eared Bat (Corynorhinus townsendii) in California. California Department of Fish 

and Game. BMCP Technical Report Number 96–97.

Pierson, E. D., M. C. Wackenhut, J. S. Altenbach, P. Bradley, P. Call, D. L. Genter, C. E. Harris, et 

al. 1999. Species Conservation Assessment and Strategy for Townsend’s Big-Eared Bat 

(Corynorhinus townsendii and C. t. pallescens). Idaho Conservation Effort, Idaho 

Department of Fish and Game, Boise.

Reed, R. A., J. Johnson-Barnard, and W.A. Baker. 1996. “Contribution of Roads to Forest 

Fragmentation in the Rocky Mountains.” Conservation Biology. 10(4):1098–1106. 

Rees, D. E., R. J. Carr, W. J. Miller. 2005. Rio Grande chub (Gila pandora): A technical 

conservation assessment. USDA Forest Service, Rocky Mountain Region. Internet 

website: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5200374.pdf.

Rees, D. E., and W. J. Miller. 2005. Rio Grande sucker (Catostomus plebeius): A technical 

conservation assessment. USDA Forest Service, Rocky Mountain Region. Internet 

website: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5206797.pdf.

Reynolds, R. T., R. T. Graham, M. H. Reiser, R. L. Bassett, P. L. Kennedy, D. A. Boyce, Jr., G. 

Goodwin, et al. 1992. Management Recommendations for the Northern Goshawk in the 

Southwestern United States. General Technical Report RM-217. Fort Collins, Colorado.

Rio Arriba County. 2016. Internet website: http://www.rio-arriba.org/.

Rio Arriba County Office of Emergency Management. 2014. Rio Arriba County Hazard 

Mitigation Plan. Internet website: http://www.rio-arriba.org/pdf/departments_and_

divisions/emergency_management/hazard_mitigation.pdf. 

Rowland, M. M., M. J. Wisdom, B. K. Johnson, and J. G. Kie. 2000. “Elk distribution and 

modeling in relation to roads.” Journal of Wildlife Management 64:672–684.

Sandoval County. 2013. All Hazard Mitigation Plan. Internet website: http://www.sandoval

county.com.lobo.com/uploads/Downloads/Divisions/EM/HMP.pdf.

Sandoval County. 2016. Sandoval County, State of New Mexico. Internet website: http://www

.sandovalcounty.com/.
Chapter 6. References

6-14 Santa Fe National Forest Geothermal Leasing EIS

Sanford, Allan R. 1983. “Magma bodies in the Rio Grande rift in central New Mexico, in Socorro 

Region II” (C. E. Chapin and J. F. Callender, editors). New Mexico Geological Society 

34th Annual Fall Field Conference Guidebook. Internet website: https://nmgs.nmt.edu/

publications/guidebooks/downloads/34/34_p0123_p0125.pdf. 

Schaub, A., J. Ostwald, and B. Siemers. 2008. “Foraging bats avoid noise.” The Journal of 

Experimental Biology 211:3174–3180.

Schlyter, P. 2006. Radiometry and photometry in astronomy. Internet website: http://stjarnhim

len.se/comp/radfaq.html#10.

Schwab, M., D. Tafoya, and M. Smith. 2008. Mineral Report—Validity Examination of the 

Brown Placer Claim #9 through #12. NMMC 145310—145313. Unpublished. Pp. 8–11.

Albuquerque, New Mexico.

Sengpielaudio. 2016. Damping of sound level (decibel dB) vs. distance. Internet website: 

http://www.sengpielaudio.com/calculator-distance.htm.

Shevenell, L., F. Goff, F. D. Vuataz, P. E. Trujillo, Jr., D. Counce, C. J. Janick, and B. Evans. 

1987. Hydrogeochemical Data for the Thermal and Nonthermal Waters and Gases of the 

Valles Caldera Southern Jemez Mountains region, New Mexico. Los Alamos National 

Laboratory Report LA-10923-OBES.

Smith, G. A., and S. D. Lynch. 2007. “Interplay of Miocene rift tectonics and rhyolitic 

magmatism in the southern Jemez Mountains, New Mexico.” In: Geology of the Jemez 

Region II (Barry S. Kues, Shari A. Kelley, and Virgil W. Lueth, editors). New Mexico 

Geological Society 58th Annual Fall Field Conference Guidebook. Albuquerque, New 

Mexico. 

Squires, J. R., and P. L. Kennedy. 2006. “Northern goshawk ecology: An assessment of current 

knowledge and information needs for conservation and management.” Studies in Avian 

Biology 31:8–62. Internet website: http://bna.birds.cornell.edu/bna/species/298. 

Squires, J. R., and R. T. Reynolds. 1997. “Northern goshawk (Accipiter gentilis).” In: The Birds 

of North America, No. 298 (A. Poole and F. Gill, editors). The Academy of Natural 

Science; Washington, DC: The American Ornithologists’ Union, Philadelphia, 

Pennsylvania.

Stahlecker, D. W., E. P. MacKerrow, H. A. Walker, J. P. Batkin, and B. R. Foy. 2014. “Persistence 

of the boreal owl in New Mexico: 1987-2012.” Western Birds 45:166–175. 

Sublette, J. E., M. D. Hatch, and M. Sublette. 1990. The Fishes of New Mexico. University of 

New Mexico Press. Albuquerque, New Mexico.

Sumi, Lisa. 2008. Shale Gas: Focus on the Marcellus Shale. Oil & Gas Accountability Project, 

Durango, Colorado. A program of EARTHWORKS, Washington, DC.

Summers, W. K. 1976. New Mexico Bureau of Mines and Mineral Resources: Hydrologic Report 

4. Catalog of Thermal Waters in New Mexico. University of New Mexico Printing Plant. 

Albuquerque, New Mexico.
Chapter 6. References

Santa Fe National Forest Geothermal Leasing EIS 6-15

Swanson, F. J., L. E. Benda, S. H. Duncan, G. E. Grant, W. F. Megahan, L. M. Reid, and R. R. 

Ziemer. 1987. “Mass failures and other processes of sediment production in Pacific 

Northwest forest landscapes.” In: Streamside management: Forestry and fishery 

interactions: Proceedings of a symposium (Ernest O. Salo and Terrance W. Cundy, 

editors). February 12-14, 1986, Seattle, Washington. Contribution No. 57. University of 

Washington, Seattle, Institute of Forest Resources: 9-38. Chapter 2.

Swetnam, T. W., and C. H. Baisan. 1996. “Historical fire regime patterns in the southwestern 

United States since AD 1700.” In: 2nd La Mesa Fire Symposium; Los Alamos, New 

Mexico (C. D. Allen, editor). General Technical Report RM-GTR-286. USDA Forest 

Service, Rocky Mountain Forest and Range Experiment Station, Fort Collins, Colorado. 

Pp. 11–32.

Tester, J. W., B. J. Anderson, A.S. Batchelor, A. S. Blackwell, D. D. Dipippo, R. Drake, E. M. 

Garnish, et al. 2006. The Future of Geothermal Energy: Impact of Enhanced Geothermal 

System (EGS) on the United States in the 21st Century. Massachusetts Institute of 

Technology and Department of Energy Report, Idaho National Laboratory, INFL/EXT06-11746. 

Trainer, F. W. 1974. “Groundwater in the southwestern part of the Jemez Mountains volcanic 

region, New Mexico.” New Mexico Geologic Society 25th Fall Field Conference 

Guidebook. Albuquerque, New Mexico. Pp. 337–345.

Trainer, F. W., R. J. Rogers, and M. L. Sorey. 2000. Geothermal Hydrology of Valles Caldera and 

the Southwest Jemez Mountains, New Mexico. Water-Resources Investigations Report 

00-4067. United States Department of the Interior, USGS, Office of the State Engineer, 

2000. Internet website: http://pubs.usgs.gov/wri/2000/4067/report.pdf. 

Triepke, F. J. 2015. Climate Change Vulnerability Assessment for the Santa Fe National Forest. 

Santa Fe, New Mexico. 

Trombulak, S. C., and C. A. Frissell. 2000. “Review of ecological impacts of roads on terrestrial 

and aquatic communities.” Conservation Biology 14:18–30.

US Census Bureau. 2010. American Fact Finder. American Community Survey 5-Year Estimates. 

Internet website: http://factfinder.census.gov/.

_____. 2014. American Fact Finder. American Community Survey 5-Year Estimates. Internet 

website: http://factfinder.census.gov/.

USFWS (United States Department of the Interior, Fish and Wildlife Service). 1993. Rule to list 

the Mexican spotted owl as a threatened species. 58 Federal Register 49, March 16, 

1993. Rules and Regulations: 50 CFR, Part 17. RIN 1018-AB 56. US Department of 

Interior, Fish and Wildlife Service, Washington, DC: 14248-14271.

_____. 2012. Final Recovery Plan for the Mexican Spotted Owl (Strix occidentalis lucida), First 

Revision. Albuquerque, New Mexico.

_____. 2013a. Rio Grande Cutthroat Trout (Oncorhynchus clarkia virginalis) Conservation 

Strategy. Colorado Parks and Wildlife, Denver, Colorado. October 2013.
Chapter 6. References

6-16 Santa Fe National Forest Geothermal Leasing EIS

_____. 2013b. Endangered and threatened wildlife and plants; determination of endangered 

species status for Jemez mountains salamander (Plethodon neomexicanus) throughout its 

range; Final Rule. Federal Register Volume 78, No. 175, 55600–55627. Washington, DC. 

_____. 2016. Environmental Conservation Online System – Profile for New Mexico Meadow 

Jumping Mouse (Zapus hudsonius luteus). Internet website: https://ecos.fws.gov/

tess_public/profile/speciesProfile.action?spcode=A0BX.

USGS (US Geological Survey). 1999. Naturally Occurring Radioactive Materials (NORM) in 

Produced Water and Oil-Field Equipment: An Issue for the Energy Industry. USGS Fact 

Sheet FS–142–99. US Geological Survey, Reston, Virginia. 

_____. 2002. Impacts of Wildfire on the Hydrology of Capulin and Rito de los Frijoles Canyons, 

Bandelier National Monument, New Mexico. Water-Resources Investigations Report 02-

4152. Albuquerque, New Mexico.

_____. 2010. Geothermal favorability map derived from logistic regression models of the western 

United States. Menlo Park, California.

Vuataz, F. D., and F. Goff. 1986. “Isotope geochemistry of thermal and nonthermal waters in the 

Valles Caldera, Jemez Mountains, northern New Mexico.” Journal of Geophysical 

Research 91(B2):1835–1853.

Watershed Boundary Dataset GIS. 2016. GIS data used to identify watershed (HUC 12) 

boundaries. Santa Fe National Forest. Santa Fe, New Mexico. Internet website: 

https://gdg.sc.egov.usda.gov/.

Wells, S. M. 2009. Watermaster’s Report Rio Chama Mainstream. New Mexico Office of the 

State Engineer. Internet website: http://www.ose.state.nm.us/WM/Reports/RioChama/

2009RioChamaWMRpt.pdf. 

Williams, C. F., and J. DeAngelo. 2008. Mapping Geothermal Potential in the Western United 

States. Geothermal Resources Council Transaction 32:181–188. Reno, Nevada.

Williams, C. F., M. J. Reed, J. DeAngelo, and S. P. Galanis, Jr. 2009. Quantifying the 

undiscovered geothermal resources of the United States. Geothermal Resources Council 

Transaction 33:995–1002. 

Williams, Colin F., Marshall J. Reed, Robert H. Mariner, Jacob DeAngelo, and S. Peter Galanis, 

Jr. 2008. Assessment of Moderate- and High-Temperature Geothermal Resources of the 

United States. US Geological Survey Fact Sheet 2008-3082. Menlo Park, California.

Wilt, M., and S. Vender Haar. 1986. “A geological and geophysical appraisal of the Baca 

geothermal field, Valles Caldera, New Mexico.” Journal of Volcanology and Geothermal 

Research 27:349–370.

Wischkaemper, J., C. L. Benner, B. D. Russell, and K. Manivannan. 2014. “Application of 

advanced electrical waveform monitoring and analytics for reduction of wildfire risk.”

2014 IEEE Innovative Smart Grid Technologies Conference, Washington DC. February 

19, 2014.
Chapter 6. References

Santa Fe National Forest Geothermal Leasing EIS 6-17

Wisdom, M., A. Ager, H. Preisler, N. Cimon, and B. Johnson. 2004. “Impacts of off-road 

recreation on mule deer and elk.” Transactions of the North American Wildlife and 

Natural Resources Conference, Alliance Communications Group, Lawrence, Kansas.

WRCC (Western Regional Climate Center). 2014. Period of Record Monthly Climate Summary 

for Los Alamos, New Mexico, Station 295084: 1981-2010. Internet website: http://www

.wrcc.dri.edu/cgi-bin/cliMAIN.pl?nmlosa.
Chapter 6. References

6-18 Santa Fe National Forest Geothermal Leasing EIS

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Chapter 7. Index

Santa Fe National Forest Geothermal Leasing EIS 7-1

Chapter 7. Index

Adaptive management, 1-23, 2-5, 2-12, 3-27

Air quality, 1-9, 1-20, 2-18, 2-19, 2-18, 

2-27, 3-60, 3-61, 3-63, 3-64, 3-65, 3-67, 

3-68, 3-69, 3-70, 3-72, 3-74, 3-75, 3-76, 

3-77, 3-142, 3-147, 3-162, 3-166, 3-169, 

3-180, 3-181, 3-182, 3-184, 4-1, 4-2, 5-4

Air Quality-Related Values, 1-20, 2-18, 

3-60, 3-67, 3-68, 3-69, 3-70, 3-72, 3-76, 

3-77

Area of Critical Environmental Concern 

(ACEC), 1-20, 3-12

Best management practice (BMP), 1-1, 1-2, 

1-15, 1-16, 2-1, 2-2, 2-3, 2-4, 2-7, 2-17, 

2-18, 2-26, 2-27, 3-2, 3-27, 3-36, 3-40, 

3-41, 3-54, 3-55, 3-58, 3-59, 3-60, 3-68, 

3-72, 3-73, 3-75, 3-76, 3-77, 3-83, 3-84, 

3-85, 3-94, 3-98, 3-118, 3-120, 3-121, 

3-150, 3-152, 3-162, 3-165, 3-168, 3-169, 

3-172, 3-180, 3-181, 3-183, 3-184, 5-1

Bighorn sheep, Rocky Mountain, 3-86, 3-87, 

3-94

Birds, migratory, 2-4, 3-80, 3-86, 3-87, 

3-89, 3-90, 3-96, 3-97, 3-117, 3-118, 

3-120

Candidate species, 5-4

Canones Creek, 3-11, 3-15, 3-16, 3-103, 

3-104

Cheatgrass, 3-80

Clean Water Act, 3-46

Council on Environmental Quality (CEQ), 

1-15, 1-19, 3-1, 3-2, 3-3, 3-157, 3-158, 

3-160, 5-3

County, Rio Arriba, 1-3, 3-20, 3-24, 3-65, 

3-101, 3-153, 3-154, 3-155, 3-156, 3-157, 

3-158, 3-159, 3-164, 3-179

County, Sandoval, 3-7, 3-24, 3-64, 3-65, 

3-66, 3-152, 3-153, 3-154, 3-155, 3-156, 

3-157, 3-158, 3-159, 3-163, 3-164, 3-179, 

3-186

Coyote Creek, 3-45, 3-48, 3-80, 3-81

Deer, mule, 3-10

Eagle, bald, 3-101

Elk, 1-27, 2-4, 2-9, 2-11, 2-12, 3-10, 3-86, 

3-87, 3-94, 3-97

Endangered species, 1-14, 2-21, 2-22, 3-98, 

3-112, 3-114, 3-120, 5-1

Endangered Species Act (ESA), 1-24, 2-7, 

2-10, 2-12, 2-22, 3-87, 3-89, 3-90, 3-98, 

3-100, 3-103, 3-187, 5-1, 5-4

Environmental justice, 2-25, 3-130, 3-137, 

3-152, 3-157, 3-158, 3-159, 3-160, 3-161, 

3-162, 3-165, 3-166, 3-167

Exploration wells, 3-69, 3-71, 3-74

Federal Land Policy and Management Act 

(FLPMA), 1-1, 1-7, 1-13, 3-7, 3-28, 3-33

Fire management, 3-17, 3-94, 3-169, 3-177

Fire regime, 3-77

Forest Service, 1-1, 1-2, 1-5, 1-6, 1-8, 1-9, 

1-11, 1-13, 1-14, 1-15, 1-17, 1-18, 1-19, 

1-22, 1-23, 2-1, 2-2, 2-3, 2-4, 2-5, 2-6, 

2-7, 2-8, 2-10, 2-11, 2-12, 2-16, 3-2, 3-4, 

3-5, 3-6, 3-7, 3-8, 3-9, 3-10, 3-11, 3-12, 

3-13, 3-14, 3-16, 3-17, 3-20, 3-25, 3-26, 

3-27, 3-28, 3-32, 3-33, 3-34, 3-35, 3-36, 

3-37, 3-38, 3-39, 3-40, 3-42, 3-46, 3-47, 

3-48, 3-51, 3-53, 3-57, 3-64, 3-67, 3-68, 

3-69, 3-72, 3-73, 3-74, 3-77, 3-78, 3-80, 

3-81, 3-82, 3-83, 3-85, 3-86, 3-87, 3-88, 

3-89, 3-91, 3-92, 3-98, 3-99, 3-100, 

3-101, 3-102, 3-103, 3-104, 3-106, 3-109, 

3-110, 3-111, 3-112, 3-113, 3-114, 3-122, 

3-123, 3-126, 3-128, 3-129, 3-130, 3-131, 

3-132, 3-134, 3-136, 3-137, 3-139, 3-142, 

3-144, 3-146, 3-147, 3-151, 3-157, 3-160, 

3-161, 3-162, 3-163, 3-164, 3-165, 3-166, 

3-167, 3-168, 3-170, 3-172, 3-173, 3-174, 

3-175, 3-176, 3-181, 3-182, 3-186, 3-188, 

4-1, 5-2, 5-3, 5-4

Fuel load, 3-79

Fugitive dust, 2-18, 3-15, 3-16, 3-17, 3-67, 

3-69, 3-70, 3-71, 3-72, 3-74, 3-75, 3-76, 

3-82, 3-113, 3-162

Geothermal development, 1-7, 1-9, 1-11, 

1-13, 1-19, 1-20, 1-23, 1-25, 2-1, 2-4, 2-8, 

2-9, 2-10, 2-12, 2-13, 2-16, 2-17, 2-18, 

2-20, 2-21, 2-22, 2-23, 2-24, 2-25, 2-26, 

2-27, 3-5, 3-13, 3-15, 3-20, 3-23, 3-24, 

3-26, 3-27, 3-29, 3-30, 3-32, 3-34, 3-35, 

3-36, 3-39, 3-40, 3-41, 3-54, 3-56, 3-58, 

3-60, 3-64, 3-68, 3-69, 3-77, 3-82, 3-83, 

3-84, 3-85, 3-91, 3-92, 3-93, 3-94, 3-95, 

3-96, 3-98, 3-112, 3-114, 3-115, 3-116, 

3-117, 3-118, 3-119, 3-120, 3-121, 3-125, 
Chapter 7. Index

7-2 Santa Fe National Forest Geothermal Leasing EIS

3-126, 3-131, 3-132, 3-133, 3-139, 3-140, 

3-141, 3-146, 3-147, 3-148, 3-149, 3-150, 

3-151, 3-152, 3-163, 3-164, 3-165, 3-166, 

3-167, 3-168, 3-169, 3-172, 3-175, 3-180, 

3-181, 3-182, 3-184, 3-185, 3-187

Geothermal exploration, 1-2, 1-9, 1-15, 

1-16, 1-19, 1-20, 2-17, 2-18, 2-24, 3-3, 

3-15, 3-16, 3-17, 3-23, 3-27, 3-40, 3-50, 

3-54, 3-57, 3-66, 3-68, 3-70, 3-71, 3-77, 

3-113, 3-121, 3-125, 3-134, 3-147, 3-150, 

3-167, 3-172, 3-181, 3-182

Geothermal power plant, 1-6, 1-11, 2-27, 

3-3, 3-32, 3-68, 3-69, 3-70, 3-74, 3-75, 

3-76, 3-152, 3-162, 3-164, 3-170, 3-180, 

3-183, 3-184

Geothermal Programmatic EIS, 1-1, 1-2, 

1-3, 1-5, 1-6, 1-8, 1-9, 1-15, 1-16, 1-23, 

2-1, 2-4, 2-5, 2-22, 3-2, 3-8, 3-9, 3-13, 

3-24, 3-34, 3-35, 3-39, 3-54, 3-68, 3-69, 

3-82, 3-92, 3-112, 3-113, 3-125, 3-132, 

3-139, 3-146, 3-161, 3-162, 3-163, 3-167, 

3-168, 3-170, 3-175, 3-180, 3-188

Geothermal reservoir, 1-3, 1-6, 1-11, 3-24, 

3-27, 3-50, 3-187, 5-2

Geothermal resource, 1-1, 1-2, 1-3, 1-6, 1-7, 

1-8, 1-9, 1-11, 1-13, 1-15, 1-22, 2-1, 2-3, 

2-4, 2-10, 2-13, 2-19, 2-24, 2-27, 3-1, 3-2, 

3-14, 3-16, 3-24, 3-27, 3-28, 3-29, 3-30, 

3-32, 3-35, 3-36, 3-54, 3-55, 3-59, 3-69, 

3-71, 3-73, 3-82, 3-91, 3-113, 3-125, 

3-131, 3-137, 3-139, 3-140, 3-141, 3-146, 

3-148, 3-150, 3-162, 3-163, 3-168, 3-175, 

3-176, 3-181, 3-183, 3-184, 3-185, 5-1, 

5-2

Geothermal system, 1-9, 1-11, 1-13, 1-20, 

2-13, 2-16, 3-20, 3-24, 3-25, 3-26, 3-49, 

3-50, 3-52, 3-54, 3-55, 3-56, 3-57

Grazing, allotment, 1-21, 2-22, 3-122, 

3-123, 3-125, 3-126, 3-136, 5-1, 5-3

Greenhouse Gases, 1-21, 2-27, 3-76, 3-177, 

3-179, 3-180, 3-183, 3-184, 3-185

Ground disturbance, 3-2, 3-17, 3-55, 3-56, 

3-115, 3-116, 3-117, 3-125, 3-129, 3-131, 

3-138

Inventoried Roadless Areas, 1-19, 1-25, 

1-26, 2-8, 2-11, 3-10

Jemez National Recreation Area, 1-3, 1-20, 

1-22, 1-23, 2-1, 2-5, 2-6, 2-7, 2-8, 2-9, 

2-10, 2-15, 2-17, 2-20, 2-21, 2-22, 2-23, 

2-24, 3-11, 3-12, 3-14, 3-15, 3-16, 3-28, 

3-35, 3-37, 3-44, 3-45, 3-46, 3-57, 3-83, 

3-85, 3-92, 3-103, 3-104, 3-114, 3-116, 

3-117, 3-125, 3-126, 3-129, 3-133, 3-140, 

3-147, 3-149, 3-163, 3-165, 3-170

Jemez River, 2-6, 2-7, 3-4, 3-5, 3-10, 3-12, 

3-15, 3-16, 3-18, 3-28, 3-42, 3-44, 3-45, 

3-46, 3-48, 3-80, 3-81, 3-103, 3-116, 

3-117, 3-135

Leasing, geothermal, 1-1, 1-2, 1-7, 1-8, 1-9, 

1-13, 1-14, 1-15, 1-19, 1-20, 1-21, 1-22, 

1-23, 1-24, 1-26, 2-1, 2-5, 2-6, 2-7, 2-9, 

2-10, 2-12, 2-13, 2-15, 2-16, 2-17, 2-18, 

2-20, 2-21, 2-22, 2-23, 2-24, 2-26, 3-1, 

3-2, 3-4, 3-6, 3-11, 3-12, 3-13, 3-14, 3-15, 

3-17, 3-23, 3-26, 3-27, 3-28, 3-30, 3-31, 

3-32, 3-35, 3-36, 3-39, 3-40, 3-52, 3-57, 

3-58, 3-67, 3-68, 3-77, 3-81, 3-83, 3-84, 

3-85, 3-91, 3-92, 3-96, 3-112, 3-114, 

3-121, 3-125, 3-126, 3-129, 3-130, 3-131, 

3-132, 3-133, 3-136, 3-137, 3-139, 3-140, 

3-141, 3-144, 3-147, 3-149, 3-150, 3-151, 

3-160, 3-161, 3-163, 3-164, 3-165, 3-166, 

3-167, 3-168, 3-171, 3-172, 3-174, 3-176, 

3-177, 3-180, 3-183, 3-186, 5-3

Leasing, oil and gas, 3-28, 3-30

Leasing, terms and stipulations, 1-9

Listed species, see Threatened and 

endangered species, 2-7, 2-10, 3-100, 

3-101, 3-120, 5-4

Mexican Spotted Owl, 1-20, 1-26, 2-9, 2-11, 

3-86, 3-89, 3-96, 3-99, 3-100, 3-102, 

3-112, 3-115, 3-116, 3-121, 3-122

Minerals, entry, 3-28

Minerals, fluid, 5-3

Minerals, locatable, 3-28

Mining Law of 1872, 3-28

National Ambient Air Quality Standards, 

3-61, 3-63, 3-64, 3-65, 3-77

National Environmental Policy Act of 1969 

(NEPA), 1-1, 1-2, 1-8, 1-14, 1-16, 1-17, 

1-18, 1-19, 2-3, 2-5, 2-12, 2-15, 2-16, 

2-20, 2-21, 2-22, 2-26, 2-27, 3-1, 3-14, 

3-16, 3-17, 3-24, 3-25, 3-26, 3-31, 3-33, 

3-35, 3-36, 3-40, 3-57, 3-73, 3-76, 3-83, 

3-92, 3-114, 3-127, 3-131, 3-132, 3-138, 

3-140, 3-146, 3-147, 3-161, 3-163, 3-165, 

3-166, 3-167, 3-168, 3-171, 3-174, 3-176, 

3-183, 3-185, 3-186, 3-187, 3-188, 4-1, 

5-3

National Park Service (NPS), 1-15, 1-19, 

1-22, 3-5, 3-7, 3-9, 3-11, 3-16, 3-129, 
Chapter 7. Index

Santa Fe National Forest Geothermal Leasing EIS 7-3

3-142, 3-147, 3-150, 3-151, 3-152, 3-170, 

3-172, 3-176, 4-2, 4-3

National Register of Historic Places 

(NRHP), 1-24, 2-2, 2-7, 2-10, 2-23, 

3-127, 3-128, 3-129, 3-130, 3-133, 3-134, 

3-140, 3-141

National Wild and Scenic Rivers System 

(NWSRS), 3-12

Nonattainment area, 3-65, 3-68

Off-highway vehicle (OHV), 3-173, 5-3

Old growth, 3-78, 3-79

Old Spanish National Historic Trail, 3-11

Ozone (O3), 3-61, 3-62, 3-65, 3-67, 3-77, 

3-179

Particulate matter (PM2.5, PM10), 3-61, 3-62, 

3-63, 3-65, 3-66, 3-70, 3-72, 3-73, 3-74, 

3-76

Phosphate, 3-55

Plants, invasive, 3-80, 3-93

Proposed species, 1-24, 2-7, 2-10, 3-90, 

3-98, 3-113, 5-4

Public access, 1-21, 3-14

Raptor, 2-4, 3-79, 3-97, 3-117, 3-118, 3-120, 

3-122

Reasonably Foreseeable Development 

Scenario (RFDS), 1-2, 1-15, 1-16, 2-1, 

2-10, 2-13, 2-14, 2-18, 2-20, 2-21, 3-2, 

3-29, 3-31, 3-32, 3-40, 3-41, 3-54, 3-57, 

3-65, 3-70, 3-71, 3-72, 3-73, 3-74, 3-75, 

3-76, 3-77, 3-82, 3-83, 3-91, 3-92, 3-114, 

3-115, 3-117, 3-118, 3-119, 3-120, 3-126, 

3-129, 3-132, 3-134, 3-138, 3-140, 3-141, 

3-146, 3-150, 3-161, 3-163, 3-164, 3-175, 

3-181, 3-182, 3-183, 3-184, 3-185, 3-186

Record of Decision (ROD), 1-1, 1-15, 2-2, 

3-172, 3-174

Redondo Creek, 1-11, 3-80

Renewable energy, 1-2, 3-27, 3-32, 3-185, 

5-3

Rights-of-way (ROW), 2-4, 2-26, 3-6, 3-7, 

3-8, 3-13, 3-83, 3-168, 3-169, 5-3

Rio Cebolla, 3-10, 3-44, 3-46, 3-47, 3-48, 

3-80, 3-81, 3-101, 3-103, 3-104, 3-106, 

3-110, 3-115

Rio Chama, 3-12, 3-18, 3-42, 3-44, 3-45, 

3-47, 3-48, 3-51, 3-81, 3-84, 3-90, 3-97, 

3-120, 3-135

Rio Grande, 1-21, 2-22, 3-10, 3-17, 3-18, 

3-19, 3-24, 3-29, 3-41, 3-42, 3-44, 3-45, 

3-46, 3-47, 3-48, 3-49, 3-52, 3-56, 3-81, 

3-84, 3-86, 3-88, 3-90, 3-95, 3-97, 3-99, 

3-100, 3-103, 3-116, 3-117, 3-120, 3-135

Rio Grande Cutthroat Trout, 1-21, 2-22, 

3-10, 3-86, 3-88, 3-89, 3-95, 3-96, 3-97, 

3-98, 3-99, 3-103, 3-104, 3-112, 3-116, 

3-117, 3-120

Rio Guadalupe, 3-103

Rio Puerco, 3-45, 3-46, 3-47, 3-48, 3-81, 

3-103, 3-104

San Antonio Creek, 1-25, 2-8, 2-10, 3-10, 

3-44, 3-47, 3-48, 3-80, 3-81, 3-101, 

3-103, 3-110, 3-115, 3-116, 3-117

Sensitive species, 3-10, 3-87, 3-89, 3-91, 

3-98, 3-99, 3-100, 3-101, 3-103, 3-113, 

3-114, 3-120, 3-122, 5-4

Snowmobile, 3-9

Socioeconomics, 2-25, 3-1, 3-152, 3-160, 

3-161, 3-162, 3-165, 3-166

Soils, erodible, 3-39, 3-55

Stipulation, Controlled surface use (CSU), 

1-22, 1-26, 2-2, 2-3, 2-4, 2-5, 2-6, 2-8, 

2-9, 2-11, 2-15, 2-17, 2-20, 2-24, 2-25, 

2-26, 3-2, 3-14, 3-17, 3-31, 3-32, 3-35, 

3-36, 3-41, 3-58, 3-59, 3-82, 3-85, 3-97, 

3-120, 3-121, 3-126, 3-133, 3-140, 3-141, 

3-149, 3-151, 3-165, 3-166, 5-1

Stipulation, No surface occupancy (NSO), 

1-22, 1-24, 2-2, 2-3, 2-4, 2-5, 2-6, 2-7, 

2-8, 2-9, 2-10, 2-11, 2-12, 2-15, 2-17, 

2-18, 2-20, 2-23, 2-24, 2-25, 2-26, 3-2, 

3-14, 3-15, 3-16, 3-17, 3-31, 3-32, 3-35, 

3-36, 3-40, 3-57, 3-58, 3-59, 3-82, 3-85, 

3-91, 3-92, 3-93, 3-95, 3-97, 3-113, 

3-114, 3-115, 3-116, 3-117, 3-118, 3-119, 

3-120, 3-121, 3-126, 3-133, 3-140, 3-141, 

3-149, 3-151, 3-161, 3-165, 3-166, 5-1, 

5-3, 5-4

Stipulation, Timing limitation (TL), 1-22, 

1-26, 2-2, 2-3, 2-4, 2-5, 2-6, 2-9, 2-11, 

2-12, 2-15, 2-20, 2-21, 2-25, 2-26, 3-2, 

3-14, 3-17, 3-31, 3-32, 3-36, 3-91, 3-94, 

3-96, 3-97, 3-113, 3-116, 3-118, 3-121, 

3-133, 3-140, 3-141, 3-151, 3-165, 3-166, 

3-176, 5-4

Surface disturbance, 2-13, 2-17, 2-18, 3-3, 

3-34, 3-35, 3-68, 3-69, 3-70, 3-71, 3-72, 

3-73, 3-74, 3-75, 3-76, 3-77, 3-92, 3-93, 

3-94, 3-95, 3-96, 3-119, 3-121, 3-134, 

3-141, 3-184, 3-187, 3-188
Chapter 7. Index

7-4 Santa Fe National Forest Geothermal Leasing EIS

Surface water, 1-9, 1-20, 2-18, 3-39, 3-42, 

3-44, 3-46, 3-47, 3-49, 3-51, 3-52, 3-53, 

3-55, 3-56, 3-57, 3-58, 3-59, 3-60, 3-92

Threatened and endangered species, 1-14, 

1-21, 2-21, 3-112, 3-114, 3-120

Threatened species, 5-4

Timber harvest, 3-77, 3-102, 3-109

Travel management, 3-13, 3-14, 3-172, 

3-173, 3-174, 3-176

Travel, motorized, 3-173

Utility corridor, 1-13, 1-14, 3-31

Vegetation, invasive species/noxious weed, 

3-80, 3-82, 3-84, 3-120, 3-187

Vegetation, Riparian, 1-24, 1-25, 2-8, 2-10, 

2-20, 3-10, 3-16, 3-45, 3-47, 3-55, 3-57, 

3-80, 3-84, 3-86, 3-88, 3-90, 3-92, 3-93, 

3-95, 3-97, 3-101, 3-102, 3-104, 3-105, 

3-108, 3-110, 3-115, 3-116, 3-117, 3-118, 

3-119, 3-120, 3-121, 3-122, 3-178

Vegetation, wetlands, 1-24, 1-25, 2-8, 2-10, 

3-5, 3-41, 3-47, 3-53, 3-57, 3-60, 3-84, 

3-90, 3-92, 3-93, 3-95, 3-101, 3-115, 

3-116, 3-117, 3-118, 3-119, 3-187

Visual resources, 1-21, 1-22, 2-24, 3-136, 

3-141, 3-142, 3-144, 3-146, 3-147, 3-149, 

3-150, 3-152, 3-161, 3-162, 3-186, 3-187, 

4-2, 4-3

Water quality, 1-9, 1-14, 1-20, 3-46, 3-52, 

3-53, 3-55, 3-57, 3-59, 3-60, 3-86, 3-88, 

3-91, 3-104, 3-137, 3-162, 3-164, 3-168

Water, groundwater, 1-14, 2-18, 3-14, 3-17, 

3-24, 3-42, 3-49, 3-50, 3-51, 3-52, 3-53, 

3-54, 3-55, 3-56, 3-57, 3-58, 3-59, 3-60, 

3-92, 3-95, 3-116, 3-187

Water, rights, 1-25, 2-8, 2-10, 3-25, 3-54, 

3-57, 3-58, 3-59, 3-92, 3-95, 3-116, 3-138

Water, surface water, 1-9, 1-20, 2-18, 3-39, 

3-42, 3-44, 3-46, 3-47, 3-49, 3-51, 3-52, 

3-53, 3-55, 3-56, 3-57, 3-58, 3-59, 3-60, 

3-92

Watershed, 1-14, 2-18, 3-4, 3-5, 3-7, 3-41, 

3-42, 3-43, 3-44, 3-45, 3-46, 3-47, 3-48, 

3-49, 3-51, 3-52, 3-53, 3-55, 3-56, 3-57, 

3-58, 3-59, 3-60, 3-79, 3-80, 3-81, 3-82, 

3-83, 3-84, 3-85, 3-97, 3-120, 5-5

Wilderness Characteristics, 1-20, 2-13, 3-12

Wildland fire, 2-20, 3-67, 3-77, 3-83, 3-84, 

3-85, 3-88, 3-104, 3-111, 3-117, 3-120, 

3-121, 3-167, 3-168, 3-179

Withdrawal, 1-13, 1-22, 2-7, 2-17, 2-18, 3-7, 

3-24, 3-40, 3-57, 3-59, 3-92, 3-95, 3-116
Appendix A

Management Areas and Prescriptions 

from Forest Plan
This page intentionally left blank.
Appendix A. Management Areas and Prescriptions from Forest Plan

Santa Fe National Forest Geothermal Leasing EIS A-1

Appendix A. Management Areas and Prescriptions from Forest Plan

Management 

Area

Acres in the 

Project Area Management Emphasis

Minerals 

Standards 

and 

Guidelines

Lands and Realty 

Standards and 

Guidelines1

A 52,500 Emphasis is on timber production and 

enhancement of wildlife habitat 

diversity, consistent with other resource 

integration. Grazing capacity is 

generally transitory in nature, but there 

are allotments in intermingled 

grasslands. Roaded dispersed recreation 

experiences are emphasized. Firewood 

is provided as a by-product of timber 

harvesting.

G04 –

mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

B 14,100 The emphasis in this area is on wildlife 

habitat improvement and key species 

habitat protection. Grazing and timber 

harvesting occur where they are 

compatible with the primary emphasis 

of this area. Recreation is mostly of a 

dispersed roaded nature. Timber 

harvesting slash will be provided for 

wildlife and firewood.

G04 –

mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

C 1,200 Emphasis is on enhancing visual 

quality and developed recreation 

opportunities, while protecting essential 

wildlife habitat and riparian zones. 

Grazing and timber harvesting occur 

where consistent with the primary 

emphasis of this area.

G04 –

mineral 

leasing 

category: 

Limited Use

J01 – Classification 

for power lines in 

excess of 69 kV: 

Avoidance

D <100 Emphasis is on enhancing visual 

quality and developed recreation 

opportunity. Grazing and timber 

harvesting occur where they are 

consistent with the primary emphasis of 

this area.

G04 –

mineral 

leasing 

category: 

Limited 

Surface Use

J01 – Classification 

for power lines in 

excess of 69 kV: 

Avoidance

E 17,700 Emphasis is on providing dispersed 

recreation opportunities, maintaining 

visual quality, and harvesting timber 

and firewood. Grazing activities vary in 

intensity over this area. Emphasis is on 

maintaining or enhancing wildlife 

habitat diversity.

G04 –

mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors
Appendix A. Management Areas and Prescriptions from Forest Plan

A-2 Santa Fe National Forest Geothermal Leasing EIS

Appendix A. Management Areas and Prescriptions from Forest Plan

Management 

Area

Acres in the 

Project Area Management Emphasis

Minerals 

Standards 

and 

Guidelines

Lands and Realty 

Standards and 

Guidelines1

F 3,300 Management area F is specific to the 

Jemez Wild and Scenic River.

Emphasis is on prohibiting road 

construction and motorized use, 

managing for high scenic integrity 

objective, and managing for semiprimitive nonmotorized recreation 

opportunity spectrum setting.

Closed to 

new mineral 

leasing

Prohibit new road 

construction 

G 8,600 Emphasis in this area is on protecting 

key wildlife habitats, improving 

habitats, and producing forage and 

firewood. Recreational opportunities 

are dispersed and consist of firewood 

and pinyon nut gathering, hunting, and 

recreational driving.

G04 –

mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

L 4,300 Emphasis is on providing semiprimitive nonmotorized recreation 

opportunities. Wildlife, range, and fuels 

may be managed where it is consistent

with this emphasis. Timber harvesting

and road building are not consistent 

with this emphasis, and neither is

scheduled in this planning period. 

These areas will receive priority in 

dispersed recreation management, trail 

and trailhead development, and trail 

maintenance.

G04 –

Mineral 

leasing 

category: 

Limited 

Surface Use

J01 – Classification 

for power lines in 

excess of 69 kV: 

Avoidance

M 600 These areas will be managed to provide 

opportunities for non-disruptive 

research and education. This 

management includes allowing natural 

processes to occur and protecting

natural features. Use restrictions will be 

imposed as necessary to keep areas in 

their natural or unmodified condition. 

No timber or firewood will be 

harvested, nor will this area be assigned 

any grazing capacity.

G04 –

Mineral 

leasing 

category: 

Limited 

Surface Use 

– No Surface 

Occupancy

J01 – Utility 

corridors are 

excluded
Appendix A. Management Areas and Prescriptions from Forest Plan

Santa Fe National Forest Geothermal Leasing EIS A-3

Appendix A. Management Areas and Prescriptions from Forest Plan

Management 

Area

Acres in the 

Project Area Management Emphasis

Minerals 

Standards 

and 

Guidelines

Lands and Realty 

Standards and 

Guidelines1

N 6,700 The emphasis here will be on 

management that protects and enhances 

essential wildlife habitat. This land area 

will not be included in the suitable 

timber base. However, certain timber 

management activities—as well as 

grazing, firewood collection, and fire 

management—may occur, when they 

are consistent with the emphasis on 

protecting this area.

G04 –

Mineral 

leasing 

category: 

Limited 

Surface Use

J01 – Classification 

for power lines in 

excess of 69 kV: 

Avoidance

P 9,800 Cultural resource location, inventory, 

nomination, and protection are 

emphasized here. Emphasis is also on 

timber production and enhancement of 

wildlife habitat diversity, consistent 

with other resource integration. Grazing 

capacity is generally transitory in 

nature, but there are allotments in 

intermingled grasslands. Roaded,

dispersed recreation experiences are 

emphasized. Firewood is provided as a 

by-product of timber harvesting.

G04 –

Mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

Q 3,200 Cultural resource site location, 

inventory, nomination, and protection 

in these areas are emphasized. The 

emphasis is also on providing dispersed 

recreation opportunities, while 

maintaining visual quality, timber 

harvesting, and firewood production. 

Grazing activities vary in intensity over 

this area. The emphasis is on 

maintaining or enhancing wildlife 

habitat diversity. Cultural resource site 

location, inventory, nomination, and 

protection in these areas are

emphasized.
Appendix A. Management Areas and Prescriptions from Forest Plan

A-4 Santa Fe National Forest Geothermal Leasing EIS

Appendix A. Management Areas and Prescriptions from Forest Plan

Management 

Area

Acres in the 

Project Area Management Emphasis

Minerals 

Standards 

and 

Guidelines

Lands and Realty 

Standards and 

Guidelines1

R 24,800 Cultural resource location, inventory, 

nomination, and protection are

emphasized. The emphasis is also on 

wildlife habitat improvement and

essential habitat protection and 

enhancement. Grazing and timber 

harvesting occur, where they are 

compatible with the primary emphasis 

of this area. Recreation is mostly 

dispersed and in roaded areas. 

Firewood, a by-product of timber 

harvest, is provided.

G04 –

Mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

S 1,300 Cultural resource site location, 

inventory, nomination, and protection 

are emphasized in these areas. 

Emphasis is also given to key wildlife 

habitat protection, habitat 

improvement, and forage and firewood 

production. Recreation is dispersed and 

consists primarily of firewood and 

Christmas tree gathering.

G04 –

Mineral 

leasing 

category: 

Standard

J01 – Unclassified 

for utility corridors

X 25,100 Management Area X is specific to the 

Jemez National Recreation Area. 

Emphasis is on managing recreation 

and other uses, while protecting soil, 

water, and wildlife resources. The 

Scenic Integrity Objective is High.

Mining is

prohibited, 

except where 

valid claims 

existed 

before the 

establishment 

of the JNRA. 

A utility corridor for 

transmission lines 

may only be 

permitted if there is 

no feasible 

alternative location; 

there is no significant 

damage to 

archaeological and 

religious sites; it is in 

the public interest; 

and a plan to 

minimize harm to 

resources has been 

developed. 

Sources: Forest Service 1987; Forest Service GIS 2015

1 Excludes Forest-Wide Standards and Guidelines
Appendix B

Stipulations and Closures by Alternative
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Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-1

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

Fish and Wildlife

Designated or 

proposed critical 

habitat

Surface occupancy and use is 

prohibited on designated or proposed

critical habitat for listed species under 

the Endangered Species Act of 1973 

(as amended), as following: 

• New Mexico meadow jumping 

mouse

• Mexican spotted owl 

• Jemez mountain salamander

Purpose: To avoid surface disturbance activities that would 

result in loss of critical habitat within these distinct localized 

areas

Changes: An exception, modification, or waiver may be 

granted if an operator could demonstrate in a site-specific 

surface use plan of operations that adverse impacts on habitat 

could be completely avoided and clearance is obtained from the 

agency biologist and the US Fish and Wildlife Service.

• •

Cultural Resources

Areas with important 

cultural resources

Surface occupancy and use is

prohibited at the following:

• Traditional cultural properties and 

Native American sacred sites, as 

identified through consultation

• Properties listed on or eligible for 

listing on the National Register of 

Historic Places, including National 

Landmarks and National Register 

Districts and Sites; also, additional 

lands outside the designated 

boundaries, to the extent 

necessary to protect values where 

the setting and integrity is critical 

to their designation or eligibility

• Areas that qualify for cultural 

resource protection based on 

Forest Plan criteria (Planning 

Areas I, P, Q, R, and S)

Purpose: To avoid surface disturbance activities that would 

result in irreversible loss of cultural resources within these 

areas where cultural resource avoidance or data recovery are 

not viable options

Changes: An exception, modification, or waiver may be 

granted if an operator’s site-specific surface use plan of 

operations were to demonstrate that adverse impacts on the 

cultural resources could be completely avoided, and clearance 

is recommended, in accordance with the requirements of 

Section 106 of the National Historical Preservation Act, and 

approved by the Forest Supervisor.

• •

Water Resources and Water Quality

Water bodies, rivers

and streams

(perennial and 

intermittent), riparian 

areas, wetlands, 

playas, 100-year 

floodplains, and a 

Surface occupancy and use is 

prohibited within a 500-foot-wide 

protection zone, measured horizontally 

from the outer edge of each feature for

the following:

• Water bodies, rivers and streams 

(perennial and intermittent), 

Purpose: To avoid adverse impacts on riparian and wetland 

resources, to prevent development in floodplains, and to remain 

consistent with law (Clean Water Act), regulation, and policy 

(National BMPs)

Changes: An exception or modification may be granted if 

surveys show that the area of a proposed activity is not a water 

•
Appendix B. Stipulations and Closures by Alternative

B-2 Santa Fe National Forest Geothermal Leasing EIS

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

500-foot-wide 

protection zone 

around them

wetlands, and playas (mapped in 

the USGS National Hydrography 

Dataset [NHD]) 

• Riparian areas are protected by a 

500-foot-wide buffer. They are 

approximately mapped within the 

terrestrial ecosystem survey and 

vegetation data sets (includes 

Terrestrial Ecosystem Units 3-8, 

10, 11, 13, 31, 33, 34, 38, 234, 

320, and 334), but they may also 

need site-specific field delineation. 

• The 100-year floodplain 

(surrounding some features) 

needs to be delineated through 

field geomorphology surveys, 

stream gage data, and hydrologic 

modeling.

feature and that impacts on a water feature are not likely to 

occur. 

Roads and power lines may cross these areas if the operator 

can show that crossing the water feature and protection zone 

will have less environmental impact than other routes and that 

adverse effects can be minimized.

Water bodies, 

perennial rivers and 

streams, riparian

areas, wetlands, 

playas, 100-year 

floodplains, and a 

500-foot-wide 

protection zone 

around them.

Surface occupancy and use is 

prohibited within a 500-foot wide 

protection zone measured horizontally 

from the outer edge of each feature for

the following:

• Water bodies, perennial rivers and 

streams, wetlands, and playas 

(mapped in the USGS NHD) 

• Riparian areas are protected by a 

500 foot-wide buffer. They are 

approximately mapped within the 

terrestrial ecosystem survey and 

vegetation data sets (includes 

Terrestrial Ecosystem Units 3-8, 

10, 11, 13, 31, 33, 34, 38, 234, 

320, and 334), but they may also 

need site specific field delineation. 

• The 100-year floodplain 

(surrounding some features) 

needs to be delineated through 

field geomorphology surveys, 

Purpose: To avoid adverse impacts on riparian and wetland 

resources, to prevent development in floodplains, and to remain 

consistent with law (Clean Water Act), regulation, and policy 

(National BMPs).

Changes: An exception or modification may be granted if 

surveys show that the area of a proposed activity is not a water 

feature and that impacts on a water feature are not likely to 

occur. 

Roads and power lines may cross these areas if the operator 

can show that crossing the water feature and protection zone 

will have less environmental impact than other routes and that 

adverse effects can be minimized. 

•
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-3

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

stream gage data and hydrologic 

modeling.

Acequias and a 50-

foot protection zone

Surface occupancy and use is 

prohibited within a 50-foot protection 

zone, as measured horizontally from 

the outer edge of the ditch for acequias 

with the New Mexico Office of the State 

Engineer (NMOSE) recognized water 

rights.

Purpose: To avoid adverse impacts on riparian and wetland 

resources and impairment of existing water rights

Changes: An exception or modification may be granted if 

surveys show that impacts on the acequia are not likely to occur 

and the New Mexico Acequia Commission agrees. 

Roads and power lines may cross these areas if the operator 

can show that crossing the acequia and protection zone would 

have less environmental impact than other routes and that 

adverse effects could be minimized. 

• •

Recognized Water 

Sources and a 1-mile 

protection zone 

around them

Surface occupancy and use is 

prohibited within a 1-mile protection 

zone for recognized water sources. In 

the project boundary, these are as 

follows: 

• Drinking water sources 

(recognized by the Drinking Water 

Bureau of the New Mexico 

Environmental Department

[NMED-DWB])

• Wells (recognized by the NMOSE)

• Springs (recognized by the 

NMOSE)

Purpose: To protect the water quality and quantity of water 

sources. Protecting water sources will help the Forest Service 

comply with its own management direction, such as the Santa 

Fe National Forest Plan (1987) and FSM 2500; laws, such as 

the Clean Water Act (1972) and the Safe Drinking Water Act 

(1974); and regulations, such as New Mexico water quality 

standards, water rights. and permits.

Changes: An exception or modification may be granted if the 

operator’s surface and subsurface hydrology studies and 

mitigation plans were to show there is no reasonable risk to the 

quality or quantity at a water source.

Roads and power lines may cross a water source protection 

zone if the operator can demonstrate that it would have less 

environmental impact than other routes and that adverse effects 

could be minimized.

•

NMED-DWB

recognized drinking 

water sources and a 

1-mile protection 

zone around them

Surface occupancy and use is 

prohibited within a 1-mile protection 

zone for NMED-DWB recognized 

drinking water sources, such as that 

within the project boundary.

Purpose: To protect the water quality and quantity of water 

sources. Protecting water sources will help the Forest Service 

comply with its own management direction, such as the Santa 

Fe National Forest Plan (1987) and FSM 2500; law, such as the 

Clean Water Act (1972) and the Safe Drinking Water Act 

(1974); and regulation, such as the New Mexico water quality 

standards, water rights, and permits.

Changes: An exception or modification may be granted if the 

•
Appendix B. Stipulations and Closures by Alternative

B-4 Santa Fe National Forest Geothermal Leasing EIS

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

operator’s surface and subsurface hydrology studies and 

mitigation plans were to show that there is no reasonable risk to 

the quality or quantity at a water source. 

Roads and power lines may cross a water source protection 

zone if the operator can demonstrate that it would have less 

environmental impact than other routes and that adverse effects 

could be minimized.

Geologic Resources

Hot springs and a 1-

mile protection zone 

around them

Surface occupancy and use is 

prohibited on hot springs. These are 

defined broadly as places on the 

earth’s surface with natural discharges 

of elevated temperature groundwater. 

Within the project area boundary there 

are two known hot springs outside of 

the JRNA: San Antonio Hot Springs

and Sulphur Springs, which is on 

private land, but the protection zone 

extends onto Forest Service lands. A 1-

mile (radius) protection zone would 

surround any known or currently 

unknown hot spring, within which the 

area would be closed to all surface 

occupancy.

Purpose: To protect the water quality, water quantity, unique 

ecosystems, and cultural values these features hold.

Changes: An exception or modification may be granted if the 

operator’s surface and subsurface hydrology studies and 

mitigation plans were to show that there is no reasonable risk to 

the quality or quantity of water creating the feature.

Roads and power lines may cross these areas if the operator 

can demonstrate there are no practicable alternatives and that 

adverse effects could be minimized. Detailed plans for 

mitigations to adverse effects would be required with the 

application for exception or modification.

•

Soils

Slopes in excess of 

40 percent

Surface occupancy and use is 

prohibited on slopes equal to or in 

excess of a 40 percent grade. These 

areas are extremely susceptible to 

erosion and mass wasting.

Purpose: To preclude surface-disturbing activities on steep 

slopes, because these areas tend to have high erosion and a 

mass wasting hazard. Additionally, water quality is more likely 

to be impaired where steep slopes have been developed. 

Without this protection there would be a high risk of impairing 

long-term soil productivity and watershed conditions. 

Additionally, these precautions must be taken to remain 

consistent with Forest Service policy.

Changes: An exception or modification may be granted if onsite inspection were to show that unstable or steep slopes do 

not exist on the specific site, or if the operator could 

demonstrate in a plan of operations that adverse effects could 

• •
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-5

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

be minimized and activities safely conducted without a loss of 

long-term site productivity. 

Power lines and roads may cross slopes equal to or exceeding 

a 40 percent gradient. Where this occurs, any vegetation or 

ground disturbance must have a minimal impact on the 

hydrologic network. This can be achieved through proper 

implementation of best management practices (BMPs) and by 

designing for sufficient and appropriate water control.

Soils with severe 

erosion potential

Surface occupancy and use is 

prohibited on all soils with severe 

erosion potential, as defined by the 

Forest Service Terrestrial Ecological 

Unit geographical information system 

(GIS) layers.

Purpose: To preclude surface-disturbing activities on severely 

erosive soils, because these areas are likely to erode. Without 

this protection there would be a high risk of impairing long-term 

soil productivity and watershed conditions. Additionally, these 

precautions must be taken to remain consistent with Forest 

Service policy.

Changes: An exception or modification may be granted if 

onsite inspection were to show that soils with severe erosion 

potential do not exist on the specific site, or if the operator could 

demonstrate in a plan of operations that adverse effects could 

be minimized and activities safely conducted without the loss of 

long-term site productivity.

Power lines and roads may cross areas with severely erosive 

soils. Where this occurs, any vegetation or ground disturbance 

must incorporate BMPs to minimize erosion potential.

•

Land Use, Recreation, and Special Designations

Developed recreation 

facilities 

Surface occupancy and use is 

prohibited on the following developed 

recreation facilities:

• San Antonio Creek Recreation 

Area

• Seven Springs Recreation Area

• Paliza Recreation Area

Purpose: To avoid incompatible development that would 

impact developed recreation facilities and sites.

Changes: No exceptions, waivers, or modifications would be 

considered.

•
Appendix B. Stipulations and Closures by Alternative

B-6 Santa Fe National Forest Geothermal Leasing EIS

Table B-1. No Surface Occupancy Stipulations for Geothermal Leasing

Resource Stipulation Purpose and Changes 

(Exception, Modification, or Waiver)

Alternative

1 2 3 4

Developed recreation 

facilities and Forest 

Service 

administrative sites

Surface occupancy and use is 

prohibited on the following developed 

recreation facilities and Forest Service 

administrative sites:

• San Antonio Creek Recreational 

Area

• Seven Springs Recreation Area

• Paliza Recreation Area

• Seven Springs Administrative Site

• Encino Administrative Site

• Encino Point Administrative Site

• Cerro Pelado Lookout 

Administrative Site

Purpose: To avoid incompatible development that would 

impact developed recreation facilities and administrative sites.

Changes: No exceptions, waivers, or modifications would be 

considered.

•

Inventoried roadless 

areas

Surface occupancy and use is 

prohibited on inventoried roadless 

areas.

Purpose: To keep surface disturbance activities outside the 

inventoried roadless area. This stipulation is needed to protect 

and maintain the roadless, semiprimitive, and nonmotorized 

character of these special areas. Examples are such elements 

as natural integrity, natural appearance, opportunity for quiet 

and solitude, manageability of boundaries, and special features, 

such as ecological, geological, scenic, cultural features.

Changes: No exceptions, waivers, or modifications would be 

considered.

• •

Visual Resources

National Forest 

System lands with a 

Scenery Management 

System integrity level 

of very high

Surface occupancy and use is 

prohibited on National Forest System 

lands with a Scenery Management 

System integrity level of very high. This 

is Management Area L in the SFNF 

Forest Plan.

Purpose: To protect important viewsheds.

Changes: An exception, modification, or waiver may be 

granted if an operator’s site-specific surface use plan of 

operations were to demonstrate that adverse impacts on the 

viewshed would not occur.

•
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-7

Table B-2. Controlled Surface Use Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Soils

Slopes between 30 

and 40 percent

Design and locate all surface-disturbing 

activities to minimize soil erosion. 

Erosion factors include fugitive dust, 

wind, and stormwater runoff. BMPs 

would be applied to all sites containing 

these soils, and additional measures 

may be required.

Purpose: To preclude surface-disturbing activities on slopes 

that tend to have high erosion and a mass wasting hazard. 

Additionally, water quality is more likely to be impaired where 

slopes have been developed. Without this protection there 

would be a risk of impairing long-term soil productivity and 

watershed conditions. Additionally, these precautions must be 

taken to remain consistent with Forest Service policy.

Changes: An exception or modification may be granted if onsite inspection were to show that unstable or steep slopes do 

not exist on the specific site, or if the operator could 

demonstrate in a plan of operations that adverse effects could 

be minimized and activities safely conducted without loss of 

long-term site productivity. 

Power lines and roads may cross these slopes. Where this 

occurs, any vegetation or ground disturbance must have a 

minimal impact on the hydrologic network. This could be 

achieved through proper implementation of BMPs and 

designing for sufficient and appropriate water control.

• •

Soils with severe 

erosion potential

Design and locate all surface-disturbing 

activities to minimize soil erosion. 

Erosion factors are fugitive dust, wind, 

and stormwater runoff. BMPs would be 

applied to all sites containing these 

soils, and additional measures may be 

required.

Purpose: To limit and modify surface-disturbing activities on 

severely erosive soils, because these areas are likely to erode. 

Without this protection there would be a high risk of impairing 

long-term soil productivity and watershed conditions. 

Additionally, these precautions must be taken to remain 

consistent with Forest Service policy.

Changes: An exception or modification may be granted if onsite inspection were to show that soils with severe erosion 

potential do not exist on the specific site.

Power lines and roads may cross areas with severely erosive 

soils. Where this occurs, any vegetation or ground disturbance 

must incorporate BMPs to minimize erosion potential.

•
Appendix B. Stipulations and Closures by Alternative

B-8 Santa Fe National Forest Geothermal Leasing EIS

Table B-2. Controlled Surface Use Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Water Resources and Water Quality

Intermittent streams 

listed in the NHD and 

ephemeral drainages 

delineated by sitespecific mapping

Design and locate all surface-disturbing 

activities to minimize or avoid impacts 

on intermittent and ephemeral 

drainages. BMPs would be applied to 

all sites containing these features, and 

additional measures may be required.

Purpose: To limit and modify surface-disturbing activities on 

severely erosive soils, because these areas are likely to erode. 

Without this protection there would be a high risk of impairing 

long-term soil productivity and watershed conditions. 

Additionally, these precautions must be taken to remain 

consistent with Forest Service policy.

Changes: An exception or modification may be granted if onsite inspection were to show that intermittent streams or 

ephemeral drainages do not exist on the specific site.

Power lines and roads may cross intermittent streams or 

ephemeral drainages. Where this occurs, any vegetation or 

ground disturbance must incorporate BMPs to minimize erosion 

potential.

•

New Mexico OSErecognized wells and 

springs

Design and locate all surface-disturbing 

activities to minimize soil erosion.

BMPs will be applied to all sites, and 

additional measures may be required. 

Proper drilling and casing processes 

will be required to protect groundwater 

quality.

Purpose: To limit and modify surface-disturbing activities near 

springs and wells that might impact water quality. Without this 

protection there would be a high risk of impairing water quality. 

Additionally, these precautions must be taken to remain 

consistent with Forest Service policy.

To limit activities that would impact groundwater quantity or 

quality. Without this protection, the owner’s water right could be 

impaired.

Changes: An exception or modification may be granted if onsite inspection were to show that the spring does not exist on 

the specified site.

•

Land Use, Recreation, and Special Designations

Dispersed 

recreational areas

Locate and design surface disturbance 

activities to be compatible with 

dispersed recreational use. Also,

reclaim disturbed areas to be 

substantially unnoticeable to dispersed 

recreational users within 1 to 3 years of 

project startup. Generally, this can be 

met by following BMPs.

Purpose: To minimize the potential for adverse impacts on

recreational values, both motorized and nonmotorized, and the 

natural settings associated with the recreation.

Changes: An exception, modification, or waiver may be 

granted if the operator could demonstrate that the proposed 

surface disturbance would have less environmental impact than 

placing the surface-disturbing activity elsewhere and that 

adverse effects could be minimized.

• •
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-9

Table B-2. Controlled Surface Use Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Visual Resources

Viewsheds with a 

Scenery Management 

System integrity level

of high

Locate and design surface disturbance 

activities to be consistent with the 

scenic integrity of high or to reclaim 

disturbed areas to meet the visual 

quality objective within 5 years of 

project startup. Generally, this can be 

met by following BMPs for minimizing 

impacts on visual quality, along with 

visual quality guidelines in the Forest 

Plan and Forest Service Scenery 

Management System Handbook 

(Agriculture Handbook 701).

Purpose: To protect the long-term scenic values in areas of 

high scenic integrity, consistent with Forest Service directives 

and the Forest Plan.

Changes: An exception, modification, or waiver may be 

granted if the operator were to demonstrate in a site-specific 

surface use plan of operations that adverse impacts on the 

viewshed would not occur.

•

Viewsheds with a 

Scenery Management 

System integrity level

of very high and high

Locate and design surface disturbance 

activities to be consistent with the 

scenic integrity or to reclaim disturbed 

areas to meet the visual quality 

objective within 5 years of project 

startup. Generally, this can be met by 

following BMPs for minimizing impacts 

on visual quality, along with visual 

quality guidelines in the Forest Plan 

and Forest Service Scenery 

Management System Handbook 

(Agriculture Handbook 701).

Purpose: To protect the long-term scenic values in areas of 

high scenic integrity, consistent with Forest Service directives 

and the Forest Plan.

Changes: An exception, modification, or waiver may be 

granted if the operator were to demonstrate in a site-specific 

surface use plan of operations that adverse impacts on the 

viewshed would not occur.

•
Appendix B. Stipulations and Closures by Alternative

B-10 Santa Fe National Forest Geothermal Leasing EIS

Table B-3. Timing Limitation Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Threatened and Endangered Species and Special Status Species

Mexican spotted owl 

designated protected 

activity centers 

(PACs)

Timing limitation would be imposed on 

drilling operations and construction 

activities from March 1 to August 31.

Purpose: To protect and limit disturbance from drilling and 

construction within Mexican spotted owl PACs (nesting/fledging 

areas). This would be to minimize risks to the owl’s reproductive 

and post-fledging success during the critical nesting/breeding 

period. This is defined in the recovery plan for this federally 

listed threatened species, as well as in the Forest Plan 

(Appendix D, p. 2). This stipulation would not apply to daily 

operations and maintenance.

Changes: An exception, modification, or waiver to the timing 

limitation may be granted if an operator’s site-specific surface 

use plan of operations were to demonstrate that adverse 

impacts on threatened and endangered species could be 

avoided, effects were documented in a biological assessment, 

and concurrence from the US Fish and Wildlife Service were 

obtained.

• •

Northern goshawk 

designated Postfledging areas (PFAs)

Timing limitation would be imposed on 

drilling operations and construction 

activities from March 1 to September 

30.

Purpose: To protect and limit disturbance from drilling and 

construction within northern goshawk nesting PFAs. This would 

be to minimize risks to reproductive and post-fledging success 

of northern goshawks during the critical nesting/breeding period,

defined in interagency goshawk guidelines and the Forest Plan 

(Appendix D, pp. 6, 10). This stipulation would not apply to daily 

operations and maintenance.

Changes: An exception, modification, or waiver to the timing 

limitation may be granted if goshawk surveys were to show that 

the area is not used for nesting.

• •

Peregrine falcon eyrie 

nesting areas

Timing limitation would be imposed on 

drilling operations and construction 

activities from March 1 to August 15.

Purpose: To protect and limit disturbance from drilling and 

construction in peregrine falcon habitat. This would be to 

minimize risks to reproductive and post-fledging success of 

peregrine falcons during the critical nesting/breeding period, 

consistent with the Forest Plan (p. 63) and Forest Service 

directives. This stipulation would not apply to daily operations

and maintenance.

Changes: An exception, modification, or waiver to the timing 

limitation may be granted if surveys were to show that the area 

is not used for nesting.

• •
Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-11

Table B-3. Timing Limitation Stipulations for Geothermal Leasing

Resource Stipulation Purpose, Changes (Exception, Modification, or Waiver) Alternative

1 2 3 4

Elk calving areas Timing limitation would be imposed on 

drilling operations and construction 

activities from June 1 to July 31.

Purpose: To protect and limit disturbance from drilling and 

construction in important elk calving areas. This would be to 

minimize risks to herd reproduction during a critical period. This 

stipulation would not apply to daily operations and maintenance.

Changes: An exception or modification to the timing limitation 

may be granted if the operator were to demonstrate that the 

drilling/construction location would not disrupt deer fawning and 

elk calving.

• •
Appendix B. Stipulations and Closures by Alternative

B-12 Santa Fe National Forest Geothermal Leasing EIS

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Appendix B. Stipulations and Closures by Alternative

Santa Fe National Forest Geothermal Leasing EIS B-13

List of Figures – Appendix B

Figure 2-1. Alternative 2 – The Proposed Action Closed to Leasing

Figure 2-2. Alternative 2 – The Proposed Action Available for Leasing Subject to 

No Surface Occupancy

Figure 2-3. Alternative 2 – The Proposed Action Available for Leasing Subject to 

Controlled Surface Use

Figure 2-4. Alternative 2 – The Proposed Action Available for Leasing Subject to 

Timing Limitations

Figure 2-5. Alternative 4 – The Development Alternative Closed to Leasing

Figure 2-6. Alternative 4 – The Development Alternative Available for Leasing Subject to 

No Surface Occupancy

Figure 2-7. Alternative 4 – The Development Alternative Available for Leasing Subject to 

Controlled Surface Use

Figure 2-8. Alternative 4 – The Development Alternative Available for Leasing Subject to 

Timing Limitations

Figure 2-9. Alternative 3 – The No Leasing Alternative Closed to Leasing
Appendix B. Stipulations and Closures by Alternative

B-14 Santa Fe National Forest Geothermal Leasing EIS

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Figure 2-1 Appendix B. Stipulations and Closures by Alternative Santa Fe National Forest Geothermal Leasing EIS B-15
Figure 2-2 Appendix B. Stipulations and Closures by Alternative B-16 Santa Fe National Forest Geothermal Leasing EIS
Figure 2-3 Appendix B. Stipulations and Closures by Alternative Santa Fe National Forest Geothermal Leasing EIS B-17
Figure 2-4 Appendix B. Stipulations and Closures by Alternative B-18 Santa Fe National Forest Geothermal Leasing EIS
Figure 2-5 Appendix B. Stipulations and Closures by Alternative Santa Fe National Forest Geothermal Leasing EIS B-19
Figure 2-6 Appendix B. Stipulations and Closures by Alternative B-20 Santa Fe National Forest Geothermal Leasing EIS
Figure 2-7 Appendix B. Stipulations and Closures by Alternative Santa Fe National Forest Geothermal Leasing EIS B-21
Figure 2-8 Appendix B. Stipulations and Closures by Alternative B-22 Santa Fe National Forest Geothermal Leasing EIS
Figure 2-9 Appendix B. Stipulations and Closures by Alternative Santa Fe National Forest Geothermal Leasing EIS B-23
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Appendix C

Best Management Practices and Mitigation 

Measures
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Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-1

Appendix C. Best Management Practices and 

Mitigation Measures

Best Management Practices (BMPs) are state-of-the-art mitigation measures applied on a sitespecific basis to avoid, minimize, reduce, rectify, or compensate for adverse environmental or 

social impacts. They are applied to management actions to aid in achieving desired outcomes for 

safe, environmentally responsible resource development by preventing, minimizing, or mitigating 

adverse impacts and reducing conflicts.

The following BMPs provide the BLM, Forest Service, industry, and stakeholders a menu of 

practices for developing geothermal energy and minimizing impacts to the environment and 

landscape. The list is not meant to be all inclusive given the constant development of improved 

practices, diversity of the area, and potential for unique site-specific conditions. Practices which 

are not included in this appendix may be implemented as needed.

Some BMPs are more suitable for consideration on a case-by-case basis depending on:

• Their effectiveness

• The balancing of increased operating costs vs. the benefit to the public and resource values

• The availability of less restrictive mitigation alternatives that accomplish the same objective

• Other site-specific factors

Guidelines for applying and selecting project-specific requirements include determining whether 

the measure would:

• Ensure compliance with relevant statutory or administrative requirements

• Minimize local impacts associated with siting and design decisions

• Promote post-construction stabilization of impacts

• Maximize restoration of previous habitat conditions

• Minimize cumulative impacts

• Promote economically feasible development of geothermal energy on Forest Service land

Only those BMPs reasonably necessary to ensure environmentally responsible geothermal 

development should be selected from the list below. Not all of the individual mitigation measures 

below will apply to most situations, and selection of appropriated BMPs and mitigation measures 

should be dependent on factors such as the project size, location, site-specific characteristics, and 

potential resource impacts. Prior to inclusion, the measures may be further modified to meet sitespecific situations and agency requirements.

This list was compiled from several sources, primarily:

• Programmatic EIS for Geothermal Leasing in the Western United States (2008)

• Forest Service National Best Management Practices for Water Quality Management on 

National Forest System Lands (2012) available at: http://www.fs.fed.us/biology/resources/

pubs/watershed/FS_National_Core_BMPs_April2012.pdf

• Forest Service Handbook (Southwestern Region) FSH 2509.22 – Soil and Water 

Conservation Handbook
Appendix C. Best Management Practices and Mitigation Measures

C-2 Santa Fe National Forest Geothermal Leasing EIS

• Santa Fe National Forest Plan (2007 as amended)

In the event that the BMPs listed here are not effective, or do not address a particular resource 

concern, there are numerous other sources which will be consulted. Some of these are:

• Forest Service Low-Volume Roads Engineering Best Management Practices Field Guide 

(2003)

• The Gold Book, Surface Operating Standards and Guidelines for Oil and Gas Exploration and 

Development (current edition)

• BLM Washington Office Fluid Minerals website 

• US DOE Protocol for Addressing Induced Seismicity Associated with Enhanced Geothermal 

Systems (2012)

• US EPA

• New Mexico Game and Fish

• New Mexico Environment Department

In keeping with the PEIS, the BMPs are listed according to the phase of operations they apply to 

the most.

C.1 Information Collection & Monitoring

C.1.1 General

• Prior to geothermal exploration and development, a subsurface geotechnical investigation 

will be conducted to analyze the soil and geologic conditions of each site with proposed 

surface disturbance. The investigation will evaluate and identify potential geologic hazards 

and will provide remedial grading recommendations, foundation and slab design criteria, and 

soil parameters for the design of geothermal power infrastructure.

• The operator will collect available information describing the environmental and sociocultural conditions in the vicinity of the proposed project and will provide the information to 

the agency.

• The agency will require suitable geotechnical or stability analyses to ensure that facilities are 

constructed to acceptable factors of safety using standard engineering practices and 

considering foundation conditions and material, construction materials and techniques, the 

seismicity of the area, and the water-related resources at risk.

• A monitoring program will be developed by the operator to ensure that environmental 

conditions are monitored during the exploration and well drilling, testing, construction, and 

utilization and reclamation phases. The monitoring program requirements, including adaptive 

management strategies, will be established at the project level to ensure that potential adverse 

impacts of geothermal development are mitigated. The monitoring program will identify the 

monitoring requirements for each major environmental resource present at the site, establish 

metrics against which monitoring observations can be measured, identify potential mitigation 

measures, and establish protocols for incorporating monitoring observations and additional 

mitigation measures into ongoing activities. The operator will provide results of the 

monitoring program to the agency in an annual report.

• The operator will comply with the Secretary of Agriculture’s rules and regulations:

♦ For all use and occupancy of the NFS lands prior to approval of an exploration plan by 

the Secretary of the Interior
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-3

♦ For uses of all existing improvements, such as forest development roads, within and 

outside the area permitted by the Secretary of the Interior

♦ For use and occupancy of the NFS lands not authorized by an exploration plan approved 

by the Secretary of the Interior

C.1.2 Paleontological and Cultural Resources

• Before any specific permits are issued under leases, treatment of cultural resources will 

follow the procedures established by the Advisory Council on Historic Preservation for 

compliance with Section 106 of the National Historic Preservation Act. A pedestrian 

inventory will be undertaken of all portions that have not been previously surveyed or are 

identified by the Forest Service or BLM as requiring inventory to identify properties that are 

eligible for the NRHP. Those sites not already evaluated for NRHP eligibility will be 

evaluated based on surface remains, subsurface testing, archival, and/or ethnographic sources. 

Subsurface testing will be kept to a minimum whenever possible if sufficient information is 

available to evaluate the site or if avoidance is an expected mitigation outcome. 

Recommendations regarding the eligibility of sites will be submitted to the Forest Service, 

and a treatment plan will be prepared to detail methods for avoidance of impacts or mitigation 

of effects. The Forest Service will make determinations of eligibility and effect and consult 

with SHPO as necessary based on each proposed lease application and project plans. In 

consultation with the Forest Service, the BLM may require modification to exploration or 

development proposals to protect such properties, or disapprove any activity that is likely to 

result in adverse effects that cannot be successfully avoided, minimized, or mitigated. 

Avoidance of impacts through project design will be given priority over data recovery as the 

preferred mitigation measure. Avoidance measures include moving project elements away 

from site locations or to areas of previous impacts, restricting travel to existing roads, and 

maintaining barriers and signs in areas of cultural sensitivity. Any data recovery will be 

preceded by approval of a detailed research design, Native American Consultation, and other 

requirements for Forest Service issuance of a permit under the Archaeological Resources 

Protection Act.

• If cultural resources are present at the site, or if areas with a high potential to contain cultural 

material have been identified, a cultural resources management plan (CRMP) will be 

developed. This plan will address mitigation activities to be taken for cultural resources found 

at the site. Avoidance of the area is always the preferred mitigation option. Other mitigation 

options include archaeological survey and excavation (as warranted) and monitoring. If an 

area exhibits a high potential, but no artifacts were observed during an archaeological survey, 

monitoring by a qualified archaeologist could be required during all excavation and 

earthmoving in the high potential area. A report will be prepared documenting these activities. 

The CRMP also will:

♦ Establish a monitoring program

♦ Identify measures to prevent potential looting/vandalism or erosion impacts

♦ Address the education of workers and the public to make them aware of the consequences 

of unauthorized collection of artifacts and destruction of property on public land 

• The operator will determine whether paleontological resources exist in a project area on the 

basis of the sedimentary context of the area, a records search for past paleontological finds in 

the area, and/or, depending on the extent of existing information, a paleontological survey.

• If paleontological resources are present at the site, or if areas with a high potential to contain 

paleontological material have been identified, a paleontological resources management plan 
Appendix C. Best Management Practices and Mitigation Measures

C-4 Santa Fe National Forest Geothermal Leasing EIS

will be developed. This plan will include a mitigation plan for avoidance, removal of fossils, 

or monitoring. If an area exhibits a high potential but no fossils were observed during survey, 

monitoring by a qualified paleontologist may be required during excavation and earthmoving 

in the sensitive area. The operator will submit a report to the agency documenting these 

activities. The paleontological resources management plan also will:

♦ Establish a monitoring program

♦ Identify measures to prevent potential looting/vandalism or erosion impacts

♦ Address the education of workers and the public to make them aware of the consequences 

of unauthorized collection of fossils on public land

C.1.3 Water Resources

The BMPs require suitable characterization of site hydrology commensurate with the potential for 

impacts to surface water and groundwater resources, to include physical and chemical 

characteristics of surface and groundwater systems, as needed, for the range of expected seasonal 

variation in precipitation and potential stormflow events likely to occur at the site for the duration 

of the minerals activities.

The operator will: 

• Evaluate the consumptive use of water in the operation and its effect on water-dependent 

ecosystems.

• Evaluate the potential for direct and indirect impacts to morphology, stability, and function of 

waterbodies, riparian areas, and wetland habitats.

• Develop a storm water management plan for the site to ensure compliance with applicable 

regulations and to prevent offsite migration of contaminated storm water or increased soil 

erosion.

• Gain a clear understanding of the local hydrogeology. Areas of groundwater discharge and 

recharge and their potential relationships with surface water bodies will be identified.

• Avoid creating hydrologic conduits between two aquifers during foundation excavation and 

other activities.

• Identify federal, state, and local permits or requirements needed to implement the project.

Examples include water quality standards, CWA 401 certification, CWA 402 permits 

(including stormwater permits), CWA 404 permits, and Coastal Zone Management Act 

requirements.

• Plan to limit surface disturbance to the extent practicable while still achieving project 

objectives.

• Provide adequate buffers and setbacks from waterbodies to avoid or minimize impacts to 

water quality and aquatic ecosystems.

• Designate specific aquatic management zones (AMZs) around water features in the project 

area.

• Design activities on or near unstable areas and sensitive soils to minimize management 

induced impacts.

• Use local direction and requirements for prevention and control of terrestrial and aquatic 

invasive species.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-5

• Use suitable tools to analyze the potential for cumulative watershed effects (CWE) to occur 

from the additive impacts of the proposed project and past, present, and reasonably 

foreseeable future activities on NFS and neighboring lands within the project watersheds.

• Consider the natural sensitivity or tolerance of the watershed based on geology, climate, and 

other relevant factors.

• Consider the existing condition of the watershed and water quality as a reflection of past land 

management activities and natural disturbances.

• Estimate the potential for adverse effects to soil, water quality, and riparian resources from 

current and reasonably foreseeable future activities on all lands within the watershed relative 

to existing watershed conditions.

• Use land management plan direction; federal, state, or local water quality standards; and other 

regulations to determine acceptable limits for CWE.

• Modify the proposed project or activity as necessary by changing project design, location, 

and timing to reduce the potential for CWE to occur.

• Consider including additional mitigation measures to reduce project effects. 

• Identify and implement opportunities for restoration activities to speed recovery of watershed 

condition before initiating additional anthropogenic disturbance in the watershed.

• Coordinate and cooperate with other federal, state, and private landowners in assessing and 

preventing CWE in multiple ownership watersheds.

• Integrate restoration and rehabilitation needs into the project plan.

• Consider water-quality improvement actions identified in a TMDL or other watershed 

restoration plan to restore impaired waterbodies within the project area.

• Identify project-specific monitoring needs.

• Document site-specific BMP prescriptions, design criteria, mitigation measures, and 

restoration, rehabilitation, and monitoring needs in the applicable NEPA documents, design 

plans, contracts, permits, authorizations, and operation and maintenance plans.

• Delineate all protected or excluded areas, including, for example, AMZs and waterbodies,

• Include 303(d) listed and TMDL waterbodies, and municipal supply watersheds, on the 

project map.

• Evaluate the condition of aquatic habitat, riparian habitat, and beneficial riparian zone 

functions and their estimated response to the proposed activity in determining the need for 

and width of the AMZ.

• Use stream class and type, channel condition, aspect, side slope steepness, precipitation and 

climate characteristics, soil erodibility, slope stability, groundwater features, and aquatic and 

riparian conditions and functions to determine appropriate AMZ widths to achieve desired 

conditions in the AMZ.

• Include riparian vegetation within the designated AMZ and extend the AMZ to include steep 

slopes, highly erodible soils, or other sensitive or unstable areas. 

• Establish wider AMZ areas for waters with high resource value and quality.

• Design and implement project activities within the AMZ to:

♦ Avoid or minimize unacceptable impacts to riparian vegetation, groundwater recharge 

areas, steep slopes, highly erodible soils, or unstable areas.

♦ Maintain or provide sufficient ground cover to encourage infiltration, avoid or minimize 

erosion, and filter pollutants.
Appendix C. Best Management Practices and Mitigation Measures

C-6 Santa Fe National Forest Geothermal Leasing EIS

♦ Avoid, minimize, or restore detrimental soil compaction.

♦ Retain trees necessary for shading and bank stabilization, and as a future source of large 

woody debris.

♦ Retain floodplain function.

♦ Restore existing disturbed areas that are eroding and contributing sediment to the 

waterbody.

• Mark the boundaries of the AMZ and sensitive areas—like riparian areas, wetlands, and 

unstable areas—on the ground before land-disturbing activities.

C.1.4 Vegetation and Fish and Wildlife

• The operator will conduct surveys for plant and animal species that are listed or proposed for 

listing as threatened or endangered and their habitats in areas proposed for development 

where these species could potentially occur, following accepted protocols and in consultation 

with the USFWS, as appropriate. Particular care should be taken to avoid disturbing listed 

species during surveys in any designated critical habitat. The operator will monitor activities 

and their effects on ESA-listed species throughout the duration of the project.

• The operator will identify important, sensitive, or unique habitat and biota in the project 

vicinity and site and should design the project to avoid (if possible), minimize, or mitigate 

potential impacts on these resources. The design and siting of the facilities will follow 

appropriate guidance and requirements from the Forest Service and other resource agencies, 

as available and applicable.

C.1.5 National Scenic and Historic Trails

• When any ROW application includes remnants of a National Historic Trail, is located within 

the viewshed of a National Historic Trail’s designated centerline, or includes or is within the 

viewshed of a trail eligible for listing on the NRHP, the operator will evaluate the potential 

visual impacts to the trail associated with the proposed project and identify appropriate 

mitigation measures for inclusion in the operation plan.

C.1.6 Air Quality and Climate

• The operator will coordinate with the New Mexico Environment Department Air Quality 

Bureau to develop and implement an air-quality monitoring plan.

C.2 Planning, Location, and Design

C.2.1 Bonding

• As outlined in the Forest Service Training Guide for Reclamation Bond Estimation and 

Administration for Minerals Plans of Operation, the Forest Service must consider the direct 

and indirect costs of stabilizing, rehabilitating, and reclaiming the area of mineral operations 

to the appropriate standards for water quality and watershed condition as determined from the 

land management plan, state and federal laws, regulations, plans, or permits when 

determining the reclamation bond amount. The bond amount determined by the Forest 

Service must include costs for:

♦ Operation and maintenance of facilities designed to divert, convey, store, or treat water. 

♦ Decontaminating, neutralizing, disposing, treating, or isolating hazardous materials at the 

site to minimize potential for contamination of soil, surface water, and groundwater.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-7

♦ Water treatment needs predicted during planning and discovered during operations to 

achieve applicable water-quality standards.

♦ Earthwork to reclaim roads, backfilling water features (diversions, ditches, and sediment 

ponds), and construction of diversion channels and drains, stream channels, and wetlands.

♦ Revegetation to stabilize the site and minimize soil erosion.

♦ Mitigation to restore natural function and value of streams, wetlands, and floodplains.

♦ Long-term operations, monitoring, and maintenance of mineral production-related 

facilities that must perform as designed to avoid or minimize contamination of surface or 

groundwater resources, including roads, diversion ditches, dams, and water treatment 

systems.

♦ Protection of the reclaimed area until long-term stability, erosion control, and revegetation has been established.

• The Forest Service coordinates with the BLM to ensure the reclamation bond required for 

operations will be sufficient to guarantee reclamation work on NFS lands to the appropriate 

standards for water quality and watershed condition as determined from the land management 

plan, state and federal laws, regulations, plans, or permits.

C.2.2 Traffic Planning

• The operator will consult with local planning authorities regarding increased traffic prior to 

the construction phase, including an assessment of the number of vehicles per day, their size, 

and type. Specific issues of concern (e.g., location of school bus routes and stops) will be 

identified and addressed in the traffic management plan.

C.2.3 Roads & Pads

• To plan for efficient use of the land, necessary infrastructure will be consolidated wherever 

possible.

• The operator will limit roads to the minimum practicable number, width, and total length 

consistent with the purpose of specific operations, local topography, geology, and climate to 

achieve land management plan desired conditions, goals, and objectives for access and waterquality management.

• The operator will use existing roads when practicable.

• The operator will plan road networks to have the minimum number of waterbody crossings as 

is practicable and necessary to achieve transportation system desired conditions, goals, and 

objectives.

• The operator will design the roads to maintain stable road prism, cut, and fill slopes.

• The operator will design cut and fill slope ratios to reduce soil loss from mass failures.

• The operator will use structural or nonstructural measures as necessary to stabilize cut and fill 

slopes.

• The operator will use brush mulches or filter fences when necessary to mitigate impacts of 

roads near water courses. 

• The operator will design the road surface drainage system to intercept, collect, and remove 

water from the road surface and surrounding slopes in a manner that minimizes concentrated 

flow in ditches, culverts, and over fill slopes and road surfaces.
Appendix C. Best Management Practices and Mitigation Measures

C-8 Santa Fe National Forest Geothermal Leasing EIS

• The operator will use structural or nonstructural measures suitable to the road materials, road 

gradient, and expected traffic levels. The operator will use an interval between drainage 

features that is suitable for the road gradient, surface material, and climate.

• The operator will use suitable measures to avoid or minimize erosion of ditches. 

• The operator will design and construct all new roads and drilling pads to a safe and 

appropriate standard, no higher than necessary to accommodate their intended use.

• Existing roads and pad sites will be used to the maximum extent feasible, but only if located 

in a safe and environmentally sound location. No new roads and pad sites will be constructed 

without agency authorization. If new roads and pad sites have been authorized, they will be 

designed and constructed by the operator to the appropriate agency standard, no higher than 

necessary to accommodate their intended function. Roads and pad sites will be routinely 

maintained by the operator to maintain public safety and to minimize impacts to the 

environment, such as erosion, sedimentation, fugitive dust, and loss of vegetation.

• An access road siting and management plan will be prepared incorporating existing agency 

standards regarding road design, construction, and maintenance, such as those described in 

the Forest Service handbook 7709.56 and the Surface Operating Standards for Oil and Gas 

Exploration and Development (i.e., the Gold Book, current edition).

• A traffic management plan will be prepared for the site access roads to ensure that no hazards 

would result from the increased truck traffic and that traffic flow would not be adversely 

impacted. This plan will incorporate measures such as informational signs, flaggers when 

equipment may result in blocked throughways, and traffic cones to identify any necessary 

changes in temporary lane configuration.

• Where possible, access roads will be located to follow natural contours and to minimize side 

hill cuts and fills. Excessive grades on roads, road embankments, ditches, and drainages shall 

be avoided, especially in areas with erodible soils.

• Roads will be designed so that changes to surface water runoff are minimized and new 

erosion is not initiated.

• Access roads will be located to minimize stream crossings. All structures crossing streams 

will be located and constructed so that they do not decrease channel stability or increase 

water velocity. The operator will obtain all applicable federal and state water crossing 

permits.

• Roads will be located away from drainage bottoms and will avoid wetlands, if practicable.

• The operator will minimize the period that disturbed areas are not vegetated by revegetating 

and/or mulching cuts and fill slopes. 

• Clearing of vegetation along rights-of-way, facilities, and special use sites will be limited to 

that which poses a hazard to the facility and operational efficiency.

C.2.4 Geotechnical Analysis

• The operator will perform a detailed geotechnical analysis prior to the construction of any 

structures, so they will be sited to avoid any hazards from subsidence or liquefaction (i.e., the 

changing of a saturated soil from a relatively stable solid state to a liquid during earthquakes 

or nearby blasting).
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-9

C.2.5 Well Pads

The operator will:

• Locate well sites on level locations that will accommodate the intended use to reduce the 

need for vertical cuts and steep fill slopes.

• Use suitable measures to stabilize fill slopes and to minimize potential of slope failures.

• Use suitable measures to provide surface drainage and to manage runoff from the work areas 

used for mud tanks, generators, mud storage, and fuel tanks in a manner that avoids or 

minimizes pollutant contamination of surface waters or groundwater.

• Use nontoxic, nonhazardous drilling fluids whenever practicable.

• Construct suitable impervious containment structures with sufficient volume and freeboard to 

avoid or minimize spills or leakages of oil, gas, salt water, toxic liquids, or waste materials 

from reaching surface waters or groundwater.

• Avoid mixing of geothermal fluids with surface water or groundwater where the chemical and 

thermal properties of the geothermal fluids would damage aquatic ecosystems and 

contaminate drinking water supplies.

• Minimize production of byproducts and wastes to the extent practicable.

• Plan space to properly handle, store, and contain byproducts and wastes.

• Recycle or properly dispose of wastes (e.g., used petroleum products, site garbage, septic 

effluent, decommissioned equipment, and used barrels or containers).

• Use applicable practices for sanitation systems and solid waste management to avoid 

contaminating surface water or groundwater from sanitation or solid waste facilities.

• Manage all chemicals, reagents, fuels, and other hazardous or toxic materials used for 

construction and operations to avoid or minimize contaminating surface water or 

groundwater.

• Require a transportation spill response plan, where applicable, that describes the petroleum 

products or other hazardous materials or chemicals that will be used in the operations, 

including the routes, amount, and frequency of shipments, and the containers and vehicles 

that are to be used. Describe in this plan the procedures, equipment, and personnel that would 

be used to respond to a spill.

C.2.6 Visual Mitigation

• The operator will incorporate visual design considerations into the planning and design of the 

project to minimize potential visual impacts of the proposal and to meet the visual resource 

management objectives of the area and the agency.

C.2.6.1 Visual Design Considerations

• Construct low-profile structures whenever possible to reduce structure visibility.

• Select and design materials and surface treatments to repeat or blend with landscape 

elements.

• Site projects outside of the viewsheds of publically accessible vantage points, or if this cannot 

be avoided, as far away as possible.

• Site projects to take advantage of both topography and vegetation as screening devices to 

restrict views of projects from visually sensitive areas.
Appendix C. Best Management Practices and Mitigation Measures

C-10 Santa Fe National Forest Geothermal Leasing EIS

• Site facilities away from and not adjacent to prominent landscape features (e.g., knobs and 

water features).

• Avoid placing facilities on ridgelines, summits, or other locations such that they will be 

silhouetted against the sky from important viewing locations.

• Collocate facilities to the extent possible to use existing and shared rights-of-way, existing 

and shared access and maintenance roads, and other infrastructure, so they do not bisect ridge 

tops or run down the center of valley bottoms.

• Site linear features (aboveground pipelines, rights-of-way, and roads) to follow natural land 

contours rather than straight lines (particularly up slopes) when possible. Fall-line cuts should 

be avoided.

• Site facilities, especially linear facilities, to take advantage of natural topographic breaks (i.e., 

pronounced changes in slope) to avoid siting facilities on steep side slopes. 

• Where available, site linear features—such as rights-of-ways and roads—to follow the edges 

of clearings (where they will be less conspicuous) rather than passing through the centers of 

clearings.

• Site facilities to take advantage of existing clearings to reduce vegetation clearing and ground 

disturbance, where possible.

• Site linear features (e.g., trails, roads, and rivers) to cross other linear features at right angles 

whenever possible to minimize viewing area and duration.

• Site and design structures and roads to minimize and balance cuts and fills and to preserve 

existing rocks, vegetation, and drainage patterns to the maximum extent possible.

• Use appropriately colored materials for structures or appropriate stains and coatings to blend 

with the project’s backdrop. Refer to the Standard Environmental Colors chart available from 

the BLM.

• Use non-reflective or low-reflectivity materials, coatings, or paints whenever possible.

• Paint grouped structures the same color to reduce visual complexity and color contrast.

• Design and install efficient facility lighting so that the minimum amount of lighting required 

for safety and security is provided but not exceeded and so that upward light scattering (light 

pollution) is minimized. This may include, for example, installing shrouds to minimize light 

from straying off-site, properly directing light to only illuminate necessary areas, and 

installing motion sensors to only illuminate areas when necessary.

• Site construction staging areas and laydown areas outside of the viewsheds of publically 

accessible vantage points and visually sensitive areas, where possible, including siting in 

swales, around bends, and behind ridges and vegetative screens.

• Discuss visual impact mitigation objectives and activities with equipment operators prior to 

commencement of construction activities.

• Mulch or scatter slash from vegetation removal and spread it to cover fresh soil disturbances 

or, if not possible, bury or compost slash.

• If slash piles are necessary, stage them out of sight of sensitive viewing areas.

• Avoid installing gravel and pavement where possible to reduce color and texture contrasts 

with existing landscape.

• Use excess fill-to–fill, uphill-side swales resulting from road construction in order to reduce 

unnatural-appearing slope interruption and to reduce fill piles.

• Avoid downslope wasting of excess fill material.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-11

• Round road-cut slopes, vary cut and fill pitch to reduce contrasts in form and line, and vary 

slope to preserve specimen trees and nonhazardous rock outcroppings.

• Leave planting pockets on slopes where feasible.

• Combine methods of reestablishing native vegetation through seeding, planting of nursery 

stock, transplanting of local vegetation within the proposed disturbance areas, and staging of 

construction-enabling direct transplanting.

• Revegetate with native vegetation establishing a composition consistent with the form, line, 

color, and texture of the surrounding undisturbed landscape.

• Provide benches in rock cuts to accent natural strata.

• Use split-face rock blasting to minimize unnatural form and texture resulting from blasting.

• Segregate topsoil from cut and fill activities and spread it on freshly disturbed areas to reduce 

color contrast and to aid rapid revegetation.

• Bury utility cables in or adjacent to the road where feasible. 

• Minimize signage and paint or coat reverse sides of signs and mounts to reduce color contrast 

with existing landscape.

• Prohibit trash burning; store trash in containers to be hauled off-site for disposal.

• Undertake interim restoration during the operating life of the project as soon as possible after 

disturbances. During road maintenance activities, avoid blading existing forbs and grasses in 

ditches and along roads.

• Randomly scarify cut slopes to reduce texture contrast with existing landscape and to aid in 

revegetation.

• Cover disturbed areas with stockpiled topsoil or mulch, and revegetate with a mix of native 

species selected for visual compatibility with existing vegetation.

• Restore rocks, brush, and natural debris whenever possible to approximate preexisting visual 

conditions.

C.2.7 Air Quality and Climate

• The operator will prepare and submit to the agency an Equipment Emissions Mitigation Plan 

for managing diesel exhaust. The Equipment Emissions Mitigation Plan will identify actions 

to reduce diesel particulate, carbon monoxide, hydrocarbons, and nitrogen oxides associated 

with construction and drilling activities. The Equipment Emissions Mitigation Plan will 

require that all drilling/construction-related engines are maintained and operated as follows:

♦ They are tuned to the engine manufacturer’s specification in accordance with an 

appropriate time frame.

♦ They do not idle for more than 5 minutes (unless, in the case of certain drilling engines, it 

is necessary for the operating scope).

♦ They are not tampered with in order to increase engine horsepower.

♦ Particulate traps, oxidation catalysts, and other suitable control devices are included on 

all drilling/construction equipment used at the project site.

♦ They use diesel fuel having a sulfur content of 15 parts per million or less, or other 

suitable alternative diesel fuel, unless such fuel cannot be reasonably procured in the 

market area.

♦ They include control devices to reduce air emissions. The determination of which 

equipment is suitable for control devices should be made by an independent Licensed 

Mechanical Engineer. Equipment suitable for control devices may include drilling 
Appendix C. Best Management Practices and Mitigation Measures

C-12 Santa Fe National Forest Geothermal Leasing EIS

equipment, work over and service rigs, mud pumps, generators, compressors, graders, 

bulldozers, and dump trucks.

C.2.8 Health and Safety

• The operator will use applicable practices for sanitation systems and solid waste management 

to avoid contaminating surface water or groundwater from sanitation or solid waste facilities.

• The operator will develop a hazardous materials management plan addressing storage, use, 

transportation, and disposal of each hazardous material anticipated to be used at the site. The 

plan will identify all hazardous materials that would be used, stored, or transported at the site. 

It will establish inspection procedures, storage requirements, storage quantity limits, 

inventory control, nonhazardous product substitutes, and disposition of excess materials. The 

plan will also identify requirements for notices to federal and local emergency response 

authorities and include emergency response plans.

• The operator will develop a waste management plan identifying the waste streams that are 

expected to be generated at the site and addressing hazardous waste determination 

procedures, waste storage locations, waste-specific management and disposal requirements, 

inspection procedures, and waste minimization procedures. This plan will address all solid 

and liquid wastes that may be generated at the site.

• The operator will develop a spill prevention and response plan identifying where hazardous 

materials and wastes are stored on-site, spill prevention measures to be implemented, training 

requirements, appropriate spill response actions for each material or waste, the locations of 

spill response kits on-site, a procedure for ensuring that the spill response kits are adequately 

stocked at all times, and procedures for making timely notifications to authorities.

• The operator will develop a transportation spill response plan that describes the petroleum 

products or other hazardous materials or chemicals that will be used in the operations, 

including the routes, amount and frequency of shipments, and containers and vehicles used.

This plan will describe the procedures, equipment, and personnel that would be used to 

respond to a spill.

• A safety assessment will be conducted to describe potential safety issues and the means that 

would be taken to mitigate them, including issues such as site access, construction, safe work 

practices, security, heavy equipment transportation, traffic management, emergency 

procedures, and fire control.

• A health and safety program will be developed to protect both workers and the general public 

during construction and operation of geothermal projects. The program will:

♦ Identify all applicable federal and state occupational safety standards 

♦ Establish safe work practices for each task (e.g., requirements for personal protective 

equipment and safety harnesses)

♦ Include Occupational Safety and Health Administration standard practices for safe use of 

explosives and blasting agents, and measures for reducing occupational electric and 

magnetic fields exposures 

♦ Establish fire safety evacuation procedures 

♦ Define safety performance standards (e.g., electrical system standards and lightning 

protection standards) 

♦ Include a training program to identify hazard training requirements for workers for each 

task and establish procedures for providing required training to all workers. 
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-13

Documentation of training and a mechanism for reporting serious accidents to 

appropriate agencies will be established.

♦ Establish a safety zone or setback for generators from residences and occupied buildings, 

roads, ROWs, and other public access areas that is sufficient to prevent accidents 

resulting from the operation of generators 

♦ Identify requirements for temporary fencing around staging areas, storage yards, and 

excavations during construction or rehabilitation activities. It will also identify measures 

to be taken during the operation phase to limit public access to hazardous facilities (e.g., 

permanent fencing would be installed only around electrical substations, and facility 

access doors would be locked).

• The operator will consult with local planning authorities regarding increased traffic during the 

construction phase, including an assessment of the number of vehicles per day, their size, and 

type. Specific issues of concern (e.g., location of school bus routes and stops) will be 

identified and addressed in the traffic management plan.

• The operator will develop a fire management strategy to implement measures to minimize the 

potential for a human-caused fire.

C.2.9 Livestock Grazing

• The operator will coordinate with the Forest and livestock operators to minimize impacts to 

livestock operations.

C.2.10 Noxious Weeds and Pesticides

• The operator will develop a plan for control of noxious weeds and invasive species, which 

could occur as a result of new surface disturbance activities at the site. The most recent 

recommendations at the state and local level should be incorporated into any operating plan 

for the geothermal exploration and development. The plan will address monitoring, education 

of personnel on weed identification, the manner in which weeds spread, and methods for 

treating infestations. The use of certified weed-free mulching will be required. If trucks and 

construction equipment are arriving from locations with known invasive vegetation problems, 

a controlled inspection and cleaning area will be established to visually inspect construction 

equipment arriving at the project area and to remove and collect seeds that may be adhering 

to tires and other equipment surfaces.

• If pesticides are used on the site, an integrated pest management plan will be developed to 

ensure that applications would be conducted within the framework of all federal, state, and 

local laws and regulations and entail only the use of EPA-registered pesticides.

C.2.11 Vegetation and Fish and Wildlife

• The operator shall prepare a habitat restoration plan to avoid (if possible), minimize, or 

mitigate negative impacts on vulnerable wildlife while maintaining or enhancing habitat 

values for other species. The plan will identify revegetation, soil stabilization, and erosion 

reduction measures that will be implemented to ensure that all temporary use areas are 

restored. The plan will require that restoration occur as soon as possible after completion of 

activities to reduce the amount of habitat converted at any one time and to speed up the 

recovery to natural habitats.
Appendix C. Best Management Practices and Mitigation Measures

C-14 Santa Fe National Forest Geothermal Leasing EIS

C.2.12 Water Rights and Usage

The operator will:

• Obtain surface water (e.g., instream flow rights) and groundwater under appropriate federal 

and state legal and regulatory authorities to avoid, minimize, or mitigate adverse effects to 

stream processes, aquatic and riparian habitats and communities, groundwater-dependent 

ecosystems, and recreation and aesthetic values.

• Locate monitoring wells according to a monitoring plan to minimize the number of wells 

needed to achieve monitoring objectives.

• Construct and complete wells consistent with applicable federal and state regulations.

• Use licensed well drilling contractors.

• Use suitable measures to avoid or minimize well contamination, inter-aquifer exchange of 

water, floodwaters from contaminating the aquifer, and infiltration of surface water.

• Operate wells in such a manner as to avoid excessive withdrawals, maintain suitable 

groundwater levels, and minimize effects to groundwater-dependent ecosystems.

• Permanently seal abandoned wells consistent with applicable federal, state, and local 

regulations and requirements.

• Locate the spring box to allow water to flow by gravity from the spring to the spring box to 

eliminate disturbance from pumps and auxiliary equipment.

• Design the collection system to avoid, minimize, or mitigate adverse effects to the spring 

development and downstream waters from excessive water withdrawal, freezing, flooding, 

sedimentation, contamination, vehicular traffic, and livestock as needed.

• Collect no more water than is sufficient to meet the intended purpose of the spring 

development.

• Ensure that enough water remains in the spring to support the source groundwater-dependent 

ecosystem and downstream aquatic ecosystems.

• Trap and remove sediment that does enter the system.

• Intercept the spring flow below the ground surface upslope of where the water surfaces.

C.3 Construction

C.3.1 General

The operator will:

• Make adjustments in the plans, authorizations, and bonds if conditions develop that are 

outside the design criteria and conduct adequate notification, emergency stabilization, or 

other activities to avoid effects before proceeding with additional operations.

• Establish and maintain construction area limits to the minimum area necessary for completing 

the project and confine disturbance to within this area.

• Develop and implement an erosion control and sediment plan that covers all disturbed areas, 

including borrow, stockpile, fueling, and staging areas used during construction activities.

• Limit operation of equipment when ground conditions could result in excessive rutting, soil 

puddling, or runoff of sediments directly into waterbodies.

• Prepare a certified Spill Prevention Control and Countermeasure Plan for each facility as 

required by 40 CFR, Part 112.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-15

• Install or construct the containment features or countermeasures called for in the Spill 

Prevention Control and Countermeasure Plan to ensure that spilled hazardous materials are 

contained and do not reach groundwater or surface water.

• Ensure that cleanup of spills and leaking tanks is completed in compliance with federal, state, 

and local regulations and requirements.

• Ensure that hazardous spill kits are adequately stocked with necessary supplies and are 

maintained in accessible locations.

• Stockpile and protect topsoil for reuse in site revegetation.

• Minimize bank and riparian area excavation during construction to the extent practicable.

• Keep excavated materials out of the waterbody.

• Use only clean, suitable materials that are free of toxins and invasive species for fill.

• Properly compact fills to avoid or minimize erosion.

C.3.2 Traffic Management

• Traffic will be restricted to the roads developed for the project. Use of other unimproved 

roads will be restricted to emergency situations.

• Signs will be placed along roads to identify speed limits, travel restrictions, and other 

standard traffic control information. Signs directing vehicles to alternative park access and 

parking will be posted in the event construction temporarily obstructs recreational parking 

areas near trailheads. Whenever active work is being performed, the area will be posted with 

“construction ahead” signs on any adjacent access roads or trails that might be affected.

• Project personnel and contractors will be instructed and required to adhere to speed limits 

commensurate with road types, traffic volumes, vehicle types, and site-specific conditions; to 

ensure safe and efficient traffic flow; and to reduce wildlife collisions and disturbance and 

fugitive dust.

• When practical, construction activities will be avoided during high recreational use periods.

C.3.3 Roads & Pads

• The operator will plan and construct, to the extent practicable, exploration roads to be 

recontoured when operations are complete.

• The operator will limit the extent of open exploratory areas at one time and restore one site 

before moving on to the next one, to the extent practicable.

• The operator will obtain agency authorization prior to borrowing soil or rock material from 

agency lands.

• Road use will be restricted during the wet season if road surfacing is not adequate to prevent 

soil displacement, rutting, and resultant stream sedimentation.

• The operator will implement suitable measures to close and physically block the road 

entrance so that unauthorized motorized vehicles cannot access the road.

• Access roads and on-site roads will be surfaced with aggregate materials where necessary to 

provide a stable road surface, support anticipated traffic, reduce fugitive dust, and prevent 

erosion.

• Dust abatement techniques will be used before and during surface clearing, excavation, or 

blasting activities. Dust abatement techniques will be used on unpaved, unvegetated surfaces 

to minimize fugitive dust. Speed limits (e.g., 25 miles per hour [40 kilometers per hour]) will 
Appendix C. Best Management Practices and Mitigation Measures

C-16 Santa Fe National Forest Geothermal Leasing EIS

be posted and enforced to reduce fugitive dust. Construction materials and stockpiled soils 

will be covered if they are a source of fugitive dust.

• Culvert outlets will be rip-rapped to dissipate water energy at the outlet and to reduce erosion. 

Catch basins, roadway ditches, and culverts will be cleaned and maintained regularly.

• The operator will report all label violations that occur during the application of dust 

suppressants or other surface stabilizers to the appropriate enforcement agency.

• The operator will respond to and report spills and other accidents during the application of 

dust suppressants or other surface stabilizers.

• The operator will design and locate stream crossings to minimize disturbance to the 

waterbody.

• The operator will locate stream crossings where the channel is narrow, straight, and uniform, 

and has stable soils and relatively flat terrain to the extent practicable.

• The operator will select a site where erosion potential is low.

• The operator will orient the stream crossing perpendicular to the channel to the extent 

practicable.

• The operator will keep approaches to stream crossings to as gentle a slope as practicable.

C.3.4 Well Pads

The operator will:

• Locate reserve pits in stable areas on the drill pad to the extent practicable.

• Locate pits away from natural watercourses, riparian areas, wetlands, floodplains, and areas 

of shallow groundwater wherever practicable.

• Use suitable measures to ensure full containment of drilling fluids where the reserve pit must 

be placed in a sensitive location or in porous material.

• Design the reserve pit to contain all anticipated drilling muds, cuttings, fracture fluids, and 

precipitation while maintaining a suitable amount of freeboard to avoid or minimize 

overtopping.

• Use suitable measures to avoid or minimize seepage from the reserve pit contaminating 

groundwater.

• Remove any visible or measurable layer of oil from the surface of the reserve pit after 

cessation of drilling and completion of operations, and continue to keep the pit free of oil.

• Use suitable measures to avoid or minimize surface waters and groundwater from entering 

open pits.

C.3.5 Pipelines

• Pipelines constructed aboveground due to thermal gradient-induced expansion and 

contraction will rest on cradles above ground level, allowing small animals to pass 

underneath. Projects should be analyzed to ensure adequate passage for all wildlife species. 

The pipeline will be raised higher to allow wildlife passage where needed. Because pipeline 

corridors through certain habitat types can alter local predator/prey dynamics by providing 

predators with lines of sight and travel corridors, large projects should be analyzed to ensure 

there will be no significant changes to predator/prey balance.

• The operator will collocate pipelines and transmission lines with roads or their rights-of-way 

where practicable.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-17

• The operator will limit corridor disturbance, particularly in or near AMZs, surface waters, 

shallow groundwater, unstable areas, hydric soils, or wetlands.

• The operator will aggressively address unauthorized uses of the corridor, such as motorized 

vehicle use, that are exposing soils, increasing erosion, or damaging the facilities.

C.3.6 Utilities

• Underground utilities will be installed to minimize the amount of open trenches at any given 

time, keeping trenching and backfilling crews close together. Avoid leaving trenches open 

overnight. Where trenches cannot be backfilled immediately, escape ramps should be 

constructed at least every 100 feet.

C.3.7 Facilities

• The BLM will request a copy of operator’s Clean Water Act (CWA) 401 Certification from 

designated federal, state, or local entities before approving a plan of operations that may 

result in any discharge into waters of the United States.

• The operator will consider the following design criteria in facility planning:

♦ Locate the facility away from the immediate vicinity of surface waters, AMZs, wetlands, 

sandy soils, shallow water tables, groundwater recharge areas, floodplains, and other 

sensitive areas to the extent practicable.

♦ Avoid unstable slopes and soils.

♦ Minimize the disturbance footprint.

• The operator will use and maintain proper erosion and sediment control practices during and 

immediately after construction.

• The operator will incorporate suitable stormwater controls in the project design.

• The operator will incorporate requirements from applicable federal, state, and local permits 

into facility construction and operation plans.

• The operator will develop a contingency plan for implementing appropriate pre-storm or 

winterization BMPs before the grading permit expires.

• The operator will conform to all applicable federal, state, and local regulations and permits 

governing water supply, sanitation, and septic systems.

• The operator will determine instream flow needs to minimize damage to scenic and aesthetic 

values; native plant, fish, and wildlife habitat; and to otherwise protect the environment 

where the operation of the facility would modify existing streamflow.

• The operator will install and seasonally monitor groundwater quality monitoring wells if a 

risk of groundwater pollution exists.

• The operator will establish a suitable inspection schedule to ensure that water diversion 

structures, conveyances, and storage facilities are performing as designed and appropriately 

maintained.

• The operator will maintain erosion and stormwater controls as necessary to ensure proper and 

effective functioning.

• The operator will prepare for unexpected failures of erosion control measures.

• The operator will implement corrective actions without delay when failures are discovered to 

prevent pollutant discharge to nearby waterbodies.

• The operator will routinely inspect construction sites to verify that erosion and stormwater 

controls are implemented and functioning as designed and are appropriately maintained.
Appendix C. Best Management Practices and Mitigation Measures

C-18 Santa Fe National Forest Geothermal Leasing EIS

• The operator will use suitable measures in compliance with local direction to prevent and 

control invasive species.

C.4 Specific Resources

C.4.1 Cultural and Paleontological Resources

• Unexpected discovery of cultural or paleontological resources during construction will be 

brought to the attention of the responsible BLM Authorized Officer immediately. Work will 

be halted in the vicinity of the find to avoid further disturbance to the resources while they are 

being evaluated and appropriate mitigation measures are being developed.

C.4.2 Noise

• The operator will take measurements to assess the existing background noise levels at a given 

site and compare them with the anticipated noise levels associated with the proposed project.

• Within 2 miles of existing, occupied residences, geothermal well drilling or major facility 

construction operations will be restricted to non-sleeping hours (7:00 am to 10:00 pm).

• All equipment will have sound-control devices no less effective than those provided on the 

original equipment. All construction equipment used will be adequately muffled and 

maintained.

• All stationary construction equipment (e.g., compressors and generators) will be located as 

far as practicable from nearby residences.

• If blasting or other noisy activities are required during the construction period, nearby 

residents will be notified by the operator at least 1 hour in advance.

• Explosives will be used only within specified times and at specified distances from sensitive 

wildlife or streams and lakes, as established by the federal and state agencies.

C.4.3 Noxious Weeds and Pesticides

• The use of certified, weed-free mulch will be required when stabilizing areas of disturbed 

soil.

• If trucks and construction equipment are arriving from locations with known invasive 

vegetation problems, a controlled inspection and cleaning area will be established to visually 

inspect construction equipment arriving at the project area and to remove and collect seeds 

that may be adhering to tires and other equipment surfaces.

• Fill materials and road surfacing materials that originate from areas with known invasive 

vegetation problems will not be used.

• Revegetation, habitat restoration, and weed control activities will be initiated as soon as 

possible after construction activities are completed.

• Use of pesticides must be approved by the agency. Pesticide use will be limited to agencyapproved pesticides and will only be applied in accordance with label and application permit 

directions and stipulations for terrestrial and aquatic applications.

C.4.4 Waste Management

• The operator will plan for suitable equipment refueling and servicing sites during project 

design.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-19

• All refueling will occur in a designated fueling area that includes a temporary berm to limit 

the spread of any spill. 

• Drip pans will be used during refueling to contain accidental releases.

• Drip pans will be used under fuel pump and valve mechanisms of any bulk fueling vehicles 

parked at the construction site.

• Any containers used to collect liquids will be enclosed or screened to prevent access to 

contaminants by wildlife, livestock, and migratory birds.

• Spills will be immediately addressed per the spill management plan, and soil cleanup and 

removal will be initiated as soon as feasible.

• The operator will use nontoxic, nonhazardous drilling fluids whenever practicable.

• The operator will construct suitable impervious containment structures with sufficient volume 

and freeboard to avoid or minimize spills or leakages of oil, gas, salt water, toxic liquids, or 

waste materials from reaching surface waters or groundwater.

C.4.5 Wildlife

• The operator will ensure that employees, contractors, and site visitors avoid harassment and 

disturbance of wildlife, especially during reproductive (i.e., courtship and nesting) seasons. In 

addition, pets will be controlled or excluded to avoid harassment and disturbance of wildlife.

• Ponds, tanks, and impoundments (including but not limited to drill pits) containing liquids 

can present hazards to wildlife. Any liquids contaminated by substances which may be 

harmful due to toxicity, or fouling of the fur or feathers (detergents and oils), should be 

excluded from wildlife access by fencing, netting, or covering at all times when not in active 

use. Liquids at excessive temperature should likewise be excluded. If exclusion is not 

feasible, such as a large pond, a hazing program based on radar or visual detection, in 

conjunction with formal monitoring, should be implemented. Clean water impoundments can 

also present a trapping hazard if they are steep-sided or lined with smooth material. All pits, 

ponds, and tanks should have escape ramps functional at any reasonably anticipated water 

level, down to almost empty. Escape ramps can take various forms depending on the 

configuration of the impoundment. Earthen pits may be constructed with one side sloped 3:1 

or greater lined ponds can use textured material; straight-sided tanks can be fitted with 

expanded metal escape ladders.

C.4.6 Air Quality

• Use of any dust suppressant must be specifically authorized by the Forest Service. The 

operator must consider the following when requesting the authorization to use dust 

suppressants:

♦ Select chemical products suitable for use on the target species or that meet project 

objectives.

♦ Use chemicals that are registered for the intended uses.

♦ Consult the Materials Safety Data Sheet and product label for information on use, 

hazards, and safe handling procedures for chemical products under consideration for use.

♦ Consider chemical solubility, absorption, breakdown rate properties, and site factors 

when determining which chemical products to use.

♦ Use chemicals with properties such that soil residual activity will persist only as long as 

needed to achieve treatment objectives.
Appendix C. Best Management Practices and Mitigation Measures

C-20 Santa Fe National Forest Geothermal Leasing EIS

♦ Consider soil type, chemical mobility, distance to surface water, and depth to 

groundwater to avoid or minimize surface water and groundwater contamination.

♦ Use a suitable pressure, nozzle size, and nozzle type combination to minimize off-target 

drift or droplet splatter.

♦ Specify management direction and appropriate site-specific response measures in project 

plans and safety plans (FSH 2109.14, chapter 60).

♦ Ensure that planned chemical use projects conform to all applicable local, state, federal, 

and agency laws, regulations, and policies.

♦ Obtain necessary permits, including CWA 402 permit coverage.

♦ Develop spill contingency plans.

♦ Obtain or provide training and licensing as required by the label and state regulations.

♦ Incorporate constraints identified on the label and other legal requirements of application 

into project plans and contracts.

♦ Be aware that states may have more restrictive requirements than the label instructions.

C.5 Operations/Utilization

C.5.1 General

• “Good housekeeping” procedures will be developed by the operator to ensure that during all 

phases of exploration and operation the site will be kept clean of noxious weeds, debris, litter, 

garbage, fugitive trash or waste, and graffiti. Scrap heaps and dumps are prohibited. Storage 

yards are to be minimized to that which is absolutely necessary.

• The operator will make adjustments in the plans, authorizations, and bonds if conditions 

develop that are outside the design criteria and conduct adequate notification, emergency 

stabilization, or other activities to avoid effects before proceeding with additional operations.

• The operator will inspect drainage structures and road surfaces after major storm events and 

perform any necessary maintenance.

C.6 Roads

The operator will:

• Maintain the road surface drainage system to intercept, collect, and remove water from the 

road surface and surrounding slopes in a manner that reduces concentrated flow in ditches, 

culverts, and over fill slopes and road surfaces.

• Conduct frequent inspections to ensure road drainage is not adversely affecting soil or water 

resources.

• Clean ditches and catch basins only as needed to keep them functioning.

• Move snow in a manner that will avoid or minimize disturbance of or damage to road 

surfaces and drainage structures.

• Mark drainage structures to avoid damage during plowing.

• Discontinue road use and snow removal when use would likely damage the roadway surface 

or road drainage features.

• Modify snow removal procedures as necessary to meet water quality concerns.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-21

• Replace lost road surface materials with similar quality material and repair structures 

damaged in snow removal operations as soon as practicable.

C.6.1 Chemical Transport and Storage

The operator will:

• Transport and handle chemical containers in a manner that minimizes the potential for leaks 

and spills.

• Inspect containers for leaks or loose caps or plugs before loading.

• Secure containers properly to avoid or minimize shifting in transport.

• Check containers periodically en route. 

• Ensure arrangements for proper storage are in place before transporting chemicals.

• Manage and store chemicals in accordance with all applicable federal, state, or local 

regulations, including label directions.

• Store chemicals in their original containers with labels intact.

• Locate chemical storage facilities at sites that minimize the possibility of impacts to surface 

water or groundwater in case accidents or fires occur.

• At a minimum, ensure that containment of a complete spill from the largest container being 

stored is possible with the spill-kit materials at the storage site.

• Check containers before storage and periodically during storage to ensure that they are 

properly sealed and not leaking.

C.6.2 Produced Water

The operator will:

• Discharge or otherwise dispose of produced water in compliance with the CWA and Safe 

Drinking Water Act, with appropriate approvals from the State and EPA.

• Reinject produced water of suitable quality into acceptable underground reservoirs when 

authorized and appropriate.

• Avoid, minimize, or mitigate surface-discharge effects including headcuts, stream crossing 

washouts, impoundments, channel stability, and flooding.

C.7 Reclamation

• A reclamation plan meeting the following objectives and standards will be submitted prior to 

site development:

Reclamation Objectives

♦ The objective of interim reclamation is to restore vegetative cover and a portion of the 

landform sufficient to maintain healthy, biologically active topsoil; control erosion; and 

minimize habitat, visual, and forage loss during the life of the well or facilities. 

♦ The long-term objective of final reclamation is to return the land to a condition 

approximating that which existed prior to disturbance. This includes restoration of the 

landform and natural vegetative community, hydrologic systems, visual resources, and 

wildlife habitats. To ensure that the long-term objective will be reached through human 

and natural processes, actions will be taken to ensure standards are met for site stability, 

visual quality, hydrological functioning, and vegetative productivity.
Appendix C. Best Management Practices and Mitigation Measures

C-22 Santa Fe National Forest Geothermal Leasing EIS

Reclamation Performance Standards

Interim Reclamation – Includes disturbed areas that may be redisturbed during operations and 

will be redisturbed at final reclamation to achieve restoration of the original landform and a 

natural vegetative community. It will be judged successful when the authorized officer 

determines that disturbed areas not needed for active, long-term production operations or 

vehicle travel have been recontoured, protected from erosion, and revegetated with a selfsustaining, vigorous, diverse, native (or as otherwise approved) plant community sufficient to 

minimize visual impacts, provide forage, stabilize soils, and impede the invasion of noxious, 

invasive, and non-native weeds.

Final Reclamation – Includes disturbed areas where the original landform and a natural 

vegetative community have been restored. It will be judged successful when the authorized 

officer determines that the original landform has been restored for all disturbed areas 

including well pads, production facilities, roads, pipelines, and utility corridors.

♦ A self-sustaining, vigorous, diverse, native (or otherwise approved) plant community is 

established on the site, with a density sufficient to control erosion and invasion by nonnative plants and to reestablish wildlife habitat or forage production. At a minimum, the 

established plant community will consist of species included in the seed mix and/or 

desirable species occurring in the surrounding natural vegetation.

♦ No single species will account for more than [to be determined by site-specific survey]

percent of the total vegetative composition unless it is evident at higher levels in the 

adjacent landscape. 

♦ Permanent vegetative cover will be determined successful when the basal cover of 

desirable perennial species is at least [to be determined by site-specific survey] percent of 

the basal cover on adjacent or nearby undisturbed areas where vegetation is in a healthy 

condition. 

♦ Plants must be resilient as evidenced by well-developed root systems and flowers. Shrubs

will be well established and in a “young” age class at a minimum; therefore, they will not 

be comprised mainly of seedlings that may not survive until the following year.

♦ Erosion features are equal to or less than the surrounding area, and erosion control is 

sufficient so that water naturally infiltrates into the soil and gullying, headcutting, 

slumping, and deep or excessive rills (greater than 3 inches) are not observed.

♦ The site is free of state- or county-listed noxious weeds, oil field debris and equipment, 

and contaminated soil. Invasive and nonnative weeds are controlled.

C.7.1 Reclamation Actions

• During initial well pad, production facility, road, pipeline, and utility corridor construction 

and prior to completion of the final well on the well pad, pre-interim reclamation stormwater 

management actions will be taken to ensure disturbed areas are quickly stabilized to control 

surface water flow and to protect both the disturbed and adjacent areas from erosion and 

siltation. This may involve construction and maintenance of temporary silt ponds, silt fences, 

berms, ditches, and mulching.

• When the last well on the pad has been completed, some portions of the well location will 

undergo interim reclamation and some portions of the well pad will usually undergo final 

reclamation. Most well locations will have limited areas of bare ground, such as a small area 

around production facilities or the surface of a rocked road. Other areas will have interim 

reclamation where workover rigs and tanks may need a level area to set up in the future. 
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-23

Some areas will undergo final reclamation where portions of the well pad will no longer be 

needed for production operations and can be recontoured to restore the original landform.

The following minimum reclamation actions will be taken to ensure that the reclamation 

objectives and standards are met. It may be necessary to take additional reclamation actions 

beyond the minimum in order to achieve the Reclamation Standards.

C.7.2 Reclamation – General

• The agency will be notified 24 hours prior to commencement of any reclamation operations.

• The operator will sample and test the site to identify hazardous materials and associated areas 

that may be contaminated by petroleum products, reactive materials, or other chemicals.

• The operator will use suitable measures to isolate, neutralize, remove, or treat hazardous or 

contaminated materials—including chemicals, reactive materials, acidic wastes, fuels, pit 

fluids, sediment, and human waste—consistent with applicable federal, state, and local 

regulations to achieve applicable standards.

• The operator will properly abandon, plug, and cap all drill holes, cores, and wells per 

applicable state or federal requirements.

• The operator will reconstruct, maintain, or decommission roads, trails, and staging areas 

consistent with the land management plan’s desired conditions, goals, and objectives for the 

area.

• The operator will use suitable measures to limit human, vehicle, and livestock access to the 

site as needed to allow for recovery of vegetation.

C.7.2.1 Housekeeping

• Immediately upon well completion, the well location and surrounding areas(s) will be cleared 

of, and maintained free of, all debris, materials, trash, and equipment not required for 

production.

• No hazardous substances, trash, or litter will be buried or placed in pits. Upon well 

completion, any hydrocarbons in the pit will be remediated or removed.

C.7.2.2 Vegetation Clearing

• Vegetation removal and the degree of surface disturbance will be minimized wherever 

possible.

• During vegetation-clearing activities, trees and woody vegetation removed from the well pad 

and access road will be moved aside prior to any soil-disturbing activities. Care will be taken 

to avoid mixing soil with the trees and woody vegetation. 

• Trees left for wood gathering will be cut and delimbed. Trunks 6 inches or more in diameter 

will be removed and placed either by the uphill side of the access road, moved to the end of 

the road, or moved to a road junction for easy access for wood gatherers and to reduce 

vehicle traffic on the well pad. Trees with a trunk diameter less than 6 inches and woody 

vegetation will be used to trap sediment or slow runoff, or they will be scattered on reclaimed 

areas to stabilize slopes, control erosion, and improve visual resources.

C.7.2.3 Topsoil Management

• Operations will disturb the minimum amount of surface area necessary to conduct safe and 

efficient operations. When possible, equipment will be stored and operated on top of 

vegetated ground to minimize surface disturbance.
Appendix C. Best Management Practices and Mitigation Measures

C-24 Santa Fe National Forest Geothermal Leasing EIS

• In areas to be heavily disturbed, the top (to be determined by a site-specific survey) inches of 

soil material will be stripped and stockpiled around the perimeter of the well location to 

control run-on and run-off, and to make redistribution of topsoil more efficient during interim 

reclamation. Stockpiled topsoil may include vegetative material. Topsoil will be clearly 

segregated and stored separately from subsoils.

• Earthwork for interim and final reclamation will be completed within 6 months of well 

completion or plugging unless a delay is approved in writing by the BLM Authorized Officer.

• Salvaging and spreading topsoil will not be performed when the ground or topsoil is frozen or 

too wet to adequately support construction equipment. If such equipment creates ruts in 

excess of 4 inches deep, the soil will be deemed too wet.

• No major depressions will be left that would trap water and cause ponding.

C.7.2.4 Seeding

• Initial seedbed preparation will consist of recontouring to the appropriate interim or final 

reclamation standard. All compacted areas to be seeded will be ripped to a minimum depth of 

18 inches with a minimum furrow spacing of 2 feet, followed by recontouring the surface and 

then evenly spreading the stockpiled topsoil. Prior to seeding, the seedbed will be scarified 

and left with a rough surface.

• If broadcast seeding is to be used and is delayed, final seedbed preparation will consist of 

contour cultivating to a depth of 4 to 6 inches within 24 hours prior to seeding, dozer 

tracking, or other imprinting in order to loosen up the soil and create seed germination microsites.

• Seed application will be conducted no more than 24 hours following completion of final 

seedbed preparation. 

• A certified weed-free seed mix designed by the Forest Service and BLM to meet reclamation 

standards will be used on all disturbed surfaces, including pipelines and road cut and fill 

slopes.

• The application rate (to be determined by site-specific survey) is based on drill-seeded to a 

depth of 0.25 to 0.5 inches, which is the method that will be used where feasible.

• Shrub species will be seeded during the winter on the ground surface or preferably on top of 

snow.

• In areas that will not be drill-seeded, the seed mix will be broadcast-seeded at twice the 

application rate shown in the table and covered no more than 0.25 inch deep with a harrow, 

drag bar, or roller or will be broadcast-seeded into imprints, such as fresh dozer cleat marks.

• Seeding will be done in (season to be determined by site-specific survey).

C.7.2.5 Erosion Control and Mulching

• Mulch, silt fencing, wattles, hay bales, and other erosion control devices will be used on areas 

at risk of soil movement from wind and water erosion.

• Mulch will be used if necessary to control erosion, create vegetation micro-sites, and retain 

soil moisture and may include hay, small-grain straw, wood fiber, live mulch, cotton, jute, or 

synthetic netting. Mulch will be free from mold, fungi, and certified free of noxious or 

invasive weed seeds.

• If straw mulch is used, it will contain fibers long enough to facilitate crimping and to provide 

the greatest cover.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-25

C.7.2.6 Pit Closure

• Reserve pits will be closed and backfilled within 60 days of release of the rig. All reserve pits 

remaining open after 60 days will require written authorization of the authorized officer.

Immediately upon well completion, any hydrocarbons or trash in the pit will be removed. Pits 

will be allowed to dry, be pumped dry, or solidified in-situ prior to backfilling.

• Following completion activities, pit liners will be completely removed or removed down to 

the solids level and disposed of at an approved landfill, or treated to prevent their 

reemergence to the surface and interference with long-term successful revegetation. If it was 

necessary to line the pit with a synthetic liner, the pit will not be trenched (cut) or filled 

(squeezed) while containing fluids. When dry, the pit will be backfilled with a minimum of 5 

feet of soil material. In relatively flat areas, the pit area will be slightly mounded above the 

surrounding grade to allow for settling and to promote surface drainage away from the 

backfilled pit.

C.7.2.7 Management of Invasive, Noxious, and Non-Native Species

• All reclamation equipment will be cleaned prior to use to reduce the potential for introduction 

of noxious weeds or other undesirable non-native species.

• An intensive weed monitoring and control program will be implemented prior to site 

preparation for planting and will continue until interim or final reclamation is approved by 

the authorized officer.

• Monitoring will be conducted at least annually during the growing season to determine the 

presence of any invasive, noxious, and non-native species. Invasive, noxious, and non-native 

species that have been identified during monitoring will be promptly treated and controlled. 

C.7.3 Interim Reclamation Procedures – Additional

C.7.3.1 Recontouring

• Interim reclamation actions will be completed no later than 6 months from when the final 

well on the location has been completed, weather permitting. The portions of the cleared well 

site not needed for active operational and safety purposes will be recontoured to the original 

contour if feasible, or if not feasible, to an interim contour that blends with the surrounding 

topography as much as possible. Sufficient semi-level area will remain for setup of a 

workover rig and to park equipment. In some cases, rig anchors may need to be pulled and 

reset after recontouring to allow for maximum interim reclamation.

• If the well is a producer, the interim cut and fill slopes prior to reseeding will not be steeper 

than a 3:1 ratio, unless the adjacent native topography is steeper. Note: Constructed slopes 

may be much steeper during drilling but will be recontoured to the above ratios during 

interim reclamation.

• Roads and well production equipment will be placed on location so as to permit maximum 

interim reclamation of disturbed areas. If equipment is found to interfere with the proper 

interim reclamation of disturbed areas, the equipment will be moved so proper recontouring 

and revegetation can occur.

C.7.3.2 Application of Topsoil & Revegetation

• Topsoil will be evenly respread and aggressively revegetated over the entire disturbed area 

not needed for all-weather operations, including road cuts and fills and to within a few feet of 
Appendix C. Best Management Practices and Mitigation Measures

C-26 Santa Fe National Forest Geothermal Leasing EIS

the production facilities, unless an all-weather, surfaced, access route or small “teardrop” 

turnaround is needed on the well pad.

• In order to inspect and operate the well or complete workover operations, it may be necessary 

to drive, park, and operate equipment on restored, interim vegetation within the previously 

disturbed area. Damage to soils and interim vegetation will be repaired and reclaimed 

following use. To prevent soil compaction, under some situations, such as the presence of 

moist, clay soils, the vegetation and topsoil will be removed prior to workover operations and 

restored and reclaimed following workover operations.

C.7.3.3 Visual Resources Mitigation for Reclamation

• Trees, if present, and vegetation will be left along the edges of the pads whenever feasible to 

provide screening. 

• To help mitigate the contrast of recontoured slopes, reclamation will include measures to 

feather cleared lines of vegetation and to save and redistribute cleared trees, debris, and rock 

over recontoured cut and fill slopes.

• To reduce the view of production facilities from visibility corridors and private residences, 

facilities will not be placed in visually exposed locations (such as ridgelines and hilltops).

• Production facilities will be clustered and placed away from cut slopes and fill slopes to allow 

the maximum recontouring of the cut and fill slopes.

• All long-term, aboveground structures will be painted (color to be determined by site-specific 

survey; from the “Standard Environmental Colors” chart) to blend with the natural color of 

the late-summer landscape background.

C.7.4 Final Reclamation Procedures – Additional

• Final reclamation actions will be completed within 6 months of well plugging, weather 

permitting.

• All disturbed areas, including roads, pipelines, pads, facilities, and interim reclaimed areas 

will be recontoured to the contour existing prior to initial construction or a contour that 

blends indistinguishably with the surrounding landscape. Resalvaged topsoil will be respread 

evenly over the entire disturbed site to ensure successful revegetation. To help mitigate the 

contrast of recontoured slopes, reclamation will include measures to feather cleared lines of 

vegetation and to save and redistribute cleared trees, woody debris, and large rocks over 

recontoured cut and fill slopes.

• Water breaks and terracing will only be installed when absolutely necessary to prevent 

erosion of fill material. Water breaks and terracing are not permanent features and will be 

removed and reseeded when the rest of the site is successfully revegetated and stabilized.

• If necessary to ensure timely revegetation, the pad will be fenced to exclude livestock grazing 

for the first two growing seasons or until seeded species become firmly established, 

whichever comes later. 

• Final abandonment of pipelines and flowlines will involve flushing and properly disposing of 

any fluids in the lines. All surface lines and any lines that are buried close to the surface that 

may become exposed in the foreseeable future due to water or wind erosion, soil movement, 

or anticipated subsequent use, must be removed. Deeply buried lines may remain in place 

unless otherwise directed by the authorized officer.
Appendix C. Best Management Practices and Mitigation Measures

Santa Fe National Forest Geothermal Leasing EIS C-27

C.7.4.1 Road Closure

The operator will:

• Remove drainage structures.

• Recontour and stabilize cut slopes and fill material.

• Reshape the channel and streambanks at crossing sites to pass expected flows without 

scouring or ponding, minimize potential for undercutting or slumping of streambanks, and 

maintain continuation of channel dimensions and the longitudinal profile through the crossing 

site.

• Restore or replace streambed materials to a particle-size distribution suitable for the site.

• Restore floodplain function.

• Implement suitable measures to promote infiltration of runoff and intercepted flow and 

desired vegetation growth on the road prism and other compacted areas.

• Use suitable measures in compliance with local direction to prevent and control invasive 

species.

C.7.4.2 Reclamation Monitoring and Final Abandonment Approval

• Reclaimed areas will be monitored annually. Actions will be taken to ensure that reclamation 

standards are met as quickly as reasonably practical.

• Reclamation monitoring will be documented in an annual reclamation report submitted to the 

authorized officer by (date to be determined). The report will document compliance with all 

aspects of the reclamation objectives and standards, identify whether the reclamation 

objectives and standards are likely to be achieved in the near future without additional 

actions, and identify actions that have been or will be taken to meet the objectives and 

standards. The report will also include acreage figures for: 

♦ Initial Disturbed Acres

♦ Successful Interim Reclaimed Acres

♦ Successful Final Reclaimed Acres 

Annual reports will not be submitted for sites approved by the authorized officer in writing as 

having met interim or final reclamation standards. Monitoring and reporting continues annually 

until interim or final reclamation is approved. Any time 30 percent or more of a reclaimed area is 

redisturbed, monitoring will be reinitiated.

• The authorized officer will be informed when reclamation has been completed, appears to be 

successful, and the site is ready for final inspection.
Appendix C. Best Management Practices and Mitigation Measures

C-28 Santa Fe National Forest Geothermal Leasing EIS

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Appendix D

Summary of Statutes and Regulations 

Governing Geothermal Leasing and 

Development on National Forest System 

Lands
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Appendix D. Summary of Statutes and Regulations Governing Geothermal Leasing and Development on 

National Forest System Lands

Santa Fe National Forest Geothermal Leasing EIS D-1

Appendix D. Summary of Statutes and 

Regulations Governing Geothermal Leasing 

and Development on National Forest System 

Lands

Geothermal leasing and development is subject to federal, state, and local statutes, executive 

orders, and regulations. Table D-1 summarizes the most pertinent statutes and regulations that are 

relevant to this EIS. It is not intended to be a comprehensive list. 
Appendix D. Summary of Statutes and Regulations Governing Geothermal Leasing and Development on National Forest System Lands

D-2 Santa Fe National Forest Geothermal Leasing EIS

Table D-1. Statutes and Regulations Governing Geothermal Leasing and Development on National Forest System Lands

Title Statue or Regulation Description

Federal Statutes and Regulations

Clean Air Act (CAA) 42 USC, Section 

7401 et seq. 

(1970)

The CAA was passed to regulate air pollution and improve air quality. It regulates air 

emissions from area, stationary, and mobile sources. This law also authorizes the EPA to 

establish National Ambient Air Quality Standards to protect public health and the 

environment. 

Clean Water Act (CWA) 33 USC, Section 

1251 et seq. 

(1972)

The CWA established the basic structure for regulating discharges of

pollutants into Waters of the United States. Also included are requirements to set water

quality standards for all contaminants in surface waters. The CWA

made it unlawful for any person to discharge any pollutant from a point source

into navigable waters without first obtaining a permit under its provision.

Endangered Species Act (ESA) 16 USC, Section 

1531 et seq. 

(1973)

The ESA protects federal threatened plants, insects, fish, and wildlife. The US Fish and 

Wildlife Service (USFWS) and the National Oceanic and Atmospheric Administration 

National Marine Fisheries Service administer the ESA on behalf of the United States. The

major components of the ESA are as follows:

• Provisions for listing threatened and endangered species

• The requirement for consultation with the USFWS and the National Oceanic and

Atmospheric Administration National Marine Fisheries Service on federal projects, 

under certain circumstances

• Prohibitions against taking listed species

• Provisions for permits to allow the incidental taking of listed species

Energy Policy Act 42 USC, Section 

15801 et seq. 

(2005)

The Energy Policy Act encourages leasing and developing geothermal resources on federal 

lands. Specifically, Section 225 requires that the Secretaries of the Interior and Agriculture 

establish a program for reducing by 90 percent the backlog of geothermal lease applications 

that were pending as of January 1, 2005. In addition, Section 222 modified the Geothermal 

Steam Act to allow only competitive lease sales for all federal geothermal resources, except 

under certain conditions. The Energy Policy Act also amended the Geothermal Steam Act 

with regard to royalties and rental fees.

Federal Land Policy and 

Management Act (FLPMA)

43 USC, Section 

1701 et seq. 

(1976)

The FLPMA mandates that multiple use and sustained yield principles govern the 

management of public lands. The concept of multiple use directs the BLM to manage public 

lands to best meet the present and future needs of the American people. The FLPMA 

Section 103 defines multiple use as “a combination of balanced and diverse resource uses 

that takes into account the long-term needs of future generations for renewable and 

nonrenewable resources”; it defines sustained yield as “the achievement and maintenance 

in perpetuity of a high-level annual or regular periodic output of the various renewable 
Appendix D. Summary of Statutes and Regulations Governing Geothermal Leasing and Development on National Forest System Lands

Santa Fe National Forest Geothermal Leasing EIS D-3

Table D-1. Statutes and Regulations Governing Geothermal Leasing and Development on National Forest System Lands

Title Statue or Regulation Description

resources of the public lands consistent with multiple use.” As a result of this FEIS, the BLM 

will amend land use plans to adopt allocations, stipulations, and BMPs to allow for 

geothermal leasing.

Geothermal Steam Act 30 USC, Section 

1001, et seq. 

(1970)

The Geothermal Steam Act of 1970, as amended, governs the leasing of geothermal steam 

and related resources on federal lands. It authorizes the Secretary of the Interior to issue 

leases for developing geothermal resources and prohibits leasing on a variety of public 

lands, such as those administered by the USFWS.

Geothermal Resource Leasing 43 CFR, Part 

3200 (2007)

43 CFR, Part 3200, Geothermal Resource Leasing, provides statutory guidance for 

geothermal leasing by the BLM. These statutes describe what lands are available or 

unavailable for geothermal leasing. They also describe requirements for all phases of 

geothermal development.

Geothermal Resource Unit 

Agreements

43 CFR, Part 

3280 (2007)

43 CFR, Part 3280, Geothermal Resource Unit Agreements, identifies the procedures that a 

prospective unit operator must follow to receive BLM approval for the following: unit area 

designation and a federal geothermal unit agreement; operational requirements once the 

unit agreement is approved; and BLM procedures in reviewing, approving, and administering 

a federal geothermal unit agreement. 

Migratory Bird Treaty Act (MBTA) 16 USC, Section 

703 et seq. (1918)

The MBTA of 1918 makes it unlawful to pursue, hunt, kill, capture, possess, buy, sell, 

purchase, or barter any migratory bird, including the feathers or other parts, nests, eggs, or 

migratory bird products. Executive Order 13186, signed January 10, 2001, sets forth the 

responsibilities of Federal agencies to further implement the provisions of the MBTA by 

integrating bird conservation principles and practices into agency activities by ensuring that 

federal actions evaluate the effects of actions and agency plans on migratory birds. 

Mining and Mineral Policy Act 30 USC, Section 

21a et seq. (1970)

The Mining and Mineral Policy Act of 1970 maintains that “it is the continuing policy of the 

federal government in the national interest to foster and encourage...the orderly and 

economic development of domestic mineral resources...” 

National Environmental Policy Act 42 USC, Section 

4321 et seq. 

(1969)

NEPA supports a national policy that requires federal agencies to review

the effects of their actions on the quality of the human environment. The review

process ensures that the environmental impacts of any federal or federally

funded action is available to public officials and citizens before decisions are

made and before actions are taken.
Appendix D. Summary of Statutes and Regulations Governing Geothermal Leasing and Development on National Forest System Lands

D-4 Santa Fe National Forest Geothermal Leasing EIS

Table D-1. Statutes and Regulations Governing Geothermal Leasing and Development on National Forest System Lands

Title Statue or Regulation Description

National Forest Management Act 16 USC, Section 

1600 et seq. 

(1976)

The National Forest Management Act is the primary statute governing the administration of 

national forests. It expanded and otherwise amended the Forest and Rangeland Renewable 

Resources Planning Act of 1974, which called for managing renewable resources on 

national forests. The National Forest Management Act requires the Secretary of Agriculture 

to assess forest lands, to develop a management program based on multiple-use and

sustained-yield principles, and to implement a resource management plan for each unit of 

the National Forest System. In doing so, the Secretary must use an interdisciplinary 

approach; coordinate with state and local resource management efforts; provide for public 

participation; and provide for multiple use and sustained-yield of products and services. The 

Secretary must revise the management plans whenever significant changes occur in a unit.

National Forest System Land 

Resource Management Planning

36 CFR, Part 219, 

Subpart A (2012)

This discusses the levels at which planning may be undertaken, depending on the scope of 

the issues, including the national, regional, national forest, or grassland or ranger district 

administrative levels. It also lists the key elements in the planning cycle. It provides detailed 

steps of the planning process, including opportunities for public comment, amendments, and 

revisions.

National Historic Preservation Act

(NHPA)

16 USC, Section 

470 et seq. (1966)

The NHPA provides for the establishment of the National Register of Historic Places (NRHP)

to include such historic properties as districts, sites, buildings, structures, and objects that 

are significant in American history, architecture, archaeology, and culture. Section 106 of the 

NHPA requires federal agencies with jurisdiction over a proposed federal project to take into 

account the effect of the undertaking on cultural resources listed on or eligible for listing on 

the NRHP. It affords State Historic Preservation Officers and the Advisory Council on 

Historic Preservation an opportunity to comment on an undertaking. The NRHP eligibility 

criteria have been defined by the Secretary of the Interior’s Standards for Evaluation (36 

CFR, Part 60).

Organic Administration Act 16 USC, Section 

551 (1897)

The Organic Administration Act authorizes the Secretary of Agriculture to promulgate rules 

and regulations for the use and occupancy of the national forests.

Public Rangelands Improvement Act 43 USC, Section 

1901 et seq. 

(1978)

The Public Rangelands Improvement Act of 1978 requires the BLM to manage,

maintain, and improve the condition of the public rangelands so that they

become as productive as feasible.
Appendix D. Summary of Statutes and Regulations Governing Geothermal Leasing and Development on National Forest System Lands

Santa Fe National Forest Geothermal Leasing EIS D-5

Table D-1. Statutes and Regulations Governing Geothermal Leasing and Development on National Forest System Lands

Title Statue or Regulation Description

State Statutes and Regulations

New Mexico Geothermal Resources 

Development Act

Senate Bill 223

(2016)

The Geothermal Resources Development Act provides for the development, regulation, and 

conservation of geothermal resources. Responsibility for administering laws and regulations 

relating to geothermal resources, as well as related appropriations, money, and records, is 

transferred from the Oil Conservation Division of the Energy, Minerals and Natural 

Resources Department, and Oil Conservation Commission to the Energy Conservation and 

Management Division of Energy, Minerals and Natural Resources Department.

Geothermal Power New Mexico 

Administrative 

Code, Chapter 

71, Article 9

Rules and regulations adopted by the Oil Conservation division of the Energy, Minerals and 

Natural Resources Department for conserving natural geothermal resources, preventing 

waste, and protecting the correlative rights of geothermal resource owners. 
Appendix D. Summary of Statutes and Regulations Governing Geothermal Leasing and Development on 

National Forest System Lands

D-6 Santa Fe National Forest Geothermal Leasing EIS

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Appendix E

Changes Made Since the Draft 

Environmental Impact Statement
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Appendix E. Changes Made Since the Draft Environmental Impact Statement

Santa Fe National Forest Geothermal Leasing EIS E-1

Appendix E. Changes Made Since the Draft 

Environmental Impact Statement

Described below is a summary of changes made in the FEIS since the DEIS was released, 

organized by chapter. Minor changes in page numbers, table numbers, and figure numbers occur 

throughout the document and are not individually highlighted below.

E.1 Abstract and Summary

The name of the Responsible Official was changed to James Melonas.

Text was added to the abstract regarding the predecisional administrative review process 

(objection process).

Text was added under the “Decision to be Made” heading regarding the forest plan amendment 

and the associated predecisional administrative review process (objection process).

Instructions for commenting on the DEIS were removed from the abstract.

A summary of appendices in the FEIS was added.

Minor edits were made to improve clarity and to correct grammatical errors.

E.2 Table of Contents and Acronyms or Abbreviation

The table of contents and list of acronyms and abbreviations were updated.

E.3 Chapter 1

A reference was added for Appendix D, Summary of Statutes and Regulations Governing 

Geothermal Leasing and Development on National Forest System Lands. 

Figure 1-3 was corrected to show that if the Forest Service does not provide concurrence and 

consent to the BLM to lease lands, the geothermal development process ends.

A discussion of past geothermal exploration near the project area was added under the “New 

Mexico Geothermal Potential” header. This discussion focuses on previous geothermal 

exploration associated with the Baca project.

Information regarding the publication of the NOA and public comment period was incorporated 

under the “Public Involvement and Scoping” header.

Additional text was added under the heading “Tribal Coordination,” including a discussion of the 

commitment for federal agencies to consult with Native American tribes, and the ethnographic 

overview and assessment.

Information on cooperating agencies was added under a new header: “Coordination with Other 

Federal and State Agencies.”

The issue statements under “Fire” and “National Park Service Values” were revised and clarified.
Appendix E. Changes Made Since the Draft Environmental Impact Statement

E-2 Santa Fe National Forest Geothermal Leasing EIS

Added Section 1.15, Forest Plan Amendments, which includes a new table (Table 1-1, 

Amendment Language by Alternative for the Geothermal EIS).

Minor edits were made to improve clarity and to correct grammatical errors.

E.4 Chapter 2

The term “natural geothermal features” was replaced with “hot springs” to improve clarity.

A footnote was added under the heading “Alternative 2-The Proposed Action” to clarify that no 

TCPs have been formally identified, and whether there are TCPs in the project area is determined 

during the identification stage of the Section 106 process of the NHPA.

Under the heading “Comparison of Alternatives,” the following edits were made:

• Land use, recreation, and special designations: impacts from increased truck traffic and 

changes in flows for natural hot springs were incorporated.

• Vegetation: the risk of wildlife was incorporated.

• Social interests, economics, and environmental justice: additional discussion of 

disproportionate, adverse impacts on tribes was incorporated. 

Minor edits were made to improve clarity and to correct grammatical errors.

E.5 Chapter 3

E.5.1 Introduction

Added a paragraph regarding the forest plan amendment.

E.5.2 Methods and Assumptions Common to the Analysis of 

Impacts

An assumption was added stating the analysis assumes the capacity of the SFNF is sufficient to 

implement the decision.

E.5.3 Cumulative Actions for Cumulative Impact Analysis

The SFNF Land Management Plan Revision EIS and Inventory and Evaluation Steps of the 

Wilderness Recommendation Process were added to the list of reasonably foreseeable future 

actions.

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.4 Land Use, Recreation, and Special Designations

Text was clarified to note that the VCNP, formerly the Baca Ranch, is a unit of the National Park 

System and is surrounded by, but not included in, the project area. 

Information on dispersed camping and recreational fishing areas in the project area was added.

Additional analysis was added regarding impacts associated with increased truck traffic, resulting 

in road improvements, and the potential for impacts on recreational hot springs.
Appendix E. Changes Made Since the Draft Environmental Impact Statement

Santa Fe National Forest Geothermal Leasing EIS E-3

Under the heading “Cumulative Impacts, Land Use, Recreation, and Special Designations,”

analysis was added regarding the inventory and evaluation steps of the wilderness 

recommendation process, and implications for any geothermal leasing that could occur in areas 

that are later recommended for wilderness designation. 

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.5 Geologic Resources

Text was revised to clarify that Quaternary Period alluvial and landslide deposits, welded 

Bandelier tuff, Tertiary basalt, basaltic-andesite, or rhyolite and breccias are not all clastic 

sedimentary rocks.

Under the heading “Geologic Setting,” a table was added showing the geologic units that occur in 

the decision area. 

Under the heading “Geologic Setting,” a description of the geologic fault zones that occur in or 

near the project was added. 

Under the heading “Seismic Activity,” text was added noting that the Rio Arriba County Hazard 

Mitigation Plan describes the probability of the Abiquiu Dam failing to be rare. 

Under the heading “Volcanic Activity,” information from the New Mexico Department of 

Homeland Security regarding the probability of a volcanic eruption in New Mexico was 

incorporated. 

Under the heading “Common Impacts Associated with Geothermal Development,” the discussion 

on subsidence was expanded. Also added was information on aquifer systems susceptible to 

subsidence and impacts associated with groundwater pumping to supply hydraulic stimulation 

and makeup water.

Under the heading “Impacts Under Alternative 1,” a discussion of indirect impacts from 

earthquakes, including the potential for structural impacts at LANL, was incorporated. 

E.5.6 Energy and Mineral Resources

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.7 Paleontological Resources

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.8 Soil Resources

No changes were made.

E.5.9 Water Resources

The term “natural geothermal features” was replaced with “hot springs”

Under the affected environment section, a discussion of the groundwater conditions at LANL was 

incorporated.
Appendix E. Changes Made Since the Draft Environmental Impact Statement

E-4 Santa Fe National Forest Geothermal Leasing EIS

Under the heading “Assumptions,” additional text was added to clarify that BMPs would be 

applied, as applicable, at the BLM permitting level to minimize impacts on water resources, and it 

is the responsibility of the applicant to obtain water rights. 

Under the header “Common Impacts Associated with Geothermal Development,” text was 

clarified to state that water would be used during all phases of geothermal resource development.

Under the header “Common Impacts Associated with Geothermal Development,” text was added 

that discusses the potential for a cone of depression in aquifers where groundwater extraction 

occurs. 

Under the header “Common Impacts Associated with Geothermal Development,” a table was 

added titled “Summary of Common Impacts on Water Resources by Geothermal Development 

Phase.” Additional text was added throughout this section to clarify what impacts are associated 

with each phase of geothermal development.

A discussion of impacts associated with groundwater contaminant migration underneath LANL 

was incorporated. 

A discussion of how future climate scenarios would affect water resources was incorporated 

under the header “Cumulative Impacts.”

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.10 Air Quality and Air Quality-Related Values

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.11 Vegetation

A section was added under the “Affected Environment” header titled “Climate Change 

Vulnerability Assessment.” This section describes the Climate Change Vulnerability Assessment 

Project, and includes climate vulnerability rankings by watershed. 

Under the header “Environmental Consequences,” a discussion of the mechanisms for 

transmission lines to cause wildfires was added. In addition, the risk of wildfire for each 

alternative was clarified. 

Headers were added under the “Affected Environment” and “Environmental Consequences” 

sections to clarify existing conditions and impacts of fire versus vegetation communities. 

A discussion of cumulative impacts from future climate change scenarios was added under the 

header “Cumulative Impacts.”

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.12 Fish and Wildlife 

Minor edits were made to improve clarity and to correct grammatical errors.

A discussion of cumulative impacts from future climate change scenarios was added under the 

header “Cumulative Impacts.”
Appendix E. Changes Made Since the Draft Environmental Impact Statement

Santa Fe National Forest Geothermal Leasing EIS E-5

E.5.13 Threatened and Endangered Species and Special Status 

Species

Additional trend data for the New Mexico meadow jumping mouse was incorporated under the 

“Affected Environment” header. 

Additional analysis and references regarding noise impacts on Mexican spotted owls was 

incorporated under the header “Environmental Consequences.”

A discussion of cumulative impacts from noise emissions was added under the header 

“Cumulative Impacts.”

A discussion of cumulative impacts from future climate change scenarios was added under the 

header “Cumulative Impacts.”

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.14 Livestock Grazing

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.15 Cultural Resources

Text was added regarding the All Pueblos Council of Governors resolution to support designating 

the Jemez Mountains as a TCP under the “Affected Environment” header.

Text was added under the “Indicators” header to note that some Pueblo representatives have 

indicated that any form of geothermal leasing anywhere in the project area would have a 

disproportionately high and adverse environmental effect on their communities, and this effect 

could not be mitigated.

An assumption was added to state that neither this programmatic geothermal leasing analysis nor 

the consent to lease specific parcels following the Forest Plan Amendment are considered to be 

undertakings that could adversely affect historic properties under the NHPA, and no further 

Section 106 review is required until authorization of surface-disturbing activities is proposed. 

An assumption was clarified to note that determination of effects and resolution of adverse effects 

must be completed before surface-disturbing activities are authorized. 

Text was added under the “Assumptions” header noting that some pueblo representatives assert 

that the entire project area and the Jemez Mountains are a live place of active worship that would 

be impacted by any geothermal resource development. 

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.16 Tribal Interests and Traditional Cultural Resources

Text was added under the “Resources” header noting that some pueblo representatives assert that 

the entire project area and the Jemez Mountains are a live place of active worship that would be 

impacted by any geothermal resource development.

Text was added under the “Resources” header to note that some Pueblo representatives have 

indicated that any form of geothermal leasing anywhere in the project area would have a 
Appendix E. Changes Made Since the Draft Environmental Impact Statement

E-6 Santa Fe National Forest Geothermal Leasing EIS

disproportionately high and adverse environmental impact on their communities, and this impact 

could not be mitigated.

Text was added to “Common Impacts Associated with Geothermal Development” to note that 

Pueblo representatives have indicated that geothermal resource drilling of any kind would 

diminish the integrity and traditional power and quality of TCPs, and would adversely affect 

traditional cultural practices and uses.

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.17 Visual Resources

An assumption was added stating geothermal infrastructure, such as transmission lines, power 

plants, and rig equipment, is not expected to exceed 155 feet (35 meters) in height.

Under the “Common Impacts Associated with Geothermal Development” header, text regarding 

the distance for lighting on a drill rig to diminish to the illumination of starlight and natural 

airglow was revised, and assumptions were added.

A description of visual impacts during each stage of geothermal resource development was added 

under the “Environmental Consequences” section.

Text was added under “Cumulative Impacts” to note that transmission lines and other geothermal 

infrastructure would likely be visible from the VCNP.

Text was added under “Cumulative Impacts” to note that none of the alternatives are anticipated 

to change projected socioeconomic impacts associated with climate change.

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.18 Social Interests, Economics, and Environmental Justice

Text under the “Affected Environment” header was revised to clarify the definition of a minority 

population and low-income population. 

A discussion of Native American tribes and their representation as a minority group was added 

under the “Affected Environment” header. 

The discussion of social impacts on local communities was expanded, in accordance with the EPA 

Promising Practices for Environmental Justice Methodologies in NEPA Reviews report.

Text was added discussing the potential for socioeconomic impacts on commercial hot spring 

operations.

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.19 Health and Safety

Minor edits were made to improve clarity and to correct grammatical errors.
Appendix E. Changes Made Since the Draft Environmental Impact Statement

Santa Fe National Forest Geothermal Leasing EIS E-7

E.5.20 Noise

Text was added under the “Affected Environment” and “Environmental Consequences” headers 

to clarify that vehicle frequency is less at night than during the day. Therefore, noise frequency 

from this source would also be less at night than during the day. 

Additional analysis regarding noise emissions from vehicle use and construction was added under 

the “Environmental Consequences” header.

E.5.21 Transportation and Access

Under the “Affected Environment” header, text was added to clarify that temporary roads are 

authorized by contract, special use permit, lease, or other written authorization, and they are 

exempt from the travel management plan. 

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.22 Climate Change

A discussion of climate change scenarios in the Southwest was added under the “Affected 

Environment” header. 

Minor edits were made to improve clarity and to correct grammatical errors.

E.5.23 Short-Term Uses and Long-Term Productivity

No changes were made.

E.5.24 Unavoidable Adverse Impacts

No changes were made.

E.5.25 Irreversible and Irretrievable Commitments of Resources

Minor edits were made to improve clarity and to correct grammatical errors.

Information on hazardous materials used or generated during geothermal activities was added.

E.6 Chapter 4

Minor edits were made to the “Cooperating Agency Team Members and Other Contributors” 

table.

E.7 Chapter 5

The term “geothermal resource” was added to the glossary.

The term “thermal resource” was added to the glossary.

The term “viewshed” was added to the glossary.

Minor edits and additions were made to the glossary definitions. 

E.8 Chapter 6

Additional references were incorporated.
Appendix E. Changes Made Since the Draft Environmental Impact Statement

E-8 Santa Fe National Forest Geothermal Leasing EIS

E.9 Chapter 7

No changes were made.

E.10 Appendices 

In Appendix A, Management Areas R, S, and X were incorporated.

In Appendix B, the term “natural geothermal feature” was replaced with “hot spring.” Text was 

incorporated to clarify that “drinking water sources” include those recognized by the NMEDDWB. Added Figure 2-9, Alternative 3 – The No Leasing Alternative Closed to Leasing.

Appendix D, Summary of Statutes and Regulations Governing Geothermal Leasing and 

Development on National Forest System Lands, was added.

Appendix E, Changes Made Since the Draft Environmental Impact Statement, was added.

Appendix F, Summary of Public Comments, was added. 

Minor edits were made to improve clarity and to correct grammatical errors.
Appendix F

Summary of Public Comments
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United States Department of Agriculture 

Forest Service

Southwestern Region

Santa Fe National Forest 

Geothermal Leasing EIS

Summary of Public Comments

Santa Fe National Forest

11 Forest Lane

Santa Fe, New Mexico 87508

March 2017 

Prepared by:

Environmental Management and Planning Solutions, Inc.

54 1⁄2 Lincoln Street

Santa Fe, New Mexico 87501
In accordance with federal civil rights law and US Department of Agriculture (USDA) civil rights 

regulations and policies, the USDA, its agencies, offices, and employees, and institutions participating in or 

administering USDA programs are prohibited from discriminating based on race, color, national origin, 

religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital 

status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal 

or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not 

all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. 

Persons with disabilities who require alternative means of communication for program information (e.g., 

Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible agency or 

USDA’s TARGET Center at (202) 720-2600 (voice and TTY), or contact USDA through the Federal Relay 

Service at (800) 877-8339. Additionally, program information may be made available in languages other 

than English. 

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, 

AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office, 

or write a letter addressed to USDA and provide in the letter all of the information requested in the form. 

To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to 

USDA by (1) mail: US Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 

Independence Avenue, SW, Washington, DC 20250-9410; (2) fax: (202) 690-7442; or (3) e-mail:

program.intake@usda.gov. 

USDA is an equal opportunity provider, employer, and lender.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

i

Table of Contents

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

Issue Topics and Responses ............................................................................................................ 1

Timing and Scope ....................................................................................................................... 1

Summary and Response .......................................................................................................... 1

General Comments...................................................................................................................... 3

Summary and Response .......................................................................................................... 3

General Comments—Regulations............................................................................................... 4

Summary and Response .......................................................................................................... 4

General Comments—Data .......................................................................................................... 6

Summary and Response .......................................................................................................... 6

Editorial Changes........................................................................................................................ 6

Summary and Response .......................................................................................................... 6

Jurisdiction and Authority........................................................................................................... 6

Summary and Response .......................................................................................................... 6

Alternatives................................................................................................................................. 7

Summary and Response .......................................................................................................... 7

Purpose and Need...................................................................................................................... 10

Summary and Response ........................................................................................................ 10

Land Use and Special Designations, Including Inventoried Roadless Areas............................ 11

Summary and Response ........................................................................................................ 11

Recreation ................................................................................................................................. 12

Summary and Response ........................................................................................................ 12

Geologic Resources and Geologic Hazards.............................................................................. 12

Summary and Response ........................................................................................................ 12

Energy and Mineral Resources................................................................................................. 15

Summary and Response ........................................................................................................ 15

Soil Resources........................................................................................................................... 16

Summary and Response ........................................................................................................ 16

Water Resources and Quality.................................................................................................... 16

Summary and Response ........................................................................................................ 16

Air Quality and Air Quality-Related Values............................................................................. 22

Summary and Response ........................................................................................................ 22

Vegetation ................................................................................................................................. 23

Summary and Response ........................................................................................................ 23

Fish and Wildlife....................................................................................................................... 23

Summary and Response ........................................................................................................ 23

Threatened and Endangered Species and Special Status Species............................................. 23

Summary and Response ........................................................................................................ 23

Cultural Resources.................................................................................................................... 26

Summary and Response ........................................................................................................ 26

Tribal Interests and Traditional Cultural Resources ................................................................. 27

Summary and Response ........................................................................................................ 27

Visual Resources....................................................................................................................... 28

Summary and Response ........................................................................................................ 28

Social Interests, Economics, and Environmental Justice .......................................................... 30

Summary and Response ........................................................................................................ 30

Responses.............................................................................................................................. 31

Health and Safety...................................................................................................................... 31
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

ii

Summary and Response ........................................................................................................ 31

Noise ......................................................................................................................................... 32

Summary and Response ........................................................................................................ 32

Transportation and Access........................................................................................................ 33

Summary and Response ........................................................................................................ 33

Climate Change......................................................................................................................... 34

Summary and Response ........................................................................................................ 34

Fire ............................................................................................................................................ 35

Summary and Response ........................................................................................................ 35

Appendix

Appendix A: List of Commenters.......................................................................................... A-1

Appendix B: Comments by Process Category and Resource Category..................................B-1
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

iii

Acronym or Abbreviation Full Term

BLM United States Department of the Interior, Bureau of Land Management

BMP best management practice

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

COA condition of approval

CSU controlled surface use

DEIS draft environmental impact statement

DOE United States Department of Energy

EIS environmental impact statement

EPA United States Environmental Protection Agency

FEIS final environmental impact statement

Forest Service United States Department of Agriculture, Forest Service

FLPMA Federal Land Policy and Management Act

IRA inventoried roadless area

LANL Los Alamos National Laboratory

MOU memorandum of understanding

NEPA National Environmental Policy Act

NOA Notice of Availability

NPS National Park Service

NSO no surface occupancy

RFDS reasonably foreseeable development scenario

SFNF Santa Fe National Forest

US United States

USFWS United States Department of the Interior, Fish and Wildlife Service
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Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Introduction

The Notice of Availability (NOA) for the Santa Fe National Forest (SFNF) Geothermal Leasing Draft 

Environmental Impact Statement (DEIS) was published in the Federal Register on July 8, 2016 (81

Federal Register 44608, July 8, 2016). The opportunity for providing comments to establish eligibility to 

object under 36 Code of Federal Regulations (CFR), Subpart 219.52, was originally scheduled to end

August 22, 2016, 45 days following the NOA. The comment period was extended to October 28, 2016, 

and a Federal Register amended notice was published on July 29, 2016 (81 Federal Register 49982, July 

29, 2016).

The SFNF received comments by mail, fax, and email and at public meetings. The SFNF recognizes that 

commenters invested considerable time and effort to submit comments on the DEIS; as such, it developed 

a comment analysis method to ensure that all comments were considered, as directed by National 

Environmental Policy Act (NEPA) regulations. 

The SFNF developed a systematic process for responding to comments to ensure all comments were 

tracked and considered. On receipt, each comment letter was assigned an identification number and 

logged into a tracking database that allowed the SFNF to organize, categorize, and respond to comments. 

Comments were coded by appropriate categories based on content of the comment. 

Comments similar to each other were grouped under a topic heading. The SFNF then drafted a statement 

summarizing the issues contained in each group of comments. The responses were crafted to respond to 

the comments and to note whether a change to the Environmental Impact Statement (EIS) was warranted. 

Text that describes changes made to the EIS is highlighted in light gray.

The SFNF received a total of 199 submissions, which were categorized into 623 unique comments. All 

commenter names are listed in Appendix A, List of Commenters. All unique comments are in Appendix 

B, Comments by Process Category and Resource Code. Also included in this appendix are the names of 

people who submitted comments on the DEIS during the comment period.

Issue Topics and Responses

Timing and Scope 

Summary and Response

Issue 1: Commenters said that the United States (US) Department of Agriculture, Forest Service (Forest 

Service) gave inadequate notice to the public about the availability of the DEIS, public comment period,

and public meetings. Inadequate notice did not allow sufficient review of the DEIS prior to the first 

meeting to identify the negative impacts on the regional and local economies and cultures.

Response 1: The Forest Service provided public notification, as required by the Council on 

Environmental Quality (CEQ) at 40 CFR, Parts 1500-1508. The agency provided information on the 

availability of the DEIS through numerous methods, including mailings, legal notice, and press releases, 

as follows: 

• The Forest Service issued a press release on July 1, 2016, announcing the pending publication of the 

DEIS and the first public meeting. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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• On July 8, 2016, the NOA was published in the Federal Register (81 Federal Register 44608, July 8, 

2016), announcing the beginning of the DEIS public comment period, ending on August 22, 2016. 

• On July 13, 2016, a press release announced two subsequent public meetings. 

• An amended NOA was issued on July 29, 2016 (81 Federal Register 49982, July 29, 2016), 

extending the public comment period to October 28, 2016. 

• On July 27, 2016, a press release was issued, adding a fourth public meeting on the DEIS. 

• A legal notice was published in The Albuquerque Journal on July 15, 2016, announcing the public 

comment period on the DEIS. 

• Hard copies of the DEIS were available at the Forest Supervisor’s office in Santa Fe, New Mexico, 

and at the Cuba Ranger District in Jemez Springs, New Mexico. 

Four public meetings were held during the comment period: 

• Santa Fe on July 7, 2016

• Jemez Pueblo on July 19, 2016

• El Rito on July 20, 2016

• Albuquerque on August 16, 2016

Issue 2: Commenters questioned the timing of the EIS and land use plan amendment when the Forest 

Service is in the beginning stages of revising the Forest Plan. 

Response 2: On March 1, 2011, the US Department of the Interior, Bureau of Land Management (BLM), 

Las Cruces District Office received Nominations of Lands for Competitive Geothermal Leasing for lands 

in the SFNF. The BLM submitted the lease parcel nomination to the Forest Service on September 2, 2011. 

On October 25, 2011, the SFNF determined that the current Forest Plan leasing stipulations were 

inadequate and that further environmental analysis was required. 

The SFNF initiated the environmental analysis process, in accordance with the memorandum of 

understanding (MOU)1 between the US Department of the Interior and the US Department of Agriculture. 

Delaying environmental analysis until completion of the Forest Plan revision would be inconsistent with 

the 2005 Energy Policy Act; it calls for “...timely completion of administrative actions, including 

amendments to applicable forest plans and resource management plans, necessary to process applications 

for geothermal leasing...” 

Amendments to the Forest Plan made as part of the final decision on this project are expected to be 

incorporated into the revised plan and its subsequent decisions. 

Issue 3: Commenters requested clarification on the expanded size of the project area, when the original 

expression of interest was for a smaller footprint.

Response 3: The Forest Service based the analysis area on inquiries from applicants and area geothermal 

potential. Geothermal potential was used to develop the reasonably foreseeable development scenario 

(RFDS), as described in Section 1.6 of the DEIS. The Forest Service considered a reduced project area 

alternative but eliminated it from further analysis because of potential inefficiencies with future project 

planning. It also considered an enlarged project area alternative, but this was eliminated from further 

analysis because of existing constraints on geothermal development potential. See the DEIS Section 2.4 

for a detailed description of the alternatives considered but eliminated from further analysis. 

 1

Implementation of Section 225 of the Energy Policy Act of 2005 Regarding Geothermal Leasing and Permitting
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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General Comments

Summary and Response

Issue 1: Several commenters stated that they favored or did not favor all or parts of one or more 

alternatives.

Response 1: The Forest Service read, analyzed, and considered the opinions, feelings, and preferences for 

one element or one alternative over another and comments of a personal or philosophical nature; however, 

because such comments are not substantive (36 CFR, Subpart 218.2 and 36 CFR, Subpart 218.25), the 

Forest Service did not respond to them individually.

Issue 2: Commenters raised general concerns about the impact on the environment from developing 

geothermal resources.

Response 2: This EIS will not authorize leasing; it will describe the restrictions on geothermal leasing. 

See section 1.9 of the EIS for the description of the decision to be made. The administrative action of 

determining areas available or unavailable for geothermal leasing has no direct impact on the 

environment; however, it is a commitment of the resource for potential future exploration, drilling 

operations and development, utilization, and reclamation and abandonment, which are subject to 

environmental review and permits. Therefore, the DEIS analyzed the potential impacts of the various 

stages that may follow a leasing decision, along with the potential cumulative impacts throughout the 

entire project area.

Issue 3: Commenters were concerned that geothermal leasing is a front for oil and gas leasing.

Response 3: While geothermal resources and oil and gas are both considered leasable minerals, this 

project addresses leasing for geothermal resources only. None of the alternatives include actions that 

would make lands available or unavailable for nongeothermal mineral leasing. 

Issue 4: One commenter asked if the agencies have some sort of contingency fund for cleaning up spills 

or contamination.

Response 4: This project evaluates area available or unavailable for geothermal leasing; no leases would 

be authorized by this DEIS. Site-specific analysis would occur after BLM lease sales at each stage of 

exploration, development, and utilization for future proposed projects. In accordance with 43 CFR, 

Subpart 3214.10, the lessee or operator must post a bond with the BLM before exploration, drilling, or 

utilization operations begin. Bonding holds all interest owners liable for plugging and abandoning wells, 

reclaiming the surface and other resources, compensatory royalties assessed for drainage, and rent and 

royalties due. The minimum bond amount varies depending on the type of activity.

Issue 5: One commenter raised concern that permanent, long-term impacts would not be irreversible.

Response 5: DEIS Section 3.25, Irreversible and Irretrievable Commitments of Resources, acknowledges 

the irreversible and irretrievable commitments of resources associated with implementing the alternatives.

Issue 6: Commenters said other types of renewable energy (e.g., solar and wind) seem better suited to the 

development area.

Response 6: While other forms of renewable energy may be possible, this project is being evaluated 

because of a lease nomination and interest in the area’s geothermal resource. If other industry 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

4

representatives apply for special use authorization permits to develop solar or wind projects, a separate 

NEPA analysis would be conducted. 

Issue 7: A commenter requested a discussion of the Baca geothermal project (Union Oil, US Department 

of Energy [DOE]) in the document.

Response 7: Discussion of the Baca Geothermal Project was added to Final Environmental Impact 

Statement (FEIS) Section 1.6.3.

Issue 8: A commenter requested that any subsequent environmental review use unbiased professional 

resources, such as the DOE’s Geothermal Technologies Office publications and staff.

Response 8: The SFNF used both in-house and contracted professional staff and the best available 

scientific data when analyzing alternatives. Publications from the DOE are included as references in the 

EIS (for example, see Section 1.6.1).

Issue 9: A commenter said that if the SFNF were to provide consent to the BLM for geothermal leasing, 

such leases could be in effect for 100 years or more, and that the RFDS underestimates impacts.

Response 9: Time frames for stages of the geothermal development process are provided in the RFDS. 

Information was added to Section 2.5 of the FEIS to clarify that utilization activity may extend beyond 

the time frame of the RFDS. The RFDS time frame is consistent with guidance provided in BLM 

Handbook 1624-1 for preparing a RFDS. 

General Comments—Regulations

Summary and Response

Issue 1: Commenters reiterated several laws, guidance, and executive orders that the Forest Service and 

the BLM are bound by, including each agency’s mission, NEPA, Forest Service NEPA guidance, and the 

Federal Land Policy and Management Act (FLPMA, which only applies to the BLM). While both 

agencies have a “multiple use, sustained yield” mission, they must advocate a conservation ethic and are 

given much discretion in their decision-making authority. The agencies are not required to allow 

geothermal leasing.

Response 1: The Forest Service acknowledges that it is mandated to comply with laws, guidance, and 

executive orders and describes this compliance in DEIS Sections 1.1 and 1.7. Appendix D, Summary of 

Statutes and Regulations Governing Geothermal Leasing and Development on National Forest System 

Lands, was added in the FEIS. The Forest Service agrees that it has discretion regarding lands available 

for geothermal leasing. This is reflected in Alternative 3, where the SFNF would amend the Forest Plan to 

implement discretionary closures to geothermal leasing on all lands in the project area not already closed 

to leasing (EIS Section 2.3.3).

Issue 2: Commenters stated that making this decision separate from the Forest Plan revision undermines 

the forest planning process by, for example, potentially allowing development in areas that could be 

recommended for wilderness designation.

Response 2: The SFNF is mandated by the Energy Policy Act of 2005 to complete administrative actions 

necessary to process applications for geothermal leasing in a timely manner. Delaying environmental 

analysis until completion of the Forest Plan revision would be inconsistent with the Energy Policy Act.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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The Inventory and Evaluation steps of the Wilderness Recommendation Process consider the current 

conditions of the land, so areas that could have future development as part of this project are considered 

as they are now, without potential development from this or any other project without a decision. In 

addition, decisions to consent to lease areas are made by the responsible official based on current 

conditions, which could include the status of an area as recommended wilderness. This information was 

incorporated into the analysis under Section 3.4.2.8.

Issue 3: Commenters stated that NEPA requires analysis of site-specific impacts before any irretrievable 

commitment of resources. By issuing a lease without a no surface occupancy (NSO) stipulation, the 

Forest Service is irretrievably committing resources before conducting a site-specific analysis.

Response 3: No leases would be issued as part of this decision; this EIS only describes the lands that 

would be available and unavailable for geothermal leasing under each alternative. Irretrievable 

commitments of resources are disclosed in DEIS Section 3.25. Site-specific impacts would be addressed 

as part of the environmental analysis for the permitting process. All development, utilization, and 

reclamation activities would be subject to further site-specific permitting and environmental analysis. 

Appropriate site-specific mitigation would be developed as necessary. 

After release of the FEIS, the responsible official (the Forest Supervisor) documents the decision in a 

Record of Decision. If the decision is to make lands available for geothermal leasing (i.e., Alternative 2 or 

4 is selected), the BLM determines NEPA adequacy, and independently prepares a separate decision 

document adopting or not adopting the Forest Service decision. Figure 1-3 in the EIS describes the 

geothermal leasing and development process in more detail. 

Issue 4: Commenters stated that the Forest Service should analyze a reasonably foreseeable leasing and 

development scenario associated with the proposed action. These impacts may be analyzed as indirect 

impacts that are later in time or farther removed but still reasonably foreseeable.

Response 4: Given the programmatic nature of the EIS and its focus on geothermal leasing, specific 

spatial development scenarios are considered speculative and are not included. The impacts analysis 

(Chapter 3 of this EIS) considers the RFDS described in Section 3.2 of the DEIS. Additional details about 

the RFDS are found on the project website: https://www.fs.usda.gov/project/?project=46886. 

Issue 5: Commenters stated that the Forest Service should strengthen the environmental consequences 

section and provide a sound analytical analysis using the best available scientific information, similar to 

the Casa Diablo IV Geothermal Development Project EIS/Environmental Impact Report.

Response 5: The Casa Diablo IV Geothermal Development EIS/Environmental Impact Report analyzed a 

defined project. As a programmatic leasing analysis, this EIS does not have that level of detail. As 

exploration and development projects are proposed, additional analysis will be done.

Issue 6: Commenters stated that the DEIS does not provide significance criteria, such that the reader 

cannot determine which impacts are significant and why.

Response 6: For each resource analyzed in Chapter 3, the Forest Service identified indicators to evaluate 

potential impacts on that resource. These indicators serve as significance criteria for the EIS. As described 

in CEQ Section 1508.27, the term “significantly” requires that both context and intensity be considered. 

Context is described in terms of the “region of influence” (see DEIS Section 3.3.2); intensity is described 

in the context of the identified indicators. Unavoidable adverse impacts are discussed under DEIS Section 

3.24. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Issue 7: Commenters stated that the Forest Service should consult with the US Fish and Wildlife Service

(USFWS), in accordance with Section 7 of the Endangered Species Act, to determine whether the 

proposed action may jeopardize any federally listed species.

Response 7: The Forest Service acknowledges its responsibilities under Section 7 of the Endangered 

Species Act. It did not begin consultation during this EIS process, due to the programmatic nature of the 

decision and the lack of information on the location of specific disturbances. Without project-specific 

details, the USFWS cannot prepare an incidental take statement. As a result, Section 7 consultation will 

occur on a project-specific basis, when project location details and proposed disturbances will be known.

General Comments—Data

Summary and Response

Issue: Commenters recommended the Forest Service review and incorporate studies and other literature 

references in the EIS. Commenters recommended the Forest Service review results from two studies done 

on seismicity. One was a study on the association between the depth of wastewater injection and 

seismicity. The other was a study related to seismic dangers at Los Alamos National Laboratories 

(LANL). One commenter recommended contacting Don Brown, and provided a list of suggested 

references related to geophysics in the region.

Response: Studies suggested by the commenters were reviewed to determine if they represented the best 

available science. Those studies that did represent the best available science were incorporated into 

Chapter 3. 

Editorial Changes

Summary and Response

Issue: Approximately 14 comments provided standard editing and word changes throughout the DEIS. 

Response: Comments citing editorial changes to the document were reviewed and incorporated as 

appropriate.

Jurisdiction and Authority

Summary and Response

Issue 1: Commenters were concerned about consultation or coordination with other agencies, including 

the US Department of the Interior, National Park Service (NPS), the BLM, and the USFWS. 

Response 1: The Forest Service has been coordinating with the BLM and the NPS since the beginning of 

the project. The BLM and NPS are cooperating agencies on the project. 

The Forest Service solicited cooperating agency comments on a preliminary DEIS before it was released 

to the public. The Forest Service met with the cooperating agencies to review comments on the 

preliminary DEIS on April 22, 2016, and revised the document based on those comments. All other local, 

state, and federal agencies are on the mailing list for the project. In addition, the Forest Service has 

coordinated with and solicited input from the USFWS and the New Mexico State Historic Preservation 

Office. The Forest Service also consulted with tribal governments, in accordance with government-togovernment consultation requirements. Chapter 1 of the FEIS was updated to include this information.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Issue 2: Commenters were concerned about the BLM’s authority with respect to the lease and changing 

SFNF stipulations.

Response 2: DEIS Section 1.5.1 states the following:

“The BLM has the delegated authority to issue geothermal leases on federal lands. It is 

the policy of the federal government, consistent with Section 2 of the Mining and Mineral 

Policy Act of 1970 and Sections 102(a)(7), (8), and (12) of the FLPMA (43 USC, Section 

1701 et seq.), to encourage the development of mineral resources, including geothermal 

resources, on federal lands. The Geothermal Steam Act of 1970 (30 USC, Section 1001 et 

seq.), which was amended and supplemented by the Energy Policy Act of 2005, provides 

statutory guidance for geothermal leasing by the BLM. Federal geothermal development 

regulations (43 CFR, Parts 3000, 3200, and 3280—Geothermal Resource Leasing and 

Geothermal Resources Unit Agreements) were made effective June 1, 2007 (72 Federal 

Register 24358, May 2, 2007), as a result of a directive provided in the Energy Policy Act 

of 2005. These statutes and regulations delineate lands that are available and unavailable 

for leasing.”

The BLM may add stipulations to the lease with the Forest Service’s consent, but the Forest Service 

stipulations cannot be removed. In addition, the BLM and Forest Service considered an alternative with 

stipulations and no exceptions, waivers, or modifications, but eliminated that alternative from detailed 

study (see DEIS Section 2.4.3). 

Issue 3: Commenters requested information on private lands in the project area and the authority or 

jurisdiction of developers drilling from those lands, as well as who holds the mineral rights beneath those 

private lands. 

Response 3: The Forest Service does not administer private lands in the project area; therefore, these 

lands are outside of the decision area for this project. 

Issue 4: Commenters were concerned about the BLM and Forest Service’s capacity and funding to 

enforce stipulations and conditions of approval (COAs) and to monitor development in the project area. 

Response 4: The BLM and Forest Service assume that personnel will be available for implementing the 

decision. This assumption was added to the FEIS in Section 3.2.

Alternatives

Summary and Response

Issue 1: Commenters said the Forest Service should modify NSO stipulations to not allow waivers, 

exceptions, or modifications in any sensitive areas. Examples are places that are potentially suitable for 

wilderness designation, water bodies, places with high levels of recreation, inventoried roadless areas

(IRAs), sacred sites, and critical habitat. The FEIS should include a map of areas subject to NSO without 

waivers, exceptions, or modifications. 

Response 1: The stipulations were selected for inclusion based on a comprehensive review of the SFNF 

1987 Forest Plan, program guidance, geothermal development activities, published data on geothermal 

development impacts, industry standards, and best professional judgment. The intent of these stipulations 

is to provide a level of protection for resource values or land uses by restricting lease operations during 

certain times or at certain locations or by mitigating unacceptable impacts, to an extent greater than 

standard lease terms or conditions. 
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As described in DEIS Section 2.2.2, an exception, waiver, or modification may not be approved unless the 

BLM Authorized Officer determines that the factors leading to the stipulation’s inclusion in the lease have 

changed sufficiently to make the protection provided by the stipulation no longer justified, or the 

proposed operations would not cause unacceptable impacts (43 CFR, Subparts 3101.1-4). BLM 

Instruction Memorandum No 2008-032 outlines the processes under which exceptions, waivers, and 

modifications are granted. An alternative with stipulations and no exceptions, waivers, or modifications 

was considered but eliminated from detailed study (see DEIS Section 2.4.3). A map showing areas subject 

to NSO without waivers, exceptions, or modifications was not included in the DEIS; this is because the 

conditions for waivers, exceptions, or modifications vary between stipulations. 

Appendix C of the DEIS also includes best management practices (BMPs) and mitigation measures to 

reduce impacts on sensitive resources.

Issue 2: Commenters said the Forest Service should provide more information on the alternatives. This 

should include a consideration of the BLM’s obligations under FLPMA and the Forest Service’s 

obligations under the National Forest Management Act. Commenters also said the alternatives should 

provide a description of a development scenario for the alternatives, based on other developed geothermal 

projects. 

Response 2: The BLM’s obligations under the FLPMA are described in DEIS Section 1.5. Appendix D, 

Summary of Statutes and Regulations Governing Geothermal Leasing and Development on National 

Forest System Lands, was added in the FEIS. Given the programmatic nature of the EIS and its focus on 

geothermal leasing, spatial development scenarios are considered speculative and are not included. The 

RFDS is available on the project website at http://www.fs.usda.gov/project/?project=46886, and the 

impacts analysis considers this RFDS in Chapter 3 (see Section 3.2 for assumptions from the RFDS used 

in the analysis).

Section 3.2 of the DEIS describes the RFDS used for Alternative 1, 2, and 4. No development is foreseen 

under Alternative 3.

Issue 3: Commenters said the DEIS does not present a reasonable range of alternatives, as the two action 

alternatives are very similar. Other possible alternatives to meet the need are not included, such as 

developing other forms of renewable energy, having a “wilderness-focused” alternative, and analyzing an 

alternative that includes only the area in which Ormat has expressed interest.

Response 3: The Forest Service considered a reasonable range of alternatives during the geothermal 

leasing planning process in full compliance with NEPA. The CEQ regulations (40 CFR, Subpart 1502.1) 

require that the Forest Service consider reasonable alternatives that meet the purpose and need of the EIS 

and that would avoid or minimize adverse impacts or enhance the quality of the human environment. 

While there are many possible alternatives or actions to manage National Forest System land in the 

planning area, the Forest Service fully considered the issues developed during the scoping process to 

determine a reasonable range of alternatives, including development of stipulations. Nondiscretionary 

closures for geothermal leasing do not vary between alternatives, because allowing geothermal leasing in 

such areas is beyond the authority of the SFNF.

Section 2.4 of the DEIS adequately describes the alternatives considered but eliminated from detailed 

study, including a “wilderness-focused” alternative and an alternative encompassing only the 46,000 acres 

where the BLM has received expressions of interest in leasing. To consider other forms of renewable 

energy would be outside the scope of the EIS.
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Issue 4: Commenters said the DEIS does not address any alternatives that were considered but eliminated 

from detailed analysis. 

Response 4: Section 2.4 of the DEIS addresses alternatives considered but eliminated from detailed 

analysis.

Issue 5: A commenter said the Forest Service should clarify Appendix B to clearly define which 

stipulations and/or exceptions, waivers, and modifications apply to each alternative. Specific stipulations 

were provided in the comment:

“...on page B-3, there is a stipulation listed for State Engineer recognized water bodies 

and a one-mile area around them. It then states that surface occupancy is prohibited, and 

also that a modification or waiver could occur if studies show no reasonable risk. The 

next column has a “dot” in Alternative 2, the proposed alternative. Does that mean this 

entire stipulation only applies in Alternative 2, meaning surface disturbance on water 

bodies is allowed in Alternative 4? Similarly, later in the page, there is a stipulation for 

OSE-acknowledged drinking water sources, stating surface occupancy is not permitted 

but that an exception could be granted. This stipulation appears to ONLY apply to 

Alternative 4. Did SFNF really mean to suggest that surface disturbance on drinking 

water sources COULD occur in the proposed alternative? Or did it mean the “exception” 

would only apply to Alternative 4?”

Response 5: In DEIS Appendix B, each stipulation is described in detail and names the alternative that 

the specific stipulation applies to (as shown in the right-hand column of the table). The entire stipulation 

and any exceptions, modifications, or waivers are assumed to apply to the identified alternatives. In the 

example highlighted by the commenter, under Alternative 2 an NSO stipulation applies to New Mexico 

Office of the State Engineer recognized water sources (which includes known drinking water sources, 

known wells, and known springs) and a 1-mile protection zone around them. A similar stipulation applies 

to Alternative 4, but only for recognized drinking water sources. Because the conditions of the 

stipulations vary slightly between Alternative 2 and 4, separate rows are provided in the table to highlight 

the difference. 

Issue 6: Commenters said companies should be required to provide plans of where they intend to drill and 

to provide proof of the final locations.

Response 6: The operator is required by law and regulation to file plans prior to any surface-disturbing 

activity, such as drilling exploratory or development wells. These plans are required to give the sitespecific details and locations (DEIS Section 1.5.2, Figure 1-3, and Section 3.2).

Issue 7: Commenters said the comparison of alternatives fails to provide specific information that is 

needed to adequately assess the difference in impacts between the alternatives, fails to provide any 

specifics and uses, uses only subjective wording to compare the alternatives, and should better describe 

impacts under Alternative 1.

Response 7: The Forest Service provided an adequate analysis that led to disclosure of the potential 

environmental consequences of the alternatives (see DEIS Chapter 3). As a result, the Forest Service took

a hard look, as required by NEPA (40 CFR, Subpart 1502.16), at the environmental consequences of the 

alternatives. This was done to enable the decision-maker to make an informed decision.

The differences between the alternatives were quantified, when possible, such as for energy and mineral 

resources; however, this quantification was limited, due to the programmatic nature of the document and 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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lack of site-specific proposals. DEIS Section 2.6, Comparison of Alternatives, is not intended to be a 

detailed description of impacts on each resource or resource use under each alternative; however, the 

analysis in this section was augmented to ensure an adequate description of the impacts under 

Alternative 1.

Purpose and Need

Summary and Response

Issue 1: Commenters stated the project area has already been tested for geothermal potential, and the 

resource was determined to be uneconomical to pursue. 

Response 1: On March 1, 2011, the BLM, Las Cruces District Office received Nominations of Lands for 

Competitive Geothermal Leasing for lands in the SFNF. The BLM submitted the lease parcel nomination 

to the Forest Service on September 2, 2011. After receiving the lease parcel nomination, the Forest 

Service is required to make a decision to consent or not consent to geothermal leasing. It is not the Forest 

Service’s decision to determine the economic feasibility of geothermal development on the SFNF. 

Instead, the Forest Service is determining if certain lands on the SFNF may be made available for

geothermal leasing. Geothermal potential on the SFNF was evaluated, as stated in the DEIS Section 1.2:

“...the United States Geological Survey...has identified approximately 194,000 acres of SFNF lands with 

significant geothermal potential; the BLM has received expressions of interest in leasing approximately 

46,000 acres of this land for geothermal energy production.”

Issue 2: Commenters stated that, as currently written, Alternative 1 would meet the purpose of and need 

for action because it could still allow for geothermal leasing, albeit on a case-by-case basis.

Response 2: As stated in DEIS Section 1.2, “the SFNF Plan, as amended (Forest Service 1987) does not 

allocate areas as open or closed to geothermal leasing, does not have adequate stipulations or BMPs to 

apply to geothermal leases to protect sensitive resources, and does not assess the reasonably foreseeable 

development scenario (RFDS), as required in the 2008 [Programmatic EIS].”

As a result, Alternative 1 would not meet the project purpose of determining if certain SFNF lands may be 

made available for geothermal leasing and would not identify reasonable and necessary conditions to 

protect resources. 

Issue 3: Commenters stated the even with full development of the RFDS, geothermal energy would 

provide only 1 percent of New Mexico’s energy. As a result, any alternative would not meet the purpose 

of and need for action to facilitate renewable energy development.

Response 3: The purpose of and need for action does not state that the Forest Service would facilitate 

development of renewable energy. DEIS Section 1.2 states the following:

“The purpose of the action is to refine the analysis available in the [programmatic EIS] in 

order to determine if certain lands in the SFNF may be made available for geothermal 

leasing and, if so, to provide consent to leasing of lands and to identify reasonable and 

necessary conditions to protect resources.

“The need for the action is twofold: (1) to allow the Forest Service to satisfy its 

respective statutory and policy mandates in responding to requests for the 

environmentally responsible development of energy resources and (2) to respond to other 

policy directives calling for clean and renewable energy.”
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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By identifying lands available or unavailable for geothermal leasing and providing consent to the BLM 

for leasing the lands, the Forest Service would meet the twofold need for the action. 

Issue 4: Commenters stated the purpose of and need for action should be revised, because it appears to 

address the purpose of and need for the DEIS instead of the proposed action. In addition, the need is too 

generic and should address the basic problem (i.e., why it is occurring in this location and why it needs to 

be addressed now).

Response 4: In accordance with NEPA, the Forest Service has discretion to establish the purpose of and 

need for action (40 CFR, Subpart 1502.13). The CEQ regulations direct that an EIS “...shall briefly 

specify the underlying purpose and need to which the agency is responding in proposing the alternatives 

including the proposed action” (40 CFR, Subpart 1502.13). 

Also, under CEQ regulations, the Forest Service is required to “study, develop, and describe appropriate 

alternatives to recommended courses of action in any proposal which involves unresolved conflicts 

concerning alternative uses of available resources as provided by section 102(2)(E) of the Act [NEPA]”

(40 CFR, Subpart 1501.2[c]). 

The breadth or narrowness of the purpose and need statement has a substantial influence on the scope of 

the subsequent analysis. The purpose and need statement provides a framework for issue identification 

and will inform the rationale for alternatives selection. The developed range of alternatives is intended to 

meet the purpose and need and address the issue, thereby providing a basis for eventual selection of an 

alternative (Forest Service Handbook 1909.15; National Environmental Policy Act Handbook; Chapter 

10, Environmental Analysis). 

The proposed action considered in the EIS meets the purpose and need by determining if certain SFNF

lands may be made available for geothermal leasing and identifying reasonable and necessary conditions 

to protect resources.

Land Use and Special Designations, Including Inventoried 

Roadless Areas

Summary and Response

Issue 1: Commenters were concerned about discrepancies in the number of IRAs in the project area. 

Specifically, West Mesa and Holiday Mesa are IRAs that may be in the project area. 

Response 1: IRAs that occur in the project area are: Youngsville, Pueblo Mesa, Cañones Creek, 

Polvadera, Virgin Canyon, Peralta Ridge, and Alamo Canyon. IRAs, including acres in the project area, 

are discussed under Section 3.4.1.3 of the DEIS. Holiday Mesa and West Mesa IRAs are not in the project 

area. 

Issue 2: A commenter was concerned that a consent determination under the proposed action could 

conflict with the ongoing (phase 2) evaluation of wilderness land designations on the SFNF. The 

commenter stated that portions of the project area may qualify for wilderness designation.

Response 2: The phase 2 evaluation of wilderness land designations on the SFNF was added to the 

reasonably foreseeable future actions in Table 3-1 of the FEIS and was added to the cumulative impacts 

analysis (Section 3.4.2.8). The Evaluation step of the Wilderness Recommendation Process considers the 

current conditions on the land, so areas that could have future development as part of this project are 

considered (evaluated) as they are now, without potential development from this or any other project 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

12

without a decision. If the wilderness land designation inventory indicates that lands with wilderness 

potential exist within the project area, the Forest Service may withhold consent to lease those lands. 

Recreation

Summary and Response

Issue 1: Commenters were concerned about impacts on recreation in the Jemez Mountains, specifically 

impacts on access, hiking, equestrian use, fishing, camping, and hunting.

Response 1: Impacts on recreational resources are described in DEIS Section 3.4. Consenting to issue a 

geothermal lease has no direct impact on the environment; however, it is a commitment of the resource 

for potential future exploration, drilling operations and development, utilization, and reclamation and 

abandonment. All of these actions are subject to environmental review and permits. 

As stated in DEIS Section 3.4.2.3, Common Impacts Associated with Geothermal Development, the 

development of geothermal resources could alter the physical, social, and operational character of the 

recreation setting, thereby changing an individual’s experiences. 

All phases of development—surveying, drilling, utilization, operation, and maintenance—could restrict 

recreation areas. This could temporarily reduce the amount of land available for recreation and accessible 

trails. This could displace some recreationists and could limit recreation. Recreationists could experience 

an increase in noise, vibration, and dust. Additionally, exploration could shift the Recreation Opportunity 

Spectrum setting. Under travel management, new roads created for a specific project would probably not 

be open to recreational use. However, this would also alter the experience for people seeking a more 

remote experience in those same areas. 

If Alternatives 1, 2, or 4 were selected in the decision, future geothermal leasing and development could 

occur in the project area. When an exploration, development, or utilization plan is submitted, projectspecific information is provided, such as the location, number of wells, and type of development. At that 

stage, specific impacts on recreation through site-specific analysis or modeling would be identified. NSO 

and controlled surface use (CSU) stipulations proposed under Alternatives 2 and 4 would reduce potential 

impacts on recreation. They would accomplish this by placing restrictions on development around 

designated recreation sites and other areas with special resource values, such as threatened and 

endangered species habitat. Possible mitigation and monitoring would be applied to reduce those impacts. 

Issue 2: Commenters were concerned about impacts on recreational use of hot springs. 

Response 2: As identified in the DEIS water resources analysis, while unlikely, drawdowns of water or 

changes in temperature and chemical composition could occur at recreational hot springs in the project 

area. This would be due to the unknown characteristics of the hydrologically interconnected aquifers in 

the region. If such impacts were to occur, they would indirectly affect recreation and socioeconomics 

during subsequent phases of exploration and development. The analysis in FEIS Sections 3.4 was

augmented to better describe these potential impacts.

Geologic Resources and Geologic Hazards

Summary and Response

Issue 1: Commenters stated that seismic activity associated with geothermal development could lead to 

contamination of the water supply, and this is concerning because the US Environmental Protection 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

13

Agency (EPA) declared the Española Basin Aquifer beneath the LANL to be a sole-source aquifer. In 

addition, seismic activities could disrupt the Abiquiu Dam and induce plutonium and uranium to enter the 

water supply. The Forest Service should analyze these impacts in the EIS.

Response 1: Impacts on water resources are described in DEIS Section 3.9.2, and impacts associated with 

seismic activity are described in Section 3.5.2. The FEIS analysis was modified to include additional 

information regarding indirect impacts from induced seismicity.

Issue 2: Commenters said the area is volcanic and has many fault zones, and that studies have shown an 

increase in the frequency of earthquakes near geothermal sites. As such, seismic activity is likely to be 

induced by geothermal development and could damage structures on private and Indian lands in nearby 

communities and historic structures. Facilities at the LANL are highly susceptible to seismic activity, and 

such activity could cause a fire at the LANL or release nuclear materials into the environment. The Forest 

Service should analyze these impacts in the EIS.

Response 2: Impacts associated with seismic activity are described in DEIS Section 3.5.2. The analysis 

describes the likelihood for impacts on volcanic activity and seismicity, protocols for addressing induced 

seismicity during geothermal projects, and mitigation measures that can be implemented if induced 

seismic events approach defined limits. Additional discussion of potential indirect impacts at the LANL 

were incorporated in the FEIS.

The site-specific likelihood for induced seismicity would be addressed as part of the environmental 

analysis for the permitting process. All development, utilization, and reclamation would be subject to 

further site-specific permitting and environmental analysis. Appropriate site-specific mitigation would be 

developed, as necessary. 

Issue 3: Commenters stated seismic monitors may not be sufficient to prevent earthquakes because even 

when water injection is halted, earthquakes could continue.

Response 3: As described in Section 3.5.2 of the DEIS, the International Energy Agency developed a 

peer-reviewed and accepted protocol for addressing induced seismicity during geothermal projects, and 

the DOE has adopted it (Majer et al. 2012; see DEIS Chapter 6). One of these protocols is to establish 

seismic monitoring. Combined with the induced seismicity hazards risk analysis and mitigation measures 

that can be implemented if induced seismic events approach defined limits, the Forest Service believes 

that seismic monitors are an acceptable method to reduce the risk of induced seismicity associated with 

geothermal energy development. 

Issue 4: Commenters said geothermal power plants can lead to subsidence, rock falls, landslides, and 

damage to homes.

Response 4: Impacts associated with subsidence are described in Section 3.5.2.3 of the DEIS. BMPs are 

included in Appendix C, Section C.2.4, to reduce the likelihood for subsidence. As described there, the 

potential for subsidence is low. Subsidence depends on the geological characteristics of the area where the 

geothermal fluids are extracted, or where any other groundwater used for cooling may be extracted. These 

conditions and the potential to impact them vary by location and the proposed development. Site-specific 

impacts on geology, including the likelihood for subsidence, rock falls, and landslides, would be 

addressed as part of the environmental analysis for the permitting process. All development, utilization, 

and reclamation would be subject to further site-specific permitting and environmental analysis. 

Appropriate site-specific mitigation would be developed, as necessary. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Issue 5: Commenters requested that the Forest Service include additional analysis in the DEIS, including 

results from the US Geological Survey’s seismic model and how often enhanced geothermal systems are

used with other geothermal production.

Response 5: The 2008 Geothermal Leasing Programmatic EIS (BLM and Forest Service 2008) discusses 

a range of development methods in Section 1.4, along with the impacts of those methods. 

The CEQ regulations require an EIS to “succinctly describe the environment of the area(s) to be affected 

or created by the alternatives under consideration. The description shall be no longer than is necessary to 

understand the effects of the alternatives. Data and analyses in a statement shall be commensurate with 

the importance of the impact, with less important material summarized, consolidated, or simply 

referenced. Agencies shall avoid useless bulk in statements and shall concentrate effort and attention on 

important issues” (40 CFR, Subpart 1502.15). 

The Forest Service complied with these regulations in describing the affected environment. The requisite 

level of information necessary to make a reasoned choice among the alternatives in an EIS is based on the 

scope and nature of the proposed decision. The affected environment provided in Chapter 3 is sufficient to 

support, at the programmatic level of analysis, the environmental impact analysis resulting from 

management actions in the DEIS.

The SFNF Geothermal Leasing EIS is a programmatic NEPA effort. Its purpose is to determine which 

SFNF lands, if any, would be available for geothermal leasing and under what stipulations. As such, the 

Forest Service described the current conditions and trends in the affected environment broadly, across a 

range of conditions, appropriate to program-level land use planning actions. The data used in the DEIS 

were the best available at the time collected. Site-specific modeling of seismicity may be done as part of 

the exploration and development analysis. 

Issue 6: Commenters stated seismic hazard has been monitored during water injection, and, while many 

micro seismic events were recorded, they were typically between 0 and 3.0 magnitude on the Richter 

scale.

Response 6: The Forest Service acknowledges that micro seismic events may be related to geothermal 

water injection activities. The potential risk of induced seismicity is discussed in DEIS Section 3.5. 

Issue 7: Several commenters opposed the use of hydraulic fracturing (also referred to as fracking).

Response 7: The text in DEIS Section 3.5.2.3 addresses enhanced geothermal systems; often referred to 

as hydro-shearing or shearing), as follows: 

“The process of stimulating production and injection wells by injecting water under 

pressure, and often at a much cooler temperature than the receiving rock, results in the 

expansion of existing fractures and sometimes the creation of new fractures through the 

movements of masses of rock at depth. This fracturing method is commonly referred to as 

hydro-shearing or shearing. These movements result in seismic activity. Since the seismic 

activity is created by the reservoir stimulation, it is distinguished from natural seismicity 

by the term induced seismicity. Whether or not the induced seismicity can be felt at the 

surface depends on the depth of the reservoir, the degree to which the rock masses are 

shifted from the stimulation, and the nature of the overlying geology and its ability to 

transfer the shock waves to the surface.

“Typically, natural fractures vary in length on a scale of 1 to 10 meters. Seismic energy 

radiated during the shearing process depends on the length of the fracture or the stress 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

15

release from the constraining natural forces. Most of the observed data from existing 

enhanced geothermal systems projects suggest that the higher energy radiated from the 

shearing is caused by a high stress release from relatively small joint lengths (Michelet et 

al. 2004). This would suggest that if there were some perceived seismicity on the surface, 

the frequency content would be too high to generate any seismic risk, but minor events 

may still raise concern among local inhabitants. As part of the NEPA process for any 

specific Enhanced Geothermal Systems proposal, mitigation measures, such as seismic 

monitoring requirements, would be developed to address the potential for seismic-related 

risks.” 

Hydroshearing for EGS is similar to hydraulic fracturing, but there are several key differences. Hydraulic 

fracturing involves injection of water and a proppant (a mix of sand and chemicals), at pressures of 9,000 

pounds per square inch or more, which breaks though the rock and creates permeability to allow as much 

natural gas or oil as possible to flow into the wellbore from shale and other low-permeability rocks. The 

hydraulic fracturing fluids injected and produced water (brine) are pumped back to the surface for 

disposal. The number of wells (on average 3 to 4 wells per square kilometer or 1 well per 60 to 80 acres) 

used in a production site uses a large quantity of water (10.0 to 20.0 cubic meters per well, or 2,640 to 

5,280 gallons per well). EGS involves hydraulically shearing rock. This is done by using water without 

proppant injected at pressures ranging from 1,500 to 2,300 pounds per square inch to make rock faces 

slide past each other slightly to create an increased network of pore spaces. Unlike hydraulic fracturing, a 

high permeability is not desired with EGS, because excessive permeability would allow water to pass 

through the geothermal system too quickly and prevent adequate time for the water to reheat. EGS 

processes do not produce any wastewater byproducts, because the fluids are recirculated in the reservoir.

Energy and Mineral Resources

Summary and Response

Issue 1: Commenters questioned the feasibility, success, and sustainability of geothermal energy 

development in the decision area, given the limited water resources available. Commenters also suggested 

the Forest Service consider developing other renewable energy sources instead of geothermal.

Response 1: It is not the Forest Service’s decision to determine the economic feasibility of geothermal 

development on the SFNF. Instead, the agency is determining if certain SFNF lands may be made 

available for geothermal leasing. As stated in DEIS Section 1.2, the US Geological Survey has “identified 

approximately 194,000 acres of SFNF lands with significant geothermal potential;” these are shown on 

DEIS Figure 1-3. In addition, DEIS Section 1.6 discusses geothermal potential in New Mexico, based on 

updated information since the 2008 programmatic EIS for geothermal leasing. Geothermal potential is 

further discussed in the RFDS, available on the project website 

(http://www.fs.usda.gov/project/?project=46886). 

Impacts on water resources and the need for operators to obtain water rights are discussed in DEIS 

Section 3.9.2. The Forest Service provided an adequate analysis that disclosed the potential environmental 

consequences of the alternatives (DEIS Chapter 3). As a result, the Forest Service has taken a hard look, 

as required by NEPA (40 CFR, Subpart 1502.16), at the environmental consequences of the alternatives in 

the DEIS. This was done to enable the decision-maker to make an informed decision.

Consideration of other forms of renewable energy is outside the scope of this EIS.

Issue 2: Commenters stated that geothermal energy is the most competitive economically and has the 

highest capacity factor, when compared to other power plants, that the decision area has a high potential 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

16

for success using the hot dry rock method, given the temperature profile, and that experiments have 

shown the potential for successful geothermal energy development.

Response 2: The Forest Service acknowledges comments in support of geothermal development. 

Issue 3: Commenters requested that the Forest Service acknowledge that geothermal development would 

be constrained by transmission opportunities.

Response 3: Transmission needs for geothermal development and the associated constraints are discussed 

in DEIS Sections 3.6.1 and 3.6.2. 

Issue 4: Commenters stated that the BLM and Forest Service do not have sufficient resources to manage 

a complex leasing program involving numerous stipulations and BMPs, and that this would lead to 

insufficient regulatory oversight of geothermal operations.

Response 4: The Forest Service and the BLM assume that sufficient funding and personnel will be 

available for implementing the decision. This assumption was added to Section 3.2.

Soil Resources

Summary and Response

Issue: Commenters stated the Forest Service must protect soils and steep slopes in the decision area, 

which are already susceptible to erosion and sedimentation.

Response: The DEIS includes measures to reduce the likelihood for erosion, sedimentation, and impacts 

on steep slopes. Alternatives 2 and 4 include an NSO stipulation on slopes in excess of 40 percent grade 

and a CSU stipulation on slopes between 30 and 40 percent grade. In DEIS Appendix B, Alternative 2 

includes an NSO for soils with severe erosion potential, and Alternative 4 includes a CSU stipulation for 

such soils. DEIS Appendix C includes additional measures to reduce impacts on steep slopes and to 

prevent soil erosion. 

Impacts on soils, including the potential for impacts on steep slopes and erosion, are presented in DEIS 

Section 3.8.2. The Forest Service provided an adequate analysis that led to disclosure of the potential 

environmental consequences of the alternatives (see DEIS Section 3.8.2). As a result, the Forest Service 

has taken a hard look, as required by NEPA (40 CFR, Subpart 1502.16), at the environmental 

consequences of the alternatives in the DEIS. This was done to enable the decision-maker to make an 

informed decision. 

Water Resources and Quality

Summary and Response

Issue 1: Multiple commenters expressed concern about how geothermal exploration could impact the hot 

springs in the area. Concerns included drawdown, change in chemistry and temperature, and impacts on

the recreational and socioeconomic values of the hot springs in the Jemez area. 

Response 1: Potential impacts on hot springs are described in detail in DEIS Section 3.9.2. The Jemez 

National Recreation Area is closed to leasing under existing laws and regulations (see 43 CFR, Subpart 

3201.11). The commercial hot springs in Jemez Springs are privately owned. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

17

Consenting to issue a geothermal lease has no direct impact on the environment; however, it is a 

commitment of the resource for potential future exploration, drilling operations and development, 

utilization, and reclamation and abandonment. All of these actions are subject to environmental review 

and permits. Because the location of future exploration and development is unknown in these areas, only 

general impacts on hot springs are discussed. 

Both Alternatives 2 and 4 place stipulations on the lease restricting drilling within a specified distance 

from hot springs, which are generally analyzed as follows:

The Alternative 2 analysis (DEIS Section 3.9.2.5) states: “Implementing a 1-mile no 

leasing protection zone around geothermal features should reduce the potential for direct 

pumping of geothermal fluids around these features. However, in this fractured and 

interconnected system, pumping some distance from the geothermal features could 

change temperature and chemical composition and flow rates.”

The Alternative 4 analysis (DEIS Section 3.9.2.7) states: “Under Alternative 4, NSO 

stipulations apply to natural geothermal features, and a 1-mile buffer around them. NSO 

stipulations would protect these resources from accidental spills or leaks from the 

pumping site and would increase the difficulty of accessing geothermal waters close to 

the geothermal features. However, this stipulation does not prevent withdrawals from 

waters near the geothermal features using advanced technology. A lessee of a NSO area 

must develop any surface infrastructure outside the NSO area and would need to use 

advanced technology, such as directional drilling, to access the geothermal resource 

under the NSO area; nevertheless, those resources could still be accessed. Therefore, this 

alternative is more likely to impact natural geothermal features, potentially affecting 

temperatures and flow rates.”

When an exploration, development, or utilization plan is submitted, project-specific information is 

provided for the location, the number of wells, and the type of development. At that stage, specific 

impacts would be identified on hot springs through site-specific analysis or modeling.

Issue 2: Commenters were concerned about geothermal drilling and its impact on groundwater aquifers 

and supply to water wells. 

Response 2: Potential impacts on groundwater aquifers are described in DEIS Section 3.9.2. Consenting 

to issue a geothermal lease has no direct impact on the environment; however, it is a commitment of the 

resource for potential future exploration, drilling operations and development, utilization, and reclamation 

and abandonment. All of these actions are subject to environmental review and permits. Because the 

location of future exploration and development is unknown, only general indirect impacts on groundwater 

are discussed. Common impacts from subsequent geothermal exploration on groundwater were identified 

as possible drawdown of aquifers and potential contamination. With respect to drawdown, the DEIS page 

3-51 states the following:

“Because the applicant would be required to obtain water rights, and the source of 

makeup water is unknown, the amount of water consumption occurring within the project 

area is unknown. However, BMPs—such as evaluating the consumptive use of water in 

the operation and its effect on water dependent ecosystems, and identifying areas of 

groundwater discharge and recharge and their potential relationship with surface water 

bodies—could be applied into the permit application or included as approved use 

authorizations by the BLM as conditions of approval. These measures would reduce the 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

18

likelihood of lowering the groundwater table to a level that would not support existing 

land uses.”

With respect to groundwater contamination, analysis text on DEIS page 3-49 states the following:

“Potential short-term impacts on water quality could also occur from accidental releases 

of chemical compounds, such as fuels, solvents for removing buildup on pipes, and 

working fluids required for drilling and operation activities, or wastewater, which could 

contaminate surface water and shallow groundwater. Impacts from accidental releases of 

wastewater, such as storm water or sanitation water, could include increased 

concentrations of nitrate, phosphate, total dissolved solids, and fecal coliform in shallow 

groundwater or surface water. The risk of occurrence of spills, or impacts if a spill occurs, 

would be reduced by incorporating in the development plan BMPs and environmental 

protection measures. Extracted geothermal fluids containing high concentrations of 

dissolved constituents and leaking into the shallow aquifer could contaminate freshwater 

supplies through faulty reinjection practices, geothermal well casing failure, and 

uncontrolled discharge of waste geothermal fluids. Protecting groundwater from 

contamination by geothermal fluids is facilitated by the use of multiple casing strings, 

whose depths are specified partly on the basis of the depths of groundwater aquifers. In 

addition, redundant blow-out prevention equipment is used.”

When an exploration, development, or utilization plan is submitted, project-specific information is 

provided on the location, number of wells, and type of development. At that stage, specific impacts on 

groundwater through site-specific analysis or modeling would be identified. BMPs would be applied to 

reduce these impacts.

Issue 3: Commenters were concerned about geothermal development affecting surface water sources, 

including acequias and Fenton Lake.

Response 3: Potential impacts on surface water resources are discussed in Section 3.9.2 of the DEIS. 

Consenting to issue a geothermal lease has no direct impact on the environment; however, it is a 

commitment of the resource for potential future exploration, drilling operations and development, 

utilization, and reclamation and abandonment. All of these actions are subject to environmental review 

and permits. Because the location of future exploration and development is unknown, only general 

indirect impacts on surface water are discussed. Text on DEIS pages 3-48 to 3-49 states the following:

“Fresh water used in the drilling operations would be trucked in or would come from 

local springs and wells at depths less than 1,000 feet (BLM 2015). Water is used during 

the well construction as drilling fluids, and for cementing the casing in place. Well depth, 

total number of wells, volume of the borehole, and the physical and chemical properties 

of the formation would affect water volume requirements during drilling 

operations...Water consumption (i.e., water that is withdrawn from a resource such as a 

river, lake, or nongeothermal aquifer that is not returned to that resource), varies between 

0.29 and 0.72 gallon per kilowatt-hour for enhanced geothermal scenarios (Clark et al. 

2011).

“Potential impacts on surface water quality due to ground disturbance during road, 

powerline, and facility development could occur from erosion and subsequent transport 

of eroded materials into surface waters in areas where vegetation has been removed and 

soils disturbed...This would be of particular concern in areas of highly erodible soils, 

near impaired stream reaches, or in sensitive watersheds.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

19

“Potential short-term impacts on water quality could also occur from accidental releases 

of chemical compounds, such as fuels, solvents for removing buildup on pipes, and 

working fluids required for drilling and operation activities, or wastewater, which could 

contaminate surface water and shallow groundwater. Impacts from accidental releases of 

wastewater, such as storm water or sanitation water, could include increased 

concentrations of nitrate, phosphate, total dissolved solids, and fecal coliform in shallow 

groundwater or surface water. The risk of occurrence of spills, or impacts if a spill occurs, 

would be reduced by incorporating in the development plan BMPs and environmental 

protection measures.”

When an exploration, development, or utilization plan is submitted, project-specific information is 

provided on the location, number of wells, and type of development. At that stage, specific impacts on 

surface water through site-specific analysis or modeling would be identified. Based on the analysis, 

mitigation and monitoring could be required.

Issue 4: Commenters requested additional analysis be conducted for impacts on the geothermal system of 

Valles Caldera National Preserve. The analysis should include the hydrothermal circulation system and 

the need to protect these resources from leasing-related impacts, as stipulated under the NPS Organic Act, 

the enabling legislation for Valles Caldera National Preserve (Public Law 113-231, Sec. 3043), and other 

laws and policies, including the Geothermal Steam Act.

Response 4: Potential impacts on the geothermal system in Valles Caldera National Preserve are 

discussed in Section 3.9.2 of the DEIS. Consenting to issue a geothermal lease has no direct impact on the 

environment; however, it is a commitment of the resource for potential future exploration, drilling 

operations and development, utilization, and reclamation and abandonment. All of these actions are 

subject to environmental review and permits. The studies and determinations required by the Geothermal 

Steam Act will be completed when specific projects are submitted. 

When an exploration, development, or utilization plan is submitted, project-specific information is 

provided on the location, number of wells, and type of development. At that stage, cumulative impacts on 

the geothermal system in Valles Caldera National Preserve would be identified through site-specific 

analysis or modeling. If possible, mitigation and monitoring would be applied to reduce those impacts.

Issue 5: Commenters requested that the following terms be added to the glossary:

• Geothermal resource

• Geothermal feature

• Thermal resource (NPS definition)

• Thermal feature (NPS definition)

Response 5: The term “geothermal resource” as defined in 30 USC, Section 1102 was added to the 

glossary. The term “geothermal feature” was replaced with “hot spring” in the FEIS. The terms “thermal 

resource” and “thermal feature” were not added to the glossary, as these terms were not used in the EIS.

Issue 6: Commenters questioned how indicators for water resources were evaluated and noted that the 

impacts of the alternatives on groundwater resources are purely speculation or assumption, rather than 

analysis.

Response 6: The method for analyzing impacts on water resources using the identified indicators is 

discussed in Section 3.9.2.2 of the DEIS. Due to the inability to predict future types of development and 

their timing and locations, the potential for these impacts to occur can be fully evaluated only after a site-
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

20

specific proposal is submitted. Any subsequent site-specific exploration or development that might occur 

in the project area would undergo NEPA review. At that time, a detailed analysis, based on indicators,

would be conducted. 

Issue 7: Commenters noted that large amounts of water would be required for production, and they 

questioned where water would come from.

Response 7: Because the location of future exploration and development is unknown, only general 

impacts on water resources are discussed in the DEIS. As stated on page 3-48, “The applicant would be 

responsible for obtaining water rights in accordance with state and federal regulations. [Freshwater] used 

in the drilling operations would be trucked in or would come from local springs and wells at depths less 

than 1,000 feet (BLM 2015).”

If Alternatives 1, 2, or 4 were to be selected and the Forest Service consents to lease, the amount of water 

and its source would be identified in a plan of exploration or development during the next phase of the 

project. Exploration and development are evaluated through subsequent NEPA analysis, when details of 

the proposed exploration are identified.

Issue 8: A commenter was concerned about existing radioactive, toxic, and hazardous pollutants found in 

the regional drinking water aquifer below the Pajarito Plateau, which is the location of the LANL. The 

commenter said over 18 million cubic feet of radioactive, toxic, and hazardous waste has been buried in 

unlined pits, trenches, and shafts in the volcanic tuff of the Pajarito Plateau, and chromium-6 has been 

detected at levels 24 times the standard of 50 parts per million in the regional drinking water aquifer. The 

commenter wanted to know how changes to flow paths from geothermal development can mobilize these 

toxins. The commenter noted that geothermal leasing could further contaminate the Española Basin Sole 

Source Aquifer with LANL pollutants.

Response 8: LANL is located east of the project area. At its closest point, LANL is just over 2 miles from 

the southern boundary of the project area. LANL is situated on a thick zone of mainly unsaturated rock 

and sediments. Groundwater below LANL occurs in three modes: perched alluvial groundwater in canyon 

bottoms, discontinuous zones of intermediate-depth perched groundwater, and the regional aquifer 

beneath the Pajarito Plateau (LANL 2005). The depth of the intermediate-depth perched groundwater

ranges from 120 feet to 750 feet, and the regional aquifer is found at 600 to 1,200 feet below the ground 

surface (LANL 2015). Groundwater in the regional aquifer generally flows east or southeast at a rate of 

approximately 30 feet per year. The Sierra de los Valles provides most of the recharge to groundwater 

beneath the Pajarito Plateau. 

Contaminants from historical laboratory operations are present in perched-intermediate groundwater 

zones and in the regional aquifer below LANL. These contaminants are associated with past liquid 

effluent releases from outfalls (the discharge point of a liquid waste stream into the environment; LANL 

2015). The results of groundwater characterization and monitoring from the 2015 LANL Annual Site 

Environmental Report (LANL 2015) indicate that two substances have notable areas of groundwater 

contamination at LANL: hexahydro-1,3,5-trinitro-1,3,5-triazine beneath Cañon de Valle, and Hexavalent 

chromium beneath Sandia and Mortandad Canyons. The water-supply wells in this area, which are owned 

and operated by Los Alamos County, meet all federal and state drinking water standards (LANL 2015).

Geothermal development could result in changes to groundwater flow paths, as described in Section 

3.9.2.3. Clarification on the mechanisms for flow path alteration and the potential impacts on existing 

LANL contaminants are provided below.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Geothermal pumping could potentially result in changes to groundwater pressurization and flow paths, 

particularly in deeper aquifers, as described in Section 3.9.2.3. This occurs through changes in 

pressurization and reduced vertical hydraulic gradients. In addition, groundwater extraction for hydraulic 

stimulation and makeup water can result in a cone of depression (DOE 2016) where water is being 

removed faster than the aquifer’s permeability allows it to be replenished. As such, extraction may result 

in a change in the rate or direction of flow in and near the well. As described in Section 3.9.2, the 

applicant would be required to obtain water rights, and the source of makeup water is unknown under 

Alternatives 1, 2, and 4. Therefore, it is unknown if water for hydraulic stimulation and makeup would be 

extracted near LANL. However, LANL has an extensive groundwater monitoring network and 

implements measures to control contaminant migration (LANL 2015). Once plans of exploration and 

development are submitted, project-specific information, studies, and modeling would help to better 

understand the groundwater system and the potential site-specific impacts with regards to LANL 

contaminant mobilization.

This analysis has been incorporated into the FEIS.

Issue 9: A commenter requested that the Forest Service consult with the EPA on this project. 

Response 9: The Forest Service coordinated with the EPA during the project and sent the EPA a copy of 

the DEIS. The EPA subsequently submitted a comment letter and rated the DEIS as EC-2, or 

Environmental Concerns—Requesting Additional Information. This comment letter is available in the 

project record. The SFNF is responding to the comments from the EPA. Changes made in response to the 

letter include:

• Incorporation of additional socioeconomic analysis based on the EPA Promising Practices for 

Environmental Justice Methodologies in NEPA Reviews (EPA 2016).

• A summary of future climate scenarios was added to Section 3.22.1 of the FEIS. An explanation of

how these climate change scenarios may affect area resources was added to the cumulative effects 

discussion of these resources, notably water resources, vegetation, and biological resources.

Issue 10: One commenter noted that the water section, similar to the air section, should follow a similar 

format and discussion of impacts from initial exploration, development and drilling, secondary 

exploration and drilling, and final plugging and reclamation. The commenter also felt that the 

assumptions in the water section would be more accurate if they included the assumptions in the air 

section. Examples of these assumptions are those concerning BMPs, state permitting requirements, the 

likelihood of using a binary power system, and the need or lack of need for related potential impact 

analyses, the number of geothermal plants, and the total area of potential surface and subsurface 

disturbance.

Response 10: The water section was revised to include additional assumptions. A table was added to 

Section 3.9.2 of the FEIS summarizing common impacts on water resources by geothermal development 

phase. 

Issue 11: A commenter said that, considering the drilling depths that may be necessary, the NSO 

stipulation around water bodies will be insufficient to protect these features.

Response 11: As described in Section 2.2 of the DEIS, “Stipulations were selected for inclusion based on 

a comprehensive review of the SFNF Forest Plan, program guidance, geothermal development activities, 

published data on geothermal development impacts, industry standards, and best professional judgment.”

Impacts on water resources based on the proposed stipulations are discussed in DEIS Section 3.9.2. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

22

Issue 12: A commenter said that the SFNF and adjacent lands have unique geothermal features that 

should not be degraded by geothermal energy development, citing the Sulphur Springs property, which 

may be conveyed to NPS jurisdiction, as an example.

Response 12: Impacts on geothermal resources are described in DEIS Section 3.9.2 and include an 

analysis of the impacts on water quantity and quality. The nomination of the Valles Caldera National 

Preserve is included in the DEIS in Table 3-1, Reasonably Foreseeable Future Actions; impacts on this

area are addressed in Section 3.9.2, Water Resources. In addition, BMPs in Appendix C, Section C.1.3,

would reduce the likelihood for impacts on water resources. 

The site-specific likelihood for impacts on water resources would be addressed as part of the 

environmental analysis for the permitting process. All exploration, development, utilization, and 

reclamation would be subject to further site-specific permitting and environmental analysis. Appropriate 

site-specific mitigation would be developed as necessary.

Air Quality and Air Quality-Related Values

Summary and Response

Issue 1: Multiple commenters noted that construction and operation of geothermal power plants, well 

maintenance, and vehicular traffic would emit criteria air pollutants, fugitive dust, and potentially toxic 

substances from the geothermal resource. One commenter expressed concern of downwind pollution, and 

another commented that visitors come to the SFNF to experience a clean, quiet forest environment.

Response 1: Section 3.10.2.3 of the DEIS described the types and sources of air pollutant emissions 

associated with exploration, development, utilization, and reclamation and abandonment. It estimated 

potential emissions associated with exploration in Table 3-9 and development in Table 3-11. These 

estimates were based on the RFDS, which described a predicted level of development that could occur in 

the project area. This section also described noncondensable gases, such as carbon dioxide, hydrogen 

sulfide, methane, and ammonia, as well as trace amounts of mercury, boron, and arsenic that could be 

present in the geothermal resource. As noted in DEIS Section 3.10.2.3, the exact characterization of the 

geothermal resource is not known at this time. 

As described in DEIS Section 3.10.2.4, additional site-specific analysis would occur at each stage of 

development if specific projects were proposed. Emissions from both drilling and construction would be 

minimized or mitigated through BMPs and/or COAs applied at the permit level. They would minimize 

impacts on air quality from well drilling, facility and infrastructure construction, and surface disturbance. 

BMPs would be incorporated into the permit applications or may be included in the approved use 

authorizations as COAs. BMPs identified in DEIS Appendix C include measures to mitigate equipment 

exhaust emissions and control fugitive dust. State air permitting would impose additional limits on 

allowable emissions from future development. The permits required and the conditions imposed in these 

permits would be determined during the project-specific permitting process.

Issue 2: Commenters said that steam plumes would cause local weather changes by affecting clouds and 

emit hydrogen sulfide, contributing to acid rain, adding that carbon dioxide and hydrogen sulfide can 

linger in valleys, causing increased pollution for local populations.

Response 2: As described in Section 3.10.2 of the DEIS, the RFDS indicates that because of the cool air 

temperatures and the scarcity of water in the project area, binary power plant technology would be used, 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

23

and plants would likely be air cooled instead of water cooled. Air-cooled plants do not produce the steam 

plumes described by the commenter. 

Additional site-specific analysis would occur at each stage of exploration, development, and utilization 

for future proposed projects. These analyses would determine measures required by the BLM and the 

state air permitting authority to minimize air pollutant emissions, including potential emissions of 

hydrogen sulfide during well drilling and well maintenance. Such measures as monitoring and abatement 

would ensure that hydrogen sulfide emissions would not result in unsafe levels and would prevent 

potential nuisance odors if hydrogen sulfide is present in the geothermal resource.

Vegetation

Summary and Response

Issue: Commenters said restoration of vegetation after geothermal development is costly and often 

increases the likelihood for the infestation and spread of invasive plant species. 

Response: The DEIS includes BMPs and mitigation measures in Appendix C to reduce surface 

disturbance and the likelihood of invasive weed introduction and spread and to encourage the success of 

reclamation. BMPs call for preparing a habitat restoration plan to avoid (if possible), minimize, or 

mitigate negative impacts on vulnerable wildlife, while maintaining or enhancing habitat values for other 

species. Such a plan would identify revegetation, soil stabilization, and erosion reduction measures to

ensure that all temporary use areas are restored. The plan would require that restoration occur as soon as 

possible after activities and will reduce the amount of habitat converted at any one time and speed up the 

recovery of natural habitats.

Fish and Wildlife

Summary and Response

Issue: Commenters said geothermal leasing and development would fragment wildlife habitats, resulting 

in impacts on the overall biodiversity of the SFNF ecosystem, and that the Forest Service should ensure 

that the proposed geothermal impacts are consistent with the Comprehensive Wildlife Conservation 

Strategy for New Mexico, which is being revised.

Response: Impacts on wildlife habitats are discussed in Section 3.12.2 of the DEIS. If consent to leasing 

were to occur, the BLM and Forest Service would coordinate with other state or federal agencies, 

including the New Mexico Department of Game and Fish, during site-specific planning, as described in 

DEIS Section 2.2.2.

Threatened and Endangered Species and Special Status Species

Summary and Response

Issue 1: Commenters said the Forest Service should consult with the USFWS, in accordance with Section 

7 of the Endangered Species Act, to determine whether the proposed action may jeopardize any federally 

listed species.

Response 1: The Forest Service acknowledges its responsibilities under Section 7 of the Endangered 

Species Act. It did not consult with the USFWS during this EIS process due to the programmatic nature of 

the decision and lack of information on the location of specific disturbances. Without project-specific 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

24

details, the USFWS cannot prepare an incidental take statement. As a result, Section 7 consultation will 

occur on a project-specific basis when details regarding project location and proposed disturbances are

known.

Issue 2: Commenters said the Forest Service should better analyze the cumulative impacts of geothermal 

leasing on threatened and endangered species, and that cumulative impacts may be significant, given the 

number of large-scale projects that occur in sensitive habitats over many years. 

Response 2: The Forest Service analyzed cumulative impacts on threatened and endangered species and 

special status species in Section 3.13.2 of the DEIS and augmented this analysis in the FEIS. The DEIS

and FEIS consider the present impacts of past actions, to the extent that they are relevant. Also considered 

in the EISs were present and reasonably foreseeable (not highly speculative) federal and nonfederal 

actions, taking into account the relationship between the proposed alternatives and these reasonably 

foreseeable actions. 

This discussion summarizes CEQ guidance from June 24, 2005, stating that “...generally, agencies can 

conduct an adequate cumulative effects analysis by focusing on the current aggregate effects of past 

actions without delving into the historical details of individual past actions.” This is because a description 

of the current state of the environment inherently includes the impacts of past actions. Information on the 

current conditions is more comprehensive and more accurate for establishing a useful starting point for 

cumulative impacts analysis. The Forest Service explicitly described its assumptions regarding proposed 

projects and other reasonably foreseeable future actions in Section 3.3 of the DEIS. 

The cumulative impacts analysis was based on the broad nature and scope of the proposed geothermal 

leasing options under consideration at the programmatic level.

Issue 3: Commenters said the Forest Service should better analyze the direct and indirect impacts of 

geothermal leasing on threatened and endangered species and that noise disturbance could cause impacts,

and geothermal development could affect Mexican spotted owl breeding and foraging.

Response 3: The Forest Service analyzed impacts on threatened and endangered species in Section 3.13.2 

in the DEIS. Specific impacts on the Mexican spotted owl are described in this section under Alternative 

2:

“Noise from geothermal activities can have impacts on [Mexican spotted owl]. Principal 

sources of noise from geothermal activities would be trucks, drilling rigs, and heavy 

machinery. The most impacts associated with noise could occur if critical life cycle 

activities (e.g., mating and nesting) were disrupted. Disturbance during mating, nesting, 

or rearing of young can cause MSO to abandon mating and nesting activities and can 

strand young, leaving them susceptible to predation and starvation.

“On the basis of the types of equipment that would likely be used, such as drilling rigs 

and graders, the noise levels at distances of less than 400 feet from binary power plants 

would be above 65 dBA. Noise levels from production wells would exceed the 65 dBA 

limit only at a distance of less than 69 feet.

“The location and timing of geothermal activities (especially exploration and 

development) may affect the migratory and other behavioral activities of MSO. They may 

cease foraging, mating, or nesting or may vacate active nest sites in areas where 

geothermal activities are occurring; MSO may permanently abandon the disturbed areas 

and adjacent habitats. In addition, exploration and development may affect movements; 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

25

for example, they may avoid a localized migratory route because of ongoing construction. 

However, drilling and construction would be prohibited between March 1 and August 31 

in MSO-designated [Protected Activity Centers]. Implementing TLs in designated PACs 

would minimize impacts on MSO during critical nesting and breeding periods.” 

The FEIS analysis was augmented to add additional literature citations.

Issue 4: Commenters stated that geothermal leasing alternatives in the DEIS do not adequately protect

several threatened and endangered species, including Mexican spotted owl, New Mexico meadow 

jumping mouse, and Jemez Mountains salamander. Moreover, future geothermal development could 

negatively impact habitat for these species. Commenters suggested that habitat for these species, 

including Protected Activity Centers for Mexican spotted owl and critical habitat for Jemez Mountains 

salamander, should be NSO, without waivers, exceptions, or modifications. 

Response 4: The Forest Service considered a reasonable range of alternatives during the geothermal 

leasing planning process, in full compliance with NEPA. The CEQ regulations (40 CFR, Subpart 1502.1) 

require that the Forest Service consider reasonable alternatives that would avoid or minimize adverse 

impacts or would enhance the quality of the human environment. While there are many possible 

alternatives or actions to manage National Forest System land in the project area, the Forest Service fully 

considered the issues developed during the scoping process. This was done to determine a reasonable 

range of alternatives, including development of stipulations. 

The DEIS includes a stipulation to protect designated or proposed critical habitat for New Mexico 

meadow jumping mouse, Mexican spotted owl, and Jemez mountain salamander (DEIS Appendix B). 

Stipulations to protect other resources may provide incidental protection to threatened, endangered, and 

sensitive species.

The stipulations were selected for inclusion based on a comprehensive review of the SFNF Forest Plan, 

program guidance, geothermal development, published data on geothermal development impacts, industry 

standards, and best professional judgment. The intent of these stipulations is to provide a level of 

protection for resource values or land uses by restricting lease operations during certain times or at certain 

locations or by mitigating unacceptable impacts, to an extent greater than under standard lease terms or 

conditions. 

As described in Section 2.2.2 of the DEIS, an exception, waiver, or modification may not be approved 

unless the BLM Authorized Officer determines that the factors leading to the stipulation’s inclusion in the 

lease have changed sufficiently to make the protection provided by the stipulation no longer justified, or 

the proposed operations would not cause unacceptable impacts (43 CFR, Subparts 3101.1-4). Stipulations 

with no exceptions, waivers, or modifications were considered but eliminated from further analysis, as 

described in Section 2.4.3:

“This alternative was considered but eliminated from detailed analysis because some 

stipulations are based on resources that are not permanent, fixed geographic points, or 

polygons and may change over time. For example, an NSO stipulation would be applied 

to designated critical habitat for species listed under the [Endangered Species Act], and a 

[timing limitation] stipulation would be applied to elk calving areas. Species may become 

delisted over time, or elk calving areas may change, based on forage availability. 

Nonconsent for resources that are dynamic, such as those examples provided above, 

would not allow for adaptive management when circumstances change.”
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

26

The DEIS includes BMPs and mitigation measures in Appendix C to reduce impacts on threatened, 

endangered, and sensitive species and their habitats. In addition, all operations must comply with the 

Endangered Species Act, regardless of what stipulations or BMPs are in place. 

Cultural Resources

Summary and Response

Issue 1: Commenters expressed concerns about protecting cultural resources, archaeological sites, 

traditional cultural properties, traditional use areas, historic buildings, and sacred sites. Commenters said 

that leasing and subsequent geothermal development are incompatible with the number and type of 

resources that could be impacted. Commenters expressed support for the resolution of the All Pueblo 

Council of Governors Resolution No. APCG 2015-11, requesting the designation of the Jemez Mountains 

as a traditional cultural property, and the closure of the entire SFNF to energy and mineral exploration.

Response 1: With this EIS, the Forest Service is programmatically evaluating lands that would be 

available and unavailable for geothermal leasing under each alternative and the stipulations that would be 

applied to these leases. The Forest Service would not consent to leasing as part of this decision. If the 

decision is to make lands available for geothermal leasing (i.e., Alternative 2 or 4 is selected), the BLM 

determines NEPA adequacy and independently prepares a separate decision document adopting or not 

adopting the Forest Service decision. Site-specific NEPA analysis would be prepared prior to any surface 

disturbance, which would identify any impacts on resources and appropriate mitigation, such as 

avoidance of cultural sites. 

Issuing a geothermal lease has no direct impact on cultural resources; however, it is a commitment of the 

resource for potential future exploration, drilling operations and development, utilization, and reclamation 

and abandonment. All of these actions are subject to further environmental review and permits during 

subsequent phases, as shown on Figure 1-3 of the DEIS. 

The Forest Service and the BLM would complete steps to meet cultural resource legal and procedural 

requirements before development begins, as outlined in the Section 106 process and the Region 3 

Programmatic Agreement (Forest Service 2003). These include consultation with the New Mexico State 

Historic Preservation Office and Native American tribes, Pueblos, or other traditional communities (DEIS 

page 3-121). Thus, there would be further site- and project-specific analysis and consultation before any 

potential geothermal exploration or development under Alternatives 1, 2, and 4. The BLM would 

complete cultural and tribal consultation requirements before site-specific exploration, development, or 

utilization. This would be completed during the leasing phase. 

Proposed NSO leasing stipulations under Alternatives 2 and 4 (DEIS Appendix B, Table B-1) would 

prevent surface occupancy at the following:

• Traditional cultural properties and Native American sacred sites, as identified through consultation

• Properties listed on or eligible for listing on the National Register of Historic Places, including 

National Landmarks and National Register Districts and Sites; also, additional lands outside the 

designated boundaries, to the extent necessary to protect values where the setting and integrity is 

critical to their designation or eligibility

• Areas that qualify for cultural resource protection, based on Forest Plan criteria (Planning Areas I, P, 

Q, R, and S)

Additional inventory and consultation will be conducted to determine the extent, the significance, and any 

adverse effects associated with leasing and subsequent development. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

27

The DEIS acknowledges the resolution of the All Pueblo Council of Governors Resolution No. APCG 

2015-11. This requests the designation of the Jemez Mountains as a traditional cultural property and the 

closure of the entire SFNF to energy and mineral exploration (DEIS page 3-26). The potential for impacts 

on these cultural resources is addressed in DEIS Sections 3.15.2 and 3.16.2. Alternative 3 is a no 

geothermal leasing alternative, which would be consistent with the resolution. Consultation on the 

entirety of the request is beyond the scope of this analysis and will be subject to further consultation by 

the Forest Service. 

Issue 2: Commenters said the Forest Service has not adequately considered information on the 

disproportionately high and adverse environmental impacts on pueblos (social impacts), if the Forest 

Service were to lease SFNF land.

Response 2: The analysis of impacts on environmental justice are in Section 3.18.2 of the DEIS. The 

Forest Service has concluded that the programmatic nature of this DEIS does not allow for analyzing 

specific environmental justice populations in the project area at this time. Site-specific considerations for 

environmental justice populations must occur to mitigate any disproportionately high and adverse impacts 

from geothermal development, in compliance with Executive Order 12898. The Forest Service has 

reviewed and revised the text to disclose the potential for environmental justice impacts that may be 

related to tribal interests and traditional cultural resources and uses. 

Tribal Interests and Traditional Cultural Resources

Summary and Response

Issue 1: Pueblo representatives commented that the Forest Service has not adequately considered 

information provided on the disproportionately high and adverse environmental impacts on pueblos if the 

SFNF were to ultimately adopt leasing of Forest land. These impacts are based on traditional uses and 

religious beliefs that would be impossible to mitigate and, thus, would be environmental justice impacts 

disproportionately affecting pueblo communities. 

Response 1: The analysis of impacts on environmental justice is in Section 3.18.2 of the DEIS. The 

Forest Service has concluded that the programmatic nature of this EIS does not allow for analyzing 

specific environmental justice populations in the project area at this time. There must be site-specific 

considerations for environmental justice populations in order to mitigate any disproportionately high and 

adverse impacts from geothermal development. This is in compliance with Executive Order 12898. The 

Forest Service reviewed and revised FEIS Section 3.18.2 to disclose the potential for environmental 

justice impacts that may be related to tribal interests and traditional cultural resources and uses.

Issue 2: Pueblo representatives commented that the full extent of impacts on pueblos are not 

acknowledged in the DEIS. The pueblo representatives identified impacts that are not merely “potential.”

If the SFNF were to approve any form of geothermal leasing, these impacts would occur for pueblo

communities in a manner that appreciably exceeds impacts on the general population. There would be 

impacts if geothermal resource development were allowed anywhere in the project area.

Response 2: “Potential” in this context referenced the fact that the Forest Service would not consent to a 

leasing request from the BLM as part of this decision. Any potential for impacts resulting from leasing or 

subsequent actions would be subject to focused analysis and consultation. Text in the FEIS was updated to 

clarify this information.

Issue 3: The pueblos provided additional information to the Forest Service after the release of the DEIS

as part of the ongoing landscape-scale ethnographic study of past and present uses by various pueblo and 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

28

other communities of the Jemez Mountains. The pueblos cannot give specific details about the sacred 

sites that are found throughout the project area, even though they would be impacted by any geothermal 

resource development. Springs throughout the project area are needed for ceremonial pilgrimages. The 

Jemez Mountains are connected to the caldera, both above and below ground. Harming any of these sites 

permanently alters the spiritual connection to ancestors at those places. Drilling would harm those 

connections by awakening the caldera and disturbing the interconnections to the rest of the Jemez 

Mountains traditional and cultural use areas. This would be the case, even if the project proponent were to 

use less-invasive advanced technology (i.e., directional drilling).

Response 3: The Forest Service will review additional information provided by the pueblos. This 

information will be incorporated, as appropriate, in FEIS Section 3.16.2, Tribal Interests and Traditional 

Cultural Resources, and throughout the FEIS. Specifically, the discussion of subsurface impacts from 

drilling will be added, if appropriate.

Issue 4: Commenters said this DEIS tiers to and incorporates the Record of Decision for the 

Programmatic EIS for Geothermal Leasing in the Western United States (BLM and Forest Service 2008), 

and that the Programmatic EIS is indefensible and must be rescinded, pending appropriate and lawful 

tribal consultation.

Response 4: Rescinding the 2008 Programmatic EIS is outside of the scope of this EIS. It is referenced 

for suggesting standard stipulations and does not implement decisions specific to the SFNF. The SFNF 

has met with and consulted the tribes and pueblos during the EIS process as described in Section 1.10 and 

1.11 and will continue to do so.

Issue 5: Commenters from one pueblo stated that there have been no tribal-specific meetings or any type 

of tribal consultation to discuss the DEIS. Commenters asserted that if leasing were approved, it would

have lasting irreversible and unmitigable negative impacts on the cultural values, traditions, and practices 

of the pueblos and tribes.

Response 5: The Forest Service consults on a government-to-government basis with Native American 

tribes. Tribal scoping activities, including tribal-specific meetings, have been ongoing since before the 

official start of the scoping period. This information was incorporated into the FEIS; see Section 1.11. The 

SFNF complied with the request for a meeting this pueblo on October 12, 2016. The agency will continue 

to consult with the pueblos on a government-to-government basis.

Visual Resources

Summary and Response

Issue 1: A commenter requested a more detailed account of indirect impacts on visual resources from 

exploration and development. Specific questions and suggestions about visual impacts are as follows:

• Are drilling rigs likely to be visible in this landscape and vegetation cover? What about during 

production? It seems in many cases the piping system once in production would not be visible.

• Would well pads be visible? If well pads are small enough, they may not be visible, and mitigation 

could limit size. 

• Power plants are likely to be visible from good distances; what about the vapor plume? Would it be 

visible year-round or only under certain conditions?

• Transmission lines in the DEIS are described as fairly short wooden poles with a 40-foot right-ofway. How visible are the poles and right-of-way likely to be in this landscape?
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

29

Response 1: The impact on visual resources are discussed in Section 3.17 of the DEIS. DEIS Section 3.2 

states: “Based on existing temperature gradient data, binary cycle power plants are most likely to be 

constructed in the project area. These plants operate at lower temperatures than flash steam plants or dry 

steam plants. Therefore, this analysis does not analyze the potential impacts of flash steam or dry steam 

geothermal plants.” As such, the assumption is that there would be no visual impacts from a vapor plume, 

because no vapor would be emitted. Additionally, visual analysis, including viewshed acres from the 

Caldera Rim and Redondo Peak, is included in Section 3.17.2.8. Text was added to the FEIS to describe

impacts on visual resources at each stage of geothermal development.

Issue 2: A commenter requested that the following assumption be added to strengthen analysis: Assuming 

spatially isotropic illumination and light of sight conditions, with no scattering or reflection due to 

aerosols, leaves, or other objects, the distance for lighting on a drill rig to diminish to the illumination of 

starlight and natural airglow on a clear moonless night (0.002 lux [Table 3-19 in DEIS]) is approximately 

10,000 feet, or 2 miles.

Response 2: The suggested assumption was added.

Issue 3: A commenter requested that text be corrected, as follows: Page 3-136, Section 3.17.2.3,

paragraph 5, sentence 20: The distance for oil rig illumination to the south is incorrect, due to an error and 

inconsistency in our April 28, 2016, letter. The sentence should be corrected to read “Using this 

information, the strongest direction that light shined from the source was south with 1.3 lux at 375 feet.”

Response 3: Text was amended to correct the error, except “shined” was replaced with “shone.”

Issue 4: Commenters were concerned about viewshed degradation, specifically impacting recreation on 

the rim trail planned for the Valles Caldera National Preserve.

Response 4: The Forest Service completed a viewshed analysis of impacts on the Valles Caldera (DEIS 

Section 3.17). Visible impacts on the Caldera Rim Trail and Redondo Peak are quantified in this 

discussion, to the extent possible, given the programmatic nature of this document. 

When an exploration, development, or utilization plan is submitted, the proponent provides projectspecific information, such as location, number of wells, and type of development. At that stage, 

cumulative impacts on the viewshed from Valles Caldera National Preserve would be identified through 

site-specific analysis or modeling. If possible, mitigation and monitoring would be applied to reduce 

those impacts.

Issue 5: A commenter made a request to extend the “closed to leasing area” to surround the private lands 

in the southeast corner of the Middle Unit. This would also protect such scenic areas as Mushroom Basin

and Ice Cave Canyon and access to San Antonio Hot Springs.

Response 5: Lands that are closed to geothermal development are based on legislation, regulation, or 

other authority. Stipulations placed on the lease can prevent certain development within certain protection 

zones. Under Alternative 2, a discretionary closure is proposed surrounding a 1-mile radius of natural hot 

springs, including San Antonio Hot Springs, in accordance with the 2008 Geothermal Leasing 

Programmatic EIS. Such areas would be closed to leasing under Alternative 3. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

30

Social Interests, Economics, and Environmental Justice

Summary and Response

Issue 1: Commenters stated that the Forest Service should require reclamation bonding if an operator 

were to declare bankruptcy or were to cease exploration and development. In addition, the Forest Service 

should require reimbursement for loss of income or damages to businesses and residents who might be 

affected by geothermal development.

Response 1: Bonding is required by regulations at 43 CFR, Parts 3214 and 3215. Bonding is also

included as a BMP in DEIS Appendix C, Section C.2.1. Reimbursement is beyond the authority of the 

Forest Service. 

Issue 2: Commenters stated that geothermal exploration and development may impact tourism and 

recreation on the SFNF, such as loss of heat and pressure in hot springs and loss of nature-oriented 

tourism.

Response 2: The DEIS provides an adequate discussion of the environmental consequences, including the 

cumulative impacts, of the presented alternatives. As required by 40 CFR, Subpart 1502.16, the DEIS 

provides a discussion of the environmental impacts of the alternatives, including the proposed action. For 

any adverse environmental impacts that the Forest Service could not avoid, it would consider the 

relationship between short-term uses of the human environment and the maintenance and enhancement of 

long-term productivity. It also would take into account any irreversible or irretrievable commitments of 

resources that would be involved in any proposal, should it be implemented. 

The DEIS addresses this issue in Section 3.18.2.4 by stating, “Recreation and tourism revenues might be 

reduced, but this would be limited to the construction phase of geothermal development. Hiking, hunting, 

wildlife viewing, sport climbing, and camping are all popular recreation activities in the area. Currently 

developed recreation facilities, special-use permit recreation sites, and areas with significant recreation 

use deemed incompatible with geothermal development would be closed to geothermal leasing. This 

would minimize impacts on current recreation and tourism revenues. Due to these stipulations and the 

dispersed nature of the popular activities, there would be minimal long-term impacts on revenues that 

come from recreation and tourism in the project area.”

The Forest Service believes the DEIS provides sufficiently detailed information to help it determine

whether to proceed with the preferred alternative or to make a reasoned choice among the other 

alternatives. In either case, the public would have an understanding of the environmental consequences, in 

accordance with 40 CFR, Subpart 1502.1. 

Issue 3: Commenters stated that geothermal development would cause numerous disruptions to minority 

and low-income populations, such as the Santa Clara Pueblo community; these impacts would be 

significant under NEPA. Earthquakes associated with geothermal development could disproportionately 

impact minority and low-income populations near LANL. Commenters recommend that SFNF use the 

Promising Practice Report (EPA 2016) to supplement the applicable requirements for considering and 

analyzing the environmental justice populations and tribes for each phase of the proposed project.

Response 3: Minority and low-income populations in the planning area are described in Section 3.18.1 of 

the DEIS. As described in DEIS Section 3.18.2, under each alternative, “The programmatic nature of this 

EIS does not allow for analyzing specific environmental justice populations in the project area at this 

time. Site-specific considerations for environmental justice populations must occur to mitigate any 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

31

disproportionately high and adverse impacts from geothermal development, in compliance with Executive 

Order 12898.”

However, additional information was incorporated into the analysis in the FEIS, based on the EPA 

Promising Practices for Environmental Justice Methodologies in NEPA Reviews (EPA 2016). This 

includes clarification of the definition of “minority population” and expanding the discussion of impacts 

on minority populations and pueblo communities. 

Issue 4: Commenters stated that geothermal development may have negative consequences on nearby 

communities that may not have the infrastructure or funds to accommodate an increase in population 

associated with project workers. Most benefits to nearby communities would be minimal and temporary. 

Communities would receive only small royalties and would not receive a decrease in utility costs. 

Response 4: Impacts on social interests, economics, and environmental justice are described in Section 

3.18.2 of the DEIS. As stated, in DEIS Section 3.18.2.4, Impacts Under Alternative 1, “A short-term 

increased demand for housing might also occur. Such an increase is not anticipated to create a significant 

burden on local housing or social service markets or induce a level of growth that the local communities 

do not have a capacity for. This is because the number of construction workers needed at any given time 

would vary throughout the completion of the project.”

This section in the DEIS also discloses the short-term and long-term economic impacts of geothermal 

electricity generation, including construction jobs and royalties (Table 3-32). 

Issue 5: Commenters stated that geothermal exploration and development raises numerous health and 

safety concerns, including the release of harmful vapors, reduced quality of well water, and increased

seismic activity.

Response 5: The DEIS addresses these issues in Sections 3.5.2, 3.9.2, and 3.18.2. The BMPs in Appendix 

C would be applied to reduce the likelihood for these impacts. Such BMPs include the use of control 

devices on drilling- and construction-related engines (to reduce air emissions), development of a health 

and safety program, and measures to avoid or minimize well contamination. 

Issue 6: Commenters stated that geothermal development could reduce property values in nearby 

communities, due to an increase in development and degradation of natural resources, such as water. 

Response 6: The DEIS addresses this issue in Section 3.18.2.4 by stating, “Property tax values of lands 

near or next to the geothermal power plant could be impacted by the perceived decrease in scenic value 

from the development. However, because geothermal plants are of small footprint and must be located 

near existing power lines, these affects would be minimal and short-term. This is because much of the 

disturbed area would be reclaimed within a few years after the completion of construction.”

Responses

Health and Safety

Summary and Response

Issue 1: Commenters expressed public health and safety concerns for neighboring communities 

associated with geothermal development, such as 329-Plutonium in the water, poisonous vapors, and the 

increased risk of fire.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Response 1: DEIS Appendix C includes measures to reduce the likelihood for impacts on public health 

and safety associated with geothermal resource development. These measures include those specific to 

public health and safety, water resources, air quality, and fire. Impacts on public health and safety from

degraded water and air quality are presented in DEIS Sections 3.9.2 and 3.10.2, respectively. The 

potential for increased risks of wildfires is presented in DEIS Sections 3.11.2 and 3.19.2. The Forest 

Service’s analysis led it to disclose the potential environmental consequences of the alternatives. As a 

result, the Forest Service has taken a hard look at the environmental consequences of the alternatives, as 

required by NEPA (40 CFR, Subpart 1502.16). This was to enable the decision-maker to make an 

informed decision. 

Issue 2: Commenters said that the Forest Service has not adequately analyzed the potential for the release 

of radioactive and hazardous materials at LANL caused by floods, earthquakes, and fires associated with 

geothermal development.

Response 2: This issue was not brought forward by Low Alamos County, a New Mexico state agency, or 

LANL. Impacts associated with seismic activity are described in Section 3.5.2 of the DEIS, and the 

potential for increased risks of wildfires is presented in DEIS Sections 3.11.2 and 3.19.2. An increase in 

flooding is not anticipated as a result of geothermal development. In Appendix C, the Forest Service has 

included measures to reduce the likelihood of impacts on public health and safety associated with 

geothermal resource development. This includes those measures specific to public health and safety, 

seismic activity, and fire. 

The site-specific likelihood for induced seismicity and fire would be addressed as part of the 

environmental analysis for the permitting process. All development, utilization, and reclamation would be 

subject to further site-specific permitting and environmental analysis. Appropriate site-specific mitigation 

would be developed, as necessary.

Issue 3: Commenters said workers also face health and safety risks from such events as explosions caused 

by the buildup of steam and large trucks driven up steep slopes.

Response 3: DEIS Appendix C, Section C.2.8 includes measures to reduce the likelihood of impacts on 

public health and safety from geothermal resource development. These impacts are presented in DEIS 

Section 3.19.2. Here, the Forest Service discloses the potential for individuals to be exposed to 

geothermal steam and vehicular accidents. The Forest Service provided an adequate analysis that led it to 

disclose the potential environmental consequences of the alternatives. As a result, the Forest Service has 

taken a hard look at the environmental consequences of the alternatives in the DEIS, as required by NEPA 

(40 CFR, Subpart 1502.16). This was done to enable the decision-maker to make an informed decision. 

Noise

Summary and Response

Issue 1: Several commenters raised concern about noise impacts from subsequent exploration and 

development of the lease.

Response 1: Noise impacts from geothermal exploration and development were analyzed in the DEIS, 

Section 3.20. Consenting to issue a geothermal lease has no direct impact on the environment; however, it 

is a commitment of the resource for potential future exploration, drilling operations and development, 

utilization, and reclamation and abandonment. All of these actions are subject to environmental review 

and permits. Because the location of future exploration and development is unknown, only general 

indirect impacts on geothermal systems are discussed. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

33

When an exploration, development, or utilization plan is submitted, project-specific information is 

provided, such as the location, number of wells, and type of development. At that stage, cumulative 

impacts from noise in the project area would be identified through site-specific analysis or modeling. If 

possible, mitigation and monitoring would be applied to reduce those impacts.

Additional information regarding vehicle noise impacts was incorporated under Section 3.20.2 in the 

FEIS.

Issue 2: A commenter noted that noise levels from infrequent noise sources have much less of an impact 

than continuous noise emitters of the same A-weighted decibels. The commenter requested that a sentence 

be added to the affected environment section of the text, as follows: “Impact areas of infrequent vehicles 

and gas-fueled pump-jacks are likely significantly smaller than those of a geothermal power plant; a 

relatively high 65 [A-weighted decibel] level at a great distance could result in significant impacts across 

large areas.”

Response 2: Noise impact analysis, including the area of impact, is provided in Section 3.20.2 of the 

DEIS. The FEIS was revised to clarify that noise impacts from geothermal operations would occur during 

both night and day.

Issue 3: A commenter requested an NSO stipulation to leases that would not allow drilling geothermal 

wells and constructing and operating generating facilities and associated long-term surface developments 

within 2 miles (10,560 feet) of any NPS-managed park unit boundary, and a CSU stipulation with a 

requirement that average noise level in any direction should not exceed 54 dBA at 1,320 feet.

Response 3: Table 3-20 of the DEIS describes stipulations and closures within a 1- and 2-mile zone 

around NPS-managed lands. A specific NSO lease stipulation would not be implemented within 2 miles 

of any NPS-managed park unit boundary. This is because most lands would be either closed to leasing or 

already subject to NSO stipulations, as quantified for each alterative in Table 3-20. Moreover, such a 

stipulation is not supported under Forest Service policy. 

BLM leasing regulations for noise are described in Section 3.20.1 of the DEIS. A CSU stipulation for 

noise levels to not exceed 54 dBA at 1,320 feet is not supported by existing Forest Service policy. 

Transportation and Access

Summary and Response

Issue 1: Commenters said the development of geothermal resources would violate the SFNF’s roadless 

plan.

Response 1: As described in Section 2.3 of the DEIS, IRAs would either be closed to geothermal leasing 

(Alternative 3) or be subject to NSO stipulations (Alternatives 2 and 4), with no exceptions, waivers, or 

modifications. As described in DEIS Section 3.4.2, there would be no direct impacts on these areas;

therefore, the EIS would be consistent with management of IRAs.

Issue 2: Commenters said the infrastructure on the SFNF is not adequate to handle increased traffic, and 

that more roads would be required if geothermal energy were developed, in order to accommodate traffic 

and equipment transport, thereby exacerbating congestion and traffic on the SFNF, particularly along 

Highway 4. It also would cause more noise and air pollution and safety issues, and would disturb wildlife 

habitat.
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Response 2: Impacts on traffic and roads are disclosed in Section 3.21.2 of the DEIS: “...these potential 

increases in congestion and traffic would mostly be temporary and limited to exploration and 

development, in contrast to the operational phase of geothermal development; this requires fewer large 

vehicles and would result in minor or negligible impacts on transportation or access. Such measures as 

traffic control plans, signage, and [timing limitations] could help to mitigate the temporary impacts on 

traffic and access during exploration and development (see Appendix C).”

The potential for vehicular accidents due to increased traffic on local roads is disclosed in Section 

3.19.2.3 of the DEIS. DEIS Section 3.20.2.3 was modified to acknowledge the temporary increase in 

noise associated with construction traffic.

Issue 3: Commenters said geothermal energy development would affect the Jemez Mountain Trail 

National Scenic Byway by increasing congestion and traffic.

Response 3: Impacts on the Jemez Mountain Trail National Scenic Byway are disclosed in Section 3.4.2 

of the DEIS: “Jemez Mountain Trail National Scenic Byway, 21.8 miles of which fall within the project 

area, could include minor, temporary impacts from congestion, resulting from large, long-wheelbase 

construction vehicle traffic during geothermal exploration and development.” Additionally, analysis was 

added to Section 3.4.2 of the FEIS regarding impacts on the Jemez Mountain Trail National Scenic 

Byway.

Issue 4: Commenters said all motor vehicles used for geothermal energy development should be subject 

to the same SFNF road closures and restrictions as the general public.

Response 4: In accordance with Forest Service Manual 2800, Minerals and Geology, an operator must 

receive advance approval to use existing roads that have been closed to the public through the plan of 

operations approval process. Requiring that all motor vehicles be subject to the same SFNF road closures 

and restrictions as the general public would be contrary to policy. 

Climate Change

Summary and Response

Issue 1: One commenter noted that geothermal power plants emit fewer greenhouse gases than other 

forms of energy production, and another commented that five 25-megawatt plants would not affect global 

warming.

Response 1: Section 3.22.2 of the DEIS described greenhouse gas emissions associated with geothermal 

power plant exploration, development, and operation. Table 3-37 provided a comparison of carbon 

dioxide emissions associated with geothermal power plants versus fossil fuel-powered plants. As noted in 

this section, “Geothermal power production creates less [carbon dioxide] per kilowatt-hour of electricity 

produced than burning fossil fuels. It would have a positive net impact on [carbon dioxide] emissions if 

used in place of fossil fuel extraction. Compared to coal and natural gas, geothermal energy has a smaller 

carbon footprint and lower gaseous emissions (Matek 2013).”

Issue 2: The EPA commented that the DEIS should estimate greenhouse gas emissions for each 

alternative. It recommended that the FEIS estimate the direct and indirect greenhouse gas emissions that 

would be caused by the proposal and its alternatives. The EPA also recommended that the FEIS identify 

and consider measures to avoid or reduce greenhouse gas emissions associated with the project. This 

would include reasonable alternatives and practicable mitigation opportunities. The agency further 

recommended that the FEIS disclose the estimated greenhouse gas reductions.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Response 2: Section 3.22.2 of the DEIS estimated carbon dioxide emissions associated with geothermal 

exploration (Table 3-35) and development (Table 3-36). There would be no direct greenhouse gas 

emissions from a leasing decision. Because the RFDS indicated the same level of development across 

Alternatives 1, 2, and 4, indirect emissions would be the same under each of these alternatives. 

Alternative 3 would not allow leasing, and no geothermal development or associated emissions would 

occur. 

As described in Section 3.22.2.4 of the DEIS, any BMPs or measures designed to reduce equipment and 

vehicle exhaust emissions to minimize impacts on air quality would also reduce greenhouse gas 

emissions. Because the DEIS evaluates potential development at a programmatic rather than projectspecific level, exact emissions or emission reductions are not known at this time.

Issue 3: A commenter said that the DEIS does not include consideration of future climate scenarios and 

how they may impact the proposal and its impacts. The commenter recommended that the FEIS describe 

potential changes to the affected environment that may result from climate change, and incorporate design

measures to improve resiliency to climate change, where appropriate. The commenter stated that the 

FEIS’s alternatives analysis should, as appropriate, consider practicable changes to the proposal. The 

purpose of this would be to make the FEIS more resilient to anticipated climate change. 

The EPA also recommended that the Forest Service determine whether the environmental impacts of the 

alternatives would be exacerbated by climate change. It stated that changing climate conditions can affect 

a proposed project, as well as its ability to meet the purpose and need presented in the DEIS. One such 

example is infrastructure that would be located in coastal regions and that may be affected by sea level 

rise. 

Another commenter noted that the Jemez Mountains are ground zero for climate change, as indicated by 

the extreme drying of the area.

Response 3: Because this is a programmatic level of analysis, the scope, scale, and timing of potential 

future projects is unknown at this time; however, a summary of future climate scenarios was added to 

Section 3.22.1 of the FEIS. An explanation of how these climate change scenarios may affect area 

resources was added to the cumulative effects discussion of these resources, notably water resources, 

vegetation, and biological resources. Future site-specific NEPA analyses will be undertaken at the 

exploration, development, and utilization phases for project-specific proposals; climate change resiliency 

will be addressed at that time. 

As described in Section 1.2 of the DEIS, one of the two needs for the proposed action is to respond to 

policy directives calling for clean and renewable energy. Renewable energy provides a means of meeting 

increased energy demand resulting from rising temperatures associated with climate change.

Fire

Summary and Response

Issue 1: Commenters said the limited fire suppression and emergency personnel in the area could limit 

the response to a wildfire caused by geothermal resource development.

Response 1: The Forest Service assumes that sufficient funding and BLM and Forest Service personnel 

will be available for implementing the decision. This assumption was added to Section 3.2 of the FEIS. 

The Forest Supervisor will consider the risk of fire, as disclosed in the EIS. The supervisor also will take 

into consideration the fire suppression and emergency personnel availability in the decision area. This will 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

36

come into play when the Forest Service decides if the proposed action should be implemented as 

proposed, modified by another action alternative, or not implemented at all. 

Issue 2: Commenters expressed concerns about the increased risk for wildfires, particularly caused by 

trees falling into power lines, and noted that this is especially a concern in an area that already has a high 

wildfire risk and that has experienced several major fires in recent years, some caused by downed power 

lines. Such fires threaten the natural environment, private property, and LANL.

Response 2: In Appendix C of the DEIS, the Forest Service included measures to reduce the likelihood 

for accidental fire associated with geothermal development. These measures are to establish fire safety 

evacuation procedures and to develop a fire management strategy. In addition, power line rights-of-way 

would be cleared of trees, which would reduce the likelihood for accidental ignitions caused by fallen 

trees.

The potential for increased risks of wildfires associated with the alternatives are presented in DEIS 

Sections 3.11.2 and 3.19.2. DEIS Section 3.19.2.4 states, “There would be a risk of human-caused fire 

from geothermal development. However, because power line rights-of-way would be cleared of trees, the 

risk of wildfire associated with trees causing downed power lines would be minor. This contrasts with

smaller service lines associated with residences, where the right-of-way owner may not clear trees at a 

long enough distance to prevent them from falling on the line.”

DEIS Section 3.11.2.8 discloses the past impacts from recent wildfires and how they relate to cumulative 

impacts. The mechanisms for which transmission lines can cause wildfires was added to Section 3.11.2. 

The Forest Service provided an adequate analysis that led to disclosure of the potential environmental 

consequences of the alternatives. As a result, the Forest Service has taken a hard look at the 

environmental consequences of the alternatives in the DEIS, as required by NEPA (40 CFR, Subpart

1502.16). This was done to enable the decision-maker to make an informed decision. 

Issue 3: Commenters requested that the Forest Service expand the issue statement for fire to include the 

potential for each alternative to contribute to fire risk and to the overall potential for wildland fire; the

impacts analysis should be expanded in a similar manner.

Response 3: The risk of accidental fire is discussed in DEIS Sections 3.19.2 and 3.11.2. The Forest 

Service revised the FEIS issue statement to include concerns about the potential for wildfires to increase. 

It augmented the FEIS analysis to include the relative risk of wildfire under each alternative.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

Appendix A: 

List of Commenters
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A-1

Appendix A: List of Commenters

Table A-1 lists those who submitted written comments on the SFNF geothermal leasing DEIS. 

Affiliations were assigned based on self-identifying information in the submission. Commenters who 

submitted comments on business, agency, or organization letterhead or who signed using their official 

agency title were considered to represent that organization. Submissions on the SFNF comment form 

provided at the DEIS meetings were assigned the affiliation that commenters noted on the form. All other 

letters were considered to be unaffiliated individuals. 

All comments received or postmarked on or before October 28, 2016, were included in this comment

report. The commenters are listed in alphabetical order by last name.

Table A-1. Commenters

First Name Last Name Affiliation

Michael Alois Read Citizen

Peter Aniello Citizen

Joni Arends Concerned Citizens for Nuclear Safety

Myron Armijo Pueblo Santa Ana

Mark Aspelin Citizen

Ernie Atencio National Parks Conservation Association

Susan Baca Seven Springs Association

Lawrence Baker Citizen

Sue Barns Citizen

Anne Beckett Citizen

Linda Bedre-Vaughn Citizen

Walter Bigbee Citizen

Bonnie Bonnlow Citizen

Stuart Bowling Citizen

Doug Bridgers Citizen

Judith Bronner Citizen

Rick Brown Citizen

Chantal Buslot Citizen

Judy Calman New Mexico Wilderness Alliance

Joanie Carlisle Citizen

Michael Chavarria Santa Clara Pueblo

Ana Chavez Citizen

Elizabeth Christine Citizen

Marc Coan Citizen

Susan Consolloy Citizen

Daisy Cortes Citizen

Therese Councilor Citizen

Loretta Crespin Citizen
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Table A-1. Commenters

First Name Last Name Affiliation

Janice Crouse Citizen

Jim Crow Citizen

Nicole D Citizen

Dulce Davidson Citizen

Cecil Dawkins Citizen

Debbie Densmore Citizen

Merle Derse Citizen

Deborah Domanski Citizen

Pat Duncan Citizen

Beth Enson Citizen

Jennifer Failla Citizen

Ruth Farbach Citizen

S Feinsod Citizen

Susanne Felser Citizen

Kristina Fisher Citizen

Victoria Flores Citizen

Margaia Forcier-Call Citizen

Joanne Forman Citizen

Nicholas Garcia Cochiti Pueblo

E Geouge Citizen

Iris Gersh Citizen

Bonnie Golden Citizen

Linda Gonzalez Citizen

Elaine Gorham Citizen

Donna Gorski Citizen

Jeanne Green Citizen

Rand Greenfield Citizen

Carlsen Griffin Citizen

Gerry Hall Citizen

Sandra Hamilton Citizen

Charles Harrison Citizen

Brook Hemenway Citizen

Marilyn Hoff Citizen

Cathy Hope Citizen

Robert Houston US Environmental Protection Agency

Richard Ito Citizen

George Jiracek Citizen

Catherine Jobling Citizen

Craig Jolly Citizen
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Table A-1. Commenters

First Name Last Name Affiliation

Harrison Jones Citizen

Harold and Angie Keene Citizen

Greg Kendall Citizen

James Kenny Citizen

Janis Kenny Citizen

Rebecca Knight Citizen

Leslie Kuhn Citizen

Phyllis Landis Citizen

Nan Laney Citizen

Melissa Larson Citizen

Michael Lawler Citizen

Kathi L'Belle Citizen

Ingrid Lienbenberg Citizen

Richard Lincoln Citizen

Moscrelle Linda Citizen

Eyia MacCallum Citizen

Judy Macfarlane Citizen

Craig Machemehl Citizen

Brian Machemehl Citizen

Jeannie Magill Citizen

M Mangan Citizen

Keith McHenry Food Not Bombs

Robert McLean Citizen

Susan Meyers Citizen

Hannah Millisa Citizen

Charlotte Minter Citizen

Rheta Moazzami Citizen

Abril Mondragon Citizen

Lucy Moore Citizen

Kathryn Mullen Citizen

Nekrasikov Citizen

John Nelson Department of the Interior

Carilene Newby Citizen

Jean Nichols Citizen

Whitney Nieman Citizen

Rebecca Oertel Citizen

Gina Ogorzaly Citizen

Jennifer Olson Citizen

John Parker Citizen
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table A-1. Commenters

First Name Last Name Affiliation

Chaya Patchell Citizen

Diane Pawliczek Citizen

Elise Peixotto Citizen

Janet Phillips Citizen

Judy Pointer Citizen

Victoria Prince Citizen

Jean Public Citizen

Richard Rael Citizen

Catherine Ralston Citizen

Arielia Raymond Citizen

Deborah Reade Citizen

Dolores Rightley Citizen

Beth Robinson Citizen

Helen Rynaski Citizen

Roberta Salazar Citizen

Veronica Sandoval Citizen

Michael Sandoval Pueblo San Felipe

Jeanne Shaub Citizen

Sabine Shurter Citizen

Virgil Siow Pueblo of Laguna

Donald Smith Citizen

Gary Smith Citizen

Jane Snyder Citizen

Doug Sporn Citizen

Sara Stewart Citizen

David Strip Citizen

Adam Sweet Citizen

Jerry Torres Citizen

Sacha Traister Citizen

Steve Traverse Citizen

Patti Tronolone Citizen

Ann Tuomey Citizen

Brittney Van Der Werff Citizen

Angelique Vargas Citizen

Evalinda Walrack Citizen

Ryszard Wasilewski Citizen

Marcia Weese Citizen

Jeanne Wheeler Citizen

Robert Wilson Village of Jemez Springs
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table A-1. Commenters

First Name Last Name Affiliation

Twila Wilt Citizen

Franz Wood Citizen

Dean Woods Citizen

Jackie Woolston Citizen

Bryan Wyberg Citizen

Jania Zukovich Citizen
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Appendix B: 

Comments by Process Category and 

Resource Category
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Appendix B: Comments by Process Category and 

Resource Category

The SFNF received 623 discrete comments from submissions received during the comment period on the 

draft EIS. The SFNF then classified these comments by process category and by resource category. This 

appendix includes comments for each process category and for each resource category. Comments are 

included verbatim from the comment letters; however, any extraneous information not considered a 

comment in the letters is not included here. Duplicate comments, such as identical comments in form 

letters, are excluded. 

Tables in this appendix are listed below.

Table Page 

Table B-1. Land Use and Special Designations (including Inventoried Roadless Areas)............................ 2

Table B-2. Geologic Resources .................................................................................................................... 3

Table B-3. Energy and Mineral Resources................................................................................................. 13

Table B-4. Water Resources and Quality.................................................................................................... 15

Table B-5. Air Quality and Air Quality Related Values............................................................................. 24

Table B-6. Vegetation................................................................................................................................. 25

Table B-7. Fish and Wildlife ...................................................................................................................... 26

Table B-8. Threatened and Endangered Species and Special Status Species............................................. 27

Table B-9. Cultural Resources.................................................................................................................... 30

Table B-10. Tribal Interests and Traditional Cultural Resources............................................................... 32

Table B-11.Visual Resources...................................................................................................................... 35

Table B-12. Social Interests, Economics and Environmental Justice......................................................... 37

Table B-13. Health and Safety.................................................................................................................... 42

Table B-14. Noise ....................................................................................................................................... 44

Table B-15. Transportation and Access...................................................................................................... 45

Table B-16. Climate Change....................................................................................................................... 46

Table B-17. Fire .......................................................................................................................................... 47

Table B-18. Recreation ............................................................................................................................... 49

Table B-19. Climate Change....................................................................................................................... 50

Table B-20. Soil Resources......................................................................................................................... 51

Table B-21. Comments Related to the Timing and/or Scope of the Proposal/Process............................... 52

Table B-22. Grammar, Punctuation, Spelling, or Minor Edits to Text, Tables, or Figures........................ 55

Table B-23. General Comments Related to this Planning/Analysis Effort................................................. 57

Table B-24. Recommended Studies or Reports to Review and Requests for Data .................................... 74

Table B-25. Comments Related to Planning Regulations........................................................................... 76

Table B-26. Comments that Propose a New Alternative, or Discuss Deficiencies in Existing 

Alternatives......................................................................................................................................... 79

Table B-27. Comments Specific to the Purpose and Need for Action........................................................ 82

Table B-28. Comments Regarding Jurisdiction or Authority ..................................................................... 83
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Table B-1. Land Use and Special Designations (including Inventoried Roadless Areas)

Wilderness evaluation - A consent determination under the proposed action of the geothermal EIS would potentially 

conflict with the on-going (phase 2) evaluation of wilderness land designations in the Santa Fe National Forest.

When we studied the map during scoping, it appeared to us that there were portions of eight IRA’s inside the 

proposal: Youngsville, Pueblo Mesa, Canones Creek, Polvadera, Peralta Ridge, Alamo Canyon, West Mesa, and 

Holiday Mesa (see Appendix A). In the DEIS, SFNF states that there are portions of seven IRA’s inside the proposal: 

Youngsville, Pueblo Mesa, Canones Creek, Polvadera, Virgin Canyon, Peralta Ridge, and Alamo Canyon (DEIS 

page 3-10). Our map does not include Virgin Canyon, and SFNF appears not to be considering Holiday Mesa or 

West Mesa. This should be clarified. 

There are also lands with wilderness potential within the proposed leasing area, and their wilderness qualities would 

be destroyed by geothermal development -- something which was not considered in the DEIS. Geothermal 

development occurred in this area 30 years ago and its negative impacts can still be seen today on the Valles 

Caldera national preserve. The Forest Service does not have the budget or staffing to manage leasing in the way that 

would be required to protect these irreplaceable resources if geothermal leasing is allowed to occur. 

“The Wilderness Alliance believes significant portions of the proposal area may qualify for wilderness designation and 

an inventory is a requirement of the forest plan revision process in which SFNF is also currently involved.”

Containing critical inventoried roadless areas; it is the location of ancient, persistent ecosystems, it is home to a 

variety of precious endangered species

Wilderness evaluation - A consent determination under the proposed action of the geothermal EIS would potentially 

conflict with the on-going (phase 2) evaluation of wilderness land designations in the Santa Fe National Forest. 

Would the consent determination effectively nullify any consideration of wilderness designations in adjacent areas of 

the Santa Fe National Forest?

The vast majority of the Valles Caldera has been retired from geothermal development by the recent decision to 

manage the area as a preserve under the National Park System. That leaves the western flank of the Caldera open 

to geothermal exploration and development. The west flank includes areas such as San Antonio Peak, San Antonio 

Hot Springs, and a number of established residential areas, such as Thompson Ridge and Rancho de la Cueva.
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Table B-2. Geologic Resources

Increasing Seismic Danger at LANL. The Defense Nuclear Facilities Safety Board (DNFSB) has dedicated much of 

its oversight of LANL on the potential increasing seismic risk to the facilities handling radioactive materials, including 

the Plutonium Facility (PF-4) at Technical Area 55 (TA-55). PF-4 stores the bulk of the plutonium at LANL, including 

large quantities of respirable plutonium. A millionth of a gram of plutonium in one’s lungs will cause cancer. The 

Board’s seismic concerns are broad. For example, In 2009, the Board made Recommendation 2009-2 “Los Alamos 

National Laboratory Plutonium Facility Seismic Safety,” which remains open/unresolved. The Board stated in its 

October 26, 2009 cover letter, “This Recommendation identifies the need to execute both immediate and long-term 

actions that can reduce the risk posed by a seismic event at the Plutonium Facility at Los Alamos National 

Laboratory.” The Recommendation states, “The Defense Nuclear Facilities Safety Board (Board) is concerned about 

the potential consequences of seismic events at Los Alamos National Laboratory’s (LANL) Plutonium Facility and the 

adequacy of the safety strategy currently being pursued to address these events. In particular, the mitigated offsite 

consequences predicated on a seismically induced large fire at this operating nuclear facility exceed the Department 

of Energy’s (DOE) Evaluation Guideline by more than two orders of magnitude. The Board believes this situation 

warrants immediate attention and action.” Page iii of the draft EIS lists the potential impacts from potential future 

geothermal leasing. Number One on the list is “increased risk of seismic activity and ground subsidence.” For CCNS, 

any activity which has the potential to increase the seismic activity in the region of LANL, the Valles Caldera and 

Jemez Mountains raise concerns about our basic safety and ability to live downwind and downstream of LANL. 

Geothermal leasing has the potential to increase the risk of seismic activity. The USFS, therefore, must accept 

Alternative 3 (No Leasing) in the Final EIS.

Geological Hazards and Seismic Risks: Geothermal development has an unknown amount of risk of negative seismic 

and geologic risks. 

Collectively these features represent unique geothermal resources that are found nowhere else in the State of New 

Mexico and in only a few locations in the United States, including Yellowstone National Park, Lassen Volcano 

National Park, a very small system in Dixie Valley, NV, and the Long Valley Caldera and the Geysers in California 

(these latter two degraded by geothermal development).6 Protecting these geothermal features from the unknown 

impacts of commercial geothermal development on adjacent lands is part of the mandate of the Valles Caldera 

National Preserve, established “to protect, preserve, and restore the fish, wildlife, watershed, natural, scientific, 

scenic, geologic, historic, cultural, archaeological, and recreational values of the area” (emphasis added)

6 Id.

The injection of fluids during hydroshearing can also cause microearthquakes with unpredictable effects on nearby 

landscapes. BLM. 2015. Reasonably Foreseeable Development Scenario: Santa Fe National Forest Geothermal 

Leasing EIS Project. Santa Fe National Forest, New Mexico. Unpublished report. BLM, New Mexico State Office, 

Santa Fe, New Mexico.

The Geothermal Steam Act of 1970 (GSA) governs the leasing of geothermal resources on public lands.12 Under the 

GSA, special consideration is given before geothermal leasing occurs near certain units of the National Park System 

determined as containing “significant thermal features.”

13 Upon receipt of an application for a geothermal lease, the 

GSA requires the Department of the Interior (DOI) to determine whether exploration, development, or utilization of the 

applied-for lands will injure an NPS site containing significant thermal features.14 If it is determined that the applied-for 

lease is reasonably likely to result in a significant adverse effect on significant thermal features, this lease may not be 

issued.15 If a determination is made that the lease is reasonably likely to adversely affect a significant thermal feature, 

a series of protective stipulations can be added to the lease if issued.16

As of the 2005 amendments to the GSA,16 units of the National Park System are listed as containing “significant 

thermal features,” requiring additional scrutiny for potentially-impactful leases.17 The GSA also sets out a procedure 

for the DOI to add national park sites to the list of sites with significant thermal features, after a public process the 

considers the quality and significance of the geothermal features.18 An example of the level of scrutiny given to 

national park sites, none of the more than 200 applications for geothermal leases for locations just west of 

Yellowstone National Park were approved because of concerns about the effect on the park of extracting subsurface 

fluids.19

12 30 U.S.C. §§ 1001-1027. 13 Id at §1026. 14 Id. at § 1026(c). 15 Id. at (C)(2). 16 30 U.S.C. § 1026(d). 17 Id. at (a)(1). These units are: Mount Rainier NP; Crater Lake NP; Yellowstone NP; John D. Rockefeller, Jr. 

Memorial Parkway; Bering Land Bridge NPres; Gates of the Arctic NP and Pres; Katmai NP; Aniakchak NM and 

Pres; Wrangell-St. Elias NP and Pres; Lake Clark NP and Pres; Hot Springs NP; Big Bend NP; Lassen Volcanic NP; 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-2. Geologic Resources

Hawaii Volcanoes NP; Haleakala NP; and, Lake Mead NRA. 18 Id. at (a)(2)-(3). 19 Steingisser and Marcus 2009 at 16.

The Sulphur Springs property is a privately owned 40-acre inholding surrounded by the Valles Caldera National 

Preserve. Several of the most unique geothermal features within the caldera are found here, including mud pots, 

fumaroles, and hot springs up to 189°F, and it is recognized as perhaps the best and most important example of 

geothermal activity in the region. NPCA is working to acquire ownership of the property and convey it to NPS 

jurisdiction, which will allow VALL to restore the site and allow for public access for interpretative and educational 

programs regarding these unique geologic resources. The acquisition would complete NPS ownership of all the land

within the boundaries of the Preserve, including the entire headwaters of the Sulphur Creek watershed, which is 

critical for consistency and continuity of the management of the Preserve’s caldera landscape. We believe that the 

potential impacts to the extraordinary resources within the Sulphur Springs inholding from geothermal development 

on SFNF lands just a few miles away remains an open question. In addition, the proposed infrastructure development 

required for commercial use of geothermal resources could make this property suddenly commercially viable and a 

target for purchase by a private speculator or industry. 

Induced Seismicity - HDR geothermal systems carry an inherent risk of causing earthquakes. A well-known incident 

of this happened in 2006 at a new HDR installation in Basel, Switzerland where an earthquake occurred eight days 

after they began injecting water. With this and other experiences, the industry now asserts such problems can be 

avoided by simply placing HDR geothermal operations away from known tectonic activity. The area covered in the 

EIS is in the Jemez Mountains, part of the Jemez lineament - a line of volcanic features stretching from the Rio 

Grande rift through Arizona. The project area is described as lying directly above the intersection of the Jemez 

Lineament and the Rio Grande Rift. Although the “super-volcano” lying beneath the nearby Valles Caldera has been 

dormant for 40,000 to 50,000 years, The region could certainly be characterized as tectonically active. There are 

several known faults beneath the project area and more than 50 earthquakes have been documented in the past 50 

years. While some scientists assert there is no way to predict if, or how much, induced seismicity will occur from HDR 

geothermal production, research at the Salton Sea geothermal facility has shown a correlation with how much water 

is injected and withdrawn and the amount of induced seismicity. It is noteworthy that the list of BMPs in Appendix C 

does not include any practices to measure seismicity levels and modify injection/withdrawal rates to help address any 

observed increases.

Cabins along Forest Road 126 in the Seven Springs area are all at risk of a rock fall or landslide originating on the 

steep slopes below the cliff faces on the west side of the road. A massive landslide could be triggered by an 

earthquake, itself a result of the hydro-fracking used for the geothermal development. Such a slide would also 

potentially cause devastating impacts to Forest Road 126 and the State Fish Hatchery.

6. While suggested that it is a nominal threat, the potential for earthquakes due to the proximity of know faults needs 

to be evaluated. 

Will extraction trigger VOLCANIC activity from the ‘fracking/extraction process’? Fracking has been known to do so. 

The caldera/volcano is relatively new in terms of history how likely is it to shift. We live a 20 min. drive SW from the 

caldera.

Considering the recent drastic increases in earthquakes in Oklahoma which one can not deny is directly correlated to 

increased fracking, and the potential to cause a volcanic eruption in the Caldera, I want no part of fracking in the 

Jemez Mountains.

Los Alamos Laboratory has the TA-55 plutonium facility not more than a mile from my home. What a disaster for me 

and all the residents around me, nay, the whole of Los Alamos County if fracking, even as far away as La Cueva 

caused an earthquake here. And God help us all if it should again open up the volcano in the Caldera, dormant now 

some ? 6 million? years! 

I am writing to express my opposition to any large scale geothermal development in the Jemez Mountain area. My 

understanding is that this would be done by breaking up the underground rock structure similar to what is done in 

“fracking”. Doing this is the Jemez Mountains is flirting with a mega-disaster. The Jemez Mountain caldera is a 

“supervolcano” that will erupt again sometime in the future. The last time it erupted it blew out rock past Los Alamos; 

the soft rock canyon formations around Los Alamos that the Native Americans utilized for shelter and storage 

because the natural “holes” could easily be hollowed out, were blown out of the Jemez caldera which is now the Valle 

Grande in this eruption. Can you imagine the devastation to populated areas nearby if this volcano were to be 

accidently reawakened? Furthermore, it is well known that there is radioactive waste improperly buried in the Los 

Alamos area, and nuclear materials are stored in facilities that are not earthquake proof. Even if a volcanic eruption 

doesn’t happen, earthquakes could very well be triggered, as they have been by fracking for natural gas, and even in 

much less geologically active areas. The presence of the radioactive material could greatly compound the disaster 

resulting from any volcanic or earthquake activity resulting from this operation.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-2. Geologic Resources

Some of these concerns were addressed in the DEIS and others were not. Of those that were addressed, the 

analysis is not encouraging. The DEIS states on page 3-17 that the project area lies above several faults and has 

experienced 54 earthquakes between 1962 and 2014. It also states that geothermal production can cause increased 

seismicity, but only when done in specific ways. It does not indicate how often occurs in those specific ways. Page 3-

20 talks about “enhanced geothermal systems”, which is essentially fracking, but does not discuss how likely that is. 

SFNF should analyze how often this procedure is used with other geothermal production so the public can have a 

better idea how likely this is. 

Unfortunately for all of us, SFNF has no control over how geothermal production would occur once it decides to allow 

leasing. Even land with NSO stipulations without exceptions can still be accessed underground. The DEIS further 

states on page 3-17 that USGS is working on a seismic model for the project area, which apparently was not 

available in time for the Draft EIS publication. We sincerely hope SFNF will wait for, and consult with, this model 

before making any final decisions about the proposal.

There have been clear results of fracking in Oklahoma - earthquakes increasing by 400%. Repeat - 400%!

This is, in itself, a danger to any area and community BUT consider how close the proposed horizontal wells are to be 

dug - 20 miles from Los Alamos; 20 miles from an area where tons of plutonium and other flammable, toxic materials 

are stored and used. The area sits above a known fault line.

Geothermal development could create dangerous seismic events. This is alarming on many levels but particularly 

due to the proximity of the proposed sites to Los Alamos National Labs which could create a nuclear hazard.

We are also aware of the likelihood of earthquake activity in the area due to the fracking and drilling. Obviously, 

earthquakes can also change and effect the flow of the hot water system under the ground. We would like to have 

assurances that earthquake activity will be considered a consequence of the drilling projects and not written off as 

some “act of God” under which they are not responsible for the results that effect our business. Earthquake activity 

can also be terribly dangerous for the older adobe buildings in the area such as the ones on our property. Truck traffic

rumbling past us on Highway 4 can degrade structures as well. If geothermal drilling is allowed in the forest, these are 

consequences that are likely to change our amazing area drastically.

Page 1-21 of DEIS: Administrative site withdrawals, Seven Springs (7 acres): Our cabin is situated on two acres in 

Seven Springs, directly east of Highway 126 along the Rio Cebolla. On the East and West sides of our property there 

are considerable rock formations. The Rio Cebolla is on the West side of our property and runs the width of our 

property

If you drive North on Highway 126 between Fenton Lake and the State Fish Hatchery, you will see the canyon is 

surrounded by a mountain of rock formations. It is a fact that geothermal drilling activity may cause minor 

earthquakes. Although small, there is a community (i.e., Seven Springs) that resides between the two mountains of 

rock. Continued seismic activity would be a disaster as over time the giant rocks will become lose and crash into the 

canyon below. Page 3-17 of the DEIS states “The report concludes that the rates of induced earthquakes are 

inherently variable and non-stationary and therefore are extremely difficult to predict on a multi-year basis.” In 

addition to destroying the community, there is a power line that also runs parallel to Highway 126. If the seismic 

activity dislodges boulders, that have the potential of weighing many tons, catastrophic forest fires are inevitable due 

to the fallen trees hitting the power lines as a result of the dislodged rocks.

Page 3-17 of DEIS, Geologic Hazards, Seismic Activity: During the September 3, 2016 meeting (i.e., Seven Springs 

Community potluck/meeting), I asked Larry Gore (Santa Fe National Forest Geologist) what kind of studies have 

been done locally regarding the potential of seismic activity (i.e., earthquakes) in the proposed development area. His 

response, “none.” Besides the exorbitant use of our State’s water resources this section alone in the DEIS is a red 

flag as to why this project should not move forward. Earlier in my comments I mentioned how our community is 

surrounded by mountains of rock formations. I know for a fact we are not the only ones. For example, the Village of 

Jemez Springs is surrounded by mountains of rock. Likewise Thompson Ridge and I could go on and on. The 

damage to our communities would be disastrous but the damage to our small communities would pale in comparison 

to continued seismic activity at our National Lab in Los Alamos. Human caused earthquakes occurring in Los Alamos 

could be disastrous to New Mexico and the Country as a whole. A quote from the DEIS “The report concludes that 

the rates of induced earthquakes are inherently variable and non-stationary and therefore are extremely difficult to 

predict on a multi-year basis (Petersen et al. 2015).” When you research the topic “geothermal drilling,” the one 

comment that always stands out is “because geothermal activity may cause minor earthquakes and land subsidence 

plants must be placed as far away from populated areas as possible.” Why would anyone put our State and/or 

Country at risk for a project with such limited potential. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-2. Geologic Resources

From the description that was given to me by Larry Gore, although this may be a geothermal project, it sounds a lot 

like fracking---pumping water into the earth at high pressure. I am very concerned that this proposed use, though 

“only water,” and only to produce geothermal energy, will produce earthquakes similar to those caused by fracking in 

Oklahoma. And in relative proximity to the Los Alamos National Laboratory!!! As if the fires near the lab a few years 

ago weren’t bad enough!! 

The area under consideration lies above several fault lines. Fracking has caused earthquakes wherever it has 

occurred, and even without fracking numerous earthquakes have happened within this particular area in the last fifty 

years. 

We have extreme concerns for our watersheds and aquifers; many studies have shown that the type of fracking 

required by binary power cycle plants greatly increases the risk of seismic impact in an area that is already highly 

prone to seismic activity. There are examples of this having happened at locations around the world where fracking is 

used. Even the “closed system” of a binary plant creates a level of disturbance, to include ground subsidence. 

Construction of geothermal power plants can affect the stability of land. In fact, geothermal power plants have led to 

subsidence (sinking and motion of the earth’s surface) in Germany, Iceland, Switzerland, and New Zealand. 

Earthquakes can be triggered due to hydraulic fracturing, which is an intrinsic part of developing enhanced 

geothermal system (EGS) power plants. Besides the fracking contributing to serious water issues, there is great 

potential for increased earthquakes in this dormant super-volcano’s system if the geothermal plants go on line. The 

proximity to Los Alamos National Lab (LANL) and its nuclear facilities alone would seem to eliminate the Jemez for 

geothermal plant consideration

I am VERY CONCERNED about the following ill-effects of FRACKING --which have not yet been frankly addressed 

by the SW-SF Forest Service.

1. What about the seismic sensitive areas in our State, including the Valle Caldera Preserve and National Park?

Induced earthquakes caused by lubrication of faults when waste fluid is reinjected into the rocks. Rybach, 2003 

shows considerable increase in frequency of earthquakes near geothermal sites. As the original stewards of Cochiti 

ancestral domain (map attached), it is in our duty and responsibility to protect our critical habitat for our future 

generations. Our opposition of the proposed exploration / extraction of geothermal energy is not merely for our 

community, but with the greater aspect of life that will be negatively impacted. In the best interest of Cochiti Pueblo 

and those that hold the Jemez mountains in reverence we request that the Jemez mountains, Santa Fe National 

Forest be closed to energy development, exploration and leasing due to the cultural value and resources found 

within. 

Most importantly, there should be no fracking done in this region, because there is too great a risk of increased 

seismic activity, like has happened in Oklahoma where fracking has become widespread, earthquakes have 

increased by 400%! Los Alamos is in easy striking range of an earthquake caused by fracking in this region, and it 

lies atop some serious earthquake fault zones! Especially of concern are four metric tons of highly flammable 

plutonium stored at PF-4 in a building vulnerable to collapse, where jiggling from seismic activity could shake loose 

the containment equipment in a way that causes a fire, possibly causing a massive deadly radiation leak! This is a 

bad idea! Don’t do it! Not in my backyard, not anywhere! 

Considering the maps from the DEIS for Geothermal development in the Jemez, one can see that the boundaries 

being considered include areas only 20 miles from the boundary of Los Alamos Labs. The primary concern here 

regarding fracking for geothermal, which is described in the DOE’s Enhanced Geothermal System (EGS) factsheet 

(attached), is that fracturing underground structures can lead to increased earthquake activity. We have seen this in 

Oklahoma where earthquake activity has increased by 400%. In fact, just a few days ago, a 5.6 magnitude 

earthquake occurred in central Oklahoma that was felt in Dallas, TX and Kansas City, MO. (See attached article 

“Record-tying Oklahoma Earthquake Felt as far away as Arizona”, Associated Press, 9-3-16) The recent earthquake 

happened in a key energy-producing area that uses fracking techniques for oil & gas extraction. DOE acknowledges 

the potential for “induced seismicity” with geothermal fracturing. The Union of Concerned scientists also concedes 

“There is evidence that hydrothermal plants can lead to a greater earthquake frequency...especially for ‘hot, dry rock’

systems equivalent to hydraulic fracturing.” (National Renewable Energy Laboratory (NREL) 2012, Renewable 

Electricity Futures Study) However, the Forest Service DEIS does not address this concern. The Forest Service 

admits “The risk of induced seismicity in the project area cannot be accurately predicted at this time.” (p3-17, DEIS or 

79 of 326 pgs) Also, “No seimogenic indices have been developed,” and “Seismic events related to geothermal 

reservoir injection could cumulatively contribute to seismic events triggered by multiple operations...the risk cannot 

be assessed at this time.” (p 3-22 DEIS) 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-2. Geologic Resources

From a March, 2011 article in the SF New Mexican, Roger Snodgrass reports: “At Los Alamos National Laboratory, 

nuclear safety issues have been complicated with seismic concerns, as geological studies have uncovered an 

increasingly precarious underground structure. Beginning in 1972, LANL made efforts to understand the seismic 

hazards on site. By 1987, LANL scientists were estimating that characteristic large earthquakes from onsite faults 

could range from Richter magnitude 6.5 up to as much as 7.8...As faults were mapped in more detail in the late 

1990s and found to run near and even beneath some LANL nuclear facilities, concern as to the possible magnitude 

and frequency of LANL earthquakes increased. A survey found a number of LANL buildings to be at considerable risk 

of earthquake-induced collapse.” “Then in 2007, NNSA issued a new detailed assessment of seismic hazard that was 

found to be considerably greater than the optimistic 1995 figures.” The new information found in the 2007 

Probabilistic Seismic Hazards Analysis increased projected seismic consequences at LANL by 50%. In its 2012 letter 

to LANL, the Defense Nuclear Facilities Safety Board, responsible for safety oversight of the nuclear weapons 

complex, addressed adequate seismic safety precautions in the current plutonium facility PF-4. The letter cites a 900 

rem dose to exposed population as a worse-case scenario in the event of a quake and resulting fire at PF-4. 900 

rems is double the lethal dose expected to cause death to 50% of an exposed population within 30 days. “The large 

plutonium inventory of PF-4, coupled with the facility’s proximity to the public, creates the potential for very high 

offsite dose consequences if the building were to collapse”, says the DNFSB. The DNFSB, over the years, has made 

practical recommendations to remedy structural and internal flaws, such as relocating ignition switches outside of 

gloveboxes (duh), but here is another excerpt from the Jan. 3, 2013 DNFSB letter: “The Defense Nuclear Facilities 

Safety Board (Board) remains deeply concerned with the seismic safety posture of the Plutonium Facility (PF-4) at 

Los Alamos National Laboratory. The Board believes a recent analysis performed by the laboratory’s contractor 

demonstrates that PF-4 is vulnerable to structural collapse. The large plutonium inventory of PF-4, coupled with the 

facility’s proximity to the public, creates the potential for very high offsite dose consequences if the building were to 

collapse. Structural upgrades necessary to fix the PF-4 vulnerabilities are currently projected to take several years to 

complete. In the interim, the potential for very high dose consequences remains.”

In 2009, the Board issued “Recommendation 2009-2, Los Alamos National Laboratory Plutonium Facility Seismic 

Safety, to focus Department of Energy (DOE) and National Nuclear Security Administration (NNSA) management 

attention on the need to improve the seismic safety posture of PF-4. “The Board acknowledges that seismic 

remediation measures have been taken at PF-4 since 2009; however, existing measures would be largely defeated

by a collapse of the PF-4 structure.” In response to the Board’s Recommendation 2010-1, Safety Analysis 

Requirements for Defining Adequate Protection for the Public and Workers, the Deputy Secretary of Energy, in a 

letter dated July 19, 2012, established guidance for evaluating these types of situations where new information 

indicates the existing control strategy of a facility is no longer viable to keep postulated offsite consequences from

exceeding the DOE Evaluation Guideline of 25 rem Total Effective Dose Equivalent. “Based on the developments 

outlined above, the potential for very high offsite dose consequences in the event of a seismically-induced collapse, 

and the amount of time it will take to address PF-4 structural vulnerabilities, the Board strongly urges DOE to 

implement additional near term measures to reduce the potential consequences of a seismically-induced collapse of

PF-4.” (Recommendation 2009-2 to the Secretary of Energy, Los Alamos National Laboratory Plutonium Facility 

Seismic Safety, Oct. 26, 2009)

New Mexico has already seen several earthquakes in the past few years, one of them epicentered in Coyote, very 

near to Los Alamos, an area included in your plans for geothermal development, was a 3.8 magnitude quake in 2011. 

The USGS database shows that there is a 22. 5% chance of a major earthquake within 50 miles of Coyote within the 

next 50 years. There is a 29% chance of a 5.0 earthquake within 31 miles of Tesuque within the

next 50 years. Although the DEIS states: “Neither of the induced seismicity zones in New Mexico are in or near the 

project area,” Los Alamos National Laboratory (LANL) is in the same US Geological Survey (USGS) Seismic Hazard 

Zone as Trinidad, Colorado and Raton, New Mexico where recent moderate M 5.3 earthquakes occurred. The 

historical record over the past 40 years shows that M 4.5 earthquakes have occurred at LANL. In light of the 

dangerous seismic situation at LANL with the PF-4 and other facilities, as well as over 10 million cu.ft. of stored lethal 

legacy materials, the probability of “induced seismicity” from geothermal extraction is not a reasonable option. For 

seismic reasons alone, alternative 3, NO geothermal leasing, is the only rational option. The collapse of PF-4 and its

4 metric tons of stored plutonium could render much of New Mexico uninhabitable for possibly thousands of years 

and could annihilate the populations of Santa Fe and surrounding communities. Geothermal extraction in this area 

should not even be a consideration.

What permits are necessary for injection? NMED Ground Water Quality Bureau? The NM Energy & Natural 

Resources Department? Is this a project that falls under the NM Geothermal Resources Development Act? Will “well 

stimulation” (fracking) be done under 20.6.2.7 NMAC? 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-2. Geologic Resources

Why was it not made clear in the DEIS that the proposed method of extracting the heat to drive the turbines, supplied 

by the underground hot water of the Jemez Mountains, would occur by means of a process more commonly known 

as fracking? And since it is also commonly known, but seldom admitted by its perpetrators, that fracking causes 

earthquakes, why wasn’t the potential danger of earthquake caused by fracking in the Jemez Mountains 

acknowledged and discussed with utmost thoroughness in the DEIS? This omission is especially disturbing 

considering that the Jemez Mountains have long been shown to be fault-riddled and very vulnerable and susceptible 

to earthquake, even apart from the assault of fracking. Couple that with the fact that Los Alamos National Laboratory 

is located within two to ten miles of where, judging by DEIS maps, fracking could take place. There earthquake 

danger is already great: “By 1987, LANL scientists were estimating that characteristic large earthquakes from onsite 

faults could range from Richter magnitude 6.5 up to as much as 7.8.” (“Concerns grow over Plutonium Plant” by 

Roger Snodgrass, SF New Mexican, reprinted in the Taos News, March 24-30, 2011.)

A major concern mentioned in the DEIS is a seismic hazard. This was carefully monitored during water injection 

(sometimes massive) at depths of over 3 kilometers. Hundreds of microseismic events were recorded but the largest 

were only about magnitude 1.0 on the expanded Richter scale. They were typically -3 to 0 magnitude. The pressuresealed, confined boundary of the HDR reservoir, where the surrounding rock remains totally sealed, is believed to 

explain the low seismic risk (Brown et al., 2012, p. 32 – 33). 

Recent strong seismic activity attributable to energy exploration and development in states bordering New Mexico 

has driven home the real danger inherent in tampering with aquifers. With the presence of Los Alamos National Lab--

a high security nuclear facility manufacturing tritium, plutonium, and other lethal radioisotopes--within these same 

Jemez Mountains, upwind of Santa Fe, and mere miles as the crow flies from the proposed development area, the 

risks for any seismic activity at all are simply too great.

2. What provisions prevent fracking? Previous exploration in our area (Thompson Ridge) showed ample hot 

underground water but not in commercially viable reservoirs. Since that time, fracking has been developed by the oil 

industry to address just that problem and has also been shown to create seismic and water resource damage. I am 

opposed to any fracking in the proposed area, especially given the proximity to Los Alamos and it’s extensive 

radiation hazards from stored materials.

If you take the time to be aware and observe the middle of the caldera is rising, Twenty years ago the water would 

pool in the center. Now it goes out to the edges. which translates to magma rising.

This proposal is extremely close to LANL. It is very well documented that fracking (whether oil and gas or geothermal) 

contributes to earthquakes in the immediate area. It is also well documented that LANL is situated in proximity to a 

number of fault lines, and that nuclear materials at LANL are poorly secured. PLUTONIUM – one of the most 

dangerous and lethal toxins on Earth, a manmade material developed to kill – is stored (some say haphazardly) in 

LANL buildings (and has been dumped in the arroyos as well). LANL already puts all of northern New Mexico and 

beyond at a huge risk. Dixon, where I live, is certainly in the evacuation zone if a nuclear criticality were to occur at 

LANL. Santa Fe is a similar distance from LANL, and Taos is only slightly further away. Is it really worth risking New 

Mexico’s capital city and all of the surrounding areas? A nuclear “accident” is, functionally, forever, given the 

extremely long lived nature of nuclear materials (millions of years).

Earthquake risk will certainly be increased due to the disruption to the Earth’s mantle. In Lake County, California, 

where I lived for several years, we had as many as 20 earthquakes a day. Long term residents were extremely 

alarmed at the increased earthquake activity, which has been widely documented where ever geothermal and oil / 

gas fracking occurs. With the close proximity of LANL and it’s nuclear materials this alone should put a halt to the 

proposal to frack the Jemez.

According to what I learnt, the potential of earthquakes induced by geothermal drilling has to be considered and taken 

extremely seriously by the decision makers! I am quoting from Ms. Trenchik’s eMail: “ Induced Seismicity -

Geothermal development could theoretically increase the number of small earthquakes within the field caused by fluid 

reinjection.....” and “Hydrothermal Eruptions - In very active volcanic areas, hydrothermal eruptions are a potential 

hazard in high temperature liquid-dominated geothermal fields......”

The potential for seismic activity is also likely. Much of the area is loose and unstable, and the risk of landslide and 

damage to homes, many of which are built on steep slopes, is not worth the risk. Again, those affected would likely 

never see just compensation

Potential seismic activity related to geothermal reservoir injection could threaten the Los Alamos National Laboratory 

where highly flammable plutonium is stored. A disaster of this magnitude greatly outweighs any benefit of geothermal 

development. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-2. Geologic Resources

Page No.: 3-19 

Section, Paragraph, Table or Figure No.: Section 3.5.2.3 Paragraph 3

Comment: Assumptions of seismic risk reduction when re-injection of water is only valid if assumed water is returned 

to where it was removed. Re-injection into a different fracture zone could increase the potential for seismicity. 

Additionally, the reduced temperature (and therefore density and viscosity) of return fluids compared to reservoir 

fluids could initiate seismicity.

While geothermal energy itself may seem like a reasonable alternative to oil, coal and nuclear energy, using the 

Enhanced System of Fracking to get the hot water to the surface, isn’t a good or smart idea in an area that is already 

known for heightened seismic activity. Being that it is too close to Los Alamos, where so much dangerous waste is 

stored and produced, this is a very risky and short sighted idea. Studies have shown increased seismic activity in 

areas where fracking occurs. The proposed geothermal area lies above several faults. 54 earthquakes have occurred 

within the Santa Fe National Forest between 1964 and 2014. Putting all this together into a risk analysis, this just 

does not make good environmental sense.

Induced Seismicity - HDR geothermal systems carry an inherent risk of causing earthquakes. A well known incident 

of this happened in 2006 at a new HDR installation in Basel, Switzerland where an earthquake occurred eight days 

after they began injecting water. The industry now asserts such problems can be avoided by simply placing HDR 

geothermal operations away from known tectonic activity. The area covered in the EIS is in the Jemez Mountains, 

part of the Jemez lineament - a line of volcanic features stretching from the Rio Grande rift through Arizona . The 

project area is described as lying directly above the intersection of the Jemez Lineament and the Rio Grande Rift. 

Although the “super-volcano” lying beneath the nearby Valles Caldera has been dormant for 40,000 to 50,000 years, 

the region could certainly be characterized as tectonically active. There are several known faults beneath the project 

area and more than 50 earth quakes have been documented in the past 50 years. While scientist assert there is no 

way to predict if, or how much, induced seismicity will occur from HDR geothermal production, research at the Salton 

Sea geothermal facility has shown a correlation with how much water is injected and withdrawn and the amount of 

induced seismicity. It is noteworthy that the list of BMPs in Appendix C does not include any practices to measure 

seismicity levels and modify injection/withdrawal rates to help address any observed increases.

Cabins along Forest Road 126 in the Seven Springs area are all at risk of a rock fall or landslide originating on the 

steep slopes below the cliff faces on the west side of the road. A massive landslide could be triggered by an 

earthquake, itself a result of the hydro-fracking used for the geothermal development. Such a slide would also 

potentially cause devastating impacts to Forest Road 126 and the State Fish Hatchery. 

“In an Enhanced Geothermal System (EGS), fluid is injected into the subsurface under carefully controlled conditions, 

which cause pre-existing fractures to re-open, creating permeability... [allowing] fluid to circulate throughout the nowfractured rock and to transport heat to the surface where electricity can be generated.” (U.S. DOE Geothermal 

Technologies Office website)

“Extracting energy from hot rock usually involves a controversial technique commonly known as fracking. Studies 

have shown increased seismic activity in areas where fracking occurs.” “The proposed geothermal area lies above 

several faults. 54 earthquakes have occurred within the Santa Fe National Forest between 1964 and 2014. The 

nearby Los Alamos National Laboratory has been required to shore up its defenses in case of a seismic event.”

(“Geothermal Energy Plan Still on Table” by T.S. Last/Albuquerque Journal Staff Writer, July 22, 2016) (LANL has not 

yet complied.) “The critics don’t think it’s a good idea at all and especially not in one of the most

alluring parts of New Mexico for recreationalists, with a dormant volcano nearby, in a zone already considered at risk 

for earthquakes and with the presence of a nuclear weapons facility a few miles away. (“Geothermal Energy Plan Still 

on Table” by T.S. Last/ Journal Staff Writer, July 22, 2016) “By 1987, LANL scientists were estimating that 

characteristic large earthquakes from onsite faults could range from Richter magnitude 6.5 up to as much as 7.8.”

(“Concerns grow over Plutonium Plant” by Roger Snodgrass, Santa Fe New Mexican, reprinted in Taos News March 

24-30, 2011)

You will need to stop the destructive methods used to extract natural resources. Earthquakes correlate. Fracking is 

causation. 

Frankly, it should be a no-brainer that hydrofracking for energy is extremely dangerous anywhere near Los Alamos 

National Laboratory (LANL). Because LANL is riddled with earthquake faults and because many Lab buildings are not 

built to withstand earthquakes, it would be criminal to do anything to increase earthquakes in this area. This single 

fact should stop the project completely. The plutonium building, PF-4 is full of tons of plutonium. These materials are 

also flammable. This building is very vulnerable to seismic collapse and if that should happen, the dose possible to 

the surrounding communities and beyond could be lethal. This is particularly true if a fire were involved as plutonium 

is most dangerous when inhaled. In addition, many containers of the WIPP waste that exploded in WIPP are still at 

the Lab. These are also extremely vulnerable to further explosions and must be kept cooled to lessen this possibility. 

A disruption of the cooling system caused by an earthquake could also be lethal.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-2. Geologic Resources

During one of the information meetings it was suggested that we could just increase the seismic monitors in the local 

area and then if seismic activity started increasing, companies could “back off” on their fracking. However, though 

science is making the connection between fracking, water injection and earthquakes clearer every day, studies are 

also showing that even stopping water injection does not necessarily stop the earthquakes immediately. They can 

continue for weeks or even months

The Forest Service needs to do further scientific study before they can possibly say that they understand the risk to 

the public from man-made earthquakes at the Lab caused by this project. And to take even a tiny risk of increasing 

the possibility of any earthquake at LANL is reckless. I remind you that it was the Forest Service that lit the Cerro 

Grande Fire which burned over Lab property and came within some meters of Area G where the WIPP waste is 

stored. Since you are now considering additional reckless activity that could put us all at risk, you don’t seemed to 

have learned any lessons from your huge mistake with that fire. 

Seismic activity, which increases significantly in areas where fracking occurs, would be catastrophic in this sensitive 

area to people and wildlife for countless generations.

I urge to NOT lease Forest Service lands for the purpose of geothermal development in the Jemez mountains. This 

area is volcanic and has many fault zones -making geothermal development in this area environmentally risky 

especially given the proximity to Los Alamos and its plutonium complex. The Jemez Mountains are a beautiful and 

much loved recreational area. Such development would negatively impact recreation and would have a negative 

impact on wildlife species. 

The heat and energy proposed to be extracted for electricity generation are part of the Mountain, and are sacred. 

Irreparable harm will be caused if Alternative 3 is not selected. You, your staff and contractors have been informed of 

the risks of the proposed extraction or fracking for heat which could result in awakening the volcano (Ethnographic 

Overview of the Jemez Mountains for the Santa Fe National Forest, New Mexico, In Support of Environmental 

Analysis Associated with Geothermal Leasing and Cooperative Forest Land Restoration Projects January 22, 2016 at 

pages 111, E.2, E.8, 11.1, A.5 and E.6) You were also given this information in our October 12th consultation 

meeting.

Los Alamos National Laboratory is within 10 -30 miles of the proposed project area. Earthquakes are a known risk 

with geothermal energy development. There is no known way to mitigate the potential effects if an earthquake or 

series of earthquakes cause the radioactive and toxic metals and substances stored and used at LANL to be 

released. The Pueblos and Tribes of New Mexico and the state of New Mexico have contributed more than its fair 

share to national energy and security: Uranium mines (Jackpile Mine on the Pueblo of Laguna was in its day the 

largest Uranium mine in the world and is still awaiting remediation), nuclear bomb testing and development, four 

military bases including White Sands Missile Range- the largest installation of the United States Armed Forces, and 

two National Laboratories. Potential risks to legacy waste sites at LANL will create unmitigable Environmental Justice 

concerns and health risks to the pueblos and tribes who surround the project area as shown in the attached map from 

the Ethnographic Overview

Depending on the location of the drilling sites, significant volumes of water can be lost and accumulate downhole. 

This could result in damaging earthquakes as the existing faults are being lubricated and start slipping. The potential 

of earthquakes induced by geothermal drilling should be considered by the decision makers as major damage could 

occur to above-surface features for which the SFNF is responsible, on private lands, including businesses and 

residences located on private lands, and to facilities of Los Alamos National Laboratory.

The EIS document associated with possible geothermal developments states, “Increased risk of seismic activity.”

This would be extremely detrimental because the Jemez is the site of very recent volcanic activity and a super 

volcano. The Jemez is also home to one of the biggest Nuclear Laboratories in the world. I think that “increased 

seismic activity” near a nuclear facility would be a very bad thing! 

Third, seismic activity is very real in our region. If the sleeping giant, Valles Caldera, is reawakened, imagine the 

catastrophic event that could occur. This area is too geologically sensitive to flirt with disaster.

The proximity to Los Alamos and the volatility of fracking and the nature of seismic events related to geothermal 

reservoir injection are too great a risk for our area. In Oklahoma where fracking has proliferated earthquakes have 

multiplied 400%. At Los Alamos National Laboratory nuclear safety issues have been complicated with seismic 

concerns as geological studies have uncovered an increasingly precarious underground structure. There are 4 metric 

tons of highly flammable plutonium stored there at PF-4 —a building vulnerable to collapse atop serious earthquake 

fault lines.

This email is in reference to fracking for geothermal in the Jemez Mountains. This impact from this will be detrimental 

to our mountains, people and way of life. This can result in earthquakes due to the location of this being on fault lines 

in which this area has already be victim to several earthquakes since the 1960’s.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-11

Table B-2. Geologic Resources

“Increase risk of seismic activity.” (EIS) can impact our fragile historic structures. 

Abiquiu Dam is an earthen dam and as such very vulnerable to induced seismic activities. Take for example the 

Geyser Geothermal Field in California. With little to no history of earth quakes prior to fracturing and pressurizing 

afterwards hundreds of induced quakes. The field has been over produced as earthquakes increased water usage 

increased and steam production diminished. Look also at the situation in Trinidad CO. Earthquakes at the Trinidad 

Dam with the advent of waste injection well with probable damage to the dam. Any well fracturing... Hydraulic... 

whether for geothermal or oil and gas in this close proximity to the dam is like playing Russian roulette with lives 

down stream. According to the USGS map details of this area. There are several major fault lines running under and 

near Abiquiu Dam. not to mention the fractured nature of the outcropping water bearing formations. This is a highly 

communicating group water outcropped area and a valuable water recharge for the Rio Chama Watershed.... Which 

is already highly stressed and over allocated in New Mexico and Texas.... Rio Grande Compact.

The geologic formations in the area being coped near Abiquiu Dam are known to be Uranium bearing. This naturally 

occurring element is stable in these formation. But all bets are of f with drilling/fracturing shaking the Uranium loose 

into the water supply. Is the BLM prepared to mitigate this most toxic and deadly/accumulative element for millions of 

families down stream? UIC only covers 10,000 years. Plutonium is 240,000 years worth of damage. Not to mention 

the fallout if epithermal neutrons with depleted uranium sinkers are used during the logging/exploration drilling 

process. By the way, there are no banned forms of logging in New Mexico. This when combined with the naturally 

occurring 238-Uranium will go to 239 Plutonium...

It would be insanely irresponsible to attempt to frack the fault-riddled Jemez Mountains under any

circumstances—for geothermal electricity or any other purpose! And it is certainly prohibitive to do so in the vicinity of 

Los Alamos National Laboratory, where highly inflammable plutonium is stored in a building subject to seismic 

collapse that is located over known earthquake fault zones!!On top of that is the obvious threat to endangered 

species and other vulnerable plant and animal species in that wilderness area , the damage geothermal development 

there would do to Jemez Hot Springs, and the increased danger of wildfire in an area that has suffered from massive 

forest fires several times in the recent past. I remember well the last time that happened, when I and members of my 

immediate family and community voluntarily evacuated our homes and left the state, when an out-of-control wildfire 

narrowly escaped setting off radioactive explosions. . . that threatened the sustainability of life in this whole part of 

Northern New Mexico!!!

The environmental impact of developing several power plants there, with the added potential for geothermal and 

radioactive devastation in that particular area should be obvious—there is plenty of evidence from other fracking sites 

in the US to demonstrate the clear and present dangers (such as the 400% increase in seismic activity since fracking 

began in Oklahoma , to name just one well established correlation)—to prohibit any consideration of such an 

environmentally irresponsible activity. The US Forest Service, the BLM, and the Santa Fe National Forest have no 

business subjecting the land, the people, and the wildlife of New Mexico to such a fate.

This letter serves to register my strong opposition to any possible plans for geothermal ‘fracking’ in the Jemez 

Mountains vicinity. Los Alamos is very nearby & there are numerous faults throughout the area - I know from 

experience that there are many toxic storage places & dumpsites around, which pose an extreme hazard as is & 

‘fracking’ would only exacerbate the problem! The Jemez hot springs, Bandelier & Valles Caldera are all important 

tourist attractions - any accident would be a serious disaster for them, as well as the wildlife & whole environment in 

general.... I ask that you choose Alternative #3 NO Leasing - the only sane option in this case

This project is all the more notorious because of the possibility of using hydraulic fracturing as part of the geothermal 

energy production. Fracking amounts to devouring literally our country, digesting a small portion of the production, 

and spewing out the remainder of the geological section (and fluids) as excrement.

Environmental effects to this proposal can be very harmful to our water, wildlife, people and land. This plan for energy 

can be very dangerous causing earthquakes and chemical leaks into our water table. At Los Alamos National 

Laboratory, nuclear safety issues are sensitive to seismic events, which is possible with the examples of how 

“fracking” has proliferated earthquakes in other areas for example Oklahoma, Colorado, California, ect.

Forbid drilling (including angled, directional drilling and fracking operations) in the subsurface of the western Caldera.

I am and have been a resident of Los Alamos for 14 years. Though I don’t have it currently, I have had a cabin in 

Jemez Springs for about seven of those years. I am vehemently opposed to fracking in the Valles Caldera. If the 

Forest Service managers believe that they must facilitate sustainable energy through possibly destroying the Valles 

Caldera and possibly a good portion of all life for miles around, I think they are extremely misguided in their mission. 

To say that’s not sustainable is an extreme understatement. The plutonium on a fault line we are sitting on in Los 

Alamos, the record of earthquakes in the Valles Caldera since the sixties, earthquakes multiplied 400 times in 

Oklahoma since fracking began, all add up to the Forest Service’s setting us up for something that could make the 

Cerro Grande Fire look like the good old days, if they continue down this fracking path
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-12

Table B-2. Geologic Resources

What is the seismic activity on the Pajarito Plateau, Jemez Mountains, Valles Caldera? How is the seismic activity 

measured at each location? Are there “strong” seismic monitors? Are there “weak” seismic monitors. Who operates 

the monitors? Is that data public? If not, the entire data sets must be made public before any NEPA process goes 

forward. Monitoring seismic motion, after the fact of geothermal development and after the fact of an earthquake 

cannot mitigate the consequences, especially with LANL right next door. In fact, an Aug. 9th Santa Fe New Mexican 

article by Rebecca Moss reports that a May Government Accountability Office (GAO) report stated that “fire 

prevention features at the PF-4 plutonium facility could fail in the event of an earthquake.” (“LANL Nuclear Bomb 

Trigger Production Questioned”, SF New Mexican, Aug. 9, 2016)

I strongly object to the Geothermal EIS Project and to any fracking in the Santa Fe National Forest, especially not 

within 20 miles or so of Los Alamos Labs, which has a plutonium complex housing plutonium tubes. A quake there 

could release plutonium to the area, dangerous to animal and human life and all of nature. The area under 

consideration lies above several fault lines. Fracking has caused earthquakes wherever it has occurred, and even 

without fracking numerous earthquakes have happened within this particular area in the last fifty years.

It has come to my attention that there is an immediate need to permanently stop the possibility of geothermal 

development of the Jemez Mountains. It sounds like a disaster waiting to happen. It is well known that fracking is 

detrimental to the environment in numerous ways. Not only would the event of earthquakes become a regular 

occurrence, but the fact that the Los Alamos National Laboratory is nestled against the Jemez slopes on the Pajarito 

Plateau, and has four metric tons of plutonium residing in PF-4, a LANL building inadequately reinforced against 

earthquake, perched on fault-riddled terrain, is an insane proposition. Surely, with all the solar advantages New 

Mexico has, we could get our electricity in a safe and environmentally intelligent manner. Please consider the health 

and welfare of the people and wildlife of Northern New Mexico, and future generations. Don't make the mistake that 

was made in New Zealand as a result of geothermal development in the Wairakei basin, which resulted in the 

extinction of approximately 70 geysers and 240 hot springs. Our Jemez Mountains are a precious jewel of hot springs 

and other geological wonders. Don't destroy what the earth has provided. Once it is violated and altered, you can 

never go back and recover what was lost.

Not only is this area a designated and protected National Preserve because of its unique beauty, history and geology, 

which fracking would very likely destroy either by instigating earthquakes as has happened in numerous other fracked 

areas, and/or by poisoning the water that supports all life in the Valles, but the area is adjacent to Los Alamos 

National Lab-- can you imagine what catastrophe would ensue from an earthquake undermining the lab? CAN YOU 

SERIOUSLY BE CONSIDERING THIS? WHAT IS WRONG WITH YOU PEOPLE? I am completely and resolutely 

opposed to this idiotic idea and will fight it, as will my extended community.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-13

Table B-3. Energy and Mineral Resources

Renewable Energy Alternatives: there are plenty of opportunities to develop solar and wind technologies in areas of

New Mexico that are not as sensitive from an ecological, cultural, and geological perspective. 

The proposed action, Alternative 2, would close some of the land within the project area to geothermal leasing, and 

impose constraints such as timing limitations (TLs), controlled surface use (CSUs) or even No Surface Occupancy 

(NSO) stipulations on lands where geothermal leases are allowed. There is also a long list of Best Management 

Practices (BMPs) that would be required on an as needed basis. While protective if carefully applied, implementation 

of these limitations, stipulations and practices would be the joint responsibility of the lessee and the BLM/Forest 

Service. Based on tight federal budgets and existing staffing levels, there are likely to be insufficient agency 

resources to manage such a complex leasing program. Staffing levels are currently insufficient to enforce the Travel 

Management Plan and for oversight of the grazing program. This will allow an unacceptable degree of independence 

to the industry in choosing which BMPs are appropriate and provide insufficient regulatory oversight of operations. It 

would be difficult for the USFS to administer such a complex leasing program.

The estimated “levelized costs of electricity” for power plants entering service in 2020 (U. S. Energy Information 

Administration, 2015) clearly lists geothermal as most competitive economically. Some comparisons are listed below 

by % costs compared to geothermal (where 100% would be equal cost): a. Conventional coal: 215 % b. Conventional 

natural gas: 169% c. Hydroelectric: 188% d. Advanced Nuclear: 214% e. Solar Voltaics: 257%; Solar Thermal: 497% 

f. Wind: 166% 

Geothermal power generation has the highest capacity factor meaning the % of full-time that power is generated. 

Some numbers are: geothermal (97%), fossil fuels (70%), hydroelectric (55%), solar (28%), and wind (23%). 

HDR experiments run by LANL over a 22 year period at the Fenton Hill site in the Jemez Mountains yielded a wealth 

of information relevant to geothermal potential there (Brown et al., 2012). 

The HDR geothermal closed-system is now included in a more general category namely Enhanced Geothermal 

Systems (EGS) which includes the enhancement of an existing, conventional geothermal system. It is notable that 

the definition a “high-grade” EGS system is a temperature of at least 200o C at a depth of less than 4 kilometers. The 

composite temperature with depth profile that LANL measured in the HDR wells drilled outside of the Valles Caldera 

yielded 300o C at 4 kilometer depth (Brown et al., 2012, p. 270). This is substantially within the high grade category 

leading to high expectations for HDR success in the Jemez Mountains. 

The highly-respected JASON Program did a comprehensive assessment of EGS opportunities. Published in 

December 2013 their conclusion was that “EGS offers important opportunities for increasing the contribution of 

geothermal energy to U.S. power production: by a few-fold over the next few years and much more if this initial 

success is appropriately leveraged over subsequent years” (JASON, 2013 ). The first and only operating EGS facility 

in the U. S. (at Desert Peak, Nevada) was successfully announced by Ormat in April 2013. 

1. I do not believe a sufficient case has been made for the development of geothermal power plants in the area. New 

Mexico has ample clean energy resources (solar and wind) which do not involve potentially damaging access to 

underground resources.

Based on Table 2-3 (page 2-14) of the DEIS roughly half (339/647) of the surface disturbance is associated with the 

transmission lines. Since the only electrical transmission technology being considered involves surface disturbance I 

think that Figures 2-2 and 2-4 of Appendix B should reflect that any development area that must connect to the 

electrical grid through blue (subject to no surface disturbance) is not useable for geothermal electrical plant siting 

because the generation plant can not connect to the electrical grid. This situation severely constrains where 

geothermal plants could be sited within the areas under consideration

The proposed action, Alternative 2, would close some of the land within the project area to geothermal leasing, and 

impose constraints such as timing limitations (TLs), controlled surface use (CSUs) or even No Surface Occupancy 

(NSO) stipulations on lands where geothermal leases are allowed. There is also a long list of Best Management 

Practices (BMPs) that would be required on an as needed basis. While protective if carefully applied, implementation 

of these limitations, stipulations and practices would be the joint responsibility of the lessee and the BLM/Forest 

Service. Based on tight federal budgets and existing staffing levels, there are likely to be insufficient agency 

resources to manage such a complex leasing program. Staffing levels are currently insufficient to enforce the Travel 

Management Plan and for oversight of the grazing program. This will allow an unacceptable degree of independence 

to the industry in choosing which BMPs are appropriate and provide insufficient regulatory oversight of operations.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-14

Table B-3. Energy and Mineral Resources

It is unclear whether this project area will be able to provide truly renewable energy or whether economically feasible 

energy extraction will be short-lived. It is unclear how geothermal features such as hot springs in the project area will 

be affected by the project, i.e. the potential of substantially cooling down hot springs. Without exploring this potential 

issue, irreversible harm can be done to geothermal features inside and outside the project area, including the Valles 

Caldera National Preserve. Please ensure that this issue will be investigated in a comprehensive and scientifically 

valid way.

At the Fenton Hill HDR (Hot Dry Rock) project site it was determined that a drilling depth between 3 – 5 km deep is 

needed to locate temperatures between 200 and 300° C that are likely to be suitable for electricity generation. The 

suggested No Surface Occupancy Stipulation around water bodies including hot springs appears to be way 

insufficient considering potential drilling depths

The contemplated exploration area must be hydrologically isolated from major faults and nearby natural hydrothermal 

reservoirs. Drilling too close to geothermal features such as a hot spring or near major fault lines may result in water 

losses making the project unsustainable. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-15

Table B-4. Water Resources and Quality

Changes in groundwater flow paths, pressurization, and temperature. Page iii of the Draft EIS lists potential impacts 

from future geothermal leasing as “changes in groundwater flow paths, pressurization, and temperature.” Changes to 

flow paths have the potential to mobilize radioactive, toxic and hazardous pollutants found in the regional drinking 

water aquifer below the Pajarito Plateau, where LANL is located. 

Over 18 million cubic feet of radioactive, toxic and hazardous waste has been buried in unlined pits, trenches and 

shafts in the volcanic tuff of the Pajarito Plateau. This volume is three times the amount of waste proposed for 

disposal at WIPP.

Evidence of radioactive, toxic and hazardous contamination has been found in surface, alluvial, intermediate and the 

deep regional drinking water aquifer below LANL. Fast-moving and toxic chromium-6 has been detected at levels 24 

times the New Mexico water protection standard of 50 parts per million in the deep regional drinking water aquifer. In 

White Rock Canyon below LANL, the deep regional aquifer discharges to springs along the Rio Grande. Pollutants 

from LANL have been detected in those Rio Grande springs. 

Changes to flow paths, pressurization and temperature could further mobilize LANL contaminants to the Rio Grande, 

a source of drinking water for the communities of Los Alamos (100% reliance on the regional drinking water aquifer), 

Santa Fe and Albuquerque. In the mid-2000s, the Sangre de Cristo Water Division of the City of Santa Fe reported in 

their annual Safe Drinking Water Act report that radioactive plutonium was detected in Buckman Well No. 1. LANL 

pollutants are already moving. Geothermal leasing has the potential to further mobilize those contaminants. The 

USFS must accept Alternative 3 (No Leasing) in the Final EIS.

USFS Must Consult with EPA about Project Review. The Environmental Protection Agency (EPA) declared that the 

Espanola Basin Sole Source Aquifer below LANL as a sole source aquifer. We incorporate the information and map 

from their website into our comments at https://www.epa.gov/dwssa and 

https://epa.maps.arcgis.com/apps/webappviewer/index.html?id=9ebb047ba3ec41ada1877155fe31356b

The EPA defines a Sole Source Aquifer as “one which supplies at least 50% of the drinking water consumed in the 

area overlying the aquifer. EPA guidelines also require that these areas have no alternative drinking water sources(s) 

which could physically, legally, and economically supply water to all who depend on the aquifer for drinking water.”

https://www3.epa.gov/region1/eco/drinkwater/pc_solesource_aquifer.html

EPA states: “Protection of ground water resources can best be achieved through an integrated and coordinated 

combination of federal, state, and local efforts.” The USFS must consult with EPA about the proposed geothermal 

leasing. Protecting the sole source aquifer must be the priority for the federal government. Geothermal leasing has 

the potential to further contaminate the Espanola Basin Sole Source Aquifer with LANL pollutants. In order to protect 

the Espanola Basin Sole Source Aquifer, the USFS must accept Alternative 3 (No Leasing) in the Final EIS.

Watershed: Geothermal development would have a significant impact on water resources of the region. The amount 

of water consumption and impact to groundwater is unknown. In addition, disturbed soil from construction will likely 

runoff into perennial and intermittent streams, with the potential to significantly alter these important water resources. 

The Valles Caldera geothermal system runs beneath most of the land managed by the National Park Service (NPS) 

within VALL. The area of the entire geothermal reservoir is about 12 to 15 square miles within the ring-fracture zone 

of the caldera and bisected by the various faults of the Jemez Lineament.1 The larger geothermal system is 

considered to have two subsystems, the Redondo Creek subsystem and the Sulphur Creek subsystem, both of which 

contain geothermal features including hot and cold springs, fumaroles, and seeps.2 The geothermal system extends 

significantly west and south from the caldera, with underground thermal connections to hot springs in San Diego 

Canyon.3 Many of the springs and features connected to this system near VALL are well known, including: 

Hummingbird Fumarole, Jemez Springs, McCauley Spring, San Antonio Hot Springs, Soda Dam, and Spence Hot 

Spring.4 Within the boundaries of the Preserve, four geographic areas contain surface geothermal features including 

Redondo Creek, Alamo Canyon, Sulphur Creek Canyon, and San Antonio Creek. Features found in these areas 

include at least 29 seasonal fumaroles, acid ponds or springs, as well as Bathhouse Spring (sometimes called San 

Antonio Warm Spring) and several individual springs, mud pots, and fumaroles clustered at Sulphur Springs.5

Collectively these features represent unique geothermal resources that are found nowhere else in the State of New 

Mexico and in only a few locations in the United States, including Yellowstone National Park, Lassen Volcano 

National Park, a very small system in Dixie Valley, NV, and the Long Valley Caldera and the Geysers in California 

(these latter two degraded by geothermal development).6 Protecting these geothermal features from the unknown 

impacts of commercial geothermal development on adjacent lands is part of the mandate of the Valles Caldera 

National Preserve, established “to protect, preserve, and restore the fish, wildlife, watershed, natural, scientific, 

scenic, geologic, historic, cultural, archaeological, and recreational values of the area” (emphasis added).

7

1 U.S. Department of the Interior and U.S. Geological Survey, “GEOTHERMAL HYDROLOGY OF VALLES 

CALDERA

AND THE SOUTHWESTERN JEMEZ MOUNTAINS, NEW MEXICO.” Water-Resources Investigations Report 00-

4067,

2000, available at: http://pubs.usgs.gov/wri/2000/4067/report.pdf at 1.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-16

Table B-4. Water Resources and Quality

2 Id. 3 Goff, F. 2002. “Geothermal Potential of Valles Caldera, New Mexico.” GHC Bulletin, December 2002. 4 Smithsonian Institution, National Museum of Natural History: Global Volcanism Program, “Valles Caldera”

available at: http://volcano.si.edu/volcano.cfm?vn=327817. 5 Robert Parmenter, Division Chief, Science and Resource Stewardship, Valles Caldera National Preserve, personal

communication, September 2016.

6 Id. 7 P.L. 113-291, Sec. 3043(b)(1).

There is widespread agreement about the harmful impacts of geothermal energy development on thermal features 

within the same system. The process of extracting geothermal fluids for power generation typically removes heat from 

natural reservoirs at over 10 times their rate of replenishment. Natural features such as hot springs, mud pots, and 

fumaroles can be easily and irreparably damaged in this way by geothermal development. Extracting geothermal 

fluids can also reduce the pressure in underground reservoirs and cause the land to sink.8 The most dramatic 

impacts of geothermal energy development has been seen in the Wairakei basin of New Zealand, including the 

extinction of all geysers (about 70), loss of approximately 240 hot springs, and ground subsidence of 14 meters.9

8 The Encyclopedia of New Zealand, Geothermal energy, Page 5 – Effects on the environment available at:

http://www.teara.govt.nz/en/geothermal-energy/page-5; Union of Concerned Scientists, Environmental Impacts

of Geothermal Energy, available at: http://www.ucsusa.org/clean_energy/our-energy-choices/renewableenergy/

environmental-impacts-geothermal-energy.html#.V_LffOTrvb3. 9 Steingisser, Alethea and Marcus, W. Andrew. 2009. “Human Impacts on Geyser Basins,” Yellowstone Science, vol. 

17, no. 1, at 10, available at: https://www.nps.gov/yell/learn/upload/YS_17_1_sm.pdf.

In addition, geothermal fluids contain high levels of sulfur, salt, and other minerals that are toxic in concentration, 

which can cause severe water quality impacts damaging aquatic life and making surface water or groundwater 

unsafe for drinking or irrigation in the event of a spill or accident. 

Surface and Ground Water Resources - HDR geothermal development will require a source of fresh water for drilling 

wells, hydro-fracking, construction, and dust control. Once operational, fresh water will be needed to inject into the 

fractured formation. It is not clear how much water would be needed, but since industry practice is an open system, 

fresh water would need to continue to be added during operation. While the test project at Fenton Hill was deemed a 

success, it should be noted that the objective was different and there was a 7% loss of injected water during 

operations. The fate of this water may not be fully understood, however it certainly will have been removed from the 

river or shallow alluvium from which it was drawn and hence not available for beneficial use.

Most streams in the area have not had a use attainability study completed. Their beneficial use is designated as 

wildlife/livestock watering. With proper management of grazing and recreational uses, streams in the area could also 

be managed for recreational use such as fishing. NM Fish and Game has undertaken projects in the area to restore 

the native Cutthroat

The EIS does not specify how impacts to groundwater will be monitored. Since development will require a source of 

fresh water, it is likely that local streams such as the Rio Cebolla, and the associated alluvial aquifers, will be used as 

a source of fresh water to inject into the deep formations as part of the hot-dry rock (HDR) process. This activity has 

potential to deplete or contaminate these precious water resources. In the oil and gas industry, research has shown 

that contamination of groundwater from hydro fracking is not due to a lack of containment in the geologic formation 

being stimulated, but rather a failure to prevent migration of contaminants up the well-string. In most cases this is due 

to a poor job of grouting the annulus between the well casing and the formation. Verification of a grout job requires 

expensive logging techniques that are often skipped due to costs. There are no BMPs given to address this concern.

5. Geothermal energy development requires freshwater, a commodity is short supply in our state. Insufficient 

argument has been made that using freshwater to produce energy is a good use of that limited resource and a better 

use of it than other possibilities. 

Will the extraction of massive amounts of geothermal water upstream deplete the hot springs downstream in Jemez 

Springs and the Pueblo and the forest and the hot springs that tourists use? 

How much water (in an already drought area) will be needed for the project to ‘get the geothermal water out of the 

ground’ - we are not Iceland.

But even if the worst doesn’t happen, not immediately anyway, many of us, myself included, love the hot springs 

around the Jemez Mountains - Ojo Caliente and both commercial and natural hot springs around Jemez Springs. 

These springs are a major contributor to the economy of the region. In other places large geothermal developments 

have dried up the hot springs in the surrounding area.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-17

Table B-4. Water Resources and Quality

Additionally, there should be a much larger buffer around water bodies and springs than just 500 feet. We suspect 

this is simply not enough distance to ensure these areas are not impacted. We understand that 500 foot buffers are 

standard for water bodies in the BLM stipulations, but in this instance, the entire proposal is in an extremely active 

riparian area. There are both surface and subsurface water bodies everywhere. SFNF should analyze geothermal 

production’s potential impacts to all water, and should choose a buffer that will actually ensure no impact to riparian 

areas. SFNF should explain how it reached the number it uses, and the science upon which the number is based. 

Page 3-48 mentions dipping into the base geothermal aquifer for water, and states that “water would be trucked in or 

would come from local springs”, but does not discuss the potential impact of doing this on recreation and on hot 

springs, which should be analyzed. SFNF can calculate approximately how much water is typically used for a 

geothermal well, and how many wells there would be if the RFDS was fully developed. The DEIS states on page 3-49 

that water use in enhanced geothermal systems varies between .29 and .72 gallons per kilowatt hour, but does not 

indicate whether this is a one-time use while the well is being drilled, or whether this is forever, over the course of the 

well’s entire life. This information seems critical, and it is missing. The DEIS also rather casually states on page 3-50 

that, “temperatures could be lowered if interconnected flow from deeper zones is reduced by returning the cooled 

geothermal water to the reservoir.” Similar impacts are mentioned on page 3-51. Does this mean hot spring 

temperatures could decline? Has SFNF analyzed the potential economic impacts to businesses which directly rely on 

the hot springs? 

We fear the proposed extraction will lower the temperature of existing hot springs in the area, as the Draft EIS 

mentions

We don’t know what effect a substantial increase in geothermal development will have on the water quality in existing 

streams. With so few year-round streams in our area, especially for trout fishing, preserving the quality of each of 

them should be a priority. Water quality already suffers from cattle grazing in the area

As we hike along the rivers and canons in that area, we note the existing riparian zones are already damaged from 

drought, logging, cattle grazing, and primitive camping. Adding construction and development to these zones would 

further increase damage to the riparian areas along the rivers

Geothermal development could lower the temperatures of the various Jemez hot springs. These springs are not only 

important attractions for the local economy, but are beautiful and amazing sites that should be protected and honored 

for generations to come.

Geothermal development would almost certainly pollute local bodies of water, the water table and endanger native 

and rare species such as the Jemez Mountains Salamander.

These are very real concerns with high possibility of happening according to the comments of Fraser Goff, who 

formerly worked for Los Alamos labs and scientifically studied the hot water aquifers in the area—he actually wrote a 

book on the subject. *Secondly, we are concerned about water quality. It’s no secret that fracking damages water

quality. We understand that there will be fracking involved and thereby unavoidably, chemicals

introduced into the ground and ground water. This could very well effect both our business (which is dependent on 

the natural hot water quality) along with damaging our drinking water supply. No one wants to soak in chemical 

tainted water when what they come for is supposed to provide therapeutic benefits...and we certainly don’t want to 

have to wonder whether we’re drinking toxic water.

Table 3-4 (Page 3-43) indicates the Headwaters of the Rio Cebolla and the Outlet Rio Cebolla will be impacted by 

this proposal. If you combine the two watersheds (i.e., Rio Cebolla and Outlet Rio Cebolla), this equates to 86.4% of 

the watershed in the Project Area. The miles of road per square mile equates to the highest road density in the 

Watershed Erodibility Index. The DEIS states “Therefore, watersheds with higher road densities have a higher risk of 

sedimentation of stream channels when there are disturbances in the watershed.” It goes without saying that we do 

not want the Rio Cebolla destroyed or damaged in any way. We do not want to have the water of the Rio Cebolla 

polluted and contaminated by drilling disturbances. To our knowledge the Rio Cebolla has never run dry. The amount 

of water flowing in the river remains constant year round. The fish, beavers, water snakes and other inhabitants of the 

Rio Cebolla flourish. Animals such as elk, deer, mountain lion, bear, raccoon, weasel, birds of all kinds, chipmunks, 

squirrels etc. thrive because they have uncontaminated water to drink. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-18

Table B-4. Water Resources and Quality

The private land owners in the Seven Springs area depend on the ground water and below surface water to sustain 

our wells. The constant drilling, associated with this geothermal project, has the potential to destroy the quality of our 

well water by depleting the water table and disrupting the quality of water with residual sedimentation. Once again I 

quote the DEIS “Therefore, watersheds with higher road densities have a higher risk of sedimentation of stream 

channels when there are disturbances in the watershed.” This project has the potential of ruining our well water 

resources. Page 3-173 of the DEIS addresses the catastrophic affect to our water resources. The DEIS states “The 

result could include a reduction in spring discharge rates and lowering of water levels in wells. Re-injecting spent 

geothermal fluids could also introduce low-quality fluids to groundwater pathways that discharge at springs or wells. 

This could also affect the quality of water.”

The Rio Cebolla drains into Fenton Lake. Fenton Lake, one of the State’s few recreational areas that includes a lake, 

will also be adversely affected by this project. If the Rio Cebolla Watershed is destroyed or damaged by this project, 

the thousands of people who visit Fenton Lake each year (i.e., fishermen, campers and hikers) will be adversely 

impacted by this decision.

The Rio Cebolla is only one of the Watersheds that would be adversely affected. Water resources are precious to the 

state of New Mexico – the benefits of this project as stated in the DEIS does not come close to the amount of 

damage that will result from the exorbitant use of our State’s water resources. These water reservoirs will be depleted 

by this project.

3. The DEIS indicates several times that geothermal development could lower the temperature of existing hot springs, 

because cooler water could mix underground with the hotter water.

The large amounts of water required for production are also an expense this especially fragile area and its local 

communities cannot support. There is also risk of water contamination during the process by the release of 

introduced chemicals or hazards that already exist in nature but are safe as long as they are undisturbed. Where is 

the water required for production coming from? The already limited Jemez watershed? 

The caldera contains both thermal and non-thermal groundwater. Like the local surface water drainage patterns, 

groundwater flows radially outward from the rim of the caldera. The most extensive and productive aquifer in the 

region underlies the Pajarito Plateau on the east side of the mountain mass. On the west side, thermal and nonthermal waters discharge from the caldera to the southwest, down Cañon de San Diego (highway 4 corridor, serving 

the entire Jemez valley community), which follows the trace of the Jemez Fault Zone. The principal geothermal 

reservoir, or aquifer, in the region is under the central and western parts of the caldera. Non-thermal water in Valles 

Caldera occurs in diverse perched aquifers (like the one that feeds my water well and those of my neighbors) and 

deeper valley-fill aquifers. The non-thermal groundwater is derived from precipitation or condensation. Discharge of 

non-thermal water from Valles Caldera takes several paths, some of which are not well understood. Some of the nonthermal groundwater discharges from springs, particularly from higher, smaller perched aquifers. (We, among other 

local residents, pull our well water from one of these perched aquifers). Water from the more extensive valley-fill 

aquifers discharges as spring flow and seepage to the principal streams. Some deeper discharge from the valley-fill 

aquifers recharges the underlying geothermal reservoir by slow leakage through relatively impermeable rocks and 

along fractures and faults. Deeper groundwater is nearly continuous in the Tesuque Formation throughout the 

watershed area, to depths of 2,000 feet or greater in some areas. This deep groundwater dates from the Ice Age and 

is recharged little if at all by present day rainfall and snowmelt. Precipitation in the high mountains and flow in the 

Santa Fe River and its tributary arroyos seeps into and recharges shallow groundwater, which, in some areas, may 

be continuous with deeper groundwater. Volcanics often serve as a “floor” or channel to concentrate percolating 

groundwater and cause it to emerge as spring flow.

So, this is a very complex and sensitive water system that is not fully understood by anyone - making it impossible to 

predict what could happen if it is tampered with. A study done by Dr. Fraser Goff, a geologist who worked in the 

Caldera for many years, including on the Baca geothermal tests, said the hydrochemical nature of the entire 

southwest portion of the Jemez drainage would be altered but how and to what extent cannot be known. The United 

States Geological Survey (USGS) reported the same thing. But serious water depletion will occur if production-level 

geothermal plants begin operations.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-19

Table B-4. Water Resources and Quality

The type of geothermal thermal plant proposed for the Jemez is called a binary cycle plant, a type of “enhanced 

geothermal system” or EGS. While pro-geothermal advocates tout these plants as a “closed system” that is not prone 

to chemical leaks or “much” water use as compared to other geothermal systems, the plant still uses a great deal of 

water and reinjects fluids into the ground to induce fracturing, i.e. “fracking”, in order to obtain the heat from the 

subsurface magma.. In fact, the binary cycle plant water consumption (i.e., water that is withdrawn from a resource 

such as a river, lake, or aquifer that is not returned to that resource), varies between 0.29 and 0.72 gallon per 

kilowatt-hour. Even the DEIS says because the applicant would be required to obtain water rights, and the source of 

makeup water is unknown, the amount of water consumption occurring within the project area is unknown. This also 

changes the current flow patterns of the groundwater that feeds the streams, river, springs, and both private and 

community wells. 

Another environmental factor to consider is water. There are riparian areas, and water sources that can potentially be 

polluted, which will have a devastating impact to a region where water is needed.

Toxic waste water entering our clean aquifers due to lowering of the water table. 

What volume of liquid is proposed to be injected through the EGS process? At what depth? into regional drinking 

water aquifer? What direction will it flow? east? or west? or some of both depending on the location of the injection 

wells? If it moves east towards the Rio Grande - Has the USFS analyzed at the amount of injection proposed and 

permitted at LANL for remediation of the co-located chromium and perchlorate plumes in Mortandad Canyon? These 

two permits allow for discharges into Mortandad Canyon. NMED groundwater discharge permit 1835 - extraction from 

and injection in to the regional drinking water aquifer of 648,000 gpd - nearly two acre feet a day of water. NMED 

groundwater discharge permit 1793 (land application) - 350,000 gpd - or more than an acre foot of water a day. 

According to the DEIS, water use will be from .29 to .72 gallons/ kwhr. From what I have read, Geothermal systems, 

depending on cooling technology, can require between 1700 and 4000 gallons/kwhr. How can you be sure that the 

companies you lease to in the future will not be using larger amounts of water that is already a scarcity in our region? 

In its secretiveness about the likely use of fracking, the DEIS also lacks any assessment of how the injected fluid 

employed during fracking would impact the Jemez Mountains’ water quality. Fracking in many other areas has 

generated widespread water pollution. Waters from the Jemez system flow eventually to the Rio Grande by way of 

the Chama River, the forks of the Jemez River, and many other streams flowing out of and/or off the mountains. 

Santa Fe derives a portion of its drinking water supply from the Rio Grande. The Rio Grande provides irrigation for 

communities almost all the way to the Gulf of Mexico. To what extent would the fluid used in fracking the Jemez 

Mountains for geothermal electricity pollute the waters depended upon by so many peoples? Roads to and from 

these five separate power plants would proliferate, creating more soil erosion, also detrimental to water quality, and 

that must be assessed. 

The hot springs in the Jemez are irreplaceable Forest, State, and National scenic, recreational, and ecological 

resource features. The DEIS readily acknowledges that geothermal development could lower the temperatures of 

these springs as a result of the mixing of underground aquifers. To risk compromising the integrity of these hot 

springs for very limited short-term energy gains is an unconscionable trade. Unique resources like these demand 

extra protections, and not cavalier incursions by private energy interests. These springs, and their sources, are on 

public lands. They should not be auctioned off to the highest commercial bidder.

Water quality and quantity are a huge concern. Perhaps you have seen the films – Gasland comes to mind – that 

document the terrible toxic impacts of the fracking drilling fluids on water quality and quantity. Groundwater drawdown 

is a huge concern, as is pollution of the groundwater leading to water quality and human / environmental health 

issues. The Jemez Mountains are cherished by many, and I am sure that the Jemez Pueblo and the other local 

Pueblos are mortified at this threat to their homeland and health.

We are dependent on private wells. In our very dry environment, water is precious and scarce. NM’s water is already 

over-allocated and the whole State of New Mexico has been drought-ridden for way too long already. How can a 

project which would require the use of huge amounts of water even be considered? Isn’t it likely that other water 

users, like residents and local businesses, would be deprived of their water rights in order to provide the required 

water resources for this project? 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-20

Table B-4. Water Resources and Quality

While there are many reasons that such development could cause significant detrimental effects on a unique and 

fragile ecosystem, there is perhaps one reason that takes precedence over all others. Water. Water is already a very 

limited resource in our state, and the Jemez Mountains are arguably at the epicenter of climate change in the 

American Southwest. We have been in an extended period of drought, with winter snowpacks being far below 

average and shorter lived, and with summer monsoons delivering much less rain than historically. Geothermal 

development of any kind would necessitate drilling wells at the very least, but would also likely include underground 

fracking. These disturbances would increase the likelihood of seismic activity in what is a sleeping Supervolcano, 

which could lead to ground subsidence and possibly much worse consequences such as earthquakes or even an 

eruption. There would certainly be changes in groundwater pressure and temperature, as well as direction and flow 

strength; and increased sediment with decreased clarity for surface water. Such changes would jeopardize the water 

supply for all surrounding communities and threaten the heritage hot springs that bring many visitors to the Jemez. 

Since there is no water on the proposed leasing sites, precious and limited water rights would have to be obtained by 

anyone wanting to build a Geothermal site. The companies standing to profit from this development would not care 

how their sites change the water supply or quality for the local community, and it seems unlikely that any money or 

power generated would significantly benefit New Mexico. Local residents will have little recourse when their water 

supplies are compromised.

Our state has the least surface water of any state, and many people who live in the areas in question may experience 

changes in ground water flow, volume, and composition, perhaps even to the point that their wells will no longer be 

viable. While there will technically be legal recourse for these individuals, the truth is that they will be left with 

worthless property and likely lack the means to fund lawyers for the years of litigation that would have to follow in 

order to perhaps be compensated.

Geothermal energy is not a renewable energy source in this instance. The use of ground water for this project, along 

with the hydraulic fracturing that will go along with it, could very likely change permanently the source of many hot 

springs in the area that bring people and money from all over the state, and provide much of the draw these 

mountains have for many of us.

We finally have National Park status for the Valles Caldera, and should not risk changes to this areas water 

resources. The impact statement clearly states surface water changes in the form of increased turbidity and sediment 

could result, endangering native fish and water sources needed dearly by native wildlife

You do not address the source of the water that will be needed for geothermal production. Where will it come from? 

Obviously from beneath the forest. I was introduced to NM wilderness in this area....first being the springs and next, 

camping in the forest. I do not want to see this lost. 

Water is scarce in this region and geothermal development could threaten ground water and lower the temperature of 

the Jemez hot springs - a vital source for the economy in this area of New Mexico. Economic development MUST 

take into consideration the people and lands of the region. 

Improve the analysis for potential impacts on the geothermal resources of Valles Caldera National Preserve

Improve the analysis for groundwater resources that could potentially be impacted by geothermal development

Page No.: 3-15

Section, Paragraph, Table or Figure No.: Section 3.4.2.8

Comment: The third paragraph in this section “Further, if the NPS successfully nominates the VCNP as a significant 

thermal feature under the Geothermal Steam Act, areas next to the caldera, or those with hydrological connections, 

may not be leased; this could reduce potential indirect impacts on land uses, recreation, and special designations.”

This statement infers that there could be impacts to the geothermal system of Valles Caldera NP from the proposed 

alternative and that the park geothermal system may only be protected if the park unit, or a portion of the park unit is 

listed as a significant thermal resource under the Geothermal Steam Act. This is incorrect, because impacts to all 

Valles Caldera NP resources, including thermal features, should be addressed and mitigated regardless of any

designation under the Geothermal Steam Act. The Valles Caldera NP was established as a unit of the National Park 

System “To protect, preserve, and restore the fish, wildlife, watershed, natural, scientific, scenic, geologic, historic, 

cultural, archeological, and recreational values of the area...” (128 Stat. 3793). The NPS requests additional analysis 

be conducted in the DEIS for impacts to the geothermal system of Valles Caldera NP, including the hydrothermal 

circulation system, and the need under the NPS Organic Act, the park enabling statute, and other laws and policies 

including the Geothermal Steam Act, to protect these resources from leasing-related impacts. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-21

Table B-4. Water Resources and Quality

Page No.: 3-38

Section, Paragraph, Table or Figure No.: Section 3.9.1.1 Paragraph 6

Comment: On page 1-9, the last 2 paragraphs under Section 1.5.2, provides a definition of “geothermal resources,”

distinguishing between a geothermal resource as mineral versus geothermal fluid; however, nowhere in the 

document is there a definition of what is considered a geothermal feature. The main hot springs in the area have 

been named, but has there been an inventory of other groundwater discharge features that might have elevated 

temperatures that might be impacted by geothermal development? There is no set rule for what constitutes a thermal 

spring (anything over 70 degrees, 12 degrees over mean air temperature, etc. are examples). National Oceanic and 

Atmospheric Administration describes warm springs as between 68-122F. Either way, some metric needs to be 

employed to determine what features are considered geothermal and which are not. We suggest definitions for 

“geothermal resource” and “geothermal feature” be included in Chapter 5, Glossary. 

It may be helpful if the DEIS were to include the NPS definition of ‘thermal resources” as comprising a subsurface 

heat source, heat conduit rock formations, and air and/or water that circulates through the formation and may 

discharge at the surface; such resources create features such as geysers, hot springs, mudpots, fumaroles, 

unique/rare mineral precipitates and formations, and hydrophilic biotic communities (NPS Management Policies § 

4.8.2.3 (2006)).

The draft EIS could also include the NPS definition of ‘‘thermal feature” as the surface manifestation of subsurface 

thermal resources, systems, or features.

Page No.: 3-48

Section, Paragraph, Table or Figure No.: Section 3.9.2.2 Bulleted List of Indicators

Comment: How were the indicators related to depletion of groundwater, groundwater mounding, and changes in 

groundwater temperature, geochemistry, springflow evaluated? Page 3-52 states cumulative impacts were 

“analyzed,” but what data/analysis/methodology/modeling or other means of impact determination was used? It 

appears that impacts of the alternatives on groundwater resources are purely speculation/assumption rather than 

“analysis.”

Dear Friends of the Forest Service: I oppose any fracking because fracking uses tremendous amounts of clean water 

and produces extremely toxic, radioactive water that would pollute the water table, rendering it unusable for people, 

wildlife, forest, agriculture.

3.9.2.2 The Methods section’s assumptions would be more accurate if it included similar assumptions as those listed 

in 3.10.2.2 for air such as BMPs, State permitting requirements, the likelihood of using a binary power system and 

need or lack of need for related potential impact analyses, number of geothermal plants, and total area of potential 

surface and subsurface disturbance. 

3.9.2.3 For consistency and a more thorough assessment of impacts, “Common Impacts Associated with 

GeoThermal Development,” should include the same format and discussion of impacts as was done in the Air section 

(3.25.2). That section’s format is based on each phase of geothermal development: initial exploration, development 

and drilling, secondary exploration and drilling, and final plugging and reclamation. The discussion should summarize 

or at least reference some of the most up to date information regarding potential water resource impacts related to 

the most likely development scenario and BMPs or engineering controls needed to minimize those impacts. For 

example, the DOE Energy Efficiency and Renewable Energy has 2016 working papers specific to each phase of 

geothermal development that discuss current technology, potential impacts, and BMPs. These papers include the 

common impacts associated with the management of large quantities of stimulation fluids, the potential impacts of 

concentrating constituents in the fluids, and the use of de-scaling agents, etc.

Website: https://www1.eere.energy.gov/library/default.aspx?page=4

The DOE publications also describe the need for “worst case” scenario evaluations (perhaps for this EIS, a 

“reasonably foreseeable scenario” instead) of the effect of down hole drilling and stimulation fluids, typical scale 

inhibitors/treatments, and depletion of the geothermal reservoir or groundwater during hydraulic stimulation.

Some specific examples of information needing better discussion and impact analysis in the “Common Impacts 

Associated with GeoThermal Development” as it pertains to water resources are: 1) Potential for increased fracturing 

causing greater connections between the geothermal reservoir and groundwater flow systems that ultimately drain 

into the San Diego Canyon groundwater, surface waters. The potential impacts to drinking water sources and surface 

waters such as Fenton Lake and area rivers (and associated the river ecosystems) need to be more specifically 

addressed in a . The DEIS states “...there are numerous faults extending from the caldera, and where there is an 

interconnection between deeper groundwater and faults, pumping could change flow paths. There also could be 

some slight changes in flow paths from pressure differences due to small differences in the extraction and reinjection 

zones. 2) Impacts of drilling fluids and cements including likely chemical compositions, operational concentration of 

those chemicals, their subsequent potential for reinjections or release, spills and disposal, and comparisons of 

constituent compositions to U.S. drinking water standards. A USGS Report (“Geothermal Hydrology of Valles Caldera 

in the Southwestern Jemez Mountains New Mexico, by Trainer, rogers and Sorey, 2000) discusses liquid waste 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-22

Table B-4. Water Resources and Quality

constituent concentrations and a LANL monitoring study of released liquid wastes. 3) Impacts of storage/disposal of 

binary system waters that are not returned to the geothermal source, 4) Impacts of scale remediation processes and 

wastes, 5) Impacts of pipe corrosion and potential for leaks and spills, and 6) Impacts of the removal and disposal of 

condenser wastes, 7) Long term impacts of stressing the geothermal reservoir and subsequent hydrologic changes 

Surface and Ground Water Resources - HDR geothermal development will require a source of fresh water for drilling 

wells, hydro-fracking, construction, and dust control. Once operational, fresh water will be needed to inject into the 

fractured formation. It is not clear how much water would be needed, but since industry practice is an open system, 

fresh water would need to continue to be added during operation. While the test project at Fenton Hill was deemed a 

success, it should be noted that there was a 7% loss of injected water during operations. The fate of this water may 

not be fully understood; however such losses during operations will remove waters from the river or shallow alluvium 

from which it was drawn and hence not be available for beneficial use. The watersheds in the area have already been 

impacted by years of drought and the resulting fires.

Most streams in the area have not had a use attainability study completed. Their beneficial use is designated as 

wildlife/livestock watering. With proper management of grazing and recreational uses streams in the area could also 

be managed for recreational use such as fishing. NM Fish and Game has undertaken projects in the area to restore 

the native Cutthroat Trout. Beaver were once common throughout the riparian areas, which have now been degraded 

from years of livestock grazing and drought. Would watershed restoration efforts be thwarted and TMDLs be 

exceeded due to geothermal leases?

The EIS does not specify how impacts to groundwater will be monitored. Since development will require a source of 

fresh water, it is likely that local streams such as the Rio Cebolla, and the associated alluvial aquifers, will be used as 

a source of fresh water to inject into the deep formations as part of the hot-dry rock (HDR) process. This activity has 

potential to deplete or contaminate these precious water resources. In the oil and gas industry, research has shown 

that contamination of groundwater from hydro fracking is not due to a lack of containment in the geologic formation 

being stimulated, but rather a failure to prevent migration of contaminants up the well-string. In most cases this is due 

to a poor job of grouting the annulus between the well casing and the formation. Verification of a grout job requires 

expensive logging techniques that are often skipped due to costs. There are no BMPs given to address this concern.

also The DEIS states that geothermal development could lower the temperature of the existing Jemez hot springs, 

impacting a major tourist attraction and the local economy. Instead, tourists would enjoy high powered electric lines, 

traffic, noise, new eroding roads, muddied rivers and lukewarm soaks.

Since the geo-hydrology of the Valles Caldera and the down-gradient San Diego Canyon are not well researched, 

documented or understood, keep the geothermal exploration and development out of the western flank of the Valles 

Caldera. 

Residents in these areas derive their household drinking water from domestic water wells that are drilled into the 

underlying volcanic and sedimentary formations that host the groundwaters. This drinking water is a precious 

resource that residents depend on for their health and running their homes. Keep geothermal drilling away from these 

residential areas to protect the underlying groundwater from any impact on the quality or quantity of the drinking 

water

The hot springs are also a precious resource that has been enjoyed by people for hundreds of years. Keep the 

geothermal drilling away from the west flank to protect the hot springs and the hot spring resources that flow downgradient into San Diego Canyon and manifest at the surface at hot springs in the Jemez Springs village, north of the 

village and as far south as the Jemez Pueblo. 

Regarding Ormat technologies; if a decision is made to allow leasing, there will be a public auction for the leases. I 

also think it is important for people to know any water used in the project would require approval from the State 

Engineer.

Water is life and if our water tables are spoiled it will affect thousands of peoples health. There are water sources that 

can potentially be polluted, which will have a devastating impact. Clean water is essential to all regions in our state. 

Do you want to drink clean water? Do you want your children to drink clean drinking water? Clean water to bathe in? 

Water resources cannot be a factor to consider down the road. The proposed geothermal energy production will 

require a great deal of water and wastewater and the forest cannot be opened up for geothermal if the effects to 

water quality, quantity and heretofore unsettled water rights have not been fully considered. Allowing use of water 

that may be subject to Pueblo water rights adjudication or settlement is an abrogation of the Department of Interior’s 

trust responsibility to the tribes. 

There is a problem of potentially unsustainable production due to excessive water use/loss, water rights issues, water 

availability, etc. Also, the proposed No Surface Occupancy buffer surrounding, for instance, hot springs appears to be 

way too small.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-23

Table B-4. Water Resources and Quality

At Fenton Hill fluids (i.e. water) were injected into the ground for steam well production. Large areas of the rock must 

be adequately hydrated to result in heat transfer. The availability of water for this process in the arid project area 

cannot be assured unless operators are allowed to access water currently allocated to other users 

(agriculture/irrigation, community, domestic or commercial wells, surface waters belonging to other 

communities/states/countries, etc.). New Mexico’s water is already over-allocated, i.e. more water rights have been 

granted than water is available to users. The NM Office of the State Engineer is responsible for the distribution of the 

scarce water resources in New Mexico. Has OSE been consulted about water issues? Why are the BLM and the 

SFNF considering introducing a project with potentially high water requirements on lands administered by the Federal 

Government in the arid and drought-ridden State of New Mexico? Is it possible that other water users will be deprived 

of their water rights in order to provide the required water resources for this project?

In addition, the DEIS indicates that geothermal development could lower the temperature of existing hot springs 

because cooler water could possibly mix with hotter water underground. Given the area is immediately next to the 

Valles Caldera National Preserve the water temperature there would also be impacted.

The EIS also states that drinking water could be impacted by “a reduction in spring discharge.” In a state where water 

is a constant shortage no community needs their water supply impacted negatively! 

Environmental issues are huge. The drinking water in the Jemez is fragile. Hydraulic fracturing needs a tremendous 

amount of water to function, and we can hardly afford to waste even a drop of water. Even now, and previously, we 

have to curtail the amount of water we use. Then, there is the environmental pollution of our drinking water supply. 

Do you think it is judicious to threaten the water supply (our ONLY source) of residents who call this home? Third, 

seismic activity is very real in our region. If the sleeping giant, Valles Caldera, is reawakened, imagine the 

catastrophic event that could occur. This area is too geologically sensitive to flirt with disaster.

I am concerned with impacts to groundwater levels. Could groundwater levels be drastically reduced?

I am concerned with how geothermal exploration could impact the hot springs that the Jemez area is so well known 

for and depends on economically.

The fracking will also lead to pollution of our water. When we lose our water we lose our lives. Not to also mention 

that the location of this is alarmingly close to Los Alamos National Laboratories and if those chemicals are set loose

in result to this fracking the affects will not only cost us our lives but the generations after us.

The EIS document associated with possible geothermal development states, “The hot springs in Valles Caldera and 

southwest of the Caldera in San Diego Canyon could be impacted by extracting and reinjecting geothermal water ...”

causing “change in ground water flow paths, pressurization, and temperature.”

Drinking water for our residents is dependent on the steady flow of cold water Springs

Drinking water could be impacted by “a reduction in spring discharge and lowering water levels in wells.” (EIS) 

Acequias use water from the Jemez River for our community sustainability. 

Surface water which feeds our acequias could have an “... increase in suspended sentiment ...” (EIS) silting in our 

irrigation ditches

The Excessive volumes of water needed to facilitate any form of production have to come from somewhere and in the 

area would only exacerbate an already tenuous water situation for millions of people down stream. With the 

expansion and clarification of the Clean Water Act “Navigable Waters” and because these aquifers outcrop and flow 

into the Rio Chama in springs/Streams, albeit sometimes intermittent they contribute and communicate with an 

“Interstate Water” Rio Chama PROTECTED WATERWAY! Not to mention the potential for ground surface water 

contamination.

New Mexico in Region 6 one of the 4 EPA regions that require injection well no Migration Petitions”... with varies 

guidelines and appropriate geological conditions.... Deeply fractured communicating water bearing formation in the 

Rio Charma. Rio Galina and Rio Puerco Watersheds are in grave question for injection activities. It appears 

historically and most probably at present as well. that non producing wells are perhaps illegally allowed to become 

waste injection wells according to the EPA

3. The DEIS indicates several times that geothermal development could lower the temperature of existing hot springs, 

because cooler water could mix underground with the hotter water. This is a direct and destructive impact on these 

resources, so the development should not be allowed to proceed.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-24

Table B-5. Air Quality and Air Quality Related Values

Similarly, toxic air emissions of hydrogen sulfide, carbon dioxide, ammonia, methane, and boron can result if not 

properly contained in a closed-loop system.11

11 Union of Concerned Scientists.

Page 2-18 of DEIS, Table 2-4 Comparison of Alternatives: Air quality. These comments apply to those who own 

property in the Jemez but also to the thousands who come to visit the Santa Fe National Forest. Those who leave 

populated areas such as Albuquerque and Santa Fe to escape noise and poor air quality expecting to spend time in a 

clean, quiet, Forest environment. Several years ago, we lived through the paving of Highway 126 in the Seven 

Springs area. We lived through the constant stream of heavy equipment. We lived through the noise associated with 

the heavy equipment, State engineers and workers driving back and forth from sun-up to sundown. We lived through 

the constant dirt in the air because of the construction. Wildlife abandoned the area because of all the construction 

activity, noise, fugitive dust and people. It is well and good to say the problem will be worse during the construction 

phase but I know this not to be true. If the roads to the power plants are paved, the fugitive dust would be reduced but 

the noise and vehicle emissions will remain. If the roads are not paved, then they will eventually deteriorate and dirt 

will be everywhere as the roads are travelled. There is no possible way to do this project in the middle of the Forest 

without causing these problems. The emissions from day-to-day plant operations will remain, vehicle emissions will 

remain and there is also a potential of carbon dioxide emissions during well maintenance

Huge transmission lines from the plant through the forest will also be installed; what are the emission hazards of 

those lines to wildlife and humans? 

Air and chemical pollution, including radioactive element Radon, toxic elements Arsenic, Mercury, Ammonia, Boron 

(highly toxic to plants) and other polluting heavy metals. The waste steam is sprayed over surrounding vegetation 

(usually rare species in geothermal areas), while waste water is either re-injected (inducing earthquakes), or pumped 

into streams and lakes untreated, as treatment is considered too costly to be economically viable. 

(Kristmannsdottir,2003). In lake Pingvallavatn, a large area of the lake bottom was found to be biologically dead due 

to toxic hot waste water pollution from nearby geothermal plants, which is altering the lake ecology.

Much less greenhouse emissions are released from geothermal power plants compared to the most common power 

generating source (coal-fired). For example, in California conventional geothermal power plants (flash and dry steam) 

emit ~5% of the CO2, ~1% of the SO2, and <1% of the NO2compared to coal-fired plants of equal size. A closed 

loop, totally contained, hot-dry rock (HDR) geothermal system as has been proven viable in the Jemez Mountains 

(Brown et al., 2012) would have near zero emissions. 

I am quoting from Ms. Trenchik’s eMail: “Geothermal exploration and development, and connected developments 

(roads and utilities) could have direct, indirect and cumulative effects to air quality and air quality related values.”

We, the concerned citizens downwind of Los Alamos, have long been impacted by air pollution from the lab (really 

evident during the Cerro Grande Fire) and it is not fair to expose us to additional manmade dangers. For over 25 

years, we testified and spoke up against WIPP (Waste Isolation Pilot Project) and said that it was not a question of IF 

there would be an accident, it was a question of when. It only took 8 years for this to happen. This is a very similar 

situation. The proposed benefit does not justify the potential risk
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-6. Vegetation

Clean-up after the damage done 30 years ago is now costing significant taxpayer dollars and sapping volunteer 

efforts. Just this week I received a news item: “Sulphur Creek Project Nearing Completion. In 2013, Los Amigos de 

Valles Caldera signed a $196,203 contract with the New Mexico Environment Department to use innovative 

restoration techniques, pioneered in New Mexico, to restore historic wetlands and wet meadow habitat in the Sulphur 

Creek Sub-Watershed on the Valles Caldera National Preserve... Los Amigos is restoring 30-45 acres of wetlands 

damaged by geothermal exploration...” Restoring 30 acres doesn’t sound like a big deal, but I have been involved in 

similar sized projects in Michigan. One involves three 20-acre spoils sites where a past EPA “remediation” project 

deposited dredged, contaminated lake-bottom materials. Those sites became epicenters of invasive Phragmites 

growth, which then spread sporadically across the wetlands in the adjacent several thousand acres of natural area 

and alongside neighboring roads. In the 7 years since we started working on the Phragmites spread, with great effort 

we have been able to contain escape from the spoils sites and gradually decrease the area covered by Phragmites in 

more than 60 separate sites of infestation. It will take at least another 10 years of work to substantially reduce the 

Phragmites, and the spoils sites will probably never restore to healthy native plant communities. So, the damage of 

carrying out such a geothermal project is not just the physical disturbance and pollution of a specific piece of land, but 

the high probability of propagation of invasive species from the disturbed sites to surrounding areas. Those invasive 

species have a life, and often exponential spread, of their own. Imagine 5,000 times the current 30-acre area at 

Sulphur Springs needing to be restored, which would be required if the proposed 136,500 acres were opened to 

geothermal extraction. How could this project even be considered, given what we already know about the long-term 

effects and costly restoration burden of the past, abortive geothermal trials in Valles Caldera? I have no faith that the 

land would be (or even could be) restored by those who damage it, because this did not happen after the earlier 

project at Valles Caldera. Moreover, the Department of Energy falsely claimed in the final EIS for that project that little 

damage had occurred. It is essential for SFNF to stay true to its mission, which is not hydraulic fracturing, but caring 

for the land 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-7. Fish and Wildlife

Biodiversity and Wildlife Conservation: Based on a study from The Nature Conservancy of the Ecological & Biological 

Diversity of the Santa Fe National Forest (using data the R3 Species Database), approximately 407 plant and animal 

species (a conservative estimate that does not include most invertebrate and plant species ) occur in the Santa Fe 

National Forest, including 231 bird species, 90 species of mammals, 39 species of reptiles, 14 species of amphibians 

and 13 species of fish. This includes 15 species listed by the state as threatened or endangered, 26 species with 

NatureServe global rankings and national rankings that warrant conservation concern, and 86 species with 

NatureServe state rankings that warrant conservation concern. The R3 Species Database identifies 22 potential 

species of concern, 76 potential species of interest, 23 bird species on the Partners in Flight Watch List, and 17 Birds 

of Conservation Concern. Approximately 25% (25.3%) of all species in the Santa Fe National Forest have been 

identified as falling within USFS planning directive categories. Geothermal leasing/development would fragment the 

land, resulting in a significant, negative impact on these species of conservation concern and the overall biodiversity 

of the Santa Fe National Forest ecosystem. It is also important to ensure that the proposed geothermal impacts are 

consistent with the Comprehensive Wildlife Conservation Strategy for New Mexico that is currently being revised. 

Page 2-20 of DEIS, Table 2-4 Comparison of Alternatives, Fish and Wildlife: This table indicates that “no direct 

impacts on fish and wildlife would occur.” How can this be? No matter if it is during the construction phase or 

following implementation fish can and will be affected by the disturbance of water sheds and the resulting sediment in 

the water. Wildlife, whose environment is only shrinking, will be disturbed by the noise, interference in their habitat 

and the increased potential of exposure to contaminants. I cannot say this enough, the impact to fish and wildlife will 

be dramatic and devastating. Quoting page 3-173 of the DEIS “As a result, hydrologic impacts associated with 

geothermal development could have secondary impacts in the plant and animal community supported by natural or 

created wetlands.”

In early July 2016 SFNF issued a draft environmental impact statement (DEIS) the proposal is still fundamentally 

inappropriate. My understanding is that there have been insufficient protections in place for endangered species and 

sensitive areas and there has been no inventory for wilderness characteristics within the project area.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-8. Threatened and Endangered Species and Special Status Species

The Jemez Mountain salamander, Mexican spotted owl, and New Mexico meadow jumping mouse are all federally 

listed as threatened or endangered and found both within the project area and within the neighboring NPS lands. 

Maintaining optimal habitat for these species throughout the Jemez Mountains should be a priority to sustain healthy 

populations in all jurisdictions

Threatened and endangered species - There are a number of threatened and endangered species known to occur in 

the project area. Of particular interest with respect to the proposed action is the Northern Meadow Jumping Mouse 

and Jemez Mountains Salamander, both endangered species known to occur in the area. It is likely that geothermal 

development would negatively impact their habitat. Recreational uses - Much of the area

3. The DEIS does not provide for adequate protection for the resident endangered species. 

Lastly, none of the documents on the SFNF website about the project, nor the DEIS itself, mention any discussions 

thus far with FWS, and to our knowledge there have been no FWS representatives at the public meetings. As 

discussed in more detail later, this project overlaps Protected Activity Centers (PACs) for the Mexican Spotted Owl 

(MSO), and is home to the recently listed Jemez Mountain Salamander and the New Mexico Meadow Jumping 

Mouse, each of which have Critical Habitat within the proposal area. SFNF is prohibited by the Endangered Species 

Act from jeopardizing the species and also from damaging designated critical habitat, and should have notified FWS 

at the earliest possible point. SFNF should prepare a Biological Assessment for each listed species to determine 

whether or not the proposed action may jeopardize any of the species5 . If the Assessment determines jeopardy may 

occur, SFNF must initiate formal consultation with FWS6 . No biological assessments seem to be included in the 

DEIS. During scoping we asked for clarification of the process SFNF went through to get to this point. Neither the 

DEIS nor the scoping report responds to this request.

5 50 C.F.R. § 402.12 6 Id.

The official policy of the United States, as expressed in the Endangered Species Act (ESA) is that “all Federal 

departments and agencies shall seek to conserve endangered species and threatened species.” 16 U.S.C. § 

1531(c)(1). Under the ESA, USFS has an affirmative duty to ensure that any action it authorizes is not likely to 

jeopardize listed species or result in the destruction or adverse modification of designated critical habitat. Id. § 

1536(a)(2). In order to fulfill this responsibility, when USFS knows that listed species are present in the action area, 

which is true in this case, it must conduct a biological assessment. Id. § 1536(c). During scoping we requested that 

the biological assessments for this project be made available on the project website, for ease of public accessibility. 

During scoping we also requested that the DEIS explain the consultation and/or conference process used by USFS 

for this project, as well as the information contained in any biological assessment and biological opinion, including 

any discretionary conservation recommendations provided by FWS. Based on the list of parties and agencies in the 

appendix, FWS was not even mailed a copy of the DEIS (page 240). We suspect that SFNF did not inform FWS of 

this proposal because of its erroneous assertion that there are no actual impacts from making the decision to lease. 

We believe, however, that SFNF must do a full impacts analysis as early as possible in conformance with NEPA 

guidance, and that with an EOI and a RFDS, potential impacts are determinable. SFNF should seek the opinion of 

FWS immediately and incorporate its comments into this analysis. 

While scoping materials suggest that ground disturbing activities will not take place in critical habitat, this does not 

negate the significant impacts to MSO that may occur based on activities that may take place throughout the 

proposed action area. Mexican spotted owls have been threatened throughout the Southwest for many decades, and 

recovery has not been achieved. Moreover, because of their use of a wide variety of habitats and the number of 

projects that take place on forest lands, the cumulative effects to this species are significant in any large-scale project 

undertaken over many years.

Breeding and nesting periods are a particularly significant time for raptor populations. In studies of MSO in New 

Mexico, breeding and nesting activities took place from March until July (Delaney et al. 1999:44). Additionally, 

foraging behavior also increased during this period (Delaney et al. 1999: 46). It is also important to note that MSO 

rely on small prey species, and the impacts of activity associated with this project on those populations are important 

to understanding the overall impacts to MSO viability and recovery. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-8. Threatened and Endangered Species and Special Status Species

The DEIS notes that there are 14 Protected Activity Centers in the project area and that there have been 17 MSO 

observations (DEIS page 3-93). It also lists the potential high impacts to MSO habitat should geothermal 

development occur, as well as serious disruption to their breeding cycles. Lastly, SFNF acknowledges in this 

document that geothermal development comes with the risk of increased fires (DEIS page 3-85), that effective habitat 

loss from disturbance and fragmentation is generally 2.5%- 3.5% higher than actual habitat loss (DEIS page 3-84), 

and also that MSO habitat has already been severely impacted by both fragmentation and fire. It appears that surface 

disturbance is still possible in PAC’s through exceptions to the NSO stipulation, and this possibility should be 

removed to ensure zero impact on this incredibly sensitive species. 

MSO are particularly sensitive to noise pollution and disruption caused by human activities. Because of the potential 

scope of the geothermal activities within the entire project area, we assume that noise pollution throughout the 

lifespan of these activities will be varied, dispersed, and significant. Studies of MSO have demonstrated that noise 

from even relatively limited recreation activities can disrupt owl activity and have “caused declines in several 

important activities that could adversely affect the reproductive success of owls” (Swarthout and Stiedl 2003: 311). 

The research suggests that human activity of any kind, especially near nesting sites, can create disruptions to MSO 

behavior and activity that directly threaten reproductive success. We encourage USFS to analyze the potential noise 

impacts from this project and future related activities as it considers the impacts to MSO in the area. Further, we 

request USFS assess how noise pollution and human behaviors in the area from ongoing recreation will contribute to 

the cumulative impacts here

The Jemez Mountains Salamander is extremely rare, and as its name suggests, limited to the Jemez area. It lays its 

eggs, and primarily lives, underground. 34,400 acres of the project area is designated critical habitat for the 

salamander, and 90% of the documented sightings of these amphibians has been on SFNF land. It requires intact 

riparian areas to survive. 

Jemez Mountains salamanders may be adversely impacted in a variety of ways if this project were to move forward. 

As part of this project, ground disturbing activities and construction of infrastructure is likely to occur, and potentially 

increase over time. Salamanders live in various forest types, but rely on access to underground habitat. Compaction 

or changes in soils and ground cover may adversely impact the salamander’s habitat in the project area. Additionally, 

development of any kind could remove and fragment salamander habitat. This is especially problematic for isolated 

populations. The DEIS lists other potential impacts to the salamander such as increased disease if populations have 

to move closer together because of habitat fragmentation, and direct injuries from equipment (DEIS page 3-105). 

According to the DEIS, surface disturbance in salamander critical habitat would still be possible through exceptions, 

modifications, or waivers (DEIS page B-1). The Endangered Species Act states that while habitat modification can be 

allowed in designated critical habitat, FWS must be consulted and that any proposal will be modified to ensure no 

harm. Designated critical habitat serves as a reminder to other agencies about the importance of protection of 

endangered species14 . Again, we do not believe FWS has seen this proposal, and it should, but we highly doubt 

geothermal development would fall into the category of causing no harm to the species. Designated critical habitat for 

the salamander should be NSO without exceptions, modifications, or waivers.

14 https://www.fws.gov/endangered/esa-library/pdf/critical_habitat.pdf

The Jemez Mountains are one of the only known places where this jumping mouse occurs, and research suggests 

that the mouse no longer exists in 73% of its historical habitat in this area (Frey and Melaney 2009). 800 acres of 

critical habitat for the mouse are within the proposal are. While the primary threat to jumping mouse is livestock 

grazing and disruption of riparian habitat, there is the possibility that this project may lead to increased activity in and 

around areas that jumping mouse inhabit. Additionally, USFS must disclose whether any recreational activities or 

livestock grazing may be pushed into or nearer to jumping mouse habitat as a result of this project. Exceptions, 

modifications, and waivers are still possible in mouse habitat in the proposed alternative and we believe there should 

be no exceptions. 

Finally, the environmental impacts of geothermal leasing in this area would be unacceptably high. This area is home 

to at least three listed species (Jemez Mountains salamander, New Mexico meadow jumping mouse, and Mexican 

spotted owl), and many sensitive riparian areas. 

The area in question is home to three Federally listed threatened or endangered species (Mexican Spotted Owl, 

Jemez Mountains Salamander, and New Mexican Meadow Jumping Mouse). Energy exploration and development in 

this area is not compatible with the protections for these species mandated under the ESA, and the Santa Fe 

National Forest will face certain litigation should this exploration and development move forward, given the precarious 

status of these species.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-8. Threatened and Endangered Species and Special Status Species

A compelling consideration is the presence of three federally listed species in the area being discussed for hydraulic 

fracturing and high-pressure steam extraction. The U.S. Fish & Wildlife Service reports that the New Mexico meadow 

jumping mouse has significantly declined in population, primarily due to “habitat loss and fragmentation across its 

range.” Its endangered species designation provides the highest level of protection. The remaining range of the 

federally endangered Jemez Mountains salamander is also centered on the region being discussed for geothermal 

extraction, which also provides critical habitat for the federally threatened Mexican spotted owl. It is impossible to 

imagine how a geothermal extraction project over 10,000s of acres could possibly be carried out while building the 

populations of these imperiled species in the same habitat. 

What about the protection of endangered species and their habitats (see list in Ms Trenchik’s eMail)? I am quoting: 

“Geothermal exploration and development, and connected development (roads and utilities) could have direct, 

indirect and cumulative effects on these species and their habitats.”

There are also there listed endangered species to protect: Jemez Mountain salamander, New Mexico meadow 

jumping mouse and the Mexican spotted owl. 

Threatened and endangered species - There are a number of threatened and endangered species known to occur in 

the project area. Of particular interest with respect to the proposed action is the Northern Meadow Jumping Mouse 

and Jemez Mountains Salamander, both endangered species known to occur in the area. It is likely that geothermal 

development would negatively impact their habitat.

1. Meadow jumping mouse habitat 2. Jemez mountain salamander habitat
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-9. Cultural Resources

Cultural Resources: Given your Archaeology background, you are also no doubt aware of the many Native American 

archeological sites and artifacts that are scattered across the area of the proposed Geothermal Leasing Project. 

We support the position of the All Pueblo Council of Governors to close the forest to geothermal leasing to protect 

traditional cultural sites and uses.25

25 Santa Fe National Forest Geothermal Leasing Draft Environmental Impact Statement.

7. The proposed development area includes spiritual and religious sites of New Mexican native communities. We 

don’t put oil jacks in the middle of cathedrals for a reason. The same reasoning applies here. 

In addition to recreation, all of the Jemez Mountains are sacred to the many pueblos in the area. They are still heavily 

used for traditional food and medicine gathering, as well as religious ceremonies. 1,962 cultural resource sites have 

already been inventoried in the project area, and only half the proposal area has been surveyed. In 2015, the All 

Pueblo Council of Governors passed a resolution, which was submitted to SFNF, steadfastly and unanimously 

opposing this geothermal leasing proposal (Attached as Appendix B). 

Yet, even with the underestimation of impacts through use of the RFDS, based upon the comments and input Santa 

Clara Pueblo has provided to the SFNF, it is clear that Santa Clara Pueblo will suffer disproportionately high and 

adverse environmental effects if the SFNF were to ultimately adopt in the NEPA Record of Decision either DEIS 

Alternative 2 (the SFNF’s preferred alternative to close some lands in the project area to leasing and impose no 

surface occupancy stipulations, time limitation stipulations, or controlled surface use stipulations on those lands for 

which leasing would be allowed) or DEIS Alternative 4 (the so-called “Development Alternative”).1 It is important to 

remember that environmental effects to be considered under NEPA must include cultural, historic, and social effects, 

whether direct, indirect, or cumulative, see 40 C.F.R. §1508.8, and “cultural resources” for NEPA covers a wider 

range of resources than “historic properties” that are part of a Section 106 consultation under the National Historic 

Preservation Act, P.L. 89-665, 80 Stat. 915, 16 U.S.C. §470 (NHPA). Indeed, we commend the SFNF for recognizing 

in the DEIS that Tribal interests and Tribal traditional and cultural resources have a broader definition which includes 

“natural landscape features, ceremonial and worship places, plant gathering locations, traditional hunting and fishing 

locations, ancestral archaeological sites, artisan material locations, rock art, and communal resources, such as 

community-maintained irrigation systems.” DEIS at 3-124. 

1 We are not addressing here any comments regarding DEIS Alternative 1, the No Action Alternative, because the 

DEIS states that Alternative 1 does not meet the purpose and need for the proposed action. See DEIS at 2-6.

Fracking should not be allowed in areas where there is immerse archaeological remains

Tribal Analysis:

EPA believes that the USFS is implementing its Tribal Analysis in accordance with Executive Order 13175 and is 

conducting government-to-government consultations with Pueblo and tribal groups. The Jemez Mountains are a 

sacred place, a sacred landscape and a historic landscape to the Pueblo and tribal groups. The Pueblo of Jemez, 

Pueblo of Zia, Pueblo of Santo Domingo (Kewa), Pueblo of Santa Ana, Pueblo of Cochiti, Pueblo of Ohkay Owingeh, 

Pueblo of Santa Clara, Pueblo de San Ildefonso, Pueblo of Nambe, Pueblo of Pojoaque, Pueblo of Tesuque, Pueblo 

of San Felipe, Jicarilla Apache Tribe, and the Navajo Nation could be directly affected by the proposed project.

The USFS has taken comments received from the public and tribes during scoping under consideration in analyzing 

alternatives. The representative of the groups interviewed (Native American and Hispanic groups) were not in favor of 

geothermal energy development, because of the impacts on water quality and availability. Their desire is to recover 

ownership of lands that were part of their original land base, and are concerned about committing lands to other uses. 

On August 10, 2015, the Pueblos Council of Governors unanimously adopted a resolution advocating closing the 

forest to geothermal leasing.

I support the All Pueblo Council of Governors Resolution No. APCG 2015-11 requesting the designation of the Jemez 

Mountains as a Traditional Cultural Property, and the closure of the entire Santa Fe National Forest to energy and 

mineral exploration and development. The Puebloans’ ancestral claim to these lands, the vast archaeological record 

supporting these claims, the nature of these sites as repositories of innumerable items of cultural patrimony, and the 

traditionally sacred nature of the very springs and waters in question here for the Pueblo peoples, all legislate against 

this being an area appropriate for energy and mineral development.

I do not believe that any geothermal or mineral leasing should be allowed within this area. Among other things 

according to the All Pueblo Council of Governors the area includes materials and items of cultural patrimony. These 

items should not be disturbed.

Jemez Springs, Valles Caldera, Fenton Lake/Cuba, and the entire Jemez region contains some of the most pristine, 

unadulterated and historically significant areas in all of New Mexico. Additionally, many pueblos within and beyond 

the Jemez region are affected. We seriously doubt fracking would be allowed in most of our national treasures, and 

we should be considered as one of those national treasures. This national treasure is near a metropolitan area 

(Albuquerque) and other important small towns/cities and provides a refuge to city dwellers without having to travel 

exhaustive miles for beauty, peace and relaxation.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-31

Table B-9. Cultural Resources

The Village of Jemez Springs is composed of many stone and mud historic buildings, the Bath House being included 

as a New Mexico State Historic structures.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-32

Table B-10. Tribal Interests and Traditional Cultural Resources

Santa Clara Pueblo submits the following comments on the Draft Environmental Impact Statement (DEIS) regarding 

whether the Santa Fe National Forest (SFNF) should consent to allowing the Bureau of Land Management (BLM) to 

conduct leasing of certain SFNF lands in the Coyote, Cuba, Espariola and Jemez Ranger Districts (as shown on 

Figure 1-1 of the DEIS, also known as the project area) for geothermal resource development. As described more 

fully herein, any leasing within the project area for the DEIS will cause a disproportionately high and adverse 

environmental effect on Santa Clara Pueblo which simply cannot be mitigated because of the nature of those 

environmental justice impacts. Therefore, the only National Environmental Policy Act, P.L. 91-190, 83 Stat. 852, 42 

U.S.C. §4321 (NEPA), alternative in the DEIS that the SFNF can and should support in a final environmental impact 

statement and NEPA Record of Decision is Alternative 3, the No Leasing Alternative. 

The full extent of impacts to Santa Clara Pueblo are not acknowledged in the DEIS 

The DEIS acknowledges that “[p]potential impacts” to Tribal traditional and cultural resources could occur if 

implementation of the NEPA alternatives: “- Result in proposed uses that are incompatible with maintaining and 

identifying cultural resources and their qualities[;] - Have an adverse impact on traditional cultural properties and 

cultural landscapes under Section 106 of the NHPA (36 CRF, Part 800)[;] - Impact or restrict access to traditionally 

used hunting, fishing, and gathering areas and species[;] - Change or reduce access to traditionally used or culturally 

important water sources and hot springs[;] - Impact culturally important trails or trail systems[; or] - Impact sacred 

sites or their settings, access, or use[.]” DEIS at 3-127 and 3-128; see also id. at 3-119 (acknowledging potential 

impacts on cultural resources if implementation of an alternative would “[r]esult in uses that are incompatible or that 

interfere with maintaining cultural resources and their qualities or traditional cultural properties, practices, and uses”).

Santa Clara Pueblo respectfully submits that the above-referenced Tribal traditional and cultural resource impacts are 

not merely “potential” impacts for our Pueblo. If any form of geothermal leasing is approved by the SFNF, these 

impacts will occur for our Pueblo community in a manner that appreciably exceeds impacts to the general population. 

Moreover, as part of this DEIS process, even without site-specific geothermal leasing NHPA Section 106 

consultations, we have demonstrated that such impacts will exist for Santa Clara Pueblo if geothermal resource 

development is allowed anywhere in the project area. Therefore, there is sufficient justification in the administrative 

record for this DEIS for the SFNF to not consent to any geothermal leasing (and to not adopt any DEIS alternative 

that includes consent or concurrence for any form of geothermal leasing). 

As the DEIS acknowledges, the SFNF is conducting a landscape-scale ethnographic study of past and present uses 

by various Pueblo and other communities of the Jemez Mountains to support the DEIS and the SFNF has already 

decided that the landscape level ethnographic overview study is being conducted “at an appropriate level for 

determining the impacts of leasing consent.” Id. at 3-127. Santa Clara Pueblo participated in multiple meetings to 

develop that ethnographic overview study and submitted additional written comments this past September on a draft 

of the study.2 In our comments, we described how the entirety of the project area (not solely the so-called “Lease 

Interest Unit”) is a living place of active worship for us and that all the land, water, plant, animals, and natural 

structures within it have a spirit and are related and thus are part of Santa Clara Pueblo’s sacred spiritual sanctuary 

which is reflected in our stories, oral histories, place names, songs, and prayers. Moreover, even though we could not 

and cannot give any specific details about particular sacred sites and uses, in our written comments we provided 

examples of plants, animals, and mineral resources we depend upon and described that our ritual practices (including 

ceremonial hunting and gathering) take place throughout the entire project area and how shrines and trails are found 

throughout the entire Jemez Mountains, and thus would be impacted by any geothermal resource development. We 

also described the importance of springs throughout the entire project area that are needed for our ceremonial 

pilgrimages and we explained how the entire project area (and all of the Jemez Mountains) is interconnected and 

connected to the Caldera, both above and below ground. 

2 The study has not yet been finalized and we were explicitly told that our written comments would still be considered 

timely to be incorporated into the final study.

Importantly, we explained why geothermal resource drilling of any kind would diminish the integrity and traditional 

power and quality of various Traditional Cultural Properties found throughout the entire project area, and why such 

drilling would adversely affect our traditional/cultural practices and uses. As our written comments on the draft Jemez 

Mountains ethnographic overview study described, everything has a living component -- the mountains, the springs, 

the shrines, the streams, the plants, the animals, the vistas, the rocks, the mesas, and even the Caldera itself -- that 

connects us to the ancestors and the deities and to all peoples and therefore the entirety of that landscape, above 

and below ground, must be respected to keep those connections intact. In our verbal comments at meetings about 

the draft ethnographic study, we emphasized how interconnected the Caldera was to the project area and the 

importance of not awakening and angering the Caldera because of the destruction and loss of life for all living things 

that would result from awakening Mother Earth in that way. Thus, these so-called “potential” impacts to Tribal 

traditional and cultural resources from geothermal development noted in the DEIS already have been demonstrated 

by Santa Clara Pueblo in the record through our comments on and for the draft landscape-level ethnographic study 

which the SFNF already deemed the acceptable level of study needed for determining whether of not to grant 

geothermal leasing consent to the BLM. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-10. Tribal Interests and Traditional Cultural Resources

We also submit there are foreseeable “significant” (as defined by NEPA regulations) impacts to our cultural and 

ethnographic resources through deterioration of structures, shrines, springs; and viewsheds from vibration, dust, 

exhaust, or watershed erosion that would be produced by construction, drilling, or operation of geothermal facilities 

and any such geothermal operations will alter the power and significance of those areas in a manner that cannot be 

restored once altered. Harming any of these sites permanently alters our spiritual connection to our ancestors at 

those places and any drilling, even if it is the presumably less invasive advanced technology “direCtional drilling”

proposed as a mitigating no surface occupancy or “NSO” stipulation in DEIS Alternative 2 (see DEIS at 2-3), also will 

harm those connections because of the awakening of the Caldera and because of the fact that the Caldera is 

interconnected to the rest of our Jemez Mountains traditional and cultural use areas. 

The DEIS acknowledges that the SFNF “is responsible for considering the impacts of its actions on traditional cultural 

properties and traditional cultural practices,” id. at 3-118, and states that the SFNF “will address environmental justice 

populations in the project area in the EIS to mitigate any disproportionate environmental impacts on [minority] 

populations.” Id. at 3-148. Yet, then the DEIS goes on to state that the “programmatic nature” of the DEIS renders it 

impossible for the SFNF to “analyze[e] specific environmental justice populations in the project area at this time” for 

both DEIS Alternatives 2 and 4. Id. at 3-152. This statement and analysis must be revised in the final environmental 

impact statement as Santa Clara Pueblo has provided sufficient information to demonstrate such environmental 

justice impacts on the Pueblo if Alternatives 2 or 4 are adopted.4

4 The DEIS contains no clear conclusion about whether environmental justice impacts exist for Alternative 3, the No 

Leasing Alternative, but admits that “[t]here would be no impacts associated with geothermal development, and the 

current social and economic profile of the surrounding area would be retained.” DEIS at 3-152.

The environmental justice impacts to Santa Clara Pueblo from geothermal drilling of any kind in the project area 

cannot be mitigated. In other sections of the DEIS besides the environmental justice section, it appears that the DEIS 

wrongly implies that mitigation is possible for impacts to Traditional Cultural Properties, Tribal traditional and cultural 

resources, and traditional cultural practices for Santa Clara Pueblo caused by geothermal development. For example, 

the DEIS at 2-22 states that, for Alternative 2: (1) “[t]he potential for impacts on cultural resources would be reduced 

by additional closures and stipulations”; (2) “[s]stipulations for other surface uses may also incidentally reduce the 

impact potential on cultural resources;” and (3)”[t]here would be new closures and NSO stipulations for traditional 

cultural properties and Native American sacred sites, as identified through consultation and site-specific consideration 

of impacts on tribal interests and traditional cultural resources and uses and their settings for each phase of 

geothermal development.” These statements appear to assume that not disturbing surface areas where geothermal 

drilling occurs (the so-called NSO stipulations) or closing off certain specific places to leasing while keeping other 

places open for drilling will provide sufficient mitigation. But, as we have explained in our verbal and written 

comments on the draft landscape-scale ethnographic study, those assumptions are incorrect. The entirety of the 

project area, both above and below ground, is interconnected. Thus, drilling in any area of the Jemez Mountains will 

awaken the Caldera and will irreparably alter the integrity, the quality, and the power of the area for the connection to 

the ancestors, spirits, and deities. This discussion must be fixed in the final environmental impact statement. 

Because no mitigation is possible for these environmental justice impacts to the Traditional Cultural Properties, Tribal 

traditional and cultural resources, and traditional cultural practices of Santa Clara Pueblo, the only viable NEPA 

alternative in the DEIS that the Forest Service should adopt in the final environmental impact statement and Record 

of Decision is Alternative 3, the No Leasing Alternative
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-34

Table B-10. Tribal Interests and Traditional Cultural Resources

It is well within the SFNF’s discretion to choose the No Leasing Alternative. Moreover, doing so would be in keeping 

with the USDA Office of Tribal Relations’ and USDA Forest Service’s Report to the Secretary of Agriculture: USDA 

Policy and Procedures Review and Recommendations: Indian Sacred Sites (Dec. 2012).5 In that report, the USDA 

Office of Tribal Relations and USDA Forest Service specifically noted that a frequent complaint of Indian nations was 

that Forest Service managers “sometimes do not use the discretion currently available to them in laws and policies 

for the benefit of the Tribes” and that “sacred site issues are not weighed equally with competing uses of the [National 

Forest Service].” See id. at 2. Of course, because cultural resources has a broader definition in NEPA than the 

narrower definition of sacred sites in Executive Order 13007, Indian Sacred Sites (May 24, 1996), this DEIS provides 

a notable opportunity for the SFNF to more fully incorporate that broader understanding of Tribal cultural landscapes 

and sacred uses of resources by exercising its discretion to deny consent to BLM for any geothermal leases on SFNF 

lands. And, of course it is essential to remember that a primary policy goal of NEPA is to “preserve important historic, 

cultural, and natural aspects of our natural heritage, and maintain, wherever possible, an environment which supports 

diversity and variety of individual choice.” 42 U.S.C.§4331(b)(4). It is with this spirit that Santa Clara Pueblo offers 

these and all of our comments, because the project area at issue in this DEIS is intricately linked to our cultural 

heritage and is part of our place of worship and integral to the cultural survival of the Santa Clara people. We do 

realize that our written comments on the draft landscape-level ethnographic study occurred after the issuance of the 

DEIS so that the SFNF did not have the benefit of having those before the DEIS was issued. Now that you do have 

them, however, it is incumbent upon the SFNF to not concur or consent to BLM allowing geothermal resource 

development leasing on any of the DEIS project area lands and to adopt Alternative 3, the No Leasing Alternative, as 

the SFNF’s preferred alternative in the final environmental impact statement and in any Record of Decision resulting 

from this DEIS.

5 http://wwwfsled.us/spf/tribalrelations/documents/sacredsites/SacredSitesFinalReportDec2012.pdf

Many sacred, indigenous sites are at risk

It is Ohkay Owingeh’s desire to make a written determination in the above reference subject. I am disappointed there 

have been no “tribal specific meetings” or any type of “tribal consultation” to discuss this Draft Environmental Impact 

Statement (DEIS). As traditional stewards of our ancestral domains, Ohkay Owingeh continues to hold firm to our 

position. The Pueblos have been caretakers of the forest from time immemorial and what the Forest Service and 

Bureau of Land Management are proposing, if approved, will have lasting irreversible and unmitigable negative 

impacts on the cultural values, traditions and practices of the Pueblos and Tribes, as stated in our letter to you dated 

June 22, 2015. I believe Executive Order 13175 clearly states that processes must be in place to ensure meaningful 

input by tribal officials in the development of policies that have tribal implications

The Jemez Mountains and the entire proposed project area is Traditional Cultural Property, in and of itself sacred, 

and contains sites, plants, minerals, wildlife, ground and surface water including springs, Native American graves, 

and cultural patrimony integral to Native American religious practice; therefore the proposed action will directly harm 

and interfere with Native American religious practice, is contrary to the Native American Religious Freedom Act and 

will cause unmitigable harm to cultural resources and sites in the proposed project area

This DEIS tiers to and incorporates the 2008 US Department of the Interior, Bureau of Land Management’s (BLM) 

recommendation to and approval by the Assistant Secretary of Land and Minerals Management Record of Decision 

(ROD) associated with the Programmatic Environmental Impact Statement (PEIS) for Geothermal Leasing in the 

Western United States. The PEIS for Geothermal Leasing in the Western Unites States is indefensible and must be 

rescinded pending appropriate and lawful tribal consultation. Tribal consultation was incomplete and pro forma at 

best, making a mockery of the spirit and letter of Executive Order 13175, the National Historic Preservation Act, and 

even BLM’s Handbook H8120 Tribal Consultation Under Cultural Resource Authorities, 2004. 

As Governor of the Pueblo of Laguna, I write in support of protections for indigenous sacred sites located in potential 

geothermal development areas of the Santa Fe National Forest. The lands under consideration have been occupied 

and used by the Pueblo People from time immemorial and continue to be of profound spiritual and religious

importance even today. 

Although the Pueblo of Laguna is not opposed to green and renewable energy development, like the use of 

geothermal resources, we have concerns that such development in this area will negatively impact our People’s use 

of the land. Our People collect medicinal plants, animals, and mineral resources for traditional ceremonies from the 

areas under consideration for geothermal development. Hunting structures and shrines occupy the development 

area. Development may cause fragmentation of the landscape and adversely impact our spiritually significant plants 

and animals. 

Rather than allowing these lands to be diminished forever by development, we suggest that the area be designated 

Traditional Cultural Property, as was done on Mount Taylor in the Cibola National Forest. I ask on behalf of our 

people that you deny mining and energy development on Santa Fe National Forest land. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-35

Table B-11.Visual Resources

Lights from up to 30 drilling pads and five power plants could have an adverse impact on the dark night skies that the 

remote Valles Caldera and Bandelier are known for. 23

23 Id.

Unless very carefully sited with a priority given to viewsheds, drilling operations, power plants, roads and traffic, and 

transmission lines will have an adverse impact on iconic scenic viewsheds, both within the NPS lands as well as from 

outside VALL and BAND looking in. 

Page 2-23 of DEIS, Table 2-4 Comparison of Alternatives, Visual resources: New Mexico is a beautiful State. The 

thought of destroying our visual beauty with power plants, power lines, unnecessary roads, heavy equipment traffic 

etc. is heartbreaking. Our State is poor but will the small amount recouped from this endeavor serve to replace all that 

is lost? The landscape will be changed. The landscape will be impacted. The beauty of our National Forest will be 

lost. 

Geothermal exploration is very important as long as it does not destroy the scenic and natural beauty of any given 

site possibly expect the public to even give this a quick read over a holiday weekend when many of us have previous 

plans which prevent attending? 

The last concern would be considerably mitigated by slightly extending the “closed to leasing” area to surround the 

private lands in the southeast corner of the Middle Unit. This would also protect scenic areas such as Mushroom 

Basin, Ice Cave Canyon, and access to San Antonio Hot Springs

Improve the analysis for visual resources by providing a general description of the landscape of the project area to 

base an analysis of general effects that can reasonably be considered

Page No.: 3-135 to 3-140

Section, Paragraph, Table or Figure No.: Sections 3.17.2.3 through 3.17.2.8

Comment: The impacts discussion is not helpful in understanding impacts to visual resources. The analysis tiers off 

of the Programmatic through Environmental Impact Statement (PEIS) for Geothermal Leasing in the Western United 

States (Bureau of Land Management and Forest

Service, 2008) for the base impacts that are very general. While there is not a specific project or location to analyze, it 

should be possible to provide a brief description of typical project components and what the potential typical impacts 

might be. There is a good and somewhat extensive discussion of potential night sky impacts. The NPS request 

similar impact analysis for visual resources be conducted. While much of the area around Valles Caldera NP would 

be closed, No Surface Occupancy (NSO) or Controlled Surface Use (CSU) depending on the alternative, it would still 

be good to know what potential effects might be - and the potential distance from the monument which could reduce 

those effects. Some general effects to consider:

• Are drilling rigs likely to be visible in this landscape and vegetation cover? What about in production? Seems in 

many cases the piping system once in production would not be

visible.

• What about pads - if they are small enough they may not be visible (could point to useful mitigation to limit size).

• Power plant is likely to be visible from good distances - what about the vapor plume? Visible year round - only under 

certain conditions?

• Transmission lines in the PEIS are described as fairly short wooden poles with 40’ right-of-way (ROW). How visible 

are the poles and ROW likely to be in this landscape?

Page No.: 3-136

Section, Paragraph, Table or Figure No.: Section 3.17.2.3

Comment: The analysis could be strengthened by better articulation of the assumptions. We suggest the following 

change: “Assuming spatially isotropic illumination and light of sight conditions, with no scattering or reflection due to 

aerosols, leaves, or other objects, the distance for lighting on a drill rig to diminish to the illumination of starlight and 

natural airglow on a clear moonless night (0.002 lux Table 3-19), is approximately 10,000 feet, or two miles.”

Page No.: 3-136

Section, Paragraph, Table or Figure No.: Section 3.17.2.3 Paragraph 5 Sentence 20

Comment: The distance for oil rig illumination to the south is incorrect, due to an error and inconsistency in our April 

28, 2016 letter. The sentence should be corrected to read “Using this information, the strongest direction that light 

shined from the source was south with 1.3 lux at 375 feet.”
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-36

Table B-11.Visual Resources

Power transmission lines attached to tall pylons will have to be constructed to transport the generated electricity to 

population centers. They will be very hard to hide from view. Apparently the possibility of underground transmission 

lines was mentioned at one of the meetings which I could not attend. I do not believe that this is a feasible solution. 

Underground transmission lines are costly and more difficult to construct and their construction is very disruptive to 

the land. Unstable slopes and bedrock formations must be avoided. Man holes and splice boxes must be installed 

along the underground line. Outages may last much longer as the line must be unburied. Large “riser structures” with 

large attachments are needed at the locations where the line transitions from underground to overhead. For these 

reasons, underground transmission lines are in most cases only considered for airport or downtown urban areas with 

no viable overhead corridor and are not a feasible solution for miles of power lines traversing the forest. This will 

leave operators with the only option of installing of overhead transmission lines which will require the clearcutting of 

many acres of forest on both sides of the lines and running roads to maintain these lines. This will tremendously 

enlarge the footprint of a geothermal power project and will probably make it impossible to operate if the No Surface 

Occupancy Stipulations are taken seriously

Geothermal power plants will have a large footprint in the forest and their stacks will belch water-vapors and 

potentially dissolved geochemicals into the air which will be visible from a long distance. Such a scenario will distract 

from the natural and scenic beauty of the entire area and maintaining an undisturbed attractive view shed appears to 

be impossible under such conditions. Also, the potential of offensive odors and environmental, health and safety 

problems caused by poisonous, corrosive, flammable and explosive hydrogen sulphide (causing the “rotten egg 

smell”) in the released vapors needs to be addressed. 

3. Viewshed degradation specifically impacting recreation on the valles caldera national preserve planned RIM trail.

Page No.: 3-131

Section, Paragraph, Table or Figure No.: Section 3.17.1

Comment: The affected environment section can be improved by including a description of what the landscape of the 

project area looks like. While this is a programmatic level document and there is not a specific project site, it still 

should be possible to describe the landscape in more detail than is provided. What is the vegetation of montane 

woodlands - colors, how tall, how dense? What is the topography besides just a change in elevation from 6,300 feet 

to 10,000 feet? Is it the same in every geographic area except where there are canyons to the southwest? Seems as 

though the different lease areas set it up for an easy discussion of the visual setting in a logical way.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-37

Table B-12. Social Interests, Economics and Environmental Justice

Environmental Justice - Communities surrounding the affected area in Rio Arriba County are all below the mean 

annual income for the US and the state of NM. Many residents live below the poverty level. Impairments of natural 

resources such as wildlife, forests, and grazing range will have a profound impact on their quality of life. The number 

of jobs resulting from geothermal leasing under the proposed action will” be minimal and of short duration.

Property Values - Clearly, anyone of the potential negative effects listed above could negatively affect the property 

values of the permanent and seasonal residents of the Jemez Mountains. Should the streams suffer from depletion or 

earthquakes commence, those of us who call the Jemez mountains home, have owned property here for generations, 

or depend on revenue from visitors would suffer devastating financial losses. The ensuing economic loss to both the 

individuals and region could be devastating.

who benefits financially and who is left with a mess after the fracking/extraction is abandoned? What is the history of 

restoration?

Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income 

Populations, 59 Fed. Reg. 7629 (Feb. 11, 1994), provides that “[e]ach Federal agency shall make achieving 

environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and 

adverse human health or environmental effects of its programs, policies, and activities on minority populations and 

low income populations.” The Executive Order is clear that the provisions apply fully to Native Americans. In 1997, 

the Council on Environmental Quality (CEQ) issued a guidance document regarding environmental justice that 

“interprets NEPA as implemented through the CEQ regulations in light of Executive Order 12898.” Council on 

Environmental Quality, Environmental Justice: Guidance Under the National Environmental Policy Act (Dec. 10, 

1997), (“CEQ EJ Guidance)3 at 21. The CEQ EJ Guidance states that agencies should consider “the effect of any 

disruption on the community structure associated with the proposed action; and the nature and degree of impact on 

the physical and social structure of the community.” Id. at 9. Through our participation in the development of the stillto-be-finalized landscape-level ethnographic study, we have provided ample examples of the disruption any 

geothermal drilling would cause to the Santa Clara Pueblo community. 

3 http://ceq.doe.govinepairegs/ej/justice.pdf

In addition, when determining whether environmental effects are disproportionately high and adverse, agencies also 

must consider “[w]hether environmental effects are significant (as employed by NEPA) and are or may be having an 

adverse impact on . . . Indian tribes that appreciably exceeds or is likely to appreciably exceed those on the general 

population.” Id. at 27 (reciting text of Executive Order 12898 regarding “Disproportionately high and adverse 

environmental effects” at §1-101). The impacts to Santa Clara Pueblo at issue are “significant” as that term applies to 

NEPA, thus meeting this environmental justice requirement. See 40 C.F.R. §1508.27 (significance analysis can 

include addressing the severity or intensity of the impact, while taking into consideration unique characteristics of the 

area including its cultural resources, and the degree to which the action may adversely impact sites eligible for listing 

on the National Register of Historic Places or may cause loss or destruction of significant cultural resources). As we 

described in our comments on the draft landscape-level ethnographic study, we have rituals and ceremonially defined 

procedures involved with our hunting activities, and we depend upon a wide variety of animals, including big and 

small game, and a large variety of song birds and predatory birds, for various needs, including food and ceremonial 

needs. The impacts to the habitat of migratory wildlife species from geothermal resource development have generally 

been acknowledged in the DEIS (see, e.g., DEIS at 3-84 (noting that the “amount of habitat actually affected by 

disturbance and fragmentation extends beyond the habitat disturbed”)) but not as it relates to environmental justice 

impacts to the Pueblo. Wildlife habitat disturbance and fragmentation caused by geothermal development would 

displace species of cultural and ceremonial importance to us in a manner that is “significant” (as defined by NEPA 

regulations) and, because of our intense and greater uses of these species than that of the general population, the 

impacts appreciably exceed that of the general population. 

As a local, authentic small business directly dependent on this natural resource, we can not afford the possibility of 

our hot water system here being compromised by the drilling in the area to be done by large corporations who don’t 

recognize our therapeutic importance to our customers and who likely wouldn’t care were they to put us out of 

business for good. We’d like to have assurances that even though this is through a governmental agency, that we will 

be reimbursed for any losses we incur due to these kinds of projects–either by the corporations or by the government. 

We stand to lose a lot if something happens due to the drilling, and we need to know that we will be able to file for 

reimbursement and actually BE reimbursed quickly.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-38

Table B-12. Social Interests, Economics and Environmental Justice

Changes to the hot water system here will effect the tourism (and so all of the businesses that are dependent on 

tourism) in our area as many of the tourists come here for the hot water. It could potentially completely ruin the area 

as a tourist destination. Having a 200 foot swath of trees cut to put power lines through not add to the beauty of the 

Jemez Mountains and will make the area less desirable for tourism and residents, as well. There’s also the potential 

effects to consider regarding the housing and property market in the area. If these projects degrade the drinking 

water aquifers, detract from the beauty of the area, wreck the hot springs, cause a decrease or stop in tourism traffic, 

cause earthquakes, etc.–current residents may move out, and potential residents will look elsewhere. The potential 

for changing the whole Jemez mountains area as well as the Village of Jemez Springs seems to be at a high risk with 

this kind of development and activity and this should be seriously considered and concretely dealt with before 

anything is ever allowed to happen.

Geothermal energy is something that should be explored, but while large corporations make money off of it, small 

businesses and residents in the area shouldn’t be considered “collateral damage” in the process. There needs to be a 

good reimbursement/compensation plan in place for potential damages and it should be ironclad--with an escrow 

account set up in advance to be accessed immediately with no law suits necessary if the potential hazards are 

realized. We’ve been in business here for over 20 years. We’ve weathered tough summers trying to make

a living due to Super Fires and bad economic times. We’ve finally reached a point where business is really picking up 

now and we’re able to expand our capacity and revenue. This is an exciting time for us and for our customers who 

have been asking us to do this. We shouldn’t have to worry about the “what if’s” of some corporate energy 

businesses who could potentially ruin it all and not be held accountable. While it may not be the business of the 

Forest Service to make these assurances for the corporations involved, it is the business of the Forest Service to

take our concerns seriously and put in place stipulations that include reimbursement for loss of income or damages to 

businesses and residents who might be effected BEFORE the considerations of the drilling corporations. Maybe 

knowing that they have to consider financial damages for their actions ahead of time will force them to include these 

things in their budgets, and have the funds available immediately.

In addition to the adverse effect of geothermal drilling to the Forest and wildlife, our property value will decrease 1) if 

the Rio Cebolla is depleted and/or contaminated, 2) if unwelcome noise results from power plant and related facility 

operations, and 3) if poor air quality results from fugitive dust and power plant emissions etc. If our property value 

decreases because of the decision to allow geothermal drilling, we would have to explore appropriate legal options.

Page 2-14 of DEIS, Table 2-3 Summary of Surface Disturbances from Drilling and Utilization: My husband is from the 

Cuba area. In the late 60s/early 70s an open pit mine was established between the Village of Cuba and the National 

Forest on Highway 126. The community was promised jobs and if the mine should close the environment would be 

returned to its original state. The mining operation lasted about 10 years. The jobs ended but the tailing ponds 

remain. The beautiful meadow that once was home to deer and elk is now cordoned off due to the contaminated 

waste that will remain for an indefinite number of years. Just as the mine near Cuba had many “unknowns” so does 

this project. I asked the Forest Geologist if this project was going to be limited to five power plants and he replied it 

depends on what geothermal activity is discovered below the soil. I asked are we talking about 5, 10, 15, 20 how 

many potential power plants -- and he didn’t know. According to this report 10 acres of land are disturbed for EACH 

power plant and related facilities. I find this very troubling and a great deception to the general public that the DEIS 

implies that you are considering five power plants but that the potential for more remains unknown – a fact the 

general public is not aware of. Upon reading the DEIS the public is lead to believe that only five power plants are 

being considered.

Even though geothermal power accounts for less than 1% of all of the sources of power produced in the United 

States, geothermal companies are subsidized by taxpayer dollars due to their extremely high up-front capital costs. It 

is not popular among investors for this reason and so as a “green” energy source, it is not likely to grow much or soon 

in the U.S. market. Nevertheless, it is pushed both by laws and politics, and especially by the current administration. 

Even though geothermal power accounts for less than 1% of all of the sources of power produced in the United 

States, geothermal companies are subsidized by taxpayer dollars due to their extremely high up-front capital costs. It 

is not popular among investors for this reason and so as a “green” energy source, it is not likely to grow much or soon 

in the U.S. market. Nevertheless, it is pushed both by laws and politics, and especially by the current administration. 

Incidentally, the only profit for the local area is the creation of 388 temporary construction jobs and about 212 

permanent jobs for those who qualify in the field, according to the SFNF. (The Geothermal Research Council claims 

the number of jobs would be 5200 temporary construction jobs and 1840 permanent jobs). The electricity will be sold 

to the grid by the geothermal company. It does not lower the cost of electricity for New Mexicans. The BLM will get 

royalties and the county will get a small amount as well from the company’s sale of the power to providers. The 

money spent for all this from the SFNF’s budget, however, will not be reimbursed. 

Drying of hot springs in the surrounding area: Leading to loss of scenery and tourism (which the small surrounding 

Native/Non- Native communities depend on), and loss of rare thermophillic plants and algal growth. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-39

Table B-12. Social Interests, Economics and Environmental Justice

Our natural and exquisite Jemez Mountain area is a draw for tourists which is one of our primary sources of revenue 

in this state. Wilderness values of peace and quiet, beautiful landscapes and abundant wildlife make the Jemez a 

very special place. Let’s not “throw the baby out with the bath”. Our precious and rare natural landscape should not 

be subject to commercial development for private profit. The Jemez belongs to us all and hopefully to future 

generations as well. Please do not lease our public lands for Geothermal or any other extractive enterprise. Stay with 

your purported vision to: plant trees, improve trails, educate the public, and improve conditions in wildland/urban 

interfaces and rural areas, to promote sustainable forest management and biodiversity conservation.

The geothermal process would most likely also steal the heat from the many Jemez hot springs so attractive to 

tourists, and thus could adversely impact the tourist industry. As a result of geothermal development in New Zealand: 

“The withdrawal of geothermal fluids for electricity production in the Wairakei basin resulted in the extinction of all 

geysers (about 70), loss of approximately 240 hot springs. . . and ground subsidence of 14 meters [about 46 feet], the 

largest ever recorded for any type of fluid withdrawal including gas and oil.” (Environment Waikato Regional Council 

2006) The EIS must contain an analysis of the possibility of similar loss of heat and pressure to the Jemez’ many hot 

springs and of the danger of a similar ground subsidence as occurred in New Zealand being repeated in the Jemez. 

Mountains, together with an assessment of the danger of earthquake caused by such subsidence. It should assess 

the impacts on the New Mexico tourist economy, should the many Jemez Mountain hot springs be destroyed.

Environmental Justice Analysis:

Based on Race/Ethnicity in 2014, all populations in the project area have more than 50 percent aggregate minority 

populations, and therefore qualify as minority populations under CEQ guidance. A large percentage of the population 

in the area identify as American Indian. The USFS noted that it will address environmental justice populations in the 

project area in the EIS to mitigate any disproportionate environmental impacts on these populations, following 

guidelines set forth in Executive Order 12898.

The degree of impact and contribution to cumulative impacts would vary by alternative.

Per SFNF, the programmatic nature of this EIS does not allow for analyzing specific environmental justice 

populations in the project area at this time. Site-specific considerations for environmental justice populations must 

occur to mitigate any disproportionately high and adverse impacts from geothermal development, in compliance with 

Executive Order 12898. Without site-specific plans for geothermal development, impacts on environmental justice 

populations in the project area cannot be determined at this time.

The trust responsibility is the US government’s permanent legal obligation to exercise statutory and other legal 

authorities to protect tribal lands, assets, resources, and treaty rights, as well as a duty to carry out the mandates of 

federal law with respect to Native American tribes. EPA recommends that the SFNF make every effort to decide on 

an alternative that has the least adverse impact to the Environmental Justice populations and tribes. We further 

recommend that SFNF utilize the Promising Practice Report to supplement the applicable requirements for 

considering and analyzing the Environmental Justice populations and tribes for each phase of the proposed project. 

For specific assistance with regard to the above comments, please contact Agatha Benjamin, P.E. at (214) 665-7292, 

EPA Region 6,1445 Ross Ave, Dallas, TX 75202.

Impacts to nature and nature-oriented tourism. The entire area of consideration and the particular “Lease Interest 

Unit” immediately surround Valles Caldera, which recently gained enhanced protection and support as a national 

park. Equivalent and adjacent wild areas are now being proposed for geothermal exploration, which involves 

infrastructure encroachment, damage to the surrounding biological communities, subsurface destabilization, and 

water pollution very similar to those caused by hydraulic fracturing for natural gas. The proposed area is part of the 

same volcanic system and is indistinguishable from the geology, plant and wildlife of Valles Caldera and Jemez 

Canyon. It makes no sense to say that part of this pristine habitat should be strongly preserved, while the adjacent 

pristine habitat should be sacrificed. This situation takes me back to two previous times in the life of Valles 

Caldera/Baca Ranch. In the mid-1970s, I was a high school student and spent five summers as a student, then 

counselor, at Hummingbird Music Camp, alongside the Jemez River in the “JNRA Unit” of the proposed geothermal 

extraction area. I was transformed by living and learning in that spectacular valley and welcoming community. At the 

same time, I was sobered (and felt our natural heritage was being taken from us) by the constant roar of heavy trucks 

with air brakes rumbling day and night down the mountain valley, with loads of logs from clear cuts in the Valles 

Caldera and Santa Fe National Forest. It was a great step forward when Valles Caldera became protected, and the 

Forest Service adopted sustainable forestry practices to keep its forest and rivers healthy well into the future, while 

also using prescribed burns to protect against catastrophic wildfires. The establishment of the Jemez National 

Recreation Area and the Wild and Scenic River designation for the East Fork of the Jemez River underscore their 

high natural value and importance for tourism.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-40

Table B-12. Social Interests, Economics and Environmental Justice

Yet now the SFNF proposes that the same area should take two steps back in time, to again feel the roar of heavy 

machinery, installation of ugly and damaging infrastructure, cutting of roads into the forest, disturbance of stream 

quality, steam and chemical damage, and diminished quality of life for those who live in this peaceful valley and 

depend on its tourism. We need to come to grip with the fact that there are very few areas in our country left with this 

quality of natural, cultural, and archeological heritage. We need to strongly conserve what we are so fortunate to 

have. I am a member and keen supporter of Los Amigos de Valles Caldera and the partnership of dozens of groups 

working to restore areas impacted by human disturbance and fire suppression, through the Southwest Jemez 

Mountains Collaborative Forest Landscape Restoration project. This project brings the whole region – its land and its 

people - long-term benefits. Geothermal extraction is the diametric opposite – a project that in the best case 

significantly benefits a commercial enterprise, while causing lasting damage to the land and the neighboring 

communities. 

Due to all the above-mentioned risks and consequences, as a resident I am not only worried about my own and other 

residents’ quality of life and our safety, but also worried that our property will lose in value or become totally 

worthless. Who would want to buy a home in an area with wildfire and earthquake risks (think alone of insuring a 

home in such areas!!!), without well water or with bad water, breathing polluted air, looking at burnt or clear-cut areas 

and power lines everywhere, being exposed to the noise and other negative effects of increased, heavy traffic - isn’t 

this a total nightmare? As for the local businesses: Would tourists still come under such circumstances, especially in 

case some of the main attractions, the warm and hot springs, are destroyed?

Environmental Justice - Communities surrounding the affected area in Rio Arriba County are all below the mean 

annual income for the US and the state of NM. Many residents live below the poverty level. Impairments of natural 

resources such as wildlife, forests, and grazing range will have a profound impact on their quality of life. The number 

of jobs resulting from geothermal leasing under the proposed action will be minimal and of short duration.

Finally, the area surrounding LANL has the largest concentration of people of color of all the DOE sites. Thus, putting 

these communities at risk would be discriminatory. There have been no comprehensive studies of disparate impacts 

on this population from the project and the possible releases from LANL earthquakes. 

These hydrofracking activities will completely change the nature of the forest, turning it into an industrial zone instead 

of a wilderness area. They could also destroy the Jemez hot springs, ruining a source of income for the local 

economy and switching the income potential of the area to outside interests. Huge electric lines, traffic, noise, roads, 

lights and other activities could become the norm throughout the forest instead. My property on Mesa Poleo could be 

impacted as you run these lines and roads through the Forest Service land that is right next to my property. This 

would destroy my property value and my personal enjoyment of my land. 

What will happen if an operator decides to cease exploration/production? Will there be sufficient funds posted by 

operators to restore the project areas to their condition before exploration/production commenced? What will happen 

if an operator goes bankrupt or decides to abandon its business activities? Will the tax payer have to foot the bill? Will 

it be deemed acceptable to have a huge mess left behind from the days of geothermal exploration/production in the 

Jemez such as unsightly plant ruins, abandoned power transmission lines and roads to nowhere? 

The proposed project area encompasses a highly valued recreation area for New Mexicans and tourists from the rest 

of the U.S. and around the world alike. The Valles Caldera National Preserve and the Jemez National Recreation 

Area are in the very middle of the project area and stand to be affected by any large scale industrial development in 

the adjoining National Forest. I would like to urge the decision makers to carefully weigh the potential benefits of the 

proposed geothermal project against the proven benefits of tourism, a clean industry which has been carefully 

groomed and developed by many small area businesses over the years and may be badly affected by industrial 

activities in the neighboring National Forest

If an industry comes into a community, it may generate jobs and offer an improved tax base but it may also change 

the social fabric of the community with unexpected and undesirable results. More public services such as schools, 

law enforcement, EMS services may be required which the community may not be able to provide on short notice. 

The community may be unable or unwilling to quickly expand its service base because of lack of funds or due to the 

fear of being left with a ghost town once the boom is gone and the bust has set in. Any large scale industrial 

development relying on one or a few operators is liable to produce such undesirable results once these operators 

have determined that they would like or have to cease production and move on.

The DEIS indicates that geothermal development could lower the temperature of existing hot springs. I am concerned 

about the degradation of these existing hot springs, a major draw to the area, if leasing were to occur. New Mexico 

needs tourism dollars more than geothermal development dollars. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-41

Table B-12. Social Interests, Economics and Environmental Justice

I believe that the geothermal plume that extends from the Caldera southwest to Jemez Springs is vital to the 

economy of Jemez Springs. Many peoples from all over the world come to the Jemez specifically for these hot 

springs. The EIS study says that “...San Diego Canyon could be impacted by extracting and reinjecting geothermal 

water...”! 

Who benefits from the hydraulic fracturing being proposed? Simple: An out-of-state corporation that only wants the 

big $$$$ and could really give a damn of the damaging sequence of events that could occur to the residents of the 

Jemez Valley and surrounding areas. And, get this: The residents of the Jemez Valley get NO BENEFIT...no 

decrease in utility costs, no plusses whatsoever overall. So, we take all the risk and no reward. What a deal.

The geothermal plume that extends from the Caldera southwest to Jemez Springs provides hot water that is vital to 

our economy.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-42

Table B-13. Health and Safety

Proximity to los Alamos - The primary responsibility of the Laboratory is assuring the safety and reliability of the 

nation’s nuclear deterrent. To invite fracking into the Jemez area is to invite risk to the nation’s safety and the security 

of the technology and materials stored at LANL.

Page 2-24 of DEIS, Table 2-4 Comparison of Alternatives, Health and safety: We lived through the Las Conchas fire. 

We were some of the lucky ones and the fire did not reach our community. But it was close enough. By having these 

power plants right in the middle of the Forest greatly increases our risk for another fire. Taking out all the trees, the 

trees that have stood for hundreds of years, for a project that might only last a decade (if not less) is sickening. 

However, the trees are only part of the problem. What about the coming and going of service equipment and the 

increased potential of human caused fires. Another fire such as the Las Conchas fire would be devastating to the 

wildlife and people residing in and near the forest but what about another fire reaching Los Alamos where nuclear 

waste/material resides in the National Lab. Has the impact of this project now reached another level – affecting the 

Nation? As the Las Conchas fire grew, the level of national uncertainty grew. People were concerned that the fire 

might reach Los Alamos where the Los Alamos National Laboratory resides. It almost did. We, the average people, 

do not know the level of nuclear experimentation that occurs in our National Lab nor the amount of nuclear waste that 

is housed there. A fire reaching the lab could be disastrous to New Mexico and the Country as a whole. 

Violent explosions caused by build up of a ‘steam pillow’ in empty hot underground reservoirs, which have previously 

killed people working in geothermal plants. (see Goff and Goff, 1997). 

Please remember that SFNF is not bound to allow geothermal leasing here by any law, rule, or guidance whatsoever. 

Federal and State laws that require a certain percentage of renewable energy to be available by the year 2020 could 

easily be met with solar energy in New Mexico which has from 283 to 350 days a year of sunshine, depending on the 

location. No need to use less desirable and more damaging technologies here, especially when the possible 

consequences are extremely high with the nearby location of Los Alamos National Lab where massively lethal 

nuclear weapon pits are manufactured and nuclear materials are stored in massive amounts. PF-4 alone contains at 

least 4 metric tons of plutonium, the most dangerous substance known to humankind. And Material Disposal Area G, 

Technical Area-54 contains over ten million cubic feet of radioactive and hazardous wastes buried in unlined pits and 

trenches, quite vulnerable to exposure and release during possible earthquakes. “In addition to direct discharges into 

the canyon systems running down from the LANL site, radioactive liquid waste and other radioactive wastes have 

been disposed of in unlined pits, trenches, and shafts across LANL property. For example, large volumes of laundry 

wastewater that was contaminated with high levels of gross alpha, gross beta, plutonium, and radioactive strontium 

were disposed of in unlined pits above Los Alamos Canyon from 1945-1961. In 1993, the Omega West reactor was 

discovered to be leaking tritium into Los Alamos Canyon. In 2004, high concentrations of hexavalent chromium (over 

400 micrograms per liter (μg/L)2) were detected in the regional aquifer beneath Mortandad Canyon.3 (LANL, 2006b)”

“LANL-derived contaminants are discharging from springs along the Río Grande. Perchlorate and organics (e.g., 

bis(2-ethylhexyl)phthalate, naphthalene) have been detected in the discharge of Spring 4, near the mouth of Pajarito 

Canyon. Explosives (e.g., 2,4-dinitrotoluene, RDX) have been detected in springs discharging near the mouth of 

Ancho Canyon (Ancho Spring, Spring 6, and Spring 9). (CCNS, 2004; LANL, 2006” (see attached report: Historic and 

Current Discharges from Los Alamos National Laboratory Analysis and Recommendations, Prepared by Amigos 

Bravos and Concerned Citizens for Nuclear Safety, Sept., 2006, Final Report) These are excerpts from one report. 

There are innumerable reports on the contamination that has occurred throughout the operation of the Los Alamos 

Labs from its beginning in 1943 when toxic materials were just dumped in the canyons. Such contamination is 

vulnerable to public exposure in the events of floods, earthquakes and fires. 

The location of LANL within the same Jemez Mountain system and so close to where DEIS maps show that fracking 

and its rearrangement of underground rocks could take place, is given virtually no attention in the DEIS. Any EIS 

must cover the dangers to Los Alamos and surrounding populations in the event of severe earthquake caused by 

fracking. “Los Alamos National Laboratory could expose its workers and neighbors to a massive and potentially 

deadly radiation leak in a major earthquake. . . The risk at the lab’s three-decade old Technical Area 55 Plutonium 

Complex is that an earthquake could shake loose plutonium handling equipment in a way that starts a fire. With 

systems designed to filter air also crippled by the quake, plutonium could leak from the building at levels at least 100 

times greater than considered safe.” (“LANL Quake Could Be Deadly” by John Fleck, Albuquerque Journal, Oct. 28, 

2016) 

It is absolutely essential that the DEIS contain a complete assessment of danger to LANL and to

surrounding population centers, such as Santa Fe, Abiquiu, Jemez Springs, Espanola and beyond to the ecology of 

the Jemez Mountains brought about by fracking-induced earthquake.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-43

Table B-13. Health and Safety

“Los Alamos National Laboratory could expose its workers and neighbors to a massive and potentially deadly 

radiation leak in a major earthquake... The risk at the labs three decade old Technical Area 55 Plutonium Complex is 

that an earthquake could shake loose plutonium handling equipment in a way that starts a fire. With systems 

designed to filter air also crippled by the quake, plutonium could leak from the building at levels at least 100 times 

greater than considered safe.” (“LANL Quake Could Be Deadly” by John Fleck, Albuquerque Journal, Oct. 28, 2009) 

“A May Government Accountability Office (GAO) report stated that ‘fire prevention features at the PF-4 plutonium 

facility could fail in the event of an earthquake.” (“LANL Nuclear Bomb Trigger Production Questioned”, SF New 

Mexican by Rebecca Moss, Aug. 9, 2016) “The Defense Nuclear Facilities Safety Board remains deeply concerned 

with the seismic safety posture of the Plutonium Facility (PF-4) at Los Alamos National Laboratory. A recent analysis 

demonstrates that PF-4 is vulnerable to structural collapse. The large plutonium inventory of PF-4 [4 metric tons], 

coupled with the facility’s proximity to the public, creates the potential for very high offsite dose consequences if the 

building were to collapse. Structural upgrades necessary to fix the PF-4 vulnerabilities are currently projected to take 

several years to complete. In the interim, the potential for very high dose consequences remains.” “A worse-case 

scenario in the event of a quake and resulting fire at PF-4 could result in a 900 rem dose to exposed population. 900 

rems is double the lethal dose expected to cause death to 50% of an exposed population within 30 days.” (Defense 

Nuclear Facilities Safety Board, 2007 & Jan. 3, 2013)

I live on Thompson Ridge and was here during that time, with huge trucks travelling up and down the very steep first 

mile of the 4 mile road into our development. Huge! means HUGE! Dangerous driving for them and anyone else who 

wants to or has to use the road. Please give this suggestion a trace of a thought before barging ahead and doing 

what has already been done

Also, the potential of offensive odors and environmental, health and safety problems caused by poisonous, corrosive, 

flammable and explosive hydrogen sulphide (causing the “rotten egg smell”) in the released vapors needs to be 

addressed. 

I oppose drilling in close proximity to LANL. How will drilling impact the safety of nuclear materials at the lab?

Water treatment facilities are not able to remove 329-Plutonium to my knowledge. Furthermore, I don’t see any due 

diligence warning any/ALL potentially at risk parties down stream or in the vicinity of the areas in question.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-44

Table B-14. Noise

As sound carries in these mountains, the noise of those drilling pads and power plants, as well as a dramatic 

increase in large truck traffic, is likely to have an adverse impact on natural quiet in VALL and BAND, which is 

becoming an extremely scarce resource. 

Night skies and noise: One of the natural splendors of the Jemez Mountains is its night skies and solitude. When 

visitors, as well as those of us who live here, come to the mountains they are amazed at the beautiful night skies and 

the astonishing ability to gaze at unobstructed views of the stars. At night, you hear nothing but the chirping of frogs, 

the howl of owls and the Rio Cebolla meandering through the canyon. This geothermal project has the potential of 

destroying our night skies and add a constant “hum” to our environment. This report may state that the noise is within 

established “decibel” limits, however, those who live or visit any mountain area know that sounds carry differently 

than they would in a populated area. Those who live or visit any mountain area know that light carries differently than 

in a populated area. The devastating impact this project would have to our beautiful forest cannot be measured in 

decibels and foot-candles. 

Noise from geothermal plants, road development, and greatly increased heavy truck traffic are a given if this proposal 

is approved. These will impact both the local residents’ quality of life but also those who come to the Jemez to relax 

and enjoy the quiet and solitude. Geothermal development would forever desecrate and change the wilderness 

character of the Jemez.

Page No.: 3-156

Section, Paragraph, Table or Figure No.: Section 3.20.1 Paragraph 2

Comment: A maximum permissible noise level of 65 dBA, per Geothermal Resources Operational Order No.4, is 

likely to be objectionable if experienced within the Valles Caldera or other nearby recreational lands. GRO Order No.4 

states that more restrictive criterial may be established, and the Supervisor has authority to use filed noise level 

measurements and accompanying data to make operational and noise control decisions to reduce the potential 

objectionability of the noise during exploration, development, and production operations. This is a strong argument for 

Best Management Practices (BMPs) and for a minimum 2 mile setback from NPS lands and other sensitive areas.

Page No.: 3-156

Section, Paragraph, Table or Figure No.: Section 3.20.1 Paragraph 3

Comment: The noise levels following the 30 to 32 dBA ambient sound level prediction appear intended to put a 65 

dBA level from GRO Order Paragraph 3 No.4 into perspective, but due to the wide range of noise types, levels, and 

measurement distances, they may not achieve this purpose. For example, the noise levels at the El Cajete Pumice 

Mine range very widely and do not make clear the source of the sound, e.g. natural sound, bird vocalizations, leaf 

rustling, mine noise, other background noise, or perhaps even wind-induced microphone turbulence noise that should 

be discarded. In addition, short term noise levels of 50 to 60 dBA from infrequent vehicle pass-bys at approximately 

200 feet would not compare to a longterm noise level of 65 dBA at a much larger 0.8 km (0.5 mile or 2640 feet). 

Similarly, the impact area from a gas-fueled pump-jack producing 55 to 60 dBA at 20 feet is far smaller than a 

geothermal power plant producing 65 dBA at a 0.8 km (0.5 mile or 2640 feet). The noise sources and their areas of 

long-term impact are not comparable. Since this section is about the affected environment, it may be advisable to add

a sentence acknowledging that the impact areas of infrequent vehicles and gas-fueled pump-jacks are likely 

significantly smaller than a geothermal power plant, and a relatively high 65 dBA level at a large distance could result 

in significant impacts across large areas.

Page No.: 3-158

Section, Paragraph, Table or Figure No.: Section 3.20.2.3 Table 3-33

Comment: Based on a predicted noise level of 54 dBA at 1,320 feet, we reiterate our recommendation of a No 

Surface Occupancy (NSO) Lease Stipulation that would not allow for drilling geothermal wells and constructing and 

operating generating facilities and associated long-term surface developments within two miles (10,560 feet) of any 

NPS park unit boundary. For those wells outside of the two mile protective buffer, a Controlled Surface Use (CSU) 

Lease Stipulation should include a requirement that the average noise level in any direction should not exceed 54 

dBA at 1,320 feet.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-45

Table B-15. Transportation and Access

Forest and wildlife habitat will necessarily be disturbed by construction of the 5 large binary cycle power plants: a 

constant flow of large, loud trucks bring materials via highway and forest service roads. This increase of heavy traffic 

and machinery alone violates the USFS’s own policy of “Caring for the Land and Serving People”. The agency must 

advocate conservation and though the mission includes “multiple use”, this does not mean all uses are appropriate 

for every area when that use will not preserve and protect the public lands in their natural condition: 

I am against any development of geothermal resources within the SFNF because currently there is not anyplace 

within the SFNF that is not within two miles of a road. That means that there is no place that can be considered “wild”

or “natural” within the forest and there is no place for wild animals to find refuge from human interference. What is the 

SFNF forest for if not for preserving wild and natural places?

The development of geothermal resources within the SFNF will only make the situation worse. We don’t need more 

roads in the SFNF. The SFNF just completed a Roadless plan. This plan will certainly be violated if there is 

geothermal development

We live along and off of State Highway 4, which is the only way in and out practically from San Ysidro to Los Alamos. 

During peak weekends the road is very busy and during major events it is hardly possible to get through. In case of a 

serious accident or road construction, drivers may have to wait for a long time to get through. There were road 

closures, too, which meant either to wait for 2 - 3 hours, or to take the “detour” via Santa Fe to get home! I cannot 

even envision what consequences we would have to face in connection with increased traffic due to the project! I 

don’t think the safety of residents, visitors, tourists and people working for the Project could be ensured! Other 

aspects are the noise and air pollution through increased traffic (including equipment transport). And: To 

accommodate traffic to the geothermal sites, extensive road construction would be required, which would also result 

in more destruction of the environment! 

here will be additional infrastructure requirements such as roads, power transmission lines, and plants if geothermal 

energy generation becomes a reality

Exploratory drilling and potentially subsequent large scale industrial developments within the National Forest will 

require extensive road construction to accommodate traffic and equipment transport to the geothermal sites. 

Will all motor vehicles used in the Geothermal Energy Development Project be subject to the same SFNF road 

closures and restrictions as the general public? If not, why not? The general public has been severely restricted in the 

use of motor vehicles in the SFNF due to the road closure policies it has issued. I suspect the same reasons relied 

upon to limit public use would likewise apply to all motor vehicles to be used in the development project. In fact, I am 

certain that the vehicles used in the development project will create a larger environmental impact than an individual 

using an ATV to get to a camping, hunting or fishing spot. How do you propose to reconcile allowing the use of motor 

vehicles in the development project, vehicles that will be larger and more destructive, and likely not even use 

established roads and trails, with still restricting the public from the use of such roads and trails in the SFNF? Such 

action will not only be discriminatory but it will make a mockery of, and illegitimate, the purported reasons relied upon 

by the SFNF to support its road closures

Lack of adequate infrastructure—Transportation upon adequate roads is lacking. Highway 4 is a two-lane highway 

that is already congested from traffic off of Highway 550. With the advent of opening the Valles Caldera reserve, 

more traffic has already been noticeable to residents. Further, this highway cannot be reengineered to a four-lane 

highway without significant changes affecting all residents in the Jemez Valley (including the Jemez Pueblo 

residents). It is noteworthy that, in one instance, there was a police pursuit of assailants which required the road to be 

closed. Residents had to turn around and go through Santa Fe/Los Alamos to return home—which may not sound 

like a big deal, but it resulted in an almost 5- hour time period to just get home for us.

State Highway 4 from Jemez Springs winds through various turns and obstacles, is also a 2-lane highway, and 

eventually traverses into Los Alamos County. Numerous vehicular accidents occur in these hairpin turns. Just ask the 

Los Alamos County Fire Department! Additionally, the national labs present other unique challenges to vehicular 

traffic due to national safety protocols.

Highway 126 reconstruction has not been completed to date; even with the improvements to the road, it will remain a 

two-lane road, accessible only via Cuba or the Fenton Lake public area. Highway 126 is not designed for big rigs and 

transportation of materials and other equipment, and the majority is a dirt road.

Jemez Mountain Trail National Scenic Byway is the only road accessing our community. Jemez Mountain Trail 

National Scenic Byway will be impacted by “... increase in congestion and traffic.” (EIS) of an industrial nature.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-46

Table B-16. Climate Change

Microclimatic Effects - Discharge of warm water vapor may affect the climate and vegetation near the power plant;

increased fog, clouds, or rainfall. Mitigation may include designating the power station to minimize discharges and 

active monitoring and control of discharges when the plant it in operation; or use of air-cooled binary plants that do not 

release any water vapor.

Greenhouse Gas Emissions and Climate Change - Geothermal exploration and development, and connected 

development (roads and utilities) could increase greenhouse gas emissions.

If a steam plant is to be built, how will that affect our weather?
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-47

Table B-17. Fire

The proposed 14 miles of electrical transmission lines will increase the risk of accidental fire ignition, which has 

already had a devastating effect on both VALL and BAND—the 2011 Las Conchas fire and the 2013 Thompson 

Ridge fire, which collectively burned nearly two-thirds of the land in both park areas, were caused by downed power 

lines. 24

24 Id.

Geothermal development could be an increased fire risk.

The DEIS indicates there would be increased fire potential if geothermal development occurred.

We have also seen what devastation can happen to the forest when a tree falls on power lines: the 2011 Los 

Conchas fire as an example. We have at least 5 endangered species in the Jemez proposed project area

Second, the DEIS indicates that the risk of fire would increase if geothermal production occurred. Given the 

catastrophic fires of recent years in the Jemez, this seems like an unreasonable risk at this time.

There have already been catastrophic fires in that region and the efforts outlined in the geothermal energy draft leads 

me to believe more fires could occur due to the geothermal fracking systems potentially used in that area.

And certainly, we all in New Mexico do not want to encourage catastrophic fires as geothermal leasing can bring on 

by lowering water tables anymore than 14 years of drought conditions are already doing. 

The DEIS admits that increased fires are a probable hazard but dismisses that fact with a statement that the trees 

and brush will be cut and maintained beneath power lines. Global warming realities are also treated dismissively in 

the document. Fires in our area have immense consequences and have increased exponentially in intensity, size and 

frequency in recent years. Any fire taking place near LANL increases the potential for catastrophic damage to lives, 

property and wildlife. Increased fire danger is not an acceptable option in New Mexico 

Three massive forest fires in the last 21 years have assaulted the Jemez Mountains. Downed power lines started two 

of those terrifying fires whose smoke reached easily as far north as Taos, where I live. The DEIS lacks any thorough 

assessment of the dangers of a proliferation of power lines to wildlife and to an increased likelihood of forest fires. 

The huge proliferation of power lines from five geothermal power plants in the Jemez could multiply the chance that 

downed power lines would start more such fires. Those three recent Jemez fires all licked at the boundaries of Los 

Alamos National Laboratory. There four metric tons of plutonium reside in PF-4, a building vulnerable to earthquake, 

perched on fault-riddled terrain. Pyrophoric plutonium can catch fire on mere contact with air, and its fires are 

treacherous to douse, since water reflects neutrons and can make the plutonium “go critical.” Any future EIS version 

must assess all possible effects of nuclear accident stemming from earthquake caused by fracking.

2. Fire danger is grossly understated in the DEIS. The Jemez Mountains have been exposed to at least four major 

fires (Sierra Grande, Lakes, Los Conchas, and Thompson Ridge) in the last fifteen years as well as many more 

lesser fires. Two of these were caused by trees falling over electrical lines. While the DEIS claims that a 200 foot 

clear zone around any power lines would prevent these fires, it ignores the danger of lightning or wind damage to 

power lines igniting underlying grass or shrubs. Moreover, the danger of fire during exploration and construction is 

very considerable as demonstrated by the recent “Mission” fire in Jemez Springs. If that had happened in a remote 

area, the damage could easily have been extreme

Do you remember the fire that threatened Los Alamos Labs waste deposits in the Jemez? This plan for fracking in the 

Jemez sounds a lot more dangerous, than even the fire was. The DEIS admits to an increased fire potential. Seismic 

events related to geothermal injection could spark off earthquakes and release both the waste deposits an/or the tons 

of highly flammable plutonium that is stored at the LANL

Within 13 years, three major wildfires almost destroyed the Jemez Mountains:

Cerro Grande, July 2000. cause: prescribed burn, burnt: 192,8 qkm (square kilometers), destroyed: 280 homes and 

70 other structures, threatened: the town of Los Alamos and the Labs, damages: around 1 billion $, the most 

destructive wildfire in NM history 

Las Conchas, July 2011, cause: downed power line, burnt: 633,7 qkm (square kilometers), destroyed: 63 homes and 

49 other structures, second largest wildfire in NM history 

Thompson Ridge, July 2013, cause: downed power line, 97 qkm (square kilometers) Building power transmission 

lines for the project will require clear-cutting of many acres of forest in order to minimize the risk of wildfires caused 

by trees falling into the power lines. After so many acres of forest already destroyed during the wildfires of 2000, 2011 

and 2013, destroying even more by clear-cutting huge areas for power lines seems sacrilegious! Instead of protecting 

what is left, man plans to destroy even more? The existing power lines pose a big enough risk for future wildfires, why 

increase the danger? Whoever has experienced and lived through the big fires we had already knows what a 

nightmare this is and will do anything to prevent another fire! 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-48

Table B-17. Fire

The risk posed by even more transmission lines through these mountains is unacceptable, given the Las Conchas 

fire aftermath. Even with diligent checking of tree health, the massive tree death in the area would make another treefall induced fire likely. In addition, the welding, moving of vehicles through the area, and construction will carry the risk

of errant sparks that could cause fire

In addition, the DEIS admits to an increased fire potential in the Mountains. We do NOT need an additional risk to life 

and property in an area that is prone to forest fires. 

Improve the analysis for fire as it relates to the potential for each of the alternatives to contribute to fire risk and 

overall potential of wildland fire

Page No.: 1-20

Section, Paragraph, Table or Figure No.: Section 1.12.18

Comment: Section 1.12.18, Fire, identifies only on aspect of the relevant issues associated with fire (measures to 

reduce risk), as stated here and in later sections. The NPS requests additional analysis of how the proposed 

alternatives would affect the fire risk and the overall potential of wildland fire. The issues statement is not written as 

an analysis question regarding potential direct and indirect effects. Instead, it is phrased in terms of the identification 

of stipulations and mitigations. We suggest the issue statement be expanded to include how would geothermal 

leasing affect fire risk and the overall potential for wildland fire. 

The effects of fire risk to other resources/values (e.g. vegetation pp3-75, 76) is considered but with no discussion of 

how the alternatives would affect that risk. In the case of vegetation (e.g., pp3-75,76) there is no discussion or 

analysis except to indicate that best management practices (BMPs) would be followed and that operators would 

develop a fire management strategy

The DEIS even admits to increased fire potential stemming from geothermal development. Three massive forest fires 

in the Jemez Mountains in the last 21 years have seriously threatened Los Alamos National Laboratory, where an 

uncontrolled plutonium fire could threaten the livability of northern New Mexico. With all of that and because of this 

next statement I demand The Alternative Three.

Forest fires in that region have been devastating. I am concerned that the outline in the geothermal energy draft that 

has been proposed for this project can cause fires if lightening were to strike. This would occur due to the geothermal 

fracking systems potentially used in that area. 

On the other hand, not clear-cutting the forest along these lines will pose an added risk of wildfires caused by trees 

falling into the power lines. Hopefully, the SFNF is not considering adding that risk to the already high wildfire risk in 

the drought-stricken forests of the Southwest. 

Finally, the DEIS indicates that development would increase fire potential. With drought and global warming the last 

thing we need is anything that increases fire potential.

The DEIS indicates there would be increased fire potential if geothermal development occurred. Given the current 

existing potential for forest fires, it is not reasonable or logical to pursue anything that could increase that risk. 

Limited fire suppression/EMS and other emergency personnel--We have very limited fire suppression/EMS and police 

forces in the entire Jemez region: most positions are volunteer only. In a catastrophic event (which could easily 

happen with hydraulic fracturing), it would take at least 45 minutes to one hour (at a minimum) to get necessary 

emergency personnel on site.

Due to an increase in power lines from the generators this adds an increase of risk of fire in our already drought 

stricken state.

4. The DEIS indicates there would be increased fire potential if geothermal development occurred.

Geothermal development occurred in this area 30 years ago and its negative impact can still be seen today

on the Valles Caldera preserve. The Draft EIS indicates that the risk of fire would increase if geothermal

production occurred, and also that the temperature of our beloved hot springs might decrease.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

B-49

Table B-18. Recreation

Recreational uses - Much of the area covered under the Draft EIS receives heavy recreational use from nearby 

population centers of Albuquerque and Rio Rancho. Current estimates indicate that about 500,000 people visit the 

Jemez recreational sites, including the monument and surrounding areas, each year. These uses go beyond those 

areas removed from geothermal development under the NSOs, TLs and CSU stipulations. Camping, hiking, fishing 

and hunting occur throughout much of the area. It is not clear whether geothermal development will necessitate road 

closures and exclusion zones that may impact public access to popular locations. Such exclusion will further 

concentrate and thereby amplify impacts of recreational uses.

As we noted during scoping, public use in the Jemez is extremely high for hiking, backpacking, equestrian trail riding, 

hunting, and fishing. The DEIS notes on page 3-8 that the Jemez Ranger District had between 591,000 and 676,000 

visitors in 2012, mostly from the Albuquerque area. People care deeply and passionately about this area. SFNF 

admitted during public meetings about the DEIS that it received 900 comments from the public and that 100% of 

those comments were opposed to this proposal. Whether or not that is unprecedented, it is remarkable and 

noteworthy. For a public agency which is supposed to represent the public’s interest, it is almost shocking that we 

have even reached this point. If every single public comment received is in opposition to geothermal leasing in the 

Jemez, why is the proposed alternative a leasing alternative? It is extremely difficult to believe a proposed action 

which includes leasing against the wishes of the entire public and even possibly the nominating company itself would 

pass the “arbitrary and capricious” test. 

This area already appears to be under stress from increased recreational activity, including spring bathing, fishing 

and primitive camping. 

First, this area is heavily used for recreation, particularly for its hot springs The DEIS indicates that geothermal 

development could lower the temperature of existing hot springs, because cooler water could mix underground with 

the hotter water. This has the potential to seriously impair the recreation value of these forests. 

The Jemez Mountains are within an hour’s drive of over a million people, countless numbers of whom rely on this 

area each and every weekend for their recreation. This is a value that far exceeds any limited value deriving from 

possible energy development.

The Jemez Mountains are heavily used by recreationists and loved by many. I lived in Lake County, California for 

several years. Lake County has significant geothermal development, and I have firsthand knowledge of the terrible 

impacts of geothermal development on the BLM lands there. First of all, much of the BLM land in Lake County was 

off-limits and the public was gated out, with guard shacks “protecting” the geothermally developed areas. The 

geothermal plants were extremely noisy – making it impossible to sleep at times when the winds blew the noise 

towards my house. The traffic was heavy, with heavy trucks, many with Halliburton logos, traveling the rural roads. 

There were roads and drilling platforms crisscrossing formerly pristine BLM lands, creating an eye sore visible from 

miles away. And – many land owners complained of foundation issues with their homes, and were attempting to get 

compensation for the damage to their homes. This is not what we want in one of the most beautiful and heavily 

recreated areas in the State of New Mexico.

Recreational uses - Much of the area covered under the Draft EIS receives heavy recreational use from nearby 

population centers of Albuquerque and Rio Rancho. These uses go beyond those areas removed from geothermal 

development under the NSOs, TLs and CSU stipulations. Camping, hiking, fishing and hunting occur throughout 

much of the area. It is not clear whether geothermal development will necessitate road closures and exclusion zones 

that may impact public access to popular locations. Such exclusion will further concentrate and thereby amplify 

impacts of recreational uses on the national

forest.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-19. Climate Change

The U.S. Government (Forest Service, BLM nor God forbid, the EPA) cannot argue that fracking for geothermal 

energy here will have one iota of effect on global warming. Five 25 megawatt generators? Get real!

Local weather changes caused by emission of steam affecting clouds. (Kristmannsdottir,2003). Hydrogen Sulfide 

(H2S) is also emitted, causing a bad smell and forming the acid rain causing compound SO2 in the atmosphere. 

Emitted Carbon dioxide (CO2) and H2S are heavy gases and can linger in valleys causing increased pollution for 

local populations. (Kristmannsdottir,2003)

Climate Change Adaptation

The DEIS does not include consideration of future climate scenarios, and how they may impact the proposal and its 

impacts. Consistent with the CEQ guidance,4 we recommend that the FEIS describe potential changes to the affected 

environment that may result from climate change. Including future climate scenarios, such as those provided by the 

USGCRP’s National Climate Assessment,5 provides information valuable to determining whether the proposal 

includes appropriate resilience and preparedness measures for the impacts of climate change.

The EPA recommends that the proposal’s design incorporate measures to improve resiliency to climate change, 

where appropriate. These changes could be informed by the future climate scenarios addressed in the “Affected 

Environment” section. The FEIS’s alternatives analysis should, as appropriate, consider practicable changes to the 

proposal to make it more resilient to anticipated climate change. Changing climate conditions can affect a proposed 

project, as well as the project’s ability to meet the purpose and need presented in the EIS. One such example would 

be infrastructure located in coastal regions that may be affected by sea level rise.

4 CEQ Guidance, p. 20 5 http://nca2014.globalchange.gov

The DEIS does not contain estimates of the GHG emissions that would be caused by the alternatives considered. 

Consistent with CEQ’s Final Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas 

Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews (CEQ Guidance), the 

EPA recommends that the FEIS estimate the direct and indirect GHG emissions that would be caused by the 

proposal and its alternatives.1 Examples of tools for estimating and quantifying GHG emissions can be found on 

CEQ’s website.2 Estimated GHG emissions levels can serve as a basis of comparison for climate change impacts 

among alternatives and appropriate mitigation measures. The EPA recommends that the FEIS identify and consider 

measures to avoid or reduce GHG emissions associated with the project, including reasonable alternatives and 

practicable mitigation opportunities, and disclose the estimated GHG reductions.3

1 White House Council on Environmental Quality, Final Guidance for Federal Departments and Agencies on 

Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act 

Reviews, p.ll, p. 16.

2 https://ceq.doe.gov/current_developments/GHG-accounting-tools.html 3 CEQ Guidance, p. 18.

Effects of Climate Change on Project Impacts

We recommend USFS determine whether the environmental impacts of the alternatives would be exacerbated by 

climate change. This determination should be informed by the future climate scenarios outlined in the affected 

environment section. If impacts may be exacerbated, additional mitigation measures may be warranted.

The Jemez is ground zero for climate change. The drying of the area has been extreme, and painfully noted by those 

of us who are natives.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-20. Soil Resources

From the DEIS: “Throughout all of the sixth-level watersheds, the categories that are consistently of concern are 

riparian and wetland vegetation, roads and trails, soil condition, and fire impacts. None of the watersheds scored 

“good” in these categories. For both roads and trails and soil condition, only two watersheds scored “fair”: Cañones 

Creek-Abiquiu Reservoir for soil condition and Outlet Rio Puerco for road and trails. All the other watersheds were 

classified as “poor” for these categories.”

Admittedly, erosion and sedimentation are already a serious problem in the targeted area. Watersheds are already in 

poor condition. Additional roads and power lines, heavy truck traffic and construction will make matters worse. The 

Forest Service’s first responsibility is to protect the natural landscapes that it oversees and preserves for the public. 

Do not abdicate your primary responsibility to the public by permitting for-profit ventures to destroy what is left. The 

maps shown in the DEIS reveal that a good amount of the land area being considered for development is composed 

of steep slopes. This makes the probabilities for erosion considerable. How can the Forest Service justify 

development on steep slopes when the FS mission is: “to sustain the health, diversity, and productivity of the nation’s 

forests and grasslands to meet the needs of present and future generations”. Expected erosion will have a 

devastating impact on watershed attributes and wildlife. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-21. Comments Related to the Timing and/or Scope of the Proposal/Process

2. The Santa Fe National Forest has not completed its Forest Revision Plan which should inform the decision 

regarding geothermal energy development (along with a myriad of other actions.) It would also require an inventory 

for wilderness designation and certain parts of the proposed development area appear to qualify for that designation.

I am extremely concerned about this proposal for several reasons. First, why is the Forest Service considering a 

Forest Plan amendment now, when it is in the process of revising the Forest Plan as a whole? Wouldn’t it be better to 

streamline resources and roll this proposal into the revision? 

Second, the scoping document states that there has only been an Expression of Interest on a fraction of the acreage 

being considered in the proposal. If the Forest Service is not obligated to facilitate this project, why is it voluntarily 

increasing the amount of acreage it will consider as available for leasing? 

The current forest plan for SFNF was finalized in 1987. SFNF initiated the Assessment process for its multi-year 

forest plan revision process in March 2014, which will utilize the new Forest Planning Rule. We still do not understand 

why analyzing availability for geothermal leasing was not simply incorporated into the forest plan revision, and no 

explanation for this was given in the DEIS, despite our raising it during scoping. We believe this is one of the most 

serious problems with the DEIS. 

A forest plan normally plans for foreseeable use and development of resources, and simply looking at where leasing 

may or may not occur is exactly the sort of topic that should be in a forest plan revision. BLM similarly analyzes which 

lands are open and closed to mineral leasing in their Resource Management Plans. Were SFNF not currently revising 

its entire plan, an amendment like this in response to an EOI would have made more sense.

Ormat Technologies, Inc. expressed interest in approximately 46,000 acres for possible development, which is not 

permitted under the current forest management plan and would require an amendment. SFNF expanded the analysis 

area more than four times to 194,000 acres, which it based on USGS’s map of highest potential for geothermal in the 

area. Despite saying at all of the public meetings that it was required to consider the proposal, land uses are 

discretionary decisions by the management agency, especially when a particular use is not even permitted in an 

existing land use plan, and SFNF could have rejected the proposal outright3 . It was certainly not obligated to expand 

the analysis area. 

3 See Wyoming ex rel. Sullivan v. Lujan 969 F.2d 877 (10th Cir.1992) (“The federal courts do not have the power to 

order competitive leasing. By law, that discretion is vested absolutely in the federal government’s executive branch 

and not in its judiciary.”)

When asked at the scoping public meetings why this project was being evaluated separately, SFNF answered that it 

wished to be efficient and expedient. But if efficiency was the goal, surely creating one EIS would have been more 

efficient (and less expensive) than creating two, and if geothermal leasing was considered as a layer in the forest 

plan revision process, SFNF could evaluate which areas were appropriate for geothermal leasing in the whole forest, 

rather than in one portion, certainly increasing efficiency by evaluating all potential future interest in the forest at once

We appreciate that when the DEIS came out SFNF held several public meetings, including one in Albuquerque, and 

ended up extending the comment period for several months. Even with the short notice of the scoping period last 

year, SFNF still received over 900 scoping comments, showing how important this area is to the public

NEPA requires agencies to actually respond to comments made by the public, either by changing the proposal, or by 

explaining why a change was not warranted8 . While this is not a requirement for scoping comments, so many were 

made that SFNF should have at least outlined or identified some responses to the public in the DEIS. 

8 See NEPA’s Forty Most Asked Questions, question 29 (Responses to Comments), available at 

https://ceq.doe.gov/nepa/regs/40/40p3.htm (“[n]ormally the responses should result in changes in the text of the EIS, 

not simply a separate answer at the back of the document. But, in addition, the agency must state what its response 

was, and if the agency decides that no substantive response to a comment is necessary, it must explain briefly why.”)

During the public meetings for the DEIS, we asked SFNF about seeing their responses to public comments, and were 

repeatedly told that responses to comments were in the scoping report published on the project website. However, 

the scoping report is merely a printed list of the public’s comments, and contains no official response by the agency. 

Additionally, the scoping report is organized by type of comment, with no indication of who made each comment, 

making it impossible to determine which comments were submitted by Valles Caldera, for example

Further, in every section of the DEIS, SFNF lists the questions the public asked about that issue during scoping, but 

does not state any response to those questions in the section itself. SFNF has not adequately responded to the 

public’s concerns in this document, and we will be attentive to comment responses that are published in the Final 

EIS. 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-21. Comments Related to the Timing and/or Scope of the Proposal/Process

First, we are very disturbed at how public notice was issued for the meeting. From the outside looking in, it appears 

(whether this was SFNF’s intention or not) that SFNF was attempting to advertise a public meeting in the way which 

garnered the least amount of public participation possible. Many things bring us to this observation, including the 

following: • The email announcing the meeting on was sent on Friday afternoon (the 1st) before the holiday weekend 

when the government would be closed on Monday. It is likely that most people who received this email notice at all 

would have received it on Tuesday July 5th; two days before the meeting. • No notice of the meeting was posted on 

the geothermal project page. Notice was placed on the “news and events” page for the SFNF, but someone looking 

at the geothermal documents could not have known there was an upcoming meeting. • The postmark for the snailmail notice NMWA received about the meeting was July 6th: one day before the meeting took place. • The public 

meeting took place before the federal register publication. As of the date of this letter, the DEIS has still not been 

published in the register. We note this will mean the comment period should be extended to 45 days after the actual 

notice is published. The Bureau of Land Management’s policy is to allow at least fifteen days between notice of a 

meeting, and the meeting itself. This seems like the minimum amount of time people would need to adequately 

review a large document and provide substantive feedback, and SFNF should adopt a similar practice. Moreover, 

NMWA complained about the public meeting notice and schedule to SFNF during scoping for this project a year ago, 

and SFNF repeated many of the things we asked it very seriously to avoid. As we noted in our scoping comments, 

“Forest Service Manual 1909.15.10 § 11.52 (4) states that USFS shall, “[e]ensure that the level of effort to inform and 

to involve the public is consistent with the scale and importance of the proposed action and the degree of public 

interest.” The Jemez Ranger District is certainly one of the most visited USFS ranger districts in New Mexico, used 

extensively by hikers, backpackers, hunters, and anglers.” This issue is incredibly important to the thousands of New 

Mexicans and other Americans who visit the Jemez for recreation, hunting, and fishing. Many people would attend 

meetings about this project if they had more than one day’s notice. Once we realized the meeting was happening, we 

sent out an alert to our members to try to get people to attend, and our office got several phone calls from people 

upset that they couldn’t go because they did not have enough notice. SFNF is acting in a way which tells us to have 

no faith that it is actively reaching out to interested parties, or that it is seriously interested in hearing from the affected 

community. We are perplexed as to why, if SFNF is genuinely interested in public input, it would issue notice for a 

meeting one day before it took place, before the federal register notice was published, and after receiving specific 

requests for more public notice during scoping. The fact that only five people turned out for the meeting does not 

mean people don’t care; it means people didn’t know.

Secondly, the public meeting itself was flawed. There was no introduction of who was present, both from the Forest 

Service and other agencies. Sheila Mallory with BLM was there and was answering questions from meeting 

attendees and no one ever said who she was. We believe there was someone else there from BLM, and perhaps 

also from Valles Caldera, There were at least two problems with the maps at the meeting. One was that there was no 

map of alternative 3, the No Leasing alternative. We understand that the map would just be “red”, but it does not give 

the impression that SFNF is presenting balanced, unbiased information when the agency only has maps of the 

development alternatives. 

Additionally, SFNF should create a map of the areas in the proposed alternative which contain a No Surface 

Occupancy without exceptions, modifications, or waivers stipulation, on the same map that shows the general NSO 

stipulations. SFNF was presenting the NSO map of the proposed alternative as if there was only 2% surface 

disturbance possible, and stating that 98% of the project area would be NSO. But this is misleading information 

because in most of the project area, a waiver or exception to the NSO stipulation is still possible. The general public 

will not understand this distinction, and it is disingenuous for SFNF to allay people’s concerns about the proposed 

alternative by telling them 98% of the project area is NSO when surface disturbance in most of the area is still 

possible. 

SFNF needs to understand that New Mexicans love the Jemez ranger district deeply. Were there adequate notice of 

public meetings and adequate time for people to review a 400 page document (preferably not in 3 days over a holiday 

weekend), people would attend and submit intelligent feedback. If SFNF really wants what it claims to want, it will 

hold more public meetings on the DEIS (including meetings in local communities and also in Albuquerque where 

there is significant interest), it will have a complete set of maps indicating exactly what all the proposals and 

alternatives are, and it will actively reach out to communities, groups, and individuals who may have an interest in the 

issue but not know the proposal is being considered.

I would like to say first, that yesterday, October 27, 2016 was the first that I had been made aware that the Forest 

Service is considering this type of use on our public lands. I only heard of it from a notice posted by a private citizen 

at my local grocery store. 

Strangely, the LANL Fenton Hill HDR site is just outside (west) of the boundary of Middle Unit of the proposed 

geothermal lease map. (Why wasn’t the known HDR drill site included in the proposed lease area?)
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-21. Comments Related to the Timing and/or Scope of the Proposal/Process

The time interval between the public release of this DEIS and the first public meeting is absurdly short and subject to 

obvious legal challenge. It took you many months to prepare this 300+ page document. How can you possibly expect 

the public to even give this a quick read over a holiday weekend when many of us have previous plans which prevent 

attending? 

Additionally, I do not feel that the public has been adequately notified of this proposal and I would like to note the

SFNF website *still* states the DEIS comment period ends in August. I am curious if that is a deliberate attempt to 

confuse citizens and reduce the number of public comments regarding this threat to our regional wellbeing.

Why even have a public forum if you cannot address any of the concerns voiced? The information dissemination that 

is presented is one-sided. None of the concerns voiced last year were addressed then, or now. Is it a solution you 

seek? How about looking at all the trouble it has caused in other states and ban fracking in New Mexico? Our water, 

health and environment are much more important than corporate greed. Solar and wind farms here would make 

much more sense to replenish the grid. Remember, this is PUBLIC LAND. The forest service is caretaking, not 

brokering our national treasures. 

The Draft EIS was published July 15, the public comment period is only 45 days, which means it ends August 28, and 

the community will only be able to object thereafter to the draft decision if a substantive comment is submitted during 

this 45 day comment period. Perhaps that is the top of the news at this point in time. Scoping meetings and official 

comment periods are two different things

The Forest Service has made few and insufficient efforts to inform the public about this project. This resulted in few 

people showing up at the information meetings. Notice of the first meetings were only given in online public service 

announcements and in the Federal Register. Yet internet coverage in the local area is spotty and expensive. Rural 

people, Hispanics, poor people and older people all have fewer opportunities to go online and even when they do 

have fewer online research skills. (http://www.pewresearch.org/fact-tank/2016/09/07/someamericans- don’t-use-theinternet-who-are-they/ <http://www.pewresearch.org/facttank/ 2016/09/07/some-Americans-don’t-use-the-internetwho-are-they> , http://jbhorrigan.weebly.com/uploads/3/0/8/0/30809311/digital_readiness.horrigan.june2014.pdf) So 

it appears that there has also been discrimination against these groups of people even in notification and 

presentation of information. This is not okay.

Even now, it is difficult to find information about the project and how to comment on the Forest Service website. It is 

not user friendly at all for people with low internet skills who might want to find out more information and might want to 

comment.

And though some increases in public participation in modifying certain protections in the project have been added, 

the public still needs more control over whether certain areas will be offbounds for development. Making unilateral 

decisions to remove prohibitions on development without public involvement or with almost no public involvement, is 

also not okay. 

I am extremely concerned about this proposal for several reasons. First, why is the Forest Service considering a 

Forest Plan amendment now, when it is in the process of revising the Forest Plan as a whole? Wouldn’t it be better to 

streamline resources and roll this proposal into the revision?

Second, the scoping document states that there has only been an Expression of Interest on a fraction of the acreage 

being considered in the proposal. If the Forest Service is not obligated to facilitate this project, why is it voluntarily 

increasing the amount of acreage it will consider as available for leasing?

I am surprised and disappointed that with only three public meetings for this issue that the SFNF would schedule one 

for Abiquiu. In the past couple of months there have been two FS public meetings in Abiquiu, one for the Carson and 

one for the SFNF, and in both meetings the local community showed itself unsuitable as a host for these meetings. 

The local community refused to cooperate with the format of the meetings, was abusive to FS staff, and was hostile 

to the point of threatening to attendees from outside the immediate community. The Carson meeting was so bad that 

apparently someone felt it was appropriate to have a officer from the Rio Arriba County Sheriff’s office in attendance 

at the SFNF wilderness meeting. Given this behavior, it seems that a different community might be more appropriate. 

Given that 1/3 of the population of the state (and an even larger percentage of likely users of the SFNF) live in 

Albuquerque, a meeting there would be far more appropriate than Abiquiu
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-22. Grammar, Punctuation, Spelling, or Minor Edits to Text, Tables, or Figures

Include a definition of “geothermal feature.” We have provided the National Park Service’s definition for “thermal 

resources” and “thermal feature” in the attachment to this letter;

Page No.: 1-4

Section, Paragraph, Table or Figure No.: Figure 1-1

Comment: Near the center of this and other maps in the DEIS, there is an odd-shaped polygon inside the Valles 

Caldera NP with a township/range designation. We suggest this polygon and the associated township/range be 

deleted from all maps. 

Page No.: 1-16 and 1-17

Section, Paragraph, Table or Figure No.: Section 1-10 and 1-11

Comment: Sections 1-10 and 1-11 provide an overview of public scoping and tribal coordination. We suggest adding 

another section here that describes coordination with other federal and state agencies, and that identifies cooperating 

agencies and entities. Among other things, this brief section would be a place to clarify the role of other agencies and 

to identify the process associated with identification of National Park Service Values (listed on page 1-21 in Section 

1.12.19 and in footnote 2). 

Page No.: 1-21

Section, Paragraph, Table or Figure No.: Section 1.12.19

Comment: In Section 1.21, Issues, significant issues are described that could be directly or indirectly caused by 

implementing the proposed action. Section 1.12.19 identifies a National Park Service Value issue. This section states 

“Issues- how would geothermal leasing affect the natural, cultural, and sensory resource values of the Bandelier 

National Monument and Values Caldera National Preserve, and what stipulations and mitigation measures are 

necessary to protect these values?” We suggest rewording the issue to include the geothermal resources of Values 

Caldera National Preserve, so the issue statement reads as follows: “Issue- How would geothermal leasing affect the 

natural, cultural and sensory resource values of the Bandelier National Monument and Values Caldera National 

Preserve, including geothermal resources, and what stipulations and mitigation measures are necessary to protect 

these values?”

Page No.: 3-8

Section, Paragraph, Table or Figure No.: Section 3.4.1.2

Comment: Under the heading “SFNF Recreation Areas,” we suggest replacing the text “The SFNF previously 

administered the VCNP” with the following “The VCNP, formally the Baca Ranch, is a unit of the National Park 

System and is surrounded by, but not included in, the project area.”

Page No.: 3-16

Section, Paragraph, Table or Figure No.: Section 3.5.1.1, Paragraph 2

Comment: Welded tuff, basalt, basalt-andesite, etc. are not classified as “clastic sedimentary rocks.”

Page No.: 3-18

Section, Paragraph, Table or Figure No.: Section 3.5.1.2 Paragraph 1

Comment: Suggest changing “However, new magma has been seen...” to “However, new magma has been 

detected...”

Page No.: 3-28

Section, Paragraph, Table or Figure No.: Table 3-2

Comment: In the first row, in the column titled “Geologic Units,” change “Yesa” to “Yeso” Formation. 

Page No.: 3-36

Section, Paragraph, Table or Figure No.: Section 3.9.1.1 Paragraph 3

Comment: Are 4th and 6th - level consistent with Hydrologic Unit Code (HUC) 8 and HUC 12, respectively? Figure 3-

1 refers to watersheds at the HUC rather than “level”.

Page No.: 3-36

Section, Paragraph, Table or Figure No.: Figure 3-1

Comment: The symbology used to identify NPS lands is inconsistent across the maps in the DEIS. In Figure 3-1, the 

Valles Caldera NP is shown with a symbol that is not included in the legend, and Bandelier NM is not symbolized or 

labeled. We suggest the units of the National Park System be delineated and labeled consistently on maps 

throughout the DEIS.

Page No.: 3-49

Section, Paragraph, Table or Figure No.: Section 3.9.2.3

Comment: In the last sentence, suggest changing “could” to “should” so the sentence reads: “Monitoring plans 

“should” be implemented to track changes occurring from the pumping.”
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-22. Grammar, Punctuation, Spelling, or Minor Edits to Text, Tables, or Figures

Page No.: 3-114

Section, Paragraph, Table or Figure No.: Figure 3-2

Comment: Figure 3-2 shows polygons labeled “Geothermal decision area.” This is an extremely informative addition 

to the map and should be included on other maps. It would be very helpful to have this information highlighted on a 

map, with full explanation, early in the DEIS.

Page No.: 4-3

Section, Paragraph, Table or Figure No.: Cooperating Agency Team Members table

Comment: Please correct the education for Anastasia Steffen to show BA, MA, & PhD for Anthropology/Archaeology. 

Page No.: B-1

Section, Paragraph, Table or Figure No.: Table B-1

Comment: Please correct the stipulation for cultural resources to read: “Surface occupancy and use is prohibited at 

the following:”.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

I am against fracking for geothermal or any other purpose. 

As you note in the DEIS, geothermal development would result in negative impacts to fish, wildlife, recreation, grazing, 

and soils. Therefore, geothermal development goes directly against the USFS motto of “caring for the land and serving 

the people”. Geothermal development does not care for the land, and it only serves some of the people (namely, the 

people making money off of it). SFNF lands are far more valuable to the majority of people when left in their natural 

state. I endorse Alternative 3, which, as I understand it, would remove the threat of geothermal development from the 

entire project area. Of the four alternatives, it is the only responsible choice that SFNF could make. 

CCNS supports and thanks the USFS for adopting the public’s Alternative 3 (No Leasing), which would “amend the 

Forest Plan to implement discretionary closures to geothermal leasing on all lands in the project area not already 

closed to leaving.”

While we support alternative energy, CCNS urges the USFS to accept Alternative 3 in the Final Environmental Impact 

Statement. We are concerned that the possible impacts from LANL to the land surface, geology and vast water 

resources on the east side of the Jemez Mountains may be exacerbated by the proposed geothermal leasing. 

Impacts to water from LANL waste handling, management and disposal practices, protection of the Espanola Basin 

Sole Source Aquifer, and increased seismic risk have not been taken into account. Some of the direct and indirect 

impacts include: 

NPCA is strongly concerned that geothermal leasing and development in the landscape around Valles Caldera 

National Preserve (VALL) will harmfully impact the resources for which the park was designated. It is not NPCA’s 

position to oppose energy development on public lands, but we are concerned about the impacts nearby geothermal 

development will have on the present geothermal activity in the Preserve. VALL is currently undergoing the 

nomination process for consideration as having “significant geothermal resources” under the Geothermal Steam Act, 

and NPCA believes that the likelihood of a “significant geothermal resources” finding should require the USFS to 

consider the cumulative impacts of geothermal leasing within the SFNF at the EIS stage, not the individual lease 

stage. Further, we have identified a number of deficiencies within the DEIS that need attention before the Final EIS is 

released. 

Due to strong concerns about the lack of information on impacts to sensitive geothermal resources inside VALL, as 

well as other potential adverse impacts to the contiguous lands, ecosystem, and habitat surrounding and buffering the 

Preserve and Bandelier National Monument (BAND), we support Alternative 3, closing all Forest Service lands inside 

the project area. 

DOI is currently preparing a nomination for VALL to be added to the list of NPS sites containing significant thermal 

features. The area currently under consideration is the entire caldera landscape within the Preserve following the 

western and southern boundaries of the Preserve, and tracks the caldera rim along the eastern and northern 

boundaries.20 This includes the numerous fumaroles and hot springs and other features described above that are 

located within the Preserve boundary. Once the DOI finalizes the nomination, it will be published in the Federal 

Register and open for a 60-day public review period. After public comments are fully considered, another notice will 

be published in the Federal Register making the designation final. This process may still need several months to 

complete. 

20 See, NPS Significant Geothermal Feature Boundary Determination, Valles Caldera National Preserve, New

Mexico, map, attached.

Given the ongoing consideration of VALL’s significant thermal features, we believe that the Santa Fe National Forest 

Geothermal Leasing EIS is the appropriate place to analyze and consider potential cumulative impacts from nearby 

leasing. The DEIS is clear that it does not evaluate impacts from potential exploration and development proposals, 

which will be conducted on a case-by-case basis including NEPA analysis once such projects are proposed. 21

However, such case-by-case determinations will be focused on the much smaller areas bounded by the lease, 

limiting the potential for impacts. Consideration of impacts only at the lease area-scale improperly overlooks the 

cumulative impacts of multiple developments occurring on the Valles Caldera geothermal system. The appropriate 

place for such consideration is this Forest-level plan, as part of a reasonably foreseeable development scenario 

(RFDS). The RFDS for the Santa Fe NF geothermal leasing project cited in the DEIS does not include any specific 

mention of potential impacts of development to the significant thermal features found within VALL (though the 

description of “hydroshearing” fluid injections and potential associated microearthquakes are also of concern). 22

Because of a high risk of impacts to thermal resources in the Preserve and a lack of study and information on 

potential impacts to these resources from any project alternatives that include development, NPCA must support 

Alternative 3, which closes all leasing in the project area. 

21 Santa Fe National Forest Geothermal Leasing Draft Environmental Impact Statement, at 1-16. 22 BLM. 2015.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

Chapter 3. Affected Environment and Environmental Consequences

This chapter fails to identify the expected impact area of influence for each resource that would be significantly 

impacted. This chapter needs to present and show the expected impact area of influence for each resource. It would 

likely vary for each resource but needs to be shown so the decision-maker and public can see the area most likely 

affected by the proposed action and alternatives. As presently written, it appears that the only impacts discussed in a 

non-specific way are those on USFS lands. There does not appear to be any specific analysis of impacts direct or 

indirect that would occur on other areas such as VALL or BAND. 

In conclusion, NPCA wants to reiterate its support for Alternative 3, closing all lands within the planning area to 

geothermal leasing. The potential to impact the unique geothermal resources of the Valles Caldera geothermal 

system and the visitor experience at Valles Caldera National Preserve and Bandelier National Monument are too 

great to risk. On behalf of our members and supporters, thank you for the opportunity to comment. Please contact us 

any time if we can answer questions or be of any assistance.

Association members, mostly property owners in the area, received an overview of the EIS and proposed action on 

September 3, 2016 from a USFS representative. There were many questions regarding the impacts of a geothermal 

leasing program, especially relating to the potential for induced seismicity and the unavailability of water resources in 

the area. Responses to these questions lacked specificity and it is clear that those involved in the analysis cannot 

provide any assurance that our property and mountains will not be negatively and permanently affected. This letter is 

intended to outline our concerns and strong objection to the other Alternatives offered.

Permanence - The risks appear to be numerous, but more importantly, the risks are grave and irreversible. Should 

anyone of the concerns listed above manifest in any significant way, the region could not recover within the 

foreseeable future. The damage is also not one that could be cured by financial compensation. Environmental 

recovery, in particular, takes a significant length of time. Therefore, the potential short-term gain from a 10-year lease 

is overshadowed by the potential for decades-or even hundreds of years-of recovery from potential damage.

The Jemez region holds historical and environmental significance in New Mexico. The region is home to the Valles 

Caldera National Preserve, Bandelier National Monument, Fenton Lake State Park, hot springs, and the Jemez 

Pueblo residents. We intend to band together with representatives of any entity opposed to the proposal (it is my 

understanding that there are many) and vehemently oppose the proposed development. We, as property owners, and 

members of the association, for the reasons stated herein, oppose the leasing and proposed development.

The government has enough of NM’s lands to ruin without ruining more. This plan is sheer idiocy and one that should 

be immediately dropped. Just think of the physical intrusion in building one plant, much less 5 plants, disrupting the 

typography, disrupting the tourist use of the land, disrupting the critters, etc. etc. Once you do it, it’s gone forever. 

There’s no going back. Surely, you don’t want that as your legacy. Besides, I live downwind from the dangers of Los 

Alamos. An earthquake there would be catastrophic for those of us in Taos. I left when the fires were raging because 

I know that they dumped all kinds of bad stuff in those arroyos, dangerous chemicals borne on the wind. So, take a 

red pencil and cross out this project

I am writing to ask you to adopt Alternative 3-- no leasing of SFNF lands for geothermal development-- of the DEIS. 

Geothermal development is an inappropriate use of our precious public lands, and risks water resource depletion, 

environmental degradation, and negative impacts on wildlife, recreational activities and tourism.

1. The Santa Fe National Forest is an artificial boundary in an environmentally complicated landscape. As such, it 

does not exist in a vacuum or operate in a bubble, with its actions somehow separate from the landscape that 

surrounds it, the air above it, and the ground beneath it. The current DEIS does not address the potential for impacts 

upon surrounding landscape, the Valles Caldera National Preserve, neighbors and local communities. 

4. Attending the public meeting at the Abiquiu Rural Events Center, I did not hear anything to suggest that SFNF staff 

have the expertise to evaluate good practices in geothermal energy development. That’s not a slam, but a realistic 

statement about where staff’s excellent skills actually reside. 

I live in the area just 3 miles North of Jemez Springs Village and have since the early 1990’s. I am concerned about 

the proposed geothermal drilling proposal. A number of years ago I toured the caldera and was told by the leader of 

our group that geothermal was not a viable project as it would effect the downstream springs, water shed, 

environment and wildlife -- I believe the ecological effects would be devastating -- the solution, do not put profits 

before people. And, as a concerned citizen and owner of a home/steward of property in the Jemez (I have disturbed 

the acreage we live on minimally). I ask you to abandon this/these reckless projects immediately and listen to the 

people of the area.
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I’m writing in regards to the proposal to allow leasing on 195,000 acres of the Santa Fe National Forest. I am strongly 

opposed to geothermal production in this area, and believe the only appropriate choice for the Forest Service to make 

is to adopt Alternative 3, which would not allow geothermal leasing to take place. In addition to being one of the mostloved and heavily-visited areas of New Mexico, the project area also contains critical ecological resources like 

endangered species, sensitive riparian zones, Inventoried Roadless Areas, and lands which contain wilderness 

areas.

Your own Draft EIS indicates that the risk of fire would increase if geothermal production occurred, and also that the 

temperature of our beloved hot springs might decrease. Please do not allow the Jemez Mountains to become a 

sacrifice zone to energy development. I SUPPORT ENERGY DEVELOPMENT BUT NOT AT THE COST OF MAJOR 

DISRUPTION TO A PRISTINE AREA AND WATER SHED.

The issue of energy development that would benefit a few and not the people or animals/plants/water/ecology has 

been an ongoing issue for years, one we have to fight ever so often. The solution is to say NO to leasing of land for 

ecologically unknown or possible disturbances and/or destruction involved in the activity of generating geothermal 

energy or any other for profit endeavor on that public land.

What cost to the environment? Future of the area? Who profits from this disruption of the ecosystem and destruction 

of so many living beings.

This type of project was tried before and the devastation to the area can still be seen decades later. Is the amount of 

energy really worth the cost, does the end justify the means? How much is to be extracted, I understand very little 

energy and what is sucked out of the earth will be added to the collective grid. So the power will not stay in our 

community in any event. Pipelines require massive amounts to forest destruction to lay.

this activity is to be done on public land and has already had steps taken before the public was ever told or asked to 

comment. This is beautiful wilderness – leave it alone. One of the sentences (in the notes) say that the Santa Fe 

National Forest Service has little influence over the project once it is in final stages. This concerns me and my 

neighbors. What is the environmental impact, clean up and restoration? What is the history of restoring old mining 

operations? There are alternative energy sources that do not do so much destruction and disruption to the 

ecosystems. Many are renewable and sustainable.

All else considered and there is much to consider — as this is a messy project —forging new roads, disruption of 

land/flora/fauna for pipelines, and what will be the extraction containment practices and clean up and what will be the 

chemical spill to the area and pollution to our water. Currently we use stream water from one of the three streams 

used for water in the Jemez area.

Any energy development is sponsored by big business with the help of corrupt government. Geothermal energy 

although relatively clean and sustainable will be developed by entities that only care about profits for themselves. No 

matter how much they promise and say they will develop in good healthy ways they will eventually abuse and cause 

irreversible damage to the environment. The National forest is New Mexico’s and the Nations greatest asset which is 

already stressed and under constant attack. Therefore I am apposed to any energy development in the national forest

How many lives, now many people and many different species depend on the downhill water flow and runoff as well 

as the underground aquifers. Protect and serve, do not drill in the Jemez. Save the water - life is priceless. 

With regard to the proposed development of geothermal energy in the Jemez mountains, I would like to demand in 

the strongest possible way that you pursue Alternative #3- No Leasing for Geothermal development in the Jemez 

mountains. 

The high value recreational opportunities, the proximity to the Los Alamos Nat’l Laboratories & particularly the Area 

55 Plutonium facility, and the existence of a large dormant volcano with many existing faults, all argue forcefully 

against the development of geothermal energy in the Jemez mountains. Please register these comments in your 

considerations for any possible development. 

I live in northern NM and I am opposed to fracking in this area. It is unsafe, unproven, the chemicals used to open 

faults and extract (in this case hot water) are dangerous to the earth, to aquifers and underground rivers of water, 

springs and to all plant, animal and human life. I am opposed to fracking. It is an idea to make some company(ies) 

very rich at the expense of the environment. 

We need renewable energy that does not create havoc underground and in our wildernesses and mountains as this 

will do. NM has the good fortune to not suffer from many earthquakes. That will change if fracking goes forward. 

Is it worth it? New Mexico doesn’t need risky projects to be a leader in producing abundant clean energy. We have 

plenty of sunshine and lots of open space to develop large solar arrays. We also have good wind sites. Such projects 

could easily meets our energy needs and produce energy to export as well. Don’t frack the Jemez Mountains for 

geothermal energy. It’s way too risky, and we don’t need it.
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Table B-23. General Comments Related to this Planning/Analysis Effort

I am opposed to any geothermal production that impacts water bodies, Inventoried Roadless Areas, cultural 

resources, and important habitat for species. Please ensure none of the land in or around these areas can be 

disturbed, that a much larger buffer is placed around water bodies, and that deviation from stipulations could not 

occur at the whim of Industry and State agencies

While some of the concerns we raised during scoping were addressed in the DEIS, we still firmly believe that when all 

the maps, resources, and values are considered, this area is not appropriate for geothermal leasing, and that SFNF 

must choose Alternative 3, the No Leasing Alternative. Even if some small portions were appropriate, the impacts to 

Inventoried Roadless Areas and other areas with wilderness characteristics would be too great, the stipulations 

outlined in the proposal are not sufficient, endangered species would likely be jeopardized, and both surface and 

subsurface waters would likely be damaged by any production. Moreover, SFNF itself has noted that of the 

approximately 900 public comments it received, not a single one was in favor of leasing. The public clearly does not 

want this, and we are frankly baffled that the proposed alternative is one that allows leasing. 

Additionally, we are still interested in hearing more about potential COA’s BLM may eventually be able to place on the 

parcels, including whether COA’s are possible (and enforceable) which would actually halt production in the event 

certain conditions are met. When discussed at the scoping meetings, BLM representatives stated that this was 

possible, but later indicated that such a COA would never actually be placed on a lease because if the potential for 

disaster was so high that production might have to be halted, BLM would not lease the parcel. Contrary to this 

optimistic view of BLM leasing practices, it has not been our experience that BLM often denies lease sales even in 

the face of potentially serious environmental damage, nor is BLM’s view always in agreement with those of scientists 

or the public. Rather than being answered later at the leasing stage of development, SFNF must answer these

questions now, during the initial analysis. It would have been more helpful to have the information

available IN the DEIS, both for the public’s benefit and the agency’s. The answers are crucial in order to know how 

critical the placement of the most appropriate stipulations are at this time. If the only real moment for the right choice 

of stipulations and surface use decisions is actually during this phase, it is vital that SFNF understand this and act 

accordingly.

Similarly, if SFNF’s reason for expanding the analysis area so far beyond the company’s proposal was in anticipation 

of future interest, it would be another reason that geothermal consideration should have just been incorporated into 

the plan revision as a layer on the whole forest. During scoping we suggested that an alternative be analyzed that 

solely looks at development within the actual EOI. SFNF did not include this as an alternative in the DEIS. 

Indeed, this past summer, SFNF released its draft wilderness inventory maps as part of the revision process. Most of 

the geothermal proposal area is included in those maps as roadless areas deserving of inventory, just as we said it 

would be during scoping. There is no mention whatsoever of this in the geothermal DEIS. If these areas are found to 

have wilderness characteristics, it would be reasonable to consider closing them through the revision process to all 

future leasing. But if the geothermal DEIS is completed first and ALLOWS for leasing in those areas, the 

consideration of that alternative in the forest plan revision could be precluded. This is exactly why agencies should 

not take any action during major planning which could preclude an alternative from being chosen, and why 

geothermal leasing should not have been evaluated separately from the forest plan revision. This problem is not 

addressed or even acknowledged in the DEIS. Incredibly, Chapter 3 of the DEIS does not even have a section on 

wilderness or wilderness inventory obligations. 

Despite our serious concerns about this, which were expressed by all ten of the organizations who signed onto our 

scoping comments, the DEIS contains a paragraph on page 2-13 regarding a “Wilderness Protection Alternative”

which was eliminated from further study. That alternative would have considered exactly what we asked for, which 

was to remove IRA’s and lands with wilderness characteristics from leasing. It was eliminated because wilderness 

inventory was “outside the scope of this project”. We believe this was a serious error. Wilderness inventory should be 

undertaken during any major amendment to a Forest Plan, and this statement exacerbates our concern that SFNF 

will preclude itself from considering these areas for wilderness recommendation in the forest plan revision, if it makes 

a decision to allow them to be leased for geothermal here. 
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Table B-23. General Comments Related to this Planning/Analysis Effort

Allowing geothermal leasing in these areas also directly conflicts with many of the stated “Needs for Change” in the 

Forest Plan Revision Assessment. These include the SFNF’s stated need to “recognize the inherent value and 

preservation of Native American traditional cultural properties and sacred sites, as well as non-Native American 

traditional cultural properties”, to “support ecological conditions that contribute to the recovery and conservation of 

federally listed species (threatened and endangered)”, and to “provide for sustainable groundwater-dependent 

ecosystems (e.g., seeps and springs, fens, and wetlands) and for the long-term protection of groundwater quality and 

quantity on the Santa Fe NF”, among many others4 . By considering this geothermal proposal without the context of 

the need for an updated Forest Plan, SFNF is potentially precluding its own ability to achieve its stated plan revision 

goals. 

4 http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd508441.pdf

Throughout the DEIS, SFNF continually states that the decision to allow leasing itself has no environmental impacts 

because all the impacts would occur later9. This is a non-sequitur and is not defensible. We know it is not defensible, 

because BLM offices and National Forests regularly create EIS’s solely for the purpose of determining which areas 

within their boundaries are suitable for leasing. In so doing, they look at site-specific impacts associated with potential 

development of those parcels. It is not legitimate to defer any impacts analysis and consideration of those impacts 

because they’re not happening right at this moment. SFNF is making the decision to allow leasing of its surface for an 

activity which will absolutely have impacts if it occurs. The whole point of this exercise is to consider those potential 

impacts. Once it makes this decision, it no longer has control over how development occurs. SFNF might wish it is 

not making any actual decisions here, but the public will not be fooled. SFNF can prevent all potential impacts by 

making the correct decision, which is to not lease this area for geothermal production.

9 See DEIS page 3-172 (“Consenting to geothermal leasing and the subsequent issuing of leases would not result in 

any unavoidable adverse impacts.”). See also DEIS page 3-48 (“Leasing land does not involve ground-disturbing 

activities or any type of construction, so there would be no direct impact on water resources. Impacts would result 

from activities pursued after leasing.”).

SFNF should require every minimization of impacts possible at every phase. SFNF should specify what minimization 

would entail, should require best management practices and best available technology at all times, should require full 

restoration at the end of any leasing period and development, and should require compensatory, off-site mitigation for 

unavoidable impacts consistent with NFMA and Secretarial Order 333011 , the subsequent 2014 Energy and Climate 

Change Task Force Report12 , and BLM’s Draft Regional Mitigation Manual Section 1794 (Draft MS-1794)13. 

11 Available at: http://www.doi.gov/news/upload/secretarial-order-mitigation.pdf 12 Available at: http://www.doi.gov/news/upload/Mitigation-Report-to-the-Secretary_FINAL_04_08_14.pdf 13 Available at:

http://www.blm.gov/style/medialib/blm/wo/Information_Resources_Management/policy/im_attachments/2013.

Par.57631.File.dat/IM2013-142_att1.pdf

This proposal does not meet SFNF’s responsibilities to preserve public land for the use and enjoyment of future 

generations of Americans. We doubt geothermal production can happen in this area on a commercially viable scale, 

leading to a concern that the proposal is geared towards infrastructure development without an end goal of 

substantially benefiting the public trust. On the other hand, development in this area does come with a high likelihood 

of damage to water, endangered species, roadless areas, and the level of enjoyment of the Jemez Ranger District 

currently felt by thousands of people every year. When viewed in this light through proper NEPA analysis, we believe 

it should become clear to SFNF that this area is better left in its current state. SFNF should choose Alternative 3, the 

No Leasing Alternative, and remove this proposal from consideration. Thank you for your consideration of our 

comments, please include these comments and maps as part of the project record, let us know if you have any 

questions, and please keep us on the list of interested parties. 

People, is this the business of the Santa Fe National Forest - to put profit above safety; to put pressure from the 

oil/gas industry above community well-being; to make use of our public lands in a manner that might destroy them? 

Please listen to the many voices calling out against this geothermal development plan. Please listen to us.

We commend the SFNF for trying to analyze some level of foreseeable impacts associated with the development of 

geothermal resources which could result from a decision to provide consent to BLM for such leasing, but note that the 

timeframe for the analysis of impacts in the DEIS through use of the “Reasonably Foreseeable Development 

Scenario” (RFDS) is too short. It appears the RFDS impacts analysis was only for a period of fifteen (15) years (see 

DEIS at 3-1) , but, if the SFNF were to give consent to BLM for leasing of lands for drilling and extracting geothermal 

resources, such leases could be in effect for one hundred (100) or more years. See DEIS at 1-8 through 1-9 

(describing ten (10) year initial lease which could be extended for two five (5) year periods and then, once 

commercial production is established, may receive a production extension of up to thirty-five (35) years and a renewal 
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Table B-23. General Comments Related to this Planning/Analysis Effort

period of up to fifty-five (55) years). We note these timeframes because it appears that using the RFDS results in an 

underestimation of impacts and, of course, there are some impacts which simply are not yet known and cannot be 

predicted. See, e.g., id. at 3-22 (noting that “the risk of seismic events triggered by specific geothermal development 

activities cannot be assessed at this time”). 

No Fracking - destroys the earth

It is paramount that Alternative #3, No Leasing be the response to this proposed project. In no way should fracking, 

which increases the potential of seismic activity be used so near to Los Alamos National Laboratory.

In summary, the resources in that area are under substantial pressure already which is only mildly under control. The 

Forest is at capacity for regulating these activities as it is; adding additional activities which require regulation and 

oversight is not practical for management under existing budgets.

I disapprove of the decision to frack in the Jemez Mountains. It would not only be detrimental to the environment but 

also to the people. The animals, the ecosystem, and the Los Alamos Labs need to be taken into consideration.

The environmental impact statement spells out the very real possibility of all of these concerns. We are adamantly 

opposed to allowing this geothermal drilling, because our first choice is to continue working on the dream of what we 

are creating here, and even with assurances that we will be compensated for any foreseen or unforeseen 

consequences of this drilling, we are very aware that corporations have the funds to hire many lawyers who can 

either find loopholes or tie things up so that we would possibly never be compensated for anything. This leaves us 

with no alternatives other than to say we are absolutely NOT in favor of this kind of activity. We can’t afford for our 

investments in our business and property to be effected by these geothermal drilling projects. This is our business 

and livelihood as well as our home.

Before any recommendation of allowing any drilling, it might be a good time for the Forest Service to set up a couple 

of boards of trustees made up of 1) residents and 2) business owners in the area who can determine ahead of time 

how much financial damage could potentially be done and to whom, and then if something unforeseen happens, 

(drinking water compromised, hot water system compromised, area tourism compromised) the boards can decide if 

and when the energy corporations are liable, along with doing the job of facilitating the current and future damage pay 

outs to those effected. Still, please note that our ultimate vote for what the Forest Service does with geothermal 

drilling in the area is that we are 100% against any of it. No drilling. No exploration. No leasing land or mineral rights 

to corporations for anything underground. We have too much to lose.

How will the geothermal companies be selected and/or monitored: There are many stories and reports on the Internet 

that state the pros and cons of geothermal activity. Many of the companies listed do not have good reputations or 

track records. They have had problems during the drilling process or have left major damage when they have 

terminated their drilling projects. Should this project go through, who is going to monitor the geothermal plants and 

who is going to ensure these companies follow the agreed contracts/guidelines. In my opinion, our State would spend 

more of our monetary resources to monitor these companies than we will recoup in income 

Our Santa Fe National Forest is a legacy that will be handed down to future generations -- if we protect it. If we allow 

companies to come in for a moment in time, to destroy the environment (e.g., trees, roads, air quality, noise), deplete 

our natural resources (i.e., water sheds and wells), create the potential for horrendous situations (e.g., fires, 

earthquakes), affect the habitat of our wildlife (e.g., destroy grazing lands, contaminate or eliminate streams and 

rivers, dislocate wildlife from where they reside), and ruin areas designated for recreational use (e.g., light, noise, air 

quality). Allowing this project to go forward will desecrate our beautiful National Forest while adding little to benefit our 

State.

The CEO’s of large industries may not care about endangered species, for example, the Jemez Mountain 

salamander, NM meadow jumping mouse or the Mexican spotted owl who reside in the proposed area, but they 

certainly should care about the safety and health of the people who live within close proximity of a nuclear laboratory 

(Los Alamos National Laboratory), a known earthquake fault zone, and an area where there have been devastating 

forest fires that have threatened LANL. It goes without saying that fracking will not decrease the occurrence of natural 

events or decrease the impact of man-made disasters. My deepest hope is that you who will be deciding this issue 

will be attuned to your conscience and remember that what is beneficial to the environment is beneficial to the 

people.

Stop the fracking?

No fracking please our land is too precious. 
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Table B-23. General Comments Related to this Planning/Analysis Effort

Regarding the geothermal development in the Jemez Ranger District and areas around the Valles Caldera. I 

advocate strongly for Alternative 3: the No Leasing Alternative. With so many different environmental factors to 

consider, including impacts to water bodies and riparian areas, three listed species (Jemez Mountains salamander, 

New Mexico meadow jumping mouse, and Mexican spotted owl), potential seismic impacts, extremely high levels of 

recreational use, it is not practical or desirable to have any geothermal leasing in this area. The levels of 

management which would be required to protect each of these resources are unreasonable, and not practical even 

for the industry.

The SFNF has selected Alternative 2 as the Proposed Action. We strongly object to Alternative 2 as the choice of 

action on the proposed geothermal leasing described in the DEIS. Further, we would also object to Alternatives 1 and 

4.

We choose Alternative 3, NO LEASING, as the only course of action to be taken concerning this geothermal leasing 

proposal 

The approximate 136,650 acres of NFS lands in the project area that would be allocated as open to geothermal 

leasing under Alternative 2 is extremely sensitive in numerous ways: watersheds, aquifers and wells, fish and wildlife 

habitat, health of both endangered species and other wildlife, forest health, hazardous waste releases from elements 

already in the ground or introduced by the project, and human health. We believe all of these will be adversely 

affected in the extreme if the geothermal leasing action is approved. 

Beyond the costs to taxpayers, the real problem is that geothermal IS NOT GREEN when it comes to potential 

serious environmental damage; and that is the real issue with the Jemez Mountains lease. Some areas of the world 

have ideal conditions in which to construct and run a geothermal power plant, like in the Philippines, where 

geothermal power accounts for about 25% of their total energy. The Jemez Mountains, however, have a unique set of 

environmental, geographical, and nuclear facility situations that make it a poor, even dangerous, choice for 

geothermal development

I am not in support of fracking in the Jemez Mountain or anywhere in New Mexico or USA. Lets get our energy from 

solar and wind. No more tearing up mother earth

As a Backcountry Horseman of the Lower Rio Grande Chapter, I support only Alternative # 3 of the proposed 

Geothermal Development Project in the Santa Fe National Forest. No leasing option. In the proposed project area, 

that would include the Jemez Mountain Trail National Scenic Byway, the Jemez Historic Site National Landmark and 

the Monument Canyon Research Natural Area, as well as SFNF administrative sites in the area.

As a NM resident who greatly enjoys the state’s vast outdoor opportunities and volunteer member of NMSAR, I 

demand the US Forest Service adopt Alternative Three and oppose any geothermal development in the proposed 

area (or any area of NM for that matter!)

I urge you to adopt Alternative 3, which would not allow geothermal leasing to take place in this sensitive area. 

Alternative 3 is the only appropriate alternative for a number of reasons. 

I recently learned about a Proposal to Mine the Jemez Mountains for geothermal electric power. As a New Mexico 

resident I am requesting Alternative # 3, No leasing, and against Action Alternative #1.

The environmental effects of your proposal can have potentially catastrophic damage to our WATER, WILDLIFE, and 

LAND. This proposal sounds like a creative plan for energy, but at the sake of some very harmful damage. At Los 

Alamos National Laboratory, nuclear safety issues are sensitive to seismic events, which is possible with the 

examples of how “fracking” has proliferated earthquakes in other areas for example Oklahoma

2. What about the scientific evidence of the dangers to our precious underground water supply; the dangers to 

devastation of land, and health of people and animals? Or look at the ill-effects to the entire ecology of our 

environment!

3. After these fracking-for-gas-Corporations have ruined the environment, created serious water shortages, 

devastated our lands and forests, how can they ever PAY for such irreversible damages Have YOU, the SW SF 

Forest Service truly looked at and studied the reports of all the trouble that has been caused already in other states? 

for the sake of their profit, the “GOD-Money”

I am opposed to geothermal development in the Jemez area. Not only would this ruin the community of Jemez 

Springs, but as is well documented, the danger of earthquake is much expanded

In particular, why is more electric power “needed” the underlying notion, unfortunately seldom examined or 

questioned is that more electricity is needed for growth. Unlimited growth which alas is still the apparent goal of public 

policy is the philosophy of the cancer cell. NO!
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Table B-23. General Comments Related to this Planning/Analysis Effort

We the Sovereign Nation of Pueblo de Cochiti oppose the exploration and extraction of geothermal energy within our 

Ancestral Lands in the Jemez Mountains of New Mexico. Cochiti Pueblo interests seeks continued protection of: 

Cochiti Ancestral Domain, just as it has protected us throughout history, Water, Cochiti cultural way of life: shrines, 

ancestral homes, minerals, Tribal communities as living organisms, Traditional Cultural Property, Watersheds, 

Coherent Landscape management, Wildlife, Vegetation, Esthetics, pristine forests, protection not just for our 

community, but for all people who may be impacted. 

The area has already been adversely impacted by the Cerro Grande (2000) and Los Conchas Wildfire (2011) and is 

still in the recovery process. The effects of exploration and drilling in an already fragile wilderness area will have a 

high impact on wildlife, plant life, and diminish its scenic and touristic (economic) value including its striking landscape 

and hot springs. Disturbances include development of new roads, power lines, heavy equipment, and drilling 

equipment. Not to mention the noise levels created which often exceed 120+dB during drilling operation and 90+dB 

during (normal) plant operations.

With the World-Wide geothermal plant conversion efficiency average of approximately 12% (1%, Chena Hot Springs, 

and 20.7% Darajat) we do not view the practicality of a geothermal plant with an efficiency conversion rate that is 

approximately 200% below the conversion factors for Coal Fired, Natural Fired Gas, Oil Fired, and Nuclear Power 

Stations within our Ancestral Domain. Additionally, there are copious amounts of environmentally damaging issues 

that arise near geothermal exploration/extraction plants such as: • Disturbance to landscapes and locations 

associated with religious beliefs and cultural uses • Increased risk of seismic activity and ground subsidence • Soil 

disturbance, compaction, and erosion • Changes in groundwater flow paths, pressurization, and temperature • 

Increased sediment and turbidity in surface water • Vegetation removal • Fish and Wildlife habitat alteration and noise 

disturbance • Increased short-term fugitive dust and vehicle emissions.

Geothermal leasing as proposed in SFNF DEIS for the Jemez Ranger District and areas around Valles Caldera is 

completely undesirable. Have SFNF administrators considered the thriving populations of plants, trees, grasses, 

animals, birds, insects, et al that live there year round or who depend on these habitats for migration?

SFNF needs to quickly to thoroughly implement a wilderness designation for the irreplaceable area. It is the said goal 

of national forests to protect & defend forests against attacking interests whose primary focus is exploitation for one 

purpose-money. This would be illicit gain. Do NF administrators want to be complicit in this exploitation of lands they 

are forsworn to protect?

I advocate strongly for Alternative 3: No Leasing.

I am writing to ask that all geothermal leasing in the project area be closed.

Do you think geothermal energy development in the Jemez Ranger District and around the beautiful Valles Caldera 

National Preserve is a good idea? Neither do we! August 16 is your chance to speak out in opposition to these plans 

by attending a public meeting and supporting the “No Leasing” alternative offered in the draft Environmental Impact 

Statement prepared by the Santa Fe National Forest. Like Yellowstone, Valles Caldera is home to world-class 

geothermal resources that need our protection. No one knows what impact commercial geothermal development in 

this region could have on these resources. What we do know is that this proposed development could impact the very 

qualities that make this preserve so special - like its dark night skies, natural quiet, scenic viewsheds, endangered 

species, cultural resources and traditional uses. I support the “No Leasing” alternative to ensure this special place 

remains protected. & while much of this language is from NPCA’s statements, this is what needs to be said, and 

thank you, Iris Gersh.

Having read information from the U.S .Forest Service, groups supporting and opposing fracking in the Jemez 

Mountains, my husband and I have concluded that we can not support the DEIS to mine the Jemez for geothermal 

electric power.

We have seen the failure of fracking and its deleterious effects on people, wildlife and environments across the 

country. Please do not be the helping hand that destroys our beautiful Jemez Mountains by permitting fracking in this 

fragile environment. As a family we respect and enjoy all that our expansive state offers in regard to outdoor 

opportunities. Fracking does not fit into the equation off New Mexico True. Please do not allow it. With science 

proving the dangers of fracking, allowing such mining within 20 miles of Los Alamos National Labs is absolutely an 

irresponsible response from the U.S. Forest Service.

What are you thinking? First, this is Not a dead SUPER volcano, it is dormant. Do you know the diff.? Los Alamos 

Labs are there. Do you know what goes on there? Not to mention all the people who live here and use this land. And 

you want to do WHAT? Are you out of you freak’en minds??

I support the NO LEASING option, Alternative #3 of the DEIS.
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Table B-23. General Comments Related to this Planning/Analysis Effort

What is the seismic activity on the Pajarito Plateau, Jemez Mountains, Valles Caldera? How is the seismic activity 

measured at each location? Are there “strong” seismic monitors? Are there “weak” seismic monitors. Who operates 

the monitors? Is that data public? If not, the entire data sets must be made public before any NEPA process goes 

forward. Monitoring seismic motion, after the fact of geothermal development and after the fact of an earthquake 

cannot mitigate the consequences, especially with LANL right next door. In fact, an Aug. 9th Santa Fe New Mexican 

article by Rebecca Moss reports that a May Government Accountability Office (GAO) report stated that “fire 

prevention features at the PF-4 plutonium facility could fail in the event of an earthquake.” (“LANL Nuclear Bomb 

Trigger Production Questioned”, SF New Mexican, Aug. 9, 2016)

I am opposed to geothermal development in and around the Jemez Ranger district and urge you to adopt Alternative 

3: The No Leasing Option. Leasing threatens water and land values, such as existing geothermal springs and 

recreational use, as well as threatened or endangered species. The draft EIS is deficient in that it did not consider

wilderness protection or Native American concerns. This relatively undeveloped area is of prime importance to the 

people of New Mexico and industrial development is fundamentally inappropriate. Such development was already 

rejected by the people of New Mexico when PNM sought to build a geothermal plant in the 80’s. 

I am new to New Mexico from MO. I spend my time outside exploring this beautiful area. We can not afford to destroy 

this space for any amount of exploration.

Unconscionable - Never Fracking!

Alt # 3

I am adamantly opposed to the proposal!!! The Forest Service needs to comply with public demands to inventory the 

public lands they oversee. Protect the environment - don’t destroy it!!!

The DEIS is borderline deceptive in its euphemistic terminology for the process by which the tapping of the 

underground magma-heated hot water is brought about, namely the “Enhanced Geothermal System.” I was unable to 

find what was meant by an “enhanced geothermal system” [EGS] without a Google search, since it wasn’t clearly 

defined in the DEIS. In a separate DOE site I learned: “In an EGS, fluid is injected into the sub surface under carefully 

controlled conditions, which cause preexisting fractures to re-open, creating permeability. . . [allowing] fluid to 

circulate throughout the now-fractured rock and to transport heat to the surface where electricity can be generated.”

I absolutely oppose geothermal development in the Jemez Mountains. I abhor the effect development could have on 

wildlife habitat, the calving areas of elk, the fawning of deer, the nesting of the New Mexico Spotted Owl, the 

Peregrine Falcon and the Northern Goshawk. I deplore how such widespread development would impact the Jemez 

Mountains as a recreational wilderness-eligible area available to all. I join with the New Mexico Pueblos in asking that 

the Jemez region be preserved for its economic and religious significance to Native Peoples. I deplore the corporate 

push to seize our commons, our public lands supposedly available to everybody, for the exclusive profits of the few. I 

deplore the complicity of the BLM and DOE in this exploitation and thievery. New Mexico has limitless supplies of sun 

and wind. Our state does not need geothermal development that endangers us all. Instead, the Jemez Mountains 

must be preserved as is, either as wilderness or national monument, for all posterity. Therefore, I demand that the 

resolution of this DEIS be Alternative Number 3–NO LEASING! 

Why would you even consider a project that could lead to earthquakes so close to los Alamos lab? That occurrence 

would be devastating. There would be negative impacts to riparian areas, animals, and hot spring temperatures. 

Alternative three: no geothermal, is the only appropriate option.

Fracking will contaminate my well water. I am not collateral damage and a citizen of the EARTH . If you poison my ? 

And if increase tremors appear or are felt let it be know it will be on your head

I strongly oppose geothermal energy development in the Jemez Ranger District and the beautiful Valles Caldera 

National Preserve. This proposed development would negatively impact the area’s physical surroundings, 

endangered species, cultural resources and traditional uses. Please keep these qualities special. I urge you to

choose the “No Leasing” alternative to keep this special area protected. Thank you for your consideration in this 

matter.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

Much of the proposed project area qualifies for possible Wilderness designation. Given statistics released just two 

weeks ago showing the loss of 10% of this planet’s wilderness over the last twenty years, it is ethically and 

ecologically incumbent upon this Forest to preserve what it can of any remaining roadless areas within its boundaries. 

Any further development within this Forest, including the geothermal development in question here, would be directly 

counter to that. (Watson et al., “Catastrophic Declines in Wilderness Areas Undermine Global Environment Targets”, 

Current Biology (2016), http://www.cell.com/current-biology/pdf/S0960-9822(16)30993-9.pdf) 7. Insofar as the 

proposed geothermal project involves tampering with water flow, it necessarily compromises the already precarious 

nature of New Mexico’s limited riparian habitats—habitats already degraded in many places on this Forest and in this 

District by livestock grazing. In a state where water flow and water rights are of primary interest not only to humans 

but to all living creatures, this sort of underground roulette is altogether too risky. For all of the above reasons, 

Alternative 3 (the No Leasing alternative), is the only ethically and ecologically viable option.

1. There is no need to endanger the fragile environment of the Jemez Mountains by exploiting its geothermal 

properties. New Mexico has ample clean energy resources (solar and wind). Problems with solar and wind generation 

of energy are confined to the surface and may be reversed if they become intolerable. Problems with geothermal 

energy generation are likely to be long-term and irreversible (e.g., see point 3 below).

3. Any development of Jemez geothermal resources will almost certainly involve “fracking” or pressure injection of 

liquids either to enlarge existing hot water reservoirs or to connect and supply injection and production wells. The 

draft EIS discusses some of the dangers of this process but does not give sufficient weight to the following 

unpredictable but very possible dangers: a. Irreversible damage to near-surface water supplies, including tribal 

resources. b. Earthquakes such as have occurred recently in Oklahoma and earlier in Colorado. c. Seismic danger to 

radioactive waste storage and other facilities at Los Alamos National Laboratory.

If the Forest Service ignores the above and other considerations and continues with option 2, I suggest that the pink 

area in the Middle Unit shown the attached markup of Figure 2-2 be administratively withdrawn. This modest 

additional withdrawal would at least add some protection for private areas in close proximity to the JNRA such as La 

Cueva and Thompson Ridge (which sits directly over the west end of the known Sulphur Spring geothermal reservoir) 

as well as widely used recreation, scenic, and wildlife areas such as Mushroom Basin, Ice Cave Canyon, and hiking 

access to San Antonio Hot Springs. These areas also include two fire stations of the Sandoval County Fire 

Department La Cueva District which cooperates closely with the Forest Service in fire management.

Recommend Alternative 3 (three). Close all Jemez Mtns lands to all government and private drilling and exploitation! 

Preserve and protect the beautiful Jemez Mtns as a National Treasure!

I am against the proposed Geothermal Leasing Project. I believe it would denigrate our forests and destroy our 

valuable hot springs tourism in the Jemez. On top of that the projects would end in failure as they always have in the 

past as our water is too corrosive for these projects. Please cancel these projects.

All u have to do is look at history. Get on the path of the greater good, meaning for the good of all _ our earth mother 

especially. Do y ever think how much she provides us with and all we do is take, time to give back. And all burning = 

more CO2 which the oceans absorb for us at a price, warming waters throwing off all ? like sharks and sea turtles. we 

are all connected. Alterative 3 is only choice.

As of now u have the nickname forest circus. Any abuse of power is always destined to fail. Any abuse of power is 

always destined to Fail. All you have to do is look at history. Get on the path of the greater good, meaning for the 

good of us all + our earth mother especially. Do you ever think how much se provides us with and all we do is take, 

time to give back. And all burning - more CO2 which the oceans absorb for us at a price warming waters throwing off 

all predators like sharks and sea turtles. we are all connected. Alterative 3 is only choice that I want that all included 

in beauty and harmony. no more destruction. as a women ms ms ? u have a responsibility to be ethical and know the 

reason u are in your position is to change the way people have treater our beautiful earth mother and oceans. And 

the once was ocean. Let’s do all we can to preserve this beauty.

I oppose geothermal fracking in the Jemez mountains

I strongly favor Alternative 3 - to amend the Forest Plan to implement discretionary closures to geothermal leasing on 

all lands in the project area that are not already closed to leasing. In contrast, the proposed Alternative 2 would open 

an enormous area of 136,650 acres in the Coyote, Cuba, Espanola, and Jemez Ranger Districts to geothermal 

exploitation, despite universal public objection. Such a decision would disrupt the quality of life in these rural 

communities, cause lasting (probably permanent) damage to sensitive natural lands and endangered wildlife, and 

negatively impact the Puebloan and Spanish culture and nature-based tourism centered on Valles Caldera, Jemez 

Springs, and La Cueva. Following are my reasons for supporting Alternative 3 and considering Alternative 2 to be 

entirely unacceptable
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

We have seen this all before - geothermal trials that quickly failed, while permanently scarring the land. In the late 

1970s and early 1980s, geothermal demonstration projects were piloted in Valles Caldera when it was still the Baca 

Ranch, under private ownership, starting with a pilot 50 MW power plant. Before I had seen the effects of this 

geothermal exploration (or knew how similar geothermal extraction is to natural gas hydraulic fracturing), I would 

have been interested in geothermal as potentially more environmentally friendly than petrochemical or gas extraction. 

However, 18 months ago, two friends and I took one of the hiking shuttles in Valles Caldera so we could reach Alamo 

Creek in the San Antonio watershed. It ended up being an informal tour of the caldera basin, with the van covering 

more than 50 miles when driving us to and from the hiking

site. What we saw along the way was a series of spoils piles from geothermal drilling (which are sources of invasive 

species growth and spread, since invasive plants are far more tolerant of soil disruption and pollution), abandoned 

pipes from geothermal test wells emerging from the ground all over the place, abandoned clearings and permanent 

geothermal structures (cinder block and rusty metal buildings) in derelict condition, and a series of roads developed 

just for that short-lived experiment. More disturbing was a wide area around the only fen in New Mexico where 

vegetation had been scalded (including mature trees) by massive steam release. The area has not recovered in the 

30+ years since the geothermal effort ended. A mining operation/trash dump was overlaid on a pristine natural area, 

and the result is awful. The geothermal exploration failed because the steam was simply too corrosive on the pipes, 

making the operation too expensive to maintain. The area defined as the “Lease Interest Unit” (on the outer edge of 

the caldera) is equally sensitive

In summary, I sincerely appreciate your requesting public input on this project. It takes a great deal of diligence and 

positive energy to be a conscientious steward of our national lands. The responsibility to care for this forest and the 

people and wildlife who rely on it make it clear that Alternative 3 – no geothermal leasing – is the only acceptable 

outcome. This choice will ensure the ongoing economic, environmental, and recreational health of

the Jemez corridor and Valles Caldera. It will also uphold our responsibility to protect the threatened and endangered 

species we are so fortunate to have, and the fabulous scenery and natural heritage of this crowning gem of New 

Mexico.

Below are some points which you already know:

Environmental factors:

1- pollution to water table, water bodies and riparian areas;--3 listed species: Jemez Mountains salamander, NM 

meadow jumping mouse, and Mexican spotted owl; extremely high public recreational usage. 

First of all, I want to say that I strongly oppose any and all geothermal development in the Jemez Mountains. I 

demand that the BLM and the USFS chose Alternative #3 – NO LEASING

We need sane responses to our environmental challenges. While on the surface geothermal development might 

seem like a “good idea”, I know from personal experience the huge negative impacts of geothermal development, 

which are on par with petroleum fracking. This proposal is just another attempt at taking the public commons for 

private profit – and if approved the Jemez will never again be the beautiful, wild place that it now is.

Just drive to the northwest part of the state and take a look at what’s going on – roads, heavy equipment and fracking 

infrastructure everywhere – on **our** (formerly public, now leased for profit) lands. (Last fall I attempted to camp at 

Navajo Lake State Park and I was sickened by the fracking chemicals and was forced to leave.)

I am shocked that our public lands are being auctioned off for private profit. These are our **public lands** - and the 

public pays the price in so many ways when our land is treated like some sort of disposable commodity whose only 

value is corporate profit – no more open space, no more quiet, no more pristine lands to escape the stresses of life 

and enjoy nature, no more clean air or water.

I am very much opposed to developing our public lands – they should be preserved for future generations to enjoy 

and appreciate. Will our children have nothing sacred handed down to them – nothing beautiful for them to enjoy, no 

clean air or water? Seriously – STOP this madness!

Alternative #3: no leasing lands for geothermal fracking is what should be decided by intelligent people. The public 

lands are for the enjoyment of people and wildlife that inhabit and visit them. It is very dangerous and harmful to the 

environment to do this geothermal fracking in this area. Nobody really wants it anywhere, so why should it be force on 

the people and lands of Valles Caldera? No. No . No fracking in the Jemez Mountains.

I am hereby advocating for Alternative 3: The No Leasing Alternative. The subject area is a historic geological 

treasure that deserves to be preserved in perpetuity for all generations to come. In particular, fracking is an 

extraordinary and reckless treatment of such a fragile environment. Please respect the wishes of the people whose 

unselfish interests are at the heart of our request.

I am demanding Alternative #3 - No Leasing, not the Alternative #1 - No Action - due to: Seismic events risk increase 

possibility in a highly reactive area. Impact to Water bodies and riparian areas
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

I am extremely worried about these plans, which would not only affect us residents, but also the environment (air and 

water, climate, landscapes, endangered species, etc.). It would also involve immense risks, like increased danger of 

wildfires caused by downed power lines, earthquakes, flash floods after erosion through clear-cut areas, etc. 

What about the protection of the Valle Grande and Bandelier, of the unique natural beauty of the Jemez Mountains, 

of the natural hot and warm springs?

Alternative #3

Do not frack the Jemez

The Forest Service only has limited control over how drilling would actually take place, and the management needed 

to ensure the protection of these values would be extremely complex. Geothermal development occurred in this area 

30 years ago and its negative impact can still be seen today on the Valles Caldera preserve. Your own Draft EIS 

indicates that the risk of fire would increase if geothermal production occurred, and also that the temperature of our 

beloved hot springs might decrease. Please do not allow the Jemez Mountains to become a sacrifice zone to energy 

development.

In addition to these water related impacts, Geothermal development would also create a cascade of lasting effects on 

the ecosystem. There would be disturbances of the soil and vegetation, including the unintended introduction of nonnative species by construction equipment; fish and wildlife habitat loss and disturbance; noise and air pollution; 

potential for fires from power lines and equipment; disruption of grazing operations and forage; potential disturbance 

of tribal cultural and religious sites that are everywhere in the Jemez. In addition, there would likely be unintended 

and unforeseen consequences we cannot even predict. 

Direct experience with and love of the land, coupled with common sense, dictates my strong opposition to geothermal 

production that will negatively effect one of the most beautiful and well-loved places in the state of new mexico.

Geothermal production brings substantial environmental consequences. I will list some important, negative 

consequences:1. Significant surface disturbance to build well pads and pumps, roads, transmission lines, pipelines, 

fresh water is required fracking is often used.

Hot springs are found in the geothermal proposal leasing area and to the adjacent, and important Valley Caldera 

National Preserve which provides an extended, continuous landscape for the preserves ecosystem health

The entire Jemez Springs community is vulnerable to negative impacts from the development of geothermal activities 

including: increased truck traffic, water contamination, tourism being negatively effected, quality of life for residents 

will be negatively effected forever.

I am not convinced that the SFNF and this proposal seriously and adequately address the multiple and varied needs 

of this very sensitive, important, and dearly beloved area. As America has grown through the years of commercial 

and residential expansion, we have continuously and systematically destroyed valuable areas containing important, 

sometimes one-of-a-kind habitats and species for our short-term, self serving goals and aims. Today we must stop 

this mindless destruction and devastation to the wilderness and species many of us treasure, appreciate and enjoy. 

As we continuously honor and love the land we have chosen to share with ecosystems and wildlife that came before 

us and whose continued health and safety we are dedicated to preserve. As a proud member of the Wilderness 

Alliance, a proud New Mexican citizen, and a human being who loves her chosen environment of New Mexico, I 

heartedly, urgently deplore destroying important landscapes and the wildlife that land embraces and supports. I 

advocate strongly for Alternative 3: the No Leasing Alternative. 

I am a resident of Taos, NM and I would like to request that fracking NOT be allowed in the Jemez Geothermal areas 

or anywhere else, for that matter. Tremendous damage will be done should this occur and we need to protect our 

earth so that we can continue to live on it.

Please do not frack geothermal for energy in the Jemez mountains this is bad policy

However, the likelihood of such an event(s) is hardly the prevailing point. It would be the devastating consequences, 

however unlikely, that make even the lower level of pressurization involved in this version of ‘fracking’ an unwise 

venture. The decision was already made many decades ago. By storing plutonium at Los Alamos, as well as far

greater quantities of lower risk materials, the United States has effectively made this area untouchable with regard to 

the introduction of further risks. 

I’m writing in regards to the proposal to allow leasing on 195,000 acres of the Santa Fe National Forest. I am strongly 

opposed to geothermal production in this area, and believe the only appropriate choice for the Forest Service to make 

is to adopt Alternative 3, which would not allow geothermal leasing to take place. In addition to being one of the mostloved and heavily-visited areas of New Mexico, the project area also contains critical ecological resources like 

endangered species, sensitive riparian zones, Inventoried Roadless Areas, and lands which contain wilderness 

areas.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

The Forest Service only has limited control over how drilling would actually take place, and the management needed 

to ensure the protection of these values would be extremely complex. Geothermal development occurred in this area 

30 years ago and its negative impact can still be seen today on the Valles Caldera preserve. Your own Draft EIS 

indicates that the risk of fire would increase if geothermal production occurred, and also that the temperature of our 

beloved hot springs might decrease. Please do not allow the Jemez Mountains to become a sacrifice zone to energy 

development.

I think this is a decision that needs more consideration! There are many consequences that would result from this 

action, and they far outweigh the benefit! 

I’m writing in regards to the proposal to allow leasing on 195,000 acres of the Santa Fe National Forest. I am strongly 

opposed to geothermal production in this area, and believe the only appropriate choice for the Forest Service to make 

is to adopt Alternative 3, which would not allow geothermal leasing to take place. In addition to being one of the mostloved and heavily-visited areas of New Mexico, the project area also contains critical ecological resources like 

endangered species, sensitive riparian zones, Inventoried Roadless Areas, and lands which contain wilderness 

areas.

The Forest Service only has limited control over how drilling would actually take place, and the management needed 

to ensure the protection of these values would be extremely complex. Geothermal development occurred in this area 

30 years ago and its negative impact can still be seen today on the Valles Caldera preserve. Your own Draft EIS 

indicates that the risk of fire would increase if geothermal production occurred, and also that the temperature of our 

beloved hot springs might decrease. Please do not allow the Jemez Mountains to become a sacrifice zone to energy 

development. 

This ancestral Sacred sites of the Valle Caldera, are not confined by “borders”, all life and we are part of these lands. 

To desecrate this area is in violation of https://www.nps.gov/nagpra/

It has already been scientifically proven that Fracking is chemically harmful to land, water and watersheds. Fracking 

leads to more earthquake activity, because it breaks earths skin. This area is much to close to Nuclear waste that has 

not been cleaned up and is still harming all life and the people.

Page No.: none

Section, Paragraph, Table or Figure No.: none

Comment: We suggest including a discussion of the history of the Baca geothermal project (Union Oil, Department of 

Energy) and the previous EIS associated with it in the DEIS.

This geothermal fracking project could also lead to earthquakes (Oklahoma) and uncontrollable forest fires which 

could expose us all to highly flammable plutonium so close to LANL. I oppose all fracking anywhere because (e.g.) 

the rich gas and oil companies in California are buying up scarce water needed for agriculture and leaving toxic 

wastepits...threatening our organic food supply. Let’s not let big money ruin our clean water supply here in New 

Mexico. Clean unfracked water is needed to support all life. No one can survive on our planet using polluted fracked 

water that contains lead, benzene, methanol, napthalene, arsenic, propane, radium and radioactive toxic sludge -

plus polluting our clean air with air pollution evaporating from toxic wastepits. Grazing animals sicken and die after 

drinking fracked runoff water. People living near the industrial wasteland left after fracking have asthma, nausea and 

organ failure.

I vote no leasing of NFS lands in SFNF for the purpose of geothermal exploration development and production. My 

reasons are that the proposed location in the Jemez mountains is vulnerable to earthquakes and; in dangerous 

proximity to the deadly substance of 4 metric tons of plutonium housed at PFA LANL, which is inadequately 

reinforced against earthquakes. A quake resulting in a fire at PF-4 would case huge death to people animals and the 

earth

Overall: I am very concerned that all the phases of geothermal energy development in the Jemez mountains of the 

Santa Fe National Forest have the potential for significant short and long term impacts to our water resources and 

that neither the 2008 PEIS or this DEIS adequately identify even the broad impacts. The appropriate level of 

environmental analysis certainly would need to be on a site specific case-by-case basis due to not only the location, 

but also constantly changing technology. 

I respectfully request that USFS authorizing officer require site/technology specific environmental analyses for 

surface-disturbing geothermal exploration or development proposals and utilization of outside professional resources 

such as the Department of Energy’s Geothermal Technologies Office publications and staff as much as possible. This 

would help ensure that the analyses are technologically current and provide unbiased assessments of potential 

environmental impacts for the specific location and technology in question
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

I strongly oppose any leasing for geothermal activity due to its potential damage for this sensitive ecosystem. I 

certainly would not approve an out-of-state company to avail themselves of our resources, with their inherent lack of 

knowledge of our arid, drought prone land. I urge the SFNF to fulfill their obligation to the public to inventory for areas 

with wilderness characteristics. We must do this for the benefit of all now, but also for future generations.

From the meetings that were held last year to this, it seems that they are only to disperse information – not receive 

any. What do we, as citizens of the affected areas, need to do to be heard with our concerns? The Environmental 

Impact Report that covers the pros of fracking have spoken, and seem to be the only views being considered. What 

about the cons? What does it take to get our voices heard? Do we need to hire a geologist to talk savvy about the 

disruption it could cause to a seismic sensitive area? Do we need to hire a lawyer to sue the forest service to stop this 

insane push to endanger our land/water/health/environment? Don’t we have enough of a water shortage to see this 

as a disaster to the community, as well as the state, in general? Who will pay for the damage after the companies 

who profit from this fiasco have laid waste to our beautiful forest, as well as our water source? 

I am a property owner in the Seven Springs community located in the Jemez Mountains, adjacent to t he project area. 

I am opposed to the proposed action under the United States Forest Service’s Draft Environmental Impact Statement 

for Geothermal Leasing in the Santa Fe National Forest. Due to concerns with environmental impacts, induced 

seismicity, and depletion of water resources detailed below, I support Alternative 3 - No Leasing.

In conclusion, while it is recognized that there are federal and state mandates to reduce our dependence on fossil 

fuels, the proposed action is too risky for area residents to support. Alternative 2 seeks to address the significant 

issues associated with geothermal development in the project area, however inadequate resources would make it 

extremely difficult for the USFS to effectively administer such a complex leasing program.

Also...Environmental factors like, pollution to water table, water bodies and riparian areas, damage to Jemez 

Mountains salamander, NM meadow jumping mouse, and Mexican spotted owl, also the public recreational usage. 

Management levels needed to protect these resources from damage are impractical and unlikely to occur also..

Despite significant public demand for the Forest Service to inventory the public lands it oversees for areas with 

wilderness characteristics, plus widespread belief that much of the Jemez Mountain project area qualifies for 

wilderness designation, the DEIS ignores this concern, and the Santa Fe National Forest rejected a “wildernessfocused” alternative as outside the scoop of the proposal which is beyond belief...also The DEIS states that 

geothermal development could lower the temperature of the existing Jemez hot springs, impacting a major tourist 

attraction and the local economy. Instead, tourists would enjoy high powered electric lines, traffic, noise, new eroding 

roads, muddied rivers and lukewarm soaks. The DEIS even admits to increased fire potential stemming

from geothermal development. Three massive forest fires in the Jemez Mountains in the last 21 years have seriously 

threatened Los Alamos National Laboratory, where an uncontrolled plutonium fire could threaten the livability of 

northern New Mexico. With all of that and because of this next statement I demand The Alternative Three.

I Demand Alternative #3, No Leasing, NOT the so-called “No Action” Alternative #1. This is unfathomable to me that 

fracking could even be considered in the wake of the nuclear disaster this could ignite... unbelievable. My daughter 

and grandchildren live here... please stop this...

Forbid leasing on the surface of the western flank

Geothermal energy exploration and production can be a positive endeavor, if it is undertaken away from existing 

communities, in a manner that preserves the serenity of the Jemez mountains and protects the groundwater and hot 

spring water resources for continued use for generations to come.

This email is to voice my objection to the development and production of geothermal energy within the Jemez 

watershed. I am in agreement with the Village of Jemez Springs, New Mexico, Resolution # 2016-019, which voices 

reasons for opposition to the Santa Fe National Forest Geothermal Leasing Project.

I want the Forest Supervisor to select OPTION 3 (no geothermal leasing allowed) in the Santa Fe National

Forest. I enjoy the natural hot springs in the forest often. I believe that allowing leasing, and eventual development, of 

the forest lands will degrade the hot springs, the surrounding forest, and increase the possibility of local earthquakes. 

In the worst case scenario, these quakes and/or water injections in the area could destabilize the deep subsurface 

enough to reactivate volcanos in the area. We rely on the many hot springs to naturally keep that risk low. Please do 

not use the hot springs in this area in that way. It’s just too great of potential consequences for the potential benefit. 

We can acquire energy in far less hazardous ways.

i am a resident of taos new mexico...... and i am urging that NO FRACKING FOR GEOTHERMAL IN THE JEMEZ 

MOUNTAINS....... the reasons are too numerous to list. the bottom line is that fracking here in new mexico would 

cause severe damage to our land and people. thank you for taking my comments into consideration
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

the public believes the prices paid by energy developers for using our lands for geothermal energy are much too low 

and that the us citizenry is being ripped off by govt making leases with their pals we think the prices that our 

geothermal should get should be raised by 2000% immediately. I think that the guys in this business have been 

ripping off the national public which owns these lands. getting $316 for leasing geothermal land in California, what a 

rip off that is. its time for our treasury to make money if we are going to despoil our natural lands and let profiteers 

use them. the profiteering have been using us. this comment is for the public record. please receipt.

I’d like to put my voice in against such development. Natural resources are scarce enough in our state. We don’t have 

an abundance of undeveloped sites with geothermal activity. Anything done that might change or affect this resource 

should not be considered. The springs in Jemez have been used as healing baths and sacred spaces long before 

America was so named. These are our heritage and should be treated with the utmost respect, not plundered for 

power. There are several native species in these areas that would be poorly affected, and there is no way to replace 

these habitats once degraded. It is not worth a little power in our lines to remove the power that these natural spaces 

have in our lives.

Please don’t allow this development to occur.

I am entirely opposed to fracking

And during at least one information meeting for the public, we were told that there would be no fracking involved in 

the project. This was incorrect information. If there hadn’t been a member of the public with over 10 years experience 

in the field, we would have been left with incorrect assumptions about this critical point of the project. All the 

documents available at the time talked about the project being hot rock fracking, but no member of the Forest Service 

corrected this statement—it was left to a member of the public

I urge the Forest Service to show some prudence here and to show that you have learned from your mistakes during 

the Cerro Grande Fire. Choose Alternative Three and stop this dangerous project now. 

A very dangerous idea. The stability of the LANL area must not be compromised. One can only imagine the 

catastrophe. Don’t. 

I am a NM resident and frequent visitor to NFS lands throughout the state, including the beautiful Jemez Mountains. I 

strongly oppose the development of an Enhanced Geothermal System in this area which lies above several faults 

and in proximity to Los Alamos Technical Area 55 Plutonium Complex.

I demand that the NFS choose Alternative #3--NO LEASING.

I recently learned about a Proposal to Mine the Jemez Mountains for geothermal electric power. As a New Mexico 

resident I am requesting Alternative # 3, No leasing, and against Action Alternative #1. 

Many New Mexico residents that I have had this proposal to Mine the Jemez Mountains for geothermal electric power 

think it is a bad idea. Many people are becoming environmentally conscious , as they realize the effects of, “fracking”

are harmful to all regions. 

I express my concerns to the Santa Fe National Forest to preserve our lands and listen to the people’s voice. The 

Dakota Access Pipeline is an example of how far this can go. Please represent our state better, and set the stage for 

environmentally safe choices, instead of potentially hazardous development plans. 

We urge you to reject the Proposed Action discussed in Alternative 2 of the Draft Environmental Impact Statement 

(DEIS), and to accept Alternative 3 to amend the Forest Plan to implement closures to geothermal leasing on all 

lands in the project area not already closed to leasing. 

In conclusion, we urge you Ms. Garcia and other decision makers at the USDA, Santa Fe National Forest to uphold 

the moral and lawful trust responsibilities to tribes including the protection of cultural resources and religious 

freedoms. I and my staff have met with you and described how important protection of the Jemez Mountains is. We 

therefore again urge you to select Alternative 3 to close all lands in the Jemez Mountains project area to geothermal

leasing

I vote for “3. the No Leasing Alternative.”

The hot waters produced by the natural geothermal activity in the Jemez are loaded with geochemical. The problem 

may be acerbated when reservoir rocks are dissolved during the geothermal power generation process. This may 

cause scaling of equipment and/or corrosion of piping which could render the production process unfeasible. 

Corrosion can also result in pipe/equipment failure leading to ground and air pollution outside the production area 

(even a closed loop system can fail in such a corrosive environment). Please consider the threat of pollution to soil, 

fauna and flora, air, ground or surface water when making your decision on this project.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

I am aware about two projects within the SFNF with less than satisfactory remediation results - the rather 

unsatisfactory remediation results of pumice mining activities along Hwy 4 and the inability to get the responsible 

movie producers to restore the location of a movie set (Wild Hogs) in a riparian area at the Las Conchas trailhead to 

its original condition. Without satisfying answers to these questions and the ability to enforce appropriate remediation, 

this proposal should probably not be contemplated by the SFNF.

Please consider that the proposed geothermal project area may be unfit for geothermal production on a large scale. 

This area is an ecologically sensitive high desert environment with scarce water resources and extreme proneness to 

erosion and soil degradation in many areas. The area is valued by visitors and residents alike for its natural and 

scenic beauty which stands to suffer greatly once large scale industrial development has been allowed into the area

Please consider refusing to allow leasing for any development in this area. If a plan moves forward, please ensure 

that water bodies, natural geothermal features, Inventoried Roadless Areas, cultural resources, habitats of 

endangered species and other important features/places are fully protected. This would require ample use of the No 

Surface Occupancy without Exception Stipulation, a much larger buffer around water bodies, and ensuring that the 

final decision document stands and cannot be altered upon the request of the Industry and State agencies.

I am opposed to any geothermal production that impacts water bodies, Inventoried Roadless Areas, cultural 

resources, and important habitat for species. Please ensure none of the land in or around these areas can be 

disturbed, that a much larger buffer is placed around water bodies, and that deviation from stipulations could not 

occur at the whim of Industry and State agencies.

I strongly oppose any plan to lease land in the Jemez for this kind of commercial development. New Mexico may be a 

poor state in need of funds, but no amount of money is worth the risk of damage to the beauty, ecology, and 

wonderful quality of life we associate with the Jemez. Why should greed for energy drive us to permit disturbance to 

the irreplaceable endangered species that live in the area? Why should we endanger the healing hot springs? Why 

trample on sites sacred to Native Americans of the area? Please, forget those dollar signs and think ahead to what 

the Jemez will be like for your grandchildren’s grandchildren

I am concerned about the impact of development on surface and ground water quality and potential degradation of 

habitat for listed species. The levels of management which would be required to protect each of these resources are 

unreasonable, and not practical even for the industry. The amount of recreational use that the Jemez Mountains sees 

from surrounding communities is of greater importance currently and for posterity than the potential dollars gained 

from leasing

With the use of fracking to create energy, it could cause a multitude of problems, including earthquakes, and 

receeding of our spectacular springs. For the love of everything New Mexican, please please please do not continue 

with this atrocity! With how much money (not to mention the destruction of wild life and beautiful spaces) is to be 

spent setting the project up, we could easily redirect that cash flow into something such as a solar plant and wind 

farms, these are extremely clean and impact the earth and environment far less.

As well there is a negative impact to water bodies, and Jemez Mountain species such as the Jemez Mountain 

salamander, the NM jumping mouse and the Mexico spotted owl.

It has been predicted that the fracking will in addition lower the temperatures of the Jemez hotsprings heavily and 

negatively impacting tourism and the local economy in that area. An increased fire potential stemming from 

geothermal development can also seriously threaten the safety of the Los Alamos lab as well as the people and 

wildlife currently enjoying life there.

As a citizen of Northern New Mexico I demand Alternative #3, No Leasing, NOT the so-called “No Action”

Alternative#1.

I support Alternative 3. Please, no geothermal activity, no fracking. Of great danger on several fronts.

4. Lack of consideration/collaboration/involvement of the Valles Caldera National Preserve and or NPS in this action. 

5. The use of outdated best practices for geothermal endeavors, you are using best practices from 2008, and it is 

2016

I DEMAND ALTERNATIVE THREE! (No Geothermal)

Dear Decisionmakers. Please keep the Valle Caldera free from development. This spectacular wilderness needs to 

be preserved and protected. I believe in alternative and sustainable energy but not at the cost of our wilderness and 

our wildlife.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-23. General Comments Related to this Planning/Analysis Effort

Ormat must be aware by now that geothermal exploration has a sad history in the Jemez, as some folks have noted 

on the Facebook pages of the Jemez Daily Post, and others spoke of at the meeting. Some 20 or 30 years ago some 

outfit, working together with the Department of Energy and PNM drilled around in the heart of what is now the Valles 

Caldera National Preserve, when it still was the Baca land, and discovered that geothermal energy production in that 

area was not financially viable. This lives in the memory of people in the Jemez, but folks bringing the matter up at 

the meeting were largely ignored by Larry Gore

Before you put together a response to the SFNF, I think you need to form a more representative group from the 

Jemez, and perhaps take into account this: geothermal energy exploitation in the Jemez is not considered to be 

financially viable for a commercial company like Ormat Technologies to undertake, unless it is government 

(federally?) subsidized. I do not know how this can be found out to be on the cards, but there is some talk of it.

Please, please refrain from defiling this spectacular natural resource. Do NOT allow leasing in the Valles Caldera.

Therefore, be it resolved: the village of Jemez Springs opposes the development and production of geothermal 

energy within the Jemez watershed. Be it further resolved: our economy and future depends on no disruption of hot 

and cold water flow, no increase in seismic activity, the preservation of our scenic beauty, and the continued ability to 

live a sustainable life. 

Please keep Valle Grande as it is! No fracking! There are alternative energy solutions!!!!! Lease no fracking!

I would like to express my dismay that commercial geothermal energy development is being considered in the Jemez 

mountains. All signs point to possibly very dangerous consequences if this kind of activity is allowed to go forward. It 

should not happen.

Geothermal should be a great upset, so long as the cost doesn’t involve reduced flows for the various Jemez 

hot/warm springs, and no new roads into roadless areas. Wilderness is the shrinking home of wildlife. 

I am very concerned about the prospect of GEOTHERMAL in the Santa Fe National Forest south of Hwy 96 near 

Abiquiu Dam in the Rio Chama Watershed. The presentation on this subject was disturbingly vague with very 

unreadable maps. According to the USGS this area is NOT a high probability for Geothermal. It also appears that the 

scoping area extends outside of the National Forest. Making Geothermal development a front for gas and oil. Larry 

Gore at the meeting emphatically stated that this was ONLY GEOTHERMAL exploration,,, NOT OIL AND GAS. Yet 

the NMOCD states that geothermal and gas and oil are coproduction activities and I assume are permitted as such... 

This is a horrid misrepresentation to the public

Does the State of New Mexico, the NMOCD, BLM or any other agency have any sort of “contingency fund” set up for 

destroyed waters and or long term health issues (failed casings say in 50 years) dam damage/failure...? I know for a 

fact that the Gas and Oil developers are above the Law pretty much across the board for any liability and the EA had 

a $15,000,000 super fund site clean up for a dry cleaner spill in Espanola and it is pretty unlikely that the EPA would 

allot any funds for such a dereliction by the State to protect a Watershed with vertical and horizontal fractures and 

known also to communicate water veering formation to water bearing formation. when the State neglected to take the 

local geology and health risks the TENORM into consideration. It appears that you all are taking a huge risk with 

perhaps NO forethought of any potential damage or responsibility.

1. With so many different environmental factors to consider, including impacts to water bodies and riparian areas, 

three listed species (Jemez Mountains salamander, New Mexico meadow jumping mouse, and Mexican spotted owl), 

potential seismic impacts, extremely high levels of recreational use, it is not practical or desirable to have any 

geothermal leasing in this area.

Absolutely no to any fracking in the Jemez area now or in the future. Protect our public lands, water for future 

generations. We demand alternative #3
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-24. Recommended Studies or Reports to Review and Requests for Data

For further information on seismic dangers at LANL, see the report attached: Deficiencies in Knowledge of Seismic 

Hazard for Proposed $6 Billion Chemistry & Metallurgy Research Replacement Nuclear Facility (CMRR-NF) at Los 

Alamos National Laboratory Need for Field Studies and a New Environmental Impact Statement November 9, 2011, 

Robert H. Gilkeson, Independent Registered Geologist, Joni Arends, Executive Director, Concerned Citizens for

Nuclear Safety

The 4.8 magnitude earthquake that hit East Texas back in 2012 was the result of wastewater injections from oil and 

gas companies. These are the findings, say scientists using a new method of research in the earthquake/geophysics 

field—Interferometric Synthetic Aperture Radar (InSAR). InSAR is a “technique for mapping ground deformation 

using radar images of the Earth’s surface that are collected from orbiting satellites,” according to the U.S. Geological 

Survey. It’s regularly used to monitor volcanoes. In East Texas, it could detect changes in the of Earth’s surface at 

the scale of centimeters. Setting InSAR’s eye on four high-volume wells used for wastewater disposal, the 

researchers began to track the changes in the Earth. Wastewater injection wells handle a byproduct of fracking, 

which study co-author William Ellsworth compares to “ancient ocean water” in that it is “too salty and too 

contaminated with other chemicals to treat economically, so the only viable solution at present is to put it back 

underground.” The wells then push that wastewater thousands of feet underground, although distances vary per well.

Other scientists have already hypothesized, using more traditional analysis, the same solutions to the East Texas 

earthquake events. As many people here have pointed out, in virtually every diary I’ve written on this subject, 

wastewater injection by itself is not the problem. Neither is hydraulic fracturing, necessarily. The issue is where the 

wastewater gets injected. The InSAR measurements revealed that wastewater injection at the shallow wells resulted 

in detectable ground uplift up to 5 miles (8 kilometers) away but only a modest rise in pore pressure, which is the 

pressure of fluids within the fractures and cavities of rocks, at the depth at which earthquakes happen 2 or more miles 

below the surface. Increasing pore pressure within a geologic fault can cause the two sides of the fault to slip and 

release seismic energy as an earthquake. According to the study’s findings, the shallow well sites seemed able to 

distribute the pressure of wastewater injection in such a way as to not travel down towards the “crystalline basement, 

a deep and faulted rock layer where earthquakes originate.” However, the deep well injection sites helped build and 

create the pressure that ended with the 2012 earthquake and subsequent tremors. The scientists involved feel that 

what’s most important about their research is that they feel this method of research (geological mapping from space) 

can help the oil and gas industry make safer decisions about how they build and operate their waste well facilities.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-24. Recommended Studies or Reports to Review and Requests for Data

I note that the DEIS contains an impressive list of Forest Service members and 11 others who contributed to its 

preparation. However, there is a glaring omission of a geophysicist on the DEIS team. This is so because a key step 

in any geothermal project is resource exploration and confirmation which is primarily the privy of geophysics. 

Therefore, a geophysicist would have strengthened many of the DEIS sections, e.g., on technical capabilities, 

geologic resources, and environmental consequences. And, recent references and important publications directly 

focused on the geothermal potential of the Jemez Mountains would have been included. Finally, the omission of Don 

Brown as one of the contributors missed the person who knows the most about geothermal in the Jemez Mountains. 

He is the only surviving key member of the LANL HDR program and even though he is of poor health, I’m sure that 

he would have gladly contributed significantly to the effort. His 657 page book (Brown et al., 2012) is the bible of the 

LANL HDR project, yet it was not referenced. Below I’ve included this reference as well as others that might be 

useful. 

References

Albrecht, M., 2011, Innovative exploration techniques for geothermal assessment at Jemez Pueblo, New Mexico, U. 

S. Dept. Energy DOE Geothermal Program Progress Report, 16 p.

Brown, D. W., D. V. Duchane, G. Heiken, and V. T. Hriscu, 2012, Mining the Earth’s Heat: Hot Dry Rock Geothermal 

Energy, Springer Geography, 657 p.

JASON, 2013, Enhanced geothermal systems, JSR-13-320, MITRE Corp., McLean, VA, 141 p.

Jiracek, G. R., 1975, Deep electrical resistivity investigations coupled with dry geothermal reservoir experiments in 

New Mexico: NSF Tech. Prog. Rept., Univ. of New Mexico, Albuquerque, 47 p.

Jiracek, G. R., C. Smith, and G. A. Dorn, 1976, Deep geothermal exploration in New Mexico using electrical 

resistivity: Proc. Second U.N. Symp. Devel. and Use of Geothermal Resources, 2, 1095-1102.

Jiracek, G. R., C. A. Swanberg, P. Morgan, and M. D. Parker, 1983, Evaluation of the geothermal resource in the 

area of Albuquerque, New Mexico: New Mexico Energy Research and Development Institute, NMERDI 2-67-2135, 

169 p.

Jiracek, G. R., C. L. Kinn, C.L. Scott, M. G. Kuykendall, W. S. Baldridge, S. Biehler, L.W. Braile, J. F. Ferguson, and 

B. Gilpin, 1996, Tracing crustal isotherms under the western margin of the Jemez Mountains using SAGE and 

industry magnetotelluric data, N. M. Geol. Soc., Field Conf. Guidebook., 47, 129-133.

Lutter, W. J., P. M. Roberts, C. H. Thurber, L. Steck, M. C. Fehler, D. G. Stafford, W. S. Baldridge, and T. A. Zeichert, 

1995, Teleseismic P-wave image of crust and upper mantle structure beneath the Valles Caldera, New Mexico: initial 

results from the 1993 JTEX passive array: Geophys. Res.,Let., 22, 505-508.

Nettleton, C.E., 1997, Magnetotelluric modeling of the Valles caldera, New Mexico, MS thesis, San Diego State 

University, 274 p.

Nishimura, T., M. Fehler, W.S. Baldridge, P. Roberts, and L.K. Steck, 1997, Heterogeneous structure around the 

Jemez volcanic field, New Mexico, USA as inferred from envelope inversion of active experiment seismic data, 

Geophys. J. Int., 131, 667-682.

Roberts, P. M., K. Aki, and M. C. Fehler, 1991, A low-velocity zone in the basement beneath the Valles Caldera, New 

Mexico, J. Geophys. Res., 96, 21,583-21,586.

Sass, J. H., and P. Morgan, 1988, Conductive heat flux in VC-1 and the thermal regime of Valles caldera, Jemez 

Mountains, New Mexico, J. Geophys. Res., 93, 6027-6039.

Steck, L. K., C. H. Thurber, M. C. Fehler, W. J. Lutter, P. M. Roberts, W. S. Baldridge, D.G. Stafford, and R. 

Sessions, 1998, Crust and upper mantle p wave velocity structure beneath Valles caldera, New Mexico: Results from 

the Jemez teleseismic tomography experiment, J. Geophys. Res., 103, 24,301-24,320.

U. S. Energy Information Administration, 2015, 2020 Levelized Costs AEO 2015, 12 p.
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Table B-25. Comments Related to Planning Regulations

It is a requirement of CEQ that all reasonably possible impacts both direct and indirect of a proposed action must be 

presented. Since there has already been an interest in leasing expressed for part of the area, it is certainly logical to 

assume that once the area is classified for leasing, it is highly likely that leasing of some or all of the area would 

occur. Therefore, this possibility must be described and analyzed as part of the proposed action, according to CEQ 

1508.8 Effects part (b): “Indirect effects, which are caused by the action and are later in time or farther removed in 

distance, but are still reasonable foreseeable.” CEQ question 18 in its “NEPA’s Forty Most Asked Questions”

26 states: 

“The EIS must identify all the indirect effects that are known, and make a good faith effort to explain the effects that 

are not known but are “reasonably foreseeable.” It is not feasible to assume that no leasing and subsequent 

development would not occur as a result of designating the area as available for geothermal leasing. As stated in 

section 1.5.1 of the DEIS, “A federal geothermal lease grants ‘the exclusive right to drill for, extract, produce, remove, 

utilize, sell, and dispose of all the geothermal resources’ in the lands described within the lease form.” Even though 

additional NEPA compliance occurs after the lease is issued, selection of a no-action alternative becomes a moot 

point since the right to develop goes with the lease. Therefore, it is essential that the impact of development be 

portrayed to the extent possible for the proposed action in this DEIS. Not portraying these potential impacts of the 

proposed action could be disjointed, which is counter to CEQ requirements and numerous court decisions. 

26 Available at: https://ceq.doe.gov/nepa/regs/40/40p3.htm.

The DEIS fails to present the criteria that were used to determine whether an impact is significant or not. CEQ 

1502.16 Environmental Consequences requires the following: “It shall include discussions of: (a) Direct effects and 

their significance (b) Indirect effects and their significance.” The impact analysis in this chapter needs to identify those 

anticipated impacts that are significant and explain why they are considered significant.

The DEIS Environmental Consequences chapter fails to present a reasonable and scientific analysis of the potential 

impacts that would be expected of the proposed action and alternatives, as required by NEPA and the CEQ 

Regulations, and needs to be redone to fully evaluate the potential impacts which may occur as a result of opening 

the area to geothermal leasing. As discussed above regarding Section 2.3.2, the description of the proposed action 

and alternatives must include a reasonably foreseeable developmental scenario, rather than including it only as a 

cited reference (this document was not available on the SFNF website until requested from the agency). Question 7 

of CEQ’s Forty Questions, Difference Between Sections of EIS on Alternatives and Environmental Consequences 

states: “The environmental consequences section should be devoted largely to a scientific analysis of the direct and 

indirect environmental effects of the proposed action and of each of the alternatives. It forms the analytic basis for the 

concise comparison in the alternatives section.” Question 18, Uncertainties About Indirect Effects of a Proposal, 

states: “The EIS must identify all the indirect effects that are known and make a good faith effort to explain the effects 

that are not known but are reasonably foreseeable.” Section 1502.2 Implementation (a) states: “Environmental impact 

statements shall be analytic rather than encyclopedic.” As presently written, the DEIS chapter 3 is encyclopedic and it 

does not present any analytical analysis of potential impacts. Section 1508.8 Effects states: “Effects include: (b) 

Indirect effects, which are caused by the action and are later in time or farther removed in distance, but are still 

reasonably foreseeable.” Chapter 3 of the DEIS fails to meet these requirements. 

Even the Forest Service’s guidance in FSH 1909.15 NEPA Handbook, Chapter 10 Environmental Analysis provides 

the following guidance: “When an agency is evaluating reasonably foreseeable significant adverse effects on the 

human environment in an environmental impact statement and there is incomplete or unavailable information, the 

agency shall always make clear that such information is lacking. a) If the incomplete information relevant to 

reasonable foreseeable significant adverse impacts is essential to a reasoned choice among alternatives and the 

overall costs of obtaining it are not exorbitant, the agency shall include the information in the environmental impact 

statement. b) If the information relevant to reasonable foreseeable significant adverse impacts cannot be obtained 

because the overall costs of obtaining it are exorbitant or the means to obtain it are not known, the agency shall 

include within the environmental impact statement: a. A statement that such information is incomplete or unavailable; 

b. a statement of the relevance of the incomplete or unavailable information to evaluating reasonably foreseeable 

significant adverse impacts on the human environment; c. a summary of existing credible scientific evidence which is 

relevant to evaluating the reasonably foreseeable significant adverse impacts on the human environment, and d. the 

agency’s evaluation of such impacts based upon theoretical approaches or research methods generally accepted in 

the scientific community. c) For the purposes of this section, “reasonably foreseeable” includes impacts which have 

catastrophic consequences, even if their probability of occurrence is low, provided that the analysis of the impacts is 

supported by credible scientific evidence, is not based on pure conjecture, and is within the rule of reason.” There are 

certainly examples available from existing geothermal projects that could be obtained and used in helping to provide 

a sound analytical analysis for the DEIS proposed action and alternatives. One such example is: Casa Diablo IV 

Geothermal Development Project Final Joint Environmental Impact Statement and Environmental Impact Report. 

June 2013 DOI Control #: DES 12-21 Publication Index #: BLM/CA/ES-2013/021+3200+1793 State Clearinghouse 

No. 2011041008. This statement covers an addition to an existing project that has had extensive monitoring.
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Table B-25. Comments Related to Planning Regulations

Before we begin our comments on the DEIS itself, we would like to remind SFNF again of both the Forest Service’s 

(USFS) mission, its decision-making discretion, and its public trust responsibilities as a federal land management 

agency. Additionally, we believe it is important for SFNF to take note of the Bureau of Land Management’s (BLM) 

mission and guidance at this time, as it would not serve the public interest for SFNF to allow something now that BLM 

must prohibit later. 

The USFS mission is “Caring for the Land and Serving People”

1

. USFS guidance states that this means the agency 

must, among other things, advocate a conservation ethic in promoting the health, productivity, diversity, and beauty of 

forests and associated lands, listen to people and respond to their diverse needs in making decisions, and protect 

and manage the national forests and grasslands so that they best demonstrate the sustainable multiple-use 

management concept

1

See http://www.fs.fed.us/fsjobs/forestservice/mission.html

USFS and BLM both have a “multiple use, sustained yield” mission, meaning that while the agencies allow resource 

development on lands under their jurisdictions, they are also charged with ensuring that these uses are sustainable, 

and do not prevent public land from being used and enjoyed by future generations. 16 U.S.C. §531 (a) states that

“multiple use” means, “[t]he management of all the various...resources of the national forests so that they are utilized 

in the combination that will best meet the needs of the American people...that some land will be used for less than all 

of the resources...without impairment of the productivity of the land, with consideration being given to the relative 

values of the various resources, and not necessarily the combination of uses that will give the greatest dollar return or 

the greatest unit output”. 

Similarly, the Federal Land Policy and Management Act (FLPMA), which guides BLM, also supports consideration 

and protection of wildlands and wildlife habitat alongside consideration of energy development and other uses. 

Section 102 states, “that it is the policy of the United States that. . .the public lands be managed in a manner. . .that, 

where appropriate, will preserve and protect certain public lands in their natural condition. . .” 43 U.S.C. §1701(a)(8). 

Notably, BLM’s multiple use guidance is even more restrictive than USFS’s

2 . 

2 See 43 U.S.C. § 1712(c)(1); see also Section 302, 43 U.S.C. § 1732(a).

The agencies hold federal land in trust for future generations of the American public. While the agencies each have a 

multiple use mission, neither agency is charged with allowing every use on every acre. Quite the opposite; it is 

expected that the agencies will reserve some areas for conservation and recreation, and will close certain areas to 

development. This is in conformance with the multiple use mandate. Additionally, agencies are given enormous 

discretion in their decision making authority. Unless Congress directly tells the agency what to do in a specific 

scenario, or the agency acts with no rational basis for its decisions, the agency has full discretion to make decisions 

within its mission. We encourage SFNF to remember that it is not bound to allow geothermal leasing here by any law, 

rule, or guidance whatsoever.

Most importantly, we remain deeply concerned that making a geothermal leasing decision separately from the forest 

plan revision will result in SFNF’s revision objectives being overshadowed. For example, as part of the revision, the 

SFNF will conduct a mandatory inventory and evaluation of lands that may be suitable for inclusion in the National 

Wilderness Preservation System and will determine whether to recommend any of those lands for wilderness 

designation. 36 C.F.R. § 219.7(c)(2)(v); Forest Service Handbook 1909.12, ch. 70 (final directives on the process for 

identifying and evaluating those lands and determining whether to recommend them for wilderness designation). 

Amending the Forest Plan to permit geothermal leasing in areas that may be identified as roadless and eventually 

recommended for wilderness protection undermines that particular process, as well as the broader forest planning 

process designed to take a comprehensive look at the SFNF’s multiple resources and uses and determine how to 

balance and manage those uses. 

The National Environmental Policy Act (NEPA) and its accompanying guidance both from the Council on 

Environmental Quality (CEQ) and the USFS NEPA Manual, make it clear that public agencies should include those 

parties who are actually interested in the development of a decision document. Forest Service Manual 1909.15.10 § 

11.52 (4) states that USFS shall, “[e]ensure that the level of effort to inform and to involve the public is consistent with 

the scale and importance of the proposed action and the degree of public interest.” The Jemez Ranger District is one 

of the most visited USFS ranger districts in New Mexico, used extensively by hikers, backpackers, hunters, and 

anglers. The level of public interest is extremely high.
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Table B-25. Comments Related to Planning Regulations

Both USFS and BLM are directed by NEPA, agency guidance, and Executive Orders to make their decisions based 

on the best scientific information available. NEPA regulations require that in an environmental analysis, “[t]he 

information must be of high quality. Accurate scientific analysis, expert agency comments, and public scrutiny are 

essential to implementing NEPA.” 40 C.F.R. § 1500.1(b). Executive Order 13563 (2011), affirming Executive Order 

12866 (1993) states that, “[o]ur regulatory system...must be based on the best available science”. The 2012 Forest 

Planning Rule states that the best available scientific information must be used to inform the planning process and 

documentation of how science was used in the plan must be included (see FSH 1909.12). The Federal Land Policy 

and Management Act (FLPMA) requires that “the [BLM] public lands be managed in a manner that will protect the 

quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and 

archeological values.” 43 U.S.C. § 1701(a)(8). 

The analysis of alternatives under NEPA is the “heart” of an environmental impact statement (EIS). 40C.F.R. § 

1502.14. An agency must “[r]rigorously explore and objectively evaluate all reasonable alternatives” to a proposed 

action. Id. § 1502.14(a); see also 42 U.S.C. § 4332(2)(E) (agencies must “study, develop and describe appropriate 

alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning 

alternative uses of available resources”). “Without substantive, comparative environmental impact information 

regarding other possible courses of action, the ability of an EIS to inform agency deliberation and facilitate public 

involvement would be greatly degraded.” New Mexico ex rel. Richardson v. BLM, 565 F.3d 683, 708 (10th Cir. 2009). 

Consistent with NEPA’s basic policy objective to protect the environment, this includes more environmentally 

protective alternatives. 40 C.F.R. § 1500.2(e) (agencies must “[u]se the NEPA process to identify and assess 

reasonable alternatives to proposed actions that will avoid or minimize adverse effects of these actions upon the 

quality of the human environment”).

NEPA guidance documents require adequate analysis of site-specific impacts before leases may be offered, or as 

soon as potential impacts are “reasonably foreseeable,” as they are here. See 40 C.F.R.§ 1502.22. NEPA analyses 

must be completed “at the earliest practicable point” and “before any irretrievable commitment of resources” (40 CFR 

1501.2; Pennaco Energy, Inc. v. U.S. Dep’t of Interior, 377 F.3d 1147, 1160 (10th Cir. 2004)). The Tenth Circuit 

established that issuing a lease without a No Surface Occupancy (“NSO”) stipulation, for example, constitutes an 

irretrievable commitment of resources. New Mexico v. BLM, 565 F.3d. at 718. Here, most of the potentially leasable 

areas do not contain an NSO stipulation, and almost none of them contain NSO-without-exceptions. Surface 

disturbance will occur when any of the parcels are developed. 

The DEIS itself states on page 1-15 that, “The 2008 Geothermal PEIS noted that designating lands for geothermal 

leasing potential and amending a land use plan, in and of itself, does not cause any direct impacts, as defined by the 

Council on Environmental Quality(CEQ) regulations (40 CFR, Part1508.8 [a]). However, it is reasonable to foresee 

that on-the-ground impacts would occur if the BLM were to issue geothermal leases but that the impacts would not 

occur until the future”. Additionally, potential site-specific impacts of geothermal development are already reasonably 

foreseeable from the Geothermal PEIS, the EOI, the RFDS, and examples of past geothermal production in this area; 

otherwise, the Forest Service would not be able to suggest which stipulations would be appropriate on each area, 

which it has taken a great deal of time to determine.

NEPA prohibits an agency from being “predecisional”. In other words, NEPA requires that federal agencies take a 

“hard look” at the issues presented, the public’s interest, the best available science, and the potential environmental 

impacts of various alternatives, and to actually weigh that evidence when making a decision7 . An agency is not 

permitted to have made decisions internally before the NEPA process is complete

7 See Natural Resources Defense Council v. Morton, 458 F.2d 827, 838 (D.C. Cir., 1972), see also Question 1a, 

Forty

Most Asked Questions Concerning the CEQ’s National Environmental Policy Act, available at 

http://energy.gov/nepa/downloads/forty-most-asked-questions-concerning-ceqs-national-environmental-policyact

(NEPA “includes all reasonable alternatives, which must be rigorously explored and objectively evaluated”).
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-26. Comments that Propose a New Alternative, or Discuss Deficiencies in Existing Alternatives

This chapter fails to cover a sufficient number of alternatives to respond to the need as currently stated in Section 1.2 

of the DEIS. Even though in our opinion the need is incorrectly stated, there are other possible alternatives to meet 

the need that are not included. For example, to meet the stated need of providing for clean and renewable energy, a 

solar energy alternative, development of improved fuel cells, and mandated conservation actions, other alternatives 

should also be presented. This chapter also fails to address any alternatives that were considered but eliminated from 

detailed analysis. It should include a discussion of any such alternatives considered and the reason for their 

elimination. CEQ 1502.14 (a) states: “Rigorously explore and objectively evaluate all reasonable alternatives, and for 

alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.”

The description of the DEIS proposed action fails to describe what is reasonably expected to occur after the proposed 

action is implemented. The description of the proposed action should include the generic description of development 

under Alternative 4, or some reasonable development scenario based on other developed geothermal projects. 

Alternative 4 is in essence part of the proposed action. Identifying and designating the area under analysis as open to 

geothermal leasing is the lynchpin to allowing development to occur, and obscuring this fact by providing a separate 

development alternative could be seen as an attempt to hide the likely impact of the proposed action from the public 

and other agencies. 

Table 2-4 Comparison of Alternatives fails to provide specific information that is needed to adequately assess the 

difference in impacts between the alternatives. This chapter needs to be redone to provide specific and quantified 

impact differences between the alternatives. As presently prepared, it fails to provide any specifics and uses only 

subjective wording to compare the alternatives, which does not provide the information to the decision maker, the 

public, and other agencies to make an informed decision or recommendation. For example, for geologic resources 

under Alternative 2 (proposed action) the statement is made that “Impacts would be the same as those described 

under alternative 1.” However, there are no impacts described under Alternative 1, therefore this provides no useful 

information. Question 7 in CEQ’s Forty Questions, deals with this issue, stating: “Discussion of the environmental 

impacts of these alternatives should be limited to a concise descriptive summary of such impacts in a comparative 

form, including charts or tables, thus sharply defining the issues and providing a clear basis for choice among 

options.

Third, while there are No Surface Occupancy stipulations on much of the proposed area, most of those stipulations 

have “exceptions” wherein the operator or the state can decide that the surface may be disturbed. Will the Forest 

Service analyze an alternative where the outlined No Surface Occupancy stipulations contain no exceptions? 

Additionally, SFNF must not simply adopt the project proponent’s desires as its proposed alternative without thorough 

consideration of impacts through NEPA analysis and consideration of how those impacts would affect BLM’s 

obligations under FLPMA, which requires that: “[i]n managing the public lands the [Secretary of Interior] shall, by 

regulation or otherwise, take any action necessary to prevent unnecessary or undue degradation of the lands.” 43 

U.S.C. §1732(b) (emphasis added), along with SFNF’s obligations under the National Forest Management Act 

(NFMA). The project proponent has a completely different objective than SFNF. SFNF must evaluate all available 

information during this process, and create a proposed alternative that conforms to the USFS’s responsibility of 

sustainably holding land in trust for the use and enjoyment of future generations of the American public. We are 

perplexed as to why the proposed alternative is a leasing alternative when production in this area is completely 

impractical, 100% of the public’s comments have been opposed to leasing, and the project proponent itself did not 

comment on its own behalf. How did SFNF emerge with a leasing alternative proposed? 

SFNF analyzed two action alternatives, and one no-leasing alternative. The two action alternatives are remarkably 

similar and we do not believe this represents a “reasonable range”. For example, the percentage of the area closed to 

leasing under Alternative 2, the proposed action, is 19%. The percentage closed to leasing in Alternative 4, the 

“development alternative” is 17%. Similarly, the area open to leasing under NSO stipulations in Alternative 2 is 79%, 

while in Alternative 4, it is 73%. 

During scoping we suggested SFNF analyze an alternative which would just look at the area Ormat actually 

expressed interest in. SFNF declined to do so in the DEIS but we believe it would have been a reasonable 

alternative. 

Additionally, Alternative 4 in the DEIS would not comply with the Roadless Rule because it still allows for the 

possibility of surface development in Inventoried Roadless Areas (in this Alternative, IRA’s are not subject to an NSO 

without exception, modification, or waiver stipulation which means exceptions could occur). 
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-26. Comments that Propose a New Alternative, or Discuss Deficiencies in Existing Alternatives

One of the things we were most concerned about during the scoping period was inadequate stipulations on sensitive 

areas in the proposal. We would of course strongly prefer that none of this proposal area be commercially developed 

for energy production at all, as we do not believe any portion is really appropriate when riparian areas, wilderness 

quality areas, recreation, cultural resources, and endangered species habitat are all fully considered. However, we 

still reviewed the stipulations in case some portion of the proposal area was approved for leasing. During scoping we 

recommended changes to some of the stipulations including the use of a “No Surface Occupancy without Exceptions, 

Modifications, or Waivers” stipulation inside all IRA’s, near all water bodies, inside all critical habitat for endangered 

species, etc. 

As noted, the most restrictive stipulation available is not simply NSO, but NSO without exceptions, modifications, or 

waivers10 . This stipulation, unlike a simple NSO stipulation, would not allow BLM, or Industry, or the State of New 

Mexico to decide that surface disturbance is warranted. It is our experience that unless the NSO stipulation 

specifically states “without exceptions, etc”, surface disturbance does often occur. While there is no hard data, recent 

informal surveys have found that BLM grants exceptions or waivers to stipulations 90% of them time when asked (if 

exceptions and waivers are possible). SFNF should be aware of this and should ensure to the greatest extent 

possible that there is no surface disturbance anywhere near places which are potentially suitable for wilderness

designation, water bodies, places with high levels of recreation, sacred sites, and critical habitat. We appreciate the 

use of stronger language for portions of the proposal in the DEIS, including inside the IRA’s and within one mile of 

geothermal springs, but the proposed action still proposes very little of the area for NSO without exceptions (while 

there is a map in Appendix B of the DEIS (figure 2-2) of areas in Alternative 2 which are subject to an NSO 

stipulation, there is no map of areas which are subject to NSO without exceptions, modifications, or waivers. This 

would be helpful information that we request SFNF provide). We cannot overstate the importance of including this. It 

is unwise to pass the buck to BLM here and rely on another agency to manage SFNF surface in the way SFNF 

believes it should be. If SFNF is intent on allowing leasing at all here, which we reiterate we do not support, it must 

use its only opportunity to secure adequate protections on sensitive areas. If SFNF believes the surface of a 

particular parcel should never be altered in any circumstance, it must place an NSO without exceptions, 

modifications, or waivers stipulation on it.

10 See Appendix A, page A-41 at:

http://www.blm.gov/style/medialib/blm/co/programs/land_use_planning/rmp/white_river/documents/proposed_rmpa_-

_final.Par.40428.File.dat/08_WRFO_OG_RMPA-FEIS_ApA_LS_2015.pdf and Appendix H, page H-35 at: 

http://www.blm.gov/style/medialib/blm/ut/natural_resources/SageGrouse/FEIS_Appendices.Par.58727.File.dat/Appen

dixH_StipulationsAssociatedWithFluidMineralLeasing.pdf

Appendix B, which outlines stipulations and closings per alternative, is confusing. For example, on page B-3, there is 

a stipulation listed for State Engineer recognized water bodies and a one-mile area around them. It then states that 

surface occupancy is prohibited, and also that a modification or waiver could occur if studies show no reasonable 

risk. The next column has a “dot” in Alternative 2, the proposed alternative. Does that mean this entire stipulation only 

applies in Alternative 2, meaning surface disturbance on water bodies is allowed in Alternative 4? Similarly, later in 

the page, there is a stipulation for OSE-acknowledged drinking water sources, stating surface occupancy is not 

permitted but that an exception could be granted. This stipulation appears to ONLY apply to Alternative 4. Did SFNF 

really mean to suggest that surface disturbance on drinking water sources COULD occur in the proposed alternative? 

Or did it mean the “exception” would only apply to Alternative 4? 

Based on the maps at the DEIS meetings, it appeared that there were some areas which were closed without 

exceptions, modifications, or waivers in Alternative 2, which were only Controlled Surface Use in Alternative 4. This 

means that there should be some areas where certain stipulations apply to both “action alternatives” but where there 

are possible exceptions in Alternative 4 which are not possible in Alternative 2. The DEIS does not make this clear. 

SFNF acknowledged the high value of natural resources in the proposal area in its scoping documents when it chose 

to place an NSO stipulation on the vast majority of the proposal. We would like to note again that SFNF wanted to 

avoid surface disturbance for a variety of reasons including slope and erosion, springs, endangered species, IRAs, 

etc. The maps for the individual resources for which SFNF chose an NSO stipulation make it clear that there are 

multiple reasons on almost every portion of the proposal area to avoid surface disturbance. In other words, it is likely 

that an area SFNF deemed appropriate for an NSO stipulation for erosion reasons is ALSO an IRA, or also contains 

a spring, or also contains an endangered species. This means that any exception granted from an NSO stipulation 

would likely damage multiple resources at once. This underscores our certainty that the only appropriate stipulation 

for these areas is NSO without exceptions. If an NSO without exception stipulation was appropriately placed on all 

the areas currently proposed as simply NSO, very little of the proposal area remains open to development, 

heightening our suspicion that none of it is suitable for leasing at all. 

Require the geothermal leasing companies to provide plans for review before they drill of where they intend to locate 

the drill holes beneath the surface
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Table B-26. Comments that Propose a New Alternative, or Discuss Deficiencies in Existing Alternatives

After drilling is complete, require the companies to provide verifiable evidence of the final location of their drill holes 

beneath the surface

Most No Surface Occupancy Stipulations can be easily overridden by so-called exceptions either suggested by the 

operator or NM state agencies. Some No Surface Occupancy Stipulations can be overridden without asking for public 

input. In the present form, the format “No Surface Occupancy Stipulations allowing Exceptions” appears to be a 

rather weak tool for the SFNF when trying to protect the surface features for which the agency is responsible. Please 

consider not allowing any exceptions for No Surface Occupancy Stipulations to enable the SFNF to truly hold 

harmless the surface areas under the protection of the USFS.

Third, while there are No Surface Occupancy stipulations on much of the proposed area, most of those stipulations 

have “exceptions” wherein the operator or the state can decide that the surface may be disturbed. Will the Forest 

Service analyze an alternative where the outlined No Surface Occupancy stipulations contain no exceptions?

2. Despite significant public comment about the Forest Service’s requirement to inventory for areas with wilderness 

characteristics during large-scale planning, the DEIS does not address this concern. I disagree with the validity of the 

Forest Service’s rejection of a “wilderness-focused” alternative, saying it was outside the scope of the proposal. It 

certainly is not, as the decision to allow geothermal development would have a direct impact on the wilderness 

qualities of those lands

Despite significant public comment about the Forest Service’s requirement to inventory for areas with wilderness 

characteristics during large-scale planning, and New Mexico Wilderness Alliance’s belief that much of the project 

area qualifies, the DEIS does not address this concern. The Santa Fe National Forest rejected a “wilderness-focused”

alternative, saying it was outside the scope of the proposal.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-27. Comments Specific to the Purpose and Need for Action

The purpose and need section of the DEIS does not deal specifically with the proposed action. The purpose and 

need section is required by Council on Environmental Quality (CEQ) Regulations and sets the parameters of the 

proposed action and alternatives to be studied in detail. As presently written, the purpose and need section appears 

to deal with the purpose and need of the DEIS instead of purpose and need of the proposed action. The proposed 

action in this case as described in Section 1.13 and Section 2.3.2, is to open certain lands in the study area to 

geothermal leasing. This then is the actual purpose of the proposed action, rather than what is stated in Section 1.2: 

“The purpose of the action is to refine the analysis available in the PEIS in order to determine if certain lands in the 

SFNF may be made available for geothermal leasing. . . .” The need as currently written is too generic and does not 

answer the questions as to why (what is the basic problem or deficiency), why here (what is the problem, why is it 

occurring only here not somewhere else) and why now (why does the problem needs to be addressed now, what is 

the urgency). For example, is there a deficiency of energy in the immediate area or New Mexico that needs to be 

solved? 

We believe some clarification is necessary regarding the DEIS’s “Purpose and Need” Statement on page 1-2. SFNF 

states that the purpose is to determine which areas should be available for geothermal leasing, and that the needs 

are (1) to satisfy policy mandates which require a response to requests for energy development on public lands, and 

(2) to facilitate development of renewable energy

According to SFNF, the current forest plan does not address geothermal, but nominations for leasing could still occur 

on a case by case basis. While we understand that it is often efficient to look at an area as a whole, we do not 

understand why Alternative 1, continuing to consider leasing on a case by case basis, does not meet the purpose and 

need statement because SFNF could still analyze potential 

Additionally, on page 3-23, SFNF notes that only .0002% of New Mexico’s energy (69 megawatt hours) was from 

geothermal in 2013, and that full development of the Reasonable Foreseeable Development Scenario would still only 

account for about 1% of New Mexico’s energy. It is extremely doubtful this would go a long way towards fulfilling 

SFNF’s policy of facilitating renewable energy, and it definitely isn’t worth it. 

Union Geothermal, many years ago, tested all over the caldera and the Jemez Mountains, to see if geothermal wells 

would be a good way to provide warmth for them to use in operating a heating company. Now, I’m not a scientist and 

also am old, so can’t remember the words used in the decision NOT to spend any more money developing such a 

system, or any system whatsoever. The pulled out completely after much testing. They had several wells coring into 

the earth, went down very far, and found it was not feasible to continue. So my question is, do you think you can do 

more with the little bit Union Geothermal found than they could have? Otherwise, why spend money and time and 

people to find out something that has already been researched? Try asking Union for their records, and you might 

see that it is not a fiscally responsible thing to do.
Santa Fe National Forest Geothermal Leasing EIS, Summary of Public Comments

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Table B-28. Comments Regarding Jurisdiction or Authority

However, there seems to be some confusion, both within the agencies and the public, about what specific decision 

making roles BLM will have. We appreciate on page 1-8 of the DEIS that USFS notes BLM’s ability to “add any 

additional terms, conditions, or stipulations that it deems necessary and appropriate”, although we would have 

appreciated citations to BLM’s regulations for this assertion. Specifically, we still would appreciate more definitive 

information regarding the BLM’s future ability to place additional stipulations and Conditions of Approval (COA) on the 

surface use of SFNF land, as well as its ability to deny leases altogether. For example, if SFNF places a No Surface 

Occupancy (NSO) stipulation on a parcel, and it is nominated for leasing, will BLM be able to expand that stipulation 

to an NSO without exceptions if it determines at the leasing phase that SFNF’s stipulations were not sufficient to 

protect the surface, even when the surface is not BLM’s jurisdiction? 

As noted in our scoping comments, we remain confused and concerned about SFNF’s level of consultation with the 

BLM, which will be responsible for all actual lease sales and drilling permits, the Fish and Wildlife Service (FWS), 

which should already have been consulted on endangered species, as well as the Park Service (NPS) which now 

manages the adjacent Valles Caldera National Preserve. USFS Manual 1909 notes that the, “[r]responsible official 

shall identify and contact other federal, state, or local agencies with an interest in the action” (see §11.3, emphasis 

added). It also states that the Lead Agency shall request the participation of each cooperating agency in the NEPA 

process at the earliest possible time, which does not seem to have happened according to the scoping report

Thompson Ridge is a private development surrounded by National forest in the Middle Unit of the DEIS. It is in a zone 

of high geothermal potential and No Surface Occupancy (NSO).

a. Does the BLM control the subsurface mineral and geothermal rights under private lands in the area?

b. What prevents geothermal development companies from purchasing or leasing areas within Thompson Ridge to 

access the NSO land?

I am especially concerned and would like specific information about USFS (and BLM) capacity and funding to monitor 

(DEIS 2.2.2), regulate, or enforce lease stipulations, conditions of approval, Best Management Practices, and 

procedures necessary to ensure impacts are minimized or avoided altogether.
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