Appendix 4: Consideration of / Response to...

Environmental Assessment North Kaibab Ranger District Travel Management Project

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Appendix 4: Consideration of / Response to Comments

This appendix was prepared to document each comment submission and the manner in which those

questions, concerns or suggestions were considered or incorporated into the North Kaibab Ranger District

Travel Management Project Environmental Assessment (EA).

Introduction In April, 2011, the North Kaibab Ranger District began the official 30-day comment period for the Travel

Management Project Environmental Assessment (EA). A legal notice was published in the Arizona Daily

Sun on April 25, 2011, inviting public comment on the Proposed Action and EA. The comment period

provided an opportunity for the public to provide early and meaningful participation on the proposed

action prior to a decision being made by the Responsible Official. Those who provided comments during

the comment period (see Tables 4-1, 4-2, 4-3, 4-4 & 4-5) are eligible to appeal the decision pursuant to 36

CFR part 215 regulations.

During the 30-day comment period, the Forest Service held public meetings in Page, AZ, Colorado City,

AZ, Kanab, UT, and Fredonia, AZ, to inform the public of the project and the EA as well as to accept

questions and comments from the public.

The District received 6,055 comment letters on the project from various interested parties including local

residents, user groups (e.g., motorized trail riders) and state and federal agencies. The vast majority of the

comments (6.037) were submitted via form letters from two specific web-sites (i.e., the Center for

Biological Diversity and the Sierra Club) via email to the District’s NEPA comment-response in-box. Of

these 6,037 form letters, 206 were received after the comment period ended.

Table 4-1: Total Comments Received during Preliminary EA 30-Day Comment Period

Comment Documents Requiring Individual Response 17

Form Letter Submissions: 5652 CBD Form Letters (Letter #

18) &. 79 Sierra Club Form Letters (Letter # 19) 5,731

Letters Not Requiring Individual Response or variations of

Form Letters; 92 variations of CBD Form Letter &

8 variations of Sierra Club Form letter. 100

Letters or Comments Received After Deadline (May 25,

2012 or later); 206 Form Letters and 1 unique Letter. 207

TOTAL 6,055

Organization of this Appendix This appendix is organized five sections to show how individual comments and concerns were addressed

in the preparation of the EA:

The first section (Introduction) describes the public comment process. The second section (this section) describes the organization of Appendix 4. The third section (Index of Commenters) contains tables identifying commenters and how they

participated in the process. The fourth section (Forest Service Consideration of / Response to Comments) contains the Forest

Service’s response to comments.

The fifth section (Copies of Comment Documents) contains scanned images of comment

documents received during the public comment period.


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The sixth section (Form Letter Submission Summary) contains tables identifying people who

submitted form letters through either the CBD or Sierra Club websites.

Table 4-2 (under Index of Commenters) lists public meetings/dates and number of Attendees during the

Preliminary EA 30-day public comment period (public meetings held between April 25 – May 25, 2012).

Table 4-3 lists the 19 letters, emails and comment forms that were submitted, analyzed and responded to

in detail and provides the document number for reference to the response table (Table 4-4). Comments

received or recorded (i.e., emails, facsimiles, letters, phone call records, comment forms, etc.), during the

official 30-day public review and comment period for the Preliminary EA were assigned a comment

number. See pages 173 to 252 for copies of the comment letters. The first number represents the letter

number and the second number represents the individual comment within that letter that required response

(for example, comment number 3-6 would be the sixth comment the FS responded to within the third

letter). Table 4-4 lists the Forest Service Consideration of / Response to Comments to the Preliminary

EA.

Table 4-5 lists the names of 5,831 individuals who submitted comment through a copy of the form letter.

In order to reduce the size of this comment response document, these comment documents were not

individually scanned. Instead, an example copy of the form letter was included along with listing of

individuals (names) and dates of submission via e-mail to the FS.

Comment documents that were received after the May 25, 2011 comment period deadline have been

documented and are available in the project file. Copies of the Comment documents are included in this

appendix (pages 173 to 252). The last section in Appendix 4 (pages 253 to 290) is a summary of the form

letter submissions regarding dates and names of those people submitting the form letters.

Index of Commenters

Table 4-2 below is a listing of the public who attended the four (4) public meetings held during the

Preliminary EA 30-day public comment period April 25 – May 25, 2012.

Table 4-2: List of Public Meetings & Attendees (See project record for sign-in sheets)

Attendees at Public Meetings held for Comment Period

Monday, April 25, 2012: Page Public Library, 479 South Lake Powell Boulevard, Page, AZ.

Harvey Schoppmann Valerie Schoppmann

Wednesday, April 27, 2012: Mojave Community College, 480 South Central Street, Colorado City, AZ.

(No public participants showed up at this meeting)

Thursday, April 28, 2012: Kanab Middle School, 690 South Cowboy Way, in Kanab, UT.

Gail Dvorak Tony Wright Karen Kramer

Chris Dvorak Linda Wright Don Kramer

Kim Creemla Bill May Jim Matson

Friday, April 29, 2012: North Kaibab Ranger District office, 430 South Main Street, Fredonia, AZ.

Steven Winward Danny Budtra Lisa & Kelly Dindlay

Rose Marie Olsen Donald C Olsen Don and Shana Cox


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The following table can be used to identify those comments that required a detailed response. (Each

commenter (see organizations or names column in table 4-3) was assigned a specific letter number, and

the comments were reviewed to facilitate responses to each comment (by comment number). Note that

statements pertaining to the NKRD or motorized activities in general, which may be statements of fact or

opinion, were treated as statements. Comments are statements that pertain directly to the Proposed

Action, Purpose and Need, or the analysis presented in the Preliminary EA during the 30-day public

review and comment period.

Table 4-3: List of Comment Submission Requiring Detailed Consideration or Response

Individual Comments with Detailed Consideration or Response(s)

Organization / Name Letter

Number

Number of

Comments

Arizona Game and Fish Dept. / Ron Sieg 1 12

(CBD et al): Center for Biological Diversity, Grand Canyon Wildlands

Council, The Sierra Club, The Wilderness Society, Great Old broads for

Wilderness, and White Mountain Conservation League 2 86

Arizona Department of Transportation / Kurtis Harris, PE 3 4

Bill May 4 1

Chris & Gail Dvorak 5 2

Donald Olsen 6 1

Five County Assoc. of Governments / Kenneth Sizemore 7 3

Ashner Enterprises / Jon Asher 8 2

The National Humane Education Society / Ginnie Maurer 9 4

Richard Budd 10 2

U.S. DOI – U.S. Fish & Wildlife Service / Steven Spangle 11 7

Gwendolyn Gaustad 12 1

Donald Cox 13 1

Shawna Cox 14 3

Serretta Foreman 15 3

John Jordan 16 2

Antone Wright 17 3

CBD Website Form Letter 18 6

Sierra Club Website Form Letter 19 2


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Forest Service Consideration of / Response to Comments

Table 4-4 Forest Service Consideration of / Response to Comments

Comment Number

Forest Service Consideration of / Response to Comment

1-1

All alternatives analyzed in detail (Chapter 2, Alternatives Analyzed in Detail) are

evaluated on an equal basis. The final decision will be based on the analysis contained in

the EA, documentation provided in the project record, and the consideration of public input.

The main difference between Alternative 2 and 4 is that Alternative 4 allows for motorized

big game retrieval of Mule deer and Alternative 2 does not. See Table 5 of EA.

1-2

GMU 12A contains a very high density of cultural resource sites. Cultural resources are

non-renewable resources and are federally protected under the National Historic

Preservation Act and other statutes. Adopting a rule of “one trip in” and “under dry

conditions” will not eliminate potential impacts to heritage resource sites from motorized

cross country travel in areas with fragile soils or surface architectural features or artifacts

easily crushed by vehicles. While wet conditions contribute to soil erosion and vegetation

damage, sandy and fine clay areas and those with crypto biotic soils can be damaged by

cross country motorized travel even under dry conditions. These areas can be found in the

pinyon-juniper zone in GMU 12, in areas known to have a high density of sites. This rule

alone will not mitigate the potential damage to cultural resource sites by motorized game

retrieval.

1-3

AGFD notes that because of human pressure in the fall, deer move increasingly into

roadless areas. The Department is concerned that not allowing motorized game retrieval

will potentially discourage hunters from hunting in these areas, possibly causing increased

resource damage by allowing the deer population to grow. This in turn would focus hunters

on roaded areas creating more hunters and vehicle impacts in those areas.

AGFD was presented with maps of proposed road closures during the initial planning effort.

Staff indicated that the proposed road closures would serve as a positive effect for deer

given the existing high road density on the NKRD, by providing more roadless areas for

deer, taking hunting pressure off the species and providing for better cover.

Concentrating hunters in roaded areas with designated camp sites will not increase vehicle

impacts in those areas if hunters comply with off road travel restrictions. Rather, it will

reduce damage from the existing condition because the activity will be limited to existing

roads and campsites which have already been established. Over 700 dispersed camping

sites are available throughout the NKRD. This should present ample space to accommodate

camping and associated vehicles. New spaces can be designated, as suggested by AGFD, if

monitoring indicates a need. The absence of motorized big game retrieval does not affect

the number of roads or campsites available; they remain the same under Alternative 2 and 4.

It should be noted that over 90% of the District is currently within 1 mile of a road. The

proposed road closures will not dramatically alter that situation allowing for ample room for

hunters to disperse.

AGFD states that deer currently move into roadless areas in the fall as a result of hunting

pressure and hunters pursue them in those locations. It is suggested that hunters might

avoid those areas if they are not allowed to retrieve downed animals by vehicle. If hunters


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Comment Number


1-3 (con’t)

are hunting in roadless areas using an OHV, they will no longer be permitted to do so

regardless of motorized game retrieval restrictions under all action alternatives. Hunters will

be required to access those areas on foot to kill the deer. Thus it follows that they should be

able to pack their animals out or arrange for assistance. The statement reinforces that cross

country travel currently becomes a greater risk to natural and cultural resources during

hunting season, because presumably hunters are using OHV’s in roadless areas to pursue,

kill and retrieve their deer. GMU 12 contains a high concentration of cultural resource

sites. Many of these sites are located on flat ridges or drainages and in fragile soils. These

areas are often the most accessible routes for OHV use.

The AGFD suggest that restricting motorized game retrieval could hypothetically cause a

major increase in deer and habitat degradation. As noted, the majority of the District is

currently within 1 mile of a road and will remain so under the proposed action.

Consequently, there are few larger roadless areas for game to retreat to on the NKRD.

Many National Forests in the west, with a higher percentage of non-wilderness roadless

areas, do not permit cross country motorized game retrieval. This policy has not limited

interest in hunting. It is unlikely that a loss of interest in hunting or habitat degradation

would occur as a result of this policy.

With regards to the California condor, the voluntary lead reduction program implemented

by the AGFD on the NKRD has been very successful. Most recent data from the effort

suggests that 75% of the hunters are using lead free ammunition, while 15% of the

remaining hunters are turning in their gut piles to the agency, for a 90% success rate.

Compliance with the program appears to be increasing annually, suggesting that the AGFD

social behavior modification program is working to address this issue. Additionally, recent

deaths of condors attributed to lead poisoning appear to be occurring in condors found in

Utah rather than the NKRD. Condors are now spending limited time on the NKRD (Kathy

Sullivan, AGFD, FS/AGFD coordination meeting on April 4, 2012).

1-4 See response 1-3.

1-5

Motor vehicle use that is specifically authorized under a written authorization issued under

federal law and/or regulations is exempted from the motor vehicle designations shown on

the MVUM (see 36 CFR 212.51(a)(8)). This includes permitted activities such as grazing

and fuelwood gathering. These actions are analyzed under separate NEPA documents.

There is no requirement in the Rule to allow for MBGR; it is at the discretion of the

Responsible Official. However, because the purpose of this project is to improve the

management of motorized vehicle use on the District in accordance with the Rule and

because the District recognizes the need to provide opportunities for the motorized retrieval

of legally taken big game animals, the District has considered allowing limited MBGR

opportunities in the Travel Management Project.


1-7

GMU 12A contains a very high density of cultural resource sites. Cultural resources are

non-renewable resources and are federally protected under the National Historic

Preservation Act and other statutes. Adopting a rule of “one trip in” and “under dry

conditions” will not eliminate potential impacts to heritage resource sites from motorized

cross country travel in areas with fragile soils or surface architectural features or artifacts


147

Comment Number


easily crushed by vehicles. While wet conditions contribute to soil erosion and vegetation

damage, sandy and fine clay areas and those with crypto biotic soils can be damaged by

cross country motorized travel even under dry conditions. These areas can be found in the

pinyon-juniper zone in GMU 12, in areas known to have a high density of sites. This rule

alone will not mitigate the potential damage to cultural resource sites by motorized game

retrieval.

1-8

The intent of proposing the 1 mile restriction to MBGR (which we are required to specify)

is to reduce the potential for spoilage and waste by providing reasonable access to downed

animals that are difficult to move long distances.

1-9

Wood cutters will not be permitted to travel off road in the pinyon-juniper zone under all

the action alternatives. This comprises a significant portion of GMU 12A. If similar rules

were in place for hunters, motorized deer retrieval would still be excluded from the pinyon-

juniper zone.

1-10

Thank you for your recommendations. Route markers are used to identify system roads or

trails. They provide information for the safety, enjoyment, and convenience of National

Forest visitors, users, cooperators, and employees (FSM 7160.2). Forest users will be able

to use route markers and information provided on the MVUM to determine whether the

road is open for public use. Public use of roads not shown on Motor Vehicle Use Maps is

prohibited (36 CFR 261.13); closed roads and unauthorized roads will not be shown on the

MVUM.

1-11 Thank you for your comment.

1-12

Thank you for your offer of assistance. The proposed corridors and additional spur routes

were evaluated with peak hunting season in mind. Should monitoring indicate that

additional camping opportunities are necessary, we will consider any future changes or

proposals under a separate environmental analysis.

2-1

Thank you for your support of the proposed action which was analyzed in detail in the EA

as Alternative 2. In accordance with law, regulation and policy, the District developed a

range of alternatives (EA, Chapter 2). In addition to the No-Action Alternative (Alternative

1), three action alternatives were analyzed in detail that would meet the Purpose and Need

for Action and address one or more issues. The No-Action alternative would continue

current management, while Alternatives 2, 3 and 4 would limit motorized travel. The

environmental consequences of implementing these alternatives are discussed in Chapter 3

of the EA. All alternatives analyzed in detail are evaluated on an equal basis. The best

information available was used to discuss the affected environment and environmental

consequences of the alternatives and the “best available science” was considered throughout

the discussions. The final decision will be based on the analysis contained in the EA,

documentation provided in the project record, and the consideration of public input.

2-2 We believe the Proposed Action is not deficient. It was developed to meet the Purpose and

Need for Action described in Chapter 1 of the EA. See FS Responses 2-3 to 2-86.

2-3 We believe the EA is not deficient because it complies CEQ Regulations (40 CFR 1500-

1508), Forest Service NEPA Regulations (36 CFR 220) and follows Forest Service Manual


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Comment Number


(FSM 1950) and Handbook (FSH 1909.15) direction. The CEQ regulations provide that an

EA shall be prepared for proposals that are not categorically excluded from documentation

and for which the need of an EIS has not been determined (36 CFR 220.7(a)). No

significant negative effects are anticipated in regards to the implementation of this project

and anticipated adverse effects are expected to be minor (see Chapter 3 of the EA). A

significance finding of the analysis of the EA will be presented as part of the Decision.

2-4

The cumulative effects of implementing Alternatives 1-4 are discussed in Chapter 3 of the

EA. The cumulative effects analyses of the EA were temporally and spatially bounded, and

as appropriate, considered the effects from actions on adjacent lands. The North Kaibab

Ranger District is located entirely within AGFD GMU 12A; it does not share a boundary

with any other District on the Kaibab NF nor does is share a boundary with the Coconino

NF.

Appendix 2 provides a partial listing of past, present, and reasonably foreseeable actions

considered in the cumulative effects analysis. Alternative 1 – the No-Action Alternative

serves as a baseline for comparison of the other alternatives; analysis of it took into

consideration the existing system, the continued allowance of cross-country travel and the

continued use/existence of unauthorized routes.

2-5 See FS response 2-4; Also see discussion or consideration of motorized big game retrieval

(MBGR) in responses: 1-5, 1-8, 2-43, 2-44, 2-46, 2-64, 2-66, 2-71, 11-1, 11-2, and 11-5.

2-6 See FS response 2-4; Also see discussion or consideration of motorized big game retrieval

(MBGR) in responses: 1-5, 1-8, 2-43, 2-44, 2-46, 2-64, 2-66, 2-71, 11-1, 11-2, and 11-5.

2-7

The environmental consequences of implementing Alternatives 1-4 on unique

characteristics of the North Kaibab Ranger District such as historic or cultural resources,

sensitive soils, non-native invasive species, wilderness areas or ecologically critical areas

are described in Chapter 3 of the EA.

See FS Response 2-4, above. The analysis of cumulative effects begins with consideration

of the direct and indirect effects on the environment that are expected or likely to result

from each alternative being analyzed in the EA. In order for an effect to be considered

cumulative, it must cross in both space and time (i.e., spatially and temporally) with the

proposed action. The EA is specific to the NKRD and its transportation system.

2-8

“An EA may be prepared in any format useful to facilitate planning, decision making, and

public disclosure as long as the requirements of paragraph (b) are met” (36 CFR 220.7(a)).

In preparing the Final EA, we complied with CEQ Regulations (40 CFR 1500-1508), Forest

Service NEPA Regulations (36 CFR 220) and followed Forest Service Manual (FSM 1950)

and Handbook (FSH 1909.15) direction. The environmental consequences of implementing

these alternatives are discussed in Chapter 3 of the EA. Scoping for the North Kaibab

Travel Management project has been extensive and has continued over a multiple years. For

details regarding public involvement, see the Public Involvement Section of Chapter 1, as

well as the discussion presented in this appendix.

2-9 The designation of a system of routes and areas for motorized use in conformance with the

Travel Management Rule is considered to be in full compliance with previous Executive


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Comment Number


Orders issued on the subject of off-road use. Considering that any action alternative would

prohibit off road use on over 520,000 acres on the NKRD (except for areas designated for

motorized big game retrieval and designated dispersed camping), it is clear that the North

Kaibab District’s plans to implement the Travel Management Rule are going to largely

reduce impacts to other Forest resources. Each route discussed in your comments and others

were specifically considered for designation or not in one or more alternatives. As a result,

only those routes that provided access or recreational opportunities while minimizing

impacts to Forest resources were included for designation in one or more alternatives.

2-10 See FS response 2-7. [Note: the North Rim of the Grand Canyon National Park is only

open on a seasonal basis. Park access is usually closed November to mid-May ]

2-11

The commenter is correct in that elements of the proposed action have generated

controversy. However, the commenter misinterprets 36 CFR 1508.27(b)(4) which states

“The degree to which the effects on the quality of the human environment are likely to be

highly controversial” (emphasis added). There is no substantial scientific controversy over

the effects as described in Chapter 3 of the EA.

2-12

Except for the amendment to prohibit cross-country travel, the Forest Service does not

agree that implementing this project would create a precedent that could affect future

planning. Travel management decisions are made at the project level and must be consistent

with the applicable land management plan (FSM 7712.2), in this case the 1988 Kaibab

National Forest Land Management Plan, as amended.

Making changes to the designated system of roads based on the need to reduce adverse

resource impacts does not establish a precedent for future actions or represent a decision in

principle about a future consideration. For instance, the Forest Plan does not currently

establish road-density standards and any discussion of road density in the EA was used to

discuss/describe anticipated effects and was used to compare alternatives. In no way does

the use of road density as an indicator or measure of effect in this EA establish that measure

as a standard to be met in future management projects. Additionally, site-specific travel

management decisions will be made with future planning efforts to achieve the desired

conditions prescribed in the Plan.

Procedures are in place to annually revise the MVUM to accommodate changes to the

designated system as a result of future management decisions and/or changing conditions.

Any future actions that alter the designated road system, alter motorized big game retrieval

restrictions or affect motorized dispersed camping opportunities will have to be evaluated

under the National Environmental Policy Act (NEPA).

2-13

We believe the Final EA is not deficient because it complies with CEQ Regulations (40

CFR 1500-1508), Forest Service NEPA Regulations (36 CFR 220) and follows Forest

Service Manual (FSM 1950) and Handbook (FSH 1909.15) direction. The CEQ regulations

provide that an EA shall be prepared for proposals that are not categorically excluded from

documentation and for which the need of an EIS has not been determined (36 CFR

220.7(a)). No significant negative effects are anticipated in regards to the implementation of

this project and anticipated adverse effects are expected to be minor (see Chapter 3 of the

EA). A significance finding will be made as part of the Decision.


150

Comment Number


For cumulative effects discussion please defer to FS Response to 2-4 above.

2-14 See FS response to 1-7, 2-7, and 2-31.

2-15

Both beneficial and adverse effects were considered in the EA (Chapter 3). Eliminating

cross-country travel for the vast majority of forest visitors will likely have a significantly

positive effect on forest resources and forest visitors. No significant negative effects are

anticipated in regards to the implementation of this project and anticipated adverse effects

are expected to be minor (see Chapter 3 of the EA). A significance finding will be made as

part of the decision.

2-16

“An EA may be prepared in any format useful to facilitate planning, decision-making, and

public disclosure as long as the requirements of paragraph (b) are met” (36 CFR 220.7(a)).

In preparing the Final EA, we complied with CEQ Regulations (40 CFR 1500-1508), Forest

Service NEPA Regulations (36 CFR 220) and followed Forest Service Manual (FSM 1950)

and Handbook (FSH 1909.15) direction. The environmental consequences of implementing

these alternatives are discussed in Chapter 3 of the EA. Scoping for the North Kaibab

Travel Management project has been extensive and has continued over multiple years. See

the Public Involvement Section in Chapter 1 of the EA.

2-17

The purpose of TMR is not to re-designate or re-analyze the existing system of roads, trails,

and areas and therefore there is no requirement to analyze the entire system. Alternative 1

or the No Action alternative is the existing system and is the baseline used to measure what

the potential change or impacts the other alternative would create or have. The proposed

action (Alternative 2) and Alternatives 3 & 4 propose changes in use to the District’s

existing transportation system. An EA provides adequate analysis in the proposed changes

in use to this system. Also see FS responses to 2-3, 2-13, 2-38, and 2-41. The purpose of

an EA is to determine if an EIS is necessary. If the responsible official determines that an

EIS is not warranted then the Final EA will be accompanied by a Finding of No Significant

Impact (FONSI).

2-18

Chapter 3 of the EA considers the four items or products brought up by the commenter.

Additionally refer to Table 4 within the “Comparison of Alternatives Analyzed in Detail”

section of the EA. Table 5 of the EA compares and addresses key issues of the alternatives.

Table 6 of the EA presents a summary of effects on resources by alternative. See the Forest

Service Final - Travel Analysis Process Report, North Kaibab Ranger District, J. Booth, M.

Williams, signed January 2010. (Forest Service TAP – January 2010)

For cumulative effects discussion please defer to FS Responses to 2-4, 2-17, and 2-50.

2-19

Specific impacts, including site-specific effects analyses, are presented throughout Chapter

3 of the EA. Also see responses to 2-17, 2-31, 2-35, and 11-7 below. A thorough analysis is

presented in the EA.

2-20

Per the Comments and Responses to the Forest Service Directives to the Travel

Management Rule (page 68268) “reviewing and inventorying all roads, trails, and areas

without regard to prior travel management decisions and travel plans would be

unproductive, inefficient, counter to the purposes of this final rule, and disrespectful of

public involvement in past decision making. … Nothing in this final rule requires


151

Comment Number


reconsideration of any previous administrative decisions that allow, restrict, or prohibit

motor vehicle use on NFS roads and NFS trails or in areas on NFS lands and that were

made under other authorities, including decisions made in land management plans and

travel plans.” And on page 28269, “This final rule does not require responsible officials to

reconsider decisions authorizing motor vehicle use on NFS roads and NFS trails” However,

the analysis of Alternative 1 (No Action) describes the effects of maintaining the current

management direction in regards to motorized vehicle use on the NKRD (see Section 2.3

and Chapter 3), which includes the official system of roads built with NEPA in the past and

unauthorized routes on the ground.

2-21

See FS Responses 2-4 and 2-7. The Grand Canyon separates the NKRD from all other

Districts of the Kaibab National Forest, as well as the Coconino National Forest and other

National Forests within the southwest region, thus there is no spatial overlap regarding the

transportation system.

2-22

The North Kaibab District acknowledges the impacts of climate change on forest resources,

particularly in regards to drought severity and vegetation change.

Specialists incorporated climate change into their effects analysis for watersheds, aquatic

species, and wildlife under each alternative, and focused on potential cumulative impacts of

each in the context of climate change. The EA includes a summary of each analysis;

specialist reports are available upon request and online. In general, the action alternatives

were found to slightly counteract the effects of climate change by providing slightly larger

areas of refuge for wildlife by decreasing cross-country travel and fragmentation by roads,

and by designating fewer roads within watersheds.

2-23

The Rule allows that the Responsible Official may permit the limited use of motor vehicles

within a specified distance of certain designated routes, and if appropriate, within specified

time periods solely for the purposes of…“retrieval of a downed big game animal by an

individual who has legally taken that animal” (36 CFR 212.51 (b)). This allowance is

optional and at the discretion of the Responsible Official. It applies only to the retrieval of a

downed animal; motorized off road travel for other hunting activities such as scouting or

accessing a favorite hunting site is prohibited by the Rule. Any game retrieval that is not

specifically allowed in the Decision would require non-motorized methods.

2-24

Permanent roads commit areas incorporated into road prisms to non-productive status for

the foreseeable future (i.e., at least 50 years). The Soils, Watershed, and Air Quality

Specialist’s Report for the North Kaibab Ranger District Travel Management Project

Environmental Assessment provides information related to the analysis of the existing road

system on the North Kaibab Ranger District as it relates to soils, watersheds, and air quality

and the No-Action Alternative, Proposed Action, and other Action Alternatives.

2-25

The analysis of soils, watersheds and air quality for this project is specific to

implementation of Travel Management Rule (36 CFR 212, Subpart B, Designation of

Roads, Trails, and Areas for Motor Vehicle Use) on the North Kaibab Ranger District. The

Rule requires each national forest or ranger District to designate those roads, trails, and

areas open to motor vehicles. It does not require comparison of the impacts of areas open to

motor vehicles to a roadless scenario.


152

Comment Number


2-26

Direct, indirect, and cumulative environmental effects of the No-Action Alternative,

Proposed Action, and other Action Alternatives resulting from implementation of Travel

Management Rule on the North Kaibab Ranger District are adequately considered and

disclosed in the Soils, Watershed, and Air Quality Section of the EA and the corresponding

specialist report (see EA, pp. 45-63; & KNF-NKRD Travel Management Project

Environmental Assessment Final Soils, Watershed, and Air Quality Specialist Report, pp.

44-55).

2-27

We understand that the designation of dispersed camping corridors may result in impacts

from concentrated use in these corridors. Yet the designation of dispersed camping

corridors to allow motorized use for the purpose of camping within a fixed distance from

designated routes is specifically authorized in the Travel Management Rule under

§212.51(b). Furthermore, the District considered not allowing dispersed camping in fixed

corridors, but this alternative was eliminated from detailed study (see the Record of

Decision for more detail). Lastly, we specifically analyzed and disclosed the impact of

concentrated use from designation of motorized dispersed camping corridors on vegetation

cover and other resources in the EA for both Alternatives 2 and 4. We understand that in

some areas, such as the Coronado, similar designations may have resulted in impacts. Yet,

what has occurred on the Coronado is not necessarily true of what may occur on the Kaibab

as the two forests contain different vegetation types, are used by different amounts of Forest

visitors, and have different areas open to motorized dispersed camping.

2-28

Four alternatives were developed in detail. Each “action alternative” (i.e. 2-4) was designed

to be a viable alternative. An additional alternative was considered but dropped from

detailed study; it is presented in Alternative Considered but Eliminated from Detail Study in

Chapter 2 with the reasons for not analyzing it in detail. The alternatives presented in

Alternatives Analyzed in Detail and in Alternative Considered but Eliminated from Detail

Study in Chapter 2 represent a range of reasonable alternatives, given the Purpose and Need

and Key Issues for the proposed action.

2-29

The Wildlife specialist report discusses several studies that identify noise from motorized

use as causing disturbance to wildlife, especially nesting birds. Disturbance from motorized

use was identified as one of the direct impacts of motorized use in the wildlife effects

analysis. Thus, disturbance from motorized noise to wildlife was one of the criteria

considered in areas where sensitive wildlife habitat is present.

The Forest reviewed and performed tests with the SPREAD GIS spatial model suggested by

the Center for Biological Diversity. This model is still in the development phases, but does

provide some basic information on how noise would propagate from a single point on the

ground. This model was not used primarily because the model lacks one very important

function, which is an indicator to identify where noise from motorized vehicles would be

inappropriate and impact users versus areas where noise from motorized use would have

little or no impact on Forest users. Instead the Forest used a much more practical approach,

which is to model the change in road use in areas designated for a non-motorized

experience.

2-30 Gavin, S.D., P. E. Komers. 2006. Do pronghorn (Antilocapra americana) perceive roads as


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a predation risk? Canadian Journal of Zoology, Volume 84, Number 12, pp. 1775-1780(6)

2-31

Dispersed Camping

Dispersed camping has long been associated with inadvertent impacts to heritage resource

sites. Modern people often chose the same camp locations as prehistoric and historic

peoples for similar reasons (accessibility, proximity to resources, protection from the

elements and aesthetics). Re-use can result in impacts to archaeological resources. The

reports referenced by CBD in regards to camping impacts to archaeological sites were

studies completed on areas of the Tusayan Ranger District (south Kaibab NF). While these

studies are applicable to the North Kaibab in terms of general human land use patterns, the

North Kaibab RD completed site specific cultural resource inventories addressing sites on

the North Kaibab as described in the NKRD Methodology for Applying Protocols for

Section 106 Compliance section of the EA. The results of the specific inventories are

summarized in the specialist report and described in detail in Betenson 2009 and 2011 and

Reid 2011-cultural resource report in progress.

The Uphus et.al, 2006 study cited by CBD emphasized using GIS spatial modeling as a tool

to quantify the occurrence of inadvertent vandalism to archaeological sites from camping,

hunting, and woodcutting activities. Not surprisingly, the study found a strong correlation

between dispersed camping and proximity to roads, as well as a strong correlation between

modern camp sites and cultural resource sites. The study also noted that a high percentage

of the sites had experienced inadvertent damage from camping or associated resource

procurement activities. The Sullivan et.al, 2003 article referenced by CBD was the basis

for the Uphus et.al, 2006 article. While this research has applicability to the North Kaibab,

specifically in regards to the types of impacts to archaeological resources that are related to

dispersed camping and resource procurement activities such as fuel wood gathering and

hunting, the North Kaibab inventory approach cited in the EA and specialist report focused

directly on sites located on the North Kaibab, forming the basis of the environmental

analysis.

To elaborate, between 2009-2011 the North Kaibab Ranger District recorded and monitored

hundreds of sites on the District while completing corridor inventories and inventorying

user generated spur roads that accessed areas used for recreational opportunities: largely

dispersed camping. The types of impacts to sites from dispersed camping most frequently

encountered included construction of fire pits on sites, artifact collecting (as noted by

collector piles), removal of pueblo architectural stone for use in fire rings, trash, temporary

outhouse depressions, as well as denuded vegetation, surface compaction, and erosion

(small gullies or deflated surfaces) created by vehicle tracks. This is similar to the findings

of the Uphus et.al. 2006 study. Some of these impacts are directly associated with vehicle

use (crushing of features and artifacts, soil erosion or compaction), while others can occur

regardless of whether the camper accessed the site on foot or by vehicle.

These results were considered during the analysis process and were incorporated into the

decision making process. As explained in the EA, corridor camping was found

inappropriate in the pinyon-juniper zone given high sites densities and the potential for the

accretion of adverse effects to sites from cross country motorized travel. To accommodate

recreational use of the area by the public, a concerted effort was made to locate spur roads

leading to recreational opportunities areas that had no heritage resource site issues. This


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served to eliminate future vehicular damage to sites and focus motorized camping in

locations that lacked site conflicts. During the inventory process, spur roads that crossed

sites or had direct access to sites were dropped from consideration, resulting in the

exclusion of areas currently used for dispersed motorized camping due to conflicts with

cultural resource sites, while providing for the inclusions of over 700 spurs in Alternatives

2, 3, and 4 that provide access for dispersed camping with no heritage resource conflicts.

While inclusion of these spurs has not been questioned by CBD, it should be noted that it

was precisely because of these observations that the District chose to limit dispersed

motorized camping in Alternatives 2 and 4 to select corridors within the ponderosa pine

zone, in locations that had been completely surveyed for cultural resource sites with low

site densities. In locations within these corridors, where sites susceptible to vehicle damage

occur, mitigation measures restricting off road travel in the vicinity of the sites will be

required. Consequently, there will be no impacts to heritage resource sites associated with

motorized vehicle travel in these proposed corridors. This is clearly noted in the EA.

Motorized Big Game Retrieval

In regards to affects created by motorized game retrieval, these impacts were discussed in

the EA under general impacts from motorized vehicles. Impacts from motorized cross

country travel can be the result of a variety of activities including recreational OHV use

such as scouting for game, antler hunting, rock hounding, site seeing, wood cutting and

game retrieval. As noted in the EA, damages caused to heritage resource sites by cross

country motorized travel differ depending on factors such as soil type, moisture, vegetation

and site type.

While vehicle tracks can be observed across sites, without “catching” someone engaged in a

specific task, it difficult to assign the damage to a single activity, though inferences can be

made about the activities occurring given the time of year and disturbances left behind (i.e.,

camp sites and/or evidence of wood cutting or animal butchering).

Consequently, a common sense approach needs to be taken when addressing this issue. The

recommendation for not allowing big game deer retrieval under Alternatives 2 and 3 was

based on consideration of several factors: the potential quantity of annual entries, the time

of year of the various hunts, and concerns with motorized cross country travel in high site

density areas. Deer takes are common in the high site density areas of the District, and

occur in the fall when moisture conditions are variable. Deer can be packed out on foot.

Bison, however, are quite large and are more difficult to pack out on foot. Additionally, the

number of takes is substantially lower. In 2009, 38 buffalo and 0 elk were killed on the

District, according to AZGF officials (AZGF 2010). Many years the take is much lower.

While there is a possibility that cross country game retrieval of either of these species could

impact a cultural resource site, given the low number of takes each year, it is anticipated

that the potential for adverse effects to a site would be negligible: 38 entries per year

equates to less than .0099% of the acreage on the NKRD. The odds of adversely affecting a

cultural resource site under these conditions are extremely low. This seems like a

reasonable compromise and an acceptable risk.

2-32 See response to comment 2-31


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2-35

We believe that the effects to cultural resources by cross country motorized travel were

adequately summarized under the effects section of the No Action Alternative: Direct and

Indirect Effects. The Uphus et.al, 2006 and Sullivan et.al, 2003 studies referenced by CBD

were focused on the South Kaibab, upper Tusayan basin area, and focused on inadvertent

impacts to sites from dispersed camping and resource procurement related activities. North

Kaibab Ranger District archaeologists visited hundreds of sites on the District in association

with travel management planning efforts. The NKRD appreciates CBD drawing our

attention to these studies and we will include them for comparison in the final specialist

report and EA as per the CBD recommendation. However, we will rely upon the results of

site specific inventories and monitoring efforts of sites located on the District for our

analysis.

It should be noted that the emphasis of the North Kaibab analysis was on motorized vehicle

impacts to sites from cross country travel. The North Kaibab examined spur roads leading

to over 800 dispersed camp sites on the Forest and eliminated from consideration any spur

roads crossing sites or accessing dispersed camp site with overlapping site conflicts. Our

inventory approach was discussed in the EA as well as the heritage resources specialist

report under the NKRD Methodology for Applying Protocols for Section 106 Compliance

section. The inventories did address both motorized impacts to sites on the District and

inadvertent vandalism to sites as a result of dispersed camping. The results of those

inventories can be found in Betenson 2009 and 2011 and Reid 2011 – Section 106 clearance

report in progress. These results will be fully addressed in the final heritage resources

specialist report and the Section 106 clearance report for this undertaking.

2-36

The Invasive Weeds section of Chapter 3 provides information on Invasive Weeds; this

information was based upon current survey data from the North Kaibab District. The

information taken from the information from analysis of cross country travel on five forests

(i.e., the Apache-Sitgreaves, Coconino, Kaibab, Prescott, and Tonto National Forests,

Arizona.) done in 2004 lists the general effects that invasive exotic weeds can have on the

environment. It also describes the various ways that weeds may be introduced or spread,

including by motorized vehicles. Additional analysis with site-specific information is

provided later in the section under the sub-headings for each alternative.

2-37

Under Alternatives 2 and 4, motorized big game retrieval would be allowed within a mile of

any open road, except within existing motorized vehicle closure areas. The Kaibab NF does

not have a complete weed survey that covers the entire North Kaibab District; however, the

effects analysis presented in Invasive Weeds section of the EA discloses the potential risks

associated with implementing Alternatives 1-4. By implementing Alternatives 2-4, the

North Kaibab District would make progress toward the Kaibab Forest Plan goals of

preventing the establishment of new noxious or invasive weed species and of controlling the

spread of weeds.

2-38 We believe the Final EA is not deficient because it complies with CEQ Regulations (40



156

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EA). The significance of the findings of the EA will be made as part of the Decision.

2-39

There is clearly a connection among specific economic impacts of OHV riding in Arizona,

OHV use in Coconino and Mohave Counties, and the State of Arizona. Each is a constituent

part of the next in that list. Thus, we believe that the analysis presented provides a

reasonable and acceptable level of detail through which to inform the decision for this

project.

2-40

The current state of conflict and displacement research would only allow the Forest to make

spurious connections among such complex topics. No peer-reviewed study exists that

allows a causal connection from a specific user conflict to lost revenue to be drawn. The

analysis present in Chapter 3 provides the state of knowledge to the most specific scale

possible.

2-41

We believe the Final EA is not deficient because it complies with CEQ Regulations (40







EA). A significance finding will be made as part of the Decision.

2-42

The Wildlife Report states: Numerous papers have been published on the effects of roads

and motorized travel on wildlife. The scientific literature documents a variety of negative

effects of roads and motorized travel on wildlife (e.g., see literature reviews in, Forman and

Alexander 1998, Trombulak and Frissell 2000, Brown et al. 2001, Ouren et al. 2007).

These are similar documents to Watson, Mark L. (compiler). 2005. Habitat Fragmentation

and the Effects of Roads on Wildlife Habitat. It will be included as an additional reference.

2-43

A Travel Analysis Process Report was initiated in 2008 and completed in January 2010 for

the NKRD (Forest Service TAP, January 2010). The EA process for implementing the

Travel Management Rule included appropriate site-specific analysis of effects of Motorized

Big Game Retrieval. Each action alternative specifies the distance from roads, the time of

year allowed, and the species allowed for legal MBGR. Thus, this analysis fully complies

with the relevant clauses of the Travel Management Rule.

2-44

Alternative 2 would allow the limited use of motor vehicles within one mile of all

designated system roads (except where prohibited) to retrieve a legally hunted and tagged

elk or bison consistent with 36 CFR 212.51(b). Alternative 4 is similar to Alternative 2, but

would additionally allow the retrieval of mule deer. Alternative 3 does not allow MBGR.

The environmental consequences of implementing alternatives 1-4 are discussed in Chapter

3 of the EA.


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No significant negative effects are anticipated in regards to the implementation of this

project and anticipated adverse effects are expected to be minor (see Ch.3 of the EA). A

significance finding will be made as part of the Decision.

2-45

The effects of different approaches to motorized big game retrieval are analyzed throughout

Chapter 3 of the EA, and are included in the Heritage Resources, Soils, Air, and Watershed,

Wildlife, and Non-Native Invasive Species specialists’ reports associated with the NKRD

Travel Management Project. A finding of significance of effects is included as part of the

Decision Notice associated with the project.

2-46

The direct, indirect, and cumulative effects of MBGR on archaeological sites are included

in the Heritage Resources section of the EA, along with the Heritage Resources Specialist

Report as part of the project record.

2-47

Direct, indirect, and cumulative environmental effects of the No Action Alternative,

Proposed Action, and other Action Alternatives resulting from implementation of Travel

Management Rule on the North Kaibab Ranger District are disclosed in Chapter 3 of this

document, and in the specialist reports included as part of the project record.

2-48

The Purpose and Need for Action is sufficient; it briefly describes the need for the project

and meets the requirements of 36 CFR 220.7(b)(1)).

See FS Response 2-43. The TAP (Forest Service TAP – January 2010) identified the

minimum road system using a science based analysis while considering public input

received during the planning process.

We considered your recommendations to adjust the purpose and need statement, however:

Your first recommendation about “the need to eliminate cross-country travel…” is already

incorporated into the purpose and need statement, although the wording we use is more

specific and relevant when defining the actions necessary to improving the management of

motorized vehicle use on the North Kaibab District.

Your second recommendation about “the need to address degradation…” is outside of the

purpose of the project which is to improve the management of motorized vehicle use on the

NKRD in accordance with the Travel Management Rule (36 CFR 212, 251 and 261). Travel

Analysis did not identify any roads that need to be decommissioned (Forest Service TAP –

January 2010).

The TAP identified the minimum road system by way of a science-based analysis that

incorporated public input.

A review of the existing and desired conditions of the Forest Plan shows that the Kaibab

National Forest provides opportunities for motorized and non-motorized recreation

consistent with Plan direction.

The statement about “the need to adjust both the core transportation system and recreation

travel network in light of …” is not supported by a review of the existing and desired

conditions section of the EA (Chapter 1).

2-49 Per FSH 1909.15 (Ch. 10 sec. 14.2): “There is no requirement to include a no action

alternative in an EA. In an EA, the effects of a no-action alternative may be documented as


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follows: The EA may document consideration of a no-action alternative through the effects

analysis by contrasting the impacts of the proposed action and any alternatives(s) with the

current condition and expected future condition if the proposed action were not

implemented. (36 CFR 220.7(b)(2)(ii)).” We believe that the no action alternative, as

described in Section 2.3 of the EA, adequately serves a baseline for estimating the effects of

other alternatives.

An alternative was considered but eliminated from detailed study that would not change the

designated road system because it would not meet the purpose and need for action.

2-50

In adding an unauthorized road to the designated system, we must consider the criteria in 36

CFR 212.55(a) and (c). And as stated in the Travel Management Rule, user-created roads

and trails may be identified through public involvement and considered in the designation

process. A District-wide travel analysis process (Forest Service TAP – January 2010) was

completed in 2010; it identified the minimum road system for the NKRD by way of a

science-based analysis that incorporated public input and did not recommend retaining any

of the existing user-created routes. However, in preparation of the EA, the District

identified a need to provide for motorized dispersed camping. Consistent with Regional

guidance (2008) and your 2006 comments on Region 3’s TMR guidelines, we proposed to

add approximately 16 miles of short spur roads to the designated system that have

historically served as access to dispersed camping sites (and other activities) on the District.

If the decision is made to add these roads to the system, we would have to amend the

“identified minimum road system” to include these roads and be consistent with FS

direction; the travel analysis provided in the EA would provide sufficient information for

such an amendment. This approach is consistent with FSM 7700 direction.

See Chapter 3 of the EA for a discussion of the condition of these short spur routes and the

environmental consequences of adding these roads to the system. There are no other

unauthorized roads proposed to be added to the system.

2-51

Additional alternatives were considered but eliminated from detailed study that would close

and provide a substantially reduced road system. [EA, pp. 24-26]. Also see Public

Involvement [EA. pp 12-13, & Appendix 4, Table 4-2]. The EA analyses the impacts of a

reduced motorized network on various resources. See FS Response to 2-18.

2-52


to be a viable alternative. Additional alternatives were considered but dropped from

detailed study; they are presented in Chapter 2 with the reasons for not analyzing them in

detail. The alternatives presented in the Alternatives Analyzed in Detail section and in the

Alternative Considered but Eliminated from Detail Study section represent a range of

reasonable alternatives, given the Purpose and Need and Key Issues for the proposed action.

2-53

By completing the EA and reviewing the project record, the responsible official has

complied with all of 36 CFR part 212.55 and Executive Order 11664. The minimum road

system for the NKRD was identified in the TAP (Forest Service TAP – January 2010), and

the recommendations were incorporated and analyzed in the EA under Alternative 2. An

additional alternative was considered but eliminated from detailed study that would close

and provide a substantially reduced road system (Chapter 2). The environmental


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consequences of implementing Alt. 1-4 are disclosed in Chapter 3 of the EA.

2-54

“While important, the scarcity or abundance of resources to maintain and administer

designated roads, trails, and areas should not be the only consideration in developing travel

management proposals” FSM 7715.5(1)(c). The transportation section in the EA provides

discussions on road maintenance, funding, and access on the. Implementation of

Alternatives 2-4 would reduce the road maintenance costs on the District while providing

adequate access for resource management and recreation activities (Section 3.1). Forest

Service appropriations are authorized by Congress and are outside the scope of this

analysis. See FS Response to 2-18.

2-55

In accordance with law, regulation and policy, the district developed a range of alternatives

(see Alternatives Analyzed in Detail section in Chapter 2). In addition to the No Action

Alternative (Alternative 1), three action alternatives were analyzed in detail that would meet

the Purpose and Need for Action and address one or more issues. See FS Response 2-18.

2-56

Several of the roads listed under the CBD, et al. comments on the proposed action included

justifications for closures that fell outside the scope of this project. The specific roads and

justifications that were not recommended for closure were cited in Forest Service TAP –

January 2010. See response 2-58.

2-57

The process followed during Travel Analysis is listed in the NKRD TAP report (Forest

Service TAP – January 2010). The TAP report’s purpose was to assess the values and risks

of forest roads and trails as they pertain to various resources and to form the basis for

further environmental analysis (i.e., this Final EA).

The Travel Management Rule and subsequent Forest Service direction require each national

forest or ranger District to designate those roads, trails, and areas open to motor vehicles. It

does not require this evaluation to be based on the relative value of the destination served

by each road, except in consideration of administrative needs.

2-58

We have reviewed your recommendations for additional road closures. We agree that

keeping the section of FR 260 near Jack’s Tank open under any of the action alternatives

would pose a risk to soils and meadow vegetation. Thus, this section is now proposed for

closure from the point where it drops into the meadow near Jack’s Tank to the intersection

with FR 282.

The remaining roads on your list were not viewed as posing a significant threat to resources

if left as ML 2 roads. They were identified as roads of concern in the TAP (Forest Service

TAP – January 2010) process, but further analysis as part of this EA deemed them suitable

to remain on the open road system.

2-59 The effects and associated mitigation measures for rare and sensitive plants are listed under

the Rare and Sensitive Plants specialist report as part of the project record.

2-60


to be a viable alternative. Additional alternatives were considered but dropped from

detailed study; they are presented in Chapter 2 with the reasons for not analyzing them in

detail. The alternatives presented in the Alternatives Analyzed in Detail section and in the

Alternative Considered but Eliminated from Detail Study section represent a range of


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reasonable alternatives, given the Purpose and Need and Key Issues for the proposed action.

2-61

The commenters’ recommendations have been considered, along with everyone else’s

comments who participated in the public involvement process, or that have occurred during

the scoping and public comment and review process for this project (See Public

Involvement section in Chapter 1 as well as Appendix 4).

2-62

Funding allocations and maintenance of the existing road system (existing now) and into

the future is an Administrative function. Repairs and maintenance (including closures) are

both pre-planned and as-needed, and the funding allocations are best estimates based on

past funding received for road maintenance. Allocation and prioritization of road

maintenance and repair is a function of continued monitoring and long-term planning under

the FS administration. An appropriate economics analysis was conducted under the

Transportation section of the EA. See FS Responses to 2-54 and 2-84.

2-63

We appreciate your support for ongoing and future restoration projects. However, until the

Kaibab National Forest has prohibited off-road travel and has the tools in place (e.g., the

MVUM) to effectively enforce the prohibition, plans to implement restoration of

unauthorized routes would be ineffective. Past efforts on the District have not been

effective in obliterating unneeded roads as users were allowed to travel cross-country (e.g.,

adjacent to closed roads) and thus created additional unwanted impacts. Once the District

has the ability to enforce off-road closures, we plan to evaluate and consider obliteration of

unneeded roads.

2-64

Cooperation with State agencies in achieving game and habitat management objectives

while protecting other forest resources is directed by the KNF Plan and other regional and

national guidance. We appreciate the information from the New Mexico Game and Fish

Department, however, the Arizona Game and Fish Department (AGFD) is responsible for

managing big game on the Kaibab National Forest. See FS Response 14-1 and the Public

Involvement Section in the EA for rationale as to why we proposed allowing MBGR.

2-65 See FS Response 2-64.

2-66

Current conditions and existing policy allow an unlimited number of trips for all aspects of

hunting that includes scouting, MBGR for all species with no limit on the distance traveled

from system roads, no restrictions on seasons or weather conditions and no requirement for

use of a direct route. Alternatives 2 & 4 apply limits on all of these currently unlimited

activities, while Alternative 3 does not allow MBGR for any species. The effects of

implementing Alternatives 1-4 on wildlife and wildlife habitat are disclosed in Chapter 3 of

the EA.

2-67






3 of the EA.



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2-68 See FS Responses 2-4, 2-46, and 2-86.

2-69

See FS Response 2-3. The effects of implementing Alternatives 1-4 on wildlife and wildlife

habitat are disclosed in the Wildlife Section of the EA. Implementation of Alternatives 2-4

would be consistent with the Travel Management Rule, Forest Plan Direction, and would

improve the District’s ability to attain Forest Plan objectives (See Chapter 3). The AZGFD

comments regarding MBGR have been addressed; See FS Response to 1-1 through 1-12,

above.

2-70

MBGR was a key issue that was addressed in the EA. The AZGFD comments regarding

MBGR have been addressed; See FS Response to 1-1 through 1-12, above. Also MBGR

was addressed in the EA as well as the potential effects on resources. See EA, Chapter 3,

and Tables 4 through 6, and 15. By limiting MBGR to Elk and Bison only, the NKRD has

addressed any potential effects, in that due to the limited number of elk and bison permits

being filled every year, there will be very limited effect on resource areas, such as heritage,

soils, and control of invasive species.

2-71






3 of the EA.




2-72

See FS Response to 2-69 and 2-70. Potential impacts caused by MBGR vary by Forest, and

District to District, based on different soil types, topography, annual precipitation, etc.

Additionally, the impact is also determined by the game management unit and the

AZGFD’s management of the issuance of the number of permits (which may vary year to

year). The AZGFD comments regarding MBGR have been addressed. See FS Response to

1-1 through 1-12, above.

2-73 This map is available in the project record. See FS Response to 2-72, above.

2-74

Both MBGR and Camping Corridors were evaluated in the EA. Direct, Indirect and

Cumulative impacts were analyzed under the EA. For cumulative effects discussion please

defer to FS Responses to 2-4, 2-17, and 2-50. The AZGFD comments regarding MBGR

have been addressed; See FS Response to 1-1 through 1-12, above. Specific impacts,

including site-specific effects analyses, are presented throughout Chapter 3 of the EA. Also

see responses to 2-31, 2-35, and 11-7. A thorough analysis is presented in the EA.

2-75 The NKRD is following the consultation requirements specified in the PMOA agreement

between the FS Region 3 and the Arizona SHPO, i.e., …Standard Consultation Protocol


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for Travel Management Route Designation (USDA Forest Service 2003 and 2006). That

agreement exempts existing system roads from Section 106 inventory requirements.

Exceptions to the protocol are being addressed under the standard Section 106 process as

follows, and will be discussed in Section 106 clearance report for this undertaking (Reid

2011 -in progress):

All spur roads were completely inventoried for heritage resource sites. Any roads found

containing heritage resource sites were dropped from consideration. The results of these

inventories can be found in Betenson 2011.

All proposed fixed distance corridors have been completely inventoried for cultural

resources. Avoidance measures have been proposed for sites within corridors susceptible to

motorized vehicle impacts. The Arizona SHPO has concurred that the proposed action will

have no adverse effect on cultural resource sites on 10/05/2011.

In general, it should be noted that the District has adequately considered heritage resources

in its analysis process, basing its alternative selection on site-specific analysis of those sites.

This is illustrated by the choice in Alternatives 2 and 4 to limit corridor camping to

previously surveyed areas with an overall low site density, and to further limit motorized

travel within those corridors to areas that do not contain sites that are susceptible to

motorized vehicle damage. Additionally, limiting motorized deer retrieval (Alternatives 2

and 3) and cross country access for wood gathering in the pinyon juniper zone (Alternatives

2, 3, 4) in areas where site densities are high takes into consideration the large number of

sites in close proximity to system roads on the District.

2-76

What the AZGFD may or may not present, or what the commenter thinks AZGFD’s

assertions are regarding game retrieval are beyond the scope of this project. Direct, Indirect

and Cumulative impacts were analyzed under the EA. For cumulative effects discussion

please defer to FS Responses to 2-4, 2-17, and 2-50. The AZGFD comments regarding

MBGR have been addressed; See FS Response to 1-1 through 1-12, above.

2-77 Alternative 3, which does not allow MBGR, was analyzed in detail in the EA.

2-78

The Travel Management Rule (TMR) allows for the use of dispersed camping corridors.

The use of motor vehicles off system roads to access campsites is a popular activity on the

District. TMR allows that the Responsible Official “…may include in the designation the

limited use of motor vehicles within a specified distance of certain designated routes, and if

appropriate within specified time periods, solely for the purposes of dispersed camping…”

(36 CFR 212.51 (b)). This allowance is optional and at the discretion of the Responsible

Official. Motorized dispersed camping occurs throughout the District, particularly during

hunting season and summer holiday weekends. A majority of this camping occurs in areas

along main NFS roads that have a close proximity to recreation opportunities, views, trails

and/or water. Motorized dispersed camping typically occurs in the same areas year after

year because they are in desirable locations and are easily accessed. Within the camping

corridor most motorized dispersed camping sites are within 300 feet of existing roads. Per

the EA Soils section pages 51-52, Alternatives 2, 3, and 4 would provide substantial

reduction in potential acres of soil disturbance over the No Action Alternative by reducing

motorized dispersed camping across the NKRD. The No Action Alternative would

continue to allow motorized dispersed camping on approximately 540,869 acres or 82


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percent of the NKRD. Alternatives 2 and 4 would continue to allow motorized dispersed

camping on approximately 23,591 acres or 3.6 percent of the NKRD. Alternative 3 would

not designate any corridors for dispersed camping. Under Alternatives 2 and 4, a reduction

from 82 % to less than 4% is considered very substantial with regards to the reduction in the

number of acres available on the Forest which can be utilized for motorized dispersed

camping.

2-79

The mitigation and monitoring measures described in the EA have been included to ensure

that effects to natural and cultural resources remain at acceptable levels during

implementation of the travel management policies.

2-80 Alternative 3, which does not include any dispersed camping corridors, was analyzed in

detail in the EA. See FS Response to 2-78 above.

2-81

The CBD statement suggests that corridor camping was designated for the mixed-conifer

zone. That was not the approach taken. Corridor camping was specifically focused in the

ponderosa pine zone, which has a relatively open understory more amenable to cross

country motorized camping. There may be small overlaps with mixed conifer vegetation

within the corridors, but the overwhelming vegetation type is ponderosa pine.

As in the pinyon-juniper timbered zone, spur routes leading to recreational opportunity

areas in the mixed-conifer were designated for inclusion into the MVUM in lieu of fixed

distance camping routes. Those routes were surveyed by archaeologists and found to be

void of cultural resource sites prior to inclusion. The site number statistics cited by CBD, in

regards to sites within 300 feet of a road, refer to the entire forest. In fact, there are only 58

sites within the proposed corridor system which represents less than 2% of the recorded

sites on the District. Not all 58 sites are susceptible to vehicle damage. This statistic will

decrease over time as more sites are found outside of these corridors.

2-82 See FS response 2-24.

2-83 See FS response 2-24.

2-84

The FS appreciates your recommendations for a “route restoration strategy,” however the

suggestion is outside the scope of this analysis. Until the Kaibab National Forest has

prohibited off-road travel and has the tools in place (e.g. the MVUM) to effectively enforce

the prohibition, plans to implement restoration of unauthorized routes would be ineffective.

Past efforts on the District have not been effective in obliterating unneeded roads as users

were allowed to travel cross-country (e.g. adjacent to closed roads) and thus created

additional unwanted impacts. Once the District has the ability to enforce off-road closures,

we plan to evaluate and consider obliteration of unneeded roads. The FS has already begun

implement strategies to inform the public on the changes to transportation management on

the Williams and Tusayan Ranger Districts, however the commenter’s request is outside the

scope of this analysis (see Purpose and Need for Action).

The impacts from unauthorized and illegal uses are impossible to account for and are

therefore outside the scope of this analysis. Mitigation and monitoring measures have been

incorporated to ensure environmental consequences are within acceptable levels.

Compliance with the travel management decision and resource damage will be monitored,


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and the decision on this travel management proposal will not preclude additional measures

being taken in the future. See FS Response to 2-54.

2-85 See FS Responses to 2-54, 2-84, and 2-86.

2-86

Travel management decisions are to be made at the project level and must be consistent

with the applicable land management plan (FSM 7712.2), in this case the 1988 Kaibab

National Forest Land Management Plan, as amended. The protection and existence of the

“special areas” presented are important, but the creation and designation of these areas are

best addressed at the Forest Plan level.

Making changes to the designated system of roads based on the need to reduce adverse

resource impacts does not establish a precedent for future actions or represent a decision in

principle about a future consideration. For instance, the Forest Plan does not currently

establish road-density standards and any discussion of road density in the EA was used to

discuss/describe anticipated effects and was used to compare alternatives. In no way does

the use of road density as an indicator or measure of effect in this EA establish that measure

as a standard to be met in future management projects. Additionally, site-specific travel

management decisions will be made with future planning efforts to achieve the desired

conditions prescribed in the Plan.

Procedures are in place to annually revise the MVUM to accommodate changes to the

designated system as a result of future management decisions and/or changing conditions.

Any future actions that alter the designated road system, alter motorized big game retrieval

restrictions or affect motorized dispersed camping opportunities will have to be evaluated

under the National Environmental Policy Act (NEPA).

We appreciate and have considered all the comments and information you have provided us

throughout the development of this project. The direct, indirect, and cumulative effects of

implementing Alternatives 1-4 are discussed in Chapter 3 of the EA.

3-1

Thank you for your comment. [Note: the FS will update its contact information with regard

to ADOT point-of-contacts, and in coordinating any information that the Final Decision

may have on ADOT rights-of-way and inholdings.]


5-1

In consideration of your comment, we investigated and found that Forest Road 249K does

not exist on the ground. The mapped location would require this road to cross an existing,

solid fence line. We did consider the adequacy of opportunities to create loops for forest

users in our analysis.


6-1

All action alternatives would require some level of road closure due to impacts of continued

use on those roads (see Chapter 3 for more detail). Thank you for your consideration of

Tread Lightly principles.

7-1 Effects of unlimited off-road travel for the purpose of mule deer hunting are considered in

each section of Chapter 3, specifically under effects of Alternatives 1 and 4.


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Comment Number



7-3 We have met several times with local government interests, and received comments

regarding this planning effort. We will continue to do so in the spirit of collaboration.

8-1 See FS Response 2-58 (re: CBD et al comment on 260 road.)

8-2

The Travel Management Rule (TMR) requires that motorized use be limited to the

designated system of roads, trails, and areas. All action alternatives evaluated in this

analysis would require consistency with the rule.


9-2

Current cross country travel impacts sensitive species. The proposed action limiting cross

country travel will benefit sensitive species including northern goshawk, Kaibab squirrel,

and California condor.

9-3

The effects of motorized use on the Kaibab Plateau are evaluated in Chapter 3 of this

document. All alternatives considered would involve some cost for the continued

maintenance and improvement of existing roads and trails. The specific costs related to each

alternative can be found in the Transportation and Social and Economic Environment

sections of the EA.

9-4

This comment is largely beyond the scope of this document. However, we did consider the

effects of each alternative on several specific species. The analysis of these effects is in

Chapter 3 under the Wildlife sections.


10-2 Hunting itself is not directly addressed by this analysis. However, the effects of motorized

big game retrieval are analyzed in detail throughout Chapter 3.

11-1

Changes in MBGR policy may affect hunter behavior and influence the amount of game

carcass parts left in the field. However, it is illegal under state law to waste game meat.

Lead bullet fragments consumed by condors and other avian scavengers are typically

concentrated in the gut pile that is left behind in the field. Currently, even with MBGR

allowed for all big game species, nearly all big game hunters field dress their harvested

animal and leave gut piles in the field. Therefore, compared to current conditions (Alt 1),

restrictions on MBGR under Alts 2, 3, or 4 would not result in a measurable increase in the

frequency of hunters leaving gut piles in the field. The FS has therefore concluded that there

would be no measurable increases in the probability of avian scavengers such as condors

and bald eagles contracting lead poisoning as a result of changes in MBGR policy under

Alts 2, 3, or 4. The AZGFD has had many incentives to increase compliance of these

recommendations in Game Management Unit 12. A 2003 survey conducted by AZGFD

discussed four actions that hunters can take to help reduce condors’ exposure to lead. An

overwhelming majority of respondents (94%) would be very willing to retrieve all animals

killed from the field, and a large majority (59%) would be very willing to hide or cover

carcasses or gut piles. Just less than a majority (48%) said that they would be very willing

to remove bullets and impacted flesh from carcasses or gut piles that they leave in the field,


166

Comment Number


and the same percentage said that they would be very willing to use lead-free ammunition

(Byrne 2003). Voluntary lead reduction efforts encouraged by AGFD and The Peregrine

Fund to reduce lead poisoning of condors have focused on trying to increase the use of non-

lead ammunition by hunters, and none of the alternatives in this EA affects those voluntary

reduction efforts.

[See FS Response to 1-3, last paragraph.]

11-2

The majority of the deer hunts occur September thru November, when the deer are on the

winter range, the east and west sides of the District. This area is predominately pinyon-

juniper with cyptobiotic soils (see Soil report for more information) which is vulnerable

from cross country travel, including big game retrieval. Impacts to this habitat and

associated species would be much greater under with the inclusion of MBGR for mule deer,

which has 61% annual harvest (or an approximate average of 954 deer per year). Impacts to

archeological sites are also very high in this habitat type.

11-3

The total project area has approximately 16 miles of unauthorized routes (spur roads) that

lead to areas identified as popular camping locations. The proposed action will authorize

3.44 miles of existing spur roads in MSO habitat that are currently considered as

unauthorized routes. These campsites (146 total) have been used historically and will not

result in any new potential effects to owls.

11-4

Most of the comment is supportive of our actions as they apply to Pediocactus. The concern

regarding big game retrieval was addressed in the EA (D.Burger).

The differences between alternatives 2, 3, and 4 are the authorization of motorized big game

retrieval for elk and bison in Alternatives 2 and 4, and the additional motorized big game

retrieval for mule deer in Alternative 4. Based on current hunt information, no elk or bison

have been found inside of the conservation area. No anticipated issues are tied to motorized

big game retrieval in the conservation area. Effects from mule deer retrieval are discussed

below.

Alternative 4 only differs from the Proposed Action in that it does not allow for retrieval of

mule deer as part of MBGR. Alternative 4 would authorize a one mile corridor for

motorized big game retrieval. The conservation area has been popular for hunting mule

deer. This would increase the level of off-road motorized vehicle travel over Alternative

2. The low precipitation and poor soils of this habitat make it more difficult to recover from

impacts when compared to other popular hunting locations on the NKRD. The creation of

ruts and reduced vegetation is possible from one round trip on every motorized game

retrieval.

By the time that the second rifle hunt in late November occurs, the cactus typically has

retracted back into the soil. Exceptions depend on climatic conditions like temperatures and

precipitation. The cactus is less susceptible to damage from vehicles when it has retracted,

but can still be crushed or compacted when driven over. Invasive species spread can occur

from seed clinging to the vehicle. The motorized game retrieval would be random and

potential impacts could only be created in the locations where motorized vehicles would

drive on the more fragile soils. Any tracks created will rehabilitate over time, but it will

take longer than other locations.


167

Comment Number


11-5

The ability to identify and enforce areas within the conservation area where MBGR would

not be permitted would be very difficult. For reasons identified in 11-1, MBGR would not

occur for deer. There is very little likelihood MBGR for elk or bison would occur in the

Paradine plains cactus conservation agreement. Elk (current estimate is at 11 individuals)

tend to use Le Fevre and Orderville canyon to the north to migrate on to the plateau and

move alongside the 67 corridor with Telephone Hill being the furthest south location.

Bison when they move off of the Grand Canyon National Park will graze in DeMotte and

Pleasant Valley meadows but use South Canyon to migrate back to the designated area in

House Rock Valley.

11-6

The District is proposing to make an exception to the 30-foot rule (see response 11-4) as a

mitigation measure to protect the Pasture Canyon Paradine plains cactus populations along

the East Side Game Road.

11-7

The Travel Management Rule exempts permitted activities. Section 212.51 states that motor

vehicle use that is specifically authorized under a written authorization issued under Federal

law or regulations are exempted from route and area designations. Thus, motorized uses that

occur under permitted authority may allow for motorized use on non-designated routes or

areas if it occurs under the terms of the permit. This rule however will not apply to the

pinyon-juniper and grassland habitat until site specific analysis is completed. In the example

of wood cutting a Forest wide permit is issued, but it does not specify specific areas, in

order for off-road travel for the purpose of wood cutting to occur in the pinyon-juniper

habitat a designated area would be selected and analyzed to avoid impacts to ecological and

cultural resources.

11-8

At the beginning of each project the FS takes advantage of the on-line environmental

review tool on the AZGFD website. In addition, the FS and AZGFD are cooperating

agencies and coordinate frequently. AZGFD provided comments on the project. FS

Archeologists have consulted with the Tribes throughout this planning process and no

issues concerning sensitive species have been identified. The FS appreciates the

coordination conducted by the FWS with local Tribes.




14-2

The effects of travel on and off the designated road system are discussed throughout

Chapter 3. Any road that is proposed for closure according to any of the action alternatives

was proposed because of concerns about resource damage of one or several kinds.

14-3

Each of the alternatives evaluated includes a different approach to motorized big game

retrieval. The travel management rule requires that any policy for motorized big game

retrieval specify a distance off road a hunter may travel, and the time of year s/he may drive

to retrieve a downed animal. Thus, all action alternatives analyzed comply with the

requirements of the rule.


168

Comment Number


15-1

Individual fuel wood gathering is addressed throughout the document. Throughout our

public involvement process, we solicited feedback regarding fuel wood gathering, and have

attempted to assure that adequate areas are available for permitted, legal uses, including fuel

wood gathering as we proceed through implementation.


15-3 See response 11-5 for response to AZGFD enforcement comment; Also see discussion

under FS Responses 2-63 and 2-84.

16-1

See FS Response 8-2. In addition, two of the action alternatives included wider camping

corridors on 203 miles of roads, and included the addition of 796 spur routes, most of which

serve existing campsites. Thus, we feel that camping opportunities outside of the 30-foot

corridors have been addressed.

16-2

Under each of the action alternatives, fuel wood gathering would be done under auspices of

a permit. Accordingly, fuel wood gatherers would be able to travel further off road within

specific vegetation types.


17-2

A variety of factors was considered when determining roads for closure, including whether

or not the road impacted sensitive resources, was redundant, or had erosion or other

structural issues. Many of the roads that were selected for closure, were originally user

generated roads or trails, that were given system number roads in recent decades. Most of

these were never designed or maintained by the Forest Service. Some of these are younger

than 50 years old. Many of these roads are located in areas that would not be selected as

suitable locations for road construction by forest road engineers. Because they were not

formally constructed, a number are in locations that have erosion issues and other problems

that continue to worsen over time.

While it is true that road maintenance activities such as blading, surfacing, and construction

of runoff ditches generally destroy archaeological remains, most of the roads proposed for

closure have never been subjected to these mechanical impacts. Consequently,

archaeological sites associated with these roads often have intact subsurface that are

gradually exposed from ongoing vehicle travel over time.

17-3 See response to comment 17-2.

18-1 Comment noted; See FS response 2-58. Additional “route” discussions can be found under

responses 1-10, 1-12, 2-9, 2-23, 2-27, 2-50, 2-63, 2-75, 2-78, 2-81, 2-84, 11-3, 11-7 & 16-1.

18-2

Comment noted; See FS response 2-17, 2-50, 2-78, and 8-2.

See EA, Chapter 1, desired conditions discussion under the following headings: Road

System, Motorized Trails and Areas, Motorized Travel Exemptions, Motor Vehicle Use for

Dispersed Camping, and Motorized Big Game Retrieval. Also see Issues discussion at the

end of Chapter 1 of the EA.


169

Comment Number


18-3 See FS Response 2-58 (re: CBD et al comment on 260 road.)

18-4

MBGR is included in the Issues discussion at the end of Chapter 1 of the EA. The AZGFD

comments regarding MBGR have been addressed; See FS Response to 1-1 through 1-12,

above. See response to 2-31, Motorized Big Game Retrieval. Also see discussion or

consideration of motorized big game retrieval (MBGR) in responses: 2-4, 2-5, 2-6, 2-43, 2-

44, 2-46, 2-64, 2-66, 2-67, 2-69 to 72, 2-74, 2-76, 2-77, 11-1, 11-4 and 11-5.

18-5

It is correct that motorized vehicles can adversely affect an archaeological site. However,

regarding the proposed camping corridors, all have been inventoried for the presence of

cultural resource sites. Site locations are known. Portions of the corridors containing

archaeological sites susceptible to vehicle damage will be posted as closed to motorized

travel. Therefore, there should be no effects to cultural resource sites in the proposed

corridors.

18-6

See response to comment 2-7, 2-36, 2-37, 2-44, 2-66, 2-67, 2-77, 2-80, 2-86, and 19-2. The

Forest is to be managed for multiple uses, not just “wildlife viewing, hiking, and other quiet

recreation” as alluded to by the commenter.

19-1

The Transportation section within chapter 3 of the EA addresses the minimum system of

roads. The minimum road system was identified in the North Kaibab TAP (Forest Service

2010). It is the road system needed for safe and efficient travel and for the administration,

utilization, and protection of National Forest System lands (36 CFR 212.5(b)). The

minimum road system is that which is needed to meet resource and other management

objectives adopted in the Kaibab National Forest Land Management Plan (in accordance

with 36 CFR part 219), laws and regulations, long-term funding expectations, and

minimizes adverse environmental impacts. The desired minimum road system attempts to

balance these elements and make progress toward a sustainable road system. Also see

Responses 2-48, 2-50, and 2-53 above.


170

Comment Number


19-2

Forest Service regulations at 36 CFR part 212 governing administration of the forest

transportation system and regulations at 36 CFR part 295 governing use of motor vehicles

off National Forest System (NFS) roads are combined and clarified in this final rule as part

212, Travel Management, covering the use of motor vehicles on NFS lands. These

regulations implement Executive Order (E.O.) 11644 (February 8, 1972), ‘‘Use of Off-Road

Vehicles on the Public Lands,’’ as amended by E.O. 11989 (May 24, 1977).

These Executive orders direct Federal agencies to ensure that the use of off-road vehicles on

public lands will be controlled and directed so as to protect the resources of those lands, to

promote the safety of all users of those lands, and to minimize conflicts among the various

uses of those lands.

The NKRD Travel Management Plan will prohibit the use of motor vehicles off the

designated system, as well as use of motor vehicles on routes and in areas that is not

consistent with the designations. The clear identification of roads, trails, and areas for motor

vehicle use on the NKRD will enhance management of the Kaibab National Forest lands;

sustain natural resource values through more effective management of motor vehicle use;

enhance opportunities for motorized recreation experiences on The NKRD; address needs

for access to NKRD; and preserve areas of opportunity on each National Forest for

nonmotorized travel and experiences.

The EA is not a decision document. This EA presents the results of the analysis of the

direct, indirect, and cumulative environmental effects of the proposed action and no action.

This analysis is intended to assist the Responsible Official in making an informed decision

on how best to implement the Travel Management Rule. That decision will be documented

in a Decision Notice signed by the KNF Forest Supervisor and will be available to the

public upon its completion. Also see responses 2-7, 2-36, and 2-37 above.


171

Copies of Comment Documents

Pages 172 to 251 are copies of the original comments with the Forest Service’s break-out of each

comment letter, based on the letter number and comment number as indicated in Table 4-3.

Appendix 4: Consideration of / Response to...

Documents

Transcript of Appendix 4: Consideration of / Response to...