Comments on the Southwest Jemez Mountains Landscape Restoration Project DEIS Due By April 15


The comment period for the Draft Environmental Impact Statement (DEIS) of the Southwest Jemez Mountains Landscape Restoration Project is already well under way. The DEIS was officially published on February 28, so the 45 day comment period will end April 15. Those who have been following the promulgation of this project, which we’ve covered extensively in La Jicarita, will have already digested the DEIS, but for those of you who haven’t—maybe because you don’t think you have a vested interest, but believe me, we all do, as the summer of 2014 approaches in the drought stricken Jemez Mountains surrounding Los Alamos National Laboratory—La Jicarita provides the following overview of the document. (Contact information for submitting comments is at the end of the article.)

The National Environmental Policy Act, or NEPA, lays down the rules that federal agencies have to follow when drafting an environmental impact statement. Various alternative actions are developed, in this case by the Santa Fe National Forest, which manages the Jemez Mountains, and which include a no-action alternative. The agency then chooses a Preferred Alternative, and the DEIS instantiates this preference by contrasting and comparing how the various alternatives meet the project’s goals.

Preferred Alternative number 1 of the Jemez DEIS proposes to treat 29,000 acres of the 110,000-acre project with mechanical treatment (thinning) and use prescribed fire on approximately 77,000 acres. Alternative number 2 is the No Action Alternative and would only treat whatever acreage is designated in the Forest Plan, a significantly smaller amount. Alternative number 3 addresses public comments submitted during the scoping period opposed to any new road development to access mechanically treated areas. It proposes using fire instead of mechanical thinning to treat those areas. Alternative number 4 responds to concerns about prescribed fire—danger to communities and smoke pollution—and would substitute mulching and chipping for fire in the mechanically treated areas. Alternative number 5 responds to concerns about treatment in Mexican spotted owl “protected activity centers”, proposed in forest plan amendments, and would reduce the number of acres treated with prescribed fire to 76,300 acres.

Southwest Jemez Mountains Restoration Project. Santa Fe National Forest image
Southwest Jemez Mountains Restoration Project. Santa Fe National Forest image

Desired Conditions

So what are the goals, or desired conditions, that this restoration project hopes to achieve? We know that undesirable conditions have resulted in decades of catastrophic fires in the Jemez Mountains: the 1954 Water Canyon fire of approximately 5,000 acres that forced the first evacuation of Los Alamos; the 1977, 15,000-acre La Mesa fire; the 1996, 16,000-acre Dome fire; the 2000 Cerro Grande fire, which burned 43,000 acres and forced another evacuation; and the 156,000-acre Las Conchas fire, then the largest fire to date that also forced evacuations at Los Alamos and Santa Clara Pueblo (the 2012 Whitewater-Baldy fire in the Gila broke that record).

In the DEIS Chapter 1 titled “Existing and Desired Conditions, What We Have and What We Want,” the Forest Service uses the language of “resilience,” the more contemporary terminology developed by forest ecologists like Tom Swetnam and Craig Allen as forest communities like the Jemez have been radically altered by drought and climate change. But descriptions of what we currently have and what we want, in the dominant ponderosa forests in the Jemez, haven’t changed in the last few decades of forest management. “What we want” is the more park-like, open forests dominated by clumps of different aged trees. “What we have” is a blanket of even-aged trees, 5 to 12 inch diameter trees growing in densities of up to 500 trees per acre. There are few large diameter trees and little understory growth. The dry mixed conifer—Douglas fir, limber pine, aspen, and ponderosa—is in the same existing state.

The desired condition is a mosaic of uneven-aged trees, including old growth. In the ponderosa forest densities would range from 4 to 20 trees per acre in groups of trees called a mosaic. Mixed conifer spacing and groupings would be of similar density. “With more open stands, fire could play its key role in maintaining both types of forests. Low-intensity surface fires would reduce or maintain fuel levels and tree densities and rejuvenate the understory bunchgrasses.”

Aspen is dependent on fire for regeneration and because of the lack of periodic, low intensity fires that were formally the pattern, the trees are mature and over mature and giving way to conifer. The desired condition is to regenerate more aspen stands, particularly on the western side of the project area. Piñon/juniper forests are also overstocked with little understory growth.

Wet mixed conifer—largely Douglas fir and white fir—have seen the least amount of human-caused change but are also overstocked and would be treated to reduce fire in Mexican spotted owl habitat.

While the Forest Service acknowledges that it has yet to complete an inventory of old growth, which it defines as “late successional stage” and “climax forest”, there are large, mature trees scattered throughout the project area, primarily in canyon bottoms and steep slopes. The desired condition is to have 20 percent old growth ponderosa and mixed conifer across the project area.

Forest encroachment into meadow and riparian habitat has diminished the vitality of streams, wetlands, and springs. Recreation, grazing, and nonnative species have also impacted native vegetation in meadows. Eroded stream banks have contributed sediment to steams, reducing water quality and fish habitat. Increasing meadow diversity would improve water quantity and quality, provide for better animal habitat, including the beaver.

There is one listed threatened species, the Mexican spotted owl, and one endangered species, the Jemez Mountains salamander, in the project area. Current conditions in the area do not meet guidelines established in the recovery plan for the spotted owl, which require ecological diversity and big trees. The salamander was only recently listed as endangered, and the Forest Service is scrambling to determine its habitat requirements. Recovery plans for both species will have to be incorporated into project actions.

There are 3,000 identified archeological sites in the project area that have been impacted by dead and down forest materials that make them more susceptible to severe wildfire. Heavy recreational use has resulted in increased vandalism, and road, trails, and grazing have resulted in erosion. The desired goal is the reduction of fuels and the prospect of high intensity wildfires. On page 141 of the DEIS, in the Recreation Chapter, the Forest Service acknowledges that the purpose and need of the project to increase forest resiliency “does not directly address recreation.” Rather, the DEIS analyzes the impacts that mechanized treatments and prescribed burns will have on recreation. Recreational use in the project area is extremely heavy. Except for one picnic area, all developed fee sites are within the boundary (six campgrounds, five picnic areas, and seven fishing sites). There are two congressionally designated recreation sites within the project, and of course, the Valles Caldera National Preserve. In 2012 approximately 600,000 people visited the Jemez Ranger District.

La Jicarita previously discussed the controversies involved in the Santa Fe National Forest Travel Management Plan, which are pertinent to the Jemez District and project area, primarily the inability of forest staff to enforce road closures. There are already too many poorly conditioned roads in the area that cause erosion and impact water quality. To access treatment sites the Forest Service plans to temporarily open some closed roads and construct temporary roads that will be closed afterwards.

The Proposed Action

Chapter 2, beginning on page 39, states that “treatments will be guided by landscape features (what we find on the ground).” Examples include vegetative cover types, slope, scenic sensitivity levels, and threatened and endangered species habitat. Following is a synopsis of the kinds of treatments proposed to achieve the “desired conditions” in the Preferred Alternative number 1.

• Uneven-aged mechanical selection cutting will be employed on 23,000 acres of ponderosa pine on slopes less than 40 percent. Trees will be cut by chainsaws, feller bunchers, or other equipment and skidded out to roads to be removed as logs or chips. Prescribed fire will then be used to reduce the fuel load every 5 to 10 years.

• Stand improvement thinning and prescribed fire will be used on 1,500 acres of ponderosa pine of young, even-aged stands on slopes less than 40 percent. Removed logs will be sold.

• Uneven-aged mechanical selection cutting will be used on 5,300 acres of dry mixed conifer dry stands on slopes less than 40 percent. Removed logs will be sold and prescribed fire used every 7 to 12 years.

• Stand improvement thinning and prescribed fire will be used on 80 acres of dry mixed conifer of young, even-aged stands on slopes less than 40 percent.

• In addition to the areas described above, prescribed fire will be used on 32,000 acres on slopes greater than 40 percent, for a total acreage of 77,000.

• Mechanical thinning will be used on 1,150 acres of wet mixed conifer on slopes less than 40 percent. Priority areas include those close to endangered species habitat, wildland-urban interface, springs, and diseased.

• Mechanical thinning will be used on 1,800 acres of aspen on slopes less than 40 percent to maintain stands or create new stands.

• Thinning will be used on 1,000 acres of piñon/juniper and the cut trees will be available for firewood. Instead of prescribed fire the slash will be scattered or piled and burned.

• Approximately 20 miles of existing closed roads will be opened to access and product removal. They will be closed after completion of the project. Approximately 12 miles of temporary roads will be constructed and decommissioned after completion.

• Riparian restoration activities would include thinning, soil stabilization, planting, construction of earthen dams and trick tanks, and pulling invasive species (see page 43). The DEIS states that “herbicides may be authorized” only upon completion of the final environmental impact statement for the Invasive Plant Control Project for the Santa Fe National Forest (the Draft Supplemental for that EIS was released on March 24).

Chapter 3 provides information regarding economic valuation of the project. Thirty percent of the pole, post and firewood products would be for private use; seventy percent for commercial use. Over the course of the entire project Alternative number 1 would produce (CCF stands for 100 cubic feet):

• 23,700 CCF of softwood sawtimber

• 800 CCF poles

• 1,800 CCF posts

• 3,300 CCF firewood

• 28,700 green tons of all other products

Sounding like a broken record, WildEarth Guardians complained about any commercial logging component in the DEIS in a “My View” in the Santa Fe New Mexican on April 6. The group has always been opposed to commercial logging in the forests of New Mexico, dating back to its support—in its former incarnation as Forest Guardians—of the Zero Cut initiative to halt all commercial logging on our national forests, whether corporate or community based. While they support federal monies being spent on restoration thinning projects, they continue to take the position that the USFS should never allow anyone to actually make a living cutting trees in the woods.

As La Jicarita stated in an article in August of 2013, what the USFS actually has in mind are stewardship contracts in which the agency will exchange goods for services. The bidding contractor can determine the value the wood they can use and trade that against what they would have charged to thin the smaller trees that they can’t use. Of the acres slated for thinning, about half have harvest potential. Other methods will include firewood sales, service contracts (thinning), and prescribed burning on very small diameter trees.

Ways to comment:

  • Email to: Comments can be included directly in the body of the e-mail message or as an attachment in Word document format (.doc, .docx), portable document format (.pdf), rich text format (.rtf), text (.txt), or hypertext markup language (.html).
  • Mail to: SW Jemez Mountains Landscape Restoration Team,11 Forest Lane, Santa Fe, NM 8750
  • Fax to: (505) 438-5390
  • Hand-deliver to: the Forest Supervisor’s Office or the Jemez Ranger District Office during business hours, 8:00am to 4:30p.m., Monday through Friday, excluding holidays. Hand delivered comments must be provided to the Forest Supervisor’s (Responsible Official) office during normal business hours, or at an official agency function (i.e. public meeting) that is designed to elicit public comments.


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