appendix 4: consideration of / response to...
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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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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.
1-6 See response 1-3.
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
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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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(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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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.
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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
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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.
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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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2-33 See response to comment 2-31
2-34 See response to comment 2-31
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
CFR 1500-1508), Forest Service NEPA Regulations (36 CFR 220) and follows Forest
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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). 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
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.
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
Four alternatives were developed in detail. Each “action alternative” (i.e. 2-4) was designed
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
Four alternatives were developed in detail. Each “action alternative” (i.e. 2-4) was designed
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
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.
No significant negative effects are anticipated in regards to the implementation of this
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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.
2-68 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
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.
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.
2-72
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.]
4-1 See response 1-10.
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.
5-2 Thank you for your comment.
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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7-2 Thank you for your comment.
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.
9-1 See FS Response 8-2.
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.
10-1 See FS Response 8-2.
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,
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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.
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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.
12-1 See FS Response 8-2.
13-1 See FS Response 8-2.
14-1 See FS Response 8-2.
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.
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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.
15-2 See response 14-3.
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.
17-1 Thank you for your comment.
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.
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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.
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Comment Number
Forest Service Consideration of / Response to Comment
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.
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Environmental Assessment North Kaibab Ranger District Travel Management Project
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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.