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Citizen's Coaltion Comment Letter on the Tonto National Forest Draft Fores Plan and Draft Envriomental Impact

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Citizen's Coaltion Comment Letter on the Tonto National Forest Draft Fores Plan and Draft Envriomental Impact COALITION COMMENTS: TONTO FOREST PLAN REVISION A CITIZEN’S COALITION COMMENT LETTER TONTO NATIONAL FOREST DRAFT FOREST PLAN AND DRAFT ENVIRONMENTAL IMPACT STATEMENT MARCH 12, 2020 1 COALITION COMMENTS: TONTO FOREST PLAN REVISION March 12, 2020 Tonto National Forest Attn: Forest Planner 2324 E McDowell Rd. Phoenix, AZ 85006 Submitted online at: https://cara.ecosystem-management.org/Public//CommentInput?Project=51592 RE: Tonto National Forest Draft Forest Plan and Draft Environmental Impact Statement The following letter is submitted on behalf of the Center for Biological Diversity, Wild Arizona, WildEarth Guardians, Defenders of Wildlife, Sierra Club, American Whitewater, Arizona Riparian Council, Arizona Mining Reform Coalition, The Rewilding Institute, The Wilderness Society, Maricopa Audubon Society, and White Mountain Conservation League. This coalition of organizations came together to provide input during the Tonto National Forest’s Plan Revision process with the goal of ensuring the best available science was used in the creation of the new Forest Plan and to advocate for greater protections for wild species and habitat and environmentally-responsible natural resource management. To summarizing our comments, we are asking for substantial revisions of major elements of the EIS and Plan. Primarily, we feel that the Wilderness Recommendation and Wild and Scenic River Eligibility evaluations have made major, systemic errors, leading to far fewer protections than these keystone landscapes deserve. Also, the Draft Plan provides few constraints on livestock grazing, which has degraded significant areas of the Tonto, and ignores a trove of science supporting the need for drastic reductions in grazing. Likewise, the plan does not provide the needed measures to protect resources from the ever growing impacts of off-road vehicles, and fails to provide needed protections for our most imperiled wildlife from mining, grazing, OHVs, climate change, old-growth logging, and habitat fragmentation. These aspects, and others, need major revision. In fact, we feel strongly that a supplemental DEIS is needed to address these key concerns prior to moving on to the Final EIS. This letter contains a tremendous amount of detailed information. We encourage you to reach out to us and seek clarification as needed. We are partners in land management, and we fully understand the pressure that the plan revision team was under to make things happen in a tight time frame. This is not easy work, but we have identified ways to make this plan really work for people, wildlife, and ecosystems. Thank you for you work, and we appreciate your consideration of our comments. For the Forests, Deserts, Waters, and Wildlife, The Tonto Coalition 2 COALITION COMMENTS: TONTO FOREST PLAN REVISION Joe Trudeau, Southwest Conservation Advocate Adam Rissien, ReWilding Advocate Center for Biological Diversity WildEarth Guardians PO Box 1013, Prescott, AZ 86302 PO Box 7516, Missoula, MT 59807 [email protected] [email protected] (928) 800-2472 (406) 370-3147 Sandy Bahr, Chapter Director Robert Peters, Ph.D., Senior Southwest Representative Sierra Club - Grand Canyon Chapter Defenders of Wildlife 514 W Roosevelt St., Phoenix, AZ 85003 210 Montezuma Ave., Suite 210, Santa Fe, NM 87501 [email protected] [email protected] (602) 253-8633 (520) 623-0447 Kelly Burke, Executive Director Kestrel Kunz, Southern Rockies Stewardship Assistant Wild Arizona American Whitewater [email protected] [email protected] (928) 606-7870 (802) 299 8405 Timothy J. Flood, Chairman Roger Featherstone, Director Conservation Committee Arizona Mining Reform Council Arizona Riparian Council PO Box 43565, Tucson, AZ 85733-3565 [email protected] [email protected] (520) 777-9500 Kim Crumbo Mike Quigley, Arizona State Director The Rewilding Institute The Wilderness Society [email protected] [email protected] 928-606-5850 (520) 334-8741 /s/ Mark W. Larson, President Thomas Hollender, President Maricopa Audubon Society White Mountain Conservation League [email protected] PO Box 72, Nutrioso, AZ 85032 [email protected] 928-245-7787 3 COALITION COMMENTS: TONTO FOREST PLAN REVISION The Center for Biological Diversity is a national, nonprofit conservation organization with more than 1.7 million members and online activists dedicated to the protection of endangered species and wild places. The members and activists of the Center are concerned with the management of our federal public lands, including our national forests, especially as that management relates to the recovery and viability of native species and their habitats. The Center has fought for protection of wilderness, wild and scenic rivers, and wildlife on the Tonto for decades. We will continue to use science, media, and legal strategies to advance the preservation and restoration of this incredible National Forest. Wild Arizona is a statewide conservation organization working to protect, link together, and restore wild lands and waters across Arizona and beyond. We pursue this mission for the enrichment and health of all generations, and to ensure Arizona's native plants and animals a lasting home in wild nature. Wild Arizona has a long history of advocacy, wilderness inventory, wild and scenic assessment, planning engagement, and stewardship partnership with the Tonto National Forest, especially for the Tonto’s trails, Wilderness Areas and Fossil Creek through our award-winning volunteer program called Wild Stew. Wild Arizona’s 2,000 members, supporters, and volunteers have contributed many thousands of hours to maintain, protect, and restore the character of Wilderness Areas on the Tonto. We are dedicated to preserving and enhancing the Tonto’s diverse ecosystems, its natural waters including streams and springs, its wilderness quality opportunities for solitude and quiet recreation, and the important landscape connectivity that the Tonto affords Arizona’s iconic wildlife, across a remarkable range of elevations and biomes. The Sierra Club is America’s largest and most influential grassroots environmental organization, with more than 3.8 million members and supporters. In addition to protecting every person's right to get outdoors and access the healing power of nature, the Sierra Club works to promote clean energy, safeguard the health of our communities, protect wildlife, and preserve our remaining wild places through grassroots activism, public education, lobbying, and legal action. Sierra Club members enjoy and explore the Tonto National Forest via hiking, backpacking, camping, kayaking, canoeing, rafting, wildlife viewing, and other activities. Our members act to protect the forest too, including advocating for protection of Wilderness, doing the on-the-ground assessments, and promoting the bills that established many of the Tonto's Wilderness Areas; helping to assess and establish Wild & Scenic Rivers processes and designations, including protection of Fossil Creek as a Wild & Scenic River; opposition to harmful mining projects, including the Carlota Mine and the proposed Resolution Copper Mine; and much more. Our members regularly help with clean-ups, trail maintenance, monitoring of riparian areas, and water quality monitoring on the Tonto National Forest. WildEarth Guardians (Guardians) is a nonprofit conservation organization whose mission is to protect and restore wildlife, wild places, wild rivers, and the health of the American West. Guardians has offices in six states, including Arizona, and has more than 278,000 members and supporting activists across the United States and the world. Guardians has an organizational interest in ensuring the Forest Service complies with all environmental laws during the Tonto Forest Plan revision process. Guardians has a demonstrated history of advocating for an ecologically and economically sustainable transportation system on the Tonto National Forest, and protecting at-risk species. Guardians continues to engage in the Tonto travel management planning process, and works to ensure the Forest Service conducts proper monitoring of Mexican spotted owl. 4 COALITION COMMENTS: TONTO FOREST PLAN REVISION Defenders of Wildlife is a national, non-profit membership organization dedicated to the protection of all native animals and plants in their natural communities. Defenders has a Southwest Office, located in Santa Fe, New Mexico, with staff also in Tucson, Arizona. Defenders has over a million members and supporters nationwide, including over 12,200 members and supporters in Arizona and New Mexico. American Whitewater is a national 501(c)(3) non-profit organization with a mission “to conserve and restore our nation’s whitewater resources and enhance opportunities to enjoy them safely”. With 6,000 individual and 100 affiliate club members, American Whitewater represents the interests of over 80,000 river enthusiasts. As conservation-minded whitewater recreationists, we place a high value on protecting naturally functioning river ecosystems, including their fish and wildlife, geomorphic processes, and potential to provide clean and safe drinking water. Our membership and the general public highly value our nation’s river systems and associated riparian zones, and we have a direct interest in maintaining healthy rivers for everyone to enjoy. There are numerous creeks and rivers within the Tonto National Forest boundary that attract our members from across the region and the country, and we support management actions that protect and
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